RFP 1820 Rumrill Blvd — San Pablo City Council, February 7, 2022

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REQUEST FOR PROPOSALS
for the development and
management of housing at

1820 Rumrill Blvd
San Pablo, CA

ISSUED:

August 2, 2021

PROPOSAL DUE:

November 1, 2021

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CITY OF SAN PABLO

REQUEST FOR PROPOSALS
for the development and management of housing located at 1820 Rumrill Blvd
Date Issued: August 2, 2021
Deadline for Questions: 4:00 P.M., Monday September 20, 2021 Date Due: 4:00 P.M., Monday, November 1, 2021
Issued By: Jennifer Kauffman , City Manager’s Office
RFP contact for all communications:

Jennifer Kauffman, Housing & Economic Development Management Analyst [email protected]
510-215-3035

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ATTACHMENT A
13 P a g e | 5

1. Executive Summary
Objective
The City of San Pablo is offering 0.50 acres of undeveloped land at 1820 Rumrill Blvd for purchase and development by a qualified and experienced developer or development team to build and manage new rental housing units. The City is seeking to maximize the site for suitable, quality affordable housing. The zoning for the site also incentivizes a commercial or mixed-use component to the development, with some flexibility on this provision based on the number of affordable housing units developed at the site.

Property
The site is a ½ acre site located at the northeast corner of Rumrill Blvd and Market Ave in San Pablo, California. The site is currently vacant and situated near single- and multi- family residential properties as well the Neighborhood Commercial Districts along Rumril Blvd and Market Ave.

The site is easily accessible by public transit with an AC Transit bus line that runs along Rumrill Blvd and another bus line the runs along Market Ave. Both bus lines provide transportation to the nearby Bay Area Rapid Transit (BART) stations located in Richmond and El Cerrito.

AC Transit Line 71 AC Transit Line 76
Development Team
The qualified development team or group of developers must have experience in developing market-rate and/or affordable housing in California as well as experience in securing financing and urban architecture. The development team must also include the capacity to operate and manage the developed property.

The City will offer the selected developer the option to enter into an Exclusive Negotiating Rights Agreement (ENA) that will define the general roles and commitments for the project. Upon successful negotiations, the City and developer will agree to a Disposition 1820
Rumrill 1820
Rumrill
and Development Agreement or other similar agreement that outlines the terms and conditions for the acquisition and development of the site.

Questions
Any questions regarding this RFP must be submitted by mail or email to the address listed below by no later than the questions submittal deadline: September 20, 2021 at 4:00 PM (PDT).

Submission Requirements
Responses are due no later than the day and time listed as the deadline and may be submitted by email or mail addressed as indicated below.

Mailing Address: San Pablo City Manager’s Office
Attn: Jennifer Kauffman
1000 Gateway Ave
San Pablo, CA 94806
Email Address: [email protected]
Submission Deadline: November 1, 2021 at 4:00 PM (PDT)

2. About San Pablo
The City of San Pablo is nestled within West Contra Costa County, located in the East Bay of California. Historically, one of the oldest Spanish settlements in the region, San Pablo is recognized as the first majority-Latino city in Contra Costa County. Currently the Hispanic or Latino population in San Pablo accounts for 62 percent of the City’s residents.

San Pablo has become a booming residential and business community with a population of about 30,990 in an area of approximately 2.6 square miles. The City is home to Contra Costa Community College and is fortunate to have a wealth of community resources, including a library, a sports park, a childcare facility, a regional healthcare facility and a career center. Many multilingual nonprofits, including First 5 and Lao Family Community Development, round out the diverse support services offered to residents. The City also offers youth programs at the award-winning San Pablo Community Center and senior services at the Senior Center to meet a variety of needs and interests, in addition to being recognized nationally and regionally for innovative and cutting-edge programs.

San Pablo households are more likely to be families with children (approximately 45 percent of all households), with a larger average household size compared to Richmond and the County. The schools serving San Pablo residents have unique support from the City Council through the San Pablo Full Service Community Schools Initiative. This initiative provides funding to support schools in becoming full-service community schools, in which the school district, city, county, community-based organizations, businesses, families and philanthropists form a strong and transparent partnership to jointly address the identified needs of students, families and the community in a comprehensive, integrated and P a g e | 6
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accountable way. In 2012, the City of San Pablo passed Measure Q, a local sales tax increase to help fund the provision of youth services.

There are a number of current housing development projects in the City. Below are two highlighted projects that include affordable units.
• Location: Block E near Chattleton Ln & Church Ln
Proposal: Development of 20 for-sale market homes, including one (1) home that will be income-restricted for sale to a "lower-income" household. Eight of the units will have a built-in accessory dwelling unit. The site will also include a public park within the proposed subdivision adjacent to the City’s newly restored Wildcat Creek Trail.
• Location: Former Civic Center at 13831 San Pablo Avenue Project: Affordable Housing Mixed-Use Development consisting of 100 units of multi-family affordable housing with residential services and approximately 10,000 square feet of commercial retail space on the ground floor. One commercial space reserved for a San Pablo local business at 15% below market rent. The Alvarado Adobe building (a 1976 replica of the original California landmarked adobe house built on this site in 1842) will remain on-site with specific CEQA mitigation measures in place, and will be re-purposed (through consultation with the San Pablo Historical & Museum Society) to an allowable and permissible use under the City’s Zoning Code and approved disposition and development agreement.

Design concept for affordable housing proposed at 13831 San Pablo Ave P a g e | 8

3. Development Goals
A. To sell the City-owned land to a developer (non-profit or for-profit) that is qualified, experienced, and has the capacity to undertake the design, development and management of a rental housing project.

B. To select a project with realistic timelines that is able to complete the financing and construction development timely.

C. To implement a project that adheres to all appropriate design considerations including the City of San Pablo’s planning regulations and building requirements.

D. To meet the goals and objectives of the City of San Pablo’s 2015–2023 Housing Element and 2020 Affordable Housing Strategy.

E. To minimize or leverage to the greatest extent possible the City’s financial assistance by using outside resources such as private, state, and federal programs.

F. To ensure the financial sustainability of the project by selecting a developer able to demonstrate its capacity to sustain both its own financial health as well as that of the development project.

