Att. 4 - Hanson Hotel Project CEQA Section 15183 Exemption Report — San Clemente City Council, April 21, 2026 (part 1 of 4)

CEQA Section 15183 Exemption Report
Hanson Hotel Project
Lead Agency:

CITY OF SAN CLEMENTE
910 Calle Negocio
San Clemente, CA 92673
Contact: Adam Atamian
949.361.6196
Prepared By:

MICHAEL BAKER INTERNATIONAL
5 Hutton Centre Drive, Suite 500
Santa Ana, CA 92707
Contact: Kristen Bogue
949.472.3505
March 2026
JN 208581
Attachment 4
This document is designed for double-sided printing to conserve natural resources.

CEQA Section 15183 Exemption Report | City of San Clemente Hanson Hotel Project
Project Summary
Name: Hanson Hotel Project
Location: The project site is located at 1801 North El Camino Real (Assessor’s Parcel Number [APN] 057-191-60) to the northwest of the intersection of North El Camino Real and East Avenida Pico, in San Clemente, California City/County: City of San Clemente / Orange County
Applicant: Jorden Segraves (Applicant Representative), Jorden Segraves Architect, Inc.; 32402 Crown Valley Parkway #102, Dana Point, CA 92629; (949) 338-2603; [email protected]
Project: The development of a three-story, 61-room boutique hotel featuring a pool, café, roof-top restaurant (3,380 sq. ft.), pool with a bar and food service, indoor cafe and hotel lobby (1,357 sq. ft.), walk up cafe (290 sq. ft.) with full range alcohol service and amplified music for the pool and roof top restaurant, outdoor dining for all restaurant and cafe areas, and a two level subterranean parking garage with 104 parking stalls.

Conclusions: The environmental analysis provided in the attached CEQA Guidelines Section 15183 Initial Study indicates that the proposed project is consistent with the development density established by the General Plan for which an EIR (i.e., the General Plan EIR) was certified. Impacts related to the proposed project were analyzed in the General Plan EIR. The project would not result in any impacts that are peculiar to the project or project site upon implementation of General Plan EIR Mitigation Measures and/or uniform policies or standards. No new project specific impacts were determined to be potentially significant that were not already identified as a significant impact under the General Plan EIR. The project would not result in any increased severity of previously identified significant impacts due to substantial new information that was not known at the time of the General Plan EIR. No potentially significant off-site impacts or cumulatively considerable project-specific impacts were identified that were not already disclosed in the General Plan EIR.

Therefore, pursuant to Public Resources Code Section 21083.3 and CEQA Guidelines Section 15183, no further environmental review is required.

Signature
City of San Clemente, Community
Development Department
Date

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 i Section 15183 Exemption Report

TABLE OF CONTENTS
I. Introduction ................................................................................................................1-1 II. Location and Existing Conditions..............................................................................2-1 III. Project Description .....................................................................................................3-1 IV. Section 15183 Exemption Criteria Analysis.................................................................4-1 V. List of Applicable General Plan EIR Mitigation Measures and Conditions of Approval ...............................................................................................5-1 VI. Conclusion ..................................................................................................................6-1 Appendices
Appendix A CEQA Guidelines Section 15183 Initial Study
Appendix B Air Quality/GHG/Energy Data
Appendix C Biological Resources Report
Appendix D Cultural and Paleontological Resources Memo
Appendix E Geotechnical Investigation
Appendix F Water Quality Management Plan
Appendix G Noise
Appendix H.1 Focused Transportation Study
Appendix H.2 VMT Screening Assessment
List of Exhibits
Exhibit 1 Regional Vicinity ...................................................................................................................... 2-2 Exhibit 2 Site Vicinity............................................................................................................................... 2-3 Exhibit 3 Conceptual Site Plan................................................................................................................ 3-2 Exhibit 4a Proposed Elevation - East...................................................................................................... 3-4 Exhibit 4b Proposed Elevation - South ................................................................................................... 3-5 Exhibit 5 Conceptual Landscape Plan ................................................................................................... 3-6 March 2026 1-1 Introduction

1.0 INTRODUCTION

PURPOSE AND SCOPE
The City of San Clemente, in its capacity as Lead Agency, is considering a proposal to develop a threestory, 61-room boutique hotel featuring a pool, café, roof-top restaurant with amplified music, and a subterranean parking garage. The approximately 32,030-square foot site is located at 1801 North El Camino Real in the City of San Clemente (City), County of Orange (County), California.

For this project, the City of San Clemente has reviewed the proposed project and has determined that it is exempt and qualifies for a Section 15183 Streamline Exemption (refer to [California Environmental Quality Act] CEQA Guidelines Section 15183). The findings of the analysis represent the independent judgment of the City of San Clemente, in its capacity as Lead Agency for the project.

Questions and/or comments should be submitted to the following contact person:

Adam Atamian, Community Development Director
City of San Clemente Community Development
910 Calle Negocio
San Clemente, CA 92673
This environmental document and all comments received shall be a part of the Environmental Record and review of the project. The following annotated outline summarizes the format and content of this Exemption Report:
• Section 1 - Introduction, provides the procedural context surrounding this Exemption's preparation and insight into its composition.
• Section 2 - Location and Existing Conditions, provides a description of the project location and an overview of the affected area.
• Section 3 – Project Description, provides a description of the proposed project. • Section 4 – Section 15183 Exemption Criteria Analysis, identifies the applicable exemption along with supporting justification for using this exemption. • Section 5 – List of Applicable General Plan EIR Mitigation Measures and Conditions of Approval (COAs), identifies the applicable General Plan EIR mitigation measures and project-specific measures that are required to be implemented in order to apply uniform standards and/or policies.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 1-2 Introduction
• Section 6 – Determination, explains the City’s findings relevant to CEQA Guidelines Section 15183.

CEQA EXEMPTION
Pursuant to the California Environmental Quality Act (CEQA) Guidelines, a Section 15183 Streamline Exemption may be prepared if the City of San Clemente, in its capacity as the Lead Agency, determines that a proposed action or project is exempt from CEQA. According to the CEQA Guidelines, an exemption must contain the following information:
• A brief description of the project;
• The location of the project (either by street address and cross street for a project in an urbanized area or by attaching a specific map);
• A finding that the project is exempt from CEQA, including a citation to the State Guidelines section or statute under which it is found to be exempt; • A brief statement of reasons to support the finding; and • The applicants name.

This Exemption Report provides a description of the proposed project, indicates the applicable sections of CEQA that support the findings for the CEQA exemption, and discusses the Lead Agency’s findings that are applicable to the proposed project. This exemption finding represents the independent judgment and position of the City of San Clemente, acting as the Lead Agency. A CEQA Guidelines Section 15183 Initial Study is provided in Appendix A, Initial Study, which includes an environmental analysis of each CEQA topic area to support the conclusion that the proposed project meets the criteria for a CEQA Guidelines Section 15183 exemption.

APPLICABLE CEQA EXEMPTION
The preparers of this document (Michael Baker International [Michael Baker], retained by the City of San Clemente) determined that a Notice of Exemption is appropriate based on the findings contained herein. Michael Baker determined that the proposed project is exempt and qualifies for a CEQA Guidelines Section 15183 exemption.

Public Resources Code Section 21083.3(b) limits the environmental review of a development project that “is consistent with the general plan of a local agency” when “an environmental impact report was certified with respect to that general plan” to effects on the environment “which are peculiar to the parcel or to the project and which were not addressed as significant effects in the prior environmental impact report, or which substantial new information shows will be more significant than described in the prior environmental impact report.” Article 12 (Special Situations) of the CEQA Guidelines identifies situations for which certain CEQA-compliance procedures may apply. Specifically, Section 15183 of the CEQA Guidelines implements Public Resources Code Section 21083.3 and applies to

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 1-3 Introduction
projects that are consistent with existing zoning, community plan, or general plan policies for which an EIR was previously certified. CEQA mandates that such projects shall not require additional environmental review, except as might be necessary to examine whether there are project-specific significant effects which are peculiar to the project or its site. Section 15183 is intended to streamline the review of such projects and reduce the need to prepare repetitive environmental studies. For projects that meet the requirements of Section 15183, the Lead Agency is required to limit its examination of environmental effects to those effects which the Lead Agency determines, in an initial study or other analysis:
1) Are peculiar to the project or the parcel on which the project would be located; 2) Were not analyzed as significant effects in a prior EIR on the zoning action, general plan, or community plan with which the project is consistent;
3) Are potentially significant off-site impacts and cumulative impacts which were not discussed in the prior EIR prepared for the general plan, community plan or zoning action; or 4) Are previously identified significant effects which, as a result of substantial new information which was not known at the time the EIR was certified, are determined to have a more severe adverse impact than discussed in the prior EIR.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 1-4 Introduction
This page intentionally left blank.

March 2026 2-1 Location and Existing Condition

2.0 LOCATION AND EXISTING CONDITIONS

PROJECT LOCATION
Regionally, the project site is located in the western portion of the City of San Clemente (City) in southern Orange County (County); refer to Exhibit 1, Regional Vicinity. The City is bordered by the City of Dana Point to the northwest, the City of San Juan Capistrano to the north, the City of Rancho Mission Viejo to the northeast, Cleveland National Forest to the east, the vast Camp Pendleton military base to the south, and the Pacific Ocean to the west. Regional access to the general area is provided via Interstate 5 (I-5) and El Camino Real/Pacific Coast Highway. Locally, the project site is located at 1801 North El Camino Real (Assessor’s Parcel Number [APN] 057-191-60) to the northwest of the intersection of North El Camino Real and East Avenida Pico; refer to Exhibit 2, Site Vicinity. Local access to the site is provided via North El Camino Real and East Avenida Pico. The project site is bound by an existing channel to the north, an existing retail building to the west, East Avenida Pico to the east, and North El Camino Real to the south.

Environmental Setting
As shown on Exhibit 2, the project site currently consists of an approximately 32,030-square-foot (0.8-acre) vacant and unimproved property within a commercial area of the City. Existing on-site terrain slopes generally down gradient from southeast to northwest. The vacant site is currently overgrown with various types of shrubs, including coastal sage scrub typical of the area. Pole-mounted overhead utilities are located on-site. Bicycle facilities and sidewalks occur along East Avenida Pico and North El Camino Real. Bus stops serving OCTA, Metrolink, and San Clemente Trolley bus lines are provided along East Avenida Pico and North El Camino Real. The San Clemente Metrolink Station is located approximately 200 feet further south and southwest.

Surrounding Land Uses
Surrounding land uses adjacent to the project site include open space/recreational, commercial/retail, and transportation uses. Specifically:
• North: Segunda Deshecha Cañada Channel and a pedestrian trail are located to the north of the site; Pico Park and open space are located further north; • East: A car wash (Russell Fischer Car Wash) is located to the east; commercial/retail and restaurant uses are located further east;

P A C I F I C O C E A N
USMC
Camp Pendleton
101
405
405
605
105
210
210
710
110
215
215
5 5
5 15
15 15
10 10
10 73
55 57
91 91
90 60
71 83
66 91
60 38
18 18
22 39
1 2
14 18
18 138
138 173
74 74
1 133
261
241
330
241
5 SAN BERNARDINO
COUNTY

RIVERSIDE
COUNTY

SAN DIEGO
COUNTY

LOS ANGELES
COUNTY
ORANGE
COUNTY
Victorville
Hesperia
Apple Valley
Lake
Arrowhead
Running
Springs
Riverside
Fontana
Ontario Pomona
Rancho
Cucamonga
Chino
Rialto
Corona
Norco
Lake
Elsinore
Hem
Beaumo
Redlands
Temecula
Fallbrook
Oceanside
Murrieta
Pasadena
West
Covina
Whittier
Burbank
Glendora
Los
Angeles
Torrance
Long
Beach
Newport
Beach
Huntington
Beach
San
Clemente
Dana
Point
Laguna
Beach San Juan
Capistrano
Santa
Ana
Garden
Grove
Fullerton
Yorba
Linda
Irvine
Moreno
Valley
Sun
City
Costa
Mesa
San
Fernando
Perris
San
Bernardino
Project Site

HANSON HOTEL PROJECT
CEQA GUIDELINES SECTION 15183 EXEMPTION REPORT
Exhibit 1
Regional Vicinity NOT TO SCALE
02/2026 • JN 210935

HANSON HOTEL PROJECT
CEQA GUIDELINES SECTION 15183 EXEMPTION REPORT
Exhibit 2
Site Vicinity
Source: Google Earth Pro, December 2025

NOT TO SCALE
02/2026 • JN 210935

N EL CAMINO REAL
E
AV
E
NIDA
PICO
E
AV
E
NIDA
PICO

PROJECT SITE

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 2-4 Location and Existing Condition
• South: Commercial development (Beach Hut Deli, an unoccupied restaurant space, and 7- Eleven Convenience Store) are located to the south, with the San Clemente Metrolink Station located further south; and
• West: Commercial development (Catalyst Surf Shop and associated surface parking lot) bounds the project site to the west.

Existing Land Use Designation and Zoning
According to the City’s online mapping tool City of San Clemente Community Map, the project site is designated as Downtown Mixed-Use 1 (MU1) by the City’ Centennial General Plan (General Plan) Land Use Map. 1 According to the General Plan, MU1 is intended to create a vertical or horizontal mix of Neighborhood Serving Commercial (NC) and Community Serving Commercial (CC) uses, with multifamily housing on the second floor or higher. This land use designation allows for 24.0 units per gross acre or 36.0 units per net acre for residential development, a 1.00 floor-area-ratio (FAR) for commercial development, and a 2.00 FAR for mixed use projects.2 Mixed use projects on lots 12,000 square feet or larger are allowed a maximum of three stories with a maximum building height of 45 feet measured from top-of-roof (TOR) and 37 feet from plate line (PL).3 The site is zoned Mixed-Use 1 within the Central Business (CB) District within the Architectural (A) and Coastal Zone (CZ) overlays (MU1-A-CB-CZ).4 It is also within the North Beach Parking (NBP) Overlay which has standards for commercial development. According to the City’s Municipal Code, the North Beach area includes the MU-1 zone to provide for a mix of uses and development standards similar to those within the Downtown transition area, while excluding stand-alone residential development. The Central Business (CB) Overlay is also known as Pedestrian (P) Overlay in the General Plan and as the Visitor Serving Commercial District (VSCD) Overlay in the Coastal Land Use Plan. The purpose of the CB Overlay designation is to signify core commercial and mixed-use districts in which the City requires pedestrian uses to be located in pedestrian spaces (on the street level of the project along the sidewalk/street), thereby facilitating visitor-serving uses and pedestrian activity along sidewalks and throughout the area. This overlay was created in order to protect existing coastal visitorserving commercial, recreational, dining, and lodging uses and provide new areas for such uses. The purpose and intent of the Architectural (A) Overlay designation is to signify a visually distinct district in San Clemente, containing structures characterized by two significant design orientations: 1) the 1 City of San Clemente, Centennial General Plan, General Plan Land Use Map, amended October 18, 2022. 2 City of San Clemente, Centennial General Plan, Table LU-1, General Plan Land Use Designations Summary Table, adopted February 2014, amended October 2022. 3 Based on the Municipal Code Section 17.24.110D2(b), “Plate Line” is defined as the top of the highest horizontal framing member or solid wall of a building or structure or part thereof, upon which roof beams or ceiling rafters rest. Features excluded from measurement under this definition shall include gable ends, sloping roofs, parapet walls and other vertical extensions which are normally controlled by limits on roof height. 4 Ibid.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 2-5 Location and Existing Condition
City's traditional architectural style, Spanish Colonial Revival, and 2) a pedestrian orientation. The purpose of the Coastal Zone (CZ) Overlay is to provide standards which preserve and protect the coastal resources within San Clemente, and implement the coastal policies in the City's Coastal Land Use Plan Element and the California Coastal Act (Division 20 of the Public Resources Code).

The project site is also situated within the General Plan North Beach/North El Camino Real Focus Area and identified as a key coastal gateway. According to the General Plan, the North Beach/North El Camino Real Focus Area is a unique, community- and coastal visitor-oriented entertainment hub and recreation area. It is an important City gateway along the historic El Camino Real/Pacific Coast Highway from beach cities to the north. The area’s ongoing revitalization is based on the community’s desire to preserve and enhance its key assets. These assets include views of the ocean, convenient beach access, a rich inventory of historic buildings, access to passive and active recreational amenities, and access to numerous visitor-serving shops and services. With access to the Metrolink rail station, the Beach Trail, numerous bikeways and pedestrian paths, and the historic El Camino Real corridor that connects many of the City’s activity areas, the North Beach/North El Camino Real Focus Area is a key multimodal transportation hub. The purpose of the North Beach Parking Overlay designation is to improve parking availability and efficiency in the North Beach area by creating parking standards for the commercially zoned parcels which are responsive to this unique area, and to protect the residents by not impacting parking in the residential area.

The project site is located in the North Beach Gateway and lies within the Avenida Pico Scenic View Corridor as established in the City’s General Plan and Coastal Land Use Plan (Coastal LUP). The General Plan prioritizes visual resources as enjoyed from public rights-of-way in this area.

Background and History
The project site has a documented history of development proposals. In 1988, the City approved a 76-room hotel on the property. In 1998, a significantly larger five-story, 93,430-squarefoot mixed-use development including 27 timeshare units and 10,000 square feet of retail space was approved by the City and the California Coastal Commission. That project received certification of a Mitigated Negative Declaration (State Clearinghouse No. 91041041). The entitlement subsequently expired, and although additional proposals were explored in later years, no other applications advanced to the City’s Planning Commission for entitlement until the current application. Since the first two projects were approved but not constructed, the City updated and approved the Centennial General Plan (General Plan) and prepared and certified, in conjunction, a certified a Program Environmental Impact Report (Final Environmental Impact Report for Centennial General Plan; State Clearinghouse [SCH] No. 2013041021). The General Plan included consideration of buildout of the project site as a mixed-use development with architectural and pedestrian considerations, as proposed under the current land use designation. The General Plan was most recently amended in January 2026.

Since the Centennial General Plan was adopted, the applicant has submitted a new application for development at the project site. This application was initially reviewed by the Design Review Subcommittee (DRSC) in 2022. That iteration included 49 hotel rooms, a 3,201-square foot restaurant, and an 888-square foot café. In response to feedback from City staff, DRSC members, and the

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 2-6 Location and Existing Condition
California Coastal Commission (CCC), the applicant revised the project substantially. Staff and the project Applicant coordinated with CCC staff on multiple occasions including an on-site visit in 2024, where CCC staff emphasized the importance of preserving blue water ocean views from the Avenida Pico Scenic Corridor and incorporating affordable overnight accommodations into the hotel proposal.

As such, the project, as currently proposed, has incorporated feedback received and would implement several key design refinements, including:
• Expanded hotel program: The hotel was increased from 49 to 61 rooms, with 25 percent (16 rooms) designated as affordable overnight accommodations consistent with CCC recommendations;
• Improved massing and scale: The building was reconfigured to reduce mass along East Avenida Pico with a stepped-back design from one to three stories to minimize second and third story encroachments into the viewshed and reflect a traditional coastal village character; • Enhanced public amenities: A rooftop restaurant and terrace (pool deck level) were added with public access and sunset/ocean views, along with at grade pedestrian areas featuring integrated community art and sculpture gardens;
• Strengthened view preservation: Visual transparency was improved across the site from East Avenida Pico and public sidewalks, maintaining alignment with view corridor protections outlined in the Coastal LUP; and
• Operational and design refinements: A dedicated loading and trash service area was created along North El Camino Real, and additional architectural and landscape modifications were made to enhance contextual compatibility and overall aesthetic quality.

March 2026 3-1 Project Description

3.0 PROJECT DESCRIPTION
The project proposes development of the Hanson Hotel, a three-story, 61-room boutique hotel featuring a pool, café, roof-top restaurant with amplified music, and a subterranean parking garage with 104 parking stalls; refer to Exhibit 3, Conceptual Site Plan. The project includes 25 percent affordable hotel rooms (16 rooms) to enhance low-cost, visitor-serving opportunities and is designed in the Spanish Colonial Revival style to align with the Architectural Overlay and the North Beach Historic District's character.

HOTEL DEVELOPMENT
The proposed Hanson Hotel includes 61 rooms, a 3,380-square-foot rooftop restaurant and bar, a 1,357 square-foot indoor café, a 290 square-foot walkup café, a hotel guest-only pool and restaurant, and a 47,275 square-foot two-level subterranean parking garage with 104 parking spaces; refer to Exhibit 3. The rooftop restaurant would offer full-service alcohol and ambient amplified music. Public amenities include access to a scenic terrace at the entry stairs, walkup and seated café services, and landscaping, while the pool and poolside bar remain exclusively available to hotel guests. Overall, the total building area (including hotel space, amenities, and garage space) would be approximately 77,308 square feet. The proposed FAR would be 0.937.

Full Alcohol Service and Amplified Music
The project would offer full range alcohol service for the rooftop restaurant (indoor and outdoor) and pool/restaurant areas. Alcohol service is proposed seven days a week from 7:00 a.m. to 10:00 p.m. for outdoor service and 7:00 a.m. to 12:00 a.m. (midnight) for the indoor portion of the rooftop restaurant.

To contribute to the ambiance of the restaurant facilities, the project also proposes background amplified music (no live entertainment) for the pool/restaurant and rooftop restaurant areas. To ensure compatibility with surrounding uses, operational safeguards are included in the project’s conditions of approval (COAs). COA 7.8 requires the applicant to limit outdoor amplified music from 8:00 am to 10:00 pm for the property and all uses. Amplified music is authorized to be played indoors from 8:00 am to 12:00 am (midnight); however, from 10:00 pm to 8:00 am all exterior windows and doors shall remain closed. Speakers would be directional (allowing tilting and aiming of sound) and mechanical screening is proposed.

HANSON HOTEL PROJECT
CEQA GUIDELINES SECTION 15183 EXEMPTION REPORT
Exhibit 3
Conceptual Site Plan
Source: Jorden Segraves Arch. Inc. 2025

NOT TO SCALE
02/2026 • JN 210935

TRUE NORTH PLAN NORTH

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 3-3 Project Description
Outdoor Restaurant Seating
The project includes outdoor dining at the rooftop restaurant, ground-level café, and walkup café.

Seating is strategically placed to avoid obstructing view corridors and public accessways, particularly along East Avenida Pico. The low-profile furnishings, landscape buffers, and lighting are compatible with the neighborhood. This amenity aligns with the City’s goals for creating inviting public spaces to the North Beach area.

ARCHITECTURAL TREATMENTS
The project’s design reflects traditional Spanish Colonial Revival architecture and integrates publicly accessible features such as native landscaped gardens, pedestrian areas, and ocean-view terraces.

The Hanson Hotel is located within the Architectural Overlay District (A-Overlay), which mandates Spanish Colonial Revival architecture. Drawing inspiration from Ole Hanson’s vision for North Beach as a hub of recreation and entertainment, the project Applicant designed the project to be visually compatible with the North Beach Historic District and adjacent historic resources. Specifically, the architecture incorporates tiered massing, with one- and two-story elements stepping down toward East Avenida Pico and recessed upper levels along North El Camino Real. A prominent turret element at the corner of North El Camino Real and East Avenida Pico anchors the site to create a distinctive visual gateway element into the North Beach area and pays tribute to a similar feature at the Ole Hanson Beach Club. The proposed hotel would have a maximum (average) building height of 45 feet and maximum PL height of 37 feet; refer to Exhibit 4a, Proposed Elevation - East, and Exhibit 4b, Proposed Elevation - South.

LANDSCAPING
The proposed landscape plan features a diverse palette of California native and drought-tolerant plant species, strategically arranged in a series of terraced gardens along East Avenida Pico and North El Camino Real; refer to Exhibit 5, Conceptual Landscape Plan. Specific areas of focus include native planting beds at the site’s corner gateway, a cultural sculpture area, and decorative plantings framing the publicly accessible walkways and terraces.

HANSON HOTEL PROJECT
CEQA GUIDELINES SECTION 15183 EXEMPTION REPORT
Exhibit 4a
Proposed Elevation - East
Source: Jorden Segraves Arch. Inc. 2025

NOT TO SCALE
02/2026 • JN 210935

HANSON HOTEL PROJECT
CEQA GUIDELINES SECTION 15183 EXEMPTION REPORT
Exhibit 4b
Proposed Elevation - South
Source: Jorden Segraves Arch. Inc. 2025
02/2026 • JN 210935

NOT TO SCALE

TRUE NORTH PLAN NORTH

HANSON HOTEL PROJECT
CEQA GUIDELINES SECTION 15183 EXEMPTION REPORT
Exhibit 5
Conceptual Landscape Plan
Source: Jorden Segraves Arch. Inc. 2025
02/2026 • JN 210935

NOT TO SCALE

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 3-7 Project Description
Additionally, 19 street trees (including date palms [Phoenix Dactalifera], New Zealand Christmas tree Pohutukawa [Metrosideros Excelsa], and Blood Orange Sanguinello [Citrus x sinensis]) would be planted along North El Camino Real and Avenido Pico within public right-of-way (off-site) as a part of the project.

Approximately 7,291 square feet, or 20 percent of the lot area, is proposed as urban open area (UOA); approximately 3,637 square feet, or 25 percent of the UOA, is proposed as landscaped area. Landscape and landscape irrigation would be designed consistent with the Department of Water Resources (DWR) administered California State Model Water Efficiency Landscape Ordinance (MWELO) guidelines. Specifically, water-conserving and native plants and high-efficiency irrigation would be utilized in the majority of the proposed landscape areas.

ACCESS AND CIRCULATION
Vehicular Access
Vehicular access to the proposed two-level subterranean garage would be provided via a full access driveway from El Camino Real.

Emergency Access
Along project frontage at El Camino Real, a proposed 10 feet by 50 feet turnout area would allow for emergency vehicle access. Existing and proposed fire access hose pull infrastructure is located along project perimeters. Additionally, fire access ladders are proposed on the roof for emergency access.

Pedestrian Access
Sidewalks along the project frontages of East Avenida Pico and North El Camino Real would be constructed . Pedestrian access is proposed in the southeastern and southwestern portions of the site along East Avenida Pico and North El Camino Real, respectively. Additionally, pedestrian pathways are proposed throughout the site to provide connectivity between hotel buildings and amenities, as well as provide connectivity to existing surrounding pedestrian facilities. The proposed public café would be fronting North El Camino Real and fully publicly accessible by pedestrians. An elevator is proposed in the northwest corner of the site.

Parking
The proposed development includes a two-level subterranean parking garage with a total of 104 parking spaces provided for employees, hotel guests, and food and beverage uses. 43 spaces would be provided on level 1 of the subterranean parking garage, and 61 spaces would be provided on level 2.

In addition, the project includes an at-grade loading and service space protected by the public sidewalk

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 3-8 Project Description
and median along North El Camino Real to accommodate large delivery and waste collection vehicles that are too large to access the subterranean garage.

Parking areas would feature Americans with Disabilities Act (ADA) compliant parking spaces, vanpool accessible spaces, and electric vehicle (EV) charging spaces, in accordance with the City and California Green Building Code Standards (CALGreen) requirements. Bicycle parking spaces are also proposed in the northeastern corner of the site. The number of parking spaces proposed exceeds the municipal code requirement of one space per hotel room, one employee space per ten hotel rooms, two spaces per manager’s unit, and the North Beach Parking Overlay standard of one space per five restaurant seats.

LIGHTING
Exterior lighting is proposed on-site at building entrances, parking areas, amenity spaces, and pedestrian walkways for security and wayfinding purposes. Lighting would also be used to illuminate architectural elements, signage, and landscape features for ambience. All lighting would comply with current energy standards, utilizing light emitting diode (LED) or efficient fluorescent lighting technology. Project lighting would be shielded to avoid glare that could affect the marine environment or the coastal canyons to the west and directed away from adjoining commercial properties in accordance with City standards. Specifically, site lighting would be designed to Dark Sky requirements in regard to the shielding of light, limiting light trespass, utilizing energy-efficient lighting, and adhering to color temperature limits. Site photometric and lighting specifications would be submitted for review as part of City’s Building Department review. The lighting plan for the proposed hotel would be consistent with industry best practice as outlined in California Title 24 and CALGreen, as well as the International Dark Sky Association (IDA) guidelines and requirements to reduce light pollution and protect night sky and night habitat.

UTILITIES
Municipal and private utility services necessary to serve the project are currently available within or adjacent to the project site. The site has utility services adjacent to the site from San Diego Gas & Electric (gas and electricity), the Municipal Water District of Orange County (water), the City of San Clemente (sewer) and CR&R (solid waste services). On-site utility infrastructure necessary to serve the project, including water, sanitary sewer, drainage, storm water runoff treatment facilities, and dry utilities, would be installed with the proposed development and would connect to the existing utilities under public streets. The site would also have available safety and emergency response resources available from the County’s police and fire departments.

PHASING AND CONSTRUCTION
The project would be constructed as a single phase with an 18-month construction period. Anticipated construction activities include grading, paving, building construction, and architectural coating. It is

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 3-9 Project Description
anticipated that approximately 14,300 cubic yards (CY) of cut would be exported o to an authorized disposal site outside the coastal zone over approximately 30 hauling days. The project is anticipated to use a hydraulic hammer pile driver for piles installation and vibratory roller for compaction of site grading and paving. Project construction would incorporate dust control measures such as regular water spraying twice per day and paved haul roads. All work would be required to comply with local noise and environmental regulations.

PERMITS AND APPROVALS
The proposed project would require permits and approvals from the City of San Clemente and other agencies prior to construction. These permits and approvals are described below.

City of San Clemente
• CEQA Clearance;
• Development Permit;
• Conditional Use Permit (CUP), for the hotel use, full-range alcohol service, and amplified music; and
• Design Review.

California Coastal Commission
• If approved by the City, the project requires a Coastal Development Permit from the California Coastal Commission.

California Department of Fish and Wildlife
• Incidental Take Permit.

San Diego Regional Water Quality Control Board
• Dewatering Permit.

South Coast Air Quality Management District
• Compliance with regulations for air quality management, including but not limited to Rules 402, 403, and 1113.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 3-10 Project Description
This page intentionally left blank.

March 2026 4-1 Section 15183 Exemption Criteria Analysis

4.0 SECTION 15183 EXEMPTION CRITERIA ANALYSIS
As discussed in Section I, Introduction, this section evaluates the project’s consistency with the requirements for an exemption pursuant to CEQA Guidelines Sections 15183.

Pursuant to CEQA Guidelines Section 15183 (a), “CEQA mandates that projects which are consistent with the development density established by existing zoning, community plan, or general plan policies for which an EIR was certified shall not require additional environmental review, except as might be necessary to examine whether there are project-specific significant effects which are peculiar to the project or its site. This streamlines the review of such projects and reduces the need to prepare repetitive environmental studies.”

CERTIFIED EIR
City Of San Clemente Centennial General Plan
The San Clemente City Council adopted a comprehensive update to the City’s General Plan titled Centennial General Plan (General Plan) and certified a Program Environmental Impact Report (Final Environmental Impact Report for Centennial General Plan; State Clearinghouse [SCH] No. 2013041021) (General Plan EIR) on February 4, 2014. The General Plan provides comprehensive, long-term goals and policies for achieving the City’s vision. It guides growth and development to achieve optimum results from the City's physical, economic, environmental, and human resources. Per State law, general plans are required to include seven elements (Land Use, Housing, Circulation, Noise, Safety, Open Space and Conservation). The organization of these seven elements, and any optional elements, are determined by the local jurisdiction. The General Plan is made up of thirteen elements: Land Use; Urban Design; Historic Preservation; Economic Development; Mobility and Complete Streets; Housing, Beaches, Parks and Recreation; Natural Resources; Coastal; Safety; Public Services, Facilities and Utilities; Growth Management; and Governance. In September 2021, the Safety Element was updated concurrently with the 6th Cycle Housing Element Update (adopted September 20, 2022, and certified by the Department of Housing and Community Development [HCD] on October 12, 2022).

The General Plan EIR was prepared as a Program EIR in conformance with the California Environmental Quality Act (CEQA; California Public Resources Code, Sections 21000, et seq.) and the CEQA Guidelines (California Code of Regulations, Title 14, Sections 15000, et seq.). According to Section 15168 of the CEQA Guidelines, a Program EIR may be prepared on a series of actions that can be characterized as one large project. Use of a Program EIR gives the Lead Agency an opportunity to consider broad policy alternatives and program-wide mitigation measures, as well as greater flexibility to address project-specific and cumulative environmental impacts on a comprehensive scale.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 4-2 Section 15183 Exemption Criteria Analysis General Plan Consistency
The proposed project would be consistent with applicable General Plan designation, as supported by Appendix A, Initial Study, Section 3.11, Land Use and Planning.

General Plan Buildout Assumptions for the Project Site
Under the General Plan, the project site is designated Downtown Mixed-Use 1 (MU1), which is intended to create a vertical or horizontal mix of Neighborhood Serving Commercial and Community Serving Commercial uses, with multi-family housing on the second floor or higher. The MU1 land use designation allows for 24.0 units per gross acre or 36.0 units per net acre for residential development, a 1.00 floor-area-ratio (FAR) for commercial development, and a 2.00 FAR for mixed-use projects.

The proposed hotel building area (hotel and restaurant building area) is approximately 30,034 square feet and would be constructed on an approximately 32,030-square foot site. Thus, the proposed mixed-use project would have a 0.94 FAR and meet the FAR requirement for commercial development under the MU1 designation.

The General Plan also identifies the site within one of eight Focus Areas considered to have the most potential for change. The site is located in the North Beach/North El Camino Real Focus Area. This Focus Area is a unique, community- and coastal visitor-oriented entertainment hub and recreation area. It is an important City gateway along the historic El Camino Real/Pacific Coast Highway from beach cities to the north. The North Beach/North El Camino Real Focus Area’s on-going revitalization is based on the community’s desire to preserve and enhance its key assets. The Focus Area’s assets include views of the ocean, convenient beach access, a rich inventory of historic buildings, access to passive and active recreational amenities, and numerous visitor-serving shops and services. With access to the Metrolink rail station, the Beach Trail, numerous bikeways and pedestrian paths, and the historic El Camino Real corridor that connects many of the City’s activity areas, the North Beach/North El Camino Real Focus Area is a key multimodal transportation hub.

The proposed hotel provides the following features that make the project compatible with the General Plan, North Beach/North El Camino Real Focus Area, and general intended vision for development of the site:
• Public Access: Rooftop restaurant, terraces, and garden (along Avenida Pico) would be open to the public and provide ocean views.
• Affordable Accommodations: Of the 61 hotel rooms, 25 percent (16 rooms) are proposed to be affordable per California Coastal Commission affordability requirements. • Transit-Oriented Location: The site is located within 350 feet from the Metrolink, bus stop, regional bike routes, hiking trails, California Coastal Trail, and a trolley stop. • Public View Corridor Protection: The building design is one story along Avenida Pico and steps up and away from the view corridor to maintain blue water views to comply with General Plan Land Use Plan Public View Corridor policies.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 4-3 Section 15183 Exemption Criteria Analysis Thus, the project would be consistent with General Plan goals and policies applicable to the site and proposed use. Refer to Section 4.11, Land Use and Planning, for a detailed analysis of the project’s consistency with the General Plan and other applicable land use plans, policies, and regulations.

General Plan EIR Findings
The General Plan EIR considered the potential environmental impacts that would result from buildout of the General Plan, which included the project site. Two environmental impact categories were identified as not being significantly affected by or affecting the proposed General Plan, based on the General Plan EIR Initial Study: Agriculture and Forestry Resources and Mineral Resources, which were not carried into the General Plan Draft EIR for further consideration.

Fifteen environmental factors were identified as potentially significant impacts of the proposed project. These factors are:
• Aesthetics/Light and Glare
• Air Quality
• Biological Resources
• Cultural Resources
• Geology/Soils
• Greenhouse Gas Emissions
• Hazards & Hazardous Materials
• Hydrology/Water Quality
• Land Use/Planning
• Noise
• Population/Housing
• Public Services
• Recreation
• Transportation/Traffic
• Utilities/Service Systems
The General Plan EIR identified four significant and unavoidable adverse impacts, as defined by CEQA, that would result from buildout of the General Plan. Unavoidable adverse impacts may be considered significant on a project-specific basis, cumulatively significant, and/or potentially significant. The Lead Agency determined that one or more unavoidable significant adverse impacts would result from the buildout of the General Plan, and prepared a “Statement of Overriding Considerations” prior to approval of the General Plan and certification of the General Plan EIR. The Statement of Overriding Considerations stated that the decision-making body has balanced the benefits of the General Plan against its unavoidable significant environmental effects and has determined that the benefits of the General Plan outweigh the adverse effects, and therefore the

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 4-4 Section 15183 Exemption Criteria Analysis adverse effects are considered to be acceptable. The impacts that were found in the General Plan EIR to be significant and unavoidable are:
• Air Quality
• Greenhouse Gas Emissions
• Noise
• Transportation/Traffic

STREAMLINED REVIEW
The streamlined review exemption pursuant to Section 15183 of the CEQA Guidelines applies only to the extent that all feasible mitigation measures for a significant effect specified in the EIR are or will be undertaken by the public agency having jurisdiction to implement such mitigation measures (CEQA Guidelines Section 15183(e)(1) and (2)). As required by CEQA, the City prepared the General Plan EIR which analyzed the environmental impacts of buildout of the General Plan. The City of San Clemente City Council certified the General Plan EIR on February 4, 2014.

Accordingly, the Section 15183 streamlined review exemption applies to the proposed project, since the project meets these criteria. The proposed project is consistent with the General Plan buildout assumptions for the project site. Also, the General Plan EIR (which considered buildout of the project site as designated MU1) was certified on February 4, 2014. All applicable mitigation measures identified in the General Plan EIR Mitigation Monitoring and Reporting Program (MMRP) to the proposed project would be implemented in addition to existing federal, State, and local laws and regulations, which are discussed in detail as part of Appendix A, Initial Study.

The analysis presented in Appendix A demonstrates that the proposed project meets the requirements of Public Resources Code Section 21083.3 and CEQA Guidelines Section 15183, and as such, no additional CEQA review beyond the findings presented below, is required for the project. Specifically:
• As explained above, the General Plan EIR was certified in conjunction with the City’s adoption of the General Plan, and the proposed project is fully consistent with General Plan, as implemented consistent with the City’s Municipal Code. (CEQA Guidelines Section 15183(d); Public Resources Code Section 21083.3(b));
• All of the applicable General Plan EIR Mitigation Measures, and/or regulatory requirements (including Conditions of Approval [COA] enforcing such regulations), relied upon to reduce environmental effects and that are applicable to the proposed project are feasible and would be implemented as part of the project (CEQA Guidelines Section 15183(e); Public Resources Code Section 21083.3(c));
• Environmental effects peculiar to the project or the parcel on which the project would be located were previously addressed as significant effects in the General Plan EIR and therefore

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 4-5 Section 15183 Exemption Criteria Analysis are exempt from further review (CEQA Guidelines Section 15183(b)(1); Public Resources Code Section 21083.3(b));
• Environmental effects of the project are not considered peculiar to the project, and therefore do not require further review, because they are substantially mitigated by previously adopted General Plan EIR Mitigation Measures and/or uniformly applied development policies and standards (CEQA Guidelines Section 15183(f); Public Resources Code Section 21083.3(d)); • There are no potentially significant off-site or cumulatively-considerable impacts of the proposed project that were not discussed by the General Plan EIR (CEQA Guidelines Sections 15183(b)(3) and 15183(j); Public Resources Code Section 21083.3(c)); and • There are no previously identified effects which, as a result of substantial new information not known at the time the EIR was certified, are more severe than discussed in the General Plan EIR. (CEQA Guidelines Section 15183(b)(4); Public Resources Code Section 21083.3(b)) Accordingly, pursuant to Public Resources Code Section 21083.3 and CEQA Guidelines Section 15183, no additional environmental review is required for the proposed project beyond the analysis and conclusions summarized in this report and supplemented by Appendix A, since the proposed project is fully consistent with the General Plan, all feasible Mitigation Measures specified in the General Plan EIR that is relevant to the project will be implemented as part of the project, and the proposed project would not result in any significant effects or more severe significant impacts to the environment beyond what was previously evaluated and disclosed as part of the General Plan EIR.

POTENTIAL ENVIRONMENTAL EFFECTS
In accordance with CEQA Guidelines Section 15183(b), “In approving a project meeting the requirements of this section, a public agency shall limit its examination of environmental effects to those which the agency determines, in an initial study or other analysis:
1) Are peculiar to the project or the parcel on which the project would be located, 2) Were not analyzed as significant effects in a prior EIR on the zoning action, general plan, or community plan, with which the project is consistent,
3) Are potentially significant off-site impacts and cumulative impacts which were not discussed in the prior EIR prepared for the general plan, community plan or zoning action, or 4) Are previously identified significant effects which, as a result of substantial new information which was not known at the time the EIR was certified, are determined to have a more severe adverse impact than discussed in the prior EIR.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 4-6 Section 15183 Exemption Criteria Analysis New Significant Impacts
The Initial Study included as Appendix A describes the potential environmental changes to the existing physical conditions that may occur if the proposed project is implemented. Evidence, based on factual and scientific data, is presented to show the cause and effect relationship between the proposed project and the potential changes in the environment. The exact magnitude, duration, extent, frequency, range, or other parameters of a potential impact are ascertained, to the extent possible, to determine whether impacts may be significant; all of the potential direct and reasonably foreseeable indirect effects are considered.

Impacts are generally classified as potentially significant impact, less than significant impact, or resulting in no impact. If impacts are determined to be potentially significant impact after implementation of General Plan EIR mitigation measures and uniformly applied policies and standards/regulations, then consideration of whether such impacts were already identified in the General Plan EIR, or if such impacts are new potentially significant impacts, are be made.

Based on Appendix A, the proposed project would not result in any new potentially significant effects that were not considered in the General Plan EIR with application of applicable General Plan EIR mitigation and/or uniform policies and standards.

Increased Significant Impacts Already Identified in the General Plan EIR The General Plan EIR found that buildout of the General Plan would result in significant and unavoidable impacts pertaining to air quality, greenhouse gas emissions, noise, and transportation/traffic. For these impacts identified as significant and unavoidable in the General Plan EIR, consideration of if the project-specific impacts are more severe than those identified in the General Plan EIR were made. Based on Appendix A, Based on Appendix A, the proposed project would not result in any increased significant effects that were not considered in the General Plan EIR upon application of applicable General Plan EIR mitigation and/or uniform policies and standards.

As discussed above, no substantial new information has been found, nor would the project specific impacts be significant. As such, the proposed project would not result in increased significant impacts compared to that described in the General Plan EIR.

Peculiar Impacts
Methodology for Consideration of Peculiar Impacts
(CEQA Guidelines Section 15183(b); Public Resources Code Section 21083.3(a)-(c).) If an impact is not peculiar to the parcel or to the project, has been addressed as a significant effect in the prior EIR, or can be substantially mitigated by the imposition of uniformly applied development policies or

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 4-7 Section 15183 Exemption Criteria Analysis standards then an additional EIR need not be prepared for the project solely on the basis of that impact. (CEQA Guidelines Section 15183(c).)
Pursuant to CEQA Guidelines Section 15183(h), an environmental effect shall not be considered peculiar to the project or parcel solely because no uniformly applied development policy or standard is applicable to it. Section 15183(e) limits the analysis of only those significant environmental effects which were previously identified in the prior EIR, and for which all applicable mitigation measures identified by the prior EIR are found to be feasible. (Public Resources Code Section 21083.3(c).) For such effects, the Lead Agency is required to make a finding at a public hearing as to whether the feasible mitigation measures will be undertaken.

Pursuant to CEQA Guidelines Section 15183(f) and Public Resources Code Section 21083.3(d), an effect of a project on the environment shall not be considered peculiar to the project or the parcel if uniformly applied development policies or standards have been previously adopted by the city or county with a finding that the development policies or standards will substantially mitigate that environmental effect when applied to future projects, unless substantial new information shows that the policies or standards will not substantially mitigate the environmental effect. The finding shall be based on substantial evidence which need not include an EIR. Such development policies or standards need not apply throughout the entire city or county but can apply only within the zoning district in which the project is located, or within the area subject to the community plan on which the lead agency is relying. Moreover, such policies or standards need not be part of the general plan or any community plan but can be found within another pertinent planning document such as a zoning ordinance. Where a city or county, in previously adopting uniformly applied development policies or standards for imposition on future projects, failed to make a finding as to whether such policies or standards would substantially mitigate the effects of future projects, the decision-making body of the city or county, prior to approving such a future project pursuant to Section 15183, may hold a public hearing for the purpose of considering whether, as applied to the project, such standards or policies would substantially mitigate the effects of the project. Such a public hearing need only be held if the city or county decides to apply the standards or policies as permitted in Section 15183.

Peculiar Impacts Findings
Based on Appendix A, there are no impacts peculiar to the project or project site, as the environmental effects were previously addressed in the General Plan EIR with application of applicable General Plan EIR mitigation and/or uniform policies and standards and, therefore, are exempt from further review.

Potentially Significant Off-Site Impacts
The proposed project would not involve any new off-site impacts that were not considered as part of the General Plan EIR.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 4-8 Section 15183 Exemption Criteria Analysis Potentially Significant Cumulative Impacts
Methodology for Consideration of Cumulative Impacts
CEQA Guidelines Section 15183(j) does not affect any requirement to analyze potentially significant cumulative impacts if those impacts were not adequately discussed in the prior EIR. If a significant cumulative impact was adequately discussed in the prior EIR, then Section 15183 may be used as a basis for excluding further analysis of that cumulative impact.

Cumulative impacts were considered for each environmental topic area analyzed as part of the General Plan EIR. As disclosed in the General Plan EIR, projected cumulative development was based on adopted general plans or related planning documents, or in a prior environmental document which has been adopted or certified, which described or evaluated regional or areawide conditions contributing to the cumulative impact. The buildout assumptions for the General Plan were projected from the General Plan, Strategic Implementation Program, Bicycle and Pedestrian Master Plan, and Climate Action Plan. Consistent with Section 15130(b)(1)(B) of the CEQA Guidelines, the General Plan EIR analyzes the environmental impacts of development in accordance with the proposed Land Use Plan. As a result, the General Plan EIR addresses the cumulative impacts of development within the City of San Clemente and the larger Orange County region surrounding it, as appropriate. In most cases, the potential for cumulative impacts is contiguous with the City boundary, since the City is the service provider for various City services and public utilities. Potential cumulative impacts related to traffic, air quality, and noise, which have the potential for impacts beyond the City boundary, have been addressed through use of a traffic model. The City utilizes a traffic model for purposes of forecasting cumulative growth within the City and regionally. Regional growth outside of the City has accounted for traffic, air quality, and noise impacts through use of this model, which is a socioeconomic traffic model that uses regional growth projections to calculate future traffic volumes.

The growth projections adopted by the City and surrounding area are used for the cumulative impact analyses of the General Plan EIR.

Project-Specific Cumulative Impact Findings
The General Plan EIR found that buildout of the General Plan would result in significant and unavoidable impacts pertaining to air quality, greenhouse gas emissions, noise, and transportation/traffic. Based on the analysis included in Appendix A, the project would not result in any increased significant environmental impacts, compared to that disclosed in the General Plan EIR.

As such, the proposed project would not result in a cumulatively considerable significant impact and the project’s cumulative considerations were already evaluated by the General Plan EIR.

March 2026 5-1 List of Applicable Conditions of Approval

5.0 LIST OF APPLICABLE GENERAL PLAN EIR MITIGATION

MEASURES AND CONDITIONS OF APPROVAL
As substantiated in Appendix A, should any potential project-specific impacts result after implementation of standard regulations, then applicable General Plan EIR mitigation measures are considered to reduce the project’s impacts. The following General Plan EIR mitigation measures were identified in the Section 15183 Initial Study (Appendix A) for the purpose of reducing project-specific impacts:

Applicable General Plan EIR Mitigation Measures:

5.3-1 The City of San Clemente shall require applicants for public and private development projects that disturb vacant land to prepare a biological resources survey. The biological resources survey shall be conducted by a qualified biologist and submitted to the City’s Planning Department. The biological resources survey shall include, but not be limited to: Analysis of available literature and biological databases, such as the California Natural Diversity Database, to determine sensitive biological resources that have been reported historically from the proposed development project vicinity; review of current land use and land ownership within the proposed development project vicinity; Assessment and mapping of vegetation communities present within the proposed development project vicinity; and general assessment of potential jurisdictional areas, including wetlands and riparian habitats. a) If the proposed development project site supports vegetation communities or mature trees that may provide habitat for special status plant or wildlife species, a focused habitat assessment shall be conducted by a qualified biologist to determine the potential for special status plant and/or animal species to occur within or adjacent to the proposed development project area.
b) If one or more special status species has the potential to occur within the proposed development project area, focused species surveys shall be conducted to determine the presence/absence of these species to adequately evaluate potential direct and/or indirect impacts to these species.
c) If construction activities are not initiated immediately after focused surveys have been completed, additional preconstruction special status species surveys may be required, in accordance with the California Endangered Species Act and Federal Endangered Species Act, to ensure impacts are avoided or minimized to the extent feasible. If preconstruction activities are required, a qualified biologist would perform these surveys as required for each special status species that is known to occur or has a potential to occur within or adjacent to the proposed development project area. d) If sensitive biological resources, including mature trees or wildlife corridors, are identified within or adjacent to the proposed development project area, as outlined in the biological resources report, the construction limits shall be clearly flagged to ensure impacts to sensitive biological resources and the wildlife corridor are avoided or minimized, to the extent feasible. Prior to implementing construction activities, the

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 4-2 Section 15183 Exemption Criteria Analysis City of San Clemente shall require applicants to contract with a qualified biologist to verify that the flagging clearly delineates the construction limits and sensitive resources to be avoided.
e) If sensitive biological resources are known to occur within or adjacent to the proposed development project area, as outlined in the biological resources report, the City of San Clemente shall require applicants to contract with a qualified biologist to develop and implement a project-specific contractor training program to educate project contractors on the sensitive biological resources within and adjacent to the proposed development project area and measures being implemented to avoid and/or minimize impacts to these species. Project Contractors shall be required to comply with the requirements of the program.
f) If sensitive biological resources are present within or adjacent to the proposed development project area and impacts may result from construction activities, as outlined in the biological resources report, the City may require that a developer retain a qualified biological monitor to be present during all or a portion of the construction activities to ensure impacts to the sensitive biological resources are avoided or minimized to the extent feasible. The specific biological monitoring requirements shall be determined on a project-by-project basis. The qualified biological monitor shall be approved by the City on a project-by-project basis based on applicable experience with the sensitive biological resources that may be impacted by the proposed development project activities.

5.3-2 The City of San Clemente shall require applicants of public and private development projects that have the potential to affect listed species to obtain written authorization from the U.S.

Fish and Wildlife Service that the grading or construction activity is in compliance with regulations on the “take” of the listed species that would directly or indirectly be impacted.

Any mitigation requirements set forth by such agencies shall be incorporated into the project’s final design plans.
4-1 City staff shall require applicants for development permits to provide studies by qualified archaeologists assessing the cultural and historical significance of any known archaeological resources on or next to each respective development site; and assessing the sensitivity of sites for buried archaeological resources. On properties where resources are identified, or that are determined to be moderately to highly sensitive for buried archaeological resources, such studies shall provide a detailed mitigation plan, including a monitoring program and recovery and/or in situ preservation plan, based on the recommendations of a qualified cultural preservation expert. The mitigation plan shall include the following requirements:
a. An archaeologist shall be retained for the project and will be on call during grading and other significant ground-disturbing activities.
b. Should any cultural/scientific resources be discovered, no further grading shall occur in the area of the discovery until the Community Development Director concurs in writing that adequate provisions are in place to protect these resources.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 4-3 Section 15183 Exemption Criteria Analysis c. Unanticipated discoveries shall be evaluated for significance by an Orange County Certified Professional Archaeologist. If significance criteria are met, then the project shall be required to perform data recovery, professional identification, radiocarbon dates as applicable, and other special studies; submit materials to the California State University Fullerton; and provide a comprehensive final report including appropriate records for the California Department of Parks and Recreation (Building, Structure, and Object Record; Archaeological Site Record; or District Record, as applicable). 4-2 City staff shall require applicants for development permits to provide studies by qualified paleontologists assessing the sensitivity of sites for buried paleontological resources. On properties determined to be moderately to highly sensitive for paleontological resources, such studies shall provide a detailed mitigation plan, including a monitoring program and recovery and/or in situ preservation plan, based on the recommendations of a qualified paleontologist.

The mitigation plan shall include the following requirements:
a. A paleontologist shall be retained for the project and will be on call during grading and other significant ground-disturbing activities.
b. Should any potentially significant fossil resources be discovered, no further grading shall occur in the area of the discovery until the Community Development Director concurs in writing that adequate provisions are in place to protect these resources.

