1 Section 15162 Consistency Evaluation – King’s Schools Campus Expansion (67675 Bolero Road) Conditional Use Permit 25-0003 and Zoning Ordinance Amendment 25-0001
Note: The sections of this document that are italicized and bold were revised following the Planning Commission hearing on September 3, 2025.
Purpose
The Environmental Impact Report for the Cathedral City 2040 General Plan Update and Active Transportation Plan (SCH #201808012) was certified by the City Council on July 28, 2021. This memo evaluates the consistency of proposed project, comprised of Conditional Use Permit 25-0003 (amending CUP 93-199), Administrative Variance 25 -0006, and Zoning Ordinance Amendment 25 -0001 (amending Chapter 9.24 of Title 9 of the C athedral City Municipal Code), with the previously adopted General Plan EIR, as well as the eligibility for exemption from further environmental review under the California Environmental Quality Act (CEQA) in accordance with Section 15162 of the CEQA Guidelines.
Background and Project Description
CONDITIONAL USE PERMIT REVISION:
Conditional Use Permit (CUP) 93-199 was approved on February 2, 1994, for the renovation of the King’s Schools campus located at 67675 Bolero Road. The existing facilities had previously been occupied by the Palm Valley School and included approximately 17,000 square feet of building area. CUP 93 -199 was approved for the King’s Schools to renovate and expand the existing campus, including adding approximately 25,000 square feet of building area over two phases of construction , for a total of 40,954 square feet of building area. An Initial Study Negative Declaration (Environmental Assessment No. 93-516) was approved for CUP 93 -199 and adopted by the Planning Commission with the CUP (Resolution No.
P94-654).
The full expansion approved for CUP 93-199 was never built out in its entirety. As of May 2025, there are 26,594 square feet of existing on -campus facilities, out of the total 40,954 square feet approved for the original CUP.
On February 4, 2025, the King’s Schools submitted a Conditional Use Permit Revision application (CUP 25- 0003) to renovate and expand the on-campus facilities. This application proposes to revise the site plan approved for CUP 93 -199 to add an additional 11,094 square feet of building area over what was previously approved, for a total of 52,048 square feet (Attachment 1 – Existing and Proposed Site Plan).
The proposed renovation would result in an additional 25,454 square feet over what exists on the campus today, which includes a private preschool, elementary school (kindergarten through fifth grade) , and middle school (sixth through eighth grade). The intent for the proposed CUP Revision is to provide more
2 space for the school’s existing student population and will not support an increase in student capacity.
ADMINISTRATIVE VARIANCE:
The proposed campus renovation would include construction of a gymnasium for indoor recreation. The proposed gymnasium would be 28 ’-7” at the highest point, which exceeds the 26 ’ maximum height for non-lodging facilities in the RR (Resort Residential) district. The project applicant is requesting an administrative variance to allow an increase of ten percent over the maximum permitted building height.
ZONING ORDINANCE AMENDMENT:
The project site is located within the planning area for Specific Plan 88-30, established in 1988. The Specific Plan, which covers approximately 45 acres, designates a base zone of R3 (Multiple -Family Residential) over the project site. Schools, either public or private, are permitted in the R3 zone subject to a conditional use permit.
However, with the 2002 General Plan Update, the City’s General Plan Land Use Map was amended to designate the subject site as Resort Residential (RR). For consistency with this General Plan Update, the City’s Zoning Map was amended, resulting in the subjec t site being rezoned to RR. Schools are not a permitted use in the RR zoning district.
To facilitate the proposed renovation and expansion of the long -established King’s Schools campus, the project proposes a Zoning Ordinance Amendment to add schools (including public and private schools, but not business or trade schools) as a permitted use in the RR district subject to a conditional use permit.
This amendment does not propose any other changes in permitted uses or development standards in the RR district, and will apply to properties City-wide that are zoned RR.