4. Site and Parcel Overview
1820 Rumrill Blvd, San Pablo, CA 94806
411-041-009-1
½ acre site, approximately 21,750 sq ft
Northeast corner of Market Avenue and Rumrill Blvd
Vacant
Single family to east, commercial to north, south, and west Commercial Mixed Use

1.5 50 units/acre
For residential, 3 stories max
For residential, 75%
Address
APN
Size
Location
Current Site Use
Surrounding Uses
Zoning
FAR
Maximum Density
Maximum Stories
Parcel Coverage
Height
For residential, 60 feet at eave and 50 feet at roof peak P a g e | 9
Affordable Housing
Provisions
CEQA
Parking
Requirements
Transportation
Access
Density Bonuses per San Pablo Municipal Code section

17.60.020 and State Law. Streamlining available per State Law.

This site would be eligible for CEQA exemptions. No CEQA review required if the housing is developed as affordable.

For residential, two covered parking spaces for each unit per Section San Pablo Municipal Code Section 17.54.020.

Adjustments and reductions available per Section 17.54.050.

AC Transit bus lines run along Rumrill Blvd (Line 71) and along Market Ave (Line 76), both with stops at the nearby BART stations located in Richmond and El Cerrito.

5. Project Considerations
City Subsidy
If the project is developed with affordable units, the City will consider supporting the project in the form of a “construction loan.” Due to limited funding relative to affordable housing needs, the City aims to minimize the subsidy it provides to the project. Any City assistance may not be directed to operating costs.

Leveraging
If a subsidy from the City is requested, the developer must demonstrate that the funds will be leveraged to the greatest extent possible.

Environmental Conditions
The City has studied the environmental conditions of the site in 2007 and 2015. In the most recent 2015 report, SLR International Corporation conducted a Phase 1 Environmental Site Assessment (See Attachment A).

Local Contracting Requirements
Prior to solicitation of bids for construction subcontracts or for material service contracts to be performed on-site during construction, a developer is required to meet with the San Pablo Economic Development Corporation and work cooperatively to afford local businesses a reasonable opportunity to bid.

6. Submission Requirements
Cover Letter
State the name of the entity that is submitting the proposal along with current contact information. Describe the interest in the site and explain the vision for the development. Include a statement discussing the developer’s qualifications for this type of work. The letter must be signed by a principal of the firm authorized to legally bind the firm.

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Team Members Overview
Provide a description of all team members, including experience on projects with similar scope and size. Include team members that will provide the following services:
• Development/ Construction
• Financing
• Architecture/ Design
• Property Management
Financing
• Describe the proposed financing plan and provide evidence that the lead development firm has the financial capability to complete the proposed project within the proposed timeline.

Information showing the financial ability to fund pre-
development cost and equity should be provided.
• Include a completed Sources and Uses budget with potential sources of debt and equity along with a detailed breakdown of hard costs and soft costs including direct construction costs, indirect development costs, financing costs, and pre-
development costs.
• Provide a pro forma that includes at least the first five years of operation.

Project Summary
Describe the project characteristics including, but not limited to:
• Approximate residential space square footage
• Number of market-rate units by bedroom size
• Number of affordable units by bedroom size
• Approximate commercial space, if proposed
• Intended uses for commercial space
• Any special features, artistic features, landscaping, etc • Energy and water efficiency plans
• Parking spaces
• Total development cost
• Amount of subsidy requested, if any
• Marketing plan
• Resident services, if any
• Development timeline
Site Plan
Include a site plan with the unit mix, parking areas, elevations and basic diagrams depicting the building footprint on the site.

Experience
Summarize similar development experience, providing information on at least three recently completed housing projects (renovation and/or new construction) as well as visuals of those projects. Include project and client names, locations, sizes, general timeline and the development costs.

RFP Schedule
Date Issued: 08/02/21
Date Questions Due: 09/20/21
Date Due: 11/01/21
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Offer
Detail the specifics of the offer for the acquisition and development of the site.

7. Selection Process
Review
City staff will review all responses submitted by the deadline for completeness and compliance with the all requirements set forth within this RFP. Each submission will be ranked against the scoring criteria listed below.

Award
The selected candidate will be awarded an ENA for 90 days. During the ENA period, the developer and City staff will negotiate a Disposition and Developmen t Agreement containing all terms and conditions of the land transaction and developmen t of the site.

SELECTION CRITERIA
25 points Developer Experience
- Experience developing comparable projects
- Success of comparable projects, including residential and landscape design, energy and water efficiency, economic resiliency, timeliness of performance schedule 25 points Project Concept
- Overall quality and compliance with code
- Extent to which project presents realistic maximization of space and housing units 20 points Affordability
- Ability to maximize affordability of units
- Overall value and community benefits
30 points Financial Feasibility
- Adequate existing assets, ability to raise equity/debt funds - Demonstrated relationship with lenders, unless financing internally - Track record of high-quality operations and maintenance P a g e | 12

8. General Terms and Conditions
All materials submitted in response to this request will become the property of the City of San Pablo and will not be returned. Any information submitted or generated is subject to public disclosure requirements.

The City reserves the right, at its sole discretion, to:
• Waive minor irregularities in submittal requirements
• Request additional information
• Request modifications of the proposal
• Accept or reject any or all proposals received
• Extend the due date of the RFP
• Interview any or all developers
• Reject, in whole or in part, any or all proposals
• Obtain additional proposals beyond the due date if the proposals received are unsatisfactory
• Negotiate with any qualified source
• Cancel all or part of this RFP at any time prior to awards The RFP is not a contract or a commitment of any kind by the City and does not commit the City to award an exclusive development option. No reimbursement will be made by the City for any cost incurred by developers in preparation of the response to this RFP.
1820 Rumrill Blvd
San Pablo, CA
Phase I Environmental Site Assessment Report
on behalf of Bright Sky Real Estate
SLR Ref: 102.01405.00001
Attachment A
i

SIGNATURE PAGE

This document has been prepared by SLR International Corporation. The material and data in this report were prepared by Mark Trevor, P.G. under the supervision and direction of Mohammad Bazargani, Principal.

DEFINITION
I declare that, to the best of my professional knowledge and belief, I meet the definition of Environmental Professional, as defined in §312.10 of 40 CFR 312.

and

QUALIFICATIONS
I have the specific qualifications based on education, training, and experience to assess a property of the nature, history, and setting of the Site. I have developed and performed all appropriate inquiry in conformance with the standards and practices set forth in 40 CFR Part 312.

Prepared by: Reviewed by:

Site Assessor’s Name: Reviewer’s Name:

Mark Trevor, P.G.

