On Aug 11, 2026, at 2:47 PM,
Thank you.
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M
August 11, 2026
Hon. Nelson Esparza, Council President
Members of the Fresno City Council
2600 Fresno Street
Fresno, CA 93721
by email
RE: City Council August 13, 2026 Agenda Item 3.-A., ID 26-1062 Workshop - South SEDA Economic Analysis
Dear Council President Esparza and Members of the City Council:
I write on behalf of CLC and RCI to respectfully request that your Council get the answers to your constituents’ questions about SEDA project financing.
Since the public is still— after eight months— in the dark about SEDA financing, we rely on you to dig deeply, and skeptically, into whatever you finally see at this workshop.
Our first concern, however, is that everyone but the Mayor and Planning staff will first see these reports at your workshop on Thursday. It is troubling that the administration is still withholding reports that should have been made fully available (including all source data) well in advance of any workshop. We request that you learn from staff, in detail, why it’s taken until August to produce the reports we were all promised in December, and which were apparently completed well before now.
This behavior is compatible with only one purpose we can think of: the reports won’t bear up to extended and careful scrutiny. Therefore, we also hope you’ll request that the administration immediately provide you (and the public of course) not only the reports but also all the source data and assumptions supporting those reports and their conclusions We ask you to question the consultants in detail about the assumptions on which the data are based, the methodology used to arrive at conclusions, and the process for finalizing the report(s).
A few essential questions (which go to show the need for time to vet this work thoroughly!):
Does the report examine all of SEDA or just South SEDA? If not all of SEDA, why not? What number of South SEDA residential units supports the revenue projections for the
City Council re: SEDA Workshop August 11, 2026 2 East of Temperance area? Within the past three months the Mayor has been reported to claim 4,800 units three times1, as well as 10,000 units2. Which is it? If the net-acreage formula is the same as that used in the May 2025 Public Utilities Financing Options Report, the actual yield is approximately 6,900 units. (See, Appendix, Table 1, infra). Does the new report use the same formulae as the prior report to calculate net acreage for each land use category? If not, why not? How do the fiscal and financing report conclusions change if the number of units is 4,800 rather than 10,000? Or if it’s 6,900? Have the consultants run the numbers for all three scenarios? Who made the choices about what formula and what numbers to use in the final version?
What assumptions were made about the housing types that will be producing revenue from residential uses? If the report assumes 10,000 units, the numbers compel the conclusion that the vast majority will be in multifamily. (See, Appendix, Table 1.) What assumptions were made about the proportion of rentals to owner-occupied units? What data support these assumptions?
What assumptions were made about the price point(s) for single-family housing units? Rental rates? What data support these assumptions
3?
Does the report accept the premise that Fresno developers will build at a 20 du/acre density? On what basis? What is the fiscal impact for the City if it approves SEDA but actual build- out falls substantially short of that density?
Does the report accept the premise that there is market demand for thousands of multi- family units in the SEDA area? On what basis? What is the fiscal impact for the City if it approves SEDA but actual home sales/rentals fall substantially short?
