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March 18, 2025 Page 4 7736-009acp printed on recycled paper Construction of the East Lakes Project would violate the Livermore Airport Land Use Compatibility (“ALUC”) Plan.13 The Agenda Report does not clarify how the Project would be brought in conformance with the ALUC and instead recommends analysis to review whether the City should override an ALUC non-compliance determination. This nonconformance must be analyzed in a new or revised DEIR. Further, significant noise impacts from the airport to sensitive receptors including residents of the East Lakes Projects must be mitigated to the greatest extent feasible before the Project can lawfully proceed. Furthermore, as demonstrated in East Bay Residents prior comments 14, the East Lakes Project site may be contaminated with perfluorinated and polyfluorinated alkyl substances (“PFAS”). The Agenda Report makes no mention of the potentially significant PFAS contamination on and adjacent to the Project site. The DEIR prepared for the Arroyo Lago Project recognized that PFAS was not quantified on the Project site and was not included in the Phase I environmental site assessment for the Project.15 The State Water Resources Control Board’s maps show that the Project site is adjacent to “Drinking Water Wells with Orders for PFAS Monitoring” for Well 08, PS Code CA0110008_004_004.16 Elevated PFAS concentrations were discovered in Zone 7 Water Agency Livermore Valley groundwater supply wells in 2019, with concentrations highest near Livermore Municipal Airport and in southwest Pleasanton near the Project site.17 The Water Agency Zone 7 commented on the DEIR’s Notice of Preparation that “Zone 7 has particular concerns about potential use of the Amazon well, due to issues with perfluorinated and polyfluorinated alkyl substances (PFAS). Zone 7 requests that the EIR clearly state the water sources proposed to be used for the Project. If these include the Amazon well, or other sources with potential PFAS concerns, then the EIR should thoroughly evaluate potential impacts due to PFAS contamination.”18 The DEIR failed to analyze or mitigate the potential PFAS contamination within the Project vicinity. PFAS contamination is a significant environmental and public health impact for the East Lakes Project and must be analyzed in an EIR concurrently with the Arroyo Lago Project, as required by CEQA. 13 Agenda Report, p. 10 of 12. 14 Attachment A. 15 DEIR, Appendix F: Hazards, Hazardous Materials, and Wildfire Supporting Information, p. 2. 16 California Water Resources Control Board Portal, California PFAS Investigation Site Map (Jan. 23, 2024). 17 DEIR Appendix A: EIR Noticing and Public Involvement, pdf p. 58 of 208. 18 Id.