Mohammad Bazargani

Assessor’s Title:

Reviewer’s Title:

Senior Geologist Principal

DATE: March 2015

EXECUTIVE SUMMARY
SLR International Corporation (SLR) performed an updated Phase I Environmental Site Assessment (Phase I ESA) for the property located at 1820 Rumrill Blvd. in San Pablo, CA (the Site). The Phase I ESA was performed in general conformance with the scope and limitations of ASTM Practice E 1527- 13 Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process. The assessment was conducted by Mark Trev or, P.G., a registered Professional Geologist in the State of California. This report includes information provided in the 2007 Phase I ESA prepared by AEI Consultants (AEI, 2007).

SITE DESCRIPTION

The Site is located on the east side of Rumrill Boulevard in a mixed commercial and residential area of San Pablo. The property totals approximately 0.41 acre and is currently vacant and unimproved.

Based on a review of historical sources, the Site was previously developed with a gasoline station as late as 1988. Prior to the gasoline station the Site was formerly developed with one private residence and two stores/restaurants as early as 1950, and one building and a shed as early as 1930.

The immediately surrounding properties consist of a commercial building to the north; Market Avenue to the south, beyond which is a grocery store; an apartment building to the east; and Rumrill Boulevard to the west, beyond which is a small retail center.

Based on nearby groundwater monitoring data, the direction of groundwater flow beneath the Site is to the southeast, at a depth of two to ten feet below grade (fbg), dependent on seasonal fluctuations.

PREVIOUS ASSESSMENT

Review of the previous Phase I (AEI, 2007) indi cates an existing recognized environmental condition relating to the Sites former use as a Chevron service station. As described in the AEI report:

 In 1984, existing underground storage tanks (USTs) at the former Chevron service station were replaced with new fiberglass USTs. The new USTs were installed in a new location in an area south of the former UST location. In March 1988, Chevron ceased operation of the service station and removed improvements including the USTs. The site has been vacant since that time.

 In April 1988, four groundwater monitoring wells were installed on the Site. Additionally, in 1997 eleven soil borings were advanced at the Site.

DRAFT PHASE I ESA – 1820 Rumrill Blvd., San Pablo, CA SLR International Corporation March 2015
iii
 Groundwater was monitored at the Site from 1988 until 1997. The highest concentrations of fuel constituents were detected in the northwestern area of the Site at 6,800 parts per billion (ppb) total petroleum hydrocarbons as gasoline (TPH- g), and 1,100 ppb benzene. Minimal hydrocarbons were detected during the last sampling event in 1996.

 In 1997, the Regional Water Quality Control Board (RWQCB) granted case closure to the site despite low levels of hydrocarbons remaining in soil.

 In 1998, Cambria advanced eight soil borings and collected groundwater samples from three borings at the Site in order to assess the potential human health risks associated with residual petroleum hydrocarbons beneath the site. The highest TPH-g, and benzene, toluene, ethylbenzene, and xylenes (BTEX) concentrations were detected in saturated soils at depths of 10 feet in the area of the first generation USTs and the dispenser island. No methyl tert butyl ether (MTBE) was detected in any of the soil samples. A maximum benzene concentration of 1,300 ppb was detected. Higher results for contaminants such as TPH-g and MTBE were discounted due to lab and/or sampling error.

 Cambria prepared a risk assessment to evaluate exposure potential to occupants of any future development on the Site from hydrocarbons beneath the site. Cambria evaluated the findings through statistical analysis (Tier 2) in which site specific information; including depth to groundwater, soil bulk density, porosity volumetric air and water content, and organic content; were taken into account. By introducing these factors into their model Cambria was able to determine that benzene in volatilization would fall under the site specific target level (SSTL).

In AEI’s 2007 Phase I, AEI concluded that the results of the Cambria health risk assessment based on 1997 groundwater data would be inadequate to characterize current risk at the Site.

As such, soil vapor study should be conducted to further evaluate the risk of volatilized benzene inhalation. SLR concurs with this recommendation.

REPORT SUMMARY

Report Section REC HREC CREC Data
Gap Comments
Site
Reconnaissance
Yes No No No Soil stockpiles and solvent
containers
Surrounding
Property
Reconnaissance
No No No No No
Environmental
Records Review
Yes No No Yes See data gaps section.

Historical Records
Review No No No No No
Interviews No No No No No

DRAFT PHASE I ESA – 1820 Rumrill Blvd., San Pablo, CA SLR International Corporation March 2015
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Report Section REC HREC CREC Data
Gap Comments
User-Provided
Information No No No No No
USTs No No No No No
ASTs No No No No No

CONCLUSIONS AND RECOMENDATIONS

SLR has performed a Phase I ESA of the Site located at 1820 Rumrill Blvd in San Pablo, Ca.

The Phase I ESA was performed in general conformance with the scope and limitations of ASTM Practice E 1527-13. Exceptions to, or deletions from, this practice are described in Section 5.0 of this report.

Recognized Environmental Conditions

This assessment has revealed the following recognized environmental conditions (RECs):

 Historical use of the Site as a service station resulted in hydrocarbon impacts to soil and groundwater which may currently affect shallow soil and/or soil vapor at the Site.

 The presence of potentially hazardous materials in the form of paint thinner containers was observed on Site. This material poses a threat of release to soil and groundwater or may have already released to soil and groundwater.

Historical Recognized Environmental Conditions

Historical recognized environmental conditions (HRECs) associated with this site are presence of the former USTs by Chevron, removal of the USTs and closure of the site under RWQCB.

Environmental Issues

The presence of soil, wood chip and gravel stockpiles is not likely to pose a potential threat of environmental impacts to Site soil, groundwater and/or surface water because the source of the material is known, was (reportedly) recently placed and is slated for removal in the near future.

Recommendations

Prior to Site redevelopment, SLR recommends conducting a soil vapor study within the footprint of proposed development to evaluate the potential inhalation hazard from residual benzene or other hydrocarbon impacts to soil. Additionally, a limited shallow soil sampling program should be conducted to confirm the absence of soil impacts from the buckets of paint thinner observed on Site.