Unanticipated discoveries shall be evaluated for significance by an Orange County Certified Professional Paleontologist. If significance criteria are met, then the project shall be required to perform data recovery, professional identification, radiocarbon dates as applicable, and other special studies; submit materials to the California State University Fullerton; and provide a comprehensive final report, including catalog with museum numbers. 10-1 Prior to the issuance of building permits for projects that involve a noise-sensitive use within the 65 dBA CNEL contour (i.e., areas in or above 65 dBA CNEL) along major roadways, freeways, and railroads, the project property owner/developers shall retain an acoustical engineer to conduct an acoustic analysis and identify, where appropriate, site design features (e.g., setbacks, berms, or sound walls), and/or required building acoustical improvements (e.g., sound transmission class rated windows, doors, and attic baffling) to ensure compliance with the City’s Noise Compatibility Criteria and the California State Building Code and California Noise Insulation Standards (Title 24 and 21 of the California Code of Regulations). 10-2 Construction activities associated with new development that occurs near sensitive receptors shall be evaluated for potential noise impacts. Mitigation measures such as installation of temporary sound barriers for construction activities that occur adjacent to occupied noisesensitive structures, equipping construction equipment with mufflers, and reducing nonessential idling of construction equipment to no more than five minutes shall be incorporated into the construction operations to reduce construction-related noise to the extent feasible.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 4-4 Section 15183 Exemption Criteria Analysis 10-4 Individual projects that use vibration-intensive construction activities, such as pile drivers, jack hammers, and vibratory rollers, near sensitive receptors shall be evaluated for potential vibration impacts. If construction-related vibration is determined to be perceptible at vibration-sensitive uses (i.e., exceed the Federal Transit Administrations vibration annoyance criterion of 78 VdB), additional requirements, such as use of less-vibration-intensive equipment or construction techniques, shall be implemented during construction (e.g., drilled piles to eliminate use of vibration-intensive pile driver).

In addition to General Plan EIR mitigation, applicable uniform policies, standards, or regulations are also considered in order to reduce impacts. Should application of uniform policies, standards, or regulations require a project to implement a project-specific measure, in order to enforce uniform policies, standards, or regulations for a project, such measures are identified as Conditions of Approval (COAs). The following COAs were identified in the Section 15183 Initial Study (Appendix A) for the purpose of reducing project-specific impacts:

Applicable Conditions of Approval (COAs):

1.9 The project shall implement the mitigation measures from City Council Resolution No. 91-94, Exhibit 2—Air Quality-1, Air Quality-3, and Lighting/Glare-1. Prior to building permit issuance, these measures shall be shown on the grading/dust control notes, erosion and stormwater plans, lighting plans, and construction specifications, as applicable. The City Planner may (i) approve equivalent or more effective measures, or (ii) issue a written determination that compliance with the current California Building Code, San Clemente Municipal Code (including the Zoning Ordinance), or other adopted regulations fully satisfies the intent of a listed measure, in which case that code compliance shall govern. The Applicant shall implement the measures during construction and operation, and the City shall verify compliance prior to final inspection/occupancy. (SCAQMD Rules 402 and 403, California Building Code, San Clemente Municipal Code)

3.2 The City Engineer shall determine that development of the site shall conform to general recommendations presented in the geotechnical studies, including specifications for site preparation, landslide treatment, treatment of cut and fill, slope stability, soils engineering, and surface and subsurface drainage, and recommendations for further study. (Municipal Code Chapter 15.36)

3.11 The Applicant shall submit, and the City Planner and Beaches, Parks and Recreation Manager shall have approved, a detailed landscape and irrigation plan incorporating drought tolerant plants, for medians, parkways, public trails, fuel modification areas, common areas, and slopes, and other landscaped areas, prepared by a registered landscape architect, and in compliance with all pertinent requirements including, but not limited to guidelines contained in the City's Master Landscape Plan of Scenic Corridors.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 4-5 Section 15183 Exemption Criteria Analysis (Municipal Code Section 17.68.020) The project shall incorporate vertical landscaping at the rear of the building (North elevation) to provide vertical screening of the structure.

Placement of the vertical landscaping and type shall be sensitive to not contribute to ocean view obstructions from the Avenida Pico Scenic Corridor.

3.13 The Applicant shall demonstrate to the satisfaction of the City Engineer that the following standards shall be satisfied:

A. All construction vehicles or equipment, fixed or mobile, operated within 1,000 feet of a dwelling shall be equipped with operating and maintained mufflers.

B. All operations shall comply with Orange County Codified Ordinance Division 6 (Noise Control).

C. Stockpiling and/or vehicle-storage areas shall be located as far as practicable and out of view from dwellings.

The City of San Clemente Noise Ordinance, limiting the hours of construction to between 7:00 a.m. and 6:00 p.m., shall be enforced.
(Municipal Code Chapter 15.36)

3.14 The Applicant shall demonstrate to the satisfaction of the City Engineer or designee that the project meets all requirements of the San Diego Regional Water Quality Control Board National Pollutant Discharge Elimination System (NPDES) Municipal Separate Strom Sewer Permit, and Federal, State, County and City guidelines and regulations, in order to control pollutant run-off. (Municipal Code Chapter 13.40)

3.19 Unless waived otherwise by the City Engineer, the developer shall acknowledge in writing that the development is subject to all State water quality and storm drain discharge permit regulations. This may include, but is not limited to, elimination of discharges such as subdrain and other non-storm related discharge. Project designs revisions may be required for compliance with such applicable regulations. (Municipal Code Chapter 15.36)

3.20 The project garage entry and exit driveway shall be designed for restricted vehicles to a right turn in and exit only. Unless approved otherwise by the City Engineer, this shall include the addition of right turn arrow markings on the pavement of the drive aisle surface. (Municipal Code Chapter 15.36) See Figure 1: Circulation and Line of Sight.

3.21 Unless approved otherwise by the City Engineer and the driveway grade is modified to meet all City Standards, in order to increase sight distance of pedestrians for vehicles exiting the garage, the project design shall remove the front landscape planter that is currently shown behind the sidewalk and immediately west of the drive aisle.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 4-6 Section 15183 Exemption Criteria Analysis Landscaping in this area should be maintained to sidewalk. (Municipal Code Chapter

15.36). See Figure 1: Circulation and Line of Sight

3.22 The development has floors below street grade (1-foot above top of full height curb), therefore a hydrology study will be need to prove the development is not subject to runon from street drainage. (Municipal Code Chapter 15.36)

4.5 Prior to the issuance of building permits for each structure or tenant improvement, other than a parking structure, the Applicant shall submit, and must obtain approval from the City Planner, a final acoustical report. The report shall demonstrate that the development will be sound attenuated against present and projected noise levels including stationary, roadway, aircraft, helicopter, and railroad noise to meet City interior and exterior noise standards. The report shall also provide verification that use of any on-site sound system will comply with the City’s noise ordinance, particularly with reference to db(c) measurements from residential properties. The report shall be accompanied by a list identifying the sheet(s) of the building plans that include required sound attenuation measures.

4.6 The Applicant shall demonstrate to the satisfaction of the Building Official that the plans include all sound attenuation measures specified in the acoustical report required by Conditions 3.13 and 4.5 as well as NOI-1.

4.10 If the project pertains to a Food Service Establishment (FSE), the Applicant shall submit, and the City Utilities Director shall approve, plans depicting the Fats, Oils, and Greases (FOG) controls, with the plans and design approved by the Orange County Health Care Agency.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 4-7 Section 15183 Exemption Criteria Analysis water system as practical, given functional and aesthetic considerations. An isolation valve shall be installed on any/all fire lines at the point of connection to the water main. (Municipal Code Section 13.04.350)

4.12 The Applicant shall submit, and the City Engineer shall approve, plans depicting the installation of an approved reduced pressure principal backflow assembly on any/all potable water systems, and any/all irrigation systems, above ground, directly after each water meter as practical, and at a minimum height of 12” from the bottom of each assembly to ground level. (Municipal Code Section 13.04.350)

Specifically, the project design shall provide a minimum three-foot setback around the perimeter of the structure, consistent with OCFA standards.

5.4 The Applicant shall submit a photometric plan within the construction documents indicating compliance with the City’s Lighting standards (17.24.130), and a letter from the preparer of the lighting plans confirming that all lighting has been installed in accordance with the approved plans, and that the lighting conforms to all standards set forth in the Municipal Code and to the satisfaction of the City Planner.

7.8 The Applicant shall limit outdoor amplified music from 8:00 am to 10:00 pm for the property and all uses. Amplified music is authorized to be played indoors from 8:00 am to 12:00 am (midnight); however, after 10:00 pm to 12:00 am all exterior windows and doors shall remain closed. Additionally, the project must comply with the City’s Noise Ordinance. (Municipal Code Sections 8.48.070 and 8.48.050) COA BIO-1 A focused habitat assessment for Crotch’s bumble bee shall be conducted by a qualified biologist to determine the potential for this species to occur within or adjacent to the proposed development project area. The habitat assessment shall conform to the requirements listed in the California Department of Fish and Wildlife’s (CDFW) 2023 “Survey Considerations for California Endangered Species Act (CESA) Candidate Bumble Bee Species” and shall be submitted to the CDFW prior to initiation of ground disturbing project activities. (Required by General Plan Mitigation Measure 5.3-1)
COA BIO-2 Because coastal California gnatcatcher has a potential to be present within the proposed development project area, focused surveys conforming to the 1997 USFWS survey protocol will be required in order to adequately evaluate potential direct and/or indirect effects to this species. Because the City of San Clemente is not a participating jurisdiction under any Natural Community Conservation Plans/Habitat Conservation Plans, a total of either six surveys at least one week apart between March 15 and June

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 4-8 Section 15183 Exemption Criteria Analysis 30 or a total of either nine surveys at least two weeks apart between July 1 and March 14 will be required. In addition, if the habitat assessment determines that suitable habitat is present on-site, focused surveys for Crotch’s bumble bee conforming to the 2023 survey protocol listed above may also be required. If so, at least three surveys spaced between two and four weeks apart between April and August will be necessary as described in the protocol. Bumble bee surveys will be required each year that project activities have not been completed, if suitable habitat remains on-site. If Crotch’s bumble bee survey results are positive, the applicant will consult with the CDFW to determine if an Incidental Take Permit would be required under CESA depending on the extent and usage of the site by the species. (Required by General Plan Mitigation Measure 5.3-1)
COA BIO-3 If construction activities are not initiated immediately after focused surveys have been completed, additional preconstruction coastal California gnatcatcher and/or Crotch’s bumble bee surveys may be required, in accordance with the California Endangered Species Act and Federal Endangered Species Act, to ensure impacts are avoided or minimized to the extent feasible. If preconstruction activities are required, a qualified biologist would perform these surveys as required for each special status species that is known to occur or has a potential to occur within or adjacent to the proposed development project area, including coastal California gnatcatcher, Crotch’s bumble bee, red diamond rattlesnake, and/or coast horned lizard. These may be combined with nesting bird protections as required under the Migratory Bird Treaty Act and California Fish and Game Code. (Required per Federal Endangered Species Act, California Endangered Species Act, Migratory Bird Treaty Act, and California Fish and Game Code)
COA BIO-4 Because sensitive coastal sage scrub habitat is present in areas immediately adjacent to the proposed development project area, the construction limits shall be clearly flagged to ensure impacts to adjacent habitats are avoided or minimized, to the extent feasible.

Prior to implementing construction activities, the City of San Clemente shall require the Applicant to contract with a qualified biologist to verify that the flagging clearly delineates the construction limits and sensitive resources to be avoided.

COA BIO-5 Prior to the start of construction, a biologist must present a Worker Environmental Awareness Program (WEAP) to the construction crew and project team. The WEAP will be focused on special-status species that are known to occur on-site or in the surrounding area including coastal California gnatcatcher and other species listed in the biological resources report that could occur such as Crotch’s bumble bee, red diamond rattlesnake, and coast horned lizard. The WEAP shall be presented to all new construction crew members prior to their first day of work on the project site, and a sign-in sheet of all attendees over time shall be kept for the project record.

COA BIO-6 A qualified and approved biological monitor shall be present during all vegetation removal and preliminary ground disturbance on the project site to ensure that impacts

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 4-9 Section 15183 Exemption Criteria Analysis to sensitive biological resources are minimized or avoided. The monitor shall have the authority to halt construction if sensitive biological resources are present on-site during construction, and will be responsible for implementing nesting bird protections in compliance with the Migratory Bird Treaty Act and California Fish and Game Code.

COA BIO-7 The applicant shall consult with the USFWS to determine if an incidental take permit under Section 10 of the Endangered Species Act will be required for this project. With adequate protections in place including but not limited to biological monitoring and avoiding the coastal California gnatcatcher nesting season (February 15 through August 30), an incidental take permit may be avoidable. The USFWS will have the final authority to determine what avoidance measures or whether an incidental take permit will be required. (Required by General Plan Mitigation Measure 5.3-2) COA BIO-8 To the greatest extent feasible, the Project will avoid construction activities during the peak nesting season (February 15 through September 15). If this time period cannot be avoided, nesting bird surveys shall be performed by a qualified avian biologist no more than 3 days prior to vegetation removal or ground-disturbing activities. Preconstruction surveys shall focus on both direct and indirect evidence of nesting, including nest locations and nesting behavior. The qualified avian biologist will make every effort to avoid potential nest predation as a result of survey and monitoring efforts. If active nests are found during the preconstruction nesting bird surveys, a qualified biologist shall establish an appropriate nest buffer to be marked on the ground. Nest buffers are species specific and shall be at least 300 feet for passerines and 500 feet for raptors. A smaller or larger buffer may be determined by the qualified biologist familiar with the nesting phenology of the nesting species and based on nest and buffer monitoring results. Construction activities may not occur inside the established buffers, which shall remain on-site until a qualified biologist determines the young have fledged or the nest is no longer active. (Migratory Bird Treaty Act and California Fish and Game Code)
COA CUL-1 Archaeological Resources Inadvertent Discovery. In the event that any subsurface cultural resources are encountered during earth-moving activities, it is recommended that all work within 50 feet be halted until a qualified archaeologist can evaluate the findings and make recommendations. Prehistoric materials can include flaked-stone tools (e.g., projectile points, knives, choppers) or obsidian, chert, or quartzite toolmaking debris; culturally darkened soil (i.e., midden soil often containing heataffected rock, ash, and charcoal, shellfish remains, and cultural materials); and stone milling equipment (e.g., mortars, pestles, handstones). Historical materials might include wood, stone, or concrete footings, walls, and other structural remains; debrisfilled wells or privies; and deposits of wood, metal, glass, ceramics, and other refuse.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 4-10 Section 15183 Exemption Criteria Analysis Professional Qualifications Standards for archaeology (required per General Plan Mitigation Measures 4-1)
COA CUL-2 Human Remains Inadvertent Discovery. If human remains are found, those remains would require proper treatment in accordance with State of California Health and Safety Code Sections 7050.5-7055. Specifically, Health and Safety Code Section 7050.5 describes the requirements if any human remains are discovered during excavation of a site. As required by state law, the requirements and procedures set forth in Section 5097.98 of the California Public Resources Code would be implemented, including notification of the County coroner, notification of the Native American Heritage Commission, and consultation with the individual identified by the Native American Heritage Commission to be the “most likely descendant.” If human remains are found during excavation, excavation must stop in the vicinity of the find and any area that is reasonably suspected to overlie adjacent remains until the County coroner has been called out, and the remains have been investigated and appropriate recommendations have been made for the treatment and disposition of the remains. (Required per State of California Health and Safety Code Sections 7050.5-7055 and California Public Resources Code Section 5097.98)
COA GEO-1 Paleontological Monitoring. Full-time paleontological monitoring is recommended during ground disturbance activities in undisturbed geologic contexts (i.e., bedrock and outcrops) that have the potential to contain significant paleontological resources.

Ground disturbance refers to activities that would impact subsurface geologic deposits, such as grading, excavation, and boring. Activities taking place in current topsoil or within previously disturbed fill sediments, e.g., clearing, grubbing, pavement rehabilitation, do not require paleontological monitoring. Bedrock can occur at varying depths depending on the portion of the project area.

The City shall retain a Society of Vertebrate Paleontology (SVP) qualified paleontologist to provide or supervise a paleontological sensitivity training to all personnel planned to be involved with earth-moving activities, prior to grading or excavation in sedimentary rock material other than topsoil. The training session will focus on how to identify paleontological resources, such as fossils that may be encountered, and the procedures to follow if identified.

Prior to grading or excavation in sedimentary rock material other than topsoil, the City shall retain an SVP-qualified paleontologist to monitor or supervise the monitoring of these activities by an SVP-qualified paleontology monitor assigned by the SVPqualified paleontologist. If fossils are discovered during grading at any depth, the paleontological monitor, in discussion with the SVP-qualified paleontologist, will notify the on-site construction supervisor, who shall redirect work away from the location of the discovery. The recommendations of the SVP-qualified paleontologist shall be implemented with respect to the evaluation and recovery of fossils, after which the on-site construction supervisor shall be notified and shall direct work to continue in the location of the fossil discovery.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 4-11 Section 15183 Exemption Criteria Analysis If any paleontological resources are encountered at the project area during construction or the course of any ground-disturbance activities, all such activities within 100 feet of the find shall halt immediately. At this time, the Applicant shall notify the City and consult with the qualified paleontologist to assess the significance of the find. The assessment will follow SVP (2010) standards. If any find is determined to be significant, appropriate avoidance measures recommended by Michael Baker International and approved by the City must be followed unless avoidance is determined to be unnecessary or infeasible by the City. If avoidance is unnecessary or infeasible, other appropriate measures (e.g., data recovery, excavation) shall be instituted.

If the fossils are determined to be significant, then the SVP-qualified paleontologist shall prepare and implement a data recovery plan. The plan shall include, but not be limited to, the following measures:
• The SVP-qualified paleontologist shall ensure that all significant fossils collected are cleaned, identified, catalogued, and permanently curated with an appropriate institution with a research interest in the materials as required by the SVP guidelines. The Cooper Lab in Santa Ana is a potential repository for this project area.
• The SVP-qualified paleontologist shall ensure that specialty studies are completed, as appropriate, for any significant fossil collected. • The SVP-qualified paleontologist shall ensure that curation of fossils is completed in consultation with the City. A letter of acceptance from the curation institution shall be submitted to the City upon curation.

An SVP-qualified paleontologist is a professional with a graduate degree in paleontology, geology, or related field, with demonstrated experience in the vertebrate, invertebrate, or botanical paleontology of California, as well as at least one year of fulltime professional experience or equivalent specialized training in paleontological research (i.e., the identification of fossil deposits, application of paleontological field and laboratory procedures and techniques, and curation of fossil specimens), and at least four months of supervised field and analytic experience in general North American paleontology.
(Required per General Plan EIR Mitigation Measure 4-2, and General Plan Policies NR-3.01, NR-3.02, and NR-3.03)
COA NOI-1 An audio limiter must be installed on the rooftop lounge sound system. It shall be programmed with a “nighttime” setting that reduces volume by at least 5dBA below the typical daytime operation. This setting shall be used from 10 p.m. until closing time. A Behringer DCX2496 or The Govnor SPL2.2 Sound Pressure Limiter, or its

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 4-12 Section 15183 Exemption Criteria Analysis equivalent, shall be utilized. (Required per General Plan EIR Mitigation Measure 10- 1 and Municipal Code Sections 8.48.070 and 8.48.050)
March 2026 6-1 Conclusion

6.0 CONCLUSION
In accordance with CEQA Guidelines Section 15183(b) and as substantiated by Appendix A, the City of San Clemente has reviewed the potential environmental effects as a result of the proposed project and has found that the project would not result in:
1) Any peculiar impacts as a result of the project or the parcel on which the project is located. 2) Any new potential significant effects, which were not considered in the General Plan EIR. 3) Any potential significant off-site impacts or cumulatively considerable impacts, which were not discussed in the General Plan EIR.
4) Any potential increased significant impacts that were previously identified as significant effects in the General Plan and as a result of substantial new information that was not known at the time the EIR was certified.

The environmental analysis provided in the CEQA Guidelines Section 15183 Initial Study (Appendix A) indicates that the proposed project is consistent with the development density established by the General Plan for which an EIR (i.e., the General Plan EIR) was certified. Impacts related to the proposed project were analyzed in the General Plan EIR. The project would not result in any impacts that are peculiar to the project or project site upon implementation of General Plan EIR Mitigation Measures and/or uniform policies or standards. No new project specific impacts were determined to be potentially significant, that were not already identified as a significant impact under the General Plan EIR. The project would not result in any increased severity of previously identified significant impacts due to substantial new information that was not known at the time of the General Plan EIR.

No potentially significant off-site impacts or cumulatively considerable project-specific impacts were identified that were not already disclosed in the General Plan EIR.

Therefore, pursuant to Public Resources Code Section 21083.3 and CEQA Guidelines Section 15183, no further environmental review is required.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Exemption Report
March 2026 6-2 Conclusion
This page intentionally left blank.

APPENDICES
This document is designed for double-sided printing to conserve natural resources.

APPENDIX A
CEQA Guidelines Section 15183 Initial Study
This document is designed for double-sided printing to conserve natural resources.

CEQA Section 15183 Initial Study
Hanson Hotel Project
Lead Agency:

CITY OF SAN CLEMENTE
910 Calle Negocio
San Clemente, CA 92673
Contact: Adam Atamian
949.361.6196
Prepared By:

MICHAEL BAKER INTERNATIONAL
5 Hutton Centre Drive, Suite 500
Santa Ana, CA 92707
Contact: Kristen Bogue
949.472.3505
March 2026
JN 208581
This document is designed for double-sided printing to conserve natural resources.

March 2026 1-1 Section 15183 Initial Study

1.0 SECTION 15183 INITIAL STUDY

1.1 PROJECT BACKGROUND

1. Project Title: Hanson Hotel Project

2. Lead Agency Name and Address:

City of San Clemente
Community Development Department
910 Calle Negocio
San Clemente, CA 92673

3. Contact Person and Phone Number:

Adam Atamian
Community Development Director
(949) 361.6196
[email protected]

4. Project Location:

The project site is located at 1801 North El Camino Real (Assessor’s Parcel Number [APN] 057-191-60) to the northwest of the intersection of North El Camino Real and East Avenida Pico, in San Clemente, California.

5. Project Sponsor’s Name and Address:

Jorden Segraves (Applicant Representative)
Jorden Segraves Architect, Inc.
32402 Crown Valley Parkway #102
Dana Point, CA 92629
(949) 338-2603
[email protected]

5. General Plan Designation:

The project site is designated as Downtown Mixed-Use 1 (MU1).

7. Zoning:

The project site is zoned Mixed-Use 1 within the Central Business (CB) District with an Architectural (A) and Coastal Zone (CZ) overlays (MU1-A-CB-CZ).

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 1-2 Section 15183 Initial Study

8. Description of the Project:

The development of a three-story, 61-room boutique hotel featuring a pool, café, roof-top restaurant (3,380 sq. ft.), pool with a bar and food service, indoor cafe and hotel lobby (1,357 sq. ft.), walk up cafe (290 sq. ft.) with full range alcohol service and amplified music for the pool and roof top restaurant, outdoor dining for all restaurant and cafe areas, and a two level subterranean parking garage with 104 parking stalls.

9. Surrounding Land Uses and Setting:

The project is located within a developed and urbanized area surrounded by primarily commercial, transit, open space, and residential uses.

10. Other public agencies whose approval may be required (e.g., permits, financing approval or participation agreement):

California Coastal Commission, California Department of Fish and Wildlife, San Diego Regional Water Quality Control Board, South Coast Air Quality Management District

1.2 ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED
The project would have potentially significant impacts, despite the application of any existing federal, State, and local laws and regulations, General Plan EIR mitigation measures, and/or COAs, as indicated by the checklist on the following pages.

Aesthetics Land Use and Planning
Agriculture and Forestry Resources Mineral Resources
Air Quality Noise
Biological Resources Population and Housing
Cultural Resources Public Services
Energy Recreation
Geology and Soils Transportation
Greenhouse Gas Emissions Tribal Cultural Resources
Hazards and Hazardous Materials Utilities and Service Systems Hydrology and Water Quality Wildfire

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 1-3 Section 15183 Initial Study

1.3 ENVIRONMENTAL DETERMINATION
On the basis of this initial evaluation:

I find that the proposed project WOULD NOT result in 1) a peculiar impact that was not identified as a significant impact under the prior EIR; 2) a significant impact that was not analyzed as significant in the prior EIR; 3) a potentially significant off-site impact or cumulative impact not discussed in the prior EIR; or 4) a more severe impact due to substantial new information that was not known at the time of the prior EIR. NO FURTHER ACTION is required and a Notice of Exemption will be filed indicating that the project IS ELIGIBLE for an EXEMPTION under CEQA Guidelines Section 15183. 
I find that the project WOULD result in 1) a peculiar impact that was not identified as a significant impact under the prior EIR; 2) a significant impact that was not analyzed as significant in the prior EIR; 3) a potentially significant off-site impact or cumulative impact not discussed in the prior EIR; or 4) a more severe impact due to substantial new information that was not known at the time of the prior EIR. I find that FURTHER ENVIRONMENTAL REVIEW is necessary to analyze those effects that are subject to CEQA, and therefore, this project is NOT ELIGIBLE for an EXEMPTION under CEQA Guidelines Section 15183.
_
Signature:

Printed Name: Adam Atamian
Title: Community Development Director
Date:

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 1-4 Section 15183 Initial Study
This page intentionally left blank.

March 2026 2-1 Environmental Analysis Methodology

2.0 ENVIRONMENTAL ANALYSIS METHODOLOGY
The following subsections of this Initial Study contain a summary of the General Plan EIR findings, a detailed environmental analysis of the project-specific impacts (including direct and indirect, shortterm, long-term, and cumulative impacts), and, if new or increased impacts result, the applicability of the General Plan EIR mitigation measures and uniform policies, standards, or regulations that would apply to such impacts. Any resulting potentially significant impacts, after application of General Plan EIR mitigation and uniform policies and standards are identified, if any.

The following analysis examines the environmental factors outlined in CEQA Guidelines Appendix G, Environmental Checklist Form, in alphabetical order. Each environmental issue is organized into the following subsections, consistent with the criteria required for consideration of CEQA Guidelines Section 15183:
• General Plan EIR Summary: This section summarizes the findings presented in the General Plan EIR. The following analysis identifies the General Plan EIR’s findings of significance for the environmental topic area of consideration, as follows:
o No Impact – Buildout of the General Plan would have no impact pertaining to the environmental topic area being considered.
o Less than Significant Impact – Buildout of the General Plan would have less than significant impacts pertaining to the environmental topic area being considered, including after application of any existing federal, State, and local laws and regulations as well as any applicable mitigation measures.
o Significant and Unavoidable Impact – Buildout of the General Plan would result in significant and unavoidable impacts pertaining to the environmental topic area being considered, despite the application of any existing federal, State, and local laws and regulations as well as any applicable programmatic mitigation measures. • Project-Specific Impacts: This section analyzes the project’s specific environmental effects consistent with the criteria for CEQA Guidelines Section 15183. This analysis describes potential environmental changes to the existing physical conditions that may occur if the proposed project is implemented. Evidence, based on factual and scientific data, is presented to show the cause and effect relationship between the proposed project and the potential changes in the environment. The exact magnitude, duration, extent, frequency, range, or other parameters of a potential impact are ascertained, to the extent possible, to determine whether impacts may be significant; all of the potential direct and reasonably foreseeable indirect effects are considered. Should standard regulations apply, such regulations are identified prior to determining the project’s significant effects.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 2-2 Environmental Analysis Methodology
Should any potential project-specific impacts result after implementation of standard regulations, then applicable General Plan EIR mitigation measures are considered to reduce the project’s impacts. In addition to General Plan EIR mitigation, applicable uniform policies, standards, or regulations are also considered in order to reduce impacts. Should application of uniform policies, standards, or regulations require a project to implement a project-specific measure, in order to enforce such uniform policies, standards, or regulations, such measures are identified as Conditions of Approval (COAs). If impacts remain potentially significant after application of General Plan mitigation and/or application of uniform policies/standards, such impacts are identified as potentially significant impacts.

This Initial Study classifies the project’s impacts, per CEQA thresholds of significance, as the following:
o No Impact – The project would have no impact pertaining to the threshold of significance being considered.
o Less than Significant Impact – The project would have less than significant impacts pertaining to the threshold of significance being considered, including after application of any existing federal, State, and local laws and regulations. o Less than Significant Impact with General Plan EIR Mitigation and/or COAs – The project would have less than significant impacts pertaining to the threshold of significance being considered after application of any General Plan EIR Mitigation Measures and/or uniform policies and standards that involve project-specific considerations (identified as COAs).
o Significant Impact Already Identified in General Plan EIR – The project would have potentially significant impacts, despite the application of any existing federal, State, and local laws and regulations, General Plan EIR mitigation measures, and/or COAs. However, such impacts were already disclosed in the General Plan EIR and the projects significant impacts would not be more that than that disclosed in the General Plan EIR.
o New Potentially Significant Impact or Increased Significant Impact – The project would have potentially significant impacts, despite the application of any existing federal, State, and local laws and regulations, General Plan EIR mitigation measures, and/or COAs. If such impacts were already identified as significant and unavoidable in the General Plan EIR, the project would have an increased significant impact, compared to that disclosed in the General Plan EIR.

March 2026 3.1-1 Aesthetics/Light and Glare

3.0 ENVIRONMENTAL ANALYSIS
The following is a discussion of potential project impacts as identified in the Initial Study.

Explanations are provided for each item.

3.1 AESTHETICS/LIGHT AND GLARE

3.1.1 General Plan EIR Summary
Less Than Significant Impact. The General Plan EIR identifies the canyons and ridgelines of the Santa Ana Mountain foothills and their transition into the coastal bluffs, canyons, and beaches as the dominant visual characteristics in the City. These characteristics are further defined by two distinct areas – with Area 1 located between the Pacific Ocean and Interstate 5 (I-5) and Area 2 located east of I-5. The City designates I-5 as a scenic roadway as it provides scenic vistas of the City, ridgelines, and ocean. The General Plan Scenic Highways Element also lists other designated scenic corridors including State Route 1 (SR-1), also known as El Camino Real. Other important vistas in the City include those visible from the San Clemente Coastal Trail. Many public places and historic buildings located in Area 1 (the Downtown area) are designated scenic vistas, and are oriented to maximize visual access to coastal canyons and the ocean; some are also scenic resources in their own right. Area 2’s most prominent natural features are its undeveloped ridgelines, providing long-range coastline views.

The General Plan EIR summarized that buildout of the General Plan would primarily occur in the form of infill development, and as such, would not degrade existing views of dominant resources.

While some development could occur on undeveloped parcels, which would result in minor changes to existing views of ridgelines or the ocean, development in these locations would be required to comply with City regulations and policies protecting scenic vistas. These would include Municipal Code Chapters 15.40, Hillside Development Ordinance, and 17.24, General Development Standards, the City’s Design Guidelines and the City’s Master Landscape Plan for Scenic Corridors, as well as the numerous policies from various Elements of the General Plan. Additionally, development on undeveloped parcels would not occur in large clusters, but would be dispersed throughout the City as the General Plan EIR Focus Areas already are largely built up under existing conditions. As such, upon adherence to City regulations and policies, the General Plan EIR concluded that buildout of the General Plan would result in less than significant impacts to scenic vistas.

The General Plan EIR established that there are no officially State-designated scenic highways in the City; however, Figure 5.1-3, Scenic Corridors Map, of the General Plan EIR, shows the City’s scenic corridors as identified by the General Plan. General Plan Policy M-1.26 requires that listed roadways be maintained and preserved as major or minor scenic corridors. Overall, the General Plan EIR found that land use changes and intensities for the General Plan Focus Areas would not represent a substantial reimagining of the character of those areas. Since those Focus Areas are largely urbanized and built out, buildout of the proposed land use plan would primarily involve gradual changes in development intensity along major scenic corridors, particularly I-5 and El Camino Real. New and/or intensified uses in the Focus Areas would not fully obstruct visual resources such as the ocean or hillsides and would not require substantial changes in topography. Allowed uses in the Focus Areas would be regulated by Design Guidelines, Municipal Code development standards, and General Plan policies that limit the height and bulk of buildings. Additionally, implementation of the General Plan

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.1-2 Aesthetics/Light and Glare
would not result in damage to any historic buildings or rock outcroppings. While development may involve the removal of street trees, trees would be required to be replaced to meet the requirements of General Plan Policy M-1.17 (requiring construction or modification of major roadways to promote the creation and maintenance of “streetscapes” and linear scenic parkways or corridors that promote the City’s visual quality and character). Therefore, buildout of the General Plan would not substantially alter scenic resources within or near scenic highways, and impacts were determined to be less than significant.

The General Plan EIR concluded that while implementation of the General Plan would alter the visual character of the Focus Areas and their immediate vicinity, it would not result in a substantial cumulative change or degradation of Cityside visual character or quality. With adherence to the City’s regulations governing scenic quality, impacts would be less than significant.

The General Plan EIR concluded that temporary sources of light and glare associated with construction activities would be confined to the Focus Areas, where substantial amounts of light and glare are already generated. Adherence to the design standards in the Municipal Code and other regulations would ensure that light and glare from new development and redevelopment projects would be minimized; overall, impacts were determined to be less than significant.

3.1.2 Project-Specific Impacts
Except as provided in Public Resources Code
Section 21099,
would the project:

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.1-3 Aesthetics/Light and Glare
a) Have a substantial adverse effect on a scenic vista? Less Than Significant Impact With General Plan EIR Mitigation and/or Uniform Policies and Standards. Based on the General Plan EIR, San Clemente residents enjoy views of the coast, interior canyons, and ridgelines from various points in the City. Ridgelines with scenic value, most of which run perpendicular to the coast, are identified in the adopted General Plan. Their scenic value is determined based on the views they afford overlooking Area 1 (mapped on General Plan EIR Figure

5.1-1, Photographs of Unique Scenic Resources) and the ocean, their own scenic value when viewed from elsewhere in the City, and their preservation of natural resources.

The project site is located in the North Beach Gateway and lies within the El Camino Real/Pacific Coast Highway and Avenida Pico Scenic View Corridors, as established in the General Plan and Coastal Land Use Plan (Coastal LUP). Based on the General Plan EIR analysis on scenic vistas, the project site is located in Area 1, the western portion of the City that spans the sloping shelf that sits atop coastal bluffs. Area 1 features moderately dense urban fabric, with older, highly connected neighborhoods that include the Downtown area and the City’s main public areas. Area 1 has a Spanish village character with many buildings featuring Spanish Colonial Revival architecture and several areas featuring views of the ocean and coastal bluffs. According to the General Plan EIR Figure 5.1-2, Visual Resources Map, both North El Camino Real and East Avenida Pico adjoining the project site are designated major visual corridors. There are no other coastal canyons, significant ridgelines, or other designated scenic vistas in the project vicinity. While there are no residential uses immediately adjacent to the project site, the residences north of the open space area above Pico Park have distant views of the ocean, which may also include views of the project site.

Exhibit 3.1-1, Key View Map, identifies the locations of six existing views depicted in Exhibit 3.1-2a through Exhibit 3.1-2c, Key Views.
• Key View 1 is from the pedestrian trail north of the project site, looking southwest. Views are of existing vegetation and disturbed land on-site, existing commercial and residential development to the west and southwest, including hillside development built to heights of approximately three to four stories, mature palm trees, East Avenida Pico, and the Pacific Ocean.
• Key View 2 is from a center median along East Avenida Pico, northeast of the project site, looking west. Views are of the roadway and streetscape design, including landscaping and pole-mounted street lights, the project site (which has shrub vegetation and a chain-link fence), commercial development and mature palm trees, and the Pacific Ocean. • Key View 3 is from North El Camino Real, looking southeast. Views or of the roadway, Catalyst Surf Shop and associated surface parking lot, street lights and traffic lights, existing development, and distant ridgelines.

HANSON HOTEL PROJECT
CEQA GUIDELINES SECTION 15183 INITIAL STUDY
Exhibit 3.1-1
Key View Map
Source: Google Earth Pro, January 2026

NOT TO SCALE
02/2026 • JN 210935
1 3
2 4
5 6

N EL CAMINO REAL

BOCA DE LA PLAYA

CALLE DESHECA

CALLE LAS BOLAS

E AVENIDA PICOE AVENIDA PICO

AVENIDA HACIENDA

PROJECT SITE

KEY VIEWS
KEY VIEW 1
KEY VIEW 2

HANSON HOTEL PROJECT
CEQA GUIDELINES SECTION 15183 INITIAL STUDY
Key Views 1 and 2 02/2026 • JN 210935 Exhibit 3.1-1a
BEFORE
BEFORE
AFTER
AFTER
Source: Jorden Segraves Architect Inc.

KEY VIEW 3
KEY VIEW 4

HANSON HOTEL PROJECT
CEQA GUIDELINES SECTION 15183 INITIAL STUDY
Key Views 3 and 4 02/2026 • JN 210935 Exhibit 3.1-1b
BEFORE
BEFORE
AFTER
AFTER
Source: Jorden Segraves Architect Inc.

KEY VIEW 5
KEY VIEW 6

HANSON HOTEL PROJECT
CEQA GUIDELINES SECTION 15183 INITIAL STUDY
Key Views 5 and 6 02/2026 • JN 210935 Exhibit 3.1-1c
BEFORE
BEFORE
AFTER
AFTER
Source: Jorden Segraves Architect Inc.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.1-8 Aesthetics/Light and Glare
• Key View 4 is from a center median along East Avenida Pico, northeast of the project site and north of Key View 2, looking west. Views are similar to Key View 2; however, the project site is less prominent and ocean views are more central.
• Key View 5 is from the open space area north of Pico Park and south of residential uses located further north, looking southwest. Views are of the surrounding open space area, Pico Park, Avenida Pico, the project site and surrounding development, mature palm trees, and expansive views of the Pacific Ocean.
• Key View 6 is from Pico Park, looking southwest. Views are of the surface parking lot that serves the park, the project site and existing vegetation, surrounding development, mature palm trees, and expansive views of the Pacific Ocean.

As demonstrated in Exhibit 3-1.2a through Exhibit 3.1-2c, the project would modify existing views along designated Scenic View Corridors (North El Camino Real and East Avenida Pico). Existing visual resources include views of the Pacific Ocean and views of the Spanish village theme architectural features, including a prevalence of streets lined with tall palm trees (consisting largely of the Mexican Fan Palm or Washingtonia robusta variety). As depicted in Exhibit 3-1.2a through Exhibit 3.1-2c, these changes would not degrade the dominant views of the Pacific Ocean from these Scenic View Corridors, nor would the project conflict with the Spanish village theme architecture.

The project’s maximum building height of 45 feet and maximum plate line (PL) height of 37 feet would be consistent with the site’s Downtown Mixed-Use 1 (MU1) land use designation, and as such would not obstruct views along these corridors beyond what the General Plan EIR analyzed.

Additionally, as a project within the Architectural Overlay District (A-Overlay), the hotel would be designed in the Spanish Colonial Revival architectural style, consistent with surrounding structures, to maintain visual continuity within the viewshed. The project Applicant designed the project to be visually compatible with the North Beach Historic District and adjacent historic resources. Specifically, the architecture incorporates tiered massing, with one- and two-story elements stepping down toward East Avenida Pico and recessed upper levels along North El Camino Real. A prominent turret element at the corner of North El Camino Real and East Avenida Pico anchors the site to create a distinctive visual gateway element into the North Beach area. Additionally, a grand stairway leading to a public podium terrace would provide ocean views. The project includes outdoor dining at a rooftop restaurant, ground-level café, and walkup café, where seating is strategically placed to avoid obstructing view corridors and public accessways, particularly along East Avenida Pico. The low-profile furnishings, landscape buffers, and lighting are compatible with the surrounding development. This amenity aligns with the City’s goals for creating inviting public spaces to the North Beach area.

Pursuant to the Municipal Code Chapter 17.24, General Development Standards, the project is subject to general development standards, resulting in new development that is harmonious with existing and potential development in the surrounding area. Standards include provisions addressing aesthetic concerns such as the preservation of topographical features (Municipal Code Section 17.24.60). The project would also be subject to the City’s Design Review Process, which enforces the General Plan

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.1-9 Aesthetics/Light and Glare
policies and Municipal Code regulations protecting scenic vistas and corridors. The Design Review process ensures that projects generally conform to the City of San Clemente Design Guidelines (Design Review Guidelines), adopted in November 1991. In addition to general discussion of urban design principles and San Clemente’s unique architectural character, the Design Guidelines include detailed and illustrated provisions aimed at ensuring quality development in the San Clemente. Concerns include scale, mass, and form; signage; site orientation of buildings; landscaping; parking; and the relationship between buildings and the street. Other provisions outline design solutions for specific development types and districts. Hand-drawn illustrations emphasize a document-wide focus on the City’s Spanish Colonial Revival architectural tradition.

Pursuant to the Municipal Code Chapter 17.68, Landscape Standards, establishes landscaping standards for private property that enhance the appearance of developments; increase the compatibility between different land uses; reduce the heat and glare generated by development; and protect public health, safety, and welfare by minimizing the impacts of soil erosion and visual pollution and promoting water conservation (Condition of Approval [COA] 3.11). The Master Landscape Plan for Scenic Corridors (Master Landscape Plan for Scenic Corridors) was adopted in 1989 and revised in 1992. Its purpose is to establish a unified landscape program for the scenic highways in San Clemente that link coastal area of the City with inland master-planned areas. The plan determines specific plant materials along specific scenic corridors. It is the intent of the plan to provide objective design and evaluation criteria to utilize when landscaping land adjacent to or affecting scenic highways.

Overall, the project would be required to comply with Municipal Code Chapter 17.24 and the City’s Design Review process, which enforces the City’s Design Guidelines and the City’s Master Landscape Plan for Scenic Corridors, as well as General Plan Policies regarding preservation of scenic views.

With adherence to uniform policies and regulations, the project would result in less than significant impacts on scenic vistas.

Applicable Conditions of Approval (COAs):

Placement of the vertical landscaping and type shall be sensitive to not contribute to ocean view obstructions from the Avenida Pico Scenic Corridor. b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway?

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.1-10 Aesthetics/Light and Glare
Less than Significant Impact With General Plan EIR Mitigation and/or COAs. Based on the California Department of Transportation (Caltrans), Statewide Scenic Highway [Map], there are no Statedesignated scenic highways within the City; however, I-5 throughout the City is State-eligible and is located 0.6-mile north of the project site.1 As analyzed in the General Plan EIR, buildout of the North Beach/Camino Real Focus Area, including the project site, would not fully obstruct visual resources such as the ocean or hillsides and would not require substantial changes in topography. The project’s maximum of 45 feet and maximum PL height of 37 feet would be consistent with the site’s land use designation, and the architecture proposes to incorporate tiered massing, with one- and two-story elements stepping down toward East Avenida Pico and recessed upper levels along North El Camino Real. As shown in the photo simulations for Key Views 2, 3, and 4 (Exhibit 3.1-2a through Exhibit

3.1-2c), project implementation would not represent a substantial change to existing views of the Pacific Ocean, or the Spanish village architectural theme in the area. Implementation of the project would not result in damage to any street trees, as no trees exist on-site. The project would be required to adhere to Municipal Code Chapters 17.24, 17.68, and 17.84, the City’s Design Guidelines and the City’s Master Landscape Plan for Scenic Corridors (COA 3.11), as well as General Plan Policies.

Following adherence to uniform policies and regulations, the project would result in less than significant impacts related to scenic highways, similar to the General Plan EIR.

Applicable Conditions of Approval (COA): Refer to COA 3.11.

c) In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?

Less than Significant Impact With General Plan EIR Mitigation and/or COAs. The proposed project is located within an urban and developed area of the City. As such, the following analysis focuses on evaluating the project’s consistency with applicable zoning and other regulations governing scenic quality.

OPERATIONS
The project site is located in the North Beach/North El Camino Real Focus Area, an urbanized area of the City that is targeted for mixed-use development in order to allow for a horizontal or vertical mix of commercial and residential uses, with a permitted maximum floor area ratio (FAR) of 1.0 for commercial uses and 2.0 for mixed uses. The project proposes a 61-room hotel with a rooftop restaurant and bar, an indoor café, a walkup café, and a hotel guest-only pool and restaurant, with an FAR of 0.937. The project’s maximum building height of 45 feet and maximum PL height of 37 feet would be consistent with the site’s MU1 land use designation. The project’s design would reflect traditional Spanish Colonial Revival architecture and integrate publicly accessible features such as 1 California Department of Transportation, Statewide Scenic Highway [Map], https://experience.arcgis.com/experience/47e2009986264718a5a13a2c81382774, accessed January 29, 2026.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.1-11 Aesthetics/Light and Glare
native landscaped gardens, pedestrian areas, and ocean-view terraces; as discussed in Response

3.1.2(a). The proposed landscape plan features a diverse palette of California native and droughttolerant plant species, strategically arranged in a series of terraced gardens along East Avenida Pico and North El Camino Real.

Implementation of the proposed project on the currently vacant project site would represent a change in the overall atmosphere and visual relationship between the site and surrounding uses. Despite this change, the project would be compatible with the village-like atmosphere of the area and would maintain general views to the Pacific Ocean. As detailed in Section 3.11, Land Use and Planning, compliance with the Municipal Code development standards, the City’s Design Review process, and General Plan policies pertaining to scenic quality and COA 3.11, the project would not substantially degrade the existing visual character or quality of the area. As such, the proposed project would not conflict with applicable zoning or regulations government scenic quality and impacts would be less than significant.

CONSTRUCTION
Project construction would occur for a duration of approximately 13 months. During this time, construction of the project could result in short-term visible construction activities, equipment, and staging areas, all of which would temporarily impact the visual character and quality of the project site and surrounding area. However, given the nature of project (an infill project), the intensity of construction activities would be relatively limited. The project would not require substantial earthwork (other than for installation of the subterranean parking garage), and the stockpiling of soils, equipment, and building materials would be minimal. Moreover, project construction activities would adhere to the City’s Municipal Code Section 15.36.190 allows for grading, right-of-way encroachment, and landscaping/irrigation construction under permit only, during specific hours. These permitted activities can occur between 7:00 a.m. to 6:00 p.m., Monday through Friday. Approval to conduct these activities beyond this time period, or on Saturday, Sunday, or during recognized holidays must be pre-approved by the City Engineer through a written request submitted by the contractor.

However, construction activities may occur outside of these hours if the City determines that the maintenance, repair, or improvement is necessary to maintain public services or cannot feasibly be conducted during normal business hours, or if construction activities comply with the stationary source noise standards of the Municipal Code. Temporary construction related activities would cease upon completion. As such, project construction activities would not conflict with zoning or other regulations governing scenic quality, and impacts would be less than significant in this regard.

Applicable Conditions of Approval (COA): Refer to COA 3.11.

d) Create a new source of substantial light or glare, which would adversely affect day or nighttime views in the area?
Less than Significant Impact With General Plan EIR Mitigation and/or COAs.. Under existing conditions, the project site is subject to nighttime lighting from surrounding development; street lighting along surrounding roadways; and light from motor vehicles traveling along these roadways.

The project would introduce new light sources on-site during construction and operation that

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.1-12 Aesthetics/Light and Glare
currently do not exist. However, light and glare associated with the proposed project would be typical of that of infill development. Exterior lighting is proposed on-site at building entrances, parking areas, amenity spaces, and pedestrian walkways for security and wayfinding purposes. Lighting would also be used to illuminate architectural elements, signage, and landscape features for ambience. All lighting would comply with current energy standards, utilizing light emitting diode (LED) or efficient fluorescent lighting technology. Project lighting would be shielded and directed away from adjoining properties in accordance with City standards. Specifically, site lighting would be designed to Dark Sky requirements in regard to the shielding of light, limiting light trespass, utilizing energy-efficient lighting, and adhering to color temperature limits. Site photometric and lighting specifications would be submitted for review as part of City’s Building Department review. Overall, the project would be required, through the City’s Design Review process, and Building Permit process, to implement best practices as outlined in California Title 24 and CALGreen, as well as the International Dark Sky Association (IDA) guidelines and requirements to reduce light pollution and protect night sky and night habitat (COAs 1.9 and 5.4). Adherence to the design standards in the Municipal Code and other regulations would ensure that light and glare from the project would be minimized; overall, impacts would be less than significant.

Applicable Conditions of Approval (COA):

March 2026 3.2-1 Agriculture and Forestry Resources

3.2 AGRICULTURE AND FORESTRY RESOURCES

3.2.1 General Plan EIR Summary
No Impacts. The General Plan EIR determined that no impacts would occur in this regard as there are no farmland areas within the City of San Clemente that are identified as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance as shown on maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency. The General Plan EIR determined that no impacts would occur in this regard as there are no areas in San Clemente zoned for agricultural use or parcels under a Williamson Act contract. The General Plan EIR determined that no impacts would occur in this regard as implementation of the General Plan would not rezone or conflict with the existing zoning of forest land or timberland as defined by Public Resources Code sections 12220(g) or 51104(g), and the City of San Clemente does not have any areas designated forest land or timberland for production or resource management.

The General Plan EIR determined that no impacts would occur in this regard as State and county maps of wildlife habitats compiled by the California Department of Forestry and Fire Protection do not identify forest uses within San Clemente. The northeastern portion of the City contains undisturbed hillside areas featuring clusters of trees. However, the land use changes proposed under the San Clemente General Plan primarily consist of changes in intensity on infill sites that are already developed and do not include development of greenfield sites at the City’s periphery. Therefore, implementation of the General Plan would not convert forest to non-forest use, and no impacts related to the loss of forest land would occur. The General Plan EIR determined that no impacts would occur in this regard as the City of San Clemente does not have any agricultural resources, and implementation of the General Plan would not covert forest uses to non-forest use. Therefore, no impacts would occur.

3.2.2 Project-Specific Impacts
In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In
determining whether impacts to forest resources,
including timberland, are significant environmental effects, lead agencies may refer to information compiled by the
California Department of Forestry and Fire Protection
regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest
Legacy Assessment project; and forest carbon
measurement methodology provided in Forest Protocols
adopted by the California Air Resources Board. Would the project:

New
Potentially
Significant
Impact or
Increased
Significant
Impact
Significant
Impact
Already
Identified
in the
General
Plan EIR
Less Than
Significant
Impact
With
General
Plan EIR
Mitigation
and/or
COAs
Less Than
Significant
Impact
No
Impact
a. Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland), as
shown on the maps prepared pursuant to the
Farmland Mapping and Monitoring Program of the
California Resources Agency, to non-agricultural
use?


HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.2-2 Agriculture and Forestry Resources
In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In
determining whether impacts to forest resources,
including timberland, are significant environmental effects, lead agencies may refer to information compiled by the
California Department of Forestry and Fire Protection
regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest
Legacy Assessment project; and forest carbon
measurement methodology provided in Forest Protocols
adopted by the California Air Resources Board. Would the project:

New
Potentially
Significant
Impact or
Increased
Significant
Impact
Significant
Impact
Already
Identified
in the
General
Plan EIR
Less Than
Significant
Impact
With
General
Plan EIR
Mitigation
and/or
COAs
Less Than
Significant
Impact
No
Impact
b. Conflict with existing zoning for agricultural use, or a Williamson Act contract? 
c. Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code
section 12220(g)), timberland (as defined by Public
Resources Code section 4526), or timberland zoned
Timberland Production (as defined by Government
Code section 51104(g))?

d. Result in the loss of forest land or conversion of forest land to non-forest use? 
e. Involve other changes in the existing environment,
which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or
conversion of forest land to non-forest use?

a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? No Impact. The project site and all adjoining properties are designated as “Urban and Built‐Up Land” by the California Department of Conservation, California Important Farmland Finder; the project site is not designated as Prime Farmland, Unique Farmland, Farmland of Statewide Importance, or Farmland of Local Importance.2 Thus, the project would not impact Prime Farmland, Unique Farmland, Farmland of Statewide Importance, or Farmland of Local Importance. b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? No Impact. Refer to Response 3.2.2(a). The project site is zoned Mixed-Use 1 within the Central Business (CB) District with an Architectural (A) and Coastal Zone (CZ) overlays (MU1-A-CB-CZ) and is not zoned or currently used for agricultural purposes. Neither the project site nor the adjoining 2 California Department of Conservation, California Important Farmland Finder, https://maps.conservation.ca.gov/dlrp/ciff/, accessed January 21, 2026.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.2-3 Agriculture and Forestry Resources
properties are zoned for agricultural use or are under a Williamson Act contract.3 As such, project implementation would not conflict with existing zoning for agricultural use or a Williamson Act contract, and no impacts would occur.
c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 122220(g)), timberland as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))?
No Impact. The project site is zoned MU1-A-CB-CZ and is not zoned as forest land (as defined in PRC section 12220(g), timberland (as defined in PRC Section 4526), or timberland zoned Timberland Production (as defined by Government Code section 4526) or use for similar purposes. As such, no impact would occur in this regard.

d) Result in the loss of forest land or conversion of forest land to non-forest use? No Impact. Refer to Response 3.2.2(c), above. Project implementation would not result in the loss of forest land or conversion of forest land to non-forest use. As such, no impacts would occur in this regard.
e) Involve other changes in the existing environment, which due to their location or nature, could result in conversion of farmland to non-agricultural use or conversion of forest land to non-forest use?
No Impact. Refer to Responses 3.2.2(a) through 3.2.2(d), above. The project site does not have any agricultural resources, and project implementation would not convert forest uses to non-forest use.

