Oakley City Council
March 10, 2026

The North Development Area, adjacent to the Contra Costa Logistics Center, is wellsuited to larger floorplate development, such as warehouse and distribution or larger scale manufacturing uses. The South Development Area, accessed from Main Street and more proximate to residential areas, is envisioned for smaller-scale industrial or industrial/flex uses.

For the fiscal and economic impact analyses, the site is assumed to be developed with 3.1 million square feet of built space, per the Project Description prepared by David Babcock + Associates, dated June 10, 2024.

Key Findings
The key findings of fiscal and economic impact analyses are presented below in 2025$. The fiscal impact analysis findings are presented as a range to reflect the potential variability in City revenues and expenditures, depending upon whether Bridgehead end users skew towards manufacturers or distribution operations. The economic impacts (e.g.: indirect and induced multiplier effects) are based on a combination of manufacturing and distribution users. Additional results and discussions of methodology and assumptions for each analysis are detailed in the subsequent Fiscal Impact Analysis and Economic Impact Analysis sections.

Fiscal Impacts

1. At buildout, Bridgehead is estimated to yield a net fiscal surplus for the City’s General Fund ranging from approximately $1.1 million to $1.4 million annually.

A comparison of annual revenues and expenditures is shown in Table 1. This net fiscal impact is based on several assumptions, described further in this report, including the Project’s estimated total net assessed value and the number of workers at buildout.

Based on these assumptions, the Project is estimated to generate between approximately $1.3 million and $2.1 million in General Fund revenues annually and require approximately $251,000 to $690,000 annually in General Fund projectrelated expenditures, depending upon the composition of end users.

2. The largest General Fund revenues generated by the Project, including $587,000 a year in property taxes and $619,000 annually in property tax in-lieu of vehicle license fees, are directly tied to new assessed value.

The proposed development is estimated to generate total secured assessed value (AV) of approximately $775 million, plus additional unsecured value, resulting in the abovereferenced gains. Estimated annual sales tax revenues ranging from $16,000 to $489,000 include taxes from spending by on-site employees elsewhere in the City, along with potential on-site business taxable sales under a manufacturing-focused scenario.
246
Economic & Planning Systems, Inc.

3. Police costs are expected to make up the largest additional expenditure impact on the City’s General Fund.

In the City’s 2024-25 Adopted Budget, Police expenditures account for 54 percent of the City’s annual General Fund expenditures (excluding transfers out). As such, police expenditures constitute the largest share of Bridgehead PUD’s public service costs, at 63 percent. The Project’s estimated impact on General Fund expenditures for Police ranges from approximately $158,000 per year under a distribution-focused scenario, with relatively fewer on-site employees, to $434,000 per year under a manufacturingfocused scenario, which would result in a higher number of employees on-site.

Table 1 provides a detailed summary of General Fund revenues and expenditures attributed to the Project at buildout and the resulting net fiscal impact to the City’s General Fund. All results for the fiscal impact analysis are expressed in constant 2025 dollars and represent the impacts of the Project annually at buildout. 247
Oakley Bridgehead Industrial PUD Fiscal and Economic Impact Analysis

Table 1 Summary of Estimated Fiscal Impacts at Buildout (2025$) In addition to the ongoing net fisccal impact at build out, discussed above, construction worker taxable spending and transient occupancy tax (TOT) is estimated to total approximately $196,000 (constant 2025 dollars), spread across the duration of the construction period.

General Fund Item Amount Percent Amount Percent
Annual Revenues [1]
Property Tax $586,800 27.6% $586,800 44.7%
Property Tax in Lieu of VLF $618,600 29.1% $618,600 47.1% Property Transfer Taxes $21,300 1.0% $21,300 1.6%
Sales Taxes $733,491 34.5% $24,248 1.8%
Franchise Tax $102,400 4.8% $37,300 2.8%
Transient Occupancy Taxes $20,000 0.9% $7,000 0.5%
Motor Vehicle In Lieu Tax $1,800 0.1% $600 0.0%
Traffic Fines $2,900 0.1% $1,000 0.1%
Business Licenses $40,100 1.9% $16,600 1.3%
Total General Fund Revenues $2,127,400 100.0% $1,313,400 100.0% Annual Expenditures [2]
City Council $1,900 0.3% $700 0.3%
City Clerk $9,800 1.4% $3,600 1.4%
City Attorney $8,800 1.3% $3,200 1.3%
City Manager $500 0.1% $200 0.1%
Finance $21,500 3.1% $7,800 3.1%
Human Resources $4,100 0.6% $1,500 0.6%
Facilities Maintenance $16,100 2.3% $5,900 2.4%
Information Technology $0 0.0% $0 0.0%
Economic Development $8,400 1.2% $3,000 1.2%
Building $700 0.1% $200 0.1%
Planning $24,000 3.5% $8,700 3.5%
Code Enforcement $19,000 2.8% $6,900 2.8%
Police $433,500 62.9% $157,600 62.9%
Public Works $120,900 17.5% $43,900 17.5%
Recreation $20,400 3.0% $7,400 3.0%
Total General Fund Expenditures $689,600 100.0% $250,600 100.0% Annual General Fund Surplus/(Deficit) $1,437,800 $1,062,800 Source: City of Oakley FY 2024-25 Adopted Budget; EPS.

Note: Values are rounded to the nearest $100.
[1] See Table A-5 for details on revenue estimating procedures. [2] See Table A-12 for details on expenditure estimating procedures.

At Project Buildout
Manufacturing
Focused
Distribution
Focused
248
Economic & Planning Systems, Inc.

Economic Impacts
Ongoing Annual Impacts at Buildout

1. Estimated on-site employment at buildout of about 2,000 jobs is estimated to generate approximately an additional 1,500 jobs throughout the County, for a total employment impact of approximately 3,500 jobs.

Direct employment onsite generates additional indirect and induced employment offsite elsewhere in the County through economic multiplier effects.

2. Estimated on-site economic output at buildout of $600 million is estimated to generate additional indirect and induced output of nearly $300 million countywide, for total ongoing economic output of approximately $900 million.

Indirect and induced output includes business-to-business activity and household spending of wages earned from direct and indirect jobs.

Table 2 summarizes the ongoing annual economic impact from operation. Impacts include the direct activity on-site, along with indirect and induced impacts throughout Contra Costa County.

Table 2 Summary of Ongoing Annual Economic Impacts at Buildout (2025$) One-Time Construction Impacts

3. Estimated direct construction employment of about 2,700 annual jobs is estimated to generate approximately an additional 1,000 jobs throughout the County. 1 Direct construction employment associated with development of Bridgehead PUD generates additional indirect and induced employment through economic multiplier 1 Economic impact modeling estimates employment over a one-year timeframe, with each job supported during the construction phase equaling one year of employment. Therefore, if the total construction period lasts 5 years, the average number of jobs in any given year would be the total divided by 5 (20% of the total).

Effect Employment
Wages
(millions)
Economic Output
(millions)
Direct 1,976 $226.1 M $603.0 M
Indirect 933 $72.9 M $173.3 M
Induced 589 $40.4 M $120.4 M
Bridgehead PUD Total 3,497 $339.3 M $896.7 M
Source: Implan; EPS.

Ongoing (Annual) Economic Impact
249
Oakley Bridgehead Industrial PUD Fiscal and Economic Impact Analysis

effects, for an estimated total employment impact of about 3,700 jobs annual jobs over the construction period.

4. Estimated direct construction-related economic output of nearly $700 million is estimated to generate over $900 million in total countywide economic output from Bridgehead PUD construction.

Over $200 million in indirect and induced output includes business-to-business activity and household spending of wages.

Table 3 summarizes the one-time economic impact from construction, including direct impacts from on-site construction as well as indirect and induced multiplier effects.

Table 3 Summary of One-Time Economic Impacts from Construction (2025$) Effect Employment
Wages
(millions)
Economic Output
(millions)
Direct 2,654 $260.9 M $678.9 M
Indirect 417 $39.2 M $117.6 M
Induced 597 $40.9 M $122.1 M
Bridgehead PUD Total 3,668 $341.0 M $918.6 M
Source: Implan; EPS.

One-Time Economic Impact
250
Economic & Planning Systems, Inc.

Fiscal Impact Analysis
This Fiscal Impact Analysis examines the Project’s estimated annual net fiscal impact on the City’s General Fund budget. Specifically, the analysis estimates whether projected General Fund revenues from the Project, at buildout, will adequately cover the cost of delivering General Fund municipal services to the Project’s employees. The Fiscal Impact Analysis assumes the City will provide all General Fund-allocated municipal services to the Project.

The following section describes the methodologies and assumptions used to calculate the fiscal impacts of the Project. The technical analysis, including data, assumptions, and detailed calculations underlying the Fiscal Impact Analysis, are provided in Appendix A.

Fiscal Impact Methodology and Assumptions
This section details the underlying methodology and assumptions used to estimate the fiscal impact of the Project on the City. It describes assumptions concerning municipal service delivery, land development, and General Fund budgeting. In addition, it details the methodology used to forecast the Project’s annual General Fund revenues and municipal service expenditures at buildout. The municipal services analyzed in this Fiscal Impact Analysis comprise of ongoing General Fund services only. The Fiscal Impact Analysis excludes any services that may be funded privately, such as common area maintenance costs, as well as an analysis of any one-time revenues generated by the Project, such as development impact fees. Further, this Fiscal Impact Analysis does not address expenditure budgeted in other City Governmental Funds or Proprietary Funds (e.g., enterprise funds), nor does it include an evaluation of the costs of building and operating any Project-specific capital or public service facilities.

General Assumptions
The Fiscal Analysis is based on the City’s Adopted Budget for Fiscal Year (FY) 2024-25, estimated citywide residential and employment populations as of the end of 2023, tax regulations and statutes as of the end of the 2023-24 Fiscal Year, and other general assumptions discussed herein. Each revenue item is estimated based on current State of California (State) legislation and current City practices. Future changes by either State or City legislation or practices may affect the revenues and expenditures estimated in this Fiscal Impact Analysis. All costs and revenues are shown in constant 2025 dollars. General fiscal and demographic assumptions are detailed in Table A-1 in Appendix A.

EPS consulted the City’s budget documents to develop forecasting methodologies for specific revenues and expenditures affected by new development in the proposed Project.

This Fiscal Impact Analysis also uses information from the following sources: Project Applicant, City of Oakley, Contra Costa County Auditor-Controller, California Department of Finance (DOF), US Census, and subscription-based data sources (e.g., CoStar).
251
Oakley Bridgehead Industrial PUD Fiscal and Economic Impact Analysis

The actual fiscal impacts of new development in the Project will vary from those presented in this Fiscal Impact Analysis if development plans or other assumptions (e.g., assessed valuations, sales tax revenue assumptions) differ from those presented.

Development Assumptions
Listed below are summaries of land use and other development-related assumptions used in this Fiscal Impact Analysis:
 Land Use: The Project is proposed to accommodate an industrial use, based on information provided by the Applicant. Commercial square feet are shown in Table A-3 in Appendix A.
 Estimated Service Population: Employment estimates for the Project are based on assumed employment densities for industrial land use. Based on firm experience analyzing industrial employment in other projects, EPS estimated that the Project would have an overall employment density of 1 employee per 800 square feet, under a manufacturing focused scenario, and 1 employee per 2,200 square feet under a distribution focused scenario. The actual employee density at buildout will likely fall somewhere between these two densities.

In estimating certain annual revenues and expenditures (service demands) related to the Project, EPS developed a “persons-served” population estimate to approximate the impacts of an employee on City revenues and costs relative to a resident. Based on industry standards, EPS applied a service demand factor of 0.50 to the Project’s projected employee population to derive the associated persons-served population.

Table A-3 in Appendix A shows the estimated employees and persons served generated by the Project’s two use scenarios.
 Assessed Value: The Fiscal Impact Analysis relies on the Project’s estimated assessed value to calculate property tax revenue to the City’s General Fund. The Project’s secured assessed value is based on the estimated value of Project site improvements and vertical construction of the Project (excluding soft costs and financing costs but including contingency). Additional unsecured assessed value for business personal property is assumed at 10 percent of the secured assessed value. EPS excludes the existing assessed value of the land on which the Project is being built, which is currently vacant. The assessed values for Project land uses are assumed to remain static—real growth in assessed value is not estimated in this analysis. The estimated assessed values are presented in Table A-4 in Appendix A.
 Vacancy Rates: Estimates for employee population and for tax-generating commercial square footage incorporate an assumed vacancy factor. This factor reflects the vacancy rate reported for the City by CoStar. The vacancy rate is detailed in Table A-4 in Appendix A.
252
Economic & Planning Systems, Inc.

General Fund Assumptions
This Fiscal Impact Analysis only considers discretionary General Fund revenues that will be generated by the Project. The analysis also accounts for offsetting revenues. Offsetting revenues are General Fund revenues dedicated to offsetting the costs of specific General Fund department functions and are excluded from this Fiscal Impact Analysis for both revenue and cost estimates. Offsetting revenues are indicated in Table A-5 and Table A12 in Appendix A. These revenues include fees charged to new development that offset costs to the Planning Development related to processing those development projects; law enforcement fees charged to the Police Department; engineering fees charged to the Public Works Department; fees charged for park rentals that offset costs to the Recreation Department; and city administration fees charged that offset costs to the City Manager’s Office.

Revenue-Estimating Methodology
EPS uses either an average-revenue approach or a marginal-revenue case-study approach to estimate Project-related General Fund and public safety revenues:
 The average-revenue approach uses the City’s FY 2024-25 budgeted revenue amounts on a citywide per capita, per employee, or per-persons-served basis to forecast revenues derived from estimated Project persons served.  The marginal-revenue case-study approach simulates actual revenue generation resulting from new development. The case-study approach for estimating sales tax revenues, for instance, forecasts taxable spending by the Project’s new residents and employees, as well as from retail uses and any on-site business-to-business transactions. Case studies used in this Fiscal Impact Analysis are discussed in greater detail later in this section.

Revenue sources not expected to increase as a result of the Project are excluded from this Fiscal Impact Analysis. These sources of revenue are not affected by the Project because they are either one-time revenue sources not guaranteed to be available in the future or there is no direct relation between the Project’s development and the revenue source.

These excluded sources are indicated in Table A-5.

A listing of all City General Fund revenue sources and the corresponding estimating procedure used to forecast future Project revenues is shown in Table A-5 in Appendix A. A summary of estimated annual General Fund revenues generated by the Project is provided in Table A-6. As shown, the Project is estimated to generate $1.3 million to $2.1 million in annual General Fund revenue at buildout. Property tax in-lieu of vehicle license fees, estimated at approximately $619,000 annually, is the largest source of Project-generated revenue. Property tax revenue, estimated at approximately $587,000, is the secondlargest revenue source, followed by sales tax revenue, with an estimated range from $24,000 for distribution to $733,000 for manufacturing. 253
Oakley Bridgehead Industrial PUD Fiscal and Economic Impact Analysis

Average Revenue Categories
An average per employee revenue multiplier was used to estimate business licenses and business license tax revenue generated by the Project. An average per persons-served multiplier was used to estimate franchise tax and transient occupancy tax revenue. These revenue multipliers are calculated in Table A-5 and the Project’s impact on these revenue sources is shown in Table A-6.

Marginal-Revenue Categories
Property Tax
Estimated annual net property tax revenue resulting from development in the Project is presented in Table A-7 in Appendix A. The property taxes the City will receive are derived from the estimated property value of the Project, shown in Table A-15 in Appendix A, and the City General Fund’s post-Educational Revenue Augmentation Fund (ERAF) share of the one percent ad valorem property tax rate, shown in Table A-14. The total assessed value represents the Project’s estimated value based on the cost of the Project improvements, minus the current assessed value of the Project site. The entire Project is assumed to be subject to property tax. In this analysis, the estimated property values are allocated to the tax rate area. The estimated assessed value for Project is assumed to remain static; real growth is not estimated.

Property Tax In Lieu of Vehicle License Fee
The Fiscal Analysis uses a formula provided by the State Controller’s Office to forecast Property Tax in Lieu of Vehicle License Fees (PTIL VLF). PTIL VLF is calculated by taking the percentage increase over the City’s current overall assessed value (as reported by the Contra Costa County Auditor-Controller for fiscal year 2024-2025) that would result from the addition of the Project’s assessed value and applying that percentage increase to the City’s current State allocation of PTIL VLF revenue (as shown in the City’s FY 2024-25 budget). This calculation of PTIL VLF based on the Project’s estimated assessed values is shown in Table A-7 in Appendix A.

Real Property Transfer Tax
Real property transfer tax is levied at the time of property sale at a rate of $0.55 per $1,000 of property value. Estimated annual real property transfer tax generated by the Project is based on the assumptions that the property will turnover approximately every 20 years, based on industry standard. Real property transfer tax revenue projections are identified in Table A-8 in Appendix A.

Sales Tax
Sales tax revenue is based on estimated taxable sales and the local sales taxes levied in the City, as summarized in Table A-9 in Appendix A. There are two sales taxes levied in Oakley: the Bradley Burns Local Sales tax (1 percent of taxable sales); and the City’s Measure J local sales tax (0.5 percent of taxable sales). Both sources go towards the General Fund. EPS uses two methodologies to account for taxable sales generated by the 254
Economic & Planning Systems, Inc.

Project –sales generated by new workers, and sales generated by industrial business-tobusiness transactions, as follows:

Annual Taxable Sales from New Employees
The sales tax analysis also accounts for taxable retail expenditures made by the new workers of the Project’s industrial tenants. Based on estimates from various surveys of worker spending during the workday, the on-site employees are estimated to spend $10 in taxable sales per workday on average over 240 annual workdays.

The analysis estimates the City will capture approximately 50 percent of taxable expenditures from the Project-based workers, accounting for spending outside the City.

The analysis assumes that no workers’ taxable spending would occur within the Project because there are no retail uses associated with the Project. Total sales revenues generated for the City by the Project’s new workers and corresponding calculations are shown in Table A-9A in Appendix A.

Annual Taxable Sales from Industrial Use (Point of Sale Activity) EPS also estimated annual sales tax revenue from the point-of-sale transactions of taxable goods and services at the Project itself. The analysis assumes that only manufacturing uses, but not warehouse or e-commerce uses, would generate point-of-sale activity. EPS used an estimated annual taxable sales-per-square-foot assumption of $15 per square foot of occupied industrial space, based on research and previous analysis of industrial developments. The estimated annual business-to-business taxable sales from Project development at buildout are shown in Table A-9B.

Transient Occupancy Tax Generated Off-Site
While the Project does not include an on-site hotel component, the future business activities on-site will likely attract business-related travel to the area. To develop an orderof-magnitude estimate of future business travel related to ongoing operations on-site at buildout, EPS estimated the ratio of business-traveler roomnights to jobs in the larger subregion stretching from Bay Point to Brentwood. The analysis focuses on midscale to upper-midscale class hotels since business travelers typically frequent hotels in this range and the existing and proposed hotels in Oakley near the Project fall into this range.

Assuming that half the customer base for roomnights in this hotel range are business travelers, each job in the sub-region translates to 0.77 annual roomnights at midscale to upper-midscale hotel properties. The estimate assumes Oakley hotels will capture 50 percent of the additional roomnight demand. The estimated annual TOT off-site elsewhere in Oakley generated by business travel spurred by the Project development at buildout is shown in Table 10.

Business License Tax
Business license tax is calculated based on $10 per employee and $100 per business. As shown in Table 11, the higher number of employees in the manufacturing scenario results in higher estimated business license tax. For both scenarios, it is assumed the average 255
Oakley Bridgehead Industrial PUD Fiscal and Economic Impact Analysis

square footage per business is 100,000 square feet, resulting in an estimated 31 businesses.

Expenditure-Estimating Methodology
This Fiscal Impact Analysis shows estimates of General Fund expenditures associated with serving the Project. Expenditures that are expected to be affected by the Project are forecasted using an average-cost approach, which uses the City’s FY 2024-25 budgeted expenditures on a citywide per person-served basis to forecast expenditures required to serve new service population generated by the Project.

A listing of all City General Fund expenditures and the corresponding estimating procedure used to forecast future Project expenditures is shown in Table A-12 in Appendix A. An adjustment factor is applied to the average-cost multipliers for all expenditure categories to reflect the percentage of departmental expenditures that are variable and likely to increase based on new development of singular projects, recognizing that some departmental costs are fixed and less impacted by service population growth.

These factors are based on EPS’s experience working in other cities. The adjustment factor for Animal Control, City Council, City Clerk, City Attorney, City Manager, Finance, Human Resources, Facilities Maintenance, Information Technology, and Recreation expenditures is 50 percent of costs; while factor for Economic Development, Building, Planning, Code Enforcement, Police, and Public Works is 75%.

A summary of estimated annual General Fund expenditures required to serve the Project at buildout is provided in Table A-13 in Appendix A. As shown, the Project is estimated to result in about $251,000 to $690,000 in annual General Fund costs at buildout. Police is the largest General Fund expenditure category, with estimated annual expenditures of approximately $158,000 to $434,000.
256
Economic & Planning Systems, Inc.

Temporary Tax Generation from Construction Employees
The construction-related employment is estimated to generate additional temporary City tax revenues, separate from the ongoing annual tax generation at buildout discussed above. Temporary tax revenues during construction include daytime taxable spending by workers, transient occupancy tax from a portion of construction workers that stay in lodging, and evening taxable spending from those staying in lodging. (Sales taxes include the Bradley Burns local option 1.0 percent plus 0.50 percent for Measure J.) The total estimated worker tax generation over the duration of the construction period is summarized below.2
 Local option sales tax from construction worker daytime spending: $48,000  Transient occupancy tax from construction workers in lodging: $143,000  Local option sales tax from evening spending by workers in lodging: $5,000  Total temporary tax revenue from construction workers: $196,000 Over a 10-year buildout, annual revenues from construction worker spending would be about $20,000 per year; over a 5-year buildout, annual revenues would be about $39,000 per year.
2 Assumptions include: 2,.654 annual construction jobs; 240 days of employment per year; average daytime taxable spending of $10; 5% of workers in lodging; $90 average daily room rate per person including some doubling up and short-term rentals; $20 evening taxable spending for overnights; 50% capture of stays and spending in Oakley. 257
Oakley Bridgehead Industrial PUD Fiscal and Economic Impact Analysis

Economic Impact Analysis
Economic impacts include ongoing annual impacts from the operation of the planned development in Bridgehead PUD (modeled at buildout) and the one-time impacts from construction of the Project. The ongoing and one-time economic impacts are presented separately.

The direct activity occurring within the Project (both the ongoing activity after completion and one-time construction activity) will generate additional economic activity throughout the local economy, resulting in the multiplier effects described below.

Overview of Economic Multiplier Effects
The direct economic activity in Bridgehead PUD will generate additional indirect economic effects in the surrounding region through business-to-business activities. In addition, onsite employees will generate induced economic activity in the surrounding region through daytime spending. For this study, the larger region analyzed for economic multiplier effects is Contra Costa County.

Figure 4 summarizes the definition of direct, indirect, and induced economic multiplier effects.

Figure 4 Economic Multiplier Effects
EPS relies on Implan Economic Input-Output software to calculate economic multiplier effects. Implan is a nationally recognized leader in economic impact modeling. 258
Economic & Planning Systems, Inc.

Economic Impact Methodology and Assumptions
This section details the underlying methodology and assumptions used to estimate the economic impacts. Assumptions for development density and resulting square footage are the same as those described above for the fiscal impact analysis. However, while the fiscal impacts provided a range, representing manufacturing at one end and distribution at the other, the economic impacts are presented as a blend of both end uses, with employee density equating to one worker per 1,500 square feet.

Ongoing economic impacts from operations at buildout are estimated assuming a variety of industrial space-using sectors will occupy space in Bridgehead PUD. Due to the speculative nature of future occupants, each included sector has been assigned an equal weighting. Sectors included in the estimate of ongoing economic impacts include:
 Warehousing and Storage
 Truck Transportation
 Wholesale – Other Durable Goods
 Miscellaneous Manufacturing
 Data Processing, Hosting, and Related
 Miscellaneous Professional, Scientific, and Technical Estimated construction cost assumptions used to calculate the one-time economic impacts from the construction phase include:
 Site Development and Infrastructure Costs of $27.9 million  Vertical Construction Costs of $651 million
Economic multiplier effects from site development and infrastructure spending are derived based on the Implan sector “Construction of New Highways and Streets,” which corresponds to the activities and inputs for land development. Multiplier effects for vertical construction are based on aggregated Implan sectors for both manufacturing and commercial structures: “Construction of New Manufacturing Structures” and “Construction of New Commercial Structures,” with equal weighting given to each sector.

Detailed economic impact assumptions and calculations are located in Appendix B. 259
Appendix A
Fiscal Impact Analysis
Table A-1 General Assumptions
Table A-2 Proposed Land Use Development Plan
Table A-3 Estimated Service Population
Table A-4 Land Use Assumptions
Table A-5 Revenue-Estimating Procedures Based on City of Oakley FY 2024-25 Adopted Budget (2025$)
Table A-6 Estimated Annual Project Revenues at Buildout (2025$) Table A-7 Estimated Property Tax Revenues (2025$)
Table A-8 Real Property Transfer Tax at Buildout (2025$) Table A-9 Estimated Taxable Sales and Use Tax Revenue (2025$) Table A-9A Estimated Annual Taxable Sales, Hybrid Market Support Method (2025$) Table A-9B Estimated Annual Taxable Sales Generated from On-site Industrial Use (2025$) Table A-10 Estimated Transient Occupancy Tax at Buildout (2025$) Table A-11 Business License Tax (2025$)
Table A-12 Expenditure-Estimating Procedures Based on City of Oakley FY 2024-25 Adopted Budget (2025$)
Table A-13 Estimated Annual Project Expenditures at Buildout (2025$) Table A-14 Preliminary Property Tax Allocations
Table A-15 Estimated Assessed Valuation at Buildout (2025$) 260
Table 1
Bridgehead Industrial PUD - Oakley
Fiscal Impact Analysis
Estimated Revenue and Expenditure Summary Comparison (2025$) General Fund Item Amount Percent Amount Percent
Annual Revenues [1]
Property Tax $586,800 27.6% $586,800 44.7%
Property Tax in Lieu of VLF $618,600 29.1% $618,600 47.1% Property Transfer Taxes $21,300 1.0% $21,300 1.6%
Sales Taxes $733,491 34.5% $24,248 1.8%
Franchise Tax $102,400 4.8% $37,300 2.8%
Transient Occupancy Taxes $20,000 0.9% $7,000 0.5%
Motor Vehicle In Lieu Tax $1,800 0.1% $600 0.0%
Traffic Fines $2,900 0.1% $1,000 0.1%
Business Licenses $40,100 1.9% $16,600 1.3%
Total General Fund Revenues $2,127,400 100.0% $1,313,400 100.0% Annual Expenditures [2]
City Council $1,900 0.3% $700 0.3%
City Clerk $9,800 1.4% $3,600 1.4%
City Attorney $8,800 1.3% $3,200 1.3%
City Manager $500 0.1% $200 0.1%
Finance $21,500 3.1% $7,800 3.1%
Human Resources $4,100 0.6% $1,500 0.6%
Facilities Maintenance $16,100 2.3% $5,900 2.4%
Information Technology $0 0.0% $0 0.0%
Economic Development $8,400 1.2% $3,000 1.2%
Building $700 0.1% $200 0.1%
Planning $24,000 3.5% $8,700 3.5%
Code Enforcement $19,000 2.8% $6,900 2.8%
Police $433,500 62.9% $157,600 62.9%
Public Works $120,900 17.5% $43,900 17.5%
Recreation $20,400 3.0% $7,400 3.0%
Total General Fund Expenditures $689,600 100.0% $250,600 100.0% Annual General Fund Surplus/(Deficit) $1,437,800 $1,062,800 Source: City of Oakley FY 2024-25 Adopted Budget; EPS.

Note: Values are rounded to the nearest $100.
[1] See Table A-5 for details on revenue estimating procedures. [2] See Table A-12 for details on expenditure estimating procedures.

At Project Buildout
Manufacturing
Focused
Distribution
Focused
Prepared by EPS 9/29/2025 Z:\Shared\Projects\SAC\242000\242140 Bridgehead Industrial\Model\242140 FIA 09-26-25 261 Table A-1
Bridgehead Industrial PUD - Oakley
Fiscal Impact Analysis
General Assumptions
Item Assumption
General Assumptions
Base Fiscal Year [1] FY 2024-25
General Demographic Characteristics
City of Oakley
Population [2] 45,736
Employees 5,748
City of Oakley Persons Served [3] 48,610
Business-Oriented Persons Served [4] 28,616
[2] DOF Table 2: E-5 City of Oakley population estimate as of 1/1/2024. [1] Reflects the City of Oakley Fiscal Year 2024-25 Adopted Budget. Revenues and expenditures are in 2024 dollars. This analysis does not reflect changes in value resulting from inflation or appreciation.