DRAFT PHASE I ESA – 1820 Rumrill Blvd., San Pablo, CA SLR International Corporation March 2015
v

CONTENTS
EXECUTIVE SUMMARY .............................................................................................................. ii

1. INTRODUCTION ............................................................................................................... 1

1.1 PROJECT INFORMATION .................................................................................... 1

1.2 OBJECTIVE .......................................................................................................... 1

1.3 PURPOSE ............................................................................................................. 2

1.4 SCOPE OF WORK, SIGNIFICANT ASSUMPTIONS, TERMS AND
CONDITIONS ........................................................................................................ 2

1.5 RELIANCE ............................................................................................................ 2

1.6 USER PROVIDED INFORMATION....................................................................... 2

1.7 PRIOR PHASE I ESA OR SITE INVESTIGATION REPORTS ............................. 3

2. SITE AND SURROUNDING AREA RECONNAISSANCE ............................................... 4

2.1 METHODOLOGY .................................................................................................. 4

2.2 RESTRICTIONS .................................................................................................... 4

2.3 GENERAL DESCRIPTION .................................................................................... 4

2.3.1 SITE AND AREA DESCRIPTION .............................................................. 4

2.3.2 SITE OPERATIONS/ACTIVITIES .............................................................. 4

2.4 EXTERIOR OBSERVATIONS ............................................................................... 5

2.5 HAZARDOUS SUBSTANCES AND PETROLEUM PRODUCTS, &
OTHER WASTE MATERIALS ............................................................................... 6

2.6 UNDERGROUND STORAGE TANKS/STRUCTURES ......................................... 6

2.7 ABOVEGROUND STORAGE TANKS................................................................... 7

2.8 ADJOINING PROPERTIES ................................................................................... 7

2.8.1 CURRENT USES OF ADJOINING PROPERTIES .................................... 7

2.8.2 OBSERVED EVIDENCE OF PAST USES OF ADJOINING
PROPERTIES............................................................................................ 7

2.8.3 PITS, PONDS, OR LAGOONS ON ADJOINING PROPERTIES ............... 7

2.8.4 OBSERVED PHYSICAL SETTING ........................................................... 7

3. RECORDS REVIEW ......................................................................................................... 8

3.1 FEDERAL/STATE ENVIRONMENTAL RECORDS .............................................. 8

3.1.1 LISTINGS FOR SITE
................................................................................. 8

3.1.2 LISTINGS FOR NEARBY SITES WITH POTENTIAL TO IMPACT THE SITE................................................................................................... 8

3.2 LOCAL/REGIONAL ENVIRONMENTAL RECORDS ............................................ 9

3.3 HISTORICAL RECORDS .................................................................................... 10

3.3.1 PREVIOUS SITE INVESTIGATIONS ...................................................... 10

3.3.2 RECORDED LAND TITLE RECORDS .................................................... 11

3.3.3 AERIAL PHOTOGRAPHS ....................................................................... 11

3.3.4 CITY DIRECTORIES ............................................................................... 12

3.3.5 HISTORICAL FIRE INSURANCE (SANBORN) MAPS ........................... 12

3.3.6 HISTORICAL TOPOGRAPHIC MAPS .................................................... 13

3.3.7 OTHER HISTORICAL SOURCES ........................................................... 13

3.4 PHYSICAL SETTING .......................................................................................... 13

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4. INTERVIEWS .................................................................................................................. 14

4.1 FINDINGS FROM INTERVIEW WITH OWNER OR OWNER’S
REPRESENTATIVE ............................................................................................ 14

4.2 FINDINGS FROM INTERVIEWS WITH MAJOR OCCUPANTS ......................... 14

5. SIGNIFICANT DATA GAPS ........................................................................................... 15

6. CONCLUSIONS .............................................................................................................. 16

LIST OF APPENDICES

APPENDIX A FIGURES

APPENDIX B SITE PHOTOGRAPHS

APPENDIX C HISTORICAL SOURCES

APPENDIX D THIRD-PARTY VE NDOR DATABASE REPORT

APPENDIX E AGENCY RECORDS

APPENDIX F LIMITATIONS

DRAFT PHASE I ESA – 1820 Rumrill Blvd., San Pablo, CA SLR International Corporation March 2015
1 1. INTRODUCTION

1.1 PROJECT INFORMATION
Client (User) Information: Consultant Information:

Bright Sky Real Estate SLR International Corporation

Site Information: Project Manager:
1820 Rumrill Blvd. Name: Mohammad Bazargani
San Pablo, CA Phone: 510-451-1761
Email: [email protected]
County: Contra Costa
Lat/Long: 37.958918/-122.355970 Assessor: Mark Trevor
Environmental Professional: Mark Trevor
Inspection Date: March 10, 2015 Sr. Reviewer: Mohammad Bazargani Interview Date: March 10, 2015
Records Date: March 2015

1.2 OBJECTIVE
The objective of this Phase I ESA is to identify, to the extent feasible pur suant to the processes outlined in the scope of work, recognized environmental conditions (RECs), historical environmental conditions (HRECs), or controlled recognized environmental conditions (CRECs) as defined by the ASTM Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process, ASTM Designation E 1527-13 (ASTM E1527) for the Site.

The ASTM Practice defines a REC as:

“…the presence or likely presence of any hazardous s ubstances or petroleum products in, on, or at a property due to release to the environment; under conditions indicative of a release to the environment or under conditions that pose a material threat of future release. De minimis conditions are not recognized environmental conditions.”

The ASTM Practice defines a HREC as:

“…the past release of any hazardous substances or petroleum products that has occurred in connection with the property and has been addressed to the satisfaction of the applicable regulatory authority or meeting unrestricted use criteria established by a regulatory authority, without subjecting the property to any required controls (for example, property use restrictions, activity and use limitations, institutional controls, or engineering controls)…”

The ASTM Practice defines a CREC as:

“…a recognized environmental condition resulting fr om a past release of hazardous substances or petroleum products that has been addressed to the satisfaction of the applicable regulatory authority, with hazardous substances or petroleum products allowed to remain in place, subject to the

DRAFT PHASE I ESA – 1820 Rumrill Blvd., San Pablo, CA SLR International Corporation March 2015
2 implementation of required controls (for example, property use restrictions, activity and use limitations, institutional controls, or engineering controls).”

1.3 PURPOSE
The purpose of Phase I ESAs is typically to permit the User to satisfy one of the requirements to qualify for the innocent landowner, contiguous property owner, or bona fide prospective purchaser limitations on Comprehensive Environmental Re sponse, Compensation, and Liability Act (CERCLA) liability. This assessment constitutes all appropriate inquiries into the previous ownership and uses of the site (hereinafter referred to as the Site) consistent with good commercial or customary practice, as defined in 42 U.S.C. §9601(35)(B) of CERCLA. If RECs are identified during this assessment, there may be continuing obligations on the part of the User to maintain their CERCLA liability limitation.

