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Appeal Application No. 2025-02 — Forty Martyrs Armenian Church Middle School (5311 W. McFadden Avenue) stating that cumulative impact analysis is required only when a project may contribute to a cumulatively considerable significant environmental impact. If a project's contribution to cumulative impacts is not cumulatively considerable, no further cumulative analysis is required. As proposed, the project does not have cumulative impacts that are considerable and qualifies for an exemption from further CEQA review pursuant to CEQA Guidelines Section 15314 (Class 14). Class 14 exempts minor additions to existing schools from CEQA review when the addition does not increase original student capacity by more than 25 percent or ten classrooms, whichever is less. The proposed school expansion would result in an eight percent increase in student enrollment and includes a total of five new classrooms, which is well within the thresholds established under the Class 14 exemption. As a result, the project is exempt from the requirement to prepare an Environmental Impact Report, and the lead agency is therefore not required to certify an EIR for this project. As previously stated, the City's review of a new development project is limited to evaluating the proposed project itself and ensuring that it meets all applicable federal, state, and local laws. 9. Appellant Request: Failure to Consider Feasible or Less Intrusive Alternatives Analysis of Issue: Projects that are categorically exempt from further environmental analysis are not required to prepared alternative design or site plan analysis. Furthermore, as previously stated and discussed in the Planning Commission staff report and resolution (Exhibit 3 to the February 3, 2026 City Council staff report), the project undergoes a development project review where City staff ensures compliance with Federal, State, and City codes. As such, staff must ensure that the project complies with zoning regulations, which require compliance with development standards including, but not limited to the following: • Setbacks from property lines • Adequate landscape • Design quality • Building Height The proposed project's location, lot configuration, proximity to residential properties, and existing construction limit the options available to construct the desired addition to the school. Reconfiguring the floor plan of the existing school building would not be a feasible option, as the project is responsible for compliance with Chapter 3 Occupancy Classification and Use) of the California Building Code Exhibit 6 — Response to Appeal Comments ity ounci 18 — 167 2/3/2026