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i SECTION 2. CEQA MISAPPLICATION AND CLASS 14 EXEMPTION INAPPLICABILITY - 2.1 CDE-Listed School Closure Status Conflicts with Class 14 Eligibility The California Department of Education (CDE) Directory lists Ar€ Guiragos Minassian Armenian — the private school operating at 5311 W. McFadden Avenue — with a school status of "Closed," showing a Closure Date of June 30, 2025 and a last update reported on July 23, 2025. As of the date of the October 27, 2025 Planning Commission hearing, the school remained listed as "Closed" in the CDE Directory. The CDE Directory includes a published disclaimer stating that information for private schools is self-reported by the school or its governing entity, and that the CDE does not verify, audit, or ensure the accuracy of such information. However, the publicly reported status of the school as "Closed" in the CDE Directory at the time the City relied on a Class 14 exemption raises a direct conflict with the threshold eligibility requirement that a Class 14 exemption may only be used for minor additions to existing schools. Reliance on a Class 14 Categorical Exemption for a school site that was publicly reported as "Closed" at the time of project consideration introduces material uncertainty as to whether the site qualified as an "existing school" for CEQA exemption purposes. Given the CDE's role as the statewide authority maintaining school status records, the discrepancy between the publicly reported closed status and the City's application of a Class 14 exemption warrants clarification and further evaluation before such an exemption may be relied upon. 2.2 Misclassification of Instructional vs. Non-Instructional Space Used to Support CEQA Class 14 Eligibility The baseline used to support the CEQA Class 14 exemption did not distinguish between instructional classroom space and non-instructional event venue space, resulting in an inaccurate representation of the project's scale, use, and associated impacts. The justification for the exemption referenced the total building square footage of approximately 14,000 square feet as "school space," without providing a breakdown of instructional versus non- instructional areas, or establishing the number of existing classrooms or instructional seat capacity. CEQA's Class 14 exemption is intended for minor additions to schools based on educational instructional use, rather than general building size or multi-use space. A portion of the space within the institutional corridor operates as a public-facing event venue not dedicated to instructional use. The facility located at 5315 W. McFadden Avenue is regularly used for large-scale events, community functions, performances, and ticketed gatherings, with public advertising and event ticketing available. This venue, known as Gugas€an Hall, offers box office hours, VIP parking, and ticketed admission for performances and social events, demonstrating a commercial event function separate from school-day educational activity. As such, the square footage of this venue is not appropriately classified as instructional school space in the context of CEQA eligibility. Despite the presence of this non-instructional event use, total building size was referenced in support of a "minor" school expansion, without identifying how much space is dedicated to classroom instruction. No evidence was provided to show how the current or proposed space aligns with actual classroom requirements, educational programming needs, or instructional capacity. Framing the expansion as"minor" based solely on total square footage, rather than 7 City Council 18 — 23 2/3/2026