San Bruno City Council
November 15, 2022

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3 Housing Element will replace the existing 2015-2023 Housing Element and serve as the City of San Bruno’s guiding policy document for meeting the City’s future housing needs at all economic levels.

All future housing development in the City must comply with the General Plan, zoning ordinance, state and federal permits, and local development standards. The City’s draft Housing Element Update was submitted to the State Department of Housing and Community Development (HCD) on July 8, 2022, and is currently being revised based on their comments.

Housing Element Update Suitable Sites Inventory
Government Code Section 65583 (a)(3) requires the City to prepare, as part of the Housing Element, to include a Suitable Sites Inventory. This is an inventory of land in San Bruno that is suitable for residential development, including vacant sites and underutilized sites with the potential for redevelopment. The Housing Element Update also includes an analysis of the relationship of the General Plan, zoning, and public facilities and services to the site inventory as well as an assessment of realistic development capacity for the planning period. Quantified housing construction and rehabilitation objectives are identified for extremely low-, very low-, low-, moderate-, and above moderate-income households.

In the 6th Cycle Regional Housing Needs Allocation (“RHNA”) imposed on the City by the Association of Bay Area Governments included 3,165 housing units, which is a substantial increase in the number of affordable housing opportunities required in comparison to the 5th Cycle RHNA allocation of 1,155 units. Additionally, the No Net Loss Law (California Government Code Section 65863) requires that enough sites are available at all times throughout the RHNA planning period to meet a jurisdiction’s remaining unmet housing needs for each income category. To ensure that sufficient capacity exists in the housing element to accommodate the RHNA throughout the planning period, HCD recommends jurisdictions create a buffer in the housing element inventory of at least 15 percent (equivalent to an additional 475 units allocated to the City of San Bruno for the 2023-2031 period).

Table 1 below presents the City’s RHNA and 15 percent buffer broken down by household income category.

Table 1: City of San Bruno RHNA by Household Income Category Household Income
Category1 RHNA 15 Percent
Buffer
Combined
Housing Targets2
Very Low (<50% AMI) 704 106 810
Low (50-80% AMI) 405 61 466
Moderate (80-120% AMI) 573 86 659
Above Moderate (>120% AMI) 1,483 222 1,705
Total Housing Units 3,165 475 3,640
Source: Association of Bay Area Governments. Final Regional Housing Needs Allocation (RHNA) Plan: San Francisco Bay Area, 2023-2031. December 2021.

Notes:
1 The AMI (area median income) in San Mateo County as of 2022 was $166,000. Source: U.S.

Department of Housing & Urban Development Office of Policy Development & Research . “FY 2022 Income Limits Documentation System”. Accessed October 25, 2022. https://www.huduser.gov/portal/datasets/il/il2022/2022summary.odn 2 Combined targets calculated by adding the City’s RHNA with the proposed 15 percent buffer.

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3 The purpose of the Suitable Sites Inventory is to evaluate whether there are sufficient sites with appropriate zoning to meet the RHNA goal. It is based on the city’s current land use designations and zoning requirements. The analysis does not include the economic feasibility of specific sites, nor does it take into consideration the owner’s intended use of the land now or in the future. It does not dictate where residential development will actually occur, and the decision whether or not to develop any particular site always remains with the owner of the property, not the city. Based on previous Housing Elements, the City anticipates that some of the sites on the list will be developed with new housing, some will not, and some housing will be built on sites not listed in the inventory.

The Housing Element Update includes 23 Housing Opportunity Sites which comprise the Suitable Sites Inventory. Many of these sites are already designated for additional housing as part of the current General Plan. The Housing Element Suitable Sites Inventory includes the Shops at Tanforan (“Tanforan”) and the San Bruno Pet Hospital (“Pet Hospital”) (collectively, the “Properties”) as potential future housing sites. The draft Housing Element includes a minimum of 1,000 housing units at the Tanforan site and 60 units at the Pet Hospital site. The Tanforan site has been identified by ABAG and the City as a prime location for housing based on the policies of Plan Bay Area 2050 and regional greenhouse gas reduction goals because of its proximity to transit. The Pet Hospital site is located across the street from the Tanforan site and within a half mile of high quality transit. ABAG did not take into consideration plans like the SFO ALUCP and the noise restrictions that regulate development of future housing when they utilized their urban simulation model to prepare the City’s RHNA number, and housing growth estimates for sites such as Tanforan. The Properties are located within Airport Influence Area B and within the 70 – 75 decibel (dB) Community Noise Equivalent Level (CNEL) contour where housing is prohibited pursuant to the SFO ALUCP, with limited exceptions.

The City’s current General Plan Policy, Health and Safety Policy, HS-40 states: “Prohibit new residential development within the 70+ Airport CNEL areas, as dictated by Airport Land Use Commission infill criteria.” The City has prepared an amendment to General Plan HS-40: “Prohibit new residential development within the 70+ Airport CNEL areas, as dictated by Airport land Use Commission infill criteria, unless, on a project by project basis, a proposed residential development is approved through the Local Agency Override process consistent with the Public Utilities Code Section 21675.1(d).” This amendment is being processed concurrently with the Housing Element.

On September 30, 2022, the City received a comment letter on San Bruno’s Housing Element update from Nupur Sinha, Director of Planning and Environmental Affairs, San Francisco International Airport. This letter is provided as Attachment 2. The letter expressed concern that residential development within 70 dB CNEL contour is incompatible with the policies of the SFO ALUCP. The letter raises many of the same concerns that were raised in the Director’s May 2022 letter in response to the city’s Reimagining Tanforan Land Use Fact Sheet. The letter cites the proposal as being the nation’s densest residential development this close to a major international airport. Lastly, the Director asks the city to remain cognizant of the Safety and Airspace compatibility policies of the SFO ALUCP. It should be noted here, the City’s application does not include enough information for C/CAG to determine whether the draft Housing Element, or the Tanforan site in particular, would comply with the Safety and Airspace compatibility policies of the SFO ALUCP. This site specific review would be done when the project is submitted for review.

The Airport Land Use Committee of C/CAG reviewed the Draft Housing Element for consistency and at its October 27, 2022 meeting, and made a recommendation to the C/CAG Board of Directors, that the C/CAG Board, acting as the Airport Land Use Commission (ALUC), find San Bruno’s draft 2023

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3 – 2031 Housing Element update to be inconsistent with the noise compatibility policies of the SFO ALUCP, due to the location of the Tanforan and Pet Hospital sites within the airport noise contours.

On November 10, 2022, the ALUC is scheduled to meet and consider the Airport Land Use Committee’s recommendation. At the time of publication of this report, it is anticipated that the C/CAG will follow the Airport Land Use Committee’s recommendation and determine that the Housing Element is not consistent with the noise compatibility policies of the SFO ALUCP because of the location of housing sites within the 70+ decibel noise contours. However, the staff report recommends that the ALUC find that the General Plan Amendment to recognize the Local Agency Override process is consistent with SFO ALUCP. The draft ALUC resolutions are attached as Attachment 3.

DISCUSSION:

SFO ALUCP Consistency Evaluation
Three airport / land use compatibility factors are addressed in the SFO ALUCP that relate to San Bruno’s 2023 – 2031 Housing Element update. These include policies for: (a) noise compatibility, (b) safety compatibility, and (c) airspace compatibility. The following sections address each factor.

Noise Compatibility
Attachment 4 shows the proposed housing opportunity sites in relation to the Community Noise Equivalent Level (CNEL) 65, 70, and 75 decibel (dB) aircraft noise exposure contours for SFO.

Pursuant to SFO ALUCP, Noise/Land Use Compatibility Land Use Criteria (Attachment 4), residential land uses are conditionally compatible in the CNEL 65-70 dB noise exposure contour range with sound insulation to reduce interior noise levels from exterior sources to CNEL 45 dB or lower and if an avigation easement is granted to the City and County of San Francisco as operator of SFO. Five housing opportunity sites, Sites 7, 15, 18, 20, and 21, are in the CNEL 65-70 dB noise exposure contour range established in the SFO ALUCP. The noise compatibility conditions of the SFO ALUCP would apply to the affected sites at the time of construction permitting.

As further outlined in SFO ALUCP Table IV-1 (Attachment 4), with a limited exception, residential land use is not compatible in the CNEL 70-75 dB noise exposure contour range. The exception applies to existing lots of record zoned for residential use as of the effective date of the SFO ALUCP (November 8, 2012). In such cases, new residences must be sound-insulated to achieve an indoor noise level of CNEL 45 dB or less from exterior sources, and the property owner must grant an avigation easement to the City and County of San Francisco prior to issuance of a building permit for the proposed building.

Two housing opportunity sites, Sites 14 and 19, are in the CNEL 70-75 dB noise exposure contour range. Site 14, the Tanforan Site, is identified to accommodate at least 1,000 housing units.

Additionally, up to 60 housing units are identified for Site 19, currently occupied by the San Bruno Pet Hospital.

The Draft Housing Element, with respect to Sites 14 and 19, is inconsistent with the SFO ALUCP noise policies.

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3 Safety Compatibility
The SFO ALUCP includes safety zones and related land use compatibility policies and criteria.

Attachment 4 shows the City’s proposed housing opportunity sites in relation to the safety compatibility zones. Two housing opportunity sites, Sites 15 and 21, are in Safety Zone 3 (Inner Turning Zone) and one housing opportunity site, Site 14 (the Tanforan Site), is in Safety Zone 4 (Outer Approach / Departure Zone). Per SFO ALUCP Table IV-2, Safety Compatibility Criteria, housing is a compatible use in Safety Zone 3 and Safety Zone 4. Therefore, the Draft Housing Element is consistent with the SFO ALUCP safety policies. Excerpts from the SFO ALUCP are included as Attachment 4.

Airspace Compatibility
The SFO ALUCP airspace policies establish maximum heights for the compatibility of new structures. The policies also stipulate the need for compliance with federal regulations requiring notification of the Federal Aviation Administration of certain proposed construction or alterations of structures. SFO ALUCP Airspace Policy AP-3 states that in order to be consistent, the maximum height of a structure must be the lower of (1) the height shown on the critical aeronautical surfaces map, or (2) the maximum height determined by the FAA not to be a “hazard to air navigation” by the FAA in an aeronautical study prepared pursuant to the filing of Form 7460-1.

Because the Draft Housing Element is a policy document and not a specific development proposal, the airspace compatibility policies of the SFO ALUCP do not directly apply. Consistency with the airspace compatibility policies would be required for future development proposals stemming from the Draft Housing Element.

Local Override Process
As a final review authority on legislative acts, the City Council may choose to override the ALUC’s determination. The local agency override process involves three mandatory steps:

1. Holding a public hearing by the local agency on the proposed override action;

2. Making of specific findings by the governing body of the local agency that the proposed local action is consistent with the purposes of the airport land use commission statutes;

3. Approval of the override action by a two-thirds vote of the local agency’s governing body; the override action must include adoption of the specific findings identified in Step 2, above.

The public hearing process for an override is a two-step process, which is established in Public Utilities Code Section 21676. The local agency override process requires two City Council meetings as follows:

1.City Council Meeting No. 1 (a public hearing, scheduled to occur on November 15, 2022):

The first step in the process is for the City Council to adopt a resolution making draft findings and declaring an intent to override the ALUC’s determination of inconsistency with the policies of the SFO ALUCP regarding the Housing Element and to provide notice, in accordance with Sections 21676(b) of the California Public Utilities Code, to the ALUC and the State of California Department of Transportation’s Division of Aeronautics. This must occur at least 45 days prior to the decision by the City Council to override the inconsistency determination, as the agencies have a 30-day comment period.

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3 2.City Council Meeting No. 2 (scheduled to occur on January 24, 2023): The second step in the process is that, not less than 45 days after notification has been sent to the ALUC and Division of Aeronautics, the City Council may decide to adopt a resolution to override the ALUC’s determination of inconsistency with the policies of the SFO ALUCP, and make specific findings that the Housing Element is consistent with the purposes of the State Aeronautics Act, as set forth in PUC Section 21670, namely the protection of public health, safety, and welfare in the areas surrounding airports. In the context of the Housing Element, it is envisioned that the City Council will consider overriding the inconsistency determination at the same meeting at which it will consider adopting the Housing Element and its associated General Plan amendment.

Pursuant to SFO ALUCP, GP-10.1, if an affected agency has not made its general plan, specific plans, and zoning ordinance, or facilities master plan consistent with the ALUCP or overridden the ALUCP as provided by law, the local agency shall refer all proposed development and land use policy actions that affect property rights within the project referral area, Area B of the (Airport Influence Area (AIA)), to the Airport Land Use Commission (the C/CAG Board) for a determination of consistency with the ALUCP prior to issuing a permit for the proposed development (PUC Section 21676.5(a)).

The City’s General Plan was adopted in March 2009, and C/CAG adopted the SFO ALUCP in November 2012. The General Plan and Zoning Code have not been reviewed for ALUCP consistency. Accordingly, any development projects in the City that are in the SFO ALUCP planning area, including those at the Tanforan site and Pet Hospital site, will be required to go through a separate project level ALUC review.

The attached resolution notifies the ALUC and the Division of Aeronautics of the City’s intent to conduct a public hearing and consider whether to adopt a resolution overriding the ALUC inconsistency determination. Any comments received by the ALUC and the Division are advisory to the City Council. However, should comments be received, the City must include them in the public record of any final decision to override the ALUC determination. The ALUC and the Division may provide comments on the intent to override within 30 days of receiving the documents; if they fail to provide comments within that time frame, the City may proceed without considering their comments.

If the resolution of intention is adopted, the City Council would formally consider overriding the inconsistency determination at a later date, at which time the City Council would consider all comments received, including from the ALUC and the Division of Aeronautics. The resolution to override the ALUC at the future hearing must be adopted by two-thirds vote of the City Council.

Implications of a Local Agency Override Action
There are two key outcomes of a local agency override of an Airport Land Use Commission (C/CAG Board) decision disapproving a proposed land use action as inconsistent with the ALUCP:
 The proposed land use action may proceed, subject to local agency review and permitting processes, as if it had been found consistent with this ALUCP by the Airport Land Use Commission (C/CAG Board).
 If a city or county overrides a decision of the Airport Land Use Commission (C/CAG Board) relating to a publicly owned airport that is not operated by that city or county, the agency operating the airport “shall be immune from liability for damages to property or personal

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3 injury caused by or resulting directly or indirectly from the public agency’s decision to override the commission’s action or recommendation”.

FISCAL IMPACT: There is no fiscal impact associated with this item.

ENVIRONMENTAL IMPACT: There is no environmental impact related to this item. Staff recommends that the City Council find that this action is not subject to the California Environmental Quality Act (CEQA) pursuant to Sections 15060(c)(2) (the activity will not result in a direct or reasonably foreseeable indirect physical change in the environment) and 15060(c)(3) (the activity is not a project as defined in Section 15378) of the CEQA Guidelines, California Code of Regulations, Title 14, Chapter 3, because it has no potential for resulting in physical change to the environment, directly or indirectly.

RECOMMENDATION:

That the City Council 1) Hold Public Hearing to Adopt a Resolution making draft findings and declaring an intent to consider overriding San Mateo City/County Association of Governments (C/CAG) Airport Land Use Commission’s (ALUC) determination of inconsistency with respect to noise policies for the Draft 2023-2031 Housing Element Update and 2) Authorize the City Manager to submit the Resolution to the Airport Land Use Commission and the State of California Department of Transportation’s Division of Aeronautics, and schedule a public hearing pursuant to Public Utilities Code Section 21676.

ALTERNATIVES:

1. The City Council may decide not to override the ALUC’s determination of inconsistency. One option is to identify alternative sites for new housing units, amend the Housing Element, and resubmit the revised document to the ALUC for consistency review. Staff does not recommend this action since the City has been allocated 3,165 housing units through the regional housing needs allocation (RHNA) process, the draft Housing Element includes a minimum of 1,000 housing units at the Tanforan site and 60 units at the Pet Hospital site. The Tanforan site has been identified by the City as a prime location for housing because of its proximity to transit and the Pet Hospital site is located across the street from the Tanforan site and within a half mile of high quality transit. It would be very difficult to accommodate these 1,060 housing units elsewhere in the community. Furthermore, this action would delay potential adoption of the Housing Element by the January 31, 2023 due date.

2. The City Council may choose to take no action. Staff does not recommend this action, as it may result in the ALUC imposing a requirement to review all land use actions, regulations, and permits under Public Utilities Code Section 21676.5, which would substantially delay entitlement and building permit processes including those related to meeting the City’s share of RHNA.

Furthermore, this action would delay potential adoption of the Housing Element by the January 31, 2023 due date.

ATTACHMENTS:

1. Resolution

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3 2. San Francisco International Airport comment letter on San Bruno’s 2023 – 2031 Housing Element update dated, September 30, 2022

3. Draft Airport Land Use Commission Resolutions

4. SFO ALUCP Exhibits

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1 RESOLUTION NO. 2022- ____

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN BRUNO MAKING

DRAFT FINDINGS AND DECLARING AN INTENT TO CONSIDER OVERRIDING SAN

MATEO CITY / COUNTY ASSOCIATION OF GOVERNMENTS (C/CAG) AIRPORT LAND USE COMMISSION’S (ALUC) DETERMINATION OF INCONSISTENCY WITH RESPECT TO NOISE POLICIES FOR THE DRAFT 2023-2031 HOUSING ELEMENT UPDATE; AND PROVIDE NOTICE PURSUANT TO THE STATE PUBLIC UTILITIES

CODE TO THE AIRPORT LAND USE COMMISSION AND THE STATE OF CALIFORNIA DEPARTMENT OF TRANSPORTATION’S DIVISION OF

AERONAUTICS REGARDING SUCH FINDINGS AND INTENT TO CONSIDER

OVERRIDING
WHEREAS, Government Code Section 65580 et seq. (Housing Element Law) requires that every city prepare and periodically update the housing element of its general plan; every city is mandated to include statutory requirements in the housing element; and every city is required to submit a draft of its housing element to the California Department of Housing and Community Development (“HCD”) for review and comment as to whether the City’s draft 2023-2031 Housing Element substantially complies with Housing Element Law; and WHEREAS, the City worked with its consultants, the community, Planning Commission and City Council to prepare its Draft 2023-2031 Housing Element Update (“Project”) as required by Housing Element Law; and
WHEREAS, the 6th Cycle Regional Housing Needs Allocation (“RHNA”) imposed on the City by the Association of Bay Area Governments (“ABAG”) included 3,165 housing units, which is a substantial increase in the number of affordable housing opportunities required in comparison to the 5th Cycle RHNA allocation of 1,155 units. As a result, the City was required to identify all available sites Citywide as potential housing opportunities, including some in proximity to the San Francisco International Airport; and
WHEREAS, the Housing Element Suitable Sites Inventory includes Site 14, the Tanforan Shops (“Tanforan”) and Site 19, the San Bruno Pet Hospital (“Pet Hospital”) (collectively, the “Properties”) as potential future housing sites, along with other sites. The Tanforan Site is identified to accommodate at least 1,000 housing units. Additionally, up to 60 housing units are identified at the Pet Hospital site; and
WHEREAS, the Tanforan site and the Pet Hospital site are located within Airport Influence Area B of the San Francisco International Airport (“SFO”), the area subject to formal C/CAG Airport Land Use Commission (“ALUC”) review, and within the 70 -75 decibel (dB) Community Noise Equivalent (CNEL) contour where housing is not a compatible use, with limited exceptions.

The exception applies to existing lots of record zoned for residential use as of the effective date of the SFO ALUCP (November 8, 2012). In such cases, new residences must be sound-insulated to achieve an indoor noise level of CNEL 45 dB or less from exterior sources, and the property owner must grant an avigation easement to the City and County of San Francisco prior to issuance of a building permit for the proposed building; and

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1 WHEREAS, two housing suitable sites, Sites 15 and 21, are in SFO ALUCP Safety Zone 3 (Inner Turning Zone) and the Tanforan Site is in Safety Zone 4 (Outer Approach / Departure Zone). Per SFO ALUCP Table IV- 2, Safety Compatibility Criteria, housing is a compatible use in Safety Zone 3 and Safety Zone 4. Therefore, the Draft Housing Element is consistent with the SFO ALUCP safety policies; and
WHEREAS, the SFO ALUCP airspace policies establish maximum heights for the compatibility of new structures. The policies also stipulate the need for compliance with federal regulations requiring notification of the Federal Aviation Administration of certain proposed construction or alterations of structures. Because the Draft Housing Element is a policy document and not a specific development proposal, the airspace compatibility policies of the SFO ALUCP do not directly apply. Consistency with the airspace compatibility policies would be required for future development proposals stemming from the Housing Element; and WHEREAS, the City proposed an amendment to its General Plan to recognize the Local Agency Override Process that is provided by State law, and referred this Amendment to the C/CAG Board, acting as the San Mateo County Airport Land Use Commission, for a determination of consistency with the SFO ALUCP; and
WHEREAS, the General Plan Amendment specifically addresses the “Local Agency Override” provision of State law [PUC Section 21675.1(d)] which provides a process for jurisdictions to override an airport land use commission disapproval of a proposed land use policy or development action, and is consistent with the provisions of the SFO ALUCP Section 3.3.3, which directly acknowledges and describes the override process; and WHEREAS, in accordance with Public Utilities Code Section 21676(b), the City referred the Project to the ALUC to review consistency with the Comprehensive Land Use Compatibility Plan for the Environs of San Francisco International Airport (“SFO ALUCP”); and WHEREAS, on November 10, 2022, the ALUC, acting pursuant to Public Utilities Code Section 21670, determined that the Project is inconsistent with the noise compatibility policies of the SFO ALUCP. The associated General Plan Amendment was also reviewed, and determined to be consistent with the policies of the SFO ALUCP; and WHEREAS, as a final review authority under Public Utilities Code Sections 21670 and 21676, the City Council may, after a public hearing, override the ALUC determination by a two- thirds vote, if the City makes specific findings that the proposed project is consistent with the purposes of the Public Utilities Code Section 21670 regarding the protection of public health, safety and welfare in the areas surrounding airports and by providing the ALUC and the Division of Aeronautics of the California Department of Transportation (“Division”) with notice of the City’s intent to consider overriding the ALUC determination along with supportive findings at least 45 days prior to the City’s action to override the ALUC; and WHEREAS, the Public Utilities Code provides that the ALUC and the Division shall respond to the notifications of the findings of the proposed override within 30 days of receiving the proposed resolution and findings; and
WHEREAS, in the event that the ALUC or Division’s comments are not available within this timeframe, the City may act without them; and

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1 WHEREAS, the comments by the ALUC and Division are advisory to the City under State law; and
WHEREAS, the City Council shall include comments from the ALUC and the Division in the final record of any final decision to override the ALUC, which may only be adopted by a two- thirds vote of the City Council; and
WHEREAS, the draft findings attached as Exhibit A to this resolution do not constitute the final findings of the City regarding the Project’s consistency with the purposes of Public Utilities Code Section 21670 and such draft findings may be revised, amended, and/or supplemented as part of any final decision to override the ALUC’s determination; and WHEREAS, should the City Council adopt this resolution making the draft findings and declaring an intent to consider overriding the ALUC determination that the Project is inconsistent with respect to the noise policies of the SFO ALUCP and directing staff to transmit the required notice to the ALUC and the Division, a public hearing will be required for the City Council to make a final decision regarding whether to override the ALUC inconsistency determination.

NOW, THEREFORE, BE IT RESOLVED, the City Council of the City of San Bruno hereby takes the following actions:

1. Makes the draft findings attached hereto as Exhibit A and incorporated herein; and

2. Declares an intent to consider overriding the Airport Land Use Commission’s determination that the draft 2023-2031 Housing Element Update is inconsistent with the Comprehensive Land Use Compatibility Plan for the Environs of San Francisco International Airport with respect to noise policies; and

3. Directs the City Manager to provide notice in accordance with Sections 21676(b) and 21676.5(a) of the State Public Utilities Code to the Airport Land Use Commission and the State of California Department of Transportation’s Division of Aeronautics at least 45 days prior to the scheduled public hearing date for consideration of the proposed overriding decision by the City Council; and

4. Directs staff to take all other actions necessary to effectuate the purpose and intent of this resolution; and

5. The City Council finds that the adoption of this resolution is not subject to the California Environmental Quality Act (“CEQA”) pursuant to Sections 15060(c)(2) (the activity will not result in a direct or reasonably foreseeable indirect physical change in the environment) and 15060(c)(3) (the activity is not a project as defined in Section 15378) of the CEQA Guidelines, California Code of Regulations, Title 14, Division 6, Chapter 3, because it has no potential for resulting in physical change to the environment, directly or indirectly. Specifically, the resolution does not have the potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment because it is limited to the City’s proposal to override the ALUC’s determination. The project is undergoing independent review and evaluation pursuant to CEQA.

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1 ---oOo---
I hereby certify that foregoing Resolution No. 2022 - ______ was introduced and adopted by the San Bruno City Council at a regular meeting on November 15, 2022, by the following vote:

AYES: Councilmembers:

NOES: Councilmembers
ABSENT: Councilmembers:

Vicky S. Hasha, Deputy City Clerk

Exhibit A: Draft Findings

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1 Exhibit A: Draft Findings

1. The foregoing recitals are true and correct and made a part of this Resolution.

2. The first purpose of Section 21670 is to provide for the orderly development of each public use airport in this State, and the area surrounding these airports so as to promote the overall goals and objectives of California airport noise standards and to prevent the creation of new noise and safety problems. The second purpose of Section 21670 is to protect public health, safety, and welfare by ensuring the orderly expansion of airports and the adoption of land use measures that minimize the public’s exposure to excessive noise and safety hazards within areas around public airports to the extent that these areas are not already devoted to incompatible uses.

3. With respect to noise policies, SFO ALUCP Policy NP-1 Noise Compatibility Zones identifies the noise compatibility zones for the purposes of the ALUCP. As depicted in the City of San Bruno’s Draft 2023-2031 Housing Element, two housing sites (Site 14, the Shops at Tanforan (the “Tanforan” site); and Site 19, the San Bruno Pet Hospital (the “Pet Hospital” site) (collectively, the “Properties”) lie within the Community Noise Equivalent Level (“CNEL”) 70-75 decibel (“dB”) noise exposure contour range where housing development would be incompatible per SFO ALUCP Table IV, Noise/Land Use Compatibility Criteria.

4. Pursuant to SFO ALUCP, Table IV-1, residential land uses are conditionally compatible in the CNEL 65-70 dB noise exposure contour range and are acceptable if sound insulation is provided to reduce interior noise levels from exterior sources to CNEL 45 dB or lower and if an avigation easement is granted to the City and County of San Francisco as operator of SFO.

5. Any project at the Tanforan site or Pet Hospital site shall incorporate noise control measures and construction standards that will lessen noise impacts to residents as follows:
a. Prior to issuance of building permits, detailed acoustical analyses shall be completed as part of the final design for the proposed residential structures. The project shall incorporate construction methods, sound attenuation features, and sound reducing barriers that reduce noise impacts in accordance with Section 21670, State Building Code, and General Plan requirements to meet the interior noise levels of 45 dB CNEL. Sound control treatments shall include mechanical ventilation for all units so that windows can be kept closed at the resident’s discretion to control noise, and special building construction techniques (such as sound-rated windows and building façade treatments) for all units.
b. The project shall include real estate disclosures in residential leases, disclosing the presence of an airport within two miles of the property, per Section 11010 of the Business and Professions Code.
c. The property owners shall grant an avigation easement to the City and County of San Francisco prior to issuance of a building permit for the proposed building or structure.
d. The project shall include an indemnification agreement with the City of San Bruno prior to issuance of building permits, ensuring that liability related to noise is assumed by the project.

