Agenda packet, regular meeting — San Clemente City Council, May 19, 2026 (part 2 of 6)

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 269

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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.
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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.
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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)
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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:

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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:
x The proposed project’s energy requirements and its energy use efficiencies by amount and fuel type during demolition, construction, and operation; (Criterion 1) x The effects of the proposed project on local and regional energy supplies; (Criterion 2) x The effects of the proposed project on peak and base period demands for electricity and other forms of energy; (Criterion 3)
x The degree to which the proposed project complies with existing energy standards; (Criterion 4)
x The effects of the proposed project on energy resources; (Criterion 5) and x 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% 275

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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 276

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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. 277

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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. 278

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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.
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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.
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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. 281

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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.
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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.
9 2) Strong seismic ground shaking? 9
3) Seismic-related ground failure, including liquefaction? 9 4) Landslides? 9
b. Result in substantial soil erosion or the loss of topsoil? 9 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?
9 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?
9 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?
9 f. Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? 9
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.
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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):

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) Seismic-related ground failure, including liquefaction? 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 284

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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.
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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. 286

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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 287

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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.

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. 288

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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.

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.

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:
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x 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.
x The SVP-qualified paleontologist shall ensure that specialty studies are completed, as appropriate, for any significant fossil collected. x 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)
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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:

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. Generate greenhouse gas emissions, either directly
or indirectly, that may have a significant impact on
the environment?
9 b. Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions
of greenhouse gases?
9 a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?

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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 293

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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.
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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. 295

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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 296

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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 297

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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
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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
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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.
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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.
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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 302

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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. 303

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3.9.2 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. Create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials?
9 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?
9 c. Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste
within one-quarter mile of an existing or proposed
school?
9 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?
9 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?
9 f. Impair implementation of or physically interfere with an adopted emergency response plan or emergency
evacuation plan?
9 g. Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury or death involving wildland fires?
9 a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
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 304

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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.
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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 x San Clemente Car Wash (1731 El Camino Real) – case closed as of April 1, 2021; x U Haul Center #717-21 (310 Avenida Pico) – case closed as of November 4, 1996; x City of San Clemente (1801 Ave Estacion) – case closed as of May 2, 1989; and x 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. 306

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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 307

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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. 308

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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. 310

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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
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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:

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. Violate any water quality standards or waste
discharge requirements or otherwise substantially
degrade surface or ground water quality?
9 b. Substantially decrease groundwater supplies or
interfere substantially with groundwater recharge
such that the project may impede sustainable
groundwater management of the basin?
9 c. Substantially alter the existing drainage pattern of the site or area, including through the alteration of
the course of a stream or river or through the
addition of impervious surfaces, in a manner
which would:
9 20 San Juan Basin Authority, Programs, https://www.sjbauthority.com/programs.html, accessed February 5, 2026. 21 San Juan Basin Authority, San Juan Basin Groundwater and Facilities Management Plan, November 2013. 312

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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
1) Result in substantial erosion or siltation onor off-site? 9 2) Substantially increase the rate or amount of
surface runoff in a manner which would result
in flooding on- or offsite?
9 3) Create or contribute runoff water which would
exceed the capacity of existing or planned
stormwater drainage systems or provide
substantial additional sources of polluted
runoff?
9 4) Impede or redirect flood flows? 9
d) In flood hazard, tsunami, or seiche zones, risk
release of pollutants due to project inundation? 9
e) Conflict with or obstruct implementation of a water
quality control plan or sustainable groundwater
management plan?
9 This analysis is based on the project-specific Water Quality Management Plan (WQMP), prepared by Toal Engineering, Inc., dated April 10, 2025; refer to Appendix F, Water Quality Management Plan. a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality?
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 313

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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. 314

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Applicable Conditions of Approval (COAs):

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)
b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
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 315

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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):

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) 316

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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. 317

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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. 318

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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.
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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:

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. Physically divide an established community? 9
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?
9 a) Physically divide an established community?
No Impact. Factors that could physically divide a community include, but are not limited to:
x Construction of major highways or roadways;
x Construction of storm channels;
x Closing bridges or roadways; and
x Construction of utility transmission lines.

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 320

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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 321

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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 322

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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). 323

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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 324

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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 325

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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 326

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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.
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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
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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.
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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.
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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.
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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. 332

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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?
9 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?
9 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. 334

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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.

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.

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 336

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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. 337

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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.
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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. 339

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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. 340

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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 341

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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.
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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. 343

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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. 344

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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. 345

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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).
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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)

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.

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 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 equivalent, shall be utilized. (Required per General Plan EIR Mitigation Measure 10-1 and Municipal Code Sections 8.48.070 and 8.48.050) b) Generation of excessive groundborne vibration or groundborne noise levels? 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 347

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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.
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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.
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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 350

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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. 351
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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 352

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(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:

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 substantial 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 environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
1) Fire protection? 9
2) Police protection? 9
3) Schools? 9
4) Parks? 9
5) Other public facilities? 9
a) Would the project result in substantial 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 environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
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 353

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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.
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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:

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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. 357
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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, 358

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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:

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x 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 360

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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 361

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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 362

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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. 363

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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):

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.

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?
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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. 365
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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.

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 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. 366

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3.18.2 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 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
9 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.
9 Assembly Bill (AB) 52 took effect July 1, 2015. Under AB 52, a tribal cultural resource is defined as sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are either included or eligible for inclusion in the California Register of Historic Resources or included in a local register of historical resources; or the lead agency, supported by substantial evidence, chooses at its discretion to treat the resources as a tribal cultural resource.

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. 367

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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 368

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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. 369
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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.
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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 371

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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 372

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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?
9 b. Have sufficient water supplies available to serve the project and reasonably foreseeable future development during
normal, dry and multiple dry years?
9 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?
9 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?
9 e. Comply with Federal, State, and local management and reduction statutes and regulations related to solid waste? 9 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 373

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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):

4.10 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.

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)

4.12 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)

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 374

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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 375

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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.
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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:

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. Substantially impair an adopted emergency
response plan or emergency evacuation plan? 9
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?
9 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?
9 d. Expose people or structures to significant risks,
including downslope or downstream flooding or 9
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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. 379
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.
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March 2026 4-2 Determination
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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. 382

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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. 383
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
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APPENDIX B
Air Quality/GHG/Energy Data
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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
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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
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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
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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
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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
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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
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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
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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
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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 — — —
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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
——————————————————
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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 — — — — — — — — — — — — — — — — — —
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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)
——————————————————
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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 — — — — — — — — — — — — — — — —
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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)
——————————————————
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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 402
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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 — 212.072 403
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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 404
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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

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
— — — — — — 1.38395 1.38395 — 0.66825 0.66825 — — — — — — — Onsite
truck

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 Dust
From
Material
Movement
— — — — — — 0.17062 0.17062 — 0.08239 0.08239 — — — — — — — 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 405
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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
— — — — — — 0.03114 0.03114 — 0.01504 0.01504 — — — — — — — 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 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

3.3. Building Construction (2026) - Unmitigated
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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

0.58782 0.49393 4.80600 6.90565 0.01205 0.18874 — 0.18874 0.17364 — 0.17364 — 1,304.47 1,304.47 0.05291 0.01058 — 1,308.94 Onsite
truck

0.17600 0.14789 1.43898 2.06764 0.00361 0.05651 — 0.05651 0.05199 — 0.05199 — 390.574 390.574 0.01584 0.00317 — 391.914 Onsite
truck

0.03212 0.02699 0.26261 0.37734 0.00066 0.01031 — 0.01031 0.00949 — 0.00949 — 64.6640 64.6640 0.00262 0.00052 — 64.8859 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 407
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Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
——————————————————
Worker 0.10512 0.10244 0.09240 1.60053 0.00000 0.00000 0.39696 0.39696 0.00000 0.09305 0.09305 — 395.463 395.463 0.00469 0.01440 1.37450 401.244 Vendor 0.02911 0.00789 0.37844 0.18943 0.00267 0.00267 0.10140 0.10406 0.00267 0.02802 0.03068 — 371.713 371.713 0.01855 0.05246 0.96038 388.771 Hauling 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)
——————————————————
Worker 0.10445 0.10244 0.10612 1.38059 0.00000 0.00000 0.39696 0.39696 0.00000 0.09305 0.09305 — 376.362 376.362 0.00536 0.01440 0.03560 380.822 Vendor 0.02858 0.00737 0.39380 0.19361 0.00267 0.00267 0.10140 0.10406 0.00267 0.02802 0.03068 — 371.896 371.896 0.01855 0.05246 0.02492 388.019 Hauling 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 Average
Daily
——————————————————
Worker 0.03127 0.03047 0.03177 0.42970 0.00000 0.00000 0.11884 0.11884 0.00000 0.02786 0.02786 — 114.230 114.230 0.00160 0.00431 0.17766 115.732 Vendor 0.00864 0.00228 0.11872 0.05734 0.00080 0.00080 0.03036 0.03116 0.00080 0.00839 0.00919 — 111.319 111.319 0.00555 0.01571 0.12438 116.263 Hauling 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 — — — — — — — — — — — — — — — — — —
Worker 0.00571 0.00556 0.00580 0.07842 0.00000 0.00000 0.02169 0.02169 0.00000 0.00508 0.00508 — 18.9121 18.9121 0.00027 0.00071 0.02941 19.1608 Vendor 0.00158 0.00042 0.02167 0.01047 0.00015 0.00015 0.00554 0.00569 0.00015 0.00153 0.00168 — 18.4301 18.4301 0.00092 0.00260 0.02059 19.2487 Hauling 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

3.4. Building Construction (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)
——————————————————
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Off-Roa 0.58782 0.49393 4.80600 6.90565 0.01205 0.18874 — 0.18874 0.17364 — 0.17364 — 1,304.47 1,304.47 0.05291 0.01058 — 1,308.94 d
Onsite
truck

0.58782 0.49393 4.80600 6.90565 0.01205 0.18874 — 0.18874 0.17364 — 0.17364 — 1,304.47 1,304.47 0.05291 0.01058 — 1,308.94 Onsite
truck

0.17600 0.14789 1.43898 2.06764 0.00361 0.05651 — 0.05651 0.05199 — 0.05199 — 390.574 390.574 0.01584 0.00317 — 391.914 Onsite
truck

0.03212 0.02699 0.26261 0.37734 0.00066 0.01031 — 0.01031 0.00949 — 0.00949 — 64.6640 64.6640 0.00262 0.00052 — 64.8859 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 0.10512 0.10244 0.09240 1.60053 0.00000 0.00000 0.39696 0.39696 0.00000 0.09305 0.09305 — 395.463 395.463 0.00469 0.01440 1.37450 401.244 Vendor 0.02911 0.00789 0.37844 0.18943 0.00267 0.00267 0.10140 0.10406 0.00267 0.02802 0.03068 — 371.713 371.713 0.01855 0.05246 0.96038 388.771 Hauling 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 409
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Daily,
Winter
(Max)
——————————————————
Worker 0.10445 0.10244 0.10612 1.38059 0.00000 0.00000 0.39696 0.39696 0.00000 0.09305 0.09305 — 376.362 376.362 0.00536 0.01440 0.03560 380.822 Vendor 0.02858 0.00737 0.39380 0.19361 0.00267 0.00267 0.10140 0.10406 0.00267 0.02802 0.03068 — 371.896 371.896 0.01855 0.05246 0.02492 388.019 Hauling 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 Average
Daily
——————————————————
Worker 0.03127 0.03047 0.03177 0.42970 0.00000 0.00000 0.11884 0.11884 0.00000 0.02786 0.02786 — 114.230 114.230 0.00160 0.00431 0.17766 115.732 Vendor 0.00864 0.00228 0.11872 0.05734 0.00080 0.00080 0.03036 0.03116 0.00080 0.00839 0.00919 — 111.319 111.319 0.00555 0.01571 0.12438 116.263 Hauling 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 — — — — — — — — — — — — — — — — — —
Worker 0.00571 0.00556 0.00580 0.07842 0.00000 0.00000 0.02169 0.02169 0.00000 0.00508 0.00508 — 18.9121 18.9121 0.00027 0.00071 0.02941 19.1608 Vendor 0.00158 0.00042 0.02167 0.01047 0.00015 0.00015 0.00554 0.00569 0.00015 0.00153 0.00168 — 18.4301 18.4301 0.00092 0.00260 0.02059 19.2487 Hauling 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

3.5. Building Construction (2027) - 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

0.56653 0.47604 4.55564 6.89930 0.01205 0.16712 — 0.16712 0.15375 — 0.15375 — 1,304.35 1,304.35 0.05291 0.01058 — 1,308.83 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)
——————————————————
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Off-Roa
Equipment

0.56653 0.47604 4.55564 6.89930 0.01205 0.16712 — 0.16712 0.15375 — 0.15375 — 1,304.35 1,304.35 0.05291 0.01058 — 1,308.83 Onsite
truck

0.30267 0.25432 2.43383 3.68593 0.00644 0.08928 — 0.08928 0.08214 — 0.08214 — 696.845 696.845 0.02827 0.00565 — 699.237 Onsite
truck

0.05524 0.04641 0.44417 0.67268 0.00117 0.01629 — 0.01629 0.01499 — 0.01499 — 115.371 115.371 0.00468 0.00094 — 115.767 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 0.10110 0.08671 0.09106 1.50178 0.00000 0.00000 0.39696 0.39696 0.00000 0.09305 0.09305 — 388.805 388.805 0.00402 0.01440 1.23280 394.428 Vendor 0.02885 0.00763 0.36381 0.18065 0.00267 0.00267 0.10140 0.10406 0.00267 0.02802 0.03068 — 364.843 364.843 0.01855 0.04980 0.87272 381.020 Hauling 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)
——————————————————
Worker 0.10110 0.08604 0.09307 1.29154 0.00000 0.00000 0.39696 0.39696 0.00000 0.09305 0.09305 — 370.034 370.034 0.00469 0.01440 0.03206 374.473 Vendor 0.02858 0.00737 0.37917 0.18483 0.00267 0.00267 0.10140 0.10406 0.00267 0.02802 0.03068 — 365.035 365.035 0.01829 0.04980 0.02260 380.355 Hauling 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 Average
Daily
——————————————————
411
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Worker 0.05365 0.04596 0.05598 0.71951 0.00000 0.00000 0.21205 0.21205 0.00000 0.04970 0.04970 — 200.389 200.389 0.00250 0.00769 0.28483 203.029 Vendor 0.01541 0.00408 0.20388 0.09749 0.00142 0.00142 0.05417 0.05559 0.00142 0.01497 0.01639 — 194.960 194.960 0.00977 0.02661 0.20096 203.333 Hauling 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 — — — — — — — — — — — — — — — — — —
Worker 0.00979 0.00839 0.01022 0.13131 0.00000 0.00000 0.03870 0.03870 0.00000 0.00907 0.00907 — 33.1767 33.1767 0.00041 0.00127 0.04716 33.6137 Vendor 0.00281 0.00074 0.03721 0.01779 0.00026 0.00026 0.00989 0.01015 0.00026 0.00273 0.00299 — 32.2778 32.2778 0.00162 0.00440 0.03327 33.6641 Hauling 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

3.6. Building Construction (2027) - 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

0.56653 0.47604 4.55564 6.89930 0.01205 0.16712 — 0.16712 0.15375 — 0.15375 — 1,304.35 1,304.35 0.05291 0.01058 — 1,308.83 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 Average
Daily
——————————————————
412
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Off-Roa 0.30267 0.25432 2.43383 3.68593 0.00644 0.08928 — 0.08928 0.08214 — 0.08214 — 696.845 696.845 0.02827 0.00565 — 699.237 d
Onsite
truck