1 “The Fresno City Council was scheduled to approve the mega development in December. Instead, Dyer pivoted and asked for direction from the council for a section of the plan he calls South SEDA. It consists of about 1,963 acres, 469 of which would be used to build 4,800 residential units, with the rest for flexible research, located at the bottom portion of the SEDA area.” Fannin, Fresno’s megadevelopment plan a tough sell for rural homeowners. ‘We’ll be pushed out’, Fresno Bee, May 8, 2026 (https://www.fresnobee.com/news/local/article314595142.html#storylink=cpy); In the East of Temperance portion of SEDA, “Dyer anticipates 4,800 total units with a third dedicated to multi-family housing and two-thirds for single family homes.” Hok & Rangel, A mega housing project resurfaces an existential question in Fresno, KVPR Interview with Fresno Mayor Jerry Dyer, June 26, 2026 (https://www.kvpr.org/government-politics/2026-06-30/a-mega-housing-project-resurfaces-an- existential-question-in-fresno); Montalvo, Fresno councilmember says measure would protect taxpayers from SEDA debt. Does it really? Fresno Bee, July 29, 2026 (https://www.aol.com/articles/fresno- councilmember-says-measure-protect-234900000.html)
2 “[T]he South SEDA portion advocated for by Fresno Mayor Jerry Dyer… is reserved for 10,000 homes and a research and tech hub.” Smith, Dyer Says He's OK With Esparza Proposal to Hand SEDA Decisions to Voters, GV Wire, July 24, 2026 (https://gvwire.com/2026/07/24/dyer-says-hes-ok-with- esparza-proposal-to-hand-seda-decisions-to-voters/)
3 See, e.g., Mayor Dyer’s claim that “most of that would be for single family residential, for homeownership at what I think to be an affordable rate for people who grew up in Fresno.” Montalvo, Fresno Mayor Jerry Dyer says he’d be ‘negligent’ not to pursue controversial SEDA project, Fresno Bee, February 21, 2026 (https://www.fresnobee.com/article314766733.html#storylink=cpy) City Council re: SEDA Workshop August 11, 2026 3 How does the report address Fresno’s dropping rate of population growth in reaching its conclusions about revenue generation? The California Department of Finance reports year- over-year growth between 2025 and 2026 at less than one tenth of one percent (0.09%)4.
Another source (see Appendix, Figure 1, infra) puts 2025-26 growth at about twice that, but still only 0.17%. If the administration rejects these sources, based on what source(s) are they claiming the growth numbers on which they wish you to rely? To what degree does the report factor in or otherwise rely on Measure C’s $55 million annual revenue for transportation improvements? Does the report address the uncertainty surrounding ongoing funding from this source? What is the fiscal impact for the City if it approves SEDA but neither Better Roads/Safe Streets nor the Mayor’s proposed City-only revenue measure becomes law?
If the report does not address the infinitesimally small chance of much building at 20 du/ac, or the administration’s improbable market demand assumptions, or the fact of population stagnation, or the uncertainty of funding for essential transportation infrastructure, can you base a decision of this gravity on this report?
Finally (for now), what type(s) of industrial development does the report use to calculate costs/revenues from the Flexible Research & Development area? Is there a formula for determining likely revenues from Research & Development activity (of which there’s basically none in Fresno County)? Where did the data come from for these analyses? Given the inconsistencies in the administration’s messaging to date, and its unwillingness to timely show its work so that we all can review it, understand it, and subject it to the test of reason, we are frankly concerned that there’s some cooking of the books going on. Of course we hope not, but we’re troubled. We therefore look to you to ask the hard questions, to refuse to accept nonresponsive answers, and to get the full picture for all of us before you make this important decision.
Thank you in advance for your attention to these matters. We’re happy to answer any questions or provide more information if needed.