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1 6. Approval of the proposed Project as described above is consistent with the noise standards of the SFO ALUCP as it would provide for orderly development adjacent to the airport and promote the overall goals and objectives of the California airport noise standards and prevent the creation of new noise and safety problems because the proposed Project provides much needed housing near transit on underutilized sites, while also utilizing advanced construction techniques to minimize any noise impacts to residents, and helping the City satisfy its large RHNA allocation and respond to the housing crisis facing the region and the State.

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September 30, 2022

TRANSMITTED VIA E-MAIL
[email protected]
Michael Smith
Senior Planner
San Bruno Community & Economic Development Department | Planning Division City of San Bruno
567 El Camino Real
San Bruno, California 94066

Subject: 2023-2031 Draft Housing Element, San Bruno, California

Thank you for notifying San Francisco International Airport (SFO or the Airport) regarding the preparation of the City of San Bruno’s draft 2023-2031 Housing Element (draft Housing Element). We appreciate this opportunity to coordinate with the City of San Bruno (the City) in considering and evaluating potential land use compatibility issues from the draft Housing Element.

The draft Housing Element establishes goals, policies, and programs to help address the City’s current and future housing needs and includes a list of recommended housing sites. It is the City’s blueprint for housing- related decisions and sets an action plan for how to meet housing goals over the coming years. The City has been allocated 3,165 housing units through the Association of Bay Area Governments’ application of the State of California’s Regional Housing Needs Allocation (RHNA) process and the draft Housing Element includes a minimum of 1,000 housing units at the former Shops at Tanforan site. The Tanforan site has been identified by the City as a prime location for housing because of its designation within the City’s Transit Corridor Plan.

The majority of the City, including the Tanforan site, is inside Airport Influence Area B as defined by the Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport (SFO ALUCP). The Tanforan site is located within the 70 decibel (dBA) Community Noise Equivalent Level (CNEL) contour and Safety Compatibility Zone 4. Moreover, many airport departure procedures are designed to ascend over the Tanforan site, and residents would experience extreme and persistent noise from aircraft departures.

SFO remains deeply concerned about the City’s plan for adding housing units at the Tanforan site. On July 27, 2021, the City released the Reimagining Tanforan Fact Sheet, which describes proposed development at the Tanforan site. On May 6, 2022, we sent a letter to the City stating our concerns for the redevelopment of the Tanforan Shopping Center, which is attached hereto as Exhibit A and incorporated by reference. A summary of the concerns outlined in that letter are as follows:

• All residential developments within 70 dBA CNEL contour are determined to be incompatible (i.e., entirety of Tanforan site);
• Redevelopment of the Tanforan site to include high-density residential units would undermine decades of scientifically informed land use planning and millions of dollars expended to safeguard public health and safety;
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Michael Smith
September 30, 2022

• The Airport has spent hundreds of millions of dollars on insulating incompatible land uses. However, any future residences at the Tanforan site will not be eligible for Federal Aviation Administration/SFO grants for sound insulation or the subsequent repair or re-installation of insulation materials when they fail over time. (This is reiterated in a May 6, 2022 letter from FAA to the City attached hereto as Exhibit B and incorporated by reference.) • The proposed redevelopment would result in the densest population per square mile under the departure flight path near a major international airport; • Heights of buildings at the Tanforan site would need to be between 55 and 90 feet above ground level to be compatible with the Airspace Compatibility Policies of the SFO ALUCP. Otherwise, any penetrations of the critical aeronautical surfaces would result in real financial and economic impacts to air carriers, cargo operators, and SFO/City of County of San Francisco, and potentially reduce airlines’ ability to transport high-value cargo (e.g., biotechnology and high-technology cargo); • The Airport encourages the City to consider Safety Zone 4 compatibility policies during planning and site development to prevent development of incompatible uses (i.e., Biosafety Level 3 and 4 facilities, children’s schools, large child day care centers, hospitals, nursing homes, stadiums, and arenas) and avoid development of critical public utilities and hazardous uses other than Biosafety Level 3 and 4 facilities.

The Airport has reviewed the recently issued draft Housing Element, which will be sent to the California Department of Housing and Community Development (HCD) on October 3, 2022. In addition to the comments presented in our May 6, 2022 letter (Exhibit A), we have the following comments regarding the draft Housing Element:

• In Chapter 3 (Housing Constraints and Resources), it states that, “local governments may take steps, provided by law, to overrule part or all of the ALUCP as it relates to their jurisdiction.” This is not true. Local agencies cannot overrule any part of the ALUCP. Rather, local agencies may override an Airport Land Use Commission determination of proposed land use policy actions or development proposals based on the ALUCP. The process is described in Section 3.3.3 of the SFO ALUCP (Local Agency Override of an Airport Land Use Commission Determination). The local agency override process requires three steps: 1) holding a public hearing by the local agency of the proposed override action, 2) making specific findings by the governing body of the local agency that the proposed local action is consistent with the purposes of the airport land use commission statutes, and 3) approval of the override action by a two-thirds vote of the local agency’s governing body. • In Chapter 3 (Housing Constraints and Resources), Tables 3-2 and 3-3 present development regulations for residential and mixed-use districts, respectively. The Airport strongly encourages the City to also include maximum height restrictions reflective of the critical aeronautical surfaces as outlined in SFO ALUCP Exhibits IV-17 and IV-18 (see Exhibit C). The Airport also requests the following language be included in the draft Housing Element:

The City shall regulate land uses and building height within the Airport Influence Area of the San Francisco International Airport in compliance with SFO critical aeronautical surfaces (SFO ALUCP Exhibits IV-17 & IV-18), in accordance with Airport Land Use Commission guidelines to assure safety of aircraft, persons, and property near the Airport.

Additionally, all proposed structures must receive a Determination of No Hazard from the DocuSign Envelope ID: E33C5440-0C7C-4F46-A8B2-F63004DD632A

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Michael Smith
September 30, 2022

FAA. For avoidance of doubt, the lower of the two heights identified by the ALUCP and the FAA shall be the controlling maximum height.

• In the City’s Application for Land Use Consistency Determination for the Housing Element update, the City presents the following proposed amendment to the General Plan, Health and Safety Policy HS-40:

Presupposing an override of an ALUC determination for noise compatibility within the General Plan undermines the purpose of the SFO ALUCP to protect the public health, safety, and welfare of residents and occupants of future noise-sensitive development, and short-circuits the due process built into Public Utilities Code Section 21675.1(d). Placing this language into the General Plan would, in essence, render incompatible the entire General Plan. If overrides are pursued, they should be pursued on a per-project basis and the City must make determinations of fact specific to that project rather than assuming a blanket override. The Airport requests that this new language be stricken and overrides continue to be considered on a per-project basis to meet the intent of the Public Utilities Code and the SFO ALUCP.

As the largest employment site in San Mateo County, SFO recognizes the importance of increasing housing supply in California and in the San Francisco Bay Area. While the Airport believes that ABAG erred in excluding airport noise criteria from its RHNA methodology, it also acknowledges that the City’s RHNA allocation requires it to plan for an additional 3,165 housing units. The Airport continues to urge the City to consider alternative locations to meet RHNA requirements, outside the 70 dBA CNEL noise contour, including the 2101 Sneath Lane Residential Project, the Bayhill Specific Plan area, and the transit-oriented development corridor along El Camino Real and San Mateo Avenue located outside of the CNEL 70 dBA contour.

Due to the proximity to the Airport, Airspace Protection Policies (AP1 through AP4) from the SFO ALUCP are enclosed (see Exhibit C) as reminders of incompatible site characteristics that pose threats to safe aircraft operations – especially as it pertains to wildlife attractants, particularly large flocks of birds – and building materials/features that reflect and create bright lights/glare.

* * *

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Michael Smith
September 30, 2022

The Airport appreciates the City’s willingness to continue to have collaborative discussions, and your consideration of these concerns. If I can be of assistance, please do not hesitate to contact me at (650) 821- 6678 or at [email protected].

Sincerely,

Nupur Sinha
Director of Planning and Environmental Affairs
San Francisco International Airport

Attachments

cc: Tamara Swann, Western-Pacific Regional Administrator, Acting, FAA Faviola Garcia, Western-Pacific Deputy Regional Administrator, Acting, FAA Laurie Suttmeier, Manager, Western-Pacific Region, FAA San Francisco Airports District Office Phillip Miller, Acting, Chief Division of Aeronautics, Caltrans Airlines for America
San Francisco Airline Airport Affairs Committee
California Airports Council
United States Congresswoman Jackie Speier
San Mateo County Supervisor David Pine
San Mateo County Supervisor Dave Canepa
California State Assemblymember Kevin Mullin
California State Senator Josh Becker
Therese McMillan, Executive Director, Association of Bay Area Governments Mark Shorett, Principal Regional Planner, Association of Bay Area Governments Sam Hindi, Chairperson, SFO Airport/Community Roundtable Marisa Prasse, California Department of Housing and Community Development Hillary Prasad, California Department of Housing and Community Development Sean Charpentier, Executive Director, City/County Association of Governments of San Mateo County Susy Kalkin, C/CAG Airport Land Use Committee

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Western-Pacific Region
Office of the Regional Administrator

777 S. Aviation Blvd.

El Segundo, CA 90245

May 18, 2022

Mr. Jovan D. Grogan
City Manager
City of San Bruno
567 El Camino Real
San Bruno, CA 94066-4247

RE: Concerns regarding the Reimagining Tanforan Redevelopment Project

Dear Mr. Grogan:

The purpose of this letter is to advise the City of San Bruno that the Federal Aviation Administration (FAA) is concerned about potential impacts to San Francisco International Airport (SFO), land use changes, and the introduction of airport incompatible land use relating to the redevelopment of the Tanforan Shopping Mall (Tanforan Mall) in San Bruno, California. As currently planned, the proposed Reimagining Tanforan Redevelopment Project (Tanforan Project) would introduce new land use compatibility issues and increase noise incompatibility due to arrival and departure operations from SFO. The FAA’s mission is to provide the safest and most efficient aerospace system in the world. Within the context of our mission, the FAA continues to seek ways to mitigate the effects of aviation-related noise by providing financial and technical assistance to airport sponsors on airport compatible land use, noise reduction planning and abatement activities.

The Reimagining San Bruno Land Use Fact Sheet (San Bruno Fact Sheet) states, “...the goal of this early engagement is to identify redevelopment solutions that are financially viable and provide long term benefits to the San Bruno community by streamlining the entitlement approval process to mitigate risks and accelerate the investments.” While there are many benefits to living in a transit-oriented development that is closely connected to mass transit, the FAA is concerned about maintaining compatibility of the existing land use and introducing high-density residences within an area known to be adversely affected by aircraft noise within the Tanforan development.

The FAA is aware that the California Department of Transportation (Caltrans) shares similar concerns, as detailed in their January 20, 2022, letter to the City of San Bruno. We are also aware that SFO has expressed concerns regarding the proposed redevelopment. The FAA is additionally concerned about the environmental justice implications of affordable housing provided in noise- incompatible land.

The City of San Bruno is directly responsible for ensuring proper planning in partnership with state, local, and private entities, and notifying purchasers of real estate and prospective residents of their exposure to direct overflight and extreme and persistent airport noise. In the past, the City of San Bruno directly received federal funding for residential sound insulation to mitigate land use compatibility issues. On May 14, 2008, the FAA reminded the City of San Bruno, via enclosure 1, of the importance of taking appropriate action to adopt zoning and further restrict the introduction of additional non-compatible land uses adjacent to or in the vicinity of SFO. The

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enclosure to that letter provides Appendix A, Table 1- Land Use Compatibility Guidelines from 14 Code of Federal Regulations Part 150 – Airport Noise Compatibility Planning (Part 150). As shown in enclosure 2, the 2019 Noise Exposure Map from the SFO Noise Compatibility Program1, a majority of the Tanforan Mall area is within the Community Noise Equivalent Level (CNEL) 70 decibel (dB) contour and is heavily affected by SFO departures from Runways 28L and 28R. The FAA continues to provide Airport Improvement Program (AIP) funding for qualified impacted City of San Bruno residences through the SFO Residential Sound Insulation Program. In accordance with FAA Final Policy on Part 150 Approval of Noise Mitigation Measures: Effect on the Use of Federal Grants for Noise Mitigation Projects (63 FR 16409), structures and new non-compatible development built after October 1, 1998, are not eligible for approval of remedial noise mitigation measures under Part 150 or AIP funding. In other words, residences in the Tanforan Project would not receive any AIP funding for residential sound insulation.

According to the San Bruno Fact Sheet, the city may add at least 1,000 and as many as 3,165 residential units. This plan would expose thousands of new residents to significant noise (above 65 dB CNEL), approximately 2,500 to 8,000 persons, using the average number of 2.62 persons per household according to the United States Census Bureau. Given that there are currently 440,000 persons nationwide exposed to significant noise, this development alone would increase the number of people exposed.

SFO primary operations use Runways 28L and 28R for landing and Runways 01R and 01L for departures. In this configuration, Runway 28R is also used for departures of heavy jets on long routes, which need the longest SFO runway (Runway 28R) due to the aircraft weight. The Tanforan Mall area aligns with the SFO Runways 28R and 28L. Use of Runway 28R for departures is not optional for these long-haul flights.

In 2019 there were an average of about 88 heavy jet departures per day; out of those heavy jet departures, 72% departed from Runway 28R or Runway 28L. On August 17, 2019, SFO’s peak departure was 209 heavy jets. Heavy jets were departing Runways 28R and 28L, from 0.5 nautical miles before the proposed development to 0.5 nautical miles after the proposed development. The proposed development is approximately 1.1 nautical miles from the end of Runways 28R and 28L. Therefore, the average altitude of departing heavy jets over the Tanforan site is 1300 to 1800 feet mean sea level.

Also, Runways 28R and 28L are used for departures when winds are strong enough from the West Southwest to no longer allow for Runways 01R and 01L to be used due to unacceptably high tailwinds/crosswinds. Use of SFO Runways 28R and 28L for all departures is not a preferred configuration for SFO. Instead, it is required based on the weather (winds), specific needs of long- haul departures, or aircraft types which require the longest possible runway. In 2019, all aircraft departed only Runway 28L or Runway 28R 7.9% of the time, the second-most-frequent runway configuration at SFO. Additionally, there are occasions when weather forces the use of Runways 10R and 10L for SFO arrivals. Such an occurrence happened on January 22, 2022; enclosure 3 is a photo of an aircraft preparing to land at SFO directly over the Tanforan Mall area. Proposed Tanforan residential units would be exposed to the type, frequency, and severity of aviation activity described above.

1 The San Francisco International Airport, Noise Compatibility Program (NCP) Update 2018 was prepared pursuant to 14 Code of Federal Regulations Part 150 requirements. The first FAA Record of Approval for a SFO NCP was issued on September 7, 1983.

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As shown in enclosures 4 and 5, Tanforan Mall is located within the footprint for the Approach/Departure Obstruction Clearance Surface (OCS)2 for existing Runway 10R/28L and Runway 10L/28R. Maintaining clearance and protection of the OCS is among critical safety factors for protecting the Nation’s airspace and aviation operations to and from SFO. Proposed structures’ heights must be below the OCS.

Noise and land use compatibility planning are complex issues that need active engagement by the City of San Bruno together in partnership with the City and County of San Francisco, Airport Commission; San Mateo County; aeronautical users such as United Airlines; the business community; and residences to establish a cohesive strategy for the health and well-being of the entire community. Please review the FAA Airport Noise Compatibility Planning Toolkit (Land Use Compatibility and Airports, A Guide for Effective Land Use Planning [PDF]). The City/County Association of Governments (C/CAG) also maintains an Airport Land Use Commission (ALUC) and Comprehensive Airport Land Use Compatibility Plan for the Environs of SFO. This government entity and legal document prepared under State of California Law may indicate further restrictions on the site to maintain airspace, noise, and safety compatibility.

Compliance with FAA guidelines and federal law does not exempt a project sponsor from complying with local regulations.

Should the City of San Bruno, known to be a noise-sensitive community representative in the SFO Airport/Community Roundtable, proceed with the Tanforan Project , exposing as many as 8,000 residents to significant aviation noise, there will be little if any mitigation the FAA would be able to implement for these residents because of the Tanforan Project’s proximity to SFO runways.

Therefore, we strongly encourage the City of San Bruno and San Mateo County officials to consider the FAA’s concerns and look to develop and maintain compatible land uses around SFO.

If you have any questions, please contact my office at (424) 405-7000.

Sincerely,

Tamara A. Swann
Regional Administrator (A)

Enclosures

c c:

Sam Hindi, Roundtable Chairperson, San Francisco
Tom Hamilton, Council member, City of San Bruno
Pamela Wu, Director, Community and Economic Development, City of San Bruno Therese McMillan, Executive Director, Association of Bay Area Governments United States Congresswoman Jackie Speier, CA – 14
th District
Phillip Miller, Acting, Chief Division of Aeronautics, Caltrans

2 Defined in FAA Advisory Circular (AC) 150/5300-13, Airport Design, and Engineering Brief 99A.

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U.S Department
of Transportation
Federal Aviation
Administration

Western-Pacific Region
Airports Division
San Francisco ADO
831 Mitten Road, Suite 210
Burlingame, CA 94010
May 14, 2008
Aaron Aknin
Community Development Director
City of San Bruno
567 El Camino Real
San Bruno, CA 94066
Dear Mr. Aknin:

Subject: San Bruno General Plan 2025 and associated Draft Environmental Impact Report
The Federal Aviation Administration (FAA) has completed a cursory review of the subject documents. As a result of that review the FAA is concerned that the San Bruno General Plan (General Plan) and Environmental Impact Report did not consider the City of San Bruno’s (City) airport land use compatibility program obligations.

As noted in the General Plan on page 7-9, the City has accepted federal funds for insulation projects in areas impacted by noise from San Francisco International Airport (SFO). The federal funds were made available to the City as a result of the City and County of San Francisco’s SFO Noise Compatibility Plan (NCP) prepared pursuant to 14 Code of Federal Regulations Part 150,
Airport Noise Compatibility
Planning (Part 150). The NCP identified noise impact areas and measures developed to achieve compatible land use with SFO operations.

When the City accepted the federal Airport Improvement Program (AIP) funds for the noise insulation projects, the City acknowledged its obligation to take appropriate action to adopt appropriate zoning and further restrict introduction of additional non-compatible land uses adjacent to or in the vicinity of the airport. The AIP grant obligations are identified in the Non-Airport Sponsors Grant Assurances.

The most recent AIP grant is 3-06-0021-29.

The General Plan Guiding Policies encourage additional residential housing in areas that are impacted by airport noise. The majority of the area designated for redevelopment is in the Community Noise Equivalent Level (CNEL) 70 decibel (dB) contour. Proposed high density residential and mixed use developments are located within the CNEL 65 dB contour.

Introduction of additional non-compatible development within the CNEL 65 dB through CNEL 70 dB is inconsistent with the NCP. Table 1 from Part 150 provides federal compatible and non-compatible land use guidelines (enclosed).

Development of local land use plans that are compatible with airport operations is key to ensuring consistency with the City’s grant obligations. The FAA encourages the City to take appropriate action to Enclosure (1)

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2 maintain compliance with its certification that it will comply with all applicable Federal laws, regulations, executive orders, policies, guidelines and requirements as they relate to use of federal funds for land use compatibility.

If you have any questions or concerns regarding this matter, I am available at (650) 876-2778 extension 613.

Sincerely,

(Original Signed by:)

Camille Garibaldi
Environmental Protection Specialist

Enclosure

cc:

Danielle Rinsler, San Francisco International Airport
Nixon Lam, San Francisco International Airport
Sandy Hesnard, California Department of Transportation

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TABLE 1—L AND USE COMPATIBILITY WITH YEARLY DAY-NIGHT AVERAGE SOUND

Land Use Yearly day-night average sound level (Ldn) in decibels < 65 65-70 70-75 75-80 80-85 > 85
Residential
Residential, other than mobile homes and
transient lodgings
Y N (1) N (1) N N N
Mobile home parks Y N N N N N
Transient lodgings Y N (1) N (1) N (1) N N

Public Use
Schools Y N (1) N (1) N N N
Hospitals, nursing homes Y 25 30 N N N
Churches, auditoriums, and concert halls Y 25 30 N N N
Government services Y Y 25 30 N N
Transportation Y Y Y (2) Y (3) Y (4) Y (4)
Parking Y Y Y (2) Y (3) Y (4) N

Commercial Use
Offices, business and professional Y Y 25 30 N N
Wholesale and retail- building materials,
hardware and farm equipment
Y Y Y (2) Y (3) Y (4) N
Retail trade-general Y Y 25 30 N N
Utilities Y Y Y (2) Y (3) Y (4) N
Communication Y Y 25 30 N N

Manufacturing and Production
Manufacturing, general Y Y Y (2) Y (3) Y (4) N
Photographic and optical Y Y 25 30 N N
Agriculture (except livestock) and forestry Y Y (6) Y (7) Y (8) Y (8) Y (8) Livestock farming and breeding Y Y (6) Y (7) N N N
Mining and fishing, resource production
and extraction

Y Y Y Y Y Y

Recreational
Outdoor sports arenas and spectator sports Y Y (5) Y (5) N N N Outdoor music shells, amphitheaters Y N N N N N
Nature exhibits and zoos Y Y N N N N
Amusements, parks, resorts, and camps Y Y Y N N N
Golf courses, riding stables and water
recreation
Y Y 25 30 N N
Numbers in parenthesis refer to notes; see continuation of Table 1 for notes and key.

The designations contained in this table do not constitute a Federal determination that any use of land covered by the program is acceptable or unacceptable under Federal, State, or local law. The responsibility for determining the acceptable and permissible land uses and the relationship between specific properties and specific noise contours rests with the local authorities. FAA determinations under Part 150 are not intended to substitute Federally determined land uses for those determined to be appropriate by local authorities in response to locally determined needs and values in achieving noise compatible land uses.
(more)

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TABLE 1—L AND USE COMPATIBILITY WITH YEARLY DAY-NIGHT AVERAGE SOUND LEVELS (CONTINUED)

Key to Table 1
Y (YES) Land Use and related structures compatible without restrictions.

N (NO) Land Use and related structures are not compatible and should be prohibited.

NLR Noise Level Reduction (outdoor to indoor) to be achieved through incorporation of noise attenuation into the design and construction of the structure. 25, 30, or
35 Land use and related structures generally compatible; measures to achieve NLR of 25, 30 or 35 dB must be incorporated into design and construction of structure.

Notes for Table 1
(1) Where the community determines that residential or school uses must be allowed, measures to achieve outdoor to indoor Noise Level Reduction (NLR) of at least 25 dB and 30 dB should be incorporated into building codes and be considered in individual approvals. Normal residential construction can be expected to provide a NLR of 20 dB, thus, the reduction requirements are often stated as 5, 10 or 15 dB over standard construction and normally assume mechanical ventilation and closed windows year round. However, the use of NLR criteria will not eliminate outdoor noise problems.
(2) Measures to achieve NLR of 25 dB must be incorporated into the design and construction of portions of these buildings where the public is received, office areas, noise sensitive areas or where the normal noise level is low.
(3) Measures to achieve NLR of 30 dB must be incorporated into the design and construction of portions of these buildings where the public is received, office areas, noise sensitive areas or where the normal noise level is low.
(4) Measures to achieve NLR of 35 dB must be incorporated into the design and construction of portions of these buildings where the public is received, office areas, noise sensitive areas or where the normal noise level is low.
(5) Land use compatible provided special sound reinforcement systems are installed. (6) Residential buildings require an NLR of 25.
(7) Residential buildings require an NLR of 30.
(8) Residential buildings not permitted.
(end of Table 1)

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CNEL 70 dB
CNEL 75 dB
CNEL 65 dB
101

CALIFORNIA
92 380

CALIFORNIA
82 CALIFORNIA
1 280

CALIFORNIA
35 E 3rd Ave
Hillside Blvd
Gr and Ave
Linda Mar Blvd T
rous
dale Dr
O
c
eana Blvd
Skyline Dr
Westborough Blvd
Fleetw
ood Dr
Sharp Park
Rd

Crestm
oor Dr
e v A o e t a M n a S
Hi ckey Blvd
Old Bays
hore Hwy
Southg ate Ave
Fa ssler Ave
Cryst
al
Springs Rd
N
Amphlet
t Blvd
Hun
tingt
on
Ave
A
deline Dr
Hillside Dr
Junipero Serra Blvd
S Airport Blvd
S Spruce Ave
Peninsula Ave
Carm
elita Ave
Lomita Ave
San Bruno Ave W
Howard Ave
E Grand Ave
G
a
te
way Dr
Callan Blvd
Manzanita Dr Millbrae Ave
Serramonte Blvd
Lude
man Ln
Airpo rt Blvd
Sneath
Ln

ElCaminoReal

SOUTH SAN FRANCISCO

BRISBANE

SAN BRUNO

BURLINGAME

PACIFICA

MILLBRAE
COLMA

DALY CITY

HILLSBOROUGH
28L
San Francisco Bay
Pacific Ocean
San Andreas Lake
San Francisco International Airport
1L1R
19L
19R
10L10R
28R

SAN MATEO

UNINCORPORATED

FOSTER CITY
0 5,000
Feet
Airport Property Boundary
Aircraft Noise Contour
Municipal Boundary

NOISE SENSITIVE FACILITIES
School
Hospital
Place of Worship
Historic Structures

GENERALIZED EXISTING LAND USE
Single Family Residential
Multi-Family Residential
Commercial
Industrial
Public
Mixed Use
Open Space/Recreation/Preservation
Park/Golf Course/Cemetery
Water
Vacant/Unknown
CNEL – Community Noise Equivalent Level
dB – Decibel
SFO 14 CFR Part 150 Noise Exposure Map Report . 120832
SOURCES: ESRI, 2014; San Mateo County Planning and Building Department, 2014; BridgeNet International, 2014; ES A Airports, 2014 Exhibit 5-2
2019 Noise Exposure Map – San Francisco International Airport Enclosure (2)

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San Francisco International Airport
Arrival
Preparing for landing at SFO to Runway 10 end. Photo taken on January 22, 2022.

Enclosure (3)

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Tanforan
Shopping
Center
Airport Design Approach/Departure Obstruction Clearance Surface (OCS) for SFO Runway 10R/28L and Runway 10L/28R and Location of Current Tanforan Shopping Center Enclosure {4}
&nbsp;
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Approach/Departure OCS Profiles
Enclosure {5}
Tanforan
Shopping Center
&nbsp;
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THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY OCTOBER 2012

Comprehensive Airport Land Use Compatibility Plan
for the Environs of San Francisco International Airport [IV-34] Airport/Land Use Compatibility Policies
and associated with human disease of varying severity.
b. Biosafety Level 3 practices, safety equipment, and facility design and construction are applicable to clinical, diagnostic, teaching, rese arch, or production facilities in which work is done with indigenous or exotic agents with a potential for respiratory transmission, and which may cause serious and potentially lethal infection. c. Biosafety Level 4 practices, safety equipment, and facility design and construction are applicable for work with dangerous and exotic agents that pose a high individual risk of life-threatening disease, which may be transmitted via the aerosol route and for which there is no available vaccine or therapy.

4.5 Airspace Protection
The compatibility of proposed land uses with respect to ai rspace protection shall be evaluated in accordance with the policies set forth in this section. These policies are established with a twofold purpose:

1. To protect the public health, safety, and welfare by minimizing the public’s expo sure to potential safety hazards that could be created through the construction of tall structures.

2. To protect the public interest in providing for the orderly development of SFO by ensuring that new development in the Airport environs a voids compromising the airspace in the Airport vicinity. This avoids the degradation in the safety, utility, efficiency, and air servic e capability of the Airport that could be caused by the attendant need to raise visibility minimums, increase minimum rates of climb, or cancel, restrict, or redesign flight procedures.

