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February 4, 2025 Page 10 7357-016j the project as a whole.42 The City required that an EIR be prepared and certified that covered all 21 proposed houses, even those already constructed, due to their violations of law.43 The court held that the piecemeal review “failed to take into account the cumulative impacts from the overall project, which… warranted full environmental review.”44 The court held that this approach violated CEQA because “Arviv was attempting to go around the rules by developing in a piecemeal fashion in order to take advantage of environmental exemptions…”45 Similarly here, the County has impermissibly piecemealed its environmental review of this Project from the East Lakes Project. The City, in annexing the Project sites has a duty to remedy this error in a new or revised DEIR. The East Lakes Project will add an additional 357 single-family, age- restricted homes and 88 age-restricted assisted living units, for a total of 445 units, and associated facilities. Construction and operation of the East Lakes Project at the same location as the Arroyo Lago Project will substantially increase the localized and regional air quality impacts, transportation impacts, GHG, hazards and other impacts generated by the projects. The combined effects of the two projects must be analyzed together in a single EIR to accurately assess their severity and ensure that proposed mitigation measures reduce the combined local and regional effects of the projects to the greatest extent feasible. 2. The Revised EIR Must Analyze Whether the City’s Services Can Adequately Serve the Project Sites The Arroyo Lago DEIR described the instant annexation proposal as a Project alternative which was “determined to be infeasible.”46 As a result, the DEIR failed to analyze whether the Projects could be adequately served by the City’s public and utility services, including but not limited to fire and water, in the event of annexation. The City must prepare a new or revised DEIR to address these impacts. 42 Id. 43 Arviv, supra, at 1346. [The five existing houses exceeded the height restrictions of the Mulholland Scenic Parkway Specific Plan, the Hillside ordinance, as well as the height limitations specified in the permits issued by the City.] 44 Id. at 1342. 45 Id at 1340. 46 DEIR, p. 6-25.