Therefore, no impacts would occur in this regard.
3 California Department of Conservation, Williamson Act Enrollment Finder, https://maps.conservation.ca.gov/dlrp/WilliamsonAct/App/?print_preview=true, accessed January 21, 2026.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.2-4 Agriculture and Forestry Resources
This page intentionally left blank.

March 2026 3.3-1 Air Quality

3.3 AIR QUALITY

3.3.1 General Plan EIR Summary
Significant and Unavoidable Impact. As detailed in the General Plan EIR, Southern California Association Government’s (SCAG) growth projections for the City of San Clemente are based on the 1993 General Plan and regional demographic trends incorporated into the Regional Transportation Plan / Sustainable Communities Strategy (RTP/SCS), which informs transportation priorities and vehicle miles travelled (VMT). The General Plan EIR assumes full buildout by 2035, resulting in higher population and employment than SCAG forecasts. Because this additional growth is not included in the South Coast Air Quality Management District’s (SCAQMD) 2012 Air Quality Management Plan (2012 AQMP) emissions inventory, the 2012 AQMP does not account for emissions from the General Plan EIR. Once adopted, future AQMP updates will incorporate these projections, making the plan consistent with regional air quality planning. However, until then, impacts related to this discrepancy are considered significant. The General Plan EIR is considered inconsistent with the AQMP because emissions from full buildout of the General Plan would cumulatively worsen existing nonattainment conditions in the South Coast Air Basin (SCAB). This growth exceeds current population and employment forecasts and is not reflected in the regional emissions inventory. While the Land Use Plan promotes higher density and mixed-use development aligned with regional transportation and land use goals, and its policies would help reduce greenhouse gas (GHG) emissions, the additional growth would still generate emissions contributing to nonattainment. It should be noted that the General Plan EIR did not include mitigation measures that would reduce the impacts associated with inconsistency with the AQMP. Therefore, the impact is significant and unavoidable.

As detailed in the General Plan EIR, construction activities under the General Plan EIR would generate short-term emissions of criteria pollutants, primarily from equipment operation, soil disturbance, and architectural coatings/asphalt. Due to the scale of buildout, emissions would likely exceed SCAQMD regional thresholds and cumulatively contribute to Basin nonattainment for ozone and particulate matter. Volatile organic compounds (VOC) and nitrogen oxides (NOx) are ozone precursors, and NOx also forms particulate matter. While regulatory measures and mitigation (e.g., dust control, low-emission equipment) can reduce impacts, the extent of development means some projects will still exceed thresholds. Because emissions cannot be quantified at the policy level and exceedances are likely, construction-related air quality impacts are considered significant and unavoidable. As discussed in the General Plan EIR, full buildout of the General Plan EIR would also produce long-term operational emissions exceeding SCAQMD daily thresholds for VOC, NOx, carbon monoxide (CO), and fine particulate matter 2.5 micrometers or smaller (PM2.5). VOC and NOx are ozone precursors, and NOx also contributes to particulate matter formation. These exceedances would worsen the Basin’s nonattainment for ozone and particulate matter. While General Plan policies (e.g., Policy NR-5.01 requiring SCAQMD mitigation measures) would reduce impacts where feasible, future development could still surpass regional thresholds. Therefore, operational air quality impacts were considered significant and unavoidable.

Industrial and commercial uses allowed under the General Plan EIR (e.g., chemical processing, dry cleaning, gas stations) could emit Toxic Air Contaminants (TACs). These emissions would require SCAQMD permits and health risk assessments under Rule 1401. Because specific sources and emissions cannot be determined now, TAC impacts are considered potentially significant.

Warehousing and industrial operations could also generate diesel particulate matter (DPM) from trucks, equipment, and rail activities, contributing to cancer and noncancer health risks near sensitive

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.3-2 Air Quality
receptors and along regional routes. This is considered a significant and unavoidable impact. Although congested intersections can create localized CO concentrations, the Basin is currently in attainment for CO standards. Modeling shows that an intersection would need traffic volumes far beyond what buildout of the General Plan would generate to create a hotspot. Therefore, CO hotspots were not an environmental concern.

Industrial land uses have the potential to generate objectionable odors that may affect nearby communities. Typical industrial odor sources include wastewater treatment plants, composting facilities, landfills, transfer stations, fiberglass and chemical manufacturing, refineries, dairies, asphalt plants, auto-body shops, and food manufacturing. While these uses must comply with SCAQMD Rule 402, additional odor-control measures may still be required to avoid creating a public nuisance. As a result, industrial development under the General Plan EIR may generate potentially significant odor impacts to a substantial number of people. The General Plan EIR also states that, if project-level environmental review finds that a project could cause nuisance odors beyond the property line, the Planning Director may require an Odor Management Plan. This applies to facilities with odorgenerating potential, such as wastewater treatment plants, composting or recycling facilities, certain manufacturing and coating operations, large coffee roasters, and food-processing facilities. When required through CEQA review, the plan must be submitted before project approval to ensure compliance with South Coast AQMD Rule 402. The Odor Management Plan must identify best available control technologies for toxics (T-BACTs) to reduce odors to acceptable levels, include enforcement mechanisms, and incorporate these measures as mitigation in the environmental document and/or site plan. As such, with the implementation of Odor Management Plan, impact would be less than significant. Residential and commercial uses can produce minor odors, such as emissions from landscaping equipment, but they are not considered major odor generators. Therefore, odors from residential and commercial uses under buildout of the General Plan are considered less than significant. Construction activities may also generate temporary odors from equipment exhaust, asphalt paving, and architectural coatings. These construction-related odors are intermittent, short-term, and confined to the immediate work area. By the time odor emissions disperse to sensitive receptors, they are expected to be diluted well below levels of concern. Consequently, odor impacts associated with construction activities are considered less than significant.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.3-3 Air Quality

3.3.2 Project-Specific Impacts
Where available, the significance criteria established by the applicable air quality management district or air
pollution control district may be relied upon to make the following determinations. Would the project:

New
Potentially
Significant
Impact or
Increased
Significant
Impact
Significant
Impact
Already
Identified
in the
General
Plan EIR
Less Than
Significant
Impact
With
General
Plan EIR
Mitigation
and/or
COAs
Less Than
Significant
Impact
No
Impact
a. Conflict with or obstruct implementation of the
applicable air quality plan? 
b. Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is
non-attainment under an applicable Federal or State
ambient air quality standard?

c. Expose sensitive receptors to substantial pollutant
concentrations? 
d. Result in other emissions (such as those leading to
odors) adversely affecting a substantial number of
people?

a) Conflict with or obstruct implementation of the applicable air quality plan? Less than Significant Impact. The General Plan EIR analyzed consistency with the SCAQMD’s 2012 AQMP, which was the latest version when the General Plan EIR was prepared. The 2012 AQMP incorporated scientific and technological information and planning assumptions from the SCAG’s 2012–2035 Regional Transportation Plan/Sustainable Communities Strategy (2012–2035 RTP/SCS).

However, these documents have since been updated. On December 2, 2022, the SCAQMD Governing Board adopted the 2022 AQMP. The 2022 AQMP incorporates the latest scientific and technical information as well as planning assumptions, including the latest applicable growth assumptions (including the City of San Clemente’s General Plan buildout assumptions) and updated emission inventory methodologies for various source categories. While SCAG has recently updated and adopted its RTP/SCS, SCAQMD has not released an updated AQMP that utilizes information and data from Connect SoCal 2024. As such, this consistency analysis is based on the 2022 AQMP and the RTP/SCS.

The SCAQMD considers projects that are consistent with the AQMP, which is intended to bring the Basin into attainment for all criteria pollutants, to also have less than significant cumulative impacts.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.3-4 Air Quality
The SCAQMD’s CEQA Air Quality Handbook provides the following criteria to evaluate the consistency of a project with applicable air quality plans:
4 • Criterion 1: Will the project result in any of the following:
o An increase in the frequency or severity of existing air quality violations; o Cause or contribute to new air quality violations; or o Delay timely attainment of air quality standards or the interim emission reductions specified in the AQMP?
• Criterion 2: Will the project exceed the assumptions utilized in preparing the AQMP? o Would the project be consistent with the population, housing, and employment growth projections utilized in the preparation of the AQMP? o Would the project implement all feasible air quality mitigation measures? o Would the project be consistent with the land use planning strategies set forth in the AQMP?
CRITERION 1
With respect to the first criterion, SCAQMD methodologies require that an air quality analysis for a project include forecasts of project emissions in relation to contributing to air quality violations and delay of attainment.
a) Would the project result in an increase in the frequency or severity of existing air quality violations? Since the consistency criteria identified under the first criterion pertains to pollutant concentrations, rather than to total regional emissions, an analysis of the project’s pollutant emissions relative to localized pollutant concentrations is used as the basis for evaluating project consistency. As discussed in Response 3.3.2(c), localized concentrations of CO, NOX, particulate matter less than 10 microns in diameter (PM10), and PM2.5 would be less than significant during project construction and operations. Therefore, the proposed project would not result in an increase in the frequency or severity of existing air quality violations. 5 b) Would the project cause or contribute to new air quality violations? As discussed in Response 3.3.2(b), the proposed project would result in emissions that are below the SCAQMD thresholds. Therefore, the project would not have the potential to cause or affect a violation of the ambient air quality standards. 4 SCAQMD is in the process of developing an Air Quality Analysis Guidance Handbook to replace the 1993 CEQA Air Quality Handbook. SCAQMD has not provided supplemented information regarding consistency analysis while the new handbook is being prepared, therefore the criteria in the 1993 CEQA Air Quality Handbook are used. 5 Due to the role reactive organic gases (ROGs) plays in ozone formation, it is classified as a precursor pollutant and only a regional emissions threshold has been established.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.3-5 Air Quality
c) Would the project delay timely attainment of air quality standards or the interim emissions reductions specified in the AQMP?
The proposed project would result in less than significant impacts with regard to regional and localized concentrations during project construction and operations; refer to Responses

3.3.2(b) and 3.3.2(c). As such, the project would not delay the timely attainment of air quality standards or 2022 AQMP emissions reductions.

CRITERION 2
With respect to the second criterion for determining consistency with SCAQMD and SCAG air quality policies, it is important to recognize that air quality planning within the SCAB focuses on attainment of ambient air quality standards at the earliest feasible date. Projections for achieving air quality goals are based on assumptions regarding population, housing, and growth trends. Thus, the SCAQMD’s second criterion for determining project consistency focuses on whether the proposed project exceeds the assumptions utilized in preparing the forecasts presented in the 2022 AQMP. Determining whether a project exceeds the assumptions reflected in the 2022 AQMP involves the evaluation of the three criteria outlined below. The following discussion provides an analysis of each of these criteria. a) Would the project be consistent with the population, housing, and employment growth projections utilized in the preparation of the AQMP?
A project is consistent with the 2022 AQMP in part if it is consistent with the population, housing, and employment assumptions that were used in the development of the 2022 AQMP.

In the case of the 2022 AQMP, three sources of data form the basis for the projections of air pollutant emissions: the City of San Clemente General Plan, SCAG’s regional growth forecast, and the SCAG RTP/SCS. The RTP/SCS also provides socioeconomic forecast projections of regional population growth.

According to the City’s online mapping tool City of San Clemente Community Map, the project site is designated as Downtown Mixed-Use 1 (MU1) by the City’ Centennial General Plan (General Plan) Land Use Map. 6 Specifically, the project site lies within the Mixed-Use 1 zoning district and is subject to the Central Business (CB), Architectural Overlay (A), and Coastal Zone (CZ) overlays (MU1-CB-A-CZ).

The project proposes a three-story, 61-room boutique hotel featuring a pool, café, roof-top restaurant with amplified music, and a subterranean parking garage with 104 parking stalls. As detailed in Section 3.11, Land Use and Planning, the project site’s MU1 land use designation is intended to create a vertical or horizontal mix of Neighborhood Serving Commercial and Community Serving Commercial uses, with multi-family housing on the second floor or higher. The MU1 designation allows for a maximum of 24.0 units per gross acre or 36.0 units per net acre for residential development, a maximum 1.00 FAR for commercial development, and a maximum 2.00 FAR for mixed-use projects. The proposed hotel building area (hotel 6 City of San Clemente, Centennial General Plan, General Plan Land Use Map, amended October 18, 2022.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.3-6 Air Quality
and restaurant building area) is approximately 30,034 square feet and would be constructed on an approximately 32,030-square foot site. Thus, the project would have a 0.94 FAR and meet the FAR requirement for commercial development under the MU1 designation. The proposed project is a conditionally permitted use in the MU1 zone as shown in Table 17.40.030, MixedUse Zone Uses, of the Municipal Code. As described in Section 1.5, Permits and Approvals, the project proposes a Conditional Use Permit for the proposed hotel use. Additionally, Table

3.11-2, Zoning Code Project Consistency Analysis, analyzes the project’s consistency with applicable MU1 development standards. As such, the project is consistent with the General Plan designation and zoning.

Overall, the total building area (including hotel space, amenities, and garage space) would be approximately 77,308 square feet. As the project would be consistent with the site’s land use and zoning, the General Plan EIR accounted for the proposed development within the retail/service buildout total and employment projections. Since the project would not provide residential uses on a parcel designated for mixed-use, the project would not provide housing opportunities in the City but would provide employment opportunities in a housing rich area.

Further, as detailed in Section 3.14, Population and Housing, the project would not result in substantial increase in employment or population. Therefore, the proposed project’s forecast population growth and VMT would be consistent with the 2022 AQMP’s assumed population growth and VMT for the proposed project site. It is also noted that the project’s construction and operational air emissions would not exceed the SCAQMD regional thresholds, and localized emissions during construction and operations would not exceed SCAQMD localized significance thresholds (LST); refer to Responses 3.3.2(b) and 3.3.2(c) below for further analysis. Therefore, the proposed project would not result in a long-term impact on the region’s ability to meet State and federal air quality standards as it has already been contemplated in the General Plan and the 2022 AQMP. As such, the proposed project would be consistent with this criterion.
b) Would the project implement all feasible air quality mitigation measures? Compliance with all feasible SCAQMD emission reduction rules and measures would be required, as discussed in Responses 3.3.2(b) and 3.3.2(c). As such, the proposed project meets this 2022 AQMP consistency criterion and no mitigation measures are required. c) Would the project be consistent with the land use planning strategies set forth in the AQMP? Land use planning strategies set forth in the 2022 AQMP are primarily based on the 2020- 2045 RTP/SCS. The San Clemente Metrolink Station is located approximately 200 feet further south and southwest of the project site. Bus stops serving Orange County Transportation Authority (OCTA), Metrolink, and San Clemente Trolley bus lines are provided along East Avenida Pico and North El Camino Real. Further, the project would also provide electric vehicle (EV) parking spaces to promote alternative transportation options. Therefore, the project would be consistent with the actions and strategies of the 2020-2045 RTP/SCS.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.3-7 Air Quality
In conclusion, the determination of 2022 AQMP consistency is primarily concerned with the longterm influence of a project on air quality in the SCAB. The proposed project would not result in a long-term impact on the region’s ability to meet State and federal air quality standards as it has already been contemplated in the General Plan and the 2022 AQMP. Further, the proposed project’s longterm influence on air quality in the SCAB would also be consistent with the SCAQMD and SCAG’s goals and policies and is considered consistent with the 2022 AQMP. Project impacts related to consistency with the 2022 AQMP are less than significant. b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or State ambient air quality standard?
Less than Significant Impact With General Plan EIR Mitigation and/or COAs.

CRITERIA POLLUTANTS
Carbon Monoxide (CO)
CO is an odorless, colorless toxic gas that is emitted by mobile and stationary sources as a result of incomplete combustion of hydrocarbons or other carbon-based fuels. In cities, automobile exhaust can cause as much as 95 percent of all CO emissions. CO replaces oxygen in the body’s red blood cells. Individuals with a deficient blood supply to the heart, patients with diseases involving heart and blood vessels, fetuses (unborn babies), and patients with chronic hypoxemia (oxygen deficiency) as seen in high altitudes are most susceptible to the adverse effects of CO exposure. People with heart disease are also more susceptible to developing chest pain when exposed to low levels of carbon monoxide.

Ozone (O3)
O3 occurs in two layers of the atmosphere. The layer surrounding the Earth’s surface is the troposphere. The troposphere extends approximately 10 miles above ground level, where it meets the second layer, the stratosphere. The stratosphere (the “good” ozone layer) extends upward from about 10 to 30 miles and protects life on Earth from the sun’s harmful ultraviolet rays. “Bad” O3 is a photochemical pollutant, and needs volatile organic compounds (VOCs), NOx, and sunlight to form; therefore, VOCs and NOx are O3 precursors. To reduce O3 concentrations, it is necessary to control the emissions of these O3 precursors. Significant O3 formation generally requires an adequate amount of precursors in the atmosphere and a period of several hours in a stable atmosphere with strong sunlight. High O3 concentrations can form over large regions when emissions from motor vehicles and stationary sources are carried hundreds of miles from their origins.

While O3 in the upper atmosphere (stratosphere) protects the Earth from harmful ultraviolet radiation, high concentrations of ground-level O3 (in the troposphere) can adversely affect the human respiratory system and other tissues. O3 is a strong irritant that can constrict the airways, forcing the respiratory system to work hard to deliver oxygen. Individuals exercising outdoors, children, and people with preexisting lung disease such as asthma and chronic pulmonary lung disease are considered to be the most

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.3-8 Air Quality
susceptible to the health effects of O3. Short-term exposure (lasting for a few hours) to O3 at elevated levels can result in aggravated respiratory diseases such as emphysema, bronchitis and asthma, shortness of breath, increased susceptibility to infections, inflammation of the lung tissue, increased fatigue, as well as chest pain, dry throat, headache, and nausea.

Nitrogen Dioxide (NO2)
NOX are a family of highly reactive gases that are a primary precursor to the formation of groundlevel ozone and react in the atmosphere to form acid rain. NO2 (often used interchangeably with NOX) is a reddish-brown gas that can cause breathing difficulties at elevated levels. Peak readings of NO2 occur in areas that have a high concentration of combustion sources (e.g., motor vehicle engines, power plants, refineries, and other industrial operations). NO2 can irritate and damage the lungs and lower resistance to respiratory infections such as influenza. The health effects of short-term exposure are still unclear. However, continued or frequent exposure to NO2 concentrations that are typically much higher than those normally found in the ambient air may increase acute respiratory illnesses in children and increase the incidence of chronic bronchitis and lung irritation. Chronic exposure to NO2 may aggravate eyes and mucus membranes and cause pulmonary dysfunction.

Coarse Particulate Matter (PM10)
PM10 refers to suspended particulate matter, which is smaller than 10 microns or ten one-millionths of a meter. PM10 arises from sources such as road dust, diesel soot, combustion products, construction operations, and dust storms. PM10 scatters light and significantly reduces visibility. In addition, these particulates penetrate into the lungs and can potentially damage the respiratory tract. On June 19, 2003, the California Air Resources Board (CARB) adopted amendments to the Statewide 24-hour particulate matter standards based upon requirements set forth in the Children’s Environmental Health Protection Act (Senate Bill 25).

Fine Particulate Matter (PM2.5)
Due to recent increased concerns over health impacts related to PM2.5, both State and federal PM2.5 standards have been created. Particulate matter impacts primarily affect infants, children, the elderly, and those with pre-existing cardiopulmonary disease. In 1997, the U.S. Environmental Protection Agency (EPA) announced new PM2.5 standards. Industry groups challenged the new standard in court and the implementation of the standard was blocked. However, upon appeal by the EPA, the United States Supreme Court reversed this decision and upheld the EPA’s new standards. On January 5, 2005, the EPA published a final rule in the Federal Register that designates the SCAB as a nonattainment area for federal PM2.5 standards. On June 20, 2002, CARB adopted amendments for Statewide annual ambient particulate matter air quality standards. These standards were revised and established due to increasing concerns by CARB that previous standards were inadequate, as almost everyone in California is exposed to levels at or above the current State standards during some parts of the year, and the Statewide potential for significant health impacts associated with particulate matter exposure was determined to be large and wide-ranging.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.3-9 Air Quality
Sulfur Dioxide (SO2)
SO2 is a colorless, irritating gas with a rotten egg smell; it is formed primarily by the combustion of sulfur-containing fossil fuels. SO2 is often used interchangeably with SOx. Exposure of a few minutes to low levels of SO2 can result in airway constriction in some asthmatics.

Volatile Organic Compounds (VOC)
VOCs are hydrocarbon compounds (any compound containing various combinations of hydrogen and carbon atoms) that exist in the ambient air. VOCs contribute to the formation of smog through atmospheric photochemical reactions and may be toxic. Compounds of carbon (also known as organic compounds) have different levels of reactivity; that is, they do not react at the same speed or do not form O3 to the same extent when exposed to photochemical processes. VOCs often have an odor, and some examples include gasoline, alcohol, and the solvents used in paints. Exceptions to the VOC designation include: CO, CO2, carbonic acid, metallic carbides or carbonates, and ammonium carbonate. VOCs are a criteria pollutant since they are a precursor to O3, which is a criteria pollutant.

The SCAQMD uses the terms VOC and ROG interchangeably (see below).

Reactive Organic Gases (ROG)
Similar to VOC, ROG are also precursors in forming O3 and consist of compounds containing methane, ethane, propane, butane, and longer chain hydrocarbons, which are typically the result of some type of combustion/decomposition process. Smog is formed when ROG and NOx react in the presence of sunlight. ROGs are a criteria pollutant since they are a precursor to O3, which is a criteria pollutant.

CONSTRUCTION EMISSIONS
Project construction activities would generate short-term criteria air pollutant emissions. The criteria air pollutants of primary concern at the proposed project site include ozone-precursor pollutants (i.e., ROG and NOx) and PM10 and PM2.5. Construction-related emissions are short term and temporary, lasting only while construction activities occur, but would be considered a significant air quality impact if the volume of pollutants generated exceeds the SCAQMD’s thresholds of significance.

Project construction would primarily generate temporary criteria pollutants from construction equipment operation on-site and construction worker vehicle trips to and from the project site, and from construction material deliveries to and from the project site. Construction input data for California Emissions Estimator Model (CalEEMod) version 2022.1 includes, but is not limited to, (1) the anticipated start and finish dates of construction activity; (2) inventories of construction equipment to be used; and (3) areas to be excavated and graded. Construction emissions were quantified by estimating the types and quantity of equipment that would be used on-site during each construction phase, as provided by the model defaults. CalEEMod also estimates off-site emissions from worker, vendor, and hauling truck trips.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.3-10 Air Quality
The construction is expected to last approximately 18 months and includes grading, building construction, paving, and architectural coating phases. The project is expected to export approximately 14,300 cubic yards of earthwork material during grading. The analysis of daily construction emissions has been prepared utilizing CalEEMod. Refer to Appendix B, Air Quality/GHG/Energy Data, for the CalEEMod outputs and results. Table 3.3-1, Maximum Daily Construction Air Emissions, presents the anticipated daily short-term construction emissions.

Table 3.3-1
Maximum Daily Construction Air Emissions
Year Pollutant (pounds per day)1,2
ROG NOX CO SO2 PM10 PM2.5
Year 1 Emissions 1.09 12.50 11.50 0.03 2.66 1.31
Year 2 Emissions 3.90 5.86 10.00 0.02 0.77 0.31
Maximum Daily Emissions 3.90 12.50 11.50 0.03 2.66 1.31 SCAQMD Thresholds 75 100 550 150 150 55
Threshold Exceeded? No No No No No No
Notes: ROG = reactive organic gases; NOX = nitrogen oxides; CO = carbon monoxide; SO2 = Sulfur Dioxide; PM10 = particulate matter smaller than 10 microns; PM2.5 = particulate matter smaller than 2.5 microns Notes:

1. Emissions were calculated using CalEEMod version 2022.1. Higher emissions between winter and summer are represented as the worst-case scenario.

2. The reduction/credits for construction emissions are based on “mitigation” included in CalEEMod and are required by the SCAQMD Rules. The adjustments applied in CalEEMod include the following: properly maintain mobile and other construction equipment; replace ground cover in disturbed areas quickly; water exposed surfaces three times daily; cover stockpiles with tarps; and limit speeds on unpaved roads to 15 miles per hour. The emissions results in this table represent the “mitigated” emissions shown in Appendix B.

Source: Refer to Appendix B, Air Quality/GHG/Energy Data.

Fugitive Dust Emissions
Construction activities are a source of fugitive dust emission that may have a substantial, temporary impact on local air quality. In addition, fugitive dust may be a nuisance to those living and working in the project area. Fugitive dust emissions are associated with land clearing, ground excavation, cut-andfill, and truck travel on unpaved roadways (including demolition as well as construction activities).

Fugitive dust emissions vary substantially from day to day, depending on the level of activity, specific operations, and weather conditions. Fugitive dust from grading, excavation and construction is expected to be short-term and would cease upon project completion. Most of this material is inert silicates, rather than the complex organic particulates released from combustion sources, which are more harmful to health.

Dust (larger than 10 microns) generated by such activities usually becomes more of a local nuisance than a serious health problem. Of particular health concerns is the amount of PM10 generated as part of fugitive dust emissions. PM10 poses a serious health hazard alone or in combination with other pollutants. PM2.5 is mostly produced by mechanical processes. These include automobile tire wear, industrial processes such as cutting and grinding, and re-suspension of particles from the ground or

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.3-11 Air Quality
road surfaces by wind and human activities such as construction or agriculture. PM2.5 is mostly derived from combustion sources, such as automobiles, trucks, and other vehicle exhaust, as well as from stationary sources. These particles are either directly emitted or are formed in the atmosphere from the combustion of gases such as NOX and SOX combining with ammonia. PM2.5 components from material in the Earth’s crust, such as dust, are also present, with the amount varying in different locations.

The project would implement required SCAQMD dust control techniques (i.e., daily watering), limitations on construction hours, and adhere to SCAQMD Rules 402 and 403 (which require watering of inactive and perimeter areas, track out requirements, etc.), to reduce PM10 and PM2.5 emissions (COA 1.9). Compliance with applicable SCAQMD Rules 402 and 403 are accounted for in the CalEEMod results. As depicted in Table 3.3-1, total PM10 and PM2.5 emissions would not exceed the SCAQMD thresholds during construction. Thus, PM10 and PM2.5 emissions impacts associated with project construction would be less than significant.

Construction Equipment and Worker Vehicle Exhaust
Exhaust emissions from construction activities include emissions associated with the transport of machinery and supplies to and from the project site, construction worker commutes to the project site, emissions produced on-site as the equipment is used, and emissions from trucks transporting materials to/from the site. As presented in Table 3.3-1, construction equipment and worker vehicle exhaust emissions (i.e., ROG, NOX, CO, SO2, PM10, and PM2.5) would not exceed the established SCAQMD thresholds for all criteria pollutants. Therefore, impacts in this regard would be less than significant
ROG Emissions

In addition to gaseous and particulate emissions, the application of asphalt and surface coatings create ROG emissions, which are O3 precursors. In accordance with the methodology prescribed by the SCAQMD, ROG emissions associated with paving have been quantified with the CalEEMod model.

As required by SCAQMD Rule 1113, all architectural coatings would comply with specifications on painting practices as well as regulation on the ROG content of paint. ROG emissions associated with the proposed project would be less than significant; refer to Table 3.3-1.

Total Daily Construction Emissions

As indicated in Table 3.3-1, criteria pollutant emissions during construction of the proposed project would not exceed the SCAQMD significance thresholds. Thus, total construction related air emissions would be less than significant.

NATURALLY OCCURRING ASBESTOS
Asbestos is a term used for several types of naturally occurring fibrous minerals that are a human health hazard when airborne. The most common type of asbestos is chrysotile, but other types such as tremolite and actinolite are also found in California. Asbestos is classified as a known human

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.3-12 Air Quality
carcinogen by State, federal, and international agencies and was identified as a toxic air contaminant by CARB in 1986.

Asbestos can be released from serpentinite and ultramafic rocks when the rock is broken or crushed.

At the point of release, the asbestos fibers may become airborne, causing air quality and human health hazards. These rocks have been commonly used for unpaved gravel roads, landscaping, fill projects, and other improvement projects in some localities. Asbestos may be released to the atmosphere due to vehicular traffic on unpaved roads, during grading for development projects, and at quarry operations. All of these activities may have the effect of releasing potentially harmful asbestos into the air. Natural weathering and erosion processes can act on asbestos bearing rock and make it easier for asbestos fibers to become airborne if such rock is disturbed. According to the California Department of Conservation Division of Mines and Geology, serpentinite and ultramafic rocks are not known to occur within the project area.7 Thus, no impacts would occur in this regard.

OPERATIONAL EMISSIONS
Long-term operational air quality impacts consist of mobile source emissions generated from projectrelated traffic and emissions from area and energy sources. Emissions associated with each source area detailed in Table 3.3-2, Maximum Daily Operational Air Emissions, are discussed below.

Table 3.3-2
Maximum Daily Operational Air Emissions
Emissions Source Pollutant (pounds per day)
ROG NOX CO SOX PM10 PM2.5
Summer Operational Emissions
Mobile 5.27 4.33 52.00 0.14 14.10 3.63
Area 1.24 0.03 3.14 <0.01 0.01 <0.01
Energy 0.02 0.39 0.33 <0.01 0.03 0.03
Total Emissions 6.53 4.75 55.50 0.15 14.10 3.66
SCAQMD Significance Threshold 55 55 550 150 150 55
Threshold Exceeded? No No No No No No
Winter Operational Emissions
Mobile 5.23 4.71 47.70 0.04 14.10 3.63
Area 0.72 0.00 0.00 0.00 0.00 0.00
Energy 0.02 0.39 0.33 <0.01 0.03 0.03
Total Emissions 5.97 5.10 48.00 0.14 14.10 3.66
SCAQMD Significance Threshold 55 55 550 150 150 55
Threshold Exceeded? No No No No No No
Notes: CO = carbon monoxide; ROG = reactive organic gases; NOX = nitrogen oxides; PM10 = particulate matter smaller than 10 microns; PM2.5 = particulate matter smaller than 2.5 microns Source: Refer to Appendix B, Air Quality/GHG/Energy Data. 7 California Department of Conservation Division of Mines and Geology, A General Location Guide for Ultramafic Rocks in California – Areas More Likely to Contain Naturally Occurring Asbestos Report, August 2000.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.3-13 Air Quality
Mobile Source Emissions
Mobile sources are emissions from motor vehicles, including tailpipe and evaporative emissions.

Depending upon the pollutant being discussed, the potential air quality impact may be of either regional or local concern. For example, ROG, NOX, SOX, PM10, and PM2.5 are all pollutants of regional concern (NOX and ROG react with sunlight to form O3 [photochemical smog], and wind currents readily transport SOX, PM10, and PM2.5). However, CO tends to be a localized pollutant, dispersing rapidly at the source. Project-generated vehicle emissions have been estimated using CalEEMod.

Based on the San Clemente 1801 N. El Camino Real – VMT Screening Assessment (VMT Screening Assessment), prepared by Michael Baker International and dated February 2, 2026; refer to Appendix H.2, VMT Screening Assessment, the project would generate a total of 1,631 average daily trips (ADT).

As shown in Table 3.3-2, emissions generated by vehicle traffic associated with the project would not exceed established SCAQMD thresholds.

Area Source Emissions
Area source emissions would be generated from consumer products, architectural coatings, and landscaping. The project’s criteria pollutant emissions from area sources would not exceed the established thresholds; refer to Table 3.3-2.

Energy Source Emissions
In terms of emissions from energy consumption, the primary use of electricity by the project would be for space heating and cooling, water heating, ventilation, lighting, appliances, landscaping equipment, and electronics. Criteria air pollutant emissions from electricity use were not quantified since criteria pollutants emissions occur at the site of the power plant, which is off-site. Therefore, only emissions associated with on-site natural gas consumption are qualified in CalEEMod. As shown in Table 3.3-2, the project’s criteria pollutant emissions associated with energy sources would be zero and would not exceed established thresholds.

Total Daily Operational Emissions
Based on the proposed land uses and operational characteristics, Table 3.3-2, summarizes the CalEEMod estimated emissions from proposed project operations and indicates the proposed project’s mobile, area, and energy source emissions combined would not exceed SCAQMD thresholds for maximum daily emissions for any criteria air pollutants. As such, the proposed project would not violate any air quality standards or contribute substantially to an existing or projected air quality violation. The proposed project’s operational air quality impacts would be less than significant.

AIR QUALITY HEALTH IMPACTS
Adverse health effects induced by criteria pollutant emissions are highly dependent on a multitude of interconnected variables (e.g., cumulative concentrations, local meteorology and atmospheric conditions, and the number and character of exposed individual [e.g., age, gender]). In particular, ozone precursors VOCs and NOx affect air quality on a regional scale. Health effects related to ozone

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.3-14 Air Quality
are therefore the product of emissions generated by numerous sources throughout a region. Existing models have limited sensitivity to small changes in criteria pollutant concentrations, and, as such, translating project-generated criteria pollutants to specific health effects or additional days of nonattainment would produce meaningless results. In other words, the project’s less than significant increases in regional air pollution from criteria air pollutants would have nominal or negligible impacts on human health.

As noted in the Brief of Amicus Curiae by SCAQMD, the SCAQMD acknowledged it would be extremely difficult, if not impossible to quantify health impacts of criteria pollutants for various reasons including modeling limitations as well as where in the atmosphere air pollutants interact and form.8 Further, as noted in the Brief of Amicus Curiae by the San Joaquin Valley Air Pollution Control District (SJVAPCD), SJVAPCD has acknowledged that currently available modeling tools are not equipped to provide a meaningful analysis of the correlation between an individual development project’s air emissions and specific human health impacts.9 The SCAQMD acknowledges that health effects quantification from ozone, as an example is correlated with the increases in ambient level of ozone in the air (concentration) that an individual person breathes. SCAQMD’s Brief of Amicus Curiae states that it would take a large amount of additional emissions to cause a modeled increase in ambient ozone levels over the entire region. The SCAQMD states that based on their own modeling in the SCAQMD’s 2012 Air Quality Management Plan, a reduction of 432 tons (864,000 pounds) per day of NOX and a reduction of 187 tons (374,000 pounds) per day of VOCs would reduce ozone levels at highest monitored site by only nine parts per billion. As such, the SCAQMD concludes that it is not currently possible to accurately quantify ozonerelated health impacts caused by NOX or VOC emissions from relatively small projects (defined as projects with regional scope) due to photochemistry and regional model limitations. As such, for the purpose of this analysis, since the project would not exceed SCAQMD thresholds for construction and operational air emissions, the project would have a less than significant impact for air quality health impacts as well.

CUMULATIVE IMPACTS
With respect to the proposed project’s construction-related air quality emissions and cumulative Basin-wide conditions, the SCAQMD has developed strategies to reduce criteria pollutant emissions outlined in the 2022 AQMP pursuant to FCAA mandates. As such, the proposed project would comply with SCAQMD Rule 403 requirements and the adopted 2022 AQMP emissions control measures. Rule 403 requires that fugitive dust be controlled with the best available control measures in order to reduce dust so that it does not remain visible in the atmosphere beyond the property line of the proposed project. Per SCAQMD rules and mandates, as well as the CEQA requirement that significant impacts be mitigated to the extent feasible, these same requirements (i.e., Rule 403 8 South Coast Air Quality Management District, Application of the South Coast Air Quality Management District for Leave to File Brief of Amicus Curiae in Support of Neither Party and Brief of Amicus Curiae. In the Supreme Court of California. Sierra Club, Revive the San Joaquin, and League of Women Voters of Fresno v. County of Fresno, April 3, 2015. 9 San Joaquin Valley Air Pollution Control District, Application for Leave to File Brief of Amicus Curiae Brief of San Joaquin Valley Unified Air Pollution Control District in Support of Defendant and Respondent, County of Fresno and Real Party In Interest and Respondent, Friant Ranch, L.P. In the Supreme Court of California. Sierra Club, Revive the San Joaquin, and League of Women Voters of Fresno v. County of Fresno, April 13, 2015.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.3-15 Air Quality
compliance, the implementation of all feasible mitigation measures, and compliance with adopted 2022 AQMP emissions control measures) would also be imposed on construction projects throughout the Basin, which would include related projects.

According to the SCAQMD CEQA Air Quality Handbook, project-related emissions that fall below the established construction and operational thresholds should be considered less than significant unless there is pertinent information to the contrary. As discussed previously, the proposed project would not result in short- or long-term air quality impacts, as emissions would not exceed the SCAQMD adopted construction or operational thresholds. Additionally, adherence to SCAQMD rules and regulations would alleviate potential impacts related to cumulative conditions on a projectby-project basis. As a result, the proposed project would not contribute a cumulatively considerable net increase of any nonattainment criteria pollutant. Therefore, the project’s incremental construction and operational impacts would be less than cumulatively considerable and impacts in this regard are less than significant.

CONCLUSION
In summary, as shown in Table 3.3-1 and Table 3.3-2, the project’s emissions would not exceed the SCAQMD adopted construction and operational thresholds. As such, the proposed project would not violate any air quality standards or contribute substantially to an existing or projected air quality violation and would not result in significant short- or long-term air quality impacts. A less than significant impact would occur in this regard.

Applicable Conditions of Approval (COA): Refer to Response 3.1.2(d), COA 1.9. c) Expose sensitive receptors to substantial pollutant concentrations?

Less than Significant Impact With General Plan EIR Mitigation and/or COAs. LSTs were developed in response to SCAQMD Governing Boards’ Environmental Justice Enhancement Initiative (I-4). The SCAQMD provided the Final Localized Significance Threshold Methodology for guidance. The LST methodology assists lead agencies in analyzing localized air quality impacts. The SCAQMD provides the LST lookup tables for one-, two-, and five-acre projects emitting CO, NOX, PM2.5, and/or PM10. The project is located within Source Receptor Area (SRA) 21, Capistrano Valley.

CONSTRUCTION LST
The SCAQMD guidance on applying CalEEMod to LSTs specifies the number of acres a particular piece of equipment would likely disturb per day.10 SCAQMD provides LST thresholds for one-, two- , and five-acre site disturbance areas; SCAQMD does not provide LST thresholds for projects over five acres. Based on CalEEMod, the project would actively disturb approximately less than an acre (approximately 0.75 acre) per day during the grading phase of construction. However, because 10 The number of acres represent the total acres traversed by grading equipment. To properly grade a piece of land, multiple passes with equipment may be required. The disturbance acreage is based on the equipment list and days of the grading phase according to the anticipated maximum number of acres a given piece of equipment can pass over in an 8-hour workday.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.3-16 Air Quality
SCAQMD does not provide LST thresholds for intermediate acreages such as less than an acre, the one-acre LST thresholds were conservatively applied in this analysis. Therefore, by applying thresholds for a smaller disturbance area than what is actually expected, the analysis provides a more conservative assessment of potential air quality impacts on nearby sensitive receptors.

The SCAQMD recommends that the nearest sensitive receptor be considered when determining a project’s localized air quality impacts. Sensitive receptors are defined as facilities or land uses that include members of the population that are particularly sensitive to the effects of air pollutants, such as children, the elderly, and people with illnesses. Examples of these sensitive receptors are residences, schools, hospitals, and daycare centers. CARB has identified the following groups of individuals as the most likely to be affected by air pollution: the elderly over 65, children under 14, athletes, and persons with cardiovascular and chronic respiratory diseases such as asthma, emphysema, and bronchitis.

The nearest sensitive receptors to the project site are the existing single-family residences located approximately 450 feet (137 meters) southwest of the project site. These sensitive land uses may be potentially affected by air pollutant emissions generated during on-site construction activities. LST thresholds are provided for distances to sensitive receptors of 25, 50, 100, 200, and 500 meters.

Although construction activities would occur further away (approximately 137 meters) from these sensitive receptors to the west, as a conservative analysis, the LST values for 100 meters were used.

Table 3.3-3, Localized Emissions Significance During Construction, shows the localized construction-related emissions for NOX, CO, PM2.5, and PM10 compared to LSTs for SRA 21. It is noted that the localized emissions presented in Table 3.3-3 are less than those in Table 3.3-1 because localized emissions include only on-site emissions (e.g., from construction equipment and fugitive dust) and do not include off-site emissions (e.g., from hauling activities). As shown in Table 3.3-3, the project’s localized construction emissions would not exceed the LSTs for SRA 18. Therefore, the localized significance impacts from project-related construction activities would be less than significant.

Table 3.3-3
Localized Emissions Significance During Construction
Source Pollutant (pounds/day)
NOX CO PM10 PM2.5
Maximum Daily Emissions1 9.19 9.69 1.80 1.06
Localized Significance Threshold2 108.00 1,234.00 10.00 6.00 Thresholds Exceeded? No No No No
Notes:

1. The grading phase emissions would present the worst-case scenario for NOX, CO, PM10, and PM2.5.

2. The Localized Significance Threshold (LST) was determined using Appendix C of the SCAQMD’s Final Localized Significant Threshold Methodology guidance document for pollutants NOX, CO, PM10, and PM2.5. The LST was based on the anticipated daily acreage disturbance for construction (one acres) and distance to sensitive receptor (100 meters) for SRA 21, Capistrano Valley.

Source: Refer to Appendix B, Air Quality/GHG/Energy Data.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.3-17 Air Quality

OPERATIONS LST
According to SCAQMD LST methodology, LSTs would apply to operational activities if the project includes stationary sources or attracts mobile sources that may spend extended periods queuing and idling at the site (e.g., warehouse or transfer facilities). The proposed project is mixed-use hotel project and would not attract mobile sources that would spend extended periods queuing and idling at the site. Therefore, no substantial vehicle queuing or idling on-site for extended periods of time are anticipated. Thus, due to the lack of such emissions, no long-term LST analysis is needed. Operational LST impacts would be less than significant in this regard.

CARBON MONOXIDE HOTSPOTS
CO emissions are a function of vehicle idling time, meteorological, and traffic flow. Under certain extreme meteorological conditions, CO concentrations near a congested roadway or intersection may reach unhealthful levels (e.g., adversely affecting residents, school children, hospital patients, and the elderly).

The SCAB is designated as an attainment/maintenance area for the federal CO standards and an attainment area under State standards. There has been a decline in CO emissions even though VMT on U.S. urban and rural roads have increased; estimated anthropogenic CO emissions have decreased 68 percent between 1990 and 2014. In 2014, mobile sources accounted for 82 percent of the nation’s total anthropogenic CO emissions.11 Three major control programs have contributed to the reduced per-vehicle CO emissions, including exhaust standards, cleaner burning fuels, and motor vehicle inspection/ maintenance programs. According to the SCAQMD CEQA Air Quality Handbook, a potential CO hotspot may occur at any location where the background CO concentration already exceeds 9.0 parts per million (ppm), which is the 8-hour California ambient air quality standard, the closet monitoring station to the project site that monitors CO concentration is the Anaheim – 812 West Vermont Street, located approximately 31.5 miles north of the project site. The most recent maximum one-hour average CO concentration at this monitoring station is available for 2025 and was measured at 2.098 ppm.12 Given that the background CO concentration does not currently exceed 9.0 ppm, a CO hotspot would not occur at the project site. Therefore, CO hotspot impacts would be less than significant.

CONCLUSION
In summary, as shown in Table 3.3-3, the project’s localized air quality emissions would not exceed the SCAQMD adopted construction and operational localized thresholds. As such, the proposed project would not result in project specific significant localized air quality impacts. A less than significant impact would occur in this regard.

Applicable Conditions of Approval (COA): Refer to Response 3.1.2(d), COA 1.9. 11 U.S. Environmental Protection Agency, Carbon Monoxide Emissions, https://cfpub.epa.gov/roe/indicator_pdf.cfm?i=10, accessed January 14, 2026. 12 California Air Resources Board, Air Quality Data, https://www.arb.ca.gov/aqmis2/aqdselect.php?tab=specialrpt, accessed January 14, 2026.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.3-18 Air Quality
d) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Less than Significant Impact. According to the SCAQMD CEQA Air Quality Handbook, land uses associated with odor complaints typically include agricultural uses, wastewater treatment plants, food processing plants, chemical plants, composting, refineries, landfills, dairies, and fiberglass molding.

The project does not contain land uses typically associated with emitting objectionable odors. Potential odor sources associated with the project may result from construction equipment exhaust and the application of asphalt and architectural coatings during construction activities and the temporary storage of typical solid waste (refuse) associated with the project’s (long-term operational) uses.

Standard construction requirements would minimize odor impacts from construction. The construction odor emissions would be temporary, short-term, and intermittent in nature and would cease upon completion of the respective phase of construction and, thus, is considered less than significant. It is expected that project-generated refuse would be stored in covered containers and removed at regular intervals in compliance with current solid waste regulations. The project would also be required to comply with SCAQMD Rule 402 to prevent occurrences of public nuisances.

Therefore, odors and other emissions (such as those leading to odors) associated with construction and operations activities of the project would be less than significant.

March 2026 3.4-1 Biological Resources

3.4 BIOLOGICAL RESOURCES

3.4.1 General Plan EIR Summary
Less Than Significant Impact. The City is geographically located within the U.S. Fish and Wildlife Service (USFWS) Orange County Southern Subregion Habitat Conservation Plan (HCP), which provides coverage for 32 plant and animal species, seven of which receive protection under the Federal Endangered Species Act (FESA).

Proposed changes in land use and land use intensity as part of General Plan implementation would be located predominantly in eight “Focus Areas” centered around Interstate 5 (I-5) and within the Rancho San Clementa neighborhood. Each Focus Area would experience a change in intensity and/or permitted use, as assigned by the General Plan, unique to its location within the City. The General Plan EIR found that development in accordance with proposed land use changes could allow for the introduction of development into currently undeveloped sites, resulting in loss of native vegetation and habitats that support sensitive species. Such land use changes that could impact biological resources would predominantly occur within six of the eight Focus Areas (excluding the Pier Bowl and South El Camino Real East of the I-5 Focus Areas), as well as at the Shorecliffs Golf Course and within designated open space within the City. Impacts to species could occur directly from habitat modification and removal and indirectly through increases in noise, light and glare, and altered drainage patterns.

According to the General Plan EIR, the Focus Areas lack natural habitat, and as such it was determined that changing the land use designations within the Focus Areas would not directly impact any sensitive species. However, sensitive species such as the California gnatcatcher can occur in coastal scrub habitats on hillsides that adjoin Focus Areas. Construction activities in these areas that adjoin habitat occupied by the California gnatcatcher could adversely impact this sensitive species as a result of disturbance during the nesting season. As such, the General Plan EIR included Mitigation Measure

5.3-1 to require that applicants of future development projects that disturb undeveloped land prepare a biological resources survey, which, depending on the results of the survey, could include: a focused habitat assessment, focused species survey(s), additional pre-construction special-status species survey(s), avoidance and minimization measures within the limits of wildlife corridors during construction, contractor training by a qualified biologist, and/or construction monitoring by a qualified biologist. Additionally, per General Plan EIR Mitigation Measure 5.3-2, any project applicants with the potential to impact a listed species during grading or construction would be required to obtain written authorization from USFWS for the “take” of that species. Following implementation of General Plan EIR Mitigation Measures 5.3-1 and 5.3-2, the General Plan EIR determined that construction within undeveloped areas and construction within areas where land use changes are proposed would result in less than significant impacts to special-status species.

In addition, the General Plan includes policies within the Natural Resources Element and Coastal Element that would reduce impacts to biological resources during construction and operation of future development projects. Policy NR-1.01 would require that the most current information available regarding sensitive biological resources is used to guide planning decisions; Policy NR-1.02 provides guidance for development within natural areas in a way that preserves biological resources; Policy NR-1.03 prohibits development within sensitive habitats, including Riparian Corridors, when feasible; Policy NR-1.04 defines the preservation of habitat of threatened and endangered species in place as the preferred habitat conservation strategy; Policy NR-1.05 encourages urban development

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.4-2 Biological Resources
within the costal canyons when such development improves the biological value and restores the function of the canyons; and Policy NR-1.06 states that the General Plan supports and follows the HCP and Habitat Management Program. Policy C-2.02 states that the City evaluates development projects as required under CEQA in order to protect the Coastal Zone; Policy C-2.05 prohibits encroachment of incompatible uses into coastal canyons and bluffs; Policy C-2.06 requires the use of native landscaping that is local to the region and consistent with the Coastal Zone (-CZ) Overlay District, and prohibits the planting of invasive species; Policy C-2.07 encourages native planting landscape restoration in coastal canyons and bluffs; Policy C-2.08 requires the protection of wetlands; Policy C-2.09 establishes coordination with State and federal resources protection agencies; Policy C2.10 establishes the protection of and development limitations within Environmentally Sensitive Habitat Areas (ESHAs); Policy C-2.11 provides guidelines for uses within the marine environment; and Policy C-2.12 discourages the introduction of non-native species.

The sensitive habitats in the City and its Sphere of Influence (SOI) include coastal sage scrub, coast live oak woodland and forest, and riparian communities such as mule fat scrub, southern willow scrub, and southern arroyo willow riparian forest. The majority of these sensitive habitats occur in land designated as Open Space-Publicly Owned or Open Space-Privately Owned, and would therefore not be impacted by implementation of the proposed General Plan. However, several patches of natural vegetation in the City are designated for residential development by the proposed General Plan, and as such the General Plan EIR determined that there would be potential for direct impacts to sensitive communities in these areas. With implementation of General Plan EIR Mitigation Measures 5.3-1 and

5.3-2, as well as applicable General Plan Policies NR-1.01, NR-1.02, NR-1.03, NR-1.04, NR-1.05, NR1.06, C-2.02, C-2.05, C-2.06, C-2.07, C-2.08, C-2.09, C-2.10, C-2.11, and C-2.12, it was determined that impacts to sensitive natural communities would be reduced to less than significant levels.

The General Plan EIR found that the ephemeral and intermittent streams distributed throughout the City and SOI, and areas identified as supporting riparian vegetation, are potential U.S. Army Corps of Engineers (USACE) and CDFW jurisdictional waters and wetlands. As such, the General Plan EIR concluded that projects considered for approval under the proposed General Plan could impact waters of the US, waters of the State, and wetlands, and impacts would be potentially significant. Such impacts would be subject to the requirements of applicable Section 404 permits from the USACE, Section 401 water quality certification, USFWS review, and CDFW 1600 Streambed Alteration Agreements.

Additionally, projects impacting waters of the US would be required to contract a qualified biologist to prepare a jurisdictional delineation to be incorporated into the CEQA documentation, per General Plan EIR Mitigation Measure 5.3-3, and projects impacting jurisdictional waters, wetlands, and riparian habitat under the jurisdiction of the USACE, CDFW, and/or San Diego Regional Water Quality Control Board (RWQCB) would be required to obtain any additional permits and adhere to any additional permit-related avoidance, minimization, and mitigation measures for impacts to jurisdictional resources, as specified by those agencies, per General Plan EIR Mitigation Measure 5.3-

4. Following adherence to General Plan EIR Mitigation Measures 5.3-3 and 5.3-4, as well as implementation of General Plan Policies NR-1.02, NR-1.03, NR-1.04, NR-1.05, and NR-1.06, it was determined that impacts to jurisdictional waters and wetlands would be reduced to less than significant levels.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.4-3 Biological Resources
The General Plan EIR identifies the major wildlife movement corridors as those within the HCP, which are located along the northern and northeastern boundaries of the City and in the SOI. The SOI is a preserve managed by the Donna O'Neill Land Conservancy and is identified as a nature preserve in the HCP. The General Plan does not propose any development in the SOI, and its status as a preserve indicates that it would not be developed in the future.

The lands along the northeastern and eastern borders of the City adjoin the Cristianitos Canyon habitat linkage, and are designated by the General Plan as Open Space-Privately Held. The open space lands along the northern border of the City that adjoin the Trampas Canyon habitat linkage are public open space, and no development would occur in this open space. Per General Plan EIR Mitigation Measure

5.3-5, any future development projects located within a designated open space or identified as a major linkage/corridor would be required to prepare a habitat connectivity evaluation, as well as implement General Plan Policies NR-1.02, NR-1.03, and NR-1.06 in order to reduce impacts to less than significant levels.

The General Plan EIR identified seven canyons as ESHAs, three of which (Calafia Canyon, Trafalgar Canyon, and Palizada Canyon) are entirely or partly within publicly owned open space; the remaining four are within areas already developed with residential land uses. As such, impacts to canyons designated as ESHAs were determined to be less than significant.

The General Plan Focus Areas that are located within the Coastal Zone (excludes the amino de Estrella/Camino de los Mares and Rancho San Clemente Business Park areas) would be subject to General Plan Policies NR-1.05, C-2.02, and C-2.05 through C-2.12. Additionally, these Focus Areas would be subject to the goals and policies of the City’s Local Coastal Plan (LCP). Following adherence to existing City regulations, the General Plan EIR determined that buildout of the General Plan would not conflict with the Coastal Zone.

