Public Comments
AGENDA ITEM 10B_REDACTED.PDF
8A - GRANT THE APPEAL AND ENSURE COMMONSENSE VMT_TRAFFIC MITIGATIONS IN THE HANSON HOTEL PROJECT TRACEY.PDF
8A - GRANT THE APPEAL AND ENSURE COMMONSENSE VMT_TRAFFIC MITIGATIONS IN THE HANSON HOTEL PROJECT LAUREL.PDF
8A - GRANT THE APPEAL AND ENSURE COMMONSENSE VMT_TRAFFIC MITIGATIONS IN THE HANSON HOTEL PROJECT BOB.PDF
8A - YES ON ROOFTOP BARS IN THIS NEIGHBORHOOD, PLEASE APPROVE HANSON HOTEL.PDF
8A - INVESTIGATE VEGETATION REMOVAL AT SITE OF THE PROPOSED HANSON HOTEL CLAIRE.PDF
8A - INVESTIGATE VEGETATION REMOVAL AT SITE OF THE PROPOSED HANSON HOTEL PATRICIA.PDF
8A - INVESTIGATE VEGETATION REMOVAL AT SITE OF THE PROPOSED HANSON HOTEL DHRUV.PDF
8A - INVESTIGATE VEGETATION REMOVAL AT SITE OF THE PROPOSED HANSON HOTEL CHRIS.PDF
8A - INVESTIGATE VEGETATION REMOVAL AT SITE OF THE PROPOSED HANSON HOTEL LINDA.PDF
8A - INVESTIGATE VEGETATION REMOVAL AT SITE OF THE PROPOSED HANSON HOTEL MEREDITH.PDF
8A - INVESTIGATE VEGETATION REMOVAL AT SITE OF THE PROPOSED HANSON HOTEL BILLPDF.PDF
8A -INVESTIGATE VEGETATION REMOVAL AT SITE OF THE PROPOSED HANSON HOTEL AMY.PDF
8A - INVESTIGATE VEGETATION REMOVAL AT SITE OF THE PROPOSED HANSON HOTEL KASSI.PDF
8A - INVESTIGATE VEGETATION REMOVAL AT SITE OF THE PROPOSED HANSON HOTEL WINSLOW.PDF
8A -INVESTIGATE VEGETATION REMOVAL AT SITE OF THE PROPOSED HANSON HOTEL EILEEN.PDF
8A - INVESTIGATE VEGETATION REMOVAL AT SITE OF THE PROPOSED HANSON HOTEL PAULINE.PDF
8A - INVESTIGATE VEGETATION REMOVAL AT SITE OF THE PROPOSED HANSON HOTEL BRINNA.PDF
8A - INVESTIGATE VEGETATION REMOVAL AT SITE OF THE PROPOSED HANSON HOTEL KATHLEEN.PDF
8A - INVESTIGATE VEGETATION REMOVAL AT SITE OF THE PROPOSED HANSON HOTEL LIZ.PDF
8A - INVESTIGATE VEGETATION REMOVAL AT SITE OF THE PROPOSED HANSON HOTEL KELLY.PDF
8A -INVESTIGATE VEGETATION REMOVAL AT SITE OF THE PROPOSED HANSON HOTEL ANDREA.PDF
8A - INVESTIGATE VEGETATION REMOVAL AT SITE OF THE PROPOSED HANSON HOTEL VINCE.PDF
8A - INVESTIGATE VEGETATION REMOVAL AT SITE OF THE PROPOSED HANSON HOTEL RYAN.PDF
8A - INVESTIGATE VEGETATION REMOVAL AT SITE OF THE PROPOSED HANSON HOTEL VIVIAN.PDF
8A - INVESTIGATE VEGETATION REMOVAL AT SITE OF THE PROPOSED HANSON HOTEL JOANNA.PDF
LETTER RE SUPPLEMENT TO APPEAL JUSTIFICATION FOR HANSON HOTEL.PDF
FINAL DEMAND LETTER - SAN CLEMENTE CITY CLERK - HANSON HOTEL HEARING 04.21.2026.PDF
8B - PUBLIC COMMENTS_ ITEM 8A FOR TONITES CC MEETING_ SUPPORT
CONTINUING OUTDOOR DINING IN SAN CLEMENTEREDACTEDPDF
1. Documents:
8A INVESTIGATE VEGETATION REMOVAL AT SITE OF THE PROPOSED HANSON HOTEL JOANNA.PDF
LETTER RE SUPPLEMENT TO APPEAL JUSTIFICATION FOR HANSON HOTEL.PDF
FINAL DEMAND LETTER - SAN CLEMENTE CITY CLERK - HANSON HOTEL HEARING 04.21.2026.PDF
8B - PUBLIC COMMENTS_ ITEM 8A FOR TONITES CC MEETING_ SUPPORT CONTINUING OUTDOOR DINING IN SAN CLEMENTE_REDACTED.PDF
8A - RE HANSON HOTEL UPDATE.PDF
From: Brad Malamud
Sent: Thursday, April 16, 2026 12:09 PM
To: Campagnolo, Laura <[email protected]>; Hall, Andy <[email protected]>; Elizabeth A. Mitchell <[email protected]>; Cabral, Victor <[email protected]>; Enmeier, Mark <[email protected]>; Knoblock, Steve <[email protected]>; Loeffler, Rick <[email protected]>; Wu, Zhen <[email protected]> Subject: Agenda Item 10B
BACKGROUND:
This item does not analyze the effect of the passage of Ballot measure BB in 2020. That is critical.
WHY? Because the Council's prior 6 year term limit is not valid. On that basis, Measure BB is applicable to any term limit, unless amended in the future (for all Council members or for the Mayor).
Thus, the critical point for the Council to consider must begin with: Given that the 6 year limit is invalid, how does BB apply to the position of a 2 year Mayoral term.
BB may apply an 8 year term limit for council including the mayor and not be limited to teh 2 - 4 year term limit.
The Mayor is a Councilmember, not a different position for which Council rules do not apply. As such, all rules applicable to Councilmembers, including measure BB, applies to the position/election of the Mayor. Thus, critically, the City Attorney should analyze the specific language of measure BB to the 2 year (not 4 year) terms of the Mayor as BB was specified as 2 consecutive 4 year terms not 8 years of service/elected position service.
That resulted as San Clemente had never in the recent past elected Council members to 2 year terms except to replace Council members. Those special rules are contained in
2.04.090 Section 1, A 3 and B. I leave it to the City Attorney to analyze Measure BB and these specific rules.
DISCUSSION:
Measure BB was approved by the voters and applies to all City Council members.
Thus, BB applies to any election of a mayor, who, in fact, is a Council member with certain ceremonial functions. The Mayor under Rosenberg's Rules of Order presides over Council meetings, and is a co-Parliamentarian (along with the City Attorney).
An analysis by the City Attorney of whether Measure BB is applicable to the term limits on a Mayoral candidate including a sitting Council member (any current member who decides to run for office or in the future).
The legal analysis is critical and requires reviewing case law, etc., and should likely be undertaken by a qualified attorney (City Attorney) or other municipal law specialist) before the City moves forward with placing anything on the ballot.
PS: on this point, because the 6 year Mayor term limit is invalid, there is really no reason to limit the Mayor's term to 6 years when all council members are given 8 consecutive years.
Thus, the Agenda which suggests reaffirming the 6 year term limit appears to be a STAFF recommendation and instead I believe that this Council, not the 2020 Council, should select the term limit if it is placed on the ballot as either 2 years, 4 years, 6 years 8 years, 10 years, etc.
Simplistically, BB limits the term of a Councilmember to "two (2) consecutive four (4) year terms."
The keys here are 1. consecutive, and 2. Four year terms.
First issue: is the mayor a Council member for purposes of BB. Yes.
Issue: BB does not limit a Council member to 8 consecutive years, but instead states 2 consecutive 4 year terms.
Clearly, the issue presented was 8 years of consecutive service on Council creating a term limit, but that is not how BB was drafted.
QUESTIONS FOR LEGAL ANALISIS:
Issues/questions that should be addressed by the City Attorney before this item is discussed/analyzed:
1. Can a Council member run for mayor after she is termed out without sitting out for two years?
The answer appears to be that she cannot.
See: 2.02.090 B. "No person ... shall again be eligible for election or appointment as a member of the City Council unless and until not less than two years has or will have elapsed ..."
This section does not state how long the next term will be (2 years not 4 years).
Because a Mayor is elected to be a "member of the City Council" the Council term limit will apply without reference to the length the Mayor will be serving but instead is triggered by the two consecutive 4 year terms already served.
2. Is a Mayor (who hasn't served on Council for at least 2 years) subject to 8 consecutive years and then is termed-out?
This depends on interpretation of the language of BB. I leave that up to the City Attorney.
But an argument can be made that BB creates an 8 year consecutive service limit.