Very truly yours,
PATIENCE MILROD
Attorney for Fresno Madera Tulare and Kings
Counties Central Labor Council, and Regenerate
California Innovation
cc: Mayor Jerry Dyer
City Attorney
City Clerk, for inclusion in the SEDA record of proceedings
4 E-1 Cities, Counties, and the State Population and Housing Estimates with Annual Percent Change — January 1, 2025 and 2026, 2025-26 City Population Percent Change Rankings, https://dof.ca.gov/forecasting/demographics/estimates-e1/
City Council re: SEDA Workshop August 11, 2026 4
Appendix
Table 1. Applying to “Refined” SEDA Plan the formulae from Table A-1 - May 2025 Public Facilities Financing Options Report
Gross Acres
South SEDA
Plan
Reduction
Factor to get
to Net
Developable
Acres
Net
Developable
Acres
Density Per
Acre Used
by City and
Public
Facilities
Financing
May 2025
Housing
Units
Likely
Predominant
Building
Type at these
Net Densities
Neighborhood
Residential = 407
acres
0.67 272.69 20 du/ac 5,454 Apartments
Mixed Residential
= 41 acres
0.67 27.47 25 du/ac 687 Apartments
Neighborhood
Town Ctr = 10
acres
0.77 7.7 30 du/ac 231 Apartments
Community Town
Ctr = 11 acres
0.83 10.23 55 du/ac 563 Apartments
Total 6,935
City Council re: SEDA Workshop August 11, 2026 5 Figure 1. Fresno County’s 2026 population is estimated at 1,037,214, reflecting a 0.17% growth rate over the past year (World Population Review based on U.S. Census Bureau data. Emphasis added.) https://worldpopulationreview.com/us-counties/california/fresno-county:
From:
To:
Subject: FW: Request for Rehearing on SEDA and Action to Protect Fresno Residents Date: Tuesday, September 1, 2026 4:38:16 PM
For item 2.-N. ID 26-1187 and 3.-A. ID 26-1091
-District 3 Office
From:
Sent: Thursday, August 27, 2026 3:30 PM
To:
Subject:
Request for Rehearing on SEDA and Action to Protect Fresno Residents
External Email: Use caution with links and attachments
Dear Members of the Fresno City Council,
My name is Ashley Mireles-Guerrero, and I am a small-business owner and resident with ties to Districts 1 and 3. I am writing today to urge the City Council to take action on two issues that could have lasting consequences for Fresno, its residents, and our future.
First, I urge the City Council to request a rehearing of the SEDA project before the Planning Commission.
Under Fresno Municipal Code Section 15-5812, the Planning Commission cannot recommend, and the City Council cannot approve, a proposed rezone or plan amendment unless specific findings can be made. Those findings include whether the proposed change is consistent with the City's General Plan and adopted policies; whether it promotes orderly and sustainable growth and protects public health, safety, and general welfare; and whether the change is necessary to achieve the City's desired balance of land uses.
Given the scale of the SEDA proposal and the concerns raised by citizens, I believe these findings deserve a more thorough and transparent review before the project moves forward.
If this project moves forward without a complete review and results in lengthy legal
challenges, additional infrastructure costs, or environmental mitigation, Fresno residents will be the ones left paying for it. Taxpayers will bear those costs. Residents will bear those impacts. The City has an opportunity to address these concerns now instead of asking Fresno residents to pay for the consequences later.
Second, I urge the City Council to consider prohibiting data centers within the City of Fresno.
We are already seeing the impacts of large-scale data centers across the country. These facilities can place massive demands on electricity and water while also contributing to noise and air pollution, and other environmental impacts.
Fresno already faces some of the worst air quality in the country, extreme heat, aging infrastructure, and neighborhoods that have spent generations carrying a disproportionate share of environmental harms. Why would we knowingly invite another resource-intensive industry into our city without first asking what that will cost the people who already live here?
The SEDA proposal includes land designated for research and development that could attract future data center development. At the same time, interest in building data centers on publicly owned land is growing. This is not a good thing. Just a few months ago, the High-Speed Rail Authority suggested it would consider building data centers on property it owns, including properties within Fresno's city limits and in communities that have already spent decades dealing with blight, disinvestment, and environmental harms.
This is not just a problem for one neighborhood or one district.
When a project puts
additional strain on our water supply, electrical grid, or public infrastructure, that burden does not stop at the edge of the neighborhood where it is built.
If infrastructure needs to be expanded, who pays?
If utilities are strained, who pays?
If environmental damage has to be mitigated, who pays?
If the City ends up in court because it failed to properly review a project, who pays? More often than not, the answer is Fresno residents and taxpayers.
Before we find ourselves responding to individual proposals one at a time, the City should establish a clear policy now. We should not wait until communities are forced to fight projects after developers have already identified a site and invested millions of dollars into making them happen. As the City Council, you have the opportunity to decide what kind of development we want to encourage and what risks and burdens we are unwilling to place on our residents.
I am asking you to act before these decisions become irreversible:
Request a rehearing on SEDA and ensure the Planning Commission can fully evaluate the project's viability and its environmental, infrastructure, and citywide impacts.
