From: Sue Wild
To: City Clerk (Public)
Subject: Public Comment for Aug. 11 City Council meeting Date: Saturday, August 8, 2026 7:31:03 PM
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City Council Members,
I would like to express my concern over the lack of new schools being built in San Ramon to accommodate families moving to all the new housing. Montevideo Elementary is already impacted, and it is the closest elementary school to Camino Ramon developments and Norris Canyon (Trumark homes.) Chevron Park is slated to have 2,700 homes, and it is also directly behind Montevideo Elementary. The closest middle school to all these new homes is Iron Horse Middle School, but how many new students can it hold? Can California High School accept all the new high schoolers coming its way?
To accommodate all these prospective new students, we need more schools! It's great that the Camino Ramon development is creating new parks, but new schools are a necessity.
Please include plans for new schools in the very near future.
Sincerely,
Sue Wild
Rancho Ramon resident,
San Ramon
Item No. 4.0 Public Comment
From: Elaine Cortez Schroth
To: City Clerk (Public)
Subject: Public Comment 8/11/26
Date: Tuesday, August 11, 2026 9:34:35 AM
Attachments: GEM x Impacts.pdf
GEM Sponsor Donor Postcard_5x7.pdf
Great Elephant Migration x Livermore, CA_Sponsor & Partner Deck (1).pdf Livermore Great Elephant Migration Exhibit - Sponsorship Form (1).pdf ***| EXTERNAL EMAIL: Think before you click and do not open attachments unless you know they are safe. |***
Public Comment: 8/11/26 Item 4
Dear Mayor Armstrong and Councilmembers:
I am thrilled to share that the Great Elephant Migration is coming to the Tri-Valley this fall, October 10 through December 6, 2026, and we hope the City of San Ramon will be part of this spectacular regional experience.
The exhibit will bring 30 life-size elephant sculptures to downtown Livermore—the only West Coast stop this year. Each elephant is handcrafted by Indigenous artisans in South India, transforming an invasive plant into extraordinary works of art while creating jobs and supporting conservation.
But this isn't just a Livermore event—it’s a regional opportunity for communities like San Ramon. South Asian and Indian-American community organizations are already stepping up as sponsors and community partners, creating opportunities to celebrate Indian heritage while sharing a universal message about conservation, coexistence and our connection to wildlife, especially the magical elephant.
San Ramon is home to a vibrant and growing Indian-American community, making this an especially meaningful opportunity for cross-cultural engagement. We hope families, businesses, schools, community organizations and cultural groups from San Ramon will participate and help make the migration a true regional celebration.
Visitors from throughout California will also be staying in local hotels, dining at restaurants, shopping, and exploring communities throughout the region—including San Ramon. Previous U.S. installations have generated millions of visitor interactions, with reported increases of 52% in foot traffic and 20% in retail sales.
There will be student field trips, community events and docent tours that bring the story of Indigenous knowledge, wildlife conservation and human-animal coexistence to life.
We invite San Ramon to participate through community awareness, volunteers, business sponsorships and cross-promotional opportunities. This is an opportunity to engage families and young people, support local businesses, celebrate our diverse communities, and showcase the Tri-Valley as a destination for arts, culture, conservation and connection.
We would love to connect with the City and San Ramon community to explore how we can make this extraordinary experience benefit the entire region.
Thank you, and please visit 333arts.org/gem to learn more. --
Item No. 4.0 Public Comment
Elaine Cortez Schroth
510.604.0621
Check out what I am working on - the Great Elephant Migration! Partnerships & Community Relations
Three Thirty Three Arts
www.333arts.org
Instagram
Intro Deck
IMPACTS
Every elephant displayed in Livermore creates lasting impact for India's people, forests and wildlife.
The Great Elephant Migration is more than a public art exhibition, it is a circular conservation model that transforms an invasive weed into opportunity. Every elephant is handcrafted in South India by Indigenous artisans, creating sustainable livelihoods, restoring forests and funding conservation.
Creating India's Largest Sustainable Indigenous Enterprise For thousands of years, Indigenous communities have been the guardians of nature. Although they make up just 6% of the world's population, Indigenous peoples protect around 80% of the planet's remaining biodiversity.
The Great Elephant Migration celebrates this extraordinary stewardship by showcasing the artistry and craftsmanship of India's Indigenous communities on the world stage.
Today, the project provides meaningful employment, financial stability, status and pride to members of the Soligas, Bettakurumbas, Kattunayakan and Paniyas tribes, communities that have lived alongside wild elephants for generations.
Impact to date:
• Over $1.5 million collectively earned through the creation of sculptures for exhibitions in USA • Employment created for 300+ Indigenous artisans, with workshops operating across 15+ villages. • Long-term ambition to create up to 1,000 Indigenous jobs by 2030, building India's largest sustainable Indigenous enterprise.
Restoring India's Forests
Every elephant is woven from Lantana camara, one of the world's most destructive invasive plant species.
Lantana has invaded an estimated 300,000 km² of India's Protected Areas, reducing habitat for elephants, tigers and countless other native species. By harvesting lantana and transforming it into art, the project removes this invasive weed while creating income for local communities.
Impact to date:
• 200+ hectares of lantana-infested forest restored since 2024. • Native vegetation and wildlife habitat are being reclaimed across South India's protected landscapes.
Climate Action
The project also supports a large-scale biochar initiative.
Harvested lantana is converted into biochar, permanently storing carbon while improving soil health.
Goals include:
• Sequestering 50,000 tons of carbon by 2030.
• Creating up to 1,000 green jobs across India's protected landscapes. • By the end of 2025, an estimated 2,625 tons of carbon will have been sequestered—far exceeding the carbon footprint of creating and transporting the exhibition.
Supporting Conservation
The impact extends well beyond the exhibition itself.
Sales of the sculptures generate funding for human-wildlife coexistence projects in India and around the world. • More than $1 million in grants has already been distributed to conservation partners. • Each elephant is paired with a conservation organization working to help people and wildlife thrive together.
Oct 10 - Dec 6, 2026
LIVERMORE
CALIFORNIA
THE GREAT ELEPHANT
MIGRATION IS COMING
TO THE BAY AREA!
Scan the QR code to support the exhibit and learn
more, or visit www.333Arts.org/gem
The Great Elephant Migration, a global public art
exhibition coming to the Bay Area for the first time and its only stop on the West Coast this year, is bringing 30 life-size elephant sculptures to Downtown Livermore
from October 10th through December 6th, 2026.
The immersive, free exhibit invites visitors into an
open-air gallery designed to spark conversation
around human-wildlife coexistence.
The exhibition is expected to draw thousands of
visitors, boosting local foot traffic while spotlighting the Tri-Valley’s role as a leader in culture, science, and environmental advocacy.
Facilitated by Elephant Family USA, with SF Bay Area
arts organizations Livermore Valley Arts and
Three Thirty-Three Arts.
We need your support!
Donors and sponsors are needed to help us fund
exhibit costs and programming, making it possible for
the exhibit to be free and accessible to all.
“The Great Elephant Migration is more than an art installation, it’s a powerful sign of unity, connecting us to the stories of wildlife and reminding us of our joint responsibility to protect our planet and wildlife. We’re proud to host this meaningful exhibition that illuminates our city’s values of environmental stewardship, cultural appreciation, and community connection. It will bring wonder, awareness, and a sense of meaning to our city.”
Sharona Nazarian, Mayor, Beverly Hills
THE GREAT ELEPHANT MIGRATION
THE GREAT ELEPHANT
MIGRATION
The Great Elephant Migration is a large-scale
environmentally positive art exhibition featuring a
herd of life-size elephants, undertaking a global
journey to amplify Indigenous knowledge and
inspire the human race,
to share space.
In 2024 and 2025, the 100-strong herd migrated across the US with installations in Newport, Rhode Island; Meatpacking District, NYC; Miami Beach, Art Basel; Houston, Texas;
Jackson Hole, Wyoming; and Beverly Hills, CA.
Their journey is raising millions to support human-wildlife coexistence projects and protect migratory animals
making spectacular journeys across land, rivers,
skies and oceans
THE MISSION
THE MISSION
ART AS A CATALYST FOR COEXISTENCE
The Migration is a platform dedicated to:
• Preserving Coexistence - In d i ge no us-l ed ent erp rise a n d circular sy s te m s.
Our partnership with The Real Elephant Collective is an enterprise model that ties livelihoods, culture and ecological restoration together – from elephant-making workshops to large-scale lantana removal and, in time, biochar and carbon sequestration.
• Promoting Coexistence -Ani mist ic worldvi ew – r econ n ect in g p e op l e to a living world.
Drawing on Indigenous traditions that see rivers, forests, animals and even the wind as relatives, not resources. The Great Elephant Migration is a reminder that other beings have agency, personality and wisdom. Humans are part of, not apart from, nature.
• Powering Coexistence - S t or y-p owe r ed co ex i st e n ce i mpa ct.
The Migration raises significant funds for coexistence projects around the world – supporting successful programs that allow people to live alongside lions, bears, buffalo, jaguars, tigers and more. But the deeper impact is narrative: making coexistence emotionally understandable and aspirational to millions of people who encounter the elephants in cities, in the media and online.
Created in partnership with local communities and global voices, the exhibition transforms city streets, parks and public spaces into powerful spaces for dialogue, empathy and action. It inspires connection between urban audiences and the wildlife with which we share our planet.
PROMOTING COEXISTENCE
PROMOTING COEXISTENCE
HIGHLIGHTS FROM THE U.S. MIGRATION
From Newport to NYC, Miami, Houston and Beverly Hills,
the herd has attracted millions of visitors from far and wide, driving record-breaking footfall, boosting tourism, uplifting local businesses and inspiring meaningful public engagement at every stop.
IMPACTS:
• 4 million people engaged at street level
• Average footfall increased by 52% in exhibition
locations during elephant exhibition period
• 20%uplift in sales for surrounding businesses.
• Weekly school and youth group visits to the herd
• 250+ students participated in online classrooms in
partnership with Think Elephants International
ROMOTING COEXISTENCE
PROMOTING COEXISTENCE
PUBLICITY & CULTURAL REACH
Since launching in July 2024, The Great Elephant
Migration has garnered over 700 features across
broadcast, print and online media.
Media reach to date: 7billion+
HIGHLIGHTS:
• 2xNew York Times front pages
• Broadcast coverage on major national news
networks:
- CNN
- ABC7
- MSNBC
• Full feature stories in high-profile publications
including:
- Forbes
- Vogue US
• Featured on Kelly Clarkson Show
POWERING COEXISTENCE
POWERING COEXISTENCE
The Great Elephant Migration supports remarkable
people around the world who have found ways to live
alongside lions, leopards, elephants, and some of the
planet’s most challenging animals, in their back yards.
Each elephant is paired with a different conservation
NGO from across many different geographies and
species. (Insert amount given in grants in 2024/25)
The exhibit also encourages conservation groups to
incorporate Indigenous knowledge and evolve to be
Indigenous led.
NGO Partnerships
NGO Partnerships
HM Que en Camilla
IG reach - 1.6m
Che r
IG reach - 3m
Kristin Davis
IG reach - 1.4m
Chris Martin
IG reach - 29m
Kris Tompkins
IG reach - 65k
Wallis Anne nberg
IG reach - 100k
NOTABLE SUPPORTERS
NOTABLE SUPPORTERS
122 million combined Instagram followers.
Supporters include:
Martha Stewart Am y Jackson Neil Patrick Harris Dr Jane Goodall Carolina Herrera Pa dm a Lakshmi Joy Crookes IG reach - 5.4m IG reach - 13.6m IG reach - 9m IG reach - 1.3m IG reach - 7.6m IG reach - 1.8m IG reach - 33 0k Le onardo DiCaprio
IG reach - 60m
Newport, RI
Meatpacking, NYC
Miami Beach, FL
Beverly Hills, CA
The Wallis Annenberg Wildlife Crossing, CA
THE GREAT ELEPHANT MIGRATION
REACHES LIVERMORE, CA
WHEN:
October 10 through December 6, 2026
WHERE:
Downtown Livermore
Its only stop on the West Coast in 2026
30 elephants from the spectacular Great Elephant Migration exhibit will arrive in Downtown Livermore this Fall!
LIVERMORE EXHIBIT ORGANIZERS
Livermore Valley Arts is an
independent 501(c)(3), non-profit
organization that operates two
spaces: the Bankhead Theater
and the Bothwell Arts Center.
The Mission of Livermore Valley
Arts is to offer a broad range of
arts opportunities and
experiences to engage, enrich,
and inspire our diverse
community.
Local Edition Creative is a
strategic arts agency with a focus
on public art consulting, program
development & management,
and engaging experiences. Their
team is passionate about
developing projects that engage
audiences in inspiring and
insightful ways - utilizing the
power of art to build bridges and
understanding.
Three Thirty-Three Arts is a San
Francisco Bay Area 501(c)(3)
non-profit affiliated with Local
Edition Creative that specializes
in community murals, public art
education, participatory arts
programming, and arts advocacy.
The mission of Three Thirty-Three
Arts is to brighten communities
through creative collaborations
and inclusive arts experiences.
SUPPORTERS OF THE EXHIBIT
(and the herd is quickly growing!)
✴ City of Livermore
✴ Livermore Commission for the Arts
✴ Visit Tri-Valley / Tracy Farhad
✴ Livermore Downtown, Inc.
✴ District 1 Supervisor / David Haubert
✴ Office of District 16 Assemblymember Rebecca Bauer-Kahan ✴ Tri-Valley Nonprofit Association
✴ Lawrence Livermore National Laboratory / Senior Advisor Scott Wilson ✴ Quest Science Center / CEO Monya Lane
✴ Livermore Winegrowers Association
✴ Livermore Lion’s Club
✴ Rotary Club of Livermore
✴ Rotary Club of Livermore Valley
✴ Three Valleys Community Foundation
✴ Pedrozzi Scholarship Foundation / Maggie Tufts
✴ Innovation Tri-Valley Leadership Group / Katie Marcel ✴ I-GATE / Yolanda Fintschenko
✴ Livermore Valley Chamber / Sherri Souza
✴ Community Advocate Mony Nop
“SO EXCITING!” “This will be fun to see in Downtown”
“Please let me know how we
can support this event”
“I would love to visit with our Fall interns”
“OMG!!! This is so cool!”
“This will be HUGE!”
EXHIBIT DISPLAY AREAS*
Bankhead Plaza
Corner of the Bankhead Theater @ Railroad Ave.
Stockmen’s Park
Livermorium
* Exhibit display areas within Downtown Livermore are coordinated with and approved by the City of Livermore and may be subject to change The elephants will be
displayed across 4 areas,
within close proximity
and walkable distance of
each location
‣ Introduces Livermore, CA to the exhibit’s high-profile national and global following ‣ Strong potential to draw tourism across the entire Bay Area and beyond ‣ Creates a meaningful and highly memorable economic impact for the community ‣ Engagement opportunity with local schools and youth for educational field trips ‣ Showcases conservation efforts around the world and the importance of storytelling through public art
‣ The exhibit will be free and accessible to all!
WHY THIS PUBLIC ART EXHIBIT?
“OMG!!! This is so cool!! I was in Beverly Hills last year as a drive by in the area and it was spectacular just what I saw from the car. This will be HUGE!!” - Michelle Henry, District Director AD 16 Thank You for your Support!