On the opposite side, a Mayor serving 4 consecutive 2 year terms would not violate, strictly speaking, the limit triggered by 2 consecutive 4 year terms.
3. A variant on #2: If a Councilmember completes her 4 year term and then runs for mayor, wins twice and wants to run for a third term, does BB apply.
See above.
I hope the City Attorney will answer these questions and any related questions she believes are implicated, and provide these answers and discussion before the Council wastes time and money on this issue/discussion.
Thank you.
Please attach this as a comment to the Agenda item.
--
Brad Malamud
From: Tracey Canziani <[email protected]>
Sent: Monday, April 20, 2026 8:56 PM
To: CityClerk Mail <[email protected]>; Carrillo, David <[email protected]>; Rehm, Zach <[email protected]>; Planning Mail <[email protected]> Subject: Grant the Appeal and Ensure Commonsense VMT/Traffic Mitigations in the Hanson Hotel Project
Hon. Mayor and Councilmembers,
I urge you to grant the appeal and appropriately study the impact on traffic and vehicle miles traveled (VMT) that will be caused by the Hanson Hotel Project. The project relies on a 1998 traffic study done using a significantly different (“level of service”) type of analysis as part of a different project that involved 27 timeshares and 10,000 square feet of retail space. The proposal argues that this new 61 room hotel and rooftop bar project is less intensive than the old proposal.
I do not agree. The old traffic analysis is based on a different type of analysis (“level of service”) rather than vehicle miles traveled. The Planning Commission staff report on the hotel project said that it would generate 1,631 daily trips, compared to the 620 daily trips generated by the old timeshare project.
Additionally, the 27 timeshare units in the 1998 project are less than half the number of hotel rooms proposed here. Timeshares usually involve longer stays as compared to hotels, suggesting that this new hotel project might create more frequent trips and more impacts.
The project does not attempt enough simple and straightforward mitigations that would reduce vehicle trips.
Please grant the appeal and ensure an appropriate VMT study is conducted.
Tracey
California
From: Laurel Jiron <[email protected]>
Sent: Sunday, April 19, 2026 4:35 PM
To: CityClerk Mail <[email protected]>; Carrillo, David <[email protected]>; Rehm, Zach <[email protected]>; Planning Mail <[email protected]> Subject: Grant the Appeal and Ensure Commonsense VMT/Traffic Mitigations in the Hanson Hotel Project
Hon. Mayor and Councilmembers,
I urge you to grant the appeal and appropriately study the impact on traffic and vehicle miles traveled (VMT) that will be caused by the Hanson Hotel Project. The project relies on a 1998 traffic study done using a significantly different (“level of service”) type of analysis as part of a different project that involved 27 timeshares and 10,000 square feet of retail space. The proposal argues that this new 61 room hotel and rooftop bar project is less intensive than the old proposal.
I do not agree. The old traffic analysis is based on a different type of analysis (“level of service”) rather than vehicle miles traveled. The Planning Commission staff report on the hotel project said that it would generate 1,631 daily trips, compared to the 620 daily trips generated by the old timeshare project.
Additionally, the 27 timeshare units in the 1998 project are less than half the number of hotel rooms proposed here. Timeshares usually involve longer stays as compared to hotels, suggesting that this new hotel project might create more frequent trips and more impacts.
The project does not attempt enough simple and straightforward mitigations that would reduce vehicle trips.
Please grant the appeal and ensure an appropriate VMT study is conducted.
Laurel
California
From: Bob Yoder <[email protected]>
Sent: Sunday, April 19, 2026 4:19 PM
To: CityClerk Mail <[email protected]>; Carrillo, David <[email protected]>; Rehm, Zach <[email protected]>; Planning Mail <[email protected]> Subject: Grant the Appeal and Ensure Commonsense VMT/Traffic Mitigations in the Hanson Hotel Project
Hon. Mayor and Councilmembers,
I urge you to deny the appeal. Unnecessary delay.
Bob
California
From: John Bibeau <[email protected]>
Sent: Sunday, April 19, 2026 4:56 PM
To: CityClerk Mail <[email protected]>; Carrillo, David <[email protected]>; Rehm, Zach <[email protected]>; Planning Mail <[email protected]> Subject: Yes on rooftop bars in this neighborhood, please approve Hanson Hotel Hon. Mayor and Councilmembers,
ANOTHER hotel project at the Outlets Mall project was just approved about a half mile away. Do you think we need more hotels in this neighborhood? The answer is YES! Finally, nice hotels and options for our relatives to stay at when they visit.
As a resident of San Clemente, I fully support a rooftop bar at this location. Please deny the appeal.
John Bibeau
John
California
From: Claire Sandefur <[email protected]>
Sent: Sunday, April 19, 2026 4:44 PM
To: CityClerk Mail <[email protected]>; Planning Mail <[email protected]>; Tatich, Tamara <[email protected]>; Ciampa, John <[email protected]> Subject: Investigate Vegetation Removal at Site of the Proposed Hanson Hotel (Item 8A, Council Meeting 4/21/26, PHP 25-323)
Hon. Mayor and Councilmembers,
Someone cleared vegetation—including coastal sage scrub and other native plants—from the site of the proposed Hanson Hotel on Pico and El Camino Real BEFORE approvals were completed at the City or Coastal Commission level. This premature cutting is a blow to our environmental protection efforts and will likely hamper any future investigation of important native plants at this site. I demand an investigation into the vegetation removal.
Claire
California
From: Patricia B <[email protected]>
Sent: Sunday, April 19, 2026 4:24 PM
To: CityClerk Mail <[email protected]>; Planning Mail <[email protected]>; Tatich, Tamara <[email protected]>; Ciampa, John <[email protected]> Subject: Investigate Vegetation Removal at Site of the Proposed Hanson Hotel (Item 8A, Council Meeting 4/21/26, PHP 25-323)
Hon. Mayor and Councilmembers,
Someone cleared vegetation—including coastal sage scrub and other native plants—from the site of the proposed Hanson Hotel on Pico and El Camino Real BEFORE approvals were completed at the City or Coastal Commission level. This premature cutting is a blow to our environmental protection efforts and will likely hamper any future investigation of important native plants at this site. I demand an investigation into the vegetation removal.
Patricia
California
From: Dhruv Bhakta <[email protected]>
Sent: Sunday, April 19, 2026 4:24 PM
To: CityClerk Mail <[email protected]>; Planning Mail <[email protected]>; Tatich, Tamara <[email protected]>; Ciampa, John <[email protected]> Subject: Investigate Vegetation Removal at Site of the Proposed Hanson Hotel (Item 8A, Council Meeting 4/21/26, PHP 25-323)
Hon. Mayor and Councilmembers,
Someone cleared vegetation—including coastal sage scrub and other native plants—from the site of the proposed Hanson Hotel on Pico and El Camino Real BEFORE approvals were completed at the City or Coastal Commission level. This premature cutting is a blow to our environmental protection efforts and will likely hamper any future investigation of important native plants at this site. I demand an investigation into the vegetation removal.
Dhruv
California
From: Chris Booth <[email protected]>
Sent: Sunday, April 19, 2026 4:23 PM
To: CityClerk Mail <[email protected]>; Planning Mail <[email protected]>; Tatich, Tamara <[email protected]>; Ciampa, John <[email protected]> Subject: Investigate Vegetation Removal at Site of the Proposed Hanson Hotel (Item 8A, Council Meeting 4/21/26, PHP 25-323)
Hon. Mayor and Councilmembers,
Someone cleared vegetation—including coastal sage scrub and other native plants—from the site of the proposed Hanson Hotel on Pico and El Camino Real BEFORE approvals were completed at the City or Coastal Commission level. This premature cutting is a blow to our environmental protection efforts and will likely hamper any future investigation of important native plants at this site. I demand an investigation into the vegetation removal.
Chris
California
From: Linda Crocker <[email protected]>
Sent: Sunday, April 19, 2026 4:21 PM
To: CityClerk Mail <[email protected]>; Planning Mail <[email protected]>; Tatich, Tamara <[email protected]>; Ciampa, John <[email protected]> Subject: Investigate Vegetation Removal at Site of the Proposed Hanson Hotel (Item 8A, Council Meeting 4/21/26, PHP 25-323)
Hon. Mayor and Councilmembers,
Someone cleared vegetation—including coastal sage scrub and other native plants—from the site of the proposed Hanson Hotel on Pico and El Camino Real BEFORE approvals were completed at the City or Coastal Commission level. This premature cutting is a blow to our environmental protection efforts and will likely hamper any future investigation of important native plants at this site. I demand an investigation into the vegetation removal.
