Item 22 2024-01917 Agreements Pertaining to the City of Sacramento Delta Shores Community Facilities District No. 2019-01 (Improvements) Improvement Area No. 1 Special Tax Bonds, Series 2024 (Two-Thirds Vote Required) and Authorize the Issuance of the City of Sacramento Delta Shores Community Facilities District No. 2019-01 (Improvements) Improvement Area No. 1 Special Tax Bonds, Series 2024 and Related Actions — Sacramento City Council, November 19, 2024 (part 4 of 4)

File ID: 2024-01776 10/22/2024 Consent Item 5.
necessary to support the “adequate progress finding” in the approval of new development within a flood hazard zone. Attached is SAFCA’s eighth annual report, the 2024 ULOP Adequate Progress Annual Report intended to serve that purpose (Attachment 3). The annual report concludes that SAFCA is meeting State standards for adequate progress on achieving a 200-year urban level of flood protection. Staff recommends that Council adopt a resolution accepting the SAFCA 2024 ULOP Adequate Progress Annual Report.

Policy Considerations: The 2040 General Plan includes the following goals and policies related to flood protection:

GOAL Environmental Resources and Constraints (ERC-6) Protection of life and property from flooding hazards.

ERC-6.6 Flood Regulations. The City shall continue to regulate new development in accordance with State requirements for 200-year level of flood protection and federal requirements for 100-year level of flood protection.

ERC-6.8 Interagency Levee Management. The City shall coordinate with local, regional, State, and federal agencies to ensure new and existing levees are adequate in providing flood protection and coordinate to achieve local certification of levees for 200-year flood protection by 2025.

Economic Impacts: Not applicable.

Environmental Considerations: Policies to achieve a 200-year level of flood protection were included in the 2040 General Plan and evaluated in the certified Master Environmental Impact Report. Acceptance of the SAFCA 2024 ULOP Adequate Progress Annual Report will enable the City to use this document for future flood-related findings in compliance with state law. Acceptance of this document constitutes an administrative action that will not result in direct or indirect physical changes in the environment, and the action is not a project that requires environmental review under the California Environmental Quality Act (CEQA). See CEQA Guidelines section 15378(b)(5); 15060 (c)(3).

Sustainability: The proposed resolution will reduce flood risk by strengthening the linkage between local land use planning decisions and flood management practices. This resolution would also support the City’s efforts to promote urban infill and redevelopment.

Commission/Committee Action: None.

Rationale for Recommendation: Approval of this resolution will achieve compliance with state law (SB 5 and subsequent amendments) thereby allowing the City to make the required findings related

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File ID: 2024-01776 10/22/2024 Consent Item 5.
to flood protection for approval of developments projects.

Financial Considerations: Not applicable.

Local Business Enterprise (LBE): Not applicable.

Background: In 2007, the California Legislature enacted SB 5 and other interrelated bills in effort to strengthen the link between flood management and local land use planning decisions. Per the new state law, effective on July 1, 2016, cities and counties within the Central Valley have been required to make one of the following findings before approving development agreements, tentative maps, discretionary permits, and ministerial permits for new residences:

1. The existing flood management facilities protect the property to an urban level of flood prote ction, or

2. The city has imposed conditions that will protect the property to an urban level of flood protection, or

3. The local flood management agency has made adequate progress on the construction of a flood protection system to provide an urban level of flood protection by 2025, or

4. The property is in an undetermined risk area.

In most cases the ULOP is defined as protection against a 200-year flood. In the Sacramento region, major improvements to levee systems are ongoing which will provide 200-year flood protection by 2025. In 2016 the City’s Local Flood Management Agency - SAFCA - prepared an ULOP Plan which has aided the City in making the “adequate progress finding” (No. 3 above). SAFCA’s ULOP plan highlights key planned improvements that will provide Sacramento with a 200-year level of flood protection, their costs, revenues to fund them, and a schedule to complete them by 2025. On June 27, 2016, the City Council accepted SAFCA’s ULOP plan (Resolution No. 2016-0226).

In order for the City to continue to rely on making the “adequate progress finding”, the California Government Code § 65007(a)(5) further requires the City to annually report to the Central Valley Flood Protection Board on its efforts in working towards completion of the 200-year flood protection system. Accordingly, SAFCA staff and consultants have prepared the 2024 ULOP: Adequate Progress Annual Report for the City to fulfill Government code requirements which document the following:
· The total project scope, schedule, and cost of the flood protection system have been developed to meet 200-year flood protection.
· That 90% of the required revenues scheduled to be received by that year have been appropriated and is being expended;
· Critical features of the Flood Protection System are under construction and progressing based upon the actual expenditures of the construction budget; and

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File ID: 2024-01776 10/22/2024 Consent Item 5.
· The City has not been responsible for a significant delay in the completion of the system.

In summary the 2024 ULOP adequate progress annual report demonstrates that:
· Over 100% of the revenue scheduled to be received has been appropriated and are currently being expended;
· Critical features of the flood protection system are under construction and progressing based upon the actual expenditures of the construction budget in that:

All Protected Areas - All of the SAFCA protected basins benefit from the Folsom Dam Modifications. The first element of the modifications, the JFP, was largely completed in 2016.Since then the completed project has been turned over to the U.S. Bureau of Reclamation and the Water Control Manual has been formally executed.

Natomas - SAFCA has largely completed its Natomas Levee Improvement Program (NLIP), which improved levees on the north and part of the west perimeter of the basin. The ARCF 2014 Natomas Basin Project is improving the basin’s remaining levees and drainage infrastructure, which are referred to in sequential reaches starting with Reach A from the American River confluence to San Juan Road and moving around the basin in a clockwise direction (USACE, 2022b). Levee construction is underway in Reach A on the SREL. Work on the drained stability berm from City Sump 160 to Gateway Oaks Boulevard will likely be completed in 2026. Work at the RD 1000 Pump Plant 1B should be completed in 2026. ULOP conformance in 2025 will require obtaining a set of record drawings as of 2025 and engineer confirmation that the interim construction condition meets ULDC. USACE Reach B (along the SREL north of San Juan Road to Elverta Road) construction is essentially complete.

Construction of Riverside Pumping Plant in this reach is underway. Levee construction is essentially complete in Reach C (from Elverta Road to the Natomas Cross Canal) with Pritchard Pumping Plant construction scheduled for 2025. Levee construction in Reach D (Natomas Cross Canal South Levee) is complete except at Highway 99. Work continues at Pumping Plant 4, where the remaining electrical equipment is expected to be installed by the end of 2024. The construction contract for Reach E (Pleasant Grove Creek Canal West Levee) was awarded in April 2023. Reaches F and G (Natomas East Main Drainage Canal West Levee) are currently being designed. Construction award is expected in 2025 and completion in 2028. A ULDC exception for freeboard deficiencies may be required in the northern part of Reach F and would require slope hardening features. At this point, it’s unclear whether this will be constructed by the USACE. If not, then SAFCA will need to design and construct, and completion would occur in 2030. Seepage cutoff wells, levee slope flattening, and improvements to two stormwater pumping stations are essentially complete on USACE Reach H (along the NEMDC West Levee from Dry Creek to the Arden Garden Connector). Reach I Contract 1 (American River North Levee west of Northgate Boulevard) included a blanket

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File ID: 2024-01776 10/22/2024 Consent Item 5.
drain constructed under the I-5 overpass and a cutoff wall to the west along the Garden Highway. Both of these components are now complete. Reach I contract 2 will begin construction in 2024. Natomas benefits from the Folsom Dam Modifications discussed above.

Dry Creek North Levee System - No construction projects are required for the Dry Creek North Levee.

Robla Creek to Arcade Creek - In 2017, fourteen relief wells were constructed along the Arcade Creek North Levee. Construction of cutoff walls under SAFCA construction Contract 4355 is now substantially complete. Improvements to the Magpie Creek Diversion Channel as part of ARCF 2016 are known as the Magpie Creek Project. The project is being designed now and will be constructed after 2025. A short reach of the Robla Creek south levee downstream of Dry Creek Road does not meet freeboard, but affects a small area and flooding would be less than three feet deep.

American River North Levee - Cutoff walls along the Arcade Creek South Levee and NEMDC East Levee and were completed by USACE in 2015.

American River South and Sacramento River East Levee - Structural improvements to the Sacramento River East Levee have been designed, and USACE has retained a construction contractor. Contract 1 included work in the Pocket area and a seepage berm near Front Street and Miller Park that is now complete (USACE, 2022a). The second contract along the Sacramento River East Levee in the Pocket area, includes cutoff wall construction, now complete, and relief wells to address seepage and stability issues. Construction Contract 3 is complete. SREL Contract 4 was awarded in 2023 and should be complete in 2024.

Work is also planned north of Miller Park near U.S. Highway 50. Encroachments in the construction footprint were removed by SAFCA. Under its “levee modernization” project, SAFCA acquired a property adjoining the levee and removed encroachments on it preparatory to splitting the property under the flood easement and conveying fee title to the State or City. A voluntary encroachment removal program has been initiated for other affected properties. The Morrison Creek and Beach Lake Levee Resiliency Project 65% design is complete. In 2019, SAFCA also constructed an oak woodland mitigation project to provide a wind-wave buffer for the levee.

South Sacramento Streams Group - Upstream of the UPRR, construction is complete on the Florin Creek channel improvements and the Florin Creek Multi-Use Basin project. This project was intended to meet FEMA 100 year criteria but was not designed to meet ULDC requirements. The Federal Emergency Management Agency (FEMA) issued a LOMR for that work that became effective on March 25, 2019. The City or County may choose to

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File ID: 2024-01776 10/22/2024 Consent Item 5.
investigate whether some areas where 200-year flood depths are below 3 feet may be newly eligible for a ULOP finding based on the project providing 100-year protection. · The City of Sacramento has not been responsible for a significant delay in the completion of the flood protection system.

The annual report shows that SAFCA is meeting State standards for adequate progress on achieving the 200-year Urban Level of Flood Protection (ULOP). On July 18, 2024, this report was reviewed and approved by the SAFCA Board for distribution to and use by local agencies.

Staff recommends the Council pass a resolution accepting SAFCA’s 2024 ULOP Adequate Progress Annual Report. When considering development within a flood hazard zone, the City will rely on SAFCA’s 2016 ULOP Plan and the most recent 2024 annual report as important pieces of substantial evidence in making the “adequate progress finding”.

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RESOLUTION NO. 2024-

Adopted by the Sacramento City Council
Date Adopted

ACCEPTING THE SACRAMENTO AREA FLOOD CONTROL AGENCY 2024 URBAN LEVEL OF FLOOD

PROTECTION ADEQUATE PROGRESS ANNUAL REPORT

BACKGROUND

A. The Central Valley Flood Protection Act of 2008 (the “Act”) prohibits cities and counties, beginning July 1, 2016, from entering into development agreements, approving discretionary permits or ministerial permits that would result in the construction of a new residence, or approving tentative or parcel maps for areas located within a flood hazard zone unless the city or county makes one of the findings set forth in the legislation. (See Government Code sections 65865.5, 65962, and 66474.5.)