For Sponsorship inquiries, contact:
Elaine Cortez Schroth
Partnerships & Community Relations
Three Thirty-Three Arts
[email protected]
Anne Giancola
Visual Arts & Education Manager
Livermore Valley Arts
[email protected]
The Great Elephant Migration - Livermore, CA
SPONSORSHIP LEVELS & BENEFITS
Presenting - $50,000
• Recognition as Presenting Sponsor in all communications, signage, and promotional materials
• Recognition in the exhibit press release
• Option to receive an elephant for temporary public display at your business location during the exhibition (conditions apply) • Livermore Valley Arts Annual Membership - Impresario
• 2026 Livermore ArtWalk - Table & booth
• Name displayed with an elephant at the exhibit
• 6 tickets to any Bankhead Presents show
• 6 tickets to the exhibit’s VIP Reception
• Recognition in exhibit materials & social media, logo on the Livermore exhibit webpage
Champion - $25,000
• Recognition in the exhibit press release
• Livermore Valley Arts Annual Membership - Virtuoso
• 2026 Livermore ArtWalk - Table
• Name displayed with an elephant
• 4 tickets to any Bankhead Presents show
• 4 tickets to the exhibit’s VIP Reception
• Recognition in exhibit materials & social media, logo on the Livermore exhibit webpage
Partner - $10,000
• Livermore Valley Arts Annual Membership - Maestro
• 2026 Livermore ArtWalk - Table or booth
• Name displayed with an elephant at the exhibit
• 2 tickets to any Bankhead Presents show
• 2 tickets to the exhibit’s VIP Reception
• Recognition in exhibit materials & social media, logo on the Livermore exhibit webpage
Patron - $5,000
• Livermore Valley Arts Annual Membership - Artiste
• 2026 Livermore ArtWalk - Collateral at LVA booth
• Name displayed with an elephant at the exhibit
• 2 tickets to the exhibit’s VIP Reception
• Recognition in exhibit materials & social media, logo on the Livermore exhibit webpage
Advocate - $2,500
• 2 ticket to the exhibit’s VIP Reception
• Recognition in exhibit materials & social media, logo on the Livermore exhibit webpage
Friend - $1,500
• 1 ticket to the exhibit’s VIP Reception
• Logo on the Livermore exhibit webpage
The Great Elephant Migration - Livermore, CA
SPONSORSHIP LEVELS & BENEFITS
PRESENTING
SPONSOR CHAMPION PARTNER PATRON ADVOCATE FRIEND
Recognition as Presenting Sponsor in all communications, signage, and promotional materials
(Deadline for inclusion on printed materials is September 1st) Option to receive an elephant for temporary public display at your business location during the exhibition (conditions apply) Recognition in the exhibit press release
(Deadline August 15th)
Tickets to any Bankhead Presents show 6 4 2
Livermore Valley Arts Annual Membership IMPRESARIO VIRTUOSO MAESTRO ARTISTE Name displayed with an elephant
(Deadline September 1st)
2026 Livermore ArtWalk Presence TABLE & BOOTH TABLE TABLE or BOOTH COLLATERAL AT
LVA BOOTH
Recognition in exhibit marketing materials and social media (Deadline for inclusion on printed materials is September 1st) Tickets to exhibit VIP reception 6 4 2 2 2 1
Logo on Livermore exhibit webpage
Sponsorship Fee $50,000 $25,000 $10,000 $5,000 $2,500 $1,500
SPONSOR COMMITMENT FORM
Name: ______________________________________________
Company/Organization: _____________________________
Address: ___________________________________________
Phone: _____________________________________________
Email: _____________________________________________
I would like to sponsor the Livermore Great Elephant
Migration exhibition:
$50,000 Presenting Sponsor
$25,000 Champion
$10,000 Partner
Payment Information:
Please contact me (us) to arrange payment
I will send a check payable to Livermore Valley Arts
Mail check to:
2400 First Street
Livermore, CA 94550
On the memo line, include: Sponsorship for GEM Exhibit
All contributions to Livermore Valley Performing Arts
Center, a 501(c)(3) organization, are tax deductible to the extent allowed by law. Sponsorship of The Livermore Great Elephant Migration exhibit will fund exhibition costs and associated programming. Funds raised beyond exhibition
expenses will support future public art programming.
Sponsor payment and logo must be received no later than 9/01/26 for recognition in printed materials For Sponsorship inquiries, please contact:
Elaine Cortez Schroth
Partnerships & Community Relations
Three Thirty-Three Arts
(510) 604-0621
[email protected]
Anne Giancola
Visual Arts & Education Manager
Livermore Valley Arts
[email protected]
Signature: __________________________
Date: _____________________________
The Livermore Great Elephant Migration Exhibit is
facilitated by Livermore Valley Arts and Three ThirtyThree Arts, in collaboration with Elephant Family USA.
Scan the QR code to
learn more, or visit
www.333Arts.org/gem
$5,000 Patron
$2,500 Advocate
$1,500 Friend
From: Reflections 285
To: City Clerk (Public)
Subject: Public Comment – August 11, 2026 City Council Meeting – Marketplace Demolition / DP 2022-0007 Date: Tuesday, August 11, 2026 4:26:49 PM
Attachments: apple-touch-icon-180x180.png
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Dear City Clerk,
I am writing in advance of tonight’s August 11, 2026 City Council meeting regarding the active Marketplace demolition at 130 Market Place (DP 2022-0007).
Today, I posted a series of questions on the City of San Ramon’s official Nextdoor page concerning the City’s oversight of the active demolition, including questions regarding demolition conditions, debris containment, dust-control measures, construction hours, inspections, and pre-demolition documentation.
Those questions are not exhaustive. I have several additional questions regarding the City’s approval, permitting, inspection, monitoring, and enforcement of this project that I intend to raise through the appropriate channels.
I am requesting that my questions be provided to the Mayor and all members of the City Council and that this correspondence be included as part of the public record for tonight’s meeting.
I would also appreciate clarification regarding which City department and responsible official should receive my remaining technical and project-compliance questions, so they can be answered by the appropriate City personnel.
Thank you
San Ramon resident
For clarity: I am exercising my right to free
speech and to petition my local
government.
nextdoor.com
Item No. 4.0 Public Comment
Regina S.
2h·Bishop Ranch
Question for the City of San Ramon regarding the active Marketplace demolition at 130 Market Place (DP 2022-0007): These photographs show the condition in which portions of the demolition site were left after work had ended for the day, including substantial demolition debris extending above the perimeter screening. Does the condition shown here comply with the City-approved demolition plan, permit requirements, and Conditions of Approval for DP 2022-0007? Specifically, what City requirements govern the height, location, containment, and overnight storage of demolition debris at this project? If this condition is compliant, please identify the applicable City-approved requirement or standard. If it is not compliant, please explain what corrective action is required. I would also like to know which City department is currently responsible for inspecting and enforcing these requirements during active demolition
Reply
Regina S.
2h·Bishop Ranch
For clarity: I am exercising my right to free speech and to petition my local government. I will be posting questions, photographs, and videos concerning the Marketplace project and requesting factual responses from the City of San Ramon. My posts reflect conditions I personally observed and documented I live less than 80 feet away from the demolition site.
Reply
Regina S.
1h·Bishop Ranch
Question for the City of San Ramon: I provided the San Ramon Police Department with video evidence, including visible date/time metadata, documenting demolition-related activity at the Marketplace project between approximately 6:00 a.m. and 7:00 a.m. on August 4, 5, and 6, 2026. Did the City determine that any of this activity violated applicable construction-hour requirements, and were any citations, warnings, notices of violation, or other enforcement actions issued? If so, I am requesting copies of those records, including the date of each violation, the entity cited or notified, and the applicable code or permit condition.
Reply
Regina S.
1h·Bishop Ranch
Question for the City of San Ramon regarding the active Marketplace demolition (DP 2022- 0007): Active demolition, debris processing, and truck loading are occurring in close proximity to occupied residential properties Bridges Apartments and Reflections’s Condominium and La Petite Academy at 1001 Market Place, a childcare facility. What specific dust-control, containment, monitoring, and mitigation measures did the City require for demolition occurring this close to occupied residences and a childcare facility? Specifically: • Did the City’s review of the demolition plan consider the proximity of the childcare facility and neighboring residences? • What dust-suppression measures are required while structures and demolition debris are being demolished, processed, moved, and loaded into trucks? • Is dust or particulate monitoring required at the project perimeter or near neighboring properties? If so, where is monitoring occurring, who reviews the results, and are those results available to the public? • When visible airborne material is generated during demolition or debris loading, how does the City determine whether it is adequately controlled and whether material is leaving the project site? • Has a City inspector observed this project while active demolition and debris loading were occurring, and if so, on what dates? • What conditions would require additional dust-control measures or a temporary suspension of demolition activity? • Which City department or official is currently responsible for verifying compliance during active demolition? Please identify the applicable Conditions of Approval, demolition-plan requirements, permit conditions, or City standards supporting the City’s response Reply
Regina S.
1h·Bishop Ranch
PUBLIC RECORD / COMPLIANCE QUESTION — 130 MARKET PLACE, DP 2022-0007 Before demolition of a regulated facility, the owner/operator is responsible for ensuring the affected structure is thoroughly surveyed for asbestos-containing material in accordance with Bay Area Air District Regulation 11, Rule 2, including appropriate sampling and laboratory analysis of suspect materials. The City of San Ramon’s public Marketplace project page contains extensive approval and project documentation. However, I have been unable to locate the pre-demolition asbestos survey or its laboratory analytical results among the publicly posted project documents. Accordingly, I am requesting that the City answer the following: Did the City receive, review, possess, or rely upon the predemolition asbestos survey for 130 Market Place before demolition proceeded? If yes, please identify the date of the survey, the certified individual or firm that performed it, the date the City received it, and the City department or official that reviewed or retained it.
Please also identify whether the survey documented asbestos-containing material (ACM), where any ACM was located, and what documentation demonstrates its disposition before demolition of the affected portions of the structures. If the City possesses the survey and laboratory results, why are those records not included with the demolition/project documents presently available on the City’s Marketplace webpage, and where may members of the public obtain the complete records? To be clear, I am not asserting that asbestos was present or that any violation occurred. I am asking the City to produce or identify the underlying records so the public does not have to speculate. Given that active demolition is occurring near occupied residences and a childcare facility, I believe these are reasonable questions concerning the City’s demolition oversight and the public record.
Reply
Regina S.
1h·Bishop Ranch
HAZARDOUS MATERIALS / PRE-DEMOLITION COMPLIANCE QUESTION — 130 MARKET PLACE, DP 2022-0007 In addition to asbestos, what pre-demolition hazardous-materials surveys, assessments, inventories, sampling, or laboratory testing were performed for the structures being demolished at 130 Market Place? Specifically, did the pre-demolition assessment evaluate potential lead-containing materials, mercury-containing equipment or lamps, PCBs or PCB-containing electrical equipment/materials, refrigerants, universal waste, batteries, fluorescent lighting components, chemicals, contaminated building materials, or other regulated hazardous materials or wastes? What materials were actually identified? For each material identified, what documentation establishes whether it was removed, abated, segregated, transported, recycled, or otherwise properly managed before or during demolition? Did the City receive or retain any hazardous-material survey, hazardous-building-material assessment, laboratory analytical results, abatement reports, clearance documentation, waste manifests, disposal records, or certifications associated with this demolition? If so, where are these records available to the public, and why are they not included among the documents currently available on the City’s Marketplace project webpage? Finally, which City department or official was responsible for reviewing the hazardous-material documentation applicable to the demolition permit, and what documentation did that official actually review before demolition was authorized to proceed? I am not alleging that any particular hazardous material was present or improperly handled. I am asking the City to identify the underlying records and explain the compliance process applicable to this demolition.
Reply
Regina S.
22m·Bishop Ranch
Question for the City of San Ramon — Condition of Approval No. 25 / DP 2022-0007 The July 23, 2026 Notice of Upcoming Demolition Activity expressly states that it was provided “in accordance with the City of San Ramon Condition of Approval No. 25 (COA 25)” and that recipients received the notice because their properties were located within 500 feet of 130 Market Place. The City Council’s final approval of this project was through Resolution No. 2023-029, which approved DP 2022-0007 with modified Conditions of Approval. Can the City please provide the complete, final text of Condition of Approval No. 25 as adopted by the City Council and identify where the complete final Conditions of Approval for DP 2022-0007 are publicly available? I would specifically like clarification regarding what COA 25 requires of the property owner/developer, what obligations apply to residents within the 500-foot notification area, and which City department is responsible for monitoring and enforcing compliance with COA 25 during demolition. Additionally, does COA 25 require the designated Noise Disturbance Coordinator to receive concerns involving dust, vibration, debris or other construction impacts, or is that position limited exclusively to noise complaints?
Reply
Regina S.
15m·Bishop Ranch
Question for the City of San Ramon — Resident Health Concerns / Marketplace Demolition Who should residents living within 500 feet of the Marketplace demolition contact if they and/or their pets are experiencing medical symptoms during the demolition period? Please identify the specific City department or responsible official to whom these concerns should be formally reported. Additionally, what information does the City require from residents in order to document, investigate, and respond to these reports? Please also clarify the City’s process for addressing multiple reports of similar symptoms from residents and/or pets living in close proximity to the demolition site.
Reply
From: Brian Swanson
To: City Clerk (Public); City Council
Cc: Planning Services (public); Planning Services (public); Engineering Services (public); Finance; Transportation Services (public); Transportation Services (public)
Subject: Public Comment: Agenda Item 9.1 - Resolution No. 2026-109 - Authorizing the Mayor to Execute a MOU Between the City of San Ramon and Participating Agencies for the I-680 Corridor Coordinated Adaptive Ramp Metering (CARM) Project - CC Meeting - 08.11.2026
Date: Tuesday, August 11, 2026 12:25:48 PM
Attachments: 07.14.2026 - PC - 07.13.2026 SRCityCouncilMtg Agenda Item 5.5 - Inadequate CEQA Exemption Record for HUD CPD CommunityFundingProjectGrant.pdf
05.20.2026 - INADEQUATE NoticeofExemption - CoCoCounty - SanRamon ITS and Communications Infrastructure Project (HEROS Number-900000010520833 and Grant Number-B-24-CP-CA-0165).pdf ***| EXTERNAL EMAIL: Think before you click and do not open attachments unless you know they are safe. |***
Attachments:
1. 07.14.2026 - PC -
07.13.2026_SRCityCouncilMtg_Agenda Item 5.5 -
Inadequate CEQA Exemption Record for HUD CPD
CommunityFundingProjectGrant.pdf; and
2. 05.20.2026 - INADEQUATE NoticeofExemption -
CoCoCounty - SanRamon ITS and Communications
Infrastructure Project.pdf
U.S. Department of Housing and Urban Development (HUD), Community Planning and Development (CPD) Community
Project Funding (CPF) Grant
(Grant Number: B-24-CP-CA-0165 and HEROS Number:
900000010520833)
Dear City Council:
Please accept this written public comment for the City of San Ramon City Council regular meeting of August 11, 2026, Agenda Item 9.1, Resolution No. 2026-109, concerning the proposed Memorandum of Understanding between the City of San Ramon and participating agencies for the Interstate 680 (I-680) Corridor Coordinated Adaptive Ramp Metering (CARM) Project. Please provide this comment to the City Council, include it in the administrative record, place it in the red binder or equivalent public comment file, and post it online under the August 11, 2026 meeting date consistent with the agenda's written comment instructions. The agenda states that written comments submitted by email with "Public Comment" and the corresponding agenda item number in the subject line will be Item No. 9.1 Public Comment
provided to the City Council and posted online under the meeting date if received before the stated cutoff.
I submit this comment because Agenda Item 9.1 is not a harmless administrative housekeeping item. The staff report asks the City Council to adopt Resolution No. 2026- 109, authorizing the Mayor to execute a Memorandum of Understanding (MOU) for the I680 CARM Project. The project framework involves the California Department of Transportation (Caltrans), the Contra Costa Transportation Authority (CCTA), the State Highway Operation and Protection Program (SHOPP), Adaptive Ramp Metering (ARM), CARM, Traffic Operation Systems (TOS), Intelligent Transportation Systems (ITS), fiber optic infrastructure, ramp widening, high-occupancy vehicle (HOV) preferential lane treatments, local arterial protections, emergency override procedures, performance monitoring, data sharing, public outreach, future operating procedures, and future funding decisions.
San Ramon should participate in corridor governance. The City should have a seat at the table. But participation should not be confused with unconditional concurrence in an incomplete environmental, operational, construction impact, public outreach, or public disclosure record. I respectfully request that the City Council either continue Agenda Item
9.1 or revise Resolution No. 2026-109 before adoption to include express reservations and conditions. At minimum, the resolution should state that the City's execution of the MOU does not constitute City concurrence that Caltrans' or CCTA's California Environmental Quality Act (CEQA), National Environmental Policy Act (NEPA), vehicle miles traveled (VMT), Senate Bill 743 (SB 743), Climate Action Plan (CAP), greenhouse gas (GHG), public outreach, construction impact, shoulder closure, emergency access, induced travel, project segmentation, or cumulative impact analysis is adequate for the corridor work as actually designed, staged, funded, constructed, optimized, and operated.