The General Plan EIR determined that the City and SOI are geographically located within the Orange County Southern Subregion HCP, which regulates the “take” of selected federally threatened species, including the California gnatcatcher. The General Plan EIR included Mitigation Measure 3-2 which would require written authorization from the USFWS if a take would occur. However, the City of San Clemente is not a Participating Jurisdiction and does not receive take coverage under the HCP. The General Plan does not propose or permit any development within open space areas, areas within a land preserve, or land within a habitat reserve. While future development that may involve land use or zoning changes could be ineligible for regulatory coverage under the HCP, those projects could apply for separate take permits, and those projects, as with all development projects within the General Plan area, would be required to undergo project-level biological assessment under CEQA. Overall, impacts were determined to be less than significant.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.4-4 Biological Resources

3.4.2 Project-Specific Impacts

Would the project:

New
Potentially
Significant
Impact or
Increased
Significant
Impact
Significant
Impact
Already
Identified in
the General
Plan EIR
Less Than
Significant
Impact With
General
Plan EIR
Mitigation
and/or
COAs
Less Than
Significant
Impact
No
Impact
a. Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?

b. Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?

c. Have a substantial adverse effect on State or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?

d. Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?

e. Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?

f. Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other
approved local, regional, or state habitat conservation plan? 
The information presented in this analysis is based on and supplemented with the Biological Resources Assessment for the Hanson Hotel Project in San Clemente, Orange County, California (Biological Resources Report), dated March 12, 2026, prepared by Michael Baker International, for the project; refer to Appendix C, Biological Resources Report.
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?
Less than Significant Impact With General Plan EIR Mitigation and/or COAs. As with the rest of the City, the project site is located within the USFWS Orange County Southern Subregion HCP; however, it should be noted that the City is not a Participating Jurisdiction under the HCP and

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.4-5 Biological Resources
does not receive take coverage under it. The project site, located within the North Beach/North El Camino Real Focus Area, is currently undeveloped, but disturbed; vegetation on-site is periodically mowed and exhibited different stages of growth. At times, the site becomes overgrown with various types of shrubs, including coastal sage scrub. As coastal sage scrub is known to support the California gnatcatcher, a sensitive species that was observed on-site in September 2025, as well as Crotch’s bumble bee, red diamond rattlesnake, and coast horned lizard, the proposed project could have potentially significant impacts on special-status species.

Based on the results of the Biological Resources Report, and per General Plan EIR Mitigation Measure

5.3-1, a focused species survey may be required if one or more species has the potential to occur within the project vicinity, followed by additional pre-construction surveys in accordance with the California Endangered Species Act (CESA) and FESA; construction boundaries may be delineated and/or limited, and educational training to the construction contractor provided if sensitive biological resources (including trees) are identified on-site; and monitoring by a qualified biologist during construction may occur if sensitive biological resources (including trees) are identified on-site and thought to be impacted. As the project has potential to directly impact the California gnatcatcher the project would also implement General Plan EIR Mitigation Measure 5.3-2, which requires the project Applicant to obtain written authorization from the USFWS that the grading or construction activities are in compliance with regulations on the “take” of federally listed species that would directly or indirectly be impacted. Further, General Plan policies NR-1.01, NR-1.04, NR-1.06, C-2.02, and C2.09 would apply to the proposed project. Following compliance with General Plan EIR Mitigation Measures 5.3-1 and 5.3-2, implementation of applicable General Plan policies, and Conditions of Approval (COA) BIO-1 through COA BIO-8 the proposed project would result in less than significant impacts to sensitive plant and wildlife species, similar to those impacts identified for buildout of the General Plan.

Applicable General Plan EIR Mitigation Measures:

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.4-6 Biological Resources
potential for special status plant and/or animal species to occur within or adjacent to the proposed development project area.
b) If one or more special status species has the potential to occur within the proposed development project area, focused species surveys shall be conducted to determine the presence/absence of these species to adequately evaluate potential direct and/or indirect impacts to these species.
c) If construction activities are not initiated immediately after focused surveys have been completed, additional preconstruction special status species surveys may be required, in accordance with the California Endangered Species Act and Federal Endangered Species Act, to ensure impacts are avoided or minimized to the extent feasible. If preconstruction activities are required, a qualified biologist would perform these surveys as required for each special status species that is known to occur or has a potential to occur within or adjacent to the proposed development project area. d) If sensitive biological resources, including mature trees or wildlife corridors, are identified within or adjacent to the proposed development project area, as outlined in the biological resources report, the construction limits shall be clearly flagged to ensure impacts to sensitive biological resources and the wildlife corridor are avoided or minimized, to the extent feasible. Prior to implementing construction activities, the City of San Clemente shall require applicants to contract with a qualified biologist to verify that the flagging clearly delineates the construction limits and sensitive resources to be avoided.
e) If sensitive biological resources are known to occur within or adjacent to the proposed development project area, as outlined in the biological resources report, the City of San Clemente shall require applicants to contract with a qualified biologist to develop and implement a project-specific contractor training program to educate project contractors on the sensitive biological resources within and adjacent to the proposed development project area and measures being implemented to avoid and/or minimize impacts to these species. Project Contractors shall be required to comply with the requirements of the program.
f) If sensitive biological resources are present within or adjacent to the proposed development project area and impacts may result from construction activities, as outlined in the biological resources report, the City may require that a developer retain a qualified biological monitor to be present during all or a portion of the construction activities to ensure impacts to the sensitive biological resources are avoided or minimized to the extent feasible. The specific biological monitoring requirements shall be determined on a project-by-project basis. The qualified biological monitor shall be approved by the City on a project-by-project basis based on applicable experience with the sensitive biological resources that may be impacted by the proposed development project activities.

5.3-2 The City of San Clemente shall require applicants of public and private development projects that have the potential to affect listed species to obtain written authorization from the U.S.

Fish and Wildlife Service that the grading or construction activity is in compliance with regulations on the “take” of the listed species that would directly or indirectly be impacted.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.4-7 Biological Resources
Any mitigation requirements set forth by such agencies shall be incorporated into the project’s final design plans.

Applicable Conditions of Approval (COAs):

COA BIO-1 A focused habitat assessment for Crotch’s bumble bee shall be conducted by a qualified biologist to determine the potential for this species to occur within or adjacent to the proposed development project area. The habitat assessment shall conform to the requirements listed in the California Department of Fish and Wildlife’s (CDFW) 2023 “Survey Considerations for California Endangered Species Act (CESA) Candidate Bumble Bee Species” and shall be submitted to the CDFW prior to initiation of ground disturbing project activities. (Required by General Plan Mitigation Measure 5.3-1)
COA BIO-2 Because coastal California gnatcatcher has a potential to be present within the proposed development project area, focused surveys conforming to the 1997 USFWS survey protocol will be required in order to adequately evaluate potential direct and/or indirect effects to this species. Because the City of San Clemente is not a participating jurisdiction under any Natural Community Conservation Plans/Habitat Conservation Plans, a total of either six surveys at least one week apart between March 15 and June 30 or a total of either nine surveys at least two weeks apart between July 1 and March 14 will be required. In addition, if the habitat assessment determines that suitable habitat is present on-site, focused surveys for Crotch’s bumble bee conforming to the 2023 survey protocol listed above may also be required. If so, at least three surveys spaced between two and four weeks apart between April and August will be necessary as described in the protocol. Bumble bee surveys will be required each year that project activities have not been completed, if suitable habitat remains on-site. If Crotch’s bumble bee survey results are positive, the applicant will consult with the CDFW to determine if an Incidental Take Permit would be required under CESA depending on the extent and usage of the site by the species. (Required by General Plan Mitigation Measure 5.3-1)
COA BIO-3 If construction activities are not initiated immediately after focused surveys have been completed, additional preconstruction coastal California gnatcatcher and/or Crotch’s bumble bee surveys may be required, in accordance with the California Endangered Species Act and Federal Endangered Species Act, to ensure impacts are avoided or minimized to the extent feasible. If preconstruction activities are required, a qualified biologist would perform these surveys as required for each special status species that is known to occur or has a potential to occur within or adjacent to the proposed development project area, including coastal California gnatcatcher, Crotch’s bumble bee, red diamond rattlesnake, and/or coast horned lizard. These may be combined with nesting bird protections as required under the Migratory Bird Treaty Act and California Fish and Game Code. (Required per Federal Endangered Species Act, California Endangered Species Act, Migratory Bird Treaty Act, and California Fish and Game Code)

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.4-8 Biological Resources
COA BIO-4 Because sensitive coastal sage scrub habitat is present in areas immediately adjacent to the proposed development project area, the construction limits shall be clearly flagged to ensure impacts to adjacent habitats are avoided or minimized, to the extent feasible.

COA BIO-6 A qualified and approved biological monitor shall be present during all vegetation removal and preliminary ground disturbance on the project site to ensure that impacts to sensitive biological resources are minimized or avoided. The monitor shall have the authority to halt construction if sensitive biological resources are present on-site during construction, and will be responsible for implementing nesting bird protections in compliance with the Migratory Bird Treaty Act and California Fish and Game Code.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.4-9 Biological Resources
The project site does not contain any critical habitat or riparian habitat and there would be no impacts to these habitat types. Based on the Biological Resources Report, prepared per General Plan EIR Mitigation Measure 5.3-1, the project site does contain one sensitive natural community, disturbed Menzies’s golden bush scrub. To further mitigate for the loss of this habitat, General Plan Policies NR-1.01, NR-1.02, NR-1.03, NR-1.04, NR-NR-1.06, C-2.02, and C-2.09 would apply to the proposed project (COAs BIO-1 through BIO-7). Following implementation of applicable General Plan policies, the proposed project would result in less than significant impacts to sensitive natural communities.

Applicable General Plan EIR Mitigation Measures: Refer to General Plan EIR Mitigation Measures 5.3-1 and 5.3-2.

Applicable Conditions of Approval (COAs): Refer to COAs BIO-1 through BIO-7.

c) Have a substantial adverse effect on State or Federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
No Impact. The project site does not contain any waters of the US, waters of the State, or wetlands under the jurisdiction of the USACE, CDFW, and/or San Diego RWQCB. Therefore, the project Applicant is not required to obtain any regulatory permits from these agencies. The proposed project would result in no impacts to wetlands and aquatic resources. d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
Less than Significant Impact With General Plan EIR Mitigation and/or COAs. Wildlife corridors and linkages are key features for wildlife movement between habitat patches. Wildlife corridors are generally defined as those areas that provide opportunities for individuals or local populations to conduct seasonal migrations, permanent dispersals, or daily commutes. Linkages generally refer to broader areas that provide movement opportunities (often between areas of conserved land) for multiple keystone/focal species or allow for propagation of ecological processes (i.e., for movement of pollinators). According to General Plan EIR Figure 5.3-6, Habitat Linkages, the project site is not located in an area with habitat linkages or wildlife corridors; the nearest linkages are located on the northeast side of the City, opposite the project site. The project site is periodically disturbed and mowed and is surrounded on three sides by a chain-link fence and the fourth side abuts a commercial building. It provides no opportunity to serve as a wildlife migration corridor other than birds moving through the area. While large mammals (i.e., coyotes or bobcats), may travel along the adjacent Segunda Deshecha Cañada Channel, this channel is a concrete box channel and covered along many segments, and would not provide continuous wildlife movement nor movement between different regions for the purpose of species migration. Though project construction may cause temporary impacts to wildlife, if present, in the channel as a result of noise and disturbance, any impacts would be localized to the immediate area adjacent to the project site. Once constructed, future

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.4-10 Biological Resources
usage of the site would have similar impacts to the current ambient conditions and would not be expected to have any greater impacts than existing development.

The project site provides nesting habitat for bird species that could occur in the area. As nesting birds are protected pursuant to the Migratory Bird Treaty Act (MBTA) and California Fish and Game Code (CFGC), additional measures listed under General Plan EIR Mitigation Measure 5.3-1 would be implemented. Additionally, General Plan EIR Mitigation Measure 5.3-2 would be implemented in order to obtain written authorization from the USFWS that grading and construction activities would occur in compliance with regulations on the “take” of federally-listed bird species, particularly California gnatcatcher. Further, General Plan policies NR-1.01, NR-1.06, C-2.02, and C-2.09 would apply to the proposed project. Finally, Condition of Approval (COA) BIO-6 would require nesting bird surveys as required by the law (MBTA and CFGC). Following compliance with General Plan EIR Mitigation Measures 5.3-1 and 5.3-2 and applicable General Plan policies, as well as compliance with existing laws and regulations (enforced through COA BIO-8 pertaining to nesting birds), the proposed project would result in less than significant impacts to migratory wildlife and native wildlife nurseries.

Applicable Conditions of Approval (COA):

COA BIO-8 To the greatest extent feasible, the Project will avoid construction activities during the peak nesting season (February 15 through September 15). If this time period cannot be avoided, nesting bird surveys shall be performed by a qualified avian biologist no more than 3 days prior to vegetation removal or ground-disturbing activities. Preconstruction surveys shall focus on both direct and indirect evidence of nesting, including nest locations and nesting behavior. The qualified avian biologist will make every effort to avoid potential nest predation as a result of survey and monitoring efforts. If active nests are found during the preconstruction nesting bird surveys, a qualified biologist shall establish an appropriate nest buffer to be marked on the ground. Nest buffers are species specific and shall be at least 300 feet for passerines and 500 feet for raptors. A smaller or larger buffer may be determined by the qualified biologist familiar with the nesting phenology of the nesting species and based on nest and buffer monitoring results. Construction activities may not occur inside the established buffers, which shall remain on-site until a qualified biologist determines the young have fledged or the nest is no longer active. (Migratory Bird Treaty Act and California Fish and Game Code)
e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
No Impact. The project site is not located within the canyon ESHAs and is not subject to any Natural Community Conservation Plan; however, the site is located within the Coastal Zone. As such, the proposed project would be subject to the goals and policies of the City’s LCP; additionally, General Plan Policies NR-1.05, C-2.02, C-2.08, and C-2.09 are applicable to the proposed project. Following adherence to existing City regulations, the proposed project would not conflict with the Coastal Zone.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.4-11 Biological Resources
The Urban Design Element of the General Plan contains several policies related to the protection of the City’s mature trees, collectively referred to as its urban forest. Policy UD-6.05 requires that historically-significant trees are designated as historic resources and preserved wherever possible, and Policy UD-6.08 encourages the preservation of mature trees rather than tree removal. Additionally, the San Clemente Code of Ordinances Title 12, Chapter 12.24, Maintenance, repair protection, and landscaping of public property by abutting property owners, includes requirements for tree maintenance, trimming, and removal. As there are no trees present on the project site, the project would not conflict with any of the above tree policies or ordinances, and no impact would occur.

f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
Less than Significant Impact With General Plan EIR Mitigation and/or COAs. The project site is not located in any areas designated for open space uses, areas designated as supplemental open space under the Southern Subregion HCP, or areas within the Southern Subregion HCP Reserve. The project site is currently zoned as Mixed Use within the General Plan EIR and is mapped as developed (i.e. not a natural vegetation community) in the Southern Subregion HCP, given the disturbed nature of the project site and surrounding developed uses. As such, the proposed project would be consistent with the Southern Subregion HCP, General Plan EIR, and General Plan Policy NR-1.06 in this regard.

Impacts would be less than significant.

Applicable Conditions of Approval (COAs): Refer to COAs BIO-1 through COA BIO-8.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.4-12 Biological Resources
This page intentionally left blank.

March 2026 3.5-1 Cultural Resources

3.5 CULTURAL RESOURCES

3.5.1 General Plan EIR Summary
Less Than Significant Impact. According to the General Plan EIR, buildout of the General Plan could impact an identified or unidentified historic resource. At the time development or redevelopment projects are proposed, the project-level CEQA document would need to identify any impacts to known or potential historical sites and structures. The Historic Preservation Element section of the proposed General Plan contains numerous polices that specifically address sensitive historical resources and their protection. Policy HP-2.03 requires mitigation of significant, adverse impacts to onsite and nearby historic resources as part of applications for general plan amendments, zoning changes, or any projects requiring environmental review. Consistent with CEQA Guidelines, Policy HP-2.05 ensures projects follow the Secretary of Interior Standards for the Treatment of Historic Properties and standards and guidelines prescribed by the State Office of Historic Preservation for any listed historic resources or properties eligible for historic listing. In addition, the City encourages adaptive reuse to preserve historic resources and prevent architecturally inappropriate changes, disrepair, and demolition through Policy HP-2.03. Further, all new development adjacent to or within a 300-foot radius of a historic resource must be compatible with the historic resource in terms of scale, massing, building materials, and general architectural treatment (Policy HP-2.06). The Municipal Code Section 17.16.170 identifies specific procedures and CEQA findings required prior to demolition of buildings, structures and other resources on the City's Designated Historic Resources List, and buildings, structures, and other resources on or eligible for listing in the California Register of Historic Resources. As such, the General Plan EIR determined that compliance with General Plan polices, Municipal Code, and State and federal regulations restricting alteration, relocation, and demolition of historical resources would ensure impacts in this regard would be less than significant.

The General Plan EIR determined that implementation of the General Plan has the potential to impact archaeological resources, and the potential to uncover undiscovered archeological resources is high.

However, in the event of an unanticipated discovery of archaeological resources during grading and excavation of the site, a qualified archaeologist would assess the find and develop a course of action to preserve the find, as indicated in Mitigation Measure 4-1. Further, existing federal, State, and local regulations would address the following: the provision of studies to identify archaeological resources; application review for projects that would potentially involve land disturbance; project-level standard conditions of approval that address unanticipated archaeological discoveries; and requirements to develop specific mitigation measures if resources are encountered during any development activity.

The proposed Natural Resources Element under the General Plan contains policies that address the management of artifacts (Policy NR-3.01) and the notification and inventory of archeological and paleontological resources (Policies NR-3.02 and 3.03). Further, review and protection of archaeological resources is also afforded by CEQA for individual projects subject to discretionary actions that are implemented in accordance with the preferred land use plan. Overall, with implementation of mitigation measures and compliance with applicable regulations, impacts would be reduced to less than significant in this regard.

As detailed in the General Plan EIR, there are 13 archaeological sites within the eight Focus Areas alone, and human habitation in coastal Orange and San Diego counties is known to date to at least approximately 7,000 years B.C. Therefore, human remains could be buried in soils in San Clemente.

Ground disturbance by projects developed pursuant to the proposed General Plan could disturb these remains. California Health and Safety Code Section 7050.5 requires that if human remains are

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.5-2 Cultural Resources
discovered within the project site, disturbance of the site shall halt and remain halted until the coroner has conducted an investigation and made recommendations to the person responsible for the excavation, or to his or her authorized representative. If the coroner determines that the remains are not subject to his or her authority and if the coroner recognizes or has reason to believe the human remains to be those of a Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission. Public Resources Code Section 5097.98, mandates the process to be followed in the event of a discovery of any human remains and would mitigate all potential impacts. As such, impacts would be less than significant.

3.5.2 Project-Specific Impacts
Would the project:

Based on the Cultural and Paleontological Resources Memo, no cultural resources were identified within the project site. However, seven cultural resources were identified within half-mile of the project site. Among these seven cultural resources, two are unevaluated prehistoric sites (P-30-001258

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.5-3 Cultural Resources
and P-30-100074) and five are historic resources. Among the five historic resources, two resources (P-30-150035 and P-30-150036) are the same resource (Aquarium Café; Ichiburi) located 100 feet south of the project site, listed on both the Spanish Colonial Revival Historic District and the Ole Hanson/Spanish Village by the Sea District. Both of these historic districts are non-contiguous districts with individual properties distributed throughout the City of San Clemente. Resource P-30- 1600086 is the San Clemente Swimming Club/San Clemente Beach Club located 0.05-mile southwest and is listed in National Register of Historic Places (NR) as an individual property and eligible for the NR as a contributor to a NR-eligible district. Resource P-30-176663 is the Burlington Northern Santa Fe Railway (formerly Atchison, Topeka, and Santa Fe Railway) located 0.1-mile west and has been found ineligible for the NR, California Register of Historical Resources (CR), or local designation through survey evaluation. Last, resource P-30-177042 is the Max Berg Plaza Park/Plaza Park located

0.45-mile south/southeast and is eligible for the NR as a contributor to a NR-eligible district.

Additionally, 22 local, State, and nationally designated historic resources were identified on the Built Environment Resources Directory (BERD) for Orange County within half-mile of the project site.

These resources include a mix of residential, commercial, religious, recreational, and educational resource types. According to the Cultural and Paleontological Resources Memo, three of the resources (the Spanish Colonial Revival Thematic Historic District, the North Beach Historic District, and the Spanish Village by the Sea Thematic Historic District) overlap with the project site. The remaining resources are located at least 0.47-miles from the project site.

Based on the Cultural and Paleontological Resources Memo, the project site has been undeveloped and vacant since 1873. However, between 2003 and 2004, the project site was graded and was utilized as a parking lot and storage area, either associated with the adjacent business to the project site, Catalyst Surf Shop, or possibly construction vehicles and trailers for a future building site that never moved forward. By 2005, the additional cars and storage area had disappeared and the site was vacant; it has remained so until present day.

As the SCCIC records search, literature and historical map review, and field survey identified no historical resources within the project site, as defined by CEQA Section 15064.5(a). No impacts would result in this regard. However, it is acknowledged that the project site is located in proximity to identified historical buildings associated with the Spanish Colonial Revival Thematic Historic District, the North Beach Historic District, and the Spanish Village by the Sea Thematic Historic District. As such, the project would be required to comply with General Plan policies and Design Guidelines that would ensure the proposed building does not affect the eligibility of these historical resources.

The Hanson Hotel is located within the Architectural Overlay District (A-Overlay), which mandates Spanish Colonial Revival architecture. The project’s design reflects traditional Spanish Colonial Revival architecture and integrates publicly accessible features such as native landscaped gardens, pedestrian areas, and ocean-view terraces. Drawing inspiration from Ole Hanson’s vision for North Beach as a hub of recreation and entertainment, the project Applicant designed the project to be visually compatible with the North Beach Historic District and adjacent historic resources. Specifically, the architecture incorporates tiered massing, with one- and two-story elements stepping down toward East Avenida Pico and recessed upper levels along North El Camino Real. A prominent turret element at the corner of North El Camino Real and East Avenida Pico anchors the site to create a distinctive

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.5-4 Cultural Resources
visual gateway element into the North Beach area and pays tribute to a similar feature at the Ole Hanson Beach Club. The proposed hotel would have a maximum (average) building height of 45 feet.

The project's layout incorporates courtyards, shaded patios, arcades, and outdoor gathering spaces, reinforcing the indoor-outdoor theme in traditional Spanish Colonial Revival architecture. Prominent features include a grand stairway leading to a public podium terrace with ocean views; an Ole Hansoninspired public art and sculpture area; and a series of vine-covered trellises, fountains, and decorative benches that create a transition from public to semi-private spaces. An overall natural color palette of terra cotta, olive green, red, and white, signature of Spanish Colonial Revival architecture, would be used. Also, the proposed landscape plan features a diverse palette of California native and droughttolerant plant species, strategically arranged in a series of terraced gardens along East Avenida Pico and North El Camino Real. Specific areas of focus include native planting beds at the site’s corner gateway, a cultural sculpture area, and decorative plantings framing the publicly accessible walkways and terraces. As such, consistent with the General Plan policies and Design Guidelines, the proposed project would not affect the eligibility of these historical resources.

In conclusion, the SCCIC records search, literature and historical map review, and field survey identified no historical resources within the project site, as defined by CEQA Section 15064.5(a).

Further, consistent with the General Plan policies and Design Guidelines, the proposed project would not affect the eligibility of off-site historical resources. The project would not cause a substantial adverse change in the significance of a historical resource pursuant to CEQA Guidelines Section 15064.5, and impacts in this regard would be less than significant. b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines §15064.5?
Less than Significant Impact With General Plan EIR Mitigation and/or COAs. Based on the Cultural and Paleontological Resources Memo, two cultural resources studies have been previously completed that intersect with the project site; a total of 11 have been completed within the half-mile search radius. A very small portion of the project site has been previously studied, as the studies adjacent to the project site did not include any of the project site itself. Though resources were identified as part of these studies, the studies covered expansive areas and the resources were found over 0.2 miles away from the project site. However, one of the reports intersecting the project site mentions that over 414,000 cubic yards of soil was removed from the bluffs area immediately north of the project site in 1992; this would have destroyed any archaeological sites that existed on the surface or near surface. The report further suggests that due to the components of an identified offsite archeological resources not far away (a metate fragment, scraper, and hammerstone), it can be understood that some kind of vegetable collection and processing was being done on or near the bluffs, which includes the project site.

Based on the Cultural and Paleontological Resources Memo, sensitivity for cultural resources consisting of archaeological sites is considered moderate on-site based upon the project site’s proximity to permanent freshwater sources and to the ocean, the site’s depositional history, and the lack of previously recorded archaeological sites within the project site and its vicinity. It is especially important to note that the entirety of the area just north of the project area was bulldozed in 1992 and

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.5-5 Cultural Resources
any archaeological sites would have been destroyed at that time. Thus, the absence of documented sites cannot definitively suggest that this area did not have any sites previously, and it has been suggested that site CA-ORA-01258, not far away from the project site, indicates that vegetable collection and food processing were done on the bluffs.

The project site is located within a quarter-mile of the coast of the Pacific Ocean, and even closer to the Arroyo San Mateo and Arroyo San Onofre streams. This area, so near to riverine, coastal, and estuary resources, would be expected to have been heavily utilized by local Native Americans, and its proximity to permanent freshwater sources indicates that the sensitivity for prehistoric archaeological resources would be moderate.

Map and aerial photograph research indicates that the project site was never developed, past grading done in possible preparation to build on the site, which never occurred. The project site therefore has potential to contain significant buried historic features, such as privies, that may intrude into the Pleistocene deposits.

In conclusion, sensitivity for buried archaeological resources is moderate due to the proximity of the project site to freshwater sources and other factors, as described above. Thus, the Cultural and Paleontological Resources Memo determined that the project site is considered to have a moderate sensitivity for archaeological resources, and there is a potential for project construction to disturb previously unknown archaeological resources during excavation into native soil. Nonetheless, the Cultural and Paleontological Resources Memo concluded that implementation of General Plan EIR Mitigation Measure 4-1 (enforced through COA CUL-1) would be required to be implemented in order to minimize impacts to previously unknown archaeological resources. Specifically, COA CUL1 requires a qualified archaeologist to be retained in the event that any subsurface cultural resources are encountered during earth-moving activities. Construction activity within 50 feet of the find would halt, and the qualified archaeologist would evaluate the finds and make recommendations.

Accordingly, and consistent with the findings of the General Plan EIR, with compliance with COA CUL-1, project impacts to archeological resources would be less than significant.

Applicable General Plan EIR Mitigation Measures:
4-1 City staff shall require applicants for development permits to provide studies by qualified archaeologists assessing the cultural and historical significance of any known archaeological resources on or next to each respective development site; and assessing the sensitivity of sites for buried archaeological resources. On properties where resources are identified, or that are determined to be moderately to highly sensitive for buried archaeological resources, such studies shall provide a detailed mitigation plan, including a monitoring program and recovery and/or in situ preservation plan, based on the recommendations of a qualified cultural preservation expert. The mitigation plan shall include the following requirements:
a. An archaeologist shall be retained for the project and will be on call during grading and other significant ground-disturbing activities.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.5-6 Cultural Resources
b. Should any cultural/scientific resources be discovered, no further grading shall occur in the area of the discovery until the Community Development Director concurs in writing that adequate provisions are in place to protect these resources. c. Unanticipated discoveries shall be evaluated for significance by an Orange County Certified Professional Archaeologist. If significance criteria are met, then the project shall be required to perform data recovery, professional identification, radiocarbon dates as applicable, and other special studies; submit materials to the California State University Fullerton; and provide a comprehensive final report including appropriate records for the California Department of Parks and Recreation (Building, Structure, and Object Record; Archaeological Site Record; or District Record, as applicable).

Applicable Conditions of Approval (COA):

COA CUL-1 Archaeological Resources Inadvertent Discovery. In the event that any subsurface cultural resources are encountered during earth-moving activities, it is recommended that all work within 50 feet be halted until a qualified archaeologist can evaluate the findings and make recommendations. Prehistoric materials can include flaked-stone tools (e.g., projectile points, knives, choppers) or obsidian, chert, or quartzite toolmaking debris; culturally darkened soil (i.e., midden soil often containing heataffected rock, ash, and charcoal, shellfish remains, and cultural materials); and stone milling equipment (e.g., mortars, pestles, handstones). Historical materials might include wood, stone, or concrete footings, walls, and other structural remains; debrisfilled wells or privies; and deposits of wood, metal, glass, ceramics, and other refuse.

The archaeologist may evaluate the find in accordance with federal, state, and local guidelines, including those set forth in the California Public Resources Code Section 21083.2, to assess the significance of the find and identify avoidance or other measures as appropriate. A qualified archaeologist must meet the Secretary of the Interior’s Professional Qualifications Standards for archaeology (required per General Plan Mitigation Measures 4-1)
c) Disturb any human remains, including those interred outside of formal cemeteries? Less than Significant Impact With General Plan EIR Mitigation and/or COAs. The proposed project would result in ground disturbance activities that could result in encountering human remains.

California Health and Safety Code Section 7050.5 requires that if human remains are discovered within the project site, disturbance of the site shall halt and remain halted until the coroner has conducted an investigation and made recommendations to the person responsible for the excavation, or to his or her authorized representative (COA CUL-2). If the coroner determines that the remains are not subject to his or her authority and if the coroner recognizes or has reason to believe the human remains to be those of a Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission. Public Resources Code Section 5097.98, mandates the process to be followed in the event of a discovery of any human remains and would mitigate all potential impacts.

As such, impacts would be less than significant.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.5-7 Cultural Resources
Applicable Conditions of Approval (COA):

COA CUL-2 Human Remains Inadvertent Discovery. If human remains are found, those remains would require proper treatment in accordance with State of California Health and Safety Code Sections 7050.5-7055. Specifically, Health and Safety Code Section 7050.5 describes the requirements if any human remains are discovered during excavation of a site. As required by state law, the requirements and procedures set forth in Section 5097.98 of the California Public Resources Code would be implemented, including notification of the County coroner, notification of the Native American Heritage Commission, and consultation with the individual identified by the Native American Heritage Commission to be the “most likely descendant.” If human remains are found during excavation, excavation must stop in the vicinity of the find and any area that is reasonably suspected to overlie adjacent remains until the County coroner has been called out, and the remains have been investigated and appropriate recommendations have been made for the treatment and disposition of the remains. (Required per State of California Health and Safety Code Sections 7050.5-7055 and California Public Resources Code Section 5097.98)

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.5-8 Cultural Resources
This page intentionally left blank.

March 2026 3.6-1 Energy

3.6 ENERGY

3.6.1 General Plan EIR Summary
Less Than Significant Impact. The General Plan EIR did not address impacts to energy resources as thresholds related to energy resources were added to Appendix G of the CEQA Guidelines after certification of the General Plan EIR. However, energy use and infrastructure considerations were evaluated under Chapter 5.15, Utilities and Service Systems, Impact 5.15-5. The General Plan EIR acknowledged that implementation of the General Plan would result in increased natural gas and electricity use within the City, thereby increasing the demand for energy services.

In regard to natural gas, natural gas service for future development will be added to the existing system by the San Diego Gas & Electric (SDG&E) and Southern California Gas (SCG) as necessary to meet the requirements of individual development projects within the project area. The utility companies have indicated that they will be able to supply the area with natural gas without impacting existing service. As such, the General Plan EIR determined that total cumulative demand, including growth in the surrounding areas, does not represent a significant impact to the energy service because of the substantial amount of reserves available.

In regard to natural gas, the General Plan EIR noted that existing energy demand is approximately 399 gigawatt hours (Gwh) per year based on average usage from 2009 to 2012 by residential and nonresidential uses, and future growth in accordance with the proposed land use plan would generate a demand of approximately 526 Gwh per year. New facilities to support the demand for electric service in the City of San Clemente would be constructed by SDG&E in accordance with the demand for new service. Because developments that would be considered for approval under the General Plan have not yet been designed or proposed, the specific electricity facilities that would need to be installed to serve those developments are unknown, as are the environmental impacts of such installations.

Such impacts would be evaluated on a project-by-project basis.

As impacts to energy resources were not discussed as thresholds in the General Plan EIR, no specific impact findings were made. However, it should be noted that no significant and unavoidable impacts related to energy resources were found in the General Plan EIR.

3.6.2 Project-Specific Impacts
Would the project:

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.6-2 Energy
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
Less than Significant Impact. Per CEQA Guidelines Appendix F, Energy Conservation, in order to ensure energy implications are considered in project decisions, CEQA requires that EIRs include a discussion of the potential energy impacts of proposed projects, with particular emphasis on avoiding or reducing inefficient, wasteful, and unnecessary energy consumption (Public Resources Code Section 21100(b)(3)). Environmental effects may include:
• The proposed project’s energy requirements and its energy use efficiencies by amount and fuel type during demolition, construction, and operation; (Criterion 1) • The effects of the proposed project on local and regional energy supplies; (Criterion 2) • The effects of the proposed project on peak and base period demands for electricity and other forms of energy; (Criterion 3)
• The degree to which the proposed project complies with existing energy standards; (Criterion 4)
• The effects of the proposed project on energy resources; (Criterion 5) and • The proposed project’s projected transportation energy use requirements and its overall use of efficient transportation alternatives, if applicable. (Criterion 6) The following impact analysis focuses on the two sources of energy that are relevant to the proposed project: electricity and transportation fuel for vehicle trips associated with project operations as well as the fuel necessary for project construction. The California Emissions Estimator Model (CalEEMod) version 2022.1 was utilized to calculate the project’s construction and operational energy consumption. The project’s estimated energy consumption is summarized in Table 3.6-1, Project and Countywide Energy Consumption. Refer to Appendix B, Air Quality/GHG/Energy Data, for CalEEMod output and energy calculations.

Table 3.6-1
Project and Countywide Energy Consumption
Energy Consumption Type Project Annual
Energy Consumption1
Orange County Annual
Energy Consumption2
Percentage
Increase Countywide
Construction
Construction Off-Road Fuel Consumption 12,846 gallons 18,350,503 gallons 0.0700% Construction On-Road Fuel Consumption 190,104 gallons 1,056,094,532 gallons 0.0180% Operation
Electricity Consumption3 550 MWh 19,225,145 MWh 0.0029% Natural Gas Consumption4 14,473 therms 338,651,335 therms 0.0043% Operational Automotive Fuel Consumption 54,868 gallons 1,012,273,716 gallons 0.0054%

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.6-3 Energy
Energy Consumption Type Project Annual
Energy Consumption1
Orange County Annual
Energy Consumption2
Percentage
Increase Countywide
Notes:

1. Project electricity consumptions as modeled in California Emissions Estimator Model Version 2022.1 (CalEEMod) computer model. Project fuel consumption calculated based on CalEEMod results. Countywide operational fuel consumption, offroad construction equipment diesel fuel consumption, and on-road fuel consumption are from CARB EMFAC2025.

2. The project’s increase in electricity consumption is compared to the total consumption in Orange County in 2024 (latest year where data is available). Construction on-road and off-road fuel consumption was compared with the projected Orange Countywide off-road and on-road fuel consumption in 2026 (first year of construction). The project increases in operational automotive fuel consumption is compared with the projected Countywide on-road fuel consumption in 2027 (first year of operation).

3. Electricity consumption data source: California Energy Commission, Electricity Consumption, https://www.energy.ca.gov/data-reports/energy-almanac/california-electricity-data/california-energy-consumptiondashboards-0, accessed January 15, 2026.

4. Natural Gas consumption data source: California Energy Commission, Natural Gas Consumption, https://www.energy.ca.gov/data-reports/energy-almanac/california-electricity-data/california-energy-consumptiondashboards-1, accessed January 15, 2026.

Source: Refer to Appendix B, Air Quality/GHG/Energy Data.

CONSTRUCTION ENERGY CONSUMPTION
During construction, the project would consume energy in two general forms: (1) the fuel energy consumed by construction vehicles and equipment; and (2) bound energy in construction materials, such as asphalt, steel, concrete, pipes, and manufactured or processed materials such as lumber and glass.

Fossil fuels used for construction vehicles and other energy-consuming equipment would be used during demolition, grading, building construction, paving, and architectural coatings. Fuel energy consumed during construction would be temporary and would not represent a significant demand on energy resources. In addition, some incidental energy conservation would occur during construction through compliance with State requirements that heavy-duty diesel equipment not in use for more than five minutes be turned off. Project construction equipment would also be required to comply with the latest U.S. Environmental Protection Agency (EPA) and California Air Resources Board (CARB) engine emissions standards. These emissions standards require highly efficient combustion systems that maximize fuel efficiency and reduce unnecessary fuel consumption. Due to increasing transportation costs and fuel prices, contractors and owners have a strong financial incentive to avoid wasteful, inefficient, and unnecessary consumption of energy during construction (Criterion 4).

The project-related incremental increase in the use of energy bound in construction materials, such as asphalt, steel, concrete, pipes and manufactured or processed materials (e.g., lumber and gas), would not substantially increase demand for energy compared to overall local and regional demand for construction materials. As indicated in Table 3.6-1, the proposed project’s construction off-road fuel consumption would be approximately 12,846 gallons, which would account for 0.0700 percent of the County’s annual off-road construction fuel consumption, and on-road fuel consumption from construction would be approximately 190,104 gallons, which would account for approximately 0.0180 percent of the County’s annual on-road fuel consumption. As such, project construction would have

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.6-4 Energy
a minimal effect on the local and regional energy supplies and would not require additional capacity (Criterion 2).

Construction fuel use is temporary and would cease upon completion of construction activities.

Construction activities would be planned and sequenced to maximize the efficiency of construction.

Therefore, there are no unusual project characteristics that would necessitate the use of construction equipment that would be less energy-efficient than at comparable construction sites in the region or State (Criterion 5). Additionally, construction contractors would be required to comply with the provisions of California Code of Regulations Title 13, Sections 2449 and 2485, which prohibit dieselfueled commercial motor vehicles and off-road diesel vehicles from idling for more than five minutes and would minimize unnecessary fuel consumption. Construction equipment would be subject to the EPA Construction Equipment Fuel Efficiency Standard, which would also minimize inefficient, wasteful, or unnecessary fuel consumption. Furthermore, the project would comply with applicable regulatory requirements including CALGreen. The latest CALGreen requires that all “New Construction” (pursuant to the Green Building Code) are required to divert 65 percent of the construction materials generated during construction. Therefore, construction fuel consumption would not be any more inefficient, wasteful, or unnecessary than other similar development projects, and a less than significant impact would occur in this regard during project construction.

OPERATIONAL ENERGY CONSUMPTION
Transportation Energy Demand. Pursuant to the Federal Energy Policy and Conservation Act of 1975, the National Highway Traffic and Safety Administration is responsible for establishing additional vehicle standards and for revising existing standards. Compliance with Federal fuel economy standards is not determined for each individual vehicle model. Rather, compliance is determined based on each manufacturer’s average fuel economy for the portion of their vehicles produced for sale in the United States.

Project-generated vehicle emissions have been estimated using CalEEMod based on the project’s average daily trips per the San Clemente 1801 N. El Camino Real – VMT Screening Assessment (VMT Screening Assessment), prepared by Michael Baker International and dated February 2, 2026; refer to Appendix H.2, VMT Screening Assessment. As indicated in Table 3.6-1, the project’s operational automotive transportation at buildout is estimated to consume approximately 54,868 gallons of fuel per year. As such, project-related mobile sources would account for approximately 0.0054 percent of the County’s forecasted annual consumption of fuel starting in 2027 (first year of operation). The proposed project would account for a nominal percentage of the forecasted annual operational automotive fuel consumption for the County and, thus, would have a nominal effect on the local and regional energy supplies. (Criterion 1 and Criterion 2).

The key drivers of transportation-related fuel consumption rely on many personal choices on when and where to drive for various purposes. The project is an infill development located in close proximity to a major transit station (200 feet from the San Clemente Metrolink Station). As such, the project would provide future temporary accommodation for transit users which promotes reliable and safe multimodal transportation. Bicycle facilities and sidewalks occur along both northbound and southbound East Avenida Pico to the east, as well as eastbound and westbound North El Camino Real to the south. Bus stops serving Orange County Transportation Authority (OCTA), Metrolink, and San Clemente Trolley bus lines are provided along East Avenida Pico and North El Camino Real.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.6-5 Energy
Further, the project would also install electric vehicle (EV) charging stations and include parking spaces for EV and bicycle in accordance with California Green Building Standards Code (CALGreen), which would promote an alternative mode of transportation and reduce fuel consumption (Criterion 4 and Criterion 6). Therefore, fuel consumption associated with vehicle trips generated by the project would not be considered inefficient, wasteful, or unnecessary in comparison to other similar developments in the region. A less than significant impact would occur.

Stationary Energy Demand. The CEC developed 2024 to 2040 forecasts for energy consumption and peak demand in support of the 2024 Integrated Energy Policy Report (2024 IEPR) for each of the major electricity and natural gas planning areas and the State based on the economic and demographic growth projections. CEC forecasted baseline electricity consumption grows at a rate of about 1.7 percent annually through 2040.13 The natural gas consumption grows at a rate of about 0.2 percent annually through 2035.14
As shown in Table 3.6-1, the project’s operational electricity and natural gas consumption would represent approximately a 0.0029 percent and 0.0043 percent increase, respectively, over the current Countywide usage, which would be significantly below CEC’s forecasts and the current Countywide usage. Therefore, the project would be consistent with the CEC’s energy consumption forecasts and would not require additional energy capacity or supplies (Criterion 1 and Criterion 2). The project would also consume energy during the same time periods as other surrounding residential and commercial developments. As a result, the project would not result in unique or more intensive peak or base period electricity demand (Criterion 3).

Furthermore, SCE is subject to California’s Renewable Portfolio Standards (RPS). The RPS requires investor-owned utilities, electric service providers, and community choice aggregators to increase procurement from eligible renewable energy resources to 60 percent of total procurement by 2030 and 100 percent of total procurement by 2045. Renewable energy is generally defined as energy that comes from resources which are naturally replenished within a human timescale such as sunlight, wind, tides, waves, and geothermal heat. The increase in the reliance of such energy resources further ensures that new development projects will not result in the waste of the finite energy resources. (Criterion 4).

Based on the analysis above, the project would not cause wasteful, inefficient, and unnecessary consumption of energy during project operation, or preempt future energy development or future energy conservation. Further, implementation of the proposed project would not warrant new energy production facilities or transmission facilities. As such, impacts resulting from the proposed project would be less than significant.

13 California Energy Commission, 2023 Integrated Energy Policy Report, page 130, July 14, 2024. 14 Based on the 2023 Integrated Energy Policy Report, the gas forecast is updated every two years, in odd years.

As such, the natural gas consumption shown here is based on the California Energy Commission, Final 2022 Integrated Energy Policy Report Update, page 140, May 10, 2023.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.6-6 Energy
b) Conflict with or obstruct a State or local plan for renewable energy or energy efficiency? Less than Significant Impact. As discussed above, operational energy consumption of the proposed project would be a nominal fraction of County’s projected energy consumption and substantially below CEC’s forecasts in the 2024 IEPR (i.e., Statewide annual average growth rates of energy demand would be 1.7 percent for electricity); refer to Table 3.6-1. The proposed project supports energy efficiency and sustainability objectives by promoting transit use and maintaining low operational energy demand. Therefore, the project would be consistent with the CEC’s 2024 IEPR. Further, the City of San Clemente Climate Action Plan, adopted in February 2014, includes goals and measures regarding energy reduction/efficiency. While all of the measures focused on City’s action and are not directly applicable to a development project, the proposed project would be consistent with some of the measures that aim to promote multimodal transportation and reduce energy consumption. For instance, the project would promote pedestrian connectivity by constructing sidewalks along southbound East Avenida Pico and eastbound North El Camino Real would be constructed at the eastern and southern boundaries of the site, respectively; encourage the use of bicycle and clean air vehicle by including bike racks and designating EV parking spaces with EV chargers installed; and reduce energy consumption by installing energy efficient appliances and committing to waste diversion goals. As such, the project would be consistent with the City’s CAP, and less than significant impacts would occur in this regard.

March 2026 3.7-1 Geology and Soils

3.7 GEOLOGY AND SOILS

3.7.1 General Plan EIR Summary
Less Than Significant Impact. The General Plan EIR noted that strong ground shaking is very likely to occur in the City during the useful lives of structures that would be developed or redeveloped pursuant to the General Plan. As described in the General Plan EIR, the two nearest active faults to San Clemente are the Glen Ivy North fault in the Elsinore Fault Zone about 17 miles northeast of the SOI, and an unnamed offshore fault 11 miles southwest of the City. In addition, two segments of the active Newport-Inglewood fault are located 19 miles northwest and 19 miles south-southeast (Rose Canyon) of the City. Peak horizontal ground acceleration from these faults is 0.34 g on and near the coast, and declines to about 0.31 g in the northeastern part of the City and SOI.

Rupture of a Known Earthquake Fault
As detailed on the Initial Study, included as Appendix A of the General Plan EIR, impacts pertaining to rupture of a known earthquake fault as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault, would be less than significant.

Seismic Hazards
Strong Seismic Ground Shaking. As detailed in the General Plan EIR, each development project considered for approval by the City under the proposed General Plan would be required to comply with seismic safety provisions of the California Building Code (CBC; Title 24, Part 2 of the California Code of Regulations) and have a geotechnical investigation conducted for the affected project site.

The geotechnical investigation would calculate seismic design parameters pursuant to CBC requirements, and would include foundation and structural design recommendations, as needed, to reduce hazards to people and structures arising from ground shaking. With compliance with CBC and implementation of design recommendations recommended by a site-specific Geotechnical investigation, the General Plan EIR determined that impacts pertaining to strong seismic ground shaking would be less than significant.

Liquefaction/Lateral Spreading. As shown on General Plan EIR Figure 5.5-5, Seismic Hazard Zones, parts of the City are in zones of required investigation for liquefaction hazard designated by the CGS.

However, geotechnical investigations for projects considered for approval by the City under the proposed General Plan would be required to evaluate the potential for liquefaction and other seismic ground failure such as lateral spreading, under the respective project sites. Geotechnical investigation reports would provide recommendations for grading and for foundation design to reduce hazards to people and structures arising from liquefaction and other ground failure. Each project would be required to comply with recommendations in the geotechnical investigation report and comply with the CBC, thereby reducing such hazards. As such, impacts pertaining to liquefaction and lateral spreading would be less than significant.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.7-2 Geology and Soils
Seismically Induced Settlement. The General Plan EIR noted that projects developed pursuant to General Plan would be required to meet the most current seismic safety requirements in the CBC. For instance, Chapter 16 of the CBC contains requirements for design and construction of structures to resist loads, including earthquake loads. Chapter 18 of the CBC contains requirements for excavation, grading, and fill; load-bearing values of soils; and foundations, footings, and piles. Additionally, the General Plan Policy S-1.05 would require that all new habitable structures be designed to mitigate impacts related to geologic and soil hazards. As each project would be required to comply with recommendations in the geotechnical investigation report and comply with the CBC, the General Plan EIR determined that impacts would be less than significant in this regard.

Landslides. Geotechnical investigations for projects considered for approval by the City under the General Plan would evaluate the potential for earthquake-induced landslides on the respective project sites, and would provide recommendations to reduce hazards to people and structures from landslides, including earthquake-induced landslides. Such recommendations may include removing landslides; burying landslides under engineered fill during site grading; buttressing, that is, placement of engineered fill on the toe of a landslide to resist further movement; or shear keys, that is, slots excavated into natural slopes in order to stabilize the upper portion of the slope without grading encroachment into the lower portion of the slope. Each project would be required to comply with recommendations in the geotechnical investigation report for its project site, thereby reducing such hazards. As such, the General Plan EIR determined that impacts would be less than significant in this regard.

Loss of Topsoil
The General Plan EIR determined that with implementation of erosion control measures in a sitespecific Storm Water Pollution Prevention Plan (SWPPP) during construction and measures in the City’s Municipal Code (Chapter 15.36 Excavations and Grading, Art. XII - Erosion Control) during operations of future projects, impacts would be less than significant.

Unstable Geologic Unit
Subsidence. The General Plan EIR noted that most of the City and SOI are not underlain by groundwater basins, ground subsidence is not considered a major hazard in San Clemente. The major cause of ground subsidence is withdrawal of groundwater. As such, the safe yield of groundwater extraction for the subbasin, set at 1,100 acre-feet per year, is intended to prevent both overdraft of the subbasin and seawater intrusion. Impacts are determined to be less than significant.

Collapsible Soils. The General Plan EIR noted that each project considered for approval under the General Plan would be required to have a geotechnical investigation conducted of its project site. The geotechnical investigation would evaluate site soils for collapsibility, and provide recommendations for grading and for engineering and placement of fill soils to minimize hazards from collapsible soils.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.7-3 Geology and Soils
Each project would be required to comply with recommendations in the geotechnical investigation report for its project site. Consequently, impacts would be less than significant.

Expansive Soils
The General Plan EIR noted clay soils derived from Capistrano Formation rock, which underlies much of the City and SOI, tend to be highly expansive. However, geotechnical investigations for projects considered for approval by the City under the General Plan would evaluate soils on each affected project site for expansion potential and would provide recommendations for grading and for foundation design to reduce hazards from expansive soils. Each project would be required to comply with recommendations in the geotechnical investigation report for its project site. Consequently, impacts would be less than significant.

Septic Tanks
As detailed on the General Plan EIR Initial Study, included as Appendix A, development in accordance with the General Plan would be required to connect with the public sewer system, and no impacts pertaining to septic tanks or alternative wastewater disposal systems would occur.

Paleontological Resources
The General Plan EIR determined that implementation of the General Plan has the potential to impact paleontological resources, and the potential to uncover undiscovered paleontological resources is high.

However, in the event of an unanticipated discovery of paleontological resources during grading and excavation of the site, a qualified paleontologist would assess the find and develop a course of action to preserve the find, as indicated in Mitigation Measure 4-2. Further, existing federal, State, and local regulations would address the following: the provision of studies to identify paleontological resources; application review for projects that would potentially involve land disturbance; project-level standard conditions of approval that address unanticipated paleontological discoveries; and requirements to develop specific mitigation measures if resources are encountered during any development activity.

The proposed Natural Resources Element under the General Plan contains policies that address the management of artifacts (Policy NR-3.01) and the notification and inventory of archeological and paleontological resources (Policies NR-3.02 and 3.03). Further, review and protection of paleontological resources is also afforded by CEQA for individual projects subject to discretionary actions that are implemented in accordance with the preferred land use plan. Overall, with implementation of mitigation measures and compliance with applicable regulations, impacts would be reduced to less than significant in this regard.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.7-4 Geology and Soils

3.7.2 Project-Specific Impacts
Would the project:

New
Potentially
Significant
Impact or
Increased
Significant
Impact
Significant
Impact
Already
Identified in
the General
Plan EIR
Less Than
Significant
Impact With
General
Plan EIR
Mitigation
and/or
COAs
Less Than
Significant
Impact
No
Impact
a. Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
1) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map
issued by the State Geologist for the area or based on
other substantial evidence of a known fault? Refer to
Division of Mines and Geology Special Publication 42.

2) Strong seismic ground shaking? 
3) Seismic-related ground failure, including liquefaction?  4) Landslides? 
b. Result in substantial soil erosion or the loss of topsoil?  c. Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and
potentially result in on-or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?

d. Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property?

e. Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water?

f. Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? 
In order to assess the project’s potential to result in impacts to geology and soils, a site-specific Geotechnical Investigation for Proposed Hotel Project at 1801 North El Camino Real, San Clemente, CA 92672 (Geotechnical Investigation), dated January 1, 2025, by Peter and Associates, was prepared for the project; refer to Appendix E, Geotechnical Investigation. Additionally, in order to assess the project’s potential to result in impacts to paleontological resources, a site-specific Cultural and Paleontological Resources Identification Memorandum for the Hanson Hotel CEQA Review Project, City of San Clemente, Orange County, California (Cultural and Paleontological Resources Memo), dated January 29, 2026, by Michael Baker International, was prepared for the project; refer to Appendix D. The results of the analysis are summarized below.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.7-5 Geology and Soils
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:

1) Rupture of a known earthquake fault, as delineated on the most recent AlquistPriolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42.

No Impact. Based on the Geotechnical Investigation, the project site is not within a designated State of California Earthquake Fault Zone (Alquist-Priolo Special Studies Zone). As such, the Geotechnical Investigation determined that the risk of surface rupture at the project site is low. No impacts would occur in this regard.
2) Strong seismic ground shaking?
Less than Significant Impact With General Plan EIR Mitigation and/or COAs. The Geotechnical Investigation identified that the project site is located in Southern California, which is a major earthquake-prone area, similar to that disclosed in the General Plan EIR. Based on the potential for ground shaking at the project site, the Geotechnical Investigation includes recommendations for structures to be designed to meet the current building code and requirements of the governing agencies, and seismic parameters provided in the Geotechnical Investigation Table 1, Seismic Design Values, that are applicable based on existing CBC regulations and the City’s Municipal Code. Overall, implementation of recommendations included in the Geotechnical Investigation prepared for the project, as required by the Municipal Code and CBC (COA 3.2), would ensure that impacts would be less than significant in this regard.

