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February 4, 2025 Page 3 7357-016j approvals from the City.8 In addition to annexation, which must be approved by both the City and the Local Agency Formation Commission (“LAFCO”), City Project approvals will include General Plan amendments, prezoning, planned unit development (“PUD”) permits, subdivision maps, CEQA review, and “other permits and approvals as determined necessary by the City.”9 This information was not disclosed to the public in the Arroyo Lago DEIR and is substantial new information which requires the DEIR to be revised and recirculated for additional public review and comment.10 As the primary approving agency for both Projects and a lead agency for the annexation, the City must assume the role of lead agency for purposes of the Projects’ entitlement process and environmental review pursuant to the California Environmental Quality Act (“CEQA”). 11 East Bay Residents submitted comments to the County on the Arroyo Lago DEIR in October 202412 which provided substantial evidence demonstrating that the DEIR prepared by the County failed to comply with CEQA. These comments remain unresolved. In particular, the DEIR improperly piecemealed its description of the Projects by failing to analyze the Arroyo Lago and East Lakes Projects in a single EIR. The Arroyo Lago and East Lakes Project share a common property owner, would undergo concurrent development and operation, and would occupy the same parcel, APN 946-4634-2. Nevertheless, the County failed to analyze the impacts of the East Lakes Project in the DEIR as part of the overall Arroyo Lago Project development proposal. The combined impacts of both Projects must be analyzed concurrently by the City due to the proposed annexation and entitlement for both Projects which is now proposed to be conducted by the City of Pleasanton. East Bay Residents’ DEIR comments, supported by expert analysis, also demonstrated that the Projects have significant, unmitigated air quality, public health, greenhouse gas, and cumulative impacts.13 While some impacts may be 8 Staff Report, pp. 2-4; Arroyo Lago Application Processing Terms; East Lakes Application processing terms. The Staff Report provides that “the applicants have expressed willingness to work with the City to modify the projects in conjunction with an annexation application, and after considering feedback from neighbors of the Arroyo Lago Project, and from City staff regarding both the Arroyo Lago and East Lakes projects, have submitted revised “City” versions of the two projects.”). 9 Staff Report, Attachments 1 and 2. 10 14 Cal. Code Regs (“CCR” or “CEQA Guidelines”) § 15088.5 11 Pub. Resources Code (“PRC”) §§ 21000 et seq.; 14 CCR” §§ 15000 et seq. 12 East Bay Residents’ DEIR comments are attached hereto as Exhibit 1. 13 East Bay Residents’ comments on air quality, public health, and greenhouse gas (“GHG”) impacts were prepared with the assistance of air quality and GHG expert Paul E. Rosenfeld, Ph.D. of Soil Water Air Protection Enterprises, whose comments are included in the SWAPE Comments (“SWAPE Comments”). The SWAPE Comments and Dr. Rosenfeld’s expert curriculum vitae (“CV”) are