Source: U.S. Census Longitudinal Employer-Household Dynamics (LEHD); California Department of Finance (DOF); JobsEQ; EPS.
[3] Service population (Persons Served) counts Oakley residents at 100% and employees working within the City at 50%, to account for the lower level of service needs for daytime/employee populations and their associated customers/clients. [4] Business-oriented persons served multiplier based on 50% of residents and 100% of employees to reflect stonger impact from local employment and more moderate impact from local residents on changes in revenue generation from general business activity in the City.

Prepared by EPS 9/29/2025 Z:\Shared\Projects\SAC\242000\242140 Bridgehead Industrial\Model\242140 FIA 09-26-25 262 Table A-2
Bridgehead Industrial PUD - Oakley
Fiscal Impact Analysis
Proposed Land Use Development Plan
Land Use Acreage
Average
Density Bldg Sq. Ft.

Bridgehead Industrial PUD FAR
Industrial 164.00 0.43 3,100,000
Source: JB2; EPS.

Buildout
Prepared by EPS 9/29/2025 Z:\Shared\Projects\SAC\242000\242140 Bridgehead Industrial\Model\242140 FIA 09-26-25 263 Table A-3
Bridgehead Industrial PUD - Oakley
Fiscal Impact Analysis
Estimated Service Population
Manufacturing Distribution
Land Use Focused Focused
Bridgehead Industrial PUD Occupied Bldg Sq. Ft. Employees Employees Industrial 2,963,600 3,705 1,347
(800 emp/sq ft) (2,200 emp/sq ft)
Persons Served [2] 1,852 674
Source: Campus Land Use Plan Northeast Quadrant Specific Plan (NEQSP), dated May 15, 2024; EPS. [1] Based on vacancy rate and employment density assumptions in Table A-4. [2] On-site employees are counted at 50% for determination of service population.

Occupied
Building
Square Feet [1]
Buildout
Service Population [1]
Prepared by EPS 9/29/2025 Z:\Shared\Projects\SAC\242000\242140 Bridgehead Industrial\Model\242140 FIA 09-26-25 264 Table A-4
Bridgehead Industrial PUD - Oakley
Fiscal Impact Analysis
Land Use Assumptions
Annual
Manufacturing Distribution
Land Use Focused Focused
Nonresidential Per Sq. Ft.

Secured $210
Unsecured $40
Total $250 5.0% 800 2,200 4.4%
[1] Assumptions reflect both secured and
Turnover
Rate [2]
Vacancy
Rate [3]
Assessed
Value
(Rounded) [1]
Source: California Department of Finance; U.S. Census Bureau, 2022 American Community Survey 1-Year Estimates; U.S. Bureau of Labor Statistics; CoStar; Saylor; EPS.
[2] Annual Turnover Rate based on assumption that industrial properties turnover once in every 20 years. [3] Estimated nonresidential vacancy rates based on 2025 data obtained from CoStar for the Antioch/Pittsburgh submarket.

Employee Density (SF/Emp)
Prepared by EPS 9/29/2025 Z:\Shared\Projects\SAC\242000\242140 Bridgehead Industrial\Model\242140 FIA 09-26-25 265 Table A-5
Bridgehead Industrial PUD - Oakley
Fiscal Impact Analysis
Revenue-Estimating Procedures Based on City of Oakley FY 2024-25 Adopted Budget (2025$) FY 2024-25 Existing Current
Estimating Case Study Budgeted Service Revenue
Item Procedure Reference Revenues Population Multiplier General Fund Revenues
Property Tax Case Study Table A-7 $5,270,000 NA -
Property Tax in Lieu of VLF Case Study Table A-7 $5,245,000 NA - Sales Taxes Case Study Table A-9 $3,050,000 NA -
Franchise Tax Persons Served Multiplier - $2,688,634 48,610 $55.31 Transient Occupancy Taxes Case Study Table A-10 $250,000 NA - Motor Vehicle In Lieu Tax Persons Served Multiplier - $46,000 48,610 $0.95 Property Transfer Taxes Table A-10 $150,000 NA -
Traffic Fines Persons Served Multiplier - $75,000 48,610 $1.54 Interfund Charges for Services [2] - $12,365,142 NA -
Developer Fees [2] - $1,549,200 NA -
Intergovernmental Revenues [2] - $330,384 NA -
Business Licenses Case Study - $125,000 28,616 $4.37
Other Revenue [1] - $592,590 NA -
Other Financing Sources [1] - $400,000 NA -
Subtotal General Fund Revenues $32,136,950 $62.17
Less Offsetting Revenues [3] $14,837,316
Net General Fund Operating Revenues $17,299,634
Source: City of Oakley FY 2024-25 Adopted Budget; EPS.
[1] This revenues source is not expected to be affected by the Project and therefore no revenue multipliers are estimated in this analysis. [2] This analysis assumes that all or part of these revenues are fully dedicated to specific General Fund departmental costs (offsetting revenues).

Because these revenues are budget-neutral and are not discretionary, they are not included in estimating discretionary Project revenues. [3] Represents the sum of offsetting revenues dedicated to General Fund department functions. These revenues are budget neutral and are netted from both total revenues and total costs (shown in Table C-1). Amounts exclude one-time grant revenues.

Prepared by EPS 9/29/2025 Z:\Shared\Projects\SAC\242000\242140 Bridgehead Industrial\Model\242140 FIA 09-26-25 266 Table A-6
Bridgehead Industrial PUD - Oakley
Fiscal Impact Analysis
Estimated Annual Project Revenues at Buildout (2025$)
Estimating
Item Procedure Source Amount Percent Amount Percent
Annual General Fund Revenues
Property Tax Case Study Table A-7 $586,800 27.6% $586,800 44.7% Property Tax in Lieu of VLF Case Study Table A-7 $618,600 29.1% $618,600 47.1% Property Transfer Taxes Case Study Table A-8 $21,300 1.0% $21,300 1.6% Sales Taxes Case Study Table A-9 $733,491 34.5% $24,248 1.8% Franchise Tax Persons Served Multiplier Table A-5 $102,400 4.8% $37,300 2.8% Transient Occupancy Taxes Case Study Table A-10 $20,000 0.9% $7,000 0.5% Motor Vehicle In Lieu Tax Persons Served Multiplier Table A-5 $1,800 0.1% $600 0.0% Traffic Fines Persons Served Multiplier Table A-5 $2,900 0.1% $1,000 0.1% Business Licenses Case Study Table A-11 $40,100 1.9% $16,600 1.3% Annual General Fund Revenues $2,127,400 100.0% $1,313,400 100.0% Source: City of Oakley FY 2024-25 Adopted Budget; EPS.

Note: Values are rounded to the nearest $100.

Annual Project Revenues at Buildout (rounded)
Manufacturing Distribution
Focused Focused
Prepared by EPS 9/29/2025 Z:\Shared\Projects\SAC\242000\242140 Bridgehead Industrial\Model\242140 FIA 09-26-25 267 Table A-7
Bridgehead Industrial PUD - Oakley
Fiscal Impact Analysis
Estimated Property Tax Revenues (2025$)
Item Assumptions Formula
1% Property Tax
Total Secured Assessed Value of Project [1] $775,000,000 a $775,000,000 Total Unsecured Assessed Value @ 10% of Secured AV 10.00% b = a * 10% $77,500,000 Total Estimated Assessed Value c = a + b $852,500,000
Property Tax Revenue (1% of Assessed Value) 1.00% d = a * 1.00% $8,525,000 Estimated Property Tax Allocation
City of Oakley 6.88% e = d * 6.88% $586,774
Contra Costa County 12.66% f = d * 12.66% $1,079,216
Other Agencies 80.46% g = d * 80.46% $6,859,010
Property Tax In Lieu of Vehicle License Fee Revenue (VLF) Total Citywide Assessed Value [2] h $7,228,081,187
Total Assessed Value of Project i = c $852,500,000
Total Assessed Value j = h + i $8,080,581,187
Percentage Change in AV k = i / h 11.79%
Property Tax In Lieu of VLF [3] $5,245,000 l = k * $5,245,000 $618,610 Source: Contra Costa County Auditor-Controller; City of Oakley FY 2024-25 Adopted Budget; EPS. [1] For assumptions and calculation of assessed value, refer to Table A-15.

Project
Buildout
[3] Property tax in lieu of VLF amount derived from the City of Oakley FY 2024-25 Adopted Budget. See Table A-5. [2] Year 2024-25 Contra Costa County Assessment Roll Values for City of Oakley. Includes citywide secured, unsecured, and homeowner exemption.

Prepared by EPS 9/29/2025 Z:\Shared\Projects\SAC\242000\242140 Bridgehead Industrial\Model\242140 FIA 09-26-25 268 Table A-8
Bridgehead Industrial PUD - Oakley
Fiscal Impact Analysis
Real Property Transfer Tax at Buildout (2025$)
Description
Assumptions
Rate per $1,000 of AV [1] $0.55
Turnover Rate
Nonresidential Sq. Ft. 5.0%
Assessed Value [2]
Industrial - Secured $775,000,000
Total Secured Assessed Value $775,000,000
Annual Transfer Tax Revenue
Industrial - Secured $21,313
Total Annual Transfer Tax Revenue $21,313
Source: City of Oakley; EPS.
[1] Based on California Revenue and Taxation Code, §§ 11911-11929, which authorizes cities and counties to levy a real estate transfer tax at a rate of $0.55 per $1,000 value.

Source/
Assumption
Project
Buildout
[2] Assessed Values (AV) derived in Table A-15 note that assessed values are based on 24/25 valuation and include no real AV growth.

Prepared by EPS 9/29/2025 Z:\Shared\Projects\SAC\242000\242140 Bridgehead Industrial\Model\242140 FIA 09-26-25 269 Table A-9
Bridgehead Industrial PUD - Oakley
Fiscal Impact Analysis
Estimated Taxable Sales and Use Tax Revenue (2025$)
Manufacturing Distribution
Item Assumptions Formula Focused Focused
Estimated Annual Taxable Sales (Rounded)
Annual Taxable Sales from New Market Support Table A-9A $4,445,400 $1,616,509 Annual Taxable Sales from Onsite Industrial Use Table A-9B $44,454,000 $0 Total Annual Taxable Sales a $48,899,400 $1,616,509
Annual Sales Tax Revenue
Bradley Burns Local Sales Tax Rate 1.0000% b = 1.0000% * a $488,994 $16,165 Measure J Sales Tax Rate [1] 0.5000% c = 0.5000% * a $244,497 $8,083 Total Sales Tax Revenue d = b + c $733,491 $24,248
Source: City of Oakley; EPS.

Project Buildout
[1] Measure J, approved in 2004, levies an additonal half-cent sales tax to support transportation related purposes.

Prepared by EPS 9/29/2025 Z:\Shared\Projects\SAC\242000\242140 Bridgehead Industrial\Model\242140 FIA 09-26-25 270 Table A-9A
Bridgehead Industrial PUD - Oakley
Fiscal Impact Analysis
Estimated Annual Taxable Sales, Hybrid Market Support Method (2025$) Manufacturing Distribution
Item Description Focused Focused
Annual Taxable Sales from New Employees Table A-3
New Employees 3,705 1,347
Average Daily Taxable Sales per New Employee $10
Work Days per Year 240
Estimated Retail Capture in City of Oakley 50%
Total City Taxable Sales from New Employees $4,445,400 $1,616,509 Total Annual City Taxable Sales from Market Support $4,445,400 $1,616,509 Taxable City Sales inside Project Area [1] 0% $0 $0
Taxable City Sales outside Project Area [1] 100% $4,445,400 $1,616,509 Source: BLS; Consumer Expenditure Survey; and EPS.

Source/
Assumption
Project Buildout
Prepared by EPS 9/29/2025 Z:\Shared\Projects\SAC\242000\242140 Bridgehead Industrial\Model\242140 FIA 09-26-25 271 Table A-9B
Bridgehead Industrial PUD - Oakley
Fiscal Impact Analysis
Estimated Annual Taxable Sales Generated from On-site Industrial Use (2025$) Manufacturing Distribution
On-Site Industrial Development Formula Focused Focused
Occupied Building Sq. Ft. [1] a 2,963,600 2,963,600
Average Taxable Sales per Sq. Ft. [2] b $15.00 $0.00
Annual Taxable Sales from On-Site Industrial Dev. c = a * b $44,454,000 $0 [1] Assumed vacancy rate for industrial use is detailed in Table A-3. [2] A taxable sales per square foot assumption representing taxable industrial sales activity, based on research of similar industrial development. This assumptions take into account use tax, which is paid to the State by in-state businesses on purchases made from out-of-state businesses. The average sales per sq ft assumes limited taxable sales from most users and higher volumes from a small share. Distribution users not anticipated to generate sales/use tax.

Source: EPS.

Project Buildout
Prepared by EPS 9/29/2025 Z:\Shared\Projects\SAC\242000\242140 Bridgehead Industrial\Model\242140 FIA 09-26-25 272 Table A-10
Bridgehead Industrial PUD - Oakley
Fiscal Impact Analysis
Estimated Transient Occupancy Tax at Buildout (2025$)
Per Job
Roomnight Manufacturing Distribution
Category Formula Multiplier Focused Focused
5-City Submarket Business Travel Sector Roomnight Demand [1] Jobs EQ Five Cities Employment a 67,841
Five Cities - Midscale to Upper Midscale Hotels
Hotel Rooms b 478
Occupancy c 60%
Average Daily Rate d $141
Total Annual Midscale to Upper Midscale Occupied Roomnights e = b * c * d 104,682 Assumed Share of Roomnight Demand From Business Travelers f 50% Annual Midscale to Upper Midscale Business Sector Roomnights g = e * f 52,341 Ratio of Annual Business Roomnight Demand to Local Employment h = g / a 0.77152 Estimated Project-Generated Midscale to Upper Midscale Roomnights Onsite Employment Estimate i 3,705 1,347
Roomnight Demand from Onsite Employment j = I * h 2,858 1,039 Assumed Oakley Capture of Project Roomnight Demand k 50% 50% Estimated Annual Roomnights Captured in Oakley l = j * k 1,429 520 Average Nightly Roomnight Demand m = l / 365 3.9 1.4
Annual Room Revenue in Oakley due to Project n = l * d $201,497 $73,272 Annual Project Generated TOT at Buildout (rounded) o = n * 10% $20,000 $7,000 Source: JobsEQ; Costar; EPS.
[1] The larger subregion, consisting of Bay Point, Pittsburg, Antioch, Oakley, and Brentwood, was used for hotel performance metrics and calculation of the ratio of local employment to business-driven roomnight demand.

Project Buildout
Prepared by EPS 9/29/2025 Z:\Shared\Projects\SAC\242000\242140 Bridgehead Industrial\Model\242140 FIA 09-26-25 273 Table A-11
Bridgehead Industrial PUD - Oakley
Fiscal Impact Analysis
Estimated Business License Tax at Buildout (2025$)
Manufacturing Distribution
Category Focused Focused
Total Industrial Square Footage 3,100,000 3,100,000
Estimated Average Sq Ft per Business 100,000 100,000
Estimated Number of Businesses 31 31
Business License Tax Per Business $100 $100
Per Business License Tax $3,100 $3,100
Number of Employees 3,705 1,347
Business License Tax Per Employee $10 $10
Per Employee License Tax $37,045 $13,471
Total Annual Estimated Business License Tax $40,145 $16,571 Project Buildout
Source: City of Oakley; EPS.

Prepared by EPS 9/29/2025 Z:\Shared\Projects\SAC\242000\242140 Bridgehead Industrial\Model\242140 FIA 09-26-25 274 Table A-12
Bridgehead Industrial PUD - Oakley
Fiscal Impact Analysis
Expenditure-Estimating Procedures Based on City of Oakley FY 2024-25 Adopted Budget (2025$) Less
FY 2024-25 Offsetting FY 2024-25 Population Net Adjusted Estimating Subtotal Revenue Net City or Persons Expenditure Adjustment Expenditure Item Procedure Expenditures [1] Expenditures Served Multiplier Factor [2] Multiplier General Fund Expenditures
Animal Control Persons Served Multiplier $491,325 - $491,325 48,610 $10.11 50% $5.05 City Council Persons Served Multiplier $98,537 - $98,537 48,610 $2.03 50% $1.01 City Clerk Persons Served Multiplier $513,657 - $513,657 48,610 $10.57 50% $5.28 City Attorney Persons Served Multiplier $460,521 - $460,521 48,610 $9.47 50% $4.74 City Manager Persons Served Multiplier $1,007,656 $983,284 $24,372 48,610 $0.50 50% $0.25 Finance Persons Served Multiplier $1,130,932 - $1,130,932 48,610 $23.27 50% $11.63 Human Resources Persons Served Multiplier $215,214 - $215,214 48,610 $4.43 50% $2.21 Facilities Maintenance Persons Served Multiplier $845,818 - $845,818 48,610 $17.40 50% $8.70 Information Technology Persons Served Multiplier - - - 48,610 $0.00 50% $0.00 Non-Departmental [3] $100 NA NA NA NA NA NA
Economic Development Persons Served Multiplier $292,475 - $292,475 48,610 $6.02 75% $4.51 Building Persons Served Multiplier $1,086,131 $1,063,300 $22,831 48,610 $0.47 75% $0.35 Planning Persons Served Multiplier $863,258 $23,500 $839,758 48,610 $17.28 75% $12.96 Code Enforcement Persons Served Multiplier $663,922 - $663,922 48,610 $13.66 75% $10.24 Police Persons Served Multiplier $15,309,796 $140,050 $15,169,746 48,610 $312.07 75% $234.05 Public Works Persons Served Multiplier $4,253,299 $24,400 $4,228,899 48,610 $87.00 75% $65.25 Recreation Persons Served Multiplier $1,244,067 $237,640 $1,006,427 45,736 $22.01 50% $11.00 Land Purchases [3] - - - NA NA NA NA
Totals $28,476,708 $2,472,174 $26,004,434 Persons Served Multiplier: $361.20 Transfers Out $6,288,200 $6,288,200
Total Annual General Fund Expenditures $34,764,908 $2,472,174 $32,292,634 Source: City of Oakley FY 2024-25 Adopted Budget; EPS.
[1] Represents departmental revenues identified for specific General Fund department functions in the City's fiscal budget. Non-departmental offsets allocated to related departments. [2] Adjustment factor recognizes some department costs are fixed. [3] Not expected to be affected by the Project and is not evaluated in this analysis.

Prepared by EPS 9/29/2025 Z:\Shared\Projects\SAC\242000\242140 Bridgehead Industrial\Model\242140 FIA 09-26-25 275 Table A-13
Bridgehead Industrial PUD - Oakley
Fiscal Impact Analysis
Estimated Annual Project Expenditures at Buildout (2025$) Estimating
Expenditures Procedure Source Amount Percent Amount Percent General Fund
City Council Persons Served Multiplier Table A-12 $1,900 0.3% $700 0.3% City Clerk Persons Served Multiplier Table A-12 $9,800 1.4% $3,600 1.4% City Attorney Persons Served Multiplier Table A-12 $8,800 1.3% $3,200 1.3% City Manager Persons Served Multiplier Table A-12 $500 0.1% $200 0.1% Finance Persons Served Multiplier Table A-12 $21,500 3.1% $7,800 3.1% Human Resources Persons Served Multiplier Table A-12 $4,100 0.6% $1,500 0.6% Facilities Maintenance Persons Served Multiplier Table A-12 $16,100 2.3% $5,900 2.4% Information Technology Persons Served Multiplier Table A-12 $0 0.0% $0 0.0% Economic Development Persons Served Multiplier Table A-12 $8,400 1.2% $3,000 1.2% Building Persons Served Multiplier Table A-12 $700 0.1% $200 0.1% Planning Persons Served Multiplier Table A-12 $24,000 3.5% $8,700 3.5% Code Enforcement Persons Served Multiplier Table A-12 $19,000 2.8% $6,900 2.8% Police Persons Served Multiplier Table A-12 $433,500 62.9% $157,600 62.9% Public Works Persons Served Multiplier Table A-12 $120,900 17.5% $43,900 17.5% Recreation Persons Served Multiplier Table A-12 $20,400 3.0% $7,400 3.0% Annual General Fund Expenditures $689,600 100.0% $250,600 100.0% Source: City of Oakley FY 2024-25 Adopted Budget; EPS.

Note: Values are rounded to the nearest $100.

Annual Cost at Buildout (rounded)
Manufacturing Distribution
Focused Focused
Prepared by EPS 9/29/2025 Z:\Shared\Projects\SAC\242000\242140 Bridgehead Industrial\Model\242140 FIA 09-26-25 276 Table A-14
Bridgehead Industrial PUD - Oakley
Fiscal Impact Analysis
Property Tax Allocations
COUNTY GENERAL 0.1265943
CITY OF OAKLEY 0.0688298
COUNTY LIBRARY 0.0195254
CONTRA COSTA FIRE 0.1455376
C C FLOOD CONTROL 0.0022912
CO WATER AGENCY 0.0004669
CC RES CONSV 0.0002118
CO CO MOSQUITO ABA 0.0020807
CONTRA COSTA WATER 0.0062047
BART 0.0082621
BAY AREA AIR MGMNT 0.0024083
EAST BAY REGNL PK 0.0392817
OAKLEY POLICE SVC 0.0120574
OAKLEY RDA PROJ 2 0.0000000
CO SUPT SCHOOLS 0.0236705
K-12 SCHOOLS ERAF 0.1217966
ANTIOCH UNIFIED 0.3424725
CO CO COMM COLLEGE 0.0601732
COMM COLLEGE ERAF 0.0181353
Total 1.0000000
Source: Contra Costa County Auditor-Controller; EPS.

Post-ERAF Shift
Allocation for TRA 19091
[1] Represents the percentage allocation of the 1% ad valorem property Prepared by EPS 9/29/2025 Z:\Shared\Projects\SAC\242000\242140 Bridgehead Industrial\Model\242140 FIA 09-26-25 277 Table A-15
Bridgehead Industrial PUD - Oakley
Fiscal Impact Analysis
Estimated Assessed Valuation at Buildout (2025$)
Item
Bridgehead Industrial PUD Per Sq. Ft. Bldg Sq. Ft.

Industrial $250 3,100,000 $775,000,000
Total Assessed Value $775,000,000
Source: EPS.
[1] Note that assessed values (AV)s are expressed in 2025$ and include no real AV growth.

Assessed Value
per Unit/Bldg Sq. Ft.

Total
Assessed Value [1]
Buildout
Development
Prepared by EPS 9/29/2025 Z:\Shared\Projects\SAC\242000\242140 Bridgehead Industrial\Model\242140 FIA 09-26-25 278 Appendix B
Economic Impact Analysis
Table B-1 Ongoing Operations Economic Multiplier Calculations Table B-2 Ongoing Annual Economic Impact Multipliers
Table B-3 One-Time Construction Economic Multiplier Calculations Table B-4 One-Time Construction Economic Impact Multipliers 279
DRAFT
Appendix Table B-1
Bridgehead Economic Impact Analysis
Ongoing Operations Economic Multiplier Caclulations
Impact Category Direct Indirect Induced Annual Total
Activity/Input [1]
Ongoing Employment at Buildout 1,976 jobs
Contra Costa County Impacts
Industry Output [2] $602,962,138 $173,285,323 $120,427,079 $896,674,540 per Direct Employee $305,184 $87,707 $60,953 $453,844
Employee Compensation [3] $226,088,592 $72,858,093 $40,394,066 $339,340,751 Employee Compensation per Employee $114,430 $78,094 $68,612 $97,025 Employment [4] 1,976 933 589 3,497
Multiplier (Rounded) 1.00 0.47 0.30 1.77
Source: Implan; EPS.
[1] For impact modeling purposes, Industrial Employment is assumed to be comprised of 16.667% Warehousing and Storage;

16.667% Truck Transportation; 16.667% Wholesale - Other Durable Goods; 16.667% Miscellaneous Manufacturing;

16.667% Data Processing, Hosting, and Related; 16.667% Misc. Professional, Scientific, Technical. [3] Includes worker wages, benefits, and proprietor's income.

Multiplier Impacts
[2] Reflects business expenditures on goods and services retained in the local economy. Inclusive of employee compensation reported below. [4] Reflects full-time and part-time workers.

Prepared by EPS 8/20/2025 Z:\Shared\Projects\SAC\242000\242140 Bridgehead Industrial\Model\242140 EIA 07-22-25 280 DRAFT
Appendix Table B-2
Bridgehead Economic Impact Analysis
Ongoing Annual Economic Impact Multipliers
Direct Indirect Induced
Assumed Employ- Direct Direct Employ- Indirect Indirect Employ- Induced Induced Activity/Sectors Share Input Type Divisor ment Income Output ment Income Output ment Income Output Ongoing Operations
Warehousing and Storage 16.7% Industry Employment Per 1,000 1,000 $83,820,293 $122,865,344 160.92 $12,807,205 $31,455,312 186.52 $12,808,479 $38,187,507 Truck Transportation 16.7% Industry Employment Per 1,000 1,000 $39,728,621 $167,799,168 637.48 $37,159,468 $96,387,632 154.55 $10,595,531 $31,587,321 Wholesale - Other Durable Goods 16.7% Industry Employment Per 1,000 1,000 $111,513,202 $392,066,806 831.48 $61,784,468 $134,070,352 336.10 $23,069,571 $68,778,704 Miscellaneous Manufacturing 16.7% Industry Employment Per 1,000 1,000 $203,080,074 $462,221,347 279.29 $31,033,320 $79,996,895 450.53 $30,936,606 $92,235,092 Data Processing, Hosting, and Related 16.7% Industry Employment Per 1,000 1,000 $117,857,255 $360,712,522 615.05 $51,442,003 $118,726,671 344.87 $23,647,033 $70,496,871 Misc. Professional, Scientific, Technical 16.7% Industry Employment Per 1,000 1,000 $130,583,304 $325,401,999 308.95 $27,027,998 $65,593,638 315.27 $21,610,928 $64,425,813 Ongoing Operations Consolidated Multipliers 100.0% Industry Employment Per 1,000 1,000 $114,430,458 $305,177,864 472.20 $36,875,744 $87,705,084 297.97 $20,444,691 $60,951,885 Source: Implan; EPS.

Prepared by EPS 8/19/2025 Z:\Shared\Projects\SAC\242000\242140 Bridgehead Industrial\Model\242140 EIA 07-22-25 281 DRAFT
Appendix Table B-3
Bridgehead Economic Impact Analysis
One-Time Construction Economic Multiplier Caclulations
Impact Category Direct Indirect Induced Total
Activity/Input [1]
Site Development and Infrastructure $27,880,000
Industrial Vertical Development $651,000,000
Total Development Cost $678,880,000
Contra Costa County Impacts
Industry Output [2]
Site Development and Infrastructure $27,880,000 $4,950,087 $5,620,441 $38,450,528 Industrial Vertical Development $651,000,000 $112,669,927 $116,446,896 $880,116,823 Total $678,880,000 $117,620,014 $122,067,337 $918,567,351 Multiplier (Rounded) 1.00 0.17 0.18 1.35
Employee Compensation [3]
Site Development and Infrastructure $12,244,483 $1,591,997 $1,885,266 $15,721,746 Industrial Vertical Development $248,644,564 $37,596,539 $39,059,925 $325,301,028 Total $260,889,047 $39,188,536 $40,945,191 $341,022,774 Employee Compensation per Employee $98,313 $94,019 $68,559 $92,980 Employment [4]
Site Development and Infrastructure 121.28 16.45 27.60 165.33 Industrial Vertical Development 2,532.39 400.37 569.63 3,502.38 Total 2,653.67 416.81 597.23 3,667.71
Multiplier (Rounded) 1.00 0.16 0.23 1.38
Source: Implan; EPS.
[1] Development cost assumptions include site prep and infrastructure at $170,000/ac and vertical construction cost of $210/sf for 3.1M sq ft. [3] Includes worker wages, benefits, and proprietor's income.

Multiplier Impacts
[2] Reflects business expenditures on goods and services retained in the local economy. Inclusive of employee compensation reported below. [4] Reflects full-time and part-time workers.

Prepared by EPS 8/19/2025 Z:\Shared\Projects\SAC\242000\242140 Bridgehead Industrial\Model\242140 EIA 07-22-25 282 DRAFT
Appendix Table B-4
Bridgehead Economic Impact Analysis
One-Time Construction Economic Impact Multipliers
Direct Indirect Induced
Employ- Direct Direct Employ- Indirect Indirect Employ- Induced Induced Activity/Sectors Input Type Divisor ment Income Output ment Income Output ment Income Output Site Development and Infrastructure
Construction of New Highways and Streets Industry Output Per $1,000,000 4.35 $439,185 $1,000,000 0.59 $57,102 $177,550 0.99 $67,621 $201,594 Industrial Vertical Development
Construction of New Manufacturing Structures Industry Output Per $1,000,000 3.53 $350,740 $1,000,000 0.66 $62,233 $184,903 0.82 $56,352 $167,998 Construction of New Commercial Structures Industry Output Per $1,000,000 4.25 $413,145 $1,000,000 0.57 $53,271 $161,241 0.93 $63,648 $189,750 Aggregated Industrial Development Multpliers Industry Output Per $1,000,000 3.89 $381,942 $1,000,000 0.62 $57,752 $173,072 0.88 $60,000 $178,874 Source: Implan; EPS.