The problem is not simply that the staff report reaches a policy conclusion. The problem is that the record before the City Council does not demonstrate that the City has understood, applied, or reconciled the transportation and environmental review principles that govern this discretionary action. The packet does not include an item-specific CEQA determination. It does not identify the applicable Caltrans or CCTA CEQA or NEPA document. It does not analyze induced travel demand, VMT, SB 743, delay, algorithmic traffic flow optimization, construction traffic, shoulder closures, emergency access, construction GHG emissions, CAP consistency, CEQA GHG Emissions Thresholds and Guidance Report consistency, fiscal and administrative impacts, public outreach, or cumulative impacts. It also does not reconcile the MOU with the City's own General Plan 2040, General Plan 2040 Environmental Impact Report (EIR), adopted mitigation measures, updated CAP, or CEQA GHG Emissions Thresholds and Guidance Report on either a project-specific or cumulative basis. The City's General Plan update page identifies Resolution No. 2023-132 as adopting CEQA findings and a Statement of Overriding Considerations, certifying the General Plan 2040 EIR, and adopting the Mitigation Monitoring and Reporting Program. (San Ramon) The City's CAP page states that on June 10, 2025, the City Council adopted Resolution No. 2025-073, adopting an updated CAP and CEQA GHG Emissions Thresholds and Guidance Report, effective immediately and replacing the 2011 CAP. (San Ramon)
The City Council's duty is not merely to accept staff's conclusion that the MOU is useful or that the City should have a seat at the table. The City Council must ensure that an adequate administrative record supports its discretionary approval and that the City does not approve, ratify, or appear to concur in a corridor implementation framework that has not been shown to comply with CEQA and has not identified the applicable NEPA documentation for federally assisted corridor components.
I. San Ramon should participate in the MOU process, but only with express safeguards
The staff report states that if the MOU is not executed, San Ramon cannot participate in the I-680 Ramp Metering Technical Committee (RMTC) or the I-680 Ramp Metering Working Group (RMWG), and decisions affecting San Ramon could be made without City staff involvement. I agree that San Ramon should not surrender its seat at the table.
However, participation is not the same thing as environmental concurrence. The staff report describes the City Council's role as authorizing execution of the MOU. Still, the proposed resolution states that the Mayor is authorized to execute the MOU "for the installation and operation of the SHOPP and CARM ramp metering projects along I-680 in San Ramon." That language is broader than simple governance participation. It should be revised.
The MOU itself says it summarizes goals, policies, processes, and procedures for coordinated ramp metering, identifies responsibilities regarding ownership, operations, and maintenance of equipment installed as part of both the Innovate 680 CARM Pilot Project and the Caltrans I-680 Ramp Metering SHOPP Project, and serves as a foundation for how future ramp meters will be operated. The same section also says the MOU is "non-legally binding." That creates an important public record issue: a document described as nonbinding is being used as the governance foundation for installed and future operational infrastructure. The City should therefore state expressly that approval is limited to participation in governance and does not ratify the adequacy of any environmental document, traffic handling plan, construction staging plan, public outreach record, or public notice record prepared by Caltrans or CCTA.
II. The "non-legally binding" label does not eliminate the need for an item-specific CEQA determination
The staff report states that the MOU is a non-legally binding document. Still, it also says the MOU addresses governance, operations, local arterial protections, performance metrics, incident response and emergency override, reporting, financial obligations, and data sharing. The nonbinding label may affect how the parties enforce the MOU against each other, but it does not automatically remove the City Council's action from CEQA review.
The City Council is still being asked to take a discretionary public agency action: adopt Resolution No. 2026-109 and authorize the Mayor to execute the MOU. The Council may approve, reject, continue, condition, or revise the resolution. That is not a ministerial action performed under fixed standards. CEQA Guidelines section 15378 defines a "project" as the whole of an action with the potential for direct physical change or reasonably foreseeable indirect physical change in the environment. (Legal Information Institute) The agenda contains only a generic statement that, unless otherwise stated, every item on the agenda is exempt from CEQA Guidelines sections 15060(c), 15061(b)(3), 15273, 15378, 15301, 15323 and/or Public Resources Code section 21065. That generic agenda language is not an item-specific CEQA finding for Agenda Item 9.1. The staff report does not identify a City CEQA determination. The proposed resolution does not contain a CEQA finding. The packet does not attach or cite any Caltrans or CCTA CEQA exemption, NEPA categorical exclusion, NEPA revalidation, environmental certification, or environmental commitment record. The attachment list includes only Resolution No. 2026-109 and the MOU.
The City may ultimately contend that its approval is limited to governance participation, that the action is not a CEQA project, that the action is exempt, or that it is relying on environmental review prepared by Caltrans or CCTA. But the City must say so in the record. It should not rely on a generic agenda statement when the resolution is written to authorize execution of an MOU for "installation and operation" of corridor ramp metering projects in San Ramon.
III. NEPA remains relevant because the corridor work has a federal funding and federal aid transportation nexus
The City does not ordinarily make the federal NEPA determination itself. NEPA applies to federal actions and federally assisted project components. However, NEPA remains relevant here because the MOU concerns federal aid transportation work administered through Caltrans and CCTA.
The MOU states that ramp metering on I-680 will be implemented and managed by Caltrans and CCTA, that SHOPP provides funding for the Caltrans-implemented segment, and that the capital construction, ramp meter system, and initial three years of initialization costs for the CARM segments are funded by federal, state, and local funds managed by CCTA. The MOU also states that CCTA improvements will be constructed under a Caltrans encroachment permit.
Caltrans has been assigned federal environmental responsibilities for many highway projects. Caltrans states that the Federal Highway Administration (FHWA) renewed Caltrans' 23 U.S.C. section 327 NEPA Assignment MOU on May 27, 2022, for a 10-year term, allowing Caltrans to continue performing federal environmental responsibilities for highway projects under NEPA and other federal laws. (Caltrans) Caltrans also states that its 23 U.S.C. section 326 Categorical Exclusion Assignment MOU assigns FHWA categorical exclusion responsibilities to Caltrans and expires April 18, 2027. (Caltrans) Recent federal changes to the Council on Environmental Quality (CEQ) regulations do not erase NEPA for this project. CEQ removed its NEPA implementing regulations from the Code of Federal Regulations effective April 11, 2025, but that action removed CEQ's regulations; it did not repeal the NEPA statute. (Land Use and Climate Innovation) For transportation projects, FHWA, the Federal Railroad Administration, and the Federal Transit Administration revised 23 C.F.R. Part 771 so that their NEPA procedures stand on their own after removal of CEQ cross-references. (Caltrans)
Accordingly, the City does not necessarily make the federal NEPA finding. Still, it should identify the applicable Caltrans NEPA categorical exclusion, NEPA revalidation, environmental certification, environmental commitment record, and any related CCTA federal aid environmental approval. If the City is not relying on any NEPA document, the resolution should expressly state that City execution of the MOU does not constitute City concurrence in the adequacy of any NEPA documentation for the underlying federal aid corridor improvements.
IV. Jurisdiction is divided, but San Ramon still has a responsibility to protect its local roadway network and administrative record
The jurisdictional posture is complicated. Caltrans owns and operates the I-680 corridor, including vehicle detection devices, ramp metering equipment, closed-circuit television cameras, and associated ITS infrastructure. CCTA will install devices along the corridor for vehicle detection and will incorporate the STREAMS freeway management platform to operate ramp meters using CARM algorithms at selected ramp locations during an initial three-year demonstration period. The City is not the owner of I-680, and it may not be the CEQA lead agency for Caltrans' State Highway System work.
But San Ramon is still a signatory party, is listed as a member of both the RMTC and RMWG, and is being asked to approve a resolution finding that participation supports improved traffic operations while protecting the function and safety of San Ramon's local roadway network. The MOU governance table identifies San Ramon staff participation through the Senior Engineer for Traffic and the Public Works Director and/or City Engineer.
The MOU's local effects are not confined to the freeway right-of-way. The staff report says the MOU includes local arterial protections, performance metrics for parallel corridor volumes, incident response and emergency override, data sharing, and City participation in ongoing operational decisions. The MOU itself also provides that unresolved issues may ultimately be referred to the Caltrans District 4 Director and the CCTA Executive Director for final resolution.
The City therefore needs a complete record showing what it is agreeing to, what it is reserving, what documents it is relying upon, what issues staff raised during MOU negotiations, and how future staff participation will be reported back to the Council and the public. City participation should not become a shield for Caltrans or CCTA to claim that local concerns have been resolved when the public record does not show the underlying analysis.
V. The packet describes an integrated corridor program, not an isolated MOU The staff report says I-680 is a critical north-south transportation artery through Contra Costa County and that peak hour congestion results in travel times approximately double those of off-peak periods. It states that Caltrans and CCTA are partnering to implement ramp metering to manage recurrent and non-recurrent congestion, improve operational efficiency without adversely affecting adjacent local arterials, and improve traffic and incident detection.
The packet then describes much more than ramp signal timing. Caltrans programmed SHOPP funds to install fiber optic cable communication trunk lines along I-680 and I-780, install or upgrade TOS, install or upgrade ramp metering, and widen or create HOV bypass lanes where feasible along the I-680 corridor. CCTA developed Innovate 680 over six years in partnership with corridor agencies as an integrated suite of improvements, and CARM is described as a central component of that program.
The MOU reinforces that point. It says the Innovate 680 Program consists of six projects:
Northbound I-680 Express Lane Completion, Transit Bus on Shoulder (TBOS), Shared Mobility Hubs, Advanced Technologies including CARM and Coordinated Adaptive Traffic Signals (CATS), Automated Driving System, and Mobility as a Service or Mobility on Demand. It then states that each of the six projects plays an important role in an integrated approach and, when operating together, will maximize I-680 corridor efficiency with secondary operational benefits to connecting state highways and local arterials.
That integrated project description is central to the CEQA and NEPA concern. The City should not treat the MOU as a narrow administrative agreement while the same packet repeatedly describes the work as an integrated corridor program.
VI. The MOU raises CEQA piecemealing and NEPA segmentation concerns The packet identifies at least three funded projects that will implement ramp metering in the corridor: the SHOPP RM/TOS Project, EA 04-1Q721, Project No. 0423000277, PPNO 2020W; CARM Project Segments 1 and 3A, EA 04-0Q960, Project No. 0418000188, PPNO 0521L; and the Northbound I-680 Express Lane Completion Phase 1, EA 04-0Q3100, Project No. 0418000070, PPNO 2311B. The MOU also states that Caltrans and CCTA anticipate CARM may be implemented along the entire I-680 corridor in Contra Costa County if performance and funding allow. At the same time, some segments are currently funded only for ARM.
That structure raises a fair question whether the corridor has been segmented into separate project labels without a complete public crosswalk. CEQA Guidelines section 15378 defines a project as the whole of the action. (Legal Information Institute) Categorical exemptions also cannot be used where cumulative impacts of successive projects of the same type in the same place over time are significant, or where unusual circumstances create a reasonable possibility of significant environmental effects. (Legal Information Institute)
The NEPA record requires the same kind of careful project framing. Federal transportation NEPA regulations require an action evaluated as a categorical exclusion, environmental assessment, or environmental impact statement to connect logical termini, have independent utility or independent significance, and not restrict consideration of alternatives for other reasonably foreseeable transportation improvements. The same regulation recognizes early and continuing public involvement for federal aid highway projects, including involvement in identifying reasonably foreseeable social, economic, and environmental impacts. (Caltrans)
The MOU acknowledges multiple project interfaces. CATS is described as managing arterial roadway traffic signal systems on local corridors that parallel or interact with I-680 ramps and as potentially receiving traffic data from CARM traffic detection devices. The Northbound I-680 Express Lane Completion Phase 1 project will interface with SHOPP RM and CARM construction, including highway and electrical installations in the braided ramp area. TBOS covers northbound I-680 from the Bollinger Canyon Road entrance ramp to the Ygnacio Valley Road exit ramp and will interface with CARM STREAMS to hold ramp signals on red as buses pass the ramp using the shoulder.
Those interfaces are not peripheral. They go directly to whether the correct project has been defined for CEQA and NEPA purposes. The City should require a project definition crosswalk before approving a resolution that could be read as supporting installation and operation of the corridor projects in San Ramon.
VII. Induced travel demand can result from physical capacity and from algorithmic traffic flow optimization
The packet should not treat induced travel demand as a concept limited to adding new freeway through lanes. The same behavioral principle is implicated when a project reduces travel time, increases speed, improves reliability, increases throughput, increases ramp storage, increases discharge capacity, or uses algorithms to make an existing corridor operate more like a higher capacity facility. Under SB 743, the environmental question is not whether the project reduces delay. The question is whether the project changes total VMT, including induced travel.
That issue is directly presented here. The MOU states that CARM can modulate throughput and metering rates across multiple ramps in real time, coordinate metering rates across all ramps along the corridor, optimize mainline traffic flows, and balance ramp queues. The MOU further states that STREAMS uses control algorithms to assess freeway mainline and ramp performance parameters simultaneously, allowing ramps across a corridor or network to work together to manage the number of vehicles waiting at ramp meters corridor-wide, minimize breakdown of freeway traffic flow, prevent impacts to adjacent arterials, and keep ramp meter wait times acceptable.
The MOU also states that CARM requires operational flexibility to increase or decrease ramp metering rates based on real-time traffic conditions, emphasizes the need for adequate entrance ramp storage and discharge capacity, and requires a high discharge rate with ramps designed for simultaneous release operations. Table B1 states that CARM has predictive response capability, supports coordination across multiple ramps to optimize metering rates for improved mainline management, requires simultaneous release to achieve operational flexibility, and requires a higher density of traffic detection, closedcircuit television cameras, and STREAMS platform licenses.
Those are not passive safety features. They are operational capacity, throughput, and reliability features. They may be beneficial for some operational purposes. Still, they also can reduce the perceived time cost of driving, alter route choice, attract trips from parallel arterials or other modes, change trip timing, and induce additional vehicle travel. That is precisely why the City should not accept delay and throughput metrics as a substitute for SB 743 VMT analysis.
The MOU's own performance metrics focus on mainline traffic volume, average travel time, average travel delay, travel time reliability, productivity, and bottleneck formation. Those metrics are useful for operations, but they are not the same as CEQA transportation impact analysis. CEQA Guidelines section 15064.3 states that VMT is generally the most appropriate measure of transportation impacts and that roadway capacity projects require an appropriate transportation impact measure consistent with CEQA and other applicable requirements. (Legal Information Institute) The Office of Planning and Research's Technical Advisory on Evaluating Transportation Impacts in CEQA states that induced travel can reduce or eliminate congestion relief benefits and that an accurate estimate of induced travel is needed to weigh the costs and benefits of highway capacity expansion. (Ventura County Transportation Commission) Caltrans' SB 743 implementation materials state that the Transportation Analysis Framework and Transportation Analysis under CEQA guide transportation impact analysis on the State Highway System under CEQA and SB 743. (Caltrans)
The same principle should be applied to algorithmic throughput and coordinated ramp metering where the project is expressly designed to increase speed, reliability, discharge rate, and corridor productivity. A project does not avoid induced travel analysis merely because capacity is delivered through software, sensors, ramp storage, queue control, queue override, simultaneous release, and corridor algorithms rather than only through conventional lane miles.
The City should therefore require a VMT analysis that evaluates both physical capacity and operational or algorithmic capacity. That analysis should ask whether CARM, ARM, SHOPP RM/TOS, ramp widening, HOV preferential lane treatments, increased ramp storage, increased ramp discharge capacity, simultaneous release, adaptive signal coordination, CATS, Countywide Smart Signal projects, and local arterial signal modernization will induce additional VMT at the corridor-wide, project-wide, and San Ramon-specific levels.
VIII. The City has repeated the same induced demand error in physical widening projects and transportation technology projects
The City's failure to address induced travel demand in Agenda Item 9.1 is not limited to a misunderstanding of non-physical or software-based transportation systems. The same record problem appears in the City's physical roadway widening and grade separation decisions. The City repeatedly treats projects as inherited implementation items, funding opportunities, settlement obligations, or technical improvements, rather than reevaluating whether current facts still support the project purpose and need under CEQA, SB 743, VMT, GHG, cumulative impact, and public participation standards.
