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III. The City Cannot Support Its Position that the Parcels Are Exempt from the Act's Requirements During a February 19, 2019 phone call with OCCORD's attorney, Ben Beach, City Attorney John Funk took the position that the Act does not apply to the Parcels because the Parcels have been held by the City "for the purpose of exchange," thereby qualifying them for the exception set forth in Cal. Gov. Code § 54221 (b). But the City's own words and deeds severely undercut this position. First, the Staff Report contravenes the idea that the Parcels were being held for the purposes of exchange. The Report makes no mention of this concept. Rather, the Report suggests the City's purposes for the Parcels can shift and have shifted: "[o]ver time, the need for these assets and interests can change, thereby creating an opportunity for their use for... purposes" [other than those for which they were originally acquired]. In this case, the Staff Report explains, the City's original purposes for holding the parcels were for "municipal operations and various improvement projects." Now, the Report states, the City proposes to sell these parcels for the purposes of revenue generation and workforce development. Nowhere in the City's recounting of its purposes for the Parcels or, indeed, in any other part of the public record is any indication that the Parcels have been held for the purpose of exchange. This is no small matter. The Surplus Land Act is the primary state law governing the sale of city -owned parcels of land. If the City intends to sell over 400,000 square feet of land and rely on a single exemption in the Act to avoid, wholesale, the application of the Act, it must establish a record that supports its position. The City has plainly not met that burden and, instead, has built a record that strongly suggests the City held the Parcels for purposes other than exchange and believed that it could freely shift its use of the Parcels. Second, there is no exception in the Act for land held for the purpose of sale, and holding the Parcels for sale does not qualify as holding land for the purpose of exchange under the Act. Several provisions of the Government Code indicate that the use of term "exchange" in the Act refers to an exchange of surplus lands for other lands, not the sale of surplus lands. See, e.g., Cal. Gov't Code § 11011(d) ("In recommending or determining the disposition of surplus lands, the Director of General Services may give priority to proposals by the state that involve the exchange of surplus lands for lands listed in those reports"); Cal. Gov't Code § 11011(f) (requiring report on disposition of surplus lands identifying "the date of sale and price received, or the value of the land received in exchange"). Indeed, the City itself has distinguished "sale" from "exchange" with regard to the disposition of other Bristol corridor parcels. In a January 15, 2019 Request for Council