Prepared by EPS 8/19/2025 Z:\Shared\Projects\SAC\242000\242140 Bridgehead Industrial\Model\242140 EIA 07-22-25 283 Green Jobs & Clean Communities
P.O. Box 79222
Corona, CA 92877
March 3, 2026
Ken Strelo
Community Development Director
City of Oakley
Re: Bridgehead Industrial Project, SCH No. 2024050471
Dear Mr. Strelo:

On behalf of the Golden State Environmental Justice Alliance (“GSEJA”), I am writing to you regarding the Bridgehead Industrial Project, SCH No. 2024050471 (“Project”).

GSEJA is withdrawing its comment letter and opposition to the Project. The Project’s developer has addressed GSEJA’s concerns about environmental mitigation.

Golden State Environmental Justice Alliance
geoi
D' �ector
City of Oakley
Planning Division
MAR 3, 2026

RECEIVED
284
10211 Sunland Blvd., Shadow Hills, CA 91040. (818) 650-0030 X101 [email protected] March 3, 2026
Ken Strelo
Community Development Director
City of Oakley
3231 Main Street
Oakley, CA 94561
Via email to [email protected]
re: Withdrawal of comment letter on the Bridgehead Industrial Project, SCH No. 2024050471
Dear City of Oakley:

On November 14, 2025, Advocates for the Environment submitted a CEQA comment letter regarding the proposed the Bridgehead Industrial Project, to be developed in the City of Oakley.

We have reached a settlement with the developer of that project, and withdraw the comments we submitted in our November 14,, 2025 letter. We no longer oppose the Bridgehead Industrial Project.

Sincerely,
Dean Wallraff, Attorney at Law
Executive Director, Advocates for the Environment
Advocates for the Environment
A non-profit public-interest law firm
and environmental advocacy organization
City of Oakley
Planning Division
MAR 3, 2026

RECEIVED
285
286
287
288
289
290
291
292
293
294
295
296
297
298
299
300
301
302
303
304
305
306
307
308
309
310
311
312
313
314
315
316
317
318
319
320
321
322
323
324
325
326
327
328
329
330
331
332
333
334
335
336
337
338
339
340
341
342
343
344
345
346
347
348
349
350
351
352
353
354
355
356
357
358
359
360
361
362
363
364
365
366
Resolution No. XX-26 Page 1 of 12
RESOLUTION NO. XX-26

A RESOLUTION OF THE CITY OF OAKLEY CITY COUNCIL CERTIFYING THE BRIDGEHEAD INDUSTRIAL PROJECT ENVIRONMENTAL IMPACT REPORT (SCH.

NO. 2024050471), MAKING CERTAIN FINDINGS CONCERNING MITIGATION

MEASURES, ADOPTING A MITIGATION MONITORING AND REPORTING

PROGRAM, MAKING FINDINGS CONCERNING ALTERNATIVES, AND ADOPTING

A STATEMENT OF OVERRIDING CONSIDERATIONS
SECTION 1. Background
WHEREAS, the City of Oakley (the “City”) prepared a Draft Environmental Impact Report (the “Draft EIR”) for the Bridgehead Industrial Project, which involves the development of 10 light industrial buildings.

The approximately 164-acre project site, identified by Assessor’s Parcel Numbers (“APNs”) 037-020-007, 037-040-007, and -015, is bounded by Big Break Road to the east, Bridgehead Road to the west, and Main Street to the south in the City of Oakley, California. The Burlington Northern Santa Fe (“BNSF”) railroad tracks bisect the project site, which is split into an approximately 87.6-acre North Development Area (APN 037- 020-007) and an approximately 76.4-acre South Development Area (APNs 037-040-007 and -015). The North and South Development Areas are used primarily for vineyard production. Existing on-site buildings associated with the vineyards are located within the North Development Area. The South Development Area is located within the River Oaks Crossing Specific Plan Area. The City of Oakley General Plan designates the North Development Area as Light Industrial (“LI”) and the South Development Area as Commercial (“CO”). The North Development Area is zoned Business Park Low (“BPL”) District and the South Development Area is zoned River Oaks Crossing Specific Plan (“SP-2”) District.

The proposed project would include the removal of the existing vineyard and associated buildings and subsequent construction of 10 light industrial buildings totaling approximately 3,117,777 square feet (“sf”) of new building space, including approximately 3,045,777 sf of warehouse space and 72,000 sf of office space, as well as associated internal roadways, parking, landscaping, utilities, and other improvements.

The project requires the following discretionary approvals from the City: General Plan Amendment, Rezone, Tentative Map, Design Review, Master Sign Program, and Development Agreement; and
WHEREAS, the Draft EIR addresses the potential environmental effects associated with the project; and
367
Resolution No. XX-26 Page 2 of 12
WHEREAS, on May 10, 2024, the City published a Notice of Preparation (“NOP”) for the project, which identified potentially significant environmental impacts attributable to the project, on which basis the City determined that an EIR was required; and WHEREAS, the NOP provided notice of the City’s determination, and solicited public input on the proposed scope and content of the EIR for the project; and WHEREAS, on May 20, 2024, the City held a public scoping meeting to receive public comments on the scope and content of the EIR; and WHEREAS, a Draft EIR with Technical Appendices, and a Notice of Availability, were prepared by the City and released for public review on September 19, 2025; and WHEREAS, the Draft EIR was available for public comment for a period of at least 45 days as required by Section 21091 of CEQA, the close of the public comment period being November 3, 2025; and
WHEREAS, during the public comment period, the City received three letters commenting on the Draft EIR; and
WHEREAS, the City prepared the Final EIR for the Bridgehead Industrial Project, which included written responses to the comments received on the Draft EIR, pursuant to Section 15089 of the CEQA Guidelines; and
WHEREAS, the Final EIR and Draft EIR make up the Bridgehead Industrial Project EIR; and
WHEREAS, the Final EIR was distributed and made available to the public at City Hall and on the City website on January 9, 2026, and consists of a list of commenters, copies of all written comments received, responses to those comments that raise environmental issues, and any revisions to the text of the Draft EIR made in response to the comments, as required by Section 15132 of the CEQA Guidelines; and WHEREAS, the project under consideration would include approval of the following:
 Approval of a General Plan Amendment (GPA 02-23) to redesignate the General Plan land use designation for the 76.4-acre South Development Area from CO to LI;
 Approval of a Rezone (RZ 04-23) to reclassify the zoning district for the North Development Area from BPL District to Planned Unit Development (P-1) District, and reclassify the zoning district for the South Development Area from SP-2 District to P-1 District;
 Approval of a Tentative Map (TM 10-23) to subdivide the three existing parcels, totaling 164 acres, into 10 lots;
368
Resolution No. XX-26 Page 3 of 12
 Approval of Design Review (DR 11-23) for site development and building architecture;
 Approval of a Master Sign Program (MSP 01-23) for sign designs and specifications for the entire site, including all future buildings and entrances; and  Approval of a Development Agreement (DA 2025-01).

WHEREAS, CEQA requires that, in connection with the approval of a project for which an EIR has been prepared which identifies one or more significant environmental effects, the decision-making agency make certain findings regarding those effects; and WHEREAS, the EIR identifies potentially significant environmental impacts and related mitigation measures and a Mitigation Monitoring and Reporting Program has been prepared; and
WHEREAS, the EIR also identifies potentially significant environmental impacts that cannot be avoided by mitigation and for which the City must adopt a Statement of Overriding Considerations pursuant to CEQA; and
WHEREAS, the EIR reflects the City's independent judgment and analysis on the potential for environmental impacts; and
WHEREAS, the Draft EIR and Final EIR are separately bound documents, incorporated herein by reference, and are available for review in the City’s Planning Division; and
WHEREAS, the City has received and considered the project EIR, made up of the Draft EIR and Final EIR, for the Bridgehead Industrial project (SCH No. 2024050471), that analyzed the potential environmental effects of the project; and WHEREAS, on January 20, 2026, the Planning Commission held a duly noticed public hearing to consider the proposed Project for recommendation to the City Council, received the staff report and staff presentation, received comments from the public and interested parties, and deliberated on the Project. At the conclusion of its deliberations, the Planning Commission took a vote and adopted 1) Planning Commission Resolution No. 2-26 recommending the City Council adopt a resolution certifying the Bridgehead Industrial Project Environmental Impact Report (SCH. No. 2024050471), make certain findings concerning mitigation measures, adopt a mitigation monitoring and reporting program, make findings concerning alternatives, and adopt a statement of overriding considerations, and 2) Planning Commission Resolution No. 3-26 recommending City Council approve the project titled, “Bridgehead Industrial Project (GPA 02-23, RZ 04-23, TM 10-23, DR 11-23, MSP 01-23, DA 2025-01),” as conditioned; and WHEREAS, on or before February 26, 2026, the Notice of Public Hearing for the Project was duly noticed in the Contra Costa Times, a newspaper of general distribution, was posted at the Project site, at Oakley City Hall located at 3231 Main Street, outside the gym at Delta Vista Middle School located at 4901 Frank Hengel Way, and outside the 369
Resolution No. XX-26 Page 4 of 12
library at Freedom High School located at 1050 Neroly Road, was posted to the City’s website, and was mailed out to all owners of property within a 500-foot radius of the project’s boundaries, to parties requesting such notice, and to outside agencies; and WHEREAS, on March 10, 2026, the City Council held a duly noticed public hearing on the project at which it received a report from City Staff, oral and written testimony from the public, and deliberated on the project. At the conclusion of its deliberations, the City Council held a vote and adopted this resolution certifying the Project EIR, making certain findings concerning mitigation measures, adopting a Mitigation Monitoring and Reporting Program, making findings concerning alternatives, and adopting a Statement of Overriding Considerations, as conditioned and revised by the City Council during its deliberations; and
WHEREAS, if any term, provision, or portion of these Findings or the application of these Findings to a particular situation is held by a court of competent jurisdiction to be invalid, void or unenforceable, the remaining provisions of these Findings, or their application to other actions related to the project, shall continue in full force and effect unless amended or modified by the City.

SECTION 2. Findings
NOW, THEREFORE, BE IT FURTHER RESOLVED that the City Council makes the following findings under the California Environmental Quality Act (“CEQA”) (California Public Resources Code [“PRC”] Sections 21000-21177) and the CEQA Guidelines (California Code of Regulations [“CCR”], Title 14, Sections 15000-15387) relating to the project. The Findings provide the written analysis and conclusions of this City Council regarding the project’s environmental impacts, mitigation measures, alternatives to the project, and the overriding considerations, which, in this City Council’s view, justify approval of the project, despite its environmental effects.

Changes to Mitigation Measures. As described in the Final EIR (Chapter 3, Revisions to the Draft EIR Text) and in the responses to comments, Mitigation Measures

4.4-1 and 4.7-2(b) have been modified. The revision to Measure 4.4-1 serves to clarify that construction, surveys, and subsequent mitigation would be required if special-status plant species are found. The revision to Mitigation Measure 4.4-1 is for clarification only and does not affect the conclusions of the Draft EIR. The revision to Mitigation Measure

4.7-2(b) clarifies that groundwater testing shall be required if lead or asbestos are detected during soil sampling. The revisions to Mitigation Measure 4.7-2(b) would not affect the analysis or conclusions of the Draft EIR. Therefore, in accordance with CEQA and the CEQA Guidelines, recirculation of the EIR is not necessary based on changes or additions to the mitigation measures in the Final EIR.

Other Changes. Various minor changes and edits have been made to the text and tables of the Draft EIR, as described in the Final EIR. The changes represent minor clarifications and amplifications of the analysis contained in the Draft EIR and do not constitute significant new information that, in accordance with CEQA Guidelines Section 15088.5, would trigger the need to recirculate portions or all of the Draft EIR. The City 370
Resolution No. XX-26 Page 5 of 12
Council finds that these changes are of a minor, non-substantive nature and do not require recirculation of the EIR.
1) That, based on review and analysis of the EIR and other information in the record and the City has considered the information contained therein, including the written and oral comments received at the public hearings on the EIR, prior to acting upon or approving the project, the EIR has been completed in compliance with CEQA; and that the EIR represents the independent judgment of the City; and 2) That the EIR contains discussion of the potential impacts, level of significance of each impact, proposed mitigation for any impact found to be potentially significant, and factual findings relating to potential environmental impacts that could result from implementation of the project. The City Council hereby refers to the EIR as support for findings and recommendations made by the Council as the City’s findings under CEQA (PRC Section 21000 et seq.) and the CEQA Guidelines (CCR, Title 14, Section 15000 et seq.) relating to the project; and
3) That the EIR provides the written analysis and conclusions of the City Council regarding the project’s environmental impacts, mitigation measures, and alternatives to the project, and shall be referenced as findings for all impacts found to have no impact, be less than significant without mitigation incorporated, or be less than significant with mitigation incorporated; and
4) That pursuant to PRC Section 21081 and CEQA Guidelines Sections 15091 et seq., the City Council adopt and make the following statement of overriding considerations regarding the remaining unavoidable impacts of the project and the anticipated economic, social and other benefits of the project.
a) Significant Unavoidable Impacts
With respect to the foregoing findings, and in recognition of those facts which are included in the record, the City has determined the following:
 The project could result in significant and unavoidable impacts related to the conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to non-agricultural use (Chapter 4.2, Agricultural Resources, Impact 4.2-1 of Draft EIR); and
 The project could result in significant and unavoidable impacts related to a conflict with or obstruction of implementation of the applicable air quality plan during project operation (Chapter 4.3, Air Quality and Greenhouse Gases, and Energy, Impact 4.3-2 of Draft EIR); and
 The project could result in cumulatively considerable, significant and unavoidable impacts related to a cumulatively considerable net increase of any criteria pollutant for which the project region is in non-attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors) (Chapter 371
Resolution No. XX-26 Page 6 of 12

4.3, Air Quality and Greenhouse Gases, and Energy, Impact 4.3-6 of Draft EIR).

The above impacts cannot be avoided or substantially reduced by feasible changes or alterations to the project, other than the changes or alterations already adopted. b) Alternatives
Summary of Discussion of Alternatives in the Final EIR
Pursuant to Section 15126.6 of the CEQA Guidelines, the EIR evaluated five potential alternatives to the project. The EIR examined the environmental impacts of each alternative in comparison with the project and the relative ability of each alternative to satisfy project objectives.

Findings Relating to Alternatives
In making these findings, the City Council certifies that it has independently reviewed and considered the information on alternatives provided in the EIR, including the information provided in comments on the Draft EIR and the responses to those comments in the Final EIR. The Draft EIR describes and evaluates in detail five alternatives to the project. A summary of each alternative, its relative characteristics, and documentation of the City Council’s findings in support of rejecting the alternatives as infeasible are presented below.

The City Council finds that the alternatives are unable to satisfy the project objectives to the same degree as the project. The City Council further finds that, on balance, none of the remaining alternatives have environmental advantages over the project that are sufficient to justify approval of such an alternative instead of the project, in light of each such alternative’s inability to satisfy the project objectives to the same degree as the project. Accordingly, based on impacts identified in the EIR, the City Council determines to approve the project instead of approving one of the remaining alternatives.

Description of Project Objectives
The project objectives are as follows:
 To construct and operate light industrial and logistics buildings and potentially data centers to provide for an underserved local demand.  To construct a project that has access to existing infrastructure.  To construct a project that provides short-term construction and long-term employment opportunities to local and regional residents thereby improving the City’s job/housing balance.
 To develop a project that is developed in a visually pleasing manner.  To develop a project that increases contributions to the City’s tax base and diversifies the local economy.
372
Resolution No. XX-26 Page 7 of 12
 To develop a project that attracts high quality customers and tenants to the City thereby diversifying the local economy.

Discussion and Findings Relating to the Alternatives Evaluated in the Draft EIR
Chapter 7, Alternatives Analysis, of the Draft EIR evaluates the following five alternatives, which are summarized below:
1) No Project (No Build) Alternative;
2) No Project (Buildout Pursuant to General Plan) Alternative; 3) Agricultural Resource Preservation Alternative;
4) Mixed-Use Alternative; and
5) Reduced Intensity Alternative.
1) No Project (No Build) Alternative.

The City has decided to evaluate a No Project (No Build) Alternative, which assumes that the current conditions of the project site would remain, and the site would not be developed. As described in the Draft EIR, the site consists of generally flat land cultivated with vineyards in the City of Oakley. Existing on-site buildings associated with the vineyards are located within the North Development Area. An existing 84-inch storm drain line runs north-to-south within the North Development Area and an existing 54-inch storm drain line runs north-south within the South Development Area. An existing 35-foot drainage easement and an overlapping 45-foot temporary construction easement are centered in the middle of the existing pipe within the North Development Area. An existing 15-foot easement for the existing pipe and a 45-foot temporary construction easement are located within the South Development Area. The No Project (No Build) Alternative would not meet any of the project objectives.

The environmental benefits that would be achieved with this Alternative are outweighed by its failure to achieve any of the project objectives, and the City rejects this alternative.
2) No Project (Buildout Pursuant to General Plan) Alternative.

The No Project (Buildout Pursuant to General Plan) Alternative would consist of buildout of the project site according to the current City of Oakley General Plan land use designations. The City of Oakley General Plan designates the North Development Area as LI and the South Development Area as CO. The amount of light industrial area would be reduced under the Alternative by 76.4 acres (164 acres versus 87.6 acres) in comparison to the proposed project, and the Alternative would result in 76.4 acres of commercial uses. Specifically, the North 373
Resolution No. XX-26 Page 8 of 12
Development Area would include a total of 1,639,484 sf of industrial development, and the South Development Area would include a total of 770,000 sf of commercial development, for a total building area of 2,409,484 sf. Development of the South Development Area with commercial uses was previously analyzed in the River Oaks Crossing Specific Plan EIR. Under the Alternative, the South Development Area would be built out pursuant to the land uses included therein, including retail, restaurant, and potentially hotel uses.

Because the No Project (Buildout Pursuant to General Plan) Alternative would include development of the project site with the same uses included in the proposed project for the North Development Area, all project objectives would generally be met. Furthermore, because the Alternative would be developed with a greater variety of uses that could increase contributions to the City’s tax base and diversify the local economy as compared to the proposed project, the Alternative would satisfy Objective #5 to a greater extent than the proposed project. However, Objective #1 would be satisfied to a lesser extent than the proposed project, given that the alternative would result in a reduction in industrial uses as compared to the project.

Overall, the Alternative would result in similar impacts in seven of the nine issue areas as compared to the project, but would result in greater impacts related to air quality, greenhouse gases, and energy. The significant and unavoidable impacts related to agricultural resources and air quality would remain under the Alternative.

Therefore, the Alternative’s ability to meet project objectives would be outweighed by its failure to reduce impacts, and the City rejects this alternative. 3) Agricultural Resource Preservation Alternative.

The Agricultural Resource Preservation Alternative would consist of a similar buildout of the components of the proposed project on a reduced development footprint in order to avoid, to the extent feasible, development of on-site vineyards with non-agricultural uses. Unlike the proposed project, the Agricultural Resource Preservation Alternative would not include buildout of Building 1 and Building 2.

As such, the Agricultural Resource Preservation Alternative would include the development of a total of approximately 99.27 acres of industrial uses, and would include approximately 64.73 acres of preserved vineyards. The total building area would be reduced to approximately 1,911,906 sf.

For environmental review purposes under CEQA, the categories of Prime Farmland, Farmland of Statewide Importance, and Unique Farmland constitute “agricultural land.” Pursuant to the California Department of Conservation Important Farmland Finder, the entire 164-acre project site is designated as Farmland of Statewide Importance. Because the Agricultural Resource Preservation Alternative would include development of the project site with the proposed uses for the majority of the site, all project objectives would be met.

However, because the Agricultural Resource Preservation Alternative would include the development of fewer industrial uses than the proposed project, the 374
Resolution No. XX-26 Page 9 of 12
Alternative would not satisfy Objective #3 to the same extent as the proposed project.

The Draft EIR determined that the Agricultural Resource Preservation Alternative would result in fewer impacts than the proposed project related to seven of the nine issue areas, and would result in similar impacts as the proposed project for the remaining two issue areas for which project impacts were identified. In addition, because the Agricultural Resource Preservation Alternative would not include development in the northwestern portion of the project site, impacts to wetlands would not occur. The significant and unavoidable impacts related to agricultural resources and air quality would remain under the Alternative. Overall, the Alternative was determined to be the environmentally superior alternative.

However, because the Agricultural Resource Preservation Alternative would include the development of fewer industrial uses than the proposed project, the Alternative would not satisfy Objective #3 to the same extent as the proposed project. Therefore, the City rejects this alternative.
4) Mixed-Use Alternative.

The Mixed-Use Alternative would consist of buildout of all both industrial and commercial uses within the same development footprint as the proposed project.

Under the Alternative, the areas designated for development of Buildings 3, 4, 5, 9, and 10 under the proposed project would instead be developed with commercial uses. Development of commercial uses in such areas would avoid development of industrial uses adjacent to the existing single-family residences located to the north and east of the North Development Area and to the south of the South Development Area. The Mixed-Use Alternative would include the development of a total of approximately 39.7 acres of commercial uses and a total of approximately 122.57 acres of industrial uses. Specifically, Buildings 3, 4, 9, and 10 would include a total of 744,613 sf of commercial development, and Buildings 1, 2, 6, 7, and 8 would include a total of 2,373,164 sf of industrial development. Because the MixedUse Alternative would include development of the project site with the same uses included in the proposed project, with the addition of commercial uses, all project objectives would generally be met. Furthermore, because the Alternative would be developed with a greater variety of uses that could increase contributions to the City’s tax base and diversify the local economy as compared to the proposed project, the Alternative would satisfy Objective #5 to a greater extent than the proposed project.

The Draft EIR determined that the Mixed-Use Alternative would result in similar impacts to the project in several resource areas, but would result in greater impacts to air quality, greenhouse gases, and energy. The significant and unavoidable impacts related to agricultural resources and air quality would remain under the Alternative. Therefore, despite the Alternative’s ability to meet project objectives, the City rejects this alternative.
375
Resolution No. XX-26 Page 10 of 12
5) Reduced Intensity Alternative.

The Reduced Intensity Alternative would include development of the project site with industrial uses at a reduced intensity as compared to the proposed project.

The Alternative would reduce the overall development footprint in order to preserve cultivated vineyards along Bridgehead Road, Main Street, and Big Break Road.

Preservation of vineyards along project area roadways would result in less visual impact as compared to the proposed project. Under the Alternative, Buildings 3, 4, and 5 would be eliminated for a total reduction of approximately 443,613 sf of industrial development in the North Development Area. In the South Development Area, Building 7 would be reduced by approximately 75,770 sf, Building 8 would be reduced by approximately 56,750 sf, and Building 10 would be reduced by approximately 61,500 sf. Overall, the Reduced Intensity Alternative would result in a total of approximately 2,480,144 sf of industrial development. Because the Reduced Intensity Alternative would include development of the project site with the same uses included in the proposed project, all project objectives would be generally met. Because the Alternative would include preservation of existing views of vineyards from project area roadways, the Alternative would satisfy Objective #4 to a greater extent than the proposed project. However, because the Reduced Intensity Alternative would include the development of fewer industrial uses than the proposed project, the Alternative would not satisfy Objective #3 to the same extent as the proposed project.

The Draft EIR determined that the Reduced Intensity Alternative would result in fewer impacts than the project in several resource areas. The significant and unavoidable impacts related to agricultural resources and air quality would remain under the Alternative. The environmental benefits that might be achieved with this alternative are outweighed by its failure to satisfy Objective #3 to the same extent as the proposed project. Therefore, the City rejects this alternative.

Findings Regarding Reasonable Range of Alternatives
The City Council finds that the range of alternatives evaluated in the EIR reflects a reasonable attempt to identify and evaluate various types of alternatives that would potentially be capable of reducing the project’s environmental effects, while accomplishing most but not all of the project objectives. The City Council finds that the alternatives analysis is sufficient to inform the City Council and the public regarding the tradeoffs between the degree to which alternatives to the project could reduce environmental impacts and the corresponding degree to which the alternatives would hinder the City’s ability to achieve the project objectives. c) Statement of Overriding Considerations
The City Council specifically adopts and makes this Statement of Overriding Considerations that this project includes all feasible measures that would eliminate or substantially lessen the significant impacts of the project on the environment, and that the remaining significant, unavoidable impacts of the project are 376
Resolution No. XX-26 Page 11 of 12
acceptable in light of the environmental, economic, social and other considerations set forth herein because the benefits of the project outweigh the significant and adverse impacts of the project. The City Council finds that each of the overriding considerations set forth below in part “d) Benefits of Proposed Project”) constitutes a separate and independent ground for finding that the benefits of the project outweigh its significant adverse environmental impacts and sets forth an overriding consideration warranting approval of the project. These matters are supported by evidence in the record.
d) Benefits of Proposed Project
The City Council has considered the EIR, the public record of proceedings on the proposed project and other written materials presented to the City as well as oral and written testimony at all public hearings related to the proposed project, and does hereby determine that implementation of the project would result in the substantial public benefits set forth below.
i) Economic Growth: The project would induce local economic growth by developing 10 light industrial buildings totaling approximately 3,117,777 sf. The project is anticipated to create approximately 3,103 new jobs for the region. ii) Generation of Taxes: Approval of the project would generate long-term sustainable property taxes, franchise taxes, and business license taxes for the City of Oakley by way of industrial development of the project site. iii) Energy Efficiency: The project would be built in compliance with all applicable regulations related to energy consumption and fuel efficiency, which would ensure that the proposed project would be designed to be energy efficient to the maximum extent possible and would result in the new development being more efficient than existing industrial buildings in the region. iv) Provision of Industrial Uses: Approval of the project would provide for the construction and operation of light industrial and logistics buildings with access to existing infrastructure to provide for an underserved local demand. 5) The Mitigation Monitoring and Reporting Program for the Bridgehead Industrial Project is incorporated and adopted as part of this resolution and attached herein as Exhibit A. The Program identifies impacts of the project, corresponding mitigation, designation of responsibility for mitigation implementation and the agency responsible for the monitoring action.
6) The City Council hereby finds and recognizes that the Final EIR contains additions, clarifications, modifications and other information in the responses to comments on the Draft EIR. This Council hereby finds and determines that such changes and additional information are not significant new information as that term is defined under the provisions of CEQA, because such changes and additional information do not indicate that any new significant environmental impacts not already evaluated would result from the project and do not reflect any substantial increase in the severity of any 377
Resolution No. XX-26 Page 12 of 12
environmental impact; that feasible mitigation measures considerably different from those previously analyzed in the Draft EIR have not been proposed that would lessen significant environmental impacts of the project; and that feasible alternatives considerably different from those analyzed in the Draft EIR have not been proposed that would lessen significant environmental impacts of the project. Accordingly, this Council hereby finds and determines that recirculation of the Draft EIR for further public review and comment is not warranted; and
7) The City Council does hereby designate the Community Development Director of the City of Oakley, located at 3231 Main Street, Oakley, California 94561, as the custodian of documents and record of proceedings on which the decision is based; and 8) The City Council does hereby make the foregoing findings with respect to the significant effects on the environment of such project, as identified in the project EIR, with the stipulations that all information in these findings is intended as a summary of the full administrative record supporting the project EIR, which full administrative record should be consulted for the full details supporting these findings, and that any mitigation measures and/or alternatives that were suggested by commenters to the Draft EIR and were not adopted as part of the project EIR are hereby expressly rejected for the reasons stated in the responses to the comments set forth in the Final EIR, and elsewhere in the record.

SECTION 3. Approval
BE IT FURTHER RESOLVED THAT, on the basis of the above Findings, the City Council certifies the Bridgehead Industrial Project Environmental Impact Report.

PASSED AND ADOPTED by the City Council of the City of Oakley this 10 th day
of March 2026 by the following vote:

AYES:

NOES:

ABSTENTION:

ABSENT:

APPROVED:

Hugh Henderson, Mayor
ATTEST:

Kim Snodgrass, City Clerk Date
Exhibit A – Bridgehead Industrial Project Mitigation Monitoring and Reporting Program 378
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

4.1 INTRODUCTION
Section 15097 of the California Environmental Quality Act (CEQA) requires all State and local agencies to establish monitoring or reporting programs for projects approved by a public agency whenever approval involves the adoption of either a “mitigated negative declaration” or specified environmental findings related to environmental impact reports.

The following is the Mitigation Monitoring and Reporting Program (MMRP) for the Bridgehead Industrial Project (proposed project). The intent of the MMRP is to ensure implementation of the mitigation measures identified within the Environmental Impact Report (EIR) for the proposed project. Unless otherwise noted, the cost of implementing the mitigation measures as prescribed by this MMRP shall be funded by the applicant.