0.05524 0.04641 0.44417 0.67268 0.00117 0.01629 — 0.01629 0.01499 — 0.01499 — 115.371 115.371 0.00468 0.00094 — 115.767 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 0.10110 0.08671 0.09106 1.50178 0.00000 0.00000 0.39696 0.39696 0.00000 0.09305 0.09305 — 388.805 388.805 0.00402 0.01440 1.23280 394.428 Vendor 0.02885 0.00763 0.36381 0.18065 0.00267 0.00267 0.10140 0.10406 0.00267 0.02802 0.03068 — 364.843 364.843 0.01855 0.04980 0.87272 381.020 Hauling 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)
——————————————————
Worker 0.10110 0.08604 0.09307 1.29154 0.00000 0.00000 0.39696 0.39696 0.00000 0.09305 0.09305 — 370.034 370.034 0.00469 0.01440 0.03206 374.473 Vendor 0.02858 0.00737 0.37917 0.18483 0.00267 0.00267 0.10140 0.10406 0.00267 0.02802 0.03068 — 365.035 365.035 0.01829 0.04980 0.02260 380.355 Hauling 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 Average
Daily
——————————————————
Worker 0.05365 0.04596 0.05598 0.71951 0.00000 0.00000 0.21205 0.21205 0.00000 0.04970 0.04970 — 200.389 200.389 0.00250 0.00769 0.28483 203.029 Vendor 0.01541 0.00408 0.20388 0.09749 0.00142 0.00142 0.05417 0.05559 0.00142 0.01497 0.01639 — 194.960 194.960 0.00977 0.02661 0.20096 203.333 Hauling 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 — — — — — — — — — — — — — — — — — —
Worker 0.00979 0.00839 0.01022 0.13131 0.00000 0.00000 0.03870 0.03870 0.00000 0.00907 0.00907 — 33.1767 33.1767 0.00041 0.00127 0.04716 33.6137 Vendor 0.00281 0.00074 0.03721 0.01779 0.00026 0.00026 0.00989 0.01015 0.00026 0.00273 0.00299 — 32.2778 32.2778 0.00162 0.00440 0.03327 33.6641 413
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Hauling 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

3.7. Paving (2027) - 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)
——————————————————
Daily,
Winter
(Max)
——————————————————
Off-Roa
d
Equipm
ent

0.57535 0.48071 4.15212 5.30895 0.00857 0.16795 — 0.16795 0.15451 — 0.15451 — 823.016 823.016 0.03339 0.00668 — 825.840 Paving 0.00000 0.00000 — — — — — — — — — — — — — — — —
Onsite
truck

0.06778 0.05663 0.48915 0.62544 0.00101 0.01979 — 0.01979 0.01820 — 0.01820 — 96.9581 96.9581 0.00393 0.00079 — 97.2908 Paving 0.00000 0.00000 — — — — — — — — — — — — — — — —
Onsite
truck

0.01237 0.01034 0.08927 0.11414 0.00018 0.00361 — 0.00361 0.00332 — 0.00332 — 16.0525 16.0525 0.00065 0.00013 — 16.1076 Paving 0.00000 0.00000 — — — — — — — — — — — — — — — —
414
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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)
——————————————————
Daily,
Winter
(Max)
——————————————————
Worker 0.05826 0.04958 0.05363 0.74423 0.00000 0.00000 0.22874 0.22874 0.00000 0.05362 0.05362 — 213.225 213.225 0.00270 0.00829 0.01847 215.783 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 0.00000 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 Average
Daily
——————————————————
Worker 0.00682 0.00584 0.00711 0.09143 0.00000 0.00000 0.02694 0.02694 0.00000 0.00632 0.00632 — 25.4627 25.4627 0.00032 0.00098 0.03619 25.7981 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 0.00000 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 — — — — — — — — — — — — — — — — — —
Worker 0.00124 0.00107 0.00130 0.01669 0.00000 0.00000 0.00492 0.00492 0.00000 0.00115 0.00115 — 4.21565 4.21565 0.00005 0.00016 0.00599 4.27117 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 0.00000 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

3.8. Paving (2027) - 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)
——————————————————
Daily,
Winter
(Max)
——————————————————
415
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Off-Roa
Equipment

0.01237 0.01034 0.08927 0.11414 0.00018 0.00361 — 0.00361 0.00332 — 0.00332 — 16.0525 16.0525 0.00065 0.00013 — 16.1076 Paving 0.00000 0.00000 — — — — — — — — — — — — — — — —
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)
——————————————————
Daily,
Winter
(Max)
——————————————————
Worker 0.05826 0.04958 0.05363 0.74423 0.00000 0.00000 0.22874 0.22874 0.00000 0.05362 0.05362 — 213.225 213.225 0.00270 0.00829 0.01847 215.783 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 0.00000 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 Average
Daily
——————————————————
416
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Worker 0.00682 0.00584 0.00711 0.09143 0.00000 0.00000 0.02694 0.02694 0.00000 0.00632 0.00632 — 25.4627 25.4627 0.00032 0.00098 0.03619 25.7981 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 0.00000 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 — — — — — — — — — — — — — — — — — —
Worker 0.00124 0.00107 0.00130 0.01669 0.00000 0.00000 0.00492 0.00492 0.00000 0.00115 0.00115 — 4.21565 4.21565 0.00005 0.00016 0.00599 4.27117 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 0.00000 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

3.9. Architectural Coating (2027) - 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

0.13715 0.11335 0.83116 1.12539 0.00173 0.01905 — 0.01905 0.01752 — 0.01752 — 133.513 133.513 0.00542 0.00108 — 133.971 Architect
ural
Coating
s

3.20110 3.20110 — — — — — — — — — — — — — — — —
Onsite
truck

0.13715 0.11335 0.83116 1.12539 0.00173 0.01905 — 0.01905 0.01752 — 0.01752 — 133.513 133.513 0.00542 0.00108 — 133.971 417
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Architect 3.20110 3.20110 — — — — — — — — — — — — — — — — ural
Coating
Onsite
truck

0.03269 0.02702 0.19811 0.26824 0.00041 0.00454 — 0.00454 0.00418 — 0.00418 — 31.8236 31.8236 0.00129 0.00026 — 31.9328 Architect
ural
Coating
s

0.76300 0.76300 — — — — — — — — — — — — — — — —
Onsite
truck

0.00597 0.00493 0.03616 0.04895 0.00008 0.00083 — 0.00083 0.00076 — 0.00076 — 5.26876 5.26876 0.00021 0.00004 — 5.28684 Architect
ural
Coating
s

0.13925 0.13925 — — — — — — — — — — — — — — — —
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 0.02022 0.01734 0.01821 0.30036 0.00000 0.00000 0.07939 0.07939 0.00000 0.01861 0.01861 — 77.7611 77.7611 0.00080 0.00288 0.24656 78.8857 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 0.00000 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 418
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Daily, — — — — — — — — — — — — — — — — — —
Winter
(Max)
Worker 0.02022 0.01721 0.01861 0.25831 0.00000 0.00000 0.07939 0.07939 0.00000 0.01861 0.01861 — 74.0069 74.0069 0.00094 0.00288 0.00641 74.8947 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 0.00000 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 Average
Daily
——————————————————
Worker 0.00479 0.00410 0.00500 0.06420 0.00000 0.00000 0.01892 0.01892 0.00000 0.00444 0.00444 — 17.8809 17.8809 0.00022 0.00069 0.02542 18.1164 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 0.00000 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 — — — — — — — — — — — — — — — — — —
Worker 0.00087 0.00075 0.00091 0.01172 0.00000 0.00000 0.00345 0.00345 0.00000 0.00081 0.00081 — 2.96039 2.96039 0.00004 0.00011 0.00421 2.99938 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 0.00000 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

3.10. Architectural Coating (2027) - 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

0.13715 0.11335 0.83116 1.12539 0.00173 0.01905 — 0.01905 0.01752 — 0.01752 — 133.513 133.513 0.00542 0.00108 — 133.971 Architect
ural
Coating
s

3.20110 3.20110 — — — — — — — — — — — — — — — —
419
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Onsite 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 truck
Daily,
Winter
(Max)
——————————————————
Off-Roa
d
Equipm
ent

0.13715 0.11335 0.83116 1.12539 0.00173 0.01905 — 0.01905 0.01752 — 0.01752 — 133.513 133.513 0.00542 0.00108 — 133.971 Architect
ural
Coating
s

3.20110 3.20110 — — — — — — — — — — — — — — — —
Onsite
truck

0.03269 0.02702 0.19811 0.26824 0.00041 0.00454 — 0.00454 0.00418 — 0.00418 — 31.8236 31.8236 0.00129 0.00026 — 31.9328 Architect
ural
Coating
s

0.76300 0.76300 — — — — — — — — — — — — — — — —
Onsite
truck

0.00597 0.00493 0.03616 0.04895 0.00008 0.00083 — 0.00083 0.00076 — 0.00076 — 5.26876 5.26876 0.00021 0.00004 — 5.28684 Architect
ural
Coating
s

0.13925 0.13925 — — — — — — — — — — — — — — — —
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 420
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Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
——————————————————
Worker 0.02022 0.01734 0.01821 0.30036 0.00000 0.00000 0.07939 0.07939 0.00000 0.01861 0.01861 — 77.7611 77.7611 0.00080 0.00288 0.24656 78.8857 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 0.00000 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)
——————————————————
Worker 0.02022 0.01721 0.01861 0.25831 0.00000 0.00000 0.07939 0.07939 0.00000 0.01861 0.01861 — 74.0069 74.0069 0.00094 0.00288 0.00641 74.8947 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 0.00000 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 Average
Daily
——————————————————
Worker 0.00479 0.00410 0.00500 0.06420 0.00000 0.00000 0.01892 0.01892 0.00000 0.00444 0.00444 — 17.8809 17.8809 0.00022 0.00069 0.02542 18.1164 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 0.00000 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 — — — — — — — — — — — — — — — — — —
Worker 0.00087 0.00075 0.00091 0.01172 0.00000 0.00000 0.00345 0.00345 0.00000 0.00081 0.00081 — 2.96039 2.96039 0.00004 0.00011 0.00421 2.99938 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 0.00000 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

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e 421
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35 / 79
Daily,
Summer
(Max)
——————————————————
Hotel 1.75243 1.57443 1.29419 15.5324 0.04300 0.02477 4.17415 4.19892 0.02309 1.05950 1.08258 — 4,390.75 4,390.75 0.17097 0.15660 13.8301 4,455.52 Enclose
d
Parking
with
Elevator

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 High
Turnover
(Sit
Down
Restaurant)

4.11640 3.69828 3.04000 36.4851 0.10101 0.05819 9.80493 9.86311 0.05423 2.48872 2.54295 — 10,313.7 10,313.7 0.40160 0.36784 32.4863 10,465.9 Total 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 Daily,
Winter
(Max)
——————————————————
Hotel 1.74065 1.56121 1.40702 14.2476 0.04133 0.02478 4.17415 4.19893 0.02310 1.05950 1.08259 — 4,221.14 4,221.14 0.17654 0.16372 0.35859 4,274.70 Enclose
d
Parking
with
Elevator

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 High
Turnover
(Sit
Down
Restaurant)

4.08872 3.66723 3.30505 33.4670 0.09707 0.05821 9.80493 9.86314 0.05425 2.48872 2.54297 — 9,915.31 9,915.31 0.41469 0.38457 0.84232 10,041.1 Total 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 Annual — — — — — — — — — — — — — — — — — —
Hotel 0.31580 0.28308 0.25986 2.67114 0.00762 0.00452 0.76168 0.76621 0.00421 0.19333 0.19755 — 706.431 706.431 0.02908 0.02722 0.98869 716.259 Enclose
d
Parking
with
Elevator

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 422
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High
Turnover
(Sit
Down
Restaurant)

0.74181 0.66494 0.61040 6.27440 0.01791 0.01062 1.78917 1.79979 0.00990 0.45413 0.46403 — 1,659.38 1,659.38 0.06830 0.06395 2.32238 1,682.47 Total 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

4.1.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
——————————————————
Hotel 1.75243 1.57443 1.29419 15.5324 0.04300 0.02477 4.17415 4.19892 0.02309 1.05950 1.08258 — 4,390.75 4,390.75 0.17097 0.15660 13.8301 4,455.52 Enclose
d
Parking
with
Elevator

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 High
Turnover
(Sit
Down
Restaurant)

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 423
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High 4.08872 3.66723 3.30505 33.4670 0.09707 0.05821 9.80493 9.86314 0.05425 2.48872 2.54297 — 9,915.31 9,915.31 0.41469 0.38457 0.84232 10,041.1 Turnover
(Sit
Down
Restaurant)
Total 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 Annual — — — — — — — — — — — — — — — — — —
Hotel 0.31580 0.28308 0.25986 2.67114 0.00762 0.00452 0.76168 0.76621 0.00421 0.19333 0.19755 — 706.431 706.431 0.02908 0.02722 0.98869 716.259 Enclose
d
Parking
with
Elevator

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 High
Turnover
(Sit
Down
Restaurant)

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
——————————————————
Hotel — — — — — — — — — — — — 41.0922 41.0922 0.03007 0.00364 — 42.9300 Enclose
d
Parking
with
Elevator
— — — — — — — — — — — — 19.2820 19.2820 0.01411 0.00171 — 20.1444 424
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High
Turnover
(Sit
Down
Restaurant)
— — — — — — — — — — — — 7.59701 7.59701 0.00556 0.00067 — 7.93678 Total — — — — — — — — — — — — 67.9713 67.9713 0.04974 0.00603 — 71.0112 Daily,
Winter
(Max)
——————————————————
Hotel — — — — — — — — — — — — 41.0922 41.0922 0.03007 0.00364 — 42.9300 Enclose
d
Parking
with
Elevator
— — — — — — — — — — — — 19.2820 19.2820 0.01411 0.00171 — 20.1444 High
Turnover
(Sit
Down
Restaurant)
— — — — — — — — — — — — 7.59701 7.59701 0.00556 0.00067 — 7.93678 Total — — — — — — — — — — — — 67.9713 67.9713 0.04974 0.00603 — 71.0112 Annual — — — — — — — — — — — — — — — — — —
Hotel — — — — — — — — — — — — 6.80329 6.80329 0.00498 0.00060 — 7.10756 Enclose
d
Parking
with
Elevator
— — — — — — — — — — — — 3.19236 3.19236 0.00234 0.00028 — 3.33513 High
Turnover
(Sit
Down
Restaurant)
— — — — — — — — — — — — 1.25777 1.25777 0.00092 0.00011 — 1.31402 Total — — — — — — — — — — — — 11.2534 11.2534 0.00823 0.00100 — 11.7567

4.2.2. Electricity Emissions By Land Use - Mitigated
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Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
——————————————————
Hotel — — — — — — — — — — — — 41.0922 41.0922 0.03007 0.00364 — 42.9300 Enclose
d
Parking
with
Elevator
— — — — — — — — — — — — 19.2820 19.2820 0.01411 0.00171 — 20.1444 High
Turnover
(Sit
Down
Restaurant)
— — — — — — — — — — — — 7.59701 7.59701 0.00556 0.00067 — 7.93678 Total — — — — — — — — — — — — 67.9713 67.9713 0.04974 0.00603 — 71.0112 Daily,
Winter
(Max)
——————————————————
Hotel — — — — — — — — — — — — 41.0922 41.0922 0.03007 0.00364 — 42.9300 Enclose
d
Parking
with
Elevator
— — — — — — — — — — — — 19.2820 19.2820 0.01411 0.00171 — 20.1444 High
Turnover
(Sit
Down
Restaurant)
— — — — — — — — — — — — 7.59701 7.59701 0.00556 0.00067 — 7.93678 Total — — — — — — — — — — — — 67.9713 67.9713 0.04974 0.00603 — 71.0112 Annual — — — — — — — — — — — — — — — — — —
Hotel — — — — — — — — — — — — 6.80329 6.80329 0.00498 0.00060 — 7.10756 426
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Enclose — — — — — — — — — — — — 3.19236 3.19236 0.00234 0.00028 — 3.33513 d
Parking
with
Elevator
High
Turnover
(Sit
Down
Restaurant)
— — — — — — — — — — — — 1.25777 1.25777 0.00092 0.00011 — 1.31402 Total — — — — — — — — — — — — 11.2534 11.2534 0.00823 0.00100 — 11.7567