Consider an outright prohibition on data centers within the City of Fresno before residents many years from now are left dealing with the consequences of decisions made today.
Please do right by your constituents and take the long-term environmental, economic, infrastructure, and legal consequences of these decisions seriously. The risks are high, not only for those of us who live and work in the city now, but also for our children and grandchildren. Now is the time to save Fresno's future.
Sincerely,
Ashley Marie Mireles-Guerrero
Author, Bookseller, and Publishing Professional
From:
To:
Subject: FW: SEDA
Date: Tuesday, September 1, 2026 4:39:28 PM
For item 3.-A. ID 26-1091
-District 3 Office
From:
Sent: Thursday, August 27, 2026 10:54 AM
To:
Subject:
SEDA
External Email: Use caution with links and attachments
Dear Councilman Arias, I ask that you work to slow any approval of SEDA. I believe there is still so much potential for housing and commerce within the core area of our city as you so eloquently stated a few months back at a city council meeting. What I see developing in our city’s central core is so encouraging to me, a life-long native of Fresno. I love our city and ask that we save urban sprawl for another day far off in the future. Thank you.
From:
To:
Subject: FW: SEDA
Date: Tuesday, September 1, 2026 4:39:31 PM
For item 3.-A. ID 26-1091
-District 3 Office
-----Original Message-----
From:
Sent: Wednesday, August 26, 2026 8:46 PM
To:
Subject: SEDA
External Email: Use caution with links and attachments
Council member, please do not consider SEDA until there is a rehearing by the Planning Commission.
Thank you,
Jeanie Borba
From:
To:
Subject: FW: SEDA
Date: Tuesday, September 1, 2026 4:40:03 PM
For item 3.-A. ID 26-1091
-District 3 Office
From:
Sent: Wednesday, August 26, 2026 8:39 PM
To:
Subject:
SEDA
External Email: Use caution with links and attachments
Dear Councilman Arias- I am writing to thank you for your ongoing efforts in opposing SEDA. I am hopeful that you will push for the city council not to consider SEDA further until there is a rehearing by the Planning Commission.
Thank you once again!
--
Ruben Nieves
From:
Cc:
Subject: FW: South SEDA Item 3-A / ID 26-1091 - Predecision Record Memorandum; Receipt and Written Disposition Requested
Date: Tuesday, September 1, 2026 5:45:37 PM
Attachments:
-----Original Message-----
From:
Sent: Tuesday, September 1, 2026 3:02 PM
To:
Subject: South SEDA Item 3-A ID 26-1091 - Predecision Record Memorandum; Receipt and Written Disposition Requested
External Email: Use caution with links and attachments
City Clerk and Members of the Fresno City Council:
Please timestamp this email and the attached South SEDA Predecision Record Memorandum; distribute both with the September 3, 2026 Council materials for Item 3-A / ID 26-1091; retain them in the public Item 3-A and South SEDA project files; and confirm the date and time received, the public-file location, and the responsible records custodian.
I do not support final South SEDA approval on the present record. This is not a request to speak or a request for Council to take final action during the September 3 informational workshop. It preserves six unresolved decision questions that should be answered before the later final hearing:
1. Who authored each land-use, absorption, market-demand, revenue, cost, and service-level assumption Council will rely upon, and what independent validation, if any, supports each assumption?
2. What is the complete public and ratepayer cost, including excluded infrastructure, operations, maintenance, and service impacts, and who bears first loss, default risk, repayment shortfalls, and cost overruns under each financing path being considered?
3. What current record identifies every first-phase landowner, option or control holder, applicant, developer, advance funder, reimbursement claimant, fee-credit recipient, infrastructure-financing beneficiary, or other party positioned to receive project-specific financial value from South SEDA decisions?
4. Which later approvals may change permitted uses, phasing, financing, infrastructure obligations, or environmental controls; who decides each one; and where is each decision classified as ministerial or discretionary?
5. What binding instrument makes the 75 percent phase gate and the school, farmland, air, water, and infrastructure safeguards enforceable; who certifies compliance; what evidence is required; and what remedy follows noncompliance?