4.2 COMPLIANCE CHECKLIST
The MMRP contained herein is intended to satisfy the requirements of CEQA as they relate to the EIR prepared for the proposed project. This MMRP is intended to be used by City staff and mitigation monitoring personnel to ensure compliance with mitigation measures during project implementation. Mitigation measures identified in this MMRP were developed in the EIR.

The EIR presents a detailed set of mitigation measures that will be implemented throughout the lifetime of the project. Mitigation is defined by CEQA Guidelines, Section 15370, as a measure that:
• Avoids the impact altogether by not taking a certain action or parts of an action; • Minimizes impacts by limiting the degree or magnitude of the action and its implementation;
• Rectifies the impact by repairing, rehabilitating, or restoring the impacted environment; • Reduces or eliminates the impact over time by preservation and maintenance operations during the life of the project; or
• Compensates for the impact by replacing or providing substitute resources or environments.

The intent of the MMRP is to ensure the implementation of adopted mitigation measures. The MMRP will provide for monitoring of construction activities as necessary and in-the-field identification and resolution of environmental concerns.

Monitoring and documenting the implementation of mitigation measures will be coordinated by the City of Oakley. The table attached to this report identifies the mitigation measures, the monitoring action for each mitigation measure, the responsible party for the monitoring action, and timing of the monitoring action. The applicant will be responsible for fully understanding and effectively implementing the mitigation measures contained within the MMRP. The City will be responsible for monitoring compliance.

4. MITIGATION MONITORING

AND REPORTING PROGRAM
379
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

4.3 MITIGATION MONITORING AND REPORTING PROGRAM
The following table indicates the mitigation measure number, the impact the measure is designed to address, the measure text, the monitoring agency, implementation schedule, and an area for sign-off indicating compliance.
380
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
Chapter 4.3 – Air Quality, Greenhouse Gas Emissions, and Energy

4.3-2 Conflict with or obstruct
implementation of the
applicable air quality plan
during project operation.

4.3-2 Prior to the approval of building permits, the
project applicant shall implement the following
measures, to the satisfaction of the City of
Oakley Planning Division:

1. All architectural coatings, paints,
finishes and adhesives used within the
project site during project construction
and operations shall be zero-VOC
emitting. Furthermore, all future
leases signed for proposed structures
or operational spaces within the
project site must contain binding
language informing future tenants of
the requirement that only zero-VOC
architectural coatings, paints, finishes
and adhesives may be used within the
project site.

2. The project applicant shall require all
tenants of the on-site industrial uses to
use zero-emission forklifts.

3. The project applicant shall require that
three percent of the medium- and
heavy-duty vehicle fleet be zero
emission by full buildout of the
proposed project. In the event there is
a disruption in the manufacturing of
zero emission vehicles/trucks or that
sufficient vehicles/trucks are not
commercially available for the
intended application, the “clean fleet
requirements” may be adjusted as
minimally as possible by the City’s
City of Oakley
Planning
Division
Prior to the approval
of building permits
381
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
Planning Division to accommodate the
manufacturing disruption or
unavailability of commercially
available vehicles/trucks.

4. Natural gas use on-site shall be
prohibited. Natural gas infrastructure
may be allowed if the applicant
implements alternative methods that
reduce the project’s emissions in an
equally effective or superior manner
as would exist without natural gas
emission infrastructure.

4.3-6 Result in a cumulatively
considerable net
increase of any criteria
pollutant for which the
project region is in nonattainment under an
applicable federal or
state ambient air quality
standard (including
releasing emissions
which exceed
quantitative thresholds
for ozone precursors).

4.3-6 Implement Mitigation Measure 4.3-2. See Mitigation Measure 4.3-2
See Mitigation
Measure 4.3-2

4.3-8 Generate GHG
emissions, either directly
or indirectly, that may
have a significant impact
on the environment, or
conflict with an
applicable plan, policy, or
regulation adopted for

4.3-8(a) Consistent with the BAAQMD’s Buildings
criterion a, prior to issuance of building permits
for the proposed project, the project applicant
shall demonstrate via project design and/or
notation included on project design that natural
gas infrastructure shall be prohibited. Natural
gas infrastructure may be allowed if the
applicant implements alternative methods that
reduce the project’s greenhouse gas
City of Oakley
Planning
Division
Prior to issuance of
building permits
382
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
the purpose of reducing
the emissions of GHGs.
emissions in an equally effective or superior
manner as would exist without natural gas
emission infrastructure, or purchases off-site
mitigation credits or forecasted mitigation units
(“FMUs”) (collectively, “GHG credits”) for
project-related GHG emissions from the
component(s) using natural gas instead of
electric. The emissions from the use of natural
gas shall be calculated by a qualified
professional utilizing BAAQMD-, CARB-, or the
USEPA-approved emissions models and
quantification methods available and submitted
to the City for review and approval, which shall
include third-party review by a qualified
consultant of the City’s selection and be
subject to applicant reimbursement of
consultant costs.

Any and all GHG credits to off-set for the use
of natural gas must be created through a
CARB-approved registry. These registries are
currently the ACR, CAR, and Verra, although
CARB may accredit additional registries in the
future. These registries use robust accounting
protocols for all GHG credits created for their
exchange, including the six currently approved
CARB protocols. This mitigation measure
specifically requires GHG credits created for
the project originate from a CARB-approved
protocol or a protocol that is equal to or more
rigorous than CARB requirements under 17
CCR 95972. The selected protocol must
demonstrate that the GHG-emissions
reductions are real, permanent, quantifiable,
383
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
verifiable, enforceable, and additional.

Definitions of these terms from 17 CCR
95802(a) are provided below.
(1) Real: GHG reductions or
enhancements result from a
demonstrable action or set of actions
and are quantified using appropriate,
accurate, and conservative
methodologies that account for all
GHG emissions sources, GHG sinks,
and GHG reservoirs within the [GHG
credit] project boundary and account
for uncertainty and the potential for
activity-shifting and market-shifting
leakage.
(2) Additional: GHG reductions or
removals that exceed any GHG
reduction, or removals otherwise
required by law, regulation, or legally
binding mandate, and that exceed any
GHG reductions or removals that
would otherwise occur in a
conservative BAU scenario.
(3) Permanent: GHG reductions and
removal enhancements are not
reversible or, when GHG reductions
and GHG-removal enhancements
may be reversible, mechanisms are in
place to replace any reversed GHGemission reductions and GHGremoval enhancements to ensure that all credited reductions endure for at
least 100 years.
384
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
(4) Quantifiable: The ability to accurately
measure and calculate GHG
reductions or GHG-removal
enhancements relative to a project
baseline in a reliable and replicable
manner for all GHG emission sources,
GHG sinks, or GHG reservoirs
included within the [GHG credit]
project boundary, while accounting for
uncertainty. activity-shifting, and
market-shifting leakage.
(5) Verifiable: A [GHG credit] project
report assertion is well-documented
and transparent such that it lends itself
to an objective review by an
accredited verification body.
(6) Enforceable: The authority for CARB
to hold a particular party liable and
take appropriate action if any of the
provisions of this article are violated.

Note that this definition of
enforceability is specific to the Capand-Trade regulation, where CARB holds enforcement authority, but this
measure will employ GHG credits
from the voluntary market, where
CARB has no enforcement authority.

Applying the definition to this
mitigation measure means that GHG
reductions must be owned by a single
entity and backed by a legal
instrument or contract that defines
exclusive ownership.
385
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
Geographic Prioritization of GHG Credits
GHG credits from reduction projects in Contra
Costa County will be prioritized before projects
in larger geographies (i.e., northern California,
California, United States, and international).

The applicant will inform brokers of the
required geographic prioritization for the
procurement of GHG credits. GHG credits from
reduction projects identified in the County that
are of equal or lesser cost compared to the
settlement price of the latest Cap-and-Trade
auction must be included in the transaction.

GHG credits from reduction projects outside of
the County may be purchased if adequate
credits cannot be found in the County or if they
exceed the maximum price identified above.

The economic and geographic analysis
undertaken to inform the selection of GHG
credits must be provided by the applicant to the
County as part of the required documentation
discussed below under Plan Implementation
and Reporting.

Types of GHG Credits
GHG credits may be in the form of GHG offsets
for prior reductions of GHG emissions verified
through protocols or FMUs for future
committed GHG emissions meeting protocols.

Because emissions reductions from GHG
offsets have already occurred, their benefits
are immediate and can be used to compensate
for an equivalent quantity of project-generated
emissions at any time. GHG credits from
FMUs must be funded and implemented within
386
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
5 years of project GHG emissions to qualify as
a GHG credit under this measure (i.e., there
can only be a maximum of 5 years lag between
project emissions and their real-world
reductions through funding a FMU in advance
and implementing the FMU on the ground).

Any use of FMUs that result in a time lag
between project emissions and their reduction
by GHG credits from FMUs must be
compensated through a prorated surcharge of
additional FMUs proportional to the effect of
the delay. Because emissions of CO2 in the
atmosphere reach their peak radiative forcing
within 10 years, a surcharge of 10 percent for
every year of lag between project emissions
and their reduction through a FMU will be
added to the GHG credit requirement (i.e.,

1.10 FMUs would be required to mitigate 1
metric ton of project GHG emissions
generated in the year prior to funding and
implementation of the FMU).

Verification and Independent Review of
GHG Credits
All GHG credits will be verified by an
independent verifier accredited by the ANSI
National Accreditation Board (ANAB) or
CARB, or an expert with equivalent
qualifications to the extent necessary to assist
with the verification. Following the standards
and requirements established by the
accreditation board (i.e., ANAB or CARB), the
verifier will certify the following.
387
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
• GHG credits conform to a CARBapproved protocol or a protocol that is equal to or more rigorous than CARB
requirements under 17 CCR 95972.

Verification of the latter requires
certification that the credits meet or
exceed the standards in 17 CCR
95972.
• GHG credits are real, permanent,
quantifiable, verifiable, enforceable,
and additional, as defined in this
measure.
• GHG credits are purchased according
to the geographic prioritization
standard defined in this measure
under Geographic Prioritization of
GHG Credits.

Verification of GHG offsets must occur as part
of the certification process for compliance with
the accounting protocol. Because FMUs are
GHG credits that will result from future
projects, additional verification must occur
beyond initial certification is required.

Verification for FMUs must include initial
certification and independent verification every
5 years over the duration of the FMU
generating the GHG credits. The verification
will examine both the GHG credit realization on
the ground and its progress toward delivering
future GHG credits. The applicant will retain an
independent verifier meeting the qualifications
described above to certify reductions achieved
388
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
by FMUs are achieved following completion of
the future reduction project.

Conformance with the foregoing requirement
shall be confirmed through review and
approval of building permit plans by the City of
Oakley Planning Division.

4.3-8(b) Consistent with the BAAQMD’s Transportation
criterion c., prior to the approval of project
improvement plans, the applicant shall indicate
that EV capable parking spaces and EV
capable spaces with EVSE shall be installed
throughout the project site consistent with
current CalGreen Tier 2 standards.

Compliance with this measure shall be
ensured by the City of Oakley Planning
Division.

City of Oakley
Planning
Division
Prior to the approval
of project
improvement plans
Chapter 4.4 – Biological Resources

4.4-1 Have a substantial
adverse effect, either
directly or through
habitat modifications, on
special-status plant
species.

Non-East Contra Costa County HCP/NCCP Plants

4.4-1 Prior to the commencement of construction,
surveys and subsequent mitigation, if plants
are found, shall follow the ECCC HCP/NCCP
guidelines for covered plant species, if either
Contra Costa wallflower, Hoover’s cryptantha,
or Antioch Dunes evening-primrose are
identified on-site, the project applicant shall
contact USFWS and CDFW to determine if an
incidental take permit is necessary for potential
project impacts to either species. USFWS and
CDFW shall determine if additional mitigation
is required, or if the requirements of the ECCC
HCP/NCCP would be satisfactory. Written
verification of the USFWS and CDFW
U.S. Fish and
Wildlife
Service
(USFWS)
California
Department of
Fish and
Wildlife
(CDFW)
City of Oakley
Planning
Division
Prior to
commencement of
construction, if
plants are found
If either Contra
Costa wallflower,
Hoover’s
cryptantha, or
Antioch Dunes
evening-primrose,
are identified on-site
389
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
determination shall be provided to the City of
Oakley Planning Division.

4.4-2 Have a substantial
adverse effect, either
directly or through
habitat modifications, on
Crotch’s bumble bee.

East Contra Costa County HCP/NCCP Permit Area
and Non-East Contra Costa County HCP/NCCP
Permit Area

4.4-2 Prior to the commencement of construction, a
qualified entomologist shall conduct a take
avoidance survey for active bumble bee colony
nesting sites in any previously undisturbed
areas, if project construction occurs during the
flying season (March through August).

Surveys shall take place during the flying
season when the species is most likely to be
detected above ground. The surveys shall
occur when temperatures are above 60
degrees Fahrenheit, on sunny days with wind
speeds below eight miles per hour, and at least
two hours after sunrise and three hours before
sunset, as such conditions are the best to
detect bumble bees. Surveyors shall conduct
transect surveys focusing on detection of
foraging bumble bees and underground nests
using visual aids such as binoculars. Survey
results, including negative findings, shall be
submitted for review and approval to the City
of Oakley Planning Division prior to the start of
ground-disturbing activities. If Crotch’s bumble
bees or potential Crotch’s bumble bees are not
detected, further mitigation shall not be
required. If potential Crotch’s bumble bees are
seen, but cannot be identified, the applicant
shall obtain authorization from CDFW to use
non-lethal netting methods to capture bumble
bees to identify the bumble bees to species. If
City of Oakley
Planning
Division
CDFW
Prior to
commencement of
construction, if
project construction
occurs during the
flying season
(March through
August)
390
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
protected bumble bee nests are found, a plan
to protect bumble bee nests and individuals to
ensure no take of Crotch’s bumble bee shall be
developed by a qualified entomologist in
consultation with the CDFW and City of Oakley
Planning Division.

4.4-3 Have a substantial
adverse effect, either
directly or through
habitat modifications, on
California glossy snake
and Northern California
legless lizard.

East Contra Costa County HCP/NCCP Permit Area
and Non-East Contra Costa County HCP/NCCP
Permit Area

4.4-3 Prior to commencement of construction, a
qualified biologist shall conduct coverboard
surveys on the project site for both California
glossy snake and Northern California legless
lizard. Flattened cardboard boxes and pieces
of plywood shall be placed abundantly
throughout the project site one month prior to
the start of project construction. The qualified
biologist shall survey the project site and check
the coverboards regularly to search for the
presence of either species. Coverboards
placed over sandy soil shall be lifted and
carefully hand-raked approximately 15 inches
deep in search of the Northern California
legless lizard. Written verification of survey
results shall be submitted to the City of Oakley
Planning Division.

If neither species is identified on-site, further
mitigation shall not be required and project
construction may proceed, provided all other
applicable permits and authorizations are
obtained. However, if the California glossy
snake or Northern California legless lizard are
identified on the project site, CDFW shall be
City of Oakley
Planning
Division
CDFW
Prior to
commencement of
construction
391
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
contacted for further guidance prior to the start
of project construction. Proof of
correspondence with CDFW and
implementation of CDFW recommendations
shall be submitted to the City of Oakley
Planning Division.

4.4-4 Have a substantial
adverse effect, either
directly or through
habitat modifications, on
western pond turtle.

East Contra Costa County HCP/NCCP Permit Area
and Non-East Contra Costa County HCP/NCCP
Permit Area

4.4-4 A western pond turtle survey shall be
conducted by a qualified biologist, at most, 48
hours prior to construction within the portion of
the North Development Area where
construction activities overlap with wetland
habitats, and within 150 feet of wetlands. The
results of the survey shall be submitted to the
City of Oakley Planning Division. If western
pond turtles or their nests are not found, further
mitigation shall not be necessary.

If a western pond turtle is observed within the
proposed impact area, a qualified biologist
shall relocate the individual to habitat of
equivalent or greater value (e.g., riparian
wetlands or riparian woodlands adjacent to a
perennial creek or intermittent drainage)
outside of the proposed impact area prior to
construction. If a western pond turtle nest is
observed within the proposed impact area, the
nest shall be fenced off and avoided until the
eggs hatch. The exclusion fencing shall be
placed, at a minimum, 25 feet from the nest. A
qualified biologist shall monitor the nest daily
during construction to ensure that hatchlings
City of Oakley
Planning
Division
48 hours prior to
construction within
the portion of the
North Development
Area where
construction
activities overlap
with wetland
habitats, and within
150 feet of wetlands
392
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
do not disperse into the construction area.

Relocation of hatchlings shall occur as
stipulated above, if necessary.

4.4-5 Have a substantial
adverse effect, either
directly or through
habitat modifications, on
Swainson’s hawk.

Non-East Contra Costa County HCP/NCCP Permit
Area

4.4-5(a) Prior to the commencement of construction,
the project applicant shall mitigate for the loss
of suitable Swainson’s hawk foraging habitat
by implementing the following measure:
• One acre of suitable foraging habitat
shall be protected for each acre of
suitable foraging habitat developed
outside of the ECCC HCP/NCCP
Permit Area. Protection shall be
through purchase of mitigation bank
credits or other land-protection
mechanism acceptable to CDFW.

Proof of purchase of mitigation credits as
required per the above mitigation options shall
be provided to the Oakley Planning Division for
review and approval prior to initiation of ground
disturbance for any portion of the project site.

4.4-5(b) The project applicant shall implement the
following avoidance measures for potential
effects on Swainson’s hawk nests during
construction:
• Prior to commencement of
construction during the nesting
season (March 15 through September
15), a qualified biologist shall conduct
City of Oakley
Planning
Division
CDFW
City of Oakley
Planning
Division
CDFW
Prior to
commencement of
construction
During construction
Prior to
commencement of
construction during
the nesting season
(March 15 through
September 15)
393
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
a preconstruction survey, at most, one
month prior to construction to
establish whether occupied
Swainson’s hawk nests occur on or
within 1,000 feet of the area of
proposed construction. The results of
the survey shall be submitted to the
City of Oakley Planning Division. If
occupied nests are not found, then
further mitigation shall not be required.
• If occupied nests are found, project
construction activity shall not occur
within a 1,000-foot buffer zone
distance from the nest unless a lesser
buffer zone is approved by the City in
consultation with CDFW. During the
nesting season, construction activities
shall be avoided within the established
buffer zone to prevent nest
abandonment. Construction
monitoring shall be required to ensure
adherence to the established buffer
zone. If young fledge prior to
September 15, construction activities
can proceed normally without a buffer
zone. If an active nest site is present,
but shielded from view and noise by
other development or other features,
the City may waive this avoidance
measure (establishment of a buffer
zone), if approved by the CDFW.
• All nest trees shall be preserved on
site, if feasible. Nest trees that cannot
be preserved may only be removed
If occupied nests
are found
394
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
outside of the nesting season (i.e.,
nest trees may only be removed
September 16 through March 14), and
subject to the requirements of ECCC
HCP/NCCP Section 6.4.3.

4.4-6 Have a substantial
adverse effect, either
directly or through
habitat modifications, on
white-tailed kite.

East Contra Costa County HCP/NCCP Permit Area

4.4-6(a) Prior to any ground disturbance related to
Covered Activities that occur during the nesting
season for white-tailed kite (March 15 to
August 31), a qualified biologist shall conduct
a preconstruction survey, at most, one month
prior to construction to establish whether whitetailed kite is nesting in trees within or visible from the site. In the event active nests are
found, an initial 300-foot buffer shall be
established around the nest tree. Ground
disturbance related to covered activities within
the buffer shall either be delayed until a
qualified biologist determines nesting is
complete, or until the applicant consults with
the ECCC HCP/NCCP Implementing Entity
and CDFW and implements CDFW-approved
measures to minimize potential disturbance. A
report detailing the methodology and results of
the survey and, if applicable, compliance with
the provisions established herein shall be
submitted for review and approval to the City of
Oakley Planning Division.

Non-East Contra Costa County HCP/NCCP Permit
Area

4.4-6(b) Implement Mitigation Measure 4.4-8.

City of Oakley
Planning
Division
See Mitigation
Measure 4.4-8
Prior to any ground
disturbance related
to Covered
Activities that occur
during the nesting
season for whitetailed kite (March 15
to August 31)
See Mitigation
Measure 4.4-8
395
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off

4.4-7 Have a substantial
adverse effect, either
directly or through
habitat modifications, on
western red bat.

East Contra Costa County HCP/NCCP Permit Area
and Non-East Contra Costa County HCP/NCCP
Permit Area

4.4-7 A bat survey shall be conducted 15 days prior
to the commencement of construction
(including tree removal). All bat surveys shall
be conducted by a biologist with known
experience surveying for bats. Both tree
canopies and understories shall be examined
for evidence of bat roosting. Written verification
of survey results shall be submitted to the City
of Oakley Planning Division. If western red bats
or other special-status bat species are not
found, further mitigation for special-status bats
shall not be required.

If special-status bats are found, a
determination shall be made by the qualified
biologist young are present. If young are found
roosting in any tree, impacts to the tree(s) shall
be avoided until the young have reached
independence of the tree. A non-disturbance
buffer fenced with orange construction fencing
shall also be established around the maternity
site. The size of the buffer zone shall be
determined by a qualified bat biologist at the
time of the surveys. If adults are found roosting
in a tree or building on the project site, but
maternal sites are not found, the following
measures shall be undertaken to avoid
impacting the bats:
• Tree trimming and/or removal shall
only be conducted during seasonal
City of Oakley
Planning
Division
15 days prior to the
commencement of
construction
(including tree
removal)
396
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
periods of bat activity: between
August 31 and October 15, when bats
would be able to fly and feed
independently, and between March 1
and April 15 to avoid hibernating bats,
and prior to the formation of maternity
colonies.
• Any trees that will be removed and
that the biologist has identified as
having potentially suitable bat roost
habitat shall be removed using a twoday phased removal method:
o On day one, in the afternoon,
limbs and branches shall be
removed using chainsaws
only. Limbs with cavities,
crevices, and deep bark
fissures shall be avoided.
o On day two, the rest of the
tree shall be removed under
the direct supervision of the
biologist.

If tree removal must occur outside of the
seasonal activity periods mentioned above
(i.e., between October 16 and February 28/29,
or between April 16 and April 30), then a
qualified biologist with at least two years of
experience surveying for bats shall conduct
preconstruction surveys within 14 days of
starting work. If the qualified biologist finds
evidence of bat presence during the surveys,
then the biologist shall develop a plan for
397
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
removal and exclusion, in conjunction with
CDFW.

4.4-8 Have a substantial
adverse effect, either
directly or through
habitat modifications, on
other nesting birds and
raptors protected under
the MBTA and CFGC,
including loggerhead
shrike.

East Contra Costa County HCP/NCCP Permit Area
and Non-East Contra Costa County HCP/NCCP
Permit Area

4.4-8 A nesting survey shall be conducted by a
qualified biologist within seven days of
commencement of project construction if the
work would commence between February 1st
and August 31st. The nesting survey shall
include an examination of the coast live oak
trees, eucalyptus and pine trees, shrubs, and
ground vegetation on the project site and within
200 feet of the entire project site (i.e., within a
zone of influence of nesting birds). The zone of
influence shall include the areas outside the
project site where birds could be disturbed by
earth-moving vibrations and/or other
construction-related noise. Written verification
of survey results shall be submitted to the City
of Oakley Planning Division. If active nests are
not found, further mitigation for nesting birds
and raptors shall not be required.

If birds are identified nesting within the zone of
influence, a qualified biologist shall establish a
temporary protective nest buffer around the
nest(s). The nest buffer shall be staked with
orange construction fencing. The buffer shall
be of sufficient size to protect the nesting site
from construction-related disturbance and shall
be established by a qualified ornithologist or
biologist with extensive experience working
with nesting birds near and on construction
City of Oakley
Planning
Division
Within seven days
of commencement
of project
construction if the
work would
commence between
February 1st and
August 31st
398
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
sites. Nesting buffers shall be 50 feet from the
nest site or nest tree dripline for passerine birds
and 300 feet for sensitive nesting birds,
including raptor species known from the region
of the project site.

Construction or earth-moving activity shall not
occur within any established nest-protection
buffer prior to September 1, unless determined
by a qualified ornithologist/biologist that the
young have fledged and have attained
sufficient flight skills to avoid project
construction zones, or that the nesting cycle is
otherwise completed. At the end of the nesting
cycle, and fledging from the nest has occurred,
as determined by a qualified biologist,
temporary nesting buffers may be removed,
and construction may commence in
established nesting buffers without further
regard for the nest site.

4.4-10 Have a substantial
adverse effect on State
or federally protected
wetlands (including, but
not limited to, marsh,
vernal pool, coastal, etc.)
through direct removal,
filling, hydrological
interruption, or other
means.

East Contra Costa County HCP/NCCP Permit Area
and Non-East Contra Costa County HCP/NCCP
Permit Area

4.4-10(a)Prior to the commencement of construction in
the North Development Area, the project
proponent shall submit a formal Aquatic
Resources Delineation to the U.S. Army Corp
of Engineers (USACE) for verification
purposes and determination as to whether the
project activities will require a Clean Water Act
(CWA) Section 404 permit. The Aquatic
Resources Delimitation shall be conducted
according to the wetland types and wetland
delineation provisions described in Table 9-5,
U.S. Army
Corp of
Engineers
(USACE)
City of Oakley
Planning
Division
Prior to
commencement of
construction in the
North Development
Area
399
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
Wetland Fee and Acreage Determination
Methods, of the ECCC HCP/NCCP. The
Aquatic Resources Delineation shall also
document the expected impact on the
jurisdictional wetlands and waters that would
result from the project. A copy of the USACE’s
determination shall be submitted to the City of
Oakley Planning Division.

4.4-10(b)If a Clean Water Act (CWA) Section 404 permit
is determined to be necessary, prior to the
issuance of grading permits, the project
applicant shall apply for a Section 404 permit
from the USACE. Waters that would be lost or
disturbed shall be restored, replaced or
rehabilitated on a “no-net-loss” basis. Habitat
restoration, rehabilitation, and/or replacement
shall be at a location and by methods
acceptable to the USACE. In the event that a
Section 404 permit is required, the project
applicant shall also apply for a Section 401
water quality certification from the Regional
Water Quality Control Board (RWQCB) prior to
the issuance of grading permits and adhere to
the certification conditions therein.

USACE
Regional
Water Quality
Control Board
(RWQCB)
Prior to issuance of
grading permits

4.4-12 Conflict with any local
policies or ordinances
protecting biological
resources, such as the
City of Oakley’s Heritage
and Protected Tree
standards.

East Contra Costa County HCP/NCCP Permit Area
and Non-East Contra Costa County HCP/NCCP
Permit Area

4.4-12 Prior to project-related tree removal, the
project applicant shall be required to comply
with the standards included in Section

9.1.1112 of the City’s Municipal Code by
implementing one of the options provided in
Section 9.1.1112(g)(11)(a), to the satisfaction
Director of the
Community
Development
Department or
the Planning
Commission
Prior to projectrelated tree removal
400
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
of the Director of the Community Development
Department or the Planning Commission, as
applicable.

Chapter 4.5 – Cultural and Tribal Resources

4.5-2 Cause a substantial
adverse change in the
significance of a unique
archeological resource
pursuant to CEQA
Guidelines, Section
15064.5 or disturb
human remains,
including those interred
outside of dedicated
cemeteries.

4.5-2(a) Prior to initiation of ground-disturbing activities, a qualified archaeologist shall conduct a short
awareness training session for all construction
workers and supervisory personnel. The
course shall explain the importance of, and
legal basis for, the protection of significant
archaeological resources. Each worker shall
also learn the proper procedures to follow in
the event cultural resources or human
remains/burials are uncovered during
construction activities, including work
curtailment or redirection and to immediately
contact their supervisor and the archaeological
monitor. The worker education session shall
include visuals of artifacts (precontact and
historic) that might be found in the project
vicinity and take place on the construction site
immediately prior to the start of construction.

Documentation of the training (i.e., a sign-in
sheet) shall be retained at the site and shall be
submitted with applicable reports to the City of
Oakley Planning Division.

4.5-2(b) During project construction, a qualified Native American monitor shall be allowed to observe
earth-moving activities. If archaeological
resources are discovered during project
construction, then all work shall halt within a
100-foot radius of the discovery. A qualified
archaeologist, meeting the Secretary of the
City of Oakley
Planning
Division
City of Oakley
Planning
Division
Prior to initiation of
ground-disturbing
activities
During project
construction
401
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
Interior’s Professional Qualification Standards
for precontact and historic archaeologists, shall
be called to evaluate the significance of the
find. Work shall not continue at the discovery
site until the archaeologist conducts sufficient
research and data collection to make a
determination that the resource is either 1) not
cultural in origin; or 2) not potentially significant
or eligible for listing on the National Register of
Historic Places (NRHP)/California Register of
Historical Resources (CRHR). If a potentially
eligible resource is encountered, then the
archaeologist and the City of Oakley Planning
Division shall arrange for either 1) total
avoidance of the resource, if possible; 2) test
excavations or total data recovery; or 3) other
alternative forms of mitigation. The
determination shall be formally documented in
writing and submitted to the City of Oakley
Division as verification that the provisions in
CEQA for managing unanticipated discoveries
have been met.