Applicable Conditions of Approval (COA):

Less than Significant Impact With General Plan EIR Mitigation and/or COAs.

Liquefaction
According to the Geotechnical Investigation, the project site has the potential to experience liquefaction, similar to that disclosed as part of the General Plan EIR. Therefore, recommendations have been included in the Geotechnical Investigation, as required in accordance with the CBC, for the installation of adequate foundation and drainage. In accordance with the CBC regulations, the building

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.7-6 Geology and Soils
structure/foundation is planned to be supported by the formational bedrock via cast in-place concrete caissons supporting grade beam footings/structural slabs or concrete driven piles with structural concrete matt slab supporting the building’s bearing walls and columns. Specifically, compaction grouting is recommended to stabilize the liquefiable underlying soil. Compaction grouting helps to improve soil bearing pressure where the loose and saturated soils lose their strength during earthquakes by densifying the soil. Compaction grouting can be implemented along with system of piles and grade beams supporting the structural slab or under any exterior slabs. The Geotechnical Investigation notes that the project site is adequate for support of the proposed improvements, provided the recommendations outlined in the report are properly implemented during design and construction of the proposed development (as required by the CBC). Overall, implementation of recommendations included in the Geotechnical Investigation prepared for the project, as required by the CBC and Municipal Code (COA 3.2), would ensure that impacts would be less than significant in this regard.

Seismically Induced Settlement
The project would be required to meet the most current seismic safety requirements in the CBC, including Chapter 16 and Chapter 18 of the CBC. According to the Geotechnical Investigation, due to the potential settlement of the underlying unsuitable earth materials, slabs-on-grade not connected with supported by grade beams and cast in place or driven piles are subject to settlement. The Geotechnical Investigation states that the project site is adequate for support of the proposed improvements, provided the recommendations outlined in the report are properly implemented during design and construction of the proposed development (as required by the CBC). Overall, implementation of recommendations included in the Geotechnical Investigation, as required by the CBC and Municipal Code (COA 3.2) would ensure that impacts would be reduced to less than significant levels.

Applicable Conditions of Approval (COA): Refer to COA 3.2.

4) Landslides?

No Impact. According to the General Plan EIR Figure 5.5-3, Landslides, the project is not located within known landslide areas. According to the Geotechnical Investigation, existing slopes are present along East Avenida Pico (portions of the slope are heavily eroded and are heavily vegetated with brush), along North El Camino Real (heavy vegetation), and a small slope is along the westerly project site property line with heavy vegetation. The Geotechnical Investigation notes that future slope instability is not a concern for this project as no future large slopes are proposed at the site, and existing on-site slopes would be temporarily shored during construction. As such, no impacts are anticipated with regard to landslides.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.7-7 Geology and Soils
b) Result in substantial soil erosion or the loss of topsoil? Less than Significant Impact. The primary concern with regard to soil erosion or loss of topsoil would be during the construction phase of the project. Grading and earthwork activities associated with construction of the proposed project and its improvements would be minimal. Additionally, earthwork and grading associated with the proposed project would be conducted in accordance with geotechnical recommendations, the project specifications, applicable sections of the California Building Code, applicable Orange County grading regulations, and other applicable regulations and rules.

As discussed in the Section 3.10, Hydrology and Water Quality, the project would be subject to the National Pollution Discharge Elimination System (NPDES) Construction General Permit and would implement the Best Management Practices (BMPs) identified for the project. Additionally, mandatory adherence to dust control measures in accordance with South Coast Air Quality Management District (SCAQMD) Rule 403 would further reduce erosion during the construction phase of the project. As such, impacts due to soil erosion and the loss of topsoil during short-term construction and operation would be less than significant.

Further, as detailed in the Section 3.10, site-specific BMPs have been designed for the project to reduce or eliminate sediment discharge to surface water from storm water and non-storm water discharges during project operation. As such, impacts due to soil erosion and the loss of topsoil during long-term operation would be less than significant.

c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on-or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
Less than Significant Impact With General Plan EIR Mitigation and/or COAs. Refer to Response 3.7.2(a) above for a discussion on landslide/ lateral spreading and liquefaction.

Subsidence
The major cause of ground subsidence is withdrawal of groundwater. According to the Geotechnical Investigation, groundwater was observed from 11 feet to 22 feet deep based on exploratory borings.

Despite the high water table, extraction of groundwater for municipal use is not proposed at or near the project site.

As detailed above, the building structure/foundation is planned to be supported by the formational bedrock via cast in-place concrete caissons supporting grade beam footings/structural slabs and/or concrete driven piles with structural concrete matt slab supporting the building’s bearing walls and columns. Specifically, compaction grouting is recommended to stabilize the liquefiable underlying soil.

Compaction grouting helps to improve soil bearing pressure where the loose and saturated soils lose their strength during earthquakes by densifying the soil. Compaction grouting can be implemented along with system of piles and grade beams supporting the structural slab or under any exterior slabs.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.7-8 Geology and Soils
Overall, implementation of recommendations included in the Geotechnical Investigation, as required by the CBC (COA 3.2), would ensure that impacts would be less than significant in this regard.

Collapsible Soils
The Geotechnical Investigation provides recommendations for grading and for engineering and placement of fill soils to minimize hazards from collapsible soils. Overall, implementation of recommendations included in the Geotechnical Investigation, as required by the CBC (COA 3.2), would ensure that impacts related to instability of the site’s geologic materials would be less than significant.

Applicable Conditions of Approval (COA): Refer to COA 3.2.

d) Be located on expansive soil, as defined in Table 18-1-B of the California Building Code (2001), creating substantial direct or indirect risks to life or property?

Less than Significant Impact With General Plan EIR Mitigation and/or COAs. Expansive soils are characterized by the ability to undergo significant volume change due to the variations in moisture content. According to the Geotechnical Investigation, on-site soils are considered to have a high expansion potential, similar to that disclosed in the General Plan EIR.

The Geotechnical Investigation provides recommendations for grading and for engineering and placement of fill soils to minimize hazards from expansive soils. With compliance with the recommendations included in the Geotechnical Investigation, as required by the CBC (COA 3.2), impacts pertaining to expansive soils would be less than significant.

Applicable Conditions of Approval (COA): Refer to COA 3.2.

e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater?

No Impact. The project does not propose the use of septic tanks or alternative wastewater disposal systems. The project would connect to existing sewer facilities and existing treatment facilities. Thus, no impact would occur.
f) Directly or indirectly destroy a unique paleontological resource or site or unique geological feature?
Less than Significant Impact With General Plan EIR Mitigation and/or COAs. Based on the Cultural and Paleontological Resources Memo prepared for the project (refer to Appendix D), the records search conducted did not identify any paleontological resources within the project site.

However, 92 localities with vertebrate and invertebrate paleontological resources have been found within 10 miles of the project site from geologic formations similar to those underlying the project

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.7-9 Geology and Soils
site and just outside its bounds. Per mitigation impact guidelines set forth by the Society of Vertebrate Paleontology, due to the fossil sensitivity of the rock formations present within the project area (young alluvial floodplain sediments and the Capistrano Formation siltstone facies), the project has a high potential to disturb paleontological resources within undisturbed bedrock and sediments. The Cultural and Paleontological Resources Memo determined that there is potential for encountering paleontological resources if undisturbed quaternary young alluvial floodplain deposits are encountered below the natural surface, or if Capistrano Formation Bedrock is encountered at any depth.

In accordance with General Plan EIR Mitigation Measure 4-2, a site-specific paleontological resources study has been prepared for the project site; refer to Appendix D. Based on General Plan EIR Mitigation Measure 4-2, on properties determined to be moderately to highly sensitive for paleontological resources. The paleontological study should provide a detailed mitigation plan, including a monitoring program and recovery and/or in situ preservation plan, based on the recommendations of a qualified paleontologist (enforced through COA GEO-1). COA GEO-1 requires full-time paleontological monitoring during ground disturbance activities in undisturbed geologic contexts [i.e., bedrock and outcrops) that have the potential to contain significant paleontological resources]). Further, the project would comply with General Plan policies that address the management of artifacts (Policy NR-3.01) and the notification and inventory of archeological and paleontological resources (Policies NR-3.02 and 3.03). Following compliance with General Plan policies NR-3.01, 3.02, and 3.02 and General Plan EIR Mitigation Measure 4-2 (enforced through COA GEO-1), the proposed project would result in less than significant impacts to paleontological resources.

Applicable General Plan EIR Mitigation Measures:
4-2 City staff shall require applicants for development permits to provide studies by qualified paleontologists assessing the sensitivity of sites for buried paleontological resources. On properties determined to be moderately to highly sensitive for paleontological resources, such studies shall provide a detailed mitigation plan, including a monitoring program and recovery and/or in situ preservation plan, based on the recommendations of a qualified paleontologist.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.7-10 Geology and Soils
Applicable Conditions of Approval (COA): Refer to Response 3.1.2(d), COA 1.9.

COA GEO-1 Paleontological Monitoring. Full-time paleontological monitoring is recommended during ground disturbance activities in undisturbed geologic contexts (i.e., bedrock and outcrops) that have the potential to contain significant paleontological resources.

If any paleontological resources are encountered at the project area during construction or the course of any ground-disturbance activities, all such activities within 100 feet of the find shall halt immediately. At this time, the Applicant shall notify the City and consult with the qualified paleontologist to assess the significance of the find. The assessment will follow SVP (2010) standards. If any find is determined to be significant, appropriate avoidance measures recommended by Michael Baker International and approved by the City must be followed unless avoidance is determined to be unnecessary or infeasible by the City. If avoidance is unnecessary or infeasible, other appropriate measures (e.g., data recovery, excavation) shall be instituted.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.7-11 Geology and Soils
• The SVP-qualified paleontologist shall ensure that all significant fossils collected are cleaned, identified, catalogued, and permanently curated with an appropriate institution with a research interest in the materials as required by the SVP guidelines. The Cooper Lab in Santa Ana is a potential repository for this project area.
• The SVP-qualified paleontologist shall ensure that specialty studies are completed, as appropriate, for any significant fossil collected. • The SVP-qualified paleontologist shall ensure that curation of fossils is completed in consultation with the City. A letter of acceptance from the curation institution shall be submitted to the City upon curation.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.7-12 Geology and Soils
This page intentionally left blank.

March 2026 3.8-1 Greenhouse Gas Emissions

3.8 GREENHOUSE GAS EMISSIONS

3.8.1 General Plan EIR Summary
Significant and Unavoidable Impacts. According to the General Plan EIR, greenhouse gas (GHG) impacts within the City of San Clemente (City) from full buildout of the proposed General Plan would not achieve the long-term GHG reductions goals under Executive Order S-03-05 and would cumulatively contribute to the long-term GHG emissions in the State. Although no mitigation measures were recommended, the General Plan EIR considered adoption of the City of San Clemente’s Climate Action Plan (CAP) as part of the project and reduction measures implemented as a result of the CAP were considered. The CAP sets GHG reduction targets for the City to achieve.

Additionally, the CAP includes measures for the City to implement in support of achieving the reduction targets. As such, the policies included in the General Plan are consistent with the CAP. The City’s CAP ensures that GHG emissions from buildout of the General Plan would be minimized.

However, additional Statewide measures would be necessary to reduce GHG emissions under buildout of the General Plan to meet the long-term GHG reduction goals under Executive Order S03-05, which identified a goal to reduce GHG emissions to 80 percent of 1990 levels by 2050. At the time the General Plan EIR was prepared; there was no plan past 2020 that achieves the long-term GHG reduction goal established under S-03-05. As identified by the California Council on Science and Technology (CCST), the State cannot meet the 2050 goal without major advancements in technology. Since no additional Statewide measures are currently available, cumulative GHG impacts due to the implementation of the General Plan would remain significant and unavoidable, and no additional feasible mitigation measures are available.

3.8.2 Project-Specific Impacts
Would the project:

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.8-2 Greenhouse Gas Emissions
Less than Significant Impact.

THRESHOLDS OF SIGNIFICANCE
Amendments to CEQA Guidelines Section 15064.4 were adopted to assist lead agencies in determining the significance of the impacts of GHG emissions. Consistent with existing CEQA practice, Section 15064.4 gives lead agencies the discretion to determine whether to assess those emissions quantitatively or qualitatively. This section recommends certain factors to be considered in the determination of significance (i.e., the extent to which a project may increase or reduce GHG emissions compared to the existing environment; whether the project exceeds an applicable significance threshold; and the extent to which the project complies with regulations or requirements adopted to implement a plan for the reduction or mitigation of GHGs). The amendments do not establish a quantified or performance-based threshold of significance; rather, lead agencies are granted discretion to establish significance thresholds for their respective jurisdictions, including looking to thresholds developed by other public agencies or suggested by other experts, such as the California Air Pollution Control Officers Association (CAPCOA), so long as any threshold chosen is supported by substantial evidence (see CEQA Guidelines Section 15064.7(c)).

The California Natural Resources Agency (CNRA) has also clarified that the CEQA Guidelines amendments focus on the effects of GHG emissions as cumulative impacts, and therefore GHG emissions should be analyzed in the context of CEQA’s requirements for cumulative impact analyses (see CEQA Guidelines Section 15064(h)(3)). A project’s incremental contribution to a cumulative impact can be found not cumulatively considerable if the project would comply with an approved plan or mitigation program that provides specific requirements to avoid or substantially lessen the cumulative problem within the geographic area of the project (see 14 CCR Section 15064[h][3].) However, CEQA Guidelines Section 15064.4 does not establish a threshold of significance. CEQA Guidelines Section 15064.6 provides lead agencies the discretion to establish significance thresholds for their respective jurisdictions, and in establishing those thresholds, a lead agency may appropriately look to thresholds developed by other public agencies or suggested by other experts, if any threshold chosen is supported by substantial evidence.

The City has not adopted a numerical significance threshold for assessing impacts related to GHG emissions nor California Air Resources Board (CARB), or any other State or regional agency adopted a numerical significance threshold for assessing GHG emissions that is applicable to the proposed project. It should be acknowledged that South Coast Air Quality Management District (SCAQMD) has adopted a significance threshold of 10,000 metric tons of carbon dioxide equivalent (MTCO2e) per year for permitted (stationary) sources of GHG emissions for which SCAQMD is the designated lead agency. To provide guidance to local lead agencies on determining significance for GHG emissions in their CEQA documents, SCAQMD has convened a GHG CEQA Significance Threshold Working Group (Working Group). Based on the last Working Group meeting held in September 2010 (Meeting No. 15), SCAQMD has proposed to adopt a tiered approach for evaluating GHG emissions for development projects where SCAQMD is not the lead agency. Under the tier approach, several conditions could be utilized to determine if a project could be presumed to result in less than significant GHG impacts and be exempt from detailed GHG assessment. For projects that

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.8-3 Greenhouse Gas Emissions
are not exempt or where no qualifying GHG reduction plans are directly applicable, SCAQMD has proposed a “bright-line” screening-level threshold of 3,000 MTCO2e annually for all land use types or the following land-use-specific thresholds: 1,400 MTCO2e for commercial projects, 3,500 MTCO2e for residential projects, or 3,000 MTCO2e for mixed-use projects. For projects that exceed the screening threshold under the tier approach, SCAQMD has proposed per capita efficiency targets, including a 2020 efficiency target of 4.8 MTCO2e per year per service population (MTCO2e/year/SP) for project-level analyses and 6.6 MTCO2e /year/SP for plan level projects (e.g., program-level projects such as general plans). The per capita efficiency targets are based on the AB 32 GHG reduction target and 2020 GHG emissions inventory prepared for CARB’s 2008 Scoping Plan. It should be noted that the General Plan EIR discussed SCAQMD’s tier approach and the associated efficiency target. The General Plan EIR utilized the efficiency threshold of 6.6 MTCO2 per year per SP for year 2020 and 4.0 MTCO2 per year per SP for the year 2035, interpolated from Executive Order S-03-05 with a long-term GHG reduction target for 2050 (i.e., 80 percent below 1990 levels).

However, the tier approach proposed in Meeting No. 15 was never adopted by the SCAQMD.

It should be noted that the General Plan EIR was prepared and adopted in 2013, and Statewide GHG reduction target has been updated since. As previously discussed, the SCAQMD has yet to adopt a GHG threshold. As such, the project’s consistency with applicable Statewide, regional, and local plans adopted for reducing GHG emissions is used to determine the significance of the project’s GHGrelated impacts on the environment. However, for informational purposes, quantitative GHG emissions have also been provided below.

PROJECT-RELATED SOURCES OF GREENHOUSE GASES
The proposed project would result in direct and indirect GHG emissions. Direct project-related GHG emissions would include emissions from construction activities, area sources, mobile sources, and refrigerants, while indirect sources would include emission from energy consumption, water demand, and solid waste generation. The most recent version of the California Emissions Estimator Model (CalEEMod), version 2022.1 was used to calculate project-related GHG emissions; refer to Appendix B, Air Quality/GHG/Energy Data. Table 3.8-1, Estimated Greenhouse Gas Emissions presents both direct and indirect GHG emissions.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.8-4 Greenhouse Gas Emissions
Table 3.8-1
Estimated Greenhouse Gas Emissions
Source CO2 CH4 N2O Refrigerants CO2e
Metric Tons/year1
Direct Emissions
Construction (amortized over 30 years) 226.80 0.01 0.02 0.27 232.60 Area Source 2,366.00 0.10 0.09 3.31 2,399.00
Mobile Source 1.47 <0.01 <0.01 0.00 1.47
Refrigerants -- -- -- 7.77 7.77
Total Direct Emissions2 2,594.27 0.11 0.11 11.35 2,640.84 Indirect Emissions
Energy 88.00 0.02 <0.01 0.00 88.80
Water Demand 0.95 0.07 <0.01 0.00 3.13
Solid Waste 4.81 0.48 0.00 0.00 16.80
Total Indirect Emissions2 93.76 0.57 0.00 0.00 108.73
Total Project-Related Emissions2 2,749.57 MTCO2e/year
Notes:

1. Emissions calculated using California Emissions Estimator Model Version 2022.1 (CalEEMod) computer model.

2. Totals may be slightly off due to rounding.

Source: Refer to Appendix B, Air Quality/GHG/Energy Data.

CONSTRUCTION EMISSIONS
Construction sources of GHG emissions include GHG emissions from construction equipment operation on-site and construction worker vehicle trips to and from the project site, and from construction material deliveries to and from the project site. Construction input data for CalEEMod include, but are not limited to, (1) the anticipated start and finish dates of construction activity; (2) inventories of construction equipment to be used; and (3) trips associated with construction activities (i.e., hauling, vendor, and worker trips). Construction GHG emissions were quantified by estimating the types and quantity of equipment that would be used on-site during each construction phase, as provided by the model defaults. CalEEMod also includes off-site GHG emissions from worker, vendor, and hauling truck trips. The project would be constructed as a single phase with an 18-month construction period. Anticipated construction activities include grading, paving, building construction, and architectural coating. It is anticipated that approximately 14,300 cubic yards (CY) of cut will be exported over approximately 30 hauling days.

Construction GHG emissions are amortized (i.e., total construction emissions divided by the lifetime of the project, assumed to be 30 years),15 then added to the operational emissions. As shown in Table

3.8-1, construction of the proposed project would result in a total of 232.60 MTCO2e per year when amortized over 30 years. This would represent a total of approximately 6,978.00 MTCO2e from all construction activities.
15 In accordance with SCAQMD guidance, projected GHGs from construction have been quantified and amortized over 30 years, which is the number of years considered to represent the life of the project. The amortized construction emissions are added to the annual average operational emissions.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.8-5 Greenhouse Gas Emissions
Mobile Source Emissions
Mobile source GHG emissions are estimated by multiplying the project’s total vehicle miles traveled (VMT) by the vehicle emission factors. The vehicle emission factors were CalEEMod default values for the Orange County. Project-generated vehicle emissions have been estimated using CalEEMod based on the project’s average daily trips per the San Clemente 1801 N. El Camino Real – VMT Screening Assessment (VMT Screening Assessment), dated February 2, 2026, prepared by Michael Baker International; refer to Appendix H.2, VMT Screening Assessment. The proposed project would result in approximately 2,399.00 MTCO2e per year of mobile source-generated GHG emissions as modeled in CalEEMod; refer to Table 3.8-1.

Area Source Emissions
GHG emissions associated with area sources include consumer products, landscape maintenance, and architectural coating. Exhaust emissions generated from landscape maintenance equipment such as lawnmowers, shedders/grinders, blowers, trimmers, chain saws, and hedge trimmers. Area source GHG emissions were calculated using standard emission rates from CARB, EPA, SCAQMD, and CalEEMod model defaults. As noted in Table 3.8-1, the proposed project would result in 1.47 MTCO2e per year of area source GHG emissions.

Refrigerants
Refrigerants are substances used in equipment for air conditioning and refrigeration. Most of the refrigerants used today are hydrochlorofluorocarbons (HFCs) or blends thereof, which can have high global warming potential (GWP) values. All equipment that use refrigerants have a charge size (i.e., quantity of refrigerant the equipment contains), and an operational refrigerant leak rate, and each refrigerant has a GWP that is specific to that refrigerant. CalEEMod quantifies refrigerant emissions from leaks during regular operation and routine servicing over the equipment lifetime and then derives average annual emissions from the lifetime estimate. As noted in Table 3.8-1, the proposed project would result in 7.77 MTCO2e per year of GHG emissions from refrigerants.

Energy Consumption
Energy consumption emissions were calculated using CalEEMod and project-specific land use data.

As detailed in Section 2.3.6, Utilities, the site has utility services adjacent to the site from San Diego Gas & Electric (serving gas and electricity upon the construction of on-site utility infrastructure). The project would indirectly result in 88.80 MTCO2e per year of GHG emissions due to energy consumption; refer to Table 3.8-1.

Water Demand
The project would be required to comply with California Green Building Standards Code (CALGreen), which requires newer developments to be fitted with low flow plumbing fixtures and fittings, as well as water-efficient landscaping. Water consumption from the proposed project was

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.8-6 Greenhouse Gas Emissions
calculated using CalEEMod default values. Emissions from indirect energy impacts due to water supply would result in 3.13 MTCO2e per year; refer; refer to Table 3.8-1.

Solid Waste
CalEEMod quantifies GHG emissions associated with solid waste in landfills. While the proposed project would not directly emit GHG emissions from solid waste, CalEEMod quantifies the GHG emissions from the decomposition over a span of 20 to 30 years of solid waste generated from a project. Solid waste associated with operations of the proposed project would result in 16.80 MTCO2e per year; refer to Table 3.8-1.

CONCLUSION
Overall, as shown in Table 3.8-1, the total amount of project related operational GHG emissions from direct and indirect sources combined would be 2,749.57 MTCO2e per year. Nonetheless, as detailed above, the City has not adopted a numerical significance threshold for assessing impacts related to GHG emissions, nor have the SCAQMD, CARB, or any other State or regional agency adopted a numerical GHG significance threshold for assessing GHG emissions that is applicable to the project.

As such, the project’s consistency with applicable Statewide, regional, and local plans adopted for reducing GHG emissions is used to determine the significance of the project’s GHG-related impacts on the environment, and quantitative GHG emissions provided above are for informational purposes only. As shown under Response 3.8(b) below, the project would be consistent with CARB’s 2022 Scoping Plan, SCAG’s Connect SoCal 2024, and the City’s CAP. As such, the project would result in less than significant impacts in regard to GHG emissions and such impacts were considered as part of buildout of the General Plan.
b) Conflict with an applicable plan, policy, or regulations adopted for the purpose of reducing the emissions of greenhouse gases?
Less than Significant Impact. As Statewide GHG reduction target has been updated since the City adopted in its CAP in February 2014, this consistency analysis would focus on project’s consistency with newer plans adopted for the purpose of reducing the emissions of GHG including the Regional Council of the Southern California Association of Governments’ (SCAG’s) Connect SoCal, A Plan for Navigating to a Brighter Future (Connect SoCal 2024; most recent Regional Transportation Plan/Sustainable Communities Strategy [RTP/SCS]), CARB’s 2022 Scoping Plan for Achieving Carbon Neutrality (2022 Scoping Plan, the latest Climate Change Scoping Plan), in addition to the City’s CAP.

The 2022 Scoping Plan was developed to achieve carbon neutrality by 2045 through a substantial reduction in fossil fuel dependence, while at the same time increasing deployment of efficient noncombustion technologies and distribution of clean energy. Connect SoCal 2024 incorporates local land use projections and circulation networks in city and county general plans and sets forth a forecasted regional development pattern which, when integrated with the transportation network, measures, and policies, will reduce GHG emissions from automobiles and light-duty trucks and achieve the GHG emissions reduction target for the region set by the CARB. The City’s CAP outlines GHG reduction

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.8-7 Greenhouse Gas Emissions
measures for various sectors, including transportation, land use, energy, solid waste, water, and wastewater.
2022 SCOPING PLAN CONSISTENCY ANALYSIS
The 2022 Scoping Plan identifies reduction measures necessary to achieve the goal of carbon neutrality by 2045 or earlier. Actions that reduce GHG emissions are identified for each Assembly Bill 32 (AB 32) inventory sector. Provided in Table 3.8-2, 2022 Scoping Plan Project Consistency Analysis , is an evaluation of applicable reduction actions/strategies by emissions source category to determine how the project would be consistent with or exceed reduction actions/strategies outlined in the 2022 Scoping Plan.

Table 3.8-2
2022 Scoping Plan Consistency Analysis
Actions and Strategies Project Consistency Analysis
Smart Growth / Vehicles Miles Traveled (VMT)
Reduce VMT per capita
to 25% below 2019
levels by 2030, and
30% below 2019 levels
by 2045
Consistent. As detailed in Section 3.17, Transportation, based on the VMT Screening Assessment, the project meets the screening criteria based on the “Project in HighQuality Transit Area (HQTA)” and is presumed to have a less than significant transportation impact. The project is surrounded by existing alternative transportation options with the San Clemente Metrolink Station located approximately 200 feet south and southwest. As a commercial development, the project would introduce jobs adjacent to a major transit station, thus reducing VMT. Therefore, the project would focus growth near destinations and mobility options.

New Residential and Commercial Buildings
All electric appliances
beginning 2026
(residential) and 2029
(commercial),
contributing to 6
million heat pumps
installed statewide by
2030
Consistent. The project is expected to consist of natural gas heating and/or cooking onsite. The City of San Clemente has not adopted an ordinance or program limiting the use of natural gas for on-site cooking and/or heating. However, if adopted, the project would comply with the applicable goals or policies limiting the use of natural gas equipment in the future. Furthermore, the project would install high efficiency lighting and appliances. As such, the project would be consistent with this action.

Construction Equipment
Achieve 25% of energy
demand electrified by
2030 and 75%
electrified by 2045
Not Applicable. It should be noted that project construction is proposed to be completed prior to 2030. As such, the project would not be required to have 25 percent of construction equipment energy demand electrified. Additionally, the City of San Clemente has not adopted an ordinance or program requiring electricity-powered construction equipment which would be consistent with the 2022 Scoping Plan.

However, if such programs or ordinances are adopted in the future, the project would be required to comply with the applicable goals or policies requiring the use of electric construction equipment in the future.

Non-combustion Methane Emissions

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.8-8 Greenhouse Gas Emissions
Actions and Strategies Project Consistency Analysis
Divert 75% of organic
waste from landfills by
2025
Consistent. SB 1383 establishes targets to achieve a 50 percent reduction in the level of Statewide disposal of organic waste to a 75 percent reduction by 2025. The law establishes an additional target that not less than 20 percent of currently disposed edible food is recovered for human consumption by 2025. The project would comply with local and regional regulations during its operational phase.

Source: California Air Resources Board, 2022 Scoping Plan, November 16, 2022.

Connect SoCal 2024 Consistency Analysis
The latest Connect SoCal 2024 was adopted by SCAG on April 4, 2024. The goals established for Connect SoCal 2024 provide a foundation for setting a vision for how the future of the SCAG Region will evolve over the next 25 years. The plan performance assessment process provides an important means for determining how well the program of investments included in Connect SoCal correspond to its foundational goals and to its vision for the future of the SCAG Region. Table 3.8-3, Connect SoCal 2024 Project Consistency Analysis, shows the project’s consistency with the four categories found within the Connect SoCal 2024. The Connect SoCal 2024 consists of a set of four high-level goals, as presented in Table 3.8-2. Each of the four Connect SoCal goals are supported by three sub-goals which provide more specific objectives within that specific focus area. The plan performance measures are designed to support achievement of these regional goals and sub-goals, with many of the measures supporting multiple goals. As shown, the proposed project would be consistent with the GHG emission reduction strategies contained in the Connect SoCal 2024.

Table 3.8-2
Connect SoCal 2024 Project Consistency Analysis
Goals and Sub-Goals Project Consistency Analysis
Mobility: Build and maintain an integrated multimodal transportation network Support investments that are wellmaintained and operated, coordinated, resilient and result in
improved safety, improved air
quality and minimized greenhouse
gas emissions
Consistent. The project is an infill development located in close proximity to a major transit station (200 feet from the San Clemente Metrolink Station). As such, the project would provide future temporary accommodation for transit users which promotes reliable and safe multimodal transportation. Bicycle facilities and sidewalks occur along both northbound and southbound East Avenida Pico to the east, as well as eastbound and westbound North El Camino Real to the south. Bus stops serving Orange County Transportation Authority (OCTA), Metrolink, and San Clemente Trolley bus lines are provided along East Avenida Pico and North El Camino Real. Further, the project would also install electric vehicle (EV) charging stations and include parking spaces for EVs and bicycles in accordance with CALGreen. As detailed in Section 3.3, Air Quality, the project would not result in significant air quality impacts; as demonstrated throughout this section, the project would not result in significant GHG impacts either. As such, the project would be well-maintained and operated, coordinated, and resilient, and would not worsen air quality or exacerbate GHG impacts.

Ensure that reliable, accessible,
affordable and appealing travel
options are readily available, while
Consistent. As detailed above, the proposed mixed-use hotel development would provide future temporary accommodation for transit users which promotes reliable and safe multimodal transportation. As a commercial development, the project would also

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.8-9 Greenhouse Gas Emissions
Goals and Sub-Goals Project Consistency Analysis
striving to enhance equity in the
offerings in high-need communities
introduce jobs adjacent to a major transit station, thus reducing VMT. As such, the project would help ensure that reliable, accessible, affordable and appealing travel options exist.

Support planning for people of all
ages, abilities and backgrounds
Consistent. As a commercial development, the project would introduce jobs adjacent to a major transit station, providing job opportunities for people in the community.

Communities: Develop, connect and sustain livable and thriving communities.

Create human-centered
communities in urban, suburban and
rural settings to increase mobility
options and reduce travel distances
Not Applicable. The proposed project is not a housing development. As such, this goal is not applicable to the proposed project. However, the proposed hotel would enhance pedestrian mobility by constructing sidewalks along southbound East Avenida Pico and eastbound North El Camino Real would be constructed at the eastern and southern boundaries of the site and promote multimodal transportation by installing EV charging stations and including parking spaces for EV and bicycle in accordance with CALGreen.

The project is also an infill development providing short-term accommodation to transit users based on its in close proximity to a major transit station (200 feet from the San Clemente Metrolink Station). As such, the project would increase mobility options and reduce travel distance.

Produce and preserve diverse
housing types in an effort to improve
affordability, accessibility and
opportunities for all households
Not Applicable. The proposed project is not a housing development. As such, this goal is not applicable to the proposed project.

Environment: Create a healthy region for the people of today and tomorrow.

Develop communities that are
resilient and can mitigate, adapt to
and respond to chronic and acute
stresses and disruptions, such as
climate change
Not Applicable. The proposed project is not a housing development. As such, this goal is not applicable to the proposed project.

Integrate the region’s development
pattern and transportation network to
improve air quality, reduce
greenhouse gas emissions and
enable more sustainable use of
energy and water
Consistent. As detailed in Section 3.3, Air Quality, the project would not result in significant air quality impacts; as demonstrated throughout this section, the project would not result in significant GHG impacts either. Further, the project would install energy efficient appliances in accordance with the latest Title 24 and install waterefficient irrigation systems as mandated by CALGreen. As such, the project would not worsen air quality, increase greenhouse gas emissions, and would enable more sustainable use of energy and water.

Conserve the region’s resources. Consistent. As demonstrated throughout this Checklist, the proposed project would not deplete or result in significant adverse impacts to the region’s resources including biological resources, cultural resources, energy, paleontological resources, water, mineral resources, tribal cultural resources, among others.

Economy: Support a sustainable, efficient and productive regional economic environment that provides opportunities for all people in the region
Improve access to jobs and
educational resources
Consistent. As a commercial development, the project would introduce jobs adjacent to a major transit station (200 feet from the San Clemente Metrolink Station), providing job opportunities for people in the community.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.8-10 Greenhouse Gas Emissions
Goals and Sub-Goals Project Consistency Analysis
Advance a resilient and efficient
goods movement system that
supports the economic vitality of the
region, attainment of clean air
and quality of life for our communities
Not Applicable. As a hotel that would not directly impact goods movement system, this subgoal is not applicable.

Source: Southern California Association of Governments, Connect SoCal, A Plan for Navigating to a Brighter Future, Chapter 3, The Plan, April 4, 2024.

CITY OF SAN CLEMENTE CLIMATE ACTION PLAN CONSISTENCY ANALYSIS The CAP identifies a comprehensive set of targets and related measures that the City will use to reduce GHG emissions and achieve the GHG reduction targets of AB 32. These actions include a combination of General Plan programs, City Council policies, resolutions, and incentives, as well as outreach and education activities. Specifically, the City of San Clemente selected a goal to reduce its community GHG emissions to a level that is 37.7 percent below its 2009 GHG emissions level by 2030.16 The CAP notes that the City will meet and exceed this goal subject to reduction measures that are technologically feasible and cost-effective through a combination of state (approximately 74 percent) and local (approximately 26 percent) efforts.

Reduction measures outlined in the CAP are categorized under four categories: Alternative Transportation, Land Use, Energy Efficiency, and Waste Reduction. While all of the measures focused on City’s action and are not directly applicable to a development project, the proposed project would be consistent with some of the measures that aim to promote multimodal transportation and reduce energy consumption. For instance, the project would promote pedestrian connectivity by constructing sidewalks along southbound East Avenida Pico and eastbound North El Camino Real would be constructed at the eastern and southern boundaries of the site, respectively; encourage the use of bicycle and clean air vehicle by including bike racks and designating EV parking spaces with EV chargers installed; and reduce energy consumption by installing energy efficient appliances and committing to waste diversion goals. As such, the proposed project would not conflict with any community actions proposed with the City’s CAP. Impacts would be less than significant.

CONCLUSION
As shown in Table 3.8-2 and Table 3.8-3, the project would be consistent with CARB’s 2022 Scoping Plan, SCAG’s Connect SoCal 2024, and the City’s CAP. As such, the project would result in less impacts pertaining to greenhouse gas emissions.
16 City of San Clemente, Climate Action Plan, Table 3, Recommended Municipal Operation Reduction Targets and Emission Levels 2020 and 2030, 2014.

March 2026 3.9-1 Hazards and Hazardous Materials

3.9 HAZARDS AND HAZARDOUS MATERIALS

3.9.1 General Plan EIR Summary
Less Than Significant Impact. The General Plan EIR noted that the alteration of land uses under the General Plan may contribute to public exposure and environmental hazards during transport, use, or disposal of hazardous materials. Specifically, the transport of hazardous materials along I-5, the railroad, and the City’s local roadways creates potential risks for spills or leaks from nonstationary source; seismic activity, flooding, marine hazards, and fires can result in hazardous materials being released onto land or into the air and water, contaminating the environment and endangering public safety. Development under the General Plan would increase the number of residents and businesses within the City, resulting in an increase in the number of hazardous materials being transported, used, and stored, and the amount of people being exposed to these materials. This would also result in an increase in the frequency of transport, use, and disposal of hazardous materials associated with commercial and industrial growth within San Clemente.

The General Plan EIR noted that accidental releases of hazardous materials can occur from a variety of causes, including highway incidents, warehouse fires, train derailments, shipping accidents, and industrial incidents. An increase in the transport of hazardous waste from an increased demand for transport, use, and disposal, within or outside the City, could result in upset or accidental conditions resulting in the release of hazardous materials. However, the increase in the transport of hazardous materials as a result of the proposed project would be limited to areas along interstates and rail lines, where commercial and industrial uses would be concentrated. Some transport of hazardous materials may occur near small commercial pockets proposed throughout various areas of the City. No facilities that are registered transporters of hazardous waste were identified on the Active Hazardous Waste Transporter Database for Orange County. As described in Response 3.9(a), construction and operation related to implementation of the General Plan would comply with all applicable existing local, State, and federal regulations to minimize potential impacts from hazardous materials.

Additionally, the General Plan EIR found that redevelopment under the General Plan may involve demolition of older buildings that contain asbestos-containing materials (ACM) or lead-based paint (LBP). Future development requiring demolition would be required to comply with the California Health and Safety Code, Occupational Safety and Health Administration (OSHA), and SCAQMD Rule 1403 related to removal of ACMs and LBPs. Compliance would require the preparation of LBP and ACM surveys for any building demolitions and appropriate remediation measures for removal of LBP and ACM during demolition activities. Overall, compliance with the existing regulations including the California Health and Safety Code, OSHA, and SCAQMD Rule 1403 (related to removal of ACM and LBP) would ensure impacts related to the accidental release of hazardous material would be minimized. Impacts would be less than significant.

The General Plan EIR noted that there are 62 hazardous materials sites listed on the DTSC’s EnviroStor or SWRCB’s GeoTracker databases. Among the 62 sites, five were leaking underground storage tank (UST) sites that were being remediated or monitored, two were dry cleaning facilities that were referred to other agencies, three were for site assessment activities at the Northrop Grumman facility, and one was a former burn dump; the remaining identified sites have received regulatory agency closure approval. The General Plan proposes new commercial and industrial development primarily focused within specific areas. A new medical office overlay would be created in the Camino de Estrella/Camino de los Mares Focus Area and an increase in FAR to encourage new and expanded businesses would occur in the Rancho San Clemente Business Park. Mixed uses would also be allowed

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.9-2 Hazards and Hazardous Materials
within the North Beach/North El Camino Real and South of El Camino Real Focus Areas. New businesses/users would be required to follow the same regulations as existing businesses/users, and the number of sites would not increase substantially from the existing quantity. The Orange County Environmental Health implements the Hazardous Waste Inspection Program for business in San Clemente to ensure that all hazardous wastes generated by businesses are properly handled, recycled, treated, stored, and disposed. The General Plan also contains policies and programs to ensure compliance with federal, state, and local regulations relating to hazardous wastes (Policies S-6.01–

6.06). The majority of new businesses would also be in the same general areas that they are now and would not be expanded into sensitive communities. All environmental investigations, sampling, and/or remediation for projects within the City shall be conducted under the oversight of a regulatory agency that has jurisdiction. Overall, compliance with existing regulations would ensure that there would not be any significant impacts. Impacts would be less than significant in this regard.

As detailed in the General Plan EIR Initial Study, included as Appendix A of the General Plan EIR, the closest airport to the City is the John Wayne Airport, approximately 25 miles northwest of the project site. There are no public or public use airports in, or in the general vicinity of San Clemente.

Therefore, no impacts would occur in this regard.

As detailed in the General Plan EIR, San Clemente’s Emergency Planning Office, within Public Works, manages disaster preparedness by maintaining the City’s Multi-Hazard Emergency Plan.

Municipal Code Chapter 8.12, Emergency Services, defines the City’s emergency functions and structure.

The Multi-Hazard Emergency Plan outlines hazards, assigns agency responsibilities, establishes coordination with other jurisdictions, defines the emergency response structure, details preplanned response actions, sets procedures for public information, identifies available resources, and guides training for emergency workers. The Orange County Fire Authority Emergency Command Center provides additional emergency and hazardous materials response. The City of San Clemente also participates in the State-required Standardized Emergency Management System (SEMS) including Incident Command System (ICS), the Master Mutual Aid Agreement, the Operational Area concept, and multiagency coordination. Overall, the General Plan determined that implementation of existing programs would ensure impacts would be less than significant in this regard.

As detailed in the General Plan EIR, a large percentage of the City is designated by CAL FIRE as Moderate, High, and Very High Fire Hazard Severity Zones. The City participates in the OCFA Pre‑Fire Management Program, which includes wildland fire planning and fuel‑modification oversight.

Local fire codes also allow OCFA to require brush clearance, hazard studies, and other site‑specific safety measures. New development in areas with combustible vegetation must submit fuel modification plans that meet OCFA guidelines before approval. Overall, upon implementation of regulatory requirements and the General Plan policies and programs, the General Plan EIR determined that impacts would be less than significant in this regard.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.9-3 Hazards and Hazardous Materials

3.9.2 Project-Specific Impacts
Would the project:

Less than Significant Impact. Construction may involve temporary hazards related to the transport, use and disposal of hazardous materials, including those used for typical construction activities (i.e., diesel fuel, motor oil, etc.). Construction contractors would be required to comply with all applicable federal, State, and local laws and regulations regarding the transport, use, storage, and disposal of

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.9-4 Hazards and Hazardous Materials
hazardous construction-related materials, including but not limited requirements imposed by the United States Environmental Protection Agency (U.S. EPA), California Department of Toxic Substances Control (DTSC), the SCAQMD, San Diego Regional Water Quality Control Board (San Diego RWQCB), and/or the Orange County Health Care Agency Environmental Health Division (Orange County Environmental Health; the Certified Unified Program Agency [CUPA] for the City for San Clemente). Thus, construction related impacts due to transport, use, and disposal of hazardous materials would be less than significant.

The project proposes a mixed-use hotel with retail/restaurant uses. Such land uses are not typically associated with the transport, use, storage, or disposal of hazardous materials. Toxic substances used and stored for this commercial use are usually low in concentration and small in quantity; therefore, there is no significant risk to humans or the environment. In addition, hazardous materials and hazardous waste programs are managed by the Orange County Environmental Health , CUPA for the City for San Clemente. The CUPA is charged with the responsibility of conducting compliance inspections for regulated facilities that handle hazardous material above certain quantities (e.g., a retail use that sells cleaning supplies and/or pool supplies). The CUPA administers permits, inspection activities, and enforcement activities. The use of any hazardous materials for operation of the proposed project would be regulated by the CUPA through a Hazardous Materials Release Response Plan and Inventory (Business Plan). Compliance with the CUPA permit requirements would reduce potential impacts to a less than significant level.

b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
Less than Significant Impact. One of the means through which human exposure to hazardous substances could occur is through accidental release. Incidents that result in an accidental release of hazardous substances into the environment can cause contamination of soil, surface water, and groundwater, in addition to any toxic fumes that might be generated. Human exposure of contaminated soil, soil gas, or water can have potential health effects based on a variety of factors, such as the nature of the contaminant and the degree of exposure.

CONSTRUCTION-RELATED IMPACTS
During construction, there is a possibility of accidental release of hazardous substances such as petroleum-based fuels or hydraulic fluid used for construction equipment. The level of risk associated with the accidental release of hazardous substances is not considered significant due to the small volume and low concentration of hazardous materials utilized for construction equipment. The construction contractor would be required to use standard construction controls and safety procedures that would minimize and/or avoid accidental release of such substances into the environment. Standard construction practices would be observed such that any materials released are appropriately contained and remediated as required by local, State, and federal law. As such, impacts in this regard would be less than significant.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.9-5 Hazards and Hazardous Materials
Construction Activities
Proposed grading activities could also result in accidental conditions involving existing on-site contamination. Based on the conditions of the project site, vacant and disturbed, there have been no reported operations at the project site that could have resulted in releases to the on-site soils, surface water, or groundwater, such that accidental conditions during construction would be anticipated. The project site has not been developed, nor reported the use, storage, or transport of hazardous materials at the site. Based on the current and past land uses, the project site is not anticipated to be associated with hazardous materials or substances. Further, the project site is not listed pursuant to Government Code Section 65962.5 (also known as the “Cortese Listing”).17 Past activities on-site have included past storage of off-site materials/soils and could include hazardous substances/materials from an off-site use; however, such activities would have been required to be conducted in accordance with existing State laws and regulations governing the reuse of soils. As such, the Geotechnical Investigation include recommendations pertaining to soil import/export during construction. With compliance with these existing laws and regulations regarding soil reuse, such impacts would be less than significant.

For potential conditions at the project site as a result of off-site properties, based on the State Water Resources Control Board’s (SWRCB’s) online database GeoTracker, several adjoining and adjacent properties within the vicinity of the project site were listed for past leaking UST (or LUST sites):
18 • San Clemente Car Wash (1731 El Camino Real) – case closed as of April 1, 2021; • U Haul Center #717-21 (310 Avenida Pico) – case closed as of November 4, 1996; • City of San Clemente (1801 Ave Estacion) – case closed as of May 2, 1989; and • Fred Stier Auto Sales Lot (1645 El Camino Real) – case closed as of April 1, 2019.

Each of these off-site properties have completed remedial activities in accordance with federal, State, and local laws and regulations and received case closure from the SWRCB. As such, the project site is not anticipated to have potential soil gas or groundwater concerns as a result of these off-site properties. Additionally, the San Clemente Metrolink Station is located approximately 200 feet further south and southwest of the project site. Transport of hazardous materials is common would be limited to areas along interstates and rail lines and are not anticipated to have significantly impacted the project site. Nonetheless, the construction contractor would be required to use standard construction controls and safety Occupational Safety and Health Administration (OSHA) procedures that would minimize and/or avoid accidental release of such substances into the environment. Standard construction practices would be observed such that any materials released are appropriately contained and remediated as required by local, State, and federal law. Upon compliance to existing local, State, and federal regulations pertaining to the accidental release of hazardous materials, less than significant impacts would occur in this regard.
17 California Environmental Protection Agency, Cortese List Data Resources, https://calepa.ca.gov/SiteCleanup/ CorteseList/, accessed on December 2, 2025. 18 State Water Resources Control Board, GeoTracker, https://geotracker.waterboards.ca.gov/map/?global_id=T0605902536, accessed January 20, 2025.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.9-6 Hazards and Hazardous Materials

OPERATIONS
Substantial risks associated with hazardous materials are not typically associated with hotel/retail and restaurant uses. Minor cleaning products along with the occasional use of pesticides and herbicides for landscape maintenance of the project site are generally the extent of hazardous materials that would be routinely utilized on-site. Thus, as the presence and on-site storage of these materials are common for commercial uses and would not be stored in substantial quantities (quantities required to be reported to a regulatory agency), impacts in this regard are less than significant.

c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school?

No Impact. The project site is not located within 0.25 mile of an existing school. The nearest school, Las Palmas Elementary School, is located approximately 0.50-mile to the southeast of the project site at 1101 Calle Puente, in the City of San Clemente. As such, no impacts would occur in this regard.

d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?

No Impact. As discussed in Response 3.9.2(b), the project site is not listed pursuant to Government Code Section 65962.5 (also known as the “Cortese Listing”). No impacts would result in this regard.

e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?

No Impact. The closest airport to the project site is the John Wayne Airport, approximately 20 miles northwest of the project site. There are no public or public use airports in, or in the general vicinity of project site. As such, the project would not result in a safety hazard or excessive noise for people residing or working in the project area, and no impacts would occur.

f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?

Less than Significant Impact. The proposed project could temporarily affect nearby roadways (e.g., North El Camino Real, East Avenida Pico, etc.) during the construction phase of the project as a result of partial lane closures. This could affect emergency response times or evacuation routes.

Additionally, the proposed project would increase the number of people who may need to evacuate the project area in the event of an emergency. All off-site improvements proposed by the project would be constructed based on industry and City design standards, rules, and regulations pertaining to maintaining adequate emergency access for any partial lane closures. Such uniform standards would ensure emergency access on North El Camino Real and East Avenida Pico during any partial lane closures, if any. Such activities would not impair implementation of, or physically interfere with an

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.9-7 Hazards and Hazardous Materials
adopted emergency response plan or emergency evacuation plan. The project would also be required to comply with OCFA requirements pertaining to emergency access on-site as well. Overall, project impacts related to emergency response would be less than significant. g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?
No Impact. According to the General Plan EIR Figure 5.7-1, Wildfire Hazard Zones, and the current CAL FIRE Map, the project is not located within a Very High Fire Severity Zone (VHFHSZ).19 As such, no impacts would occur in this regard.
19 CAL FIRE, Fire Hazard Severity Zones, https://experience.arcgis.com/experience/ 5065c998b4b0462f9ec3c6c226c610a9, accessed January 29, 2026.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.9-8 Hazards and Hazardous Materials
This page intentionally left blank.

March 2026 3.10-1 Hydrology and Water Quality

3.10 HYDROLOGY AND WATER QUALITY

3.10.1 General Plan EIR Summary
Less Than Significant Impact.

CONSTRUCTION-RELATED IMPACTS
The General Plan EIR established that, as required by the General Construction Permit (GCP) and associated local National Pollutant Discharge Elimination System (NPDES) program regulations, project applicants for future development pursuant to the proposed General Plan would be required to submit the following Permit Registration Documents (PRDs) to the State Water Resources Control Board (SWRCB): Notice of Intent (NOI), Risk Assessment (Standard or Site-Specific), Particle Size Analysis (if site-specific risk assessment is performed), site map, Stormwater Pollution Prevention Plan (SWPPP), Active Treatment System (ATS) Design Documentation (if ATS is determined necessary), and annual fee/certification.

As the City resides in a watershed considered to be a high-risk receiving water body (San Clemente HA 901.30), the General Plan EIR anticipated that all construction projects subject to the GCP would be, at minimum, a Risk Level 2 (based on a scale from 1 to 3), with the exception of the southern portion of the Rancho San Clemente Business Park Focus Area. An effective combination of erosion and sediment control best management practices (BMPs) should be selected based on the specific site conditions, in particular during major soil-disturbing activities. Good housekeeping practices, such as waste and materials management, non-stormwater management, and tracking controls would be required at all times. Overall the General Plan EIR determined that with adherence to the GCP and NPDES regulations, construction impacts would be less than significant.

OPERATIONAL IMPACTS
In accordance with the requirements of the City’s Local Implementation Program (LIP) under the Orange County Drainage Area Management Plan (OC DAMP), and per the regulations of the Fourth Term [Municipal Separate Storm Sewer System] MS4 permit, the General Plan EIR requires that new development and significant redevelopment projects incorporate low impact development (LID)/site design and source control BMPs to address post-construction stormwater runoff management. In addition, priority development projects would be required to implement site design/LID and source control BMPs applicable to their specific priority project categories, as well as implement treatment control BMPs where necessary. Selection of LID and additional treatment control BMPs would be based on the pollutants of concern for the specific project site and the BMPs’ ability to effectively treat those pollutants, in consideration of site conditions and constraints. Further, both priority and non-priority projects would be required to develop a project-specific Water Quality Management Plan (WQMP) that describes the BMPs chosen for the project, as well as includes operation and maintenance requirements for all structural and any treatment control BMPs. Overall, the General Plan EIR found that following incorporation of site design, LID features, and BMPs as required under the City LIP and OC DAMP, operational impacts would be less than significant.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.10-2 Hydrology and Water Quality

GROUNDWATER SUPPLIES OR RECHARGE
The City operates two groundwater wells, which provide approximately six percent of the total water supply for the City. The General Plan EIR concluded that groundwater production from these wells would remain stable over a 25-year projection despite buildout of the General Plan, as proposed development would occur primarily within built out areas of the City, resulting in minimal changes in impervious conditions. Impacts would be less than significant.

ALTERING THE EXISTING DRAINAGE PATTERN
During construction, projects would be required to implement site-specific SWPPPs, which would include erosion-control BMPs to reduce drainage impacts to less than significant levels. The General Plan EIR found that, following buildout of the General Plan, runoff rates and imperviousness in the area would essentially remain unchanged from existing conditions due to the built out condition of each Focus Area. Because the sizing of the regional storm drain system was designed to accommodate full buildout potential, including flow based on proposed and future land use changes, no increases in peak flow or volumes were to be expected. Further, under the proposed condition, the existing flooding conditions and extent of the 100-year and 500-year flood plains were expected to remain unchanged, and no housing or structures were proposed within the 100-year flood hazard area.

Nonetheless, project-specific WQMPs would be implemented to ensure the operation and maintenance for all structural BMPs. In addition, for those land use changes occurring in Focus Areas subject to hydromodification requirements, additional runoff controls for peak flow and volume (e.g., flow duration control) would be required to comply with the Hydromodification Plan (HMP).

Implementation of hydromodification controls would act to reduce peak flows and volumes over the long term as individual projects are implemented. Overall, the General Plam EIR found that impacts would be less than significant.