1.4 SCOPE OF WORK, SIGNIFIC ANT ASSUMPTIONS, TERMS AND

CONDITIONS
The scope of work, significant assumptions, and terms and conditions applicable to this Phase I ESA are identified in the following documents:

 SLR International Corporations’ Purchase Order
 ASTM Standard Practice, Designation E 1527-13
 Statement of Limitations presented in Appendix F of this report

1.5 RELIANCE
This report was prepared for the exclusive use of the following:

o Bright Sky Real Estate

No other entity may rely on the information pres ented in the report without the express written consent of SLR International Cor poration (SLR). Any use of this Phase I ESA report constitutes acceptance of the terms and conditions under which it was prepared. SLR’s liability extends only to its client and not to any other parties who may obtain a copy of the Phase I ESA report.

1.6 USER PROVIDED INFORMATION
Prior to initiating the site reconnaissance, SLR requested the following information from the User of this ESA report:

DRAFT PHASE I ESA – 1820 Rumrill Blvd., San Pablo, CA SLR International Corporation March 2015
3 User-Provided Information Findings
Information on environmental liens on the Site: The User reported that no information related to environmental liens was noted on the title
documents.

Information on Site activity and use limitations
(AULs):

The User reported that no information related to
AULs was noted on the title documents.

Specialized knowledge or experience of the User
that is material to RECs in connection with the
Site:

The User reported no specialized knowledge or
experience that is material to RECs in
connection with the Site.

Knowledge that Site purchase/sale price is
significantly lower than market value:

Not provided
Commonly known or reasonably ascertainable
information about the Site material to RECs:

The User provided SLR with the previous Phase
I ESA performed at the site, prepared by AEI
Consultants in 2007.

Reason why the User wants to have the Phase I
ESA performed:

To identify RECs in connection with the Site.

1.7 PRIOR PHASE I ESA OR SI TE INVESTIGATION REPORTS
As part of this investigation the following reports were provided to SLR:

Phase I Environmental Site Assessment, 1820 Rumrill Blvd., San Pablo, CA 94806. Prepared for: City of San Pablo by: AEI Consultants, July 12, 2007.

As appropriate pertinent information obtained from the report is discussed throughout this report. A copy of the prior report is provided in Appendix C.

DRAFT PHASE I ESA – 1820 Rumrill Blvd., San Pablo, CA SLR International Corporation March 2015
4 2. SITE AND SURROUNDING AREA RECONNAISSANCE
SLR conducted a site visit of the property. The weat her-related conditions at the time of the site visit were foggy with a light breeze and approximately 60 degrees Fahrenheit.

2.1 METHODOLOGY
SLR utilized the following methodology to observe the Site:
 Traverse the outer Site boundary.
 Traverse transects across the Site.
 Visually observe items of potential interest.

2.2 RESTRICTIONS
Restriction Type Comments
Weather-related restrictions: None
Facility access restrictions: None
Client-related restrictions: None

2.3 GENERAL DESCRIPTION

2.3.1 SITE AND AREA DESCRIPTION
The Site located on the east side of Rumrill Boulevard in a mixed commercial and residential area and is identified as assessor’s parcel number (APN) 411-041-009.The Site is approximately 0.41 acres and is currently vacant and unimproved. Site security is provided by a chain-link fence that surrounds all open sides of the fence. At the time of the Site visit, the fence was damaged in multiple places and open to pedestrians and vehicles.

Estimated % of Site covered by
Buildings and/or pavement:
0%
Observed evidence of past Site
use(s):

None observed
Sewage disposal method: Municipal (if developed)
Electric utility: Pacific Gas & Electric (if developed) Natural Gas: Pacific Gas & Electric (if developed)
Potable Water: Municipal (if developed)

Figures presented in Appendix A show general locati on and site plan. Photographs are provided in Appendix B.

2.3.2 SITE OPERATIONS/ACTIVITIES
The Site is currently vacant and there is no authorized activity.

DRAFT PHASE I ESA – 1820 Rumrill Blvd., San Pablo, CA SLR International Corporation March 2015
5 2.4 EXTERIOR OBSERVATIONS
As there are no structures or other development s on Site, the only observations are exterior. As previously discussed, the Site is an undeveloped and unpaved lot. The surface is primarily soil and grass with some debris. Approximately 20-30 cubic yards of soil were visible during the visit, stockpiled in roughly 5 piles. A larger pile of gr avel and pile of wood cuttings were also observed.

Several 5-gallon buckets of paint thinner were observed amongst the soil stockpiles in the rear portion of the Site. The location is indicated on Figure 2.

SLR made the following observations during the si te reconnaissance activities, as described in Section 2.1:

Observation Description
Roads or paths with no apparent
outlet observed on the Site or
adjacent roadways, alleyways, or
easements:

None observed
Standing water: None observed
On-site pits, ponds, or lagoons: None observed
Stained soil or pavement: None observed
Stressed vegetation: None observed
Cuts or markings in pavement areas
or parking areas that could indicate
the former or current presence of
USTs or other buried structures:

None observed

Concrete structures that could
indicate the location of former UST
dispensers:

None observed
On-site solid waste disposal including
land filling, dumping, disturbed soils,
or direct burial activities:

Four 5-gallon metals cans of paint thinner and
miscellaneous garbage were observed. Stockpiled soil,
wood chips and gravel were also observed.

Wastewater: The facility does not generate industrial wastewater.

Stormwater drains and conveyance: None observed
Water wells including monitoring
wells:

None observed
Septic systems: None observed
Drum rings, i.e. circular depressions
in asphalt or soil that indicated the
former storage or presence of drums:

None observed
Onsite railroad tracks or spurs: None observed
Emergency generators: None observed

DRAFT PHASE I ESA – 1820 Rumrill Blvd., San Pablo, CA SLR International Corporation March 2015
6 2.5 HAZARDOUS SUBSTANCES AN D PETROLEUM PRODUCTS, &

OTHER WASTE MATERIALS
The Site contained apparently discarded buckets of industrial paint thinner. Cursory field observations indicated the containers were partially or completely empty. The Site is a vacant lot and does not use hazardous materials or petroleum products.