CEQA Guidelines Section 15162 Criteria
Section 15162 (SUBSEQUENT EIRS AND NEGATIVE DECLARATIONS) (a) When an EIR has been certified or a negative declaration adopted for a project, no subsequent EIR shall be prepared for that project unless the lead agency determines, on the basis of substantial evidence in the light of the whole record, one or more of the following:
(1) Substantial changes are proposed in the project which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects;
(2) Substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revisions of the previous EIR or Negative Declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or (3) New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete or the Negative Declaration was adopted, shows any of the following:
3 A. The project will have one or more significant effects not discussed in the previous EIR or negative declaration;
B. Significant effects previously examined will be substantially more severe than shown in the previous EIR;
C. Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or
D. Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative.
(b) If changes to a project or its circumstances occur or new information becomes available after adoption of a negative declaration, the lead agency shall prepare a subsequent EIR if required under subdivision (a). Otherwise the lead agency shall determine whether to prepare a subsequent negative declaration, an addendum, or no further documentation.
Certified CEQA Document
The Environmental Impact Report for 2040 General Plan Update and Active Transportation Plan (referred to herein as the General Plan EIR) was certified by City Council on July 28, 2021. The EIR evaluated the potential environmental impacts associated with t he implementation of the City’s Comprehensive General Plan Update, including the proposed land use designations and the updated General Plan Land Use Map. The EIR analyzed environmental impacts using the existing physical conditions in the City as a baseline.
CEQA Guidelines Section 15162 Consistency Evaluation
According to CEQA Guidelines Section 15162, when an EIR has been certified for a project, no subsequent EIR shall be prepared unless new significant environmental effects or a substantial increase in the severity of previously identified significant effects would occur.
The General Plan EIR contemplated the 5.2 -acre project site including the existing 26,594 square feet of on-campus facilities and the Resort Residential (RR) land use designation. As set forth in the following discussion, staff have determined that the pro posed CUP Revision, Administrative Variance, and Zoning Ordinance Amendment are substantially consistent with the conditions analyzed in the General Plan EIR and therefore the proposed project would not result in any of the three criteria in CEQA Guidelines Section 15162, as listed above. As such, no further environmental documentation is necessary.
(a) When an EIR has been certified for a project, no subsequent EIR shall be prepared for that project unless the lead agency determines, on the basis of substantial evidence in the light of the whole record, one or more of the following:
4 (1) Substantial changes are proposed in the project which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identifie d significant effects
The project does not propose substantial changes that would require a revision to the General Plan EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects.
CONDITIONAL USE PERMIT REVISION:
As stated in the project description above, the conditional use permit for the original King’s Schools campus renovation was approved in 1994. During the preparation of the General Plan EIR in 2018 -2021, the campus existed and operated in its current state. The school, therefore, was accounted for in the baseline environmental conditions used to analyze potential impacts in the General Plan EIR.
The proposed revision to CUP 93 -199 would not expand the private school campus beyond the existing
5.2-acre site, nor does it propose any off-site improvements. All new construction would occur within the developed area of the project site. Project construction would be subject to all applic able construction and pre-construction mitigation measures established in the General Plan EIR, and no new impacts or changes in previously identified impacts would occur.
The proposed campus renovation will upgrade and expand the school’s classrooms, as well as administrative, operational, and multi-purpose spaces. This will include replacing existing portables with permanent buildings for classrooms, the construction of a new gymnasium for indoor recreation, as well as the construction of additional surface parking areas. A hydrology study and water quality management plan were prepared for the project to ensure that the new buildings and impervious surfaces will not impact water quality or result in increased run-off.