4.5.1 FEDERAL REGULATIONS REGARDING TALL STRUCTURES
14 Code of Federal Regulations (CFR) Part 77, Safe, Efficient Use and Preservation of the Navigable Airspace , governs the FAA’s review of proposed construction exceeding certain height limits, defines airspace obstruction criteria, and provides for FAA aeronautical studies of proposed construction. Appendix F describes the FAA airspace review process and the extent of FAA authority related to airspace protection.

4.5.2 PART 77, SUBPART B, NOTIFICATION PROCESS
Federal regulations require any person proposing to build a ne w structure or alter an existing structure with a height that would exceed the elevations described in CFR Part 77 , Subpart B, Section 77.9, to prepare an FAA Form 7460-1, Notice of Proposed Construction or Alteration , and submit the notice to the FAA. The regulations apply to buildings and other structures or portions of structures, such as mechanical equipment, flag poles, and other projections that may exceed the aforementioned elevations.

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THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY OCTOBER 2012

Comprehensive Airport Land Use Compatibility Plan
for the Environs of San Francisco International Airport Airport/Land Use Compatibility Policies [IV-35]
Exhibit IV-10 depicts the approximate elevations at which the 14 CFR Part 77 notification requirements would be triggered; see Exhibit IV-11 for a close-up view of the northern half and Exhibit IV-12 for a close-up view of the southern half of the area. These exhibits are provided for informational purposes only. Official determinations of the areas and elevations within which the federal notification requ irements apply are subject to the authority of the FAA.

The FAA is empowered to require the filing of notices for proposed construction based on considerations other than height. For example, in some areas of complex airspace and high air traffic volumes, the FAA may be concerned about the potential for new construction of any height to interfere with electronic navigation aids. In these areas, the FAA will want to review all proposed construction projects.

The FAA has developed an on-line tool for project sponsors to use in determining whether they are required to file a Notice of Proposed Construction or Alteration. Sponsors of proposed projects are urged to refer to this website to determine whether they are required to file Form 7460-1 with the FAA:
https://oeaaa.faa.gov/oeaaa/external/gisTools/gisAction.jsp?action=showNoNoticeRequiredToolForm

4.5.3 AIRSPACE MAPPING
Part 77, Subpart C, establishes obstruction standards for the airspace around airports including approach zones, conical zones, transitional zones, and horizontal zones known as “imaginary surfaces.” Exhibit IV-13 depicts the Part 77 Civil Airport Imaginary Surfaces at SFO. The imaginary surfaces rise from the primary surface, which is at ground level immediately around the runways. The surfaces rise gradually along the appr oach slopes associated with each runway end and somewhat more steeply off the sides of the runw ays. The FAA considers an y objects penetrating these surfaces, whether buildings, trees or ve hicles travelling on roads and railroads , as obstructions to air navigation.

Obstructions may occur without compromis ing safe air navigation, but they must be marked, lighted, and noted on aeronautical publications to ensure that pilots can see and avoid them.

Close-up views of the north and south sides of the Part 77 surfaces are provided in Exhibit IV-14 and Exhibit IV-15, respectively. Additionally, Exhibit IV-16 provides an illustration of the outer approach and transitional surfaces located on the southeast side of the Part 77 surfaces.

Together with its tenant airlines, SFO has undertaken a mappin g effort to illustrate the critical aeronautical surfaces that protect the airspace required for multiple types of f light procedures such as those typically factored into FAA aeronautical studies, as shown on Exhibit IV-17 and Exhibit IV-18. These aeronautical surfaces include those established in accordance with FAA Order 8260.3B, U.S. Standard for Terminal Instrument Procedures (TERPS) , and a surface representing the airspace required for One-Engine Inoperative (OEI) departures from Runway 28L (to the west through the San Bruno Gap).
16 The exhibits depict the lowest elevations from the combination of the OEI procedure surface and all TERPS surfaces. The surf aces are defined with Required Obstacle Clearance (ROC) criteria to ensure safe separation of aircraft using the procedures from the underlying obstacles. Any proposed structures penetrating these surfaces are likely to receive Determinations of Hazard (DOH) from the FAA through the 7460-1 aeronautical study process. These surfaces indicate the maximum height at which structures can be considered compatible with Airport operations.

16 See Appendix F, Section F.3.2 for a discussion of one-engine inoperative procedures.

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280
380
280
280
101
101
101
101
1 35
82 82
1 1
82 ROLLINS RD

HILLSIDE BLVD
E 3RD AVE

CALIFORNIA DR

BAYSHORE BLVD

EL CAMINO REAL

MISSION RD
87TH ST

AIRPORT BL V D

CALLAN BLVD

GRAND AVE

MILLER AVE

SOUTHG ATE AVE

TROUSDALE DR

SHARP PARK RD

SNEATH LN

PARK WY

C RESPI DR
FLEETW
OO
D D R

MURCHISON D R

SULLIVAN AVE

ST FR ANCIS BLVD

JOHN DALY BLVD

RALSTON AVE

HE LEN DR

ARROYO DR

S AIRPORT BLVD

SKYLINE BO

ULEVARD

GENEVA AVE

N HUMBOLDT ST

FASSLER AVE

BAYSHORE HW
Y

TILTON AVE

N AMPHLETT BLVD
N M

CDONNELL R
D

STATE HIGHW
AY 35

HUNTINGTON AVE

LINDA MAR BLVD

HICKEY BL V D

SHAW RD

ADELINE DR
E 4TH AVE
TER

RA NOVA BLVD

HILLSIDE DR

LINDEN AVE

LO MITA AVE

S SPRUCE AVE

SERRA MONTE BLVD

CHESTNUT AVE

N DELAWARE ST

BELLEVUE AVE

E GRAND AVE

S NORFOLK ST

HOLLY A
V
E

CARMELITA AVE

S LINDEN AVE UTAH AVE

LOYOLA DR
RAY DR

DWIGHT RD

OCCIDENTAL AVE

N SAN MATEO DR
C

RESTMOOR DR

JENEVEIN AVE
M

ADISON AVE

MILLBRAE AVE

SISTER CITIES BLVD

CRYSTA L SPRINGS RD

W SAN B RUNO AVE

SEBASTIAN DR

ALTA MESA DR
LER
IDA WY

PARK PLAZA DR

PARK BLVD

JUNIPERO SERRA BLVD

ALICA N TE DR

MAGNOLIA AVE

SAN MATEO AVE

BROADWAY

HOFFMAN ST

RICHMOND DR
SE

VILLE DR

MONTEREY RD

RIDGEWOOD DR

EASTON DR

EARL AV E

SAN ANTONIO AVE

SHARON AVE

LARKSPUR DR
GATEW
A
Y DR

EL CERRITO AVE

CHATEAU DR

WESTLAKE AVE

BELLA VISTA DR
LIT T

LEFIELD AVE

CROCKER AVE

E MARKET ST

LINCOLN AVE

OAKS DR

EL CAMINO REAL

ODDSTAD BLVD

HUNT DR

SUMMIT DR

EUCALYPTUS AVE

HELEN DR

STATE HIGHW
AY 35

W SAN BRUNO AVE
EL CAM

INO REAL

SNEATH LN

MAGNOLIA AVE

HILLSIDE BLVD
E 3RD AVE
PacificaPacifica
Daly CityDaly City
San BrunoSan Bruno
BrisbaneBrisbane
San MateoSan Mateo
ColmaColma
HillsboroughHillsborough
South San FranciscoSouth San Francisco
MillbraeMillbrae BurlingameBurlingame
San FranciscoSan Francisco
Foster CityFoster City
BroadmoorBroadmoor
MontaraMontara
San Pedro Valley County ParkSan Pedro Valley County Park San Bruno Mt State & Cnty ParkSan Bruno Mt State & Cnty Park Golden Gate National Rec AreaGolden Gate National Rec Area McNee Ranch State ParkMcNee Ranch State Park
San Andreas LakeSan Andreas Lake

1. This map is intended for informational and conceptual planning purposes, generally representing the aeronautical surfaces considered most critical by San Francisco
International Airport (SFO) and its constituent airlines. It does not represent actual survey data, nor should it be used as the sole source of information regarding compatibility with airspace clearance requirements in the development of data for an FAA Form 7460-1, Notice of Proposed Construction or Alteration.

SFO does not certify its accuracy, information, or title to the properties contained in this plan. SFO does make any
warrants of any kind, express or implied, in fact or by law, with respect to boundaries, easements, restrictions, claims, overlaps, or other encumbrances affecting such properties.

2. This map does not replace the FAA's obstruction evaluation / airport airspace analysis (OE/AAA) review process. Proposing construction at elevations and heights that are lower than the critical aeronautical surfaces shown on this map, (a) does not relieve the construction sponsor of the obligation to file an FAA Form 7460-1, and (b) does not ensure that the proposal will be acceptable to the FAA, SFO, air carriers, or other agencies or stakeholders. SFO, San Mateo County, and local authorities having jurisdiction reserve the right to re-assess, review, and seek modifications to projects that may be consistent with this critical aeronautical surfaces map but that through the FAA OE/AAA process are found to have unexpected impacts to the safety or efficiency of operations at SFO.

Notes:

Exhibit IV-17

CRITICAL AERONAUTICAL SURFACES
-- NORTHWEST SIDE
Comprehensive Airport Land Use Plan
for the Environs of San Francisco International Airport C/CAG
City/County Association of Governments
of San Mateo County, California
Municipal Boundary
Road
Freeway
Railroad
Airport Property
BART Station
CALTRAIN Station
Regional Park or Recreation Area
Sources: San Francisco International Airport, Jacobs
Consultancy, and Planning Technology Inc., 2009
0 0.5 10.25
Miles
NORTH
Ground level
(Terrain)
Elevation of critical aeronautical surfaces, feet
Above Mean Sea Level (AMSL), North American
Vertical Datum of 1988 (NAVD88)
100
Height of Critical Aeronautical Surfaces, Feet Above
Ground Level (AGL)
LEGEND
Elevation of terrain, feet AMSL
Critical
aeronautical
surfaces

AIRPORT
Mean sea level
Elevation, feet AMSL
100
200
300
400
Elevation of critical aeronautical surfaces, feet AMSL (represented on plan with contours) Height of critical aeronautical surfaces,feet AGL (represented on plan with color gradient) Calculated as - =
0 Ground level
(Terrain)
A
B
C
A B C
A
B
C
A
C
35 and lower
35- 65
65 - 100
100 - 150
150 and more

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LEGEND
Elevation of critical aeronautical surfaces, feet
Above Mean Sea Level (AMSL), North American
Vertical Datum of 1988 (NAVD88)
100
Exhibit IV-18

CRITICAL AERONAUTICAL SURFACES
-- SOUTHEAST SIDE
Comprehensive Airport Land Use Plan
for the Environs of San Francisco International Airport C/CAG
City/County Association of Governments
of San Mateo County, California
Height of Critical Aeronautical Surfaces, Feet Above
Ground Level (AGL)
Municipal Boundary
Road
Freeway
Railroad
Airport Property
BART Station
CALTRAIN Station
Regional Park or Recreation Area
0 0.5 10.25
Miles
NORTH
SQL
82 280
101
101
101
92 82
92 92

ROLLINS RD
E 3RD AVE

CALIFORNIA DR

S NORFOLK ST

ALAMEDA DE LAS PULGAS
P

ARROTT DR

E HILLSDALE BLVD

AIRPORT B LVD

CRYSTAL SP RINGS RD
31ST AVE
28TH AVE

S DELAWARE ST

S GRANT ST

W HILLSDALE BLVD

HA YNE R D

OLD COUNTY RD
ELM ST
9TH AVE

FOSTER CITY BLVD

TROUSDALE DR

HALLMARK DR
42N D AVE

MURCHISON D R

SHELL BLVD

CHATEAU DR

SAN C A RLOS A VE
CANA
D
A RD

HILLER ST

MARINE PKWY

BEACH PARK BLVD

RALSTON AVE

N HUMBOLDT ST

POLHEMUS RD

BAYSHORE HW
Y

TILTON AVE

N AMPHLETT BLVD
N M

CDONNELL R
D

EL CERRITO AVE

SHAW RD
22ND AVE
STATE HIGHWAY 92

CEDAR ST

ADELINE DR

HILLSIDE DR

N DELAWARE ST

BUNKER HILL DR

DE ANZA BLVD

S AIRPORT BLVD

SOUTH RD

CARMELITA AVE
E 40TH A VE

LOYOLA DR

EDINBURGH ST

REDWOOD SHORES PKWY
RAY DR

DWIGHT RD

OCCIDENTAL AVE

N SAN MATEO DR

PALM AVEBOREL AVE

SEAPORT BLVD
M

ARINERS ISLA ND BLVD

MILLBRAE AVE

KEHOE AVE

SEBASTIAN DR

S AMPHLETT BLVD

VIRGINIA AVE

PARK BLVD

SHELL PKWY

MAGNOLIA AVE

CURTISS ST

PASADENA DR

CHULA VISTA DR
W

SANTA INEZ AVE

LEXINGTO
N AVE

GLENDORA DR

LAUREL ST

LOS PRAD
O
S
ALLEY

BROADWAY

HELEN DR

RICHMOND DR

NORTE DAME AVE
W 25TH AVE

PORT ROYAL AVE

EASTON DR

TICONDE R O GA DR

SAN ANTONIO AVE

SWORDFISH ST

SHARON AVE

SANDERLING ST
W 5TH AVE

EL CAMINO REAL

FOREST VIEW AVE

BELLA VISTA DR

COLUMBIA DR

SAN MATEO AVE

OAKS DR

ARBOR AVE

TILIA ST

BARROILHET AVE
E 25TH AVE

HUNT DR

BERMUDA DR

SUMMIT DR

HELEN DR

BEACH PARK BLVD

MAGNOLIA AVE

MAGNOLIA AVE

PALM AVE
E 3RD AVE

RALSTON AVE
Lower Crystal Springs RsvrLower Crystal Springs Rsvr
Upper Crystal ReservoirUpper Crystal Reservoir
Elevation of terrain, feet AMSL
Critical
aeronautical
surfaces

AIRPORT
Ground level
(Terrain)
Mean sea level
Elevation, feet AMSL
100
200
300
400
Elevation of critical aeronautical surfaces, feet AMSL (represented on plan with contours) Height of critical aeronautical surfaces, feet AGL (represented on plan with color gradient) Calculated as - =
0 1. This map is intended for informational and conceptual planning purposes, generally representing the aeronautical surfaces considered most critical by San Francisco
International Airport (SFO) and its constituent airlines. It does not represent actual survey data, nor should it be used as the sole source of information regarding compatibility with airspace clearance requirements in the development of data for an FAA Form 7460-1, Notice of Proposed Construction or Alteration.

SFO does not certify its accuracy, information, or title to the properties contained in this plan. SFO does make any
warrants of any kind, express or implied, in fact or by law, with respect to boundaries, easements, restrictions, claims, overlaps, or other encumbrances affecting such properties.

2. This map does not replace the FAA's obstruction evaluation / airport airspace analysis (OE/AAA) review process. Proposing construction at elevations and heights that are lower than the critical aeronautical surfaces shown on this map, (a) does not relieve the construction sponsor of the obligation to file an FAA Form 7460-1, and (b) does not ensure that the proposal will be acceptable to the FAA, SFO, air carriers, or other agencies or stakeholders. SFO, San Mateo County, and local authorities having jurisdiction reserve the right to re-assess, review, and seek modifications to projects that may be consistent with this critical aeronautical surfaces map but that through the FAA OE/AAA process are found to have unexpected impacts to the safety or efficiency of operations at SFO.

Notes:

Sources: San Francisco International Airport, Jacobs
Consultancy, and Planning Technology Inc., 2009
A
B
C
A B C
A
B
C
A
C
35 and lower
35- 65
65 - 100
100 - 150
150 and more

226 of 342

THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY NOVEMBER 2012

Comprehensive Airport Land Use Compatibility Plan
for the Environs of San Francisco International Airport Airport/Land Use Compatibility Policies [IV-55]
Exhibit IV-19, which is provided for information purposes only, depicts a profile view of the lowest critical airspace surfaces along the extended centerline of Runway 10L-28R – the TERPS Obstacle Departure Procedure (ODP) surface, representing standard all-engines departures, and the approximate OEI surface developed by SFO through independent study in consultation with the airlines serving SFO. The exhibit also shows the terrain elevation beneath the airspace surfaces and various aircraft approach and departure profile s, based on varying operatin g assumptions. The exhibit illustrates a fundamental principle related to the design of airspace protection surfaces. The surfaces are always designed below the actual aircraft flight profile which they are designed to protect, thus providing a margin of safety.

Note that the ODP climb profile is above the ODP airspace surface, and the OEI climb profile is above the OEI airspace surface.

4.5.4 AIRSPACE PROTECTION POLICIES
The following airspace protection policies (AP) shall apply to the ALUCP.

AP-1 COMPLIANCE WITH 14 CFR PART 77, SUBPART B, NOTICE OF PROPOSED

CONSTRUCTION OR ALTERATION
AP-1.1 Local Government Responsibility to Notify Project Sponsors Local governments should notify sponsors of proposed projects at the earliest opportunity to file Form 7460-1, Notice of Proposed Construction or Alteration , with the FAA for any proposed project that would exceed the FAA notification heights, as shown approximately on Exhibit IV-10. Under Federal law, it is the responsibility of the project sponsor to comply with all notification and other requirements described in 14 CFR Part 77. This requirement applies independent of this ALUCP.

AP-1.2 FAA Aeronautical Study Findings Required Before Processing Development Application
The sponsor of a proposed project that would exceed the FAA notification heights, as shown approximately on Exhibit IV-10, shall present to the local government permitting agency with his or her application for a development permit, a copy of the findings of the FAA’s aeronautical study, or evidence demonstrating that he or she is exempt from having to file an FAA Form 7460-1. It is the responsibility of the local agency to consider the FAA determination study findings as part of its review and decision on the proposed project.

AP-2 COMPLIANCE WITH FINDINGS OF FAA AERONAUTICAL STUDIES Project sponsors shall be required to comply with the findings of FAA aeronautical studies with respect to any recommended alterations in the building design and height and any recommended marking and lighting of their structures for their proposed projects to be deemed consistent with this ALUCP.

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THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY NOVEMBER 2012

Comprehensive Airport Land Use Compatibility Plan
for the Environs of San Francisco International Airport Airport/Land Use Compatibility Policies [IV-59]

AP-3 MAXIMUM COMPATIBLE BUILDING HEIGHT
In order to be deemed consistent with the ALUCP, the maximum height of a new building must be the lower of (1) the height shown on the SFO critical aeronautical surfaces map (Exhibits IV-17 and IV-18), or (2) the maximum height determined not to be a “hazard to air navigation” by the FAA in an aeronautical study prepared pursuant to the filing of Form 7460-1.

For the vast majority of parcels, the height limits established in local zoning ordinances are lower than the critical airspace surfaces. In those cases, the zoning district height regulations will control. Compliance with the zoning district height and the SFO critical aeronautical surfaces map, however, does not relieve the construction sponsor of the obligation to file a FAA Form 7460-1 Notice of Proposed Construction or Alteration, if required, and to comply with the determinations resulting from the FAA’s aeronautical study.

For a project to be consistent with this ALUCP, no local agency development permits shall be issued for any proposed structure that would penetrate the aeronautical surfaces shown on Exhibits IV-17 and IV-18 or the construction of which has not received a Determination of No Hazard from the FAA, or which would cause the FAA to increase the minimum visibility requirements for any instrument approach or departure procedure at the Airport.

AP-4 OTHER FLIGHT HAZARDS ARE INCOMPATIBLE
Proposed land uses with characteristics that may caus e visual, electronic, or wildlife hazards, particularly bird strike hazards, to aircraft taking off or landing at the Airport or in flight are incompatible in Area B of the Airport Influence Area. They may be permitted only if the uses are consistent with FAA rules and regulations. Proof of consistency with FAA rules and regulations and with any performance standards cited below must be provided to the Airport Land Use Commission (C/CAG Board) by the sponsor of the proposed land use action.

Specific characteristics that may create hazards to aircraft in flight and which are incompatible include:
(a) Sources of glare, such as highly reflective build ings or building features, or bright lights, including search lights or laser displays, which would interfere with the vision of pilots making approaches to the Airport.
(b) Distracting lights that that could be mistaken by pilots on approach to the Airport for airport identification lighting, runway edge lighting, runway end identification lighting, or runway approach lighting.
(c) Sources of dust, smoke, or water vapor that ma y impair the vision of pilots making approaches to the Airport.
(d) Sources of electrical interference with aircraft or air traffic control communications or navigation equipment, including radar.
(e) Land uses that, as a regular byproduct of th eir operations, produce thermal plumes with the potential to rise high enough and at sufficient velocities to interfere with the control of aircraft in

228 of 342

THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY NOVEMBER 2012

Comprehensive Airport Land Use Compatibility Plan
for the Environs of San Francisco International Airport [IV-60] Airport/Land Use Compatibility Policies
flight. Upward velocities of 4.3 meters (14.1 feet) per second at altitudes above 200 feet above the ground shall be considered as potentially interfering with the control of aircraft in flight.17 (f) Any use that creates an increased attraction for wi ldlife, particularly large flocks of birds, that is inconsistent with FAA rules and regulations, including, but not limited to, FAA Order 5200.5A, Waste Disposal Sites On or Near Airports , FAA Advisory Circular 150/5200-33B, Hazardous Wildlife Attractants On or Near Airports , and any successor or replacement orders or advisory circulars. Exceptions to this policy are acceptable for wetlands or other environmental mitigation projects required by ordinance, statute, court order, or Record of Deci sion issued by a federal agency under the National Environmental Policy Act.

4.5.5 iALP AIRSPACE TOOL
In consultation with C/CAG, SFO developed the iALP Airspace Tool, a web-based, interactive tool to evaluate the relationship of proposed buildi ngs with the Airport’s critical airspace surfaces. The iALP Airspace Tool is designed to assist planners, developers, and other interested persons with the implementation of the airspace protection policies of the SFO ALUCP. The tool helps users determine: (1) the maximum allowable building height at a given site, and/or (2) whether a building penetrates a critical airspace surface, and by how much, given the proposed building height.

A more detailed description of the iALP Airspace Tool an d a tutorial explaining how to use it is presented in Appendix J. Use of this tool, however, does not relieve a project sponsor of the duty to comply with all federal regulations, including the obligation to file Form 7460-1, Notice of Proposed Construction or Alteration, with the FAA.

17 This is a threshold establis hed by the California Energy Commission in its review of power plant licensing applications. See Blythe Solar Power Project:

Supplemental Staff Assessment, Part 2,. CEC-700-2010-004-REV1-SUP-PT2, July 2010. California Energy Commission. Docket Number 09-AFC-6, p.

25. This criterion is based on guidance established by the Australian Government Civil Aviation Authority (Advisory Circular AC 139-05(0), June 2004). The FAA’s Airport Obstructions Standards Committee (AOSC) is studying this matter but has not yet issued specific guidance.

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RESOLUTION 22-96

RESOLUTION OF THE BOARD OF DIRECTORS OF THE CITY/COUNTY ASSOCIATION OF

GOVERNMENTS OF SAN MATEO COUNTY, ACTING AS THE SAN MATEO COUNTY AIRPORT LAND USE COMMISSION, DETERMINING THAT THE CITY OF SAN BRUNO DRAFT 2023-2031 HOUSING

ELEMENT IS NOT CONSISTENT WITH THE COMPREHENSIVE AIRPORT LAND USE COMPATIBILITY PLAN FOR THE ENVIRONS OF SAN FRANCISCO INTERNATIONAL AIRPORT.

RESOLVED, by the Board of Directors of the City/County Association of Governments of San Mateo County (C/CAG), in its capacity as the San Mateo County Airport Land Use Commission, that,
WHEREAS, in accordance with the requirements of California Public Utilities Code Section 21676(b) a local agency General Plan, Zoning Ordinance and/or any affected specific plan must be consistent with the applicable airport/land use criteria in the relevant adopted Airport Land Use Compatibility Plan; and
WHEREAS, the City of San Bruno has referred its Draft Housing Element to C/CAG, acting as the Airport Land Use Commission, for a determination of consistency with the relevant airport/land use compatibility criteria in the Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport (SFO ALUCP); and WHEREAS, the Draft Housing Element identifies goals, policies, and programs to address San Bruno’s Regional Housing Needs Allocation (RHNA), and includes a list of housing opportunity sites; and
WHEREAS, the Draft Housing Element includes an inventory of 23 housing opportunity sites identified for development or redevelopment of mixed-use or residential projects that would be counted towards the San Bruno’s RHNA obligation; and
WHEREAS, three airport/land use compatibility factors are addressed in the SFO ALUCP that relate to the proposed general plan housing element amendment. These include policies for: (a) noise compatibility, (b) safety compatibility, and (c) airspace compatibility, as discussed below:
a. N
oise Compatibility - Pursuant to SFO ALUCP, Table IV-1, Noise/Land Use Compatibility Land Use Criteria, residential land uses are conditionally compatible in the CNEL 65-70 dB noise exposure contour range and are acceptable if sound insulation is provided to reduce interior noise levels from exterior sources to CNEL 45 dB or lower and if an avigation easement is granted to the City and County of San Francisco as operator of SFO. Five housing opportunity sites, Sites 7, 15, 18, 20, and 21, are located within the CNEL 65-70 dB contour. The noise compatibility conditions of the SFO ALUCP would apply to the affected sites at the time of construction permitting.

As
further outlined in SFO ALUCP Table IV-1, with a limited exception, residential land use is not compatible in the CNEL 70-75 dB noise exposure contour range. The exception applies to existing lots of record zoned for residential use as of the effective date of the SFO ALUCP (November 8, 2012). In such cases, new residences must be sound insulated to

230 of 342

achieve an indoor noise level of CNEL 45 dB or less from exterior sources, and the property owner must grant an avigation easement to the City and County of San Francisco prior to issuance of a building permit for the proposed building.

T
wo housing opportunity sites, Sites 14 and 19, are in the CNEL 70-75 dB noise exposure contour range. Site 14 is presently zoned P-D (Planned Development) and designated in the City’s General Plan for regional commercial use, and Site 19 is zoned C-N (Neighborhood Commercial) and designated in the General Plan for multi-use.

T
he Draft Housing Element, with respect to Sites 14 and 19, is inconsistent with the SFO ALUCP noise policies.
b. S
afety Compatibility - The SFO ALUCP includes safety zones and related land use compatibility policies and criteria. Two housing opportunity sites, Sites 15 and 21, are in Safety Zone 3 (Inner Turning Zone) and one housing opportunity site, Site 14 (the Tanforan Site), is in Safety Zone 4 (Outer Approach / Departure Zone). Per SFO ALUCP Table IV- 2, Safety Compatibility Criteria, housing is a compatible use in Safety Zone 3 and Safety Zone 4. Therefore, the Draft Housing Element is consistent with the SFO ALUCP safety policies
c. A
irspace Compatibility - The SFO ALUCP airspace policies establish maximum heights for the compatibility of new structures. The policies also stipulate the need for compliance with federal regulations requiring notification of the Federal Aviation Administration of certain proposed construction or alterations of structures.

B
ecause the Draft Housing Element is a policy document and not a specific development proposal, the airspace compatibility policies of the SFO ALUCP do not directly apply.

Consistency with the airspace compatibility policies would be required for future development proposals stemming from the Draft Housing Element.

