EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
in these events would be required to cross the roadway repeatedly throughout play. That repeated crossing pattern-by adults focused on competition and movement, not vehicle traffic-creates an additional, foreseeable point of conflict between pedestrians and vehicles.
The submitted plan itself shows that the natural path of travel from the heart of the tennis and pickleball courts to the food truck and pool cuts directly across the internal drive and circulation area tied to the bungalow component. In the real world, children do not stop at neat crossing points and wait for vehicles. They run where they have always run. Members move where they have always moved. The danger is therefore not speculative. It is foreseeable on the face of the design.
FOOD TRICK
(NCT A PART)
LAKE
NAYACAVA
RANCHO
VALENCI
CASA NEW TITNESS /
PALMERO LOFT BUILEING
ASTIALS ON B PARKING SIALS,
150
Proposed site plan showing the internal roadway and parking area ("Conflict Zone") bisecting the Chib's primary tennis and pickleball facilities, where regular pedestrian movement— particularly by children and players rotating between courts—intersects directly with vehicular traffic.
The economic justification for introducing this risk has also shifted. At Golf Realty Fund's presentation on Friday, January 23, 2026, members were told that bungalow revenue was necessary to fund the pool and fitness improvements. Later, Golf Realty Fund represented to the Council that it has sufficient funds to build and maintain those improvements even if the Page |7
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
aggressive revenue projections tied to the bungalow and loft component do not materialize. By Golf Realty Fund's own later account, it does not need this additional revenue stream to construct and maintain the facilities. If that is true, then the question for the Council is not whether more revenue would be desirable. The question is whether this added safety risk is worth the cost. It is not.
The concern becomes even more serious because Camaraderie Clubs has already stated that it will not manage the lodging facilities. That means a third party will do so. A third-party lodging operation brings with it its own traffic patterns: guest arrivals and departures, deliveries, rideshare traffic, off-site food runs, and trips for alcohol and other services that are not necessarily integrated with Club operations, including when dining facilities are closed (e.g Mondays). These risks are compounded by the fact that members themselves will use the same internal circulation area for parking and access to the tennis and pickleball facilities, further increasing vehicle volume in the same environment where children and members are walking and running between athletic and pool facilities. And in each and every one of these scenarios, the Council should assume alcohol will be consumed.
The timing of this application only heightens the concern. Golf Realty Fund appears to be trying to push this project through because it is running out of time under its own contractual obligations, which may expose it to financial consequences. But a private deadline is not a legal basis to shortcut public safety review. The fact that the owner may feel urgency is a reason for the Council to slow down, not a reason to approve an incomplete and under-analyzed design.
A comprehensive, independent safety study must be completed. At a minimum, that study should evaluate pedestrian circulation, child movement patterns, vehicle conflict points, visibility and sightlines, construction-phase hazards, and the operational risks associated with the bungalow and loft component. Without that work, approval would be premature.
The City would never route an internal lodging-access road through one of its own active recreational spaces without rigorous safety analysis. It should not permit that result here simply because the project is privately proposed. The stakes are high. If a child is struck by a vehicle in a conflict zone the plans themselves create, the resulting liability exposure would be extraordinary. As a trial lawyer, I view the owner, the operator, and the City as the approving authority as obvious defendants in that scenario, and the exposure could exceed $100 million in a catastrophic injury case. That outcome is not worth a minor, unnecessary revenue stream. And it can only even be argued to be worth the risk if a comprehensive safety study is done first.
Page |8
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
Costa Mesa, CA 92626
ENENSTEIN PHAM GLASS (714) 292-0262
GUTENPLAN & BOLLING LLP epggblaw.com
Jesse K. Bolling
Managing Partne
[email protected]
3. The proposed plan will have additional adverse effects on the Club's tennis program and daily operations, and if the back courts are not lit, tennis will wither at the Beyond the serious safety concerns addressed above, the proposed project would also materially impair the Club's tennis and pickleball program and its broader day-to-day operations.
First, the project threatens the viability of nighttime tennis at the Club. As the proposed plan makes clear, the six back courts at the far western end of the property become critically important if three existing lit courts are removed. If those back courts cannot be lit, the Club will effectively go from seven lit courts to only four. That reduction would fundamentally alter the Club's evening tennis program and, in practical terms, could cause tennis at the Club to wither.
Most notably, it would jeopardize some of the Club's some of the most popular organized evening events, including Men's Night and Ladies' Night, where large groups of players participate in round-robin doubles. The junior program, which goes until 7:00 p.m. PST, would also be jeopardized. For many members, those events are the core of the Club's tennis culture and one of the principal reasons they remain active members.
Any loss of courts must be tethered to the back courts being capable of lawful nighttime use. At present, however, the problem is that the prior conditional use permit associated with those courts reportedly does not allow lighting because of their proximity to neighboring homes. (Exhibit B.) Golf Realty Fund appears to be exploring technological solutions to reduce light spill, but the practical reality remains the same: nearby homeowners would be looking at illuminated courts on a nightly basis. That issue should not be ignored or deferred. It should be confronted directly now because, without a realistic and enforceable solution, the project substantially diminishes the Club's ability to function as a tennis facility.
Second, the elimination of three tennis courts will materially affect daytime operations as well. The Club's tennis program is not limited to casual drop-in use. It supports numerous teams, private lessons, daily junior programs, clinics, and organized member play throughout the week.
While no club can honestly claim that every court is full at every hour of every day, that is not the standard. The relevant question is whether the reduction in court inventory will impair operations during the hours that matter most. It plainly will. Peak usage periods will be squeezed.
Team practices and matches will be harder to schedule. Private instruction and junior programming will face greater competition for court time. The junior program in particular is a meaningful asset to the Club, run by a strong professional staff and designed to develop high- level young players. Orange County has already produced elite junior talent, and there is no reason that program should be diminished by a redevelopment plan that prioritizes lodging over courts.
Page | 9
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
Third, Golf Realty Fund has represented that the courts will remain open during construction. On the present record, however, it is difficult to see how that can occur in a safe and functional way. The project already proposes to remove courts, insert internal circulation, and carry out major construction immediately adjacent to active recreational use. If the road and bungalow components were eliminated, there would at least be a greater possibility of preserving meaningful tennis operations during construction. But under the current design, the notion that children can safely attend junior camp, that coaches can conduct lessons, and that teams can play normally while roads are being paved and heavy construction is underway has not been substantiated. The Council should not simply assume that normal Club operations can continue through a prolonged and invasive construction process without a detailed, credible operational plan.
Taken together, these impacts are not secondary or incidental. They go to the heart of what The Huntington Club is and how it functions. This is not merely a question of replacing old facilities with new ones. It is a question of whether the Club's tennis community, junior development program, and nighttime member culture will survive the project in anything like their present form. On the current record, there is substantial reason to doubt that they will.
4. The City's Zoning Code does not allow people to sleep overnight in recreational space.
The Council's discretion under the Conditional Use Permit process is not unlimited. A CUP is not a blank check to authorize any use the City wishes to allow based on generalized notions of "good cause." Under the Huntington Beach Zoning Code, a CUP may be granted only where the Council can make the required findings, including that the proposed use is consistent with the General Plan and all applicable requirements of the Municipal Code. Most importantly, the Council must be able to find that the proposed use will comply with the provisions of the base district and other applicable provisions of the Zoning Code. If those findings cannot be made, denial is required.
That requirement has procedural consequences here. The Council must be able to support each required finding with substantial evidence in the administrative record at the time of approval. Where material issues— such as whether the project can be operated safely-remain unresolved, the Council cannot defer that determination to a future study. Absent substantial evidence demonstrating that the project can be operated safely, the Council cannot make the findings necessary to approve the Conditional Use Permit.
That is the core issue here. The subject property is in the OS-PR district. Huntington Beach's zoning regulations provide that uses not listed in a district's land use controls are prohibited. In OS-PR, "Park & Recreation Facilities" may be allowed with a CUP, and certain Page | 10
EPG-BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
ancillary uses may be permitted in limited form, but the Code does not separately list general lodging or visitor accommodations as an authorized OS-PR use. From a legal perspective, the threshold question, therefore, is not whether the bungalow and loft component may be desirable or financially beneficial. The threshold question is whether that lodging component is actually an authorized use in OS-PR at all.
The City's own use-classification scheme sharpens that issue. Huntington Beach distinguishes between "Clubs and Lodges," on the one hand, and "Visitor Accommodations," on the other. "Clubs and Lodges" are recreational or social facilities primarily for members or guests. "Visitor Accommodations" are separately defined lodging uses, including hotels, motels, and similar short-term occupancy arrangements. The Code thus does not treat private club use and overnight lodging use as interchangeable. They are different use categories. That distinction matters here because the proposed bungalow and loft component appears, in substance, to function as a lodging use rather than merely as part of the Club's traditional recreational operations.
Accordingly, if the City's position is that the bungalow and loft component constitutes a lodging or visitor-accommodation use, then the Council should identify precisely where that use is permitted or conditionally permitted in OS-PR. If the City's position is instead that the lodging component is merely accessory or incidental to the recreational use, then the Council should explain how overnight accommodations are truly subordinate to, and customarily associated with, the principal recreational use of the site, rather than a separate revenue-generating use added to the property. Either way, the Council must still make the finding that the project complies with the base district. A CUP does not eliminate that requirement.
There is a further problem. The Huntington Beach Code contemplates that, if a proposed use cannot be clearly classified within an existing use category, the answer is not simply to approve it by CUP anyway. Rather, the Code assigns use-classification decisions to the Director and, where no existing classification clearly applies, the proper remedy is a change to the zoning text. In other words, the City may not use the CUP process to create a new hybrid use that the Code does not presently authorize.