4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
——————————————————
Hotel 0.03703 0.01852 0.33664 0.28278 0.00202 0.02558 — 0.02558 0.02558 — 0.02558 — 401.672 401.672 0.03555 0.00076 — 402.786 Enclose
d
Parking
with
Elevator

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 High
Turnover
(Sit
Down
Restaurant)

0.00573 0.00287 0.05211 0.04377 0.00031 0.00396 — 0.00396 0.00396 — 0.00396 — 62.1781 62.1781 0.00550 0.00012 — 62.3506 Total 0.04276 0.02138 0.38876 0.32655 0.00233 0.02955 — 0.02955 0.02955 — 0.02955 — 463.850 463.850 0.04105 0.00087 — 465.136 Daily,
Winter
(Max)
——————————————————
Hotel 0.03703 0.01852 0.33664 0.28278 0.00202 0.02558 — 0.02558 0.02558 — 0.02558 — 401.672 401.672 0.03555 0.00076 — 402.786 427
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Enclose 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 d
High
Turnover
(Sit
Down
Restaurant)

0.00573 0.00287 0.05211 0.04377 0.00031 0.00396 — 0.00396 0.00396 — 0.00396 — 62.1781 62.1781 0.00550 0.00012 — 62.3506 Total 0.04276 0.02138 0.38876 0.32655 0.00233 0.02955 — 0.02955 0.02955 — 0.02955 — 463.850 463.850 0.04105 0.00087 — 465.136 Annual — — — — — — — — — — — — — — — — — —
Hotel 0.00676 0.00338 0.06144 0.05161 0.00037 0.00467 — 0.00467 0.00467 — 0.00467 — 66.5013 66.5013 0.00589 0.00013 — 66.6858 Enclose
d
Parking
with
Elevator

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 High
Turnover
(Sit
Down
Restaurant)

0.00105 0.00052 0.00951 0.00799 0.00006 0.00072 — 0.00072 0.00072 — 0.00072 — 10.2943 10.2943 0.00091 0.00002 — 10.3229 Total 0.00780 0.00390 0.07095 0.05960 0.00043 0.00539 — 0.00539 0.00539 — 0.00539 — 76.7956 76.7956 0.00680 0.00014 — 77.0086

4.2.4. Natural Gas Emissions By Land Use - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
——————————————————
Hotel 0.03703 0.01852 0.33664 0.28278 0.00202 0.02558 — 0.02558 0.02558 — 0.02558 — 401.672 401.672 0.03555 0.00076 — 402.786 Enclose
d
Parking
with
Elevator

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 428
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High 0.00573 0.00287 0.05211 0.04377 0.00031 0.00396 — 0.00396 0.00396 — 0.00396 — 62.1781 62.1781 0.00550 0.00012 — 62.3506 Turnover
(Sit
Down
Restaurant)
Total 0.04276 0.02138 0.38876 0.32655 0.00233 0.02955 — 0.02955 0.02955 — 0.02955 — 463.850 463.850 0.04105 0.00087 — 465.136 Daily,
Winter
(Max)
——————————————————
Hotel 0.03703 0.01852 0.33664 0.28278 0.00202 0.02558 — 0.02558 0.02558 — 0.02558 — 401.672 401.672 0.03555 0.00076 — 402.786 Enclose
d
Parking
with
Elevator

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 High
Turnover
(Sit
Down
Restaurant)

0.00573 0.00287 0.05211 0.04377 0.00031 0.00396 — 0.00396 0.00396 — 0.00396 — 62.1781 62.1781 0.00550 0.00012 — 62.3506 Total 0.04276 0.02138 0.38876 0.32655 0.00233 0.02955 — 0.02955 0.02955 — 0.02955 — 463.850 463.850 0.04105 0.00087 — 465.136 Annual — — — — — — — — — — — — — — — — — —
Hotel 0.00676 0.00338 0.06144 0.05161 0.00037 0.00467 — 0.00467 0.00467 — 0.00467 — 66.5013 66.5013 0.00589 0.00013 — 66.6858 Enclose
d
Parking
with
Elevator

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 High
Turnover
(Sit
Down
Restaurant)

4.3. Area Emissions by Source
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4.3.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
——————————————————
Consum
er
Product
s

0.64273 0.64273 — — — — — — — — — — — — — — — —
Architect
ural
Coating
s

0.07630 0.07630 — — — — — — — — — — — — — — — —
Landsca
pe
Equipm
ent

0.55959 0.51643 0.02646 3.14480 0.00019 0.00559 — 0.00559 0.00422 — 0.00422 — 12.9322 12.9322 0.00054 0.00011 — 12.9789 Total 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 Daily,
Winter
(Max)
——————————————————
Consum
er
Product
s

0.64273 0.64273 — — — — — — — — — — — — — — — —
Architect
ural
Coating
s

0.07630 0.07630 — — — — — — — — — — — — — — — —
Total 0.71903 0.71903 — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Consum
er
Product
s

0.11730 0.11730 — — — — — — — — — — — — — — — —
430
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Architect
Coatings

0.01392 0.01392 — — — — — — — — — — — — — — — —
Landsca
pe
Equipm
ent

0.06995 0.06455 0.00331 0.39310 0.00002 0.00070 — 0.00070 0.00053 — 0.00053 — 1.46649 1.46649 0.00006 0.00001 — 1.47178 Total 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

4.3.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
——————————————————
Consum
er
Product
s

0.64273 0.64273 — — — — — — — — — — — — — — — —
Architect
ural
Coating
s

0.07630 0.07630 — — — — — — — — — — — — — — — —
Landsca
pe
Equipm
ent

0.64273 0.64273 — — — — — — — — — — — — — — — —
431
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Architect 0.07630 0.07630 — — — — — — — — — — — — — — — — ural
Coating
Total 0.71903 0.71903 — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Consum
er
Product
s

0.11730 0.11730 — — — — — — — — — — — — — — — —
Architect
ural
Coating
s

0.01392 0.01392 — — — — — — — — — — — — — — — —
Landsca
pe
Equipm
ent

4.4. Water Emissions by Land Use

4.4.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
——————————————————
Hotel — — — — — — — — — — — 2.96513 1.31850 4.28363 0.30501 0.00734 — 14.0963 Enclose
d
Parking
with
Elevator
— — — — — — — — — — — 0.00000 0.00850 0.00850 0.00001 <

0.000005
— 0.00888
432
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High — — — — — — — — — — — 1.00391 0.44490 1.44882 0.10327 0.00249 — 4.77107 Turnover
(Sit
Down
Restaurant)
Total — — — — — — — — — — — 3.96905 1.77190 5.74095 0.40828 0.00983 — 18.8763 Daily,
Winter
(Max)
——————————————————
Hotel — — — — — — — — — — — 2.96513 1.31850 4.28363 0.30501 0.00734 — 14.0963 Enclose
d
Parking
with
Elevator
— — — — — — — — — — — 0.00000 0.00850 0.00850 0.00001 <

0.000005
— 0.00888
High
Turnover
(Sit
Down
Restaurant)
— — — — — — — — — — — 1.00391 0.44490 1.44882 0.10327 0.00249 — 4.77107 Total — — — — — — — — — — — 3.96905 1.77190 5.74095 0.40828 0.00983 — 18.8763 Annual — — — — — — — — — — — — — — — — — —
Hotel — — — — — — — — — — — 0.49091 0.21829 0.70920 0.05050 0.00122 — 2.33381 Enclose
d
Parking
with
Elevator
— — — — — — — — — — — 0.00000 0.00141 0.00141 <

0.000005
<

0.000005
— 0.00147
High
Turnover
(Sit
Down
Restaurant)
— — — — — — — — — — — 0.16621 0.07366 0.23987 0.01710 0.00041 — 0.78990 Total — — — — — — — — — — — 0.65712 0.29336 0.95048 0.06759 0.00163 — 3.12518

4.4.2. Mitigated
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Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
——————————————————
Hotel — — — — — — — — — — — 2.96513 1.31850 4.28363 0.30501 0.00734 — 14.0963 Enclose
d
Parking
with
Elevator
— — — — — — — — — — — 0.00000 0.00850 0.00850 0.00001 <

0.000005
— 0.00888
High
Turnover
(Sit
Down
Restaurant)
— — — — — — — — — — — 1.00391 0.44490 1.44882 0.10327 0.00249 — 4.77107 Total — — — — — — — — — — — 3.96905 1.77190 5.74095 0.40828 0.00983 — 18.8763 Daily,
Winter
(Max)
——————————————————
Hotel — — — — — — — — — — — 2.96513 1.31850 4.28363 0.30501 0.00734 — 14.0963 Enclose
d
Parking
with
Elevator
— — — — — — — — — — — 0.00000 0.00850 0.00850 0.00001 <

0.000005
— 0.00888
High
Turnover
(Sit
Down
Restaurant)
— — — — — — — — — — — 1.00391 0.44490 1.44882 0.10327 0.00249 — 4.77107 Total — — — — — — — — — — — 3.96905 1.77190 5.74095 0.40828 0.00983 — 18.8763 Annual — — — — — — — — — — — — — — — — — —
Hotel — — — — — — — — — — — 0.49091 0.21829 0.70920 0.05050 0.00122 — 2.33381 434
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< — 0.00147

0.000005
<

0.000005
Enclose — — — — — — — — — — — 0.00000 0.00141 0.00141
d
Parking
with
Elevator
High
Turnover
(Sit
Down
Restaurant)
— — — — — — — — — — — 0.16621 0.07366 0.23987 0.01710 0.00041 — 0.78990 Total — — — — — — — — — — — 0.65712 0.29336 0.95048 0.06759 0.00163 — 3.12518

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
——————————————————
Hotel — — — — — — — — — — — 17.9992 0.00000 17.9992 1.79896 0.00000 — 62.9731 Enclose
d
Parking
with
Elevator
— — — — — — — — — — — 0.00000 0.00000 0.00000 0.00000 0.00000 — 0.00000 High
Turnover
(Sit
Down
Restaurant)
— — — — — — — — — — — 11.0695 0.00000 11.0695 1.10635 0.00000 — 38.7283 Total — — — — — — — — — — — 29.0687 0.00000 29.0687 2.90531 0.00000 — 101.701 Daily,
Winter
(Max)
——————————————————
435
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Hotel — — — — — — — — — — — 17.9992 0.00000 17.9992 1.79896 0.00000 — 62.9731 Enclose
d
Parking
with
Elevator
— — — — — — — — — — — 0.00000 0.00000 0.00000 0.00000 0.00000 — 0.00000 High
Turnover
(Sit
Down
Restaurant)
— — — — — — — — — — — 11.0695 0.00000 11.0695 1.10635 0.00000 — 38.7283 Total — — — — — — — — — — — 29.0687 0.00000 29.0687 2.90531 0.00000 — 101.701 Annual — — — — — — — — — — — — — — — — — —
Hotel — — — — — — — — — — — 2.97997 0.00000 2.97997 0.29784 0.00000 — 10.4259 Enclose
d
Parking
with
Elevator
— — — — — — — — — — — 0.00000 0.00000 0.00000 0.00000 0.00000 — 0.00000 High
Turnover
(Sit
Down
Restaurant)
— — — — — — — — — — — 1.83268 0.00000 1.83268 0.18317 0.00000 — 6.41192 Total — — — — — — — — — — — 4.81265 0.00000 4.81265 0.48101 0.00000 — 16.8378

4.5.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
——————————————————
Hotel — — — — — — — — — — — 17.9992 0.00000 17.9992 1.79896 0.00000 — 62.9731 436
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Enclose — — — — — — — — — — — 0.00000 0.00000 0.00000 0.00000 0.00000 — 0.00000 d
Parking
with
Elevator
High
Turnover
(Sit
Down
Restaurant)
— — — — — — — — — — — 11.0695 0.00000 11.0695 1.10635 0.00000 — 38.7283 Total — — — — — — — — — — — 29.0687 0.00000 29.0687 2.90531 0.00000 — 101.701 Daily,
Winter
(Max)
——————————————————
Hotel — — — — — — — — — — — 17.9992 0.00000 17.9992 1.79896 0.00000 — 62.9731 Enclose
d
Parking
with
Elevator
— — — — — — — — — — — 0.00000 0.00000 0.00000 0.00000 0.00000 — 0.00000 High
Turnover
(Sit
Down
Restaurant)
— — — — — — — — — — — 11.0695 0.00000 11.0695 1.10635 0.00000 — 38.7283 Total — — — — — — — — — — — 29.0687 0.00000 29.0687 2.90531 0.00000 — 101.701 Annual — — — — — — — — — — — — — — — — — —
Hotel — — — — — — — — — — — 2.97997 0.00000 2.97997 0.29784 0.00000 — 10.4259 Enclose
d
Parking
with
Elevator
— — — — — — — — — — — 0.00000 0.00000 0.00000 0.00000 0.00000 — 0.00000 High
Turnover
(Sit
Down
Restaurant)
— — — — — — — — — — — 1.83268 0.00000 1.83268 0.18317 0.00000 — 6.41192 437
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Total — — — — — — — — — — — 4.81265 0.00000 4.81265 0.48101 0.00000 — 16.8378

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
——————————————————
Hotel — — — — — — — — — — — — — — — — 44.2526 44.2526
High
Turnover
(Sit
Down
Restaurant)
— — — — — — — — — — — — — — — — 2.69818 2.69818
Total — — — — — — — — — — — — — — — — 46.9508 46.9508
Daily,
Winter
(Max)
——————————————————
Hotel — — — — — — — — — — — — — — — — 44.2526 44.2526
High
Turnover
(Sit
Down
Restaurant)
— — — — — — — — — — — — — — — — 2.69818 2.69818
Total — — — — — — — — — — — — — — — — 46.9508 46.9508
Annual — — — — — — — — — — — — — — — — — —
Hotel — — — — — — — — — — — — — — — — 7.32652 7.32652
High
Turnover
(Sit
Down
Restaurant)
— — — — — — — — — — — — — — — — 0.44671 0.44671
438
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Total — — — — — — — — — — — — — — — — 7.77324 7.77324

4.6.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
——————————————————
Hotel — — — — — — — — — — — — — — — — 44.2526 44.2526
High
Turnover
(Sit
Down
Restaurant)
— — — — — — — — — — — — — — — — 2.69818 2.69818
Total — — — — — — — — — — — — — — — — 46.9508 46.9508
Daily,
Winter
(Max)
——————————————————
Hotel — — — — — — — — — — — — — — — — 44.2526 44.2526
High
Turnover
(Sit
Down
Restaurant)
— — — — — — — — — — — — — — — — 2.69818 2.69818
Total — — — — — — — — — — — — — — — — 46.9508 46.9508
Annual — — — — — — — — — — — — — — — — — —
Hotel — — — — — — — — — — — — — — — — 7.32652 7.32652
High
Turnover
(Sit
Down
Restaurant)
— — — — — — — — — — — — — — — — 0.44671 0.44671
Total — — — — — — — — — — — — — — — — 7.77324 7.77324
439
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4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipm
ent
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
——————————————————
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
——————————————————
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.7.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipm
ent
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
——————————————————
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
——————————————————
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
440
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Total — — — — — — — — — — — — — — — — — —

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipm
ent
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
——————————————————
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
——————————————————
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.8.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipm
ent
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
——————————————————
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
——————————————————
Total — — — — — — — — — — — — — — — — — —
441
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Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipm
ent
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
——————————————————
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
——————————————————
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.9.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipm
ent
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
——————————————————
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
——————————————————
442
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Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetati
on
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
——————————————————
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
——————————————————
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
——————————————————
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
——————————————————
443
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Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
——————————————————
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
——————————————————
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
——————————————————
Subtotal — — — — — — — — — — — — — — — — — —
———————————————————
Daily,
Winter
(Max)
——————————————————
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
——————————————————
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
——————————————————
Subtotal — — — — — — — — — — — — — — — — — —
———————————————————
444
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Annual — — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
——————————————————
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
——————————————————
Subtotal — — — — — — — — — — — — — — — — — —
———————————————————