WHEREAS, at its October 27, 2022 meeting, based on the factors listed above, the Airport Land Use Committee unanimously recommended that the C/CAG Board of Directors, acting as the Airport Land Use Commission, determine that the City of San Bruno Draft 2023-2031 Housing Element be found inconsistent with the noise compatibility policies of the SFO ALUCP; and, NOW THEREFORE BE IT RESOLVED, by the Board of Directors of the City/County Association of Governments for San Mateo County, acting as the San Mateo County Airport Land Use Commission, that the City of San Bruno Draft 2023-2031 Housing Element is not consistent with the Noise Compatibility policies and criteria contained in the Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport.

PASSED, APPROVED, AND ADOPTED, THIS 10TH DAY OF NOVEMBER 2022.

Davina Hurt, Chair

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RESOLUTION 22-104

RESOLUTION OF THE BOARD OF DIRECTORS OF THE CITY/COUNTY ASSOCIATION OF

GOVERNMENTS OF SAN MATEO COUNTY, ACTING AS THE SAN MATEO COUNTY AIRPORT LAND USE COMMISSION, DETERMINING THAT THE CITY OF SAN BRUNO’S GENERAL PLAN

AMENDMENT TO RECOGNIZE THE LOCAL AGENCY OVERRIDE PROCESS THAT IS PROVIDED BY

STATE LAW IS CONSISTENT WITH THE POLICIES OF THE COMPREHENSIVE AIRPORT LAND USE COMPATIBILITY PLAN FOR THE ENVIRONS OF SAN FRANCISCO INTERNATIONAL AIRPORT.

RESOLVED, by the Board of Directors of the City/County Association of Governments of San Mateo County (C/CAG), in its capacity as the San Mateo County Airport Land Use Commission, that,
WHEREAS, California Government Code Section 65302.3 states that a local agency General Plan, Zoning Ordinance and/or any affected specific plan must be consistent with the applicable airport/land use criteria in the relevant adopted Airport Land Use Compatibility Plan (ALUCP); and WHEREAS, the City of Bruno has proposed an amendment to its General Plan to recognize the Local Agency Override process that is provided by State law, and has referred this Amendment to the C/CAG Board, acting as the San Mateo County Airport Land Use Commission, for a determination of consistency with the SFO ALUCP; and
WHEREAS, the General Plan Amendment specifically addresses the “Local Agency Override” provision of state law [PUC Section 21675.1 (d)] which provides a process for jurisdictions to override an airport land use commission disapproval of a proposed land use policy or development action, and is consistent with the provisions of the SFO ALUCP Section 3.3.3, which directly acknowledges and describes the override process; and
NOW THEREFORE BE IT RESOLVED, by the Board of Directors of the City/County Association of Governments for San Mateo County, acting as the San Mateo County Airport Land Use Commission, that the City of San Bruno’s General Plan Amendment is determined to be consistent with the applicable airport land use policies and criteria contained in the Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport.

PASSED, APPROVED, AND ADOPTED, THIS 10TH DAY OF NOVEMBER 2022.

Davina Hurt, Chair

232 of 342

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7 11
12 15 21
14 /gid00036/gid00047/gid00038/gid00045/gid00001/gid00024/gid00017/gid00001/gid00067/gid00035 /gid00036/gid00047/gid00038/gid00045/gid00001/gid00024/gid00017/gid00001/gid00067/gid00035 /gid00036/gid00047/gid00038/gid00045/gid00001/gid00024/gid00017/gid00001/gid00067/gid00035 /gid00036/gid00047/gid00038/gid00045/gid00001/gid00024/gid00017/gid00001/gid00067/gid00035 /gid00036/gid00047/gid00038/gid00045/gid00001/gid00023/gid00022/gid00001/gid00067/gid00035 /gid00036/gid00047/gid00038/gid00045/gid00001/gid00023/gid00022/gid00001/gid00067/gid00035 /gid00036/gid00047/gid00038/gid00045/gid00001/gid00023/gid00022/gid00001/gid00067/gid00035 /gid00036/gid00047/gid00038/gid00045/gid00001/gid00023/gid00022/gid00001/gid00067/gid00035 82 280
380
101
101
101

CALLAN BLVD

MISSION RD

MILLER AVE

HILLSIDE BLVD

HIC KEY BLVD

SN EAT H LN

PARK WY

OAKMONT DR

FLEET WOOD D R

ARROYO DR

S AIRPORT BLVD

SHARP PARK RD

N M CDONN ELL RD

AIRPORT BLVD

LINDEN AVE

L OMITA AVE

S SPR UCE AVE

CHESTNU T AVE

E GRAND AVE

WESTBOROUG
H BLVD

HOLLY AVE

S LIND EN AVE

HELEN DR

UTAH AVE

CRESTMO
O
R DR

JUN IPERO SERR A BLVD

JENEVEIN AVE
M
AD
IS
O
N AVE

SISTER CIT IES BLVD

CR Y S TAL SPRINGS RD

E SAN BRU NO AVE

W SA N BRU NO A VE

W O RANGE AVE

ALTA MESA D R

PARK BLVD

ROLLINGWOOD DR
M
AGN
O

LIA AVE

SAN MATEO AVE

RIC HMOND DR

OLYMPIC D R

EVERGREEN AVE

WHITMAN WY
RIDGEW
OOD DR

LAU REL AVE
S

T FRANCIS BLVD

BAYSHORE HWY

SKYLIN E BOULEVAR D
A

VALON DR

LITT LEF IELD AVE

TAYLOR BLVD

SH AN NON DR

EL CAMINO REAL

EU CALYPT US AVE

HILLCREST BLVD

LAR KSPUR DR

OLD BAYSH OR E BLVD

MOSSW OOD LN

GRAN D AVE

SKYLIN E BOULEVAR D

SAN MATEO AVE

MILLER AVE

AIRPORT BLVD

AIRPORT BLVD

W SAN BR UNO AVESNEATH LN HUNT IN GT ON AVE

EL CAMINO REAL

HICKEY BLVD

MAGN OLIA AVE
Cattle Hill
810
San Bruno Mountain
1314
PacificaPacifica
Daly CityDaly City
San BrunoSan Bruno
South San FranciscoSouth San Francisco
BrisbaneBrisbane
ColmaColma
MillbraeMillbrae
San FranciscoSan Francisco
BroadmoorBroadmoor
BurlingameBurlingame
San Bruno Mt State & Cnty ParkSan Bruno Mt State & Cnty Park Golden Gate National Rec AreaGolden Gate National Rec Area 0 0.4 0.80.2
Miles
Exhibit IV-3
Comprehensive Airport Land Use Plan
for the Environs of San Francisco International Airport

AIRPORT INFLUENCE AREA B --

NORTH SIDE
NORTH
San FranciscoSan Francisco
BayBay
C/CAG
City/County Association of Governments
of San Mateo County, California
CNEL 65 dB
San FranciscoSan Francisco
International AirportInternational Airport
Elevation 13.2 FeetElevation 13.2 Feet10L
10R
19 R
1 R
1 L
19 L
28R
28L
Municipal Boundary
Road
Regional Park or Recreation Area
Freeway
Railroad
CNEL Contour, 2020 Forecast
LEGEND
Airport Property
BART Station
CALTRAIN Station
Outer Boundary of Safety Zones
Open Space
Local Park, Golf Course, Cemetery
14 CFR Part 77 Conical Surface
Outer Boundary of TERPS Approach and
OEI Departure Surfaces
Boundary for Airport Influence Area B
Sources:
100:1 FAA Notification Zone: Ricondo & Associates, Inc. and Jacobs Consultancy, based on 14 CFR Part 77, Subpart B, Section 77.9.

Outer Boundary of TERPS Approach and OEI Departure
Surfaces: San Francisco International Airport, Jacobs
Consultancy, and Planning Technology Inc., 2009
Safety Compatibility Zones: Jacobs Consultancy Team, 2009; Ricondo & Associates, Inc., 2011
Noise Contour: URS Corporation and BridgeNet International.

Draft Environmental Assessment, San Francisco International Airport Proposed Runway Safety Area Program, June 2011
6 3
13 20
18 19
1 7
11 12 15 21
9 5
2 22
23 17
1016
8 4
14 /gid00052/gid00064/gid00077/gid00001/gid00035/gid00081/gid00084/gid00077/gid00078/gid00001/gid00037/gid00081/gid00064/gid00069/gid00083/gid00001/gid00019/gid00017/gid00019/gid00020/gid00014/gid00001/gid00019/gid00017/gid00020/gid00018 /gid00041/gid00078/gid00084/gid00082/gid00072/gid00077/gid00070/gid00001/gid00038/gid00075/gid00068/gid00076/gid00068/gid00077/gid00083/gid00001/gid00054/gid00079/gid00067/gid00064/gid00083/gid00068/gid00001/gid00052/gid00084/gid00072/gid00083/gid00064/gid00065/gid00075/gid00068/gid00001/gid00052/gid00072/gid00083/gid00068/gid00082

Exhibit IV-7
Comprehensive Airport Land Use Plan
for the Environs of San Francisco International Airport

SAFETY COMPATIBILITY ZONES
NORTH
San FranciscoSan Francisco
BayBay
San FranciscoSan Francisco
International AirportInternational Airport
28 L
28 R
10 L
10 R 19
L
19 R
1 R
1 L
Elevation 13.2 FeetElevation 13.2 Feet
C/CAG
City/County Association of Governments
of San Mateo County, California
11 LEGEND
1 - Runway Protection Zone-Object Free Area1 - Runway Protection Zone-Object Free Area 2 - Inner Approach/Departure Zone2 - Inner Approach/Departure Zone 3 - Inner Turning Zone3 - Inner Turning Zone
4 - Outer Approach/Departure Zone4 - Outer Approach/Departure Zone 5 - Sideline Zonee5 - Sideline Zonee
0 0.25 0.50.125
Miles
Place of Worship
BART Station
CALTRAIN Station
School
Hospital
Airport Property
Safety Compatibility Zones

ENGLISH AS A

SECOND LANGUAGE

INSTITUTE

MILLBRAE SERRA CONVALESCENT HOSPITAL
MILLS
101

GOLDEN GATE

NATIONAL

CEMETERY

SHOPS AT TANFORAN
U n i n c .U n i n c .

COOLIDGE GRAMMAR SCHOOL

GLEN OAKS SCHOOL

MILLBRAE MONTESSORI SCHOOL

EDGEMONT SCHOOL

SAINT VERONICA ELEMENTARY SCHOOL

SIERRA MORENA SCHOOL

CALVARY LUTHERAN PRE-SCHOOL

HAPPY HALL SCHOOL

BAYSIDE PARK

ANGUS AVE

PINE ST

KAINS AVE

BAYHILL DR

NOOR AVE

TANFORAN AVE

MAHLER RD

HINCKLEY RD

STANTON RD

MALCOLM RD

MITTEN RD

COWAN RD

BURLWAY RD
Safety Compatibility Zones:
- Jacobs Consultancy Team, 2009; Ricondo & Associates, Inc., 2011 County Base Maps:
- San Mateo County Planning & Building Department, 2007 Local Plans:
- Burlingame Bayfront Specific Area Plan, August 2006
- Burlingame Downtown Specific Plan, January 2009
- Burlingame General Map, September 1984
- North Burlingame/ Rollins Road Specific Plan, February 2007 - Colma Municipal Code Zoning Maps, December 2003
- Daly City General Plan Land Use Map, 1987
- Hillsborough General Plan, March 2005
- Millbrae Land Use Plan, November 1998
- Pacifica General Plan, August 1996
- San Bruno General Plan, December 2008
- San Mateo City Land Use Plan, March 2007
- San Mateo County Zoning Map, 1992
- South San Francisco General Plan, 1998
Sources:

Municipal Boundary
Road
Regional Park or Recreation Area
Freeway
Railroad
Open Space
Planned use not mapped
Public
Multi-Family Residential
Single Family Residential
Commercial
Industrial, Transportation, and Utilities
Local Park, Golf Course, Cemetery
Mixed Use
Transit Oriented Development
Planned Land Use Per General Plans:

Internal boundaries of ALP-defined areas
22 33
33 44
22 33
33 11
44 55
55 55
55 55
55 55
55 22
44 3333
33 33
22 44
11 11

MILLBRAE SCHOOL

HOOVER CHILDRENS CENTER

MILLBRAE NURSERY SCHOOL
380
101
101
101
82 ROLLINS RD

CALIFORNIA DR AIRPORT BLVD

SNEATH LN

MURCHISON DR

HILLC REST BLVD

HELEN DR

S AIRPORT BLVD

TROUSDALE DR

BAYSHORE HW
Y

ADELINE DR

LOMITA AVE

S SPRUCE AVE

HILLSIDE DR

S MCDONNELL RD

S LINDEN AVE

UTAH AVE
RAY DR

DWIGHT RD
JENEVE
IN AVE

OAK GROVE AVE
M
ADIS
O
N AVE

MILLBRAE AVE

CRY S TAL SPRINGS RD

E SAN BRUNO AVE

SEBASTIAN DR

PARK BLVD

BLOOMFIELD RD

E MILLB

RAE AVE

CARMELITA AVE
MAGNO

LIA AVE

N HUMBOLDT ST
SAN M

ATEO AVE

W ORANGE AVE
BROADW
AY

RICHMOND DR

TAYLOR BLVD

POPLAR AVE

WHITMAN WY

RIDGEWOOD DR

EASTON DR

LAUREL AVE

CRESTMOOR DR

LARKSPUR DR
QUESAD
A WY

S ASHTON AVE

ASHTON AVE

W SAN BRUN
O AVE

EVA DLEIFELTTIL

N BAYSHORE BLVD

SKYLINE BOULEVARD

EL CAMINO REAL

HUNT DR

OLD BAY

SHORE BLVDMOSSWOOD LN

EL CAMINO REAL

MAGNOLIA AVE

CRESTMOOR DR

HUNTINGTON AVE

EL CAMINO REAL

W SAN BRUNO AVE

COYOTE POINT RECREATION AREA

BAYSIDE PARK

GREEN HILLS COUNTRY CLUB

POPLAR CREEK GOLF COURSE

JUNIPERO SERRA COUNTY PARK

SISTERS OF MERCY

MILLS HIGH SCHOOL

BAYFRONT PARK

PENINSULA HIGH SCHOOL

THE CROSSINGS

CAPUCHINO HIGH SCHOOL

MILLS CANYON PARK

PENINSULA HOSPITAL

WASHINGTON PARK

BURLINGAME HIGH SCHOOL

SOUTH SAN FRANCISCO HIGH SCHOOL

CENTRAL PARK

SAN MATEO PERFORMING ARTS CENTER

PARKSIDE INTERMEDIATE SCHOOL

BURLINGAME INTERMEDIATE SCHOOL

POINT SAN BRUNO

BELLE AIR ELEMENTARY SCHOOL

CUERNAVACA PARK

MILLS ESTATE PARK

TAYLOR MIDDLE SCHOOL

PONDEROSA ELEMENTARY SCHOOL

SPRING VALLEY ELEMENTARY SCHOOL

GREEN HILLS ELEMENTARY SCHOOL

BRENTWOOD PARK

MEADOWS ELEMENTARY SCHOOL

SAINT VERONICA ELEMENTARY SCHOOL

SAN MATEO HIGH SCHOOL
DECIMA M. ALLEN ELEMENTARY SCHOOL

CRESTMOOR ELEMENTARY SCHOOL

SHORELINE PARK

POINT SAN BRUNO PARK

HARBOR VIEW PARK

EL CRYSTAL ELEMENTARY SCHOOL
PARK

LOMITA PARK ELEMENTARY SCHOOL

VICTORIA PARK

SAINT DUNSTANS ELEMENTARY SCHOOL
MCKINLEY ELEMENTARY SCHOOL WASHINGTON ELEMENTARY SCHOOLROOSEVELT ELEMENTARY SCHOOLBURLINGAME FIRE STATION 35

BURLINGAME CITY HALL
PARK
BURLINGAME FIRE STATION 34

OUR LADY OF ANGELS ELEMENTARY SCHOOL

ALPINE PARK

PALOMA PARK
MillbraeMillbrae
BurlingameBurlingame
San BrunoSan Bruno
South San FranciscoSouth San Francisco
San MateoSan Mateo
HillsboroughHillsborough
San Andreas LakeSan Andreas Lake
Exhibit IV-7
Comprehensive Airport Land Use Plan
for the Environs of San Francisco International Airport

SAFETY COMPATIBILITY ZONES
NORTH
San FranciscoSan Francisco
BayBay
San FranciscoSan Francisco
International AirportInternational Airport
28 L
28 R
10 L
10 R 19
L
19 R
1 R
1 L
Elevation 13.2 FeetElevation 13.2 Feet
C/CAG
City/County Association of Governments
of San Mateo County, California
11 LEGEND
1 - Runway Protection Zone-Object Free Area1 - Runway Protection Zone-Object Free Area 2 - Inner Approach/Departure Zone2 - Inner Approach/Departure Zone 3 - Inner Turning Zone3 - Inner Turning Zone
4 - Outer Approach/Departure Zone4 - Outer Approach/Departure Zone 5 - Sideline Zonee5 - Sideline Zonee
0 0.25 0.50.125
Miles
Place of Worship
BART Station
CALTRAIN Station
School
Hospital
Airport Property
Safety Compatibility Zones

ENGLISH AS A

SECOND LANGUAGE

INSTITUTE

MILLBRAE SERRA CONVALESCENT HOSPITAL
MILLS
101

GOLDEN GATE

NATIONAL

CEMETERY

SHOPS AT TANFORAN
U n i n c .U n i n c .

COOLIDGE GRAMMAR SCHOOL

GLEN OAKS SCHOOL

MILLBRAE MONTESSORI SCHOOL

EDGEMONT SCHOOL

SAINT VERONICA ELEMENTARY SCHOOL

SIERRA MORENA SCHOOL

CALVARY LUTHERAN PRE-SCHOOL

HAPPY HALL SCHOOL

BAYSIDE PARK

ANGUS AVE

PINE ST

KAINS AVE

BAYHILL DR

NOOR AVE

TANFORAN AVE

MAHLER RD

HINCKLEY RD

STANTON RD

MALCOLM RD

MITTEN RD

COWAN RD

BURLWAY RD
Safety Compatibility Zones:
- Jacobs Consultancy Team, 2009; Ricondo & Associates, Inc., 2011 County Base Maps:
- San Mateo County Planning & Building Department, 2007 Local Plans:
- Burlingame Bayfront Specific Area Plan, August 2006
- Burlingame Downtown Specific Plan, January 2009
- Burlingame General Map, September 1984
- North Burlingame/ Rollins Road Specific Plan, February 2007 - Colma Municipal Code Zoning Maps, December 2003
- Daly City General Plan Land Use Map, 1987
- Hillsborough General Plan, March 2005
- Millbrae Land Use Plan, November 1998
- Pacifica General Plan, August 1996
- San Bruno General Plan, December 2008
- San Mateo City Land Use Plan, March 2007
- San Mateo County Zoning Map, 1992
- South San Francisco General Plan, 1998
Sources:

Municipal Boundary
Road
Regional Park or Recreation Area
Freeway
Railroad
Open Space
Planned use not mapped
Public
Multi-Family Residential
Single Family Residential
Commercial
Industrial, Transportation, and Utilities
Local Park, Golf Course, Cemetery
Mixed Use
Transit Oriented Development
Planned Land Use Per General Plans:

Internal boundaries of ALP-defined areas
22 33
33 44
22 33
33 11
44 55
55 55
55 55
55 55
55 22
44 3333
33 33
22 44
11 11

MILLBRAE SCHOOL

HOOVER CHILDRENS CENTER

MILLBRAE NURSERY SCHOOL
6 3
13 20
18 19
1 7
11 12 15 21
9 5
2 22
23 17
1016
8 4
14 44
/gid00052/gid00064/gid00077/gid00001/gid00035/gid00081/gid00084/gid00077/gid00078/gid00001/gid00037/gid00081/gid00064/gid00069/gid00083/gid00001/gid00019/gid00017/gid00019/gid00020/gid00014/gid00001/gid00019/gid00017/gid00020/gid00018 /gid00041/gid00078/gid00084/gid00082/gid00072/gid00077/gid00070/gid00001/gid00038/gid00075/gid00068/gid00076/gid00068/gid00077/gid00083/gid00001/gid00054/gid00079/gid00067/gid00064/gid00083/gid00068/gid00001/gid00052/gid00084/gid00072/gid00083/gid00064/gid00065/gid00075/gid00068/gid00001/gid00052/gid00072/gid00083/gid00068/gid00082 82 280
380
101
101

EL CAMINO REAL

MISSION RD

CALLAN BLVD

HILLSIDE BLVD

GRAND AVE

MILLER AVE

SNEATH LN

PARK WY

OAKMONT DR

FLEETWOOD DR

ARROYO DR

S AIRPORT BLVD

N MCDONNELL RD

HUNTINGTON AVE

AIRPORT BLVD

LOMITA AVE

S SPRUCE AVE

CHESTNUT AVE

S MCDONNELL RD

E GRAND AVE

WESTB OROUGH BLVD

HOLLY AVE

S LINDEN AVE

UTAH AVE

CRESTMO
OR DR

JENEVEIN AVE
M
ADIS
O
N AVE

SISTER CITIES BLVD

CRY S TAL SPRINGS RD

E SAN BRUNO AVE

W SAN BRUNO AVE

W O RANGE AVE

HICKEY BLVD

ALTA MESA DR

PARK BLVD

SHARP PARK RD

ROLLINGWOOD DR

JUNIPERO SERRA BLVD
MAGNO

LIA AVE

EVERGREEN AVE

SAN MATEO AVE

HELEN DR

OLYMPIC DR

GLENVIEW DR

WHITMAN WY
RIDGEW
OOD DR

EARL A V E

SERRAMONTE BLVD

SAN ANTONIO AVE
7TH AVE

SKYLINE BOULEVARD

RICHMOND DR
A
V

ALON DR

BARCELONA DR

LITTLEFIELD AVE

BAYSHORE HWY

EL CAMINO REAL

EUCALYPTUS AVE

TAYLOR BLVD

MOSSWOOD LN

EL CAMINO REAL

AIRPORT BLVD

W SAN BRUNO AVE

MAGNOLIA AVE

GRAND AVE

SNEATH LN

SKYLINE BOULEVARD

HUNTINGTON AVE

MILLER AVE
San BrunoSan Bruno
South San FranciscoSouth San Francisco
PacificaPacifica
MillbraeMillbrae
Daly CityDaly City
ColmaColma BrisbaneBrisbane
San Bruno Mt State & Cnty ParkSan Bruno Mt State & Cnty Park Golden Gate National Rec AreaGolden Gate National Rec Area San Andreas LakeSan Andreas Lake
BurlingameBurlingame
0 0.25 0.50.125
Miles
Exhibit IV-14
Comprehensive Airport Land Use Plan
for the Environs of San Francisco International Airport 14 CFR PART 77 AIRPORT IMAGINARY

SURFACES -- NORTH SIDE
NORTH
BART Stations
CALTRAIN Stations
Municipal Boundary
Roads
Regional Park or Recreation Area
Freeways
Railroads
San FranciscoSan Francisco
International AirportInternational Airport
San FranciscoSan Francisco
BayBay
C/CAG
City/County Association of Governments
of San Mateo County, California
Elevation 13.2 FeetElevation 13.2 Feet
Isometric Drawing of 14 CFR Part 77, Section 77.19
Civil Airport Imaginary Surfaces
Sources:
14 CFR Part 77 Surfaces: City and County of San Francisco, Ricondo & Associates, Inc., 2010
LEGEND
Elevation Contour, feet AMSL100' MSL
14 CFR Part 77 Civil Airport Imaginary Surfaces
10L
10R 19
R
1 R
1 L
163.2' MSL
200' MSL
250' MSL
300' MSL
Horizontal Surface
163.2' MSL
10R = 5.9' MSL
10L = 5.4' MSL
163.2' MSL150' MSL
163.2' MSL150' MSL
100' MSL
100' MSL
50' MSL
19R = 8.8' MSL
1L = 10.3' MSL
1R = 11.3' MSL
50' MSL100' MSL
163.2' MSL200' MSL
250' MSL
300' MSL350' MSL
363.2' MSL
50' MSL
19 L
19L =10.0' MSL50' MSL
350' MSL
363.2' MSL
50' MSL
100' MSL
6 3
13 20
18 19
1 7
11 12 15 21
9 5
2 22
23 17
1016
8 4
14 /gid00052/gid00064/gid00077/gid00001/gid00035/gid00081/gid00084/gid00077/gid00078/gid00001/gid00037/gid00081/gid00064/gid00069/gid00083/gid00001/gid00019/gid00017/gid00019/gid00020/gid00014/gid00001/gid00019/gid00017/gid00020/gid00018 /gid00041/gid00078/gid00084/gid00082/gid00072/gid00077/gid00070/gid00001/gid00038/gid00075/gid00068/gid00076/gid00068/gid00077/gid00083/gid00001/gid00054/gid00079/gid00067/gid00064/gid00083/gid00068/gid00001/gid00052/gid00084/gid00072/gid00083/gid00064/gid00065/gid00075/gid00068/gid00001/gid00052/gid00072/gid00083/gid00068/gid00082

City Council Agenda Item
Staff Report

CITY OF SAN BRUNO
DATE:November 15, 2022
TO:Honorable Mayor and Members of the City Council
FROM:Jovan D. Grogan, City Manager
PREPARED BY:Lupita Huerta, City Clerk
SUBJECT: Re-appoint Expired Members and Make New Appointments to Fill Current Vacancies on the Culture & Arts Commission, Parks & Recreation Commission, and Traffic Safety & Parking Committee
BACKGROUND:

The City of San Bruno has 10 citizen Advisory Commissions, Boards and Committees, commonly referred to as “CBCs”. As the governing body for the City of San Bruno, the City Council appoints all members to CBCs.

In October of every even year, half of the City’s current CBC Members’ terms expire, and a recruitment to fill those seats occurs. At that time expiring members who wish to be reappointed to serve another term are invited to submit a new application for possible reappointment to the committee, board, or commission that they currently serve. Additionally, positions on CBCs become vacant from time to time. When this occurs, the City Clerk’s Office administers a recruitment for the vacant position and notifies the City Council of the vacancy.

At present, there are several vacant positions on CBCs (listed below) and, on October 31, 2022, the four-year terms for 23 terms of existing appointees expired. Several existing members have applied to be reappointed, some members have elected not to be reappointed, and there are new applicants for some vacant and expiring CBC positions.

Staff presented the appointment process at a Special City Council meeting on October 11, 2022 and received direction from the City Council to schedule interviews as soon as possible for the Boards, Commissions, and Committees that may be in jeopardy of a quorum and to proceed with the remaining interviews.

At the October 25, 2022 Regular City Council meeting, City Council re-appointed and appointed the following CBC members to the respective commission, boards and committees:

Bicycle & Pedestrian Advisory Committee
•Cecile Riborozo
•Nina Stupi
•Matthew Cheng-Zedler
•1 Vacancy

238 of 342

Honorable Mayor and Members of the City Council
November 15, 2022

Citizens Crime Prevention Committee
•Rhonda Boone
•Robert Riechel
•Deanna Robinson
•1 Vacancy
Planning Commission
•Rick Biasotti
•Marco Durazo
•Gerard Madden
•1 Vacancy
DISCUSSION:

A summary of the 10 Citizen Advisory Commissions, Boards and Committees is noted below:

•Bicycle & Pedestrian Advisory Committee, 7 Members
•Citizen Crime Prevention Committee, 7 Members
•Citizens Revenue Measure Oversight Committee, 7 Members •Culture & Arts Commission, 7 Members
•Emergency Preparedness Committee, 5 Members
•Parks & Recreation Commission, 8 Members plus 1 Youth
•Planning Commission, 7 Members
•Recreation and Aquatics Center Advisory Committee, 8 Members •Senior Citizens Advisory Board, 7 Members
•Traffic, Safety & Parking Committee, 5 Members
Appointees to CBCs are not compensated by the City and service on the bodies is voluntary.