6. What decision sequence remains; which body takes each action; what notice or instrument records it; and what date or event does the City contend begins any applicable objection, appeal, referendum, CEQA, Government Code section 65009, or other review period?
For each question, please identify the responsive record by title, author, date, page or URL, and custodian. If no responsive record presently exists, please state that. If a record will be produced later, please identify the responsible official and publication date.
If the City considers a record unnecessary, please identify the authority and substitute evidence Council will rely
upon.
Please direct the responsible staff to provide a written disposition with enough time for meaningful public review before the later final hearing. A nonresponse should remain recorded as unanswered; it should not be treated as proof that a record does not exist.
Respectfully,
Rene Campos
Fresno resident
SOUTH SEDA - PREDECISION RECORD MEMORANDUM PAGE 1 OF 8
Transmittal and Record-Custody Request
MATTER LOCK
South SEDA only - P23-03090 / P23-03091 / EIR SCH No. 2022020486 September 3, 2026 - Item 3-A / ID 26-1091 - Workshop: South SEDA Economic Analysis Submitted to: Office of the City Clerk, City of Fresno
Public record: September 3, 2026 Council meeting - Item 3-A / ID 26-1091 Submitter:
Rene Campos, Fresno resident
RECORD-CUSTODY REQUEST
City Clerk and Members of the Fresno City Council: Please timestamp this memorandum, distribute it with Item 3-A, retain it in the public Item 3-A and South SEDA project files, identify the responsible records custodian, and confirm receipt. This is a preliminary evidence and notice memorandum for an informational workshop. It is not a claim that Item 3-A is a final approval hearing and it does not ask Council to take final action on September 3.
DECISION REQUESTED
Before Council calendars or takes final action on South SEDA, please direct staff to answer the six record categories in this memorandum. For each category, the requested response is one of four positions:
1. Identify the existing record.
2. Identify the responsible official and a date certain for publication.
3. State that no responsive record presently exists.
4. State that the record is not required, cite the authority, and identify the substitute evidence Council will rely upon.
Completion standard: Each category has a dated written disposition and the cited records are available with enough time for meaningful review before the later final hearing. Silence or nonresponse is recorded only as unanswered; it is not proof that a record does not exist.
Respectfully submitted,
Rene Campos
Fresno resident
PREDECISION RECORD MEMORANDUM - ITEM 3-A Prepared September 1, 2026 SOUTH SEDA - PREDECISION RECORD MEMORANDUM PAGE 2 OF 8
One Required Finding, One Express Limitation
THE VERIFIED RECORD
Fresno Municipal Code section 15-5812 uses mandatory approval language: Council "shall not approve" the amendment unless Criteria A, B, and C are met. Criterion C includes increasing land inventory "to meet market demand." The August 31, 2026 Economic & Planning Systems report uses land-use assumptions supplied by the City. EPS states that it did not independently evaluate the proposed land-use feasibility and did not independently evaluate market support for the City-prepared absorption scenarios.
THE PRECISE QUESTION
What record evidence will Council rely upon for Criterion C's employment-use and market-demand component before final action?
This comparison does not establish a violation, does not establish that the City's assumptions are false, and does not establish that no other supporting record exists. It identifies a verified scope limitation that should be reconciled in the final decision record.
THE BROADER OFFICIAL-RECORD TENSION
The City describes South SEDA as paying for itself. The EPS report, however, models alternatives rather than selecting a binding financing structure; limits the identified predevelopment-cost scope to sewer-main improvements; excludes other backbone infrastructure from that analysis; models an early subsidy under one route; and excludes certain funds, capital facilities, and service arrangements from the fiscal perimeter.
The requested cure is a reproducible record showing what evidence, costs, financing terms, enforceable controls, and final instruments Council will actually rely upon.