B. On March 1, 2016, the City Council adopted Ordinance No. 2016-0012, which makes various changes to the City Code to conform to the Act.

C. One of the Act’s required findings—the “adequate-progress finding”—allows development to proceed within a flood hazard zone if the city or county finds the local flood management agency has made adequate progress (as defined in Government Code section 65007) on the construction of a flood protection system that will result in flood protection equal to or greater than the urban level of flood protection (“ULOP”) in urban or urbanizing areas or the national Federal Emergency Management Agency (“FEMA”) standard of flood protection in nonurbanized areas intended to be protected by the system.

D. The California Department of Water Resources has declared that the adequate-progress finding must be based on the following: a report prepared by the applicable local flood management agency demonstrating adequate progress; a report prepared by a professional civil engineer that documents the data and analysis for demonstrating the property, development project, or subdivision will have an urban level of flood protection at the time when the flood protection system is completed; a report by an independent panel of experts on the review of the report prepared by the professional civil engineer; a response by the professional civil engineer to the comments from the independent panel of experts; the most recent annual report prepared by local flood management agency that was submitted to the Central Valley Protection Board documenting the efforts in working toward completion of the flood protection system; and any additional data and information that cities or counties use to make the finding. (See California Department of Water Resources, Urban Level of Flood Protection Criteria, page 2-10.)

E. In 2016, consistent with these mandates, the City of Sacramento’s (City) local flood management agency—the Sacramento Area Flood Control Agency (SAFCA)—prepared documents to support the adequate-progress. On June 21, 2016, the City Council adopted

Resolution No. 2016-0226 accepting SAFCA’s urban level of flood protection plan and adequate progress baseline report and adequate progress towards an urban level of flood protection engineer’s report.

F. On November 7, 2017, the City Council adopted Resolution No. 2017-0418 accepting SAFCA’s ULOP Adequate Progress Annual Report.

G. On November 20, 2018, the City Council adopted Resolution No. 2018-0445 accepting SAFCA’s ULOP Adequate Progress Annual Report.

H. On October 22, 2019, the City Council adopted Resolution No. 2019-0398 accepting SAFCA’s ULOP Adequate Progress Annual Report.

I. On October 13, 2020, the City Council adopted Resolution No. 2020-0326 accepting SAFCA’s ULOP Adequate Progress Annual Report.

J. On November 9, 2021, the City Council adopted Resolution No. 2021-0328 accepting SAFCA’s ULOP Adequate Progress Annual Report.

K. On October 11, 2022, the City Council adopted Resolution No. 2022-0313 accepting SAFCA’s ULOP Adequate Progress Annual Report.

L. On October 24, 2023, the City Council adopted Resolution No. 2023-0337 accepting SAFCA’s ULOP Adequate Progress Annual Report

M. In 2024, SAFCA has prepared the following to support the adequate-progress finding: the Urban Level of Flood Protection Adequate Progress Annual Report. This document concludes that the levees that protect much of the City do not currently meet ULOP requirements, but SAFCA is meeting the State standards in demonstrating adequate progress towards achieving ULOP in urban or urbanizing areas or the national Federal Emergency Management Agency standard of flood protection in nonurbanized areas for property located within a flood hazard zone, intended to be protected by the system, by 2025.

N. On July 18, 2024, the SAFCA Board of Directors approved the ULOP Adequate Progress Annual Report for distribution to and use by the City and other agencies.

O. The 2024 ULOP Adequate Progress Annual Report is an informational document that describes actions already being undertaken or planned by SAFCA and is not subject to the California Environmental Quality Act (CEQA). The environmental effects of the projects have been addressed at a program level by the 2016 Updated Local Funding Mechanisms for Sacramento Area Flood Control Improvements Subsequent Environmental Impact Report (EIR) and the underlying 2007 Program EIR. Policies to achieve a 200-year level of flood protection were included in the 2040 General Plan and evaluated in the certified Master Environmental Impact Report. The City’s acceptance of the SAFCA 2024 Urban Level of Flood Protection Adequate Progress Annual Report will enable the City to use that document and the ULOP and Engineer’s Report for flood related findings in compliance with State law. Acceptance of these

documents constitutes an administrative action that will not result in direct or indirect physical changes in the environment, and the action is not a project that requires environmental review under the California Environmental Quality Act (CEQA). See CEQA Guidelines sections 15378(b)(5) and 15060(c)(3). The need for additional CEQA compliance for individual projects will need to be considered at the time those projects are advanced.

BASED ON THE FACTS SET FORTH IN THE BACKGROUND, THE CITY COUNCIL RESOLVES AS FOLLOWS:

Section 1. The City Council accepts SAFCA’s 2024 ULOP Adequate Progress Annual Report, attached as Exhibit A and by this reference made a part of this resolution

Section 2. When considering development within a flood hazard zone, the City may rely on the 2024 ULOP Adequate Progress Annual Report, the ULOP and the Engineer’s report referenced in Resolution No. 2016-0226, as substantial evidence that SAFCA has made adequate progress (as defined in Government Code section 65007) on the construction of a flood protection system that will result in flood protection equal to or greater than the urban level of flood protection in urban or urbanizing areas or the national Federal Emergency Management Agency standard of flood protection in nonurbanized areas for property located within a flood hazard zone, intended to be protected by the system.

Table of Contents:

Exhibit A – SAFCA’s 2024 ULOP Adequate Progress Annual Report

2024

Urban Level of Flood Protection

Annual Report

Final – August 2024

1325 J Street Suite 1700
Sacramento, CA 95814

(916) 874-7606

Final 2024 Urban Level of Flood Protection Annual Report 1

TABLE OF CONTENTS

1. Introduction ............................................................................................................................. 2

2. Planned scope, Schedule, and Cost ......................................................................................... 2

2.1 Project Scope .................................................................................................................... 3

2.2 Schedule ............................................................................................................................ 6

2.3 Costs, Revenues, and Appropriations.............................................................................. 10

3. Construction of Critical Features .......................................................................................... 11

4. Delays .................................................................................................................................... 13

5. References for Data Used ...................................................................................................... 14

FIGURES

Figure 1: SAFCA Projects .............................................................................................................. 4

TABLES

Table 1: Timeline for Projects ........................................................................................................ 7

Table 2: ARCF Natomas Basin Project Status Detail ..................................................................... 8 Table 3: ARCF 2016 Project Status Detail ..................................................................................... 9 Table 4: Morrison Creek and Beach Lake Levee Resiliency Project Status Detail ...................... 10 Table 5: Planned Expenditures ($millions, all sources)................................................................ 10 Table 6: Cumulative Planned Expenditures, Actual Appropriations and Actual Expenditures Through 2023-2024 ($millions, all sources) ................................................................................. 11

Final 2024 Urban Level of Flood Protection Annual Report 2

1. INTRODUCTION

California Government Code (CGC) Section 65007(a)(5) requires local agencies to “annually report to the Central Valley Flood Protection Board on the efforts in working toward completion of the flood protection system.” State requirements are further described in the Urban Level of Flood Protection Criteria (ULOP Criteria; DWR, 2013).

This report describes Sacramento Area Flood Control Agency (SAFCA)’s efforts in improving the regional flood protection system over the fiscal year ending on June 30, 2024. Section 5 of the SAFCA Final Urban Level of Flood Protection Plan and Adequate Progress Baseline Report (ULOP Plan) noted that the majority of funding for SAFCA’s projects comes from State and Federal agencies over which SAFCA has no control (SAFCA, 2016).

This annual report only addresses the State Plan of Flood Control (SPFC) facilities. The local land use agencies, acting as floodplain managers, must consider this plan along with their own data to determine whether residual risks, including interior drainage and flood sources not managed by SPFC facilities, affect development projects to such a degree that the projects would be subject to flood protection findings under state law. If a land use agency is required to make a flood protection finding, the finding must be selected from one of those summarized below:

(1) Existing facilities provide ULOP in urban areas or meet the Federal Emergency Management Agency (FEMA) standard in nonurbanized areas;

(2) Conditions on the project will protect it to the applicable standard;

(3) The local flood management agency has made adequate progress on a flood system providing the applicable level of protection. For urban and urbanizing areas protected by project levees, ULOP will be achieved by 2025; or

(4) The property in an undetermined risk area has met ULOP based on substantial evidence in the record.

Development in areas dependent on flood risk reduction projects that are still under construction typically relies on the third finding listed above. In the event that ULOP has not been or cannot be achieved by 2025 under one of the possible findings, the local agency may not approve certain development activities within the affected area. This report is not intended to be a substitute for the independent judgment of the local agencies in adopting their findings.

2. PLANNED SCOPE, SCHEDULE, AND COST

CGC Section 65007(a)(1) requires the local flood management agency to report “the total project scope, schedule, and cost” of meeting ULOP with the agency’s flood protection system. This information was detailed in the ULOP Plan and is summarized here.

Final 2024 Urban Level of Flood Protection Annual Report 3

2.1 Project Scope

The following projects, illustrated in Figure 1, will help attain the Urban Level of Flood Protection in SAFCA’s protected areas.

Folsom Dam Modifications – Folsom Dam Modifications include three related projects: the Folsom Joint Federal Project (JFP), the Folsom Dam Raise Project, and the Folsom Dam Water Control Manual Update.

The JFP is a joint project of the US Bureau of Reclamation, US Army Corps of Engineers (USACE), DWR, and SAFCA. The JFP created a new, gated auxiliary spillway on the east abutment of the dam, enabling the dam to be operated to accommodate a 200-year flood with a discharge of about 115,000 cubic feet per second (cfs) into the lower American River. The design flow accommodated by full use of the dam's river outlets and the auxiliary spillway is 160,000 cfs.

The Folsom Dam Raise Project is increasing the height of the main dam, wing dams, and dikes that contain Folsom Reservoir. Congress has authorized raising the height of the wing dams and dikes by 3.5 feet. This will allow flood operators to store more flood water when forecasted inflows are decreasing (resulting in no imminent threat to the dam) and the additional storage is required to maintain releases from the dam at a level that can be safely contained by the downstream levee system. The project also includes improving the flood gates on the main dam (USACE, 2017).

The Folsom Dam Water Control Manual was updated in 2019 to optimize operations at the dam with the JFP improvements. Once the Folsom Dam Raise Project is completed, the manual will be adjusted again to reflect the increased reservoir storage capacity created by that project.

American River Common Features (ARCF) 2014 Natomas Basin Project (formerly called the Natomas Basin USACE Project) – The Natomas levees are being improved in two phases.

Physical construction of the Natomas Levee Improvement Program (NLIP) Local Project, led by SAFCA, is complete and comprised eighteen miles of improvements to the Natomas Cross Canal south levee and the Sacramento River East Levee. The ARCF 2014 Natomas Basin Project consists of levee improvements around the remainder of the 42-mile Natomas Basin perimeter.