CBCs are “standing” bodies, which are different from “ad hoc” bodies in that they have a regular meeting schedule. Ad hoc bodies/committees do not have a regular meeting schedule, are typically established for a limited duration and their authorization must be renewed on an annual basis by the City Council.

The City Council conducted or will conduct interviews at Special City Council meetings scheduled on:

•Saturday, October 22, 2022
•Tuesday, October 25, 2022
•Wednesday, October 26, 2022
•Wednesday, November 30, 2022
The interviewees are invited to attend through the City Clerk’s Office, and have the option of interviewing in-person or connecting via Zoom. The process for the reappointment is fully detailed in Attachment 1 to this report, Section 8 of the DRAFT City Council Policies and Procedures Manual.

At the November 15, 2022 meeting, the City Council will consider appointments to the Culture & Arts Commission; Parks & Recreation Commission; and Traffic Safety & Parking Committee.

239 of 342

Honorable Mayor and Members of the City Council
November 15, 2022

Individuals seeking reappointment and new applicants to these bodies can be found on Attachment 2.

FISCAL IMPACT:

There is no fiscal impact.

ENVIRONMENTAL IMPACT:

There is no environmental impact.

RECOMMENDATION:

Re-appoint Expired Members and Make New Appointments to Fill Current Vacancies on Culture & Arts Commission, Parks & Recreation Commission, and Traffic Safety & Parking Committee.

ALTERNATIVES:

ATTACHMENTS:

1. Section 8 of DRAFT City Council Policies and Procedures Manual

2. Matrix of Applicants for the three Commissions, Boards and Committees being Re- appointed/Appointed.

3. Matrix of Advisory Commissions, Boards and Committees (CBCs) With Details on Vacant and Expiring Terms as well as New Applications

240 of 342

ATTACHMENT 1: Section 8 of DRAFT City Council Policies and Procedures Manual Section 8. Appointments to City Commissions, Boards and Committees (CBCs)

A. Appointments per San Bruno Municipal Code Process

1. In accordance with the San Bruno Municipal Code, the Mayor shall make all appointments to and removals from City boards, commissions, and committees, subject to approval by the City Council. (SB MuniCode 2.04.120 and CA Gov’t Code §40605)

2. Use of the Alternative Appointment Process for Commission, Board or Committee Members
a. The Mayor may elect to use the Alternative Appointment Processes outlined in Sections 7.B and 7.C.
b. A majority of the City Council may only elect to use the Alternative Appointment Process after the Mayor has
proposed an appointment(s) that the City Council has not approved in accordance with SB MuniCode 2.04.120 and
CA Gov’t Code §40605.

3. Removals from City boards, commissions, and committees shall follow the process outlined in SB MuniCode 2.04.120 as well as applicable Federal and State law.

B. Alternative Appointment Process for Commission, Board or Committee Members

Does not apply to San Bruno Community Foundation Board of Director Appointments, see Section 7.C.

Round One: Nominations

oMayor or Presiding Officer of the Meeting to facilitate nominations oCouncil members to be given the opportunity to make a Motion for Consideration for Appointment for any applicant
•Requires a Second

Note: Any applicant that receives a Motion and a Second advances to Round 2 (no vote of the full City Council taken at this time).

During the nomination process, Council members will not be called upon in alpha order. Members must ask to be recognized through the Chair if they would like to make a nomination.

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Round Two: Simultaneous Voting Process for Nominees
oCity Clerk to call Council members alphabetically, with the Vice Mayor and Mayor last.
oOnce called upon, Council members shall vote for their preferred nominee or abstention.
oIn the event of a tie or if no single nominee receives three votes from the City Council, the appointment process proceeds to Round Three.
•The nominee(s) that receive the lowest number of votes (or are tied for the lowest number of votes) shall be eliminated. ▪Note: If five nominees each receive one vote, all five nominees advance to Round Three.

Round Three: Simultaneous Voting Process for Nominees, if needed oCity Clerk to call Council members alphabetically, with the Vice Mayor and Mayor last.
oOnce called upon, Council members shall vote for their preferred nominee or abstention.
oIn the event of a tie or if no single nominee receives three votes from the City Council, the appointment process proceeds to Round Four.
•The nominee(s) that receive the lowest number of votes (or are tied for the lowest number of votes) shall be eliminated. ▪Note: If five nominees each receive one vote, all five nominees advance to Round Four.

Round Four: Simultaneous Voting Process for Nominees, if needed oCity Clerk to call Council members alphabetically, with the Vice Mayor and Mayor last.
oOnce called upon, Council members shall vote for their preferred nominee or abstention.
oIn the event of a tie or if no single nominee receives three votes from the City Council, the appointment process ends and Council shall provide direction to staff whether to leave the position vacant or conduct a new recruitment process to fill the vacancy.

Page Break

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C. Appointment Process for SBCF Board of Director Appointments

Founded in 2013 by the City of San Bruno, the San Bruno Community Foundation (SBCF) is a 501(c)(3) tax-exempt nonprofit organization. The SBCF is distinguished from other City CBC’s in that its legal structure is a dependent- nonprofit corporation under the City of San Bruno and SBCF Board members have a legal fiduciary duty to the Foundation (not the City). As such, the City Council has established the following Alternative Process for appointing SBCF Board members, which may be used at the discretion of the Mayor or a majority of the City Council.

1. Advertising for and recruitment of SBCF Board members shall be done in accordance with Section 7D of this document, with the exception that:
oThe City Council shall receive all applications.
oThe Council may meet to review applications and determine which applicants to invite for an interview.
oThe SBCF Board shall select two members to attend and
participate in the City Council interview process.
oThe appointment process for SBCF Board members shall follow the procedures outlined in Section 7A (option: Section 7B) of this document.

D. Recruitment Officer for Commission, Board or Committee Members

1. The City Clerk serves as the official Recruitment Officer for members of the CBC’s. As such, the City Clerk is responsible for advertising vacancies (whether scheduled or unscheduled) in conformance with Government Code section 54974, receiving and processing applications, scheduling interviews, and preparing staff reports related to CBC appointments. Additionally, as the CBC Recruitment Officer, the City Clerk is responsible for maintaining the City’s official lists of CBC membership, vacancies, appointment dates, and term expirations.

2. Prior to the end of the term for a filled position or when a CBC position is vacated, the City Clerk shall initiate a recruitment, which includes an initial recruitment period of 10 business days or greater, and/or schedule interviews to fill the position, if there are at least 2 individuals have applied for vacancy.

3. Per Government Code Section 54974 (a), a Notice of Vacancy, shall be posted not earlier than 20 days before, or not later than 20 days after the vacancy occurs. The Notice of Vacancy shall be posted to the City’s website, as well as published on the City’s social media accounts, and the City Clerk’s Office will share the Notice of Vacancy with the City Council during the initial recruitment period, schedule permitting. The initial recruitment period may be extended at the discretion of the City Clerk in the event that fewer than 2 individuals have applied for the vacancy.

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4. Per Government Code Section 54974 (a), final appointment to the board, commission, or committee shall not be made by the legislative body for at least 10 working days after the posting of the notice in the clerk’s office.

5. Notwithstanding a decision to extend the initial recruitment period, the City Clerk shall furnish all submitted applications to the City Council at the close of the initial recruitment period and each subsequent recruitment period. During the period when the recruitment is extended, if a majority of the City Council requests to interview the applicants, the City Clerk shall work to schedule interviews with the City Council.

6. Unless directed by a majority of the City Council, all CBC applicants shall be given the opportunity to be interview by the City Council.

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Commissions, Boards & Committees
Applicants
CBC Applicant Currently Holds Seat New Applicant
Culture & Arts Commission 4 Open Seats
(2 incumbents seeking reappointment. 3 full terms and 1 vacant partial term expiring in 2024) Jeanne George X
Janet Monaghan X
Megan Dahlgren X
Mario Guitron X
Parks & Recreation
Commission
5 Open Seats
(4 incumbents seeking reappointment. 4 full terms and 1 youth representative vacancy) Kris Gonzales X
Lorry Greenberg X
David Nigel X
Mike Palmer X
Wesley Liu (Youth Rep) X
Pavan Prasad (Youth Rep) X
Cole Rohlfs (Youth Rep) X
Traffic Safety & Parking 3 Open Seats
(2 incumbents seeking reappointment + 1 vacant. All full terms.) Rhonda Collins X
John Lampros X
Quinton Cutlip X
Matthew Stenberg X
Sean Quinn X
Kevin You X

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City of San Bruno

ADVISORY COMMISSIONS BOARDS COMMITTEES
BODY Size Quorum Expiring Total Open
Seats
Cont.

Service
# of
Applications
Bicycle & Pedestrian Advisory Committee: 7 4 3
(plus 1 vacant)
4 2 6 new / 3 on file
Rob Anicetti (2024) 2024
Matt Gaines (2024) 2024
David Nigel (2022) 2022 Y
Cecile Riborozo (2022) 2022 Y
Paul Rose (2024) 2024
Gus Sinks (2022) 2022 N
VACANCY (2024) 2024
Citizens Crime Prevention Committee 7 4 3
(plus 1 vacant)
4 3 1 new
Rhonda Boone (2022) 2022 Y
Peter Carey (2024) 2024
Chad Keele (2024) 2024
Robert Riechel (2022) 2022 Y
Deanna Robinson (2022) 2022 Y
Richard Wong (2024) 2024
VACANCY (2024) 2024
Citizens Revenue Measure Oversight Committee 7 4 4 4 TBD 1 new / 1 on file Vaughn Gregory (2024) 2024
Anthony Clifford (2022) 2022 TBD
Jim Evangelist (2024) 2024
Ariella Fioranelli (2022) 2022 TBD
Frank Hedley (2022) 2022 TBD
John Marty (2022) 2022 TBD
John Seevers (2024) 2024
Culture & Arts Commission 7 4 4
(includes 2 vacant)
4 2 2 new / 2 on file
Pamela Gamble (2024) 2024
Jeanne George (2022) 2022 Y
Janet Monaghan (2022) 2022 Y
Pamela Maddden (2024) 2024
Melissa Rohlfs (2024) 2024
VACANCY (2022) 2022
Revised 10.11.22
New text shown in red

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City of San Bruno

ADVISORY COMMISSIONS BOARDS COMMITTEES
VACANCY (2022) 2022
Emergency Preparedness Committee 5 3 2 2 2 1 new
Ron LaPedis (2022) 2022 Y
Janet Lutus (2022) 2022 Y
Zidane Mili (2024) 2024
George Peponis (2024) 2024
Malcolm Robinson (2024) 2024
Parks & Recreation Commission 8 + 1 youth 5 4
(plus 1 vacant youth)
5 4 1 on file
Kris Gonzales (2022) 2022 Y
Lorry Greenberg (2022) 2022 Y
Tom Kuhn (2024) 2024
Jessica Martinucci (2024) 2024
David Nigel (2022) 2022 Y
Mike Palmer (2022) 2022 Y
Lucy Zamattia (2024) 2024
Michael Zastrow (2024) 2024
VACANCY, Youth Rep (when graduate high school) When graduate HS 3 new Planning Commission 7 4 4 4 3 1 new / 3 on file
Rick Biasotti (2022) 2022 Y
Marco Durazo (2022) 2022 Y
Mary Lou Johnson (2024) 2024
Auros Harman (2024) 2024
Kelly Lethin (2024) 2024
Gerard Madden (2022) 2022 Y
Valentine Morgan (2022) 2022 N
Recreation and Aquatics Center Advisory
Committee
8 5 0 0 N/A 0
Linda Mason
Michael Salazar
Kris Gonzales
Auros Harman
Kelly Lethin
Malissa Netane-Jones
Revised 10.11.22
New text shown in red

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City of San Bruno

ADVISORY COMMISSIONS BOARDS COMMITTEES
Michael Palmer
Jim Ruane
Senior Citizen Advisory Board 7 4 0 0 N/A 0
Bunny Epperson (2024) 2024
Linda Holman (2023) 2023
Pricilla Martinez (2024) 2024
Ralph Olcese (2023) 2023
Joyce Satow (2023) 2023
AARP Rep - Herb Chu
Nutrition Site Rep - Barbara Cox
Traffic Safety & Parking Committee 5 3 3
(includes 1 vacant)
3 2 4 new / 1 on file
Rhonda Collins (2022) 2022 Y
Roberta Hannibal (2024) 2024
John Lampros (2022) 2022 Y
Stephen Seymour (2024) 2024
VACANCY (2022) 2022
*Some applicants submitted applications for multiple committees. *Some applications were on file with the City Clerk's Office.

Revised 10.11.22
New text shown in red

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City Council Agenda Item
Staff Report

CITY OF SAN BRUNO
DATE:November 15, 2022
TO:Honorable Mayor and Members of the City Council
FROM:Jovan D. Grogan, City Manager
PREPARED BY:Sandeep Krishnamurthy, San Bruno CityNet Services Director SUBJECT: Receive and Discuss Report on Evaluation of San Bruno CityNet Services Enterprise and Business Plan
BACKGROUND: The City of San Bruno’s annual Audit Report for 2021-22 recommended the evaluation of the CityNet Enterprise and its business plan. To this end, the City issued an RFP for the Enterprise evaluation on February 28, 2022 and selected a qualified vendor, John Staurulakis Inc. (JSI), by mid-April 2022.

DISCUSSION: JSI conducted a detailed evaluation of the CityNet Enterprise as well as its Enterprise business plan, based on a fiber upgrade, originally presented to the San Bruno City Council on March 12, 2019. Based on inputs from JSI, CityNet has developed and attached a presentation for the Council Study Session scheduled for a Special City Council meeting on November 15, 2022.

FISCAL IMPACT: The cost to produce JSI’s of the CityNet Enterprise was $50,000. The expense was funded by a prior appropriation by the City Council.

ENVIRONMENTAL IMPACT: There is no environmental impact. The action is not a project subject to CEQA.  City Council’s action is not considered a “Project” per CEQA Guidelines and therefore no further environmental analysis is required.

RECOMMENDATION: Receive and discuss Report on Evaluation of San Bruno CityNet Services Enterprise and Business Plan.

ALTERNATIVES: Provide direction to staff to further analyze San Bruno CityNet Services evaluation and business plan
ATTACHMENTS:

1. City of San Bruno CityNet Enterprise Evaluation Phase 1 Report

2. JSI Summary of Analysis – San Bruno Business Case Review

3. CityNet Study Session, November 15, 2022

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City of San Bruno
Phase I Report

June 13, 2022

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I. Introduction
A. Background
JSI’s analysis focused on producing several interrelated financial assessments surrounding the options available to the City of San Bruno related to the deployment of upgraded facilities designed to revitalize and enhance the City’s current CityNet offerings.

As conveyed by management, and consistent with the general analytical scope conveyed in its underlying Request for Proposal (“RFP”), the City is seeking to understand:

1. Whether a financial business case can be made to support upgrading the City’s network infrastructure to enable a substantially more robust broadband service offering.

2. What level of performance is required from the business case to support the level of investment forecasted to be required (including attendant financing costs).

3. Whether it would be financially advisable for the City to exit the market as a service provider given the trendlines present in the business case and the forecasted financial demands attributable to the network upgrades forecasted to be required to sustain the operation’s competitive viability.

4. The enterprise value associated with the CityNet operation as a data point in the City’s assessment of whether to enhance or exit CityNet’s operating position.

Phase I of JSI’s engagement addresses the first three areas of consideration reflected above. Phase II of our engagement will result in a valuation of CityNet’s commercial operation.

B. Environmental Considerations
As noted by the City in its underlying Request for Proposals (RFP), market dynamics surrounding traditional cable (CATV) services and broadband Internet are undergoing significant and accelerating change. Concerning the former, demand for CATV services continues to suffer ongoing, steady, and material erosion. Specifically:

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• CATV subscriptions fell by 15% in 2020.
• Subscription declines are accelerating. In Q1 of 2022, providers reported a decline of 3.2M subscribers, materially higher than the 2.2M subscriber loss reported for the previous year. • CATV programming costs have dramatically outpaced inflation impacting both CATV operator margins and relative customer attrition rates when such increases are passed through to consumers.
• Demographic-based viewership trends are not favorable to traditional CATV models. Nearly all Americans aged 25-34 access programming content through the Internet, with 90% of young people preferring this access method.

The landscape surrounding broadband Internet has experienced a similar level of evolution to that of CATV services, although its trajectory is one marked by profound year-over-year growth. Specifically, between 2018 and 2021, average household broadband usage doubled.

Further, as reflected below, forecasts anticipate broadband demand continuing its rapid growth trajectory.

Illustration 1 – Forecasted Broadband Demand Growth

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The preceding data points collectively affirm the basis for management’s desire to pivot the positioning of its products from a CATV-focused foundation with the Internet as a complementary option to one in which broadband Internet is positioned as the City’s premier product.

The cited data similarly illustrates that upgrading the City’s service delivery infrastructure is of critical importance to the commercial viability/marketability of the City’s service offerings and its ability as a municipal concern to deliver to its citizenry services that are capable of meeting both their current as well as evolving service needs. Absent the City’s investment in its broadband infrastructure, the ability of CityNet’s offerings to address the evolving demands of the marketplace will progressively erode. Such erosion in marketplace relevancy will, in turn, ultimately translate into a declining level of financial performance, and from a public policy perspective, a decline in the “public good” value the City can extend to its residents through its supported service offerings.

The remaining sections of this report will examine the approach/analytical framework leveraged in conjunction with our analysis, the findings produced, and our conclusions/recommendations from our analysis.

II. Executive Summary and Recommendations
As outlined in the following section of the report, JSI examined three principal scenarios surrounding the potential deployment of more robust network infrastructure. Specifically, our analysis included:
• A financial forecast relating the implications of a fiber to the premise (“FTTP”) deployment using prevailing as well as optimized financial/operational performance statistics versus the forecasted financial performance of the organization’s current “steady state” operating position, • A financial forecast reflecting an exit from the CATV business case with ongoing provision of Broadband services reflecting both a “no modification” scenario to current non-programming operating costs as well as a scenario where operations are modified / optimized; and, • A financial forecast relating the implications of a rehab of the City’s existing hybrid COAX/Fiber network, again under steady state as well as modified/optimized operating/financial performance metrics.

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As reflected above, all three scenarios include a sub-scenario that identifies areas of potential optimization. Each cited primary scenario includes a forecast in which performance levels in key areas of the business are sufficiently optimized to produce a sustainable cash-flow positive or near cash flow positive operating position.

CityNet’s present operations are currently producing an operating loss. This reality, married to the capital-intensive nature of a fiber to the premise (“FTTP”) or Hybrid Fiber COAX deployment, will require the City to engineer material adjustments to drive both higher revenue production (higher subscription levels married to more robust average revenue per user (“ARPU”) performance levels) and a lower operating cost position.

As noted above, underlying trends in broadband demand dictate that the City must enhance its current network if its broadband product suite is to remain viable.

Upgrade options available to the City include:
• A near full replacement of the City’s infrastructure via a full FTTP network deployment; and • A retrofit and upgrade of the City’s COAX-based network infrastructure.

The net cash flow (post servicing of debt) is forecasted to be materially higher under the hybrid fiber/COAX-based scenario as reflected in both the steady state as well as the optimized scenarios modeled. However, fiber remains the gold standard by which to deliver broadband solutions. As noted in the preceding section of this report, demand for broadband continues to experience significant and consistent growth. An FTTP-based infrastructure is the most robust, future proof technology choice available, and as a public concern whose service motivations include the promotion of maximized delivered value to residents and accelerated prospects for economic development, the benefits of an FTTP deployment should be seriously weighed despite the financial challenges presented by the technology’s capital investment demands.

The central question for the City is whether it believes that the operational optimization required to produce a cash flow positive/neutral outcome is sufficiently executable and can be effectively realized.

All things being equal, the operational optimization required under a hybrid fiber / COAX deployment is materially less expansive than those required from a full FTTP deployment. Nevertheless, under either

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network deployment scenario, unless the City is prepared to absorb the operating losses projected by the non-modified/non-optimized scenarios, or is confident in its ability to produce the operating results reflected in the modified/optimized scenarios, it should seriously explore exiting its current operating position through a sale of the CityNet enterprise.

Concerning a scenario involving the elimination of CityNet’s CATV service offering, unless the City is prepared to dramatically reduce operational expenses, eliminating cable services from CityNet’s operation would not produce accretive, positive contributions to cash flow. Management has identified steps required to rationalize the City’s cable service solution financially. We recommend that such optimization be explored and modeled before making any decision to eliminate CATV services to the City’s residents.

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III. Approach to Analysis
The analysis conducted leveraged historic operational, subscription and financial data obtained from the City, which were, in turn, introduced into JSI’s comprehensive forecasting models. Specifically, our analysis is founded on:

1. 12-month trailing account-level financial information. a. From the preceding information, alternative forecasting techniques were discretely applied depending on the characteristics of each revenue and expense account.

2. 12-month trailing demand data for each product offering spanning the City’s CATV broadband and voice business lines.

3. Rate design/pricing data reflect prevailing rates for each discrete service offered by CityNet.

4. Engineered Capital Investment forecasts developed from .kmz-based mapping provided by management and anchored to existing network assets owned and maintained by the City.

5. 100% debt financing of all capital investment attributable to the hybrid fiber/COAX and FTTP network deployment scenarios. Attributes of the assumed debt instrument include a loan term of 15 years and an interest rate of 5.50%.

Based on the preceding foundational information provided, JSI produced three core financial forecasts, with each such forecast further broken into three additional sub-analyses. The following matrix outlines each of the discrete analyses conducted.

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Illustration 2 – Forecasted Broadband Demand Growth

Scenario Description
Scenario 1 - Base
This scenario represents the analysis's baseline. The intent of this scenario is to provide a financial illustration of forecasted results based on an extension of historic trends, and where appropriate, adjustments to such trends based on anticipated/assumed changes to underlying operating costs.

For example COLA increases to personnel costs.

Scenario 1 (a) This scenario is identical to Scenario 1 - Base, but with the imposition of debt service associated with the deployment of a FTTP architecture.

Scenario 1 (b)
This scenario uses Scenario 1 - Base, baseline demand data, but then assumes optimization of several components of the business case including rate design resulting in average revenue per user (ARPU) enhancement, defined "spike" in subscription due to assumed market response to a more robust product offering, defined optimization in operating costs including material reductions in CATV programming fees, and reductions in realized overall operating costs.

Scenario 2 - Base
This scenario leverages broadband and voice demand data consistent with Scenario 1- Base, but assumes the elimination of CATV services from the organization's product lineup. Within this no- CATV-based scenario, expense allocations were adjusted to recognize the implications of the service's elimination.

Scenario 2 (a) This scenario is identical to Scenario 2 - Base, but with the imposition of debt service associated with the deployment of a FTTP architecture.

Scenario 2 (b)
This scenario uses Scenario 2 - Base, baseline demand data, but then assumes optimization of several components of the business case including rate design resulting in average revenue per user (ARPU) enhancement, defined "spike" in subscription due to assumed market response to a more robust product offering, defined optimization in operating costs including material reductions in CATV programming fees, and reductions in realized overall operating costs.

Scenario 3 - Base
This scenario leverages broadband and voice demand data consistent with Scenario 1- Base, but assumes upgrades to the City's network infrastructure come by way of a targeted upgrade to the City's hybrid COAX/Fiber infrastructure rather than deployment of a FTTP infrastruture as reflected in preceding Scenarios (1(a), (b), Secnario 2(a),(b).

Scenario 3 (a) This scenario is identical to Scenario 3 - Base, but with the imposition of debt service associated with the deployment of a FTTP architecture.

Scenario 3 (b)
This scenario uses Scenario 3 - Base, baseline demand data, but then assumes optimization of several components of the business case including rate design resulting in average revenue per user (ARPU) enhancement, defined "spike" in subscription due to assumed market response to a more robust product offering, defined optimization in operating costs including material reductions in CATV programming fees, and reductions in realized overall operating costs. For comparabity purposes, all assumptions for the base case as well as modified / optimized view are identical to Scenario 1 - Base Case.

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All modeled scenarios employ a shared foundational approach to developing forecasted revenues and expenses. Specifically:
• Revenue for broadband, video, and voice product lines was developed by applying linear regression trending to supplied historic, per product demand data. CityNet’s prevailing rate structures at the per-product offering level were then applied to the trended demand data. • Expense forecasts were developed based on a two-part process. First, based on guidance provided by City Management, JSI allocated CityNet’s recorded operating costs to the organization’s discrete product lines (CATV, broadband, voice) in order to derive margin levels on a per-product basis. Specifically, under the Steady State Baseline Run, 47.5% of non-direct recorded expenses were allocated to CATV and broadband product sets, with 5% of such expenses allocated to voice. Direct expenses (programming costs for video and Internet expenses to broadband) were directly assigned to their relevant product lines. • Once baseline allocation of expenses was defined, JSI applied a range of discrete forecasting techniques, which were chosen based on the observed complexion of reported historical expense data. Forecasting methods leveraged within the CityNet analysis are summarized in the table below.

Illustration 3 – Forecasting Methodologies Applied at Account Level

Technique Description Context Used
Trended Linear regression foreasting method projecting future values based on inherent trends in historic data.

When clear, observable trends were
inherent in supplied historical data
Annual Adjustment Factor Applied a defined annual adjustment factor to baseline data.

When changes to prevailing expenses
levels are anticipated. For example,
increases to personnel costs over time.

Average Singular average value forecasted forward based on average values observed from supplied historic data
When no observable trends were
inherent in the data.

Indexed
Forecasted expenses for a given line item were forecast based on a specified/observed relationship with a separate operating account. For example programming expenses were indexed to forecasted subscription revenue.

When there is a defined relationship
between two accounts wherein
fluctuation in the forecasted value of one
account is expected to produce a
comparable impact/level of movement
in the account for which an indexed
forecasting method is used.

Defined Static Value Employs a single, defined static value for the course of the forecasting period
When a value is expected to be largely
fixed on a going forward basis
Last Month Employs the value reflected in the most recent financial reporting period
When a value is expected to be carried
forward based on the company's most
recent results.

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The following modeled scenarios, which will be described and summarized more fully below, were modeled in a fashion intended to identify the financial implications of the go-forward options available to the City of San Bruno.

IV. Analysis Outcomes
A. Steady State Baseline Run
This scenario was intended to plot the future financial performance of CityNet’s offerings based on forecasting the prevailing trendlines of the City’s existing business case. As outlined in Illustration 2 above, Scenario 1 is broken into Base, Base w/ FTTP Deployment and Associated debt, and Base with FTTP Deployment and Modified Assumptions / Optimized Operations. A summary of forecasted results related to Scenario 1 is reflected in Illustrations 4 and 5 below.

As reflected in the cited Illustrations, based on information provided by management, CityNet’s operations are currently running at an operating loss. Absent action taken to raise revenue and/or cut expenses, the operation’s present negative cash flow position is forecasted to deepen as declines in CATV and broadband internet subscription falter due to prevailing subscription-based trends continuing to play out. Financial implications of the foregoing, married to certain inflationary expenses (such as payroll) which are forecasted to increase over time, will further deepen prevailing and forecasted operating losses.

Management has recognized this operating/financial dynamic and is taking specific action to address such issues through targeted operational initiatives already underway1. Additionally, the need to upgrade the City’s infrastructure to remain competitively relevant, a prerequisite to financial vitality, led

1 Management has noted that it is well underway in its efforts to pair CATV programming costs . This is a particularly meaningful initiative as management is targeting a 30% operating margin relative to the relationship between top-line subscription revenue, and associated programming costs. Presently, CityNet’s gross margin is a negative 27%. Additionally, management has identified numerous opportunities to reduce prevailing operating expense levels.