FLOOD HAZARDS/TSUNAMI/SEICHE ZONES
The City of San Clemente is not within the inundation area of any major dam or levee. The General Plan EIR determined that all elevations of approximately 9.5 feet or less above mean sea level along the coastline within the City would be subject to inundation based on sea level rise estimates. As a majority of development and infrastructure is planned above this elevation, impacts were determined to be less than significant in this regard. Similarly, the projected tsunami inundation area and inundation line are well below the majority of the developable land use areas and primarily affect open space land uses and existing beachfront properties or trailer parks. As a result, tsunami impacts are considered less than significant. Further, the existing storm drain system includes upstream debris basins to control debris and sediment from storm events, and the built-out conditions of the City also reduce the chance and likelihood of major mudflow conditions. Therefore, impacts from seiches and mudflows are considered less than significant

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.10-3 Hydrology and Water Quality

CONFLICT WITH WATER QUALITY PLAN OR SUSTAINABLE GROUNDWATER

MANAGEMENT PLAN
The City is within the San Juan Valley Groundwater Basin, which is managed by the San Juan Basin Authority (SJBA), Municipal Water District of Orange County (MWDOC), California RWQCB and the SWRCB. SJBA developed a joint groundwater monitoring program with Santa Margarita Water District (SMWD) and South Coast Water District (SCWD). This program is designed to satisfy mitigation recommendations and release an annual report based on the collection of surface water, groundwater, biotic and climate data gathered in the field; which is also supplemented with previously existing data from reliable sources.20,21 The San Juan Basin Groundwater Management and Facilities Plan (Basin Plan) was updated in 2013 by the SJBA. As discussed in Section 3.19, the General Plan EIR stated that SCWD available imported supply is greater than shown, and SCWD is capable of providing its customers all their demands with significant reserves in multiple dry years from 2015 through 2035.

Water demands due to General Plan implementation would not deplete groundwater supplies in the San Juan Groundwater Basin because: 1), such water demands within SCWD’s service area would account for only 0.3 percent of total forecast 2035 SCWD water demands; 2) SCWD expects to have imported water supplies adequate for its total water demands through the 2015-2035 period; and 3) SCWD would need approval from the San Juan Basin Authority and the SWRCB before carrying out its planned expansion of groundwater production from the San Juan Basin.

3.10.2 Project-Specific Impacts
Would the project:

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.10-4 Hydrology and Water Quality
Would the project:

Less than Significant Impact With General Plan EIR Mitigation and/or COAs.

CONSTRUCTION IMPACTS
Clearing, grading, excavation, and construction activities associated with buildout of the proposed project may impact water quality due to sheet erosion of exposed soils and subsequent deposition of particulates in local drainages. Grading activities lead to exposed areas of loose soil and sediment stockpiles that are susceptible to uncontrolled sheet flow. Although erosion occurs naturally in the environment, primarily from weathering by water and wind action, improperly managed construction activities can lead to substantially accelerated rates of erosion that are considered detrimental to the environment.

Both State and local regulations would effectively reduce construction stormwater runoff impacts from project development. The project Applicant would be required to implement site-specific BMPs including but not limited to erosion controls and sediments controls pursuant to Municipal Code

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.10-5 Hydrology and Water Quality
Article XII, Erosion Control. Additionally, as discussed in the Geotechnical Investigation prepared for the project (refer to Appendix E), dewatering of subsurface soils during construction would be necessary as the lower level floors for the proposed parking structure are anticipated to be below the existing water table. As such, the project would adhere any BMPs or minimization measures imposed by the San Diego Regional Water Quality Control Board (RWQCB) pursuant to a Waste Discharge Requirement (WDR) permit to discharge to the City’s storm drain system (MS4) (COAs 3.14 and

3.19). Implementation of such BMPs would ensure that the proposed project does not violate any water quality standards or waste discharge requirements during construction activities and impacts associated with construction activities would be less than significant.

OPERATION IMPACTS
Pursuant to the City’s LIP and Fourth Term MS4 permit, and consistent with General Plan Policies PSFU-5.11, PSFU-7.04, and PSFU-7.06 (and enforced through Municipal Code Article XII, Erosion Control), the project Applicant has prepared a site-specific WQMP; refer to Appendix F. The WQMP specifies the site drainage system is designed to treat and partially retain stormwater runoff through the use of a Modular Wetlands System (MWS) Linear bio-filtration unit, ensuring treatment prior to discharge. This design approach would ensure runoff is filtered prior to direct runoff into the City’s storm drain system and ultimately into the Pacific Ocean. The proposed drainage system incorporates a combination of surface drain inlets, channel drains, and an underground piping network strategically located throughout the hardscape, landscape, and basement slab areas. This layout is intended to efficiently capture excess runoff, reduce surface water accumulation, and minimize the potential for standing water or localized ponding. Captured runoff would be conveyed toward the rear yard, where flows would enter the MWS bio-filtration units for treatment. After treatment, flows would be directed to a sump pump system and subsequently discharged to North El Camino Real via energy dissipation structures and curb outlets, in accordance with City standards (Municipal Code Article XII, Erosion Control), as well as federal, State, and local laws and regulations (COAs 3.14 and 3.19).

Where feasible, runoff from paved areas would be directed away from building foundations and allowed to flow into adjacent landscaped areas prior to being collected by the area drain system. This approach promotes incidental surface infiltration and reduces the volume of runoff requiring treatment. The MWS bio-filtration unit is specifically designed to remove sediment, hydrocarbons, nutrients, and other urban pollutants from stormwater prior to off-site discharge. To manage runoff along the easterly side of the lot, the drainage strategy includes impervious surface dispersion, allowing runoff to flow into adjacent landscaped planters. Runoff from the lower portion of the driveway, the trash vehicle loading zone and two-level subterranean garage would be captured by inlets, channel drains and pipe system and conveyed to a sump pump located on the lower level of the subterranean parking garage. From there, it would be pumped to the MWS unit for treatment prior to discharge.

The WQMP details additional site design, non-structural source control, and structural BMPs, as well as LID BMPs that the project would incorporate. The project is exempt from hydromodification.

Long-term maintenance of BMPs would ensure that water quality and waste discharge requirements are not violated. Therefore, long-term operation of the project would not result in substantial impacts to water quality, water quality standards, or waste discharge requirements associated with long-term operational activities, and impacts would be less than significant.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.10-6 Hydrology and Water Quality
Applicable Conditions of Approval (COAs):

Less than Significant Impact. According to the Geotechnical Investigation, site ground waters are considered brackish and not fit for human consumption. As such, groundwater underlying the project site is not used for groundwater supply purposes. Nonetheless, as discussed above, dewatering activities would be required to comply with any BMPs or minimization measures imposed by the San Diego RWQCB pursuant to a WDR permit. During operation, the project does not propose groundwater extraction activities on-site. As discussed in Section 3.19, Utilities and Service Systems, water supplied by San Clemente Water District (City Water District), Santa Margarita Water District (SMWD), and South Coast Water District (SCWD), including groundwater supply, was projected to exceed the City’s demands and would be sufficient to accommodate the demands of forecasted population increase under the General Plan, including buildout of the project site. As such, project impacts pertaining to water demand would be less than significant and indirect impacts to groundwater supplies would also be less than significant.
c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of stream or river or through the addition of impervious surfaces, in a manner which would:

1) Result in substantial erosion or siltation on- or off-site? Less than Significant Impact With General Plan EIR Mitigation and/or COAs. Under existing conditions, the project site is a vacant, disturbed site. The existing terrain of the project site slopes northward toward the Segunda Deshecha Cañada Channel, a regional drainage facility located along the northern boundary of the site. Additional slope patterns direct flow westward from the eastern edge near Avenida Pico, southward toward North El Camino Real, and eastward from the adjacent

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.10-7 Hydrology and Water Quality
property on the west, which contributes off-site run-on to the project area. Overall, the topography facilitates overland sheet flow in the absence of existing grading or formal drainage improvements.

Minor signs of natural erosion are present.

During construction, proposed grading activities associated with the project would temporarily expose soils to water and air, which would increase erosion susceptibility while the soils are exposed. Under post-development conditions, the impervious surface area would increase and, as a result, the amount of exposed soils on the project site would decrease. As discussed in Response 3.10(a), the project Applicant would be required to comply with BMPs for construction activities and operations (Municipal Code Article XII, Erosion Control) (COAs 3.14 and 3.19). Therefore, storm water runoff flows leaving the project site would not carry substantial amounts of sediment. Following construction, wind and water erosion on the project site would be minimized, as the areas disturbed during construction would be landscaped or covered with impervious surfaces. Compliance with the City’s Municipal Code Article XII, Erosion Control, requirements would ensure that water and wind erosion impacts would be less than significant.

Applicable Conditions of Approval (COAs): Refer to COAs 3.14 and 3.19. 2) Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site?
Less than Significant Impact With General Plan EIR Mitigation and/or COAs. According to the WQMP, project implementation would increase imperviousness on-site by 92 percent, which would increase the rate of runoff and potentially result in flooding conditions. As described in Response 3.10(a), the WQMP prepared for the project specifies a site drainage system within the developed portion of the site, which is designed to treat and partially retain stormwater runoff through the use of a MWS Linear bio-filtration unit. Captured runoff would be conveyed toward the rear yard, where it would enter the MWS bio-filtration units for treatment. After treatment, flows will be directed to a sump pump system and subsequently discharged to North El Camino Real via energy dissipation structures and curb outlets, in accordance with City standards. The project is exempt from hydromodification. Additionally, the proposed project would be consistent with General Plan Policies S-2.02, S-2.03, and S-2.04 of the Safety Element regarding drainage and flood control (COA 3.22).

Overall, based on the WQMP prepared for the project, the proposed project would not increase the rate or amount of surface runoff in a manner that would result in flooding on- or off-site and would not contribute runoff water that would exceed the capacity of the existing storm drain system. With adherence to existing water quality regulations, including implementation of required BMPs, the proposed project would not provide substantial additional sources of polluted runoff. Project specific impacts related to increased flooding would be less than significant.

Applicable Conditions of Approval (COAs):

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.10-8 Hydrology and Water Quality
3) Create or contribute runoff water which would exceed the capacity of existing or planned storm water drainage systems or provide substantial additional sources of polluted runoff?
Less than Significant Impact With General Plan EIR Mitigation and/or COAs. Refer to Response 3.10.2(b), 3.10.2(c)(1), and 3.10.2(c)(2). According to the WQMP, project implementation would increase imperviousness on-site by 92 percent. As described in Response 3.10(a), the WQMP prepared for the project specifies a site drainage system within the developed portion of the site, which is designed to treat and partially retain stormwater runoff through the use of a MWS bio-filtration units. Captured runoff will be conveyed to the MWS bio-filtration units for treatment prior to discharge. After treatment, flows will be directed to a sump pump system and subsequently discharged to North El Camino Real via energy dissipation structures and curb outlets, in accordance with City standards. Overall, the proposed project would not increase the rate or amount of surface runoff in a manner that would not contribute runoff water that would exceed the capacity of the existing storm drain system. With adherence to existing water quality regulations, including implementation of required BMPs, the proposed project would not provide substantial additional sources of polluted runoff. Impacts in this regard would be less than significant.

Applicable Conditions of Approval (COAs): Refer to COAs 3.14 and 3.19.

4) Impede or redirect flood flows?
Less than Significant Impact With General Plan EIR Mitigation and/or COAs. Refer to Response 3.10.2(c)(2). According to the WQMP, project implementation would increase imperviousness on-site by 92 percent. As described in Response 3.10(a), the WQMP prepared for the project specifies a site drainage system within the developed portion of the site, which is designed to treat and partially retain stormwater runoff through the use of a MWS Linear bio-filtration unit.

Captured runoff will be conveyed toward the rear yard, where it will enter the MWS bio-filtration units for treatment. After treatment, flows will be directed to a sump pump system and subsequently discharged to North El Camino Real via energy dissipation structures and curb outlets, in accordance with City standards. The project is exempt from hydromodification. Additionally, the proposed project would be consistent with General Plan Policies S-2.02, S-2.03, and S-2.04 of the Safety Element regarding drainage and flood control. Overall, the proposed project would not increase the rate or amount of surface runoff in a manner that would result in flooding on- or off-site. Impacts related to flood flows would be less than significant.

Applicable Conditions of Approval (COAs): Refer to COA 3.22.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.10-9 Hydrology and Water Quality

d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
Less than Significant Impact.

FLOOD HAZARD
According to Figure 5.8-4, San Clemente Flood Zone Map, of the General Plan EIR, as well as Federal Emergency Management Agency’s (FEMA) Flood Map Service Center, the site is located within a 500 Year Flood Zone, or a 0.2 percent annual chance flood hazard area (Zone X).22 While the project site is located within a 500 Year Flood Zone23, it is not within a 100-year flood zone; development of proposed drainage improvements, implementation of BMPs per the site-specific WQMP, and adherence to applicable General Plan Safet Element Policies and Municipal Code regulations would be required. As the project site is not situated within a 100-year flood hazard zone, impacts in this regard are less than significant.

TSUNAMI
As depicted in General Plan EIR Figure 5.8-5, Projected Sea Level Rise, and Figure 5.8-6, Tsunami Emergency Response Planning Zone, the project site is not within an area at risk of seas level rise or tsunamis where inundation would occur. Impacts would be less than significant in this regard.

SEICHE
A seiche is an oscillation of a body of water in an enclosed or semi-enclosed basin, such as a reservoir, harbor, lake, or storage tank. No water body is located on-site. Although the Segunda Deshecha Cañada Channel adjoins the project site, it is not anticipated to have the capacity to result in seiche impacts. As such, no impacts would occur in this regard.

e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
Less than Significant Impact. Geotechnical investigations conducted in preparation for the WQMP determined that, due to the proposed underground parking structure, infiltration would not be a proposed method of water quality management. The project site is exempt from hydromodification.

Additionally, post-project conditions would increase imperviousness on-site by 92 percent, and groundwater extraction activities are not proposed; however, it is acknowledged that the groundwater underlying the project site is brackish and not suitable for drinking water purposes.

As detailed in Response 3.10(a), both construction and operation of the project would adhere to State, regional, and local regulations around water quality standards. The project Applicant would be 22 Federal Emergency Management Agency, Flood Insurance Rate Map #06059C0517K, March 21, 2019. 23 Federal Emergency Management Agency, Flood Insurance Rate Map #06059C0517K, March 21, 2019.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.10-10 Hydrology and Water Quality
required to comply with BMPs for construction activities and operations pertaining to water quality in order to meet the San Diego RWQCB’s water quality standards for the basin (Municipal Code Article XII, Erosion Control). No other sustainable groundwater management plans apply to the project site. As such, impacts would be less than significant.

March 2026 3.11-1 Land Use and Planning

3.11 LAND USE AND PLANNING

3.11.1 General Plan EIR Summary
Less Than Significant Impact. The General Plan EIR concluded that buildout of the General Plan would involve development of vacant land, intensification of existing land uses, and the introduction of new land uses on parcels throughout the City. Land use changes proposed within the Focus Areas are intended to tie into the existing uses and surrounding neighborhoods and development would occur within existing urban areas and infill sites, which is not expected to divide an established community. As such, the General Plan EIR concluded that impacts would be less than significant.

The General Plan EIR determined that the General Plan, last updated in 1993, would be consistent with State Planning Law and California Complete Streets Act (Assembly Bill 1358). Additional General Plan consistency analysis related to applicable goals and principles from the SCAG 2012-2035 Regional Transportation Plan/Sustainable Communities Strategy and SCAG Compass Blueprint were included in the General Plan EIR, which concluded that buildout of the General Plan would not conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. Thus, impacts were determined to be less than significant.

3.11.2 Project-Specific Impacts
Would the project:

The key factor with respect to this threshold is the potential to create physical barriers that change the connectivity between areas of a community to the extent that persons are separated from other areas

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.11-2 Land Use and Planning
of the community. The project does not propose to construct any major highways or roadways, storm channels, bridges or roadways, or utility transmission lines that would physically divide a community.

The project site is currently vacant, disturbed land surrounded by urban development. The project site is located in the northwestern corner of the El Camino Real and Avenida Pico intersection within the North Beach/North El Camino Real Focus Area. The Focus Area is a unique community and coastal visitor-oriented entertainment hub and recreation area with ongoing revitalization efforts that focus on its major assets, including views of the ocean, convenient beach access, a rich inventory of historic buildings, access to passive and active recreational amenities, and numerous visitor-serving shops and services. The nearby Metrolink rail station, Beach Trail, numerous bikeways and pedestrian paths, and the historic El Camino Real corridor establish the Focus Area as a key multimodal transportation hub.

Surrounding land uses adjacent to the site include open space/recreational, commercial/retail, and transportation uses. Given the urban environment and existing physical improvements surrounding the site, the proposed mixed-use hotel development would not physically divide an established communities in the project area. Rather, the project would develop a vacant, infill site within the North Beach/North El Camino Real Focus Area in a manner that would contribute towards revitalizing the Focus Area with a coastal visitor-oriented use that provides and enhances existing ocean views, beach access, and recreational amenities. Therefore, no impacts would result in this regard.

b) Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
Less than Significant Impact. The following discussion analyzes the project’s consistency with applicable land use plans, policies, and regulations, including the General Plan, Municipal Code, and Coastal LUP.

GENERAL PLAN CONSISTENCY
According to the General Plan, the site’s MU1 land use designation is intended to create a vertical or horizontal mix of Neighborhood Serving Commercial and Community Serving Commercial uses, with multi-family housing on the second floor or higher. The MU1 designation allows for a maximum of

24.0 units per gross acre or 36.0 units per net acre for residential development, a maximum 1.00 FAR for commercial development, and a maximum 2.00 FAR for mixed-use projects. The proposed hotel building area (hotel and restaurant building area) is approximately 30,034 square feet and would be constructed on an approximately 32,030-square foot site. Thus, the project would have a 0.94 FAR and meet the FAR requirement for commercial development under the MU1 designation.

The General Plan also identifies the site within one of eight Focus Areas considered to have the most potential for change, the North Beach/North El Camino Real Focus Area. This Focus Area is a unique, community- and coastal visitor-oriented entertainment hub and recreation area. It is an important City gateway along the historic El Camino Real/Pacific Coast Highway from beach cities to the north. The North Beach/North El Camino Real Focus Area’s on-going revitalization is based on the community’s desire to preserve and enhance its key assets. The Focus Area’s assets include

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.11-3 Land Use and Planning
views of the ocean, convenient beach access, a rich inventory of historic buildings, access to passive and active recreational amenities, and numerous visitor-serving shops and services. With access to the Metrolink rail station, the Beach Trail, numerous bikeways and pedestrian paths, and the historic El Camino Real corridor that connects many of the City’s activity areas, the North Beach/North El Camino Real Focus Area is a key multimodal transportation hub.

Table 3.11-1, General Plan Land Use Element Project Consistency Analysis, analyzes the project’s consistency with applicable Land Use Element policies. As analyzed, the project would be consistent with the General Plan Land Use Element.

Table 3.11-1
General Plan Land Use Element Project Consistency Analysis Relevant General Plan Policies Project Consistency Analysis Mixed-Use Land Use Policies
LU-3.03. Ground Floor Retail. In pedestrian-oriented
environments, we require retail uses to be located on the ground floor to provide convenience and good visibility for shoppers. Whenever possible, we require off-street parking to be screened and located on the side or at the rear of buildings.

Consistent. The proposed hotel development includes a
ground floor walk-up public café fronting North El Camino Real that would be fully accessible to pedestrians, as well as a ground floor indoor café for hotel guests. Additionally, offstreet parking would be provided in a subterranean parking garage that is screened from public views.

LU-3.04. Upper Floors. Where buildings over two stories are allowed, we require building facades above the second floor to be set back from lower, street-facing facades to minimize building height and bulk, pursuant to the Design Guidelines and applicable Specific Plans.

North Beach/North El Camino Real Focus Area Policies
LU-10.01. Historic Preservation. We preserve North Beach historic resources, through measures such as considering the establishment of a historic district, ensuring new
development is consistent with the Historic Preservation and Urban Design Elements, providing historic preservation incentives and enforcing the protective measures of the Zoning Ordinance.

Consistent. The project acknowledges the North Beach
Historic District’s character and is designed to be visually compatible with the district and adjacent historic resources.

The Hanson Hotel is designed with Spanish Colonial Revival architecture specific to the Ole Hanson era, consistent with the historic character of the North Beach Historic District.

LU-10.03. Gateways. We enhance and maintain attractive
gateways and informational signage signifying arrival to the North Beach/North El Camino Real area at the following
locations along North El Camino Real: 1) the northern
entrance to North Beach, 2) the historic entryways to Max Berg Plaza Park at El Portal, and 3) the southern entryway to the area at Avenida Palizada.

Consistent. The project is located at one of the gateways to the North Beach/North El Camino Real Focus Area. The
project proposes a prominent turret element at the corner of North El Camino Real and East Avenida Pico to anchor the site, creating a distinctive visual gateway element into the North Beach area and pays tribute to a similar feature at the Ole Hanson Beach Club.

LU-10.05. Ocean Views. We preserve the General Plandesignated public view corridor from Avenida Pico through Consistent. The proposed project takes advantage of ocean views in the project area by incorporated a stepped-back

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.11-4 Land Use and Planning
Relevant General Plan Policies Project Consistency Analysis North Beach and encourage new development along El
Camino Real to take advantage of ocean vistas.
design for the hotel building in a way that minimizes view encroachment for the scenic ocean views, and incorporates a rooftop restaurant and terrace (pool deck level) that provides public access to sunset/ocean views. Ocean-view terraces, including a grand stairway leading to a public podium terrace with ocean views, are also proposed throughout the hotel’s outdoor spaces.

LU-10.06. Quality Development. We require that site,
building and landscape development be of high quality
design and materials and that promote pedestrian activity, in accordance with the Urban Design Element, North Beach Specific Plan and Zoning Ordinance.

Consistent. Refer to response to LU-3.03. Additionally, the project would comply with all applicable MU1 zoning district development standards and Central Business (CB),
Architectural Overlay (A), and Coastal Zone (CZ) overlay requirements. The project requires a Design Review and
Development Permit, among other discretionary approvals, that would entail City review and approval of all proposed site, building, and landscape plans.

LU-10.09. Bike and Pedestrian Environment. We provide a high quality bicycle and pedestrian environment with “living street” designs, consistent landscaping, lighting, sidewalks, traffic calming measures, bikeways and trails, consistent with the Bicycle and Pedestrian Master Plan, Tree
Ordinance and Design Guidelines.

Consistent. The project contributes towards creating a
pedestrian oriented environment in the North Beach area.

Specifically, sidewalks along southbound East Avenida Pico and eastbound North El Camino Real would be constructed along the eastern and southern project frontages,
respectively. Pedestrian access to the hotel is proposed in the southeastern and southwestern portions of the site along East Avenida Pico and North El Camino Real, respectively.

Additionally, pedestrian pathways are proposed throughout the site to provide connectivity between hotel buildings and amenities, as well as provide connectivity to existing
surrounding pedestrian facilities. The proposed walk-up public café would front North El Camino Real and be fully accessible to pedestrians along the adjacent sidewalks.

North Beach/North El Camino Real Focus Area Policies
LU-10.17. Art in Public and Private Places. We encourage the incorporation of art in public and private spaces that reflects the area’s historic and small town beach character.

Consistent. The project integrates an Ole Hanson-inspired public art and sculpture garden with a series of vine-covered trellises, fountains, and decorative benches in the Spanish Colonial Revival architecture style to complement the North Beach Historic District.

LU-10.18. Partnerships. We create public-private business partnerships to develop City owned property and
encourage the development of privately-owned land and to help transform the district into an active, mixed-use,
recreation and entertainment hub.

Consistent. The project site is privately-owned and the proposed infill commercial development would help revitalize the North Beach/North El Camino Real Focus Area and
contribute to its historic character.

Source: City of San Clemente, Centennial General Plan Land Use Element, adopted February 2014, amended December 2016.

ZONING CODE CONSISTENCY
The project site lies within the Mixed-Use 1 zoning district and is subject to the Central Business (CB), Architectural Overlay (A), and Coastal Zone (CZ) overlays (MU1-CB-A-CZ).

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.11-5 Land Use and Planning
Mixed-Use 1 Zoning District
The proposed hotel use is a conditionally permitted use in the MU1 zone as shown in Municipal Code Table 17.40.030, Mixed-Use Zone Uses. As described in Section 2.5, Permits and Approvals, the project proposes a Conditional Use Permit for the proposed hotel use. Additionally, Table 3.11-2, Zoning Code Project Consistency Analysis, analyzes the project’s consistency with applicable MU1 development standards. As analyzed, the project would be consistent with applicable MU1 development standards.

Table 3.11-2
Zoning Code Project Consistency Analysis
Development Standard Requirement Proposed Project Compliance? Lot Area 6,000 square feet minimum 32,030 square feet Yes Lot Width 60 feet minimum 201.5 feet along El Camino
Real
Yes
Front Setback 0 feet (Urban Main Street) Approximately 5 feet Yes Interior/Street Side Setback 0 feet Approximately 3 feet Yes Rear Setback 0 feet Approximately 3 feet Yes
Building Height 45 feet maximum;
37 feet plate line (PL) height
45 feet maximum height and
37 feet PL height
Yes
Stories 3 stories 3 stories Yes
Hotel Density 1 guest room per 500 square
foot lot area (64 rooms)
61 rooms Yes
Parking 96 stalls required 104 stalls provided Yes
Lot Coverage/
Urban Open Area
20 percent minimum;
100 percent maximum

22.89 percent
(7,291 square feet)
Yes
Floor Area Ratio (FAR) 1.0 FAR 0.94 FAR Yes
Source: City of San Clemente, San Clemente Municipal Code, updated November 17, 2025.

Central Business Overlay District
The CB Overlay District is also known as Pedestrian (P) Overlay in the General Plan and as the Visitor Serving Commercial District [VSCD] Overlay in the Coastal LUP. The purpose of the CB Overlay District is to signify core commercial and mixed-use districts in which the City requires pedestrian uses to be located in pedestrian spaces (on the street level of the project along the sidewalk/street), thereby facilitating visitor-serving uses and pedestrian activity along sidewalks and throughout the area.

The proposed project is located at the intersection of North El Camino Real and East Avenida Pico, a main pedestrian intersection and thoroughfare. The hotel use is a visitor-serving use and the project proposes pedestrian access improvements to contribute towards the pedestrian space and intent of the CB Overlay District. Specifically, sidewalks along southbound East Avenida Pico and eastbound North El Camino Real would be constructed along the eastern and southern project frontages, respectively. Pedestrian access to the hotel is proposed in the southeastern and southwestern portions of the site along East Avenida Pico and North El Camino Real, respectively. Additionally, pedestrian pathways are proposed throughout the site to provide connectivity between hotel buildings and

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.11-6 Land Use and Planning
amenities, as well as provide connectivity to existing surrounding pedestrian facilities. The proposed public café would front North El Camino Real and be fully accessible to pedestrians along the adjacent sidewalks. Thus, the proposed development would be a pedestrian-oriented use with commercial and pedestrian-oriented spaces fronting adjacent sidewalks and roadways. Overall, the proposed use sufficiently generates pedestrian activity to be appropriate in a pedestrian-oriented space and meets the intent and purpose of the CB Overlay District.

Architectural Overlay District
The purpose and intent of the A Overlay District is to signify a visually distinct district in San Clemente, containing structures characterized by two significant design orientations: 1) the City's traditional architectural style, Spanish Colonial Revival, and 2) a pedestrian orientation. The project requires a Development Permit to ensure compliance with the architectural review criteria detailed in Municipal Code Section 17.56.020(E), Architectural Review Criteria. Specifically, the project is required to be designed with Spanish Colonial Revival architecture of the Ole Hanson-era or other Spanish architectural styles (e.g., Monterey, Mediterranean, Mission, etc.). All new structures are also required to reflect a pedestrian orientation.

The proposed project’s design reflects traditional Spanish Colonial Revival architecture and integrates publicly accessible features such as native landscaped gardens, pedestrian areas, and ocean-view terraces. Drawing inspiration from Ole Hanson’s vision for North Beach as a hub of recreation and entertainment, the project is designed to be visually compatible with the North Beach Historic District and adjacent historic resources. Specifically, the architecture incorporates tiered massing, with oneand two-story elements stepping down toward East Avenida Pico and recessed upper levels along North El Camino Real. A prominent turret element at the corner of North El Camino Real and East Avenida Pico anchors the site to create a distinctive visual gateway element into the North Beach area and pays tribute to a similar feature at the Ole Hanson Beach Club. The project's layout incorporates courtyards, shaded patios, arcades, and outdoor gathering spaces, reinforcing the indoor-outdoor theme in traditional Spanish Colonial Revival architecture. Prominent features include a grand stairway leading to a public podium terrace with ocean views, an Ole Hanson-inspired public art and sculpture area, and a series of vine-covered trellises, fountains, and decorative benches create a transition from public to semi-private spaces. An overall natural color palette of terra cotta, olive green, red, and white, signature of Spanish Colonial Revival architecture, is also proposed. As such, the project would comply with the A Overlay District standards.

Coastal Zone Overlay District
The CZ Overlay District provide standards which preserve and protect the coastal resources within San Clemente and implement the coastal policies in the General Plan Coastal Element, Coastal LUP, and the California Coastal Act. The CZ Overlay District is applicable to all development within the Coastal Zone, including the project site. Specifically, Municipal Code Section 17.56.050, Coastal Zone (-CZ) Overlay District, focuses on development standards along coastal bluffs, coastal canyons, and coastal beaches. The project site is not located adjacent to any coastal bluffs, canyons, or beaches.

Nevertheless, a consistency analysis of the project with applicable Coastal LUP policies is provided in

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.11-7 Land Use and Planning
the table below. As analyzed, the project would be consistent with the Coastal LUP and thus, also compliant with the CZ overlay district standards.

COASTAL LAND USE PLAN
The site is located within the Coastal Zone. While the City does not have a certified Local Coastal Program, the City does have a certified Coastal LUP, dated March 2018. Table 3.11-3, Coastal Land Use Plan Project Consistency Analysis, analyzes the project’s consistency with applicable Coastal LUP policies. As analyzed, the project would be consistent with the City’s Coastal LUP.

Table 3.11-3
Coastal Land Use Plan Project Consistency Analysis
Relevant Coastal Land Use Plan Policies Project Consistency Analysis Commercial Development Policies
LU-16 Development Quality. Require that new development protect community character by providing architecture,
landscaping and urban design in keeping with the character of the surrounding development, and by respecting the
architectural character and scale of adjacent buildings. Infill development and redevelopment shall be reviewed for
compatibility with the character of the surrounding
neighborhood as part of the coastal development permit
application review process.

Consistent. The project site is located within the North Beach Historic District and the Architectural (A) Overlay District. As stated above, the proposed project’s design reflects traditional Spanish Colonial Revival architecture and integrates publicly accessible features such as native landscaped gardens,
pedestrian areas, and ocean-view terraces. Drawing
inspiration from Ole Hanson’s vision for North Beach as a hub of recreation and entertainment, the project is designed to be visually compatible with the North Beach Historic District and adjacent historic resources. Specifically, the architecture incorporates tiered massing, with one- and two-story elements stepping down toward East Avenida Pico and recessed upper levels along North El Camino Real. A prominent turret element at the corner of North El Camino Real and East Avenida Pico anchors the site to create a distinctive visual gateway element into the North Beach area and pays tribute to a similar feature at the Ole Hanson Beach Club. The project's layout
incorporates courtyards, shaded patios, arcades, and outdoor gathering spaces, reinforcing the indoor-outdoor theme in traditional Spanish Colonial Revival architecture. Prominent features include a grand stairway leading to a public podium terrace with ocean views, an Ole Hanson-inspired public art and sculpture area, and a series of vine-covered trellises, fountains, and decorative benches create a transition from public to semi-private spaces. An overall natural color palette of terra cotta, olive green, red, and white, signature of Spanish Colonial Revival architecture, is also proposed. Therefore, the project would contribute towards the existing community’s historic character. The project requires a Development Permit and Design Review, among other discretionary approvals, which would ensure the project’s compatibility with the character of the surrounding neighborhood.

LU-17 Identification of Commercial Areas. Require distinctive entry and informational signage, street trees, street furniture, pedestrian-scaled lighting, and other improvements to
Consistent. The project is located at one of the gateways to the North Beach/North El Camino Real Focus Area. The
project proposes a prominent turret element at the corner of

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.11-8 Land Use and Planning
Relevant Coastal Land Use Plan Policies Project Consistency Analysis uniquely identify individual commercial districts, including: the Downtown Core, North Beach, South El Camino Real, Pico
Plaza, Los Molinos, Camino de los Mares, Avenida Pico,
Marblehead Coastal, and Shorecliffs.

North El Camino Real and East Avenida Pico to anchor the site, creating a distinctive visual gateway element into the North Beach area and pays tribute to a similar feature at the Ole Hanson Beach Club.

LU-19 Environmental Compatibility and Quality. Require
commercial districts and uses to be compatible with their environmental setting, promote City environmental goals and be designed and operated to avoid or mitigate environmental impacts.

Consistent. As analyzed throughout this Compliance
Memorandum, the project would minimize environmental
impacts through implementation of existing regulations and/or adopted mitigation measures from the General Plan EIR.

LU-20 Visitor-Serving Commercial Uses in the Visitor Serving Commercial District (VSCD) Overlay. Protect existing and encourage new visitor-serving commercial uses over other types of new commercial development in VSCD Overlay
designated commercial and mixed-used lots. Development
designed to enhance public opportunities for coastal
recreation shall have priority over general commercial
development on private lands suitable for visitor-serving commercial recreational facilities. These uses enhance public opportunities for coastal recreation and shall have priority over general commercial development in the VSCD Overlay. The Overlay protects the visitor-serving uses and prevents the conversion of existing visitor-serving development to other uses.

Consistent. The proposed hotel development would convert an existing vacant lot into a visitor-serving commercial use.

Hotel guests and visitors would have the opportunity to access the nearby beach for coastal recreation activities. Thus, the project would help revitalize and contribute towards creating more visitor-serving commercial uses in the North Beach area.

Visitor-Serving Land Use and Development Policies
LU-40 Priority Use. Prioritize visitor-serving commercial and/or recreation uses over private residential or general commercial development in the VSCD Overlay. The Overlay protects
existing visitor-serving uses and prevents the conversion of existing visitor-serving development to other uses.

Consistent. Refer to response to LU-20.

LU-41 Protection of Overnight Accommodations Stock.

Discourage reduction in total stock of overnight
accommodations in existence as of the effective date of adoption of this Land Use Plan. Based on the City’s 2018 inventory shown in Table 2-2, there are ten hotels/motels in the City’s coastal zone providing 309
rooms and 160 campsites.

Consistent. The site is currently vacant and the project would provide a 61-room boutique hotel. Thus, the project would increase the City’s overall overnight accommodations stock.

LU-42 Overnight Accommodations. Protect, encourage and, where feasible, provide lower cost overnight accommodations in the Coastal Zone, including the possibility of a youth or elder hostel.

Consistent. The project proposes a 61-room boutique hotel in the Coastal Zone. The project also incorporates affordable overnight accommodation. Specifically, the project provides 25 percent (16 rooms) designated as affordable overnight accommodation to enhance low-cost, visitor serving
opportunities, consistent with California Coastal Commission requirements.

LU-43 Lower and Moderate Cost Accommodations. Prohibit
the loss of existing lower cost facilities, including lower cost hotel, motel or inn units, or campsites, unless they are replaced with comparable facilities, mitigation, or in-lieu fees are provided to fund other lower-cost overnight visitor accommodations in the City or the greater Southern California coastal zone area.

Consistent. Refer to responses to LU-41 and LU-42.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.11-9 Land Use and Planning
Relevant Coastal Land Use Plan Policies Project Consistency Analysis LU-46 Range of Pricing. Encourage new overnight visitor accommodation developments to provide a range of rooms
and room prices in order to serve all income ranges.

Consistent with Section 30213 of the Coastal Act, the City shall in no event (1) require that overnight room rental be fixed at an amount certain for any privately owned and operated hotel, motel, or other similar visitor-serving facility located on either public or private land; nor (2) establish or approve any method for the identification of low or moderate income persons for the purpose of determining eligibility for overnight room rentals in any such facilities.

Consistent. Refer to response to LU-42.

LU-50 Pier Bowl and North Beach. Prioritize visitor-serving and recreational uses in areas designated mixed use in the Pier Bowl and North Beach areas.

Consistent. Refer to response to LU-20.

North Beach/North El Camino Real Focus Area
LU-71 Gateways. Enhance and maintain attractive gateways and informational signage signifying arrival to the North Beach/North El Camino Real area at the following locations along North El Camino Real: 1) the northern entrance to North Beach, 2) the historic entryways to Max Berg Plaza Park at El Portal, and 3) the southern entryway to the area at Avenida Palizada.

Consistent. Refer to response to LU-17.

LU-72 Quality Development. Require that site, building and landscape development be of high quality design and
materials and promote pedestrian activity.

Consistent. Refer to response to LU-16.

Additionally, the project contributes towards creating a pedestrian oriented environment in the North Beach area.

LU-75 Partnerships. Create public-private business
partnerships to develop City owned property and encourage the development of privately-owned land to
help transform the district into an active, mixed-use, recreation and entertainment hub.

LU-78 Design Treatment. Require that new buildings and
major building remodels in North Beach and on portions of El Camino Real utilize Spanish Colonial Revival architecture, per the Architectural Overlay District requirements.

Consistent. Refer to response to LU-16.

Visual Resources
VIS-1 Visual Character and Aesthetic Resources
Preservation. New development shall be designed to preserve the visual character and aesthetic resources of the City’s Consistent. As analyzed in Section 3.1, Aesthetics,
implementation of the proposed project on the currently vacant project site would represent a change in the overall

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.11-10 Land Use and Planning
Relevant Coastal Land Use Plan Policies Project Consistency Analysis coastal zone including preservation of the physical features of coastal bluffs and canyons, and where feasible, enhance and restore scenic and visual qualities of the coastal zone, including to and along the ocean and coastal bluffs, visually significant ridgelines, and coastal canyons, open spaces, prominent, mature trees on public lands, and designated significant public
views (as identified on Figure 6-1 Scenic Gateways and
Corridors, Figure 6-2-A Public View Corridors and Figure 6-2- B Public View Corridors). Where protection of visual character and aesthetic resources is not feasible, impacts should be mitigated.
atmosphere and visual relationship between the site and surrounding uses. Despite this change, the project would be compatible with the village-like atmosphere of the area.

Additionally, the proposed hotel use is a conditionally permitted use in the MU1 zone and consistent with applicable MU1 development standards as well as the General Plan’s buildout of the North Beach/North El Camino Real Focus Area.

As demonstrated in the photo simulations of the proposed project in Exhibit 3-1.2a through Exhibit 3.1-2c, the project would result in changes to existing views of the project site from designated visual corridors (North El Camino Real and East Avenida Pico) and would result in changes to existing views of designated visual resources (Pacific Ocean) from public viewpoints. However, these changes would be minor and would not degrade the dominant views along these
corridors or degrade the value of these scenic resources. The project’s maximum building height of 45 feet and maximum PL height of 37 feet would be consistent with the site’s MU1 land use designation, and as such would not obstruct views along visual corridors or views of scenic resources beyond what the General Plan EIR analyzed. Additionally, as a project within the A Overlay District, the proposed hotel would be designed in the Spanish Colonial Revival architectural style, consistent with surrounding structures, to maintain visual continuity within the viewshed. The project Applicant also designed the project to be visually compatible with the North Beach Historic District and adjacent historic resources.

VIS-2 Scenic Corridors and Scenic Roadways. Enhance and protect existing locally designated Scenic Corridors and Scenic Roadways and identify opportunities for the
designation of new Scenic Corridors and Scenic Roadways.

Any roadway designated as a new Scenic Corridor or Scenic Roadway shall: 1) identify scenic roadways, 2) describe significant visual linkages between the resources and
amenities of San Clemente, and 3) establish objective design and landscaping criteria to maintain quality visual experiences along such corridors through appropriate landscaping,
enhancement and protection of public views.

Consistent. Refer to response to VIS-1.

Additionally, the project would be required to comply with Municipal Code Chapter 17.24, the City’s Design Guidelines and the City’s Master Landscape Plan for Scenic Corridors, as well as General Plan Policies, regarding preservation of scenic views.

VIS-3 Major and Minor Scenic Corridors. Require the following roadways be maintained and preserved as major or minor
scenic corridors with key entry points as shown in Figure 6-1 Scenic Gateways and Corridors:
a. Avenida Pico
b. El Camino Real/Pacific Coast Highway
c. Ola Vista
Consistent. Refer to response to VIS-1 and VIS-2.

VIS-4 Signs. Limit the size, height, numbers, and type of signs to limit sign clutter and minimize their impact to Scenic Corridors and community character.

Consistent. The proposed hotel would not include any freestanding signs and thus, would not result in sign clutter that would adversely impact the surrounding community character.

VIS-6 Public View Corridors. New development shall preserve and improve the Public View Corridors, as designated on the Public View Corridors Map (Figure 6-2-A Public View
Consistent. Refer to response to VIS-1 and VIS-2.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.11-11 Land Use and Planning
Relevant Coastal Land Use Plan Policies Project Consistency Analysis Corridors and Figure 6-2-B Public View Corridors). Additional Public View Corridors to and along the shoreline and/or scenic coastal areas may be identified through the regulatory
process. The City shall preserve and improve Public View Corridors on public property, specifically, in its capital improvements programs and discretionary approvals. The City shall also encourage other agency planning efforts to do so to the maximum extent feasible. New development shall
implement the following visual protection measures:
a. New development including buildings and landscaping
shall be sited and designed to avoid or minimize
impacts to public views. Siting and design of buildings and landscape shall avoid impacts on Public View
Corridors to the extent feasible and blend man-made
and man-introduced features with the natural
environment. New development shall require a view
analysis to ensure that the development avoids or
reduces impacts on Public View Corridors.
b. Utilities, traffic signals, and public and private signs and lights shall not adversely impact Public View Corridors, consistent with safety needs.
c. Where important public vistas of distant landscape
features occur along streets, street trees shall be
selected and planted so as to facilitate viewing of the distant features.
d. Street trees planted along designated Public View
Corridors shall have narrow form and open structure to
allow greater visual access. Street trees shall be
carefully placed and/or properly pruned, following best arboricultural practices, to achieve the desired goals
without interruption of significant public views to and along the ocean.

Proposed utility, signage, and lighting improvements would only be provided to serve the proposed development and be consistent with safety needs and Municipal Code standards.

Additionally, the project proposed to plant a total of 19 street trees (including date palms, New Zealand Christmas tree Pohutukawa, and Blood Orange Sanguinello) along North El Camino Real and Avenido Pico within public right-of-way to meet the requirements of General Plan Policy M-1.17
(requiring construction or modification of major roadways to promote the creation and maintenance of “streetscapes” and linear scenic parkways or corridors that promote the City’s visual quality and character).

VIS-9 Underground Utilities. Utilities shall be located underground to avoid the adverse impacts to aesthetic
resources caused by public utilities and unmanned
telecommunications antennas and facilities, where feasible and where costs of such undergrounding does not pose
economic hardship. Where undergrounding is determined by the City to not be physically possible, such features shall be located and designed to reduce their visibility, not adversely impact public view corridors to and along the ocean, and be consistent with prevailing architectural character and scale. In beaches, parks and open spaces areas, such facilities shall be designed and located to blend in with natural colors, textures and landforms.

Consistent. All proposed utility improvements would be
underground and thus, would avoid any adverse aesthetic impacts related to aboveground utility facilities.

VIS-10 Development Review. Review and require changes to development proposals, as needed, to minimize obstructions of designated significant public views and designated Public View Corridors, and to ensure public and private development projects in the Coastal Zone use high-quality materials and are designed to be attractive and aesthetically compatible with Consistent. Refer to response to VIS-1 and VIS-2.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.11-12 Land Use and Planning
Relevant Coastal Land Use Plan Policies Project Consistency Analysis adjacent structures, site improvements, utilities and landscape features.

VIS-11 Building Heights and Setbacks. Review the heights and setbacks of all new and re-developed structures in the Coastal Zone to ensure the preservation of existing public views to and along the ocean, scenic coastal areas, and existing or new Public View Corridors designated on Figure 6- 1 Scenic Gateways and Corridors, Figure 6-2-A Public View Corridors and Figure 6-2-B Public View Corridors. Structures shall not exceed the height limits identified in Chapter 2, Section 2.3 Land Use Designations, Table 2-1. Structures may be required to be lower than the maximum height limit in order to protect, restore and/or enhance public views.

Consistent. Refer to response to VIS-1 and VIS-2.

VIS-12 Public View Analysis. When appropriate, new
development and redevelopment projects which have, or will have, the potential to impact public views to and along the ocean and scenic coastal areas, shall require an analysis of the effect of the proposed project on public views. This analysis shall accurately pictorially, digitally, photographically, or physically, indicate the proposed site in its current state and compare it with an illustration showing the proposed building volume (at the same scale) in its proposed location.

Consistent. Refer to response to VIS-1 and VIS-2.

VIS-18 Compatible Landscaping. Require new development
and re-development to provide landscaping themes that are compatible with and reinforce the visual character of the community.

Consistent. The proposed landscape plan features a diverse palette of California native and drought-tolerant plant species, strategically arranged in a series of terraced gardens along East Avenida Pico and North El Camino Real; refer to Section 15183 Exemption Report, Chapter 2, Project Description, Exhibit 5, Conceptual Landscape Plan. Specific areas of focus include native planting beds at the site’s corner gateway, a cultural sculpture area, and decorative plantings framing the publicly accessible walkways and terraces. Additionally, a total of 19 street trees would be planted along North El Camino Real and Avenido Pico within public right-of-way (off-site) as a part of the project. The proposed landscaping and plant palette would complement the Spanish Colonial Revival architectural style.

VIS-21 Construction Staging Areas. The location of
construction staging areas for new development in or adjacent to the Public View Corridors shall not adversely impact the Public View Corridors, to the maximum extent feasible.

Consistent. All construction staging would occur on-site and would not extend beyond the project boundaries. Short-term aesthetic construction impacts would be minimized to the maximum extent feasible with temporary screening.

Historic & Cultural Resources
CUL-13 New Development. Through the design review
process, encourage that new development and redevelopment is compatible with adjacent existing historic structures in terms of scale, mass, building materials and architectural treatment.

Consistent. The proposed development would be three stories and would include building facades that are set back from the lower, street-facing facades to minimize building height and bulk. Specifically, the architecture incorporates tiered massing, with one- and two-story elements stepping down towards East Avenida Pico and recessed upper levels along North El Camino Real. Further, as described above, the
development is designed in the Spanish Colonial Revival architectural style, in compliance with the A Overlay District requirements.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.11-13 Land Use and Planning
Relevant Coastal Land Use Plan Policies Project Consistency Analysis CUL-15 Architectural Overlay District. Require that new buildings and major remodels in the Del Mar/T-Zone, North Beach, and Pier Bowl areas, and on portions of El Camino Real designated with an Architectural Overlay District on Figures 2-1 (A-G) utilize Spanish Colonial Revival
architecture.

Consistent. Refer to response to LU-16.

CUL-16 Architectural Quality. Ensure that the City's
architecture in key community and tourist/visitor-serving areas maintain a high quality of design consistent with the City's history.

Consistent. Refer to response to LU-16.

CUL-17 Preserving Distinctive Architecture. Encourage
applicants for projects involving new development, additions and remodels to follow design standards (per the
Implementation Plan) for Spanish Colonial Revival
architectural style, except that remodels of architecturally significant buildings eligible or potentially eligible for historic listing with distinctive styles other than Spanish Colonial Revival, such as Post-Modern and Mid-Century Modern
architectural styles, should reinforce the buildings’ original architectural design.

Consistent. Refer to response to LU-16.

CUL-21 Native Trees. Encourage the planting of Native
California trees where their use is aesthetically, horticulturally and ecologically appropriate. Examples of potentially
appropriate species include Coast Live Oak, California
Sycamore and White Alder.

Consistent. Refer to response to VIS-18.

Source: City of San Clemente, Local Coastal Program Land Use Plan, March 2018.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.11-14 Land Use and Planning
This page intentionally left blank.

March 2026 3.12-1 Mineral Resources

3.12 MINERAL RESOURCES

3.12.1 General Plan EIR Summary
No Impact. As detailed on the General Plan EIR Initial Study, included as Appendix A of the General Plan EIR, San Clemente does not contain any mineral resources of Statewide or regional importance and the proposed land use changes under the General Plan would not impact areas near existing oil wells. As such, no impact would occur in this regard.

As detailed on the General Plan EIR Initial Study, included as Appendix A, there are no permitted mining operations within the City of San Clemente that provide aggregate materials to Southern California. Local land use plans do not identify mineral resources within the City. Therefore, the proposed General Plan would not have an adverse impact on mineral resource recovery sites. No impacts would occur in this regard.

3.12.2 Project-Specific Impacts
Would the project:

New
Potentially
Significant
Impact or
Increased
Significant
Impact
Significant
Impact
Already
Identified
in the
General
Plan EIR
Less Than
Significant
Impact
With
General
Plan EIR
Mitigation
and/or
COAs
Less Than
Significant
Impact
No
Impact
a. Result in the loss of availability of a known mineral resource that would be of value to the region and the
residents of the state?

b. Result in the loss of availability of a locally-important mineral resource recovery site delineated on a local
general plan, specific plan or other land use plan?

a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
No Impact. As the project site does not contain any mineral resources of Statewide or regional importance and is not located near existing oil wells, project development would not impact any areas of a known mineral resource. 24 No impacts would occur. b) Result in the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? No Impact. Refer to Response 3.12.2(a). No impacts would occur in this regard. 24 California Department of Conservation Geologic Energy Management Division, WellSTAR, https://maps.conservation.ca.gov/CalGEM/wellfinder/, accessed January 20, 2026.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.12-2 Mineral Resources
This page intentionally left blank.

March 2026 3.13-1 Noise

3.13 NOISE

3.13.1 General Plan EIR Summary
Significant and Unavoidable Impact. As detailed in the General Plan EIR, construction activities associated with development allowed under the General Plan EIR could result in substantial increases in ambient noise levels that could potentially exceed permitted noise levels on a temporary basis.

However, Municipal Code Section 15.36.190 allows for grading, right-of-way encroachment, and landscaping/irrigation construction under permit only, during specific hours. Approval to conduct these activities beyond this time period, or on Saturday, Sunday, or during recognized holidays must be pre-approved by the City Engineer through a written request submitted by the contractor.

The General Plan EIR concludes that significant noise impacts could result from heavy earthmoving equipment and truck hauling during construction of future development projects. As the General Plan anticipates increased development intensity, construction-related noise would vary depending on specific site conditions that are not yet known. Because individual project designs, locations, and construction schedules were not available at the time, construction noise levels at sensitive receptors were not precisely quantified. Construction activities would be temporary and intermittent but would still elevate ambient noise in areas surrounding each project site. Since some construction may occur near noise-sensitive receptors and could last for extended durations depending on the project type, noise disturbances could be substantial. Consequently, construction noise impacts associated with General Plan implementation were considered significant and unavoidable.

The General Plan EIR concludes that noise within the City of San Clemente is governed by federal, state, and local regulations, including the City’s Municipal Code, which sets limits for new stationary-source noise. Proposed development under the General Plan EIR Land Use Plan would introduce typical residential and commercial noise. Noise in San Clemente is regulated through federal, state, and local requirements, including the City’s Municipal Code, which establishes property-line limits for new stationary noise sources. Buildout under the proposed Land Use Plan would introduce additional residential, commercial, industrial, and institutional uses, but typical noise from these activities—such as landscaping, maintenance, and HVAC systems—is generally short, intermittent, and not a substantial contributor to overall noise levels. The City enforces its Noise Ordinance through Police and Code Enforcement staff, and any exceedance is treated as a nuisance subject to fines or legal abatement. Although large commercial and industrial operations may generate higher noise from trucks and equipment, much of the machinery is typically housed indoors, and operations on private property can be regulated as stationary sources. Each future project would undergo CEQA review to ensure that noise complies with municipal standards and does not adversely affect sensitive receptors. With adherence to the Noise Ordinance and implementation of applicable policies (S-4.01, LU-1.06, and LU-2.03), stationary-source noise impacts would remain less than significant.

The General Plan EIR also concludes that two roadway segments (Avenida Pico between Avenida La Pata and Camino La Pedriza, and Avenida La Pata between Calle Saluda and Avenida Vista Hermosa) where future traffic is expected to raise ambient noise levels by more than 5 dBA compared to 2012

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.13-2 Noise
conditions, would result in levels above 65 dBA CNEL. Because both segments contain single-family and multifamily residential receptors, these increases represent substantial changes in the noise environment, and the resulting traffic noise impacts were considered significant and unavoidable.