The USACE is planning and implementing the remaining elements (USACE, 2015):

• American River North Levee adjacent to Natomas Basin – widen 2 miles of levee in place and install a seepage cutoff wall through the levee and foundation. • Sacramento River East Levee adjacent to Natomas Basin – construct 5 miles of adjacent levee, 3.3 miles of deep seepage cutoff walls, and 4.3 miles of seepage berms • Pleasant Grove Creek Canal adjacent to Natomas Basin - Widen 3.3 miles of levee in place and install a soil bentonite cutoff wall on the Pleasant Grove Creek Canal West Levee.
• Natomas East Main Drainage Canal (NEMDC)/Steelhead Creek West Levee – widen

12.8 miles of existing levee and install 10.7 miles of cutoff wall.

2022 Urban Level of Flood Protection Annual Report 4

Figure 1: SAFCA Projects

2022 Urban Level of Flood Protection Annual Report 5

• Natomas Cross Canal (NCC) South Levee – complete construction at gaps not remediated as part of NLIP at Bennett and Northern pumping plants and at the State Route 99 closure structure.

ARCF 2016 (formerly called American River Common Features General Reevaluation Report (GRR)) – The ARCF GRR was authorized by Congress in the Water Resources Development Act (WRDA) 2016 and is now known as ARCF 2016. ARCF 2016 features include additional bank protection along the American and Sacramento Rivers; levee height and seepage improvements along Arcade Creek; levee improvements, levee extension, purchase of flowage easements, and channel widening on the Magpie Creek Diversion Channel (MCDC); and changes to the Sacramento Weir and Bypass. On the Sacramento River East Levee downstream of the American River, ARCF 2016 is improving deficient sites with features like the following:

• Slurry cutoff walls to address levee seepage and stability • Rock bank protection to address erosion
• Geotextile slope stabilization to address levee stability • Slope flattening to address levee stability
• Levee raise to address freeboard deficiency

Bank protection along the American River consists of rock revetment with planting berms where feasible. In some cases “launchable rock” trenches, when undermined by erosion, are designed to release rocks onto the erosion surface.

Levee Accreditation Project (LAP) – The LAP is a locally-led construction project that advanced portions of the ARCF 2016 prior to congressional authorization and funding. The LAP includes slurry cutoff walls along the Arcade Creek North Levee, the NEMDC East Levee, and the Arcade Creek South Levee (AECOM, 2015). SAFCA also began design along the Sacramento River East Levee (SREL) downstream of the American River. SAFCA’s design project included stability berms, relief wells, relief well improvements, cutoff walls, and toe drains. The project also included erosion repairs. The USACE took over design efforts along the Sacramento River in 2018 and is leading construction. Structures and vegetation encroaching on the levees will be removed if necessary to meet National Flood Insurance Program (NFIP) standards and the State’s Urban Levee Design Criteria (ULDC).

The southernmost reach of the SREL at its junction with the Beach Lake Levee was evaluated in 2018 (MBK, 2018). MBK recommended improving the Beach Lake Levee and the Sacramento River East Levee downstream of the Beach Lake Levee. The recommendations included raising the Beach Lake Levee to meet ULDC requirements, possibly in conjunction with a riparian wind-wave buffer and DWR improvements to the levees of the McCormack-Williamson Tract.

These improvements can provide ULOP. SAFCA has proceeded with the wind-wave buffer and is designing potential levee improvements consistent with ULDC known as the Morrison Creek and Beach Lake Levee Resiliency Project. In 2022 SAFCA submitted a grant request to FEMA to complete the levee raise with additional nature-based features for resiliency. The grant was awarded in 2024.

Final 2024 Urban Level of Flood Protection Annual Report 6

South Sacramento County Streams Group (SSSG) Project – USACE was the lead agency on this completed project, which consisted of improvements to the Beach Levee, levees and channels along Morrison Creek and its tributaries in South Sacramento, including Florin Creek, Elder Creek, and Unionhouse Creek. Physical work is now complete.

Florin Creek Multi-Use Basin Project – In moderate and larger flood events, the completed Florin Creek Multi-Use Basin Project can store up to 30 acre-feet of Florin Creek flows at Florin Creek Park on the north bank of Florin Creek (ESA, 2014). It provides at least 100-year flood protection within its floodplain in conjunction with the Florin Creek capacity improvements constructed by USACE as part of the South Sacramento County Streams Group Project.

Non-Structural Actions – The state’s ULDC (DWR, 2012) are incorporated by reference in the ULOP Criteria and require many actions that are good practices for the effective operation and maintenance of levee systems to sustain system performance. These actions include such measures as engineering evaluation and documentation, development of security and safety plans, and other items. The non-structural actions and their necessity are described in greater detail in the Adequate Progress Engineer’s Report (MBK, 2016). Ongoing operation, maintenance, repair, and rehabilitation may be considered ongoing non-structural actions that to the extent required are funded by SAFCA and its land use agency and local maintaining agency partners. Progress on these actions is not reported here unless the actions are “critical features” under the meaning of CGC Section 65007(a)(3).

2.2 Schedule

The Urban Level of Flood Protection must be achieved by the year 2025 in order for land use agencies, in approving new development, to make a finding that adequate progress is being made on the construction of a flood protection system (CGC §65865.5, §65962, and §66474.5). Table 1 on the next page lists the schedule for SAFCA projects. Table 2 provides additional detail on the ARCF 2014 Natomas Basin Project, Table 3 provides additional detail on the ARCF 2016 Project, and Table 4 provides additional detail on the Morrison Creek and Beach Lake Levee Resiliency Project.

Final 2024 Urban Level of Flood Protection Annual Report 7

Table 1: Timeline for Projects
Project
Natomas
Levee
System
Dry
Creek
Levee
System
Robla
Creek –
Arcade
Creek
Levee
System
American
River
North
Levee
System
American
River South
and
Sacramento
River East
Levee
System
South
Sacramento
Streams
Levee
System
Construction
Status
Folsom Dam
Modifications
- JFP
JFP
required for
ULOP
Not
required
JFP
required for
ULOP
JFP
required
for ULOP
JFP required
for ULOP
JFP required
for ULOP
JFP complete.

Folsom Dam
Modifications
- Raise
Not
required for
ULOP
Not
required
for
ULOP
Not
required for
ULOP
Not
required
for ULOP
Not required
for ULOP
Not required
for ULOP
Not required
for ULOP
ARCF 2014
Natomas
Basin Project
Required
for ULOP
(Table 2)
Not
required
Not
required
Not
required
Not required Not required See detail in
Table 2
NLIP Local
Project
Required
for ULOP
Not
required
Not
required
Not
required
Not required Not required Complete
ARCF 2016
(elements
required for
200-year
protection)
Provides
resiliency
(lowers
water
surface)
Not
required
Provides
resiliency
Some
elements
required
for ULOP
(Table 3)
Some
elements
required for
ULOP
(Table 3)
Provides
resiliency
See detail in
Table 3
LAP Not
required
Not
required
Required
for ULOP
Required
for ULOP
Not required Not required Complete by
2023
SSSG Not
required
Not
required
Not
required
Not
required
Not required Site
specific*
Complete
Florin Creek
Multi-Use
Basin
Not
required
Not
required
Not
required
Not
required
Not required Site
specific*
Complete
Additional
South
Sacramento
SPFC
Project(s) at
Beach Lake
Levee
Not
required
Not
required
Not
required
Not
required
Some
elements
required for
ULOP
(
Table 4)
Not
Required
See detail in
Table 4
*This plan provides 200-year design flood risk reduction in the South Sacramento Streams area downstream of the Union Pacific Railroad (UPRR), subject to the evaluation of additional south Sacramento SPFC projects. Upstream of UPRR, the land use agency’s determination of whether ULOP is attained will depend on the specific site and development proposal as some areas of residual flooding over 3 feet deep remain. At some sites, the listed projects will help attain ULOP.

Final 2024 Urban Level of Flood Protection Annual Report 8

Table 2: ARCF Natomas Basin Project Status Detail
Element Status
Elements
Required
for ULOP
ULOP Ready
for
Engineer’s
Report*
Reach A
Gateway Oaks Dr
to Farm Rd
Cutoff wall work upstream of I-80 to be
completed in 2024, with the full adjacent
levee to be completed in 2025. Pumping
Plant 1B and drained stability berm from
Sump 160 to Gateway Oaks Drive to be
finished in 2026.

All Complete by
2025**
Reach B
San Juan Rd to
W. Elverta Rd
Levee construction complete. Pumping
Plant #3, and I-5 window complete.

Riverside Pumping Plant underway.

Elkhorn Pumping Plant to begin in 2025.

All Complete by
2025**
Reach C
W. Elverta Rd to
Sankey Rd
Levee construction completed by SAFCA.

Pritchard Pumping Plant to begin
construction in 2025.

All Complete by
2025**
Reach D
Sankey Rd to
Howsley Rd
Levee construction completed by SAFCA.

Highway 99 window work begins 2024.

Pumping Plant #4 to be completed 2024.

All Complete by
2025
Reach E
Howsley Rd to
Sankey Rd
Levee construction began Spring 2023 and
continues in 2024.

All Complete by
2025
Reaches F&G
Sankey Rd to
NEMDC
Pumping Station
Levee construction and slope improvements
to start in 2025 and be completed in 2028
(2030 if landside slope hardening features
aren’t contracted by USACE). Pumping
Plant #6 to begin Summer 2024.

All Construction
underway by
2025.***
Reach H
NEMDC
Pumping Station
to Northgate Blvd
Contract 1 - NEMDC Pump Station to
Arden-Garden: Work has been completed.

Contract 2 - Arden-Garden to Northgate:

Landside levee work and installation of
maintenance road to begin 2024.

All Complete by
2025
Reach I
Northgate Blvd to
Gateway Oaks Dr
Contract 2: Landside levee improvements
and installation of maintenance road to
begin 2024.

All Complete by
2025
Sources: USACE 2022b, SAFCA.
*Reflects status at the time of this report based on the substantial completion of construction features sufficient to complete an Engineer’s Report showing attainment of ULOP. Estimates are subject to change. SAFCA cannot control the schedule of projects led by other agencies. **Construction is expected to be substantially complete by the end of 2025. Final completion and documentation may go into 2026.
***The schedule for reaches F&G is contingent on continued full funding from the federal government and continued actions by the SAFCA Board of Directors authorizing necessary real estate purchases as well as the USACE constructing the landside slope hardening.

Final 2024 Urban Level of Flood Protection Annual Report 9

Table 3: ARCF 2016 Project Status Detail
Element Status Elements Required
for ULOP
ULOP
Attainment*
Sacramento River
East Levee –
Seepage,
Stability, &
Overtopping
Contracts C1 and C2 complete.

Contract C3 complete.

SREL C4 under construction.

All Complete by
2025
Sacramento River
East Levee –
Erosion
Contract C1 complete. C2 to be
constructed in 2023 and 2024.

Only C1 and C2 are
required for ULOP.

Contracts C1
and C2
complete by
2025.

Magpie Creek Construction will begin after
2025.

Areas where flood
depths are greater
than 3 feet and
buildings cannot be
elevated.

Attainment
will be after
2025.

North Area
Streams
Work on Arcade Creek is
complete except for utility
remediation at NEMDC to be
completed by 2025. A short
reach of the Robla Creek South
Levee does not meet freeboard
but the area protected is below the
applicable 3-foot flood depth
criterion LOC-1 in the ULOP
Criteria.

