My home and neighborhood would be directly impacted by the proposed general plan update and this plan would not benefit our community.
My specific objections to the areas labeled HOTEL OVERLAY are as follows:
1. Violates the existing General Plan. The site is currently zoned for low density residential and is designated in the general plan as hillside/open space or limited development area. I request the current zoning be retained.
2.Emergency Evacuation routes for wildfire or landslide would be severely impacted by congestion.
An increase in the transient population of the magnitude proposed would increase the likelihood of NOT being able to evacuate the area quickly which is designated by Cal Fire as a Severe Fire Risk area.
HOTEL TRAFFIC WOUD WORSEN THIS SIGNIFICANTLY. In addition Fire Risk would be significantly increased with large scale construction activities.
3.Increased Traffic problems, we are already seeing traffic congestion particularly during the summer on Crown Valley and other roads in and out of the city. A Hotel/Commercial property would bring 24/7 operations, deliveries, late night events, and traffic noise to our quiet neighborhood along with SEVERE TRAFFIC CONGESTION.
4. Light pollution, from parking garages and hotel operations would be severely increased and is completely out of character for our quiet residential community.
5. View Impacts, hillside views are a major reason residents moved here. A hotel/commercial operation would impact those views, property values and privacy.
6. Water Supply a large Hotel/commercial complex uses enormous amounts of water for guest rooms landscaping laundry pools etc. California continues to experience a long term water scarcity a hotel here would be irresponsible and strain existing infrastructure.
7. Environmental and landslide risks increased by long term construction activities. My concerns include erosion, wild life disruption, hillside stability. The area is close to the 1998 El Niño landslide that destroyed homes. Several ancient landslide areas exist on the hillside. Air quality would be severely impacted by construction activities and increased traffic.
I also stand with the following objections raised by our neighbor Thom Taylor:
The Case Against Developing Area O
Through countless Laguna Niguel Environmental Review Board, Planning Commission, and City Council meetings, the idea of building on the Area O hill has been repeatedly reviewed, revised, litigated, and studied. Since proposals first challenged the conflict between safety and profit in 1986, the land has remained untouched. From then until 1992, when the current house/guesthouse zoning was approved, not a single structure has been built.
Why Has Nothing Been Built?
Because the land is simply undevelopable.
Ingress and egress are both unsafe and practically impossible. The hydrology of the area, coupled with seven ancient landslides, creates dangerous and unstable geological conditions. Proposed access roads over the years would require 60 foot plus retaining walls and still failed to present a viable solution for emergency vehicle turnarounds. This creates yet another fire and public safety risk.
At one point, a developer who had just completed the Chanteclair development across from Laguna Niguel Regional Park proposed boring a massive hole into the side of the hill to gain access. The terrain is that problematic. While the views might be breathtaking, the land itself is a non-starter for development—unsafe and unworkable.
A Risky Gamble by Allrise Capital
Allrise Capital, the current landowner, is a self-described risk/reward company. It is gambling that it can overturn well-established, documented unsafe conditions in pursuit of profit. But the City is under no obligation to enable or support this gamble.
History Cannot Be Ignored
The physical and geological facts about Area O have already been established through years of analysis, community resistance, and expert review. Decisions by previous City leaders were made following extensive consultation with geotechnical experts and environmental review. Even the current zoning was approved under pressure, as the City settled with former landowner Hon to avoid litigation —reaching what was considered the least unsafe compromise possible. Anything beyond that would be reckless.
Nothing Has Changed
It was unsafe and unworkable in the 1980s and 1990s, and that remains true today. The myriad issues —ranging from public safety, environmental impact, flora and fauna disruption, access, traffic congestion, hydrological instability, and fire risk—are unchanged and unfixable. Neither the City nor any landowner can alter the fundamental nature of this land.
Please, do not waste the time and resources of the City or its residents.
Not then, not now.