For that reason, the Council should require a clear answer to a simple question before acting: what, exactly, is the legal use classification for the proposed bungalows and lofts, and where is that use authorized in OS-PR? And critically, the Council must also be able to determine—based on substantial evidence that the project, as designed, can be operated safely before any approval is granted. Unless and until those questions are answered in a manner that allows the Council to make the required findings, approval of the lodging component would be legally vulnerable and premature.
Page | 11
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
Costa Mesa, CA 92626
ENENSTEIN PHAM GLASS (714) 292-0262
GUTENPLAN & BOLLING LLP epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
5. There is no justifiable basis to move forward with the proposed plan unless and until, at a minimum, a comprehensive safety study is conducted.
For all of these reasons, there is no justifiable basis for the Council to move forward with the proposed plan unless and until a comprehensive safety study is completed. Without that study, the Council lacks substantial evidence necessary to determine that the project can be operated safely and therefore cannot make the findings required for approval of the Conditional Use Permit.
We therefore respectfully request that the Council continue this matter for at least 60 days so that the proposed project can be evaluated on a more complete and reliable record.
Respectfully Submitted,
ENENSTEIN PHAM GLASS GUTENPLAN & BOLLING, LLP
By:
Jesse K. Bolling, Esq.
Cc:
• Casey McKeon, Mayor: [email protected]
• Butch Twining, Mayor Pro Tem: [email protected] • Gracey Van Der Mark, Councilmember: Gracey. [email protected] • Pat Burns, Councilmember: [email protected]
• Don Kennedy, Councilmember: [email protected] Chad Williams, Councilmember; Chad. [email protected] • Andrew Gruel, Councilmember: [email protected] Page |12
EXHIBIT A
Julie Ann Crandall
From: The Huntington Club < [email protected]> Sent: Saturday, February 7, 2026 8:11 AN
To: Jesse Bolling
Subiect: Camaraderie Clubs Clarification ~ Townhall Meeting x
Saturday, February 7, 2026
Dear Members of The Huntington Club,
It has been two weeks since Golf Realty Fund and Johnathon Baily held a town hall meeting at the Huntington Club to discuss the New Performance Center Building, new pool, and bungalow project. Over the past two weeks, we have noticed some confusion regarding the relationship between the tenant of THC (Camaraderie Clubs) and the landlord/property owner (Golf Realty Fund). To clarify, Camaraderie Clubs pays rent to code is cats biatoms However, a the propony aunt menton in the planning commission meeting on January 27th, they have yet to fulfill their obligations. In the past six years since the lease was signed, Golf Realty Fund is still in the process of obtaining the necessary approvals for the project.
In addition, Camaraderie clubs would like to clarify the following misconceptions we have heard from the members.
1. Johnathon Baily represents Golf Reality Trust and is not affiliated with Camaraderie Clubs or involved in our operational decisions regarding THC. We want to make it very clear: WE DO NOT ENDORSE HIS STATEMENT MADE DURING THE TOWN HALL MEETING, where he said, "WE ARE COMFORTABLE AND CONFIDENT IN THE
ECONOMICS, AND YOU GUYS ARE FREE TO SPEAK WITH YOUR WALLETS AND SAY, 'HEY, NO, THIS CLUB ISN'T FOR US; WE WILL LEAVE."" Jonathon Baily and Golf Realty Trust do not have the authority to make such statements to you, our valued customers, and members of THC. As made evident by the recent survey, we value member feedback and will use that feedback to frame our capital investment and operational opportunities. We deeply value your membership and thank you for choosing to be a part of our Club.
2. Currently, Camaraderie Clubs has no financial interest or contractual obligation to manage the bungalows and loft apartments proposed by Golf Realty Fund. Camaraderie Clubs has been steadfast in its efforts to compel the landlord to honor its obligations to construct a new swimming pool and upgrade the fitness facilities over the past 6 years.
The ownership of The Huntington Club is dedicated to the ongoing improvement of the Club and its facilities, aiming to preserve and enhance the experience enjoyed by its members.
We will always advocate for the interests of the Club and its members with conviction and respect. Please direct any questions about the project to Golf Realty Fund as they. will be best equipped to answer questions about their project.
Sincerely,
Travis Brasher - Managing Partner, Camaraderie Clubs
Joe Saikali - General Manager
6501 Palm Ave. Huntington Beach, CA 92648 714.536.8866
This message was sent to Jesse Bolling <[email protected]> by Huntington Club Click here to unsubscribe from further communications
Huntington Beach Planning Commission
P.O. BOX 190 CALIFORNIA 92648
August 6, 1985
.. Huntington Beach Company
2110 Main Street
Huntington Beach, CA 92648
SUBJECT: CONDITIONAL USE PERMIT NO. 85-25/COASTAL DEVELOPMENT PERMIT NO. 85-19/NEGATIVE DECLARATION NO. 385-26
REQUEST: To termit construction
of 6 tennis courts.
LOCATION: East side of palm Ave.
approximately 300 ft.
south of Cherryhill Ave.
FINDINGS FOR APPROVAL CONDITIONAL USE PERMIT NO. 85-25:
1. The proposed six tennis courts are compatible with surrounding land uses and in conformance with the General Plan policies because facility will become an integral part of the
existing seacliff. Country club.
2. The proposed tennis courts will not be detrimental to the generrl health, welfare, safety and convenience of persons residing or working in the neighborhood because the facility will lave hours of operation limited to the daytime:
3. The iocation, site layout, and design of the proposed development does properly adapt the structure to streets, driveways and other uses in a harmonious manner.
FINDINGS FOR APPROVAL COASTAL DEVELOPMENT PERMIT NO. 85-2:
The proposal for 6 tennis courts is consistent with the City • 1.
Coastal Zone suffix as well as other provisions of the
Huntington Beach Ordinance Code applicable to the property; and conforus with the plans, policies, reguirements and standards of the City's Coastal Land Use Plan.
2. The proposed development can be provided with infrastructure in a manner that is consistent with the Coastal Land Use Plan.
3. The proposed development conforms with the public access and public recreation policies of Chapter 3 of the california Coastal Act.
CONDITIONS OF APPROVAL CONDITIONAL USE PERMIT NO. 85-25:
1. The site plan dated May 22, 1985 shall be the approved layout.
2. Prior to issuance of building permits, the applicant shall submit a landscape and irrigation plan to the Department of Development Services and Department of Public Works for review and approval.
3. The tennis courts hours of operation shall be limited to daytime hours. No artificial lighting shall be permitted.
4. A copy of the tennis club membership/entry requirements shall be submitted to the Department of Development Services to assure the membership/use is limited to country club members.
5. All building spoils, such a unused lumber, wire, pipe and surplus or unusable materials, shall be disposed of at an off-site facility equipped to handle them.
I hereby certify that Conditional Use Permit No. 85-25, Coastal Development Permit No. 85-19 and Negative Declaration No. 85-26 was approved by the Planning Commission of the City of Huntington Beach on August 5, '1985 by the foregoing citations and conditions.
Sincerely,
Ilnena Wilt/fir
James W. Palin
Secretary
Planning Commission
JWP: 1p
(3037đ(3)
From: Levin, Shannon
To: Villasenor, Jennifer
Subject: FW: Huntington Club members letter
Date: Monday, April 20, 2026 11:13:40 AM
Attachments: 2026.04.10 Letter to HBCC (FINAL).pdf
From: Dennis Donsker <[email protected]>
Sent: Monday, April 20, 2026 10:38 AM
To: CITY COUNCIL (INCL. CMO STAFF) <[email protected]> Subject: FW: Huntington Club members letter
Some people who received this message don't often get email from [email protected]. Learn why this is Please come and visit this weekend, see what a wonderful club we have and how we use the facilities. The new layout makes no "common sense". There could be a hidden agenda by Golf Realty Fund to force out the tennis and pickleball members. build more bungalows and turn this property into a golf resort.
5EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
April 10, 2026
SENT VIA EMAIL
Huntington Beach City Council
2000 Main Street
Huntington Beach, CA 92648
Email: [email protected]
Re: April 21, 2026 Hearing re The Huntington Club Remodel and Bungalows Dear Mayor and Members of the City Council,
I submit this letter in two capacities: (1) as pro bono counsel to appellants Cheryl Gates, Susan Ridgeway, and Douglas Scott Warren; and (2) as a current member of The Huntington Club with a direct interest in the continued availability and character of its facilities. I am an active golf and tennis member of the Club, and my family and I regularly participate in its athletic programs.
To summarize, Golf Realty Fund has a reported contractual obligation of approximately $10 million to $15 million to complete improvements at the Club. In structuring that arrangement, Golf Realty Fund retained control over the buildout, positioning itself to convert that obligation into an additional revenue stream through hotel-like lodging for "members and their guests." At the most recent hearing, Golf Realty Fund implied that it does not need that additional revenue to fund the renovations; it simply seeks an additional revenue stream from the property.
Standing alone, that economic choice would not necessarily be problematic. The problem is the particular plan Golf Realty Fund has chosen to pursue. As proposed, it introduces serious safety risks for Club members and their families. Members and their children move constantly through this area circulating among the courts, the pool, the fitness center, and food service locations often in unpredictable patterns that are inherent to an active recreational environment.
The proposed design forces those same children to cross an internal roadway serving both lodging-related traffic and everyday member vehicle traffic, as members will naturally use that area for convenient parking in the more than thirty new parking spaces located directly adjacent to the tennis and pickleball courts. The plan therefore concentrates vehicle traffic in the exact space where children and families are moving on foot.
