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February 4, 2025 <br />Page 4 <br /> <br />7357-016j <br /> <br />lessened if the Projects utilize City public services and utilities in lieu of <br />constructing new facilities, the Projects would result in new impacts on, inter alia, <br />public services and utilities, which were not analyzed by the County. In particular, <br />the DEIR failed to analyze whether the Projects could be adequately served by the <br />City’s public and utility services, including but not limited to fire and water, in the <br />event of annexation. The Project descriptions have also been revised since the <br />original DEIR was released. These changes in the Projects must be thoroughly <br />analyzed and included in a new or revised DEIR, in addition to the pending <br />environmental studies identified in the Staff Report. <br /> <br />EBRRD asks the City Council to direct City Staff to prepare a new <br />DEIR, or revise and recirculate the Arroyo Lago DEIR, to analyze the <br />Arroyo Lago and East Lakes Projects in a single EIR, and to address the <br />potentially significant impacts associated with the City’s proposed <br />annexation and entitlement actions for the Projects. This analysis must <br />include disclosure and mitigation of all potentially significant <br />environmental and public health impacts associated with construction <br />and operation of the Projects.14 A revised and recirculated EIR is required <br />where, as here, significant new information, like changes in the project <br />description and annexation, is disclosed after the original EIR was <br />prepared.15 <br /> <br />I. STATEMENT OF INTEREST <br /> <br />East Bay Residents is an unincorporated association of individuals and labor <br />organizations that may be adversely affected by the potential public and worker <br />health and safety hazards and environmental and public service impacts of the <br />Project. The association includes International Brotherhood of Electrical Workers <br />Local 595, UA Plumbers and Pipefitters Local 342, Sheet Metal Workers Local 104, <br />Sprinkler Fitters Local 483, their members and families, and other individuals that <br />live and/or work in Alameda County. <br /> <br /> <br />attached to Exhibit 1 as Exhibit A. East Bay Residents’ comments on noise and vibration were <br />prepared with the assistance of Ani Toncheva, acoustics, noise, and vibration expert of Wilson Ihrig. <br />Ms. Toncheva’s Comments (“Toncheva Comments”) and Ms. Toncheva’s CV are attached to Exhibit 1 <br />as Exhibit B. <br />14 Alternatively, the City may need to prepare a supplemental EIR. A Supplemental EIR is required <br />to analyze the “changes [that] would be necessary to make the previous EIR adequately apply to the <br />project in the changed situation.” Id. at § 15163(a)(2). <br />15 Id. at § 15088.5(a).