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to management’s initiation of this analytical exercise involving evaluating strategic options for CityNet’s product suite.

With regard to the modified/optimized operating scenario modeled, enhanced performance of key aspects of the operation were assumed in select areas where optimized performance of CityNet’s operation were deemed feasible. Such assumed optimization includes:
• Broadband ARPU was assumed to increase from $68.61 to $81.29. This would be accomplished through 1) elimination of numerous grandfathered rate designs in conjunction with consolidating available broadband rate offerings and 2) more proactive/aggressive efforts to sell value related to higher speed tier offerings.
• Demand stimulation associated with deploying a substantially more robust product offering.

Demand stimulation modeled reflected a 10%-15% increase in subscription levels to select broadband speed tier offerings.
• Consistent with management guidance, the modified/optimized scenarios indexed programming costs to 70% of associated CATV top-line revenue.
• Remaining operating costs were paired by 25% over prevailing baseline levels except for City corporate allocated expenses, which were maintained at 100% of forecasted levels.

Illustrations 4 and 5 illustrate an executable path to achieving positive net cash flow associated with CityNet’s operation. However, doing so will require focused execution in the areas cited. Under the optimized scenarios modeled, CityNet’s operations can generate aggregate net positive cash flow for the period modeled while simultaneously meeting the debt service obligations required to finance a FTTP deployment.

1. Implications of Allocated City Overheads
To provide additional insight into the relative financial performance of CityNet’s operation, JSI modeled baseline and optimized scenarios that both include and exclude allocated City overheads.

The purpose of running dual scenarios is to 1) provide insight into the margin performance of the CityNet operation attributable solely to direct operating expenses related to the delivery of products and services and 2) highlight that the City is receiving revenue from the CityNet operation that would

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otherwise be absent. Such illustrations are relevant in that they provide insight into the level of margin the operation either contributes to or “consumes” from the City’s available discretionary funds.

Illustration 4 – Summarized Results of Annualized Forecasted Cash Flow

Base Base W/
Debt
Modified w/
Debt
2023 (1,752,138) (1,752,138) 1,919,597
2024 (1,983,403) (2,473,210) 1,326,694
2025 (1,906,710) (3,318,881) 385,757
2026 (1,733,170) (3,565,176) 116,372
2027 (1,564,799) (3,396,805) 201,594
2028 (1,431,355) (3,263,360) 252,037
2029 (1,488,491) (3,320,497) 196,738
2030 (1,577,623) (3,409,629) 123,080
2031 (1,689,334) (3,521,339) 27,192
2032 (1,780,460) (3,612,466) (47,761)
2033 (1,873,667) (3,705,673) (124,432)
2034 (1,969,532) (3,801,538) (203,393)
2035 (2,068,132) (3,900,138) (284,713)
2036 (2,169,548) (4,001,553) (368,468)
2037 (2,663,389) (4,495,395) (844,256)
(27,651,751) (51,537,800) 2,676,038
CASH FLOW - Total
From Annual Summary

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Illustration 5 – Summarized Results of Annualized Forecasted Cash Flow – Net of City of San Bruno Overhead Expense Allocations

B. Elimination of CATV Service
While CityNet’s operations are, on the whole, producing negative cash flow results, its broadband operation is, based on expense allocations assumed, producing consistently positive cash flows. In conjunction with CATV’s broader industry subscription trends, this reality begs the question as to whether the City should suspend the CATV portion of its operation.

Base Base W/
Debt
Modified w/
Debt
2023 (926,137) (926,137) 2,745,598
2024 (1,157,402) (1,647,209) 2,152,695
2025 (1,080,709) (2,492,880) 1,211,758
2026 (907,169) (2,739,175) 942,373
2027 (738,798) (2,570,804) 1,027,595
2028 (605,353) (2,437,359) 1,078,038
2029 (662,490) (2,494,496) 1,022,739
2030 (751,622) (2,583,628) 949,081
2031 (863,332) (2,695,338) 853,193
2032 (954,459) (2,786,465) 778,240
2033 (1,047,666) (2,879,672) 701,569
2034 (1,143,531) (2,975,537) 622,609
2035 (1,242,131) (3,074,137) 541,288
2036 (1,343,546) (3,175,552) 457,534
2037 (1,837,387) (3,669,393) (18,255)
(15,261,733) (39,147,782) 15,066,056
From Annual Summary
CASH FLOW - Total

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As reflected in Illustrations 6 and 7 below, however, simply eliminating the CATV operation is not a panacea to driving positive overall cash flows, nor a concomitant ability to effectively finance the network upgrades necessary to render the City’s remaining product offerings financially sustainable.

All things being equal, the elimination of CATV service would result in the operational costs allocated to the CATV business case in Scenario 1 - Base case (including financing costs) shifting to the pro forma results forecasted for CityNet’s remaining services – broadband and voice.

Should such a course be pursued as a result of, for example, the perceived implications of industry-wide trends in CATV subscription, several material adjustments would be required in the City’s current operational framework to create a sustainable foundation for ongoing broadband/voice-only operations. To this point, the following represents the optimization steps modeled which were identified as necessary to produce a sustainable broadband/voice-only operation. • Broadband ARPU was assumed to increase from $68.61 to $81.29. This would be accomplished through 1) elimination of numerous grandfathered rate designs in conjunction with consolidating available broadband rate offerings and 2) more proactive/aggressive efforts to sell value of higher speed tier offerings.
• Demand stimulation associated with deploying a substantially more robust product offering.

Demand stimulation modeled reflected a 10%-15% increase in subscription levels to select broadband speed tier offerings.
• The remaining operating costs were paired by roughly 56% over prevailing baseline levels except for programming costs which were eliminated entirely, and City corporate allocated expenses which were maintained at 100% of forecasted levels.

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Illustration 6 – Summarized Results of Annualized Forecasted Cash Flow

Base Base W/
Debt
Modified w/
Debt
2023 (2,276,697) (2,276,697) 1,623,757
2024 (2,376,111) (2,865,918) 1,304,207
2025 (2,443,574) (3,855,745) 361,461
2026 (2,522,764) (4,354,770) (17,353)
2027 (2,607,422) (4,439,428) (40,791)
2028 (2,694,633) (4,526,639) (80,200)
2029 (2,784,471) (4,616,477) (120,763)
2030 (2,877,017) (4,709,023) (162,518)
2031 (2,992,856) (4,824,861) (226,002)
2032 (3,091,070) (4,923,076) (270,252)
2033 (3,192,246) (5,024,252) (315,804)
2034 (3,296,475) (5,128,481) (362,699)
2035 (3,403,851) (5,235,856) (410,979)
2036 (3,514,470) (5,346,476) (460,687)
2037 (4,017,959) (5,849,965) (901,395)
(44,091,617) (67,977,666) (80,018)
CASH FLOW - Total
From Annual Summary

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Illustration 7 – Summarized Results of Annualized Forecasted Cash Flow – Net of City of San Bruno Overhead Expense Allocations

C. Modernization of Existing COAX-Based Network Infrastructure:

The final primary scenario modeled assumed a retrofit of the City’s existing coaxial cable infrastructure.

Under this scenario, nominal levels of fiber deployment were assumed (22.38 miles versus a full FTTP fiber deployment requiring roughly 5X the fiber level at ~111.88 miles). Lower electronic and placement costs rendered a CAPEX estimate of less than a third of the complete FTTP network design.

Base Base W/
Debt
Modified w/
Debt
2023 (1,450,696) (1,450,696) 2,449,758
2024 (1,550,110) (2,039,917) 2,130,208
2025 (1,617,573) (3,029,744) 1,187,463
2026 (1,696,763) (3,528,769) 808,648
2027 (1,781,421) (3,613,427) 785,210
2028 (1,868,632) (3,700,638) 745,801
2029 (1,958,470) (3,790,476) 705,238
2030 (2,051,016) (3,883,022) 663,484
2031 (2,166,854) (3,998,860) 600,000
2032 (2,265,069) (4,097,075) 555,749
2033 (2,366,245) (4,198,251) 510,197
2034 (2,470,474) (4,302,480) 463,302
2035 (2,577,849) (4,409,855) 415,023
2036 (2,688,468) (4,520,474) 365,314
2037 (3,191,958) (5,023,964) (75,394)
(31,701,599) (55,587,648) 12,310,000
From Annual Summary
CASH FLOW - Total

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It should be noted, however, that this approach does have its drawbacks relative to an entire FTTP- based business case; namely:

1. Fiber is a more robust technology, and deployment costs forecasted for the FTTP design are sufficient to support the deployment of a 10Gig level of service to the fiber distribution hut (“FDH”), which will position the City to provide class-leading broadband speeds to its residents throughout the modeled period.

2. Fiber allows the ability to support symmetrical upload/download speeds, a capability not supported by the COAX network design option. Enabling symmetrical speeds significantly enhances the competitive stature of the resulting product.

3. The COAX-based network design will leverage material components of the existing network.

Older networks require greater network maintenance efforts.

Nevertheless, capital demands are substantially less under the COAX-based network scenario. As Illustrations 8 and 9 reflect, cash flow from the operation is forecasted to be materially higher than the preceding two scenarios, all things being equal.

To create a consistent assumption foundation by which to build an applicable “inter-scenario comparison”, assumptions surrounding the Modified/Optimized scenario of a COAX-based deployment were consistent with the FTTP-based Scenario 1 – Modified/Optimized scenario. Namely:
• Broadband ARPU was assumed to increase from $68.61 to $81.29. This would be accomplished through 1) elimination of numerous grandfathered rate designs in conjunction with consolidating available broadband rate offerings and 2) more proactive/aggressive efforts to sell value of higher speed tier offerings.
• Demand stimulation associated with deploying a substantially more robust product offering.

Demand stimulation modeled reflected a 10%-15% increase in subscription levels to select broadband speed tier offerings.
• Consistent with management guidance, indexed programming costs to 70% of associated CATV top-line revenue.
• The remaining operating costs were paired by 25% over prevailing baseline levels except for City corporate allocated expenses, which were maintained at 100% of forecasted levels.

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Illustration 8 – Summarized Results of Annualized Forecasted Cash Flow

Base Base W/
Debt
Modified w/
Debt
2023 (1,752,138) (1,752,138) 1,919,597
2024 (1,983,403) (2,117,551) 1,682,353
2025 (1,906,710) (2,293,474) 1,411,165
2026 (1,733,170) (2,234,918) 1,446,630
2027 (1,564,799) (2,066,547) 1,531,852
2028 (1,431,355) (1,933,102) 1,582,295
2029 (1,488,491) (1,990,239) 1,526,996
2030 (1,577,623) (2,079,371) 1,453,338
2031 (1,689,334) (2,191,081) 1,357,450
2032 (1,780,460) (2,282,208) 1,282,497
2033 (1,873,667) (2,375,415) 1,205,826
2034 (1,969,532) (2,471,280) 1,126,866
2035 (2,068,132) (2,569,880) 1,045,545
2036 (2,169,548) (2,671,295) 961,791
2037 (2,663,389) (3,165,136) 486,002
(27,651,751) (34,193,636) 20,020,202
CASH FLOW - Total
From Annual Summary

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Illustration 9 – Summarized Results of Annualized Forecasted Cash Flow – Net of City of San Bruno Overhead Expense Allocations

Base Base W/
Debt
Modified w/
Debt
2023 (926,137) (926,137) 2,745,598
2024 (1,157,402) (1,291,550) 2,508,354
2025 (1,080,709) (1,467,473) 2,237,166
2026 (907,169) (1,408,917) 2,272,631
2027 (738,798) (1,240,546) 2,357,853
2028 (605,353) (1,107,101) 2,408,296
2029 (662,490) (1,164,237) 2,352,997
2030 (751,622) (1,253,370) 2,279,340
2031 (863,332) (1,365,080) 2,183,451
2032 (954,459) (1,456,207) 2,108,498
2033 (1,047,666) (1,549,414) 2,031,827
2034 (1,143,531) (1,645,279) 1,952,867
2035 (1,242,131) (1,743,878) 1,871,547
2036 (1,343,546) (1,845,294) 1,787,792
2037 (1,837,387) (2,339,135) 1,312,003
(15,261,733) (21,803,618) 32,410,220
From Annual Summary
CASH FLOW - Total

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V. Final Conclusions Recommendations:

Management has effectively identified the strategic and tactical options before the organization, specifically, 1) modernize the organization’s network while optimizing its operational position, or 2) exit the business via a sale of the enterprise.

Phase II of JSI’s analysis is designed to formulate an enterprise value for CityNet’s operation which will provide critical context to the process of weighing the City’s options as defined above. Equally relevant to determining the appropriate path for the City is:
• Management’s relative confidence in making the operational changes necessary to produce accretive cash flow of a level necessary to 1) service attendant debt related to capital investments necessary to sustain the organization’s competitive relevancy and 2) produce the level of financial performance sufficient to meet the City’s expectations surrounding the financial performance of the operation; and,
• The City’s view of the importance of remaining a service provider to the city’s residents related to ensuring a level of service that would otherwise be unavailable;

JSI would recommend that in conjunction with the City’s consideration of its strategic and tactical options, and upon completion of the Phase 2 Valuation component of this analysis, CityNet prepare a tactical plan to effect the operational enhancements necessary to produce cash flows sufficient to 1) service the debt related to the desired level and form of network upgrades deemed appropriate and 2) produce the level of financial performance targeted by the City.

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Appendix A
Financial Illustrations

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Illustration 10 - Comparative Results CATV Business Case Base Case
Base Base W/
Debt
Modified w/
Debt
2023 (2,083,036) (2,083,036) (104,963)
2024 (2,251,299) (2,483,957) (614,042)
2025 (2,144,662) (2,815,444) (1,053,515)
2026 (1,930,593) (2,800,796) (1,146,763)
2027 (1,717,401) (2,587,603) (1,041,457)
2028 (1,537,794) (2,407,996) (955,062)
2029 (1,547,389) (2,417,592) (973,360)
2030 (1,587,559) (2,457,762) (1,008,933)
2031 (1,628,340) (2,498,542) (1,045,119)
2032 (1,667,527) (2,537,730) (1,079,718)
2033 (1,707,240) (2,577,443) (1,114,853)
2034 (1,748,009) (2,618,212) (1,151,056)
2035 (1,789,860) (2,660,063) (1,188,360)
2036 (1,832,824) (2,703,027) (1,226,799)
2037 (2,071,695) (2,941,898) (1,461,173)
(27,245,228) (38,591,101) (15,165,174)

CASH FLOW

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Illustration 11 – CATV Pro Forma – Base Case – No Buildout / No Debt

CATV - BASE - NO DEBT
2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 Revenue 3,580,077 3,192,084 3,080,166 3,076,706 3,073,247 3,069,779 3,066,318 3,062,859 3,059,763 3,059,262 3,059,262 3,059,262 3,059,262 3,059,262 3,059,262 Expenses 5,857,878 5,638,148 5,419,593 5,202,065 4,985,413 4,802,338 4,808,473 4,845,183 4,882,868 4,921,554 4,961,268 5,002,036 5,043,887 5,086,851 5,130,957 Operating Income (2,277,802) (2,446,065) (2,339,428) (2,125,358) (1,912,166) (1,732,559) (1,742,155) (1,782,325) (1,823,105) (1,862,293) (1,902,006) (1,942,774) (1,984,626) (2,027,590) (2,071,695) EBITDA (2,083,036) (2,251,299) (2,144,662) (1,930,593) (1,717,401) (1,537,794) (1,547,389) (1,587,559) (1,628,340) (1,667,527) (1,707,240) (1,748,009) (1,789,860) (1,832,824) (2,071,695) Debt Service
Cash Flow (2,083,036) (2,251,299) (2,144,662) (1,930,593) (1,717,401) (1,537,794) (1,547,389) (1,587,559) (1,628,340) (1,667,527) (1,707,240) (1,748,009) (1,789,860) (1,832,824) (2,071,695) Cumulative Cash Flow (2,083,036) (4,334,335) (6,478,997) (8,409,590) (10,126,991) (11,664,784) (13,212,173) (14,799,732) (16,428,072) (18,095,599) (19,802,839) (21,550,848) (23,340,708) (25,173,532) (27,245,228)

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Illustration 12 – CATV Pro Forma – Base Case – FTTP Buildout With Debt

Illustration 13 – CATV Pro Forma – Base Case – FTTP Buildout With Debt – Modified Assumptions

CATV - BASE - W/ OVERBUILD DEBT
2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 Revenue 3,580,077 3,192,084 3,080,166 3,076,706 3,073,247 3,069,779 3,066,318 3,062,859 3,059,763 3,059,262 3,059,262 3,059,262 3,059,262 3,059,262 3,059,262 Expenses 5,857,878 5,638,148 5,419,593 5,202,065 4,985,413 4,802,338 4,808,473 4,845,183 4,882,868 4,921,554 4,961,268 5,002,036 5,043,887 5,086,851 5,130,957 Operating Income (2,277,802) (2,446,065) (2,339,428) (2,125,358) (1,912,166) (1,732,559) (1,742,155) (1,782,325) (1,823,105) (1,862,293) (1,902,006) (1,942,774) (1,984,626) (2,027,590) (2,071,695) EBITDA (2,083,036) (2,251,299) (2,144,662) (1,930,593) (1,717,401) (1,537,794) (1,547,389) (1,587,559) (1,628,340) (1,667,527) (1,707,240) (1,748,009) (1,789,860) (1,832,824) (2,071,695)

47.50% Debt Service -$ (232,658)$ (670,781)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ Cash Flow (2,083,036) (2,483,957) (2,815,444) (2,800,796) (2,587,603) (2,407,996) (2,417,592) (2,457,762) (2,498,542) (2,537,730) (2,577,443) (2,618,212) (2,660,063) (2,703,027) (2,941,898) Cumulative Cash Flow (2,083,036) (4,566,994) (7,382,437) (10,183,233) (12,770,836) (15,178,833) (17,596,424) (20,054,186) (22,552,728) (25,090,458) (27,667,901) (30,286,113) (32,946,176) (35,649,203) (38,591,101)

CATV - MODIFIED - W/ OVERBUILD DEBT
2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 Revenue 3,580,077$ 3,192,084$ 3,080,166$ 3,076,706$ 3,073,247$ 3,069,779$ 3,066,318$ 3,062,859$ 3,059,763$ 3,059,262$ 3,059,262$ 3,059,262$ 3,059,262$ 3,059,262$ 3,059,262$ Expenses 3,879,806$ 3,768,233$ 3,657,665$ 3,548,032$ 3,439,266$ 3,349,404$ 3,364,240$ 3,396,355$ 3,429,445$ 3,463,543$ 3,498,677$ 3,534,880$ 3,572,185$ 3,610,623$ 3,650,232$ Operating Income 3,254,749$ (576,149)$ (577,499)$ (471,326)$ (366,020)$ (279,625)$ (297,922)$ (333,496)$ (369,682)$ (404,281)$ (439,416)$ (475,619)$ (512,923)$ (551,362)$ (590,970)$ EBITDA (104,963)$ (381,383)$ (382,733)$ (276,561)$ (171,254)$ (84,859)$ (103,157)$ (138,730)$ (174,917)$ (209,516)$ (244,650)$ (280,853)$ (318,157)$ (356,596)$ (590,970)$

47.50% Debt Service - (232,658) (670,781) (870,203) (870,203) (870,203) (870,203) (870,203) (870,203) (870,203) (870,203) (870,203) (870,203) (870,203) (870,203) Cash Flow (104,963)$ (614,042)$ (1,053,515)$ (1,146,763)$ (1,041,457)$ (955,062)$ (973,360)$ (1,008,933)$ (1,045,119)$ (1,079,718)$ (1,114,853)$ (1,151,056)$ (1,188,360)$ (1,226,799)$ (1,461,173)$ Cumulative Cash Flow (104,963)$ (719,005)$ (1,772,520)$ (2,919,283)$ (3,960,740)$ (4,915,802)$ (5,889,162)$ (6,898,095)$ (7,943,215)$ (9,022,933)$ (10,137,786)$ (11,288,842)$ (12,477,202)$ (13,704,001)$ (15,165,174)$

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Illustration 14 - Comparative Results Broadband Business Case Base Case

Base Base W/
Debt
Modified w/
Debt
2023 377,265 377,265 2,070,927
2024 339,792 107,134 2,037,122
2025 318,223 (352,558) 1,590,152
2026 281,765 (588,438) 1,439,077
2027 241,139 (629,064) 1,423,189
2028 199,299 (670,904) 1,391,559
2029 156,212 (713,991) 1,359,011
2030 111,838 (758,364) 1,325,517
2031 66,140 (804,063) 1,291,045
2032 19,073 (851,130) 1,255,564
2033 (29,400) (899,602) 1,219,049
2034 (79,322) (949,525) 1,181,465
2035 (130,739) (1,000,942) 1,142,780
2036 (183,698) (1,053,901) 1,102,958
2037 (433,007) (1,303,210) 867,203
1,254,580 (10,091,293) 20,696,617

CASH FLOW

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Illustration 15 – Broadband Pro Forma – Base Case – No Buildout / No Debt

BROADBAND- BASE - NO DEBT
2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 Revenue 3,726,816 3,725,756 3,741,706 3,743,909 3,743,119 3,742,327 3,741,537 3,740,747 3,739,958 3,739,166 3,738,376 3,737,586 3,736,796 3,736,005 3,735,215 Expenses 3,544,317 3,580,729 3,618,248 3,656,909 3,696,746 3,737,794 3,780,091 3,823,675 3,868,584 3,914,859 3,962,541 4,011,674 4,062,301 4,114,468 4,168,222 Operating Income 182,500 145,027 123,458 87,000 46,373 4,533 (38,554) (82,927) (128,626) (175,693) (224,165) (274,088) (325,505) (378,463) (433,007) EBITDA 377,265 339,792 318,223 281,765 241,139 199,299 156,212 111,838 66,140 19,073 (29,400) (79,322) (130,739) (183,698) (433,007) Debt Service
Cash Flow 377,265 339,792 318,223 281,765 241,139 199,299 156,212 111,838 66,140 19,073 (29,400) (79,322) (130,739) (183,698) (433,007) Cumulative Cash Flow 377,265 717,058 1,035,281 1,317,046 1,558,185 1,757,483 1,913,695 2,025,534 2,091,673 2,110,746 2,081,347 2,002,024 1,871,285 1,687,588 1,254,580

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Illustration 16 – Broadband Pro Forma – Base Case – FTTP Buildout With Debt

Illustration 17 – Broadband Pro Forma – Base Case – FTTP Buildout With Debt – Modified Assumptions

BROADBAND - BASE - W/ OVERBUILD DEBT
2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 Revenue 3,726,816 3,725,756 3,741,706 3,743,909 3,743,119 3,742,327 3,741,537 3,740,747 3,739,958 3,739,166 3,738,376 3,737,586 3,736,796 3,736,005 3,735,215 Expenses 3,544,317 3,580,729 3,618,248 3,656,909 3,696,746 3,737,794 3,780,091 3,823,675 3,868,584 3,914,859 3,962,541 4,011,674 4,062,301 4,114,468 4,168,222 Operating Income 182,500 145,027 123,458 87,000 46,373 4,533 (38,554) (82,927) (128,626) (175,693) (224,165) (274,088) (325,505) (378,463) (433,007) EBITDA 377,265 339,792 318,223 281,765 241,139 199,299 156,212 111,838 66,140 19,073 (29,400) (79,322) (130,739) (183,698) (433,007)

47.50% Debt Service -$ (232,658)$ (670,781)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ Cash Flow 377,265 107,134 (352,558) (588,438) (629,064) (670,904) (713,991) (758,364) (804,063) (851,130) (899,602) (949,525) (1,000,942) (1,053,901) (1,303,210) Cumulative Cash Flow 377,265 484,399 131,841 (456,596) (1,085,660) (1,756,565) (2,470,556) (3,228,920) (4,032,983) (4,884,113) (5,783,715) (6,733,240) (7,734,182) (8,788,083) (10,091,293)

BROADBAND - MODIFIED - W/ OVERBUILD DEBT
2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 Revenue 4,785,421 5,011,104 5,029,903 5,106,737 5,120,201 5,118,817 5,117,436 5,116,056 5,114,675 5,113,291 5,111,910 5,110,530 5,109,149 5,107,765 5,106,384 Expenses 2,909,259 2,936,089 2,963,735 2,992,222 3,021,575 3,051,822 3,082,988 3,115,102 3,148,193 3,182,290 3,217,424 3,253,628 3,290,932 3,329,371 3,368,979 Operating Income 1,876,162 2,075,015 2,066,168 2,114,515 2,098,626 2,066,996 2,034,449 2,000,954 1,966,483 1,931,001 1,894,486 1,856,902 1,818,217 1,778,395 1,737,406 EBITDA 2,070,927 2,269,780 2,260,933 2,309,280 2,293,391 2,261,761 2,229,214 2,195,719 2,161,248 2,125,767 2,089,251 2,051,668 2,012,983 1,973,160 1,737,406

47.50% Debt Service -$ (232,658)$ (670,781)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ Cash Flow 2,070,927 2,037,122 1,590,152 1,439,077 1,423,189 1,391,559 1,359,011 1,325,517 1,291,045 1,255,564 1,219,049 1,181,465 1,142,780 1,102,958 867,203 Cumulative Cash Flow 2,070,927$ 4,108,049$ 5,698,201$ 7,137,279$ 8,560,467$ 9,952,026$ 11,311,037$ 12,636,554$ 13,927,599$ 15,183,163$ 16,402,212$ 17,583,677$ 18,726,457$ 19,829,414$ 20,696,617$

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Illustration 18 - Comparative Results Voice Business Case Base Run

Base Base W/
Debt
Modified w/
Debt
2023 (46,367) (46,367) (46,367) 2024 (71,896) (96,387) (96,387) 2025 (80,271) (150,880) (150,880) 2026 (84,342) (175,943) (175,943) 2027 (88,537) (180,137) (180,137) 2028 (92,860) (184,460) (184,460) 2029 (97,314) (188,914) (188,914) 2030 (101,903) (193,503) (193,503)
2031 (127,134) (218,734) (218,734)
2032 (132,006) (223,607) (223,607)
2033 (137,027) (228,628) (228,628)
2034 (142,201) (233,802) (233,802)
2035 (147,532) (239,133) (239,133)
2036 (153,026) (244,626) (244,626)
2037 (158,686) (250,286) (250,286)
(1,661,103) (2,855,406) (2,855,406)

CASH FLOW

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Illustration 19 – Voice Pro Forma – Base Case – No Buildout / No Debt

VOICE - BASE - NO DEBT
2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 Revenue 258,459 236,764 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 Expenses 325,328 329,162 333,113 337,184 341,379 345,701 350,155 354,745 359,474 364,346 369,367 374,541 379,872 385,366 391,026 Operating Income (66,869) (92,398) (100,773) (104,844) (109,039) (113,361) (117,815) (122,405) (127,134) (132,006) (137,027) (142,201) (147,532) (153,026) (158,686) EBITDA (46,367) (71,896) (80,271) (84,342) (88,537) (92,860) (97,314) (101,903) (127,134) (132,006) (137,027) (142,201) (147,532) (153,026) (158,686) Debt Service
Cash Flow (46,367) (71,896) (80,271) (84,342) (88,537) (92,860) (97,314) (101,903) (127,134) (132,006) (137,027) (142,201) (147,532) (153,026) (158,686) Cumulative Cash Flow (46,367) (118,264) (198,535) (282,877) (371,414) (464,274) (561,587) (663,490) (790,624) (922,630) (1,059,658) (1,201,859) (1,349,391) (1,502,417) (1,661,103)

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Illustration 20 – Voice Pro Forma – Base Case – FTTP Buildout With Debt