This creates a direct and foreseeable conflict between vehicles and pedestrians. That risk is compounded by the nature of the proposed use, which will introduce guest traffic, ride-share Page | 1
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
activity, deliveries, and the potential for alcohol-related driving into the same space where children are playing and moving freely. The foreseeable result is not minor or theoretical it is the risk of serious injury in a setting that has always functioned as a protected recreational environment. Up until now, Golf Realty Fund has asked the Council to allow that plan to proceed without the benefit of a comprehensive safety study, ostensibly because its contractual deadline to complete these improvements will expire in early May 2026.
That private timing pressure is no substitute for a complete and reliable public record, particularly where the safety of Huntington Beach families who use what many regard as the City's crown jewel is at stake. More time is needed to determine whether this design can be made safe. Without that work, approval would expose Golf Realty Fund, its tenant, and the City of Huntington Beach to substantial liability if a member-or worse, a child—is injured.
In good faith discussions between the Appellants and Golf Realty Fund, the concept of a comprehensive safety study has been raised. Golf Realty Fund appears amenable to conducting such a study, but there remains a critical procedural issue. It is my understanding that Golf Realty Fund prefers that the safety study be imposed along with approval of the plan. We respectfully submit that this approach is improper under the circumstances and should be rejected.
The Council should instead retain jurisdiction over this matter and require completion of the safety study before any approval is granted. The Appellants' ability to advocate on behalf of the Club's membership is tied to this appeal. As a non-equity club, members do not control the property; their voice is exercised through this process and through the Council's oversight. If the project is approved subject to later study, that voice is effectively extinguished, and future decisions regarding safety, design, and implementation will be left to private entities whose interests may not align with those of the citizens most directly affected.
Moreover, the Council cannot make the required findings in support of approval without first establishing, based on substantial evidence, that the project can be operated safely. Nor may the Council defer that determination to a future study, as doing so would leave a critical component of the approval unsupported by the administrative record at the time of decision. Where material safety concerns remain unresolved, approval would be premature because the record would not contain substantial evidence sufficient to support the findings required for a Conditional Use Permit.
Based on the foregoing, we respectfully request that the Council continue this hearing for at least 60 days so that the proposed plan can be more fully evaluated, particularly in light of the serious safety concerns created by placing a roadway with significant parking capacity in the middle of the Club's tennis and pickleball facilities. The Council should direct Golf Realty Fund to conduct a comprehensive safety study by an independent consultant approved by the Council Page |2
EPG-BLAW Orange County Office
3200 Bristol Street, Suite 400
Costa Mesa, CA 92626
ENENSTEIN PHAM GLASS
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
and Appellants. Once completed, that study should be circulated for review and comment, and only then should the Council determine whether the project, as proposed, is safe enough for approval.
1. The factual background demonstrates no evaluation of safety concerns amid contractual time pressure and a breakdown between owner and operator.
The factual statements set forth in this letter are based on a combination of publicly available materials and information obtained through discussions with individuals represented to have knowledge of the operations, agreements, and history of the Club. Except where expressly supported by cited documents or witnessed by me or my clients, these statements are provided on an informational basis only. I therefore do not present these statements as adjudicated fact, but rather as contextual background to assist the Council in understanding the circumstances surrounding the proposed project.
• The entity operating the Club, Camaraderie Clubs, is led by Travis Brasher, who previously served as a golf professional at the Club when it operated under its former name, Seacliff Country Club. Mr. Brasher founded the Travis Mathew apparel brand, which was later sold, and has since returned, now as the tenant overseeing operations at the Club, rebranding it as The Huntington Club.
• Prior to the COVID-19 pandemic, Camaraderie Clubs entered into a long-term lease agreement-reported to be approximately 30 years in duration-with the property owner, Golf Realty Fund, under which it operates the Club.
• As part of that long-term lease arrangement, both Camaraderie Clubs and Golf Realty Fund are understood to have contemplated and committed to significant capital improvements to the Club's infrastructure in recognition of the age and condition of the existing facilities.
• Camaraderie Clubs has invested substantial capital into the Club, reported to be in the range of approximately $8 million to $10 million.
• Golf Realty Fund, as property owner, is likewise understood to have committed to a significant capital contribution toward redevelopment of the property, reported to be in the range of approximately $10 million to $15 million, none of which has yet been deployed. The lease or related agreements reportedly include a deadline for completion of those improvements in early May 2026. Based on that reported deadline, Golf Realty Fund appears to be under substantial time pressure to obtain approvals and move the project forward.
Page |3
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
Costa Mesa, CA 92626
ENENSTEIN PHAM GLASS
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
• The proposed project includes demolition and replacement of fitness and swimming facilities, as well as the addition of new structures, including bungalow units, loft-style accommodations, and related site improvements. More specifically, the project includes (i) conversion or construction of second-floor space within a proposed fitness facility into loft-style accommodations and (ii) construction of detached bungalow-style units on the property. The project would also eliminate three lit tennis courts used for nighttime play and divide the tennis and pickleball facilities with a large internal road serving the bungalow component, including more than thirty parking spaces located within that internal circulation area.
• Golf Realty Fund also submitted an alternative concept involving the addition of a third story to the fitness facility without including the bungalow lodging component.
According to information provided by a City employee, that submission was marked "Incomplete" because it did not contain sufficient detail to determine whether it complied with applicable height limitations. Even if that proposal ultimately raised height- compliance issues, the City retains discretion to evaluate whether such limitations could be addressed or modified through appropriate planning mechanisms. A plan without an internal roadway through the recreational core, therefore, is theoretically possible. • At a presentation by Golf Realty Fund to Club members on Friday, January 23, 2026, at which Camaraderie Clubs was absent, a representative of Golf Realty Fund told members that revenue from the bungalow component was necessary to fund reconstruction of the pool and fitness improvements. Golf Realty Fund has also provided the City with aggressive revenue projections for these rental units, particularly in light of the competition from multiple high-end beachfront hotels in the area. In subsequent representations to the City Council, however, Golf Realty Fund indicated that it has sufficient financial resources to build and maintain the proposed improvements even if those revenue projections were not realized. Those two positions are difficult to reconcile and bear directly on whether the bungalow component is truly necessary or instead an added revenue stream being pursued despite the costs it imposes. • I received a written communication distributed by Camaraderie Clubs to Club members dated February 7, 2026 (Exhibit A). In that communication, Camaraderie Clubs expressly states that it "has no financial interest or contractual obligation to manage the bungalows and loft apartments proposed by Golf Realty Fund." • The same communication also alludes to the statements made by Golf Realty Fund during its town hall meeting with Club members concerning the proposed project. At that meeting, Golf Realty Fund stated that members were "free to speak with [their] wallets" in response to the proposed changes.
Page | 4
EPG-BLAW Orange County Office
3200 Bristol Street, Suite 400
Costa Mesa, CA 92626
ENENSTEIN PHAM GLASS
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
• The February 7, 2026 communication further clarifies that Camaraderie Clubs does not endorse that statement and distinguishes its operational role from that of the property owner with respect to the proposed development.
• It is anticipated that, if the contemplated redevelopment obligations are not satisfied within the early May 2026 timeframe, a dispute between landlord and tenant may arise, potentially resulting in litigation. This point is noted solely to provide context regarding the relationship between landlord and tenant, which, from my perspective, is troubling. • In negotiations among the parties, there has been a general refusal to have all sides sit down together to resolve their issues. Golf Realty Fund has asserted that Camaraderie Clubs contractually agreed to limit or waive its ability to object to certain aspects of the redevelopment plan, including the bungalow component. I have learned nothing that contradicts that assertion. At the town hall meeting, Golf Realty Fund flashed a specific portion of the lease when making that point to members, but I was not provided with a sufficient opportunity to review that provision in full. Further, Appellants' suggestion that a thorough dialogue among all the affected parties would be the best course toward resolution has been dismissed.
2. Golf Realty Fund proposes an unsafe conflict zone within the Club's recreational core that introduces high-traffic areas into the center of club facilities visited daily by families.
The plans submitted to the City do not merely remodel a private club. They change the way this entire recreational area would function on a daily basis. Instead of keeping vehicular circulation at the perimeter, the proposed design pulls vehicle movement into the same part of the site where members and their families naturally move back and forth between the tennis courts, the pickleball courts, the bungalow area, the food truck location, and the pool and fitness complex.
That matters because this part of the Club is not a static space. It is one of the most active family areas on the property. During a recent tennis tournament, I watched my own three children-ages 8, 6, and 3—consistently move among the courts, the fitness center, the pool, and the food truck area. Children were running back and forth for smoothies, food, and breaks between matches. Parents and members were doing the same thing. That pattern of movement is not unusual; it is exactly how this area of the Club is actually used.
The City would never design one of its own recreational spaces this way. In publicly used Huntington Beach recreation areas, vehicular circulation is kept at the edges, while the interior is reserved for fields, courts, trails, playgrounds, and gathering space. That is not accidental. It Page |5
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
Costa Mesa, CA 92626
ENENSTEIN PHAM GLASS
GUTENPLAN & BOLLING LLP (714) 292-0262
epegblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
reflects a basic safety judgment: where children and families are moving freely, cars should not be routed through the middle of the activity zone.
Huntington
160 CENTRAL PARK
Contral Park Library Hontington Beach Eist
Parking Central Park/Secret Garden
Waratated downt Tom
Vehicular Access
Recreation
& Parking Parking
HBSC Recreations
Parking
CENTRAL PARK
• BASEBALL/SOFTBALL FIELDS
Coral Pas Dr
TURF FIELDS
Gold ARENA FIELD Recreation
• GRASS FIELDS
CATTING CAGES
SNACK BAR / RATHROOMS
FLAY GROUND
• HOSC OFFICE
Vehicular Access
& Parking
Huntington Beach park design consistently places vehicular circulation at the perimeter, while interior space is reserved for active recreation. This separation reflects a fundamental safety principle: where children and families are moving freely, vehicles are kept out of the activity zone.
