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March 18, 2025 Page 5 7736-009acp printed on recycled paper The City is required to fully comply with CEQA review prior to approving any Project-related entitlements, including any annexation-related approvals for the East Lakes Project. The proposed annexations would be the first obligation of City resources towards approval of the Project.19 In Save Tara v. City of West Hollywood, the California Supreme Court concluded that a city’s “conditional agreement to sell land for private development, coupled with financial support, public statements, and other actions by its officials committing the city to the development, was, for CEQA purposes, an approval of the project that was required… to have been preceded by preparation of an EIR.”20 In Save Tara, the city had expressed its favor for the project, defended it publicly, devoted substantial public resources to it, and announced a detailed agreement to go forward with the project, all without CEQA review. The Court held that this approach violated CEQA. Similarly here, the City’s proposal to proceed with annexation of the Project sites triggers the City’s duty to fully examine the Projects’ conformance with CEQA in a single EIR prior to approval. The proposed action by the City Council to proceed with the East Lakes application is the first step towards Project approval, and requires CEQA compliance prior to approval. We urge the City Council to direct City staff to fully comply with CEQA and prepare a single EIR analyzing the Arroyo Lago and East Lakes Projects prior to taking any action on approval, annexation, or entitlements for the Projects. Thank you for your attention to these comments. Please include them in the record of proceedings for the Arroyo Lago and East Lakes Projects. Sincerely, Kelilah D. Federman Attachment KDF:acp 19 Save Tara v. City of West Hollywood (2008) 45 Cal.4th 116, 131. 20 Id.