Linda
California
From: Meredith Sheahan <[email protected]>
Sent: Sunday, April 19, 2026 4:11 PM
To: CityClerk Mail <[email protected]>; Planning Mail <[email protected]>; Tatich, Tamara <[email protected]>; Ciampa, John <[email protected]> Subject: Investigate Vegetation Removal at Site of the Proposed Hanson Hotel (Item 8A, Council Meeting 4/21/26, PHP 25-323)
Hon. Mayor and Councilmembers,
Someone cleared vegetation—including coastal sage scrub and other native plants—from the site of the proposed Hanson Hotel on Pico and El Camino Real BEFORE approvals were completed at the City or Coastal Commission level. This premature cutting is a blow to our environmental protection efforts and will likely hamper any future investigation of important native plants at this site. I demand an investigation into the vegetation removal.
Meredith
California
From: Bill Hoy <[email protected]>
Sent: Sunday, April 19, 2026 4:12 PM
To: CityClerk Mail <[email protected]>; Planning Mail <[email protected]>; Tatich, Tamara <[email protected]>; Ciampa, John <[email protected]> Subject: Investigate Vegetation Removal at Site of the Proposed Hanson Hotel (Item 8A, Council Meeting 4/21/26, PHP 25-323)
Hon. Mayor and Councilmembers,
Someone cleared vegetation—including coastal sage scrub and other native plants—from the site of the proposed Hanson Hotel on Pico and El Camino Real BEFORE approvals were completed at the City or Coastal Commission level. This premature cutting is a blow to our environmental protection efforts and will likely hamper any future investigation of important native plants at this site. I demand an investigation into the vegetation removal.
Bill
California
From: Amy Dilling <[email protected]>
Sent: Sunday, April 19, 2026 4:08 PM
To: CityClerk Mail <[email protected]>; Planning Mail <[email protected]>; Tatich, Tamara <[email protected]>; Ciampa, John <[email protected]> Subject: Investigate Vegetation Removal at Site of the Proposed Hanson Hotel (Item 8A, Council Meeting 4/21/26, PHP 25-323)
Hon. Mayor and Councilmembers,
Someone cleared vegetation—including coastal sage scrub and other native plants—from the site of the proposed Hanson Hotel on Pico and El Camino Real BEFORE approvals were completed at the City or Coastal Commission level. This premature cutting is a blow to our environmental protection efforts and will likely hamper any future investigation of important native plants at this site. I demand an investigation into the vegetation removal.
Amy
California
From: Kassi Marshall <[email protected]>
Sent: Monday, April 20, 2026 8:16 AM
To: CityClerk Mail <[email protected]>; Planning Mail <[email protected]>; Tatich, Tamara <[email protected]>; Ciampa, John <[email protected]> Subject: Investigate Vegetation Removal at Site of the Proposed Hanson Hotel (Item 8A, Council Meeting 4/21/26, PHP 25-323)
Hon. Mayor and Councilmembers,
Someone cleared vegetation—including coastal sage scrub and other native plants—from the site of the proposed Hanson Hotel on Pico and El Camino Real BEFORE approvals were completed at the City or Coastal Commission level. This premature cutting is a blow to our environmental protection efforts and will likely hamper any future investigation of important native plants at this site. I demand an investigation into the vegetation removal.
Kassi
California
From: Winslow Lincoln <[email protected]>
Sent: Monday, April 20, 2026 7:13 AM
To: CityClerk Mail <[email protected]>; Planning Mail <[email protected]>; Tatich, Tamara <[email protected]>; Ciampa, John <[email protected]> Subject: Investigate Vegetation Removal at Site of the Proposed Hanson Hotel (Item 8A, Council Meeting 4/21/26, PHP 25-323)
Hon. Mayor and Councilmembers,
Someone cleared vegetation—including coastal sage scrub and other native plants—from the site of the proposed Hanson Hotel on Pico and El Camino Real BEFORE approvals were completed at the City or Coastal Commission level. This premature cutting is a blow to our environmental protection efforts and will likely hamper any future investigation of important native plants at this site. I demand an investigation into the vegetation removal.
Winslow
California
From: Eileen Nakada <[email protected]>
Sent: Monday, April 20, 2026 7:07 AM
To: CityClerk Mail <[email protected]>; Planning Mail <[email protected]>; Tatich, Tamara <[email protected]>; Ciampa, John <[email protected]> Subject: Investigate Vegetation Removal at Site of the Proposed Hanson Hotel (Item 8A, Council Meeting 4/21/26, PHP 25-323)
Hon. Mayor and Councilmembers,
Someone cleared vegetation—including coastal sage scrub and other native plants—from the site of the proposed Hanson Hotel on Pico and El Camino Real BEFORE approvals were completed at the City or Coastal Commission level. This premature cutting is a blow to our environmental protection efforts and will likely hamper any future investigation of important native plants at this site. I demand an investigation into the vegetation removal.
Eileen
California
From: Pauline Faye <[email protected]>
Sent: Sunday, April 19, 2026 10:59 PM
To: CityClerk Mail <[email protected]>; Planning Mail <[email protected]>; Tatich, Tamara <[email protected]>; Ciampa, John <[email protected]> Subject: Investigate Vegetation Removal at Site of the Proposed Hanson Hotel (Item 8A, Council Meeting 4/21/26, PHP 25-323)
Hon. Mayor and Councilmembers,
Someone cleared vegetation—including coastal sage scrub and other native plants—from the site of the proposed Hanson Hotel on Pico and El Camino Real BEFORE approvals were completed at the City or Coastal Commission level. This premature cutting is a blow to our environmental protection efforts and will likely hamper any future investigation of important native plants at this site. I demand an investigation into the vegetation removal.
Pauline
California
From: Brinna Lee <[email protected]>
Sent: Sunday, April 19, 2026 9:31 PM
To: CityClerk Mail <[email protected]>; Planning Mail <[email protected]>; Tatich, Tamara <[email protected]>; Ciampa, John <[email protected]> Subject: Investigate Vegetation Removal at Site of the Proposed Hanson Hotel (Item 8A, Council Meeting 4/21/26, PHP 25-323)
Hon. Mayor and Councilmembers,
Someone cleared vegetation—including coastal sage scrub and other native plants—from the site of the proposed Hanson Hotel on Pico and El Camino Real BEFORE approvals were completed at the City or Coastal Commission level. This premature cutting is a blow to our environmental protection efforts and will likely hamper any future investigation of important native plants at this site. I demand an investigation into the vegetation removal.
Brinna
California
From: Kathleen Armenteros <[email protected]> Sent: Sunday, April 19, 2026 8:18 PM
To: CityClerk Mail <[email protected]>; Planning Mail <[email protected]>; Tatich, Tamara <[email protected]>; Ciampa, John <[email protected]> Subject: Investigate Vegetation Removal at Site of the Proposed Hanson Hotel (Item 8A, Council Meeting 4/21/26, PHP 25-323)
Hon. Mayor and Councilmembers,
Someone cleared vegetation—including coastal sage scrub and other native plants—from the site of the proposed Hanson Hotel on Pico and El Camino Real BEFORE approvals were completed at the City or Coastal Commission level. This premature cutting is a blow to our environmental protection efforts and will likely hamper any future investigation of important native plants at this site. I demand an investigation into the vegetation removal.
Kathleen
California
From: Liz Navarro <[email protected]>
Sent: Sunday, April 19, 2026 7:06 PM
To: CityClerk Mail <[email protected]>; Planning Mail <[email protected]>; Tatich, Tamara <[email protected]>; Ciampa, John <[email protected]> Subject: Investigate Vegetation Removal at Site of the Proposed Hanson Hotel (Item 8A, Council Meeting 4/21/26, PHP 25-323)
Hon. Mayor and Councilmembers,
Someone cleared vegetation—including coastal sage scrub and other native plants—from the site of the proposed Hanson Hotel on Pico and El Camino Real BEFORE approvals were completed at the City or Coastal Commission level. This premature cutting is a blow to our environmental protection efforts and will likely hamper any future investigation of important native plants at this site. I demand an investigation into the vegetation removal.
Liz
California
From: Kelly Spencer <[email protected]>
Sent: Sunday, April 19, 2026 6:49 PM
To: CityClerk Mail <[email protected]>; Planning Mail <[email protected]>; Tatich, Tamara <[email protected]>; Ciampa, John <[email protected]> Subject: Investigate Vegetation Removal at Site of the Proposed Hanson Hotel (Item 8A, Council Meeting 4/21/26, PHP 25-323)
Hon. Mayor and Councilmembers,
Someone cleared vegetation—including coastal sage scrub and other native plants—from the site of the proposed Hanson Hotel on Pico and El Camino Real BEFORE approvals were completed at the City or Coastal Commission level. This premature cutting is a blow to our environmental protection efforts and will likely hamper any future investigation of important native plants at this site. I demand an investigation into the vegetation removal.