The project plans submitted here do the opposite. They create a conflict zone where ordinary member movement intersects with internal vehicular circulation serving both lodging- related traffic and everyday member parking activity. The internal road does not simply pass near the courtsit runs directly through the recreational area and includes more than thirty parking spaces that will attract regular member use. The issue is not whether a careful adult can look both ways and cross. The issue is whether an active tennis and pickleball environment- used by children, teens, and families should be redesigned to require exactly that kind of vigilance in the first place.
The risk is particularly acute at the pickleball courts. Under the current layout, the pickleball courts sit adjacent to one another, and weekly ladder events regularly utilize all eight pickleball couts (four in each court bank). During those events, players continuously rotate between the two courts based on wins and losses. Under the proposed plan, the internal road would run between the two courts that are currently adjacent, meaning that players participating
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
in these events would be required to cross the roadway repeatedly throughout play. That repeated crossing pattern-by adults focused on competition and movement, not vehicle traffic-creates an additional, foreseeable point of conflict between pedestrians and vehicles.
The submitted plan itself shows that the natural path of travel from the heart of the tennis and pickleball courts to the food truck and pool cuts directly across the internal drive and circulation area tied to the bungalow component. In the real world, children do not stop at neat crossing points and wait for vehicles. They run where they have always run. Members move where they have always moved. The danger is therefore not speculative. It is foreseeable on the face of the design.
FOOD TRUCK
(NOT A PART)
LAKE
NAYACAVA
RANCHO
VALENCIA
CACA NEW FITNESS /
PALMERO LOFT BUILING
No Couflict Zone
STIMUS ON
150
Proposed site plan showing the internal roadway and parking area ("Conflict Zone") bisecting the Club's primary tennis and pickleball facilities, where regular pedestrian movement— particularly by children and players rotating between courts—intersects directly with vehicular traffic.
The economic justification for introducing this risk has also shifted. At Golf Realty Fund's presentation on Friday, January 23, 2026, members were told that bungalow revenue was necessary to fund the pool and fitness improvements. Later, Golf Realty Fund represented to the Council that it has sufficient funds to build and maintain those improvements even if the Page | 7
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
aggressive revenue projections tied to the bungalow and loft component do not materialize. By Golf Realty Fund's own later account, it does not need this additional revenue stream to construct and maintain the facilities. If that is true, then the question for the Council is not whether more revenue would be desirable. The question is whether this added safety risk is worth the cost. It is not.
The concern becomes even more serious because Camaraderie Clubs has already stated that it will not manage the lodging facilities. That means a third party will do so. A third-party lodging operation brings with it its own traffic patterns: guest arrivals and departures, deliveries, rideshare traffic, off-site food runs, and trips for alcohol and other services that are not necessarily integrated with Club operations, including when dining facilities are closed (eg Mondays). These risks are compounded by the fact that members themselves will use the same internal circulation area for parking and access to the tennis and pickleball facilities, further increasing vehicle volume in the same environment where children and members are walking and running between athletic and pool facilities. And in each and every one of these scenarios, the Council should assume alcohol will be consumed.
The timing of this application only heightens the concern. Golf Realty Fund appears to be trying to push this project through because it is running out of time under its own contractual obligations, which may expose it to financial consequences. But a private deadline is not a legal basis to shortcut public safety review. The fact that the owner may feel urgency is a reason for the Council to slow down, not a reason to approve an incomplete and under-analyzed design.
A comprehensive, independent safety study must be completed. At a minimum, that study should evaluate pedestrian circulation, child movement patterns, vehicle conflict points, visibility and sightlines, construction-phase hazards, and the operational risks associated with the bungalow and loft component. Without that work, approval would be premature.
The City would never route an internal lodging-access road through one of its own active recreational spaces without rigorous safety analysis. It should not permit that result here simply because the project is privately proposed. The stakes are high. If a child is struck by a vehicle in a conflict zone the plans themselves create, the resulting liability exposure would be extraordinary. As a trial lawyer, I view the owner, the operator, and the City as the approving authority as obvious defendants in that scenario, and the exposure could exceed $100 million in a catastrophic injury case. That outcome is not worth a minor, unnecessary revenue stream. And it can only even be argued to be worth the risk if a comprehensive safety study is done first.
Page | 8
EPG-B LAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
3. The proposed plan will have additional adverse effects on the Club's tennis program and daily operations, and if the back courts are not lit, tennis will wither at the Club.
Beyond the serious safety concerns addressed above, the proposed project would also materially impair the Club's tennis and pickleball program and its broader day-to-day operations.
First, the project threatens the viability of nighttime tennis at the Club. As the proposed plan makes clear, the six back courts at the far western end of the property become critically important if three existing lit courts are removed. If those back courts cannot be lit, the Club will effectively go from seven lit courts to only four. That reduction would fundamentally alter the Club's evening tennis program and, in practical terms, could cause tennis at the Club to wither.
Most notably, it would jeopardize some of the Club's some of the most popular organized evening events, including Men's Night and Ladies' Night, where large groups of players participate in round-robin doubles. The junior program, which goes until 7:00 p.m. PST, would also be jeopardized. For many members, those events are the core of the Club's tennis culture and one of the principal reasons they remain active members.
Any loss of courts must be tethered to the back courts being capable of lawful nighttime use. At present, however, the problem is that the prior conditional use permit associated with those courts reportedly does not allow lighting because of their proximity to neighboring homes. (Exhibit B.) Golf Realty Fund appears to be exploring technological solutions to reduce light spill, but the practical reality remains the same: nearby homeowners would be looking at illuminated courts on a nightly basis. That issue should not be ignored or deferred. It should be confronted directly now because, without a realistic and enforceable solution, the project substantially diminishes the Club's ability to function as a tennis facility.
Second, the elimination of three tennis courts will materially affect daytime operations as well. The Club's tennis program is not limited to casual drop-in use. It supports numerous teams, private lessons, daily junior programs, clinics, and organized member play throughout the week.
While no club can honestly claim that every court is full at every hour of every day, that is not the standard. The relevant question is whether the reduction in court inventory will impair operations during the hours that matter most. It plainly will. Peak usage periods will be squeezed.
Team practices and matches will be harder to schedule. Private instruction and junior programming will face greater competition for court time. The junior program in particular is a meaningful asset to the Club, run by a strong professional staff and designed to develop high- level young players. Orange County has already produced elite junior talent, and there is no reason that program should be diminished by a redevelopment plan that prioritizes lodging over courts.
Page |9
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
Costa Mesa, CA 92626
ENENSTEIN PHAM GLASS
(714) 292-0262
GUTENPLAN & BOLLING LLP
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
Third, Golf Realty Fund has represented that the courts will remain open during construction. On the present record, however, it is difficult to see how that can occur in a safe and functional way. The project already proposes to remove courts, insert internal circulation, and carry out major construction immediately adjacent to active recreational use. If the road and bungalow components were eliminated, there would at least be a greater possibility of preserving meaningful tennis operations during construction. But under the current design, the notion that children can safely attend junior camp, that coaches can conduct lessons, and that teams can play normally while roads are being paved and heavy construction is underway has not been substantiated. The Council should not simply assume that normal Club operations can continue through a prolonged and invasive construction process without a detailed, credible operational plan.
Taken together, these impacts are not secondary or incidental. They go to the heart of what The Huntington Club is and how it functions. This is not merely a question of replacing old facilities with new ones. It is a question of whether the Club's tennis community, junior development program, and nighttime member culture will survive the project in anything like their present form. On the current record, there is substantial reason to doubt that they will.
4. The City's Zoning Code does not allow people to sleep overnight in recreational space.
The Council's discretion under the Conditional Use Permit process is not unlimited. A CUP is not a blank check to authorize any use the City wishes to allow based on generalized notions of "good cause." Under the Huntington Beach Zoning Code, a CUP may be granted only where the Council can make the required findings, including that the proposed use is consistent with the General Plan and all applicable requirements of the Municipal Code. Most importantly, the Council must be able to find that the proposed use will comply with the provisions of the base district and other applicable provisions of the Zoning Code. If those findings cannot be made, denial is required
That requirement has procedural consequences here. The Council must be able to support each required finding with substantial evidence in the administrative record at the time of approval. Where material issues-such as whether the project can be operated safely-remain unresolved, the Council cannot defer that determination to a future study. Absent substantial evidence demonstrating that the project can be operated safely, the Council cannot make the findings necessary to approve the Conditional Use Permit.
That is the core issue here. The subject property is in the OS-PR district. Huntington Beach's zoning regulations provide that uses not listed in a district's land use controls are prohibited. In OS-PR, "Park & Recreation Facilities" may be allowed with a CUP, and certain Page | 10
EPG-BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
ancillary uses may be permitted in limited form, but the Code does not separately list general lodging or visitor accommodations as an authorized OS-PR use. From a legal perspective, the threshold question, therefore, is not whether the bungalow and loft component may be desirable or financially beneficial. The threshold question is whether that lodging component is actually an authorized use in OS-PR at all.
The City's own use-classification scheme sharpens that issue. Huntington Beach distinguishes between "Clubs and Lodges," on the one hand, and "Visitor Accommodations," on the other. "Clubs and Lodges" are recreational or social facilities primarily for members or guests. "Visitor Accommodations" are separately defined lodging uses, including hotels, motels, and similar short-term occupancy arrangements. The Code thus does not treat private club use and overnight lodging use as interchangeable. They are different use categories. That distinction matters here because the proposed bungalow and loft component appears, in substance, to function as a lodging use rather than merely as part of the Club's traditional recreational operations.
