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November 8, 2024 Page 8 7357-013acp printed on recycled paper impact, which cumulatively may have disastrous consequences.36 Public agencies must interpret the project broadly to encompass the whole of the action and its environmental impacts.37 The Senior East County Lakes Project is a proposed housing development project on the Project site, which will result in reasonably foreseeable environmental impacts and is currently “Under Review” by Alameda County.38 The two projects are to be developed simultaneously, on common property under common ownership, and will result in overlapping and potentially significant individual and cumulative environmental impacts which must be analyzed together in a single EIR to fully address the environmental consequences of the projects and avoid artificially reducing their impacts. On June 4, 2024, USL Pleasanton Lakes L.P submitted an SB 330 application for the Senior East County Lakes, a proposed Builders Remedy39 project to be located at parcel APN 946-4634-002 (the same parcel proposed for the Arroyo Lago Project’s offsite improvements).40 The Senior East County Lakes Project proposes to develop a 61.6-acre southwestern portion of the parcel with senior housing (age restricted for 55 years and older) consisting of 357 single-family residences and duet homes and 212 multifamily independent and/or assisted living units (569 total units).41,42 The Senior East County Lakes Project proposes a high density independent/assisted living facility which will include approximately 1,822 parking spaces and an internal circulation system to accommodate bike and vehicular travel, as well as ingress and egress to the Property.43 36 Id.; See also City of Santee v. County of San Diego (1989) 214 Cal.App.3d 1438, 1452; Citizens Assn. for Sensible Development of Bishop Area v. County of Inyo (1985) 172 Cal.App.3d 151, 165. 37 14 Cal. Code Regs. § 15378. 38 DEIR, p. 3-7. 39 The Builder’s Remedy, Gov. Code § 65589.5(d)(5), prohibits a local government from denying a housing development that includes 20% lower-income housing or 100% moderate-income housing that does not conform to the local government's underlying zoning, if the local government has not adopted a compliant housing element. Builders Remedy projects are subject to CEQA review. 40 Exhibit C – Housing Crisis Act of 2019 SB 330 Preliminary Application Form APN 946-434-002 (June 4, 2024); Exhibit D – Letter from Holland & Knight to Albert Lopez, Planning Director Alameda County, Re Submittal of SB 330 Preliminary Application for “Builder’s Remedy” Project at Busch Rd., Alameda County, APN 946-4634-002 (June 4, 2024). 41 USL Pleasanton Lakes. L.P., Housing Crisis Act of 2019 SB 330 Preliminary Application for Project at Busch Rd., Alameda County, APN 946-4634-002 (June 4, 2024). 42 DEIR, p. 3-7. 43 Letter from Holland & Knight USL Pleasanton Lakes L.P. to Planning Director Albert Lopez, Submittal of SB 330 Preliminary Application for “Builder’s Remedy” Project at Busch Rd., Alameda County, APN 946-4634-002 (June 4, 2024).