4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetati
on
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
——————————————————
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
——————————————————
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e 445
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Daily, — — — — — — — — — — — — — — — — — —
Summer
(Max)
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
——————————————————
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.6. Avoided and Sequestered Emissions by Species - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
——————————————————
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
——————————————————
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
——————————————————
Subtotal — — — — — — — — — — — — — — — — — —
———————————————————
Daily,
Winter
(Max)
——————————————————
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
446
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Sequest — — — — — — — — — — — — — — — — — —
ered
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
——————————————————
Subtotal — — — — — — — — — — — — — — — — — —
———————————————————
Annual — — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
——————————————————
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
——————————————————
Subtotal — — — — — — — — — — — — — — — — — —
———————————————————

5. Activity Data

5.1. Construction Schedule
Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description Grading Grading 6/1/2026 7/31/2026 5.00000 45.0000 —
Building Construction Building Construction 8/1/2026 9/30/2027 5.00000 304.000 — Paving Paving 10/1/2027 11/30/2027 5.00000 43.0000 —
Architectural Coating Architectural Coating 8/1/2027 11/30/2027 5.00000 87.0000 —

5.2. Off-Road Equipment
447
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5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Grading Graders Diesel Average 1.000000 6.00000 148.000 0.41000 Grading Rubber Tired Dozers Diesel Average 1.000000 6.00000 367.000 0.40000 Grading Tractors/Loaders/Back
hoes
Diesel Average 1.000000 7.00000 84.0000 0.37000
Building Construction Cranes Diesel Average 1.000000 4.00000 367.000 0.29000 Building Construction Forklifts Diesel Average 2.00000 6.00000 82.0000 0.20000 Building Construction Tractors/Loaders/Back
hoes
Diesel Average 2.00000 8.00000 84.0000 0.37000
Paving Tractors/Loaders/Back
hoes
Diesel Average 1.000000 7.00000 84.0000 0.37000
Paving Cement and Mortar
Mixers
Diesel Average 4.00000 6.00000 10.00000 0.56000
Paving Pavers Diesel Average 1.000000 7.00000 81.0000 0.42000 Paving Rollers Diesel Average 1.000000 7.00000 36.0000 0.38000 Architectural Coating Air Compressors Diesel Average 1.000000 6.00000 37.0000 0.48000

5.2.2. Mitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Grading Graders Diesel Average 1.000000 6.00000 148.000 0.41000 Grading Rubber Tired Dozers Diesel Average 1.000000 6.00000 367.000 0.40000 Grading Tractors/Loaders/Back
hoes
Diesel Average 1.000000 7.00000 84.0000 0.37000
Building Construction Cranes Diesel Average 1.000000 4.00000 367.000 0.29000 Building Construction Forklifts Diesel Average 2.00000 6.00000 82.0000 0.20000 Building Construction Tractors/Loaders/Back
hoes
Diesel Average 2.00000 8.00000 84.0000 0.37000
Paving Tractors/Loaders/Back
hoes
Diesel Average 1.000000 7.00000 84.0000 0.37000
448
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Paving Cement and Mortar
Mixers
Diesel Average 4.00000 6.00000 10.00000 0.56000
Paving Pavers Diesel Average 1.000000 7.00000 81.0000 0.42000 Paving Rollers Diesel Average 1.000000 7.00000 36.0000 0.38000 Architectural Coating Air Compressors Diesel Average 1.000000 6.00000 37.0000 0.48000

5.3. Construction Vehicles

5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Grading Worker 7.50000 18.5000 LDA,LDT1,LDT2
Grading Vendor — 10.2000 HHDT,MHDT
Grading Hauling 39.7333 20.0000 HHDT
Grading Onsite truck — — HHDT
Building Construction Worker 30.3698 18.5000 LDA,LDT1,LDT2 Building Construction Vendor 11.8514 10.2000 HHDT,MHDT
Building Construction Hauling 0.00000 20.0000 HHDT
Building Construction Onsite truck — — HHDT
Paving Worker 17.5000 18.5000 LDA,LDT1,LDT2
Paving Vendor — 10.2000 HHDT,MHDT
Paving Hauling 0.00000 20.0000 HHDT
Paving Onsite truck — — HHDT
Architectural Coating Worker 6.07396 18.5000 LDA,LDT1,LDT2 Architectural Coating Vendor — 10.2000 HHDT,MHDT
Architectural Coating Hauling 0.00000 20.0000 HHDT
Architectural Coating Onsite truck — — HHDT

5.3.2. Mitigated
449
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Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Grading Worker 7.50000 18.5000 LDA,LDT1,LDT2
Grading Vendor — 10.2000 HHDT,MHDT
Grading Hauling 39.7333 20.0000 HHDT
Grading Onsite truck — — HHDT
Building Construction Worker 30.3698 18.5000 LDA,LDT1,LDT2 Building Construction Vendor 11.8514 10.2000 HHDT,MHDT
Building Construction Hauling 0.00000 20.0000 HHDT
Building Construction Onsite truck — — HHDT
Paving Worker 17.5000 18.5000 LDA,LDT1,LDT2
Paving Vendor — 10.2000 HHDT,MHDT
Paving Hauling 0.00000 20.0000 HHDT
Paving Onsite truck — — HHDT
Architectural Coating Worker 6.07396 18.5000 LDA,LDT1,LDT2 Architectural Coating Vendor — 10.2000 HHDT,MHDT
Architectural Coating Hauling 0.00000 20.0000 HHDT
Architectural Coating Onsite truck — — HHDT

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies
Non-applicable. No control strategies activated by user.

5.5. Architectural Coatings
Phase Name Residential Interior Area
Coated (sq ft)
Residential Exterior Area
Coated (sq ft)
Non-Residential Interior Area
Coated (sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
Architectural Coating 0.00000 0.00000 45,051.0 15,017.0 —

5.6. Dust Mitigation
450
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5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (Cubic
Yards)
Material Exported (Cubic
Yards)
Acres Graded (acres) Material Demolished (sq. ft.) Acres Paved (acres) Grading — 14,300.0 33.7500 0.00000 0.00000
Paving 0.00000 0.00000 0.00000 0.00000 0.00000

5.6.2. Construction Earthmoving Control Strategies
Non-applicable. No control strategies activated by user.

5.7. Construction Paving
Phase Name Land Use Area Paved (acres) % Asphalt
Paving Hotel 0.00000 0%
Paving Enclosed Parking with Elevator 0.00000 100%
Paving High Turnover (Sit Down Restaurant) 0.00000 0%

5.8. Construction Electricity Consumption and Emissions Factors kWh per Year and Emission Factor (lb/MWh)
Year kWh per Year CO2 CH4 N2O
2026 0.00000 588.983 0.03300 0.00400
2027 0.00000 588.983 0.03300 0.00400

5.9. Operational Mobile Sources

5.9.1. Unmitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year Hotel 487.024 487.024 487.024 177,764 5,898.90 5,898.90 5,898.90 2,153,100 Enclosed Parking
with Elevator

0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 451
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High Turnover (Sit
Down Restaurant)
1,144.00 1,144.00 1,144.00 417,561 13,856.3 13,856.3 13,856.3 5,057,552

5.9.2. Mitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year Hotel 487.024 487.024 487.024 177,764 5,898.90 5,898.90 5,898.90 2,153,100 Enclosed Parking
with Elevator

0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 High Turnover (Sit
Down Restaurant)
1,144.00 1,144.00 1,144.00 417,561 13,856.3 13,856.3 13,856.3 5,057,552

5.10. Operational Area Sources

5.10.1. Hearths
Land Use Hearth Type Unmitigated (number) Mitigated (number) Hotel Wood Fireplaces 0 0
Hotel Gas Fireplaces 0 0
Hotel Propane Fireplaces 0 0
Hotel Electric Fireplaces 0 0
Hotel No Fireplaces 0 0
Hotel Conventional Wood Stoves 0 0
Hotel Catalytic Wood Stoves 0 0
Hotel Non-Catalytic Wood Stoves 0 0
Hotel Pellet Wood Stoves 0 0
Enclosed Parking with Elevator Wood Fireplaces 0 0
Enclosed Parking with Elevator Gas Fireplaces 0 0
Enclosed Parking with Elevator Propane Fireplaces 0 0
Enclosed Parking with Elevator Electric Fireplaces 0 0
Enclosed Parking with Elevator No Fireplaces 0 0
452
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Enclosed Parking with Elevator Conventional Wood Stoves 0 0 Enclosed Parking with Elevator Catalytic Wood Stoves 0 0 Enclosed Parking with Elevator Non-Catalytic Wood Stoves 0 0 Enclosed Parking with Elevator Pellet Wood Stoves 0 0
High Turnover (Sit Down Restaurant) Wood Fireplaces 0 0 High Turnover (Sit Down Restaurant) Gas Fireplaces 0 0
High Turnover (Sit Down Restaurant) Propane Fireplaces 0 0 High Turnover (Sit Down Restaurant) Electric Fireplaces 0 0 High Turnover (Sit Down Restaurant) No Fireplaces 0 0
High Turnover (Sit Down Restaurant) Conventional Wood Stoves 0 0 High Turnover (Sit Down Restaurant) Catalytic Wood Stoves 0 0 High Turnover (Sit Down Restaurant) Non-Catalytic Wood Stoves 0 0 High Turnover (Sit Down Restaurant) Pellet Wood Stoves 0 0

5.10.2. Architectural Coatings
Residential Interior Area Coated (sq
ft)
Residential Exterior Area Coated (sq
ft)
Non-Residential Interior Area Coated
(sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)

0.00000 0.00000 45,051.0 15,017.0 —

5.10.3. Landscape Equipment
Season Unit Value
Snow Days day/yr 0.00000
Summer Days day/yr 250.000

5.10.4. Landscape Equipment - Mitigated
Season Unit Value
Snow Days day/yr 0.00000
453
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Summer Days day/yr 250.000

5.11. Operational Energy Consumption

5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) Hotel 332,572 45.0990 0.0330 0.0040 1,253,323
Enclosed Parking with
Elevator
156,055 45.0990 0.0330 0.0040 0.00000
High Turnover (Sit Down
Restaurant)
61,484.9 45.0990 0.0330 0.0040 194,012

5.11.2. Mitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) Hotel 332,572 45.0990 0.0330 0.0040 1,253,323
Enclosed Parking with
Elevator
156,055 45.0990 0.0330 0.0040 0.00000
High Turnover (Sit Down
Restaurant)
61,484.9 45.0990 0.0330 0.0040 194,012

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated
Land Use Indoor Water (gal/year) Outdoor Water (gal/year) Hotel 1,547,373 25,920.7
Enclosed Parking with Elevator 0.00000 12,960.4
High Turnover (Sit Down Restaurant) 523,899 6,480.19
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5.12.2. Mitigated
Land Use Indoor Water (gal/year) Outdoor Water (gal/year) Hotel 1,547,373 25,920.7
Enclosed Parking with Elevator 0.00000 12,960.4
High Turnover (Sit Down Restaurant) 523,899 6,480.19

5.13. Operational Waste Generation

5.13.1. Unmitigated
Land Use Waste (ton/year) Cogeneration (kWh/year)
Hotel 33.3975 0.00000
Enclosed Parking with Elevator 0.00000 0.00000
High Turnover (Sit Down Restaurant) 20.5394 0.00000

5.13.2. Mitigated
Land Use Waste (ton/year) Cogeneration (kWh/year)
Hotel 33.3975 0.00000
Enclosed Parking with Elevator 0.00000 0.00000
High Turnover (Sit Down Restaurant) 20.5394 0.00000

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated
Land Use Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced Hotel Household
refrigerators and/or
freezers
R-134a 1,430.00 0.00000 0.60000 0.00000 1.000000
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Hotel Other commercial A/C R-410A 2,088.00 1.80000 4.00000 4.00000 18.0000 and heat pumps
Hotel Walk-in refrigerators
and freezers
R-404A 3,922.00 0.00040 7.50000 7.50000 20.0000
High Turnover (Sit
Down Restaurant)
Household
refrigerators and/or
freezers
R-134a 1,430.00 0.00000 0.60000 0.00000 1.000000
High Turnover (Sit
Down Restaurant)
Other commercial A/C
and heat pumps
R-410A 2,088.00 1.80000 4.00000 4.00000 18.0000
High Turnover (Sit
Down Restaurant)
Walk-in refrigerators
and freezers
R-404A 3,922.00 0.00040 7.50000 7.50000 20.0000

5.14.2. Mitigated
Land Use Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced Hotel Household
refrigerators and/or
freezers
R-134a 1,430.00 0.00000 0.60000 0.00000 1.000000
Hotel Other commercial A/C
and heat pumps
R-410A 2,088.00 1.80000 4.00000 4.00000 18.0000
Hotel Walk-in refrigerators
and freezers
R-404A 3,922.00 0.00040 7.50000 7.50000 20.0000
High Turnover (Sit
Down Restaurant)
Household
refrigerators and/or
freezers
R-134a 1,430.00 0.00000 0.60000 0.00000 1.000000
High Turnover (Sit
Down Restaurant)
Other commercial A/C
and heat pumps
R-410A 2,088.00 1.80000 4.00000 4.00000 18.0000
High Turnover (Sit
Down Restaurant)
Walk-in refrigerators
and freezers
R-404A 3,922.00 0.00040 7.50000 7.50000 20.0000

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated
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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
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres

5.18.1.2. Mitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres

5.18.1.2. Mitigated
Biomass Cover Type Initial Acres Final Acres

5.18.2. Sequestration
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5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)

5.18.2.2. Mitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)

6. Climate Risk Detailed Report

6.1. Climate Risk Summary
Cal-Adapt midcentury 2040–2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG emissions will continue to rise strongly through 2050 and then plateau around 2100.

Climate Hazard Result for Project Location Unit
Temperature and Extreme Heat 8.65000 annual days of extreme heat Extreme Precipitation 3.10000 annual days with precipitation above 20 mm Sea Level Rise — meters of inundation depth
Wildfire 0.00000 annual hectares burned
Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if received over a full day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (Radke et al., 2017, CEC-500-2017-008), and consider inundation location and depth for the San Francisco Bay, the Sacramento-San Joaquin River Delta and California coast resulting different increments of sea level rise coupled with extreme storm events. Users may select from four scenarios to view the range in potential inundation depth for the grid cell. The four scenarios are: No rise, 0.5 meter, 1.0 meter, 1.41 meters Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider historical data of climate, vegetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

6.2. Initial Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 1 0 0 N/A
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Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise 1 0 0 N/A
Wildfire 1 0 0 N/A
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation 0 0 0 N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures.

6.3. Adjusted Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 1 1 1 2
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise 1 1 1 2
Wildfire 1 1 1 2
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation 1 1 1 2
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures.

6.4. Climate Risk Reduction Measures
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7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores
The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.