The table below describes the visual and/or physical observations made by SLR during the site reconnaissance, in interviews, and during the records review portions of the assessment:

Observation Description
Industrial or manufacturing operations: None
Hazardous substances and petroleum
products:

The following hazardous substances and petroleum
products were observed at the time of the Site visit:

- 4 5-gallon cans of Crown Industrial Series Paint
Thinner. An MSDS available from the internet
indicates constituents of medium aliphatic naptha
(95%) and 1, 2, 4 trimethylbenzene (5%)

No evidence of leakage from buckets was visible.

Drums (5 gallons): See above.

Strong, pungent, or noxious odors: None observed
Pools of liquid: None observed
Unidentified substance containers: None observed
Garbage and debris: Minor miscellaneous trash and debris.

PCB-containing equipment including
hydraulic lifts, elevators, and
transformers:

None observed
Oil or gas well exploration or refinery
activities:

None observed
Known or potential prolonged use,
misapplication, or storage/disposal of
pesticides/herbicides:

None observed
Discharges, migration or run-off of
potential contaminants to the Site from
an off-site source:

None observed

2.6 UNDERGROUND STORAG E TANKS/STRUCTURES
Existing USTs: None reported or observed
Former USTs:

An unknown quantity of petroleum USTs were removed in 1984 and replaced with 3 x 10,000-gallon gasoline USTs and 1 x 1,000-gallon waste oil UST. All 4 USTs were reported removed in 1988.

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7 Other Underground
Structures:

None observed or reported.

2.7 ABOVEGROUND STORAGE TANKS
Existing ASTs: None reported or observed.

Former ASTs: None reported or observed.

2.8 ADJOINING PROPERTIES

2.8.1 CURRENT USES OF ADJOINING PROPERTIES
West: Across Rumrill Blvd by commercial retail and restaurants.

East: Immediately by Residential
South: Across Market Ave by commercial retail and restaurants.

North: Immediately by commercial retail and restaurants.

2.8.2 OBSERVED EVIDENCE OF PAST USES OF ADJOINING PROPERTIES There was no obvious evidence that the past uses of adjoining properties were significantly different than current operations and uses.

2.8.3 PITS, PONDS, OR LAGOON S ON ADJOINING PROPERTIES
No pits, ponds, or lagoons were observed on adjoining properties.

2.8.4 OBSERVED PHYSICAL SETTING
Topography of the Site and
surrounding area:

The topography of the Site is relatively flat.

DRAFT PHASE I ESA – 1820 Rumrill Blvd., San Pablo, CA SLR International Corporation March 2015
8 3. RECORDS REVIEW

3.1 FEDERAL/STATE EN VIRONMENTAL RECORDS
A regulatory agency database search report was obtained from a third-party environmental database search firm, Environmental Data Resources, Inc (EDR). A complete copy of the database report, including the date the report was prepared, the date the information was last updated, and the definition of databases searched, is provided in Appendix D.

3.1.1 LISTINGS FOR SITE
The Site was listed under the following databases: CA LUST, CA HIST UST, CA SWEEPS UST, CA HIST CORTESE, CA RGA LUFT, and CA CONTRA COSTA CO SITE. Specific database listings are discussed below if determined the listing involves a potential recognized environmental condition at the Subject Site.

CA LUST – California Leaking Underground Storage Tanks

LUST records contain an inventory of reported leaking underground storage tank incidents. The Subject Site has 2 CA LUST listings:

 Chevron – Case opened in 1988, closed in 1997 (Affected media – soil)  Chevron – Case opened in 1988, closed in 1997(Affected media – groundwater)

3.1.2 LISTINGS FOR NEARBY SITES WI TH POTENTIAL TO IMPACT THE SITE The regulatory agency database report identified no nearby sites with the potential to impact the subject Site within the ASTM standard search radius.

CA LUST – California Leaking Underground Storage Tanks

Twelve sites within a ½-mile radius of the Site were identified during the LUST database search. Of the 12 LUST sites, nine are listed with a “case closed” status. One of the closed “case closed” LUST site is located adjacent and west of the Site, beyond Rumrill Boulevard and is discussed below. Of the remaining active LUST sites, all are listed as being located at a distance and/or in a topographic position which would preclude them from impacting the Site.

The Lee Property, located at 1801 Rumrill Boulevard, was the location of a service station from 1952 until 1977. In 2000, four soil borings were advanced in the area of the former service station.

Subsequent analysis of soil sample collected at the time indicated the presence of TPH-g and benzene. In 2002, AEI installed four groundwater monitoring wells to assess the extent and stability of the hydrocarbon plume. Soil, soil vapor, and groundwater samples were collected

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9 from seven borings in 2003. In 2004, three additional groundwater monitoring wells were installed at the site. The closest monitoring well to the Site was MW-2. MW-2 routinely exhibited significantly lower fuel constituent contamination than MW-1 (located directly west MW-2) which routinely had the highest concentrations. This data appeared to indicate that contamination was not moving in the direction of MW-2 (to the east). Therefore, it would appear that the Site, located at least an additional 50 feet away from the area of highest concentrations, would not likely have been impacted due to a release from this site. This site received “case closure” in 2005.

Based on regulatory status, relative distance, and/or groundwater flow direction, these LUST sites are not considered to be an environmental concern.

3.2 LOCAL/REGIONAL ENVIRONMENTAL RECORDS
SLR contacted the following sources to request information pertaining to the Site use and/or indicative of RECs in connection with the Site or adjoining properties. The files requested and/or the sources contacted were used to assist in determining if RECs exist at the Site and to document the validity of information found in the regulatory agency database search summarized above as it relates to the Site and adjoining properties.

Agency Name Finding
State Water Board
San Francisco Bay Regional
Water Quality Control Board
(SFRWQCB)
2101 Webster St.

Oakland, CA 94612
(reviewed via GeoTracker)
SLR reviewed available files for the Site and nearby sites using the SWRCB Geotracker database. Files pertaining to the Site confirmed previously documented information regarding the former Chevron service station, LUST-related activities and case closure.

No files subsequent to the 1197 Case Closure letter filed by SFRWQCB.

Contra Costa County Health Department
Contra Costa County
Environmental Health
Services
50 Douglas Drive,
Suite 310
Martinez, CA 94553
A file review at Contra Costa Environmental Health was not performed because the Site has been vacant since the closure of the Chevron station. Thus it is unlikely that files other than those pertaining to the Chevron LUST case would exist, and the LUST case is sufficiently well documented for the scope of this document.