Sincerely,
Caitlin Huggins
Laguna Niguel, CA 92677
All The Best,
Caitlin Huggins
Debbie Salahi
26 year homeowner and resident
Erica Roess | Senior Planner
City of Laguna Niguel
Community Development Department
30111 Crown Valley Parkway
Laguna Niguel, CA 92677
[email protected]
Tel: 949-362-4067
From: [email protected] <[email protected]> Sent: Monday, June 2, 2025 3:31 PM
To: Erica Roess <ERoess@cityoflagunaniguel.org>; Jonathan Orduna <JOrduna@cityoflagunaniguel.org>; John Morgan <JMorgan@cityoflagunaniguel.org>
Subject: FW: Laguna Niguel General Plan Update
Starla Barker, AICP | Principal Planner
De Novo Planning Group |
www.denovoplanning.com
[email protected] | 949-396-8193
Southern California | 180 East Main St #108 | Tustin, CA 92780 Northern California | 1020 Suncast Ln #106 | El Dorado Hills, CA 95762
From: Denae Hermawan <
Sent: Monday, June 2, 2025 2:58 PM
To: generalplaninfo@cityoflagunaniguel.org
Subject: Laguna Niguel General Plan Update
Hi Starla,
I wanted to officially submit my concerns for the proposed "hospitality" section outlined below. I live at Laguna Niguel, CA. I just heard about this proposal from a neighbor via text (the city has not contacted me, even though it appears that my home might be the closest property to the "hospitality" section. If the map is to scale, I'm wondering if this would be about 200 ft from my property line?
Does the city have a Civil Engineering report they can share to show that this has been properly tested for safety? I am concerned about hill slides behind my home if a hotel is built here. Please let me know if there is any additional information that may be available. Thank you!
Denae Hermawan
E-mails to and from the City (and their attachments) may be subject to the California Public Records Act and thus subject to public disclosure unless otherwise exempt under the Act.
ac fic I land V l age I
e sie m w l on@gma l com
Sent via form submission from Laguna Niguel General Plan Name: Jessica Wilton
Email: accepts marketing: false
Subject: Strong Opposition to Proposed Rezoning for Hospitality Development Near Pacific Island Drive & Crown Valley Parkway
Message: Dear Laguna Niguel City Council Members,
I am writing to express my strong opposition to the proposal to rezone the area near the Pacific Island Village Neighborhood near the intersection of Pacific Island Drive and Crown Valley Parkway to allow for hospitality development. This proposal represents a serious threat to the character, safety, and livability of our neighborhood, and it should be rejected outright.
Our community has worked hard to build and preserve a residential environment that supports families, preservation of nature, and quality of life. Introducing hotels or other hospitality related businesses would fundamentally disrupt that balance. Increased traffic, noise, and late night activity are inevitable consequences of such development. These issues would not only diminish property values but also erode the sense of safety and cohesion that defines our neighborhood.
Moreover, the proposed rezoning appears to prioritize commercial interests over community welfare.
The long term impacts—on infrastructure, traffic, and public safety—have not been adequately addressed. Our local roads and services are already strained, and adding transient lodging will only exacerbate these challenges.
There are more appropriate areas for hospitality development that do not encroach on established residential zones. The city should be investing in thoughtful, community driven planning that strengthens neighborhoods, not undermines them.
I urge you to vote against this rezoning proposal and stand with the residents who have built and sustained this community for decades. We expect our elected and appointed officials to protect our neighborhoods, not open them up to disruptive commercial expansion.
Thank you for your attention and for considering the serious concerns of those of us who call this area home.
Sincerely,
Jessie Wilton
Pacific Island Village I
Manage Submissions
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The Final EIR is available on the City’s General Plan Update “Documents & Maps” webpage LINKED HERE.
For additional information related to this project, please contact John Morgan, Deputy Community Development Director, by telephone at (949) 362-4332, or by e-mail at generalplaninfo@cityoflagunaniguel.org. Please include “Laguna Niguel General Plan Update” in the subject line.
Sincerely,
General Plan Update Team
City of Laguna Niguel
30111 Crown Valley Parkway
Laguna Niguel, CA 92677
E-mails to and from the City (and their attachments) may be subject to the California Public Records Act and thus subject to public disclosure unless otherwise exempt under the Act.
October 28, 2025
Members of the Planning Commission
City of Laguna Niguel
30111 Crown Valley Parkway
Laguna Niguel, CA 92677
RE: Comments on the City of Laguna Niguel Draft General Plan Update and Draft Environmental Impact Report (SCH No. 2024060260)
Dear Honorable Members of the Planning Commission,
The Kennedy Commission (the Commission) is a broad-based coalition of residents and community organizations that advocates for the production of homes affordable for families earning less than $30,000 annually in Orange County. Formed in 2001, the Commission has been successful in partnering and working with Orange County jurisdictions to create effective housing and land-use policies that have led to the new construction of homes affordable to lower-income working families.
