E. Homeland Security Measures.

Under Section 6254(aa), an agency may withhold "[a] document prepared by or for a state or local agency that assesses its vulnerability to terrorist attack or other criminal acts intended to disrupt the public agency's operations and that is for distribution or consideration in a closed session. Cal. Gov't Code § 6254(aa).  Under Section 6254(ab), critical infrastructure information that is voluntarily submitted to the California Emergency Management Agency or used by that office is exempt.  No reported cases have discussed these exemptions.  But see County of Santa Clara v. Superior Court, 170 Cal. App. 4th 1301, 1316, 89 Cal. Rptr. 3d 374 (2009) (rejecting county’s argument that GIS basemap data was exempt under federal Critical Infrastructure Information Act, since information was provided by County not to it, as required under Act).