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The proposed use of a CEQA Class 14 Categorical Exemption does not align with the conditions present at this location, due to the unique circumstance of senior and ADA-affected residents living on an R-1 property that shares a direct boundary with the Applicant's institutional school property, as well as a second, separate institutional property. This creates a dual-institutional adjacency that results in an elevated level of environmental and sensory exposure not typical of single-family residential zoning. t Class 14 (§15314) is limited to minor physical additions to existing school facilities and is not intended to cover projects that involve programmatic expansion or changes in operational intensity. The expansion from K-6 to K-8 introduces additional grade levels and associated changes to daily campus activity, outdoor use, traffic patterns, noise levels, and after-hours or evening functions along a shared residential boundary. These conditions reflect new or intensified impacts, rather than a continuation of existing baseline operations. CEQA Guidelines §15300.2 identifies conditions under which categorical exemptions do not apply, including circumstances where a project may involve unusual conditions or cumulative impacts. The configuration of two separate institutional uses directly abutting the only immediately impacted residence is not a typical adjacency for an R-1 parcel and results in continuous sensory exposure—including noise, lighting, movement, and privacy intrusion— that exceeds what is reasonably expected for a single-family home. The affected residents include elderly and disability-protected individuals, whose health, daily living, and sensory tolerance thresholds differ from the general population. Exposure to increased noise, activity, lighting spillover, and traffic circulation may create disproportionate and adverse effects on individuals with medical vulnerabilities, limited mobility, or disability- - related sensitivity to environmental disruptions. In addition to CEQA considerations, the location involves residents protected under the ADA, the Fair Housing Act, Section 504, and California Government Code §11135, which collectively recognize age and disability as protected classes. Land-use decisions that result in increased burdens, disturbances, or diminished quiet enjoyment for such protected populations carry heightened sensitivity and implications for equitable access, stability, and full enjoyment of one's home. The combination of (1) a programmatic expansion with intensified operational impacts, (2) dual institutional boundary adjacency, and (3) the presence of senior and disability-protected residents creates a set of conditions that do not fall within the narrow intent or applicability of the Class 14 exemption. In summary, the City's reliance on a CEQA Class 14 exemption was misstated, unsupported, and materially inconsistent with CEQA requirements and exclusionary conditions. Based on the deficiencies outlined above, the City's reliance on a CEQA Class 14 Categorical Exemption was not supported by an accurate assessment of the project's nature, scope, baseline conditions, operational intensity, or cumulative environmental effects. The exemption was applied without consideration of programmatic expansion, dual-institutional boundary impacts, multi-parcel cumulative activity, or the presence of senior and disability- protected residents whose exposure to environmental and sensory impacts constitutes an unusual circumstance under CEQA. These substantive omissions prevented a lawful CEQA determination and resulted In an approval unsupported by the necessary factual and regulatory foundation. 9 City Council 18 — 25 2/3/2026