The Commission appreciates the opportunity to comment on the City of Laguna Niguel’s Draft General Plan Update (GPU) and accompanying Draft Environmental Impact Report (DEIR).
While the City’s initiative to modernize its 1992 plan is commendable, the proposed GPU fails to ensure adequate and balanced housing opportunities, particularly for lower-income residents. The General Plan Update does not further the City's housing policies nor the City’s obligations under California housing, environmental, and fair housing laws.
Housing Projections
The DEIR projects that Laguna Niguel will accommodate 3,464 new housing units by 2045 and claims this figure meets or exceeds the Southern California Association of Governments’ (SCAG) regional growth forecast. However, nearly half of those projected homes—1,500 units—are contained within the three Opportunity Area Overlays: Marketplace, Town Center, and the Chet Holifield Federal Building (CHFB) site. These overlays are entirely discretionary and will require separate future approvals, including General Plan amendments, zoning changes, and specific plans, before any housing can be built.¹
Given that these overlays are contingent on future discretionary actions, the housing they envision is uncertain and cannot be treated as part of the City’s realistic development capacity.
As HCD guidance explains, housing goals are minimums and not maximums when planning for housing growth. As the city is creating new housing opportunities as part of the General Plan update, it must be consistent with housing goals and examine how it will implement affordable housing policies and programs to achieve equitable housing development. Jurisdictions must create planning and opportunities that are certain, feasible and are likely-to-develop on sites being identified for future growth.
Without these overlays, the plan provides only 1,964 assured housing units—a growth rate that will not meet even the City’s existing Regional Housing Needs Allocation (RHNA) for future cycles. Furthermore, none of these projected units are guaranteed to be affordable. By counting speculative overlays as planned housing, the Draft EIR creates a false appearance of progress while masking a substantial shortfall in real and concrete housing opportunities.
Affordable Housing
The General Plan Update fails to create consistency with Housing Element policies that may further housing opportunities for all income segments. None of the housing contemplated under the overlays includes any affordability requirements or commitments to lower-income households. Absent inclusionary housing standards, or affordability requirements in the Overlays, all new development in these areas will likely be market-rate, contrary to the City’s duty to affirmatively further fair housing (AFFH) and create housing opportunities for all income segments, especially for lower income.
As part of General Plan Updates, cities must create consistency in planning. Jurisdictions must take meaningful actions to overcome patterns of segregation and foster inclusive communities.
Concentrating all new development potential into a few overlay areas while protecting existing single-family neighborhoods perpetuates spatial inequality. The result is a pattern where wealthier neighborhoods remain insulated from change while lower-income housing needs are not being integrated into the communities and planning areas.
The Chet Holifield Federal Building site exemplifies this issue. Although the Housing Element identifies it as one of the most significant opportunities for affordable housing production in South Orange County, the GPU maintains a Business Park base zoning that prohibits residential use. The only path to housing at this site is through an optional overlay, and even then, no affordable housing is required or being incentivized. By failing to make a range of housing affordability types available or required on this site, the City is foregoing a rare and transformative opportunity to meet regional and local housing needs.
To comply with the AFFH requirement and Housing Element planning goals, Laguna Niguel must ensure that residential development within the overlays is both mandatory and inclusive of affordability requirements. Optional, market-driven housing is insufficient to demonstrate compliance with fair housing and the goal to create affirmative housing in the City.
General Plan Consistency
State law requires that all elements of a General Plan remain internally consistent and aligned with the Housing Element.³ The City’s Housing Element outlines policies to increase affordable housing opportunities and ensure realistic capacity for lower-income households. However, the Draft GPU undermines these objectives by relying on speculative overlays and omitting any programs that create affordable housing opportunities for all income segments.
This inconsistency between the Land Use Element and the Housing Element could render the plan legally vulnerable under the Internal Consistency Doctrine, which mandates that all General Plan elements must be mutually compatible and internally coherent.⁴ If adopted as written, the GPU would fail to provide a legally adequate framework for increasing housing in a balanced manner.