The recent Crow Canyon Road Widening Project illustrates the problem. The State Clearinghouse record identifies the Crow Canyon Road Widening Project as a 2002 Negative Declaration, with the City of San Ramon as lead agency. The project description included roadway improvements to Crow Canyon Road, Camino Ramon, Crow Canyon Place, and Alcosta Boulevard, and widening off-ramps from I-680 to Crow Canyon Road. (CEQAnet) The City's later project FAQ states that the road widening work cost approximately $12.5 million, was required by the Dougherty Valley Settlement Agreement, and was funded with developer funds allocated specifically for that project. A settlement obligation or developer-funded capital list may explain why a project remained in a program. Still, it does not substitute for current CEQA, SB 743, VMT, GHG, public outreach, emergency access, or cumulative impact analysis.
The City's record should not assume that a project conceived in the 2002 environmental setting, or carried forward because of the Dougherty Valley Settlement Agreement, remains justified in 2026 without current evidence. The proper question is not whether a legacy project appears on an old list. The proper question is whether the current record demonstrates that the project remains environmentally, operationally, and legally justified under today's transportation policy, today's VMT framework, today's climate standards, and today's actual congestion and travel behavior data.
The same concern applies to Bollinger Canyon Road. Public reporting on the Bollinger Canyon Road widening project described a widening to accommodate City Center Bishop Ranch, General Plan buildout, and Dougherty Valley buildout, including an additional travel lane in each direction from Market Place to I-680 and multiple added turn lanes. (Danville San Ramon) The City's own current construction projects page later described the Bollinger Canyon Road and Iron Horse Trail pedestrian overcrossing as a project that removes bicycles and pedestrians from the at-grade crossing/intersection, "thereby improving the flow of vehicles traveling on Bollinger Canyon Road." (San Ramon) The City's official page states that the Iron Horse Trail Bicycle and Pedestrian Overcrossing at Bollinger Canyon Road opened to the public on July 19, 2025. (San Ramon) The California State Association of Counties described the same project as a $29 million, 340-foot, cablestayed bridge with 900 feet of mechanically stabilized earth wall approaches, eliminating a previously signaled crossing and completing a link in the regional Iron Horse Trail system. (California State Association of Counties)
Those facts do not mean the overcrossing lacks bicycle and pedestrian safety value. The point is different: the City has repeatedly justified expensive roadway, signal, and grade separation projects by claiming improved vehicle flow, reduced delay, or congestion relief, while failing to address induced demand, VMT, GHG emissions, multimodal tradeoffs, cumulative impacts, and whether each project's purpose remains coherent when viewed together with the others. Widening Bollinger Canyon Road for capacity and later building a very expensive overcrossing to remove an at-grade trail crossing for vehicle flow reasons are not unrelated choices. They are part of a transportation system design posture that should be evaluated cumulatively, not defended project by project as isolated improvements.
The Norris Canyon Road HOV direct access ramp episode shows that a different approach is possible. CCTA states that the I-680 HOV Direct Access Ramps project included potential dedicated HOV on- and off-ramps in San Ramon, and that the 2010 Project Study Report studied a Norris Canyon alternative and a No Build alternative, with a project cost estimate of $102 million for the Norris Canyon HOV direct access ramp alternative. (Contra Costa Transportation Authority) The Tri-Valley Transportation Council states that in March 2016 the City of San Ramon withdrew support for the project, CCTA suspended work, and the project was removed from the project list and no longer considered for funding. (Tri-Valley Transportation Council) That decision demonstrates that San Ramon can reject or halt a transportation project when the public record, community concerns, cost, and policy context do not support moving forward. That lesson should be carried forward. It should not be forgotten each time a new transportation technology, widening, grade separation, or legacy project list comes before the City Council.
The same scrutiny should apply here. The I-680 CARM MOU may be presented as a nonbinding governance document. Still, the project is designed to increase system efficiency, manage mainline flow, increase ramp storage and discharge capacity, coordinate metering rates, integrate with arterial signal systems, and support future operations across the corridor. The City should not repeat the same pattern by approving Resolution No. 2026-109 without current VMT analysis, induced travel analysis, CAP and GHG consistency analysis, public outreach, construction emergency access analysis, and a cumulative project crosswalk.
IX. No San Ramon-specific VMT, SB 743, CAP, CEQA GHG Thresholds, or construction traffic and emergency access analysis has been prepared or referenced
The packet does not include a San Ramon-specific VMT analysis, SB 743 transportation impact analysis, CAP consistency analysis, CEQA GHG Emissions Thresholds and Guidance Report consistency analysis, construction GHG analysis, construction traffic analysis, shoulder closure analysis, or emergency access analysis. The attachment list for Agenda Item 9.1 includes only the resolution and the MOU.
This is not a minor technical omission. CEQA Guidelines section 15064.3 states that VMT is generally the most appropriate measure of transportation impacts, that transportation projects reducing or having no impact on VMT may be presumed less than significant, and that roadway capacity projects require an appropriate transportation impact measure consistent with CEQA and other applicable requirements. It also requires assumptions used to estimate VMT to be documented and explained in the environmental document. (Legal Information Institute)
The packet does not explain whether ramp widening, increased ramp storage, increased discharge capacity, CARM coordination across ramps, HOV preferential lane treatments, induced travel, diversion to local arterials, or changes in trip timing or route choice affect VMT. It also does not explain whether the project reduces VMT, has no VMT impact, induces VMT, or relies on a prior programmatic VMT analysis.
The packet uses delay, travel time, and congestion management as operational performance metrics. For example, the MOU proposes to compare average travel time, average travel delay, travel time reliability, mainline traffic volume, productivity, and bottleneck formation before and during ramp metering operations. Those operational metrics may be useful, but they do not substitute for CEQA transportation impact analysis under SB 743. The City's record must distinguish operational performance from CEQA significance, and it must evaluate induced travel and VMT rather than relying on delay reduction as a proxy for environmental compliance.
The GHG record is similarly incomplete. CEQA Guidelines section 15064.4 requires a good faith effort, based on scientific and factual data to the extent possible, to describe, calculate, or estimate GHG emissions resulting from a project, and directs agencies to consider whether emissions exceed an applicable threshold and whether the project complies with regulations or requirements adopted to implement a statewide, regional, or local GHG reduction plan. (San Ramon)
The packet contains no San Ramon CAP consistency analysis and no CEQA GHG Thresholds consistency analysis. It does not explain whether the SHOPP RM/TOS Project, CARM, ramp widening, HOV preferential lane work, fiber and TOS installation, vehicle detection, directional drilling, repaving, construction staging, or future operations are consistent with San Ramon's adopted CAP and CEQA GHG thresholds. It also does not quantify or qualitatively disclose construction GHG emissions for work in San Ramon.
That omission is particularly serious because Caltrans' own Standard Environmental Reference states that all projects must report construction GHG emissions in the environmental document, including CEQA exemptions, and that GHG emissions should be included in the categorical exemption along with standard specifications and avoidance or minimization measures that also benefit GHG reduction. (CivicLive) Caltrans' Standard Environmental Reference is also intended to help state and local agency staff plan, prepare, submit, and evaluate environmental documents for transportation projects, including local agency highway and local streets and roads projects with FHWA funding or approvals. (Caltrans)
X. Construction impacts on the operating I-680 corridor and shoulder closures require specific analysis
The MOU recognizes that I-680 is not an ordinary local facility. It describes I-680 as a sixto ten-lane major north-south freeway through Contra Costa County and states that the I680 segment within Contra Costa County is considered a Lifeline Highway route. That designation makes construction shoulder closures, constrained ramps, K-rail, ramp staging, traffic congestion, and emergency access more important.
The MOU also recognizes that emergency access may depend on shoulder availability. It states that Caltrans District 4 Traffic Management Center staff will be able to override ARM system control and deactivate ramp signals, especially where shoulders are inadequate to allow emergency vehicle access, and that CCTA operations staff will have comparable CARM override authority. The incident response section similarly states that the California Highway Patrol or local emergency services may request override or deactivation where shoulders are inadequate to allow emergency vehicles to pass.
Those provisions address future ramp metering operations. They do not analyze present construction conditions. In the past week and a half, I personally experienced four incidentrelated congestion events just north of San Ramon in which emergency response appeared to be slowed by restricted or unavailable freeway shoulder access. Those observations are consistent with the exact emergency access vulnerability that the MOU itself acknowledges.
The packet does not provide a construction emergency access plan, shoulder closure analysis, California Highway Patrol coordination record, Freeway Service Patrol coordination record, Transportation Management Plan, Traffic Handling Plan, Lane Closure System record, public advisory record, or incident response protocol addressing current construction conditions. The City should require Caltrans and CCTA to produce a construction emergency access and incident response analysis before the City approves the MOU or, at minimum, as an express condition of participation. That analysis should address temporary shoulder closures, narrowed shoulders, K-rail, ramp closures, directional drilling, fiber conduit installation, retaining wall work, soil nail wall work, ramp resurfacing, disabled vehicle refuge, tow response, Freeway Service Patrol response, ambulance access, fire access, California Highway Patrol access, and public notification.
XI. Field conditions confirm that construction and staging are already occurring in San Ramon
The MOU states that construction of the Caltrans SHOPP project, EA 04-1Q721, began in November 2025, and that CCTA expects initial CARM enhancement construction from Alcosta Boulevard to Willow Pass Road to begin in 2027. Separate Caltrans records produced in response to my public records requests identified related Bollinger Canyon Road work as EA 04-1Q7214, "Install Fiber Optic Cable System, Ramp Metering, and Widen Freeway On-Ramps." Caltrans described the southbound I-680 on-ramp from eastbound Bollinger Canyon Road as involving a new retaining wall, ramp widening, roadway resurfacing, and ramp metering, and described the westbound Bollinger Canyon Road on-ramp as involving ramp widening, resurfacing, and ramp metering, with closures and detours.
The limited Project Schedule Outlook that Caltrans produced does not resolve the issue. It identifies Location 24, the southbound El Cerro Boulevard on-ramp; Location 26, the southbound Stone Valley Road on-ramp; and Location 27, the northbound Stone Valley Road on-ramp, and identifies excavation, soil nail wall construction, demolition, retaining wall activities, daytime closures, nighttime closures, and lane closures. It does not provide comparable information for Bollinger Canyon Road, Crow Canyon Road, Alcosta Boulevard, or the full corridor schedule.
Caltrans' own environmental certification for EA 1Q721 identifies CEQA and NEPA categorical approvals dated May 3, 2022, a NEPA revalidation dated December 19, 2024, an updated Environmental Commitment Record dated December 19, 2024, a Stormwater TBMP Certification dated December 9, 2024, and a certification expiration date of December 19, 2025 if the project was not advertised within twelve months. The underlying CEQA and NEPA categorical form for EA 1Q720 described a project to install fiber optic cable communication trunk lines along I-680 and I-780, install or upgrade TOS, install or upgrade ramp metering elements, and widen or create HOV bypass lanes at multiple ramp locations.
More recently, I documented construction staging and preparation in the Caltrans Park and Ride lot at Bollinger Canyon Road and I-680, including a dump truck carrying two reels of fiber conduit and a directional drill on a trailer. These observations appear directly related to the fiber, TOS, and ramp metering scope described by Caltrans and reflected in the MOU. The City should require Caltrans and CCTA to identify the project component, environmental document, construction staging authorization, traffic handling plan, drilling or conduit plans, public notice, stormwater controls, and environmental commitments covering that activity.
XII. The public outreach record is inadequate and appears to be mainly agency review, not public outreach
The public outreach deficiency is one of the most important problems with this item.
CCTA's Innovate 680 Program was developed over six years in partnership with local agencies along the I-680 corridor, and the staff report describes CARM as a central component of that program. But the packet does not show a comparable six-year public outreach record. Instead, the staff report emphasizes an iterative staff and agency review process: CCTA used multiple rounds of review involving partner agencies, City staff actively participated, and staff provided substantive written feedback. The MOU document history likewise shows drafts for CCTA, Caltrans, and local agency review from April 2025 through May 2026. Still, it does not show drafts circulated for broad public review, public workshops, neighborhood meetings, public hearings, or public comment periods during the six-year development of Innovate 680.
The MOU's public outreach section is mostly prospective. It states that ramp metering implementation and operation "will include" a robust public information and education program primarily managed by CCTA and supported by the Caltrans Public Information Office. It says outreach and education are needed to prepare the public for different ramp metering operations, and that Innovate 680 websites and social media "will be utilized" to educate the public before activation. It then states that, as the activation date approaches, there "will be" press releases and targeted social media messaging, and outreach "may include" presentations to local governing bodies and public events. That is not evidence of meaningful public outreach during the six-year development of Innovate 680, nor is it evidence of outreach during current construction and staging.
To the extent CCTA or Caltrans point to a few webinars or surveys, those are not a substitute for robust public outreach. A webinar or survey may solicit project-specific concerns, preferences, or reactions. Still, it is not the same as a transparent public process that discloses the full project scope, alternatives, cumulative projects list, VMT analysis, CAP and GHG analysis, construction schedule, shoulder closure effects, emergency access risks, and jurisdictional responsibilities. Public outreach is not merely asking people to respond to a predetermined project framework. It requires timely disclosure, meaningful public education, an opportunity to understand the project before key commitments are made, and a clear way for public concerns to affect project design, environmental review, construction staging, and operations.
The current packet does not provide that record. It does not attach public outreach summaries, survey results, webinar materials, written public comments, response-tocomment materials, public meeting notices, outreach plans, equity outreach records, or documentation showing how public input changed the project. The only attachments are the resolution and MOU.
This matters because the MOU itself anticipates that the public may not be able to distinguish whether a ramp is operated under ARM or CARM and directs public queries primarily to the Caltrans Customer Service Request portal. It also says Caltrans and CCTA will identify public information points of contact and include names, phone numbers, and emails in the future Ramp Metering Operations and Maintenance Procedures (RMOMP).
That is too late. The public information points of contact should be identified now, and the public outreach record should be posted before the City Council approves the MOU.
Public outreach also cannot wait until ramp metering activation. Public information is needed now, during construction and staging. Residents and corridor users need to know which ramps are affected, which shoulders are closed, which Park and Ride lots are used for staging, when directional drilling or fiber conduit installation is occurring, when ramp closures or detours are scheduled, whether delays are expected during daytime or nighttime periods, how emergency access is maintained, where complaints should be submitted, and which agency is responsible for response.
XIII. This reflects a recurring City record problem in transportation technology approvals, including the July 14, 2026 ITS and Communications Infrastructure Project
The deficiencies in Agenda Item 9.1 are not isolated. They are consistent with a recurring City record problem in transportation technology and infrastructure actions: the City treats ITS, communications infrastructure, signal modernization, freeway operations, and corridor technology approvals as administrative, technical, funding, or coordination steps, while failing to square those actions with the City's CEQA duties, NEPA documentation, VMT, SB 743, GHG, CAP, emergency access, construction impacts, cumulative impacts, public outreach, and adopted General Plan 2040 mitigation framework.
The most recent example is the July 14, 2026 City Council Agenda Item 5.5, Resolution No. 2026-098, concerning the San Ramon ITS and Communications Infrastructure Project. That item concerned a U.S. Department of Housing and Urban Development (HUD) Community Planning and Development (CPD) Community Project Funding (CPF) grant for the City's ITS and Communications Infrastructure Project. (See previous written public comments attached.) The staff report acknowledged that HUD-funded projects are subject to NEPA and HUD's NEPA implementing regulations, stated that the NEPA environmental review had been completed and uploaded to the HUD Environmental Review Online System (HEROS), and stated that the project had been "converted to exempt" in HEROS.
The July 14 staff report also included a separate CEQA Compliance section. It stated that, after initial environmental review by Verdantas, staff filed a Notice of Exemption with the Contra Costa County Clerk on May 20, 2026, and identified the asserted CEQA categorical exemptions as Existing Facilities, Replacement or Reconstruction, New Construction or Conversion of Small Structures, and Minor Alterations to Land.
The resolution for that item also acknowledged that until the project fully completed the environmental review process, the City could not commit or spend project funds on construction or enter contracts for construction or physical work.