4.5-2(c) In the event of the accidental discovery or
recognition of any human remains, further
excavation or disturbance of the find or any
nearby area reasonably suspected to overlie
adjacent human remains shall not occur until
compliance with the provisions of CEQA
Guidelines Section 15064.5(e)(1) and (2) has
occurred. The Guidelines specify that in the
event of the discovery of human remains other
than in a dedicated cemetery, further
excavation at the site or any nearby area
Native
American
Heritage
Commission
(NAHC)
City of Oakley
Planning
Division
In the event of the
accidental discovery
or recognition of any
human remains
402
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
suspected to contain human remains shall not
occur until the county coroner has been
notified to determine if an investigation into the
cause of death is required. In the case of the
proposed project, if the Contra Costa County
Coroner determines that the remains are
Native American, then, within 24 hours, the
Coroner must notify the Native American
Heritage Commission (NAHC), which in turn
will notify the most likely descendants who may
recommend treatment of the remains and any
grave goods. The potential exists that the
NAHC may be unable to identify a most likely
descendant, the most likely descendant fails to
make a recommendation within 48 hours after
notification by the NAHC, or the landowner or
his/her authorized agent rejects the
recommendation by the most likely descendant
and mediation by the NAHC fails to provide a
measure acceptable to the landowner. In such
case, the landowner or an authorized
representative shall rebury the human remains
and grave goods with appropriate dignity at a
location on the property not subject to further
disturbances. Should human remains be
encountered, a copy of the resulting County
Coroner report noting any written consultation
with the NAHC shall be submitted for review
and approval to the City of Oakley Planning
Division.

Contra Costa
County
Coroner

4.5-3 Cause a substantial
adverse change in the
significance of a tribal
cultural resource, as

4.5-3 Implement Mitigation Measures 4.5-2(a)
through 4.5-2(c).

See Mitigation
Measures 4.5-
2(a) through

4.5-2(c)
See Mitigation
Measures 4.5-2(a)
through 4.5-2(c)
403
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
defined in PRC Section
21074.

Chapter 4.6 – Geology and Soils

4.6-3 Be located on a
geological unit or soil
that is unstable, or that
would become unstable
as a result of the project,
and potentially result in
on or off-site landslide,
lateral spreading,
subsidence, liquefaction,
or collapse, or be located
on expansive soil, as
defined in Table 18-1B of
the Uniform Building
Code.

4.6-3 Prior to issuance of a grading permit, the
applicant/developer shall incorporate the
recommendations of a design-level
geotechnical report into the Improvement
Plans for approval by the City Engineer. The
recommendations shall include, but are not
limited to, the options available to reduce
impacts related to lateral spreading,
liquefaction, and subsidence/settlement. Once
final grading plans are designed, the project’s
geotechnical engineers shall determine the
appropriate methods of mitigating the effects of
lateral spreading, liquefaction, and
subsidence/settlement, such as:
• Remove and replace potentially
liquefiable soils and/or expansive and
corrosive soils;
• Strengthen foundations (e.g., posttensioned slab, reinforced mat or grid foundation, or other similar system) to
resist excessive differential settlement
associated with seismically-induced
liquefaction;
• Support the proposed structures on an
engineered fill pad (minimum of 5 feet
thick) in order to reduce differential
settlement resulting from seismicallyinduced liquefaction and post-seismic pore pressure dissipation; and/or
City Engineer
Director of
Public Works
Chief Building
Official
Qualified
Geotechnical
Engineer
Prior to issuance of
a grading permit
404
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
• Densify potentially liquefiable soils
with an in-situ ground improvement
technique such as deep dynamic
compaction, vibro-compaction, vibroreplacement, compaction grouting, or other similar methods.

All grading and foundation plans for the
development shall be designed by a Civil and
Structural Engineer and reviewed and
approved by the Director of Public Works/City
Engineer, Chief Building Official, and a
qualified Geotechnical Engineer prior to
issuance of grading and building permits to
ensure that all geotechnical recommendations
specified in the geotechnical report are
properly incorporated and utilized in the project
design.

4.6-4 Directly or indirectly
destroy a unique
paleontological resource
or site or unique geologic
feature.

4.6-4 Should construction or grading activities result
in the discovery of unique paleontological
resources, all work within 100 feet of the
discovery shall cease. The City of Oakley
Community Development Department shall be
notified, and the resources shall be examined
by a qualified archaeologist, paleontologist, or
historian, at the developer’s expense, for the
purpose of recording, protecting, or curating
the discovery as appropriate. The
archaeologist, paleontologist, or historian shall
submit to the City of Oakley Community
Development Department for review and
approval a report of the findings and method of
curation or protection of the resources. Work
may only resume in the area of discovery when
City of Oakley
Community
Development
Department
Should construction
or grading activities
result in the
discovery of unique
paleontological
resources
405
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
the preceding requirements have been
implemented. The language of this mitigation
measure shall be included on any future
grading plans, utility plans, and/or
improvement plans approved by the City of
Oakley.

Chapter 4.7 – Hazards and Hazardous Materials

4.7-1 Create a significant
hazard to the public or
the environment through
the routine transport,
use, or disposal of
hazardous materials.

4.7-1 Prior to issuance of Certificate of Occupancy,
future building tenant(s) shall disclose any use
or disposal of hazardous materials that would
occur as part of project operations to the City
of Oakley Planning Division and the Contra
Costa County Fire Protection District
(CCCFPD). In the event that project operations
would include such actions, the future building
tenant(s) shall notify the Contra Costa Health
Services Hazardous Materials Program
(CCHSHMP) of the hazardous materials that
would be handled during operations and file a
Hazardous Materials Management Plan
(HMMP) and Hazardous Materials Inventory
Statement (HMIS) to CCHSHMP. The HMMP
and HMIS shall consist of general business
information, basic information on the location,
type, quantity, and health risks of hazardous
materials, and emergency response and
training plans. Any and all requirements
enforced by CCHSHMP shall be adhered to
with a report documenting proof of compliance
submitted to the City of Oakley Planning
Division and CCHSHMP.

City of Oakley
Planning
Division
Contra Costa
County Fire
Protection
District
(CCCFPD)
Contra Costa
Health
Services
Hazardous
Materials
Program
(CCHSHMP)
Prior to issuance of
a Certificate of
Occupancy

4.7-2 Create a significant
hazard to the public or
the environment through

4.7-2(a) Prior to issuance of building permits, a qualified Environmental Engineer firm shall review the
building plans to determine the vapor intrusion
City Engineer Prior to issuance of
building permits
406
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
reasonably foreseeable
upset and accident
conditions involving the
likely release of
hazardous materials into
the environment.
risk factor. If potential health risks are identified
in exceedance of the applicable environmental
screening levels (ESLs) established by the
Regional Water Quality Control Board
(RWQCB), building plans shall be revised to
incorporate a vapor intrusion mitigation system
(VIMS). The VIMS shall be required to
demonstrate that potential health risks related
to vapor intrusion are adequately reduced to
below the applicable ESLs. For example,
measures required to reduce the potential for
vapor intrusion may include a vapor barrier to
block vapors, passive or active subsurface
system to capture and divert potential vapors,
and/or other equivalent measures. The VIMS
shall be submitted to the City Engineer for
review and approval.

4.7-2(b) Prior to approval of grading permits, a surficial soil sample laboratory analysis shall be
conducted in the vicinity of the existing
buildings within the project site by a qualified
Environmental Engineer in accordance with
the California Department of Toxic Substances
Control (DTSC) Interim Guidance for Sampling
Agricultural Properties dated August 7, 2008.

Once the soils are collected, the soils shall be
tested for lead and asbestos. If encountered
during soil sampling, the groundwater shall
also be tested. If soil or groundwater
contaminates are not found, further action is
not required; however, if lead or asbestos is
found to be higher than the allowable
thresholds, the assessment shall include the
City of Oakley
Planning
Division
Prior to approval of
grading permits
407
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
appropriate mitigation including, but not limited
to, soil remediation to an acceptable total
threshold limit concentration (TTLC) level per
applicable State and federal regulations by
excavation of the contaminated soil, and
subsequent transportation and disposal off-site
at an appropriate Class I or Class II facility
permitted by DTSC; or by properly capping the
contaminated soil, in compliance with DTSC
regulations (e.g., placing soils underneath
project roadways, etc.). Materials containing
more than one (1) percent asbestos that is
friable are also subject to Bay Area Air Quality
Management District (BAAQMD) regulations.

Removal of materials containing more than
one (1) percent friable asbestos shall be
completed in accordance with BAAQMD
Section 11-2-303. All recommended mitigation
measures shall be implemented by the project
applicant, subject to review and approval by
the City of Oakley Planning Division.

Chapter 4.8 – Hydrology and Water Quality

4.8-1 Violate any water quality
standards or waste
discharge requirements
or otherwise substantially
degrade surface or
ground water quality
during construction.

4.8-1 Prior to issuance of any grading permits, the
contractor shall prepare a Storm Water
Pollution Prevention Plan (SWPPP) for review
and approval by the Central Valley RWQCB.

The contractor shall file the Notice of Intent
(NOI) and associated fee to the SWRCB. The
SWPPP shall serve as the framework for
identification, assignment, and implementation
of BMPs. The contractor shall implement
BMPs to reduce pollutants in stormwater
discharges to the maximum extent practicable.

Construction (temporary) BMPs for the project
Central Valley
RWQCB
City of Oakley
Public Works
Director/City
Engineer
Prior to issuance of
any grading permits
408
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
may include, but are not limited to: fiber rolls,
straw bale barrier, straw wattles, storm drain
inlet protection, velocity dissipation devices, silt
fences, wind erosion control, stabilized
construction entrance, hydroseeding,
revegetation techniques, and dust control
measures. The SWPPP shall also be
submitted to the City of Oakley Public Works
Director/City Engineer for review and approval
and shall remain on the project site during all
phases of construction. Following
implementation of the SWPPP, the contractor
shall subsequently demonstrate the SWPPP’s
effectiveness and provide for necessary and
appropriate revisions, modifications, and
improvements to reduce pollutants in
stormwater discharges to the maximum extent
practicable.

4.8-2 Violate any water quality
standards or waste
discharge requirements
or otherwise substantially
degrade surface or
ground water quality
during operation.

4.8-2 As part of the Improvement Plan submittal
process, the preliminary Stormwater Control
Plan provided during environmental review
shall be submitted in final format for the review
and approval of the City of Oakley Public
Works Director/City Engineer. The final
Stormwater Control Plan will be reviewed in
concert with the Improvement Plans to confirm
conformity between the two. The report shall
be prepared by a Registered Civil Engineer
and shall, at a minimum, include: A written text
addressing existing conditions, the effects of
the proposed improvements, all appropriate
calculations, watershed maps, changes in
flows and patterns, and proposed on- and offsite improvements to accommodate flows from City of Oakley
Public Works
Director/City
Engineer
During the
Improvement Plan
submittal process
409
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
this project. The report shall identify water
quality protection features and methods to be
used during construction, as well as long-term
post-construction water quality measures. The
final Stormwater Control Plan shall be
prepared in conformance with the
requirements of the C.3 Guidebook that are in
effect at the time of Improvement Plan
submittal.

4.8-4 Substantially alter the
existing drainage pattern
of the site or area,
including through the
alteration of the course
of a stream or river or
through the addition of
impervious surfaces, in a
manner which would:
substantially increase the
rate or amount of surface
runoff in a manner which
would result in
substantial erosion or
siltation on- or off-site;
substantially increase the
rate or amount of surface
runoff in a manner which
would result in flooding
on- or off-site; or create
or contribute runoff water
which would exceed the
capacity of existing or
planned stormwater
drainage systems or

4.8-4 Prior to approval of final project improvement
plans, a final drainage plan shall be submitted
to the City of Oakley Public Works Director/City
Engineer for review and approval
demonstrating the project’s compliance with all
State stormwater standards and requirements.

The final drainage plan shall identify the water
quality treatment and source control measures
needed to ensure that stormwater runoff from
the proposed project is adequately treated and
peak flows do not exceed the capacity of the
receiving storm drainage system.

City of Oakley
Public Works
Director/City
Engineer
City of Oakley
Engineering
Department
Prior to approval of
final project
improvement plans
410
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
provide substantial
additional sources of
polluted runoff.

4.8-5 Substantially alter the
existing drainage pattern
of the site or area in such
a manner as to impede
or redirect flood flows, or
in flood hazard, tsunami,
or seiche zone, risk
release of pollutants due
to project inundation.

4.8-5 Prior to grading activities, the Improvement
Plans shall show that the building pads of
Building 2 and Building 3 are raised above the
100-year base flood elevation. A Hydrology
Study shall be submitted for the review and
approval of the City of Oakley Public Works
Director/City Engineer. The Hydrology Study
shall be reviewed in concert with the
Improvement Plans to determine if the fill
required as part of the proposed project would
result in a base flood elevation increase of
greater than one foot at surrounding
properties.

Should the Hydrology Study determine that a
base flood elevation increase of greater than
one foot would occur at surrounding properties,
as part of the Improvement Plan submittal
process, the project applicant shall obtain a
Conditional Letter of Map Revision Based on
Fill from FEMA for the placement of Building 2
and Building 3 within the FEMA-identified
Flood Hazard Zone AE within the North
Development Area. A copy of the Conditional
Letter of Map Revision Based on Fill from
FEMA shall be submitted to the Public Works
and Engineering Department prior to issuance
of certificates of occupancy for Building 2 and
Building 3.

City of Oakley
Public Works
Director/City
Engineer
Prior to approval of
Improvement Plans
411
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
Chapter 4.10 - Noise

4.10-2 Generation of a
substantial permanent
increase in ambient
noise levels in the vicinity
of the project in excess
of standards established
in the local general plan
or noise ordinance, or
applicable standards of
other agencies.

4.10-2(a)Prior to approval by the City Engineer of the
final Improvement Plans for the proposed
project, the Improvement Plans shall include
the following requirements:
• Eight-foot-tall sound walls shall be
constructed along portions of the
northern boundary of the North
Development Area, in the location
indicated in Figure 4.10-5 and the
Environmental Noise Assessment.
• The noise barrier wall shall be
constructed of concrete panels,
concrete masonry units, earthen
berms, or any combination of these
materials or equivalent materials, as
approved by the City engineer, that
achieve the required total height and
acoustical attenuation. Wood shall not
be used due to eventual warping and
degradation of acoustical
performance. The barrier height shall
be relative to the commercial building
pads or the nearby residences,
whichever is greater.

4.10-2(b)Prior to approval by the City Engineer of the
final Improvement Plans for the proposed
project, the Improvement Plans shall indicate
that development of the proposed project
includes installation of quiet pavement at the
following roadway segments, as indicated in
Figure 4.10-6 and the Environmental Noise
City Engineer
City Engineer
Prior to approval by
the City Engineer of
final Improvement
Plans
Prior to approval of
Improvement Plans
412
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
Assessment prepared for the proposed project
by Saxelby Acoustics:

1. Main Street from Bridgehead Road to
Sandy Lane; and

2. Big Break Road, north of the at-grade
railroad crossing.

The pavement would be required for any
portion of the roadway passing a noisesensitive use, and for a distance of 100 feet on either side of the sensitive-use.

4.10-4 Generation of a
substantial permanent
increase in ambient
noise levels associated
with development of the
proposed project in
combination with future
development.

4.10-4 Implement Mitigation Measures 4.10-2(a) and

4.10-2(b).

See Mitigation
Measures

4.10-2(a) and

4.10-2(b)
See Mitigation
Measures 4.10-2(a)
and 4.10-2(b)
Chapter 4.12 – Transportation

4.12-1 Conflict with a program,
plan, ordinance, or policy
addressing the
circulation system during
construction activities.

4.12-1 Prior to the issuance of grading and building
permits, the project applicant shall prepare a
Construction Traffic Management Plan for
review and approval by the City Engineer. The
requirements within the construction
management plan shall include, but are not
necessarily limited to, the following elements:
• A project staging plan to maximize onsite storage of materials and equipment;
• A set of comprehensive traffic control
measures, including scheduling of
City Engineer Prior to issuance of
grading and building
permits
413
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
major truck trips and deliveries to
avoid peak hours; lane closure
proceedings; signs, cones and other
warning devices for drivers; and
designation of construction access
routes;
• Provisions for maintaining adequate
emergency access to the project site;
• Permitted construction hours, per City
of Oakley standards;
• Designated locations for construction
staging areas;
• Identification of parking areas for
construction employees, site visitors,
and inspectors, including on-site
locations;
• Signs posted at the entrances to the
construction sites noting who to
contact if there are questions or
concerns, along with a contact phone
number; and
• Provisions for street sweeping to
remove construction-related debris on
public streets.

4.12-2 Conflict with a program,
plan, ordinance, or policy
addressing the
circulation system,
including transit,
roadway, bicycle, and
pedestrian facilities.

4.12-2 Prior to Improvement Plan approval, the
Improvement Plans for the proposed project
shall indicate that development of the
proposed project includes:
• In accordance with the 2022 California
Green Building Code:
o Short-term bicycle parking
(bicycle racks) for at least five
percent of the number of
City Engineer Prior to approval of
Improvement Plans
414
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
vehicle parking spaces shall
be provided onsite; and
o Long-term bicycle parking
(bicycle lockers) for at least
five percent of the tenant
employees working onsite
shall be provide onsite.
• Consistent with Figure 3-8 Bikeway
Network Plan of the City of Oakley
General Plan:
o A Class I bicycle path shall be
installed along the project’s
Big Break Road frontage;
• Crosswalks and actuated pedestrian
signals shall be installed at the
intersection of Live Oak Avenue and
Main Street on all four approaches;
• Crosswalks shall be installed at the
intersection of Big Break Road and
Vintage Parkway on all four
approaches;
• The proposed sidewalk on Main Street
shall be extended from the eastern
edge of the project site to the
intersection of Main Street and Big
Break Road; and
• Sidewalks shall be provided along all
primary internal roadways.
o A Class II bicycle lane shall be
along the project’s
Bridgehead Road frontage,
consistent with Figure 3-8
Bikeway Network Plan of the
415
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
City of Oakley’s General Plan;
and
o Class IV separated bikeway
along the project’s Main
Street frontage.

Inclusion of the foregoing requirements on the
Improvement Plans for the proposed project
shall be subject to review and approval by the
City Engineer.

4.12-4 Substantially increase
hazards to vehicle safety
due to a geometric
design feature (e.g.,
sharp curves or
dangerous intersections)
or incompatible uses
(e.g., farm equipment).

4.12-4(a)Prior to Improvement Plan approval, the
Improvement Plan for the proposed project
shall be reviewed by the City Engineer to
ensure that adequate sight distance is
maintained at all project driveways. Objects
greater than three feet in height (i.e.,
landscaping, monument signs, etc.) shall not
be allowed within the sight distance triangles at
project driveway intersections. Particular
attention should be given to the northern
project driveway on Bridgehead Road.

4.12-4(b)Prior to Improvement Plan approval, the
Improvement Plans for the proposed project
shall indicate that development of the
proposed project includes:
• The proposed westernmost driveway
on Main Street shall be relocated to the
east. The driveway shall have a
minimum separation of 250 feet from
the existing Dutch Bros. Coffee
driveway to provide for adequate and
safe operations without conflicts;
City Engineer
City Engineer
Prior to approval of
Improvement Plans
Prior to approval of
Improvement Plans
416
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
• The proposed internal “horseshoe
shaped” intersection located north of
the intersection of Main Street and
Live Oak Avenue shall be redesigned
to include a 90-degree intersection of
internal streets with the maximum
amount of throat depth possible. The
intersection shall have a minimum
throat depth of 200 feet;
• The two proposed eastern driveways
on Main Street shall be relocated to
align with existing streets on the south
side of the roadway to eliminate
turning conflicts and clarify right of
way; and
• R5-2 “No Trucks” signs shall be
installed on internal roadways at the
locations illustrated on Figure 4.12-4.

Installation of the signs shall be
required to prevent trucks from exiting
the project site by way of Big Break
Road during project operation, where
heavy trucks are prohibited.

Inclusion of the foregoing requirements on the
Improvement Plans for the proposed project
shall be subject to review and approval by the
City of Oakley City Engineer.
417
Reso. No. XX-26 Page 1 of 5 January 20, 2026
RESOLUTION NO. XX-26

RESOLUTION OF THE CITY COUNCIL OF THE CITY OF OAKLEY MAKING

FINDINGS AND APPROVING A GENERAL PLAN AMENDMENT TO AMEND THE

LAND USE DESIGNATION FROM COMMERCIAL (CO) TO LIGHT INDUSTRIAL (LI) FOR A PORTION OF THE PROJECT KNOWN AS “BRIDGEHEAD INDUSTRIAL PROJECT (GPA 02-23)” (APN 037-020-007)
WHEREAS, on December 13, 2023, Oxfoot Oakley LLC ("Applicant") filed an application requesting approval of:
1) a General Plan Amendment (GPA 02-23) to redesignate the General Plan Land Use Designation of the southern portion (approximately 76.4-acres) of the approximately 164-acre site from Commercial (CO) to Light Industrial (LI); 2) a Rezone (RZ 04-23) to re-classify the Zoning District for the entire project from BPL (Business Park Low) District (northern portion) and SP-2 (River Oaks Crossing Specific Plan) District (southern portion) to P-1 (Planned Unit Development) District in conjunction with a Preliminary Development Plan;
3) a Tentative Map (TM 10-23) to subdivide the three existing parcels totaling approximately 164 acres into 10 lots;
4) a Design Review (DR 11-23), including site design and building architecture for 10 buildings totaling approximately 3.12 million square feet; 5) a Master Sign Program (MSP 01-23) for sign designs and specifications for the entire site, including all future buildings and entrances; and 6) a Development Agreement (DA 2025-01) ("Project").

The northern and southern portions are bisected by the BNSF railroad tracks and are referred to as the North Development Area and the South Development Area. The North Development Area is zoned BPL (Business Park Low) District and is bordered by the Oakley Logistics Center to the west, Big Break Road to the east, open space to the north, and the BNSF railroad tracks to the south (APN 037-020-007). The South Development Area is zoned SP-2 (River Oaks Crossing Specific Plan) District and is bordered by Bridgehead Road to the west, the BNSF railroad tracks to the east and north, and Main Street to the south (APNS 037-040-007 and 037-040-015); and WHEREAS, on March 26, 2025, the project application was deemed complete per Government Code section 65920 et. seq; and
WHEREAS, at the time of the application submittal for the Project, the project site was designated Light Industrial (LI) (North Development Area) and Commercial (CO) (South Development Area) on the Oakley General Plan Land Use Map, and zoned BPL 418
Reso. No. XX-26 Page 2 of 5 March 10, 2026
(Business Park Low) District (North Development Area) and SP-2 (River Oaks Crossing Specific Plan) District (South Development Area); and
WHEREAS, on January 20, 2026, the Planning Commission held a duly noticed public hearing to consider the proposed Project for recommendation to the City Council, received the staff report and staff presentation, received comments from the public and interested parties, and deliberated on the Project. At the conclusion of its deliberations, the Planning Commission took a vote and adopted 1) Planning Commission Resolution No. 2-26 recommending the City Council adopt a resolution certifying the Bridgehead Industrial Project Environmental Impact Report (SCH. No. 2024050471), make certain findings concerning mitigation measures, adopt a mitigation monitoring and reporting program, make findings concerning alternatives, and adopt a statement of overriding considerations, and 2) Planning Commission Resolution No. 3-26 recommending City Council approve the project titled, “Bridgehead Industrial Project (GPA 02-23, RZ 04-23, TM 10-23, DR 11-23, MSP 01-23, DA 2025-01),” as conditioned; and WHEREAS, on or before February 26, 2026, the Notice of Public Hearing for the Project was duly noticed in the Contra Costa Times, a newspaper of general distribution, was posted at the Project site, at Oakley City Hall located at 3231 Main Street, outside the gym at Delta Vista Middle School located at 4901 Frank Hengel Way, and outside the library at Freedom High School located at 1050 Neroly Road, was posted to the City’s website, and was mailed out to all owners of property within a 500-foot radius of the project’s boundaries, to parties requesting such notice, and to outside agencies; and WHEREAS, on March 10, 2026, the City Council opened the public hearing at which it received a report from City Staff, oral and written testimony from the public, and deliberated on the project. At the conclusion of its deliberations, the City Council took a vote and adopted this resolution to approve the project, as revised by the City Council during its deliberations; and
WHEREAS, on March 10, 2026, the City Council took the following additional actions related to the Project:
 Adoption of City Council Resolution No. XX-26, certifying the Bridgehead Industrial Project Environmental Impact Report (SCH No. 2024050471);  Waiving the first reading and introducing of an ordinance to approve the Project’s Rezone application (RZ 04-23);
 Waiving the first reading and introducing an ordinance to approve the Project’s Development Agreement application (DA 2025-01); and  Adoption of City Council Resolution No. XX-26 approving the Project’s proposed Tentative Map (TM 10-23), Design Review (DR 11-23), and Master Sign Program (MSP 01-23); and
WHEREAS, these Findings are based upon the City’s General Plan, the City’s Zoning Ordinance, the City’s Commercial and Industrial Design Guidelines, and the 419
Reso. No. XX-26 Page 3 of 5 March 10, 2026
information submitted to the City Council at its March 10, 2026 meeting, both written and oral, including oral information provided by the applicant, as reflected in the minutes of such meetings, together with the documents contained in the file for the project (hereinafter the “Record”); and
WHEREAS, if any term, provision, or portion of these Findings or the application of these Findings to a particular situation is held by a court of competent jurisdiction to be invalid, void or unenforceable, the remaining provisions of these Findings, or their application to other actions related to the Project, shall continue in full force and effect unless amended or modified by the City.

NOW, THEREFORE, BE IT RESOLVED THAT, on the basis of the above findings of fact and the entire Record, the City Council makes the following additional findings in support of the Project approval for the General Plan Amendment (GPA 02-23) as shown in Exhibit “A” of this resolution:

A. Regarding the application requesting approval of a General Plan Amendment (GPA 02-23) to redesignate the General Plan Land Use Designation of the southern portion (approximately 76.4-acres) of the approximately 164-acre site from Commercial (CO) to Light Industrial (LI), the City Council finds that:

1. Redesignation of the South Development Area from CO to LI would not result in any internal inconsistencies within the General Plan, in that the LI designation is an existing designation in the General Plan and it exists on the North Development Area and on the Oakley Logistics Center project located north and west of the Project site; and

2. The General Plan Amendment would align with applicable existing goals, policies and implementation programs in the General Plan:
a. The South Development Area lies within an area identified in the General Plan as the “Northwest Oakley Special Planning Area”, which the General Plan envisions as the primary employment center within Oakley; and
b. The General Plan indicates that the Light Industrial designation is intended to accommodate a wide variety of light manufacturing and warehousing and distribution uses, providing the City with the flexibility to accommodate a broader array of employment uses than the Business Park designation;
c. The Amendment would align with General Plan Policy 2.1.6:

Promote the placement of the most intensive non-residential development (Commercial, Business Park, and Light Industrial) in 420
Reso. No. XX-26 Page 4 of 5 March 10, 2026
the Northwest Oakley Planning Area, in that the amendment would allow for the proposed project to exist on the South Development Area which is located in the Northwest Oakley Special Planning Area.
d. The Amendment would align with General Plan Policy 2.4.1:

Encourage the development and intensification of employment centers, including high quality, professional office campuses, business parks, and industrial parks, along with related mixed-use development and open spaces. The centers shall be located in areas fully served by public facilities and services, located along major arterials with easy freeway access and with access from public transit, and accessible to bicyclists and pedestrians, in that the amendment would allow the South Development Area to be
developed with the project. The South Development Area is located on Main Street, a major arterial within the City, and it is located near easy freeway access.
e. The Amendment would align with General Plan Policy 2.4.2: Ensure there is adequate land available to accommodate desired industrial development. This includes light industrial and utility energy uses in appropriate locations, and excludes heavy industrial uses, in that the amendment would increase the availability of developable light industrial land with access to utilities with the vision to be developed with desirable, job producing light industrial uses.

3. The Amendment would allow for the entirety of the project to come to fruition, which would provide for additional light industrial land in an area envisioned by the Oakley General Plan for such land use, mainly due to its proximity to other similar uses, access the Main Street, and proximity to State Route 160.

4. The Amendment would place an existing Land Use Designation on the property thereby maintaining internal consistency within the General Plan.

It would not inherently create detrimental conditions for the community’s public health, safety, and welfare in that the types of uses permitted in the Light Industrial designation are not inherently more detrimental than those permitted in the Commercial designation (i.e. each proposed use is unique in its impact on surrounding uses and the environment and this entire project has been analyzed under the California Environmental Quality Act). 421
Reso. No. XX-26 Page 5 of 5 March 10, 2026
B. The General Plan Amendment (GPA 02-23) application was analyzed under the Bridgehead Industrial Project Environmental Impact Report (SCH No. 2024050471), certified by the City of Oakley City Council on March 10, 2026.

