12th and Imperial Station, America Plaza Station, and the Convention Center Station Digital Wayfinding

2026040216

San Diego Metropolitan Transit System (MTS)

NOE - Notice of Exemption

4/6/2026

4/6/2026

Mark Olson

San Diego Metropolitan Transit System (MTS)

Director of Marketing and Communications

Lead/Public Agency / Project Applicant

1255 Imperial Avenue Suite 1000
San Diego, CA 92101

(619) 557-4588

Mark.Olson@sdmts.com

Bill Tagliaferri

Big Outdoor Opco, LLC

PM

Project Applicant

6 E. 39th Street Suite 1200
New York, NY 10016

(914) 804-1356

bill@bigoutdoor.com

Imperial & National, W. Broadway & Kettner, First Ave between J & E Harbor Dr.

92101

12th and Imperial Station, America Plaza Station:, Convention Center Station:

Statutory Exemption

Pub. Resources Code, § 21080.25 (b)(2), (8), (9) (transportation project exemptions and criteria) Pub Resources Code, §

The Project is statutorily exempt under Public Resources Code section 21080.25, subdivision (b ), which includes projects that would improve customer information and wayfinding for transit riders (subdivision (b)(2)) and the maintenance, repair, relocation replacement, or removal of any utility infrastructure associated with these types of projects (subdivision (b)(8)). The Projects for state-of-the-art digital displays at MTS's 12th and Imperial Station, America Plaza Station, and Convention Center Station, all located within the existing MTS right-of-way. All three Project locations will provide wayfinding information, promote transit services and generate additional revenue to support public transit operations within MTS' s service area. Therefore, the Project is within the scope of projects subject to Public Resources Code section 21080.25(b)(2) and (8). In compliance with the statutory exemption criteria in Public Resources Code section 21080.25, subdivision (c), the Project would be carried out by MTS as the lead agency under CEQA by execution of a License Agreement for the construction and operation of the Project at MTS's 12th and Imperial Station, America Plaza Station, and the Convention Center Station subject to all terms and conditions therein, including a minimum of 10 percent share of display time which may be used for wayfinding and informational messaging such as transit schedules and special MTS promotions or emergency messaging, as needed, and which may not be sold to third parties and will remain for MTS's exclusive use. Therefore, MTS is carrying out the Project by executing a License Agreement for construction and operation. Although "wayfinding" is not specifically defined in State law, the San Diego Municipal Code uses the term to mean signage displayed near the public right-of-way "that directs pedestrians and cyclists· to nearby attractions and transit connections." (See SDMC § 143.1020(b)(7)(I).) Here, the Project will improve customer information and wayfinding for transit riders at MTS's 12th and Imperial Station, America Plaza Station, and the Convention Center Station by dedicating a minimum of 10 percent of display time solely for wayfinding and informational messaging such as train schedules and special transit ridership promotions and will therefore meet the legislative purpose of improving mobility and connectivity by enhancing access to transit. Further, the displays at all three Project locations will include a static MTS transit map that will not change with the digital screen copy. The transit map will provide an additional wayfinding resource to transit riders. Therefore, the Project will meet the legislative purpose of improving mobility and connectivity by enhancing access to transit. This display percentage is consistent with other digital wayfinding projects that use private advertising dollars to finance the wayfinding installation, maintenance and liability related to such devices instead of scarce public transit fare dollars, regardless of whether the wayfinding/advertising device is a smaller kiosk or a larger digital format. Additionally, the project's revenue sharing will also provide reliable revenue to MTS to continue improving its transit system in accordance with its governing laws. The Project would also be located within MTS's existing public right-of-way in the City of San Diego. Public Resources Code section 21071(a)(l) defines an "Urbanized area" as an incorporated city that has a population of at least 100,000 persons. The City of San Diego is an incorporated city that has a population of 1.3 8, million according to the United States Census Bureau. Therefore, the Project is in an urbanized area within an existing public right-of-way. The Project would not add physical infrastructure that increases new automobile capacity on existing rights-of-way except for minor modifications needed for the efficient and safe movement of transit vehicles. The Project consists of construction and operation of outdoor digital wayfinding structures and supporting structures, fixture connections, electrical supply and related equipment and accessories and will not increase new automobile capacity on existing rights-of-way. The Project is proposed to be located at MTS's 12th and Imperial Station, America Plaza Station, and the Convention Center Station. All three Project locations are located on MTS property and do not require demolition of any affordable housing units. In compliance with the statutory exemption criteria in Public Resources Code section 21080.25, subdivision {f), the Project would be constructed by a skilled and trained workforce or, alternatively, under a project labor agreement. The construction contract for the Project will include an enforceable commitment to MTS that the contractor and its subcontractors at every tier will use a skilled and trained workforce to perform all work on the project or a contract that falls within an apprenticeship occupation in the building and construction trades in accordance with Chapter 2.9 (commencing with Section 2600) of Part 1 of Division 2 of the Public Contract Code. The Project is also statutorily exempt under Public Resources Code section 21080, subdivisions (b){l0), (11) and State CEQA Guidelines section 15275, subdivision (a) as a project for the institution or increase of passenger or commuter service on rail lines or high occupancy vehicle lanes already in use, including the modernization of existing stations and parking facilities. Due to its improvement of the Project locations and addition of passenger wayfinding improvements to the existing MTS transit use, the Project falls within this statutory exemption. Additionally, the Project is categorically exempt under State CEQA Guidelines section 15303 (Class 3) because it consists of the construction and location of limited numbers of new, small facilities or structures. The Project consists of construction and operation of three outdoor wayfinding structures and supporting structures, fixture connections, electrical supply and related equipment and accessories, to be located within an urbanized area on premises not to exceed a total of 5,000 square feet. Within urbanized areas, the Class 3 categorical exemption applies by its terms to commercial structures of up to 10,000 square feet in floor area and accessory or appurtenant structures. Based on its size and location, the Project therefore falls within the Class 3 categorical exemption. State CEQA Guidelines section 15311 (Class 11) also specifically exempts construction, or replacement of minor structures accessory to (appurtenant to) existing commercial, industrial, or institutional facilities, including but not limited to on-premise signs. The Project would also fall within this exemption as construction of a sign accessory to MTS' s transit use. Finally, State CEQA Guidelines section 15332 (Class 32) applies to projects characterized as infill development that is consistent with the applicable general plan designation and policies and zoning designation and regulations; occurs within city limits on a project site of no more than five acres substantially surrounded by urban uses; is on a site with no value as habitat for endangered, rare or threatened species; would not result in any significant effects relating to traffic, noise, air quality or water quality; and is on a site that can be adequately served by all required utilities and public services. Here, the Project meets the criteria for infill development at all three locations. None of exceptions to the categorical exemptions in State CEQA Guidelines section 15300.2 applies. The Project is not located in a particularly sensitive environment as the Project is located entirely within developed areas of San Diego and all impact areas are within disturbed areas. The· cumulative impact of successive projects of the same type in the same place over time is not significant, as no similar wayfinding structures of this scale are proposed within the vicinity of the proposed wayfinding kiosks. The Project will not result in any damage to scenic resources within a highway officially designated as a state scenic highway as none of the three Project locations are located within a designated state scenic highway. The Project locations are not included on any list compiled pursuant to Section 65962.5 of the Government Code (i.e. the Cortese List). Toe Project will not cause a substantial adverse change in the significance of a historical resource.