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November 8, 2024 Page 3 7357-013acp printed on recycled paper County failed to analyze the impacts of the Senior East County Lakes Project in the DEIR as part of the overall Arroyo Lago Project development proposal. EBRRD has reviewed the DEIR and technical appendices with its experts and concludes that the DEIR fails to comply with the California Environmental Quality Act (“CEQA”).8 The DEIR improperly piecemeals its description of the Project by omitting a discussion or impact analysis of the Busch Road Project, lacks an adequate description of baseline conditions, and has significant, unmitigated air quality, public health, and noise impacts. The Project may also result in significant, unmitigated hazards, water supply and odor impacts which are not evaluated in the DEIR. The DEIR must be revised and recirculated to correct these errors and omissions. EBRRD’s 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 hereto as Exhibit A. SWAPE found that the DEIR significantly underestimates construction air quality impacts, and fails to adequately mitigate the Project’s significant GHG impacts. Moreover, the DEIR fails to adequately analyze the cumulative impacts of the Project with the concurrent Senior East County Lakes Project on the Project site proposed by the Applicant. EBRRD’s 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 hereto as Exhibit B. Ms. Toncheva’s comments identify significant and unmitigated noise impacts from construction of the Project. Moreover, the sewer treatment plant element of the Project will result in significant operational noise impacts to sensitive receptors in the community and at the Senior East County Lakes Project. The attached expert reports are incorporated by reference into this comment letter as if fully set forth herein and must be considered part of the record for this Project. East Bay Residents reserves the right to submit supplemental comments at any later hearings and proceedings related to the Project.9 8 Pub. Resources Code (“PRC”) §§ 21000 et seq.; 14 Cal. Code Regs (“CCR” or “CEQA Guidelines”) §§ 15000 et seq. 9 Gov. Code § 65009(b); PRC § 21177(a); Bakersfield Citizens for Local Control v. Bakersfield (“Bakersfield”) (2004) 124 Cal. App. 4th 1184, 1199-1203; see Galante Vineyards v. Monterey Water Dist. (1997) 60 Cal. App. 4th 1109, 1121.