Jobs-Housing Imbalance
The DEIR and General Plan describe an intent to “balance jobs and housing,” but the nature of the proposed job growth calls that claim into question. The GPU projects the addition of 5,467 new jobs and more than 1 million square feet of new commercial and retail space, bringing the citywide total to roughly 6.86 million square feet by 2045.⁵ Much of this expansion—particularly at the CHFB and Marketplace sites—is dedicated to retail, hospitality, and service-oriented uses.
These industries primarily create low- and moderate-wage jobs, often paying near minimum wage. Workers in these sectors will be unable to afford Laguna Niguel’s market-rate housing and will likely commute from other cities. Rather than reducing Vehicle Miles Traveled (VMT) and greenhouse gas emissions, this pattern will worsen both, undermining the City’s environmental and equity goals.
The City’s own DEIR identifies increased VMT and conflicts with state climate targets as “significant and unavoidable” impacts.⁶ Affordable housing located near job centers is a well-established mitigation strategy for these outcomes, as it allows workers to live closer to employment, reducing commute distances and emissions. Yet the DEIR fails to analyze how incorporating mandatory affordable housing within overlays could offset these very impacts—a clear oversight under CEQA’s requirement to consider feasible mitigation measures.⁷ By expanding commercial uses while neglecting to secure affordable housing, the City effectively creates a greater jobs-housing balance. The plan will attract thousands of new workers but provide few, if any, places for them to afford to live, exacerbating regional housing pressures and undermining the City’s environmental objectives.
CEQA Alternatives
CEQA Guidelines §15126.6 requires an EIR to evaluate a reasonable range of project alternatives capable of reducing significant impacts while achieving most project objectives.
The DEIR evaluates only two alternatives: a “No Project” scenario and a “Reduced Growth” option. Neither alternative considers mandatory residential development within the overlays or inclusion of affordable housing requirements—both of which are feasible, legally relevant options that could substantially reduce VMT, GHG emissions, and displacement pressures.
By failing to include an affordable housing-focused alternative, the City has not met CEQA’s obligation to assess environmentally superior approaches that address identified impacts.⁸ Incorporating a housing-centered alternative would directly support CEQA’s environmental purposes by linking land use, housing, and transportation in a way that meaningfully reduces emissions and vehicle travel.
Public Concerns
Many community members have expressed to the City regarding the absence of clear policies supporting the implementation of affordable housing development in the Draft General Plan and Draft Environmental Impact Report (DEIR). There is significant public support for high-density affordable housing requirements within the three Opportunity Areas. As noted in the Staff Report of this Planning Commission Meeting, “Notably, close to 90% of [the] comments were submitted by individuals affiliated with Homes for All, a regional affordable housing advocacy organization.” This demonstrates the community’s recognition of the urgent need for affordable housing in Laguna Niguel.
The City has both the responsibility and the opportunity to address these concerns with updating the General Plan, to include meaningful policies that will ensure the facilitation and production of affordable housing. While the Staff Report acknowledges the value of community engagement in shaping the goals and policies in the Draft General Plan, the current draft lacks specific language that commits the City to prioritize affordable housing development.
Recommendations
The Commission urges the City to revise the Draft General Plan Update and DEIR to address these deficiencies. The Commission is requesting the following in the Housing Overlays in the Draft General Plan Update:
● Require a minimum of 3,000 homes across the three overlays, with the largest share assigned to the Ziggurat site
● Require that housing in the overlays be mandatory, not optional ● Designate at least 15% of units in each overlay as affordable to low- and very low-income households
These commitments should be supported by clear timelines and measurable implementation standards.
The City should also evaluate a new DEIR alternative that integrates affordable housing as a mitigation strategy and recognizes its role in reducing VMT and GHG emissions. Finally, the City should revise the General Plan text to explicitly affirm its obligation to affirmatively further fair housing and ensure affordable housing opportunities are distributed more equitably across all neighborhoods in Laguna Niguel.
Conclusion
The City of Laguna Niguel’s Draft General Plan Update and DEIR fall short of meeting both the spirit and letter of California’s housing and environmental law. By relying on speculative overlays, omitting programs that facilitate affordable housing, and emphasizing commercial expansion over residential balance, the plan perpetuates exclusion and deepens the regional housing crisis.