Kelly
California
From: Andrea Rodriguez <[email protected]>
Sent: Sunday, April 19, 2026 6:06 PM
To: CityClerk Mail <[email protected]>; Planning Mail <[email protected]>; Tatich, Tamara <[email protected]>; Ciampa, John <[email protected]> Subject: Investigate Vegetation Removal at Site of the Proposed Hanson Hotel (Item 8A, Council Meeting 4/21/26, PHP 25-323)
Hon. Mayor and Councilmembers,
Someone cleared vegetation—including coastal sage scrub and other native plants—from the site of the proposed Hanson Hotel on Pico and El Camino Real BEFORE approvals were completed at the City or Coastal Commission level. This premature cutting is a blow to our environmental protection efforts and will likely hamper any future investigation of important native plants at this site. I demand an investigation into the vegetation removal.
Andrea
California
From: Vince Randazzo <[email protected]>
Sent: Sunday, April 19, 2026 5:39 PM
To: CityClerk Mail <[email protected]>; Planning Mail <[email protected]>; Tatich, Tamara <[email protected]>; Ciampa, John <[email protected]> Subject: Investigate Vegetation Removal at Site of the Proposed Hanson Hotel (Item 8A, Council Meeting 4/21/26, PHP 25-323)
Hon. Mayor and Councilmembers,
Someone cleared vegetation—including coastal sage scrub and other native plants—from the site of the proposed Hanson Hotel on Pico and El Camino Real BEFORE approvals were completed at the City or Coastal Commission level. This premature cutting is a blow to our environmental protection efforts and will likely hamper any future investigation of important native plants at this site. I demand an investigation into the vegetation removal.
Vince
California
From: Ryan Stanley <[email protected]>
Sent: Sunday, April 19, 2026 5:09 PM
To: CityClerk Mail <[email protected]>; Planning Mail <[email protected]>; Tatich, Tamara <[email protected]>; Ciampa, John <[email protected]> Subject: Investigate Vegetation Removal at Site of the Proposed Hanson Hotel (Item 8A, Council Meeting 4/21/26, PHP 25-323)
Hon. Mayor and Councilmembers,
Someone cleared vegetation—including coastal sage scrub and other native plants—from the site of the proposed Hanson Hotel on Pico and El Camino Real BEFORE approvals were completed at the City or Coastal Commission level. This premature cutting is a blow to our environmental protection efforts and will likely hamper any future investigation of important native plants at this site. I demand an investigation into the vegetation removal.
Ryan
California
From: Vivian Worthington <[email protected]> Sent: Sunday, April 19, 2026 5:02 PM
To: CityClerk Mail <[email protected]>; Planning Mail <[email protected]>; Tatich, Tamara <[email protected]>; Ciampa, John <[email protected]> Subject: Investigate Vegetation Removal at Site of the Proposed Hanson Hotel (Item 8A, Council Meeting 4/21/26, PHP 25-323)
Hon. Mayor and Councilmembers,
Someone cleared vegetation—including coastal sage scrub and other native plants—from the site of the proposed Hanson Hotel on Pico and El Camino Real BEFORE approvals were completed at the City or Coastal Commission level. This premature cutting is a blow to our environmental protection efforts and will likely hamper any future investigation of important native plants at this site. I demand an investigation into the vegetation removal.
Vivian
California
From: Joanna Rice <[email protected]>
Sent: Monday, April 20, 2026 6:04 PM
To: CityClerk Mail <[email protected]>; Planning Mail <[email protected]>; Tatich, Tamara <[email protected]>; Ciampa, John <[email protected]> Subject: Investigate Vegetation Removal at Site of the Proposed Hanson Hotel (Item 8A, Council Meeting 4/21/26, PHP 25-323)
Hon. Mayor and Councilmembers,
Someone cleared vegetation—including coastal sage scrub and other native plants—from the site of the proposed Hanson Hotel on Pico and El Camino Real BEFORE approvals were completed at the City or Coastal Commission level. This premature cutting is a blow to our environmental protection efforts and will likely hamper any future investigation of important native plants at this site. I demand an investigation into the vegetation removal.
Joanna
California
550 CALIFORNIA STREET, SUITE 1200
SAN FRANCISCO, CA 94104
T: (415) 552-7272 F: (415) 552-5816
www.smwlaw.com
GABRIEL M.B. ROSS
Attorney
[email protected]
April 21, 2026
Via Electronic Mail
Members of the City Council
c/o Laura Campagnolo, City Clerk
City of San Clemente
910 Calle Negocio
San Clemente, CA 92673
E-Mail: [email protected]
Re: Supplement to Appeal Justification for Hanson Hotel (1801 N. El Camino Real); Agenda Item 8A, De Novo Appeal Hearing of Public Hearing Project 25-323, Development Permit 25-324, and
Conditional Use Permit 25-329
Dear Councilmembers:
On behalf of UNITE HERE Local 11 (“Local 11” or “Appellant”), we respectfully submit this supplemental justification of the appeal filed September 2, 2025 (“Appeal”) of the City of San Clemente (“City”) Planning Commission’s August 20, 2025 approvals of Development Permit No. 25-324 and Conditional Use Permit 25-329 (collectively, “Entitlements”) and associated findings under the California Environmental Quality Act (“CEQA”), concerning the proposed Hanson Hotel (“the Project”).
Local 11, through its counsel the Law Office of Jordan R. Sisson, previously submitted extensive comments in opposition to the Project approvals in its appeal justification dated September 2, 2025 (“Appeal Letter”). The Appeal Letter identified serious deficiencies in the Planning Commission’s approvals of the Entitlements and the Project’s CEQA findings which merited denial of the permits. The City has failed to address the concerns identified in the Appeal Letter, in many cases failing to respond at all. This supplemental letter fully incorporates by reference the Appeal Letter and all exhibits thereto.
In addition, the City has introduced several new justifications for the Project approvals, none of which resolve the Project’s inadequacies under CEQA, the City Council
April 21, 2026
City’s General Plan, and the California Coastal Act (“Coastal Act”).1 It also fails to so much as mention a critical new development: the apparently unauthorized removal of vegetation on the Project site, including native coastal sage scrub, in January 2026.2 The Project as proposed will likely have significant, adverse effects on the natural and human environment in the City. It could result in potentially devastating effects to special-status species and protected habitats in the Marblehead/Sea Summit open space preserve while generating significant local traffic and noise. This should be unsurprising. The Project site is on one of the only mixed use-zoned parcels in the City that directly adjoins an open space area. It is possibly the only mixed use parcel in the City that is adjacent to Coastal Act-protected Environmentally Sensitive Habitat Area (“ESHA”). And there is a strong possibility that the site itself meets the criteria to be deemed ESHA by the California Coastal Commission (“Coastal Commission”), which would preclude essentially all development.
The City must therefore take exceptional care to ensure that development of the site, if it is appropriate at all, avoids impacting these sensitive resources. Because the City has failed to address these critical questions and recent developments, the City should grant the Appeal and withhold approving the Entitlements until the applicant prepares a full environmental impact report (“EIR”) and demonstrates consistency with applicable General Plan and Coastal Act policies.
I. The City cannot find that the Project is “exempt” from CEQA under CEQA Guidelines section 15183 because that section is not a CEQA exemption.
As the Appeal Letter discussed, the Project cannot evade further CEQA review by relying on a mitigated negative declaration from a previous development proposal for the 1 The agenda for the appeal hearing was released on April 15, 2026, allowing less than a week to review the thousand-page long CEQA findings document prior to the April 21, 2026 deadline for written comments. Our comments here provide an overview of the document’s deficiencies, while Local 11 reserves the right to submit further oral comments at the hearing. See San Clemente Municipal Code § 17.12.140.E (body hearing appeal may consider new evidence and issues outside those raised in the appeal document).
2 The factual details of this vegetation removal are outlined in the letter submitted to the Council on April 15, 2026 by the California Native Plant Society (“CNPS Letter”), attached hereto as Attachment 1. We have separately attached photos depicting the vegetation removal as Attachment 2.
City Council
April 21, 2026
Project site because conditions have changed. Agenda Packet 3 (“AP”) 64, 69-70. Nor can the City find that the Project is exempt from CEQA under a Class 32 categorical exemption, because, as the City admits, the Project’s purported lack of significant impacts results from future project-specific mitigation measures. AP 70. The City has apparently abandoned these arguments, because it now asserts that it is “not relying on the 1998 Mitigated Negative Declaration or a Class 32 categorical exemption.” AP 7.
Instead, the staff report now recommends the Council find the Project “exempt” from CEQA pursuant to CEQA Guidelines4 section 15183 because the Project is allegedly consistent with the allowable density for its parcel under the City’s General Plan and its accompanying Program EIR (“General Plan EIR”). AP 8. The proposed Council resolution too includes findings that the Project is “exempt” from CEQA under this section. AP 11-12.