I do not cite the July 14 ITS item to endorse the adequacy of that environmental record. To the contrary, that item raised its own concerns regarding approval chronology, Notice of Exemption timing, project approval authority, and the relationship between the HUD environmental review and CEQA process. (See the INADEQUATE Notice of Exemption attached.) But the July 14 item shows that the City knows how to identify a federal environmental review pathway, identify a CEQA exemption theory, and attach environmental review materials when it chooses to do so.
That makes the omission in Agenda Item 9.1 more serious, not less. The August 11 CARM item concerns a much broader corridor operating framework involving Caltrans, CCTA, SHOPP, CARM, ARM, TOS, ITS, fiber optic infrastructure, ramp widening, HOV preferential lane treatments, local arterial interface, emergency override, public outreach, performance metrics, data sharing, and future operations. Yet the packet does not include an item-specific CEQA finding, does not identify any Caltrans or CCTA CEQA document being relied upon, does not identify any applicable NEPA categorical exclusion or revalidation, and attaches only Resolution No. 2026-109 and the MOU.
The July 14 ITS item also underscores the cumulative impact issue. The HUD environmental review identifies that the City's ITS and Communications Infrastructure Project runs along Crow Canyon Road, Camino Ramon, and San Ramon Valley Boulevard. Those same corridors are functionally related to the I-680 ramp metering and local arterial management framework now before the Council. The MOU's Appendix B identifies related ITS projects that interface with
I-680 ramps, including the Countywide Smart Signal Project and the Innovate 680 CATS project on Danville Boulevard, Hartz Avenue, and San Ramon Valley Boulevard.
The City therefore cannot evaluate Agenda Item 9.1 in isolation. At minimum, the administrative record should explain whether and how the City's ITS and Communications Infrastructure Project, the Countywide Smart Signal Project, local arterial signal modernization projects, CARM, ARM, TOS, fiber optic trunk lines, ramp widening, and related freeway and arterial systems interact. If these projects are unrelated for CEQA or NEPA purposes, the record should explain why. If they are related through data, operations, construction staging, traffic diversion, incident response, emergency access, or cumulative effects, they should be disclosed and analyzed as part of the whole corridor program.
Approving Resolution No. 2026-109 without that crosswalk would repeat the same basic failure: treating transportation technology projects as administrative implementation actions while omitting the environmental, transportation, climate, cumulative impact, public outreach, and emergency access analysis needed to support the approval.
XIV. The MOU's appendix confirms that the cumulative impact analysis is incomplete
The MOU's Appendix B identifies related ITS projects that interface with I-680 ramps, but the staff report does not provide a complete cumulative impact analysis. Appendix B states that it provides information on planned local arterial ITS projects that will interface with I680 ramps. It then identifies the Countywide Smart Signal Project, which will modernize traffic signal infrastructure at 365 intersections throughout Contra Costa County, including signalized intersections along routes of regional significance and key parallel and intersecting arterial routes along the I-680 corridor, with construction scheduled to begin in late July 2026.
Appendix B also identifies the Danville Townwide Traffic Signal Modernization project, which is in construction and involves 26 signalized intersections along Sycamore Valley Road, Camino Tassajara, and Crow Canyon Road, a route of regional significance that provides key access to I-680. It also identifies the City of Concord ITS/Signal Modernization project as in construction. Finally, it identifies the Innovate 680 CATS Danville Boulevard, Hartz Avenue, and San Ramon Valley Boulevard demonstration project as the primary arterial management system for Innovate 680, operating across jurisdictions in traffic adaptive mode on specified corridors and enabling multijurisdictional signal timing coordination, transit signal priority, and other traffic management functions across the program area, including ramp terminal intersection signals operated by Caltrans.
These are not unrelated background items. They are reasonably foreseeable, overlapping, and operationally connected projects that can affect I-680, ramp queues, local arterial delay, traffic diversion, emergency response, construction staging, public information, and induced travel demand. CEQA Guidelines section 15130 requires cumulative impact analysis where a project's incremental effect is cumulatively considerable and requires either a list of past, present, and probable future projects producing related impacts or a summary of projections from adopted plans or related planning documents. (Legal Information Institute)
The City should require a cumulative impact analysis that includes each participating jurisdiction's reasonably foreseeable corridor-related projects, including local smart signal projects. These arterial projects feed I-680, ramp terminal projects, active transportation projects, trail projects, construction projects affecting local access to ramps, and algorithmic traffic management projects designed to increase corridor throughput. At minimum, that analysis should include San Ramon, Danville, Walnut Creek, Pleasant Hill, Concord, Contra Costa County, CCTA, Caltrans, and the Metropolitan Transportation Commission. It should include or expressly explain the exclusion of the Crow Canyon Road Iron Horse Trail Overcrossing, Iron Horse Trail double tracking or related trail corridor work, San Ramon Valley Boulevard improvements, Crow Canyon Road projects, Bollinger Canyon Road projects, and other local arterial or ITS projects feeding I-680.
XV. The MOU confirms this is a complex ITS project, but the key systems documents are not attached
The MOU's glossary states that ITS refers to any transportation project or system that uses technology and communication networks to improve traffic flow, safety, security, and access, and it states that all Innovate 680 projects and the Caltrans SHOPP project can be considered ITS. The glossary also explains that the Concept of Operations is a key document within the systems engineering process for complex ITS projects and is intended to confirm user needs and operational practices.
Yet the packet does not attach the CARM Concept of Operations, the RMOMP, the Caltrans Traffic Handling Plan, the Transportation Management Plan, the environmental revalidation documents, the public outreach plan, the public comment record, the induced travel analysis, the VMT analysis, or the construction staging and emergency response protocols. The MOU states that system integration details were still being coordinated at the time the MOU was executed and would be finalized during the CARM design phase.
The MOU also states that the RMOMP will be prepared later and will cover ramp metering operations, ramp closure operations, emergency and incident response and override, communications protocol, data collection and sharing, training, maintenance procedures, emergency repair procedures, asset management, and related matters.
Those are not minor implementation details. They are the documents that will determine how the system operates, how emergencies are handled, how closures occur, how data is shared, how the public will be informed, and whether the project changes corridor travel behavior. They should be posted publicly and returned to the Council before activation of ramp metering operations affecting San Ramon.
XVI. Performance metrics and the Dashboard should not become a transparency substitute
The staff report states that corridor stakeholders, including the City, will have read-only access to the STREAMS Smart Motorways Dashboard to monitor real-time and historic ramp metering performance. The MOU says the Dashboard will display mainline and ramp conditions, including volumes, speed, occupancy, ramp wait times, queue information, ramp metering parameters, and ramp metering rates, but will not offer direct data export capabilities for ramp metering parameters and rates to protect proprietary information.
A read-only Dashboard for agency staff is not the same as public transparency. The MOU states that vehicle detector data will be available on the Caltrans ITS network and will be made publicly available through the Caltrans Performance Measurement System or a similar system, and that reports, summaries, and spreadsheets could be generated as needed. The City should require San Ramon-specific public summaries of queue length, ramp wait time, local arterial delay, incidents, emergency access issues, lane and shoulder closures, public complaints, operational adjustments, and any observed changes in VMT or travel behavior.
The performance metrics also do not replace environmental analysis or public outreach.
The MOU provides for mainline, ramp, arterial, transit, total trip travel time, safety, field observation, and functional performance reporting. Those metrics may be useful for operations, but they do not substitute for VMT, GHG, CAP consistency, construction emissions, cumulative impacts, public outreach, emergency access analysis, or induced travel analysis before the City acts.
XVII. The staff report's fiscal impact analysis is materially incomplete The staff report's fiscal impact analysis is materially incomplete. It states that there is "no direct fiscal impact to the City" because the MOU imposes no direct financial obligation on local jurisdictions and because Caltrans funds capital and operating costs for ramp metering infrastructure through SHOPP and, through CCTA, federal, state, and local funds managed by CCTA. That is not an adequate fiscal analysis for this item.
At most, the staff report establishes that the MOU does not impose a direct capital payment obligation on San Ramon at the moment of approval. It does not establish that the MOU has no fiscal, administrative, staff, operational, emergency response, public records, public outreach, data, or future policy cost to the City.
The same staff report acknowledges that San Ramon would participate in both the I-680 Ramp Metering Technical Committee and the I-680 Ramp Metering Working Group, and that those bodies are where technical and operational issues are discussed and resolved.
It further states that if the MOU is not executed, decisions that could affect San Ramon will be made without City staff involvement. That confirms that City staff involvement is not incidental. It is the mechanism by which San Ramon is expected to protect its interests.
The MOU also identifies San Ramon staff positions as members of the governance structure. San Ramon's Senior Engineer for Traffic is listed for the Ramp Metering Technical Committee, and the Public Works Director and/or City Engineer is listed for the Ramp Metering Working Group. Those commitments require staff time, technical review, meeting preparation, data review, issue tracking, public inquiry response, interagency coordination, and potentially Council follow-up. The staff report does not estimate any of those costs.
The cost and funding section of the MOU also does not support a simple "no fiscal impact" conclusion. The MOU states that CARM capital construction, the ramp meter system, and the initial three years of initialization costs are funded by federal, state, and local funds managed by CCTA. It also states that CCTA and Caltrans are coordinating to seek additional funding to complete CARM enhancement for remaining segments and future CARM operations. The MOU further states that CARM ramps will be funded and operated by CCTA for an initial three years as a demonstration project; that the later operating methodology will depend on performance and available funding; and that CCTA will identify funds for CARM beyond the initial three-year period during the final year of the demonstration period.
That is not a complete fiscal record. It identifies a demonstration period and future funding uncertainty. The City should not treat the absence of an immediate direct invoice to San Ramon as equivalent to no fiscal impact. The City should require a fiscal and administrative impact analysis addressing staff time, technical participation, data infrastructure, Dashboard access and training, public inquiry handling, California Public Records Act processing, emergency access coordination, public outreach, local arterial monitoring, Council reporting, and future amendments or operating decisions.
The MOU's data-sharing provisions reinforce this concern. The MOU states that stakeholders will receive read-only access to the STREAMS Smart Motorways Dashboard and that vehicle detector data will be made available through Caltrans PeMS or a similar system, with reports, summaries, and spreadsheets generated as needed. If San Ramon is expected to monitor system performance, respond to resident concerns, evaluate local arterial effects, and participate in governance decisions, the City must identify the staff and technical resources needed to do so.
The City should also account for fiscal exposure created by public accountability.
Residents will not distinguish between Caltrans, CCTA, ARM, CARM, SHOPP, TOS, STREAMS, CATS, or the City's own ITS projects when ramp queues, shoulder closures, construction staging, emergency response constraints, or local arterial impacts occur. The City will receive public complaints, public records requests, Council inquiries, and interagency coordination obligations. The fiscal section does not address those reasonably foreseeable burdens.
The City should revise the fiscal analysis to distinguish between:
1. direct capital payment obligations, which the MOU may not impose immediately;
2. staff and administrative costs, including RMTC and RMWG participation, data review, public inquiry response, public records processing, Council reporting, and interagency coordination;
3. local operational costs, including arterial monitoring, signal coordination, emergency access coordination, and incident response coordination;
4. future funding and amendment exposure, including costs that may arise if CARM continues, expands, reverts to ARM, or requires additional local infrastructure or data systems; and
5. public accountability costs, including the burden of responding to residents, businesses, emergency responders, and local road users affected by construction, staging, ramp metering, shoulder closures, and arterial diversion.
The City should not approve Resolution No. 2026-109 based on a fiscal analysis that says "no direct fiscal impact" while omitting the actual staff, governance, monitoring, emergency response, data, public outreach, and future operating burdens created by participation in the MOU.
XVIII. The City should not rely on staff's MOU review conclusion without the written comment and response record
The staff report states that City staff actively participated in the MOU review process and provided substantive written feedback, and that staff is satisfied the current MOU adequately addresses San Ramon's concerns. The MOU document history shows multiple drafts between April 2025 and May 2026, including drafts for Caltrans, CCTA, and local agency review.
If San Ramon staff provided substantive written feedback, that feedback should be in the public record before the Council approves the MOU. The packet does not include City comments, CCTA responses, a redline, unresolved issue list, or comment and response matrix. The Council and public therefore cannot evaluate whether San Ramon's concerns were actually resolved or only summarized.
The City should post the City's written comments on the MOU, CCTA's response matrix, any redline showing changes made to address San Ramon's concerns, and any public outreach or public comment materials that CCTA or Caltrans claim support the MOU.
XIX. Requested revisions before approval
I respectfully request that the City Council not approve Resolution No. 2026-109 as drafted. If the Council chooses to proceed, it should revise the resolution and direct staff to include the following safeguards.
First, require an item-specific CEQA determination and identify the applicable NEPA documentation. Before approving Resolution No. 2026-109, the City should make an item-specific CEQA determination for the City's discretionary action and identify any Caltrans or CCTA CEQA document being relied upon. The City should also identify the applicable Caltrans NEPA categorical exclusion, NEPA revalidation, environmental certification, and environmental commitments for the federally assisted project components, or expressly state that City execution of the MOU does not constitute City concurrence that any Caltrans or CCTA CEQA or NEPA documentation is adequate.
Second, add a CEQA and NEPA reservation. The resolution should state that City execution of the MOU does not constitute City concurrence that any CEQA categorical exemption, NEPA categorical exclusion, revalidation, environmental certification, VMT analysis, SB 743 analysis, GHG analysis, CAP consistency analysis, project segmentation analysis, construction impact analysis, emergency access analysis, public outreach analysis, induced travel analysis, algorithmic throughput analysis, or cumulative impact analysis prepared by Caltrans or CCTA is adequate for the corridor work as actually constructed, staged, funded, optimized, and operated.
Third, revise the resolution language. The phrase authorizing the MOU "for the installation and operation" of the SHOPP and CARM projects should be revised to clarify that the City is authorizing participation in corridor governance and is not independently approving physical construction, environmental compliance, future operational changes, or project expansion without required public process.
Fourth, require a complete project crosswalk. Before activation or any future construction phase affecting San Ramon, Caltrans and CCTA should provide a public crosswalk identifying EA 1Q720, EA 04-1Q721, EA 04-1Q7214, EA 04-1Q722, EA 04- 0Q960, EA 04-0Q3100, SHOPP RM/TOS, CARM, ARM, Northbound Express Lane Completion, CATS, TBOS, Countywide Smart Signal, local arterial ITS projects, ramp repaving or repair projects, Park and Ride staging, directional drilling, fiber conduit installation, environmental documents, traffic handling plans, and public information responsibilities.
Fifth, require San Ramon-specific VMT, SB 743, CAP, and CEQA GHG Thresholds analysis. The analysis should explain whether the project reduces VMT, has no VMT impact, induces VMT, or relies on prior programmatic analysis. It should also explain whether construction and operation are consistent with San Ramon's adopted CAP and CEQA GHG thresholds.
Sixth, require induced travel analysis for both physical and algorithmic capacity.
Caltrans and CCTA should evaluate induced travel demand from ramp widening, increased ramp storage, increased ramp discharge capacity, simultaneous release, queue control, queue override, coordinated metering rates, CARM algorithms, CATS, Countywide Smart Signal implementation, arterial optimization, and other operational strategies designed to increase speeds, reliability, or throughput. The City should not accept delay reduction, productivity, or throughput as a substitute for VMT analysis.
Seventh, require a current context review of legacy widening and grade separation projects. The City should identify how Agenda Item 9.1 relates to recent and reasonably foreseeable transportation projects, including the Crow Canyon Road Widening Project, the Bollinger Canyon Road widening project, the Bollinger Canyon Road Iron Horse Trail Overcrossing, the Crow Canyon Road Iron Horse Trail Overcrossing, the Citywide ITS and Communications Infrastructure Project, the Countywide Smart Signal Project, and other arterial or freeway interface projects. The record should explain whether these projects are being advanced under current CEQA, VMT, GHG, and cumulative impact standards, or whether they are being implemented primarily because they remain on older settlement, development, grant, or capital improvement lists.
Eighth, require construction traffic, shoulder closure, and emergency access analysis. The City should require a construction stage plan addressing shoulder closures, lane closures, ramp closures, K-rail, daytime congestion, nighttime work, Park and Ride staging, directional drilling, fiber conduit installation, pavement resurfacing, retaining wall work, soil nail wall work, California Highway Patrol coordination, fire and ambulance access, Freeway Service Patrol response, tow response, disabled vehicle refuge, incident clearance, public advisories, and public complaints.