Accordingly, if the City's position is that the bungalow and loft component constitutes a lodging or visitor-accommodation use, then the Council should identify precisely where that use is permitted or conditionally permitted in OS-PR. If the City's position is instead that the lodging component is merely accessory or incidental to the recreational use, then the Council should explain how overnight accommodations are truly subordinate to, and customarily associated with, the principal recreational use of the site, rather than a separate revenue-generating use added to the property. Either way, the Council must still make the finding that the project complies with the base district. A CUP does not eliminate that requirement.
There is a further problem. The Huntington Beach Code contemplates that, if a proposed use cannot be clearly classified within an existing use category, the answer is not simply to approve it by CUP anyway. Rather, the Code assigns use-classification decisions to the Director and, where no existing classification clearly applies, the proper remedy is a change to the zoning text. In other words, the City may not use the CUP process to create a new hybrid use that the Code does not presently authorize.
For that reason, the Council should require a clear answer to a simple question before acting: what, exactly, is the legal use classification for the proposed bungalows and lofts, and where is that use authorized in OS-PR? And critically, the Council must also be able to determine-based on substantial evidence—that the project, as designed, can be operated safely before any approval is granted. Unless and until those questions are answered in a manner that allows the Council to make the required findings, approval of the lodging component would be legally vulnerable and premature.
Page |11
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
Costa Mesa, CA 92626
ENENSTEIN PHAM GLASS
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
5. There is no justifiable basis to move forward with the proposed plan unless and until, at a minimum, a comprehensive safety study is conducted.
For all of these reasons, there is no justifiable basis for the Council to move forward with the proposed plan unless and until a comprehensive safety study is completed. Without that study, the Council lacks substantial evidence necessary to determine that the project can be operated safely and therefore cannot make the findings required for approval of the Conditional Use Permit.
We therefore respectfully request that the Council continue this matter for at least 60 days so that the proposed project can be evaluated on a more complete and reliable record.
Respectfully Submitted,
ENENSTEIN PHAM GLASS GUTENPLAN & BOLLING, LLP
By:
Jesse K. Bolling, Esq
Cc:
• Casey McKeon, Mayor: [email protected]
Butch Twining, Mayor Pro Tem: [email protected] • Gracey Van Der Mark, Councilmember: Gracey. [email protected] • Pat Burns, Councilmember: [email protected]
• Don Kennedy, Councilmember: [email protected] • Chad Williams, Councilmember; Chad. [email protected] • Andrew Gruel, Councilmember: [email protected] Page | 12
EXHIBIT A
Julie Ann Crandall
From: The Huntington Club <[email protected]>
Sent: Saturday, February 7, 2026 8:11 AM
To: Jesse Bolling
Subiect: Camaraderie Clubs Clarification ~ Townhall Meeting Saturday, February 7, 2026
Dear Members of The Huntington Club,
It has been two weeks since Golf Realty Fund and Johnathon Baily held a town hall meeting at the Huntington Club to discuss the New Performance Center Building, new pool, and bungalow project. Over the past two weeks, we have noticed some confusion regarding the relationship between the tenant of THC (Camaraderie Clubs) and the landlord/property owner (Golf Realty Fund). To clarify, Camaraderie Clubs pays rent to Golf Realty Fund through a triple net lease. This lease outlines obligations for capital expenditures for both the tenant and the property owner. So far, Camaraderie Clubs has met and exceeded its capital obligations. However, as the property owner mentioned in the planning commission meeting on January 27th, they have yet to fulfill their obligations. In the past six years since the lease was signed, Golf Realty Fund is still in the process of obtaining the necessary approvals for the project.
In addition, Camaraderie clubs would like to clarify the following misconceptions we have heard from the members.
1.Johnathon Baily represents Golf Reality Trust and is not affiliated with Camaraderie Clubs or involved in our operational decisions regarding THC. We want to make it very clear: WE DO NOT ENDORSE HIS STATEMENT MADE DURING THE TOWN HALL MEETING, where he said, "WE ARE COMFORTABLE AND CONFIDENT IN THE
ECONOMICS, AND YOU GUYS ARE FREE TO SPEAK WITH YOUR WALLETS AND SAY, 'HEY, NO, THIS CLUB ISN'T FOR US; WE WILL LEAVE.'" Jonathon Baily and Golf Realty Trust do not have the authority to make such statements to you, our valued customers, and members of THC. As made evident by the recent survey, we value member feedback and will use that feedback to frame our capital investment and operational opportunities. We deeply value your membership and thank you for choosing to be a part of our Club.
2. Currently, Camaraderie Clubs has no financial interest or contractual obligation to manage the bungalows and loft apartments proposed by Golf Realty Fund. Camaraderie Clubs has been steadfast in its efforts to compel the landlord to honor its obligations to construct a new swimming pool and upgrade the fitness facilities over the past 6 years.
The ownership of The Huntington Club is dedicated to the ongoing improvement of the Club and its facilities, aiming to preserve and enhance the experience enjoyed by its members.
We will always advocate for the interests of the Club and its members with conviction and respect. Please direct any questions about the project to Golf Realty Fund as they will be best equipped to answer questions about their project.
Sincerely,
Travis Brasher - Managing Partner, Camaraderie Clubs
Joe Saikali - General Manager
6501 Palm Ave. Huntington Beach, CA 92648 714.536.8866
This message was sent to Jesse Bolling <[email protected]> by Huntington Club Click here to unsubscribe from further communications
Mi Huntington Beach Planning Commission
P.O. BOX 190 CALIFORNIA 92648
August 6, 1985
Huntington Beach Company
2110 Main Street
Huntington Beach, CA 92648
SUBJECT: :: CONDITIONAL USE PERMIT NO. 85-25/COASTAL DEVELOPMENT PERMIT NO. 85-19/NEGATIVE DECLARATION NO. 185-26
REQUEST: To permit construction
of 6 tennis courts.
LOCATION: East side of Palm Ave.
approximately 300 ft.
south of Cherryhill Ave.
FINDINGS FOR APPROVAL CONDITIONAL USE PERMIT NO. 85-25:
1. The proposed six tennis courts are compatible with surrounding land uses and in conformance with the General Plan policies because the facility will become an integral part of the existing Seacliff Country club.
2. The proposed tennis courts will not be detrimental to the generrl health, welfare, safety and convenience of persons residing or working in the neighborhood because the, facility will have houxs of operation limited to the daytime.
3. The location, site layout, and design of the proposed development, does properly adapt the structure to streets, driveways and other uses in a harmonious manner,
FINDINGS FOR APPROVAL COASTAL DEVELOPMENT PERMIT NO. 85-2:
1. The proposal for 6 tennis courts is consistent with the City Coastal zone suffix as well as other provisions of the
Huntington Beach Ordinance Code applicable to the property; and conforms with the plans, policies, reguirements and standards of the City's Coastal Land Use Plan.
2. The proposed development can be provided with infrastructure in manner that is consistent with the Coastal Land Use Plan.
3. The proposed development conforms with the public access and public recreation policies of Chapter 3 of the California Coastal Act.
CONDITIONS OF APPROVAL CONDITIONAL USE PERMIT NO. 85-25:
1. The site plan dated May 22, 1985 shall be the approved layout.
2. Prior to issuance of building permits, the applicant shall submit a landscape and irrigation plan to the Department of Development Services and Department of Public Works for review and approval.
3. The tennis courts hours of operation shall be limited to daytime hours. No artificial lighting shall be permitted.
4. A copy of the tennis club membership/entry requirements shall be submitted to the Department of Development Services to assure the membership/use is limited to country club members.
5. All building spoils, such a unused lumber, wire, pipe and surplus or unusable materials, shall be disposed of at an off-site facility equipped to handle them.
I hereby certify that Conditional Use Permit No. 85-25, Coastal" Development Permit No. 85-19 and Negative Declaration No. 85-26 was approved by the Planning Commission of the City of Huntington Beach on August 5, '1985 by the foregoing citations and conditions.
Sincerely,
Ilmena Witt/ fir
James W. Palin
Secretary
Planning Commission
JWP: 1p
(3037đ(3)
From: Levin, Shannon
To: Villasenor, Jennifer
Subject: FW: THC BUNGALOW PROJECT
Date: Monday, April 20, 2026 10:07:23 AM
Attachments: 2026.04.10 Letter to HBCC (FINAL).pdf
From: Robin Brunner <[email protected]>
Sent: Saturday, April 18, 2026 2:00 PM
To: CITY COUNCIL (INCL. CMO STAFF) < [email protected]> Subject: THC BUNGALOW PROJECT
[Some people who received this message don't often get email from [email protected]. Learn why this is important at https://aka.ms/LearnAboutSenderldentification]
Dear City Council,
I'm a longtime member of the Huntington Club (23 years) and a neighbor that owns a house behind the back tennis courts for 28 years. I share the beliefs and concerns in the attached letter.
We walk over to enjoy the club and are alarmed at the possible future placement of a road dividing the club in half. I can't imagine who thought that was a safe decision for children and adults alike. There must be another way to make this safer for the community and keep the relaxed club flow that is there now.
I'm also concerned about the talk of lighting the back courts. We paid millions of dollars for a home with the assurance these courts could never be lit. We enjoy countless evenings outside relaxing in peace and fear there's a possibility of that being taken from us. I understand there is new technology of how courts can be lit with minimal light pollution. However, it's not only the lights that become an issue with playing after dark. Loud noises including screaming, swearing and loud music is a regular occurrence during daytime play and during night time play on current lit courts. It's easy to witness by stopping by the club any given evening to hear.
It's one thing when it's closer to the club, but when our home is 6 feet from the courts it becomes very disruptive.