The City cannot find this, or any, project “exempt” from CEQA under this provision. Section 15183 is not an exemption. Rather, it allows certain projects that are consistent with an adopted general plan to rely on prior environmental review when, and only when, the agency demonstrates that the effects of the project were adequately analyzed in the prior EIR and that the project will not result in project-specific significant effects that are peculiar to the project or its site. CEQA Guidelines § 15183(a). It imposes an affirmative obligation on the lead agency to demonstrate, based on substantial evidence in the record, that the project’s environmental effects were adequately analyzed in the prior EIR and that no project-specific significant effects peculiar to the site exist.
As discussed below, the record lacks substantial evidence to qualify this Project for streamlined review.
II. The Project does not qualify for streamlined review under CEQA Guidelines section 15183 because there is no demonstration of consistency with the Coastal LUP.
Having accepted that the Project is subject to CEQA, the City attempts to truncate its environmental review using CEQA Guidelines section 15183. That streamlining provision only applies to projects that “are consistent with the development density 3 Citations herein to the “Agenda Packet” are to the bates numbered pages of the Agenda Report for the April 21, 2026 City Council hearing on this Appeal. 4 Citations herein to the “CEQA Guidelines” are to Title 14, sections 15000 et seq. of the California Code of Regulations.
City Council
April 21, 2026
established by existing zoning, community plan, or general plan policies for which an EIR was certified.” CEQA Guidelines § 15183(a).
The City does not, and cannot, make such a finding here. The General Plan EIR determined that development under the General Plan would not conflict with Coastal Act policies for biological resource protection because the City would implement the Coastal Act’s resource protection policies through a Coastal Land Use Plan (“Coastal LUP”), which was yet to be adopted. See General Plan DEIR at 5.3-34, -36. As a result, the General Plan EIR never actually studied how projects might conflict with the Coastal LUP.
The General Plan EIR thus deferred CEQA review of future projects’ impacts on ESHA. An EIR must discuss potential impacts to areas designated as ESHA under the Coastal Act. Banning Ranch Conservancy v. City of Newport Beach (2017) 2 Cal.5th 918, 941. Even development that is merely adjacent to ESHA triggers statutory mitigation obligations. Pub. Res. Code § 30240(b) (development “adjacent to [ESHA] shall be sited and designed to prevent impacts which would significantly degrade those areas”). ESHA-adjacent development thus must be carefully analyzed for impacts on ESHA.
The Project site here is clearly adjacent to an area identified in the General Plan EIR as ESHA, and may actually qualify as ESHA itself, as further discussed below and in Local 11’s earlier Appeal Letter. See AP 61-62; General Plan at p. 167, fig. C-2. The City cannot rely on the General Plan EIR’s finding of consistency with applicable land use policies that protect ESHA, because those policies did not exist when the General Plan was certified. As such, the City cannot rely on the General Plan EIR to restrict the scope of its CEQA review under Guidelines section 15183.
The City also makes no findings, and sets forth no evidence, that the Project is consistent with the development restrictions contained in General Plan Coastal Element Policies C-2.05 and C-2.10. Those policies directly require the City to protect ESHA according to the more specific dictates of its certified Coastal LUP, as further described in Section V below.
Instead, the City dismisses this issue with two conclusory statements, both of which are incorrect. First, it says that the General Plan EIR already determined that buildout in the area would not cause a significant impact by conflicting with Coastal Act policies. AP 237. But the EIR found no significant impact only “[u]pon implementation of regulatory requirements and standard conditions of approval,” including the local coastal program. General Plan DEIR at 5.3-36 to -37. This finding leaves open the possibility that, as here, a future project could be inconsistent with those coastal policies City Council
April 21, 2026
and thereby cause a significant impact. Second, the City asserts that the Project site is “not located within the canyon ESHAs” so its ESHA policies do not apply. AP 244.
Setting aside that the Project site may well qualify as ESHA, this assertion does not account for the Coastal LUP’s limits on development in ESHA-adjacent areas.
These include clear density limits, such as maintaining a 100-foot development buffer around ESHA, and confining development adjacent to ESHA buffers to lowimpact land uses. See Coastal LUP at 4-42 to 4-43 (Policies RES-54, -57, -59, -60).
Where the City does discuss consistency with the Coastal LUP, it skips any analysis of ESHA-related development restrictions. AP 307-13.
Because the City does not discuss whether the Project is consistent with these General Plan policies, it cannot support its finding that the Project is consistent with the policies covered by the General Plan EIR, as is required for streamlined review under section 15183.
III. The City’s analysis of impacts to biological resources does not meet its obligations under CEQA Guidelines § 15183.
For the City to rely on the General Plan EIR it would need to undertake CEQA review of any previously unanalyzed or site-specific factors. The City’s record does not show any such review. The City entirely ignores the potential conflicts between the proposed Project and its Coastal Zone ESHA management policies. These policies, adopted after the General Plan EIR was certified, were “not analyzed as significant effects” in that EIR, and relate to “potentially significant off-site impacts” not discussed in that EIR. CEQA Guidelines § 15183(b)(2)-(3). They are plainly within the scope of the City’s CEQA review obligations under section 15183.
Nonetheless, the initial study goes out of its way to find that conflicts with resource-protection policies are less than significant.5 AP 238. To justify this finding, it simply says that the Project site is not in coastal canyon ESHA, and that adherence to existing City regulations would not conflict with the Coastal Zone. AP 244. As discussed in Section II, however, the City’s Coastal LUP contains several policies on ESHAadjacent development that conflict with the Project. These policies are incorporated into the City’s General Plan. The City is obligated to analyze these potential conflicts and identify mitigation for any impacts. Failing to do so violates CEQA’s disclosure obligations even under a streamlined analysis.
5 The City is actually inconsistent on whether it characterizes this potential impact as “less than significant,” see AP 238, or “no impact,” see AP 244-45.
City Council
April 21, 2026
IV. In light of recent vegetation removal at the Project site, CEQA requires a new biological resources analysis.
The City also cannot approve the Project as proposed because it is not operating on current information. An agency’s decision not to update the environmental baseline in light of conditions that changed during the preparation of a CEQA document must be supported by substantial evidence. Citizens for Open Government v. City of Lodi (2012) 205 Cal.App.4th 296, 318-19.
Here, the vegetation removal described in the CNPS Letter has fundamentally shifted the environmental baseline with respect to biological resources. The letter describes removal of nearly all the vegetation in January 2026, including a native coastal sage scrub community. See CNPS Letter at 1; see also Attachment 2. However, the City continues to rely on a biological resource assessment whose field surveys concluded in December 2025. AP 456. That the site may now appear more disturbed because of this vegetation removal actually underscores the City’s need to update its analysis to rely on current, accurate baseline information. The coastal sage scrub community documented on the site has been disturbed before and could easily be growing back during construction.
Effects of these grow-back conditions on the frequency with which the special-status California gnatcatcher (which has previously been observed on the site), Crotch’s bumble bee, or other protected species may visit the site are unknown and unstudied. Because the vegetation has ecological continuity with the Sea Summit preserve, see CNPS Letter at 1, the recent vegetation removal may affect wildlife movement patterns in unanticipated ways and contribute to new offsite impacts.
Moreover, “removal” of “major vegetation” is “development” under the Coastal Act requiring a Coastal Development Permit (“CDP”). Pub. Res. Code § 30106. If a CDP was not obtained for this removal, the Coastal Commission may impose penalties for a violation of the act, including potentially requiring restoration of this habitat, which would further change the environmental setting. Id. § 30811. We will provide the Commission with a copy of this letter and a request that they investigate the matter.
In light of the change in conditions resulting from the vegetation removal and the serious possibility of a Coastal Commission restoration order that further changes natural conditions, the City lacks sufficient information to make informed CEQA findings. To approve the Project nonetheless would be an abuse of its discretion.
City Council
April 21, 2026
V. The Project as proposed likely violates the Coastal Act and the City’s General Plan.
The Project is directly adjacent to Coastal Commission-designated ESHA.
Approving it as proposed would therefore likely conflict with several policies in the City’s General Plan Coastal Element and associated Coastal LUP.
These include:
• General Plan Policy NR-1.03, prohibiting grading and development in “sensitive habitats,” which per the City’s initial study includes the coastal sage scrub at the Project site (AP 236, 239), “unless no feasible project alternative exists which reduces environmental impacts to less than significant levels, or it is replaced with habitat of equivalent value, as acceptable to the City Council” • General Plan Policy C-2.05, “restricting the encroachment of development, incompatible land uses and sensitive habitat disturbance into designated coastal canyons and coastal bluff areas, consistent with the Local Coastal Program” • General Plan Policy C-2.10, “restricting development in ESHAs consistent with the Local Coastal Program and the California Coastal Act.” The Coastal LUP in turn imposes restrictions on ESHA-adjacent development including buffer zones and intensity limits. For example:
• LUP Policy RES-54, stating that a “100-foot buffer, shall be provided around all ESHA” or “the largest feasible buffer” where there is existing development • LUP Policy RES-57, requiring “ESHA buffers [to] be maintained exclusively with native vegetation to serve as transitional habitat”
• LUP Policy RES-59, requiring “[w]here feasible, [to] confine development adjacent to ESHAs to low impact land uses, such as open space and passive recreation”
• LUP Policy RES-62, requiring “mitigation in the form of habitat creation or substantial restoration for allowable impacts to ESHA and other sensitive resources that cannot be avoided through the implementation of siting and design alternatives”
• LUP Policy RES-65, requiring open space dedication in “conjunction with new development” that “preserve[s] ESHA, buffers, and all mitigation areas” City Council
April 21, 2026
Approval of the Project as proposed violates the City’s obligation that development be consistent with General Plan policies. Orange Citizens for Parks & Recreation v. Superior Court (2016) 2 Cal.5th 141, 153 (“The propriety of virtually any local decision affecting land use and development depends upon consistency with the applicable general plan and its elements.”). The Entitlements cannot be legally approved.