Fire Department
Contra Costa County Fire
District (CCCFD)

SLR contacted CCCFD for information on the Site to identify any evidence of previous or current hazardous material
usage. No information regarding current or prior use or storage of hazardous materials was on file for the Site with the CCCFD.

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10 3.3 HISTORICAL RECORDS
Historical records reviewed are described below. Documentation for this section is provided in Appendix C.

3.3.1 PREVIOUS SITE INVESTIGATIONS
Full Service Station Demolition with Removal of All Above-Ground and Sub-Surface Installations - Blaine Tech Services, 1988

In 1984, existing USTs at the former Chevron service station were replaced with new fiberglass USTs.

The new USTs were installed in a new location in an area south of the former UST location. In March 1988, Chevron ceased operation of the service stati on and removed all improvements including the USTs. The USTs reportedly included three relatively new 10,000-gallon gasoline tanks and one older 1,000-gallon waste oil tank.

Groundwater Monitoring - Gettler-Ryan Inc., 1988-1996

Groundwater was monitored at the Site from 1988 until 1997. Groundwater varied from depths of two to ten feet bgs, and was shown to fluctuate seasonally. Groundwater water flow direction was routinely towards the south. The highest concentrations of fuel constituents were detected in the northwestern area of the Site at 6,800 parts per billion (ppb) total petroleum hydrocarbons as gasoline (TPH-g), and 1,100 ppb benzene. No hydrocarbons were detected during the last sampling event in 1997.

LUST Case Closure Report – RWQCB, 1997

A 1997 Case Closure letter-report prepared by RWQCB indicates that groundwater conditions were below Maximum Contaminant Levels for benzene and other dissolved hydrocarbons were low to non- detect. Low-level residual hydrocarbons remained in Site soil.

Investigation Report-Former Chevron Service Station 9-4780 - Cambria, 1998

In 1998, Cambria advanced eight soil borings and collected groundwater samples from three borings at the Site in order to assess the potential human health risks associated with residual petroleum hydrocarbons beneath the site. The highest TPH-g, and benzene, toluene, ethylbenzene, and xylenes (BTEX) concentrations were detected in saturated soils at depths of 10 feet in the area of the first generation USTs and the dispenser island. No methyl tert butyl ether (MTBE) was detected in any of the soil samples. A maximum benzene concentration of 1,300 ppb was detected. Higher results for contaminants such as TPH-g and MTBE were discounted due to lab and/or sampling error.

Risk Based Corrective Action Report-Former Chevron Service Station 9-4780 - Cambria, 1998

With the site data collected during their onsite activities, Cambria prepared a risk assessment to evaluate exposure potential to occupants of any future development on the Site from

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11 hydrocarbons beneath the site. For the purpose of their risk assessment, Cambria assumed future commercial development. Cambria considered the potential exposure pathways as dermal contact/ingestion/inhalation from surface and subsurface soils by onsite construction workers; and, inhalation of BTEX vapors volatilizing from soil and groundwater to indoor and outdoor air onsite.

Cambria based their risk assessment (Tier 1) model on maximum soil and groundwater concentrations of BTEX and MTBE. Cambria’s results indicated that volatilization of benzene from groundwater to indoor air; with a given concentration of 1,300 ppb in groundwater, would exceed published risk based screening levels. As such, Cambria then reevaluated the findings through statistical analysis (Tier 2) in which site specific information; including depth to groundwater, soil bulk density, porosity volumetric air and water content, and organic content; were taken into account. By introducing these factors into their model Cambria was able to determine that benzene in volatilization would fall under the site specific target level (SSTL).

Phase I Environmental Site Assessment Report – AEI 2007

A Phase I ESA was prepared by AEI Consultants for the Site owner, the City of San Pablo in 2007.

AEI concluded that their assessment revealed no evidence of recognized environmental conditions in connection with the property except for those associated with the Chevron UST case. AEI recommended a soil vapor study be conducted on the Site prior to redevelopment.

3.3.2 RECORDED LAND TITLE RECORDS
Land title records and deeds were not provided by the User, and public records were not searched because the historical use of the Site appeared to be sufficiently documented by other reviewed sources.

3.3.3 AERIAL PHOTOGRAPHS
Year Observations: Site and Adjoining Properties
1939 In the 1939 aerial photograph, the southwest corner of the Site is developed with a building. Rumrill Boulevard is present to the west and Market Street is present to the south. The adjacent properties to the north, east, and west are undeveloped. The property to the south is developed with a commercial building. The adjacent property to the northeast is developed with a residence.
1946 The 1946 aerial photograph differs from the previous aerial, in that a (potentially) commercial building is located on the southeast corner of the Site, and an apparently private residence is located on the northeast corner of the Site. A commercial building is located to the north. Further development is evident in the general areas south and east of the Site.
1950 No significant changes.
1958 The 1958 aerial photograph differs from the previous aerial, in that the adjacent property (beyond Rumrill Boulevard) to the west is developed with a retail complex including a service station.
1968 No significant changes.
1974 The 1974 aerial photograph differs from the previous aerial, in that the Site has been redeveloped as a gasoline station. Residential structures are present to the east. 1982 No significant changes.
1993 The 1993 aerial photograph differs from the previous aerial, in that the Site is vacant.

DRAFT PHASE I ESA – 1820 Rumrill Blvd., San Pablo, CA SLR International Corporation March 2015
12 Year Observations: Site and Adjoining Properties
The service station to the west is also no longer present. 1998,
2005,
2009,
2010,
2012
The Site and surrounding properties are developed essentially as they are today.

Aerial photographs were provided by the EDR-Aerial Photo Decade Package, EDR Inquiry No. 4224123.9, dated March 5, 2015.

3.3.4 CITY DIRECTORIES
Year Occupant Listed
1980 Joe Squellati Chevron
1985 Joe Squellati Chevron
1990 Listed as “XXXX”
1992 Address Not Listed
1995 Address Not Listed
1999 Address Not Listed
2003 Address Not Listed
2008 Address Not Listed
2013 Address Not Listed
City directories were provided by the EDR-City Directory Image Report, EDR Inquiry No. 4224123.5, dated March 5, 2015

3.3.5 HISTORICAL FIRE INSURANCE (SANBORN) MAPS
Year Observations, Site and Adjoining Properties
1930 On the 1930 Sanborn map, the Site is depicted with a structure labeled as vacant.

