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November 8, 2024 Page 7 7357-013acp printed on recycled paper California courts have repeatedly held that “an accurate, stable and finite project description is the sine qua non of an informative and legally sufficient EIR.”28 CEQA requires that a project be described with enough particularity that its impacts can be assessed.29 Without a complete project description, the environmental analysis under CEQA is impermissibly limited, thus minimizing the project’s impacts and undermining meaningful public review.30 Accordingly, a lead agency may not hide behind its failure to obtain a complete and accurate project description.31 “The significance of an accurate project description is manifest, where, as here, cumulative environmental impacts may be disguised or minimized by filing numerous, serial applications.”32 Further, “[e]nvironmental considerations [can] not become submerged by chopping a large project into many little ones—each with a minimal potential impact on the environment—which cumulatively may have disastrous consequences.”33 Here, the Project is impermissibly piecemealed from the proposed Senior East County Lakes Project on APN 946-4634-002, rendering the DEIR’s Project Description inadequate. A. The DEIR Impermissibly Piecemeals the Project from the Senior East County Lakes Project CEQA prohibits piecemeal review of the significant environmental impacts of a project.34 A project under CEQA refers to the “whole of an action which has the potential for resulting in either a direct physical change in the environment, or reasonably foreseeable indirect physical change in the environment.”35 CEQA’s prohibition on piecemealing ensures that environmental considerations are not diluted by dividing a large project into smaller ones, each with a minimal potential 28 Stopthemillenniumhollywood.com v. City of Los Angeles (2019) 39 Cal.App.5th 1, 17; Communities for a Better Environment v. City of Richmond (2010) 184 Cal.App.4th 70, 85–89; County of Inyo v. City of Los Angeles (3d Dist. 1977) 71 Cal.App.3d 185, 193. 29 14 CCR § 15124; see, Laurel Heights I, supra, 47 Cal.3d 376, 192-193. 30Id. 31 Sundstrom v. County of Mendocino (“Sundstrom”) (1988) 202 Cal.App.3d 296, 311. 32 Arviv Enters., Inc. v. South Area Planning Comm’n (2002) 101 CA4th 1333, 1345. 33 Bozung v. Local Agency Formation Com. (1975) 13 Cal.3d 263, 283-284; see also Citizens Assn. for Sensible Development of Bishop Area v. County of Inyo (1985) 172 Cal.App.3d 151, 165 (county abused its discretion in adopting negative declarations for each portion of the project because it failed to consider the cumulative impacts of the project as a whole); Burbank-Glendale-Pasadena Airport Authority v. Hensler (1991) 233 Cal.App.3d 577, 592 (“A narrow view of a project could result in the fallacy of division, that is, overlooking its cumulative impact by separately focusing on isolated parts of the whole.”). 34 Laurel Heights Improvement Assn., 47 Cal. 3d at 396; See Bozung v. Local Agency Formation Com. (1975) 13 Cal.3d 263, 283-284; See also Pub. Res. Code § 21002.1(d). 35 14 Cal. Code Regs. § 15378(a).