The Commission urges the City to revise its General Plan and EIR to ensure that Laguna Niguel’s future growth is inclusive, environmentally sustainable, and consistent with its obligations under CEQA, the Housing Element Law, and the Fair Housing Act.
We appreciate your consideration of these comments and remain available to collaborate with City staff to strengthen the plan. If you have any questions, please feel free to contact me at (949) 250-0909 or [email protected].
Sincerely,
Cesar Covarrubias
Executive Director
Footnotes
1. City of Laguna Niguel, Draft Environmental Impact Report – General Plan Update (June 2024), Section 3.0, “Project Description,” pp. 3-7 to 3-10.
2. Government Code §65583(c).
3. Lesher Communications, Inc. v. City of Walnut Creek (1990) 52 Cal.3d 531, 540–541.
4. City of Laguna Niguel, Draft Environmental Impact Report, Table 3-3, “Projected Citywide Buildout,” p. 3-13.
5. Ibid., Section 4.8, “Greenhouse Gas Emissions,” and Section 4.13, “Transportation,” pp. 4-132–4-156.
6. Public Resources Code §21002; CEQA Guidelines §§15021(a)(2), 15126.4(a)(1).
7. CEQA Guidelines §15126.6(a)–(b); Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 564.
The Chet Holifield property provides an excellent opportunity for mixed use, putting housing in close proximity to jobs. In the General Plan Update, rather than making a vague, or "intentionally flexible," statement about public benefit, I encourage you to be bold, to be clear.
Laguna Niguel can do more to encourage the development of af fordable housing so that
essential workers who work in our community can live in our community. I love open space and I'm not a fan of high-density housing, but I have come to understand that I need to look beyond myself because far too many families in our area are housing insecure or homeless. Essential workers like teachers, nurses, child care providers, grounds keepers, first responders and many young adults, trying to establish their independence, are priced out of housing in our area.
Laguna Niguel can do it's part to help address the County's affordable housing crisis by:
Requiring at least 3,000 homes across the three overlays, with the largest share assigned to the Chet Holifield site.
Requiring that housing in the overlays be mandatory, not optional.
Designating at least 15% of units in each overlay as affordable to low- and very low- income households.
Sincerely,
Marcella Lawson
John Morgan | Deputy Community
Development Director
City of Laguna Niguel
30111 Crown Valley Parkway
Laguna Niguel, CA 92677
[email protected]
Tel: 949-362-4332
From: Patrick Russell
Sent: Friday, November 7, 2025 10:18 AM
To: Jonathan Orduna <JOrduna@cityoflagunaniguel.org>; John Morgan <JMorgan@cityoflagunaniguel.org> Subject: 56 acre property at NW corner of Crown Valley Parkway and Pacific Island Drive
Dear Mr. Orduna, Mr. Morgan, City Council, Planning Commission, and City Staff, As a 35 year homeowner in Laguna Niguel adjacent to the referenced property, I was surprised to learn that the property is being considered for rezone to allow hospitality use. I am strongly opposed to the rezone of this property for hospitality use for several reasons. For decades, this un-built steep ridge has existed as a natural buffer and wildlife sanctuary along busy Crown Valley Parkway. The relief provided by these beautiful natural slopes and wildlands represent the unique character and environmental balance of Laguna Niguel. They are a visually appealing contrast to the dense built-out environment in our city. A large commercial hotel will
forever change the character of this natural feature and will negatively affect the residents of Laguna Niguel. We already have two very mega resorts less than a mile away that generate an enormous amount of traffic, noise, trash, etc. and are a burden to adjacent neighborhoods.
Vehicular access for guests, large service and trash trucks for any commercial hotel/development on this site would be very difficult, disruptive and impactful to all Laguna Niguel residents. It would also lead to more air/water pollution, noise and traffic congestion and loss of natural habitat in our town. We want to maintain the natural beauty, character, and charm of Laguna Niguel. This is not the place to add another hotel resort.
I request that you deny the application for rezone on this property.
Please distribute to the parties shown above.
Thank you,
Patrick Russell
Laguna Niguel
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Designate at least 15% of units in each overlay as affordable to low- and very low-income households.
Our city’s growth should benefit all members of the community, including those who need housing the most. I strongly encourage the Council to strengthen these protections in the Final General Plan.