All Complete by
2025. An
isolated
floodplain
with
insufficient
freeboard on
Robla Creek
South levee
may remain.

American River –
Erosion
Contract C1 under construction.

C2 – under construction.

C3A – under construction in 2024

Only C1 and C2 are
required for ULOP.

Complete by
2025.

Sources: USACE 2022c, USACE 2022d, SAFCA
*Attainment status reflects the most current information at the time of this report. These estimates are subject to change. SAFCA cannot control the schedule of projects led by other agencies.

Final 2024 Urban Level of Flood Protection Annual Report 10

Table 4: Morrison Creek and Beach Lake Levee Resiliency Project Status Detail Element Status
Elements
Required for
ULOP
ULOP
Attainment*
Up to 1.7 Foot
Levee and
Floodwall Raise,
Seepage berm
and Pump Station
Improvements
Major pump station maintenance is
planned to start in 2024. Backwater
freeboard will be provided under an
emergency management plan in the
event of a rural levee failure on the
Sacramento River downstream of
Beach Lake Levee.

Required for
ULOP.

SAFCA is
investigating
whether a ULDC
exception is
feasible allowing
interim findings to
be made under the
Urban Level of
Flood Protection
Criteria until
completion of
construction
within five years.

Source: SAFCA
*Attainment status reflects the most current information at the time of this report. These estimates are subject to change. SAFCA cannot control the schedule of projects led by other agencies.

2.3 Costs, Revenues, and Appropriations

System improvement costs, or planned expenditures, were shown in the ULOP Plan as required by CGC Section 65007(a)(1). Revenues to fund those expenditures were also identified pursuant to CGC 65007(a)(2)(A). Table 5 shows combined planned expenditures for all agencies along with actual expenditures. Table 5 demonstrates that expenditures are keeping pace with or exceeding the planned level.

Table 5: Planned Expenditures ($millions, all sources)
Fiscal
Year
2015-
2016
2016-
2017
2017-
2018
2018-
2019
2019-
2020
2020-
2021
2021-
2022
2022-
2023
2023-
2024
2024-
2025
2025-
2026
Original
ULOP
Plan
Costs*
$171.6 $141.0 $111.3 $149.9 $125.5 $125.5 $163.6 $126.6 $126.6 $108.8 $53.9 Actual
Spent** $167.8 $114.3 $123.1 $171.3 $428.3 $644.5 $608.3 $242.7 $199.0 N/A N/A * Original ULOP Plan Costs include capital projects and levee modernization. Values in the 2016 ULOP Plan included system operations and maintenance (O&M) which are no longer shown. ** Actual expenditures are SAFCA actuals plus estimates of other agency expenditures based on funding agreements and/or the progress of the projects.

SAFCA, State, and Federal appropriations also remain consistent with the plan, as shown in Table 6. CGC Section 65007(a)(2)(A) specifies that adequate progress means that 90 percent of the revenues scheduled to be received by that year have been appropriated and are currently

Final 2024 Urban Level of Flood Protection Annual Report 11

being expended. Table 6 shows this requirement has been met with over 100 percent of scheduled revenues appropriated to date. The Federal and State appropriations reflect Congressional authorizations and executed funding agreements. SAFCA appropriations reflect past spending and current year appropriations. Section 3 of this report will describe how these appropriations are being expended.

Table 6: Cumulative Planned Expenditures, Actual Appropriations and Actual Expenditures Through 2023-2024 ($millions, all sources) Agency
Planned
Expenditures*
Actual
Appropriations**
Actual
Expenditures***
Percent
Appropriated
Versus Planned
Expenditures****
Federal $1,489.9 $2,736.8 $2,801.5 >100%
State $870.0 $1,056.6 $867.1 >100%
Local $47.5 $47.4 $47.5 100%
SAFCA $388.7 $538.73 $548.3 >100%
Total $2,796.1 $4,379.53 $4,264.4 >100%
Notes:
*Planned expenses are the planned cumulative capital project expenses from Fiscal Year 2006-2007 through Fiscal Year 2021-2022 as shown in the 2016 ULOP report. ** For purposes of this report, State appropriations represent the amount of executed State funding agreements with SAFCA. Amounts listed as SAFCA appropriations include past spending plus current year appropriations to avoid double-counting unspent appropriations from prior years. *** Actual expenditures are SAFCA actuals plus estimates of other agency expenditures based on funding agreements and/or the progress of the projects. June 2024 expenditures projected and subject to revision.
**** The federal and total percent appropriated exceed 100% because the federal Bipartisan Budget Act of 2018 (Public Law 115-123) included full funding for the American River Common Features and Folsom Dam Raise.

3. CONSTRUCTION OF CRITICAL FEATURES

Pursuant to Government Code Section 65007(a)(3), adequate progress on construction of a flood protection system means that critical features of the system are under construction and progress is indicated by the expenditure of the budgeted construction funds. The preceding section documented that SAFCA expenditures are on track. This section provides a brief summary of the construction progress in each of the SAFCA protected areas. This report does not distinguish between expenditures for physical construction and those for pre-construction permitting, engineering, and design because the cash flow and planned expenditures in the ULOP Plan do not provide line items for construction alone; and the pre-construction work is a planned and necessary component of ULOP Plan implementation.

All Protected Areas – All of the SAFCA protected basins benefit from the Folsom Dam Modifications. The first element of the modifications, the JFP, was largely completed in 2016.

Final 2024 Urban Level of Flood Protection Annual Report 12

Since then the completed project has been turned over to the U.S. Bureau of Reclamation and the Water Control Manual has been formally executed.

Natomas – SAFCA has largely completed its Natomas Levee Improvement Program (NLIP), which improved levees on the north and part of the west perimeter of the basin. The ARCF 2014 Natomas Basin Project is improving the basin’s remaining levees and drainage infrastructure, which are referred to in sequential reaches starting with Reach A from the American River confluence to San Juan Road and moving around the basin in a clockwise direction (USACE, 2022b). Levee construction is underway in Reach A on the SREL. Work on the drained stability berm from City Sump 160 to Gateway Oaks Boulevard will likely be completed in 2026. Work at the RD 1000 Pump Plant 1B should be completed in 2026. ULOP conformance in 2025 will require obtaining a set of record drawings as of 2025 and engineer confirmation that the interim construction condition meets ULDC. USACE Reach B (along the SREL north of San Juan Road to Elverta Road) construction is essentially complete. Construction of Riverside Pumping Plant in this reach is underway. Levee construction is essentially complete in Reach C (from Elverta Road to the Natomas Cross Canal) with Pritchard Pumping Plant construction scheduled for 2025. Levee construction in Reach D (Natomas Cross Canal South Levee) is complete except at Highway 99. Work continues at Pumping Plant 4, where the remaining electrical equipment is expected to be installed by the end of 2024. The construction contract for Reach E (Pleasant Grove Creek Canal West Levee) was awarded in April 2023. Reaches F and G (Natomas East Main Drainage Canal West Levee) are currently being designed. Construction award is expected in 2025 and completion in 2028. A ULDC exception for freeboard deficiencies may be required in the northern part of Reach F and would require slope hardening features. At this point, it’s unclear whether this will be constructed by the USACE. If not, then SAFCA will need to design and construct, and completion would occur in 2030. Seepage cutoff wells, levee slope flattening, and improvements to two stormwater pumping stations are essentially complete on USACE Reach H (along the NEMDC West Levee from Dry Creek to the Arden Garden Connector).

Reach I Contract 1 (American River North Levee west of Northgate Boulevard) included a blanket drain constructed under the I-5 overpass and a cutoff wall to the west along the Garden Highway. Both of these components are now complete. Reach I contract 2 will begin construction in 2024. Natomas benefits from the Folsom Dam Modifications discussed above.

Dry Creek North Levee System – No construction projects are required for the Dry Creek North Levee.

Robla Creek South Levee, NEMDC East Levee, and Arcade Creek North Levee – In 2017, fourteen relief wells were constructed along the Arcade Creek North Levee. Construction of cutoff walls under SAFCA construction Contract 4355 is now substantially complete.

Improvements to the Magpie Creek Diversion Channel as part of ARCF 2016 are known as the Magpie Creek Project. The project is being designed now and will be constructed after 2025. A short reach of the Robla Creek south levee downstream of Dry Creek Road does not meet freeboard, but affects a small area and flooding would be less than three feet deep.

American River North Levee – Cutoff walls along the Arcade Creek South Levee and NEMDC East Levee and were completed by USACE in 2015.

Final 2024 Urban Level of Flood Protection Annual Report 13

American River South and Sacramento River East Levee – Structural improvements to the Sacramento River East Levee have been designed, and USACE has retained a construction contractor. Contract 1 included work in the Pocket area and a seepage berm near Front Street and Miller Park that is now complete (USACE, 2022a). The second contract along the Sacramento River East Levee in the Pocket area, includes cutoff wall construction, now complete, and relief wells to address seepage and stability issues. Construction Contract 3 is complete. SREL Contract 4 was awarded in 2023 and should be complete in 2024.

South Sacramento Streams Group – Upstream of the UPRR, construction is complete on the Florin Creek channel improvements and the Florin Creek Multi-Use Basin project. This project was intended to meet FEMA 100 year criteria but was not designed to meet ULDC requirements.

The Federal Emergency Management Agency (FEMA) issued a LOMR for that work that became effective on March 25, 2019. The City or County may choose to investigate whether some areas where 200-year flood depths are below 3 feet may be newly eligible for a ULOP finding based on the project providing 100-year protection.

4. DELAYS

Adequate progress towards achieving an Urban Level of Flood Protection means, according to Government Code section 65007(a)(4), that “the city or county has not been responsible for a significant delay,” among other things. In SAFCA’s flood protected areas, this standard has been achieved. As Table 6 demonstrated, to date local agencies have exceeded 100% of their planned expenditures for flood protection.

The ULOP Criteria recommend that annual progress reports address “any delay in State funding appropriation consistent with an agreement between a State agency and a local flood management agency.” As demonstrated earlier, State appropriations to date exceed their planned level.

As the December 31, 2025 deadline for ULOP attainment draws near, it is evident that new delays to remaining scheduled construction activities could constrain attainment for affected portions of the subject basins. Should such a delay arise, the affected jurisdiction or jurisdictions would need to choose whether to temporarily suspend development approvals as required by current ULOP legislation, or to seek a legislative extension that may entail the assumption of some liability for future flood damage to any developments approved without ULOP.

Final 2024 Urban Level of Flood Protection Annual Report 14

5. REFERENCES FOR DATA USED

AECOM. 2015. Draft Environmental Impact Report. North Sacramento Streams, Sacramento River East Levee, Lower American River, and Related Flood Improvements Project. State Clearinghouse No. 2008072060. Prepared for Sacramento Area Flood Control Agency. March.

DOF (California Department of Finance). 2019. State budget detail. Department of Water Resources. May Revise. Available at:
http://www.ebudget.ca.gov/2019-
20/pdf/GovernorsBudget/3000/3860.pdf. Accessed 5/31/2019.

DWR (California Department of Water Resources). 2012. Urban Levee Design Criteria. May.

DWR. 2013. Urban Level of Flood Protection Criteria. November.