Indicator Result for Project Census Tract
Exposure Indicators —
AQ-Ozone 60.6596
AQ-PM 47.4300
AQ-DPM 81.2570
Drinking Water 35.0818
Lead Risk Housing 13.4846
Pesticides 0.00000
Toxic Releases 18.6047
Traffic 90.1625
Effect Indicators —
CleanUp Sites 58.1747
Groundwater 0.00000
Haz Waste Facilities/Generators 2.51489
Impaired Water Bodies 77.2995
Solid Waste 79.9542
Sensitive Population —
Asthma 11.0793
Cardio-vascular 37.3006
Low Birth Weights 1.92456
Socioeconomic Factor Indicators —
Education 13.1106
Housing 43.2826
Linguistic 13.3036
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Poverty 20.3769
Unemployment 21.1088

7.2. Healthy Places Index Scores
The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

Indicator Result for Project Census Tract
Economic —
Above Poverty —
Employed —
Median HI —
Education —
Bachelor's or higher —
High school enrollment —
Preschool enrollment —
Transportation —
Auto Access —
Active commuting —
Social —
2-parent households —
Voting —
Neighborhood —
Alcohol availability —
Park access —
Retail density —
Supermarket access —
Tree canopy —
Housing —
Homeownership —
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Housing habitability —
Low-inc homeowner severe housing cost burden —
Low-inc renter severe housing cost burden —
Uncrowded housing —
Health Outcomes —
Insured adults —
Arthritis 0.0
Asthma ER Admissions 88.9
High Blood Pressure 0.0
Cancer (excluding skin) 0.0
Asthma 0.0
Coronary Heart Disease 0.0
Chronic Obstructive Pulmonary Disease 0.0
Diagnosed Diabetes 0.0
Life Expectancy at Birth 0.0
Cognitively Disabled 80.8
Physically Disabled 7.0
Heart Attack ER Admissions 85.1
Mental Health Not Good 0.0
Chronic Kidney Disease 0.0
Obesity 0.0
Pedestrian Injuries 0.0
Physical Health Not Good 0.0
Stroke 0.0
Health Risk Behaviors —
Binge Drinking 0.0
Current Smoker 0.0
No Leisure Time for Physical Activity 0.0
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Climate Change Exposures —
Wildfire Risk 0.0
SLR Inundation Area 73.3
Children 47.4
Elderly 2.0
English Speaking 0.0
Foreign-born 0.0
Outdoor Workers 75.6
Climate Change Adaptive Capacity —
Impervious Surface Cover 35.3
Traffic Density 0.0
Traffic Access 23.0
Other Indices —
Hardship 0.0
Other Decision Support —
2016 Voting 0.0

7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a) 15.0000 Healthy Places Index Score for Project Location (b) —
Project Located in a Designated Disadvantaged Community (Senate Bill 535) No Project Located in a Low-Income Community (Assembly Bill 1550) No Project Located in a Community Air Protection Program Community (Assembly Bill 617) No a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

7.4. Health & Equity Measures
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No Health & Equity Measures selected.

7.5. Evaluation Scorecard
Health & Equity Evaluation Scorecard not completed.

7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.

8. User Changes to Default Data

8.1. Justifications
Screen Justification
Land Use The proposed Hanson Hotel involves the development of a three-story, 61-room boutique hotel on a 32,030 square-foot (0.8 acre) vacant parcel. Conservatively 3,500 square feet of landscaping is added.

Construction: Construction Phases Based on the construction questionnaire Operations: Vehicle Data Based on the San Clemente 1801 N. El Camino Real - VMT Screening Assessment, dated February 2, 2025. High Turnover trips account for trips from both the Fine Dining and Café components of the project.

8.3. Land Use
Model Parameter Units Default Value New Value
Lot Area acre 2.03333 0.80000
Building Area sq. ft 88,572.0 28,308.0
Landscape Area sq. ft — 2,000.00
Lot Area acre 0.93600 0.00000
Building Area sq. ft 41,600.0 42,275.0
Landscape Area sq. ft — 1,000.000
Lot Area acre 0.03962 0.00000
Landscape Area sq. ft — 500.000
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8.4. Construction

8.4.1. Construction Phases
Phase Type Phase Name Model Parameter Default Value New Value Grading Grading Start Date 6/18/2026 6/1/2026
Grading Grading End Date 6/20/2026 7/31/2026
Grading Grading Work Days per Phase 2.00000 45.0000
Building Construction Building Construction Start Date 6/21/2026 8/1/2026 Building Construction Building Construction End Date 11/8/2026 9/30/2027 Building Construction Building Construction Work Days per Phase 100.0000 304.000 Paving Paving Start Date 11/9/2026 10/1/2027
Paving Paving End Date 11/16/2026 11/30/2027
Paving Paving Work Days per Phase 5.00000 43.0000
Architectural Coating Architectural Coating Start Date 11/17/2026 8/1/2027 Architectural Coating Architectural Coating End Date 11/24/2026 11/30/2027 Architectural Coating Architectural Coating Work Days per Phase 5.00000 87.0000

8.5. Operations

8.5.1. Mobile Sources

8.5.1.1. Vehicle Data
Land Use Model Parameter Units Default Value New Value
Hotel Weekday Trip Rate size/day 8.36000 7.98400
Hotel Saturday Trip Rate size/day 8.19000 7.98400
Hotel Sunday Trip Rate size/day 5.95000 7.98400
High Turnover (Sit Down Restaurant) Weekday Trip Rate size/day 112.180 662.805 High Turnover (Sit Down Restaurant) Saturday Trip Rate size/day 122.400 662.805 465
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High Turnover (Sit Down Restaurant) Sunday Trip Rate size/day 142.640 662.805 High Turnover (Sit Down Restaurant) Weekday Primary Trip % 33.3500 100.0000 High Turnover (Sit Down Restaurant) Weekday Divert Trip % 23.6500 0.00000 High Turnover (Sit Down Restaurant) Weekday Pass-By Trip % 43.0000 0.00000 466
Hanson Hotel Energy Calculations
Constrution On-Road (Mobile) Fuel Consumption
Phase Phase Length
(# days) # Worker Trips Worker Trip Length Total VMT Fuel Consumption Factor (Miles/Gallon/Day) Total Fuel Consumption (gallon) Grading 45 7.5 18.5 6,244 251
Building Construction 304 754.56486 18.5 4,243,673 170,409 Paving 43 17.5 18.5 13,921 559
Architectural Coating 87 150.912972 18.5 242,894 9,754
180,972.60
Phase Phase Length
(# days) # Vendor Trips Vendor Trip Length Total VMT Fuel Consumption Factor (Miles/Gallon/Day) Total Fuel Consumption (gallon)
Grading 45 0 10.2 0 0
Building Construction 304 13.04 10.2 40,434 4,846
Paving 43 0 10.2 0 0
Architectural Coating 87 0 10.2 0 0
4,846.00
Phase Phase Length
(# days) # Hauling Trips Hauling Trip Length Total VMT Fuel Consumption Factor (Miles/Gallon/Day)1 Total Fuel Consumption (gallon)
Grading 45 39.733 20 35,760 4,286
Building Construction 304 0 20 0 0
Paving 43 0 20 0 0
Architectural Coating 87 0 20 0 0
4,285.77
190,104.37
1,056,094,532

0.0180%
Total Construction On-Road (Mobile) Fuel Consumption (gallon)

WORKER TRIPS

VENDOR TRIPS

HAULING TRIPS

24.90284233

8.343886151

8.343886151
Hauling Trips Total
Vendor Trips Total
Worker Trips Total
Source: Refer to CalEEMod outputs for assumptions used in this analysis.

Notes:

1. Countywide operational fuel consumption, off-road construction equipment diesel fuel consumption, and on-road fuel consumption are from CARB's EMFAC2021.

Percentage Increase Countywide
Countywide On-Road (Mobile) Fuel Consumption (2026) (gallon) 1 467
Hanson Hotel Energy Calculations
Construction Off-Road (Equipment) Fuel Consumption
Phase Name Offroad Equipment Type Amount Usage
Hours
Horse
Power
Load
Factor
Fuel Consumption
Rate (gallon/hour)1
Duration (total
hours/day) # days Total Fuel Consumption (gallon)
Grading Graders 1 6 148 0.41 2.43 6 44 640.78
Grading Rubber Tired Dozers 1 6 367 0.4 5.87 6 44 1,550.21 Grading Tractors/Loaders/Backhoes 1 7 84 0.37 1.24 7 44 382.91 Building Construction Cranes 1 4 367 0.29 4.26 4 88 1,498.53 Building Construction Forklifts 2 6 82 0.2 0.66 12 88 692.74 Building Construction Tractors/Loaders/Backhoes 2 8 84 0.37 1.24 16 88 1,750.43 Paving Tractors/Loaders/Backhoes 1 7 84 0.37 1.24 7 88 765.81 Paving Cement and Mortar Mixers 4 6 10 0.56 0.22 24 242 1,300.99 Paving Pavers 1 7 81 0.42 1.36 7 242 2,305.20
Paving Rollers 1 7 36 0.38 0.55 7 242 926.96
Architectural Coating Air Compressors 1 6 37 0.48 0.71 6 242 1,031.50 12,846.05
18,350,502.68

0.0700%
Where:

Fuel Consumption Factor for a diesel engine is 0.04 gallons per horsepower per hour (gal/hp/hr) and a gasoline engine is 0.06 gal/hp/hr.

Total Construction Off-Road Fuel Consumption (gallon)
Notes:

1. Fuel Consumption Rate = Horsepower x Load Factor x Fuel Consumption Factor Countywide Off-Road Fuel Consumption (2026) (gallon) 2
Source: Refer to CalEEMod outputs for assumptions used in this analysis.

Percentage Increase Countywide

2. Countywide operational fuel consumption, off-road construction equipment diesel fuel consumption, and on-road fuel consumption are from CARB's OFFROAD2021 (v1.0.5) Emissions Inventory. 468
Hanson Hotel Energy Calculations
Operation On-Road (Mobile) Fuel Consumption
Vehicle Type Percent of Vehicle Trips1 Daily Trips2 Annual Vehicle Miles Traveled
Average Fuel Economy
(miles per gallon)3 Total Annual Fuel Consumption (gallon)4 Passenger Cars 0.49 807 3,567,027 22 162,138
Light/Medium Trucks 0.48 781 3,450,759 17.3 199,466
Heavy Trucks/Other 0.03 44 193,372 6.4 30,214
Total 1.00 1,631 7,211,158 -- 391,818
391,818
1,012,273,716

0.0387%
Source: Refer to CalEEMod outputs for assumptions used in this analysis.

Notes:

1. Percent of Vehicle Trip distribution based on trip characteristics within the CalEEMod model.

2. Daily Trips taken from Traffic Study

3. Average fuel economy derived from the Department of Transportation.

Total Operational On-Road (Mobile) Fuel Consumption (gallon)

4. Total Daily Fuel Consumption calculated by dividing the daily VMT by the average fuel economy (i.e., VMT/Average Fuel Economy).

5. Countywide operational fuel consumption, off-road construction equipment diesel fuel consumption, and on-road fuel consumption are from CARB's EMFAC2021.

Countywide On-Road Fuel Consumption (2027) (gallon) 5
Percentage Increase Countywide
469
Hanson Hotel Energy Calculations
Operational Electricty and Natural Gas Usage
(kWh/yr) (MWh/yr) (kBTU/yr) (Therms/yr)
Hotel 332,572 333 1,253,323 12,533
Enclosed Parking with 156,055 156 00
High Turnover (Sit Down Restaurant) 61,485 61 194,012 1,940 Total 550,112 550 1,447,335 14,473
Project Annual Energy Consumption Orange County Annual Energy Consumption (2024)1,2 Percentage Increase Countywide
550 19,225,145 0.0029%
14,473 338,651,335 0.0043%
Source: Refer to CalEEMod outputs for assumptions used in this analysis.

1. County annual electricity consumption data source: California Energy Commission, Electricity Consumption, https://www.energy.ca.gov/data-reports/energy-almanac/california-electricity-data/california-energy-consumption-dashboards-0

2. County annual 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-consumption-dashboards-1 Land Use
Natural Gas (therms)
Source: Refer to CalEEMod outputs for assumptions used in this analysis.

Energy Type
Notes:

Electricity Use Natural Gas Use
Electricity (MWh)
470

APPENDIX C
Biological Resources Assessment
471
This document is designed for double-sided printing to conserve natural resources. 472
5 HuƩon Centre Drive, Suite 500 | Santa Ana, CA 92707
Office: 949-472-3505 | Fax: 949-472-8373
March 12, 2026 JN 210935

CITY OF SAN CLEMENTE
John Ciampa, Contract Planner
910 Calle Negocio
San Clemente, CA 92673
SUBJECT: Biological Resources Assessment for the Hanson Hotel Project in San Clemente, Orange County, California
Dear John Ciampa,
Michael Baker International is pleased to submit this technical letter report documenting the results of a biological resources assessment for the proposed Hanson Hotel project (Project) located in San Clemente, Orange County, California. The Project proposes to develop the subject property into a hotel. This report is intended to satisfy the requirements of the California Environmental Quality Act (CEQA) Section 15183: “Projects Consistent with a Community Plan, General Plan, or Zoning” and Measure 5.3-1 of the City of San Clemente’s Centennial General Plan Environmental Impact Report (General Plan EIR), which partially states that:

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.

1.0 PROJECT LOCATION
The approximately 0.74-acre Project site is located at 1801 North El Camino Real, San Clemente, California, 92672 (Attachment A, Figure 1, Regional Vicinity and Figure 2, Survey Area). The Project site is north and east of North El Camino Real, west of East Avenida Pico, and south of Pico Park and is within Section 32, Township 08 South, Range 07 West of the Dana Point 7.5- minute United States Geological Survey (USGS) topographic quadrangle map. The Project site is located within the boundaries of the Orange County Southern Subregion Habitat Conservation 473
Biological Resources Assessment March 12, 2026
Hanson Hotel Project Page 2
Plan (HCP) but is not within the Southern Reserve or in an area designated as Supplemental Open Space.

2.0 EXISTING SITE CONDITIONS
The Project site is located in the City of San Clemente less than 500 feet from the beach. The Project site is disturbed but undeveloped and is adjacent to major roadways to the east and south, a mostly-covered concrete channel to the north, and a commercial building to the west. The greater survey area to the north and west consists primarily of undeveloped open space associated with the Sea Summit Trails system. Elevations within the Project site range from approximately 25 feet above mean sea level in the center of the site to 35 feet above mean sea level along its eastern edge, running alongside Avenida Pico. Vegetation on-site is periodically mowed and mostly cleared and exhibited different stages of growth over time during various field surveys conducted for this project. Refer to Attachment B for representative photographs taken throughout the Project site.

The Web Soil Survey shows that the survey area supports six soil types (Attachment A, Figure 3, USDA Soils Map):
x 100: Alo clay, 9-15 percent slopes
x 102: Alo clay, 30-50 percent slopes, warm MAAT, MLRA 20 x 115: Beaches
x 134: Calleguas clay loam, 50-75 percent slopes, eroded x 177: Myford sandy loam, 9-30 percent slopes, eroded
x 209: Sorrento clay loam, 2-9 percent slopes, warm MAAT, MLRA 19

3.0 METHODS

3.1 Literature Review
Prior to conducting the field survey, Michael Baker conducted a thorough literature review and records search to characterize existing site conditions and assess the potential for special-status1 biological resources to occur that might pose a constraint to Project implementation. A query of the California Natural Diversity Database (CNDDB; CNDDB 2026) and California Native Plant Society (CNPS) Online Inventory of Rare and Endangered Plants of California (CNPS 2026) was conducted to obtain a list of special-status plant and wildlife species occurrence records within the US Geological Survey (USGS) Dana Point and San Clemente, California 7.5-minute quadrangle maps. The US Fish and Wildlife Service (USFWS) IPaC online database was also reviewed to identify special-status species and other resources, such as Critical Habitat, known or expected to occur on the Project site or within the immediate vicinity (USFWS 2026a). Due to the results listed in the IPaC report, the USFWS Critical Habitat for Threatened & Endangered Species mapping tool (USFWS 2026b) was accessed to determine the location of designated 1 Special-status refers to plant and wildlife species that are federal or state-listed, proposed, or candidates; plant species that have been designated a California Rare Plant Rank 1, 2, or 4 by the California NaƟve Plant Society; wildlife species that are designated by the California Department of Fish and Wildlife as Fully Protected, or Species of Special Concern; and other state or locally rare vegetaƟon communiƟes. 474
Biological Resources Assessment March 12, 2026
Hanson Hotel Project Page 3
Critical Habitat in relation to the Project site. Other sources of information about the Project site and surrounding area include the US Department of Agriculture (USDA), Natural Resources Conservation Service (NRCS) Web Soil Survey (USDA NRCS 2026) and the USFWS National Wetlands Inventory (USFWS 2026c). All the information obtained informed our understanding of the Project site and assisted with the field survey and subsequent analysis. The results presented in this report provide a detailed assessment of the suitability of the habitat on-site to support special-status plant and wildlife species and other sensitive natural resources.

3.2 Habitat Assessment/Field Survey
The Project site was previously visited by Michael Baker biologist Ryan Winkleman on April 2, 2025 to evaluate general biological resources and determine if the proposed development met the criteria for a Class 32 CEQA exemption. Due to access restrictions, the site was only viewable from the public right-of-way (sidewalk) during the April survey and was not directly entered.