Thank you for your consideration,
Sincerely,
Robert Henry
I urge the City to:
· Require a minimum of 3,000 homes across the three overlays, with the largest share assigned to the Ziggurat site.
· Require that housing in the overlays be mandatory, not optional. · Designate at least 15% of units in each overlay as affordable to low- and very low- income households.
Our city’s growth should benefit all members of the community, including those who need housing the most. I strongly encourage the Council to strengthen these protections in the Final General Plan.
Thank you for your consideration.
Sincerely,
Susan Cross
Building (CHFB or Ziggurat) site. Each overlay is discretionary, requiring future General Plan amendments, rezoning, and specific plans before any housing can actually be built.
When removing those speculative overlays, the GPU only provides 1,964 assured units—a number that not only falls short of the City’s projected growth but also fails to position Laguna Niguel to meet its current or future RHNA obligations. Treating discretionary overlays as part of the City’s “realistic capacity” is misleading and inconsistent with HCD’s guidance, which requires that housing projections be based on feasible, likely-to-develop sites.
Under state law, RHNA and General Plan housing goals represent minimums, not ceilings. The GPU’s discretionary framework effectively caps housing opportunities below what is needed to address local and regional housing shortages.
Affordable Housing and Fair Housing
The GPU does not include any requirements or commitments for affordable housing within the overlays. Without clear inclusionary percentages, affordability covenants, or density bonus partnerships, new housing will be exclusively market-rate. This approach is inconsistent with the City’s Housing Element commitments to encourage and facilitate the development of affordable housing and to Affirmatively Further Fair Housing (AFFH) in all parts of the city.
Concentrating all potential growth into a few commercial areas while leaving existing single-family neighborhoods untouched perpetuates exclusionary land-use patterns and fails to integrate affordability citywide. As Laguna Niguel updates its guiding plan for the next 20 years, it must take meaningful actions to overcome segregation and foster inclusivity, as required by both state housing law and federal fair housing principles.
The Chet Holifield Federal Building site presents a particularly significant opportunity.
Identified in the City’s Housing Element as one of the most important sites for affordable housing in South Orange County, the GPU nonetheless keeps the site’s base zoning as Business Park—which prohibits residential use. Housing would only be allowed through an optional overlay, with no affordability requirement.
If the City does not take this opportunity to mandate and integrate affordable housing here, it will forfeit a generational chance to create truly inclusive, mixed-income housing and remain out of compliance with the Housing Element’s goals and policies.
Internal Consistency and Legal Vulnerability
California’s Internal Consistency Doctrine requires that all elements of a General Plan be consistent with each other. The GPU’s reliance on optional overlays, lack of enforceable housing policies, and absence of affordability measures directly conflict with the City’s certified Housing
Element—which commits to increasing affordable housing opportunities for lower-income households.
If adopted in its current form, the GPU would be legally vulnerable for internal inconsistency, risking future challenges and possible HCD decertification.
Jobs-Housing Imbalance and Environmental Impacts
The DEIR anticipates 5,467 new jobs and more than 1 million square feet of new commercial and retail space, bringing the citywide total to approximately 6.86 million square feet by 2045.
The majority of these new jobs would be in retail, hospitality, and service-oriented sectors—positions that generally pay low to moderate wages. Workers in these sectors will be unable to afford Laguna Niguel’s market-rate housing and will be forced to commute from outside the city.
Rather than reducing Vehicle Miles Traveled (VMT) and greenhouse gas (GHG) emissions, this dynamic will increase them, contradicting the City’s environmental and climate goals. The DEIR itself identifies these impacts as “significant and unavoidable.” A clear and feasible mitigation strategy—requiring affordable housing near job centers—was never analyzed. By failing to include this as a CEQA mitigation measure or project alternative, the DEIR omits a readily available solution that would directly reduce the project’s environmental impacts.
Overestimated Commercial Demand and Market Infeasibility The GPU’s long-range vision includes large quantities of new retail, commercial, and office space—an approach that has already proven problematic in nearby cities. Laguna Hills, for example, is now seeking to amend its Development Agreement for the Village at Laguna Hills after discovering that its ambitious plan for retail and office space far exceeded market demand.
Despite being well into its entitlement phase, Laguna Hills now must “change gears” and reconsider the land uses to make the project financially viable. This should serve as a cautionary example for Laguna Niguel. The City’s plan envisions even greater amounts of commercial and office space—spread over multiple sites and projected over 20 years—despite regional data showing stagnant demand for large-scale retail and corporate office development.
