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instructional need or classroom count, materially misstates the property's educational <br /> baseline. <br /> Without a clear breakdown of classroom, instructional, and non-instructional functions, the <br /> project's alignment with CEQA Class 14 cannot be accurately assessed. A valid determination <br /> requires understanding how much of the existing and proposed space is educational in nature, <br /> and whether the addition constitutes a minor increase in instructional capacity. The record <br /> did not provide this necessary distinction. <br /> As presented, the basis for relying on a CEQA Class 14 exemption is materially compromised <br /> and cannot be relied upon for approval. <br /> 2.3 Unexamined Cumulative Impacts,_Parking Demand,, and Event-Based Use <br /> Disqualifying CEQA Class 14 Exemption <br /> In addition to the misclassification of space, the CEQA Class 14 exemption did not account for <br /> cumulative use, parking demand, or non-school event activity across the multi-institutional <br /> corridor. The project was represented as a minor expansion of school use, however, the <br /> intensity of activity, traffic, and parking demand in this corridor extends beyond school hours <br /> and includes evening, weekend, and commercial event functions. CEQA requires that <br /> determinations consider the full scope of operational impacts, including cumulative effects, <br /> yet this analysis did not occur. <br /> Parking was characterized as adequate based on shared institutional lots, without <br /> acknowledging that these lots serve public ticketed events and are monetized for non-school <br /> use, including VIP and valet parking. Event venue use typically triggers higher parking <br /> requirements than school instructional use, due to visitor volume, peak-time overlaps, and <br /> nighttime operations. The project materials did not disclose or evaluate how event parking, <br /> school operations, and proposed expansion would interact, nor did they consider the resulting <br /> - impact on nearby residential properties. <br /> The stated purpose of the expansion was to accommodate two additional grade levels, with <br /> enrollment increasing from 180 to a maximum of 195 students. However, no enrollment data, <br /> growth projections, or instructional capacity analysis was provided to substantiate the need <br /> for expansion. Further, no conditions of approval or enforcement measures were included to <br /> ensure that the 195-student limit would remain in place. The absence of an enforceable cap, <br /> combined with additional multi-use space, creates a potential for increased intensity beyond <br /> what was represented at the hearing. <br /> The multi-institutional corridor comprised of 5305, 5311, 5315, and 5321 W. McFadden <br /> Avenue reflects cumulative activity levels not limited to a single school campus. Event use, <br /> school programs, extracurricular activities, community gatherings, and church-affiliated <br /> functions collectively produce traffic, noise, and parking demand affecting adjacent residential <br /> properties. These cumulative impacts were not evaluated prior to asserting CEQA exemption <br /> eligibility. <br /> As presented, the basis for relying on a CEQA Class 14 exemption is materially compromised <br /> and cannot be relied upon for approval. <br /> 2. CEQA—Class 14 Exemption Inapplicable Due to Senior and ADA-Protected <br /> Residents at a Dual-Institutional Boundary <br /> 8 <br /> City Council 18 — 24 2/3/2026 <br />