No Scenario Was Developed Employing Modified / Optimized Voice Assumptions

VOICE - BASE - W/ OVERBUILD DEBT
2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 Revenue 258,459 236,764 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 Expenses 10,351$ 329,162$ 333,113$ 337,184$ 341,379$ 345,701$ 350,155$ 354,745$ 359,474$ 364,346$ 369,367$ 374,541$ 379,872$ 385,366$ 391,026$ Operating Income 248,108 (92,398) (100,773) (104,844) (109,039) (113,361) (117,815) (122,405) (127,134) (132,006) (137,027) (142,201) (147,532) (153,026) (158,686) EBITDA (46,367) (71,896) (80,271) (84,342) (88,537) (92,860) (97,314) (101,903) (127,134) (132,006) (137,027) (142,201) (147,532) (153,026) (158,686) 5% Debt Service -$ (24,490)$ (70,609)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ Cash Flow (46,367) (96,387) (150,880) (175,943) (180,137) (184,460) (188,914) (193,503) (218,734) (223,607) (228,628) (233,802) (239,133) (244,626) (250,286) Cumulative Cash Flow (46,367) (142,754) (293,634) (469,576) (649,714) (834,174) (1,023,087) (1,216,591) (1,435,324) (1,658,931) (1,887,559) (2,121,361) (2,360,493) (2,605,119) (2,855,406)

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Illustration 21 - Comparative Results Broadband Business Case –

NO CATV SERVICE
Base Base W/
Debt
Modified w/
Debt
2023 (2,230,330) (2,230,330) 1,670,124
2024 (2,304,214) (2,769,531) 1,400,594
2025 (2,363,303) (3,704,866) 512,341
2026 (2,438,422) (4,178,828) 158,590
2027 (2,518,885) (4,259,291) 139,346
2028 (2,601,774) (4,342,179) 104,260
2029 (2,687,158) (4,427,563) 68,150
2030 (2,775,114) (4,515,520) 30,986
2031 (2,865,722) (4,606,128) (7,268)
2032 (2,959,064) (4,699,469) (46,646)
2033 (3,055,219) (4,795,624) (87,177)
2034 (3,154,274) (4,894,680) (128,898)
2035 (3,256,318) (4,996,724) (171,846)
2036 (3,361,444) (5,101,850) (216,061)
2037 (3,859,273) (5,599,678) (651,108)
(42,430,514) (65,122,260) 2,775,387

CASH FLOW

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Illustration 22 – Broadband Pro Forma – No Buildout / No Debt

NO CATV SERVICE

BROADBAND- NO CATV - NO DEBT
2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 Revenue 3,726,816 3,725,756 3,741,706 3,743,909 3,743,119 3,742,327 3,741,537 3,740,747 3,739,958 3,739,166 3,738,376 3,737,586 3,736,796 3,736,005 3,735,215 Expenses 6,346,677 6,419,501 6,494,541 6,571,862 6,651,536 6,733,632 6,818,226 6,905,393 6,995,211 7,087,761 7,183,126 7,281,391 7,382,646 7,486,980 7,594,487 Operating Income (2,619,861) (2,693,746) (2,752,834) (2,827,953) (2,908,416) (2,991,305) (3,076,689) (3,164,645) (3,255,253) (3,348,595) (3,444,750) (3,543,805) (3,645,849) (3,750,975) (3,859,273) EBITDA (2,230,330) (2,304,214) (2,363,303) (2,438,422) (2,518,885) (2,601,774) (2,687,158) (2,775,114) (2,865,722) (2,959,064) (3,055,219) (3,154,274) (3,256,318) (3,361,444) (3,859,273) Debt Service
Cash Flow (2,230,330) (2,304,214) (2,363,303) (2,438,422) (2,518,885) (2,601,774) (2,687,158) (2,775,114) (2,865,722) (2,959,064) (3,055,219) (3,154,274) (3,256,318) (3,361,444) (3,859,273) Cumulative Cash Flow (2,230,330) (4,534,544) (6,897,847) (9,336,269) (11,855,155) (14,456,928) (17,144,086) (19,919,200) (22,784,922) (25,743,986) (28,799,205) (31,953,479) (35,209,797) (38,571,241) (42,430,514)

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Illustration 23 – Broadband Pro Forma – Base Case – FTTP Buildout With Associated Debt – NO CATV SERVICE

Illustration 24 – Broadband Pro Forma – FTTP Buildout With Debt – Modified Assumptions – NO CATV SERVICE

BROADBAND - NO CATV - W/ OVERBUILD & DEBT
2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 Revenue 3,726,816 3,725,756 3,741,706 3,743,909 3,743,119 3,742,327 3,741,537 3,740,747 3,739,958 3,739,166 3,738,376 3,737,586 3,736,796 3,736,005 3,735,215 Expenses 6,346,677 6,419,501 6,494,541 6,571,862 6,651,536 6,733,632 6,818,226 6,905,393 6,995,211 7,087,761 7,183,126 7,281,391 7,382,646 7,486,980 7,594,487 Operating Income (2,619,861) (2,693,746) (2,752,834) (2,827,953) (2,908,416) (2,991,305) (3,076,689) (3,164,645) (3,255,253) (3,348,595) (3,444,750) (3,543,805) (3,645,849) (3,750,975) (3,859,273) EBITDA (2,230,330) (2,304,214) (2,363,303) (2,438,422) (2,518,885) (2,601,774) (2,687,158) (2,775,114) (2,865,722) (2,959,064) (3,055,219) (3,154,274) (3,256,318) (3,361,444) (3,859,273)

95.00% Debt Service -$ (465,317)$ (1,341,563)$ (1,740,406)$ (1,740,406)$ (1,740,406)$ (1,740,406)$ (1,740,406)$ (1,740,406)$ (1,740,406)$ (1,740,406)$ (1,740,406)$ (1,740,406)$ (1,740,406)$ (1,740,406)$ Cash Flow (2,230,330) (2,769,531) (3,704,866) (4,178,828) (4,259,291) (4,342,179) (4,427,563) (4,515,520) (4,606,128) (4,699,469) (4,795,624) (4,894,680) (4,996,724) (5,101,850) (5,599,678) Cumulative Cash Flow (2,230,330) (4,999,861) (8,704,727) (12,883,554) (17,142,845) (21,485,025) (25,912,588) (30,428,108) (35,034,235) (39,733,704) (44,529,329) (49,424,008) (54,420,732) (59,522,582) (65,122,260)

BROADBAND - NO CATV - MODIFIED - W/ OVERBUILD DEBT
2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 Revenue 4,785,421 5,011,104 5,029,903 5,106,737 5,120,201 5,118,817 5,117,436 5,116,056 5,114,675 5,113,291 5,111,910 5,110,530 5,109,149 5,107,765 5,106,384 Expenses 3,504,828 3,534,724 3,565,530 3,597,273 3,629,981 3,663,683 3,698,411 3,734,196 3,771,068 3,809,062 3,848,212 3,888,553 3,930,120 3,972,952 4,017,087 Operating Income 1,280,593 1,476,380 1,464,373 1,509,464 1,490,221 1,455,134 1,419,025 1,381,860 1,343,607 1,304,229 1,263,698 1,221,977 1,179,029 1,134,813 1,089,297 EBITDA 1,670,124 1,865,911 1,853,904 1,898,995 1,879,752 1,844,665 1,808,556 1,771,391 1,733,138 1,693,760 1,653,229 1,611,508 1,568,560 1,524,344 1,089,297

95.00% Debt Service -$ (465,317)$ (1,341,563)$ (1,740,406)$ (1,740,406)$ (1,740,406)$ (1,740,406)$ (1,740,406)$ (1,740,406)$ (1,740,406)$ (1,740,406)$ (1,740,406)$ (1,740,406)$ (1,740,406)$ (1,740,406)$ Cash Flow 1,670,124 1,400,594 512,341 158,590 139,346 104,260 68,150 30,986 (7,268) (46,646) (87,177) (128,898) (171,846) (216,061) (651,108) Cumulative Cash Flow 1,670,124$ 3,070,718$ 3,583,059$ 3,741,649$ 3,880,995$ 3,985,254$ 4,053,405$ 4,084,390$ 4,077,123$ 4,030,477$ 3,943,301$ 3,814,403$ 3,642,557$ 3,426,496$ 2,775,387$

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Illustration 25 - Comparative Results Voice Business Case –

NO CATV

Base Base W/
Debt
Modified w/
Debt
2023 (46,367) (46,367) (46,367) 2024 (71,896) (96,387) (96,387) 2025 (80,271) (150,880) (150,880) 2026 (84,342) (175,943) (175,943) 2027 (88,537) (180,137) (180,137) 2028 (92,860) (184,460) (184,460) 2029 (97,314) (188,914) (188,914) 2030 (101,903) (193,503) (193,503)
2031 (127,134) (218,734) (218,734)
2032 (132,006) (223,607) (223,607)
2033 (137,027) (228,628) (228,628)
2034 (142,201) (233,802) (233,802)
2035 (147,532) (239,133) (239,133)
2036 (153,026) (244,626) (244,626)
2037 (158,686) (250,286) (250,286)
(1,661,103) (2,855,406) (2,855,406)

CASH FLOW

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Illustration 26 – Voice Pro Forma – No Buildout / No Debt

This scenario assumes no expense reductions would accompany the elimination of CATV service. Non-Programming related operating expenses previously allocated to CATV in the Base run were re-allocated to Broadband (95%) and Voice (5%).

VOICE - NO CATV - NO DEBT
2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 Revenue 258,459 236,764 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 Expenses 325,328 329,162 333,113 337,184 341,379 345,701 350,155 354,745 359,474 364,346 369,367 374,541 379,872 385,366 391,026 Operating Income (66,869) (92,398) (100,773) (104,844) (109,039) (113,361) (117,815) (122,405) (127,134) (132,006) (137,027) (142,201) (147,532) (153,026) (158,686) EBITDA (46,367) (71,896) (80,271) (84,342) (88,537) (92,860) (97,314) (101,903) (127,134) (132,006) (137,027) (142,201) (147,532) (153,026) (158,686) Debt Service
Cash Flow (46,367) (71,896) (80,271) (84,342) (88,537) (92,860) (97,314) (101,903) (127,134) (132,006) (137,027) (142,201) (147,532) (153,026) (158,686) Cumulative Cash Flow (46,367) (118,264) (198,535) (282,877) (371,414) (464,274) (561,587) (663,490) (790,624) (922,630) (1,059,658) (1,201,859) (1,349,391) (1,502,417) (1,661,103)

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Illustration 27 – Voice Pro Forma – FTTP Buildout With Debt - NO CATV SERVICE

No Scenario Was Developed Employing Modified / Optimized Voice Assumptions

VOICE - NO CATV - W/ OVERBUILD DEBT
2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 Revenue 258,459 236,764 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 Expenses 11,534$ 329,162$ 333,113$ 337,184$ 341,379$ 345,701$ 350,155$ 354,745$ 359,474$ 364,346$ 369,367$ 374,541$ 379,872$ 385,366$ 391,026$ Operating Income 246,925 (92,398) (100,773) (104,844) (109,039) (113,361) (117,815) (122,405) (127,134) (132,006) (137,027) (142,201) (147,532) (153,026) (158,686) EBITDA (46,367) (71,896) (80,271) (84,342) (88,537) (92,860) (97,314) (101,903) (127,134) (132,006) (137,027) (142,201) (147,532) (153,026) (158,686) 5% Debt Service -$ (24,490)$ (70,609)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ Cash Flow (46,367) (96,387) (150,880) (175,943) (180,137) (184,460) (188,914) (193,503) (218,734) (223,607) (228,628) (233,802) (239,133) (244,626) (250,286) Cumulative Cash Flow (46,367) (142,754) (293,634) (469,576) (649,714) (834,174) (1,023,087) (1,216,591) (1,435,324) (1,658,931) (1,887,559) (2,121,361) (2,360,493) (2,605,119) (2,855,406)

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Illustration 28 - Comparative Results CATV Business Case – Modernization of Existing COAX-Based Network Infrastructure Base Base W/
Debt
Modified w/
Debt
2023 (2,083,036) (2,083,036) (104,963)
2024 (2,251,299) (2,483,957) (614,042)
2025 (2,144,662) (2,815,444) (1,053,515)
2026 (1,930,593) (2,800,796) (1,146,763)
2027 (1,717,401) (2,587,603) (1,041,457)
2028 (1,537,794) (2,407,996) (955,062)
2029 (1,547,389) (2,417,592) (973,360)
2030 (1,587,559) (2,457,762) (1,008,933)
2031 (1,628,340) (2,498,542) (1,045,119)
2032 (1,667,527) (2,537,730) (1,079,718)
2033 (1,707,240) (2,577,443) (1,114,853)
2034 (1,748,009) (2,618,212) (1,151,056)
2035 (1,789,860) (2,660,063) (1,188,360)
2036 (1,832,824) (2,703,027) (1,226,799)
2037 (2,071,695) (2,941,898) (1,461,173)
(27,245,228) (38,591,101) (15,165,174)

CASH FLOW

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Illustration 29 – CATV Pro Forma – No Buildout / No Debt

CATV - COAX PLANT - NO DEBT
2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 Revenue 3,580,077 3,192,084 3,080,166 3,076,706 3,073,247 3,069,779 3,066,318 3,062,859 3,059,763 3,059,262 3,059,262 3,059,262 3,059,262 3,059,262 3,059,262 Expenses 5,857,878 5,638,148 5,419,593 5,202,065 4,985,413 4,802,338 4,808,473 4,845,183 4,882,868 4,921,554 4,961,268 5,002,036 5,043,887 5,086,851 5,130,957 Operating Income (2,277,802) (2,446,065) (2,339,428) (2,125,358) (1,912,166) (1,732,559) (1,742,155) (1,782,325) (1,823,105) (1,862,293) (1,902,006) (1,942,774) (1,984,626) (2,027,590) (2,071,695) EBITDA (2,083,036) (2,251,299) (2,144,662) (1,930,593) (1,717,401) (1,537,794) (1,547,389) (1,587,559) (1,628,340) (1,667,527) (1,707,240) (1,748,009) (1,789,860) (1,832,824) (2,071,695) Debt Service
Cash Flow (2,083,036) (2,251,299) (2,144,662) (1,930,593) (1,717,401) (1,537,794) (1,547,389) (1,587,559) (1,628,340) (1,667,527) (1,707,240) (1,748,009) (1,789,860) (1,832,824) (2,071,695) Cumulative Cash Flow (2,083,036) (4,334,335) (6,478,997) (8,409,590) (10,126,991) (11,664,784) (13,212,173) (14,799,732) (16,428,072) (18,095,599) (19,802,839) (21,550,848) (23,340,708) (25,173,532) (27,245,228)

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Illustration 30 – CATV Pro Forma – Base Case – Buildout With Associated Debt – Modernization of Existing COAX-Based Network Infrastructure

Illustration 31 – CATV Pro Forma – Buildout With Associated Debt – Modernization of Existing COAX-Based Network Infrastructure

CATV - COAX PLANT - W/ OVERBUILD DEBT
2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 Revenue 3,580,077 3,192,084 3,080,166 3,076,706 3,073,247 3,069,779 3,066,318 3,062,859 3,059,763 3,059,262 3,059,262 3,059,262 3,059,262 3,059,262 3,059,262 Expenses 5,857,878 5,638,148 5,419,593 5,202,065 4,985,413 4,802,338 4,808,473 4,845,183 4,882,868 4,921,554 4,961,268 5,002,036 5,043,887 5,086,851 5,130,957 Operating Income (2,277,802) (2,446,065) (2,339,428) (2,125,358) (1,912,166) (1,732,559) (1,742,155) (1,782,325) (1,823,105) (1,862,293) (1,902,006) (1,942,774) (1,984,626) (2,027,590) (2,071,695) EBITDA (2,083,036) (2,251,299) (2,144,662) (1,930,593) (1,717,401) (1,537,794) (1,547,389) (1,587,559) (1,628,340) (1,667,527) (1,707,240) (1,748,009) (1,789,860) (1,832,824) (2,071,695)

47.50% Debt Service -$ (232,658)$ (670,781)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ Cash Flow (2,083,036) (2,483,957) (2,815,444) (2,800,796) (2,587,603) (2,407,996) (2,417,592) (2,457,762) (2,498,542) (2,537,730) (2,577,443) (2,618,212) (2,660,063) (2,703,027) (2,941,898) Cumulative Cash Flow (2,083,036) (4,566,994) (7,382,437) (10,183,233) (12,770,836) (15,178,833) (17,596,424) (20,054,186) (22,552,728) (25,090,458) (27,667,901) (30,286,113) (32,946,176) (35,649,203) (38,591,101)

CATV - MODIFIED - W/ OVERBUILD DEBT - COAX PLANT
2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 Revenue 3,580,077$ 3,192,084$ 3,080,166$ 3,076,706$ 3,073,247$ 3,069,779$ 3,066,318$ 3,062,859$ 3,059,763$ 3,059,262$ 3,059,262$ 3,059,262$ 3,059,262$ 3,059,262$ 3,059,262$ Expenses 3,879,806$ 3,768,233$ 3,657,665$ 3,548,032$ 3,439,266$ 3,349,404$ 3,364,240$ 3,396,355$ 3,429,445$ 3,463,543$ 3,498,677$ 3,534,880$ 3,572,185$ 3,610,623$ 3,650,232$ Operating Income 3,254,749$ (576,149)$ (577,499)$ (471,326)$ (366,020)$ (279,625)$ (297,922)$ (333,496)$ (369,682)$ (404,281)$ (439,416)$ (475,619)$ (512,923)$ (551,362)$ (590,970)$ EBITDA (104,963)$ (381,383)$ (382,733)$ (276,561)$ (171,254)$ (84,859)$ (103,157)$ (138,730)$ (174,917)$ (209,516)$ (244,650)$ (280,853)$ (318,157)$ (356,596)$ (590,970)$

47.50% Debt Service - (232,658) (670,781) (870,203) (870,203) (870,203) (870,203) (870,203) (870,203) (870,203) (870,203) (870,203) (870,203) (870,203) (870,203) Cash Flow (104,963)$ (614,042)$ (1,053,515)$ (1,146,763)$ (1,041,457)$ (955,062)$ (973,360)$ (1,008,933)$ (1,045,119)$ (1,079,718)$ (1,114,853)$ (1,151,056)$ (1,188,360)$ (1,226,799)$ (1,461,173)$ Cumulative Cash Flow (104,963)$ (719,005)$ (1,772,520)$ (2,919,283)$ (3,960,740)$ (4,915,802)$ (5,889,162)$ (6,898,095)$ (7,943,215)$ (9,022,933)$ (10,137,786)$ (11,288,842)$ (12,477,202)$ (13,704,001)$ (15,165,174)$

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Illustration 32 - Comparative Results Broadband Business Case – Modernization of Existing COAX-Based Network Infrastructure

Base Base W/
Debt
Modified w/
Debt
2023 377,265 377,265 2,070,927
2024 339,792 107,134 2,037,122
2025 318,223 (352,558) 1,590,152
2026 281,765 (588,438) 1,439,077
2027 241,139 (629,064) 1,423,189
2028 199,299 (670,904) 1,391,559
2029 156,212 (713,991) 1,359,011
2030 111,838 (758,364) 1,325,517
2031 66,140 (804,063) 1,291,045
2032 19,073 (851,130) 1,255,564
2033 (29,400) (899,602) 1,219,049
2034 (79,322) (949,525) 1,181,465
2035 (130,739) (1,000,942) 1,142,780
2036 (183,698) (1,053,901) 1,102,958
2037 (433,007) (1,303,210) 867,203
1,254,580 (10,091,293) 20,696,617

CASH FLOW

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Appendix A

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Illustration 33 – Broadband Pro Forma – No Buildout / No Debt

BROADBAND- COAX PLANT - NO DEBT
2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 Revenue 3,726,816 3,725,756 3,741,706 3,743,909 3,743,119 3,742,327 3,741,537 3,740,747 3,739,958 3,739,166 3,738,376 3,737,586 3,736,796 3,736,005 3,735,215 Expenses 3,544,317 3,580,729 3,618,248 3,656,909 3,696,746 3,737,794 3,780,091 3,823,675 3,868,584 3,914,859 3,962,541 4,011,674 4,062,301 4,114,468 4,168,222 Operating Income 182,500 145,027 123,458 87,000 46,373 4,533 (38,554) (82,927) (128,626) (175,693) (224,165) (274,088) (325,505) (378,463) (433,007) EBITDA 377,265 339,792 318,223 281,765 241,139 199,299 156,212 111,838 66,140 19,073 (29,400) (79,322) (130,739) (183,698) (433,007) Debt Service
Cash Flow 377,265 339,792 318,223 281,765 241,139 199,299 156,212 111,838 66,140 19,073 (29,400) (79,322) (130,739) (183,698) (433,007) Cumulative Cash Flow 377,265 717,058 1,035,281 1,317,046 1,558,185 1,757,483 1,913,695 2,025,534 2,091,673 2,110,746 2,081,347 2,002,024 1,871,285 1,687,588 1,254,580

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Appendix A

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Illustration 34 – Broadband Pro Forma – Modernization of Existing COAX-Based Network Infrastructure

Illustration 35 – Broadband Pro Forma – Modernization of Existing COAX-Based Network Infrastructure

BROADBAND - COAX PLANT - W/ OVERBUILD DEBT
2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 Revenue 3,726,816 3,725,756 3,741,706 3,743,909 3,743,119 3,742,327 3,741,537 3,740,747 3,739,958 3,739,166 3,738,376 3,737,586 3,736,796 3,736,005 3,735,215 Expenses 3,544,317 3,580,729 3,618,248 3,656,909 3,696,746 3,737,794 3,780,091 3,823,675 3,868,584 3,914,859 3,962,541 4,011,674 4,062,301 4,114,468 4,168,222 Operating Income 182,500 145,027 123,458 87,000 46,373 4,533 (38,554) (82,927) (128,626) (175,693) (224,165) (274,088) (325,505) (378,463) (433,007) EBITDA 377,265 339,792 318,223 281,765 241,139 199,299 156,212 111,838 66,140 19,073 (29,400) (79,322) (130,739) (183,698) (433,007)

47.50% Debt Service -$ (232,658)$ (670,781)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ Cash Flow 377,265 107,134 (352,558) (588,438) (629,064) (670,904) (713,991) (758,364) (804,063) (851,130) (899,602) (949,525) (1,000,942) (1,053,901) (1,303,210) Cumulative Cash Flow 377,265 484,399 131,841 (456,596) (1,085,660) (1,756,565) (2,470,556) (3,228,920) (4,032,983) (4,884,113) (5,783,715) (6,733,240) (7,734,182) (8,788,083) (10,091,293)

BROADBAND - MODIFIED - W/ OVERBUILD DEBT - COAX PLANT
2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 Revenue 4,785,421 5,011,104 5,029,903 5,106,737 5,120,201 5,118,817 5,117,436 5,116,056 5,114,675 5,113,291 5,111,910 5,110,530 5,109,149 5,107,765 5,106,384 Expenses 2,909,259 2,936,089 2,963,735 2,992,222 3,021,575 3,051,822 3,082,988 3,115,102 3,148,193 3,182,290 3,217,424 3,253,628 3,290,932 3,329,371 3,368,979 Operating Income 1,876,162 2,075,015 2,066,168 2,114,515 2,098,626 2,066,996 2,034,449 2,000,954 1,966,483 1,931,001 1,894,486 1,856,902 1,818,217 1,778,395 1,737,406 EBITDA 2,070,927 2,269,780 2,260,933 2,309,280 2,293,391 2,261,761 2,229,214 2,195,719 2,161,248 2,125,767 2,089,251 2,051,668 2,012,983 1,973,160 1,737,406

47.50% Debt Service -$ (232,658)$ (670,781)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ (870,203)$ Cash Flow 2,070,927 2,037,122 1,590,152 1,439,077 1,423,189 1,391,559 1,359,011 1,325,517 1,291,045 1,255,564 1,219,049 1,181,465 1,142,780 1,102,958 867,203 Cumulative Cash Flow 2,070,927$ 4,108,049$ 5,698,201$ 7,137,279$ 8,560,467$ 9,952,026$ 11,311,037$ 12,636,554$ 13,927,599$ 15,183,163$ 16,402,212$ 17,583,677$ 18,726,457$ 19,829,414$ 20,696,617$

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Appendix A

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Illustration 36 - Comparative Results Voice Business Case – Modernization of Existing COAX-Based Network Infrastructure

Base Base W/
Debt
Modified w/
Debt
2023 (46,367) (46,367) (46,367) 2024 (71,896) (96,387) (96,387) 2025 (80,271) (150,880) (150,880) 2026 (84,342) (175,943) (175,943) 2027 (88,537) (180,137) (180,137) 2028 (92,860) (184,460) (184,460) 2029 (97,314) (188,914) (188,914) 2030 (101,903) (193,503) (193,503)
2031 (127,134) (218,734) (218,734)
2032 (132,006) (223,607) (223,607)
2033 (137,027) (228,628) (228,628)
2034 (142,201) (233,802) (233,802)
2035 (147,532) (239,133) (239,133)
2036 (153,026) (244,626) (244,626)
2037 (158,686) (250,286) (250,286)
(1,661,103) (2,855,406) (2,855,406)

CASH FLOW

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Appendix A

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Illustration 37 – Voice Pro Forma – No Buildout / No Debt

VOICE - COAX PLANT - NO DEBT
2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 Revenue 258,459 236,764 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 Expenses 325,328 329,162 333,113 337,184 341,379 345,701 350,155 354,745 359,474 364,346 369,367 374,541 379,872 385,366 391,026 Operating Income (66,869) (92,398) (100,773) (104,844) (109,039) (113,361) (117,815) (122,405) (127,134) (132,006) (137,027) (142,201) (147,532) (153,026) (158,686) EBITDA (46,367) (71,896) (80,271) (84,342) (88,537) (92,860) (97,314) (101,903) (127,134) (132,006) (137,027) (142,201) (147,532) (153,026) (158,686) Debt Service
Cash Flow (46,367) (71,896) (80,271) (84,342) (88,537) (92,860) (97,314) (101,903) (127,134) (132,006) (137,027) (142,201) (147,532) (153,026) (158,686) Cumulative Cash Flow (46,367) (118,264) (198,535) (282,877) (371,414) (464,274) (561,587) (663,490) (790,624) (922,630) (1,059,658) (1,201,859) (1,349,391) (1,502,417) (1,661,103)

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Appendix A

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Illustration 38 – Voice Pro Forma – Modernization of Existing COAX-Based Network Infrastructure

No Scenario Was Developed Employing Modified / Optimized Voice Assumptions

VOICE - COAX PLANT - W/ OVERBUILD DEBT
2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 Revenue 258,459 236,764 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 232,340 Expenses 10,351$ 10,351$ 10,351$ 10,351$ 10,351$ 10,351$ 10,351$ 10,351$ 10,351$ 10,351$ 10,351$ 10,351$ 10,351$ 10,351$ 10,351$ Operating Income 248,108 226,413 221,989 221,989 221,989 221,989 221,989 221,989 221,989 221,989 221,989 221,989 221,989 221,989 221,989 EBITDA (46,367) (71,896) (80,271) (84,342) (88,537) (92,860) (97,314) (101,903) (127,134) (132,006) (137,027) (142,201) (147,532) (153,026) (158,686) 5% Debt Service -$ (24,490)$ (70,609)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ (91,600)$ Cash Flow (46,367) (96,387) (150,880) (175,943) (180,137) (184,460) (188,914) (193,503) (218,734) (223,607) (228,628) (233,802) (239,133) (244,626) (250,286) Cumulative Cash Flow (46,367) (142,754) (293,634) (469,576) (649,714) (834,174) (1,023,087) (1,216,591) (1,435,324) (1,658,931) (1,887,559) (2,121,361) (2,360,493) (2,605,119) (2,855,406)

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Financial & Strategic
Assessment - Phase I
1CITY OF SAN BRUNO – PHASE I ASSESSMENT
Date: September 2021
Prepared for: City of San Bruno

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Suggestion: Add Agenda Slide
Agenda
• Background
• Market Dynamics
• Suggested Slide – Investment scenarios in broadband infrastructure • Analysis Summary – Base, Base + FTTP, FTTP Optimized • Analysis Summary – Base, Base + CATV Retrofit, CATV Retrofit Optimized • Analysis Summary – No CATV, No CATV + FTTP, No CATV + FTTP Optimized • Recommendations for Business Continuity
CITY OF SAN BRUNO – PHASE I ASSESMENT 2

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Background
CITY OF SAN BRUNO – PHASE I ASSESSMENT 3
JSI was contracted by the City of San Bruno (“SB” or the “City”) to conduct financial assessments of the the CityNet Enterprise a well as CityNet’s current voice, video, and broadband (“VVB”) offerings (operating under the “CityNet” name).