Ninth, require a complete public outreach record and a public outreach plan before activation. The City should require CCTA and Caltrans to provide all public outreach records for Innovate 680 and CARM, including webinars, surveys, meeting notices, presentation materials, comments received, response materials, public concerns, equity outreach, and documentation showing how public input changed the project. The City should also require a real public outreach plan for construction, staging, activation, emergency access, local arterial effects, induced travel, and long-term operations. A few webinars or surveys should not be treated as equivalent to meaningful public outreach.
Tenth, require a cumulative impact analysis. The City should require Caltrans and CCTA to identify past, present, and reasonably foreseeable projects that may contribute to cumulative construction, traffic, emergency response, GHG, VMT, induced travel, or local arterial impacts. That list should include corridor-wide and jurisdiction-specific ITS, smart signal, arterial, trail, active transportation, ramp terminal, and freeway projects in San Ramon, Danville, Walnut Creek, Pleasant Hill, Concord, Contra Costa County, and adjacent jurisdictions.
Eleventh, require a crosswalk to prior City transportation technology approvals. The City should identify and cross-reference related San Ramon transportation technology and communications infrastructure actions, including the July 14, 2026 Agenda Item 5.5, Resolution No. 2026-098, San Ramon ITS and Communications Infrastructure Project; the Countywide Smart Signal Project; local arterial signal modernization projects; and any City fiber, communications, signal, adaptive traffic management, or corridor data projects that interact with I-680 ramp metering, CARM, ARM, TOS, or CATS. The City should explain whether those projects are part of the cumulative setting, whether they share infrastructure, data, corridors, construction staging, or operational objectives, and whether they were included in the VMT, GHG, public outreach, emergency access, and cumulative impact analysis.
Twelfth, require public release of environmental and traffic handling records. The City should request and post the CEQA and NEPA documents, revalidation forms, environmental certifications, environmental commitment records, VMT analysis, GHG analysis, traffic handling plans, transportation management plans, Lane Closure System records, ramp closure schedules, shoulder closure plans, detour plans, public advisory records, and emergency response protocols for San Ramon ramps.
Thirteenth, require the Concept of Operations and RMOMP to return to the Council.
The Concept of Operations and RMOMP will contain the actual user needs, operating procedures, ramp closure procedures, emergency response and override protocols, data sharing procedures, training, maintenance procedures, public information procedures, and system integration details. They should be posted and returned to the Council before activation of ramp metering operations affecting San Ramon.
Fourteenth, require public information points of contact now. The MOU says Caltrans and CCTA public information contacts will be included in the RMOMP, but the City should require those contacts before approval or as a condition of approval. The public should not be passed among Caltrans, CCTA, San Ramon, and other agencies without a clear responsible contact.
Fifteenth, require a complete fiscal and administrative impact analysis. The City should revise the staff report's fiscal analysis to distinguish between absence of an immediate direct capital payment obligation and the actual fiscal, staff, administrative, public outreach, data, public records, local arterial monitoring, emergency response, governance, and Council reporting burdens created by participation in the MOU. The analysis should estimate staff time for RMTC and RMWG participation, Dashboard and PeMS data review, public inquiry response, California Public Records Act response, local arterial monitoring, emergency coordination, Council reporting, and future amendments or operating decisions.
Sixteenth, require City staff reporting. Staff should return to the Council before activation, after the first three months of operation, and every six months during the demonstration period with a San Ramon-specific report on local arterial effects, public complaints, emergency response issues, transit impacts, bicycle and pedestrian interface issues, shoulder closures, ramp closures, Park and Ride staging, public outreach, induced travel indicators, and unresolved governance matters.
Seventeenth, require posting of RMTC and RMWG materials. The City should post San Ramon-relevant RMTC and RMWG agendas, staff reports, performance reports, public complaint summaries, public outreach summaries, and decision logs. If the City relies on those bodies to protect San Ramon's interests, the public needs visibility into what is being discussed and decided.
XX. Conclusion
San Ramon should participate in the I-680 ramp metering governance structure, but it should not approve Resolution No. 2026-109 as if the only question is whether the City wants a seat at the table. The packet shows that this is a coordinated corridor program involving Caltrans, CCTA, SHOPP, CARM, ARM, TOS, fiber optic infrastructure, vehicle detection, ramp modifications, local arterial protections, incident response, public outreach, performance metrics, future operating agreements, related ITS projects, and algorithmic traffic flow optimization.
The City should take the seat, but it should also insist on the complete record needed to protect San Ramon's residents, local arterials, emergency response, public transparency, public participation, and environmental compliance position. That record should include an item-specific CEQA determination or express environmental reservation, identification of the applicable NEPA documentation, VMT and SB 743 analysis, induced travel analysis for both physical and algorithmic capacity, CAP and CEQA GHG Thresholds consistency analysis, construction GHG analysis, construction traffic and emergency access analysis, cumulative impact analysis, a project crosswalk, public outreach records, public advisory records, and the actual Concept of Operations and RMOMP.
Approving Resolution No. 2026-109 on this record would reflect not informed corridor governance, but a failure to demonstrate that the City has applied the transportation, climate, emergency access, cumulative impact, CEQA, and NEPA compliance principles implicated by the MOU.
I respectfully request that the City Council continue Item 9.1 or revise Resolution No. 2026- 109 to include the safeguards described above.
Respectfully submitted,
Brian C. Swanson, AICP
San Ramon Resident, Voter, and Taxpayer
From: Brian Swanson >
Sent: Monday, August 10, 2026 10:57 PM
To: >
Subject: Fwd: City Council Meeting - August 11, 2026
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From: City of San Ramon <[email protected]> Date: Fri, Aug 7, 2026 at 5:07 PM
Subject: City Council Meeting - August 11, 2026
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City of San Ramon | 7000 Bollinger Canyon Road, San Ramon, CA 94583 | (925) 973-2500 | www.sanramon.ca.gov Brian Swanson >
Public Comment: Agenda Item 5.5 — Request to Pull Consent Agenda Item 5.5; Inadequate CEQA Exemption Record for San Ramon ITS and Communications Infrastructure Project for the U.S. Department of Housing and Urban Development (HUD) Community Planning and Development (CPD) Community Project Funding (CPF) Grant - City Council Meeting - July 14, 2026 1 message
Brian Swanson >
To: Clerk City <[email protected]> Mon, Jul 13, 2026 at 11:31 AM City Council:
Please accept this written public comment for the July 14, 2026 City Council meeting, Agenda Item 5.5, Resolution No. 2026-098, concerning the San Ramon Intelligent Transportation System ("ITS") and Communications Infrastructure Project.
I respectfully request that Agenda Item 5.5 be removed from the Consent Calendar for separate discussion. This item should not be approved as a routine consent item because the record raises unresolved questions regarding: (1) the City's California Environmental Quality Act ("CEQA") exemption determination; (2) the relationship between the federal National Environmental Policy Act ("NEPA")/U.S. Department of Housing and Urban Development ("HUD") environmental review and the City's separate CEQA obligations; (3) the validity, timing, and delegated authority for the May 20, 2026 Notice of Exemption ("NOE"); (4) the adequacy of the City's analysis of vehicle miles traveled ("VMT"), transportation throughput, vehicle speeds, public safety, and cumulative transportation impacts; and (5) the City's failure to evaluate the project against its own Updated Climate Action Plan ("CAP") and CEQA Greenhouse Gas ("GHG") Emissions Thresholds and Guidance Report.
The issue is not whether replacing aging traffic signal communications infrastructure may be useful. The issue is whether the City has made a legally adequate CEQA determination supported by substantial evidence before proceeding with a project that is expressly intended to support expansion of the City's smart traffic signal system, improved automated license plate reader ("ALPR") connections, high-speed public facility communications, continuation of autonomous vehicle testing on public roadways, and other public uses. The City's own project description characterizes the project in those operational terms.
I. Requested City Council Action
I respectfully request that the City Council:
1. Pull Agenda Item 5.5 from the Consent Calendar for separate discussion.
2. Clarify whether the Council is making any CEQA determination tonight, or only authorizing the Mayor to execute the HUD/NEPA document.
3. Identify the project approval date supporting the City's May 20, 2026 NOE filing. 8/11/26, 8:12 AM Gmail - Public Comment: Agenda Item 5.5 — Request to Pull Consent Agenda Item 5.5; Inadequate CEQA Exemption Record for S… https://mail.google.com/mail/u/0/?ik=73ed25eff8&view=pt&search=all&permthid=thread-a:r-5315867113090780905%7Cmsg-a:r-7563245275623673… 1/12
4. Identify the City official or body that made the CEQA exemption determination and the legal authority or delegation supporting that action.
5. Clarify whether Deborah Fehr, as Senior Civil Engineer/Project Manager, was authorized to make and file the CEQA exemption determination on behalf of the City as lead agency, identify the source of that delegated authority, and identify the City action that constituted project approval before the May 20, 2026 Notice of Exemption filing.
6. Direct staff to prepare a corrected CEQA record addressing:
· CEQA Guidelines sections 15301(c), 15302(c), 15303(d), and 15304(f); · the exceptions to categorical exemptions under CEQA Guidelines section 15300.2; · VMT and transportation impacts under CEQA Guidelines section 15064.3; · induced or redistributed vehicle demand;
· increased throughput;
· signal progression;
· changed vehicle speeds;
· public safety;
· pedestrian, bicycle, transit, school, senior, disabled-user, and emergency-response effects; · cumulative transportation effects from approved, pending, and reasonably foreseeable Bishop Ranch, City Center, Chevron Park, Camino Ramon, Crow Canyon, Bollinger Canyon, San Ramon Valley Boulevard, and I-680 access area projects;
· whether the project involves negligible or no expansion of existing or former use; · whether the project involves negligible or no expansion of capacity; · whether Class 3 and Class 4 cover only construction components or the full operational ITS project.
7. Direct staff to evaluate the project against the City's CAP and CEQA GHG Emissions Thresholds and Guidance Report, including any applicable CAP consistency checklist, transportation-sector assumptions, the VMT/GHG relationship, and the quantitative threshold pathway, where applicable.
8. Withdraw and re-file the NOE, if necessary, after a valid project approval and an adequate CEQA exemption determination.
II. CEQA Applies; the Issue Is Whether the Claimed Exemptions Are Valid This project constitutes a CEQA project unless a statutory or categorical exemption applies. The existence of a claimed exemption does not eliminate CEQA obligations; it requires the lead agency to establish that the project qualifies for the exemption and that no exception to the exemption applies. A categorical exemption is not the absence of CEQA; it is a CEQA compliance pathway that requires the lead agency to determine that the project fits within the claimed exemption and that no exception to the exemption applies.
Public Resources Code section 21065 defines a CEQA "project" to include an activity that may cause a direct or reasonably foreseeable indirect physical change in the environment, and that is directly undertaken by a public agency or supported by public agency contracts, grants, subsidies, loans, or similar assistance. This ITS and Communications Infrastructure Project is a City public works and transportation infrastructure project, supported by a $2 million HUD Community Project Funding grant, involving physical work in public rights-of-way and reasonably foreseeable operational transportation effects.
The City's own record confirms that CEQA applies. The staff report includes a "CEQA Compliance" section stating that staff filed an NOE with the Contra Costa County Clerk on May 20, 2026, and that the project is exempt under CEQA Guidelines sections 15301(c), 15302(c), 15303(d), and 15304(f). The County-filed NOE likewise identifies the project as categorically exempt and includes a Verdantas memorandum titled "CEQA Notice of Exemption: Memorandum of Findings."
The City therefore cannot treat CEQA as irrelevant. The question is whether the City's exemption record is legally sufficient.
III. The City Should Not Conflate HUD/NEPA Review With CEQA Compliance Agenda Item 5.5 is primarily framed as a HUD/NEPA action. The staff report states that HUD-funded projects are subject to NEPA and HUD's NEPA-implementing regulations, that the NEPA environmental review was uploaded to HUD's Environmental Review Online System (HEROS), and that the project was "converted to exempt" in HEROS. The recommended action is to authorize the Mayor to execute the HUD "Environmental Review for Activity/Project that is Categorically Excluded Subject to Section 58.5."
That is a federal environmental review action. It does not, by itself, constitute the City's CEQA determination. The City separately prepared and filed a CEQA Notice of Exemption and relied on a Verdantas CEQA memorandum; however, the 8/11/26, 8:12 AM Gmail - Public Comment: Agenda Item 5.5 — Request to Pull Consent Agenda Item 5.5; Inadequate CEQA Exemption Record for S… https://mail.google.com/mail/u/0/?ik=73ed25eff8&view=pt&search=all&permthid=thread-a:r-5315867113090780905%7Cmsg-a:r-7563245275623673… 2/12 administrative record should clearly distinguish the federal HUD/NEPA determination from the separate California CEQA determination and identify the City action, authority, and substantial evidence supporting the CEQA exemption decision.
The HUD environmental review package evaluates the project under 24 C.F.R. Part 58 and federal laws and authorities, including airport hazards, flood insurance, Clean Air Act conformity, contamination and toxic substances, endangered species, explosive and flammable hazards, farmland protection, floodplain management, historic preservation, noise, sole-source aquifers, wetlands, and wild and scenic rivers. Those federal compliance factors do not substitute for the City's obligation to determine whether the California CEQA categorical exemptions apply, whether any CEQA Guidelines section 15300.2 exception applies, or whether VMT and transportation effects have been adequately addressed.
The HUD package itself confirms this federal orientation. It identifies the project as categorically excluded under 24 C.F.R. section 58.35(a), subject to federal laws and authorities, and converted to exempt under 24 C.F.R. section 58.34(a) (12) because no mitigation, formal permit, or license is required under those federal authorities. That federal conclusion does not answer CEQA's separate questions about categorical exemptions, VMT, cumulative impacts, unusual circumstances, or GHG consistency.
CEQA is intended to inform government decision makers and the public about the potential environmental effects of proposed activities and to prevent significant, avoidable environmental damage. NEPA/HUD compliance may be required to preserve HUD grant funding, but it does not replace CEQA. The City's staff report provides substantially more discussion of the federal HUD/NEPA environmental review pathway than the separate CEQA exemption determination.
The CEQA discussion should therefore be evaluated independently to ensure that the record contains substantial evidence supporting the claimed CEQA exemptions. That is not adequate for a project whose own description includes smart-signal expansion, ALPR connections, autonomous vehicle testing support, and citywide communications functions.
IV. Resolution No. 2026-098 Does Not Appear to Make a CEQA Determination Resolution No. 2026-098 appears primarily intended to authorize the Mayor's execution of the HUD/NEPA environmental review document rather than to adopt a new CEQA exemption determination. The resolution recites the HUD grant, NEPA compliance requirements, HEROS process, Programmatic Categorical Exclusion, and the need for the Mayor's signature on the federal environmental review document.
The existence of a CEQA Notice of Exemption and Verdantas CEQA memorandum confirms that the City undertook a separate CEQA exemption pathway. The unresolved issue is whether the administrative record clearly identifies the City action that approved the project for CEQA purposes, the official authority under which the exemption determination was made, and the substantial evidence supporting that determination before the May 20, 2026 NOE filing.
The record, therefore, raises questions regarding its timing, authority, and clarity. The County-filed NOE reflects a May 20, 2026 filing date and identifies Deborah Fehr as the City contact and project manager. The Verdantas CEQA memorandum, dated May 13, 2026, states that the City, as the lead agency, determined the project was categorically exempt. The City should identify the administrative action that constituted project approval before the NOE filing, the delegation or authorization allowing staff to make the CEQA determination, and the record supporting that determination.
The Council should identify what City action constituted project approval before the May 20 NOE filing. If the project was approved by staff, the City should identify the delegated authority. If a prior Capital Improvement Plan (CIP) budget action approved the project, the City should identify the approval date and explain whether that action included or relied upon the CEQA exemption determination. If the project was not approved before the NOE was filed, the City should explain how the NOE complied with CEQA Guidelines section 15062.
The City Council should also identify whether tonight's action is:
a HUD/NEPA signature authorization only;
a CEQA approval;
a project approval;
a ratification of a prior CEQA determination;
or all of the above.