The proposed campus renovation will not support an increase in student capacity. The school’s enrollment is approximately 300 students (Attachment 2 – Student Enrollment). The preschool program has capacity for up to 75 students based on state licensing. The kindergarten through eighth grades each have one class per grade (nine classes total), with an average of 25 students and a maximum of 28 students per class. The campus currently has preschool five classrooms as well as one classroom per grade (nine total) for the kindergarten through eighth grade s. The proposed campus renovation would add one specialized preschool classroom, dedicated for indoor group activities, and five specialized classrooms for the kindergarten through eighth grades: three rooms dedicated to art, music, and computer courses, and two rooms dedicated to middle school elective courses. None of the proposed classrooms are intended to support increased student capacity. Given that that the CUP Revision would not result in a meaningful change in the number of students or staff, it also would not result in a significant increase in the traffic generated by the campus during daily operations, relative to the traffic and noise analyzed in the baseline conditions for the General Plan EIR.
5 Likewise, the campus renovation would not generate new sources of on-site noise, nor would the volume of noise generated by daily operations be expected to increase. Once the proposed gymnasium is constructed, n oise generated by typical operations may decrease as some physical education and recreation activities, currently held exclusively outdoors, are moved to indoor facilities . Overall, the proposed CUP Revision will not result in meaningful changes to the school’s standard operations, as analyzed in the baseline conditions for the General Plan EIR, including impacts related to transportation, air quality, noise, and public services.
In addition to day-to-day operations, the school also periodically organizes special events, such as open houses, student musicals, graduation, and fundraising events . Currently, these events are either held outdoors on the campus or at an off -site venue. After construction of the proposed gymnasium, the school intends to use the facility to host these events on -campus. All on-campus special events will be organized by the school for its students, and will be typical of events associated with schools. While these events would generate additional vehicle trips to and from the site, the increased traffic would be periodic and temporary, and therefore would not result in new significant impacts or a substantial increase in the severity of previously identified impacts.
ADMINISTRATIVE VARIANCE:
The General Plan EIR analyzed land uses based on the land use designations established in the General Plan Land Use Map. This map designates the subject site as Resort Residential, which corresponds with the RR (Resort Residential) zoning district. The RR zoning district allows range of maximum building heights depending on the proposed land use and the type and proximity of surrounding land uses.
The proposed campus renovation would include construction of a multi -purpose building, including a gymnasium. The gymnasium portion of the proposed multi-purpose building would be 28’-7” tall, which exceeds the 26-foot maximum building height for non-lodging facilities in the RR district. This portion of the building is set back by approximately 80 feet from the nearest adjacent property, which is zoned RR.
A lodging facility on this same location would be allowed a building height of up to 40 feet.
The proposed 28’-7” building height would be allowed for lodging facilities in the RR district, and therefore is consistent with the intent of the Resort Residential land use designation. Therefore, the proposed height would have been accounted for in the conditions analyzed in the General Plan EIR, and no changes or revisions to the EIR would be needed to account for the proposed administrative variance.
ZONING ORDINANCE AMENDMENT:
The General Plan EIR analyzed land uses based on the proposed designations set forth in Table LU -2 of the General Plan, which defines the purpose of the RR district as follows:
This low-density designation is intended to accommodate single family and attached residential development in a master planned resort setting. On- site amenities typically include golf courses, tennis and swimming facilities, as well as tourist/resort-serving commercial uses. This designation also allows hotels/motels and ancillary visitor and tourist-serving commercial uses.
6 The uses permitted in the RR zoning district (subject to a planned unit development permit or a conditional use permit) correspond with the uses described above, including single and multi-family dwellings as well as tourist-serving uses such as hotels, restaurants, golf courses, health spas, and conference rooms. The proposed Zoning Ordinance Amendment would add schools (either public or private, but not including business or trade schools) as a conditionally permitted use in the RR district.
Other than the RR zoning district, all the other residential zoning districts in the City (including RE, R1, R2, RM, R3, R4, DRN) permit schools with a conditional use permit. This indicates that schools are a use that is consistent and compatible with the intent of residential land use designations. The proposal to add schools as a conditionally permitted use in the RR zoning district would thus remain consistent with the purpose of the Resort Residential designation as set forth in the General Plan, as well as the current CUP approved for the school, which has been in place since 1994. Therefore, the proposed Z oning Ordinance Amendment would not require a general plan amendment for consistency and the project would not require major revisions to the General Plan EIR.