DWR. 2017. Central Valley Flood Protection Plan 2017 Update. August.

EPS (Economic & Planning Systems, Inc.). 2016. Sacramento Area Flood Control Agency Development Impact Fee Program 2016 Update. Prepared for Sacramento Area flood Control Agency (SAFCA). October.

ESA, 2014. Florin Creek Multi-Use Basin Project. Initial Study with Intent to Adopt a Mitigated Negative Declaration. State Clearinghouse No. 2014032030. Prepared for Sacramento Area Flood Control Agency. March.

MBK (MBK Engineers). 2016. Sacramento Area Flood Control Agency Adequate Progress Towards an Urban Level of Flood Protection Engineer’s Report. Prepared for SAFCA.

MBK. 2018. Status of ULDC Evaluation of the Beach Lake Levee. Memo to Pete Ghelfi, SAFCA, from Ric Reinhardt, P.E., MBK Engineers.

SAFCA. 2016. Sacramento Area Flood Control Agency Final Urban Level of Flood Protection Plan and Adequate Progress Baseline Report. Prepared for the City of Sacramento and parts of Sacramento and Sutter counties. June 10.

SAFCA. 2017. 2017 Urban Level of Flood Protection Adequate Progress Annual Report.

Prepared for the City of Sacramento and parts of Sacramento and Sutter counties. August 9.

USACE (United States Army Corps of Engineers). 2015. American River Common Features General Reevaluation Report. Final Report. Sacramento District. December. Available at:
http://www.spk.usace.army.mil/Portals/12/documents/civil_works/CommonFeatures/Final_ARC F_GRR_Jan2016.pdf. Accessed June 3, 2016.

USACE. 2017. Record of Decision. Folsom Dam Raise Project. Placer, Sacramento, and El Dorado Counties, California. December 18. Available at:
https://www.spk.usace.army.mil/Portals/12/documents/civil_works/JFP/Raise/ROD_FolsomDam _Raise_Signed_18Dec2017.pdf?ver=2018-03-09-124144-317. Accessed 7/31/2019.

Final 2024 Urban Level of Flood Protection Annual Report 15

USACE. 2022a. Sacramento Levee upgrades. Available at:
https://www.spk.usace.army.mil/Missions/Civil-Works/Sacramento-Levee-Upgrades/ . Accessed
5/18/2022.

USACE. 2022b. Natomas Basin. Available at: https://www.spk.usace.army.mil/natomas/ .

Accessed 5/18/2022.

USACE. 2022c. Unpublished schedule information on American River Common Features 2016.

May 19.

USACE. 2022d. Unpublished schedule information on Lower American River erosion contracts.

June 17.

WSP Parsons Brinckerhoff (PB). 2016. Engineer’s Report. Sacramento Area Flood Control Agency. Consolidated Capital Assessment District No. 2. June 13.

Office 916-874-7606
Fax 916-874-8289
1325 J Street, Suite 1700
Sacramento, CA 95814

August 22, 2024

Mr. Remi Mendoza Mr. Kevin Siu
Planning Division Department of Water Resources
City of Sacramento County of Sacramento
300 Richards Blvd, 3rd Floor 827 Seventh St, Room 301
Sacramento, CA 95811-0218 Sacramento, CA 95814

Mr. David Tomm
Public Works
County of Sutter
1130 Civic Center Blvd.

Yuba City, CA 95993

Subject : URBAN LEVEL OF FLOOD PROTECTION ADEQUATE PROGRESS

ANNUAL REPORT

Dear Sirs:

Enclosed please find the Sacramento Area Flood Control Agency (SAFCA) 2024 Urban Level of Flood Protection Annual Report. This report identifies SAFCA’s progress on achieving the Urban Level of Flood Protection (ULOP) for State Plan of Flood Control (SPFC) facilities within our jurisdiction. On July 18, 2024, the SAFCA Board of Directors approved Resolution No. 2024-056 approving distribution of this report. Because this progress is germane to the authorities vested in your agency, I encourage your agency to use the information provided herein in conjunction with your own data and judgment in reporting annual progress to the Central Valley Flood Board prior to September 30.

SAFCA staff recommend a close reading of the enclosed report. No local or state delays in ULOP funding have occurred, and SAFCA, State, and Federal appropriations remain consistent with the ULOP plan. SAFCA is working diligently with our state and federal partners to have major ULOP projects substantially complete by the December 2025 deadline and will continue to coordinate with you, especially as we begin work on an interim Engineer’s report in early 2025.

2024 ULOP Annual Report

Page 2 ends

SAFCA appreciates the opportunity to work with your agency on flood matters of mutual interest and looks forward to continued cooperation in achieving adequate progress in this and future years.

Sincerely,

Gary Bardini, P.E.

Director of Planning

Enclosure

cc (w/o enclosure):

Jason Campbell
Melanie Saucier
Mick Klasson

Appraisal Review
Delta Shores CFD No. 2019-01 (Improvement Area No. 1)
SWQ of Interstate 5 and Cosumnes River Boulevard
Sacramento, California 95832
BBG File #0124021152
Prepared For
Mr. Bill Sinclair
Real Property Agent
City of Sacramento, Department of Public Works
915 “I” Street, 2nd Floor
Sacramento, CA 95814
Appraisal Review Report Date
November 14, 2024
Prepared By
BBG, Inc., Northern California
Sacramento Office
1708 Q Street
Sacramento, CA 95811
Client Manager: Scott Beebe, MAI
Ph: (916) 949-7360
BBG Website
bbgres.com

November 14, 2024

Mr. Bill Sinclair
Real Property Agent
City of Sacramento, Department of Public Works
915 “I” Street, 2nd Floor
Sacramento, CA 95814

Re: Appraisal Review
Delta Shores CFD No. 2019-01 (Improvement Area No. 1)
SWQ of Interstate 5 and Cosumnes River Boulevard
Sacramento, California 95832

Prepared by John E. Carrothers, MAI
BBG File #0124021152
Dear Mr. Sinclair:

BBG is pleased to provide this appraisal review of the appraisal report prepared completed by John Carrothers, MAI of Smith & Associates pertaining to the Delta Shores CFD No. 2019 -01 (Improvement Area No. 1) commonly referred to as the CFD. The appraisal report date is November 14, 2024, with a date of value of September 25, 2024. The attached review report incorporates by reference the entire appraisal (152 pages, plus the Addenda), referred to as “the Report”.

The purpose of the attached appraisal review is to provide my opinion as to the completeness, accuracy, adequacy, relevance, and reasonableness of salient aspects of the written appraisal report in compliance with Review Standards 3 and 4 of the Uniform Standards of Professional Appraisal Practice (USPAP 2024).

I assessed the appraisal’s compliance with Standards 1 and 2 of the USPAP and the Appraisa l Standards for Land Secured Financing, published by the California Debt and Investment Advisory Commission (CDIAC).

Summary Observations and Conclusions
After my review of the Report, it is my opinion the report under review complies with Standards 1 and 2 of USPAP and the appraisal regulations issued in connection with CDIAC. Further, the market value opinions are consistent with the relevant market conditions and the market data presented in the report as of the date of value.

My opinions are summarized as follows:
▪ The material under review is complete.
▪ The data used is adequate and relevant.

Mr. Sinclair
November 14, 2024

Page 2 ends

▪ The methods and techniques used are appropriate.
▪ The value opinions stated in the Report are adequately supported and are credible, given the data and analyses presented. However, I express no opinions of value of the subject properties. ▪ In my judgment, the Report complies with the Uniform Standards of Professional Appraisal Practice.

I limited my review work solely to a review of the Report. I did not gather any substantial additional data.

I inspected the subject property on September 27, 2024, including the market data. Further, I did not complete any independent verification of the market data or market information.

Thank you for the opportunity to provide this appraisal review. Please contact me should you have questions.

Respectfully submitted,

BBG

Scott Beebe, MAI
Certified General Real Estate Appraiser
California License #AG015266

Mr. Sinclair
November 14, 2024

Page 3 ends

TABLE OF CONTENTS

TRANSMITTAL LETTER

TABLE OF CONTENTS

INTRODUCTION
Reviewer Identification 4
Client and Intended Users of the Review 4
Intended Use and Purpose of the Review 4
Appraisers 5
Subject Property Identification 5
Appraisal Report Information and Conclusions 7
Scope of Work 8

APPRAISAL REVIEW
Introduction and Factual Descriptions 9
Subject Property Descriptions 10
Market Analysis and Highest and Best Use 10
Valuation Methodology 11
Cost Approach 11
Sales Comparison Approach 12
Income Capitalization Approach 13
Reconciliation, Final Value Conclusion & Insurable Replacement Cost 14 Additional USPAP and CDIAC Appraisal Standards 16

APPENDIX
A – Assumptions and Limiting Conditions
B – Certification
C – Standard Assumptions and Limiting Conditions
D – Qualifications of Reviewer

Mr. Sinclair
November 14, 2024

Page 4 ends

INTRODUCTION

REVIEWER IDENTIFICATION

Company:

BBG
1708 Q Street
Sacramento, CA 95811

Reviewer: Scott Beebe, MAI
California Certified General Real Estate
Appraiser, AG 015266
Expires February 10, 2025
916-949-7360
[email protected]

Date of Appraisal Review: November 14, 2024

CLIENT AND INTENDED UERS OF THE REVIEW:

Review Client:

Bill Sinclair, City of Sacramento

Review Intended Users: City of Sacramento, CFD finance team and prospective bond investors. No other users are intended.

INTENDED USE AND PURPOSE

OF THE REVIEW

Intended Use:

The intended use of this appraisal review is to assist the client’s reliance on the Report for underwriting the bond financing secured by the subject property described in the Report. No other uses are intended.

Purpose of the Review: The purpose of the appraisal review is to develop and report a credible opinion of the quality of another
appraiser’s work while considering the completeness,
accuracy, adequacy, relevance, and reasonableness of
the conclusions in the Report. This review is to
determine if the results of the work under review are
credible for the intended users’ intended use.

I a lso assessed the appraisal’s compliance with
Standards 1 and 2 of the Uniform Standards of
Professional Appraisal Practice (USPAP) and the
appraisal regulations issued in connection with CDIAC. I inspected the subject property on September 27, 2024
including the market data. Further, no independent
Mr. Sinclair
November 14, 2024

Page 5 ends

verification of the market data or market information
was made. This review report was completed and
written in conformance with Standard s 3 and 4 of
USPAP, respectively.

APPRAISER

Company:

Smith & Associates
111 Woodmere Road, Suite 140
Folsom, CA 95630

Appraiser: John E. Caruthers, MAI
State Certified General Real Estate Appraiser,
California AG 014187
Expiration April 11, 2025
916-357-5860
[email protected]

SUBJECT PROPERTY IDENTIFICATION
The real property in the appraisal report under review is:

The subject property is located along the southwest quadrant of Interstate 5 and Cosumnes River Boulevard in the City of Sacramento. The property includes a total land area of 107.22 acres generally allocated among 77.46 acres for 348 lots, south of Cosumnes River Boulevard, as well as a development site of 8.851 acres, respectively, north of Cosumnes River Boulevard. The current zoning for the development site north of Cosumnes River Boulevard includes both HDR and MDR. The remaining land area represents acreages for non-revenue generating land uses including Parks, Detention Basin, and Open Space.