C. The Project complies with Measure J Growth Management requirements.

BE IT FURTHER RESOLVED THAT, on the above Findings and the Record, the City Council approves the Applicant’s request for approval of a General Plan Amendment as shown in Exhibit “A” of this resolution.

PASSED AND ADOPTED by the City Council of the City of Oakley at a meeting held on the 10
th day of March 2026, by the following vote:

AYES:

NOES:

ABSENT:

ABSTENTIONS:

APPROVED:

Hugh Henderson, Mayor
ATTEST:

Kim Snodgrass, City Clerk Date
422
Exhibit “A”
Existing and Proposed Land Use Designations
Bridgehead Industrial Project
Existing Proposed
423
Ord. No. XX-26 Page 1 of 5 XX, 2026
ORDINANCE NO. XX-26

AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF OAKLEY APPROVING A REZONE FROM BPL (BUSINESS PARK LOW) DISTRICT AND SP-2 (RIVER OAKS CROSSING SPECIFIC PLAN) DISTRICT TO P-1 (PLANNED UNIT DEVELOPMENT) DISTRICT FOR THE PROJECT KNOWN AS “BRIDGEHEAD INDUSTRIAL PROJECT (RZ 04-23)”
(APNS 037-020-007, 037-040-007 and 037-040-015)

FINDINGS
WHEREAS, on December 13, 2023, Oxfoot Oakley LLC ("Applicant") filed an application requesting approval of:
1) a General Plan Amendment (GPA 02-23) to redesignate the General Plan Land Use Designation of the southern portion (approximately 76.4-acres) of the approximately 164-acre site from Commercial (CO) to Light Industrial (LI); 2) a Rezone (RZ 04-23) to re-classify the Zoning District for the entire project from BPL (Business Park Low) District (northern portion) and SP-2 (River Oaks Crossing Specific Plan) District (southern portion) to P-1 (Planned Unit Development) District in conjunction with a Preliminary Development Plan;
3) a Tentative Map (TM 10-23) to subdivide the three existing parcels totaling approximately 164 acres into 10 lots;
4) a Design Review (DR 11-23), including site design and building architecture for 10 buildings totaling approximately 3.12 million square feet; 5) a Master Sign Program (MSP 01-23) for sign designs and specifications for the entire site, including all future buildings and entrances; and 6) a Development Agreement (DA 2025-01) ("Project").

The northern and southern portions are bisected by the BNSF railroad tracks and known as the North Development Area and the South Development Area. The North Development Area is zoned BPL (Business Park Low) District and is bordered by the Oakley Logistics Center to the west, Big Break Road to the east, open space to the north, and the BNSF railroad tracks to the south (APN 037-020-007). The South Development Area is zoned SP-2 (River Oaks Crossing Specific Plan) District and is bordered by Bridgehead Road to the west, the BNSF railroad tracks to the east and north, and Main Street to the south (APNS 037-040-007 and 037-040-015); and WHEREAS, the proposal complies with the requirements of the rezoning application requirements of Section 2.4.012 (a) of the Oakley Municipal Code; and 424
Ord. No. XX-26 Page 2 of 5 XX, 2026
WHEREAS, on March 26, 2025, the project application was deemed complete per Government Code section 65920 et. seq; and
WHEREAS, on January 20, 2026, the Planning Commission held a duly noticed public hearing to consider the proposed Project for recommendation to the City Council, received the staff report and staff presentation, received comments from the public and interested parties, and deliberated on the Project. At the conclusion of its deliberations, the Planning Commission took a vote and adopted 1) Planning Commission Resolution No. 2-26 recommending the City Council adopt a resolution certifying the Bridgehead Industrial Project Environmental Impact Report (SCH. No. 2024050471), make certain findings concerning mitigation measures, adopt a mitigation monitoring and reporting program, make findings concerning alternatives, and adopt a statement of overriding considerations, and 2) Planning Commission Resolution No. 3-26 recommending City Council approve the project titled, “Bridgehead Industrial Project (GPA 02-23, RZ 04-23, TM 10-23, DR 11-23, MSP 01-23, DA 2025-01),” as conditioned; and WHEREAS, on or before February 26, 2026, the Notice of Public Hearing for the Project was duly noticed in the Contra Costa Times, a newspaper of general distribution, was posted at the Project site, at Oakley City Hall located at 3231 Main Street, outside the gym at Delta Vista Middle School located at 4901 Frank Hengel Way, and outside the library at Freedom High School located at 1050 Neroly Road, was posted to the City’s website, and was mailed out to all owners of property within a 500-foot radius of the project’s boundaries, to parties requesting such notice, and to outside agencies; and WHEREAS, on March 10, 2026, the City Council opened the public hearing at which it received a report from City Staff, oral and written testimony from the public, and deliberated on the project. At the conclusion of its deliberations, the City Council took a vote and adopted this resolution to approve the project, as revised by the City Council during its deliberations; and
WHEREAS, on March 10, 2026, the City Council took the following additional actions related to the Project:
 Adoption of City Council Resolution No. XX-26, certifying the Bridgehead Industrial Project Environmental Impact Report (SCH No. 2024050471);  Adopting of City Council Resolution No. XX-26, approving the Project’s proposed General Plan Amendment (GPA 02-23);
 Waiving the first reading and introducing an ordinance to approve the Project’s Development Agreement application (DA 2025-01); and  Adoption of City Council Resolution No. XX-26 approving the Project’s proposed Tentative Map (TM 10-23), Design Review (DR 11-23), and Master Sign Program (MSP 01-23); and
WHEREAS, these Findings are based upon the City’s General Plan, the City’s Zoning Ordinance, the City’s Commercial and Industrial Design Guidelines, and the 425
Ord. No. XX-26 Page 3 of 5 XX, 2026
information submitted to the City Council at its March 10, 2026 meeting, both written and oral, including oral information provided by the applicant, as reflected in the minutes of such meetings, together with the documents contained in the file for the project (hereinafter the “Record”); and
WHEREAS, if any term, provision, or portion of these Findings or the application of these Findings to a particular situation is held by a court of competent jurisdiction to be invalid, void or unenforceable, the remaining provisions of these Findings, or their application to other actions related to the Project, shall continue in full force and effect unless amended or modified by the City.

NOW, THEREFORE, BE IT RESOLVED THAT, on the basis of the above findings of fact and the entire Record, the City Council makes the following additional findings in support of the Project approval for the Rezone (RZ 04-23):

SECTION 1. Findings
A. Regarding the application requesting approval of a Rezone (RZ 04-23) to reclassify the Zoning District for the entire project from BPL (Business Park Low) District (northern portion) and SP-2 (River Oaks Crossing Specific Plan) District (southern portion) to P-1 (Planned Unit Development) District in conjunction with a Preliminary Development Plan, the Planning Commission finds that:

1. Consistent with the applicable evaluation criteria found in Oakley Municipal Code section 9.1.1002 Planned Unit Development (P-1), part h.4.c:
a. Given favorable market conditions, the applicant intends to start construction within two years from the effective date of the zoning change and plan approval;
b. The proposed planned unit development is consistent with the General Plan, in that the Rezone to P-1 (Planned Unit Development) District would allow for a consistent set of development and use regulations throughout the entire project in a manner consistent with the existing and proposed Light Industrial Land Use Designation; and c. The proposed planned unit development is fully in conformity with the applicable performance standards therein, and will constitute an efficient and well organized development, with adequate provisions for truck access service and necessary storage.

2. Consistent with the applicable standards pertaining to Rezone applications found in Oakley Municipal Code section 2.4.012 Rezoning, part d:
426
Ord. No. XX-26 Page 4 of 5 XX, 2026
a. The change proposed will substantially comply with the General Plan, in that the planned unit develop will include uses and development regulations applicable to light industrial development at the scale proposed by the project, which would comply with the underlying General Plan designation of Light Industrial (existing and as proposed);
b. The uses authorized or proposed in the land use district are compatible within the district and to uses authorized in adjacent districts, in that the types of uses permitted in the Proposed P-1 District include truck and trailer parking and storage, general warehousing, high-cube warehousing, cold storage warehousing, fulfillment center, parcel hub, automated sorting center, distribution and logistics facility, transload facility, general manufacturing, office, data center, and industrial battery storage. The PUD also includes definitions and characteristics of each of those uses;
c. Community need, but not necessarily future financial success, has been demonstrated for the use proposed, in that the City of Oakley General Plan envisions the area the project lies within as an employment center and the proposed P-1 District will allow for a planned development with consistent design and internal circulation, and uses compatible with light industrial job creation.

B. The Rezone (RZ 04-23) application was analyzed under the Bridgehead Industrial Project Environmental Impact Report (SCH No. 2024050471), certified by the City of Oakley City Council on March 10, 2026.

C. The Project complies with Measure J Growth Management requirements.

SECTION 2. Property Defined and Rezoned
A. 164 acres of real property generally located north of Main Street, east of Bridgehead Road, and west of Big Break Road in Oakley, CA 94561 (APNs 037- 020-007, 037-040-007 and 037-040-015).

SECTION 3. Effective Date and Posting
This ordinance shall take effect and be in force thirty (30) days from and after the date of its passage. The City Clerk shall cause the ordinance to be published within fifteen (15) days after its passage in a newspaper of general circulation, or by publishing a summary of the proposed ordinance, posting a certified copy of the proposed ordinance in the City Clerk’s Office at least five (5) days prior to the City Council meeting at which the ordinance is to be adopted, and within fifteen (15) days after its adoption, publishing a summary of 427
Ord. No. XX-26 Page 5 of 5 XX, 2026
the ordinance with the names of the Council Members voting for and against the ordinance.

PASSED AND ADOPTED by the City Council of the City of Oakley on this day of , by the following vote:

AYES:

NOES:

ABSENT:

ABSTENTIONS:

APPROVED:

Hugh Henderson, Mayor
ATTEST:

Kim Snodgrass, City Clerk Date
I HEREBY CERTIFY that in accordance with Government Code Section 40806, this ordinance is a true and correct copy of a city ordinance. It has been published or posted pursuant to law.

Kim Snodgrass, CMC
City Clerk
428
Reso. No. XX-26 Page 1 of 28 January 20, 2026
RESOLUTION NO. XX-26

RESOLUTION OF THE CITY COUNCIL OF THE CITY OF OAKLEY MAKING

FINDINGS AND APPROVING A TENTATIVE MAP, DESIGN REVIEW, AND A MASTER SIGN PROGRAM FOR THE PROJECT KNOWN AS “BRIDGEHEAD INDUSTRIAL PROJECT (TM 10-23, DR 11-23, MSP 01-23)”
(APNS 037-020-007, 037-040-007, 037-040-015)
WHEREAS, on December 13, 2023, Oxfoot Oakley LLC ("Applicant") filed an application requesting approval of:
1) a General Plan Amendment (GPA 02-23) to redesignate the General Plan Land Use Designation of the southern portion (approximately 76.4-acres) of the approximately 164-acre site from Commercial (CO) to Light Industrial (LI); 2) a Rezone (RZ 04-23) to re-classify the Zoning District for the entire project from BPL (Business Park Low) District (northern portion) and SP-2 (River Oaks Crossing Specific Plan) District (southern portion) to P-1 (Planned Unit Development) District in conjunction with a Preliminary Development Plan;
3) a Tentative Map (TM 10-23) to subdivide the three existing parcels totaling approximately 164 acres into 10 lots;
4) a Design Review (DR 11-23), including site design and building architecture for 10 buildings totaling approximately 3.12 million square feet; 5) a Master Sign Program (MSP 01-23) for sign designs and specifications for the entire site, including all future buildings and entrances; and 6) a Development Agreement (DA 2025-01) ("Project").

The northern and southern portions are bisected by the BNSF railroad tracks and are referred to as the North Development Area and the South Development Area. The North Development Area is zoned BPL (Business Park Low) District and is bordered by the Oakley Logistics Center to the west, Big Break Road to the east, open space to the north, and the BNSF railroad tracks to the south (APN 037-020-007). The South Development Area is zoned SP-2 (River Oaks Crossing Specific Plan) District and is bordered by Bridgehead Road to the west, the BNSF railroad tracks to the east and north, and Main Street to the south (APNS 037-040-007 and 037-040-015).

WHEREAS, on March 26, 2025, the project application was deemed complete per Government Code section 65920 et. seq; and
WHEREAS, at the time of the application submittal for the Project, the project site was designated Light Industrial (LI) (North Development Area) and Commercial (CO) (South Development Area) on the Oakley General Plan Land Use Map, and zoned BPL 429
Reso. No. XX-26 Page 2 of 28 March 10, 2026
(Business Park Low) District (North Development Area) and SP-2 (River Oaks Crossing Specific Plan) District (South Development Area); and
WHEREAS, on January 20, 2026, the Planning Commission held a duly noticed public hearing to consider the proposed Project for recommendation to the City Council, received the staff report and staff presentation, received comments from the public and interested parties, and deliberated on the Project. At the conclusion of its deliberations, the Planning Commission took a vote and adopted 1) Planning Commission Resolution No. 2-26 recommending the City Council adopt a resolution certifying the Bridgehead Industrial Project Environmental Impact Report (SCH. No. 2024050471), make certain findings concerning mitigation measures, adopt a mitigation monitoring and reporting program, make findings concerning alternatives, and adopt a statement of overriding considerations, and 2) Planning Commission Resolution No. 3-26 recommending City Council approve the project titled, “Bridgehead Industrial Project (GPA 02-23, RZ 04-23, TM 10-23, DR 11-23, MSP 01-23, DA 2025-01),” as conditioned; and WHEREAS, on or before February 26, 2026, the Notice of Public Hearing for the Project was duly noticed in the Contra Costa Times, a newspaper of general distribution, was posted at the Project site, at Oakley City Hall located at 3231 Main Street, outside the gym at Delta Vista Middle School located at 4901 Frank Hengel Way, and outside the library at Freedom High School located at 1050 Neroly Road, was posted to the City’s website, and was mailed out to all owners of property within a 500-foot radius of the project’s boundaries, to parties requesting such notice, and to outside agencies; and WHEREAS, on March 10, 2026, the City Council opened the public hearing at which it received a report from City Staff, oral and written testimony from the public, and deliberated on the project. At the conclusion of its deliberations, the City Council took a vote and adopted this resolution to approve the project, as revised by the City Council during its deliberations; and
WHEREAS, on March 10, 2026, the City Council took the following additional actions related to the Project:
 Adoption of City Council Resolution No. XX-26, certifying the Bridgehead Industrial Project Environmental Impact Report (SCH No. 2024050471);  Adoption of City Council Resolution No. XX-26 approving the Project’s proposed General Plan Amendment.
 Waiving the first reading and introducing of an ordinance to approve the Project’s Rezone application (RZ 04-23);
 Waiving the first reading and introducing an ordinance to approve the Project’s Development Agreement application (DA 2025-01); and WHEREAS, these Findings are based upon the City’s General Plan, the City’s Zoning Ordinance, the City’s Commercial and Industrial Design Guidelines, and the information submitted to the City Council at its March 10, 2026 meeting, both written and 430
Reso. No. XX-26 Page 3 of 28 March 10, 2026
oral, including oral information provided by the applicant, as reflected in the minutes of such meetings, together with the documents contained in the file for the project (hereinafter the “Record”); and
WHEREAS, if any term, provision, or portion of these Findings or the application of these Findings to a particular situation is held by a court of competent jurisdiction to be invalid, void or unenforceable, the remaining provisions of these Findings, or their application to other actions related to the Project, shall continue in full force and effect unless amended or modified by the City.

NOW, THEREFORE, BE IT RESOLVED THAT, on the basis of the above findings of fact and the entire Record, the City Council makes the following additional findings in support of the Project approval for the Tentative Map (TM 10-23), Design Review (DR 11- 23), and Master Sign Program (MSP 01-23) applications:

A. Regarding the application requesting approval of a Tentative Map (TM 10-23) to subdivide the three existing parcels totaling approximately 164 acres into 10 lots, the City Council finds that:

1. The proposed Tentative Map (Subd. 9694) has been reviewed for compliance with all applicable codes in the Subdivision Map Act and City’s Subdivision Ordinance. The applicant has proposed the P-1 District which allows the project to develop its own unique development standards. The Final Development Plan (part of the applicant’s plans and proposed PUD document) lists the specific development standards applicable to the project. The Tentative Map, as proposed meets all applicable codes and regulations.

2. The proposed Tentative Map, together with the provisions of its design and improvements, is consistent with the Zoning Code and Project’s P-1 District, and applicable General Plan land use designations, in that it allows for orderly development in a light industrial area that meets the vision of the General Plan;

3. The site is physically suitable for the project, in that it is accessible from two streets identified in the General Plan as a Major Arterial (Main Street and Bridgehead Road) and one as a Minor Arterial (Big Break Road);

4. The site is not physically constrained, in that the site is relatively flat and is large enough in size to accommodate all required parking, landscaping, and stormwater treatment facilities;

5. The design of the subdivision and type of improvements are not likely to cause serious public health problems. Construction and grading of the 431
Reso. No. XX-26 Page 4 of 28 March 10, 2026
project are subject to building or grading permits, and violations of any such permits are subject to appropriate enforcement;

6. The design of the subdivision includes the construction of improvements within public right-of-way that are consistent with the City’s design standards; and

7. The design of the subdivision and the type of improvements will not conflict with easements, acquired by the public at large, for access through or use of property within the proposed subdivision.

B. Regarding the application requesting approval of a Design Review (DR 11-23), including site design and building architecture for 10 buildings totaling approximately 3.12 million square feet, pursuant to the Standards for Design Review Applications (Oakley Municipal Code section 9.1.1604 Design Review, part f), the City Council finds that:

1. Site planning, including building siting (location), setback and orientation; entries, circulation and parking; landscape setbacks and buffers; and location of trash, loading and service areas, and mechanical equipment have all been analyzed and found to be consistent with the City of Oakley Commercial and Industrial Design Guidelines and the P-1 District regulations for the proposed project;

2. Architecture will comply with the Design Guidelines, in that the conceptual building designs show tilt-up concrete buildings that will feature unique design and detailing between the North and South Development Areas in a manner that complement each other. Building facades along Main Street, Bridgehead Road and Big Break Road will feature additional architectural detailing to create a more visually interesting appearance. This includes office area offsets, added variation in articulation and colors, and a higher glass to wall ratio at the corner where there are typically building entrances.

3. Landscaping and site elements will comply with the Design Guidelines, in that significant landscaping, including trees for screening and parking lot shade, is proposed throughout the site, along the adjacent roadways, and in general landscape areas. Vinyl clad fencing will be used for a majority of the perimeter with the exception of a portion of the northern boundary where a masonry, or similar material, sound wall will be installed; and

4. Streetscapes will be improved along the project frontages in compliance with the City of Oakley Standard Details, including curb, gutter, and sidewalk 432
Reso. No. XX-26 Page 5 of 28 March 10, 2026
along the project’s Main Street, Bridgehead Road, and Big Break Road frontages.

C. Regarding the application requesting approval of a Master Sign Program (MSP 01- 23) for sign designs and specifications for the entire site, including all future buildings and entrances, the City Council finds that:

1. The proposed Master Sign Program complies with the General Standards for Approval for sign permits, pursuant to Oakley Municipal Code section

9.5.116 Sign Permits, part b, in that:
a. The materials, colors, design, height, size and scale of the signs are visually compatible with the structures, site, and uses to which the signs correspond, and the neighborhood in which the sign is located; b. The placement and size of the signs will not threaten or impair the safety of pedestrians, bicyclists, or motorists;
c. The signs are of professional quality and are clear and legible; d. The height and size of the letters and graphics on the signs enable pedestrians and motorists to readily identify the messages, facility or site from a sufficient distance that will enable them to safely and conveniently read the message or access the facility or the site; e. The signs do not unreasonably impair the visibility of existing signs on adjacent property; and
f. The signs comply with the purpose and standards of the City’s Sign Ordinance (Chapter 9.5 of the Oakley Municipal Code).

D. The Tentative Map (TM 10-23), Design Review (DR 11-23), and Master Sign Program (MSP 01-23) applications were analyzed under the Bridgehead Industrial Project Environmental Impact Report (SCH No. 2024050471), certified by the City of Oakley City Council on March 10, 2026.

E. The Project complies with Measure J Growth Management requirements.

BE IT FURTHER RESOLVED THAT, on the above Findings and the Record, the City Council approves the Applicant’s request for approval of the project titled, “Bridgehead Industrial Project (TM 10-23, DR 11-23, MSP 01-23),” subject to the following Conditions of Approval:
433
Reso. No. XX-26 Page 6 of 28 March 10, 2026
Conditions of Approval
Applicant shall comply with the requirements of the Oakley Municipal Code. Any exceptions must be stipulated in these Conditions of Approval. Conditions of Approval are based on the Applicant’s Plans date stamped received by the Planning Division on July 22, 2024, the Applicant’s Project Description dated March 25, 2025, the Applicant’s Planned Unit Development dated March 20, 2025 and revised on February 9, 2026, and the Development Agreement attached to the Project Staff Report, as well as additional information acquired since that time and made a part of the project file.

THE FOLLOWING CONDITIONS OF APPROVAL SHALL BE SATISFIED PRIOR TO

THE ISSUANCE OF A BUILDING PERMIT UNLESS OTHERWISE NOTED (BOLD CONDITIONS ADDED OR AMENDED AT PUBLIC HEARING):

Planning Division Conditions
General:

1. This project is approved, as shown on the Applicant’s Plans date stamped received by the Planning Division on July 22, 2024, the Applicant’s Project Description dated March 25, 2025, the Applicant’s Planned Unit Development dated March 20, 2025 and revised on February 9, 2026, and the Development Agreement attached to the Project Staff Report, all as conditioned herein.

2. This approval shall be effectuated within the term of the Development Agreement executed for the project. Should the Development Agreement not be executed, the approvals shall be subject to the applicable terms for each entitlement included in the Oakley Municipal Code. Prior to said expiration date, the applicant may apply for an extension of time pursuant to the provisions of the applicable section of the Oakley Municipal Code.

3. All construction drawings and plot plans submitted for plan check shall be in substantial compliance with the plans presented to and approved by the City Council and as conditioned herein.

4. All conditions of approval shall be satisfied by the owner/developer. All costs associated with compliance with the conditions shall be at the owner/developer’s expense.

5. Noise generating construction activities, including such things as power generators, shall be limited to the hours of 7:30 a.m. to 5:30 p.m. Monday through Friday, and shall be prohibited on City, State and Federal Holidays.

The restrictions on allowed working days and times may be modified on prior written approval by the Community Development Director. 434
Reso. No. XX-26 Page 7 of 28 March 10, 2026

6. Should archaeological materials be uncovered during grading, trenching or other on- site excavation(s), earthwork within 30 yards of these materials shall be stopped until a professional archaeologist who is certified by the Society of Professional Archaeology (SOPA) has had an opportunity to evaluate the significance of the find and suggest appropriate mitigation(s), if deemed necessary.

7. All mitigation measures addressed in the Project’s certified Environmental Impact Report (“EIR”) (SCH No. 2024050471), consisting of the Draft EIR and Final EIR, shall be implemented as outlined in the Mitigation Monitoring Program included in the Final EIR, per the review and approval of the Community Development Director or other assigned monitoring party.

8. The Applicant shall indemnify, defend, and hold harmless the City of Oakley, the City Approving Authorities, and the officers, agents, and employees of the City from any and all claims, damages and liability (including, but not limited to, damages, attorney fees, expenses of litigation, costs of court).

9. All development regulations and use allowances for the project shall be subject to the Project’s approved Rezone consisting of a P-1 District and accompanying Planned Unit Development document. In the event a development regulation or use is not covered in the P-1 District, the LI (Light Industrial) District shall be used, subject to the final determination by the Community Development Director.

Mitigation Measures:

10. The Applicant shall implement all adopted Mitigation Measures of the Bridgehead Industrial Project Environmental Impact Report (“EIR”) (SCH No. 2024050471), certified by the City of Oakley City Council on March 10, 2026, as included in the Mitigation Monitoring and Reporting Program (“MMRP”) of the EIR. The MMRP is attached as Exhibit “A” to this resolution.

Site Plan:

11. All passenger vehicle parking spaces shall be double striped. Width for each parking space may be measured from the center point of the double striping.

Double striping shall have a minimum four-inch gap between stripes.

12. Parking stalls and drive aisles shall comply with the regulations found in OMC section 9.1.1402 “Off-Street Parking,” subject to review and approval by the Community Development Director.

13. A final lighting and photometric plan shall be submitted with the building permit plans. The minimum requirement shall be one foot of candlelight within public parking areas and pedestrian pathways.
435
Reso. No. XX-26 Page 8 of 28 March 10, 2026

14. Details for onsite light poles shall be included in the building permit plans submittal and shall include spec sheets showing maximum height of the poles.

Bases shall be textured and painted to complement the building architecture.

Light poles shall be a maximum height 30 feet and shall provide glare shields where adjacent to other properties or near existing residences, per the review and approval of the Community Development Director.

15. Trash enclosures shall match Oakley Disposal and City standards and shall provide adequate space to accommodate both trash and recycling. Also, trash enclosures shall be constructed with a roof to match the building design and materials, have metal gates, and when appropriate be surrounded by screening landscaping and/or climbing vines on three sides per the review and approval of the Community Development Director.

16. Storage shall be contained inside the respective buildings. Storage containers are not allowed and pallets, boxes, cardboard etc. shall not be stored outside.

17. The sound wall to be installed along a portion of the northern property line of the North Development Area shall be decorative in design and color to match the general architecture and colors of the main buildings. Smooth-surfaced, concrete-colored CMU is not permitted.

Architectural Details:

18. Roof-mounted equipment shall be architecturally screened from view.

19. All exterior light fixtures shall be of the same or similar design to those proposed in the Applicant’s Plans, subject to the review and approval of the Community Development Director. Specs for the exterior fixtures, including building lights, shall accompany the construction drawings for building permits, and be subject to review and approval of the Community Development Director.

Landscaping:

20. A landscaping and irrigation plan for all front yard, right-of-way, parks, open space, and trail landscaping shall conform to the Oakley Water Efficient Landscape Ordinance (“WELO”), and the Guidelines for Implementation of the City of Oakley Water Efficient Landscape Ordinance and shall be installed prior to final occupancy. The plan shall be prepared by a licensed landscape architect and shall be certified to be in compliance with the City’s Water Conservation Ordinance by including the following signed statement on the cover sheet or same sheet as the WELO calculations in a visible text box:
“These plans are certified to conform to the Oakley Water Efficiency Landscape Ordinance.”
436
Reso. No. XX-26 Page 9 of 28 March 10, 2026

21. California native drought tolerant plants shall be used as much as possible. All trees shall be a mix of 15-gallon and 24-inch box; all shrubs shall be a minimum five-gallon size, except as otherwise noted.

22. All landscaped areas not covered by shrubs or groundcover shall be covered with bark or acceptable alternative as reviewed and approved by the Community Development Director. On slopes greater than 3 to 1, the Applicant shall use an alternative to bark per the review and approval of the Community Development Director. Areas covered with bark shall use a weed barrier.

23. The Applicant shall maintain all private landscaping until occupancy, or as specifically indicated elsewhere in these conditions of approval.

Signage:

24. All signage shall be consistent with the adopted Master Sign Program. Signs that comply with a Master Sign Program are still subject to Planning review and building permits. Modifications to the Master Sign Program may be subject to City Council approval.

Big Break Regional Trail:

25. The Applicant/Developer shall be responsible for the design and construction of the Big Break Regional Trail, and all associated improvements, located in the North Development Area. Final design of the trail corridor shall incorporate gate entry structures, signage, bollards, branding and fencing consistent with other existing Big Break Regional Trail segments in the region. The applicant may refer to the East Bay Regional Park District Standard Plans for further guidance. Such details shall be submitted for approval along with the first phase of development for the North Development Area.

Waste Management Plan:

26. The Applicant shall submit a Waste Management Plan that complies with the City of Oakley Construction and Demolition Debris Recycling Ordinance.

Building Division Conditions

27. The Applicant shall provide proof of compliance with CalGreen Code related to the total number and type of electric vehicle (EV) capable spaces and electric vehicle charging stations (EVCS) for the entire shopping center. The proposed project is subject to the nonresidential standards set forth in Section 5.106.5.3.1 and 5.106.5.3.2 of the CALGreen Code. Pursuant to Section 5.106.5.3.1 and

5.106.5.3.2, the proposed project would be required to provide the number of EV capable and EVCS spaces based on the total number of parking spaces in accordance with table 5.106.5.3.1. The Applicant may exercise the alternative power allocation method in section 5.106.5.3.6 which may result in a lower 437
Reso. No. XX-26 Page 10 of 28 March 10, 2026
criterion for the total number of EV capable and EVCS spaces required to meet CALGreen standards in accordance with table 5.106.5.3.6. Modifications to the EV parking and charging spaces may be approved by the Community Development Director provided that compliance with the CalGreen Code requirements are maintained.

