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That said, the CEQA guidelines anticipate the over-inclusivity of categorical exemptions, such as the infill development exemption claimed by the Commission to apply to the Russell Fischer Car Wash Project, but interestingly, not to the 2018 Russell Fischer Retail/Restaurant Project proposed for the same site. The guidelines address the problem of "over-inclusivity" in categorical exemptions by establishing a list of exceptions to the exemptions. The City adopted Local Guidelines for Implementing CEQA ("Local Guidelines") in 2019. These exceptions to the categorical exemptions are reflected in section 3.22 of the Local Guidelines (See Resolution No. 2019-050). The Local Guidelines state: "All classes of categorical exemptions are qualified. None of the categorical exemptions are applicable if any of the following circumstances exist: (1) The cumulative impact of successive projects of the same type in the same place over time is significant; (2) there is a reasonable possibility that the activity will have a significant effect on the environment due to unusual circumstances." Even if the Russell Fischer Car Wash Project met the five conditions for the infill categorical exemption, two exceptions to that exemption apply: (1) the cumulative impacts exception (14 CCR § 15300.2(b)), and (2) the unusual circumstances exception (14 CCR § 15300.2(c).) These exceptions are address in tarn below. Even if the Car Wash Project was categorically exempt, the exception from that exemption applies because the Commission failed to consider the cumulative impact of approving numerous car washes all within close proximity — roughly a 2-mile radius. (See Exhibit A.) For instance, the City just recently approved Rocket Express Car Wash at 1703 East 17`h Street. The City is considering approval of the Russell Fischer Car Wash Project at 301 and 325 N. Tustin Avenue. Two additional applications for new car wash developments have been submitted to the City including one at Grand Avenue between 17`h Street and Fairhaven Avenue, and another at N. Tustin Avenue and Santa Clara Avenue. (See East Peninsula Educ. Council, Inc. v. Palos Verdes Peninsula Unified Sch. Dist. (1989) 210 Cal.App.3d 155 [The district failed to evaluate the cumulative impact of additional school closures when determining the school closure at issue was categorically exempt from CEQA. The court set aside the approvals and required the district to evaluate the cumulative impacts in determining whether the physical changes were categorically exempt].) The Russell Fischer Car Wash Project, even if it meets the general requirements for the infill development exemption, is nonetheless subject to CEQA review because the unusual circumstances exception to categorical exemptions applies. This exception was confirmed in Friends of Mammoth v. Board of Supervisors (1972) 8 Cal.3d 247 (Friends of Mammoth). There, the Supreme Court explained that the majority of private projects for which a government permit or similar entitlement is necessary are minor in scope and thus have little or no effect on the public environment, but when they do have a significant effect on the environment, such effects will be due to unusual circumstances. (Id. at p. 272.) 18 75A-28