Michael Baker biologists Ryan Winkleman and Trina Ming conducted a second field survey of the Project site on September 25, 2025 in response to a public comment letter disputing the April 2025 survey findings, during which direct access onto the site was obtained. Mr. Winkleman and Ms. Ming conducted a third and final field survey on December 8, 2025 to assess biological resources in the immediate Project vicinity, as required by MMP Measure 3-1. The area evaluated in December 2025 included the Project site and a 300-foot buffer (survey area), but it should be noted that due to right-of-access issues, the buffer outside of the Project site could not be directly accessed and was instead evaluated from the public right-of-way including adjacent sidewalks and the fenceline of Pico Park, from trails within the adjacent Sea Summit, and from within the Project site.

During all three field surveys, Michael Baker biologists evaluated vegetation communities and land covers based on the descriptions of terrestrial vegetation classification systems described in A Manual of California Vegetation (Sawyer et al. 2009). In addition, site characteristics such as soil condition, topography, hydrology, anthropogenic disturbances, indicator species, condition of on-site vegetation communities, and the presence of potentially regulated jurisdictional features were noted. A formal aquatic resources delineation was not conducted during any of the three site visits. Michael Baker used geographic information systems (GIS) software to digitize the mapped vegetation communities and overlayed the data onto an aerial photograph to further analyze existing conditions and quantify the acreages of each vegetation community on-site.

All plant and wildlife species detected during the field surveys were recorded in field notebooks.

Plant species observed were identified by visual characteristics and morphology in the field while unusual and less familiar plant species were photographed and later identified using taxonomic guides. Plant species nomenclature and taxonomy follow The Jepson Manual: Vascular Plants of California, second edition (Baldwin et al. 2012) and scientific names are provided immediately following common names of plant species (first reference only). Wildlife detections were made through aural and visual detection, as well as observation of sign including scat, trails, tracks, burrows, and nests. Field guides used to assist with identification of species during the field survey included The Sibley Guide to Birds (Sibley 2014) for birds, A Field Guide to Western Reptiles and Amphibians (Stebbins 2003) for herpetofauna, and A Field Guide to Mammals of North America (Reid 2006) for mammals. Wildlife species taxonomy follows the North American Butterfly 475
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Association (NABA, NABA 2024) for butterflies, the Society for the Study of Amphibians and Reptiles (Nicholson 2025) for herpetofauna, the American Ornithological Society for birds (Chesser et al. 2023), and Wilson and Reeder (2005) for mammals. Scientific names are provided immediately following common names of wildlife species (first reference only).

The potential for special-status species to occur in the survey area was evaluated based on each species' known geographic distribution and elevation range; species-specific habitat requirements (e.g., vegetation communities/land covers, soils, hydrology, slope/aspect, and other requirements); life history traits (e.g., disturbance tolerance); and Michael Baker biologists’ expertise, knowledge, and best professional judgement. Current and historic records of species identified during the literature review were also considered during the analysis; however, a species' potential to occur determination was not solely based on the age or location of these previously documented records. The potential to occur categories used in this analysis are defined as follows:
x Present: The species was observed or detected within the study area during 2025 surveys. x Expected: The study area is within the known geographic distribution and elevation range of the species, there is high quality suitable habitat (considering vegetation, soils, and other factors) is present, and there is viable landscape connectivity to a local, known extant population(s) or sighting(s) within the study area.
x Moderate: The study area is within the known geographic distribution and elevation range of the species, there is moderate to low quality suitable habitat (considering vegetation, soils, and other factors), and there is limited or no landscape connectivity to a local, known, extant population.
x Not Expected: The study area is outside the known geographic distribution and elevation range of the species, there is marginal to no suitable habitat, and there is no connectivity to known, extant populations.
x Absent: The species was not detected during focused or agency-approved protocol surveys.

4.0 RESULTS
The Project site was previously visited by Michael Baker biologists on April 2 and September 25, 2025 Michael Baker biologists Ryan Winkleman and Trina Ming conducted a third survey on December 8, 2025 between 0923 and 1056 hours to document current and existing conditions within the Project site and the 300-foot buffer. Weather conditions during the final survey were sunny with temperatures ranging from 62 to 74 degrees Fahrenheit with wind speeds ranging from 0 to 1 miles per hour.

4.1 Vegetation Communities and Land Covers
The survey area supports the following vegetation communities and land cover types: California sagebrush - (purple sage) scrub, disturbed California sagebrush - (purple sage) scrub, coyote brush scrub, disturbed coast prickly pear scrub, disturbed Menzies’s golden bush scrub, quailbush scrub, disturbed quailbush scrub, disturbed, and developed land as summarized in Table 1, 476
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Vegetation Communities and Land Cover Types, and depicted in Attachment A, Figure 4, Vegetation Communities and Land Cover Types.

TABLE 1. VEGETATION COMMUNITIES AND LAND COVER TYPES
Vegetation Community/Land Cover Project Site
(Acres)
Survey Area
(Acres)
California sagebrush - (purple sage) scrub - 1.16
Disturbed California sagebrush - (purple
sage) scrub - 0.24
Coyote brush scrub - 0.83
Disturbed coast prickly pear scrub - 0.41
Disturbed Menzies’s golden bush scrub 0.36 -
Quailbush scrub 0.14 -
Disturbed quailbush scrub - 0.30
Disturbed 0.25 0.45
Developed - 7.97
TOTAL 0.75* 11.36
*This total is slightly higher than the official acreage due to rounding.

California Sagebrush - (Purple Sage) Scrub
The California sagebrush - (purple sage) scrub (Artemisia californica –[Salvia leucophylla] shrubland alliance, Artemisia californica association) vegetation community was located within the western portion of the survey area. This vegetation community consisted of a mixture of California sagebrush (Artemisia californica), big saltbush (Atriplex lentiformis), coyote brush (Baccharis pilularis), and lemonade berry (Rhus integrifolia).

Disturbed California Sagebrush - (Purple Sage) Scrub
The disturbed California sagebrush - (purple sage) scrub (Disturbed Artemisia californica –[Salvia leucophylla] shrubland alliance, Artemisia californica association) vegetation community was located within the western portion of the survey area. This vegetation community consisted of a mixture of native shrub species including California sagebrush, big saltbush, bush sunflower (Encelia californica), box-thorn (Lycium sp.), coastal goldenbush (Isocoma menziesii), coast prickly pear (Opuntia littoralis), coast cholla (Cylindropuntia prolifera), and California buckwheat (Eriogonum fasciculatum). Portions of this vegetation community were disturbed, consisting of non-native coppery mesemb (Malephora crocea) and bare areas. 477
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Coyote Brush Scrub
The coyote brush scrub (Baccharis pilularis shrubland alliance, Baccharis pilularis association) vegetation community was present in the northern section of the survey area. This vegetation community was dominated by coyote brush with other native shrubs in lower quantities including big saltbush, coast goldenbush, mule fat (Baccharis salicifolia), California sagebrush, and coast cholla.

Disturbed Coast Prickly Pear Scrub
The disturbed coast prickly pear scrub (disturbed Opuntia littoralis - Opuntia oricola - Cylindropuntia prolifera shrubland alliance, Cylindropuntia prolifera - mixed coastal scrub association) vegetation community was located within the central portion of the survey area.

Dominant vegetation coverage in this community consisted of coast cholla with other native shrubs present including big saltbush, bush sunflower, California sagebrush, box-thorn, and coast prickly pear. Portions of the vegetation community consisted of non-native coppery mesemb and bare ground with disturbance noted on the eastern edge of this vegetation community. This vegetation community is designated as a sensitive community by the California Department of Fish and Wildlife (CDFW), but it does not have a specific sensitivity ranking.

Disturbed Menzies’s Golden Bush Scrub
The disturbed Menzies’s golden bush scrub (Disturbed Isocoma menziesii shrubland alliance, Isocoma menziesii association) vegetation community was located within the Project site. This area was previously maintained and has since revegetated primarily with coastal goldenbush and coyote brush providing a high component of native cover. Additional species noted include small individuals of big saltbush and stinkwort (Dittrichia graveolens). A large component of this vegetation community consisted of bare ground and trash present surrounding native shrubs. This vegetation community is designated as a sensitive “S3” community by the CDFW, indicating that mitigation for its loss may be necessary.

Quailbush Scrub
The quailbush scrub (Atriplex lentiformis shrubland alliance, Atriplex lentiformis association) vegetation community was located within the Project site along the northern and eastern edges.

Predominant vegetation coverage consisted of big saltbush with a smaller quantity of coyote brush. Native thatch was present between native shrubs.

Disturbed Quailbush Scrub
The disturbed quailbush scrub (disturbed Atriplex lentiformis shrubland alliance, Atriplex lentiformis association) vegetation community was located in the central portion of the survey area. A majority of the land cover within this vegetation community consisted of bare ground intermixed with scattered big saltbush, coyote brush, and coast goldenbush shrubs. 478
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Disturbed
The disturbed land was present in the southwest corner of the Project site as well as in an open lot in the southwest section of the survey area.

Developed
The developed land cover was present throughout the survey area and was associated with commercial development, North El Camino Real, East Avenida Pico, and a concreted portion of Segunda Deshecha Cañada.

4.2 General Floral Inventory
A total of 25 species of native or naturalized plants, 18 native (72 percent) and 7 non-native (28 percent), were recorded on-site. Attachment C, Species Compendiums, contains a list of observed plant species.

4.3 General Wildlife Inventory
A total of 23 wildlife species, all birds, were observed during the field survey, 21 native (91 percent) and 2 non-native (9 percent). The most commonly occurring birds during the two field surveys included yellow-rumped warbler (Setophaga coronata), white-crowned sparrow (Zonotrichia leucophrys), American crow (Corvus brachyrhynchos), and house finch (Haemorhous mexicanus). Attachment C, Species Compendiums, contains a list of detected wildlife species.

4.4 Special-Status Biological Resources
Sensitive Natural Communities
Seven natural communities considered sensitive by the CDFW were reported in the CNDDB from the two USGS 7.5-minute quadrangle map region. These include:
x Southern Coast Live Oak Riparian Forest
x Southern Coastal Salt Marsh
x Southern Cottonwood Willow Riparian Forest
x Southern Dune Scrub
x Southern Foredunes
x Southern Sycamore Alder Riparian Woodland
x Valley Needlegrass Grassland
None of these sensitive vegetation communities are present on-site or in the surrounding survey area. However, the Project site does contain one sensitive vegetation community, disturbed Menzies’s golden bush scrub. This community has an “S3” designation under the CDFW, indicating that impacts or its loss may require compensatory mitigation (CDFW 2025). 479
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Special-Status Plant Species
A total of 49 special-status plant species were reported in the CNDDB and CNPS Online Inventory of Rare and Endangered Plants of California from the USGS 7.5-minute quadrangle map region including the Dana Point and San Clemente maps and in the vicinity by IPaC. After a review of specific habitat preferences, known distributions, and elevation ranges, 17 special-status plant species have the potential to occur within the buffer area only due to the presence of suitable habitat including aphanisma (Aphanisma blitoides), Coulter's saltbush (Atriplex coulteri), south coast saltscale (Atriplex pacifica), Orcutt's pincushion (Chaenactis glabriuscula var. orcuttiana), seaside cistanthe (Cistanthe maritima), Blochman's dudleya (Dudleya blochmaniae ssp. blochmaniae), many-stemmed dudleya (Dudleya multicaulis), cliff spurge (Euphorbia misera), decumbent goldenbush (Isocoma menziesii var. decumbens), Robinson's pepper-grass (Lepidium virginicum var. robinsonii), woolly-headed lessingia (Lessingia hololeuca), California box-thorn (Lycium californicum), cliff malacothrix (Malacothrix saxatilis var. saxatilis), south coast branching phacelia (Phacelia ramosissima var. austrolitoralis), white rabbit-tobacco (Pseudognaphalium leucocephalum), Nuttall's scrub oak (Quercus dumosa), and chaparral ragwort (Senecio aphanactis). No special-status plant species have the potential to occur within the project site due to a lack of suitable habitat. Attachments D, E, and F contain the plant-related literature review results.

Special-Status Wildlife Species
A total of 31 special-status wildlife species were reported in the CNDDB from the two USGS 7.5- minute quadrangle map region and in the vicinity by IPaC. Two special-status wildlife species were observed during the field surveys and are considered present: coastal California gnatcatcher (Polioptila californica californica; federal threatened and California species of special concern [SSC]) was observed within the Project site during the September 2025 survey and within the survey buffer during the December 2025 survey and a northern harrier (Circus hudsonius; California SSC) was observed just outside the survey area during the December 2025 survey.

Additional special-status wildlife species that have a moderate potential to occur include Crotch’s bumble bee (Bombus crotchii; California Candidate endangered), which may forage on the Project site but would not be expected to nest due to long-term disturbance and lack of suitable soil substrate, as well as red-diamond rattlesnake (Crotalus ruber; California SSC) and coast horned lizard (Phrynosoma coronatum; California SSC) within the survey buffer where habitat is more intact and less disturbed but likely not within the Project site itself. Remaining special-status wildlife species from the literature review are not expected to occur in the Project site or survey area due to a lack of suitable habitat and a review of specific habitat preferences, known distributions, and elevation ranges. Attachments D and F contain the wildlife-related literature review results.

Critical Habitat
Under the US Endangered Species Act (ESA), Critical Habitat may be established for species listed as threatened or endangered. Critical Habitat refers to specific areas within the geographical 480
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range of a species that were occupied at the time it was listed that contain the physical or biological features that are essential to the survival and eventual recovery of that species and that may require special management considerations or protection, regardless of whether the species is still extant in the area. Areas that were not known to be occupied at the time a species was listed can also be designated Critical Habitat if they contain one or more of the physical or biological features that are essential to that species’ conservation and if the other areas that are occupied are inadequate to ensure the species’ recovery.

In the event that a project may result in take or adverse modification to a listed species’ designated Critical Habitat, a project proponent may be required to engage in suitable mitigation. However, consultation for impacts to Critical Habitat is only required when a project has a federal nexus.

This may include projects that occur on federal lands, require federal permits (e.g., Clean Water Act [CWA] Section 404 permit), or receive any federal oversight or funding. If there is a federal nexus, then the federal agency that is responsible for providing funds or permits would be required to consult with the USFWS under the ESA.

The survey area is not located within any designated Critical Habitat.

State and Federal Jurisdictional Aquatic Features
Four key agencies regulate activities within coastal streams, wetlands, and riparian areas in California. The US Army Corps of Engineers (USACE) Regulatory Branch regulates activities that result in the discharge of dredged or fill material into waters of the US, including wetlands, pursuant to Section 404 of the CWA and Section 10 of the Rivers and Harbors Act. Of the state agencies, the Regional Water Quality Control Board (RWQCB) regulates discharges to waters of the State, including wetlands, pursuant to Section 401 of the CWA, Section 13263 of the California Porter-Cologne Water Quality Control Act, State Wetland Definition and Procedures for Discharges of Dredged or Fill Material to Waters of the State; the CDFW regulates alterations to lakes, streambeds, and associated riparian habitat pursuant to Section 1600 et seq. of the CFGC; and the California Coastal Commission (CCC) regulates land use in the coastal zone pursuant to the California Coastal Act (CCA).

Based on a review of aerial photographs, USGS 7.5-minute quadrangle maps, USFWS National Wetland Inventory maps, and observations made during the field survey, there are no jurisdictional drainage features within the Project site. The Segunda Deshecha Cañada Channel flows immediately north of the Project site, out of the hills and out onto the beach into the Pacific Ocean.

Adjacent to the Project it is mostly undergrounded within a concrete box channel, with only the part of it adjacent to the Project’s northeastern corner uncovered and open. However, it is located entirely outside of the Project site and is the only jurisdictional drainage feature within the survey area.