Additionally, there is a small shed north of the structure. The adjacent property to the north is depicted as vacant. A dwelling is depicted on an adjacent property to the east. Dwellings and stores are depicted on the adjacent property to the south, beyond Market Avenue. The area to the west is not depicted. 1950 The 1950 Sanborn map differs from the previous map, in that the building previously labeled as vacant on the Site is now labeled as a store. Additionally, a building is now depicted on the southeast corner. This building is also labeled as a store. A dwelling and two out- buildings are depicted on the northeast corner of the Site. The property to the north is depicted with a building labeled as a store. 1965 The 1965 Sanborn map differs from the previous map, in that the out buildings associated with the dwelling on the northeast corner of the Site are no longer depicted. The stores depicted on the southern extent of the subject property are now additionally labeled as restaurants. An apartment building is depicted on an adjacent property to the east.

Historical fire insurance maps were provided by the EDR-Certified Sanborn Map Report, EDR Inquiry No. 4224123.3, dated October 01, 2014

DRAFT PHASE I ESA – 1820 Rumrill Blvd., San Pablo, CA SLR International Corporation March 2015
13 3.3.6 HISTORICAL TOPOGRAPHIC MAPS
Historical topographic maps were provided by the EDR-Historical Topographic Map report, EDR Inquiry No. 4224123.4, dated March 4, 2015. A review of topographic maps from 1895 to present did not reveal any new and significant environmental information about the Site. The topographc maps are included in Appendix D.

3.3.7 OTHER HISTORICAL SOURCES
No other historical sources were consulted during the course of this investigation.

3.4 PHYSICAL SETTING
Topography: The Site is located at an elevation 35 and is generally flat.

Soil/Bedrock Data: Underlying soils are interbedded sand, silt and clay; and potentially artificial imported fill.

Estimated Depth to
Groundwater/
Direction of
Gradient:

According to a previous ESA by AEI, depth to groundwater ranges form 2-10 fbg and flows to the south. According to groundwater monitoring reports from a LUST site located approximately 100 feet to the southeast, groundwater flows to the southeast.

DRAFT PHASE I ESA – 1820 Rumrill Blvd., San Pablo, CA SLR International Corporation March 2015
14 4. INTERVIEWS

4.1 FINDINGS FROM INTERVIE W WITH OWNER OR OWNER’S

REPRESENTATIVE
Name, Organization, Years
Familiar with Site:

Ms. Sonia Rivas, City of San Pablo ( via
questionnaire)
Current Use of Site: None
Past Use(s) of Site: Unknown
Current or Past Hazardous/
Petroleum Material Use, Storage,
Disposal:

Refer to Chevron site documentation.

Past Releases of
Hazardous/Petroleum Materials
on the Property:

Refer to Chevron site documentation.

Other Environmental Information
(Permits, etc.):

4.2 FINDINGS FROM INTERVIEWS WITH MAJOR OCCUPANTS
None, no Site occupants currently exist.

DRAFT PHASE I ESA – 1820 Rumrill Blvd., San Pablo, CA SLR International Corporation March 2015
15 5. SIGNIFICANT DATA GAPS
Data gaps are a lack of or inability to obtain information required by the ASTM E1527 Practice despite good faith efforts by the environmental professional to gather such information. Data gaps may have resulted from incompleteness in any of the activities required in the Practice, including, but not limited to the site reconnaissance, records review, or interviews. The presence of a data gap may or may not present a REC due to the possibility that a REC could be discovered if the missing information is obtained.

During the performance of this assessment, the following significant data gaps were identified:

 The historic Site property owner(s) (i.e. during the service station era) could not be interviewed as no contact information was public ly available. Therefore, this constitutes a data gap. However, based on information obtained from other sources including, such as aerial photographs and Sanborn maps, this data gap is not expected to significantly alter the overall findings of this investigation.

 Review of files at Contra Costa County was not performed as the files reportedly pertain only to the closed Chevron LUST case, which has been well documented through review of the previous ESA and RWQCB files available through the Geotracker website.

As the Site has been vacant with the same owner since the since the previous file review in 2007, it is unlikely any new significant information is available.

DRAFT PHASE I ESA – 1820 Rumrill Blvd., San Pablo, CA SLR International Corporation March 2015
16 6. CONCLUSIONS
SLR has performed a Phase I ESA of the Site located at 1820 Rumrill Blvd in San Pablo, CA. The Phase I ESA was performed in general conformance with the scope and limitations of ASTM Practice E 1527-13. Exceptions to, or deletions from, this practice are described in Section 5.0 of this report.

Recognized Environmental Conditions

This assessment has revealed the following recognized environmental conditions (RECs):

 Historical use of the Site as a service station resulted in hydrocarbon impacts to soil and groundwater which may currently affect shallow soil and/or soil vapor at the Site.

 The presence of potentially hazardous materials in the form of paint thinner was observed on Site. This material poses a threat of release to soil and groundwater or may have already released to soil and groundwater. Cursory field observations suggested the cans were partially or completely empty, however, the absence of product does not provide information on the likelihood of a leak prior to the time of the Site visit.

Historical Recognized Environmental Conditions

This assessment has revealed presence of USTs associated with past use of the property as a service station. The soil and groundwater were impacted as a result of historical use. The USTs were removed and the site was granted closure by the RWQCB.

Controlled Recognized Environmental Conditions

This assessment has revealed no evidence of controlled recognized environmental conditions (CRECs).

Environmental Issues

Environmental issues include environmental concerns identified by AEI that warrant discussion but do not qualify as recognized environmental conditions, as defined by the ASTM Standard Practice E1527-05. The presence of wood chip and gravel stockpiles of unknown provenance could pose a potential threat of environmental impacts. However, the User reported to SLR that the current Site owner (the City of San Pablo) has been allowing a subcontractor (Ghillotti Brothers) to stage material at the Site for a nearby active construction project. If this information is accurate, it is unlikely that the material has had a significant environmental impact on the Site. The City has indicated the contractor will remove the soil prior to the close of property sale.

Significant Data Gaps

During the performance of this assessment, the following significant data gaps were identified:

DRAFT PHASE I ESA – 1820 Rumrill Blvd., San Pablo, CA SLR International Corporation March 2015
17 such as aerial photographs and Sanborn maps, this data gap is not expected to significantly alter the overall findings of this investigation.

De Minimis or Other Potential Issues

No potential issues and de minimus conditions were observed.

Recommendations

San Pablo City CouncilFebruary 7, 2022

San Pablo City Council
February 7, 2022