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November 8, 2024 Page 14 7357-013acp printed on recycled paper have been released from wastewater treatment plants in the region, prompting site investigations and incident responses, and notice of violations for violations of Air District Rule 1-301, Public Nuisance.60 The DEIR fails to adequately analyze these odor impacts and concludes, absent substantial evidence, that “[t]he proposed project would not result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.” The Arroyo Lago and Senior East County Lakes projects must be analyzed in a single EIR which evaluates the combined odor, air quality, and health effects of the proposed placement of hundreds of new residences in close proximity to Arroyo Lago’s new sewage treatment plant, among other combined impacts. The Arroyo Lago Project may also necessitate a revised design to move the proposed sewage treatment plant farther away from the Senior East County Lakes Project residences, as required by the East County Area Plan.61 The County must prepare an EIR which accurately analyzes both projects, including updating the Project Description to account for development of the Senior East County Lakes Project, any changes in design, capacity, or location that are necessary for required offsite improvements, and all potential project alternatives that may require consideration under CEQA. IV. THE DEIR FAILS TO ADEQUATELY CHARACTERIZE THE EXISTING ENVIRONMENTAL SETTING CEQA requires that a lead agency include a description of the physical environmental conditions in the vicinity of the Project as they exist at the time environmental review commences.62 As numerous courts have held, the impacts of a project must be measured against the “real conditions on the ground.”63 The description of the environmental setting constitutes the baseline physical conditions by which a lead agency may assess the significance of a project’s impacts.64 Use of the proper baseline is critical to a meaningful assessment of a project’s 60 Bay Area Air Quality Management District, Compliance and Enforcement Division INCIDENT REPORT, City of Richmond Wastewater Treatment Plant/Veolia, Site # A2482, 601 Canal Blvd. Richmond, California (Dec. 07, 2023), available at: https://www.baaqmd.gov/~/media/files/compliance-and-enforcement/incident- reports/2023/incidentreport_veolia_richmondwwtp_h2sodors_update_120723- pdf.pdf?rev=6d4d944cd4ee44f6a91a3a59e152c9a0. 61 ECAP, p. 71, Policy 302 requires that the “County shall include buffer zones within new residential and sensitive receptor site plans to separate those uses away from freeways, arterials, point sources, and hazardous material locations.” 62 CEQA Guidelines, § 15125, subd. (a). 63 Save Our Peninsula Com. v. Monterey Bd. of Supervisors (2001) 87 Cal.App.4th 99, 121-22; City of Carmel-by-the Sea v. Bd. of Supervisors (1986) 183 Cal.App.3d 229, 246. 64 CEQA Guidelines, § 15125, subd. (a).