Property Address: SWQ of Interstate 5 and Cosumnes River Boulevard Sacramento, CA 95832

Mr. Sinclair
November 14, 2024

Page 6 ends

Assessor’s Parcel Numbers and Owners:

PROJECT AREA/OWNER # LOTS APNs
MDR-1 110 053-0220-019 thru 128
KB Home
LDR-1 81 053-0220-001 thru 018
KB Home 053-0230-015 thru 077
LDR-2 77 053-0250-001 thru 004,
Meritage Homes 053-0250-047 thru 092,
053-0240-001 thru 008,
053-0240-045 thru 051
053-0230-001 thru 004
LDR-2 80 053-0250-005 thru 046,
M&H Realty 053-0240-009 thru 022,
053-0240-031 thru 044,
053-0230-005 thru 014
HDR & MDR SITE 8.851 AC 119-0010-026
M&H Realty (portion)

The description above includes all of the taxable parcels within the boundaries of the Delta Shores CFD No. 2019 -1, Improvement Area 1. In addition, there are non -revenue parcels included in the district.

Land Area:

The subject property includes 348 residential lots and

8.851 acres of HDR/MDR acres. Site development is
nearly completed for this project as of the effective date of valu e. In addition, home development has
commenced including the completion of 5 model homes
(Portion of MDR-1 and LDR-1).

Improvements:

The property has 5 model homes under construction
(Portion of MDR-1 and LDR-1). The homes range in size
from 1,685 to 2,693 SF. The proposed base pricing
ranges from $605,000 to $755,990.

Mr. Sinclair
November 14, 2024

Page 7 ends

APPRAISAL REPORT INFORMATION AND CONCLUSIONS

Date of the Report: November 14, 2024

Date of Inspection: September 27, 2024

Effective Date of Market Value: September 27, 2024

Interest Appraised: Fee simple estate

Report Type: The appraisal report is identified as an Appraisal Report in accordance with Standards Rule 2 -2(a) of the Uniform
Standards of Professional Appraisal Practice.

Valuation Approaches: Sales Comparison Approach, Subdivision Development Method, Land Residual Analysis and Valuation per declared cost reported under the permit for the model homes.

Market Value Descriptions: The market values estimated for the subject properties as of the date of inspection.

Opinions of Market Value: Ownership/ Description/ Value by Ownership KB Home, MDR-1, 107 lots and 3 models: $22,150,000
KB Home, LDR-1, 79 lots and 2 models: $20,636,000
Meritage Homes, 77 lots: $19,700,000
M & H Realty, 80 lots: $19,615,000
M & H Realty, 8.851 acres MDR/HDR: $6,550,000
Total: $88,651,000

Appraisal Client: Mr. Bill Sinclair, City of Sacramento

Appraisal Intended User: City of Sacramento, CFD finance team and prospective bond investors.

Appraisal Intended Use: The intended use of this report is to reasonably validate the estimated value -to-lien coverage for purposes for a land - secured bond financing. The appraisal is not intended for any other use or users.

Mr. Sinclair
November 14, 2024

Page 8 ends

SCOPE OF WORK

The Client/Reviewer agreed upon Scope of Work for this review assignment outlined as follows:

• I read the submitted appraisal report in its entirety.

• I determined the report’s compliance with Standards 1 and 2 of the Uniform Standards of Professional Appraisal Practice (USPAP) and compliance with CDIAC appraisal requirements.

• I developed opinions as to the completeness, accuracy, adequacy, relevance, and reasonableness of various salient aspects of the written report.

• I did not provide my own market value opinion but during the review period I did provide comments and questions based on the draft reports provided by the Client prepared by the appraiser .

• I determined the reliability of the market values reported in the appraisal based solely on the contents of the appraisal report under review and generally accepted appraisal methodology and valuation techniques.

• I inspected the subject property. I reviewed the market data. Further, no independent verification of the market data or market information was made.

• I completed this written review report in compliance with Standard 4 of the Uniform Standards of Professional Appraisal Practice (USPAP).

Mr. Sinclair
November 14, 2024

Page 9 ends

APPRAISAL REVIEW CHECKLIST

INTRODUCTION AND FACTUAL DESCRIPTIONS YES NO N/A

1. Letter of transmittal accurately reflects the contents of the report? X

2. Is the property adequately identified through legal description, parcel number(s), parcel map, etc.?
X

3. Does the appraisal correctly define and identify the real property interest appraised?
X

4. Are the dates of inspection, date of report and effective date of value stated? If applicable, are retrospective and prospective values properly i dentified per USPAP?
X

5. Does the appraisal provide a correct definition of market value and cite the source of the definition?
X

6. Are the intended use (s), client/intended user(s) and scope of work of the appraisal identified, including a description of the extent of collecting, confirming, and reporting data?
X

7. Are all applicable extraordinary assumptions and/or hypothetical conditions disclosed and presented in a clear and conspicuous manner in the report? X

8. Is a statement of ownership history of the subject property provided, and is any listing, option, or pending contract disclosed and discussed? X

9. Are the discussion and analyses of regional and neighborhood data and trends relevant and adequate considering the scope of the assignment?

X
Comments:

The introduction and factual descriptions in the General Information section sufficiently present the subject identification, history, current ownership and sale history, the facilities and costs the City will finance by way of bonds issued on behalf of a CFD, and the purpose and use of the appraisal. The correct property rights appraised, and the market value definitions are provided. Additionally, a separate section reports the developer’s marketing and development strategy (refer to report page 106).

The Report provides a detailed Scope of Work section. The Report employs Extraordinary Assumptions (EAs) and Hypothetical Conditions (HC) . Given the stated scope of work and the intended use, the assumptions and conditions are appropriate. I recommend that appraisal user carefully review the assumptions and conditions that are premises for the valuation.

The Regional and Neighborhood analyses are detailed and relevant. A history of the subject is included. The approved entitlements as of September 25, 2024 are reported and analyzed.

Mr. Sinclair
November 14, 2024

Page 10 ends

SUBJECT PROPERTY DESCRIPTIONS YES

NO N/A

1. Is the site description adequate, including size, shape, frontage, drainage, and discussion of surrounding properties? X

2. Are easements, flood plain, wetlands, earthquake zone, and/or other encumbrances adequately identified and addressed? X

3. Are environmental hazards identified and addressed or standard disclaimer included? X

4. Are zoning and tax analysis adequately addressed? X

5. Is the description of improvements adequate, including photographs, site plan and drawings of improvements? X

6. Is improvement conformance with zoning considered? X

Comments: The appraisal included detailed description and analysis of the physical, legal, environmental characteristics of the site and improvements. This description as reported beginning on page 30 was adequately reported.

MARKET ANALYSIS AND HIGHEST AND BEST USE

YES

N/A

1. Is the historical performance of the market presented and analyzed? X

2. Is the position (such as design of the project or the marketing efforts) of the subject property within the market considered? X

3. Is the level of market analysis compliant with the terms of the engagement and the size and complexity of the subject property?

4. Does the appraisal follow the four criteria of highest and best use an alysis? X

5. Is highest and best use as vacant analyzed? X

6. Is highest and best use as improved (proposed) analyzed? X

7. Are any probable physical, legal, or external changes considered, such as a pending change in zoning that may impact property value? X

8. Does the appraisal provide an adequate discussion of the potential for an expansion of, or changes to, the existing improvements?

X
Comments: The appraisal beginning on page 78 included detailed market analysis including pricing, absorption, market capture, real estate supply and demand factors and trends. The subject pricing and absorption conclusions were consistent with the Market Study report prepared by John Burns Real Estate dated J uly 23, 2024 (located in addenda).

Mr. Sinclair
November 14, 2024

Page 11 ends

VALUATION METHODOLOGY YES NO N/A

1. Are exclusions of one or more of the three traditional approaches to value properly disclosed? X

2. Is the rationale for the exclusion of one or more of the three traditional approaches to value reasonable? X

COST APPROACH YES NO N/A

1. Are land sales current, comparable, and appropriately adjusted? X

2. Is the land value conclusion logical and reasonable? X

3. Is basis for the replacement cost estimate properly documented? X

4. Does the estimated cost to complete proposed improvements include leasing expenses and/or holding cost during construction?

5. Are all forms of accrued depreciation considered and supported? X

6. Does the appraisal account for and adequately support entrepreneurial profit obtained from non-confidential or proprietary sources? X

7. Is the cost approach conclusion logical and reasonable? X

Comments: The report deemed the cost approach to not be applicable to the development of credible assignment results for the valuation analyses. Nevertheless, parts of the appraisal utilize cost estimates that have support and appear credible (supported by developer’s budgets and costs, cost comparables, and a cost service) for the cost estimates for development of the land residuals /extraction analysis . The costs used appear reasonable and supported.

Mr. Sinclair
November 14, 2024

Page 12 ends

SALES COMPARISON APPROACH (SCA) YES NO N/A

1. Are the land sales current and reasonably comparable? X

2. Are the land sales sufficiently identified and the descriptions adequate? X

3. Is the appropriate unit of comparison analyzed? X

4. Is the reasoning and analysis employed adequate and are the sales properly adjusted? X

5. Is the final value conclusion of the sales comparison approach logical and reasonable? X

Comments
(SCA) LDR &
MDR SFR lots:

The appraisal utilized nine land sale comparables to arrive at finished lot values. The quality of the comparable land sale data was good. The sales has unadjusted prices from $189,536 to $470,000 per lot. Appropriate adjustments were applied to the sale s with final adjusted prices from $292,734 to $340,200 per lot with an average of $316,297 and a median of $312,985. A Benchmark Value of $310,000 was concluded which included building permit fees. Refinements were applied to the Benchmark Value to arriv e at finished lot values for each product type.

These conclusions were as follows from this approach:

LDR -1 lots: The 81 LDR lots were valued at $250,000 per lot from this approach. This value is reasonable for the minimum lot size of 5,700 SF.

LDR -2 lots: The 77 LDR lots were valued at $260,000 per lot from this approach. This value is reasonable for the minimum lot size of 6,825 SF.

MDR lots: The 110 MDR lots were valued at $186,000 per lot from this approach. This value is reasonable for the minimum lot size of 3,230 SF.

Comments
(SCA)

HDR/MDR
acres:

The 8.851 acres (two parcels) of medium and high density acreage was valued at $50,000 per achievable unit. The estimated achievable units for th ese sites was 131 units. The quality of the comparable land sale data was good. This valuation was based on three comparable land sales. The sales has prices from $44,555 to $52,291 per unit. square foot. Appropriate analysis was performed to arrive at the per unit value conclusion. The valuation of this land type was supported and reasonable.