The risk is clear: without a strong housing component, Laguna Niguel could face years of stalled development, unimplemented overlays, and eventual amendments to correct course—just as Laguna Hills now faces.
CEQA Alternatives and Missed Mitigation Opportunities
Under CEQA Guidelines §15126.6, the City is required to consider a reasonable range of alternatives that could reduce significant environmental impacts. The DEIR evaluates only a “No Project” and “Reduced Growth” alternative, neither of which incorporates mandatory housing in overlays or affordability requirements.
A feasible, environmentally superior alternative would integrate affordable housing directly into the overlays, reducing VMT and GHG impacts by allowing workers to live near employment centers. By excluding this alternative, the City has not met CEQA’s obligation to evaluate feasible mitigation measures that could substantially lessen identified impacts.
Community Engagement and Lack of Responsiveness
Throughout this process, The Kennedy Commission and community advocates have mobilized residents via email and text campaigns, encouraging public participation and the submission of written comments supporting stronger housing commitments. Despite this clear and consistent feedback, no modifications have been made to include mandatory housing or affordability provisions in the overlays.
Equally troubling has been the City’s inconsistent and unclear communication surrounding the required 45-day public review period for the Draft General Plan and Environmental Impact Report. The City’s first and only direct email announcement regarding the availability of the Draft General Plan was sent at 5:11 p.m. on July 3rd, heading into a long holiday weekend.
That email merely stated that the General Plan was available for public review—it did not identify the start or end date of the 45-day review period, nor did it reference the Environmental Impact Report.
Roughly forty days after that initial notice, The Kennedy Commission became aware of the missing information. In response, we immediately mobilized our network of advocates, convened a community meeting to review the documents, and coordinated the submission of public comments. These comments were accompanied by an email to City staff, specifically raising concern about the lack of a clearly stated review period—either on the website or via public notice.
Only after this inquiry did the City act to retroactively post a 45-day review period. However, this update was made without notice to those on the City’s mailing list. The deadline initially appeared on the City’s website as October 9th, yet subsequent communication to the public listed October 8th—and even then, the email failed to mention the Draft General Plan or its deadline at all. Residents were left to discover the changes themselves by repeatedly checking the website, creating unnecessary confusion and barriers to participation.
This pattern of poor communication and lack of responsiveness severely undermines the City’s stated commitment to transparency and public engagement. It has also called into question
whether the General Plan Update process meaningfully incorporates community voices—especially those advocating for equitable housing opportunities and inclusion within Laguna Niguel’s long-term vision.
Recommendations
To ensure legal compliance, environmental soundness, and equitable outcomes, the Commission urges the City Council to adopt the following revisions before approving the General Plan Update and DEIR:
1. Require a minimum of 3,000 homes across the three overlay areas, with the largest share at the Chet Holifield (Ziggurat) site.
2. Ensure that housing in the overlays is mandatory, not optional.
3. Require that at least 15% of all homes in each overlay be affordable to low- and very low-income households.
Additionally, the City should:
● Evaluate an Affordable Housing Alternative under CEQA as a mitigation measure for VMT and GHG impacts;
● Align the General Plan’s Land Use Element with the Housing Element to avoid internal inconsistency; and
● Reassess the feasibility of large-scale retail and commercial projections based on current and future market conditions.
Conclusion
The City of Laguna Niguel’s Draft General Plan Update and DEIR, as currently proposed, fall short of both the spirit and the letter of California’s housing, environmental, and fair housing laws. By continuing to rely on optional overlays, speculative commercial projections, and unenforceable housing assumptions, the plan risks perpetuating exclusion and deepening the regional housing crisis.
Laguna Niguel has a unique opportunity to build a more balanced, inclusive future—one that welcomes new neighbors home and creates real opportunities for lower-income workers to live near where they work. A plan that mandates housing, ensures affordability, and realistically reflects market conditions will meet the City’s legal obligations while advancing a more equitable, sustainable community for all.
We appreciate your consideration of these comments and remain available to collaborate with City staff to strengthen the plan. If you have any questions, please feel free to contact me at or
Sincerely,
Cesar Covarrubias
Executive Director