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February 4, 2025 <br />Page 5 <br /> <br />7357-016j <br /> <br />Individual members of East Bay Residents and its affiliated labor <br />organizations who live, work, recreate and raise their families in Alameda County. <br />They would be directly affected by the Project’s environmental and health and <br />safety impacts. Individual members may also work on the Project itself. <br />Accordingly, they will be first in line to be exposed to any health and safety hazards <br />that exist onsite. East Bay Residents has an interest in enforcing environmental <br />laws that encourage sustainable development and ensure a safe working <br />environment for its members. Environmentally detrimental projects can jeopardize <br />future jobs by making it more difficult and more expensive for business and <br />industry to expand in the region, and by making it less desirable for businesses to <br />locate and people to live there. <br /> <br />II. THE CITY MUST PREPARE A NEW DEIR, OR REVISE AND <br />RECIRCULATE THE ARROYO LAGO DEIR, TO ANALYZE <br />ANNEXATION AND APPROVAL OF BOTH PROJECTS <br /> <br />A. The City Must Assume the Role of Lead Agency for Both Projects <br /> <br /> The proposed annexation of the Arroyo Lago and East Lakes Project sites, <br />and the proposed transfer of entitlement approvals to the City of Pleasanton, <br />require the City to assume the role of lead agency for the Projects under CEQA and <br />analyze the Projects in a single EIR. <br /> <br />By annexing the Project sites, the City of Pleasanton becomes the successor <br />CEQA lead agency after Alameda County.16 In Gentry v. City of Murrieta, the lead <br />agency changed during the CEQA environmental review process. In that case, as <br />here, the County prepared the environmental review document.17 Then, when the <br />City of Murieta was incorporated, it took over as lead agency.18 The City of Murieta <br />then released the negative declaration as its own.19 Similarly here, upon <br />annexation, the City of Pleasanton would be deemed the successor lead agency and <br />must take over as lead agency to revise the DEIR prepared for the Arroyo Lago <br />Project to include the East Lakes Project and include analysis of impacts associated <br />with annexation in a recirculated EIR. <br /> <br /> <br />16 Gentry v. City of Murrieta (1995) 36 CA4th 1359, 1383. <br />17 Id. at 1398. <br />18 Id. <br />19 Id.