Claim Grade / confidence
Section 15-5812 and Criterion C contain the quoted mandatory and market-demand language. Fact / A-primary / 100% EPS states the identified independent-evaluation limits. Fact / A-primary / 100% The current public record needs reconciliation before a robust final Criterion C finding. Inference / 80% Other competent evidence may exist or may be published before final action. Alternative / 20% Fact that materially defeats the inference: authenticated market-demand evidence, a reproducible model, complete cost and financing records, and operative implementation instruments placed in the final record.
PREDECISION RECORD MEMORANDUM - ITEM 3-A Prepared September 1, 2026 SOUTH SEDA - PREDECISION RECORD MEMORANDUM PAGE 3 OF 8
Six Requested Record Categories
Requested response format: record title; author or custodian; date; page or URL; responsible official; publication date; and one of the four positions listed on page 1.
1. WHO BUILT AND VALIDATED THE ASSUMPTIONS
Identify who authored each land-use, absorption, market-demand, revenue, cost, and service-level assumption Council will rely upon, and the independent validation, if any, supporting each assumption. Include the native workbook, formulas, macros, linked inputs, revisions, downside cases, and quality-control material; identify the legal basis for any withheld component.
2. WHO PAYS WHEN THE MODEL FAILS
Identify the complete public and ratepayer cost, including excluded infrastructure, operations, maintenance, and service impacts, and who bears first loss, default risk, repayment shortfalls, cost overruns, O&M;, General Fund exposure, enterprise-fund exposure, and utility-rate exposure under each financing path being considered.
3. WHO RECEIVES PROJECT-SPECIFIC VALUE
Identify the current record listing each first-phase APN, landowner, option or control holder, applicant, developer, agent, advance funder, reimbursement claimant, fee-credit recipient, development-agreement party, infrastructure-financing beneficiary, or other party positioned to receive project-specific financial value. This does not allege concealed ownership or improper benefit.
4. WHAT CAN CHANGE LATER AND WHO DECIDES
Identify every later approval that may change permitted uses, phasing, financing, infrastructure obligations, or environmental controls; the official or body deciding each one; whether each decision is classified as ministerial or discretionary; and the final Development Code, use matrix, conflict hierarchy, and Director authority.
5. WHAT MAKES EACH SAFEGUARD ENFORCEABLE
Identify the binding instrument for the 75% phase gate and school, farmland, air, water, and infrastructure safeguards; the certifying official; required evidence; public reporting and challenge process; and the automatic remedy or consequence for noncompliance.
6. WHAT STARTS EACH REVIEW OR CHALLENGE CLOCK
Identify the remaining decision sequence, body and instrument for each action, final-packet publication date, administrative-record closure point, Notice of Determination custodian, and the date or event the City contends begins any applicable objection, appeal, referendum, CEQA, Government Code section 65009, or other review period.
PREDECISION RECORD MEMORANDUM - ITEM 3-A Prepared September 1, 2026 SOUTH SEDA - PREDECISION RECORD MEMORANDUM PAGE 4 OF 8
Current Status and Proof-to-Close Matrix
Category Current bounded status Proof that closes the gap Criterion C / market demand Mandatory wording and EPS scope limits verified. Other final-finding evidence is not identified here.
Exact supporting record, author, date, page or URL, and Council reliance statement.
Native model Public tables expose an .xlsm identifier. Complete native file and dependencies are not verified.
Native file, linked inputs, data dictionary, version record, QC material, and hash.
Financing / first loss EPS evaluates several routes. No selected binding structure is verified. Selected instrument, obligor, repayment, subsidy, debt service, first loss, default, O&M;, and backstop.
Full public cost $72.0M is modeled 2029 sewer-main predevelopment scope; other backbone infrastructure is outside the report.
All-funds capital and operating schedule: exclusions, estimates, funds, payer, timing, downside case.
Phase / school / code Partial 75% rule and school policies exist. Named certification, enforcement, quantitative-school, matrix, and final-use-table details remain open.
Operative metric, data, certifier, reporting, procedure, appeal, consequence, remedy, school standards, and code hierarchy.
Project-specific benefits / final trigger Authenticated first-phase control/benefit schedule and final-action/NOD sequence are not verified.
