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February 4, 2025 Page 13 7357-016j omissions resulted in substantial underestimation of the Arroyo Lago Project’s air emissions. When properly calculated, SWAPE found that the Project’s construction and operational air pollutant impacts would be significant and remain unmitigated. The County has not responded to public comments on the DEIR, and has not updated the DEIR’s air quality analysis to correct these errors. SWAPE’s comments continue to demonstrate that the Arroyo Lago Project would result in potentially significant unmitigated air quality impacts.56 A revised EIR must be circulated to provide an accurate construction-related air quality analysis. 4. The Revised EIR Must Analyze the Projects’ Potentially Significant Hazards Impacts The DEIR failed to include any analysis regarding the potentially significant hazards and water quality impact of the Projects associated with perfluorinated and polyfluorinated alkyl substances (“PFAS”). The State Water Resources Control Board’s maps show that the Project sites are adjacent to “Drinking Water Wells with Orders for PFAS Monitoring” for Well 08, PS Code CA0110008_004_004.57 The Water Agency Zone 7 commented on the NOP 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.”58 The DEIR failed to analyze the potential PFAS contamination within the Project vicinity. In 2019, pursuant to an order from the California State Water Resource Control Board Division of Drinking Water, the City began testing its water for PFAS including, but not limited to, perfluorooctanoic acid (“PFOA”) and perfluorooctane sulfonic acid (“PFOS”).59 During this testing, the City discovered 56 SWAPE Comments, p. 4; Comtys. for a Better Env’t v. Cal. Resources Agency (2002) 103 Cal.App.4th 98, 110-111 (when impact exceeds CEQA significance threshold, agency must disclose in the EIR that the impact is significant); Schenck v. County of Sonoma (2011) 198 Cal.App.4th 949, 960; CBE v. SCAQMD, 48 Cal.4th at 327 (impact is significant because exceeds “established significance threshold for NOx … constitute[ing] substantial evidence supporting a fair argument for a significant adverse impact”). 57 California Water Boards, California PFAS Investigation Site Map, 58 DEIR, Appendix A: EIR Noticing and Public Involvement, pdf p. 59 of 208. 59 https://www.paloaltoonline.com/media/reports_pdf/1687827492.pdf.