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March 18, 2025 Page 3 <br />7736-009acp <br /> printed on recycled paper <br /> The County released a Draft Environmental Impact Report (“DEIR”) for the Arroyo Lago Project September 2024 with a comment period that closed on November 8, 2024. 8 In October 2024, East Bay Residents submitted comments to the County on the Arroyo Lago DEIR which provided substantial evidence demonstrating that the County’s DEIR failed to comply with CEQA.9 The DEIR impermissibly piecemealed its description of the Arroyo Lago and East Lakes Projects by failing to analyze the 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. The Arroyo Lago and East Lakes <br />Projects are part of a single overarching development which must be <br />analyzed in a single EIR to address the environmental consequences of the overall development.10 East Bay Residents’ DEIR comments, supported by expert analysis, also demonstrated that annexation and development of the Projects have significant, unmitigated air quality, public health, noise, greenhouse gas, and cumulative impacts.11 The City must assume the role of lead agency for both Projects’ <br />entitlement process and environmental review pursuant to the California <br />Environmental Quality Act (“CEQA”)12 in order to adequately analyze and mitigate the Projects’ significant environmental impacts. <br /> <br />8 County of Alameda, Arroyo Lago Residential Project Notice of Preparation of an Environmental Impact Report (May 12, 2023) Exhibit 6, identifying USL Pleasanton Lakes as owner of parcels APN 946-1350-3-10 and APN 946-4634-2. <br />9 East Bay Residents’ DEIR comments are attached hereto as Exhibit 1. <br />10 Arviv Enters., Inc. v. South Area Planning Comm’n (2002) 101 CA4th 1333, 1336. <br />11 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 attached to Exhibit 1 as Exhibit A. East Bay Residents’ comments on noise and vibration were prepared with the assistance of Ani Toncheva, acoustics, noise, and vibration expert of Wilson Ihrig. Ms. Toncheva’s Comments (“Toncheva Comments”) and Ms. Toncheva’s CV are attached to Exhibit 1 as Exhibit B. <br />12 Pub. Resources Code (“PRC”) §§ 21000 et seq.; 14 CCR” §§ 15000 et seq.