3.13.2 Project-Specific Impacts
Would the project result in:

REGULATORY FRAMEWORK
State
The State Office of Planning and Research Noise Element Guidelines include recommended exterior and interior noise level standards for local jurisdictions to identify and prevent the creation of incompatible land uses due to noise. The Noise Element Guidelines contain a land use compatibility table that describes the compatibility of various land uses with a range of environmental noise levels in terms of the CNEL.

A noise environment of 50 CNEL to 60 CNEL is “normally acceptable” for residential uses. The Office of Planning and Research recommendations also note that, under certain conditions, more restrictive standards than the maximum levels cited may be appropriate.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.13-3 Noise
Local
City of San Clemente General Plan
The Safety Element of the General Plan establishes policies to protect residents from noise. Goals and policies related to noise in the Safety Element and the Land Use Element are detailed below.

GOAL: Minimize exposure to excessive noise levels by taking appropriate actions to avoid or mitigate the detrimental effects of exposure to excessive noise levels on humans and animals and in particular on sensitive land uses.

S-4.01. Noise Control. We effectively control ambient and stationary noise conditions by maintaining baseline information, monitoring conditions, following State guidelines, and enforcing locally adopted ordinances and building codes.

S-4.02. Street Design. We consider noise impacts when designing new streets.

S-4.03. Interagency Collaboration. We encourage and collaborate with local, regional, and statewide transportation agencies to minimize transportation-related noise impacts and provide appropriate mitigation measures that also consider impacts to community character and on natural resources (e.g., views).

S-4.04. Balance Between Noise Control and View Protection. We will continue to work with local, State, and Federal agencies to reduce highway- and railroad-generated noise levels to within acceptable levels identified in the General Plan, while seeking to re-establish ocean views blocked by noise barriers on Interstate 5.

S-4.05. Rail-related Noise. We minimize the noise impact of passenger and freight rail service on sensitive land uses by coordinating with rail authorities to effectively manage train noise and by aggressively pursuing noise mitigation measures that apply to rail uses.

S-4.06. Truck Routes. To minimize truck traffic noise impacts to sensitive land uses, we designate areas where truck traffic is prohibited.

San Clemente Municipal Code
Table 3.13-1, Exterior Noise Standards, summarizes the exterior noise limits for the various land uses within the City.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.13-4 Noise
Table 3.13-1
Exterior Noise Standards
Land Use Leq Noise Level dBA Time Period
Residential 55 7 a.m. – 10 p.m.
50 10 p.m. – 7 a.m.

Commercial 65 7 a.m. – 10 p.m.
601 10 p.m. – 7 a.m.

Notes:

1. Standard only applies if commercial, industrial or manufacturing buildings are occupied during these hours.

Sources: City of San Clemente, San Clemente Municipal Code Section 8.48.050, Exterior Noise Standards, adopted February 16, 2016.

A. It shall be unlawful for any person at any location within the City to create any noise, or to allow the creation of any noise on property owned, leased, occupied, or otherwise controlled by such person, when the foregoing causes the noise level, when measured on any other property to exceed:

1. The noise standard for a cumulative period of more than thirty (30) minutes in any hour.

2. The noise standard plus five (5) dB(A) for a cumulative period of more than fifteen (15) minutes in any hour; or

3. The noise standard plus ten (10) dB(A) for a cumulative period of more than five (5) minutes in any hour; or

4. The noise standard plus fifteen (15) dB(A) for a cumulative period of more than one (1) minute in any hour; or

5. The noise standard plus twenty (20) dB(A) for any period of time.

B. In the event the ambient noise level exceeds any of the five (5) noise limit categories above, the allowable noise level under said category shall be increased to reflect the ambient noise level.

Amplified Music
Section 8.48.070 of the Municipal Code states the following: “The following acts, among others, are declared to be loud, disturbing and unnecessary noises in violation of this chapter, unless specifically exempted from the provisions of this chapter in Section 8.48.090; the following list shall not be deemed to be exclusive: …B. Radios, phonographs, etc. on Private Property or Within Vehicles in Public: Operating, playing or permitting the operation or playing of any radio, receiving set, television set, phonograph, drum, musical instrument, or similar device, on private property or within vehicles in public, which produces or reproduces sound:

1. In such manner as to disturb the peace, quiet and comfort of a person of normal sensitiveness.

2. At any time with louder volume than is necessary to provide convenient hearing of the device by voluntary listeners located in the same room, vehicle or chamber as the device.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.13-5 Noise

3. Between the hours of 10:00 p.m. and 7:00 a.m. in such a manner as to create a noise disturbance across a residential or commercial real property line or at any time to violate the provisions of Sections 8.48.050 and 8.48.060.”
Construction Activity
Noise associated with construction activity is exempt from exterior noise standards provided that construction activities take place between the hours of 7:00 a.m. and 6:00 p.m. on Monday through Friday, between the hours of 8:00 a.m. and 6:00 p.m. on Saturday, excluding City-recognized holidays.

Additionally, Municipal Code Section 15.36, states that grading and equipment operations within onehalf mile of a structure for human occupancy shall not be conducted between the hours of 5:30 p.m. and 7:30 a.m. nor on Saturdays, Sundays and City-recognized holidays.

EXISTING NOISE SETTING
Existing Stationary Noise Levels
The primary sources of stationary noise in the project vicinity are urban-related activities (i.e., mechanical equipment). The noise associated with these sources may represent a single-event noise occurrence, short-term, or long-term/continuous noise.

Mobile Sources
Most of the existing noise in the project area is generated from traffic along surrounding roadways, including East Avenida Pico and North El Camino Real.

Existing Ambient Noise Levels
To quantify existing ambient noise levels in the project area, Veneklasen visited the proposed location on July 10, 2025, to perform measurements of the existing background noise levels at the nearest properties that could potentially be impacted. Short-duration measurements (30 minutes long) were taken between the hours of 6:00 pm and 9:30 pm, a period during business hours when ambient levels are expected to be lower. Ambient noise measurements during nighttime were not possible due to access restriction. Results are presented in terms of the Leq or average sound level, which includes steady-state and transient noises. Given all the measured ambient levels are higher than those indicated in Municipal Code Section 8.48.050, measured levels were considered as ambient levels during daytime as per Municipal Code Section 8.48.050.B; nighttime ambient levels will be maintained as per indicated in Section 8.48.050. The noise levels measured near the project site are identified in Table 3.13-2, ShortTerm Noise Measurements.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.13-6 Noise
Table 3.13-2
Short-Term Noise Measurements
Property Type Average (Leq) Ambient
Level, (dBA) Before 10 pm
Business
Hours of
Operation
Catalyst Commercial 68.0 10 am – 5 pm
7-Eleven Commercial 68.0 24 hours open
Russell Fischer Car Care Commercial 66.0 8 am – 6 pm
Propane Refill at U-Haul Commercial 74.0 7 am – 7 pm
5 North El Camino Real Residential 56.0 --
100 Boca De La Playa Residential 55.0 --
Notes: dBA = A-weighted decibels; Leq = Average Sound Level

1. Land uses of the closest sensitive receptor based on the land use designation for exterior noise standards; refer to Table 3.13-

1. Source: Veneklasen Associates, The Hanson Hotel; San Clemente, California Property Line Noise Veneklasen Project No. 8746- 001, August 1, 2025; refer to Appendix G.
a) Generation of a substantial temporary or permanent increase in ambient noise levels in in the vicinity of the project excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? Less than Significant Impact With General Plan EIR Mitigation and/or COAs.

CONSTRUCTION NOISE
Construction Equipment Noise
Ground-borne noise and other types of construction-related noise impacts typically occur during the initial grading phase, which has the potential to create the highest levels of noise. Construction equipment produces maximum noise levels when equipment is operating under full power conditions (i.e., the equipment engine at maximum speed). However, equipment used on construction sites typically operates under less than full power conditions, or part power. To characterize constructionperiod noise levels more accurately, the average (Leq) noise level associated with each construction stage is calculated based on the quantity, type, and usage factors for each type of equipment that would be used during each construction stage. These noise levels are typically associated with multiple pieces of equipment simultaneously operating on part power.

Construction of the proposed project is expected to last approximately 18 months and includes grading, building construction, paving, and architectural coating phases. The project is expected to export approximately 14,300 cubic yards of earthwork material during grading. The proposed project construction activities would also include pile driving and shoring activities.

The nearest sensitive receptors to the project site are the existing single-family residences located approximately 450 feet to the southwest of the project site. However, the project site is located

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.13-7 Noise
approximately 55 feet south of the Sea Summit Habitat Preserve area (Open Space). To maintain the quiet nature of this use, construction noise impacts are analyzed at both Sea Summit Habitat Preserve and the nearest residential uses. Additionally, construction activities would occur throughout the project site, and it should also be noted that the maximum construction noise levels would intermittently occur for a few days when construction equipment is operating closest to the nearest sensitive uses. The remainder of the time, the construction noise levels would be much lower because the equipment would be working in an area farther away from the existing sensitive uses.

The City of San Clemente does not have a quantitative threshold that applies to noise levels at active construction sites. To evaluate whether the proposed project would generate potentially significant temporary construction noise levels at off-site sensitive receiver locations, a construction-related noise level threshold was utilized from the Occupational Noise Exposure prepared by the National Institute for Occupational Safety and Health (NIOSH). As a division of the U.S. Department of Health and Human Services, NIOSH identifies a noise level threshold based on the duration of exposure to the source. The construction-related noise level threshold starts at 85 dBA for more than eight hours per day, and for every 3-dBA increase, the exposure time is cut in half. For the purposes of this analysis, the lowest, most conservative construction noise level threshold of 85 dBA Leq was used as an acceptable threshold for construction noise at the nearby sensitive receiver locations. Since this construction-related noise level threshold represents the energy average of the noise source over a given time, they are expressed as Leq noise levels. Therefore, the noise level threshold of 85 dBA Leq over a period of eight hours or more is used to evaluate the potential project-related construction noise level impacts at the nearby sensitive receiver locations.

The General Noise Assessment methodology prescribed in the Federal Transit Administration (FTA) Manual recommends evaluating construction noise from the center of the site, stating under the variable distance in its construction noise calculation to “assume that all equipment operates at the center of the project.” As such, the construction noise levels shown in Table 3.13-3, Construction Noise Levels at the Nearest Sensitive Receptors, are estimated using the distance from the center of the project site to the property line of the existing sensitive receptors, which is approximately 110 feet to the closest sensitive receptors to the north (Sea Summit Habitat Preserve) and 570 feet to the southwest of the project site (single-family residences). Noise levels from construction equipment and activities were modeled using the Federal Highway Administration’s Roadway Construction Noise Model (RCNM). To present a conservative impact analysis, the estimated noise levels were calculated for a scenario in which all heavy construction equipment were assumed to operate simultaneously; refer to Appendix G.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.13-8 Noise
Table 3.13-3
Construction Noise Levels at the Nearest Residential Receptors Phase
Estimated Exterior Construction Noise Level at
110 feet (Center of the Project Site to the
Northern Open Space Receptors) (dBA Leq)1
Estimated Exterior Construction Noise Level at
570 feet (Center of the Project Site to the
Southwestern Residential Receptors) (dBA Leq)1
Grading 77.7 63.4
Building
Construction 77.0 62.7
Paving 77.4 63.1
Architectural
Coating 66.8 52.6
Notes:

1. These noise levels conservatively assume the simultaneous operation of all heavy construction equipment at the same precise location. Refer to Appendix G for modeled construction equipment.

Source: Federal Highway Administration, Roadway Construction Noise Model (RCNM), 2006.

As shown in Table 3.13-3, construction-generated noise levels would range from 66.8 dBA Leq to 77.7 dBA Leq at the nearest sensitive receptor (Sea Summit Habitat Preserve) property boundary located approximately 110 feet north from the geographic center of the project site and would not exceed the applicable threshold of 85 dBA. Further, construction-generated noise levels would range from 52.6 dBA Leq to 63.4 dBA Leq at the nearest residential sensitive receptor property boundary located approximately 570 feet southwest from the geographic center of the project site and would not exceed the applicable threshold of 85 dBA. As such, project construction would not exceed NIOSH’s noise threshold of 85 dBA for construction activities, and impacts related to construction noise would be less than significant.

Further, all construction activities would be conducted in accordance with the City of San Clemente Section 15.36.190 which allows for grading, right-of-way encroachment, and landscaping/irrigation construction under permit only, during specific hours. These permitted activities can occur between 7:00 a.m. to 6:00 p.m., Monday through Friday. Construction of the proposed project would not require any nighttime construction activities. As such, impacts related to construction noise would be less than significant.

Construction Mobile Noise
Construction activities would also cause increased noise along access routes along East Avenida Pico and North El Camino Real due to the movement of equipment and workers, as well as haul trips.

According to California Department of Transportation (Caltrans), a doubling of traffic (100 percent increase) on a roadway would result in a perceptible increase in traffic noise levels (3 dBA).25 As such, a significant impact would occur if construction-related trips double existing traffic volumes.

According to the project’s air quality modeling, it is anticipated that project construction would generate a total maximum of 212 two-way trips per day, including 60 two-way worker trips per day, 25 California Department of Transportation, Technical Noise Supplement to the Traffic Noise Analysis Protocol, September 2013.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.13-9 Noise
24 two-way vendor trips and 80 two-way hauling trips per day; refer to Appendix B, Air Quality/GHG/Energy Data. Per the General Plan EIR Section 5.14, Transportation and Traffic, 2013 traffic counts along East Avenida Pico and North El Camino Real are 20,523 and 16,034 average daily trips (ADTs), respectively. As such, project-related construction trips would not result in a doubling of the traffic volumes along East Avenida Pico and North El Camino Real, and therefore, there would not be a perceptible increase (3 dBA) in construction-related traffic noise. Additionally, mobile traffic noise from construction trips would be temporary and would cease upon project construction completion. Thus, impacts in this regard would be less than significant.

OPERATIONAL NOISE
Off-Site Mobile Noise
The proposed project would result in additional traffic on adjacent roadways, thereby increasing vehicular noise in the vicinity of existing land uses. As discussed above and according to Caltrans, a doubling in roadway traffic volumes is required to generate any noticeable increase in roadway noise levels. Based on the San Clemente 1801 N. El Camino Real – VMT Screening Assessment (VMT Screening Assessment), prepared by Michael Baker International and dated February 2, 2026; refer to Appendix H.2, VMT Screening Assessment, the project would generate a total of 1,631 average daily trips (ADT).

As previously stated, the ADTs along East Avenida Pico and North El Camino Real are 20,523 and 16,034 ADTs, respectively. As such, the project’s trip generation (approximately 1,631 ADTs) would not double existing traffic volumes along East Avenida Pico and North El Camino Real and therefore, there would not be a perceptible increase (3 dBA) in traffic noise. Impacts would remain less than significant.

Mechanical Equipment
Stationary noise sources associated with the proposed project would include simultaneous operation of the pool lounge and rooftop lounge, including crowd noise and background music, during all hours of the day. A noise impact study (Veneklasen Noise Memo) was prepared for the proposed project to evaluate project-related stationary noise impacts; refer to Appendix G.

Based on Veneklasen Noise Memo, the noise levels from roof top lounge and pool area activities shall not exceed 55 dBA during daytime and 50 dBA during nighttime at residential units; and 65 dBA during daytime and 60 dBA during nighttime at commercial units; refer to Table 3.13-1 and Appendix G. In the event the ambient noise level exceeds any of the five (5) noise limit categories above, the allowable noise level under said category shall be increased to reflect the ambient noise level.

With the acoustical measurements previously performed at the proposed location and the historical data, the Veneklasen Noise Memo utilized iNoise v2024.2 rev 1 software in order to predict the noise level at several locations. The Veneklasen Noise Memo modeled the simultaneous operation of the pool lounge and rooftop lounge, including crowd noise and background music, during all hours of the day. Per the architect’s direction, directional loudspeakers were selected and positioned at a height of 7 feet, angled 45 degrees downward to focus sound on the audience area. Therefore, the indicated conditions were modeled to reflect the noise levels at the indicated locations.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.13-10 Noise
As shown in Table 3.13-4, Future Hanson Hotel Noise Levels (dBA) and Limit, simultaneous operation of the pool lounge and rooftop lounge, including crowd noise and background music would not exceed the City of San Clemente noise thresholds for daytime and nighttime hours. As such, impacts would be less than significant in this regard.

Table 3.13-4
Future Hanson Hotel Noise Levels (dBA) and Limit Compliance Property Type Project’s Operational Noise
Levels (Leq, dBA)
Noise Limits (Leq, dBA)
(Daytime/Nighttime)
Daytime/Nighttime
Compliance
Catalyst Commercial 43 68/601 Yes/NA
7-Eleven Commercial 56 68/601 Yes/Yes
Russell Fischer
Car Care Commercial 56 66/601 Yes/NA
Propane Refill at
U-Haul Commercial 48 74/601 Yes/NA
5 North El
Camino Real Residential 46 56/50 Yes/Yes
100 Boca De La
Playa Residential 48 55/50 Yes/Yes
Notes: dBA = A-weighted decibels; Leq = Average Sound Level;

1. Land uses of the closest sensitive receptor based on the land use designation for exterior noise standards; refer to Table

3.13-2.

Source: Veneklasen Associates, The Hanson Hotel; San Clemente, California Property Line Noise Veneklasen Project No. 8746- 001, August 1, 2025; refer to Appendix G
As shown in Table 3.13-4, the proposed project outdoor areas comply with the San Clemente’s daytime and nighttime noise requirements at nearby commercial locations (S1, S2, S3 and 7-Eleven) as well as at the closest residential locations S4, S5 and 313 Via Salamaca.

To ensure the General Plan EIR Mitigation Measure 10-1 and Municipal Code Sections 8.48.070 and

8.48.050 pertaining to noise are met, the project would be required to comply with COAs 3.13, 4.5,

4.6, 7.8, and NOI-1. Specifically COA NOI-1 would require an audio limiter to be installed on the rooftop lounge sound system. It would be programmed with a “nighttime” setting that reduces volume by at least 5dBA below the typical daytime operation. This setting would be used from 10 p.m. until closing time. A Behringer DCX2496 or The Govnor SPL2.2 Sound Pressure Limiter, or its equivalent, would be utilized. With compliance with the General Plan EIR Mitigation Measure 10-1 and Municipal Code Sections 8.48.070 and 8.48.050, implemented through COAs 3.13, 4.5, 4.6, 7.8, and NOI-1, the project’s specific noise impacts would be less than significant.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.13-11 Noise
Conclusion
In summary, the proposed project’s construction and operational noise levels would not exceed the applicable City’s noise thresholds, and the project would result in less impacts. The proposed project’s operational noise levels would also not exceed the applicable City’s noise thresholds.

Applicable General Plan EIR Mitigation Measures:
10-1 Prior to the issuance of building permits for projects that involve a noise-sensitive use within the 65 dBA CNEL contour (i.e., areas in or above 65 dBA CNEL) along major roadways, freeways, and railroads, the project property owner/developers shall retain an acoustical engineer to conduct an acoustic analysis and identify, where appropriate, site design features (e.g., setbacks, berms, or sound walls), and/or required building acoustical improvements (e.g., sound transmission class rated windows, doors, and attic baffling) to ensure compliance with the City’s Noise Compatibility Criteria and the California State Building Code and California Noise Insulation Standards (Title 24 and 21 of the California Code of Regulations). 10-2 Construction activities associated with new development that occurs near sensitive receptors shall be evaluated for potential noise impacts. Mitigation measures such as installation of temporary sound barriers for construction activities that occur adjacent to occupied noisesensitive structures, equipping construction equipment with mufflers, and reducing nonessential idling of construction equipment to no more than five minutes shall be incorporated into the construction operations to reduce construction-related noise to the extent feasible.
10-4 Individual projects that use vibration-intensive construction activities, such as pile drivers, jack hammers, and vibratory rollers, near sensitive receptors shall be evaluated for potential vibration impacts. If construction-related vibration is determined to be perceptible at vibration-sensitive uses (i.e., exceed the Federal Transit Administrations vibration annoyance criterion of 78 VdB), additional requirements, such as use of less-vibration-intensive equipment or construction techniques, shall be implemented during construction (e.g., drilled piles to eliminate use of vibration-intensive pile driver).

Applicable Conditions of Approval (COA):

3.13 The Applicant shall demonstrate to the satisfaction of the City Engineer that the following standards shall be satisfied:

A. All construction vehicles or equipment, fixed or mobile, operated within 1,000 feet of a dwelling shall be equipped with operating and maintained mufflers.

B. All operations shall comply with Orange County Codified Ordinance Division 6 (Noise Control).

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.13-12 Noise
C. Stockpiling and/or vehicle-storage areas shall be located as far as practicable and out of view from dwellings.

The City of San Clemente Noise Ordinance, limiting the hours of construction to between 7:00 a.m. and 6:00 p.m., shall be enforced.
(Municipal Code Chapter 15.36)

Less than Significant Impact. Project construction can generate varying degrees of groundborne vibration, depending on the construction procedure and the construction equipment used. Operation of some heavy-duty construction equipment generates vibrations that spread through the ground and diminish in amplitude with distance from the source. The effect on buildings located in the vicinity of

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.13-13 Noise
the construction site often varies depending on soil type, ground strata, and construction characteristics of the receiver building(s). The results from vibration can range from no perceptible effects at the lowest vibration levels, to low rumbling sounds and perceptible vibration at moderate levels, to slight damage at the highest levels. Groundborne vibrations from construction activities rarely reach levels that damage structures.

The types of construction vibration impacts include human annoyance and building damage. Human annoyance occurs when construction vibration rises significantly above the threshold of human perception for extended periods of time. Building damage can be cosmetic or structural. The Caltrans Transportation and Construction Vibration Guidance Manual identifies various vibration damage criteria for different building classes. The nearest sensitive receptors to the project site are the single-family dwellings located approximately 450 feet to the southwest of the project site. However, it should be noted that construction would occur throughout the project site and would be localized at a single point. Nevertheless, to present a more conservative analysis, the following evaluation would utilize the 450 feet distance (when measured from the sensitive receptor’s building façade to the project’s southwestern property line) to determine potential vibratory impacts. Since the nearest sensitive receptor (a single‑family dwelling located to the southwest) is likely an older residential structure, a significant vibration impact related to building damage would occur if project-generated vibration were to exceed Caltrans’ 0.3 inches per second (in/sec) PPV threshold for older residential buildings at this location. Further, the nearest historic building is located approximately 100 feet south of the project site (across North El Camino Real), therefore, a significant vibration impact related to building damage would occur if project-generated vibration were to exceed Caltrans’ 0.25 inches per second (in/sec) PPV threshold for the historic building at this location.

Table 3.13-5, Vibration Levels of Construction Equipment, shows the reference vibration levels of construction equipment at 25 feet, at 100 feet (at historic building), and at 450 feet (at the closest single-family residential sensitive receptors to the southwest).

As indicated in Table 3.13-5, vibration velocities from typical heavy construction equipment used during project construction would range from 0.003 to 1.518 in/sec PPV at 25 feet from the source of activity. At a distance of 100 feet, vibration levels at the nearest historic building would range from less than 0.001 to 0.14 in/sec PPV and would not exceed the applicable 0.2 in/sec PPV significance threshold. At a distance of 450 feet, vibration levels at the nearest residential receptors would range from less than 0.001 to 0.026 in/sec PPV, which would remain below the 0.3 in/sec PPV threshold.

Therefore, construction‑related vibration impacts would not exceed applicable significance criteria and would be less than significant.

The project proposes a mixed-use hotel use and would not involve land uses that involve operation of trucks or rail use. As such, the project would not generate groundborne vibration that could be felt by surrounding uses. The proposed project would not result in any operational vibrations and impacts would be less than significant in this regard.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.13-14 Noise
Table 3.13-5
Vibration Levels of Construction Equipment
Equipment
Approximate peak
particle velocity at 25
feet (in/sec)1
Approximate peak particle velocity
at 100 feet (in/sec)1 Approximate peak particle velocity at 450 feet (in/sec)1
Large
bulldozer

0.089 0.019 0.003
Loaded trucks 0.076 0.016 0.003
Small
bulldozer

0.003 <0.001 <0.001
Pile Driving
(typical)

0.644 0.140 0.026
Vibratory
Rollers

0.210 0.045 0.008
Notes:

1. Calculated using the following formula:

PPV equip = PPVref x (25/D)1.1
where: PPV equip = the peak particle velocity in in/sec of the equipment adjusted for the distance PPV ref = the reference vibration level in in/sec from Table 7-4 of the FTA Transit Noise and Vibration Impact Assessment Manual.

D = the distance from the equipment to the receiver
Source: Federal Transit Administration, Transit Noise and Vibration Impact Assessment Manual, Table 7-4 Vibration Source Levels for Construction Equipment, September 2018.

Conclusion
In summary, the proposed project would not expose persons to construction and operational vibration levels in excess of Caltrans’ construction threshold and the proposed project would not generate groundborne vibration that could be felt by surrounding uses during operation. c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
No Impact. The proposed project site is not located within an airport land use plan or within two miles of a public airport or public use airport. The nearest airport to the project site is John Wayne Airport, located approximately 20.0 miles to the northwest of the project site. According to John Wayne Airport, the project site is located outside of the airport’s noise contours.26 Therefore, no impact would occur in this regard.
26 John Wayne Airport, John Wayne Airport Orange County – 2024 Annual Community Noise Equivalent Level (CNEL) Contours, https://files.ocair.com/media/2025-03/CNEL%20Noise%202024.pdf?VersionId=sP5JZJ.HJkeYtq9jJslfTN9s.mUL.i1n, accessed January 18, 2026.

March 2026 3.14-1 Population and Housing

3.14 POPULATION AND HOUSING

3.14.1 General Plan EIR Summary
Less Than Significant Impact. The General Plan EIR concluded that buildout of the General Plan would increase population, housing, and employment beyond the Southern California Association of Governments’ (SCAG’s) regional forecasts for the City. However, the General Plan would improve the job-housing balance in the City and would be consistent with regional policies. Overall, impacts were determined to be less than significant.

As detailed on the General Plan EIR Initial Study, included as Appendix A, development proposed under the General Plan would alter existing land use designations and could displace nonconforming housing with new development. However, the General Plan is not expected to displace a substantial amount of existing housing, and it would increase the number of dwelling units by allowing higher intensity residential uses and mixed-use development. Impacts would be less than significant.

3.14.2 Project-Specific Impacts
Would the project:

The project site is located in the North Beach/North El Camino Real Focus Area, an area of the City that is targeted for mixed-use development in order to allow for a horizontal or vertical mix of commercial and residential uses. The project proposes a 61-room hotel with a rooftop restaurant and

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.14-2 Population and Housing
bar, an indoor café, a walkup café, and a hotel guest-only pool and restaurant. Overall, the total building area (including hotel space, amenities, and garage space) would be approximately 77,308 square feet. As the project would be consistent with the site’s land use and zoning, the General Plan EIR accounted for the proposed development within the retail/service buildout total and employment projections. Since the project would not provide residential uses on a parcel designated for mixed-use, the project would not provide housing opportunities in the City, but would provide employment opportunities. As such, the project would help improve the job-housing imbalance in the housing-rich City. As the General Plan EIR considered buildout of the project site pertaining to indirect population increase as a result on new employees, as discussed above, the proposed project would not result in unplanned population growth in the City, either directly or indirectly. Impacts in this regard would be less than significant.

b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
No Impact. The project site is currently vacant, disturbed land. As such, development of the project site would not result in a substantial number of existing people or housing to be displaced. The project has no potential to displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere, and no impact would occur.

March 2026 3.15-1 Public Services

3.15 PUBLIC SERVICES

3.15.1 General Plan EIR Summary
Less Than Significant Impact. Regarding fire protection, the General Plan EIR determined that although buildout of the General Plan would increase the population and businesses in San Clemente, leading to higher demand for fire protection services. However, the City and Orange Conty Fire Authority (OCFA) would maintain appropriate firefighter staffing to ensure compliance with National Fire Protection Association (NFPA) standards for response time and coverage upon implementation of the General Plan. Policies and implementation measures in the General Plan are designed to ensure collaboration between City departments, OCFA, and other involved agencies to achieve the City’s development goals in phases, working within the budget and infrastructure constraints of the City.

Following this process, sufficient revenue would be available for necessary service improvements to provide for adequate fire facilities, equipment, and personnel upon buildout of the General Plan. In addition, future projects would be reviewed by the City and OCFA on an individual basis and would be required to comply with requirements in effect at the time building permits are issued. Therefore, impacts to fire services resulting from buildout of the General Plan would be less than significant.

Regarding police protection, the General Plan EIR determined that upon implementation of the General Plan, compliance with General Plan policy S-7.01 to provide adequate staffing, facilities, and supplies and Policy S-7.05 to create local, State and Federal emergency services agencies to enhance safety resources in the City, would ensure that the City and Orange County Sheriff Department (OCSD) maintain levels of police protection consistent with the OCSD’s service standards. Provision of police services under the General Plan would continue to be funded by revenues in the City’s General Fund, which would be expected to grow as new units and businesses are added in San Clemente. Facilities, equipment, and personnel needed to serve additional residents in the City would be financed by increases in tax revenue generated by new housing units and businesses. Therefore, impacts on police protection services resulting from buildout of the General Plan would be less than significant.

Regarding schools, the General Plan EIR determined that population growth in San Clemente under the General Plan would result in additional students (the addition of 2,394 students) in San Clemente and would likely require expanded school services and new or expanded school facilities. Despite this increased need, payment of SB 50 development impact fees would provide funding for the financing of new school facilities. Therefore, impacts on school services resulting from buildout of the General Plan are assumed to be less than significant.

Refer to Section 3.16, Recreation, for a discussion of the General Plan EIR’s findings relevant to parks and other recreational facilities.

Regarding other public facilities, the General Plan EIR determined that buildout of the General Plan would result in an increase in demand for library services in San Clemente. New facilities, books, and personnel would be necessary to reach adequate levels of service. However, additional City and county tax revenues generated from new dwelling units and businesses in San Clemente would contribute toward the financing of additional library space and services in the City. Implementation of policies and implementation measures in the General Plan would assist in providing library services that meet local needs. Residents of the City also have access to the entirety of the Orange County Public Library

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.15-2 Public Services
(OCPL) library system and its materials. For all of the above reasons, buildout of the General Plan is not anticipated to have a significant impact on library services

3.15.2 Project-Specific Impacts
Would the project:

1) Fire protection?
Less than Significant Impact. As the project would construct a new hotel and retail/restaurant uses on-site, the project would result in an increased demand for fire protection, police protection, schools, and libraries, compared to the existing condition. However, the project would not require any General Plan amendments or zone change; upon approval of the conditional use permit, the project would be consistent with the land uses anticipated for the site; refer to Section 3.11, Land Use and Planning. Thus, the project has already been accounted for under the assumptions for buildout of the General Plan and demand for fire protection, police protection, schools, and libraries would not increase from what was considered in the General Plan EIR. Furthermore, with the payment of mandatory property taxes and impact fees as required by the Municipal Code, the project would not result in adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.15-3 Public Services
environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives. The project’s impacts related to public services would be less than significant.

Recreational impacts, including impacts related to public parks, are analyzed in Section 3.16, Recreation, and determined to be less than significant.
2) Police protection?
Less than Significant Impact. Refer to Response 3.15.2(a). The project’s impacts related to public services would be less than significant.
3) Schools?
Less than Significant Impact. Refer to Response 3.15.2(a). The project’s impacts related to public services would be less than significant.
4) Parks?
Less than Significant Impact. Refer to Response 3.15.2(a) and Section 3.16, Recreation, for an analysis regarding parks and other recreational facilities. The project’s impacts related to public services would be less than significant.
5) Other public facilities?
Less than Significant Impact. Refer to Response 3.15.2(a). The project’s impacts related to public services would be less than significant.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.15-4 Public Services
This page intentionally left blank.

March 2026 3.16-1 Recreation

3.16 RECREATION

3.16.1 General Plan EIR Summary
Less Than Significant Impact. According to the General Plan EIR, buildout of public open space areas under the General Plan could accommodate new or expanded parks and recreational facilities needed to meet the City’s parkland standard. Private Open Space areas, which include private golf clubs and publicly accessible trails, would continue to provide supplementary recreational opportunities to City residents under the General Plan. The combination of parkland dedication, in lieu fees and passive open space opportunities will provide adequate recreational amenities for future residents, and build out of the General Plan would not cause a substantial physical deterioration of existing facilities. Impacts are less than significant.

The General Plan EIR noted that the 971 acres of land designated for public open space under the General Plan would includes parks and recreational facilities. Although a majority of this acreage is not used for parks and recreation and would likely remain unimproved open space upon buildout, some of the acreage could be improved as parks and recreational facilities. As such, development pursuant to the General Plan would result in the construction of new or expansion of existing recreational facilities in the City. However, the General Plan EIR determined that goals, policies, and actions in the General Plan, along with existing federal, State, and local regulations, would mitigate potential adverse impacts to the environment that may result from the expansion of parks, recreational facilities, and trails upon buildout of the General Plan. Furthermore, subsequent environmental review would be required for development of park projects under the General Plan. Consequently, the General Plan EIR concluded that the General Plan would not result in significant impacts relating to new or expanded recreational facilities.

3.16.2 Project-Specific Impacts
Would the project:

New
Potentially
Significant
Impact or
Increased
Significant
Impact
Significant
Impact
Already
Identified
in the
General
Plan EIR
Less Than
Significant
Impact
With
General
Plan EIR
Mitigation
and/or
COAs
Less Than
Significant
Impact
No
Impact
a. Would the project increase the use of existing
neighborhood and regional parks or other
recreational facilities such that substantial physical
deterioration of the facility would occur or be
accelerated?

b. Does the project include recreational facilities or
require the construction or expansion of recreational
facilities which might have an adverse physical effect
on the environment?


HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.16-2 Recreation
a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?

Less than Significant Impact. As the project would construct a new hotel and retail/restaurant uses on-site, the project would result in an increased demand for recreational facilities compared to the existing condition. However, the project would not require any General Plan amendments or zone change; upon approval of the conditional use permit, the project would be consistent with the land uses anticipated for the site; refer to Section 3.11. Thus, the project has already been accounted for under the assumptions for buildout of the General Plan and demand for recreational facilities would not increase from what was considered in the General Plan EIR. Therefore, project impacts related to recreational facilities would be less than significant. b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?
Less than Significant Impact. Refer to Response 3.16(a). The project would provide both outdoor and indoor recreational amenities on-site. No other improvements pertaining to park and recreation facilities are proposed. The physical impacts resulting from the construction of these facilities have been addressed in the analyses presented throughout this checklist evaluation. Project impacts related to new or expanded recreational facilities would be less than significant.

March 2026 3.17-1 Transportation

3.17 TRANSPORTATION

3.17.1 General Plan EIR Summary
Significant and Unavoidable Impact. Implementation of the proposed General Plan would promote the use of alternative transportation modes, and several policies were included in the Mobility Element to promote the development of new or expansion of facilities. Policies were also included to require public outreach and education to promote alternative modes and their safe use.

Policy M-1.12 would ensure that development projects and subdivisions are designed and/or retrofitted to incorporate, and be efficiently served by, public transit, pedestrian and bicycle facilities.

Policy M-1.19 promotes the consideration of multimodal alternative improvements to nonautomotive facilities during street redesign projects. Policies M-2.01 through M-2.36 were included specifically to promote the use of alternative modes of transportation and to assist in the implementation of the Bicycle and Pedestrian Master Plan (BPMP). Overall, the General Plan EIR determined that if a project was found to be consistent with the Mobility Element, no conflict with policies, plans, and programs for alternative transportation would occur.

Regarding vehicular circulation, the General Plan EIR found that implementation of the General Plan, including both the Mobility and Complete Streets Elements, would result in several intersections and roadway segments operating at below acceptable levels of service (LOS). As such, General Plan EIR Mitigation Measure 14-1, which would require specific intersection improvements be implemented as outlined in Table 5.14-15, Summary of Intersection Impacts and Mitigations Measures, of the General Plan EIR, and Mitigation Measure 14-2, which would require specific roadway segment improvements be implemented as outlined in Table 5.14-16, Summary of Roadway Segment Impacts and Mitigation Measures, of the General Plan EIR, were determined necessary in order to operate at acceptable LOS. Still, as right-of-way acquisitions would be required in order to implement both General Plan EIR Mitigation Measures 14-1 and 14-2, and such acquisitions cannot be guaranteed, impacts in this regard were determined to be significant and unavoidable. It is acknowledged that the General Plan EIR did not analyze whether or not buildout of the General Plan would conflict with CEQA Guidelines Section 15064.3, subdivision (b), as LOS, not vehicle miles traveled (VMT), was the measurement used to analyze traffic impacts when the General Plan EIR was prepared and certified.

The General Plan EIR established that reclassification improvements of certain arterials throughout the City required to accommodate projected circulation needs would be designed in accordance with established roadway design standards, some of which have also been incorporated into the Mobility and Complete Streets Element of the General Plan. Future roadway improvements associated with development and redevelopment activities under the General Plan would be designed based on these standards as well. Future improvements would be subject to review and future consideration by the City, and an evaluation of the roadway alignments, intersection geometrics, and traffic control features would be needed. Roadway improvements would have to be made in accordance with the City’s Circulation Plan, roadway functional design guidelines, and meet design guidelines included in the California Manual of Uniform Traffic Control Devices (MUTCD) and the Caltrans Roadway Design Manual.

Conflicts between vehicular traffic and other forms of travel such as bicyclists and pedestrians may also cause traffic hazards. Implementation of Policy M-3.01 requires that pedestrian, vehicular, and bicycle circulation on public and private property are coordinated and designed to maximize safety, comfort and aesthetics and are consistent with federal, State, Orange County, and local laws, codes,

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.17-2 Transportation
and standards. In addition, Policy M-3.04 encourages the use of traffic calming measures to slow traffic where non-motorized travel is encouraged. Policy M-3.03 requires collaboration with the Capistrano Unified School District and private schools to identify and implement safety measures to improve safe travel to and from schools for students, parents, residents, and school employees. Policy M-3.06 requires balance of emergency response time and evacuation needs with other community concerns, such as Urban Design and traffic calming. Overall, implementation of the General Plan would not result in hazardous conditions, create conflicting uses, or cause a detriment to emergency vehicles access. Since roadway improvements would have to be made in accordance with the City’s Circulation Plan and roadway functional design guidelines, and with implementation of Policies M-3.01 through M-3.06, the General Plan EIR found that impacts would be less than significant, and no mitigation would be required.

Implementation of the General Plan would not cause a detriment to emergency vehicles access. Since roadway improvements would have to be made in accordance with the City’s Circulation Plan and roadway functional design guidelines, and with implementation of General Plan Policies M-3.01 through M-3.06, the General Plan EIR found that impacts would be less than significant, and no mitigation would be required.

3.17.2 Project-Specific Impacts
Would the project:

New
Potentially
Significant
Impact or
Increased
Significant
Impact
Significant
Impact
Already
Identified
in the
General
Plan EIR
Less Than
Significant
Impact
With
General
Plan EIR
Mitigation
and/or
COAs
Less Than
Significant
Impact
No
Impact
a. Conflict with a program plan, ordinance or policy
addressing the circulation system, including
transit, roadway, bicycle and pedestrian facilities?

b. Conflict with or be inconsistent with CEQA
Guidelines Section 15064.3, subdivision (b)? 
c. Substantially increase hazards due to a
geometric design feature (e.g., sharp curves or
dangerous intersections) or incompatible uses
(e.g., farm equipment)?

d. Result in inadequate emergency access? 
The information presented in this analysis is based on and supplemented with the following studies:
• The Hansen Hotel Focused Transportation Study, prepared by Fehr & Peers, dated January 17, 2025; refer to Appendix H.1, Focused Transportation Study.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.17-3 Transportation
• San Clemente 1801 N. El Camino Real – VMT Screening Assessment, Technical Memorandum (VMT Screening Memo) prepared by Michael Baker International, dated February 2, 2026; refer to Appendix H.2, VMT Screening Assessment.
a) Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadways, bicycle and pedestrian facilities? Less than Significant Impact. The site is located within the North Beach/North El Camino Real Focus Area. With access to the Metrolink rail station, the Beach Trail, numerous bikeways and pedestrian paths, and the historic El Camino Real corridor that connects many of the City’s activity areas, the North Beach/North El Camino Real Focus Area is a key multimodal transportation hub.

Within the project vicinity, bicycle facilities and sidewalks occur along both northbound and southbound East Avenida Pico to the east, as well as eastbound and westbound North El Camino Real to the south. Bus stops serving OCTA, Metrolink, and San Clemente Trolley bus lines are provided along East Avenida Pico and North El Camino Real. The San Clemente Metrolink Station is located approximately 200 feet further south and southwest.

Under the proposed project, sidewalks along southbound East Avenida Pico eastbound North El Camino Real would be constructed at the eastern and southern boundaries of the site, respectively.

Pedestrian access is proposed in the southeastern and southwestern portions of the site along East Avenida Pico and North El Camino Real, respectively. Additionally, pedestrian pathways are proposed throughout the site to provide connectivity between hotel buildings and amenities, as well as provide connectivity to existing surrounding pedestrian facilities. The proposed public café would be fronting North El Camino Real and fully accessible by pedestrians. An elevator is also proposed in the northwest corner of the site. Vehicular access to the proposed two-level subterranean garage would be provided via a full access driveway from El Camino Real. An additional garage egress would be provided in the northeastern corner of the site.

Overall, the project would not conflict with existing pedestrian, bicycle, or transit facilities, or other aspects of the City’s circulation system. As detailed in Table 3.17-1, General Plan Mobility Element Consistency Analysis, the project would contribute improvements to the circulation system and would not conflict with a program, plan, ordinance, or policy related to transit, roadway, bicycle, and pedestrian facilities. Impacts would be less than significant in this regard.

Table 3.17-1
General Plan Mobility Element Project Consistency Analysis Relevant General Plan Policies Project Consistency Analysis M-1.06. Driveway Access Points. We require the number of driveway access points onto arterial roadways to be minimized and located to ensure the smooth and safe flow of vehicles and bicycles.

Consistent. Vehicular access to the proposed two-level
subterranean garage would be provided via a full access driveway from El Camino Real. An additional garage egress would be provided in the northeastern corner of the site. This is necessary as there are currently no driveways on site.

M-1.08. Transportation Mode Choice. We actively work to reduce automobile use and improve the efficiency of the roadways based on locally collected data and on goals set Consistent. Bus stops serving OCTA, Metrolink, and San
Clemente Trolley bus lines are provided along East Avenida Pico and North El Camino Real. The San Clemente Metrolink

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.17-4 Transportation
Relevant General Plan Policies Project Consistency Analysis through a collaborative process involving City staff, residents and other stakeholders.

Station is located approximately 200 feet further south and southwest. The project would not remove or impede access to these transit stops, and by providing a hotel development onsite, the project would allow guests and hotel employees access to alternative transportation within the mobility hub of the North Beach/North El Camino Real Focus Area as well as connection to the rest of the City. Additionally, the existing sidewalks along southbound East Avenida Pico eastbound
North El Camino Real would be constructed at the eastern and southern boundaries of the site, respectively, providing safe pedestrian access to and from the site. Further, internal pedestrian pathways and pedestrian site ingress/egress would connect to the existing bicycle facilities that occur along both northbound and southbound East Avenida Pico to the east, as well as eastbound and westbound North El Camino Real to the south. Bicycle parking spaces are also proposed in the northeastern corner of the site
M-1.12. Design Integration. City supports development that is designed and/or retrofitted to incorporate, and be efficiently served by, public transit, pedestrian and bicycle facilities.

M-2.01. Electric Vehicles. We support the use of
neighborhood- and long-range electric vehicles and identify routes and designate special parking for such Neighborhood Electric Vehicles (NEVs) at beaches and commercial
locations.

Consistent. Parking spaces would include electric vehicle (EV) charging spaces, in accordance with the City and California Green Building Code Standards (CALGreen) requirements.

M-2.02. Pedestrian Facilities. Public streets shall provide pedestrian facilities in accordance with the adopted City standards.

Consistent. Refer to the response to Policies M-1.08 and M1.12.

M-2.07. Coordinated Land Use Planning for Transit. We
encourage higher density, mixed-use development in areas with existing and planned transit service.

Consistent. The project would develop a mixed-use site
consistent with the General Plan land use designation and zoning, within the North Beach/North El Camino Real Focus Area, a key multimodal transportation hub with access to the Metrolink rail station, the Beach Trail, numerous bikeways and pedestrian paths, and the historic El Camino Real corridor that connects many of the City’s activity areas.

M-2.08. Transit Service. We support the maintenance of
existing bus service and encourage transit service
enhancements by OCTA to ensure all residents have access to adequate and safe transit.

Consistent. Refer to the response to Policies M-1.08 and M1.12.

M-2.11. Bicycle and Pedestrian Wayfinding. Bicycle and
pedestrian network wayfinding and information shall be
provided through signs, street markings or other technologies.

Consistent. . Exterior lighting is proposed on-site at building entrances, parking areas, amenity spaces, and pedestrian walkways for security and wayfinding purposes.

M-2.12. Integration of Bicycle Planning. We integrate
development of the bicycle facilities network into larger land use planning and development projects.

Consistent. Refer to the response to Policies M-1.08 and M1.12.

M-2.13. Bicycle and Pedestrian Network. We plan,
develop and maintain a comprehensive bicycle and pedestrian network as specified in the San Clemente Bicycle and
Pedestrian Master Plan.

M-2.14. Bicycle Friendly Streets. We consider every public street in San Clemente as a street that cyclists could use.

M-2.15. Bicycle-Friendly Infrastructure. We shall employ bicycle-friendly infrastructure design using new technologies

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.17-5 Transportation
Relevant General Plan Policies Project Consistency Analysis and innovative treatments, where necessary to improve
bicyclists’ safety and convenience.

M-2.18. Design Standards. We support the design
principles in the City’s Design Manual for Living Streets in determining the appropriate standard to apply to a given situation, the City will seek to maximize cyclists’ and pedestrians’ safety, comfort and convenience, in balance with other roadway users.

Consistent. The proposed sidewalk improvements along East Avenida Pico eastbound North El Camino Real would be
developed consistent with the City’s Circulation Plan, roadway functional design guidelines, and meet design guidelines included in the California Manual of Uniform Traffic Control Devices (MUTCD) and the Caltrans Roadway Design Manual.

M-2.23. Skateboarding. We encourage and support
skateboard use as an efficient and legitimate transportation mode to connect gaps between destination and transit stops and rail stations.

Consistent. Proposed pedestrian improvements open to the public would not exclude skateboarding activities.

M-2.26. Bicycle and Pedestrian Facility Design
Standards. We shall utilize the Caltrans Highway Design Manual and other infrastructure guidelines as appropriate to design and maintain bicycle and pedestrian facilities to high safety standards.

Consistent. Refer to the response to Policy M-2.18.

M-2.30. Walking and Biking Trips. We encourage city staff, employees, residents and visitors to walk and bicycle as often as possible.

Consistent. Refer to the response to Policies M-1.08 and M1.12.

M-2.31. Improvements along Bicycle and Pedestrian
Routes. We improve and maintain alternative transportation infrastructure and assign a high priority to improvements along primary pedestrian and bicycle routes to schools.

Consistent. Refer to the response to Policies M-1.08 and M1.12, as well as response to Policy 2-18.

M-2.35. American Disabilities Act. All new streets shall have provisions for the adequate and safe movement of
pedestrians, in accordance with the American Disabilities Act.

Consistent. Parking spaces would feature Americans with Disabilities Act (ADA) compliant parking spaces vanpool accessible spaces. Additionally, an elevator is also proposed in the northwest corner of the site to provide access to site amenities.

M-3.01. Connected Roadway Network. We require
development projects to connect to and where necessary, improve local streets to allow travel by all modes and ensure connectivity with the larger City-wide roadway network.

Consistent. Refer to the response to Policies M-1.08 and M1.12, as well as response to Policy 2-18.

M-3.02. Complete Streets Roadway Standards. We
require that pedestrian, vehicular, and bicycle circulation on public and private property is coordinated and designed to maximize safety, comfort and aesthetics and is consistent with Federal, State, Orange County, and local laws, codes, and standards.

Source: City of San Clemente, Centennial General Plan, adopted February 2014, amended January 2026. b) Conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b)? Less than Significant Impact. According to the VMT Screening Memo, the project would result in approximately 1,631 daily trips based on the proposed land use. As the project would be consistent with the site’s land use designation and zoning, this trip generation was included in the LOS analysis within the General Plan EIR, which was determined to result in significant and unavoidable impacts.

As the City has not adopted VMT guidelines, the VMT Screening Memo utilized the Orange County Guidelines for Evaluating VMT Under CEQA (County Guidelines) and the Governor’s Office of

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.17-6 Transportation
Planning and Research (OPR) Technical Advisory (TA) on Evaluating Transportation Impacts for CEQA for the VMT assessment. Per OPR’s Technical Advisory, residential, retail, office projects, or projects that have a mix of those uses whose project site boundaries are within 0.5-mile of an existing major transit stop, planned major transit stop, or a stop/transit center along a high-quality transit corridor would normally be presumed to have a less than significant transportation impact. Unless the project is inconsistent with the Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), has a floor area ratio (FAR) less than 0.75, provides an excessive amount of parking, or reduces the number of affordable residential units, the project would be considered less than significant. As detailed in the VMT Screening Memo, the project is located within 0.5-mile of an existing major transit stop, has an FAR of 0.937, is consistent with the RTP/SCS, does not provide an excessive amount of parking, and does not reduce the number of affordable residential units.

Therefore, the project is presumed to result in a less than significant transportation impact under CEQA and a detailed VMT analysis is not required. Accordingly, the project would not conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b), and impacts would be less than significant.

PROJECT TRIP GENERATION
As detailed in Table 3.17-1, Project Trip Generation, the project is forecast to generate 1,631 average daily vehicle trips. This trip generation estimate is considered highly conservative since no trip internalization credits nor passby trip reductions have been applied to the trip generation, despite the project being within a Transit Priority Area (TPA) and proposing a San Clemente Trolley stop in front of the hotel..

Table 3.17-1
Project Trip Generation
Land Use Units Average Daily
Trips
AM Peak Hour Trips PM Peak Hour Trips
Total In / Out Total In / Out
Hotel (ITE
Code 310) Rooms 487 28 16 / 12 36 18 / 18
Fine Dining
(ITE Code 310) ksf 213 2 2 / 0 20 13 / 7
Café (ITE
Code 310) ksf 931 27 14 / 13 9 5 / 4
Total Trip Generation 1,631 57 32 / 25 65 36 / 29
Source: Fehr & Peersl, The Hansen Hotel Focused Transportation Study, dated January 17, 2025; refer to Appendix H.1, Focused Transportation Study.

Although level of service (LOS) is no longer considered an environmental impact for the purpose of CEQA considerations, a comparison is provided for informational purposes. Per City guidelines, LOS D is identified as the performance threshold for the Project. Based on the Focused Transportation Study, all study intersections are forecast to operate acceptably with and without the addition of the project’s traffic. Therefore, no infrastructure improvements are recommended with the project.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.17-7 Transportation
c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? Less than Significant Impact With General Plan EIR Mitigation and/or COAs. Project-related construction or operation would not require the construction of new roadways. Vehicular access to the proposed two-level subterranean garage would be provided via a full access driveway from El Camino Real. An additional garage egress is provided in the northeastern corner of the site. These improvements would not increase hazards as the ingress/egress points would conform to the Circulation Plan, roadway functional design guidelines, and meet design guidelines included in the MUTCD and the Caltrans Roadway Design Manual consistent with General Plan Policies M-3.01 and M-3.02 (COAs 3.20 and 3.21). Therefore, impacts related to sharp curves or dangerous intersections would not occur. Thus, the project would be compatible with existing and planned land uses in the surrounding area and would not substantially increase safety hazards due to incompatible uses. Project impacts related to geometric hazards during operation would be less than significant.

Applicable Conditions of Approval (COAs):

Landscaping in this area should be maintained to sidewalk. (Municipal Code Chapter

15.36). See Figure 1: Circulation and Line of Sight
d) Result in inadequate emergency access?

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.17-8 Transportation
Less than Significant Impact With General Plan EIR Mitigation and/or COAs. Construction activity would occur on the project site and within roadway right-of-way. Therefore, the project may result in temporary obstructions to adjacent sidewalks and travel lanes, which could impact vehicle movement or emergency access. Construction activities would be conducted in compliance with applicable City requirements, and temporary traffic control measures would be implemented in accordance with the MUTCD. This includes coordination and accommodation of the needs of emergency service providers. Thus, impacts related to emergency access would be less than significant.

Along project frontage at N. El Camino Real, a proposed 10 feet by 50 feet turnout area would allow for emergency vehicle access. On-site emergency access would be required to comply with applicable codes, ordinances, and standard conditions, including the current edition of the California Fire Code, and would meet the City’s width and turnaround requirements to provide adequate emergency access (COAs 3.20 and 3.21). The City’s Fire Department reviews project plans to confirm that adequate internal street widths and turning radii are provided. During the City’s review of the proposed project, the City would confirm that the project would provide adequate access to-and-from the project site for emergency vehicles. The City would also confirm the layout of the project’s proposed structures and drive aisles are sufficient to provide adequate on-site circulation for emergency vehicles. Further, the project would be consistent with applicable policies contained in the General Plan Safety Element.