Furthermore, as the Appeal Letter notes, the Project as proposed appears inconsistent with the Coastal Act’s and the General Plan’s policies on lower-cost overnight accommodations (“LCOAs”) because it lacks enforceable conditions of approval to ensure that these policies are implemented. AP 65-69. The City rejoins that it “defers to the Coastal Commission’s established authority and evolving standards to ensure compliance with Coastal Act requirements.” AP 6. The City cannot dodge its responsibility like this. The City’s own General Plan requires that it “where feasible, provide low cost overnight accommodations.” General Policy C-1.14. The applicant’s own Project proposal shows that LCOAs are feasible. Unless the City ensures that these accommodations are provided, the approval will be inconsistent with the General Plan and thus invalid. The Coastal Commission is likely to agree. The City should impose a condition of approval mandating the LCOAs now and spare the taxpayers the expense of further considering a project that may need to be substantially modified.
Likewise, denying the permits would be the more prudent course of action in light of the fact that the Coastal Commission may well designate the Project site as ESHA. See Douda v. California Coastal Commission (2008) 159 Cal.App.4th 1181, 1194 (Coastal Commission can designate areas as ESHA when it is the CDP-issuing agency). ESHA is “any area in which plant or animal life or their habitats are either rare or especially valuable because of their special nature or role in an ecosystem and which could be easily disturbed or degraded by human activities and developments.” Pub. Res. Code § 30107.5.
As the City’s own biological resources assessment notes, the federally threatened California gnatcatcher has been observed on the Project site over multiple field visits during 2025. AP 461; see also Coastal LUP at 4-7 (noting that the Coastal Commission designated “all areas that were used by the . . . coastal California gnatcatcher” as ESHA within the Marblehead/Sea Summit area); id. at 4-13 (“Any Coastal Sage Scrub occupied by the Coastal California gnatcatcher or other rare species will qualify as ESHA because of the especially valuable role it plays in the ecosystem.”). Field visits also noted an already-disturbed Menzies’s golden bush scrub community (designated as sensitive by the state), stating that “mitigation for its loss may be necessary.” AP 459. And the Project site is adjacent to a designated ESHA area that the Coastal Commission specifically made a reserve for the sensitive Blochman’s dudleya. AP 64.
The observed presence of rare and sensitive species on and near the site, clear threat of disturbance or degradation, and its adjacency to protected ESHA make the site a City Council
April 21, 2026
strong candidate to be designated as ESHA. This would make the Project impossible as proposed, because only land uses “dependent” on protected “habitat values” may be allowed within designated ESHA. Pub. Res. Code § 30240(a). As such, the City should not approve the Entitlements until it has the information to be more certain that the Coastal Commission will not designate the Project site as ESHA.
VI. Conclusion
For the foregoing reasons, Local 11 respectfully requests that the City grant the Appeal and withhold approving the Entitlements for the Project until, at minimum:
• The applicant prepares a full EIR consistent with CEQA, which robustly analyzes potential impacts to biological resources, including due to conflict with applicable General Plan and Coastal LUP policies on ESHA-adjacent development, and which is reflective of the current state of the Project site after the January 2026 vegetation removal;
• The applicant modifies the Project to be consistent with applicable Coastal LUP policies for ESHA-adjacent areas and includes information demonstrating to the City’s satisfaction that the Project site is not eligible to be designated as ESHA; • The City conditions any approval of the Entitlements on an enforceable commitment to uphold Coastal Act and General Plan LCOA policies as discussed in the Appeal Letter, and;
• The applicant demonstrates that the Project is consistent with the City’s General Plan, including its Coastal Element policies on natural resources protection.
Without these changes, the Project cannot be legally approved.
Very truly yours,
SHUTE, MIHALY & WEINBERGER LLP
Gabriel M.B. Ross
City Council
April 21, 2026
Cc: Rick Loeffler, Mayor
Steve Knoblock, Mayor Pro Tem
Victor Cabral, Council Member
Mark Enmeier, Council Member
Zhen Wu, Council Member
Andrew Willis, Southern CA Enforcement Manager, California Coastal Commission (by email and U.S. mail)
Attachments:
Attachment 1 – Letter from Orange County Chapter, California Native Plant Society to San Clemente City Council (April 15, 2026)
Attachment 2 – Photos depicting vegetation removal
Attachment 1
To conserve California native plants and their natural habitats, today and into the future, through science, education, stewardship, gardening, and advocacy OCCNPS.org | P.O. Box 54891, Irvine, CA 92619-4891
San Clemente City Council
[email protected]
[email protected]
15 April 2026
Dear Mayor and Members of the City Council,
On behalf of the Orange County Chapter of the California Native Plant Society (OCCNPS), we submit the following comments regarding the proposed Hansen Hotel project at 401 El Camino Real, scheduled for public hearing on April 21, 2026.
OCCNPS previously submitted a detailed comment letter to the City on August 26, 2025, documenting the presence of a disturbed but functioning coastal sage scrub plant community on the project site. That assessment was based on a field visit and botanical survey conducted by qualified biologists and included a species inventory demonstrating that native coastal sage scrub species dominated the site, despite some disturbance. These findings directly contradicted the conclusion in the City’s staff report that the site lacked sensitive biological resources and supported the project’s claimed exemption from environmental review. A copy of our August 26, 2025 comment is attached.
We reiterate our fundamental concern that the site, due to its vegetation, ecological function, and direct adjacency to the extensive Sea Summit open space preserve, may qualify as Environmentally Sensitive Habitat Area (ESHA) under the California Coastal Act. The assertion that the site is “substantially surrounded by urban uses” is not supported by the actual landscape context, in which a significant portion of the site borders conserved natural habitat with ecological continuity.
Since submission of our August 2025 letter, a significant and troubling development has occurred. In January 2026, OCCNPS was notified that all vegetation on the site had been removed. A subsequent site visit confirmed that the property had been completely cleared to bare soil, eliminating all previously documented native plant cover, including coastal sage scrub vegetation.
This action raises serious concerns. Vegetation removal and site clearing constitute “development” under the California Coastal Act and may require a Coastal Development Permit (CDP), particularly where sensitive habitat resources are present or may be present. At this time, we have been unable to identify any approved CDP, waiver, or other coastal authorization for this activity through publicly available records, including the California Coastal Commission’s permitting portal. Furthermore, City records indicate that the project’s discretionary permits remain pending.
The removal of vegetation under these circumstances appears to have occurred prior to completion of environmental review and may have altered or eliminated biological resources that are central to determining the project’s impacts. This raises substantial concerns regarding compliance with both the California Coastal Act and the California Environmental Quality Act (CEQA), and whether the environmental baseline for the project has been improperly modified.
Importantly, the absence of vegetation today does not negate the documented presence of coastal sage scrub habitat prior to clearing. Our biologist records and photography confirm this vegetation and a disturbed coastal To conserve California native plants and their natural habitats, and increase understanding, appreciation, and horticultural use of native plants.
OCCNPS.org | P.O. Box 54891, Irvine, CA 92619-4891
sage scrub plant community. Sound environmental review must rely on accurate baseline conditions, not conditions resulting from recent disturbance.
Given these concerns, OCCNPS respectfully requests that the City of San Clemente take the following actions:
1. Deny approval of the Conditional Use Permit and Development Permit for the Hansen Hotel project unless and until full compliance with CEQA and the California Coastal Act is demonstrated;
2. Require preparation of a comprehensive biological assessment based on pre-disturbance conditions, including consideration of the site’s prior coastal sage scrub community and its potential qualification as ESHA;
3. Coordinate with the California Coastal Commission to determine whether unauthorized development, including vegetation removal, has occurred and to ensure appropriate regulatory oversight;
4. Require restoration of the site to its prior coastal sage scrub habitat, or to a condition of equal or greater ecological function, using locally native species appropriate to the region and consistent with adjacent conserved lands;
5. Ensure that any future project design, landscaping, and mitigation measures avoid the use of invasive or non-local plant species and instead support the long-term ecological integrity of the surrounding natural habitat.