APN/control/benefit record plus final instruments, hearing, record-close point, and NOD custodian.
Status rule: "Not verified in the reviewed public packet" does not mean "does not exist." A category changes status only when the exact record is identified, produced, and preserved.
FISCAL RECONCILIATION
The EPS headline is a modeled annual General Fund surplus of $17.2 million at buildout under stated assumptions. Table 3-2 separately identifies additional impacts, including Comprehensive Street Maintenance costs, and shows $11.898 million after the identified General Fund
and additional impacts. Neither number is a guaranteed all-funds net result.
Precision control: The modeled early subsidy is not an approved obligation. The EPS packet evaluates alternatives and does not itself select or authorize a final financing route.
PREDECISION RECORD MEMORANDUM - ITEM 3-A Prepared September 1, 2026 SOUTH SEDA - PREDECISION RECORD MEMORANDUM PAGE 5 OF 8
Procedural Status, Boundaries, and Renewal Point
WHAT IS HAPPENING NOW
Step Verified status
Applications / EIR P23-03090 / P23-03091 / EIR SCH No. 2022020486.
Planning Commission Recommended approval; Council remains the later final-action body.
Economic work EPS analyses dated August 31, 2026.
September 3 Item 3-A is an informational workshop; the City says no final South SEDA action or vote that day.
Later final action Exact hearing, instruments, record-close point, and notice sequence remain to be identified.
WHAT THIS MEMORANDUM DOES NOT CLAIM
It does not claim corruption, collusion, falsity, concealed ownership, an approved subsidy, a present entitlement, a current construction authorization, a specific unlisted use, or a completed legal violation. It does not treat a missing public record as proof that the record does not exist.
WORKSHOP VERSUS FINAL HEARING
This preliminary memorandum provides notice of specific record questions. It does not assume that the September 3 workshop alone satisfies every issue-exhaustion or objection requirement. Before the later properly noticed final hearing closes, any final public submission should be updated against the complete final packet, state each specific objection and requested cure, and expressly address any proposed approval or EIR certification.
LATE MATERIAL
If materials distributed to a Council majority are public records under Government Code section 54957.5, please make them available promptly. If staff or Council intends to rely on material released too late for meaningful review, the requested procedural response is to continue the final item or reopen the record long enough for a meaningful response. This is a request, not a claim that every late release automatically requires a continuance.
Disposition rule: The City is not asked to adopt this form as a legal duty. A City response, correction, refusal, alternative record, or citation to contrary authority should be preserved without argument.
PREDECISION RECORD MEMORANDUM - ITEM 3-A Prepared September 1, 2026 SOUTH SEDA - PREDECISION RECORD MEMORANDUM PAGE 6 OF 8
Primary-Source Register
Official source Proposition Locator
FMC Findings, Exhibit M Mandatory approval wording; Criterion C includes employment uses and market demand. PDF pp. 1, 5-6 Aug. 31 EPS analyses City inputs and EPS independent-evaluation limits. Packet p. 23 / report p. 3 Same EPS analyses Sewer-main scope; other backbone infrastructure outside report. Packet p. 24 / report p. 4 Same EPS analyses Financing alternatives, subsidy ranges, repayment scenarios. Packet pp. 25-26, 39-41 Same EPS analyses GF/additional-impact results; excluded funds and capital/service scope. Packet pp. 50-51 / report pp. 30-31 Same EPS analyses Native workbook identifier. Packet p. 115 2026 Specific Plan Code dependency, unlisted-use rule, school policies, 75% rule, implementation matrix. Plan pp. 34-35, 65, 100, 102-107 Final agenda / City SEDA page Item 3-A workshop; no final action Sept. 3; later Council action. ID 26-1091 / current status page
OFFICIAL URLS
Agenda: https://agendas.fresno.gov/en/meetings/cmrth3dok00ndpezf7164vccy Item 3-A packet: https://agendas.fresno.gov/api/v1/attachments/cmthyn0dadumrpe47akpywpe4/file Exhibit M: https://agendas.fresno.gov/api/v1/attachments/cmsrw14kpqyympepln4vsy5ym/file Specific Plan: https://agendas.fresno.gov/api/v1/attachments/cmsrw14qdqyyypepl9m3t9mdr/file City status page: https://www.fresno.gov/seda-and-south-seda/ Source-control rule: Secondary reporting is not used to prove a claim in this memorandum. Exact official-file hashes and archived copies are maintained in the private evidentiary ledger.