Mr. Sinclair
November 14, 2024

Page 13 ends

INCOME APPROACH YES NO N/A

1. If Income Approach excluded, was proper justification provided?

2. Is Income Approach methodology adequately summarized? X

3. Is Subject Revenue analyzed and estimated? X

4. Is Lot absorption analyzed and estimated? X

5. Are remaining lot development construction costs analyzed and estimated?
X

6. Are Holding and Sales costs detailed and analyzed? X

7. Is the Discount Rate and Profit supported and analyzed? X

8. Were inputs to the discounted cash flow reasonable? X

9. Were all calculations in Income Approach model mathematically correct ? X

10. Were appropriate deductions and discounts applied or accounted for in the analysis?
X

11. Is the final value estimates consistent with the data presented? X

Comments
(LDR & MDR
SFR lots):

An Extraction and Discounted Cash Flow analyses were performed to supplement the Sales Comparison Approach in the valuation of the finished lot s. The inputs , quality of data and assumptions regarding the above referenced factors were adequately considered. These conclusions were as follows from this approach:

LDR -1 lots: The Extraction and Discounted Cash Flow methods arrived at finished lot value of $235,000 per lot for these 81 lots. This was reconciled with the Sales Comparison Approach $250,000 per lot) to arrive at a final lot value of$240,000.

LDR -2 lots: The Extraction and Discounted Cash Flow methods arrived at finished lot value of $258,000 per lot for these 77 lots. This was reconciled with the Sales Comparison Approach $260,000 per lot) to arrive at a final lot value of $260,000.

MDR lots: The Extraction and Discounted Cash Flow methods arrived at finished lot value of $190,000 per lot for these 110 lots. This was reconciled with the Sales Comparison Approach $186,000 per lot) to arrive at a final lot value of $188,000.

Mr. Sinclair
November 14, 2024

Page 14 ends

RECONCILIATION, FINAL VALUE CONCLUSIONS YES NO N/A

1. Is the estimated exposure time disclosed and reasonable? X

2. Is the final value appropriately divided between realty and non-realty items? Is the impact of their inclusion/exclusion on the estimate of value discussed? X

3. Are final value estimates consistent with the data presented, and sufficient documentation included to assess the appraisal's logic, reasoning, judgment, and analysis?
X

4. Is the as-is value appropriately analyzed? X

Comments (KB
Home lots &
Homes):

KB has 107 MDR-1 lots valued at $188,000 per lot and 70 LDR-1 lots valued at $240,000 per lot. Adjustments to the valuation included the deduction of the remaining construction cost and addition of the permits paid. The model homes were valued separatel y using the lot value plus cost valuation declared with the building permit. The following was concluded for the KB ownership:

Market Value (KB Home – MDR-1)
MDR-1 - 107 Lots $188,000/lot $20,116,000
Less: Remaining Offsites -$460,693
Plus Permits $1,017,069
Indicated Value $20,672,376
Rounded $20,670,000

Plus:

Lot 323 Home $455,000
Lot 324 Home $505,000
Lot 325 Home $520,000
Aggregate Value $22,150,000

Market Value (KB Home - LDR-1)
LDR-1 - 79 Lots $240,000/lot $18,960,000
Less: Remaining Offsites -$339,238
Plus: Permits $908,461
Indicated Value $19,529,223
Rounded $19,530,000

Plus:

Lot 226 Home $620,000
Lot 227 Home $486,000
Aggregate Value $20,636,000

Mr. Sinclair
November 14, 2024

Page 15 ends

Comments
(Meritage
Homes lots):

Meritage Homes has 77 LDR-2 lots valued at $260,000 per lot. Adjustments to the valuation included the deduction of the remaining construction cost. The following was concluded for the Meritage Homes ownership:

Market Value (Meritage Homes - LDR-2)
LDR-2 - 77 Lots $260,000/lot $20,020,000
Less: Remaining Offsites -$322,485
Indicated Lot Value $19,697,515
Aggregate Value $19,700,000

Comments
(M&H Realty
lots):

M&H Realty has 80 LDR -2 lots valued at $260,000 per lot. Adjustments to the valuation included the deduction of the remaining construction cost. The following was concluded for the M&H Realty ownership:

Market Value (M&H Realty - LDR-2)
LDR-2 - 80 Lots $260,000/lot $20,800,000
Less: Remaining Offsites -$1,184,619
Indicated Value $19,615,381
Aggregate Value $19,615,000

Market Value (M&H Realty - HDR & MDR)

8.851 acre - 131 Units $50,000/lot $6,550,000

REVIEWER’S CONCLUSIONS

Summary Comments:

The appraisal appropriately valued the subject based on the intended use and methods peers would use and users of the service would expect.

The aggregate or cumulative conclusion of $88,651,000 appears reasonably supported by the market data and analyses included within the appraisal.

The reported extraordinary assumptions applied in the appraisal were reasonable.

Mr. Sinclair
November 14, 2024

Page 16 ends

ADDITIONAL USPAP & FIRREA REPORTING REQUIRMENTS

YES

N/A

1. Are general assumptions and limiting conditions reasonable? X

2. Are the extraordinary assumptions and hypothetical conditions reasonable and prominently disclosed? X

3. Is certification signed by appraiser(s) who prepared the report? X

4. Are qualifications included in the report for all appraisers providing a significant contribution to the completion of the appraisal assignment? X

5. Does the appraisal conform to generally accepted appraisal standards as evidenced by the USPAP and the appraisal regulations of CDIAC? X

6. Is appraisal written with sufficient information and analysis to support the institution's decision to engage in the transaction? X

7. Does the appraisal analyze and report appropriate deductions and discounts for proposed construction or renovation, partially leased buildings, non - market lease terms, and tract developments with unsold units? X

8. Did state licensed or certified appraisers prepare the appraisal? X

9. If information was unavailable, is that fact disclosed and explained in the report? X

10. Are engagement instructions and other appraiser correspondence included in the report? X

11. Are third party studies well supported, incorporated into the appraisal or are the conclusions of the third -party studies modified with supporting data by the appraiser to justify the changes?

Comments: In my opinion, given the reasons put forth previously in this review, the appraisal report complies with USPAP and the CDIAC appraisal requirements.

This review is subject to the Assumptions and Limiting Conditions contained in this report. The reviewer’s compensation is not contingent on an action or event result from the analysis, opinions, or conclusions in or the use of this report.

Certification
We certify that, to the best of our knowledge and belief:

1. The statements of fact contained in this report are true and correct.

2. The reported analyses, opinions, and conclusions are limited only by the reported assumptions and limiting conditions, and are our personal, impartial, and unbiased professional analyses, opinions, and conclusions.

3. We have no present or prospective interest in the property that is the subject of this report and no personal interest with respect to the parties involved.

4. We have performed prior services, as an appraiser regarding the property that is the subject of this report within the three-year period immediately preceding acceptance of this assignment.

5. We have no bias with respect to the property that is the subject of this report or to the parties involved with this assignment.

6. Our engagement in this assignment was not contingent upon developing or reporting predetermined results.

7. Our compensation for completing this assignment is not contingent upon the development or reporting of a predetermined value or direction in value that favors the cause of the client, the amount of the value opinion, the attainment of a stipulated result, or the occurrence of a subsequent event directly related to the intended use of this appraisal.

8. Our analyses, opinions, and conclusions were developed, and this report has been prepared, i n conformity with the Uniform Standards of Professional Appraisal Practice as well as applicable state appraisal regulations.

9. The reported analyses, opinions, and conclusions were developed, and this report has been prepared, in conformity with the Code of Professional Ethics and Standards of Professional Appraisal Practice of the Appraisal Institute.

10. The use of this report is subject to the requirements of the Appraisal Institute relating to review by its duly authorized representatives.

11. Scott Beebe did not inspect the subject property.

12. No one provided significant real property appraisal assistance to the person(s) signing this certification.

13. We have experience in appraising properties similar to the subject and are in compliance with the Competency Rule of USPAP.

14. As of the date of this report, Scott Beebe, MAI has completed the continuing education program for Designated Members of the Appraisal Institute.

Scott Beebe, MAI
Certified General Real Estate Appraiser
California License #AG01526

STANDARD ASSUMPTIONS AND LIMITING CONDITIONS
This appraisal report has been made with the following general assumptions:
1) Notwithstanding that Appraiser may comment on, analyze or assume certain conditions in the appraisal, BBG, Inc. shall have no monetary liability or responsibility for alleged claims or damages pertaining to: (a) title defects, liens or encumbrances affecting the property; (b) the property’ s compliance with local, state or federal zoning, planning, building, disability access and environmental laws, regulations and standards; (c) building permits and planning approvals for improvements on the property; (d) structural or mechanical soundness or safety; (e) contamination, mold, pollution, storage tanks, animal infestations or other hazardous conditions affecting the property; and (f) other conditions and matters for which licensed real estate appraisers are not customarily deemed to have professional expertise. Accordingly:
a) The Appraiser has not conducted any engineering or architectural surveys in connection with this appraisal assignment. Information reported pertaining to dimensions, sizes, and areas is either based on measurements taken by the Appraiser or the Appraiser’s staff or was obtained or taken from referenced sources and is considered reliable. The Appraiser and BBG, Inc. shall not be monetarily liable or responsible for or assume the costs of preparation or ar rangement of geotechnical engineering, architectural, or other types of studies, surveys, or inspections that require the expertise of a qualified professional.
b) Unless otherwise stated in the report, only the real property is considered, so no consideration is given to the value of personal property or equipment located on the premises or the costs of moving or relocating such personal property or equipment. Further, unless otherwise stated, it is assumed that there are no subsurface oil, gas or other mineral deposits or subsurface rights of value involved in this appraisal, whether they are gas, liquid, or solid. Further, unless otherwise stated, it is assumed that there are no rights associated with extraction or exploration of such elements considered. Un less otherwise stated it is also assumed that there are no air or development rights of value that may be transferred.
c) Any legal description or plats reported in the appraisal are assumed to be accurate. Any sketches, surveys, plats, photographs, drawings or other exhibits are included only to assist the intended user to better understand and visualize the subject property, the environs, and the competitive data. BBG, Inc. has made no survey of the property and assumes no monetary liability or responsibilit y in connection with such matters.
d) Title is assumed to be good and marketable, and in fee simple, unless otherwise stated in the report.

The property is considered to be free and clear of existing liens, easements, restrictions, and encumbrances, except as stated. Further, BBG, Inc. assumes there are no private deed restrictions affecting the property which would limit the use of the subject property in any way. e) The appraisal report is based on the premise that there is full compliance with all applicable f ederal, state, and local environmental regulations and laws unless otherwise stated in the appraisal report; additionally, that all applicable zoning, building, and use regulations and restrictions of all types have been complied with unless otherwise stat ed in the appraisal report. Further, it is assumed that all required licenses, consents, permits, or other legislative or administrative authority, local, state, federal and/or private entity or organization have been or can be obtained or renewed for any use considered in the value opinion. Moreover, unless otherwise stated herein, it is assumed that there are no encroachments or violations of any zoning or other regulations affecting the subject property, that the utilization of the land and improvements is within the boundaries or property lines of the property described, and that there are no trespasses or encroachments.

f) The American Disabilities Act (ADA) became effective January 26, 1992. The Appraiser has not made a specific compliance survey or analy sis of the property to determine whether or not it is in conformity with the various detailed requirements of ADA. It is possible that a compliance survey of the property and a detailed analysis of the requirements of the ADA would reveal that the property is not in compliance with one or more of the requirements of the Act. If so, this fact could have a negative impact upon the value of the property. Since the Appraiser has no direct evidence relating to this issue, possible noncompliance with the requirem ents of ADA was not considered in estimating the value of the property.
g) No monetary liability or responsibility is assumed for conformity to specific governmental requirements, such as fire, building, safety, earthquake, or occupancy codes, except where sp ecific professional or governmental inspections have been completed and reported in the appraisal report. h) It is assumed the subject property is not adversely affected by the potential of floods; unless otherwise stated herein. Further, it is assumed all water and sewer facilities (existing and proposed) are or will be in good working order and are or will be of sufficient size to adequately serve any proposed buildings. i) Unless otherwise stated within the appraisal report, the depiction of the physical condi tion of the improvements described therein is based on visual inspection. No monetary liability or responsibility is assumed for (a) the soundness of structural members since no engineering tests were conducted; (b) the condition of mechanical equipment, p lumbing, or electrical components, as complete tests were not made; and (c) hidden, unapparent or masked property conditions or characteristics that were not clearly apparent during the Appraiser’s inspection.
j) If building improvements are present on the si te, it is assumed that no significant evidence of termite damage or infestation was observed during physical inspection, unless so stated in the appraisal report.