The protection of coastal sage scrub habitat and its associated species is a matter of regional and statewide importance. The sequence of events at this site—particularly the removal of native vegetation during an active entitlement process—warrants careful scrutiny and a cautious approach.
We appreciate your consideration of these comments and respectfully urge the City to base its decision on sound science, accurate environmental baselines, and full compliance with applicable environmental laws. cc: CA Coastal Commission
Sincerely,
Ron Vanderhoff Elizabeth Wallace Laura Camp
Director and Plant Science Chair Co-President Co-President CNPS, Orange County Chapter
PO Box 54891, Irvine, CA 92619-4891
OCCNPS.org
[email protected]
Attachment 2
Channel Law Group, LLP
8383 Wilshire Blvd.
Suite 750
Beverly Hills, CA 90211
Phone: (310) 347-0050
Fax: (323) 723-3960
www.channellawgroup.com
JULIAN K. QUATTLEBAUM, III
JAMIE T. HALL *
CHARLES J. McLURKIN
GREGORY T. WITTMANN
*ALSO Admitted in Texas
Writer’s Direct Line: (310) 982-1760
[email protected]
April 21, 2026
VIA EMAIL
Laura Campagnolo
Elizabeth Mitchell
Andy Hall
City of San Clemente
910 Calle Negocio
San Clemente, CA 92673
[email protected]
[email protected]
[email protected]
Re: Demand to Continue April 21, 2026 De Novo Hearing and Re-Issue Public Hearing Notice — Hanson Hotel, 1801 N. El Camino Real (PHP 25-323; CUP 25-329; DP 25-324)
Dear Ms. Campagnolo, Ms. Mitchell and Mr. Hall:
This firm in conjunction with Shute Mihaly & Weinberger, LLP represents Unite Here Local 11 ("Local 11"), appellant in the pending de novo appeal of the Planning Commission's August 20, 2025 approval of the Hanson Hotel project. I write to demand that today’s City Council hearing be continued and re-noticed because the Notice of Public Hearing ("Notice") states the wrong project address-not once, but twice.
The Notice identifies the site as “801 North El Camino Real” in its bold subject heading and again in the opening paragraph. The correct address is 1801 North El Camino Real—the 0.8- acre parcel at the northwest corner of North El Camino Real and Avenida Pico, adjacent to Pico Park and the Sea Summit open space, as identified in the Planning Commission Staff Report, the Notice of Appeal, and the Appeal Justification. The two addresses are roughly a mile apart, and the Notice contains no cross-streets, parcel number, site description, or vicinity map that would allow a reader to locate the correct site.
City of San Clemente
April 21, 2026
2 SCMC § 17.12.100(B)(3)(b) clearly requires that a public hearing notice include the location of the subject property. A notice that misstates the project address twice and provides nothing from which the reader could fix the error does not comply.
Nor can the defect be excused as substantial compliance, which “excuses technical imperfections only after the statutory objective has been achieved.” Smith v. Board of Supervisors (1989) 216 Cal.App.3d 862, 874. Where a notice affirmatively misstates essential content, it is "not merely technically imperfect; it was legally insufficient," and courts will not substitute a different form of notice for the one prescribed by statute. Id. at 874-875; accord County of Riverside v. Superior Court (1997) 54 Cal.App.4th 443, 450-451; Sounhein v. City of San Dimas (1992) 11 Cal.App.4th 1255, 1260–1261 (notice defect precluding meaningful public participation “cannot be deemed harmless or nonprejudicial”).
The same is true here. The Notice affirmatively misdirects the public to the wrong neighborhood: owners within 300 feet of 801 N. El Camino Real are not the owners entitled to mailed notice under SCMC § 17.12.100(B)(2)(a), and interested persons who relied on the Notice were unable to locate the correct project site. Any City Council decision on this record is therefore vulnerable under Government Code § 65010(b), which directs courts to set aside landuse actions where the procedural error was prejudicial, the complaining party suffered substantial injury, and a different result would have been probable absent the error.
On behalf of Local 11, we demand that the City: (1) continue the April 21, 2026 hearing to a date no earlier than ten days after a corrected Notice is published, mailed, and posted in compliance with SCMC § 17.12.100 and Government Code sections 65090 and 65091; (2) mail notice to all property owners within 300 feet of 1801 North El Camino Real per SCMC §
17.12.100(B)(2)(a); (3) identify the project in the corrected Notice as 1801 North El Camino Real (northwest corner of North El Camino Real and Avenida Pico); and (4) file the required affidavits under SCMC § 17.12.100(B)(5). Please confirm in writing by 12:00 p.m. on April 21, 2026 that the hearing will be continued and re-noticed. Local 11 reserves all rights and remedies, including a petition for writ of mandate under Code of Civil Procedure section 1094.5 and an action to set aside the City Council's decision under Government Code section 65010(b).
I may be contacted at 310-982-1760 or [email protected] with any questions.
Sincerely,
Jamie T. Hall
From: Donna Vidrine
Sent: Tuesday, April 21, 2026 10:08 AM
To: Campagnolo, Laura <[email protected]>
Subject: public comments: item 8a for tonites CC meeting/ Support Continuing Outdoor Dining in San Clemente
Good evening Mayor and Members of the City Council,
My name is Donna Vidrine, and I am a San Clemente resident and a member of the Chamber of Commerce, supporting local business and economic vitality in our city.
I’m here tonight to express my support for the continuation of the outdoor dining program through January 1, 2029, along with the proposed zoning amendment and staff-recommended updates.
The staff report is thoughtful, thorough, and builds on what has already proven to be a successful program for San Clemente. These updates strengthen the program with clearer standards for design, improved oversight, a defined review process, and appropriate enforcement.
Importantly, the refinements strike a balance. Limiting parklets to directly in front of the associated business, ensuring they do not impact neighboring storefronts, and reducing the number on Avenida Del Mar from 14 to 10 demonstrates responsiveness to community concerns. The overall parking impact—19% on Del Mar and just 3% of total downtown public parking—is measured and reasonable.
The enhanced aesthetic standards will further elevate the look and feel of our downtown, aligning with the character of San Clemente.
I also support directing program fees toward solutions that offset parking impacts—such as expanded free trolley service, improved public parking access, and other transportation options.
This is not about continuing a temporary response to COVID. This is a forward-looking decision—one that enhances our downtown vitality, supports local businesses, and contributes to the lifestyle that defines San Clemente as the “Spanish Village by the Sea.” I respectfully ask for your vote tonight to continue this program through 2029. Thank you for your time and consideration.
Campagnolo, Laura
From:
Sent:
To:
Cc:
Subject:
Hi Adam
Rachel Nasre <[email protected]>
Tuesday, April 21, 2026 1:39 PM
Jorden Segraves; Atamian, Adam
Rehm, Zach; Ciampa, John
Re: Hanson Hotel Update
BA
Thank you for your email and for the update regarding the Appellant's request to postpone the de novo hearing.
As the project applicant, we must respectfully but firmly object to the requested postponement. Given the substantial amount of time, effort, and financial resources that have already been invested in this project in reliance on the scheduied hearing date, a delay at this stage is both prejudicial and unacceptable.
The stated basis for the postponement-a clerical issue in the Notice of Public Hearing-does not appear to rise to a level that would justify further delay, particularly where it results in material harm to the applicant. We have proceeded in good faith throughout this process, incurring significant costs associated with project preparation, coordination, and attendance all in anticipation of the duly noticed hearing.
VS/hile we understand the City's interest in maintaining a legally defensible process, we respectfully submit that such considerations must also be balanced against the applicant's right to a timely and fair hearing. Any additional delay will further impact project timelines, increase costs, and create continued uncertainty.
Accordingly, we urge the City Council to deny the request for postponement and proceed with the hearing as scheduled.
At a minimum, we request that the Council carefully consider the prejudice to the applicant in determining whether good cause exists to continue the matter.
We will plan to attend this evening's meeting and are prepared to address this issue on the record.
Thank you for your consideration.
Rachel Nasre, CPA RN Investments, LLC 310-293-5196 This email transmission, including any attachments, may contain material that is confidential, privileged and/or attorney work product for the sole use of the intended recipient. Any review, reliance, dissemination or distribution by anyone other than the named addressee, or forwarding without the express permission of the sender, is strictly prohibited. if you are not the intended recipient, please contact the sender by reply email or telephone, delete this message, and destroy all copies of the message immediately. Thank you in advance for your cooperation. To ensure compliance with Internal Revenue Service Circular 230, we inform you that any U.S. Federal Tax advice contained in this communication is not intended or written to be used, and cannot be used, for the purpose of (1 ) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any tax-related matter(s) addressed herein.
