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approval and requires CEQA review. Thus, with the current Zoning Code, Vista would need to undergo CEQA review to expand its school operations, However, Vista applied for the Amendment to the City's Zoning Code to add "sohools" as a permitted use in the SD-82 zone to permit Vista's expansion by right, Because the City views the Amendment and expanslon as two separato projects, it wrongly assumes that no CFQA review is required. Thus, the City and Vista appear to be sneaking in a circumvention of necessary CEQA review by approving Buis Project. This is evident considering the City could have amended the Zoning Code to continue to require a CUP, which is required by childcare centers in the SD-82 zone, Moreover, the Amendment to the Zoning Code is a discretionary action that will create significant onvironrnental impacts as discussed below, 2. The.Pr o)ect1& NotExempt from C9QA, The City Council Stalf Report states that the City has determined that the Project Is exempt from CEQA and, therefore, no environmental review is necessary, That Is untuo. The City incorrectly assumes that amending the Zoning Code to allow a permitted use at the Project's property will not create all environmental impact, but the City has not evaluated any of the potential environmental impacts that will result from the expansion of the charter school, C13QA Guidelines section 15378 defines a "project" as the whole of an action, which has a potential for resulting in either a direct physical change in the environment or a reasonably foreseeable indirect physical change in the environment. Again, the Amendment to the Zoning Code and the expansion are the whole of the action, or the "Project," under CFQX Thus, the City cannot improperly piecemeal the Project. By approving the Project, there will be a direct physical change because school expansion will involve construction, additional students, increased traffic, noise impacts, etc. Thus, to City has a duty to study and mitigate the potential signifroant environmental impacts of the Project, pdol� to approving the Project. 3, The Project Will Cause Signlfieant.ttnvitwotrtentatlmpoe4,i4 There will be traffic, circulation, and safety impacts fiom the Project. This is, proven 'by the Trafflo Impact Report that the District was forced to have prepared by MI that unequivocally identifies traffic, circulation, and safety impacts that will result ttom the Pro] eot. The District provided that report to the City on October 25, 2019, but the City ignored the Traffic hnpact Report. Incredibly, the City did not have its own Traffic Impact Report prepared for this Project. Site Distances. More importantly, and as detailed in IBi's Traffic impact Report, from a safety and circulation standpoint, there are inadequate site distances for vehicles exiting the Project via the 51' Street driveways and Fairview Street. Per the Traffic Impact Report, the Highway Design Manual C%4anual") sets forth the rnitrimum sight distance necessary for vehicles exiting driveways. (Traif"ic impact Report, p, 34.) As such, "the [MJanual states that there needs to be areas with clear sight lines (i.e. areas to be free of any obstructions) so that vehicles can enter the traffic stream. safely." (Id.) Table 201.1 of the Manual states that for streets with a 35-mph speed limit (i.e. Fairview Street and Sth Street), a minimum of 250 feet is required fnr any vehicle travelling on either street to stop in time for vehicles exiting the project driveways. (Id.) The analysis indicates that to obtain the 250 -feet required, an area approximately 10 foot back of the cutir for a distance of 120 feet from the driveway be relatively ftee of obstructions (walls, landscaping, on -street parking) is recommended. (Id.) As shown in Figure 9 of the Traffic Impact Report, Oho Project's current sight distance is not adequate and therefore signi'llcant safety impacts are anticipated at the following locations;