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February 4, 2025 Page 6 7357-016j Pursuant to CEQA, the City would become successor lead agency when it annexes the Project sites and is required to conduct environmental review of its actions that reflects its independent judgment.20 There can only be one CEQA lead agency for a particular project.21 As a general rule, the agency that acts first will normally serve as the lead agency.22 However, depending on the circumstances, the agency that acts first might not always be the appropriate lead agency.23 An annexation constitutes a “project” for CEQA purposes.24 Here, the City is the CEQA successor lead agency following annexation. Approval of the Projects’ land use entitlements by the City also requires the City to assume the role of lead agency. The Staff Report explains that approval of the Projects’ underlying entitlements will be transferred to the City in conjunction with annexation, and will require City approval of General Plan amendments, prezoning, PUD permits, subdivision maps, CEQA review, and “other permits and approvals as determined necessary by the City.”25 The CEQA Guidelines specify that when a project is to be carried out by a private party, the lead agency shall be the public agency with the greatest responsibility for supervising or approving the project “as a whole.”26 “Greatest responsibility” is defined as “the agency with general governmental powers, such as a city or county, rather than an agency with a single or limited purpose such as an air pollution control district or a district which will provide a public service or public utility to the project.”27 Here, the City will become the agency with the “greatest responsibility” to approve the Projects’ land use entitlements, in addition to its lead agency role related to annexation. In particular, the proposed prezoning of the Project sites demonstrates that the City must assume the role of CEQA lead agency. The CEQA Guidelines provide that, when a city prezones an area, the city will act as lead agency and the LAFCO as a responsible agency for any subsequent annexation.28 20 PRC § § 21082.1. 21 City of Redding v. Shasta County Local Agency Formation Comm’n (1989) 209 CA3d 1169, 1174. 22 14 CCR §15051(c). 23 See Fullerton Joint Union High Sch. Dist. v. State Board of Educ. (1982) 32 C3d 779, 795 n15. 24 Pub. Resources Code § 21065(c); see Bozung v. LAFCO (1975) 13 C3d 263 (court held that approval of annexation was CEQA project because it involved issuance of entitlement to a person by a public agency). 25 Staff Report, Attachments 1 and 2. 26 14 CCR § 15051(b); Eller Media Co. v. Cmty. Redevelopment Agency (2003) 108 Cal.App.4th 25, 38; see also, PRC § 21067. 27 14 CCR § 15051(b)(1) (emphasis added). 28 14 CCR §15051(b)(2).