The present agenda packet does not make that clear.
V. The Verdantas CEQA Memorandum Exists, But the City Must Demonstrate That It Supports the City's Exemption Determination
The County-filed materials include a Verdantas "CEQA Notice of Exemption: Memorandum of Findings" dated May 13, 2026. That memorandum states that the project is exempt under Classes 1, 2, 3, and 4. It also states that the City has determined the project would not result in a significant adverse impact and that none of the exceptions under CEQA Guidelines section 15300.2 apply.
8/11/26, 8:12 AM Gmail - Public Comment: Agenda Item 5.5 — Request to Pull Consent Agenda Item 5.5; Inadequate CEQA Exemption Record for S… https://mail.google.com/mail/u/0/?ik=73ed25eff8&view=pt&search=all&permthid=thread-a:r-5315867113090780905%7Cmsg-a:r-7563245275623673… 3/12 The existence of a CEQA memorandum does not end the issue. The question is whether the memorandum provides substantial evidence supporting each claimed exemption, whether the City relied upon that memorandum through an authorized CEQA decision process, and whether the administrative record clearly demonstrates that the exemption determination preceded the NOE filing.
The memorandum is inadequate because it treats the project primarily as replacement or modernization of physical communications infrastructure within existing public rights-of-way. That is an incomplete description of the project's environmental function. The project description states that the project will remove existing copper signal interconnect cable, upgrade pull boxes, install new conduit, install 288-strand fiber optic cable, and upgrade network equipment to accommodate fiber optic cable. It also states that the project's goal is to replace antiquated traffic signal communication infrastructure with a publicly owned comprehensive fiber optic network allowing expansion of the City's smart traffic signal system, improved ALPR connections, secure high-speed internet connections to public facilities, continuation of autonomous vehicle testing on public roadways, and many other public uses.
The CEQA memorandum does not meaningfully analyze the operational transportation consequences of that system.
VI. The Class 1 Existing Facilities Exemption Is Not Adequately Supported The City relies on CEQA Guidelines section 15301(c), the Class 1 Existing Facilities exemption. Class 1 applies to operation, repair, maintenance, permitting, leasing, licensing, or minor alteration of existing facilities involving negligible or no expansion of existing or former use; the key consideration is whether the project involves negligible or no expansion of use. (Justia)
The Verdantas memorandum concludes that the project does not entail an expansion of existing use because it renovates existing facilities, brings them up to modern standards, and does not substantially expand the physical size or scale of installations located in the public right-of-way.
That analysis is too narrow.
For an ITS project, "use" cannot be reduced to the physical size of pull boxes, conduit, or fiber. The relevant use includes the operational function of the traffic signal communications system. A project that replaces copper interconnect cable with 288-strand fiber, fills system gaps, upgrades network equipment, expands smart-signal capability, improves ALPR connections, and supports autonomous vehicle testing may change the nature or degree of the facility's use even if the physical construction footprint is mostly within existing rights-of-way.
The California Supreme Court's decision in Sunflower Alliance v. Department of Conservation provides important guidance regarding interpretation of the Class 1 "negligible or no expansion of existing or former use" standard, emphasizing that the analysis concerns the nature and scope of the proposed use rather than merely the degree of environmental harm or physical alteration. (Justia)
The City's CEQA memorandum does not apply that framework. It focuses on the physical footprint and construction disturbance, not on changes in operational function. The City should provide additional substantial evidence explaining why replacing the copper traffic-signal interconnect infrastructure with a comprehensive fiber optic network supporting smart signals, ALPR connections, autonomous vehicle testing support, and other public uses constitutes a negligible or no expansion of existing or former use. The issue is not the physical size of the improvements alone; it is whether the operational function and capacity of the transportation communications system remain within the scope of the existing use contemplated by CEQA Guidelines section 15301(c).
VII. The Class 2 Replacement or Reconstruction Exemption Is Not Adequately Supported The City also relies on CEQA Guidelines section 15302(c), the Class 2 Replacement or Reconstruction exemption. Class 2 applies to the replacement or reconstruction of existing utility systems or facilities that involve negligible or no expansion of capacity.
The Verdantas memorandum states that the project serves substantially the same purpose and capacity as the infrastructure being replaced. But the same memorandum acknowledges that the project would install new conduit, pull boxes, fiber optic cable, required ancillary components where system gaps exist, 288-strand fiber optic cable, and upgraded network equipment. The staff report likewise describes the project as a Citywide ITS Upgrade Project and identifies its purpose as expanding smart traffic signal capabilities and improving communications infrastructure.
The City has not adequately explained what "capacity" means for a traffic signal communications and ITS system.
Capacity for this project may include:
communications bandwidth;
8/11/26, 8:12 AM Gmail - Public Comment: Agenda Item 5.5 — Request to Pull Consent Agenda Item 5.5; Inadequate CEQA Exemption Record for S… https://mail.google.com/mail/u/0/?ik=73ed25eff8&view=pt&search=all&permthid=thread-a:r-5315867113090780905%7Cmsg-a:r-7563245275623673… 4/12 number of connected intersections or devices;
signal coordination capability;
real-time traffic management capability;
network reliability and redundancy;
ability to support ALPR connections;
ability to support autonomous vehicle testing;
ability to support active traffic management;
ability to improve signal progression;
ability to increase effective vehicle throughput;
ability to support additional traffic cameras, sensors, or connected devices.
The City should identify the baseline operational capability of the existing traffic signal communications system and compare it with that of the proposed fiber optic network. Without that comparison, the record does not clearly establish whether the project represents replacement within existing capacity or an expansion of system capability.
The CEQA memorandum does not compare the existing copper signal interconnect system to the proposed 288-strand fiber optic system in terms of operational capacity. Without that comparison, the Class 2 exemption is not adequately supported.
VIII. The Class 3 and Class 4 Exemptions Do Not Address the Full Operational Project The City also relies on Class 3 and Class 4. Class 3 covers certain limited new construction of small structures and utility extensions; Class 4 covers minor alterations to land, including minor trenching and backfilling where the surface is restored. The City's memorandum relies on those exemptions for the installation of conduit, pull boxes, fiber optic cable, network equipment, and localized trenching.
Those exemptions may address discrete construction components. They do not automatically exempt the full operational ITS project that those components enable.
The project spans approximately 2 miles of Crow Canyon Road, 1.4 miles of Camino Ramon, and 2.9 miles of San Ramon Valley Boulevard, for roughly 6.3 corridor miles. It is not merely a single utility extension or isolated trenching activity. It is a multi-corridor traffic signal communications and ITS backbone project that the City says will enable smart signal expansion, ALPR connectivity, high-speed public-facility communications, autonomous vehicle testing, and other public uses.
The City should clarify whether Classes 3 and 4 are being used only for physical construction components, or whether the City is using those construction-related exemptions to exempt the full operational project. If the latter, the record is inadequate.
IX. VMT and Transportation Effects Are Missing or Inadequately Addressed CEQA Guidelines section 15064.3 provides that VMT is generally the most appropriate measure of transportation impacts. For transportation projects, projects that reduce or have no impact on VMT should be presumed less than significant. At the same time, agencies must analyze roadway capacity projects under an appropriate transportation impact measure consistent with CEQA. The regulation also recognizes that effects on transit and non-motorized travel may be relevant, and that assumptions used to estimate VMT should be documented and explained. (Legal Information Institute)
The City's CEQA memorandum does not evaluate whether the project's operational characteristics raise transportationrelated considerations under CEQA Guidelines section 15064.3, nor does it explain why VMT-related assumptions, travel behavior, or transportation system effects are not relevant to the exemption determination.
It does not explain whether the ITS project will:
reduce VMT;
have no impact on VMT;
increase effective vehicle throughput in a way that could increase VMT; change route choice;
change trip timing;
change trip lengths;
change signal progression;
increase effective corridor capacity;
alter vehicle speeds;
affect pedestrian, bicycle, or transit operations;
affect safety for non-motorized users;
8/11/26, 8:12 AM Gmail - Public Comment: Agenda Item 5.5 — Request to Pull Consent Agenda Item 5.5; Inadequate CEQA Exemption Record for S… https://mail.google.com/mail/u/0/?ik=73ed25eff8&view=pt&search=all&permthid=thread-a:r-5315867113090780905%7Cmsg-a:r-7563245275623673… 5/12 interact with approved and foreseeable development in the same corridors.
The HUD/NEPA package does not fill that gap. The HUD review includes federal air quality, historic preservation, floodplain, noise, contamination, wetlands, and related federal compliance screens. It does not provide a CEQA VMT analysis under CEQA Guidelines section 15064.3. That is especially important because the project's purpose is tied to traffic signal communication, smart traffic signal expansion, support for autonomous vehicle testing, and active transportation system management.
VMT is not evaluated through the NEPA/HUD checklist in this record. It is a CEQA transportation-impact consideration that must be evaluated within the context of the project's actual operational purpose and reasonably foreseeable effects.
The City should not treat the HUD/HEROS conversion-to-exempt status as a substitute for a CEQA analysis of whether this ITS project's operational functions may affect transportation conditions, VMT assumptions, travel behavior, or related environmental effects.
The issue is not whether every Intelligent Transportation System project necessarily requires a standalone VMT analysis.
Rather, the issue is whether the City has provided substantial evidence supporting its conclusion that this specific project — which is intended to expand smart traffic signal capabilities, improve transportation communications, support connected and autonomous vehicle testing, and enhance active traffic management capabilities — will not result in transportation-related environmental effects requiring further consideration under CEQA Guidelines section 15064.3.
The City should therefore explain whether and how the project's operational characteristics affect, or do not affect:
· VMT assumptions underlying the General Plan 2040 Environmental Impact Report (EIR), CAP, and CEQA GHG Thresholds Report;
· vehicle throughput and effective corridor capacity;
· route choice and travel behavior;
· signal progression and vehicle speeds;
· pedestrian, bicycle, transit, school, senior, and disabled-user conditions; · emergency response operations; and
· cumulative transportation conditions associated with approved and reasonably foreseeable development within the affected corridors.
Without that analysis, the CEQA record evaluates the physical installation of infrastructure while failing to address the operational transportation functions that the completed ITS system is specifically intended to enhance.
X. Increased Throughput, Signal Progression, Vehicle Speeds, and Public Safety Were Not Adequately Evaluated
The project is an Intelligent Transportation System project. Its stated purpose includes expansion of the City's smart traffic signal system and improved communications for public infrastructure.
Coordinated signals and upgraded traffic communications may improve operations. But operational efficiency is not automatically environmentally neutral. Signal coordination and active traffic management can:
increase vehicle throughput;
increase effective corridor capacity;
stabilize or increase vehicle speeds;
change platooning;
affect left-turn and side-street gaps;
reduce crossing opportunities for pedestrians and bicyclists; change pedestrian and bicycle exposure at crossings;
affect school, senior, disabled user, and transit user safety; shift traffic from parallel routes;
interact with freeway access and ramp operations;
affect emergency response movement.
The CEQA memorandum does not address these issues. It states that the project supports General Plan 2040 and ITS Master Plan goals for smart traffic engineering, connected and autonomous vehicle support, active traffic management, and freeway operations. Still, it treats those as planning-consistency points rather than as operational changes that require environmental analysis.
Automobile delay itself is no longer the CEQA transportation-impact metric. But that does not mean changes to the transportation system disappear from CEQA. VMT, transit effects, non-motorized travel, public safety, speeds, and cumulative transportation conditions remain relevant where supported by the project record. 8/11/26, 8:12 AM Gmail - Public Comment: Agenda Item 5.5 — Request to Pull Consent Agenda Item 5.5; Inadequate CEQA Exemption Record for S… https://mail.google.com/mail/u/0/?ik=73ed25eff8&view=pt&search=all&permthid=thread-a:r-5315867113090780905%7Cmsg-a:r-7563245275623673… 6/12 The City should analyze whether the ITS project affects vehicle speeds, signal progression, throughput, conflict exposure, pedestrian/bicycle crossing conditions, or other public safety conditions along Crow Canyon Road, Camino Ramon, and San Ramon Valley Boulevard.
XI. The Cumulative Impact Analysis Is Woefully Inadequate CEQA Guidelines section 15300.2(b) provides that categorical exemptions are inapplicable when the cumulative impact of successive projects of the same type in the same place over time is significant. Section 15300.2(c) also prevents use of a categorical exemption where there is a reasonable possibility of a significant effect due to unusual circumstances. (Legal Information Institute)
The Verdantas memorandum acknowledges the cumulative-impact exception but does not conduct a meaningful cumulative impact analysis. Instead, it relies heavily on consistency across the General Plan 2040 Traffic and Circulation Element, ITS Master Plan integration, fiber optic network expansion, traffic cameras, Internet of Things devices, smart traffic engineering, connected and autonomous vehicle support, active traffic management, freeway operations, and CIP consistency. It then concludes that the annual review and approval of the CIP, including this project, ensure consistency with the General Plan 2040 and therefore "avoids any potential for adverse cumulative impacts." That is not a cumulative impact analysis. It is a consistency assertion. Consistency with adopted planning documents may inform a CEQA analysis. Still, it does not replace project-specific evaluation of whether the project contributes to significant cumulative effects or whether a categorical exemption exception applies.
A project may be consistent with the General Plan 2040, ITS Master Plan, and Capital Improvement Program and still contribute to cumulative transportation impacts on VMT, throughput, speed, safety, or multimodal impacts. Consistency with a plan does not automatically establish that no CEQA Guidelines section 15300.2 exception applies.
The cumulative analysis is also too narrow. It should not be limited to successive ITS, signal coordination, fiber, communications, roadway, and transportation projects. Those projects matter, but they are not the whole cumulative setting.
The City must also evaluate the approved, pending, and reasonably foreseeable development projects that will use the same transportation network, affect the same intersections and corridors, and rely on the same traffic, VMT, signal timing, throughput, public-safety, and circulation assumptions.
That includes the broader Bishop Ranch/City Center/Chevron Park growth context, including but not limited to:
approved Bishop Ranch and City Center projects;
the Orchards/Chevron Park redevelopment;
BR-7 and BR-11;
BR-8/Canopy;
BR-12/Annabel;
the Bishop Ranch affordable housing/service center project; CityWalk/Bishop Ranch redevelopment concepts;
DMU-N zoning and floor-area-ratio changes;
parking reductions and exceptions;
cumulative development along Camino Ramon, Crow Canyon Road, Bollinger Canyon Road, San Ramon Valley Boulevard, and I-680 access routes;
future projects identified in the General Plan 2040, CIP, ITS Master Plan, specific plans, or related planning documents;
reasonably foreseeable projects affecting the same intersections, signal systems, crossings, sidewalks, bicycle facilities, transit stops, and emergency response routes.
The cumulative transportation setting is the network into which all of these projects feed. The ITS project may increase system efficiency, signal coordination, throughput, and active traffic management at the same time the City is approving substantial development in the Bishop Ranch/City Center/Chevron Park area.
A meaningful cumulative analysis should ask whether this ITS project, together with approved and reasonably foreseeable development and transportation projects, may:
increase vehicle throughput;
increase effective corridor capacity;
improve signal progression in a way that changes route choice or trip timing; induce or redistribute vehicle demand;
increase or stabilize vehicle speeds;
8/11/26, 8:12 AM Gmail - Public Comment: Agenda Item 5.5 — Request to Pull Consent Agenda Item 5.5; Inadequate CEQA Exemption Record for S… https://mail.google.com/mail/u/0/?ik=73ed25eff8&view=pt&search=all&permthid=thread-a:r-5315867113090780905%7Cmsg-a:r-7563245275623673… 7/12 change VMT or trip length;
affect pedestrian and bicycle exposure;
affect school, senior, disabled user, and transit user safety; affect emergency response movements;
affect transit operations;
compound transportation impacts from nearby housing and mixed-use approvals; rely on stale or generalized assumptions from the General Plan 2040 EIR rather than on current conditions.
The CEQA memorandum does not do that work.
XII. The General Plan 2040 EIR Statement of Overriding Considerations Undermines the City's Conclusory Cumulative-Impact Reasoning
The City's CEQA memorandum relies on consistency with the General Plan 2040 and CIP to dismiss cumulative impacts.