28. Plans shall meet the currently adopted California Codes as well as the newest T-24 Energy requirements from the State of California Energy Commission. To confirm the most recently adopted codes please contact the Building Division at (925) 625-7005.

29. Prior to requesting a Certificate of Occupancy from the Building Division, all Conditions of Approval required for occupancy must be completed. When the Public Works Division and the Planning Division place Conditions of Approval on the project, those divisions will sign off on the project prior to the request for a Building division final inspection. Similarly, if the Health Department and/or Fire Department reviewed and approved the original plans, those departments must sign off on the project prior to the request for a final inspection by the Building Division.

PUBLIC WORKS AND ENGINEERING CONDITIONS OF APPROVAL

THE FOLLOWING SHALL BE SATISFIED PRIOR TO THE APPROVAL OF AN ENCROACHMENT AND/OR GRADING PERMIT:

30. GENERAL. All public improvements shall be made according to the latest adopted City Standard Drawings and Specifications. All work shall conform to the applicable City ordinances. The adjacent public right-of-way shall be kept clear of all job-related dirt and debris at the end of the day. Dirt and debris shall not be washed into storm drainage facilities. The storing of goods and materials on the sidewalk and/or the street will not be allowed unless a special permit is issued. The developer's representative in charge shall be at the job site during all working hours. Failure to maintain the public right-of-way according to this condition may result in the City performing the required maintenance at the developer's expense. All conditions of approval shall be satisfied by the owner(s)/developer(s). All costs associated with compliance with the conditions shall be at the owner(s)/developer(s)’s expense.

31. ENCROACHMENT PERMIT. All work in the public right-of-way, including any blockage or partial closure of sidewalks will require an Encroachment Permit.

Special provisions such as limitations on work hours, protective enclosures, or other means to facilitate public access in a safe manner may be required.

32. GRADING PERMIT. All earthwork must comply with the City’s Grading Ordinance. A Grading Permit must be issued by the public works department prior to site disturbance.
438
Reso. No. XX-26 Page 11 of 28 March 10, 2026

33. PUBLIC WORKS INSPECTIONS. The developer or their representative shall notify the Engineering Inspector at least forty-eight (48) hours before starting any work pertaining to on-site drainage facilities, grading or paving, and all improvements in approved plans. Failure to do so will result in rejection of work that was completed without inspection.

34. PRECONSTRUCTION MEETING. Prior to issuance of any permit or the commencement of any site work, the general contractor shall:
a. Along with the project applicant, attend a pre-construction meeting with the City Engineer to discuss the project conditions of approval, working hours, site maintenance and other construction matters. b. Acknowledge in writing that they have read and understand the project conditions of approval and will make certain that all project subcontractors have read and understand them prior to commencing work and that a copy of the project conditions of approval will be posted on site at all times during construction.

35. CONSTRUCTION STREET PARKING. No vehicle having a manufacturer's rated gross vehicle weight exceeding ten thousand (10,000) pounds shall be allowed to park on the portion of a street which abuts property in a residential zone without prior approval from the City Engineer.

36. EROSION CONTROL. Interim and final erosion control plans shall be prepared and submitted to the Public Works Department. A Notice of Intent (NOI) and Storm Water Pollution Prevention Plan (SWPPP) shall be submitted to the State SMARTS system for projects disturbing more than one acre and obtain a WDID number. A maximum of two weeks is allowed between clearing of an area and stabilizing/building on an area if grading is allowed during the rainy season.

Interim erosion control measures, to be carried out during construction and before installation of the final landscaping shall be included. Interim erosion control method shall include, but are not limited to: silt fences, fiber rolls (with locations and details), erosion control blankets, City standard seeding specification, filter berms, check dams, retention basins, etc. Provide erosion control measures as needed to protect downstream water quality during winter months. The grading, drainage, erosion control plans and SWPPP shall comply with applicable measures contained in the City of Oakley’s NPDES Permit.

37. DUST CONTROL. Blowing dust shall be reduced by timing construction activities so that paving and building construction begin as soon as possible after completion of grading, and by landscaping disturbed soils as soon as possible. Further, water trucks shall be present and in use at the construction site. All portions of the site subject to blowing dust shall be watered as often as deemed necessary by the City, or a minimum of three times daily, or apply (non439 Reso. No. XX-26 Page 12 of 28 March 10, 2026
toxic) soil stabilizers on all unpaved access roads, parking areas, and staging areas at construction sites to ensure proper control of blowing dust for the duration of the project. Watering on public streets shall not occur. Streets will be cleaned by street sweepers or by hand as often as deemed necessary by the City Engineer, or at least once a day. Watering associated with on-site construction activity shall take place between the hours of 8 a.m. and 5 p.m. and shall include at least one late-afternoon watering to minimize the effects of blowing dust. All public streets soiled or littered due to this construction activity shall be cleaned and swept daily during the workweek to the satisfaction of the City. Demolition or earthwork activities shall be halted when wind speeds (instantaneous gusts) exceed 25 MPH. All trucks hauling soil, sand, or other loose debris shall be covered.

38. FIRE CONTROL. The project developer shall keep the site free of fire hazards from the start of construction until final inspection. The plan must adhere to the satisfaction of the Contra Costa Fire District.

39. SILT AND MUD IN PUBLIC RIGHT-OF-WAY. It is the responsibility of contractor and homeowner to make sure that all dirt tracked into the public right-of-way is cleaned up daily. Mud, silt, concrete, and other construction debris SHALL NOT be washed into the City’s storm drains. Construction entrances must be in place per the Erosion Control Plan.

40. TRAFFIC CONTROL PLAN. The project sponsor will be required to work with the Public Works Department to develop a traffic control plan per the current California MUTCD. This plan will include, but not be limited to, the following measures:
a. Construction activities shall be strategically timed and coordinated to minimize traffic disruption for schools, residents, businesses, and special events. The schools located on the haul route shall be contacted to help with the coordination of the trucking operation to minimize traffic disruption.
b. Flag persons shall be placed at locations necessary to control one-way traffic flow, if required. All flag persons shall have the capability of communicating with each other to coordinate the operation. c. Prior to construction, advance notification of all affected residents and emergency services shall be made regarding one-way operation, specifying dates and hours of operation and lane closures on main arterial and collector streets, and will be permitted only between the hours of 8:30AM to 2:30PM on M, T, TH & F. 8:30AM to 12:00PM on W. d. The traffic control plan shall be reviewed for compliance with the project’s Haul Route, approved by the City of Oakley.
440
Reso. No. XX-26 Page 13 of 28 March 10, 2026
e. A full road closure will require a detour plan and a road closure permit issued by the Public Works Department.

41. CONSTRUCTION MANAGEMENT PLAN. The Applicant shall submit a construction management plan that shall incorporate at a minimum the Earth Movement Plan, Traffic Control Plan, Project Schedule, site security fencing, employee parking, construction staging area, construction trailer, and proposed outhouse locations. The public street shall not be used for any construction related activities, including parking for workers and storage of vehicles. The Traffic Control Plan shall be consistent with the Construction Traffic Plan as required in the Project EIR Mitigation Measure 4.12-1.

42. RESTORATION OF PUBLIC IMPROVEMENTS. The developer shall repair or replace all existing improvements not designated for removal that are damaged or removed because of developer's operations. Improvements such as, but not limited to: curbs, gutters, sidewalks, driveways, signs, pavements, raised pavement markers, thermoplastic pavement markings, etc. shall be repaired and replaced to a condition equal to or better than the original condition.

Existing improvement to be repaired or replaced shall be at the direction of the Public Works & Engineering Inspector and shall comply with all Title 24 Disabled Access provisions. Developer shall request a walk-through with the Engineering Construction Inspector before the start of construction to verify existing conditions.

43. SIDEWALK REPAIR. The developer shall repair and replace to existing City standards any sidewalk damaged now or during construction of this project.

Sidewalk repair shall match existing color, texture, and design, and shall be constructed per City Standard Details. The limits of sidewalk repair will be determined by the Public Works Inspector during the construction phase of the project.

44. CURB AND GUTTER. The developer shall repair and replace, to existing City standards, any curb and gutter damaged now or during construction of this project. New curb and gutter shall be constructed per City Standard Details.

The limits of curb and gutter repair will be determined by the Public Works Inspector during the construction phase of the project.

45. CONSTRUCTION NOISE. Between the hours of 7:30 a.m. to 5:30 p.m., weekdays and 9:00 a.m. to 5:30 p.m. weekends and holidays, construction, alteration, or repair activities shall be allowed. No individual piece of equipment shall produce a noise level exceeding eighty-five (85) dBA at twenty-five (25) feet. If the device is located within a structure on the property, the measurement shall be made at distances as close to twenty-five (25) feet from the device as possible. The noise level at any point outside of the property plane shall not exceed eighty-five (85) dBA. Pickup and delivery of materials and equipment is 441
Reso. No. XX-26 Page 14 of 28 March 10, 2026
restricted to the hours listed above unless prior written approval is obtained by the Public Works Department.

46. GOOD HOUSEKEEPING. Good housekeeping practices shall be observed at all times during the course of construction. Superintendence of construction shall be diligently performed by a person or persons authorized to do so at all times during working hours. The storing of goods and/or materials on the sidewalk and/or the street will not be allowed unless a special permit is issued by the Engineering Division. The adjacent public right-of-way shall be kept clear of all job-related dirt and debris at the end of the day. Dirt and debris shall not be washed into storm drainage facilities. The storing of goods and materials on the sidewalk and/or the street will not be allowed unless a special permit is issued. The developer's representative in charge shall be at the job site during all working hours. Failure to maintain the public right-of-way according to this condition may result in the City performing the required maintenance at the developer's expense.

47. SITE SUPERVISION. The General Contractor shall provide qualified supervision on the job site at all times during construction.

48. TREE REMOVAL. Copies of all necessary tree removal permits shall be provided prior to issuance of a grading permit.

49. EASEMENTS. Owner/Applicant/Developer shall provide copy of recorded Grant of Easements and/or land acquisitions and duly executed rights of entry for all permanent and temporary construction of improvements required for the project and shall fully comply with their requirements.

THE FOLLOWING SHALL BE SATISFIED PRIOR TO THE APPROVAL OF THE GRADING PLAN:

50. EXISTING WELLS. All abandoned or inactive wells on the subject site shall be destroyed in accordance with the required abandonment wells standards by the agencies responsible for the wells. Provide documentation that any gas wells located onsite have been abandoned per regulations.

51. GEOLOGY AND SOIL MITIGATION MEASURES. A geotechnical investigation shall be conducted for the project to determine the surface and sub-surface conditions at the site and to determine the potential for surface fault rupture on the site. The geotechnical study shall provide recommendations for site grading as well as the design of foundations, retaining walls, concrete slab-on-grade construction, excavation, drainage, on-site utility trenching and pavement sections. The soils report shall include specific criteria and standards governing site grading, drainage, pavement design, retaining wall design, and erosion control. All recommendations of the investigation shall be incorporated into project plans. One copy of the geologic report shall be submitted with the 442
Reso. No. XX-26 Page 15 of 28 March 10, 2026
grading permit and public improvement application. Prior to issuance of any permit, the applicant’s soils engineer shall review the final grading and drainage plans to ensure that designs for foundations, retaining walls, site grading, and site drainage are in accordance with their recommendations. The applicant’s soils engineer’s approval shall then be conveyed to the City either by letter or by signing the plans.

52. GRADING.
a. Grade any slopes with a vertical height of four (4) feet or more at a slope of 3H to 1V. Retaining walls that may be installed to reduce the slope must be masonry and comply with the City’s building code. b. Retaining wall or other suitable option acceptable by the City Engineer is required where the grade differential between property or adjacent lots are greater than 6”. Retaining walls are required to be identified on the grading plans and shall have a note stating a separate building permit is required for retaining wall greater than four (4) feet in height, measured from the bottom of footing to top of wall.
c. At least one week prior to commencement of grading, the applicant shall post at the site and mail to the owners of property within 300 feet to the exterior boundary of the project site notice that construction work will commence. The notice shall include a list of contact persons with their name, title, phone number and area of responsibility. The person responsible for maintaining the list shall be included. The list shall always be kept current and shall consist of persons with authority to indicate and implement corrective action in their area of responsibility.

The names of the individual responsible for noise and litter control shall be expressly identified in the notice. The notice shall be reissued with each phase of major grading activity. A copy of the notice shall be concurrently transmitted to the City Engineer. The notice shall be accompanied by a list of the names and addresses of the property owners noticed, and a map identifying the area noticed. d. Submit a Haul Route Plan to the City Engineer for review and approval prior to importing or exporting any material from the site. The plan shall include the location of the borrow or fill area, the proposed haul routes, the estimated number and frequency of trips, and the proposed schedule of hauling. Based on this plan, the City Engineer shall determine whether pavement condition surveys must be conducted along the proposed haul routes to determine what impacts the trucking activities may have. The project proponents shall be responsible for repairing to their pre-construction condition any roads along the utilized routes. 443
Reso. No. XX-26 Page 16 of 28 March 10, 2026
e. Prior to commencement of any site work that will result in a land disturbance of one acre or more, the applicant shall provide evidence to the City Engineer that the requirements for obtaining a State General Construction Permit have been met. Such evidence may be a copy of the Notice of Intent Letter sent by the State Water Resources Control Board. The WDID Number shall be shown on the grading plan prior to approval by the City Engineer.
f. The burying of any construction debris is prohibited on construction sites.

53. NPDES – NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM.

Comply with all rules, regulations and procedures of the NPDES for municipal, construction and industrial activities as promulgated by the California State Water Resources Control Board, the Regional Water Quality Control Board (Central Valley – Region IV), including the Stormwater C.3 requirements as detailed in the Guidebook available at www.cccleanwater.org Compliance shall include developing long-term best management practices (BMPs) for the reduction or elimination of storm water pollutants. The project design shall incorporate wherever feasible, the following long-term BMPs in accordance with the Contra Costa Clean Water Program for the site’s storm water drainage.
 Offer pavers for household driveways and/or walkways as an option to buyers.  Minimize the amount of directly connected impervious surface area.  Delineate all storm drains with “No Dumping, Drains to the Delta” permanent metal markers per City Standards.
 Construct concrete driveway weakened plane joints at angles to assist in directing run-off to landscaped/pervious areas prior to entering the street curb and gutter.
 Distribute public information items regarding the Clean Water Program to buyers.  Other alternatives as approved by the City Engineer.
 Prepare an Operations and Maintenance Manual for the project’s storm water control measures.

THE FOLLOWING SHALL BE SATISFIED PRIOR TO THE APPROVAL OF THE IMPROVEMENT PLAN:

54. PUBLIC IMPROVEMENTS. Construct the project streets within public right of way to City public road standards and as shown on the Tentative Map with the following exceptions:
a. The minimum street grade may be lowered from the standard 1% to

0.75% provided that the project proponent demonstrates that the City’s drainage standards can be achieved.
444
Reso. No. XX-26 Page 17 of 28 March 10, 2026
b. Submit a turning radius exhibit to the City Engineer for review and approval to illustrate that the ninety-degree turns of project entrances can accommodate the largest expected vehicle to use the streets without the inclusion of City standard elbows. If the exhibit illustrates that elbows are necessary to accommodate the expected traffic, then they shall be included in the improvement plans. Provide a minimum outside turning radius of 45 feet and a minimum inside turning radius of 28 feet within each cul-de-sac or knuckle. Show truck turning radius for garbage truck for garbage pickup.

55. PRIVATE IMPROVEMENTS. Private onsite improvement plans shall be prepared by a California registered civil engineer, reviewed, and approved by the City.

56. ROADWAY IMPROVEMENTS. The following improvements shall be installed by the developer. Plans for those improvements shall be prepared by a California registered civil engineer, reviewed, and approved by the City, to the satisfaction of the City Engineer.
a. Main Street shall be improved to its ultimate roadway width including a landscaped median island per the City of Oakley Standard Plans. The developer must notify all affected businesses in the area with the installation of the median island. The developer may request to enter into a reimbursement agreement for construction costs related to the improvements associated with the landscaped median island per the Traffic Impact Fee Program.
b. Bridgehead Road shall be improved to its ultimate roadway width along the project frontage per the City of Oakley Standard Plans. c. Big Break Road shall be improved to its ultimate roadway width along the project frontage per the City of Oakley Standard Plans. d. Traffic Signal Improvements:
i. Modify the existing traffic signal at the intersection of Main Street and Live Oak Avenue to serve the access road to the project. ii. Submit a traffic warrant for Bridgehead Road and the project site intersection based on build-out conditions. If a signal is deemed warranted, construct the necessary improvements to signalize the intersection to the satisfaction of the City Engineer. iii. Submit a traffic warrant for Big Break Road and Vintage Parkway intersection based on build-out conditions. If a signal is deemed 445
Reso. No. XX-26 Page 18 of 28 March 10, 2026
warranted, construct the necessary improvements to signalize the intersection to the satisfaction of the City Engineer. e. Developer shall have a Traffic Engineer analyze the appropriate pedestrian safety improvements for the trail crossing Big Break Road to connect to the Big Break Regional Trail. The Traffic Engineer’s analysis and proposed improvements shall be submitted to the City Engineer for review and approval. Upon approval by the City Engineer, the Developer shall construct the proposed trail crossing improvements prior to occupancy of the first building in the North Development Area. f. Developer shall have a Traffic Engineer analyze the appropriate pedestrian safety improvements at the railroad crossing on Big Break Road. The Traffic Engineer’s analysis and proposed improvements shall be submitted to the City Engineer for review and approval. Upon approval by the City Engineer, the Developer shall construct the proposed pedestrian railroad crossing improvements prior to occupancy of the first building in the North Development Area.

57. DRIVEWAYS AND DESIGN GEOMETRY. Prior to Improvement Plan approval, the Improvement Plans for the proposed project shall indicate that development of the proposed project includes:
 The proposed westernmost driveway on Main Street shall be relocated to the east. The driveway shall have a minimum separation of 250 feet from the existing Dutch Bros. Coffee driveway to provide for adequate and safe operations without conflicts;
 The proposed internal “horseshoe shaped” intersection located north of the intersection of Main Street and Live Oak Avenue shall be redesigned to include a 90-degree intersection of internal streets with the maximum amount of throat depth possible. The intersection shall have a minimum throat depth of 200 feet;
 The two proposed eastern driveways on Main Street shall be relocated to align with existing streets on the south side of the roadway to eliminate turning conflicts and clarify right of way; and
 R5-2 “No Trucks” signs shall be installed on internal roadways at the locations illustrated on Figure 4.12-4. Installation of the signs shall be required to prevent trucks from exiting the project site by way of Big Break Road during project operation, where heavy trucks are prohibited.

Inclusion of the foregoing requirements on the Improvement Plans for the proposed project shall be subject to review and approval by the City of Oakley City Engineer and be consistent with implementation of the Project EIR Mitigation Measure 4.12-4(b).
446
Reso. No. XX-26 Page 19 of 28 March 10, 2026

58. PEDESTRIAN AND BYCICLE FACILITIES. Prior to Improvement Plan approval, the Improvement Plans for the proposed project shall indicate that development of the proposed project includes:
 In accordance with the 2022 California Green Building Code:
o Short-term bicycle parking (bicycle racks) for at least five percent of the number of vehicle parking spaces shall be provided onsite; and
o Long-term bicycle parking (bicycle lockers) for at least five percent of the tenant employees working onsite shall be provide onsite.  Consistent with Figure 3-8 Bikeway Network Plan of the City of Oakley General Plan:
o A Class I bicycle path shall be installed along the project’s Big Break Road frontage;
 Crosswalks and actuated pedestrian signals shall be installed at the intersection of Live Oak Avenue and Main Street on all four approaches;  Crosswalks shall be installed at the intersection of Big Break Road and Vintage Parkway on all four approaches;
 The proposed sidewalk on Main Street shall be extended from the eastern edge of the project site to the intersection of Main Street and Big Break Road; and
 Sidewalks shall be provided along all primary internal roadways. o A Class II bicycle lane shall be along the project’s Bridgehead Road frontage, consistent with Figure 3-8 Bikeway Network Plan of the City of Oakley’s General Plan; and
o Class IV separated bikeway along the project’s Main Street frontage.

Inclusion of the foregoing requirements on the Improvement Plans for the proposed project shall be subject to review and approval by the City Engineer and be consistent with implementation of the Project EIR Mitigation Measure

4.12-2.

59. DRAINAGE IMPROVEMENTS.
a. Collect and convey all stormwater entering and /or originating on this property, without diversion and within an adequate storm drainage facility, to an adequate natural watercourse having definable bed and banks, or to an existing adequate public storm drainage facility that conveys the storm waters to an adequate natural watercourse. b. Submit a final hydrology and hydraulic report including 10-year and 100- year frequency event calculations for the proposed drainage system and stormwater basins to the City Engineer for review and approval. The report shall include an analysis of the downstream storm drain facilities to confirm adequate capacity exists to convey post construction flows. 447
Reso. No. XX-26 Page 20 of 28 March 10, 2026
The report must include a narrative that describes the project’s proposed overland release for storm water runoff. In the event of a failure of the project’s storm drain system, the overland release path shall convey storm water runoff to a public street right-of-way or drainage channel.

All structure finished floor elevations shall be designed to be a minimum of 12 inches above the 100-year storm elevation, or the overland release elevation.
c. The hydrology and hydraulic report must be submitted to and reviewed by the Contra Costa County Flood Control District. This project is subject to drainage improvements intended for Drainage Area 29H. d. If runoff from the proposed project cannot be directed to flow into public street rights-of-way, the project will be required to obtain surface drainage easements from the adjacent private properties. e. Design and construct all storm drainage facilities in compliance with the Municipal Code and City design standards.
f. Prevent storm drainage from draining across the sidewalk(s) and driveway(s) in a concentrated manner.
g. Dedicate a public drainage easement over the drainage system that conveys storm water run-off from public streets.
h. Dedicate a public storm drainage easement as required for the proposed relocation of the existing 84” storm drain.
i. On-site parking area and driveways shall not surface drain across public sidewalk or driveway aprons.
j. Proposed Buildings 2 and 3 must be protected from or removed from the Flood Zone. If this is to be accomplished by the placement of fill, a CLOMR must be processed with FEMA pursuant to the Project EIR Mitigation Measure 4.8-5.

60. SIGHT DISTANCE. For the project driveways’ ingress and egress, provide an exhibit that will analyze the sight distance required for the appropriate speed limit identified with this project as required by the City Engineer.

Prior to Improvement Plan approval, the Improvement Plan for the proposed project shall be reviewed by the City Engineer to ensure that adequate sight distance is maintained at all project driveways. Objects greater than three feet in height (i.e., landscaping, monument signs, etc.) shall not be allowed within the sight distance triangles at project driveway intersections. Particular attention should be given to the northern project driveway on Bridgehead Road. 448
Reso. No. XX-26 Page 21 of 28 March 10, 2026

61. DESIGN CHANGES. The Applicant's registered Engineer shall notify the City Engineer, in writing, at least 72 hours in advance of all differences between the proposed work and the design indicated on the plans. Any proposed changes shall be subject to the approval of the City before altered work is started. A plan revision must be submitted for approval by the City Engineer.

62. JOINT TRENCH PLANS. The applicant shall submit Joint Trench Composite Plans to the City for review prior to approval of improvement plans or recordation of the final map. The developer shall provide joint trench composite plans for the underground electrical, gas, telephone, cable television and communication conduits and cables including the size, location and details of all trenches, locations of building utility service stubs and meters and placements or arrangements of junction structures as a part of the improvement Plan submittals for the project. The composite drawings and/or utility improvement plans shall be signed by a licensed civil engineer. The joint trench plans shall include street and/or site lighting and associated photometrics. A letter shall be provided by PG&E stating that public streetlight billing will be per Rule LS2A, and that private lights shall be metered with billing to the owner. Pole numbers, assigned by PG&E, shall be clearly delineated on the plans.

63. UTILITIES & UNDERGROUNDING. The project is required to underground the existing overhead power and utility lines along the project’s frontage at Main Street, Bridgehead Road, and Big Break Road.
a. Underground all new and existing power and utility distribution facilities per City of Oakley code section Title 6 Chapter 8 Underground Utility Districts.
b. All utility boxes shall be installed underground, and all wires and cables must be installed in conduits. Compliance with this condition shall be at the discretion of the City Engineer.
c. Above ground utility boxes shall be camouflaged per the review and approval of the City Engineer.
d. A written approval from Diablo Water District and Iron House Sanitary District must be provided that all underground utility improvements have passed all testing requirements prior to commencement of paving a street.

64. STREETLIGHTS. Install streetlights along all public streets as required by the City Engineer. The City Engineer shall determine the final number and location of the lights, and the lights shall be on an LS2-A rate service. Streetlights shall be spun aluminum “cobra head” style as required by the City of Oakley Standard Plans.
449
Reso. No. XX-26 Page 22 of 28 March 10, 2026

65. LANDSCAPE IMPROVEMENTS. Each parcel must design landscape improvements that aligns with the maintenance responsibility boundary for each Parcel unless a formal Property Management Company/Owner’s Association will be responsible for common area landscaping for this project. a. Prepare landscape plans for landscape improvements within the public right of way. Landscape plans shall be prepared by a licensed landscape architect.
b. Install public right-of-way landscaping along the project’s frontages as required by the City Engineer and Community Development Director. c. Maintain all Main Street median landscaping until such time that the adjacent roadway improvements have been accepted for maintenance. d. Prior to the issuance of certificate of occupancy, an inspection will be performed to verify the health and location of the street trees. Trees in poor health or those without adequate clearance from utilities will require replacement or relocation.
e. Landscaping at street corners must adhere to sight distance requirements.

66. FENCING. Any proposed fencing and walls shall be located on private property and maintained by the property owner(s) and/or Property Management Company/Owner’s Association. The design and placement of walls, fences, and sign features near intersections and driveways shall allow stopping site distance per Caltrans standards and comply with the City’s corner sight distance requirements.

67. GATE: Any proposed private gates are to be set be minimum 20’ from all public and private streets, roads, and alleys.

68. SOUNDWALL. Soundwalls shall be installed within private property and not within public right of way.

69. MAINTENANCE EXHIBIT. Submit a maintenance exhibit showing the responsible maintenance entity of proposed subdivision improvements. Exhibit must clearly show which areas are to be maintained by the City of Oakley and areas to be maintained by the property owner(s) and/or Property Management Company/Owner’s Association.

70. PHASING PLAN. Submit a phasing plan for the project streets to the City Engineer for review if the street improvements will be phased. The plan shall 450
Reso. No. XX-26 Page 23 of 28 March 10, 2026
include provisions for temporary turn-around facilities and access to the occupied lots per the approval of the City Engineer and Fire District.

THE FOLLOWING PUBLIC WORKS AND ENGINEERING CONDITIONS OF APPROVAL SHALL BE SATISFIED PRIOR TO THE APPROVAL OF THE FINAL MAP:

71. BONDS. The applicant shall supply suitable securities for all improvements that are a part of the development in a form acceptable to the City in the amount of 100% (performance), 50% (labor and material) prior to issuance of any permit.

72. FINAL MAP. Submit a Final Map prepared by a Licensed Land Surveyor. The final map shall be recorded, and the Subdivision Agreement must be executed before any building permits are issued. Insurance shall be provided per the terms of the Subdivision Agreement.

73. DEDICATIONS. The following shall be dedicated on the final map. The dedication shall be recorded before any permits are issued and under specific timelines listed below:
a. Dedicate the required right-of-way along the project frontage on Main Street, Bridgehead Road, and Big Break Road as shown on the Tentative Map.
b. Acquire the necessary private roadway easement and private utility easement through Industrial Way as shown in the Vesting Tentative Map, to connect with the private access road between Buildings 1 and 2 at the North Development Area. Failure to obtain such easements may limit the allowable uses in the North Development Area due to the lack of truck access to the North Development Area via Big Break Road. c. Public Utility Easement (PUE): 10’ PUE beyond public right of way as required.
d. Ingress-egress, storm drainage easements, emergency access easements as required.
e. Any necessary rights of way, rights of entry, permits and/or easements for the construction of off-site, temporary or permanent, public and private road, utility and drainage improvements shall be furnished to the City. Prior to the issuance of the first building permit, the applicant must provide the necessary documentation that any existing easements no longer necessary have been quitclaimed.
f. Dedicate a minimum 14-foot-wide right-of-way for the portion of the proposed Big Break Regional Trail that runs along the north portion of 451
Reso. No. XX-26 Page 24 of 28 March 10, 2026
the North Development Area. Dedication shall be made with the recording of the first Final Map in the North Development Area.

74. PRIVATE EASEMENTS. Agreements detailing rights, limitations, and responsibilities of involved parties shall accompany each private easement. The easements and associated agreements shall be recorded simultaneously with the final map.

75. UTILITY SETBACKS. Building foundations shall be set back from utility lines a sufficient distance to allow excavation of the utility without undermining the house foundation. The City Engineer shall determine the appropriate setback based on the depth of the utility, input from the project soils engineer, and the type of foundation.