One last concern regarding the bungalows. We've attended all the council meetings and heard all the talk of who is allowed to use these bungalows... I have not heard if weddings booked at the club will be able to use them. Weddings are a big money maker for the club and could see them selling the bungalows as a package for the bride to get ready and wedding party to stay and/or have parties. Has this been discussed? What would stop the club from charging an extra amount to book weddings (i.e. bungalow package) to make these people temporary members as a loop hole to allow them access to the bungalows. As a neighbor living close to these, I'm very concerned over the noise and security of our neighborhood as well.
Thanks for taking the time to read my concerns and thank you for keeping our city a wonderful and safe place to live.
Robin Brunner
6312 Turnberry Cir HB
714.756.0943
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP
Jesse K. Bolling
[email protected]
April 10, 2026
SENT VIA EMAIL
Huntington Beach City Council
2000 Main Street
Huntington Beach, CA 92648
Email: [email protected]
Re: April 21, 2026 Hearing re The Huntington Club Remodel and Bungalows Dear Mayor and Members of the City Council,
I submit this letter in two capacities: (1) as pro bono counsel to appellants Cheryl Gates, Susan Ridgeway, and Douglas Scott Warren; and (2) as a current member of The Huntington Club with a direct interest in the continued availability and character of its facilities. I am an active golf and tennis member of the Club, and my family and I regularly participate in its athletic programs.
To summarize, Golf Realty Fund has a reported contractual obligation of approximately $10 million to $15 million to complete improvements at the Club. In structuring that arrangement, Golf Realty Fund retained control over the buildout, positioning itself to convert that obligation into an additional revenue stream through hotel-like lodging for "members and their guests." At the most recent hearing, Golf Realty Fund implied that it does not need that additional revenue to fund the renovations; it simply seeks an additional revenue stream from the property.
Standing alone, that economic choice would not necessarily be problematic. The problem is the particular plan Golf Realty Fund has chosen to pursue. As proposed, it introduces serious safety risks for Club members and their families. Members and their children move constantly through this area circulating among the courts, the pool, the fitness center, and food service locations-often in unpredictable patterns that are inherent to an active recreational environment.
The proposed design forces those same children to cross an internal roadway serving both lodging-related traffic and everyday member vehicle traffic, as members will naturally use that area for convenient parking in the more than thirty new parking spaces located directly adjacent to the tennis and pickleball courts. The plan therefore concentrates vehicle traffic in the exact space where children and families are moving on foot.
This creates a direct and foreseeable conflict between vehicles and pedestrians. That risk is compounded by the nature of the proposed use, which will introduce guest traffic, ride-share Page | 1
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
activity, deliveries, and the potential for alcohol-related driving into the same space where children are playing and moving freely. The foreseeable result is not minor or theoretical —it is the risk of serious injury in a setting that has always functioned as a protected recreational environment. Up until now, Golf Realty Fund has asked the Council to allow that plan to proceed without the benefit of a comprehensive safety study, ostensibly because its contractual deadline to complete these improvements will expire in early May 2026.
That private timing pressure is no substitute for a complete and reliable public record, particularly where the safety of Huntington Beach families who use what many regard as the City's crown jewel is at stake. More time is needed to determine whether this design can be made safe. Without that work, approval would expose Golf Realty Fund, its tenant, and the City of Huntington Beach to substantial liability if a member—or worse, a child—is injured.
In good faith discussions between the Appellants and Golf Realty Fund, the concept of a comprehensive safety study has been raised. Golf Realty Fund appears amenable to conducting such a study, but there remains a critical procedural issue. It is my understanding that Golf Realty Fund prefers that the safety study be imposed along with approval of the plan. We respectfully submit that this approach is improper under the circumstances and should be rejected.
The Council should instead retain jurisdiction over this matter and require completion of the safety study before any approval is granted. The Appellants' ability to advocate on behalf of the Club's membership is tied to this appeal. As a non-equity club, members do not control the property; their voice is exercised through this process and through the Council's oversight. If the project is approved subject to later study, that voice is effectively extinguished, and future decisions regarding safety, design, and implementation will be left to private entities whose interests may not align with those of the citizens most directly affected.
Moreover, the Council cannot make the required findings in support of approval without first establishing, based on substantial evidence, that the project can be operated safely. Nor may the Council defer that determination to a future study, as doing so would leave a critical component of the approval unsupported by the administrative record at the time of decision. Where material safety concerns remain unresolved, approval would be premature because the record would not contain substantial evidence sufficient to support the findings required for a Conditional Use Permit.
Based on the foregoing, we respectfully request that the Council continue this hearing for at least 60 days so that the proposed plan can be more fully evaluated, particularly in light of the serious safety concerns created by placing a roadway with significant parking capacity in the middle of the Club's tennis and pickleball facilities. The Council should direct Golf Realty Fund to conduct a comprehensive safety study by an independent consultant approved by the Council Page |2
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
and Appellants. Once completed, that study should be circulated for review and comment, and only then should the Council determine whether the project, as proposed, is safe enough for approval.
1. The factual background demonstrates no evaluation of safety concerns amid contractual time pressure and a breakdown between owner and operator.
The factual statements set forth in this letter are based on a combination of publicly available materials and information obtained through discussions with individuals represented to have knowledge of the operations, agreements, and history of the Club. Except where expressly supported by cited documents or witnessed by me or my clients, these statements are provided on an informational basis only. I therefore do not present these statements as adjudicated fact, but rather as contextual background to assist the Council in understanding the circumstances surrounding the proposed project.
• The entity operating the Club, Camaraderie Clubs, is led by Travis Brasher, who previously served as a golf professional at the Club when it operated under its former name, Seacliff Country Club. Mr. Brasher founded the Travis Mathew apparel brand, which was later sold, and has since returned, now as the tenant overseeing operations at the Club, rebranding it as The Huntington Club.
• Prior to the COVID-19 pandemic, Camaraderie Clubs entered into a long-term lease agreement-reported to be approximately 30 years in duration—with the property owner, Golf Realty Fund, under which it operates the Club.
• As part of that long-term lease arrangement, both Camaraderie Clubs and Golf Realty Fund are understood to have contemplated and committed to significant capital improvements to the Club's infrastructure in recognition of the age and condition of the existing facilities.
• Camaraderie Clubs has invested substantial capital into the Club, reported to be in the range of approximately $8 million to $10 million.
• Golf Realty Fund, as property owner, is likewise understood to have committed to a significant capital contribution toward redevelopment of the property, reported to be in the range of approximately $10 million to $15 million, none of which has yet been deployed. The lease or related agreements reportedly include a deadline for completion of those improvements in early May 2026. Based on that reported deadline, Golf Realty Fund appears to be under substantial time pressure to obtain approvals and move the project forward.
Page /3
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
• The proposed project includes demolition and replacement of fitness and swimming facilities, as well as the addition of new structures, including bungalow units, loft-style accommodations, and related site improvements. More specifically, the project includes (i) conversion or construction of second-floor space within a proposed fitness facility into loft-style accommodations and (i) construction of detached bungalow-style units on the property. The project would also eliminate three lit tennis courts used for nighttime play and divide the tennis and pickleball facilities with a large internal road serving the bungalow component, including more than thirty parking spaces located within that internal circulation area.
• Golf Realty Fund also submitted an alternative concept involving the addition of a third story to the fitness facility without including the bungalow lodging component.
According to information provided by a City employee, that submission was marked "Incomplete" because it did not contain sufficient detail to determine whether it complied with applicable height limitations. Even if that proposal ultimately raised height- compliance issues, the City retains discretion to evaluate whether such limitations could be addressed or modified through appropriate planning mechanisms. A plan without an internal roadway through the recreational core, therefore, is theoretically possible. • At a presentation by Golf Realty Fund to Club members on Friday, January 23, 2026, at which Camaraderie Clubs was absent, a representative of Golf Realty Fund told members that revenue from the bungalow component was necessary to fund reconstruction of the pool and fitness improvements. Golf Realty Fund has also provided the City with aggressive revenue projections for these rental units, particularly in light of the competition from multiple high-end beachfront hotels in the area. In subsequent representations to the City Council, however, Golf Realty Fund indicated that it has sufficient financial resources to build and maintain the proposed improvements even if those revenue projections were not realized. Those two positions are difficult to reconcile and bear directly on whether the bungalow component is truly necessary or instead an added revenue stream being pursued despite the costs it imposes. • I received a written communication distributed by Camaraderie Clubs to Club members dated February 7, 2026 (Exhibit A). In that communication, Camaraderie Clubs expressly states that it "has no financial interest or contractual obligation to manage the bungalows and loft apartments proposed by Golf Realty Fund." • The same communication also alludes to the statements made by Golf Realty Fund during its town hall meeting with Club members concerning the proposed project. At that meeting, Golf Realty Fund stated that members were "free to speak with [their] wallets" in response to the proposed changes.
Page | 4
EPG-BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
• The February 7, 2026 communication further clarifies that Camaraderie Clubs does not endorse that statement and distinguishes its operational role from that of the property owner with respect to the proposed development.
• It is anticipated that, if the contemplated redevelopment obligations are not satisfied within the early May 2026 timeframe, a dispute between landlord and tenant may arise, potentially resulting in litigation. This point is noted solely to provide context regarding the relationship between landlord and tenant, which, from my perspective, is troubling. • In negotiations among the parties, there has been a general refusal to have all sides sit down together to resolve their issues. Golf Realty Fund has asserted that Camaraderie Clubs contractually agreed to limit or waive its ability to object to certain aspects of the redevelopment plan, including the bungalow component. I have learned nothing that contradicts that assertion. At the town hall meeting, Golf Realty Fund flashed a specific portion of the lease when making that point to members, but I was not provided with a sufficient opportunity to review that provision in full. Further, Appellants' suggestion that a thorough dialogue among all the affected parties would be the best course toward resolution has been dismissed.