There are no drainage features within the Project site, which is in turn fenced on all sides. Direct impacts to drainage features are not expected to occur and a formal aquatic resources delineation is not recommended.
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4.5 Wildlife Corridors and Habitat Linkages
Wildlife corridors link areas of suitable habitat that are otherwise separated by areas of nonsuitable habitat such as rugged terrain, changes in vegetation, or human disturbance. Wildlife corridors are essential to the regional ecology of a species because they provide avenues of genetic exchange and allow animals to access alternative territories as dictated by fluctuating population densities. Fragmentation of open space areas by urbanization creates “islands” of wildlife habitat that are more or less isolated from each other. Corridors mitigate the effects of this fragmentation by (1) allowing animals to move between remaining habitats, thereby permitting depleted populations to be replenished and promoting genetic exchange; (2) providing escape routes from fire, predators, and human disturbances, thus reducing the risk of catastrophic events (such as fire or disease) that could lead to local extinction; and (3) serving as travel routes for individual animals as they move within their home ranges in search of food, water, mates, and shelter. Wildlife corridors are usually bounded by urban land areas or other areas unsuitable for wildlife. The corridor generally contains suitable cover, food, and/or water to support species and facilitate movement while in the corridor. Larger, landscape-level corridors (often referred to as “habitat or landscape linkages”) can provide both transitory and resident habitat for a variety of species. Although it is commonly used as a synonym for wildlife corridor, a habitat linkage refers to a more substantial, or wider, land connection between two habitat areas. Habitat linkages allow for the periodic exchange of animals between habitat areas, which is essential to maintain adequate gene pools.

The Project site is adjacent to the Sea Summit Trails area in San Clemente, California, approximately 500 feet from the beach. It is completely in uplands and is surrounded on all sides by a chain-link fence. Although the Project site may allow local movement by bird species, because of the chain-link fence it provides no connectivity for large mammal species to any biological resources or open space areas in the local or regional vicinity and does not serve as either a habitat linkage or wildlife corridor.

5.0 IMPACT ANALYSIS
The following discussion examines the impacts to biological resources that may occur as a result of the proposed project. The determination of impacts is based on both the features of the proposed project and the biological values of the habitat and sensitivity of plant and wildlife species potentially affected.

Impacts to biological resources are assessed using impact significance threshold criteria, which mirror the policy statement contained in the CEQA, Section 21001(c) of the California Public Resources Code. The questions below model those included in the checklist of questions listed in Appendix G of the CEQA guidelines and that are considered to determine if the project would have significant impacts to biological resources.

The analysis in this document is written in such a way that it analyzes the proposed Project’s impacts in relation to what was already analyzed and approved in the City of San Clemente’s Centennial General Plan EIR. If the General Plan EIR already analyzed an impact and the 482
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proposed Project does not contain additional significant impacts that exceed what was already approved, the Project is considered consistent with the General Plan EIR.

5.1 Impacts to Special-Status Species
a) Would the project 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?
Previous Significance Determination:

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 483
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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 NR1.02 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 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 C-2.10 establishes the protection of and development limitations within Environmentally Sensitive Habitat Areas (ESHAs); Policy C2.11 provides guidelines for uses within the marine environment; and Policy C-2.12 discourages the introduction of non-native species.

Project-Specific Analysis: 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 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.

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 preconstruction 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 484
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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 C-2.09 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 BIO-1 through 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.

As stated above, impacts to sensitive plant and wildlife species were evaluated in the General Plan EIR, and found to be less than significant with mitigation measures incorporated. There are no impacts that are peculiar to the project or project site related to sensitive plant and wildlife species. No significant impacts that were not identified as significant under the General Plan EIR have resulted. No potentially significant off-site impacts or cumulative impacts that were not discussed in the General Plan EIR have resulted. The project would not result in any increased severity of impacts due to substantial new information that was not known at the time of the General Plan EIR. Therefore, pursuant to Public Resources Code Section 21083.3 and CEQA Guidelines Section 15183, no further environmental review is required.

5.2 Impacts to Sensitive Natural Communities
b) Would the project 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? Previous Significance Determination: 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.

Project-Specific Analysis: Riparian habitats are those occurring along the banks of rivers and streams. Sensitive natural communities are natural communities that are considered rare in the region by regulatory agencies, known to provide habitat for sensitive animal or plant species, or known to be important wildlife corridors.

The project site does not contain any critical habitat or riparian habitat and there would be no impacts to these habitat types. The project site does contain one sensitive natural community, 485
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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. Following implementation of applicable General Plan policies, the proposed project would result in less than significant impacts to sensitive natural communities.

As stated above, impacts to riparian habitats and sensitive natural communities were evaluated in the General Plan EIR, and found to be less than significant with mitigation measures incorporated. As such, there are no impacts that are peculiar to the project or project site related to riparian habitats and sensitive natural communities. No significant impacts that were not identified as significant under the General Plan EIR have resulted. No potentially significant offsite impacts or cumulative impacts that were not discussed in the General Plan EIR have resulted.

The project would not result in any increased severity of impacts due to substantial new information that was not known at the time of the General Plan EIR. Therefore, pursuant to Public Resources Code Section 21083.3 and CEQA Guidelines Section 15183, no further environmental review is required.

5.3 Impacts to State or Federal Wetlands
c) Would the project 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?
Previous Significance Determination: 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.

Project-Specific Analysis: 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. 486
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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.

As stated above, impacts to wetlands and aquatic resources were evaluated in the General Plan EIR, and found to be less than significant with mitigation measures incorporated. As such, there are no impacts that are peculiar to the project or project site related to wetlands and aquatic resources. No significant impacts that were not identified as significant under the General Plan EIR have resulted. No potentially significant off-site impacts or cumulative impacts that were not discussed in the General Plan EIR have resulted. The project would not result in any increased severity of impacts due to substantial new information that was not known at the time of the General Plan EIR. Therefore, pursuant to Public Resources Code Section 21083.3 and CEQA Guidelines Section 15183, no further environmental review is required.

5.4 Impacts to Wildlife Movement or Wildlife Corridors
d) Would the project 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?
Previous Significance Determination: 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.

Project-Specific Analysis: 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 487
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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 (e.g., 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 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-8 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.

As stated above, impacts to migratory wildlife were evaluated in the General Plan EIR, and found to be less than significant with mitigation measures incorporated. As such, there are no impacts that are peculiar to the project or project site related to migratory wildlife. No significant impacts that were not identified as significant under the General Plan EIR have resulted. No potentially significant off-site impacts or cumulative impacts that were not discussed in the General Plan EIR have resulted. The project would not result in any increased severity of impacts due to substantial new information that was not known at the time of the General Plan EIR. Therefore, pursuant to Public Resources Code Section 21083.3 and CEQA Guidelines Section 15183, no further environmental review is required.

5.5 Conflicts with Local Policies or Ordinances
e) Would the project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Previous Significance Determination: 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 488
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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.

Project-Specific Analysis: 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.

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.

Impacts related to consistency with policies protecting biological resources were analyzed in the General Plan EIR and found to be less than significant. The project would not result in any impacts that are peculiar to the project or project site. No significant impacts that were not identified as significant under the General Plan EIR have resulted. No potentially significant off-site impacts or cumulative impacts that were not discussed in the General Plan EIR have resulted. The project would not result in any increased severity of impacts due to substantial new information that was not known at the time of the General Plan EIR. Therefore, pursuant to Public Resources Code Section 21083.3 and CEQA Guidelines Section 15183, no further environmental review is required.

5.6 Conflicts with Adopted Habitat Conservation Plan
f) Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
489
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Previous Significance Determination: 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.

Project-Specific Analysis: 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 (Attachment A, Figure 5, Southern Subregion HCP Map). 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.

Impacts related to habitat conservation plans were analyzed in the General Plan EIR and found to be less than significant. The project would not result in any impacts that are peculiar to the project or project site. No significant impacts that were not identified as significant under the General Plan EIR have resulted. No potentially significant off-site impacts or cumulative impacts that were not discussed in the General Plan EIR have resulted. The project would not result in any increased severity of impacts due to substantial new information that was not known at the time of the General Plan EIR. Therefore, pursuant to Public Resources Code Section 21083.3 and CEQA Guidelines Section 15183, no further environmental review is required.

6.0 MITIGATION MEASURES
Implementation of the following General Plan EIR measures and policies would ensure compliance and consistency with the General Plan EIR, thus avoiding any further environmental review.

General Plan EIR Mitigation Measures:

MM 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 490
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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 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 491
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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.

MM 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 US 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.

General Plan EIR Policies:

NR-1.01 Information. We acquire and maintain the most current information available regarding the status and location of sensitive biological elements (species and natural communities) and use this information to guide decisions that could affect biological resources.

NR-1.02 Natural Areas. In natural areas that are undeveloped or essentially so, we require applicants for proposed projects to:
a) avoid significant impacts, including retention of sufficient natural space where appropriate;
b) retain watercourses, riparian habitat, and wetlands in their natural condition;
c) maintain habitat linkages (wildlife corridors) between adjacent open spaces, water sources and other habitat areas and incorporate these into transportation projects and other development projects to maintain habitat connectivity;
d) incorporate visually open fences, or vegetative cover to preserve views, ensure continued access and to buffer habitat areas, open space linkages or wildlife corridors from development, as appropriate; e) locate and design roads such that conflicts with biological resources, habitat areas, linkages or corridors are minimized; and 492
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f) utilize open space or conservation easements when necessary to protect sensitive species or their habitats.

NR-1.03 Sensitive Habitats. We prohibit development and grading which alters the biological integrity of sensitive habitats, including Riparian Corridors unless no feasible project alternative exists which reduces environmental impacts to less than significant levels, or it is replaced with habitat of equivalent value, as acceptable to the City Council.
a) Where no environmentally feasible alternative exists, development within Riparian Corridors shall avoid removal of native vegetation; prevent erosion, sedimentation and runoff; provide for sufficient passage of native and anadromous fish; prevent wastewater discharges and entrapment; prevent groundwater depletion or substantial interference with surface and subsurface flows; and protect and re-establish natural vegetation buffers.

NR-1.04 Threatened and Endangered Species. We preserve the habitat of threatened and endangered species in place as the preferred habitat conservation strategy.

NR-1.06 Habitat Conservation Plan. We support and will follow the U.S. Fish and Wildlife Services Orange County Southern Subregion Habitat Conservation Plan (HCP) and Habitat Management Program.

C-2.02 Development Proposals. We protect the natural resources found in the Coastal Zone by evaluating development proposals, as required under the California Environmental Quality Act and as described in the Zoning Ordinance.

C-2.09 Coordination with State and Federal Agencies. We work with the state and federal resource protection agencies, businesses, private organizations and individuals to protect our natural and marine resources.

Applicable Conditions of Approval:

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 493
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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 FESA, MBTA, and CFGC)
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. 494
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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.

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. Pre-construction 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 (MBTA) and California Fish and Game Code (CFGC))
495
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7.0 CONCLUSIONS
The proposed project, with implementation of the various measures and policies described above, is considered to be consistent with the General Plan EIR and no further environmental review is required. Please feel free to contact me at (949) 533-0918 or at [email protected] with any questions you may have regarding the results and/or conclusions of this report.

Sincerely,
Ryan Winkleman
Senior Biologist
Attachments
A. Figures
B. Site Photographs
C. Species Compendiums
D. CNDDB Literature Review Results
E. CNPS Literature Review Results
F. IPaC Literature Review Results
y,
496
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REFERENCES
Baldwin et al. 2012, January. The Jepson Manual: Vascular Plants of California, Thoroughly Revised and Expanded, Second Edition.

CDFW (California Department of Fish and Wildlife). 2025. Natural Communities List Arranged Alphabetically by Life Form. February 2025.
https://wildlife.ca.gov/Data/VegCAMP/Natural-Communities Chesser, R. T., S. M. Billerman, K. J. Burns, C. Cicero, J. L. Dunn, B. E. Hernández-Baños, R. A.

Jiménez, Oscar Johnson, N. A. Mason, and P. C. Rasmussen. 2025. Check-list of North American Birds (online). American Ornithological Society. https://checklist.americanornithology.org/taxa/.

CNDDB (California Natural Diversity Database). 2026. RareFind 5 [Internet]. California Department of Fish and Wildlife.

CNPS (California Native Plant Society), Rare Plant Program. 2026. Rare Plant Inventory (online edition, v9.5). Website https://www.rareplants.cnps.org.

NABA (North American Butterfly Association). 2024. Checklist of North American Butterflies, Butterflies Occurring North of Mexico, Edition 2.3. Website https://naba.org/butterflynames-checklist/.

Nicholson, K. E. (ed.). 2025. Scientific and Standard English Names of Amphibians and Reptiles of North America North of Mexico, with Comments Regarding Confidence in Our Understanding. Ninth Edition. Society for the Study of Amphibians and Reptiles. 87pp.

Reid, F.A. 2006. A Field Guide to Mammals of North America, Fourth Edition. Houghton Mifflin Company, New York, New York.

Sawyer, J.O., T. Keeler-Wolf, and J. Evens. 2009. A Manual of California Vegetation (Second Edition). California Native Plant Society, Sacramento, California, USA.

Sibley, D.A. 2014. The Sibley Guide to Birds, Second Edition. Alfred A. Knopf, Inc., New York, New York.

Stebbins, R.C. 2003. A Field Guide to Western Reptiles and Amphibians, Third Edition. Houghton Mifflin Company, New York, New York.

USDA NRCS (US Department of Agriculture, Natural Resources Conservation Service). 2026.

Web Soil Survey. Website
https://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx.

USFWS (US Fish and Wildlife Service). 2026a. Information for Planning and Consultation (IPaC). Website https://ipac.ecosphere.fws.gov/location/index. 497
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USFWS. 2026b. Critical Habitat for Threatened & Endangered Species. Website https://fws.maps.arcgis.com/home/webmap/viewer.html?webmap=9d8de5e265ad4fe098 93cf75b8dbfb77.

USFWS. 2026c. National Wetlands Inventory. Website
https://fwsprimary.wim.usgs.gov/wetlands/apps/wetlands-mapper/.

Wilson, D.E., and D.M. Reeder, eds. 2005. Mammal Species of the World: A Taxonomic and Geographic Reference. 3rd ed. Online version. Baltimore, Maryland: Johns Hopkins University Press. http://www.bucknell.edu/msw3/.
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504

ATTACHMENT B
Site Photographs

505
Attachment B – Site Photographs
Hanson Hotel Project B-1
Biological Resources Assessment
Photograph 1: Northeast-facing view from the southwest corner of the Project site in December 2025 showing disturbed land.

Photograph 2: North/northeast-facing view from the eastern portion of the project site in December 2025 depicting disturbed Menzies’s golden bush scrub and quailbush scrub. 506
Attachment B – Site Photographs
Hanson Hotel Project B-2
Biological Resources Assessment
Photograph 3: Northwest-facing view from December 2025 of the Project site’s interior depicting disturbed Menzies’s golden bush scrub.

Photograph 4: Northwest-facing view from East Avenida Pico in December 2025 of the survey area showing disturbed quailbush scrub.
507
Attachment B – Site Photographs
Hanson Hotel Project B-3
Biological Resources Assessment
Photograph 5: Southeast-facing view from the northern boundary of the survey area in December 2025 depicting coyote brush scrub.