But the City's own General Plan 2040 page states that on December 12, 2023, the City Council adopted Resolution No. 2023-132, which adopted CEQA Findings and a Statement of Overriding Considerations, and certified the Final EIR for the San Ramon General Plan 2040 Project, related applications, and the Mitigation Monitoring and Reporting Program. (San Ramon)
That prior Statement of Overriding Considerations cannot be used as a substitute for project-specific analysis or as a basis to assume that later transportation system projects are automatically within the scope of prior environmental conclusions. A Statement of Overriding Considerations is not a finding that impacts do not exist. Rather, it is adopted when significant environmental effects remain after consideration of feasible mitigation measures, and the agency determines that the project benefits warrant approval despite those remaining impacts.
Nor does the existence of a prior Statement of Overriding Considerations automatically require additional CEQA review for every subsequent activity. Rather, where a later project relies upon the same transportation-system assumptions, planning documents, and cumulative growth context, the agency should explain why the prior environmental conclusions remain applicable and why the later activity qualifies for the claimed exemption.
If the General Plan 2040 EIR identified significant and unavoidable transportation, circulation, or VMT impacts, then General Plan 2040 consistency alone does not establish that later transportation system projects are exempt from further consideration. Instead, the City should explain whether the later activity remains within the assumptions, mitigation framework, and cumulative conditions evaluated in the prior program-level analysis. It underscores the need for later analysis, especially where the subsequent project implements transportation-system technology, smart signal coordination, active traffic management, freeway operations, fiber optic network expansion, and connected/autonomous vehicle support.
The City should not rely on General Plan 2040 and ITS Master Plan consistency as both:
1. the policy basis for expanding smart signal, active traffic management, fiber optic communications, and connected/autonomous vehicle support; and
2. the reason no cumulative transportation analysis is needed.
Such reasoning would create an internal inconsistency in the administrative record: the City relies on transportation system expansion objectives to justify the project's purpose, while simultaneously relying on those same objectives as evidence that expanded transportation system effects do not require further analysis.
If the City intends to rely on the General Plan 2040 EIR or ITS Master Plan as context for this project, it should explain whether this later ITS project:
implements or extends transportation-system improvements assumed in the General Plan 2040 EIR; contributes to impacts previously found significant and unavoidable; changes corridor throughput, signal progression, speed, route choice, or VMT; interacts with approved and foreseeable Bishop Ranch/City Center/Chevron Park growth; remains within the scope of prior program-level analysis; requires additional project-level analysis before the City may rely on categorical exemptions.
CEQA Guidelines section 15168 provides that whether a later activity is within the scope of a program EIR is a factual question based on substantial evidence in the record. The City's current CEQA memo does not appear to make that factual showing. It instead treats General Plan 2040 and CIP consistency as the conclusion.
XIII. The City Must Also Evaluate the Project Against the CAP and CEQA GHG Thresholds Report 8/11/26, 8:12 AM Gmail - Public Comment: Agenda Item 5.5 — Request to Pull Consent Agenda Item 5.5; Inadequate CEQA Exemption Record for S… https://mail.google.com/mail/u/0/?ik=73ed25eff8&view=pt&search=all&permthid=thread-a:r-5315867113090780905%7Cmsg-a:r-7563245275623673… 8/12 The City's CEQA memorandum relies on consistency with the General Plan 2040 and the Capital Improvement Program to dismiss cumulative impacts. It also invokes the General Plan 2040 Traffic and Circulation Element, the ITS Master Plan, smart traffic engineering, support for connected and autonomous vehicles, active traffic management, fiber optic network expansion, traffic cameras, Internet of Things devices, freeway operations, and "Sustainability & Smart City" policies.
That reliance creates an additional omission: the City does not appear to evaluate the ITS and Communications Infrastructure Project against the City's CAP and CEQA GHG Emissions Thresholds and Guidance Report.
That omission matters because the City adopted the CAP and CEQA GHG Emissions Thresholds and Guidance Report on June 10, 2025, by Resolution No. 2025-073, effective immediately, replacing the 2011 CAP. The City describes the CAP as the primary implementation strategy of the San Ramon General Plan 2040 for establishing a long-term GHG reduction strategy consistent with State GHG reduction targets for 2030 and 2045. (San Ramon) CEQA Guidelines section 15064.4 provides that a lead agency shall make a good-faith effort, to the extent possible, based on scientific and factual data, to describe, calculate, or estimate project GHG emissions. CEQA Guidelines section 15183.5 provides a framework for GHG reduction plans, including quantification of emissions, substantial-evidence-based reduction levels, measures or performance standards, monitoring, and amendment mechanisms. (Legal Information Institute)
The City's own CEQA GHG Thresholds Report states that CEQA requires discretionary plans and projects to undergo environmental review that includes evaluation of plan- or project-related GHG emissions, and that CEQA Guidelines section 15183.5 establishes a framework for qualified GHG reduction plans that cumulatively reduce GHG emissions and allow lead agencies to analyze and mitigate plan- and project-level GHG emissions. (Plan San Ramon) The ITS project is not merely a neutral administrative or paperwork item. The project description states that the project would replace antiquated traffic signal communication infrastructure with a publicly owned fiber optic network, enabling expansion of the City's smart traffic signal system, improved ALPR connections, secure, high-speed internet connections to public facilities, the continuation of autonomous vehicle testing on public roadways, and other public uses. The Countyfiled CEQA memorandum similarly describes the installation of 288-strand fiber optic cable, the upgrade of network equipment, and the modernization of traffic signal and communications infrastructure.
Those operational features may have implications for GHG emissions in the transportation sector. Signal coordination and active traffic management may reduce idling in some circumstances. Still, they may also increase vehicle throughput, stabilize or increase travel speeds, change route choice, affect trip timing, affect mode choice, or interact with induced or redistributed demand. Those same operational issues are directly related to VMT, transportation sector emissions, and public safety.
The City's current CEQA record does not explain how the project relates to the City's own adopted CAP and CEQA GHG Thresholds framework, despite relying on General Plan 2040 policies, ITS Master Plan objectives, smart-city strategies, sustainability objectives, and transportation-system improvements to support the exemption determination.
This comment does not suggest that every categorically exempt project requires a separate GHG analysis or CAP consistency checklist. Rather, where a lead agency relies upon adopted climate policies, transportation-system strategies, smart-city objectives, or General Plan consistency as evidence supporting a CEQA exemption determination, the administrative record should explain how the project relates to the City's adopted climate framework and whether the operational assumptions underlying those policies remain valid.
The ITS project presents precisely that question. The City describes the project as enabling expansion of the smart traffic signal system, improved ALPR connections, secure high-speed public facility communications, continued autonomous vehicle testing, and other public uses. Those operational changes may provide benefits, including reduced delay or improved efficiency. Still, they may also affect vehicle throughput, travel speeds, route choice, travel behavior, VMT assumptions, and transportation sector GHG emissions.
The City should therefore explain whether the project:
· implements a CAP transportation sector measure;
· relies upon transportation or VMT assumptions incorporated into the CAP or CEQA GHG Thresholds Report;
· reduces or increases transportation-sector GHG emissions; · changes transportation demand, travel behavior, or operational conditions in a manner relevant to CAP implementation; and
· remains consistent with the assumptions supporting the City's adopted climate strategy. 8/11/26, 8:12 AM Gmail - Public Comment: Agenda Item 5.5 — Request to Pull Consent Agenda Item 5.5; Inadequate CEQA Exemption Record for S… https://mail.google.com/mail/u/0/?ik=73ed25eff8&view=pt&search=all&permthid=thread-a:r-5315867113090780905%7Cmsg-a:r-7563245275623673… 9/12 The City should not rely upon the CAP, General Plan 2040, ITS Master Plan, and sustainability policies as affirmative evidence supporting a CEQA exemption determination while omitting discussion of whether the project remains consistent with the City's adopted CAP/GHG assumptions and implementation framework. If the project is exempt, the City should explain why the exemption remains valid after considering the City's own CAP/GHG framework. If the City relies on CAP/GHG consistency to support that there is no significant GHG or cumulative impact, the record must contain the consistency analysis and substantial evidence supporting it.
The present record does not clearly demonstrate that analysis. It relies on consistency with the General Plan 2040 and CIP, invokes smart-city and sustainability objectives, and concludes that there are no cumulative impacts without evaluating the City's own adopted CAP/GHG Thresholds Report. That is not an adequate CEQA record for a project whose purpose is to expand smart signals, fiber optic, transportation communications, and roadway operational capabilities.
The issue is therefore not whether the ITS project is beneficial or whether improved communications infrastructure may support climate objectives. The issue is whether the City has demonstrated, through substantial evidence, that the operational consequences of this transportation-system investment are consistent with the same VMT, GHG, and implementation assumptions that the City relies upon elsewhere in its planning and regulatory framework.
XIV. The Significant Effect/Unusual Circumstances Analysis Is Conclusory The Verdantas memorandum states that there are no unusual circumstances on or next to the project site and that no unusual circumstances are anticipated with construction. It also states that nearby sensitive receptors include residential homes adjacent to San Ramon Valley Boulevard, but that construction and operation would not create unusual circumstances resulting in significant environmental impacts.
That analysis is conclusory.
The unusual circumstance is not merely the presence or absence of sensitive receptors. The unusual circumstance is that this project is not simply small-scale underground utility maintenance. It is a multi-corridor ITS communications backbone supporting smart traffic signals, active traffic management, ALPR connections, autonomous vehicle testing, and other public uses.
The City should analyze whether those operational functions create a reasonable possibility of significant effects related to VMT, throughput, vehicle speeds, public safety, pedestrian/bicycle exposure, transit operations, emergency response, GHG emissions, or cumulative transportation conditions.
XV. The Scenic Highway and Hazardous Materials Discussions Do Not Cure the Transportation and GHG Defects
The Verdantas memorandum recognizes that a portion of the project would occur along San Ramon Valley Boulevard, adjacent to Interstate 680, an officially designated State Scenic Highway, but dismisses the issue because the improvements are primarily subterranean and would not affect the visual character after completion.
That may address part of the scenic-highway exception, but it does not address transportation operations, VMT, throughput, speed, safety, or GHG implications.
The memorandum also identifies the Department of Toxic Substances Control Soil Management Agreement for aerially deposited lead-contaminated soils and notes that the Electro Test Inc. site, located approximately 0.2 miles north of Crow Canyon Road, is listed on EnviroStor. The City may be able to manage those issues through construction specifications and monitoring. Still, the memorandum does not explain how those controls will be incorporated into project plans, specifications, contracts, or construction oversight. That is an implementation issue, separate from the missing transportation and CAP/GHG analysis.
Neither the scenic highway discussion nor the hazardous materials discussion cures the absence of meaningful VMT, throughput, speed, safety, cumulative transportation, and CAP/GHG analysis.
XVI. The Agenda's Generic CEQA Disclaimer Is Not a Substitute for Item-Specific CEQA Review The first page of the agenda states that unless otherwise stated, every item on the agenda is exempt from CEQA Guidelines sections 15060(c), 15061(b)(3), 15273, 15378, 15301, 15323, and/or Public Resources Code section 21065.
That generic agenda language is not an item-specific CEQA determination.
For Agenda Item 5.5, the staff report separately relies on CEQA Guidelines sections 15301(c), 15302(c), 15303(d), and 15304(f). The City cannot rely on generic agenda boilerplate, NEPA/HUD forms, or a conclusory CEQA memorandum to 8/11/26, 8:12 AM Gmail - Public Comment: Agenda Item 5.5 — Request to Pull Consent Agenda Item 5.5; Inadequate CEQA Exemption Record for S… https://mail.google.com/mail/u/0/?ik=73ed25eff8&view=pt&search=all&permthid=thread-a:r-5315867113090780905%7Cmsg-a:r-756324527562367… 10/12 support a categorical exemption for a multi-corridor ITS and communications infrastructure project.
XVII. This Item Reflects the Same CEQA Posture at Issue in Pending Matters Involving the City I recognize that the City Council is not adjudicating pending litigation through this agenda item. However, this project raises similar implementation concerns regarding CEQA process, transportation assumptions, cumulative analysis, mitigation implementation, and administrative record completeness. Agenda Item 5.5 reflects the same recurring CEQA posture that is at issue in pending matters involving the City:
reliance on abbreviated or streamlined CEQA pathways;
use of prior planning consistency as a substitute for current analysis; insufficient cumulative impact analysis;
insufficient VMT and transportation documentation;
insufficient analysis of mitigation, implementation, and monitoring; lack of integration with the City's CAP and CEQA GHG Thresholds Report; reliance on exemption paperwork without a clear Council-level CEQA finding or identified delegation.
Those concerns are directly relevant here. This project affects the same transportation system that must accommodate growth and transportation assumptions related to Bishop Ranch, City Center, Chevron Park, Camino Ramon, Crow Canyon, Bollinger Canyon, San Ramon Valley Boulevard, and I-680.
The City should not continue to treat CEQA as a form-processing exercise. CEQA exemptions are intended to provide administrative efficiency where the factual circumstances support them. They are not intended to replace project-specific analysis of operational changes, cumulative conditions, or consistency with the City's own adopted environmental and climate planning framework.
XVIII.Conclusion and Requested Action
The City may be able to pursue HUD funding and modernize traffic signal communications infrastructure. But it should not do so through an inadequate CEQA record.
Before approving Agenda Item 5.5, the City Council should clarify:
1. whether the Council is making a CEQA determination tonight;
2. whether the May 20, 2026 NOE was filed after a valid project approval;
3. whether Deborah Fehr, Public Works/Engineering Services, or Traffic Engineering had delegated authority to make and file the CEQA exemption determination, and identify the ordinance, resolution, administrative policy, or other delegation document supporting that authority;
4. whether the Verdantas CEQA memorandum adequately supports Classes 1, 2, 3, and 4;
5. whether the project involves negligible or no expansion of existing or former use under Class 1, especially after Sunflower Alliance;
6. whether the project involves negligible or no expansion of capacity under Class 2, given the 288-strand fiber, network upgrades, smart signal expansion, ALPR connections, and autonomous vehicle testing support;
7. whether Class 3 and Class 4 apply only to construction components or to the full operational ITS project;
8. whether CEQA Guidelines section 15300.2 exceptions apply;
9. whether VMT, induced or redistributed demand, signal progression, throughput, vehicle speeds, public safety, pedestrian/bicycle exposure, transit effects, and cumulative transportation effects have been adequately evaluated;
10. how the City's December 2023 General Plan 2040 EIR Findings and Statement of Overriding Considerations affect the City's ability to rely on categorical exemptions for this ITS and Communications Infrastructure Project;
11. whether the project was reviewed for consistency with the City's CAP and CEQA GHG Emissions Thresholds and Guidance Report, including the CAP consistency checklist, transportation sector assumptions, VMT/GHG relationship, and quantitative thresholds where applicable.
For these reasons, I respectfully request that the City Council pull Agenda Item 5.5 from Consent, direct staff to correct the CEQA record, and refrain from relying on the May 20, 2026 NOE unless and until the City identifies the valid project approval, delegated authority, and substantial evidence supporting the claimed exemptions.
Respectfully submitted,
Brian C. Swanson, AICP
San Ramon Resident, Voter, and Taxpayer
On Fri, Jul 10, 2026 at 5:45 PM City of San Ramon <[email protected]> wrote:
8/11/26, 8:12 AM Gmail - Public Comment: Agenda Item 5.5 — Request to Pull Consent Agenda Item 5.5; Inadequate CEQA Exemption Record for S… https://mail.google.com/mail/u/0/?ik=73ed25eff8&view=pt&search=all&permthid=thread-a:r-5315867113090780905%7Cmsg-a:r-756324527562367… 11/12 The City Council meeting will begin at 7:00 p.m. on Tuesday, July 14, 2026.
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City of San Ramon | 7000 Bollinger Canyon Road, San Ramon, CA 94583 | (925) 973 2500 | www sanramon ca gov 8/11/26, 8:12 AM Gmail - Public Comment: Agenda Item 5.5 — Request to Pull Consent Agenda Item 5.5; Inadequate CEQA Exemption Record for S… https://mail.google.com/mail/u/0/?ik=73ed25eff8&view=pt&search=all&permthid=thread-a:r-5315867113090780905%7Cmsg-a:r-756324527562367… 12/12