76. UTILITY EASEMENTS. Deed restrictions shall be placed on lots containing utility easements, as applicable. The deed restrictions shall specify that no trees, fences, or hardscape are allowed within the easement boundaries, and that maintenance access must be provided. The City will assist and provide guidance for the deed language and the Applicant's surveyor shall prepare the legal description and plat. The Applicant shall pay any recordation costs.

77. PROPERTY MANAGEMENT COMPANY/OWNER’S ASSOCIATION: Prior to the sale of any lot or acceptance of site improvements, whichever occur first, Developer must formalize a Property Management Company/Owner’s Association for the project and define maintenance responsibility for each Parcel and adjacent public right of way. Conditions, Covenants and Restrictions (CC&R’s), shall be reviewed and approved by the City of Oakley and recorded.

The formal document must be filed outlining the maintenance responsibility of private roadways, alleys and common landscape, private infrastructures and onsite storm drain systems within the development.

78. MAINTENANCE AGREEMENT. A Maintenance Agreement by and between the City of Oakley and the property owner(s) and/or Property Management Company/Owner’s Association must be prepared outlining the necessary maintenance responsibilities between each parcel and adjacent public right of way concurrent with the recordation of the Final Map(s).

79. DRAINAGE FEES. Applicant shall comply with the drainage fee requirements for the designated Drainage Area as adopted by the County Board of Supervisors. The applicant shall pay the fee in effect at the time of the Final Map approval.

80. ANNEXATIONS
a. The applicant shall establish a funding mechanism to cover the ongoing financial impact their project has on fire protection services provided in 452
Reso. No. XX-26 Page 25 of 28 March 10, 2026
the City. All costs associated with meeting this condition of approval shall be paid for by the applicant. Compliance with this requirement shall be to the satisfaction of the City Engineer and shall be completed prior to final map approval.
b. The applicant shall establish a funding mechanism to cover the ongoing financial impact their project has on police services provided in the City.

All costs associated with meeting this condition of approval shall be paid for by the applicant. Compliance with this requirement shall be to the satisfaction of the City Engineer and shall be completed prior to final map approval.
c. The applicant shall establish a funding mechanism to cover the ongoing financial impact their project has on maintenance and operation services associated with public landscaping, parks, publicly accessible trails, streetlighting, and stormwater facilities. All costs associated with meeting this condition of approval shall be paid for by the applicant.

Compliance with this requirement shall be to the satisfaction of the City Engineer and shall be completed prior to final map approval.

THE FOLLOWING SHALL BE SATISFIED PRIOR TO THE ISSUANCE OF THE BUILDING PERMIT(S):

81. PAD CERTIFICATION. A letter from a licensed land surveyor stating that the building pad was constructed in accordance with the approved plans shall be provided prior to the issuance of the building permit.

82. FLOODPLAIN PERMIT. Submit a Floodplain Permit for structures proposed within the floodplain area. A floodplain permit or FEMA issued CLOMR shall be processed prior to the issuance of a Building Permit.

83. SOILS ENGINEER CONSTRUCTION OBSERVATION. During construction, all excavations and grading shall be inspected by the applicant’s soils engineer prior to placement of concrete and/or backfill so they can verify that the actual conditions are as anticipated in the design-level geotechnical report and recommend appropriate changes in the recommendations contained in the report, if necessary. The results of the construction observation and testing should be documented in an “as-built” letter/report prepared by the applicants’ soils engineer and submitted to the City before any building permit is granted.

84. AGREEMENT FOR STORMWATER BEST MANAGEMENT PRACTICES
INSPECTION AND MAINTENANCE OBLIGATIONS. The property owner/ Property Management Company/Owner’s Association shall enter into an agreement with the City for maintenance of the stormwater filtration devices required to be installed on this project. The agreement will specify that certain routine maintenance shall be performed by the property owner or Property 453
Reso. No. XX-26 Page 26 of 28 March 10, 2026
Management Company/Owner’s Association and will specify device maintenance reporting requirements. The agreement will also specify routine inspection requirements, permits and payment of fees. The agreement shall be recorded prior to release of any occupancy permits.

85. Developer shall apply to and obtain the required permits from Ironhouse Sanitation District for new connections to the sewer main in Malicoat Avenue, and to Diablo Water District for new domestic water service connections to the water main in Malicoat Avenue.

86. AS-BUILT PLANS. After completion of the construction of all work, the original plans shall have all changes (change orders and field changes) clearly marked.

The "as-built" plans shall again be signed and "wet-stamped" by the civil engineer who prepared the plans, attesting to the changes. The original "asbuilt" plans shall be reviewed and approved by the Engineering Inspector. A Mylar and AutoCAD disk of the approved "as-built" plans shall be provided to the City before acceptance of improvements.

87. IMPACT FEES. Comply with the requirements of the development impact fees listed below, in addition to those noticed by the City Council in Resolution 85-00 and 08-03. The applicant shall pay the fees in the amounts in effect at the time each building permit is issued.
a. Traffic Impact Fee (authorized by Ordinance No. 14-00, adopted by Resolution 49-03, update Resolution No 91-21);
b. Regional Transportation Development Impact Mitigation Fee or any future alternative regional fee adopted by the City (authorized by Ordinance No. 14-00, adopted by Resolution No. 73-05);
c. Park Land Dedication In-Lieu Fee (adopted by Ordinance No. 03-03, updated Resolution No. 48-17);
d. Park Impact Fee (authorized by Ordinance No. 05-00, adopted by Resolution No. 19-03, updated Resolution No. 48-17);
e. Public Facilities Fee (authorized by Ordinance No. 05-00, adopted by Resolution No. 18-03);
f. Fire Facilities Impact Fee (adopted by Resolution No. 24-21); g. General Plan Fee (adopted by Resolution No. 53-03);
h. East Contra Costa County Habitat Conservation Plan Fee (adopted by Ordinance 6-23).
454
Reso. No. XX-26 Page 27 of 28 March 10, 2026
The applicant should contact the City Engineer prior to constructing any public improvements to determine if any of the required improvements are eligible for credits or reimbursements against the applicable traffic benefit fees or from future developments.

ADVISORY NOTES
The following Advisory Notes are provided to the applicant as a courtesy but are not a part of the conditions of approval. Advisory Notes are provided for the purpose of informing the applicant of additional ordinance requirements that must be met in order to proceed with development.

A. The applicant/owner should be aware of the expiration dates and renewing requirements prior to requesting building or grading permits.

B. The project will require a grading permit pursuant to the Oakley Municipal Code.

C. The applicant shall comply with the requirements of Ironhouse Sanitary District.

D. The applicant shall comply with the requirements of the Diablo Water District.

E. The applicant shall comply with the requirements of the Contra Costa Water District.

F. The applicant shall comply with the requirements of the Contra Costa County Fire Protection District.

G. The applicant shall comply with the requirements of Contra Costa Environmental Health if subject to applicable permits.

H. The applicant shall comply with the requirements of the Building Inspection Division. Building permits are required prior to the construction of most structures.

I. This project may be subject to the requirements of the Department of Fish and Wildlife. It is the applicant’s responsibility to notify the Department of Fish and Wildlife, P.O. Box 47, Yountville, California 94599, of any proposed construction within this development that may affect any fish and wildlife resources, per the Fish and Game Code.

J. The applicant shall be responsible for paying applicable CEQA filing fees for the County Clerk for the Notice of Determination as well as the State Department of Fish and Wildlife’s Filing Fee.

K. This project may be subject to the requirements of the Army Corps of Engineers.

It is the applicant's responsibility to notify the appropriate district of the Corps of Engineers to determine if a permit is required, and if it can be obtained. 455
Reso. No. XX-26 Page 28 of 28 March 10, 2026
PASSED AND ADOPTED by the City Council of the City of Oakley at a meeting held on the 10
th day of March 2026, by the following vote:

AYES:

NOES:

ABSENT:

ABSTENTIONS:

APPROVED:

Hugh Henderson, Mayor
ATTEST:

Kim Snodgrass, City Clerk Date
Exhibit A – Bridgehead Industrial Project Mitigation Monitoring and Reporting Program 456
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

4.1 INTRODUCTION
Section 15097 of the California Environmental Quality Act (CEQA) requires all State and local agencies to establish monitoring or reporting programs for projects approved by a public agency whenever approval involves the adoption of either a “mitigated negative declaration” or specified environmental findings related to environmental impact reports.

The following is the Mitigation Monitoring and Reporting Program (MMRP) for the Bridgehead Industrial Project (proposed project). The intent of the MMRP is to ensure implementation of the mitigation measures identified within the Environmental Impact Report (EIR) for the proposed project. Unless otherwise noted, the cost of implementing the mitigation measures as prescribed by this MMRP shall be funded by the applicant.

4.2 COMPLIANCE CHECKLIST
The MMRP contained herein is intended to satisfy the requirements of CEQA as they relate to the EIR prepared for the proposed project. This MMRP is intended to be used by City staff and mitigation monitoring personnel to ensure compliance with mitigation measures during project implementation. Mitigation measures identified in this MMRP were developed in the EIR.

The EIR presents a detailed set of mitigation measures that will be implemented throughout the lifetime of the project. Mitigation is defined by CEQA Guidelines, Section 15370, as a measure that:
• Avoids the impact altogether by not taking a certain action or parts of an action; • Minimizes impacts by limiting the degree or magnitude of the action and its implementation;
• Rectifies the impact by repairing, rehabilitating, or restoring the impacted environment; • Reduces or eliminates the impact over time by preservation and maintenance operations during the life of the project; or
• Compensates for the impact by replacing or providing substitute resources or environments.

The intent of the MMRP is to ensure the implementation of adopted mitigation measures. The MMRP will provide for monitoring of construction activities as necessary and in-the-field identification and resolution of environmental concerns.

Monitoring and documenting the implementation of mitigation measures will be coordinated by the City of Oakley. The table attached to this report identifies the mitigation measures, the monitoring action for each mitigation measure, the responsible party for the monitoring action, and timing of the monitoring action. The applicant will be responsible for fully understanding and effectively implementing the mitigation measures contained within the MMRP. The City will be responsible for monitoring compliance.

4. MITIGATION MONITORING

AND REPORTING PROGRAM
457
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

4.3 MITIGATION MONITORING AND REPORTING PROGRAM
The following table indicates the mitigation measure number, the impact the measure is designed to address, the measure text, the monitoring agency, implementation schedule, and an area for sign-off indicating compliance.
458
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
Chapter 4.3 – Air Quality, Greenhouse Gas Emissions, and Energy

4.3-2 Conflict with or obstruct
implementation of the
applicable air quality plan
during project operation.

4.3-2 Prior to the approval of building permits, the
project applicant shall implement the following
measures, to the satisfaction of the City of
Oakley Planning Division:

1. All architectural coatings, paints,
finishes and adhesives used within the
project site during project construction
and operations shall be zero-VOC
emitting. Furthermore, all future
leases signed for proposed structures
or operational spaces within the
project site must contain binding
language informing future tenants of
the requirement that only zero-VOC
architectural coatings, paints, finishes
and adhesives may be used within the
project site.

2. The project applicant shall require all
tenants of the on-site industrial uses to
use zero-emission forklifts.

3. The project applicant shall require that
three percent of the medium- and
heavy-duty vehicle fleet be zero
emission by full buildout of the
proposed project. In the event there is
a disruption in the manufacturing of
zero emission vehicles/trucks or that
sufficient vehicles/trucks are not
commercially available for the
intended application, the “clean fleet
requirements” may be adjusted as
minimally as possible by the City’s
City of Oakley
Planning
Division
Prior to the approval
of building permits
459
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
Planning Division to accommodate the
manufacturing disruption or
unavailability of commercially
available vehicles/trucks.

4. Natural gas use on-site shall be
prohibited. Natural gas infrastructure
may be allowed if the applicant
implements alternative methods that
reduce the project’s emissions in an
equally effective or superior manner
as would exist without natural gas
emission infrastructure.

4.3-6 Result in a cumulatively
considerable net
increase of any criteria
pollutant for which the
project region is in nonattainment under an
applicable federal or
state ambient air quality
standard (including
releasing emissions
which exceed
quantitative thresholds
for ozone precursors).

4.3-6 Implement Mitigation Measure 4.3-2. See Mitigation Measure 4.3-2
See Mitigation
Measure 4.3-2

4.3-8 Generate GHG
emissions, either directly
or indirectly, that may
have a significant impact
on the environment, or
conflict with an
applicable plan, policy, or
regulation adopted for

4.3-8(a) Consistent with the BAAQMD’s Buildings
criterion a, prior to issuance of building permits
for the proposed project, the project applicant
shall demonstrate via project design and/or
notation included on project design that natural
gas infrastructure shall be prohibited. Natural
gas infrastructure may be allowed if the
applicant implements alternative methods that
reduce the project’s greenhouse gas
City of Oakley
Planning
Division
Prior to issuance of
building permits
460
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
the purpose of reducing
the emissions of GHGs.
emissions in an equally effective or superior
manner as would exist without natural gas
emission infrastructure, or purchases off-site
mitigation credits or forecasted mitigation units
(“FMUs”) (collectively, “GHG credits”) for
project-related GHG emissions from the
component(s) using natural gas instead of
electric. The emissions from the use of natural
gas shall be calculated by a qualified
professional utilizing BAAQMD-, CARB-, or the
USEPA-approved emissions models and
quantification methods available and submitted
to the City for review and approval, which shall
include third-party review by a qualified
consultant of the City’s selection and be
subject to applicant reimbursement of
consultant costs.

Any and all GHG credits to off-set for the use
of natural gas must be created through a
CARB-approved registry. These registries are
currently the ACR, CAR, and Verra, although
CARB may accredit additional registries in the
future. These registries use robust accounting
protocols for all GHG credits created for their
exchange, including the six currently approved
CARB protocols. This mitigation measure
specifically requires GHG credits created for
the project originate from a CARB-approved
protocol or a protocol that is equal to or more
rigorous than CARB requirements under 17
CCR 95972. The selected protocol must
demonstrate that the GHG-emissions
reductions are real, permanent, quantifiable,
461
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
verifiable, enforceable, and additional.

Definitions of these terms from 17 CCR
95802(a) are provided below.
(1) Real: GHG reductions or
enhancements result from a
demonstrable action or set of actions
and are quantified using appropriate,
accurate, and conservative
methodologies that account for all
GHG emissions sources, GHG sinks,
and GHG reservoirs within the [GHG
credit] project boundary and account
for uncertainty and the potential for
activity-shifting and market-shifting
leakage.
(2) Additional: GHG reductions or
removals that exceed any GHG
reduction, or removals otherwise
required by law, regulation, or legally
binding mandate, and that exceed any
GHG reductions or removals that
would otherwise occur in a
conservative BAU scenario.
(3) Permanent: GHG reductions and
removal enhancements are not
reversible or, when GHG reductions
and GHG-removal enhancements
may be reversible, mechanisms are in
place to replace any reversed GHGemission reductions and GHGremoval enhancements to ensure that all credited reductions endure for at
least 100 years.
462
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
(4) Quantifiable: The ability to accurately
measure and calculate GHG
reductions or GHG-removal
enhancements relative to a project
baseline in a reliable and replicable
manner for all GHG emission sources,
GHG sinks, or GHG reservoirs
included within the [GHG credit]
project boundary, while accounting for
uncertainty. activity-shifting, and
market-shifting leakage.
(5) Verifiable: A [GHG credit] project
report assertion is well-documented
and transparent such that it lends itself
to an objective review by an
accredited verification body.
(6) Enforceable: The authority for CARB
to hold a particular party liable and
take appropriate action if any of the
provisions of this article are violated.

Note that this definition of
enforceability is specific to the Capand-Trade regulation, where CARB holds enforcement authority, but this
measure will employ GHG credits
from the voluntary market, where
CARB has no enforcement authority.

Applying the definition to this
mitigation measure means that GHG
reductions must be owned by a single
entity and backed by a legal
instrument or contract that defines
exclusive ownership.
463
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
Geographic Prioritization of GHG Credits
GHG credits from reduction projects in Contra
Costa County will be prioritized before projects
in larger geographies (i.e., northern California,
California, United States, and international).

The applicant will inform brokers of the
required geographic prioritization for the
procurement of GHG credits. GHG credits from
reduction projects identified in the County that
are of equal or lesser cost compared to the
settlement price of the latest Cap-and-Trade
auction must be included in the transaction.

GHG credits from reduction projects outside of
the County may be purchased if adequate
credits cannot be found in the County or if they
exceed the maximum price identified above.

The economic and geographic analysis
undertaken to inform the selection of GHG
credits must be provided by the applicant to the
County as part of the required documentation
discussed below under Plan Implementation
and Reporting.

Types of GHG Credits
GHG credits may be in the form of GHG offsets
for prior reductions of GHG emissions verified
through protocols or FMUs for future
committed GHG emissions meeting protocols.

Because emissions reductions from GHG
offsets have already occurred, their benefits
are immediate and can be used to compensate
for an equivalent quantity of project-generated
emissions at any time. GHG credits from
FMUs must be funded and implemented within
464
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
5 years of project GHG emissions to qualify as
a GHG credit under this measure (i.e., there
can only be a maximum of 5 years lag between
project emissions and their real-world
reductions through funding a FMU in advance
and implementing the FMU on the ground).

Any use of FMUs that result in a time lag
between project emissions and their reduction
by GHG credits from FMUs must be
compensated through a prorated surcharge of
additional FMUs proportional to the effect of
the delay. Because emissions of CO2 in the
atmosphere reach their peak radiative forcing
within 10 years, a surcharge of 10 percent for
every year of lag between project emissions
and their reduction through a FMU will be
added to the GHG credit requirement (i.e.,

1.10 FMUs would be required to mitigate 1
metric ton of project GHG emissions
generated in the year prior to funding and
implementation of the FMU).

Verification and Independent Review of
GHG Credits
All GHG credits will be verified by an
independent verifier accredited by the ANSI
National Accreditation Board (ANAB) or
CARB, or an expert with equivalent
qualifications to the extent necessary to assist
with the verification. Following the standards
and requirements established by the
accreditation board (i.e., ANAB or CARB), the
verifier will certify the following.
465
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
• GHG credits conform to a CARBapproved protocol or a protocol that is equal to or more rigorous than CARB
requirements under 17 CCR 95972.

Verification of the latter requires
certification that the credits meet or
exceed the standards in 17 CCR
95972.
• GHG credits are real, permanent,
quantifiable, verifiable, enforceable,
and additional, as defined in this
measure.
• GHG credits are purchased according
to the geographic prioritization
standard defined in this measure
under Geographic Prioritization of
GHG Credits.

Verification of GHG offsets must occur as part
of the certification process for compliance with
the accounting protocol. Because FMUs are
GHG credits that will result from future
projects, additional verification must occur
beyond initial certification is required.

Verification for FMUs must include initial
certification and independent verification every
5 years over the duration of the FMU
generating the GHG credits. The verification
will examine both the GHG credit realization on
the ground and its progress toward delivering
future GHG credits. The applicant will retain an
independent verifier meeting the qualifications
described above to certify reductions achieved
466
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
by FMUs are achieved following completion of
the future reduction project.

Conformance with the foregoing requirement
shall be confirmed through review and
approval of building permit plans by the City of
Oakley Planning Division.

4.3-8(b) Consistent with the BAAQMD’s Transportation
criterion c., prior to the approval of project
improvement plans, the applicant shall indicate
that EV capable parking spaces and EV
capable spaces with EVSE shall be installed
throughout the project site consistent with
current CalGreen Tier 2 standards.

Compliance with this measure shall be
ensured by the City of Oakley Planning
Division.

City of Oakley
Planning
Division
Prior to the approval
of project
improvement plans
Chapter 4.4 – Biological Resources

4.4-1 Have a substantial
adverse effect, either
directly or through
habitat modifications, on
special-status plant
species.

Non-East Contra Costa County HCP/NCCP Plants

4.4-1 Prior to the commencement of construction,
surveys and subsequent mitigation, if plants
are found, shall follow the ECCC HCP/NCCP
guidelines for covered plant species, if either
Contra Costa wallflower, Hoover’s cryptantha,
or Antioch Dunes evening-primrose are
identified on-site, the project applicant shall
contact USFWS and CDFW to determine if an
incidental take permit is necessary for potential
project impacts to either species. USFWS and
CDFW shall determine if additional mitigation
is required, or if the requirements of the ECCC
HCP/NCCP would be satisfactory. Written
verification of the USFWS and CDFW
U.S. Fish and
Wildlife
Service
(USFWS)
California
Department of
Fish and
Wildlife
(CDFW)
City of Oakley
Planning
Division
Prior to
commencement of
construction, if
plants are found
If either Contra
Costa wallflower,
Hoover’s
cryptantha, or
Antioch Dunes
evening-primrose,
are identified on-site
467
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
determination shall be provided to the City of
Oakley Planning Division.

4.4-2 Have a substantial
adverse effect, either
directly or through
habitat modifications, on
Crotch’s bumble bee.

East Contra Costa County HCP/NCCP Permit Area
and Non-East Contra Costa County HCP/NCCP
Permit Area

4.4-2 Prior to the commencement of construction, a
qualified entomologist shall conduct a take
avoidance survey for active bumble bee colony
nesting sites in any previously undisturbed
areas, if project construction occurs during the
flying season (March through August).

Surveys shall take place during the flying
season when the species is most likely to be
detected above ground. The surveys shall
occur when temperatures are above 60
degrees Fahrenheit, on sunny days with wind
speeds below eight miles per hour, and at least
two hours after sunrise and three hours before
sunset, as such conditions are the best to
detect bumble bees. Surveyors shall conduct
transect surveys focusing on detection of
foraging bumble bees and underground nests
using visual aids such as binoculars. Survey
results, including negative findings, shall be
submitted for review and approval to the City
of Oakley Planning Division prior to the start of
ground-disturbing activities. If Crotch’s bumble
bees or potential Crotch’s bumble bees are not
detected, further mitigation shall not be
required. If potential Crotch’s bumble bees are
seen, but cannot be identified, the applicant
shall obtain authorization from CDFW to use
non-lethal netting methods to capture bumble
bees to identify the bumble bees to species. If
City of Oakley
Planning
Division
CDFW
Prior to
commencement of
construction, if
project construction
occurs during the
flying season
(March through
August)
468
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
protected bumble bee nests are found, a plan
to protect bumble bee nests and individuals to
ensure no take of Crotch’s bumble bee shall be
developed by a qualified entomologist in
consultation with the CDFW and City of Oakley
Planning Division.

4.4-3 Have a substantial
adverse effect, either
directly or through
habitat modifications, on
California glossy snake
and Northern California
legless lizard.

East Contra Costa County HCP/NCCP Permit Area
and Non-East Contra Costa County HCP/NCCP
Permit Area

4.4-3 Prior to commencement of construction, a
qualified biologist shall conduct coverboard
surveys on the project site for both California
glossy snake and Northern California legless
lizard. Flattened cardboard boxes and pieces
of plywood shall be placed abundantly
throughout the project site one month prior to
the start of project construction. The qualified
biologist shall survey the project site and check
the coverboards regularly to search for the
presence of either species. Coverboards
placed over sandy soil shall be lifted and
carefully hand-raked approximately 15 inches
deep in search of the Northern California
legless lizard. Written verification of survey
results shall be submitted to the City of Oakley
Planning Division.

If neither species is identified on-site, further
mitigation shall not be required and project
construction may proceed, provided all other
applicable permits and authorizations are
obtained. However, if the California glossy
snake or Northern California legless lizard are
identified on the project site, CDFW shall be
City of Oakley
Planning
Division
CDFW
Prior to
commencement of
construction
469
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
contacted for further guidance prior to the start
of project construction. Proof of
correspondence with CDFW and
implementation of CDFW recommendations
shall be submitted to the City of Oakley
Planning Division.

4.4-4 Have a substantial
adverse effect, either
directly or through
habitat modifications, on
western pond turtle.

East Contra Costa County HCP/NCCP Permit Area
and Non-East Contra Costa County HCP/NCCP
Permit Area

4.4-4 A western pond turtle survey shall be
conducted by a qualified biologist, at most, 48
hours prior to construction within the portion of
the North Development Area where
construction activities overlap with wetland
habitats, and within 150 feet of wetlands. The
results of the survey shall be submitted to the
City of Oakley Planning Division. If western
pond turtles or their nests are not found, further
mitigation shall not be necessary.

If a western pond turtle is observed within the
proposed impact area, a qualified biologist
shall relocate the individual to habitat of
equivalent or greater value (e.g., riparian
wetlands or riparian woodlands adjacent to a
perennial creek or intermittent drainage)
outside of the proposed impact area prior to
construction. If a western pond turtle nest is
observed within the proposed impact area, the
nest shall be fenced off and avoided until the
eggs hatch. The exclusion fencing shall be
placed, at a minimum, 25 feet from the nest. A
qualified biologist shall monitor the nest daily
during construction to ensure that hatchlings
City of Oakley
Planning
Division
48 hours prior to
construction within
the portion of the
North Development
Area where
construction
activities overlap
with wetland
habitats, and within
150 feet of wetlands
470
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
do not disperse into the construction area.

Relocation of hatchlings shall occur as
stipulated above, if necessary.

4.4-5 Have a substantial
adverse effect, either
directly or through
habitat modifications, on
Swainson’s hawk.

Non-East Contra Costa County HCP/NCCP Permit
Area

4.4-5(a) Prior to the commencement of construction,
the project applicant shall mitigate for the loss
of suitable Swainson’s hawk foraging habitat
by implementing the following measure:
• One acre of suitable foraging habitat
shall be protected for each acre of
suitable foraging habitat developed
outside of the ECCC HCP/NCCP
Permit Area. Protection shall be
through purchase of mitigation bank
credits or other land-protection
mechanism acceptable to CDFW.

Proof of purchase of mitigation credits as
required per the above mitigation options shall
be provided to the Oakley Planning Division for
review and approval prior to initiation of ground
disturbance for any portion of the project site.

4.4-5(b) The project applicant shall implement the
following avoidance measures for potential
effects on Swainson’s hawk nests during
construction:
• Prior to commencement of
construction during the nesting
season (March 15 through September
15), a qualified biologist shall conduct
City of Oakley
Planning
Division
CDFW
City of Oakley
Planning
Division
CDFW
Prior to
commencement of
construction
During construction
Prior to
commencement of
construction during
the nesting season
(March 15 through
September 15)
471
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
a preconstruction survey, at most, one
month prior to construction to
establish whether occupied
Swainson’s hawk nests occur on or
within 1,000 feet of the area of
proposed construction. The results of
the survey shall be submitted to the
City of Oakley Planning Division. If
occupied nests are not found, then
further mitigation shall not be required.
• If occupied nests are found, project
construction activity shall not occur
within a 1,000-foot buffer zone
distance from the nest unless a lesser
buffer zone is approved by the City in
consultation with CDFW. During the
nesting season, construction activities
shall be avoided within the established
buffer zone to prevent nest
abandonment. Construction
monitoring shall be required to ensure
adherence to the established buffer
zone. If young fledge prior to
September 15, construction activities
can proceed normally without a buffer
zone. If an active nest site is present,
but shielded from view and noise by
other development or other features,
the City may waive this avoidance
measure (establishment of a buffer
zone), if approved by the CDFW.
• All nest trees shall be preserved on
site, if feasible. Nest trees that cannot
be preserved may only be removed
If occupied nests
are found
472
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM
Bridgehead Industrial Project
Impact
Number Impact Mitigation Measures
Monitoring
Agency
Implementation
Schedule Sign-off
outside of the nesting season (i.e.,
nest trees may only be removed
September 16 through March 14), and
subject to the requirements of ECCC
HCP/NCCP Section 6.4.3.

4.4-6 Have a substantial
adverse effect, either
directly or through
habitat modifications, on
white-tailed kite.

East Contra Costa County HCP/NCCP Permit Area

4.4-6(a) Prior to any ground disturbance related to
Covered Activities that occur during the nesting
season for white-tailed kite (March 15 to
August 31), a qualified biologist shall conduct
a preconstruction survey, at most, one month
prior to construction to establish whether whitetailed kite is nesting in trees within or visible from the site. In the event active nests are
found, an initial 300-foot buffer shall be
established around the nest tree. Ground
disturbance related to covered activities within
the buffer shall either be delayed until a
qualified biologist determines nesting is
complete, or until the applicant consults with
the ECCC HCP/NCCP Implementing Entity
and CDFW and implements CDFW-approved
measures to minimize potential disturbance. A
report detailing the methodology and results of
the survey and, if applicable, compliance with
the provisions established herein shall be
submitted for review and approval to the City of
Oakley Planning Division.

Non-East Contra Costa County HCP/NCCP Permit
Area

4.4-6(b) Implement Mitigation Measure 4.4-8.

City of Oakley
Planning
Division
See Mitigation
Measure 4.4-8
Prior to any ground
disturbance related
to Covered
Activities that occur
during the nesting
season for whitetailed kite (March 15
to August 31)
See Mitigation
Measure 4.4-8
473
Final EIR
Bridgehead Industrial Project
January 2026
Chapter 4 – Mitigation Monitoring and Reporting Program