The project does not propose changes to the City’s circulation system; as such, project operation would not impact emergency access. The project's proposed on-site circulation network would be consistent with City standards for emergency access and circulation.

While project construction activities occurring adjacent to N. El Camino Real and E. Avenida Pico (e.g., driveway improvements and utility connections) may require a partial lane closure along such roadways. Any such closure would be short-term in nature and traffic in both directions would be maintained at all times. Thus, impacts in this regard would be less than significant. Overall, project implementation is not anticipated to result in inadequate emergency access, and impacts would be less than significant.

Applicable Conditions of Approval (COAs): Refer to COAs 3.20 and 3.21.

March 2026 3.18-1 Tribal Cultural Resources

3.18 TRIBAL CULTURAL RESOURCES

3.18.1 General Plan Update EIR Summary
Less Than Significant Impact. The General Plan EIR was prepared and adopted in 2014, a year before the adoption of AB 52 in 2015. As such, impacts to tribal cultural resources were not evaluated in the General Plan EIR. Although the General Plan Update EIR did not analyze tribal cultural resources as a standalone topical area, tribal cultural resources impacts associated with the General Plan were analyzed in General Plan EIR. The summary of the General Plan EIR findings are provided in Section 3.5.1. According to the General Plan EIR, buildout of the General Plan could impact an identified or unidentified historic resources, which included consideration of historic tribal cultural resources. Policy HP-2.03 requires mitigation of significant, adverse impacts to onsite and nearby historic resources as part of applications for general plan amendments, zoning changes, or any projects requiring environmental review. Consistent with CEQA Guidelines, Policy HP-2.05 ensures projects follow the Secretary of Interior Standards for the Treatment of Historic Properties and standards and guidelines prescribed by the State Office of Historic Preservation for any listed historic resources or properties eligible for historic listing. The Municipal Code Section 17.16.170 identifies specific procedures and CEQA findings required prior to disturbance of historical resources listed on or eligible for listing in the California Register of Historic Resources. As such, the General Plan EIR determined that compliance with General Plan polices, Municipal Code, and State and federal regulations restricting alteration of historical resources would ensure impacts in this regard would be less than significant.

In addition to historical considerations, the General Plan EIR consulted tribes for the purpose of Senate Bill 18 (SB 18) and the cultural resources analysis of the General Plan EIR. The General Plan EIR found that in the event of an unanticipated discovery of archaeological resources during grading and excavation of the site, a qualified archaeologist would assess the find and develop a course of action to preserve the find, as indicated in Mitigation Measure 4-1. Further, existing federal, State, and local regulations would address the following: the provision of studies to identify archaeological resources; application review for projects that would potentially involve land disturbance; project-level standard conditions of approval that address unanticipated archaeological discoveries; and requirements to develop specific mitigation measures if resources are encountered during any development activity. Overall, with implementation of mitigation measures and compliance with applicable regulations, impacts would be reduced to less than significant.

Ground disturbance by projects developed pursuant to the proposed General Plan could disturb these remains. California Health and Safety Code Section 7050.5 requires that if human remains are discovered within the project site, disturbance of the site shall halt and remain halted until the coroner has conducted an investigation and made recommendations to the person responsible for the excavation, or to his or her authorized representative. If the coroner determines that the remains are not subject to his or her authority and if the coroner recognizes or has reason to believe the human remains to be those of a Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission. Public Resources Code Section 5097.98, mandates the process to be followed in the event of a discovery of any human remains and would mitigate all potential impacts. As such, impacts would be less than significant.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.18-2 Tribal Cultural Resources

3.18.2 Project-Specific Impacts
Would the project:

This analysis is supplemented with the site-specific Cultural And Paleontological Resources Identification Memorandum for the Hanson Hotel CEQA Review Project, City of San Clemente, Orange County, California (Cultural and Paleontological Resources Memo), dated January 29, 2026 by Michael Baker International, prepared for the project; refer to Appendix D.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.18-3 Tribal Cultural Resources
a) Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:

1) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k), or
2) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

Less than Significant Impact With General Plan EIR Mitigation and/or COAs. With respect to tribal consultation for the proposed project, AB 52 states that prior to the release of a negative declaration, mitigated negative declaration, or environmental impact report for a project, a lead agency shall begin consultation with a California Native American tribe that is traditionally and culturally affiliated with the geographic area of the proposed project, if the tribe requested to the lead agency, in writing, to be informed by the lead agency of proposed projects in that geographic area and the tribe requests consultation. As this environmental document (i.e., a CEQA Guidelines Section 15183 Compliance Checklist) is not a Negative Declaration, Mitigated Negative Declaration, or Environmental Impact Report, AB 52 consultation would not apply to the proposed project.

As discussed in Response 3.5(a), the project site does not contain any known historical resources as defined by Section 15064.5 of the CEQA Guidelines. Impacts in this regard would be less than significant.

The Cultural and Paleontological Resources Memo indicates that the project site, given its proximity to riverine, coastal, and estuary resources, would be expected to have been heavily utilized by local Native Americans, and the project site is considered to have a moderate sensitivity for cultural resources. Therefore, the proposed project could result in impacts to previously-unknown tribal cultural resources that may be buried beneath the project site’s surface. As detailed in Response

3.5.2(a), the project would be subject to General Plan EIR Mitigation Measure 4-1 (enforced through COA CUL-1), which would require a qualified archaeologist to be retained in the event that any subsurface cultural resources are encountered during earth-moving activities. Construction activity within 50 feet of the find would be required to halt, and the qualified archaeologist would evaluate the finds and make recommendations. If human remains are encountered during any construction activities, existing regulations (enforced through COA CUL-2) would require excavation to stop in the vicinity of the find and any area that is reasonably suspected to overlie adjacent remains until the County coroner has been called out, and the remains have been investigated and appropriate recommendations have been made for the treatment and disposition of the remains in accordance with State of California Health and Safety Code Sections 7050.5-7055. Specifically, Health and Safety

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.18-4 Tribal Cultural Resources
Code Section 7050.5 describes the requirements if any human remains are discovered during excavation of a site. As required by state law, the requirements and procedures set forth in Section 5097.98 of the California Public Resources Code would be implemented, including notification of the County coroner, notification of the Native American Heritage Commission, and consultation with the individual identified by the Native American Heritage Commission to be the “most likely descendant.” Accordingly, and consistent with the findings of the General Plan EIR, with implementation of General Plan EIR Mitigation Measure 4-1 (enforced through COA CUL-1) and compliance with existing regulations in regard to human remains (enforced through COA CUL-2), project impacts to previously-unknown tribal cultural resources would be reduced to less than significant levels.

Applicable General Plan EIR Mitigation Measures: Refer to Response 3.5.2, General Plan EIR Mitigation Measures 4-1 and 4-2.

Applicable Conditions of Approval (COA): Refer to Response 3.5.2, COAs CUL-1 and CUL-2.

March 2026 3.19-1 Utilities and Services Systems

3.19 UTILITIES AND SERVICE SYSTEMS

3.19.1 General Plan Update EIR Summary
Less Than Significant Impact.

WATER UTILITIES
City residents and businesses are serviced by three water districts: San Clemente Water District (City Water District), Santa Margarita Water District (SMWD), and South Coast Water District (SCWD).

The City Water District receives its water from three main sources: groundwater from the City’s wells, recycled water from treated wastewater, and imported water from the Municipal Water District of Orange County (MWDOC), which is a member agency of the Metropolitan Water District of Southern California (MWD).

For the City Water District, the General Plan determined that the City’s projected supplies exceed demands and are sufficient to accommodate the demands of forecasted population increase under the General Plan. Further, water demands due to General Plan buildout would not deplete groundwater supplies in the San Clemente Sub-Basin because the City Water District has existing and planned water supplies that are adequate even with a large increase in water demands, while General Plan buildout is forecast to increase City Water District water demands by a small fraction; and because planned groundwater production in the Sub-Basin by 2015 would still be below the safe pumping yield. As such, project impacts to City Water District would be less than significant.

For SMWD, as no land use changes are proposed in SMWD’s service area under the General Plan, buildout of the proposed Centennial General Plan would have no impact on SMWD’s water supply and delivery systems.

For SCWD, the SCWD 2010 UWMP states that available imported supply is greater than shown, and SCWD is capable of providing its customers all their demands with significant reserves in multiple dry years from 2015 through 2035. Water demands due to General Plan implementation would not deplete groundwater supplies in the San Juan Groundwater Basin because: 1), such water demands within SCWD’s service area would account for only 0.3 percent of total forecast 2035 SCWD water demands; 2) SCWD expects to have imported water supplies adequate for its total water demands through the 2015-2035 period; and 3) SCWD would need approval from the San Juan Basin Authority and the State Water Resources Control Board before carrying out its planned expansion of groundwater production from the San Juan Basin. Therefore, impacts to SCWD’s water supply and delivery systems would be less than significant.

WASTEWATER FACILITIES
The General Plan EIR determined that impacts to the wastewater treatment providers are less than significant as the City confirmed there is sufficient capacity to accommodate the increase in sewer demand Citywide and for each Focus Area, and no major improvements are required. Further, the Water Reclamation Plant owned and operated by the City is also slated for a significant expansion to increase recycled water production up to 4.4 MGD by 2015. Therefore, no new major sewer upgrades are anticipated or recommended for the General Plan land use changes. Impact would be less than significant.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.19-2 Utilities and Services Systems

STORMWATER FACILITIES
The General Plan EIR determined that proposed runoff rates under buildout of the General Plan remain essentially unchanged as compared to existing conditions due to the built out condition of the City and each Focus Area. No new storm water drainage facilities are anticipated with the General Plan. Impacts are less than significant.

DRY UTILITIES
The General Plan EIR acknowledged that implementation of the General Plan would result in increased natural gas and electricity use within the City, thereby increasing the demand for energy services. In regard to natural gas, natural gas service for future development will be added to the existing system by the San Diego Gas & Electric (SDG&E) and Southern California Gas (SCG) as necessary to meet the requirements of individual development projects within the project area. The utility companies have indicated that they will be able to supply the area with natural gas without impacting existing service. As such, the General Plan EIR determined that total cumulative demand, including growth in the surrounding areas, does not represent a significant impact to the energy service because of the substantial amount of reserves available.

Such impacts would be evaluated on a project-by-project basis.

The General Plan EIR identified that growth in the City under buildout of the General Plan would necessitate the construction or expansion of communication facilities; however, installation of communication infrastructure is implemented by private companies who base service needs on customer demand. The City of San Clemente has purview over design review and is required to approve new private infrastructure facilities prior to their placement, as regulated by the California Public Utilities Commission. Impact would be less than significant.

WATER SUPPLIES
For the City Water District, the General Plan EIR determined that the City’s projected supplies exceed demands and are sufficient to accommodate the demands of forecasted population increase under the General Plan. Further, water demands due to General Plan buildout would not deplete groundwater supplies in the San Clemente Sub-Basin because the City Water District has existing and planned water supplies that are adequate even with a large increase in water demands, while General Plan buildout is forecast to increase City Water District water demands by a small fraction; and because planned

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.19-3 Utilities and Services Systems
groundwater production in the Sub-Basin by 2015 would still be below the safe pumping yield. As such, project impacts to City Water District would be less than significant.

For SMWD, as no land use changes are proposed in SMWD’s service area under the General Plan, the General Plan EIR determined that buildout of the General Plan would have no impact on SMWD’s water supply and delivery systems.

In regard to long term reliability, the General Plan EIR notes that MWD’s 2010 Regional Urban Water Management Plan (2010 UWMP) shows that the region can provide reliable water supplies not only under normal conditions but also under both the single driest year and the multiple dry year hydrologies.

WASTEWATER TREATMENT CAPACITIES
The General Plan EIR determined that impacts to the wastewater treatment providers are less than significant as the City confirmed there is sufficient capacity to accommodate the increase in sewer demand Citywide and for each Focus Area, and no major improvements are required. Further, the Water Reclamation Plant owned and operated by the City is also slated for a significant expansion to increase recycled water production up to 4.4 MGD by 2015. Therefore, no new major sewer upgrades are anticipated or recommended for the Centennial General Plan land use changes. Impact would be less than significant.

SOLID WASTE CAPACITIES AND REGULATIONS
The General Plan EIR assumed that adequate capacity for the proposed project is available for the foreseeable future based on Orange County’s Countywide Integrated Waste Management Plan (CIWMP). Furthermore, the City of San Clemente has actively pursued programs to comply with federal, State, and local regulations related to solid waste and facilities to minimize impacts from project-generated solid waste. Therefore, impacts are considered less than significant.

As detailed in the General Plan EIR, the CalRecycle requires that all counties have an approved Countywide Integrated Waste Management Plan (CIWMP). To be approved, the CIWMP must demonstrate sufficient solid waste disposal capacity for at least 15 years, or identify additional available capacity outside of the county’s jurisdiction. Orange County’s CIWMP, approved in 1996, contains

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.19-4 Utilities and Services Systems
future solid waste disposal demand based on the County population projections previously adopted by the Board of Supervisors. The Orange County landfill system has capacity in excess of 15 years.

The Orange County IWMB has also prepared a Regional Landfill Options for Orange County, a 40- year strategic plan to evaluate options for waste disposal for Orange County. Therefore, it may be assumed that adequate capacity for the proposed project is available for the foreseeable future.

Furthermore, the City of San Clemente has actively pursued programs to comply with federal, State, and local regulations related to solid waste and facilities to minimize impacts from project-generated solid waste. Therefore, impacts are considered less than significant.

3.19.2 Project-Specific Impacts
Would the project:

New
Potentially
Significant
Impact or
Increased
Significant
Impact
Significant
Impact
Already
Identified in
the General
Plan EIR
Less Than
Significant
Impact
With
General
Plan EIR
Mitigation
and/or
COAs
Less Than
Significant
Impact
No
Impact
a. Require or result in the relocation or construction of new or expanded water, or wastewater treatment or storm water
drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?

b. Have sufficient water supplies available to serve the project and reasonably foreseeable future development during
normal, dry and multiple dry years?

c. Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?

d. Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?

e. Comply with Federal, State, and local management and reduction statutes and regulations related to solid waste?  a) Require or result in the relocation or construction of new or expanded water, wastewater treatment, or storm water drainage, electric power, natural gas, or telecommunication facilities, the construction or relocation of which could cause significant environmental effects?
Less than Significant Impact With General Plan EIR Mitigation and/or COAs. The proposed project is located in an urban area and municipal and private utility services necessary to serve the project are currently available adjacent to the project site. On-site utility infrastructure necessary to

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.19-5 Utilities and Services Systems
serve the project, including water, sanitary sewer, storm drain, and dry utilities (i.e., electrical, natural gas, and telecommunications), would be installed on-site as part of the proposed development and appropriate connections would be made to the existing utilities. The final sizing and design of on-site facilities would occur during the final project design. As detailed throughout, the proposed project is consistent with the site’s General Plan land use designation and, thus, was contemplated as part of the buildout of the General Plan. As such, project’s impacts to utility infrastructure have already been considered in the General Plan EIR, and any infrastructure upgrade required would have been planned by applicable service providers. Construction and connection of proposed water, sanitary sewer, drainage, and dry utilities would be subject to compliance with all applicable local, State, and federal laws, ordinances, and regulations and uniform standards (COAs 4.10, 4.11, 4.12, and 4.13). Thus, impacts associated with the project’s infrastructure improvements would be less than significant.

Applicable Conditions of Approval (COAs):

4.11 The Applicant shall submit, and must obtain approval from the City Engineer, plans depicting the installation of an approved double-detector check backflow assembly on any/all fire lines above ground and as near to the point of connection to the potable water system as practical, given functional and aesthetic considerations. An isolation valve shall be installed on any/all fire lines at the point of connection to the water main. (Municipal Code Section 13.04.350)

4.13 Prior to the issuance of building permits, the architectural, civil (if applicable), and landscape plans shall be revised to incorporate all modifications directed at the Planning Commission hearing to address Orange County Fire Authority (OCFA) requirements. Specifically, the project design shall provide a minimum three-foot setback around the perimeter of the structure, consistent with OCFA standards. b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years?

Less than Significant Impact. The project site is served by the City Water District. According to the General Plan EIR Table 5-15-1, City of San Clemente UWMP Projected Normal Year Water Supply and Demand (afy), and Table 5-15-2, City of San Clemente UWMP Projected Multiple Dry Year Water Supply and Demand (afy), the City Water District would be capable of providing adequate water supply to its service

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.19-6 Utilities and Services Systems
area under a normal supply and demand scenario, single dry-year supply and demand scenario, and multiple dry-year supply and demand scenarios through 2035. The water supply predictions are based on existing General Plan designations and account for increased demand as growth within the City occurs. As detailed throughout, the proposed project is consistent with the site’s General Plan land use designation and thus, was contemplated as part of the buildout of the General Plan. Further, as detailed in Section 3.14, the project would not result in a population increase above what was analyzed in the General Plan EIR. Thus, construction of the proposed project was already contemplated in the UWMP and sufficient water supplies would be available to serve the project and reasonably foreseeable future development under the project during normal, dry, and multiple dry years. Project impacts related to water supply would be less than significant.

c) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?

Less than Significant Impact. As detailed throughout, the proposed project is consistent with the site’s General Plan land use designation and thus, was contemplated as part of the buildout of the General Plan. Further, as detailed in Section 3.14, the project would not result in significant population increase. Thus, buildout of the proposed project site was already contemplated in the UWMP and sufficient wastewater treatment capacity remained to serve the project’s projected demand. Project impacts related to wastewater treatment capacity would be less than significant.

d) Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?

Less than Significant Impact. According to the General Plan EIR, majority of solid waste in the City is transferred to the Prima Deshecha Sanitary Landfill in the City of San Juan Capistrano. This landfill serves the majority of the City and can accept up to 4,000 tons of waste per day (tpd), a remaining capacity of 132,600,000 cubic yard, and an anticipated closure date of 2067.

Based on the project’s air quality and greenhouse gas modeling, project operations are expected to generate approximately 53.9 tons of solid waste per year, or 8.0 tons of waste per day; refer to Appendix B, Air Quality/GHG/Energy Data. Project-generated solid waste represents approximately

0.002 percent of Prima Deshecha Sanitary Landfill’s maximum permitted throughput per day; and thus, the project is not anticipated to generate solid waste in excess of State or local standards.

Additionally, the existing solid waste facilities would have ample capacity to accommodate increased volumes of waste from the City through 2045. Overall, impacts would be less than significant. e) Comply with federal, State, and local management and reduction statutes and regulations related to solid waste?
Less than Significant Impact. All construction activities would be subject to conformance with relevant federal, State, and local requirements related to solid waste disposal. Specifically, per Municipal Code Section 8.69.025, Minimum Construction and Demolition Debris Diversion Requirements, the

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.19-7 Utilities and Services Systems
project should reuse, recycle, or divert the minimum percentage of construction and demolition (C&D) debris generated by the project at a minimum rate of 75 percent. Further, per Municipal Code

8.69.040, Submission of Waste Management Plan, the project Applicant should complete and submit a Waste Management Plan that details: 1) the estimated volume or weight of project C&D debris, by materials type, to be generated; 2) the maximum volume or weight of such C&D materials that can feasibly be diverted via reuse and/or recycling; 3) the vendor or facility that the applicant proposes to use to collect or receive that C&D material; and 4) the estimated volume or weight of C&D materials that will be landfilled. In conformance with the Municipal Code, the project Applicant is required to work with future contract waste haulers for implementation.

During project operation, the project would be required to comply with Senate Bill 1383 (SB 1383) and Assembly Bill 1826 (AB 1826). SB 1383 requires everyone (commercial businesses and residential properties) across the State to participate in source-separated recycling. As required by state regulation SB 1383, the City adopted Local Ordinance 1728 on April 5, 2022, which provides enforcement and fines for non-participating entities. Every business in San Clemente must participate in recycling and organics programs. The California Legislature passed AB 1826 in September 2014. This law requires all businesses that generate two cubic yards or more of commercial solid waste (trash) per week to enroll in a program to recycle organic waste rather than send it to the landfill. Organic waste includes grass trimmings, yard waste, food waste, vegetable trimmings, plate scrapings, spoiled food, and excess food inventory. Overall, the project would comply with applicable solid waste regulations and impacts would be less than significant in this regard.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.19-8 Utilities and Services Systems
This page intentionally left blank.

March 2026 3.20-1 Wildfire

3.20 WILDFIRE

3.20.1 General Plan Update EIR Summary
Less Than Significant Impact. Figure 5.7-1, Wildfire Hazard Zones, of the General Plan EIR identifies parts of the City that are in Very High Fire Hazard Severity Zones (VHFHSZ) designated by the California Department of Forestry and Fire Prevention (CAL FIRE). These VHFHSZs are in Local Responsibility Areas (LRAs), meaning that the Orange County Fire Authority (OCFA) and the City are financially responsible for fire suppression in those areas. All of the City’s Sphere of Influence (SOI) is in a VHFHSZ designated by CAL FIRE as a State Responsibility Area (SRA), where the State bears the cost of suppressing wildfire. While buildout of the General Plan would primarily consist of infill development, the General Plan EIR found that land use changes and redevelopment could expose people or structures to heightened risks related to wildfires, potentially resulting in significant impacts. As such, all future development would be required to incorporate site-specific recommendations from the OCFA Fire Chief, as applicable, submit a fuel modification, if applicable, and implement General Plan Safety Element Policy S-3.01, which would require coordination with OCFA to minimize adverse effects of fires, wildfires and related hazards like erosion, hazardous materials release, and structural collapse through compliance with the City’s building and fire codes.

While Wildfire was not analyzed independently in the General Plan EIR, the General Plan EIR determined that adherence to the above regulatory requirements would reduce impacts related to wildfire; additionally, the General Plan EIR found that buildout of the General Plan would not result in significant impacts related to emergency response, conflicts with an evacuation plan, or fire protection services. Overall, impacts regarding wildfire were found to be less than significant.

3.20.2 Project-Specific Impacts
If located in or near State responsibility areas or lands classified as very high fire hazard severity zones, would the project:

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 3.20-2 Wildfire
If located in or near State responsibility areas or lands classified as very high fire hazard severity zones, would the project:

New
Potentially
Significant
Impact or
Increased
Significant
Impact
Significant
Impact
Already
Identified
in the
General
Plan EIR
Less Than
Significant
Impact
With
General
Plan EIR
Mitigation
and/or
COAs
Less Than
Significant
Impact
No
Impact
landslides, as a result of runoff, post-fire slope
instability, or drainage changes?
a) Substantially impair an adopted emergency response plan or emergency evacuation plan?
No Impact. The project site is not located in a VHFHSZ within an SRA.27 As such, the project site would not be subject to wildfire hazards or require installation or maintenance of wildfire associated infrastructure. The proposed project would also not substantially impair an adopted emergency response plan or emergency evacuation plan. Nonetheless, the project would coordinate with OCFA and comply with all applicable building and fire codes in order to minimize wildfire risks, per General Plan Safety Element Policy S-3.01. Overall, impacts from the project related to wildfire would be less than significant.
b) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
No Impact. Refer to Response 3.20.2(a). No impact would occur in this regard.

c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
No Impact. Refer to Response 3.20.2(a). No impact would occur in this regard.

d) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?
No Impact. Refer to Response 3.20.2(a). No impact would occur in this regard. 27 CAL FIRE, Fire Hazard Severity Zones,
https://experience.arcgis.com/experience/5065c998b4b0462f9ec3c6c226c610a9, accessed January 29, 2026.

March 2026 4-1 Determination

4.0 DETERMINATION
Based on the analysis contained in this CEQA Guidelines Section 15183 Initial Study, the proposed project is consistent with the development density established by the General Plan for which an EIR (i.e., the General Plan EIR) was certified. Impacts related to the proposed project were analyzed in the General Plan EIR. The project would not result in any impacts that are peculiar to the project or project site upon implementation of General Plan EIR Mitigation Measures and/or uniform policies or standards. No new project specific impacts were determined to be potentially significant that were not already identified as a significant impact under the General Plan EIR. The project would not result in any increased severity of previously identified significant impacts due to substantial new information that was not known at the time of the General Plan EIR. No potentially significant off-site impacts or cumulatively considerable project-specific impacts were identified that were not already disclosed in the General Plan EIR.

Therefore, pursuant to Public Resources Code Section 21083.3 and CEQA Guidelines Section 15183, no further environmental review is required.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 4-2 Determination
This page intentionally left blank.

March 2026 5-1 References

5.0 REFERENCES
CAL FIRE, Fire Hazard Severity Zones,
https://experience.arcgis.com/experience/5065c998b4b0462f9ec3c6c226c610a9, accessed January 20, 2026.

California Department of Conservation Geologic Energy Management Division, WellSTAR, https://maps.conservation.ca.gov/CalGEM/wellfinder/, accessed January 20, 2026.

California Department of Conservation, California Important Farmland Finder, https://maps.conservation.ca.gov/dlrp/ciff/, accessed January 21, 2026.

California Department of Conservation, Williamson Act Enrollment Finder, https://maps.conservation.ca.gov/dlrp/WilliamsonAct/App/?print_preview=true, accessed January 21, 2026.

California Department of Transportation, Statewide Scenic Highway [Map], https://experience.arcgis.com/experience/47e2009986264718a5a13a2c81382774, accessed January 20, 2026.

California Environmental Protection Agency, Cortese List Data Resources, https://calepa.ca.gov/SiteCleanup/ CorteseList/, accessed on December 2, 2025.

City of San Clemente, Centennial General Plan, General Plan Land Use Map, amended October 18, 2022.

City of San Clemente, Centennial General Plan, Table LU-1, General Plan Land Use Designations Summary Table, adopted February 2014, amended October 2022.

Federal Emergency Management Agency, Flood Insurance Rate Map #06059C0517K, March 21, 2019.

Google, Google Earth, accessed January 20, 2026.

Michael Baker International, Biological Resources Assessment for the Hanson Hotel Project in San Clemente, Orange County, California, March 12, 2026.

Michael Baker International, San Clemente 1801 N. El Camino Real – VMT Screening Assessment, Technical Memorandum, February 2, 2026.

Michael Baker International, Cultural and Paleontological Resources Identification Memorandum for the Hanson Hotel CEQA Review Project, City of San Clemente, Orange County, California, January 29, 2026.

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 5-2 References
State Water Resources Control Board, GeoTracker,
https://geotracker.waterboards.ca.gov/map/?global_id=T0605902536, accessed January 20, 2025.

San Juan Basin Authority, Programs, https://www.sjbauthority.com/programs.html, accessed February 5, 2026.

San Juan Basin Authority, San Juan Basin Groundwater and Facilities Management Plan, November 2013.

Toal Engineering, Inc., Preliminary Water Quality Management Plan, April 10, 2025.

March 2026 6-1 Report Preparation Personnel

6.0 REPORT PREPARATION PERSONNEL

LEAD AGENCY

CITY OF SAN CLEMENTE
Community Development Department
910 Calle Negocio
San Clemente, CA 92673
Adam Atamian, Community Development Director
Jonathan Lightfoot, City Planner
Johnathan Ciampa, Planner

ENVIRONMENTAL CONSULTANTS

MICHAEL BAKER INTERNATIONAL
5 Hutton Centre Drive, Suite 500
Santa Ana, California 92707
949.472.3505
Kristen Bogue, Project Manager
Allison Beauregard, Environmental Analyst
Winnie Woo, Environmental Analyst
Frances Yau, Senior Environmental Analyst
Eddie Torres, Technical Manager
Darshan Shivaiah, Technical Specialist
Jeanette Cappiello, Graphic Artist
Paige Kohler, MA, RPA, Senior Archaeologist
Susan Wood, PhD, Senior Architectural Historian
Jordan Gray, Senior Transportation Planner
Ryan Winkleman, Senior Biologist

HANSON HOTEL PROJECT
CEQA Guidelines Section 15183 Initial Study
March 2026 6-2 Report Preparation Personnel
This page intentionally left blank.

APPENDIX B
Air Quality/GHG/Energy Data
This document is designed for double-sided printing to conserve natural resources.

The Hansen Hotel Detailed Report, 2/24/2026
1 / 79
The Hansen Hotel Detailed Report
Table of Contents

1. Basic Project Information

1.1. Basic Project Information

1.2. Land Use Types

1.3. User-Selected Emission Reduction Measures by Emissions Sector

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds

2.2. Construction Emissions by Year, Unmitigated

2.3. Construction Emissions by Year, Mitigated

2.4. Operations Emissions Compared Against Thresholds

2.5. Operations Emissions by Sector, Unmitigated

2.6. Operations Emissions by Sector, Mitigated

3. Construction Emissions Details

3.1. Grading (2026) - Unmitigated

3.2. Grading (2026) - Mitigated

3.3. Building Construction (2026) - Unmitigated
The Hansen Hotel Detailed Report, 2/24/2026
2 / 79

3.4. Building Construction (2026) - Mitigated

3.5. Building Construction (2027) - Unmitigated

3.6. Building Construction (2027) - Mitigated

3.7. Paving (2027) - Unmitigated

3.8. Paving (2027) - Mitigated

3.9. Architectural Coating (2027) - Unmitigated

3.10. Architectural Coating (2027) - Mitigated

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated

4.1.2. Mitigated

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated

4.2.2. Electricity Emissions By Land Use - Mitigated

4.2.3. Natural Gas Emissions By Land Use - Unmitigated

4.2.4. Natural Gas Emissions By Land Use - Mitigated

4.3. Area Emissions by Source

4.3.1. Unmitigated
The Hansen Hotel Detailed Report, 2/24/2026
3 / 79

4.3.2. Mitigated

4.4. Water Emissions by Land Use

4.4.1. Unmitigated

4.4.2. Mitigated

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated

4.5.2. Mitigated

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated

4.6.2. Mitigated

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated

4.7.2. Mitigated

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated

4.8.2. Mitigated

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated
The Hansen Hotel Detailed Report, 2/24/2026
4 / 79

4.9.2. Mitigated

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated

4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated

4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated

4.10.6. Avoided and Sequestered Emissions by Species - Mitigated

5. Activity Data

5.1. Construction Schedule

5.2. Off-Road Equipment

5.2.1. Unmitigated

5.2.2. Mitigated

5.3. Construction Vehicles

5.3.1. Unmitigated

5.3.2. Mitigated

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies
The Hansen Hotel Detailed Report, 2/24/2026
5 / 79

5.5. Architectural Coatings

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities

5.6.2. Construction Earthmoving Control Strategies

5.7. Construction Paving

5.8. Construction Electricity Consumption and Emissions Factors

5.9. Operational Mobile Sources

5.9.1. Unmitigated

5.9.2. Mitigated

5.10. Operational Area Sources

5.10.1. Hearths

5.10.2. Architectural Coatings

5.10.3. Landscape Equipment

5.10.4. Landscape Equipment - Mitigated

5.11. Operational Energy Consumption

5.11.1. Unmitigated

5.11.2. Mitigated

5.12. Operational Water and Wastewater Consumption
The Hansen Hotel Detailed Report, 2/24/2026
6 / 79

5.12.1. Unmitigated

5.12.2. Mitigated

5.13. Operational Waste Generation

5.13.1. Unmitigated

5.13.2. Mitigated

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated

5.14.2. Mitigated

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated

5.15.2. Mitigated

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps

5.16.2. Process Boilers

5.17. User Defined

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated
The Hansen Hotel Detailed Report, 2/24/2026
7 / 79

5.18.1.2. Mitigated

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated

5.18.1.2. Mitigated

5.18.2. Sequestration

5.18.2.1. Unmitigated

5.18.2.2. Mitigated

6. Climate Risk Detailed Report

6.1. Climate Risk Summary

6.2. Initial Climate Risk Scores

6.3. Adjusted Climate Risk Scores

6.4. Climate Risk Reduction Measures

7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores

7.2. Healthy Places Index Scores

7.3. Overall Health & Equity Scores

7.4. Health & Equity Measures

7.5. Evaluation Scorecard
The Hansen Hotel Detailed Report, 2/24/2026
8 / 79

7.6. Health & Equity Custom Measures

8. User Changes to Default Data

8.1. Justifications

8.3. Land Use

8.4. Construction

8.4.1. Construction Phases

8.5. Operations

8.5.1. Mobile Sources

8.5.1.1. Vehicle Data
The Hansen Hotel Detailed Report, 2/24/2026
9 / 79

1. Basic Project Information

1.1. Basic Project Information
Data Field Value
Project Name The Hansen Hotel
Construction Start Date 6/1/2026
Operational Year 2027
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 1.80000
Precipitation (days) 0.20000
Location 33.433361926132676, -117.63191110101543
County Orange
City San Clemente
Air District South Coast AQMD
Air Basin South Coast
TAZ 6003
EDFZ 12
Electric Utility San Diego Gas & Electric
Gas Utility Southern California Gas
App Version 2022.1.1.37

1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft)
Special Landscape
Area (sq ft)
Population Description
Hotel 61.0000 Room 0.80000 28,308.0 2,000.00 — — —
The Hansen Hotel Detailed Report, 2/24/2026
10 / 79
Enclosed Parking
with Elevator
104.000 Space 0.00000 42,275.0 1,000.000 — — —
High Turnover (Sit
Down Restaurant)

1.72600 1000sqft 0.00000 1,726.00 500.000 — — —

1.3. User-Selected Emission Reduction Measures by Emissions Sector Sector # Measure Title
Construction C-10-A Water Exposed Surfaces
Construction C-10-C Water Unpaved Construction Roads
Construction C-11 Limit Vehicle Speeds on Unpaved Roads

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 4.05494 3.90216 12.4667 11.5240 0.03422 0.45402 6.14004 6.59406 0.42050 2.79487 3.21537 — 4,534.73 4,534.73 0.27742 0.44844 5.85105 4,681.15 Mit. 4.05494 3.90216 12.4667 11.5240 0.03422 0.45402 2.20111 2.65514 0.42050 0.89292 1.31342 — 4,534.73 4,534.73 0.27742 0.44844 5.85105 4,681.15 %
Reduced
— — — — — — 64% 60% — 68% 59% — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 3.99207 3.86194 5.30592 8.47985 0.01471 0.19140 0.49836 0.68976 0.17630 0.12106 0.29736 — 2,052.72 2,052.72 0.07682 0.07744 0.06053 2,077.78 Mit. 3.99207 3.86194 5.30592 8.47985 0.01471 0.19140 0.49836 0.68976 0.17630 0.12106 0.29736 — 2,052.72 2,052.72 0.07682 0.07744 0.06053 2,077.78 %
Reduced
— — — — — — — — — — — — — — — — — —
The Hansen Hotel Detailed Report, 2/24/2026
11 / 79
Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 1.24681 1.16096 3.39307 5.55224 0.00928 0.11503 0.90618 1.01946 0.10594 0.38081 0.48544 — 1,264.32 1,264.32 0.05722 0.07847 0.61322 1,278.74 Mit. 1.24681 1.16096 3.39307 5.55224 0.00928 0.11503 0.42056 0.53384 0.10594 0.14633 0.25096 — 1,264.32 1,264.32 0.05722 0.07847 0.61322 1,278.74 %
Reduced
— — — — — — 54% 48% — 62% 48% — — — — — — —
Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 0.22754 0.21187 0.61924 1.01328 0.00169 0.02099 0.16538 0.18605 0.01933 0.06950 0.08859 — 209.323 209.323 0.00947 0.01299 0.10153 211.709 Mit. 0.22754 0.21187 0.61924 1.01328 0.00169 0.02099 0.07675 0.09743 0.01933 0.02670 0.04580 — 209.323 209.323 0.00947 0.01299 0.10153 211.709 %
Reduced
— — — — — — 54% 48% — 62% 48% — — — — — — —

2.2. Construction Emissions by Year, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily -
Summer
(Max)
— — — — — — — — — — — — — — — — — —
2026 1.51240 1.09099 12.4667 11.5240 0.03422 0.45402 6.14004 6.59406 0.42050 2.79487 3.21537 — 4,534.73 4,534.73 0.27742 0.44844 5.85105 4,681.15 2027 4.05494 3.90216 5.85987 10.0075 0.01644 0.18883 0.57775 0.76658 0.17394 0.13967 0.31361 — 2,269.27 2,269.27 0.08170 0.07874 2.35209 2,297.13 Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — — —
2026 0.72085 0.60374 5.30592 8.47985 0.01471 0.19140 0.49836 0.68976 0.17630 0.12106 0.29736 — 2,052.72 2,052.72 0.07682 0.07744 0.06053 2,077.78 2027 3.99207 3.86194 5.05552 8.37567 0.01471 0.18700 0.49836 0.66814 0.17204 0.12106 0.27747 — 2,039.42 2,039.42 0.07589 0.07478 0.05466 2,063.66 Average
Daily
— — — — — — — — — — — — — — — — — —
2026 0.40213 0.31491 3.14546 3.97107 0.00862 0.11328 0.90618 1.01946 0.10463 0.38081 0.48544 — 1,174.82 1,174.82 0.05722 0.07847 0.61322 1,200.25 2027 1.24681 1.16096 3.39307 5.55224 0.00928 0.11503 0.31208 0.42711 0.10594 0.07542 0.18136 — 1,264.32 1,264.32 0.04631 0.04266 0.54740 1,278.74 Annual — — — — — — — — — — — — — — — — — —
The Hansen Hotel Detailed Report, 2/24/2026
12 / 79
2026 0.07339 0.05747 0.57405 0.72472 0.00157 0.02067 0.16538 0.18605 0.01909 0.06950 0.08859 — 194.506 194.506 0.00947 0.01299 0.10153 198.716 2027 0.22754 0.21187 0.61924 1.01328 0.00169 0.02099 0.05695 0.07795 0.01933 0.01376 0.03310 — 209.323 209.323 0.00767 0.00706 0.09063 211.709

2.3. Construction Emissions by Year, Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily -
Summer
(Max)
— — — — — — — — — — — — — — — — — —
2026 1.51240 1.09099 12.4667 11.5240 0.03422 0.45402 2.20111 2.65514 0.42050 0.89292 1.31342 — 4,534.73 4,534.73 0.27742 0.44844 5.85105 4,681.15 2027 4.05494 3.90216 5.85987 10.0075 0.01644 0.18883 0.57775 0.76658 0.17394 0.13967 0.31361 — 2,269.27 2,269.27 0.08170 0.07874 2.35209 2,297.13 Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — — —
2026 0.72085 0.60374 5.30592 8.47985 0.01471 0.19140 0.49836 0.68976 0.17630 0.12106 0.29736 — 2,052.72 2,052.72 0.07682 0.07744 0.06053 2,077.78 2027 3.99207 3.86194 5.05552 8.37567 0.01471 0.18700 0.49836 0.66814 0.17204 0.12106 0.27747 — 2,039.42 2,039.42 0.07589 0.07478 0.05466 2,063.66 Average
Daily
— — — — — — — — — — — — — — — — — —
2026 0.40213 0.31491 3.14546 3.97107 0.00862 0.11328 0.42056 0.53384 0.10463 0.14633 0.25096 — 1,174.82 1,174.82 0.05722 0.07847 0.61322 1,200.25 2027 1.24681 1.16096 3.39307 5.55224 0.00928 0.11503 0.31208 0.42711 0.10594 0.07542 0.18136 — 1,264.32 1,264.32 0.04631 0.04266 0.54740 1,278.74 Annual — — — — — — — — — — — — — — — — — —
2026 0.07339 0.05747 0.57405 0.72472 0.00157 0.02067 0.07675 0.09743 0.01909 0.02670 0.04580 — 194.506 194.506 0.00947 0.01299 0.10153 198.716 2027 0.22754 0.21187 0.61924 1.01328 0.00169 0.02099 0.05695 0.07795 0.01933 0.01376 0.03310 — 209.323 209.323 0.00767 0.00706 0.09063 211.709

2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
The Hansen Hotel Detailed Report, 2/24/2026
13 / 79
Unmit. 7.19022 6.52955 4.74940 55.4888 0.14654 0.11809 13.9791 14.0972 0.11108 3.54821 3.65930 33.0377 15,251.0 15,284.0 3.97748 0.54128 93.2672 15,638.0 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 6.59116 5.96885 5.10083 48.0411 0.14073 0.11254 13.9791 14.0916 0.10689 3.54821 3.65511 33.0377 14,670.0 14,703.1 3.99561 0.56502 48.1517 15,019.5 Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 6.94019 6.28876 5.17542 51.4972 0.14238 0.11634 13.9773 14.0936 0.10977 3.54777 3.65753 33.0377 14,832.1 14,865.1 3.99291 0.56746 66.9498 15,201.0 Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 1.26658 1.14770 0.94451 9.39824 0.02598 0.02123 2.55085 2.57209 0.02003 0.64747 0.66750 5.46977 2,455.62 2,461.09 0.66107 0.09395 11.0843 2,516.70

2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 5.86884 5.27271 4.33418 52.0175 0.14402 0.08296 13.9791 14.0620 0.07731 3.54821 3.62553 — 14,704.5 14,704.5 0.57256 0.52444 46.3164 14,921.4 Area 1.27862 1.23546 0.02646 3.14480 0.00019 0.00559 — 0.00559 0.00422 — 0.00422 — 12.9322 12.9322 0.00054 0.00011 — 12.9789 Energy 0.04276 0.02138 0.38876 0.32655 0.00233 0.02955 — 0.02955 0.02955 — 0.02955 — 531.821 531.821 0.09079 0.00690 — 536.148 Water — — — — — — — — — — — 3.96905 1.77190 5.74095 0.40828 0.00983 — 18.8763 Waste — — — — — — — — — — — 29.0687 0.00000 29.0687 2.90531 0.00000 — 101.701 Refrig. — — — — — — — — — — — — — — — — 46.9508 46.9508 Total 7.19022 6.52955 4.74940 55.4888 0.14654 0.11809 13.9791 14.0972 0.11108 3.54821 3.65930 33.0377 15,251.0 15,284.0 3.97748 0.54128 93.2672 15,638.0 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 5.82937 5.22844 4.71207 47.7145 0.13840 0.08299 13.9791 14.0621 0.07735 3.54821 3.62556 — 14,136.4 14,136.4 0.59123 0.54830 1.20091 14,315.8 Area 0.71903 0.71903 — — — — — — — — — — — — — — — —
The Hansen Hotel Detailed Report, 2/24/2026
14 / 79
Energy 0.04276 0.02138 0.38876 0.32655 0.00233 0.02955 — 0.02955 0.02955 — 0.02955 — 531.821 531.821 0.09079 0.00690 — 536.148 Water — — — — — — — — — — — 3.96905 1.77190 5.74095 0.40828 0.00983 — 18.8763 Waste — — — — — — — — — — — 29.0687 0.00000 29.0687 2.90531 0.00000 — 101.701 Refrig. — — — — — — — — — — — — — — — — 46.9508 46.9508 Total 6.59116 5.96885 5.10083 48.0411 0.14073 0.11254 13.9791 14.0916 0.10689 3.54821 3.65511 33.0377 14,670.0 14,703.1 3.99561 0.56502 48.1517 15,019.5 Average
Daily
— — — — — — — — — — — — — — — — — —
Mobile 5.79511 5.19463 4.76854 49.0167 0.13992 0.08297 13.9773 14.0603 0.07733 3.54777 3.62509 — 14,289.6 14,289.6 0.58816 0.55066 19.9990 14,488.4 Area 1.10231 1.07275 0.01812 2.15397 0.00013 0.00383 — 0.00383 0.00289 — 0.00289 — 8.85769 8.85769 0.00037 0.00008 — 8.88962 Energy 0.04276 0.02138 0.38876 0.32655 0.00233 0.02955 — 0.02955 0.02955 — 0.02955 — 531.821 531.821 0.09079 0.00690 — 536.148 Water — — — — — — — — — — — 3.96905 1.77190 5.74095 0.40828 0.00983 — 18.8763 Waste — — — — — — — — — — — 29.0687 0.00000 29.0687 2.90531 0.00000 — 101.701 Refrig. — — — — — — — — — — — — — — — — 46.9508 46.9508 Total 6.94019 6.28876 5.17542 51.4972 0.14238 0.11634 13.9773 14.0936 0.10977 3.54777 3.65753 33.0377 14,832.1 14,865.1 3.99291 0.56746 66.9498 15,201.0 Annual — — — — — — — — — — — — — — — — — —
Mobile 1.05761 0.94802 0.87026 8.94554 0.02553 0.01514 2.55085 2.56600 0.01411 0.64747 0.66158 — 2,365.81 2,365.81 0.09738 0.09117 3.31107 2,398.73 Area 0.20117 0.19578 0.00331 0.39310 0.00002 0.00070 — 0.00070 0.00053 — 0.00053 — 1.46649 1.46649 0.00006 0.00001 — 1.47178 Energy 0.00780 0.00390 0.07095 0.05960 0.00043 0.00539 — 0.00539 0.00539 — 0.00539 — 88.0491 88.0491 0.01503 0.00114 — 88.7653 Water — — — — — — — — — — — 0.65712 0.29336 0.95048 0.06759 0.00163 — 3.12518 Waste — — — — — — — — — — — 4.81265 0.00000 4.81265 0.48101 0.00000 — 16.8378 Refrig. — — — — — — — — — — — — — — — — 7.77324 7.77324 Total 1.26658 1.14770 0.94451 9.39824 0.02598 0.02123 2.55085 2.57209 0.02003 0.64747 0.66750 5.46977 2,455.62 2,461.09 0.66107 0.09395 11.0843 2,516.70

2.6. Operations Emissions by Sector, Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
The Hansen Hotel Detailed Report, 2/24/2026
15 / 79
Mobile 5.86884 5.27271 4.33418 52.0175 0.14402 0.08296 13.9791 14.0620 0.07731 3.54821 3.62553 — 14,704.5 14,704.5 0.57256 0.52444 46.3164 14,921.4 Area 1.27862 1.23546 0.02646 3.14480 0.00019 0.00559 — 0.00559 0.00422 — 0.00422 — 12.9322 12.9322 0.00054 0.00011 — 12.9789 Energy 0.04276 0.02138 0.38876 0.32655 0.00233 0.02955 — 0.02955 0.02955 — 0.02955 — 531.821 531.821 0.09079 0.00690 — 536.148 Water — — — — — — — — — — — 3.96905 1.77190 5.74095 0.40828 0.00983 — 18.8763 Waste — — — — — — — — — — — 29.0687 0.00000 29.0687 2.90531 0.00000 — 101.701 Refrig. — — — — — — — — — — — — — — — — 46.9508 46.9508 Total 7.19022 6.52955 4.74940 55.4888 0.14654 0.11809 13.9791 14.0972 0.11108 3.54821 3.65930 33.0377 15,251.0 15,284.0 3.97748 0.54128 93.2672 15,638.0 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 5.82937 5.22844 4.71207 47.7145 0.13840 0.08299 13.9791 14.0621 0.07735 3.54821 3.62556 — 14,136.4 14,136.4 0.59123 0.54830 1.20091 14,315.8 Area 0.71903 0.71903 — — — — — — — — — — — — — — — —
Energy 0.04276 0.02138 0.38876 0.32655 0.00233 0.02955 — 0.02955 0.02955 — 0.02955 — 531.821 531.821 0.09079 0.00690 — 536.148 Water — — — — — — — — — — — 3.96905 1.77190 5.74095 0.40828 0.00983 — 18.8763 Waste — — — — — — — — — — — 29.0687 0.00000 29.0687 2.90531 0.00000 — 101.701 Refrig. — — — — — — — — — — — — — — — — 46.9508 46.9508 Total 6.59116 5.96885 5.10083 48.0411 0.14073 0.11254 13.9791 14.0916 0.10689 3.54821 3.65511 33.0377 14,670.0 14,703.1 3.99561 0.56502 48.1517 15,019.5 Average
Daily
— — — — — — — — — — — — — — — — — —
Mobile 5.79511 5.19463 4.76854 49.0167 0.13992 0.08297 13.9773 14.0603 0.07733 3.54777 3.62509 — 14,289.6 14,289.6 0.58816 0.55066 19.9990 14,488.4 Area 1.10231 1.07275 0.01812 2.15397 0.00013 0.00383 — 0.00383 0.00289 — 0.00289 — 8.85769 8.85769 0.00037 0.00008 — 8.88962 Energy 0.04276 0.02138 0.38876 0.32655 0.00233 0.02955 — 0.02955 0.02955 — 0.02955 — 531.821 531.821 0.09079 0.00690 — 536.148 Water — — — — — — — — — — — 3.96905 1.77190 5.74095 0.40828 0.00983 — 18.8763 Waste — — — — — — — — — — — 29.0687 0.00000 29.0687 2.90531 0.00000 — 101.701 Refrig. — — — — — — — — — — — — — — — — 46.9508 46.9508 Total 6.94019 6.28876 5.17542 51.4972 0.14238 0.11634 13.9773 14.0936 0.10977 3.54777 3.65753 33.0377 14,832.1 14,865.1 3.99291 0.56746 66.9498 15,201.0 Annual — — — — — — — — — — — — — — — — — —
Mobile 1.05761 0.94802 0.87026 8.94554 0.02553 0.01514 2.55085 2.56600 0.01411 0.64747 0.66158 — 2,365.81 2,365.81 0.09738 0.09117 3.31107 2,398.73 Area 0.20117 0.19578 0.00331 0.39310 0.00002 0.00070 — 0.00070 0.00053 — 0.00053 — 1.46649 1.46649 0.00006 0.00001 — 1.47178 The Hansen Hotel Detailed Report, 2/24/2026
16 / 79
Energy 0.00780 0.00390 0.07095 0.05960 0.00043 0.00539 — 0.00539 0.00539 — 0.00539 — 88.0491 88.0491 0.01503 0.00114 — 88.7653 Water — — — — — — — — — — — 0.65712 0.29336 0.95048 0.06759 0.00163 — 3.12518 Waste — — — — — — — — — — — 4.81265 0.00000 4.81265 0.48101 0.00000 — 16.8378 Refrig. — — — — — — — — — — — — — — — — 7.77324 7.77324 Total 1.26658 1.14770 0.94451 9.39824 0.02598 0.02123 2.55085 2.57209 0.02003 0.64747 0.66750 5.46977 2,455.62 2,461.09 0.66107 0.09395 11.0843 2,516.70

3. Construction Emissions Details

3.1. Grading (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.21927 1.02452 9.19052 9.69044 0.01582 0.41898 — 0.41898 0.38547 — 0.38547 — 1,714.25 1,714.25 0.06954 0.01391 — 1,720.14 Dust
From
Material
Movement
— — — — — — 5.32287 5.32287 — 2.57021 2.57021 — — — — — — — Onsite
truck

0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 — 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.15032 0.12631 1.13308 1.19471 0.00195 0.05166 — 0.05166 0.04752 — 0.04752 — 211.346 211.346 0.00857 0.00171 — 212.072 The Hansen Hotel Detailed Report, 2/24/2026
17 / 79
Dust
From
Material
Movement
— — — — — — 0.65624 0.65624 — 0.31687 0.31687 — — — — — — — Onsite
truck

0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 — 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.02743 0.02305 0.20679 0.21803 0.00036 0.00943 — 0.00943 0.00867 — 0.00867 — 34.9908 34.9908 0.00142 0.00028 — 35.1109 Dust
From
Material
Movement
— — — — — — 0.11976 0.11976 — 0.05783 0.05783 — — — — — — — Onsite
truck

0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 — 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.02596 0.02530 0.02282 0.39526 0.00000 0.00000 0.09803 0.09803 0.00000 0.02298 0.02298 — 97.6619 97.6619 0.00116 0.00355 0.33944 99.0897 Vendor 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 — 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 Hauling 0.26717 0.04117 3.25335 1.43834 0.01840 0.03504 0.71914 0.75418 0.03504 0.20168 0.23672 — 2,722.81 2,722.81 0.20673 0.43098 5.51160 2,861.92 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.00318 0.00310 0.00323 0.04370 0.00000 0.00000 0.01208 0.01208 0.00000 0.00283 0.00283 — 11.6158 11.6158 0.00016 0.00044 0.01807 11.7686 Vendor 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 — 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 Hauling 0.03272 0.00486 0.41967 0.17798 0.00227 0.00432 0.08865 0.09297 0.00432 0.02486 0.02918 — 335.739 335.739 0.02549 0.05313 0.29312 352.504 Annual — — — — — — — — — — — — — — — — — —
Worker 0.00058 0.00057 0.00059 0.00797 0.00000 0.00000 0.00221 0.00221 0.00000 0.00052 0.00052 — 1.92313 1.92313 0.00003 0.00007 0.00299 1.94842 The Hansen Hotel Detailed Report, 2/24/2026
18 / 79
Vendor 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 — 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 Hauling 0.00597 0.00089 0.07659 0.03248 0.00041 0.00079 0.01618 0.01697 0.00079 0.00454 0.00533 — 55.5855 55.5855 0.00422 0.00880 0.04853 58.3610

3.2. Grading (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

San Clemente City CouncilApril 21, 2026

San Clemente City Council
April 21, 2026