On Tuesday, April 21, 2026 at 01:24:35 PM PDT, Atamian, Adam <[email protected]> wrote:
Hello Rachel and Jorden,
The City received correspondence earlier today from the Appellant's legal counsel requesting that the de novo hearing be postponed due to a clerical issue identified in the Notice of Public Hearing (specifically, an incomplete project address). This issue was brought to staffs attention this morning. 1 Staff will be forwarding the Appellant's request to the City Council and recommending tonight that the hearing be renoticed for the May 19th meeting, which is the next available date that meets noticing requirements.
We understand this is a frustrating development, particularly given the time and effort that has gone into preparing for thiS hearing, and that it mad affeCt 'your prOjeCt timeline andcoordinatiol1. Ourgoal iStOkeepthe prOCeSSmOVing forward in a way that is clear and legally defensible, while minimizing additional disruption where possible.
We do recommend that you still attend tonight's meeting, as it will be at the Council's discretion whether to grant the postponement and whether tO take public comment from thOSe in attendance. Additionally, the Appellant haS submitted a comment letter in response to the City's agenda report and CEQA documentation, which is attached for your reference.
Sincerely,
Adam Atamian
Community Development Director
p: (g49) 361-6196
ata [email protected]
APleaseconsidertheenvironment beforeprintingthise-mail
From: Jorden Segraves <[email protected]>
Sent: Tuesday, April21, 2026 12:04 PM
To: Rachel Nasre <[email protected]>; Ciampa, John <[email protected]>; Atamian,Adam <[email protected]>
Subject: Re: Hanson Hotel Update
What?
Jorden Segraves
AIA, LEED AP, NCARB
Jorden Segraves Architect Inc.
Ohana Living
949.338.2603
From: Rachel Nasre <[email protected]>
Sent: Tuesday, April 21, 2026 11:53:41 AM
TO: JOhn Ciampa <ciampai@san-clementeaorg>; Adam Atamian <atamiana@San<lemente00rg>; JordenSegraveS <jordens@ jorden-arch.com>
Subject: Re: Hanson Hotel Update
Ijust heard our hearing is being pushed out???? is this correct Rachel Nasre, CPA RN Investments, LLC 310-293-5196 This email transmission, including any attachments, may contain material that is confidential, privileged and/or attorney work product for the sole use of the intended recipient. Any review, reliance, dissemination Or distribution by anyone other than the named addressee, or forwarding without the eXpreSS permission of the senderi iS StriCtly prohibited. IfyOu are net the intended reCipient, please COntaCthe sender by reply e-mailOrtelephone,delete this message, and destroy all copies of the message immediately. Thank you in advance for your cooperation. To ensure compliance with Internal Revenue Service Circular 230, we inform you that any u.s. Federal Tax advice contained in this communication is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal RevenueCode or (2) promoting, marketing or recommending to another party any tax-related matter(s) addressed herein. 2 On Thursday, March 26, 2026 at 06:00:08 PM PDT, Flores, Andy <[email protected]> wrote:
Hi Rachel,
The amount(s) required to proceed with the hearing are as follows:
S61,709 - CEQA analysis
S7,000 - City Attorney Review (est.)
S7,000 - City Staff time (est.)
S6,984.88 - Negative balance (PA 430831)
Total: S82,693.88
Please let us know if you have any questions.
Building l Code Compliance I PI l Social Services and Grants From: Rachel Nasre <[email protected]>
Sent: Thursday, March 26, 2026 1:26 PM
To: Ciampa, John <[email protected]>; Flores, Andy <[email protected]> Cc: Jorden Segraves <[email protected]>; Rehm, Zach <[email protected]>; Atamian, Adam <[email protected]>
Subject: Re: Hanson Hotel Update
Just to confirm I need to bring a check in for the $6984.88 to bring the account to O balance plus the associated costs for the next city council hearing? \/S/hich Usually you request a 'l OK deposit for that Thank you
Rachel
Rachel Nasre, CPA RN Investments, LLC 310-293-5196 This email transmission, including any attachments, may contain material that is confidential, privileged and/or attorney work product for the sole use of the intended recipient. Any review, reliance, dissemination or distribution by anyone other than the named addressee, or forwarding without the express permission of the sender, is strictly prohibited. If you are not the intended recipient, please contact the sender by reply email or telephone, delete this message, and destroy all copies of the message immediately. Thank you in advance for your cooperation. To ensure compliance with Internal Revenue Service Circular 230, we inform you that any u.s. Federal Tax advice contained in this communication is not intended or written to be used, and cannot be used, for the purpose of (1 ) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any tax-related matter(s) addressed herein.
On Thursday, March 26, 2026 at 11:49:34 AM PDT, Flores, Andy <floresa(,san-clemente.orq> wrote:
Hi Rachel,
3 Thank you for your patience. Attached please find the project account report (xlsx). Along with this repon are invoices City staff are able to provide to you. City Attorney invoices are not public records. However, the invoices generally reflect work associated with the following project related activities:
Review of City staff reports and resolutions applicable to the project Legal review and analysis of complex CEQA requirements that applicable to the project Legal review and analysis related to the applicant's appeal Project related conferences with City staff and/or other parties Project related correspondence
Please note that two invoices from Michael Baker International (MBI) are still outstanding due to the account currently being overdrawn.
MBI-Invoice 1266585 - 513,550
MBI-Invoice 1279951- S:[0,942
This does not account for other project related invoices staff has yet to receive.
Please let us know if you have any questions.
Thank you,
l Code Compliance I PI l Social Services and Grants
From: Rachel Nasre <[email protected]>
Sent: Wednesday, March 25, 2026 2:30 PM
To: Ciampa, John <[email protected]>; Flores, Andy <[email protected]> Cc: Jorden Segraves <[email protected]>; Rehm, Zach <[email protected]>; Atamian, Adam <[email protected]>
Subject: Re: Hanson Hotel Update
Hi Andy and Adam
I have not received a reply yet. I will need to know before paying anything the correct balance due, if any. I have also included the attached showing a O balance. 1will need clarification to the accounting provided.
I would appreciate a prompt reply because I have a scheduled April 21 city council hearing Thank you
Rachel Nasre, CPA RN Investments, LLC 310-293-5196 This email transmission, including any attachments, may contain material that is confidential, privileged andlor attorney work product for the sole use of the intended recipient. Any review, reliance, dissemination or distribution by anyone other than the named addressee, or forwarding without the express permission of the sender, is strictly prohibited. If you are not the intended recipient, please contact the sender by reply email or telephone, delete this message, and destroy all copies of the message immediately. Thank you in advance for your cooperation. To ensure compliance with Internal Revenue Service Circular 230, we inform you that any u.s. Federal Tax advice contained in this communication is not intended or written to be used, and cannot be used, for the purpose of (1 ) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any tax-related matter(s) addressed herein.
4 On Tuesday, March 24, 2026 at 05:41 :51 PM PDT, Rachel Nasre <[email protected]> wrote:
Hi Andy
I received the above email from John regarding the account balance for the Hanson Hotel. I would like to know how the CEQA Appeal deposit of $53,697 was used. Can you provide an expense report/ GL for how these funds/deposit was used. VS/hat was provided to me was not sufficient.
Thank you
Rachel Nasre, CPA RN Investments, LLC 310-293-5196 This email transmission, including any attachments, may contain material that is confidential, privileged and/or attorney work product for the sole use of the intended recipient. Any review, reliance, dissemination or distribution by anyone other than the named addressee, or forwarding without the express permission of the sender, is strictly prohibited. If you are not the intended recipient, please contact the sender by reply email or telephone, delete this message, and destroy all copies of the message immediately. Thank you in advance for your cooperation. To ensure compliance with Internal Revenue Service Circular 230, we inform you that any u.s. Federal Tax advice contained in this communication is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any tax-related matter(s) addressed herein.
On Friday, March 20, 2026 at 03:04:32 PM PDT, Ciampa, John <[email protected]> wrote:
Rachel,
I wanted to give you an update that the CEQA report is being completed and everything is on track for the April 21s' City Council hearing. The public hearing notice will be drafted next week and sent over to the Clerk for distribution and publication.
To complete the CEQA work by the consultant (MBI) there are additional outstanding funds that are needed to cover their work and the anticipated work by staff and the City attorney for the appeal hearing with the City Council. Below is the summary breakdown of the remaining funds that are needed. Please provide these funds by this coming Wednesday (3/25) at noon to stay on schedule for the April 21sf City Council hearing date as these funds are required to complete all of the documents for the City Council Appeal.
CEQA contract for 15183 Analysis Remaining (S42,635 was received previously for the In-Fill Exemption analysis and the 15183 budget was 104,344): S61,709
Staff time drafting the notice and hearing documents: S7,000 City Attorney Review: §7,000
Outstanding negative deposit account balance: S6,984.88 I have provided the account information regarding deposits and expenses for your review. Please coordinate with Andy Flores, copied on this email, for processing the payment.
John
5 John Ciampa l City of San Clemente
Contract Planner I Planning Division
910 Calle Negocio, San Clemente, CA 92673
http://www.san-clemente.orq