2. Golf Realty Fund proposes an unsafe conflict zone within the Club's recreational core that introduces high-traffic areas into the center of club facilities visited daily by families.
The plans submitted to the City do not merely remodel a private club. They change the way this entire recreational area would function on a daily basis. Instead of keeping vehicular circulation at the perimeter, the proposed design pulls vehicle movement into the same part of the site where members and their families naturally move back and forth between the tennis courts, the pickleball courts, the bungalow area, the food truck location, and the pool and fitness complex.
That matters because this part of the Club is not a static space. It is one of the most active family areas on the property. During a recent tennis tournament, I watched my own three children-ages 8, 6, and 3 consistently move among the courts, the fitness center, the pool, and the food truck area. Children were running back and forth for smoothies, food, and breaks between matches. Parents and members were doing the same thing. That pattern of movement is not unusual; it is exactly how this area of the Club is actually used.
The City would never design one of its own recreational spaces this way. In publicly used Huntington Beach recreation areas, vehicular circulation is kept at the edges, while the interior is reserved for fields, courts, trails, playgrounds, and gathering space. That is not accidental. It Page | 5
TEPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
reflects a basic safety judgment: where children and families are moving freely, cars should not be routed through the middle of the activity zone.
Huntington
Contral Park Library Contral Park/Seet Carden ".™ MEN PARK Parking
Vehicular Acèess
HOGC
& Parking Parking
HBSC Recreations
Parking
CENTRAL PARK
• BASEBALL/SOFTBALL FIELDS West
TURF FIELDS
Gold Secret Carder
ARENA FIELD Recreation
GRASS FIELDS the tol
CATTING CAGES
) SNACK BAR / BATHROOMS
FLAY GROUND
• HBSC OFFICE
& Parking
Huntington Beach park design consistently places vehicular circulation at the perimeter, while interior space is reserved for active recreation. This separation reflects a fimdamental safety principle: where children and families are moving freely, vehicles are kept out of the activity cone.
The project plans submitted here do the opposite. They create a conflict zone where ordinary member movement intersects with internal vehicular circulation serving both lodging- related traffic and everyday member parking activity. The internal road does not simply pass near the courtsit runs directly through the recreational area and includes more than thirty parking spaces that will attract regular member use. The issue is not whether a careful adult can look both ways and cross. The issue is whether an active tennis and pickleball environment— used by children, teens, and families should be redesigned to require exactly that kind of vigilance in the first place.
The risk is particularly acute at the pickleball courts. Under the current layout, the pickleball couts sit adjacent to one another, and weekly ladder events regularly utilize all eight pickleball courts (four in each cout bank). During those events, players continuously rotate between the two courts based on wins and losses. Under the proposed plan, the internal road would run between the two courts that are currently adjacent, meaning that players participating Page | 6
EPG-BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partnet
[email protected]
in these events would be required to cross the roadway repeatedly throughout play. That repeated crossing pattern-by adults focused on competition and movement, not vehicle traffic-creates an additional, foreseeable point of conflict between pedestrians and vehicles.
The submitted plan itself shows that the natural path of travel from the heart of the tennis and pickleball courts to the food truck and pool cuts directly across the internal drive and circulation area tied to the bungalow component. In the real world, children do not stop at neat crossing points and wait for vehicles. They run where they have always run. Members move where they have always moved. The danger is therefore not speculative. It is foreseeable on the face of the design.
FOOD TRJCK
(NCT A PART)
LAKE
NAYACAVA
05 RANCHO
VALENCIA
CACA NEW TITNESS /
PALMERO LOFT BUILDING
Contict Zone
B PARKING STALLS,
1S0X
Proposed site plan showing the internal roadway and parking area ("Conflict Zone") bisecting the Chib's primary tennis and pickleball facilities, where regular pedestrian movement— particularly by children and players rotating between courts—intersects directly with vehicular traffic.
The economic justification for introducing this risk has also shifted. At Golf Realty Fund's presentation on Friday, January 23, 2026, members were told that bungalow revenue was necessary to fund the pool and fitness improvements. Later, Golf Realty Fund represented to the Council that it has sufficient funds to build and maintain those improvements even if the Page |7
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
aggressive revenue projections tied to the bungalow and loft component do not materialize. By Golf Realty Fund's own later account, it does not need this additional revenue stream to construct and maintain the facilities. If that is true, then the question for the Council is not whether more revenue would be desirable. The question is whether this added safety risk is worth the cost. It is not.
The concern becomes even more serious because Camaraderie Clubs has already stated that it will not manage the lodging facilities. That means a third party will do so. A third-party lodging operation brings with it its own traffic patterns: guest arrivals and departures, deliveries, rideshare traffic, off-site food runs, and trips for alcohol and other services that are not necessarily integrated with Club operations, including when dining facilities are closed (e.g Mondays). These risks are compounded by the fact that members themselves will use the same internal circulation area for parking and access to the tennis and pickleball facilities, further increasing vehicle volume in the same environment where children and members are walking and running between athletic and pool facilities. And in each and every one of these scenarios, the Council should assume alcohol will be consumed.
The timing of this application only heightens the concern. Golf Realty Fund appears to be trying to push this project through because it is running out of time under its own contractual obligations, which may expose it to financial consequences. But a private deadline is not a legal basis to shortcut public safety review. The fact that the owner may feel urgency is a reason for the Council to slow down, not a reason to approve an incomplete and under-analyzed design.
A comprehensive, independent safety study must be completed. At a minimum, that study should evaluate pedestrian circulation, child movement patterns, vehicle conflict points, visibility and sightlines, construction-phase hazards, and the operational risks associated with the bungalow and loft component. Without that work, approval would be premature.
The City would never route an internal lodging-access road through one of its own active recreational spaces without rigorous safety analysis. It should not permit that result here simply because the project is privately proposed. The stakes are high. If a child is struck by a vehicle in a conflict zone the plans themselves create, the resulting liability exposure would be extraordinary. As a trial lawyer, I view the owner, the operator, and the City as the approving authority as obvious defendants in that scenario, and the exposure could exceed $100 million in a catastrophic injury case. That outcome is not worth a minor, unnecessary revenue stream. And it can only even be argued to be worth the risk if a comprehensive safety study is done first.
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
3. The proposed plan will have additional adverse effects on the Club's tennis program and daily operations, and if the back courts are not lit, tennis will wither at the Club.
Beyond the serious safety concerns addressed above, the proposed project would also materially impair the Club's tennis and pickleball program and its broader day-to-day operations.
First, the project threatens the viability of nighttime tennis at the Club. As the proposed plan makes clear, the six back courts at the far western end of the property become critically important if three existing lit courts are removed. If those back courts cannot be lit, the Club will effectively go from seven lit courts to only four. That reduction would fundamentally alter the Club's evening tennis program and, in practical terms, could cause tennis at the Club to wither.
Most notably, it would jeopardize some of the Club's some of the most popular organized evening events, including Men's Night and Ladies' Night, where large groups of players participate in round-robin doubles. The junior program, which goes until 7:00 p.m. PST, would also be jeopardized. For many members, those events are the core of the Club's tennis culture and one of the principal reasons they remain active members.
Any loss of courts must be tethered to the back courts being capable of lawful nighttime use. At present, however, the problem is that the prior conditional use permit associated with those courts reportedly does not allow lighting because of their proximity to neighboring homes. (Exhibit B.) Golf Realty Fund appears to be exploring technological solutions to reduce light spill, but the practical reality remains the same: nearby homeowners would be looking at illuminated courts on a nightly basis. That issue should not be ignored or deferred. It should be confronted directly now because, without a realistic and enforceable solution, the project substantially diminishes the Club's ability to function as a tennis facility.
Second, the elimination of three tennis courts will materially affect daytime operations as well. The Club's tennis program is not limited to casual drop-in use. It supports numerous teams, private lessons, daily junior programs, clinics, and organized member play throughout the week.
While no club can honestly claim that every court is full at every hour of every day, that is not the standard. The relevant question is whether the reduction in court inventory will impair operations during the hours that matter most. It plainly will. Peak usage periods will be squeezed.
Team practices and matches will be harder to schedule. Private instruction and junior programming will face greater competition for court time. The junior program in particular is a meaningful asset to the Club, run by a strong professional staff and designed to develop high- level young players. Orange County has already produced elite junior talent, and there is no reason that program should be diminished by a redevelopment plan that prioritizes lodging over courts.
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
Third, Golf Realty Fund has represented that the courts will remain open during construction. On the present record, however, it is difficult to see how that can occur in a safe and functional way. The project already proposes to remove courts, insert internal circulation, and carry out major construction immediately adjacent to active recreational use. If the road and bungalow components were eliminated, there would at least be a greater possibility of preserving meaningful tennis operations during construction. But under the current design, the notion that children can safely attend junior camp, that coaches can conduct lessons, and that teams can play normally while roads are being paved and heavy construction is underway has not been substantiated. The Council should not simply assume that normal Club operations can continue through a prolonged and invasive construction process without a detailed, credible operational plan.
Taken together, these impacts are not secondary or incidental. They go to the heart of what The Huntington Club is and how it functions. This is not merely a question of replacing old facilities with new ones. It is a question of whether the Club's tennis community, junior development program, and nighttime member culture will survive the project in anything like their present form. On the current record, there is substantial reason to doubt that they will.
