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I <br /> • No updated compatibility assessment with adjacent R-1 zoning <br /> • No requirement to evaluate alternative configurations or mitigations <br /> This procedural choice deprived the public and decision-makers of the full evaluative process <br /> ordinarily required for a change of this magnitude, including impacts associated with traffic, <br /> noise, parking, land use, and cumulative corridor activity. <br /> 4.4 Lack of Updated Impact Analysis Underscores Inappropriateness of Mod ification <br /> No updated traffic assessment, noise evaluation, or residential compatibility study was <br /> provided to account for the change from K-6 to K-8 or for the introduction of new <br /> programmatic functions and dual-use field/parking. The absence of updated analysis is <br /> directly linked to the City's choice to process the application as a modification instead of <br /> requiring a new CUP, thereby bypassing the protections and scrutiny that a new CUP process <br /> would mandate. <br /> The decision to process the application as a modification to CUP No. 1982-18 rather than as <br /> a new CUP was inappropriate given the substantive change in use, significant intensification <br /> of operations, and expanded impacts to adjacent R-1 residential property. This procedural <br /> misstep materially reduced the level of required analysis, constrained public participation, and <br /> limited the scope of review necessary to evaluate the project's appropriateness and impacts. <br /> This improper use of the CUP modification process constitutes an independent and sufficient <br /> basis to vacate and remand the approval so that the project may undergo the proper review <br /> required for a new CUP. <br /> 14 <br /> City Council 18 — 30 2/3/2026 <br />