The assessment was to be conducted in two phases with Phase I designed to help the City understand the:

1. Commercial & financial viability of upgrading the City’s network infrastructure examining both an upgrade to the City’s principally Coax-based infrastructure as well as a Fiber to the Premise (“FTTP”) overbuild of CityNet’s current network,

2. Level of operating performance required to address the forecasted CAPEX implications of the upgrade paths examined; and,

3. Potential for the City to exit the market as a service provider should the prospects of an exit appear more beneficial to the City’s interest than making additional investments necessary to support its service suite.

Phase II entails the calculation of an enterprise value associated with the CityNet operation and is addressed through a separate presentation and report.

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Market Dynamics
CITY OF SAN BRUNO – PHASE I ASSESSMENT 4
Market dynamics surrounding traditional cable television (CATV) services and broadband internet are undergoing significant and accelerating change.

CityNet’s CATV services continues to suffer material
erosion with subscription declines accelerating and
programming costs outpacing inflation. While Management is taking aggressive, prudent, and productive steps to
address the financial dynamics of the business case,
underlying subscription trends in linear CATV service which are systemic to the service will continue to pose challenges to CityNet’s operation.

From a Broadband perspective, projected peak bandwidth
requirements are expected to grow exponentially over the next 10 years (see chart) and the current Coax cable-heavy network will simply not be able to support these needs
absent material remediation.

Peak Bandwidth Requirements – House of 4
Absent investment in broadband infrastructure, the City’s ability to address the evolving demands of the marketplace will progressively erode and financial performance will further deteriorate

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Network Deployment / Upgrade Scenarios Examined

1. Fiber to the Premise (“FTTP”)
This scenario examined an overbuild of the City’s existing Coax-based plant with a hybrid Active-E and XGS-PON design.

Introduction of dedicated strands at aggregation points allows CityNet to address the specialized needs of customers requiring dedicated, higher bandwidth speeds supported by an Active-E topology.

XGS-PON provides four times the downstream bandwidth of standard GPON with its basic implementation, and up to sixteen times the bandwidth with the expansion of wavelengths.

Such a framework represents the “Gold Standard” for broadband networks, and would position the City to:
• Address both present and future needs of its constituents. Bandwidth demand continues to experience double digit growth, with the Fiber Broadband Association projecting the average usage for a family of four will exceed 2Gbps (symmetrical) by 2030. • Position the City to competitively differentiate the services offered from those available from alternative providers.

CITY OF SAN BRUNO – PHASE I ASSESMENT 5

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Forecasted CAPEX Investment – FTTP Scenario
CITY OF SAN BRUNO – PHASE I ASSESMENT 6

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Network Deployment / Upgrade Scenarios Examined

2. CATV / COAX Network Retrofit
This scenario examined a retrofit of the City’s existing Coax-based plant.

Benefit of this scenario is that it leverages existing infrastructure within the core network. While a reasonable level of new fiber is assumed, it is far less than that required for a full FTTP-based network deployment.

Such a scenario would allow the City to offer Gigabit level speed on an asymmetrical basis (Fiber offers the ability to provide symmetrical bandwidth).

Given trends in broadband speed demand, this design will require subsequent investment/remediation in order to remain in step with marketplace trends.

CITY OF SAN BRUNO – PHASE I ASSESMENT 7

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Forecasted CAPEX Investment – Coax Retrofit Scenario
CITY OF SAN BRUNO – PHASE I ASSESMENT 8

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Analysis Summary – Base, Base + FTTP, FTTP Optimized
CITY OF SAN BRUNO – PHASE I ASSESSMENT 9
This set of scenarios compares the forecast of the steady state business case to the steady state business case assuming the deployment of a FTTP network, as well a FTTP-based business case wherein the performance of the business case is optimized.

1. Base – Existing trajectory/performance of CATV, Broadband and Voice product offerings extended into the future using varied forecasting methodologies based on historic account activity.

2. Base W/ Debt – Base forecast with the introduction of a FTTP deployment and the debt service costs attendant to its financing.

3. Modified W/ Debt – Forecast of cash flows assuming a FTTP deployment in conjunction with an optimization of a range of revenue and expense related areas of operation/performance.
• Broadband ARPU was assumed to increase from $68.61 to $81.29. This would be accomplished through 1) elimination of numerous grandfathered rate designs in conjunction with consolidating available broadband rate offerings and 2) more proactive/aggressive efforts to sell value related to higher speed tier offerings. • Increase in subscription levels ranging between 10%-15% depending on speed/pricing tier based on the assumption that higher market share would be enabled as a result of more compelling/robust offerings.
• CATV programming costs indexed to 70% of associated CATV top-line revenue (reflecting material reduction from prevailing levels).  Management has related they have orchestrated such an outcome and such savings are currently being implemented.) • Remaining operating costs paired by 25% over prevailing baseline levels except for City corporate allocated expenses, which were maintained at 100% of forecasted levels.

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Analysis Summary – Base, Base + CATV Retrofit, CATV Retrofit Optimized
CITY OF SAN BRUNO – PHASE I ASSESSMENT 10
This set of scenarios compares the forecast of the steady state business case to the steady state business case assuming the deployment of an upgraded Coax- based network, as well an upgraded Coax-based business case wherein the performance of the business case is optimized.

1. Base – Existing trajectory/performance of CATV, Broadband and Voice product offerings extended into the future using varied forecasting methodologies based on historic account activity.

2. Base W/ Debt – Base forecast with the introduction of a FTTP deployment and the debt service costs attendant to its financing.

3. Modified W/ Debt – Forecast of cash flows assuming a FTTP deployment in conjunction with an optimization of a range of revenue and expense related areas of operation/performance.
• Broadband ARPU was assumed to increase from $68.61 to $81.29. This would be accomplished through 1) elimination of numerous grandfathered rate designs in conjunction with consolidating available broadband rate offerings and 2) more proactive/aggressive efforts to sell value related to higher speed tier offerings. • Increase in subscription levels ranging between 10%-15% depending on speed/pricing tier based on the assumption that higher market share would be enabled as a result of more compelling/robust offerings.
• CATV programming costs indexed to 70% of associated CATV top-line revenue (reflecting material reduction from prevailing levels).  Management has related they have orchestrated such an outcome and such savings are currently being implemented.) • Remaining operating costs paired by 25% over prevailing baseline levels except for City corporate allocated expenses, which were maintained at 100% of forecasted levels.

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Analysis Summary – No CATV, No CATV + FTTP, No CATV + FTTP Optimized CITY OF SAN BRUNO – PHASE I ASSESSMENT 11
No CATV: This foundational scenario assumes elimination of CATV based on accelerating marketplace subscription trends and is also divided into three sub- scenarios:

1. Base – Existing trajectory/performance of Broadband and Voice product offerings with the simple elimination of CATV revenue and expenses directly / solely related to the provision of CATV services (programming costs).

2. Base W/ Debt – Base scenario with the introduction of debt associated with the deployment of a FTTP topology.

3. Modified W/ Debt – Forecast of cash flows assuming elimination of CATV made conjunctively with a FTTP deployment and the optimization of a range of revenue and expense related areas of operation/performance. • Broadband ARPU was assumed to increase from $68.61 to $81.29. This would be accomplished through 1) elimination of numerous grandfathered rate designs in conjunction with consolidating available broadband rate offerings and 2) more proactive/aggressive efforts to sell value related to higher speed tier offerings. • Increase in subscription levels ranging between 10%-15% depending on speed/pricing tier.

Assumption, more compelling/robust offerings result in higher marketplace demand. • Remaining operating costs were paired by roughly 56% over prevailing baseline levels except for programming costs which were eliminated entirely, and City corporate allocated expenses which were maintained at 100% of forecasted levels.

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Broadband as a Public Good
Broadband is widely regarded as the essential service of our age.

As noted by the Brookings Institute, “Increasing access and usage of broadband infrastructure….. (and the amenities, digital skills, online education, and job search opportunities that come with it) lead to higher property values, increased job and population growth, higher rates of new business formation, and lower unemployment rates.*”
In the evaluation of its business case options, assessment of the “Public Good” nature of Broadband, and the City’s unique position of the “guarantor” of equitable broadband access is a worthwhile point of examination.
◦ In assessing the relative value and/or “weight” assigned to the importance of the public good provided by CityNet’s suite of products, the following considerations merit examination. ◦ If the City were to exit the market, would access to high-speed broadband within the City be materially impacted?
◦ Would affordability of broadband access suffer as a result of the City’s exit from the market? Ultimately, the foregoing questions provide an important qualitative public policy consideration for the City’s Management and Board. The weight assigned to such a qualitative public policy consideration should in turn be influenced by the relative confidence assigned by the City’s Board and Management to its operational ability to engineer a business case reflective of consistent positive cash flows and financial sustainability. *Brookings – The Benefits and Costs of Broadband Expansion – 2021.

CITY OF SAN BRUNO – PHASE I ASSESMENT 12

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Summary
CITY OF SAN BRUNO – PHASE I ASSESSMENT 13
Given market placed trends related to Broadband and CATV services, CityNet Management has recommended a pivot in its service provider position from one in which CATV is the foundational offering, to a framework in which Broadband is positioned as the organization’s leading solution. JSI strongly endorses this strategy.

With regard to Broadband, given the forecasted explosive growth in bandwidth demand, mid to long-term viability of CityNet’s operations is reliant on a material retro-fit of the City’s existing Cable infrastructure, or deployment of a FTTP topology.

A FTTP deployment represents the most robust option to future proof the City’s technology/service delivery position.

Such a deployment would:
• Position CityNet to meet the prospective needs of its citizenry well into the future, • Allow the organization to offer multi-gigabit, symmetrical bandwidth services enhancing its ability to maximize the “public good” value of the services offered to the City’s residents while competitively differentiating its offering relative to the market’s competitive alternatives.

A retrofit of the City’s Coax-based infrastructure would allow the extension of asymmetrical gigabit enable broadband services which would:
• Enable the City to offer a substantially more robust broadband offering than is presently available, while • Producing materially more free cash flow after debt service than the FTTP deployment scenario (all else equal).

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Recommendations for Business Continuity
CITY OF SAN BRUNO – PHASE I ASSESSMENT 14

1. Fiber – the gold standard
Fiber represents the gold standard, and places providers deploying the technology in the most robust competitive position, with the capability of leveraging a network flexible enough to adapt to the market’s forecasted ongoing bandwidth demand growth. The eroding competitive stature of CityNet’s product offerings is directly related to the deferment of investment required to sustain product relevancy. Plans involving limited or short-term remediation of the City’s service capabilities may temporarily stem the customer attrition trends presently in play, but will not place CityNet in a position to provide a service that is positively differentiated from other marketplace options, or effectively address mid to longer-term trends related to growing broadband demand.

2. Business case optimization – necessary to enable required upgrade investment The issue the City must confront is whether it can successfully engineer an optimization of its present business case of the nature and scope reflective in the optimized scenarios detailed herein. Absent this ability, the City’s financial wherewithal to financially underwrite the deployment of either the remediation of its existing Coax plant, or the more extensive capital requirements related to the deployment of a FTTP network, would be materially compromised.

3. Tactical plan recommended for financial optimization JSI recommends the City formulate a detailed tactical plan to produce the level of financial optimization reflected in the scenarios set forth in JSI’s analysis. This plan could then be assessed by the City as to the feasibility of producing the financial outcomes deemed necessary to warrant sustaining its service provider position.

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Phase II – Enterprise Valuation
This briefing reflects analysis, observations and recommendations surrounding the options before the City relative to re-invigorating the service capabilities inherent in CityNet’s technology offerings.

As noted herein, without a solid, executable tactical plan to optimize operations, the ability for the City to finance the upgrades necessary will be compromised.

CityNet Management requested that JSI conduct a valuation of the CityNet enterprise in order to provide insight as to whether an exit from its current service provider position represented a more fiscally prudent step than engaging in a network upgrade and accompanying operational optimization initiative.

A separate valuation report has been delivered which provides guidance relative to the enterprise value of CityNet’s operation. When assessing the options to re-invest in the City’s service operations, or exit the market through a sale of the organization’s assets, care must be taken to assess several critical considerations.
◦ Presently, the City recovers material dollars from CityNet’s operation by way of allocated expenses. ◦ The City will continue to be responsible for pension payments to current and past employees. Presently such pension costs are supported through CityNet’s operation. ◦ As noted herein, there are potential paths to profitability to both finance the upgrades modeled herein, as well as re -pay the Enterprise Loan extended from the City’s General Revenue Fund.

Examination of the City’s available options, including a potential sale of the enterprise and exit from the business must include careful consideration of the foregoing points.

CITY OF SAN BRUNO – PHASE I ASSESMENT 15

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CITYNET STUDY SESSION
NOVEMBER 2022

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CityNet Study Session
Agenda
• Current situation
• Proposed Next Steps
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CityNet Study Session

CURRENT SITUATION
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Loan to CityNet from City’s General Fund
• Loan Advances - ($14,091,008)
• Total Fund Balance - ($17,878,960)
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CABLE INDUSTRY STATUS
Customer Base – 2018 to 2022

66.4 M (’18)
82 M (’22)

51.9 M
43 M

31.4 M
25 M
Cable Internet Television Phone
How We Stack Up
Broadband Cable TV Phone
53% · 44% (’18)
67% · 44% (’22)
41% · 38%
35% · 26%
25% · 6%
20% · 7%
National San Bruno CityNet
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Subscription Data – 2019 - 2022
Year Service Homes Internet
Subscribers
TV Subscribers
46% of San Bruno Households
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CityNet Expenditures & Revenues: 2019-23
Year Expenditure Revenue Deficit %
2018-19 $12,158,037 $9,739,497 ($2,418,540) (25%)
2019-20 $11,027,817 $9,303,574 ($1,724,243) (19%)
2020-21 $9,921,671 $9,017,047 ($904,624) (10%)
2021-22 $9,588,400 $8,566,131 ($1,022,269) (11%)
2022-23
(Budget)
$8,712,432 $8,937,164 $224,732 2.5%
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Summary
2019-23 Expenditure Revenue Difference %
Reduction
from 2019 to
2023
$3,445,605 $802,333 $2,643,272 77%
Margin
improvement
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SAN BRUNO CITYNET’S SITUATION
San Bruno CityNet’s Infrastructure Investments

PROJECT COST YEAR COMMENTS
270 Mhz System and 46.7 miles of cable $565,000 1971 12 channel system launched Additional 13 miles of cable $86,000 1975 Expanded to 24 channels, with Set Top Boxes 450 Mhz System Upgrade $2,200,000 1985 60 channels fully addressable 750 Mhz System Upgrade $7,100,000 1999 117 channels; high speed data ISP business launch $300,000 2002 Launch of broadband internet Cable VOD launch $425,000 2004 Enhanced system functionality Router Upgrade; 10k CMTS $1,700,000 2007 Internet and phone capacity increase System upgraded to 100% digital $230,000 2008 Increased channel capacity Upgrade to Arris E6000 $450,000 2012 Enabled enhanced monetization of capacity Router Upgrade with 10 Gigahertz Cards $894,800 2014 Increased internet capacity Upgraded VOD Storage $200,000 2015 Greater Cable VOD capacity CAP 1000 Equipment Upgrade $115,000 2017 Increase HD channel capacity MDU Fiber Projects (Shelter Creek, Peninsula Place & Crystal Springs) $2,200,000 2016-18 Fiber into select MDUs Router Upgrade Project $1,600,000 2018 Increased internet capacity TOTAL $18,065,000 51 Years
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SAN BRUNO CITYNET’S SITUATION
Performance (Continued)
20 years
Revenue per
$1 Spend
$300B $6.00
National San Bruno Cable
50 years
$18.1M
20 years
$1.8T
20 years
$185M $10.22
10 RevenueInfrastructure Spend

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11 SAN BRUNO CITYNET’S SITUATION
What San Bruno CityNet is Doing Right Now

NEW STREAMING TV PACKAGES & RATE CARD
App based platform due for commercial launch
January – March 2023

ALL HD TV PLATFORM
Part of Streaming TV launch on Roku, iOS,
Android & Amazon platforms

TEST FIBER ROLLOUT TO SAN BRUNO

NEIGHBORHOOD
Completed in the Marisol and Skyline
neighborhoods. Others in planning/execution
modes

PERFORMANCE IMPROVEMENTS
Increased internet capacity, speeds and
reliability.

NEW INTERNET MARKETING
Modest efforts in targeted Internet
marketing has led to some replacement of
lost bundle subscribers. More campaigns
underway.

CONTINUING COST CONTROLS
Continuous engagement on new service
deals with vendors to enable cost savings
and margin improvements
CHANNEL 1
Upgrade to HD, new platform and hybrid
telecast mostly complete

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SAN BRUNO CITYNET’S SITUATION
Customer Calls: July 2019 – September 2022
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200
400
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1600
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2000
Jul
Aug
Sept
Oct
Nov
Dec
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
CALLS
Calls Received Calls Answered Cable Customer Calls Fiber Customer Calls

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THE PATH FORWARD
Fiber Buildout Rationale
Consumers
More bandwidth
& faster speeds =
fiber
More apps =
more internet
bandwidth & speeds
Internet
video
Connected
appliances
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SAN BRUNO CITYNET’S SITUATION
San Bruno CityNet’s Crossroads
Enterprise has provided competitive
service to San Bruno for 51 years
Limited recent investment in installing
fiber in one neighborhood and select
apartment complexes, with good results
(67% aggregate broadband penetration)
51 14
System needs to offer higher internet
speeds and better streaming TV
options to serve customers
Internet usage on San Bruno Cable
has exploded—11 Gig to 23 Gig growth from
2018-22. System needs to provide
operational continuity and exponentially
better internet connectivity to cater to its
customers
Smart Home/Business Crossroads
Continue with replacements for operational continuity and a neighborhood fiber upgrade to serve the SB community at a higher level of effectiveness?

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THE PATH FORWARD
Fiber Buildout Rationale
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SAN BRUNO’S SMARTCITY POTENTIAL
San Bruno City Specifics
Lane miles with 300 RO Street Lights to
be served through Fiber (+ Traffic Lights!)
Fiber connectivity for Parking Meters in
Downtown San Bruno
Smart City Crossroads
Continue with replacements for operational continuity and a neighborhood fiber upgrade to serve the public needs of the San Bruno community at a higher level of effectiveness?
180
16 Potential for cost savings through
CityNet Fiber and iOT connectivity
(already provided to the City
organization, pump stations, SBPSD, PD
Wireless, Fire Cameras, Senior Center
and new SBRAC)
15,000 Digital Water Meters connectable
with Fiber

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Positive ROI from Fiber Investment in San
Bruno

PROPERTY ACCESS

RIGHTS UNITS SERVICABLE
HOMES

SUBSCRIBERS
(% SERVICE

PENETRATION)
Peninsula
Place MDU
Non-
exclusive 860 819 (95%) 524 (64%)
Crystal
Springs MDU
Non-
exclusive 437 415 (95%) 216 (52%)
Shelter Creek
MDU
Exclusive
at start 1,296 1,241 (96%) 936 (75%)
Marisol Single
Family (July
2022)
Non-
exclusive 100 100 (100%) 42 (42%)
Total 2,693
(18.3%)
2,575
(96%)
1,718
(67%)
Subscribers generate
$2,201,789 in annual
subscription revenue with
$990,805 (45%) in post
fiber revenue growth

18.3% of San Bruno
homes have San Bruno
Cable’s fiber
Most fibered homes are in
MDUs (96%)
Cost of fiber install:
$2,300,000
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Customer Testimonials –Marisol Fiber Upgrade
• Our home had San Bruno CityNet’s fiber internet service installed 3 months ago. The installation process was professional and we have had no trouble at all with the service. (CityNet Customer on Adriatic Way, San Bruno)
• We have 1 Gig internet and phone as well as international Tagalog language TV and the Preferred TV package from San Bruno CityNet Services. The technicians who installed our services were knowledgeable and courteous. We have had no trouble in the 3 weeks since we got installed and look forward to trouble free services in the future. (CityNet Customer on Miraluna Drive, San Bruno) 18 327 of 342

Customer Testimonials –Marisol Fiber Upgrade
• We had our internet service installed 4 weeks ago. Our internet service delivered on fiber has worked great for us. (CityNet Customer on Miraluna Drive, San Bruno)
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CityNet Study Session

PROPOSED NEXT STEPS
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City’s Options - Recommendations
• Hybrid solution proposed
• Maintain Operational Status
• Continue Fiber Upgrade
• Keep system operational by eliminating dependance on recognized point of failure for HFC cable - active tap management server (aka City Manager!) • 500 taps (19%) already replaced
• 1,040 taps on order
• Outsource tap replacement to part time employee teams in SB backyards • Continue with Fiber Upgrade, with limited neighborhood rollouts • 2,400 homes and 50 lane miles in 3 years @$1,250 per home ($3 million upfront investment in 2023; additional $1 million/year investment requested for 2 years from 2023-25, self sustaining from fiscal 2025) • 57% system penetration by 2030 (mirrors national fiber penetration projections) Note: Fiber upgraded areas do not have taps and no need for tap replacement • Business plan changes to continue per plan
• 100% fiber rollout in all new business park and residential developments (Miraluna, Skyline Ridge, Bay Hill, Tanforan & others to come)
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PART 3 · THE PATH FORWARD
Proposed Operational Continuity & Neighborhood
Fiber Upgrade Costs (Fiscal 2023 – 2025)
Contingency (15%)
$750,000
Working Capital
$5,000,000
Total
$5,750,000+ =
Fiber Equipment &
Limited Additional
Labor
$4,250,000
Tap Replacements
(Operational
Continuity)
$650,000
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Business Strategies and Plan as presented in March 2019 Market Appropriate through 2022 and going forward
23 ISP Strategy
3 Services Strategy
“Thick Pipe, Thin Pipe” Strategy
Internet AccessTV Phone
100% Last Mile Subscriber Relationship Shared Subscriber Relationship 23 332 of 342

24 ENTERPRISE BUSINESS STRATEGY

ISP FOCUS, TV ADD ON, PHONE ADD ON
System Strategies – Market Appropriate through
2022 and going forward

PRODUCT STRATEGY

PRIMARY EMPHASIS ON

INTERNET

PRICING STRATEGY
NO CONTRACTS; 30% LOWER
VS. COMPETITION RACK RATES

MARKETING STRATEGY
GRASSROOTS FOCUS;

LIMITED PROMOTIONS

TECH STRATEGY
ASSET LIGHT; BYOD TV

OPERATIONAL STRATEGY

REDUCE FAULTS, CALLS & TRUCK ROLLS

RIGHTSIZE HEADCOUNT

CONTENT ACQUISITION

STRATEGY

DATA BASED CURATION
Business Strategies and Plan as presented in March 2019 24 333 of 342

PRODUCT EXISTING

RATE CARD (PRIOR TO

UNBUNDLING)

NEW RATE CARD BENEFIT
FIBER INTERNET +

LOCAL TV
COMBO - $85/MO. SEPARATE:

INTERNET - $80/MO.

BASIC TV - $35/MO.
100% CUSTOMER
CHOICE; IMPROVED

ENTERPRISE MARGIN
CABLE INTERNET +

LOCAL TV
COMBO - $40/MO. -
$75/MO.

SEPARATE:

INTERNET - $40/MO.
- $70/MO.

BASIC TV - $35/MO.
100% CUSTOMER
CHOICE; IMPROVED

ENTERPRISE MARGIN
EXPANDED CABLE TV $103.55/MO.
(MOVIE CHANNELS
EXTRA)
$110/MO.
(SOME MOVIE

CHANNELS INCLUDED)

CURATED CONTENT WITH

IMPROVED ENTERPRISE
MARGIN

ONE TO FOUR

PREMIUM MOVIE

CHANNEL PACKAGE(S)
$27/MO. - $67/MO. NOT AVAILABLE INCLUDED IN NEW

EXPANDED CABLE TV

CONTINUING BUSINESS MODEL CHANGES

CURRENT AND PROPOSED PRODUCT RATES
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PRODUCT EXISTING RATE CARD
(PRIOR TO UNBUNDLING)

NEW RATE CARD BENEFIT
SPORTS TIER NOT OFFERED $65/MO. FIRST TIME AVAILABILITY SPORTS AND NEWS TIER NOT OFFERED $75/MO. FIRST TIME AVAILABILITY

BASIC INTERNET AND LOW
INCOME
$19.95/MO. - BASIC

INTERNET
$20.55/MO. - BASIC TV
$9.95/MO. - LOW INCOME

INTERNET
$15.46/MO. - LOW INCOME
TV
NO CHANGE MAINTAINS CITY’S SERVICE

COMMITTMENT TO

QUALIFIED LOW INCOME

RESIDENTS

CONTINUING BUSINESS MODEL CHANGES
CURRENT AND PROPOSED PRODUCT RATES (continued)
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STREAMING TV INFORMATIONAL MARKETING
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STREAMING TV INFORMATIONAL MARKETING
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CURRENT TARGETED INTERNET MARKETING
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Expanding Outside San Bruno
• Federal Government & State Government Grants
 Current funding for areas under 25 MBPS Downstream & 3 MBPS Upstream internet speeds
CA State focus on middle mile networks
Opportunity may emerge for last mile fiber in future grant series (Grant writing assistance to be sourced @ estimated $50,000 per application package) • Cities exploring city owned fiber internet
White label solution on offer from San Bruno CityNet
Palo Alto, Colma, East Palo Alto some examples
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Recent Industry Headlines and Implications
• You Hated Your Cable Package. Your Streaming Services Are Bringing It Back.

Implication: The significance of TV packages to consumers is diminished but not eliminated • Streaming Tops Cable-TV Viewing for the First Time
Netflix, Hulu, Prime Video and other platforms set records for share of U.S. viewing time in July
Implication: Streaming TV is here to stay
• Comcast Fails to Gain Broadband Subscribers for First Time Implication: Consumer pull back from COVID Stay at Home needs • Comcast Launches Smart TV for U.S. Market in Bid to Take On Roku, Amazon Like its peers in the pay-TV industry, Comcast has been losing cable customers as consumers flee the traditional bundle for streaming services. The company had nearly 19 million cable-TV customers as of June 30, after losing 399,000 during the second quarter.

Implication: Why buy a cable TV system/ISP when you can own the living room experience and associated $ without paying the cost of last mile delivery? 31 340 of 342

Industry Headlines from Wall Street Journal
• Americans Aged 50 and Up Are Powering Streaming Growth The group accounted for 39% of streaming watch time as of May 2022, outpacing growth of all other demographic segments
Implication: The classic pay TV demographic is embracing streaming TV 32 341 of 342

Comments or Questions?
Thank you!
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