Further, unless so stated in the appraisal report, no termite inspection report was available . No monetary liability or responsibility is assumed for hidden damages or infestation. k) Unless subsoil opinions based upon engineering core borings were furnished, it is assumed there are no subsoil defects present, which would impair development of the land to its maximum permitted use or would render it more or less valuable. No monetary liability or responsibility is assumed for such conditions or for engineering which may be required to discover them. l) BBG, Inc., excepting employees of BBG Assessment, In c., and the appraiser(s) are not expert s in determining the presence or absence of hazardous substances toxic materials, wastes, pollutants or contaminants (including, but not limited to, asbestos, PCB, UFFI, or other raw materials or chemicals) used in construction or otherwise present on the property. BBG , Inc. and the appraiser(s) assume no monetary liability or responsibility for the studies or analyses which would be required to determine the presence or absence of such substances or for loss as a resu lt of the presence of such substances.

The Client is free to retain an expert on such matters in this field; however, Client retains such expert at Client’s own discretion, and any costs and/or expenses associated with such retention are the responsibility of Client.
m) BBG, Inc. is not an expert in determining the habitat for protected or endangered species, including, but not limited to, animal or plant life (such as bald eagles, gophers, tortoises, etc.) that may be present on the property. BBG, Inc. assu mes no monetary liability or responsibility for the studies or analyses which would be required to determine the presence or absence of such species or for loss as a result of the presence of such species. The Appraiser hereby reserves the right to alter, amend, revise, or rescind any of the value opinions contained within the appraisal repot based upon any subsequent endangered species impact studies, research, and investigation that may be provided. However, it is assumed that no environmental impact studies were either requested or made in conjunction with this analysis, unless otherwise stated within the appraisal report.

2) If the Client instructions to the Appraiser were to inspect only the exterior of the improvements in the appraisal process, the physi cal attributes of the property were observed from the street(s) as of the inspection date of the appraisal. Physical characteristics of the property were obtained from tax assessment records, available plans, if any, descriptive information, and interviewi ng the client and other knowledgeable persons. It is assumed the interior of the subject property is consistent with the exterior conditions as observed and that other information relied upon is accurate. 3) If provided, the estimated insurable value is inclu ded at the request of the Client and has not been performed by a qualified insurance agent or risk management underwriter. This cost estimate should not be solely relied upon for insurable value purposes. The Appraiser is not familiar with the definition o f insurable value from the insurance provider, the local governmental underwriting regulations, or the types of insurance coverage available. These factors can impact cost estimates and are beyond the scope of the intended use of this appraisal. The Appraiser is not a cost expert in cost estimating for insurance purposes. 4) The dollar amount of any value opinion herein rendered is based upon the purchasing power and price of the United States Dollar as of the effective date of value. This appraisal is based o n market conditions existing as of the date of this appraisal.
5) The value opinions reported herein apply to the entire property. Any proration or division of the total into fractional interests will invalidate the value opinions, unless such proration or di vision of interests is set forth in the report. Any division of the land and improvement values stated herein is applicable only under the program of utilization shown. These separate valuations are invalidated by any other application. 6) Any projections of income and expenses, including the reversion at time of resale, are not predictions of the future. Rather, they are BBG, Inc.’s best estimate of current market thinking of what future trends will be. No warranty or representation is made that such projecti ons will materialize. The real estate market is constantly fluctuating and changing. It is not the task of an appraiser to estimate the conditions of a future real estate market, but rather to reflect what the investment community envisions for the future in terms of expectations of growth in rental rates, expenses, and supply and demand. The forecasts, projections, or operating estimates contained herein are based on current market conditions, anticipated short -term supply and demand factors, and a continu ed stable economy. These forecasts are, therefore, subject to changes with future conditions.
7) The Appraiser assumes no monetary liability or responsibility for any changes in economic or physical conditions which occur following the effective date of value within this report that would influence or potentially affect the analyses, opinions, or conclusions in the report. Any subsequent changes are beyond the scope of the report.
8) Any proposed or incomplete improvements included in the appraisal report are assumed to be satisfactorily completed in a workmanlike manner or will be thus completed within a reasonable length of time according to plans and specifications submitted.
9) If the appraisal report has been prepared in a so-called “public non-disclosure” state, real estate sales prices and other data, such as rents, prices, and financing, are not a matter of public record. If this is such a “non- disclosure” state, although extensive effort has been expended to verify pertinent data with buyers, sellers, brokers, lenders, lessors, lessees, and other sources considered reliable, it has not always been possible to independently verify all significant facts. In these instances, the Appraiser may have relied on verification obtained and reported by appraisers outside of our office. Also, as necessary, assumptions and adjustments have been made based on comparisons and analyses using data in the report and on interviews with market participants. The information furnished by others is believed to be reliable, but no war ranty is given for its accuracy.
10) Although the Appraiser has made, insofar as is practical, every effort to verify as factual and true all information and data set forth in this report, no responsibility is assumed for the accuracy of any information furnished the Appraiser either by the Client or others. If for any reason, future investigations Standard Assumptions and Limiting Conditions Page 21
APPRAISAL REVIEW – DELTA SHORES CFD NO. 2019-01 (IMPROVEMENT AREA NO. 1) Copyright © 2024 BBG, Inc. All rights reserved.

should prove any data to be in substantial variance with that presented in this report, the Appraiser reserves the right to alter or change any or all analyses, opinions, or conclusions and/or opinions of value. 11) The right is reserved by the Appraiser to make adjustments to the analyses, opinions, and conclusions set forth in the appraisal report as may be required by consideration of additional or more reliable data t hat may become available. No change of this report shall be made by anyone other than the Appraiser. The Appraiser shall have no monetary liability or responsibility for any unauthorized change(s) to the report. 12) The submission of the appraisal report constitutes completion of the services authorized and agreed upon.

Such appraisal report is submitted on the condition the Client will provide reasonable notice and customary compensation, including expert witness fees, relating to any subsequent required atten dance at conferences, depositions, or judicial or administrative proceedings. In the event the Appraiser is subpoenaed for either an appearance or a request to produce documents, a best effort will be made to notify the Client immediately. The Client has t he sole responsibility for obtaining a protective order, providing legal instruction not to appear with the appraisal report and related work files, and will answer all questions pertaining to the assignment, the preparation of the report, and the reasonin g used to formulate the opinion of value. Unless paid in whole or in part by the party issuing the subpoena or by another party of interest in the matter, the Client is responsible for all unpaid fees resulting from the appearance or production of documents regardless of who orders the work. 13) Client shall not disseminate, distribute, make available or otherwise provide any Appraisal Report prepared hereunder to any third party (including without limitation, incorporating or referencing the Appraisal Report , in whole or in part, in any offering or other material intended for review by other parties) except to (a) any third party expressly acknowledged in a signed writing by Appraiser as an “Intended User” of the Appraisal Report provided that either Appraiser has received an acceptable release from such third party with respect to such Appraisal Report or Client provides acceptable indemnity protections to Appraiser against any claims resulting from the distribution of the Appraisal Report to such thi rd party, (b) any third party service provider (including rating agencies and auditors) using the Appraisal Report in the course of providing services for the sole benefit of an Intended User, or (c) as required by statute, government regulation, legal pro cess, or judicial decree. In the event Appraiser consents, in writing, to Client incorporating or referencing the Appraisal Report in any offering or other materials intended for review by other parties, Client shall not distribute, file, or otherwise make such materials available to any such parties unless and until Client has provided Appraiser with complete copies of such materials and Appraiser has approved all such materials in writing. Client shall not modify any such materials once approved by Appraiser. In the absence of satisfying the conditions of this paragraph with respect to a party who is not designated as an Intended User, the receipt of an Appraisal Report by such party shall not confer any right upon such party to use or rely upon such report, and Appraiser shall have no liability for such unauthorized use or reliance upon such report. In the event Client breaches the provisions of this paragraph, Client shall indemnify, defend and hold Appraiser, and its affiliates and their officers, directors, employees, contractors, agents and other representatives (Appraiser and each of the foregoing an “Indemnified Party” and collectively the “Indemnified Parties”), fully harmless from and against all losses, liabilities, damages and expenses (collectively, “Damages”) claimed against, sustained or incurred by any Indemnified Party arising out of or in connection with such breach, regardless of any negligence on the part of any Indemnified Party in preparing the Appraisal Report.

Scott Beebe, MAI
Senior Managing Director
Work: 916-949-7360
[email protected]

PROFILE
Scott Beebe is a Senior Managing Director at BBG in the Sacramento office. Mr. Beebe has over 30 years of experience in the valuation and analysis of commercial real estate including multi-family, retail, industrial, office, mixed-use and development land. Prior to BBG, Scott was one of the founding partners of Integra Realty R esources in 1999. Specialized property types include all types of lodging facilities, affordable housing, senior apartment communities, sports and health club facilities, golf course properties, automobile dealerships, manufactured home parks, self-storage facilities, regional malls and power centers and others.

Mr. Beebe has provided valuation and consulting services for condemnation purposes, estate, financing, equity participation and due diligence support. Specialized services include portfolio valuations, institutional- grade property valuations, market feasibility studies and acquisition/disposition counseling. Mr. Beebe has testified as an expert witness in superior and municipal courts. Clients served include life insurance companies, pension funds and pension fund advisors, banks and financial institutions, conduits, developers and investors, law firms, businesses/ corporations and government.

PROFESSIONAL AFFILIATIONS & LICENCES
Appraisal Institute, Member (MAI)
Lambda Alpha International – Honorary Land Economics Society

General Certified Appraiser:

State of California (License # AG 015266)

EDUCATION

B.B.A. Degree, Business Administration, University of Texas, Austin, Texas, 1988

Successfully completed numerous real estate related courses and seminars sponsored by the Appraisal Institute, accredited universities and others.

Currently certified by the Appraisal Institute’s voluntary program of continuing education for its designated members.

Sacramento City CouncilNovember 19, 2024

Sacramento City Council
November 19, 2024