PREDECISION RECORD MEMORANDUM - ITEM 3-A Prepared September 1, 2026 SOUTH SEDA - PREDECISION RECORD MEMORANDUM PAGE 7 OF 8
Official-Record Crosswalk
Decision point Official proposition Verified limit / question Exact requested answer Criterion C FMC 15-5812 includes employment uses and
market demand.
EPS did not independently test City feasibility or
scenario market support.
Identify other evidence with title, author, date, and
page.
Reproducibility Published tables identify a native .xlsm workbook. Native file, links, metadata, version chain not verified publicly.
Publish file/dependencies or legal basis for withheld
components.
Fiscal result EPS models specified development and financing scenarios.
Selected obligor, subsidy, first loss, default, O&M;,
downside allocation not locked.
Identify selected structure and each public exposure.
Complete cost EPS limits predevelopment costs to sewer mains. Headline is not a complete all-funds capital/service assignment.
Publish excluded cost, payer, fund, timing, downside
case.
Phase / school Plan has a partial 75% rule and OS-8.3 to OS-8.5 policies.
Certification, enforcement, quantitative standards,
matrix entries, remedies not identified.
Publish operative controls and responsible officials.
Final code Plan defers use table and bars unlisted uses pending update.
Final classifications, procedure, conflict rule, Director authority open.
Publish final code and relationship to plan.
Finality / notice September 3 is a workshop; final action is later. Final instruments, hearing, record close, NOD sequence open.
Publish decision calendar, packet date, instruments,
custodian.
EIGHT HIGHEST-VALUE OFFICIAL PAGES
1 Exhibit M p. 5 - Criterion C / market demand
2 EPS packet p. 23 / report p. 3 - independent-evaluation limits 3 EPS packet p. 24 / report p. 4 - sewer-only scope / other backbone 4 EPS packet p. 40 / report p. 20 - subsidy ranges
5 EPS packet p. 51 / report p. 31 - excluded fiscal perimeter 6 Specific Plan p. 100 - partial 75% rule
7 Specific Plan p. 65 - school policies OS-8.3 to OS-8.5 8 Specific Plan p. 104 - implementation-matrix comparison Analytical control: Source fact, inference, alternative explanation, and proof hole remain separate. A scope limitation is not converted into an admission of illegality.
PREDECISION RECORD MEMORANDUM - ITEM 3-A Prepared September 1, 2026 SOUTH SEDA - PREDECISION RECORD MEMORANDUM PAGE 8 OF 8
Requested Record-Disposition Matrix
For each row, staff or Council may identify an existing record, provide a publication date, state that no responsive record presently exists, or state that the item is not required and identify the authority and substitute evidence.
Record category Position Responsible official Due date Record / authority / URL
1. Assumptions, authors, validation
2. Complete cost and first loss
3. Control and project-specific value
4. Later approvals and decision authority
5. Binding safeguards and remedies
6. Final action and review clocks
Requested Council direction: Direct the responsible staff to provide a written disposition for each row and place every identified record in the public South SEDA file with enough time for meaningful review before the later final hearing.
PRESERVATION AND RENEWAL
- Please preserve this memorandum, the transmittal email, every attachment, and the City's written disposition in the Item 3-A and South SEDA project files. - Please confirm the date and time received, the public-file location, and the responsible records custodian. - This memorandum will be reviewed against the complete final packet and may be renewed or supplemented before the later final hearing.
PREDECISION RECORD MEMORANDUM - ITEM 3-A Prepared September 1, 2026