4. The City's Zoning Code does not allow people to sleep overnight in recreational space.
The Council's discretion under the Conditional Use Permit process is not unlimited. A CUP is not a blank check to authorize any use the City wishes to allow based on generalized notions of "good cause." Under the Huntington Beach Zoning Code, a CUP may be granted only where the Council can make the required findings, including that the proposed use is consistent with the General Plan and all applicable requirements of the Municipal Code. Most importantly, the Council must be able to find that the proposed use will comply with the provisions of the base district and other applicable provisions of the Zoning Code. If those findings cannot be made, denial is required
That requirement has procedural consequences here. The Council must be able to support each required finding with substantial evidence in the administrative record at the time of approval. Where material issues such as whether the project can be operated safely—remain unresolved, the Council cannot defer that determination to a future study. Absent substantial evidence demonstrating that the project can be operated safely, the Council cannot make the findings necessary to approve the Conditional Use Permit.
That is the core issue here. The subject property is in the OS-PR district. Huntington Beach's zoning regulations provide that uses not listed in a district's land use controls are prohibited. In OS-PR, "Park & Recreation Facilities" may be allowed with a CUP, and certain Page | 10
EPG-BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
ancillary uses may be permitted in limited form, but the Code does not separately list general lodging or visitor accommodations as an authorized OS-PR use. From a legal perspective, the threshold question, therefore, is not whether the bungalow and loft component may be desirable or financially beneficial. The threshold question is whether that lodging component is actually an authorized use in OS-PR at all.
The City's own use-classification scheme sharpens that issue. Huntington Beach distinguishes between "Clubs and Lodges," on the one hand, and "Visitor Accommodations," on the other. "Clubs and Lodges" are recreational or social facilities primarily for members or guests. "Visitor Accommodations" are separately defined lodging uses, including hotels, motels, and similar short-term occupancy arrangements. The Code thus does not treat private club use and overnight lodging use as interchangeable. They are different use categories. That distinction matters here because the proposed bungalow and loft component appears, in substance, to function as a lodging use rather than merely as part of the Club's traditional recreational operations.
Accordingly, if the City's position is that the bungalow and loft component constitutes a lodging or visitor-accommodation use, then the Council should identify precisely where that use is permitted or conditionally permitted in OS-PR. If the City's position is instead that the lodging component is merely accessory or incidental to the recreational use, then the Council should explain how overnight accommodations are truly subordinate to, and customarily associated with, the principal recreational use of the site, rather than a separate revenue-generating use added to the property. Either way, the Council must still make the finding that the project complies with the base district. A CUP does not eliminate that requirement.
There is a further problem. The Huntington Beach Code contemplates that, if a proposed use cannot be clearly classified within an existing use category, the answer is not simply to approve it by CUP anyway. Rather, the Code assigns use-classification decisions to the Director and, where no existing classification clearly applies, the proper remedy is a change to the zoning text. In other words, the City may not use the CUP process to create a new hybrid use that the Code does not presently authorize.
For that reason, the Council should require a clear answer to a simple question before acting: what, exactly, is the legal use classification for the proposed bungalows and lofts, and where is that use authorized in OS-PR? And critically, the Council must also be able to determine based on substantial evidence-that the project, as designed, can be operated safely before any approval is granted. Unless and until those questions are answered in a manner that allows the Council to make the required findings, approval of the lodging component would be legally vulnerable and premature.
Page | 11
EPG-BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
anaging Partr
[email protected]
5. There is no justifiable basis to move forward with the proposed plan unless and until, at a minimum, a comprehensive safety study is conducted.
For all of these reasons, there is no justifiable basis for the Council to move forward with the proposed plan unless and until a comprehensive safety study is completed. Without that study, the Council lacks substantial evidence necessary to determine that the project can be operated safely and therefore cannot make the findings required for approval of the Conditional Use Permit.
We therefore respectfully request that the Council continue this matter for at least 60 days so that the proposed project can be evaluated on a more complete and reliable record.
Respectfully Submitted,
ENENSTEIN PHAM GLASS GUTENPLAN & BOLLING, LLP
By:.
Jesse K. Bolling, Esq.
Cc:
Casey McKeon, Mayor: [email protected]
Butch Twining, Mayor Pro Tem: [email protected] Gracey Van Der Mark, Councilmember: Gracey. [email protected] • Pat Burns, Councilmember: [email protected]
• Don Kennedy, Councilmember: [email protected] • Chad Williams, Councilmember; Chad. [email protected] • Andrew Gruel, Councilmember: [email protected] Page | 12
EXHIBIT A
Julie Ann Crandall
From: The Huntington Club < [email protected]> Sent: Saturday, February 7, 2026 8:11 AM
To: Jesse Bolling
Subject: Camaraderie Clubs Clarification ~ Townhall Meeting Saturday, February 7, 2026
Dear Members of The Huntington Club,
It has been two weeks since Golf Realty Fund and Johnathon Baily held a town hall meeting at the Huntington Club to discuss the New Performance Center Building, new pool, and bungalow project. Over the past two weeks, we have noticed some confusion regarding the relationship between the tenant of THC (Camaraderie Clubs) and the landlord/property owner (Golf Realty Fund). To clarify, Camaraderie Clubs pays rent to Golf Realty Fund through a triple net lease. This lease outlines obligations for capital expenditures for both the tenant and the property owner. So far, Camaraderie Clubs has met and exceeded its capital obligations. However, as the property owner mentioned in the planning commission meeting on January 27th, they have yet to fulfill their obligations. In the past six years since the lease was signed, Golf Realty Fund is still in the process of obtaining the necessary approvals for the project.
In addition, Camaraderie clubs would like to clarify the following misconceptions we have heard from the members.
1.Johnathon Baily represents Golf Reality Trust and is not affiliated with Camaraderie Clubs or involved in our operational decisions regarding THC. We want to make it very clear: WE DO NOT ENDORSE HIS STATEMENT MADE DURING THE TOWN HALL MEETING, where he said, "WE ARE COMFORTABLE AND CONFIDENT IN THE
ECONOMICS, AND YOU GUYS ARE FREE TO SPEAK WITH YOUR WALLETS AND SAY, 'HEY, NO, THIS CLUB ISN'T FOR US; WE WILL LEAVE.'' Jonathon Baily and Golf Realty Trust do not have the authority to make such statements to you, our valued customers, and members of THC. As made evident by the recent survey, we value member feedback and will use that feedback to frame our capital investment and operational opportunities. We deeply value your membership and thank you for choosing to be a part of our Club
2. Currently, Camaraderie Clubs has no financial interest or contractual obligation to manage the bungalows and loft apartments proposed by Golf Realty Fund. Camaraderie Clubs has been steadfast in its efforts to compel the landlord to honor its obligations to construct a new swimming pool and upgrade the fitness facilities over the past 6 years.
The ownership of The Huntington Club is dedicated to the ongoing improvement of the Club and its facilities, aiming to preserve and enhance the experience enjoyed by its members.
We will always advocate for the interests of the Club and its members with conviction and respect. Please direct any questions about the project to Golf Realty Fund as they will be best equipped to answer questions about their project.
Sincerely,
Travis Brasher - Managing Partner, Camaraderie Clubs
Joe Saikali - General Manager
6501 Palm Ave. Huntington Beach, CA 92648 714.536.8866
his message was sent to Jesse Bolling <[email protected]> by Huntington Clu lick here to unsubscribe from further communication
Huntington Beach Planning Commission
P.O. BOX 190 . CALIFORNIA 92648
August 6, 1985
Huntington Beach Company
2110 Main Street
Huntington Beach, CA 92648
SUBJECT:: CONDITIONAL USE PERMIT NO. 85-25/COASTAL DEVELOPMENT PERMIT NO. 85-19/NEGATIVE DECLARATION NO. 385-26
REQUEST: To permit construction
of 6 tennis courts.
LOCATION: East side of Palm Ave.
approximately 300 ft.
south of Cherryhill Ave.
FINDINGS FOR APPROVAL CONDITIONAL USE PERMIT NO. 85-25:
1. The proposed six tennis courts are compatible with surrounding land uses and in conformance with the General Plan policies because the facility will become an integral part of the existing Seacliff Country Club.
2. The proposed tennis courts will not be detrimental to the generrl health, welfare, safety and convenience of persons residing or working in the neighborhood because the facility wijl lave hours of operation limited to the daytime.
3. The iocation, site layout, and design of the proposed development does properly adapt the structure to streets, driveways and other uses in a harmonious manner,
FINDINGS FOR APPROVAL COASTAL DEVELOPMENT PERMIT NO. 85-2:
1. The proposal for 6 tennis courts is consistent with the City suffix as well as other provisions of the
Huntington Beach Ordinance Code applicable to the property; and conforms with the plans, policies, reguirements and standards of the City's Coastal Land Use Plan.
2. The proposed development can be provided with infrastructure in, a manner that is consistent with the Coastal Land Use Plan.
3. The proposed development conforms with the public access and public recreation policies of Chapter 3 of the californía Coastal Act.
CONDITIONS OF APPROVAL CONDITIONAL USE PERMIT NO. 85-25:
1. The site plan dated May 22, 1985 shall be the approved layout.
2. Prior to issuance of building permits, the applicant shall submit a landscape and irrigation plan to the Department of Development Services and Department of Public Works for review and approval.
3. The tennis courts hours of operation shall be limited to daytime hours. No artificial lighting shall be permitted.
4. A copy of the tennis club membership/entry requirements shall be submitted to the Department of Development Services to assure the membership/use is limited to country club members.
5. All building spoils, such a unused lumber, wire, pipe and surplus or unusable materials, shall be disposed of at an off-site facility equipped to handle them.
I hereby certify that conditional Use Permit No. 85-25, Coastai Development Permit No. 85-19 and Negative Declaration No. 85-26 was approved by the Planning Commission of the City of Huntington Beach on August 5, 1985 by the foregoing citations and conditions.
Sincerely,
Irena Wilt/ fir
James W. Palin
Secretary
Planning Commission
JWP: 1p
(3037d (3)