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SECTION 8 — CUMULATIVE IMPACT FAILURE The City failed to evaluate cumulative impacts arising from interconnected institutional uses along the McFadden Avenue corridor, resulting in an incomplete and legally insufficient review that does not meet required standards for land use or environmental consideration. 8.1 Improper Segmentation and Failure to Evaluate the Whole of the Action The review and approval of the project were improperly segmented to focus solely on the applicant's parcel, without accounting for the combined impacts of multiple CUP-authorized institutional uses along the McFadden corridor. Rather than evaluating the "whole of the action," the City reviewed the project in isolation, disregarding the cumulative and overlapping effects created by interconnected operations, shared facilities, and concurrent institutional activity. This segmented approach prevented a full and accurate assessment of the project's true residential and environmental impacts. T 8.2 Multi-Institutional Corridor,Creates Compounded and Continuing Impacts The institutional properties at 5305, 5311, 5315, and 5321 W. McFadden Avenue collectively form a continuous institutional corridor, functioning in coordinated or overlapping capacities. Shared pedestrian pathways, emergency access easements, coordinated or public-facing uses, and active CUP conditions create a sustained institutional presence along the eastern boundary of the R-1 Trust residence. The combined effect is not a single neighboring use, but a corridor-level institutional condition producing amplified daily activity, noise, circulation, and operational influence along a single residential property line. These compounded impacts far exceed what is typical for a single-site school adjacency, and should have triggered cumulative impact evaluation. 8.3 Cumulative Environmental and Operational Burdens on the Adjacent R-1 Residence The Trust residence is uniquely burdened as the only R-1 property directly sharing a boundary with more than one Institutional site. The cumulative effects include increased noise, vehicle and pedestrian circulation, lighting spillover, loss of privacy, activity during school and non- school hours, and continuous institutional presence at the property line. The presence of senior and ADA-protected residents heightens the significance of these impacts, as cumulative environmental exposure has a disproportionate effect on individuals with medical, mobility, or sensory-vulnerability considerations. These layered impacts required integrated review, yet were not acknowledged or assessed. 8.4 Failure to Consider Reasonably Foreseeable Future Institutional Intensification Cumulative impact review also requires consideration of reasonably foreseeable future conditions—not solely existing uses. In this corridor, future intensification is not speculative; it is evidenced by (1) a previously approved CUP for 5321 W. McFadden Avenue that has not yet been constructed or operationalized, (2) programmatic expansion from K-6 to K-8, (3) conversion of a portion of the athletic field to multi-use parking, and (4) ongoing event-based and non-instructional activity, including commercial ticketed events at 5315 W. McFadden Avenue. These known and documented factors demonstrate an active pattern of institutional expansion. Failing to account for this foreseeable progression rendered the cumulative impact evaluation materially incomplete. 21 City Council 18 — 37 2/3/2026