In addition to residential uses, the R esort Residential designation and RR zoning district contemplate tourist-serving commercial uses. Private and public schools would be expected to generate similar or less significant environmental effects – including in terms of transportation, air quality and greenhouse gas, public services and utility impacts – than these commercial uses that may support numerous employees and draw large numbers of visitors from the wider region and beyond.
Therefore, the impacts analyzed for the Resort Residential designation in the General Plan EIR would encompass potential impacts associated with public and private schools. As such, the proposed Zoning Ordinance Amendment would not require major revisions of the General Plan EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects.
(2) Substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revisions of the previous EIR due to the involvement of new significant environmental effects or a substantial increase in the severi ty of previously identified significant effects; or
Since the certification of the General Plan EIR in 2021, there have been no substantial changes to the environmental setting that would result in new or more severe environmental impacts.
As set forth in subsection (a)(1) above, the King’s Schools campus was accounted for in the existing conditions analyzed in the EIR, and the proposed campus renovation , including the CUP Revision and Administrative Variance, will not result in substantial changes with respect to the circumstances under which the General Plan was undertaken. Likewise, the proposed Zoning Ordinance Amendment to add schools as a conditionally permitted use in the RR zoning district would remain consistent with the Resort Residential land use designation as analyzed in the EIR, and therefore no substantial changes with respect
7 to the circumstances under which the General Plan was undertaken will occur. The area surrounding the project site is mostly built out, and no other new projects are being contemplated at this time. The surrounding environmental conditions and regulatory requirements analyzed in the General Plan EIR remain current and therefore no revisions to the original analysis are required under CEQA Guidelines §15162(a)(2).
(3) New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete, shows any of the following:
a. The project will have one or more significant effects not discussed in the previous EIR or negative declaration;
b. Significant effects previously examined will be substantially more severe than shown in the previous EIR;
c. Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or
d. Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative.
The proposed project does not result in new information that was not known or could not have been known at the time of the General Plan EIR certification. a. The proposed project will not result in any significant effects that were not analyzed in the General Plan EIR. As demonstrated above, the General Plan EIR analyzed potential impacts and established mitigation measures for implementation of the General Plan based on the existing conditions and assuming build out of the land use map, including the Resort Residential designation. As discussed above, the proposed CUP Revision, Administrative Variance, and ZOA are substantially consistent with the conditions an alyzed in the General Plan EIR, and would not result in significant effects not previously discussed.
b. The proposed project would not result in substantially more severe significant effects than previously analyzed in the General Plan EIR. As demonstrated above, the proposed CUP Revision, Administrative Variance, and ZOA are substantially consistent with the conditions analyzed in the General Plan EIR, and therefore would not result in substantially more severe significant effects than previously analyzed because no increase in school capacity will result, and the site is currently in use as a school.
c. Applicable mitigation measures established in the General Plan EIR will continue to apply to the
8 proposed project and will continue to adequately mitigate potential impacts. d. There are no additional mitigation measures that would apply to reduce any significant effects that were different than those analyzed under the General Plan EIR. The mitigation measures analyzed in the General Plan EIR will continue to apply to the proposed project.
(b) If changes to a project or its circumstances occur or new information becomes available after adoption of a negative declaration, the lead agency shall prepare a subsequent EIR if required under subdivision (a). Otherwise the lead agency shall determine whether to prepare a subsequent negative declaration, an addendum, or no further documentation.
The General Plan EIR covers the proposed project within its scope. As set forth in subdivision (a) above, no further documentation is required as the proposed project complies with the anticipated use for the
5.2-acre site as analyzed in the baseline conditions and anticipated for the Resort Residential designation.
Potential impacts from the proposed project were sufficiently analyzed in the General Plan EIR, no new circumstances have occurred and no new information of significance has become available sin ce the certification of the EIR. No further documentation is required pursuant to CEQA Guidelines Section 15162.