Photograph 6: Northeast-facing view from the southwestern corner of the survey area in December 2025 showing disturbed California sagebrush - (purple sage) scrub. 508
Attachment B – Site Photographs
Hanson Hotel Project B-4
Biological Resources Assessment
Photograph 7: Northwest-facing view from the central portion of the survey area in December 2025 showing disturbed coast prickly pear scrub immediately west of Segunda Deshecha Cañada.
509

ATTACHMENT C
Species Compendiums

510
Attachment C – Wildlife Species Observed List
Hanson Hotel Project C-1
Biological Resources Assessment
Species Type: Scientific Name Common Name Status: Federal/State Status: Other Birds
ACCIPITRIDAE—HAWKS, KITES, EAGLES, & ALLIES
Buteo jamaicensis red-tailed hawk
Circus hudsonius northern harrier SSC
PASSERELLIDAE—NEW WORLD SPARROWS
Melospiza melodia song sparrow
Melozone crissalis California towhee
Zonotrichia leucophrys white-crowned sparrow
CORVIDAE—CROWS & JAYS
Corvus brachyrhynchos American crow
TROCHILIDAE—HUMMINGBIRDS
Calypte anna Anna's hummingbird
Selasphorus sasin Allen's hummingbird
TROGLODYTIDAE—WRENS
Thryomanes bewickii Bewick's wren
Troglodytes aedon house wren
PARULIDAE—WOOD-WARBLERS
Geothlypis trichas common yellowthroat
Leiothlypis celata orange-crowned warbler
Setophaga coronata yellow-rumped warbler
SYLVIIDAE—SYLVIID WARBLERS
Chamaea fasciata wrentit
LARIDAE—GULLS, TERNS, & SKIMMERS
Larus occidentalis western gull
FRINGILLIDAE—FRINGILLINE & CARDUELINE FINCHES & ALLIES
Haemorhous mexicanus house finch
COLUMBIDAE—PIGEONS & DOVES
Columba livia rock pigeon (rock dove)*
Zenaida macroura mourning dove
TYRANNIDAE—TYRANT FLYCATCHERS
Sayornis nigricans black phoebe
MIMIDAE—MOCKINGBIRDS & THRASHERS
Toxostoma redivivum California thrasher
511
Attachment C – Wildlife Species Observed List
Hanson Hotel Project C-2
Biological Resources Assessment
Species Type: Scientific Name Common Name Status: Federal/State Status: Other POLIOPTILIDAE—GNATCATCHERS
Polioptila caerulea blue-gray gnatcatcher
Polioptila californica californica coastal California gnatcatcher FT, SSC STURNIDAE—STARLINGS
Sturnus vulgaris European starling*
* Non-native
Status Legend:

Federal: FT: Federally listed as threatened
State: SSC: California Species of Special Concern
512
Attachment C – Plant Species Observed List
Hanson Hotel Project C-3
Biological Resources Assessment
Species Type: Scientific Name Common Name Status: Federal/State Status: Other

EUDICOTS
AIZOACEAE—Fig-Marigold Family
Malephora crocea coppery mesemb*
ANACARDIACEAE—Sumac Or Cashew Family
Rhus integrifolia lemonade berry
ASTERACEAE—Sunflower Family
Artemisia californica California sagebrush
Baccharis pilularis coyote brush
Baccharis salicifolia mulefat
Dittrichia graveolens stinkwort*
Encelia californica California brittle bush
Isocoma menziesii Menzies’s golden bush
Pseudognaphalium californicum ladies' tobacco
BORAGINACEAE—Borage Family
Heliotropium curassavicum salt heliotrope
BRASSICACEAE—Mustard Family
Hirschfeldia incana short podded mustard*
CACTACEAE—Cactus Family
Cylindropuntia prolifera coast cholla
Opuntia littoralis coast prickly pear
CHENOPODIACEAE—Goosefoot Family
Atriplex lentiformis quailbush
Chenopodium album lambsquarters*
Salsola australis Russian thistle*
CLEOMACEAE—Cleome Family
Peritoma arborea bladderpod
MYRSINACEAE—Myrsine Family
Lysimachia arvensis scarlet pimpernel*
POLYGONACEAE—Buckwheat Family
Eriogonum fasciculatum California buckwheat
SOLANACEAE—Nightshade Family
513
Attachment C – Plant Species Observed List
Hanson Hotel Project C-4
Biological Resources Assessment
Species Type: Scientific Name Common Name Status: Federal/State Status: Other Lycium andersonii Anderson’s boxthorn
Solanum douglasii greenspot nightshade
VERBENACEAE—Vervain Family
Verbena lasiostachys western vervain

MONOCOTS
POACEAE—Grass Family
Distichlis spicata salt grass
Elymus condensatus giant wild rye
STRELITZIACEAE—No Common Name
Strelitzia nicolai giant bird of paradise *
* Non-native
514

ATTACHMENT D
CNDDB Literature Review Results

515
Species Element Code Federal Status State Status Global Rank State Rank Rare Plant
Rank/CDFW
SSC or FP
Actinemys pallida
southwestern pond turtle
ARAAD02032 Proposed
Threatened
None G2 SNR SSC
Agelaius tricolor
tricolored blackbird
ABPBXB0020 None Threatened G1G2 S2 SSC
Aimophila ruficeps canescens
southern California rufous-crowned sparrow
ABPBX91091 None None G5T3 S4 WL
Anaxyrus californicus
arroyo toad
AAABB01230 Endangered None G1G2 S2 SSC
Anniella stebbinsi
Southern California legless lizard
ARACC01060 None None G3 S3 SSC
Antrozous pallidus
pallid bat
AMACC10010 None None G4 S3 SSC
Arizona elegans occidentalis
California glossy snake
ARADB01017 None None G5T2 S2 SSC
Aspidoscelis hyperythra
orange-throated whiptail
ARACJ02060 None None G5 S2S3 WL
Athene cunicularia
burrowing owl
ABNSB10010 None Candidate
Endangered
G4 S2 SSC
Bombus crotchii
Crotch's bumble bee
IIHYM24480 None Candidate
Endangered
G2 S2
Bombus pensylvanicus
American bumble bee
IIHYM24260 None None G3G4 S2
Branchinecta sandiegonensis
San Diego fairy shrimp
ICBRA03060 Endangered None G2 S1
Campylorhynchus brunneicapillus sandiegensis
coastal cactus wren
ABPBG02095 None None G5T3Q S2 SSC
Chaetodipus californicus femoralis
Dulzura pocket mouse
AMAFD05021 None None G5T3 S3
Chaetodipus fallax fallax
northwestern San Diego pocket mouse
AMAFD05031 None None G5T3T4 S3S4
Choeronycteris mexicana
Mexican long-tongued bat
AMACB02010 None None G3G4 S1 SSC
Coelus globosus
globose dune beetle
IICOL4A010 None None G1G2 S1S2
Crotalus ruber
red-diamond rattlesnake
ARADE02090 None None G4 S3 SSC
Quad IS (Dana Point (3311746) OR San Clemente (3311745)) AND Taxonomic Group IS (Fish OR Amphibians OR Reptiles OR Birds OR Mammals OR Mollusks OR Arachnids OR Crustaceans OR Insects) Query Criteria:

Report Printed on Tuesday, December 09, 2025
Commercial Version -- Dated November, 30 2025 -- Biogeographic Data Branch Page 1 of 2 Information Expires 5/30/2026
Selected Elements by Scientific Name
California Department of Fish and Wildlife
California Natural Diversity Database
516
Species Element Code Federal Status State Status Global Rank State Rank Rare Plant
Rank/CDFW
SSC or FP
Danaus plexippus plexippus pop. 1
monarch - California overwintering population
IILEPP2012 Proposed
Threatened
None G4T1T2Q S2
Dipodomys stephensi
Stephens' kangaroo rat
AMAFD03100 Threatened Threatened G2 S3
Elanus leucurus
white-tailed kite
ABNKC06010 None None G5 S3S4 FP
Empidonax traillii extimus
southwestern willow flycatcher
ABPAE33043 Endangered Endangered G5T2 S3
Eucyclogobius newberryi
tidewater goby
AFCQN04010 Endangered None G3 S3 SSC
Eumops perotis californicus
western mastiff bat
AMACD02011 None None G4G5T4 S3S4 SSC
Gila orcuttii
arroyo chub
AFCJB13120 None None G1 S2 SSC
Icteria virens
yellow-breasted chat
ABPBX24010 None None G5 S4 SSC
Myotis yumanensis
Yuma myotis
AMACC01020 None None G5 S4
Neotoma lepida intermedia
San Diego desert woodrat
AMAFF08041 None None G5T3T4 S3S4 SSC
Nyctinomops femorosaccus
pocketed free-tailed bat
AMACD04010 None None G5 S3 SSC
Oncorhynchus mykiss irideus pop. 10
steelhead - southern California DPS
AFCHA0209J Endangered Endangered G5T1Q S1
Perognathus longimembris pacificus
Pacific pocket mouse
AMAFD01042 Endangered Candidate
Endangered
G5T2 S2 SSC
Phrynosoma blainvillii
coast horned lizard
ARACF12100 None None G4 S4 SSC
Plestiodon skiltonianus interparietalis
Coronado skink
ARACH01114 None None G5T5 S2S3 WL
Polioptila californica californica
coastal California gnatcatcher
ABPBJ08081 Threatened None G4G5T3Q S2 SSC
Spea hammondii
western spadefoot
AAABF02020 Proposed
Threatened
None G2G3 S3S4 SSC
Streptocephalus woottoni
Riverside fairy shrimp
ICBRA07010 Endangered None G1G2 S2
Thamnophis sirtalis pop. 1
south coast gartersnake
ARADB3613F None None G5T1T2 S1S2 SSC
Vireo bellii pusillus
least Bell's vireo
ABPBW01114 Endangered Endangered G5T2 S3
Record Count: 38
Report Printed on Tuesday, December 09, 2025
Commercial Version -- Dated November, 30 2025 -- Biogeographic Data Branch Page 2 of 2 Information Expires 5/30/2026
Selected Elements by Scientific Name
California Department of Fish and Wildlife
California Natural Diversity Database
517
Species Element Code Federal Status State Status Global Rank State Rank Rare Plant
Rank/CDFW
SSC or FP
Aphanisma blitoides
aphanisma
PDCHE02010 None None G3G4 S2 1B.2
Atriplex coulteri
Coulter's saltbush
PDCHE040E0 None None G3 S2 1B.2
Atriplex pacifica
south coast saltscale
PDCHE041C0 None None G4 S2 1B.2
Brodiaea filifolia
thread-leaved brodiaea
PMLIL0C050 Threatened Endangered G2 S2 1B.1
Calochortus weedii var. intermedius
intermediate mariposa-lily
PMLIL0D1J1 None None G3G4T3 S3 1B.2
Chaenactis glabriuscula var. orcuttiana
Orcutt's pincushion
PDAST20095 None None G5T1 S1 1B.1
Chorizanthe polygonoides var. longispina
long-spined spineflower
PDPGN040K1 None None G5T3 S3 1B.2
Comarostaphylis diversifolia ssp. diversifolia
summer holly
PDERI0B011 None None G3T2 S2 1B.2
Dudleya blochmaniae ssp. blochmaniae
Blochman's dudleya
PDCRA04051 None None G3T2 S2 1B.1
Dudleya multicaulis
many-stemmed dudleya
PDCRA040H0 None None G2 S2 1B.2
Eryngium pendletonense
Pendleton button-celery
PDAPI0Z120 None None G1 S1 1B.1
Euphorbia misera
cliff spurge
PDEUP0Q1B0 None None G5 S2 2B.2
Harpagonella palmeri
Palmer's grapplinghook
PDBOR0H010 None None G4 S3 4.2
Isocoma menziesii var. decumbens
decumbent goldenbush
PDAST57091 None None G3G5T2T3 S2 1B.2
Lasthenia glabrata ssp. coulteri
Coulter's goldfields
PDAST5L0A1 None None G4T2 S2 1B.1
Lycium brevipes var. hassei
Santa Catalina Island desert-thorn
PDSOL0G0N0 None None G5T1Q S1 3.1
Monardella hypoleuca ssp. intermedia
intermediate monardella
PDLAM180A4 None None G4T2? S2? 1B.3
Myosurus minimus ssp. apus
little mousetail
PDRAN0H031 None None G5T2Q S2 3.1
Navarretia prostrata
prostrate vernal pool navarretia
PDPLM0C0Q0 None None G2 S2 1B.2
Quad IS (Dana Point (3311746) OR San Clemente (3311745)) AND Taxonomic Group IS (Ferns OR Gymnosperms OR Monocots OR Dicots OR Lichens OR Bryophytes) Query Criteria:

Report Printed on Monday, January 12, 2026
Commercial Version -- Dated January, 2 2026 -- Biogeographic Data Branch Page 1 of 2 Information Expires 7/2/2026
Selected Elements by Scientific Name
California Department of Fish and Wildlife
California Natural Diversity Database
518
Species Element Code Federal Status State Status Global Rank State Rank Rare Plant
Rank/CDFW
SSC or FP
Nolina cismontana
chaparral nolina
PMAGA080E0 None None G3 S3 1B.2
Pentachaeta aurea ssp. allenii
Allen's pentachaeta
PDAST6X021 None None G4T1 S1 1B.1
Pseudognaphalium leucocephalum
white rabbit-tobacco
PDAST440C0 None None G4 S2 2B.2
Quercus dumosa
Nuttall's scrub oak
PDFAG050D0 None None G3 S3 1B.1
Senecio aphanactis
chaparral ragwort
PDAST8H060 None None G3 S2 1B.2
Suaeda esteroa
estuary seablite
PDCHE0P0D0 None None G3 S2 1B.2
Record Count: 25
Report Printed on Monday, January 12, 2026
Commercial Version -- Dated January, 2 2026 -- Biogeographic Data Branch Page 2 of 2 Information Expires 7/2/2026
Selected Elements by Scientific Name
California Department of Fish and Wildlife
California Natural Diversity Database
519
Species Element Code Federal Status State Status Global Rank State Rank Rare Plant
Rank/CDFW
SSC or FP
Southern Coast Live Oak Riparian Forest
Southern Coast Live Oak Riparian Forest
CTT61310CA None None G4 S4
Southern Coastal Salt Marsh
Southern Coastal Salt Marsh
CTT52120CA None None G2 S2.1
Southern Cottonwood Willow Riparian Forest
Southern Cottonwood Willow Riparian Forest
CTT61330CA None None G3 S3.2
Southern Dune Scrub
Southern Dune Scrub
CTT21330CA None None G1 S1.1
Southern Foredunes
Southern Foredunes
CTT21230CA None None G2 S2.1
Southern Sycamore Alder Riparian Woodland
Southern Sycamore Alder Riparian Woodland
CTT62400CA None None G4 S4
Valley Needlegrass Grassland
Valley Needlegrass Grassland
CTT42110CA None None G3 S3.1
Record Count: 7
Quad IS (Dana Point (3311746) OR San Clemente (3311745)) AND Taxonomic Group IS (Dune OR Scrub OR Herbaceous OR Marsh OR Riparian OR Woodland OR Forest OR Alpine OR Inland Waters OR Marine OR Estuarine OR Riverine OR Palustrine) Query Criteria:

Report Printed on Monday, January 12, 2026
Commercial Version -- Dated January, 2 2026 -- Biogeographic Data Branch Page 1 of 1 Information Expires 7/2/2026
Selected Elements by Scientific Name
California Department of Fish and Wildlife
California Natural Diversity Database
520

ATTACHMENT E
CNPS Literature Review Results

521
522
523
524
525
526

ATTACHMENT F
IPaC Literature Review Results
527
528
529
530
531
532
533
534
535
536
537
538

APPENDIX D
Cultural and Paleontological Resources Memo
539
This document is designed for double-sided printing to conserve natural resources. 540
MBAKERINT L .COM
3100 Zinfandel Drive , Suite125,Rancho Cordova, CA 95670 P: (916) 3618384 F: (916) 361-1574
January 29, 2026
Jonathan Lightfoot, City Planner

CITY OF SAN CLEMENTE
910 Calle Negocio
San Clemente, CA 92673
RE: CULTURAL AND PALEONTOLOGICAL RESOURCES IDENTIFICATION MEMORANDUM

FOR THE HANSON HOTEL CEQA REVIEW PROJECT, CITY OF SAN CLEMENTE,

ORANGE COUNTY, CALIFORNIA
Dear Mr. Lightfoot:

In support of the Hanson Hotel CEQA Review Project (project), Michael Baker International completed a South Central Coastal Information Center (SCCIC) records search, literature and historical map review, built environment survey, and buried archaeological site sensitivity analysis to determine if the project area contains historical resources, as defined in California Environmental Quality Act (CEQA) Guidelines Section 15064.5(a), that may be impacted by the project. Additionally, Michael Baker International requested a paleontological records search from the Natural History Museums of Los Angeles County (NHMLAC), and completed an online and published database review to identify paleontological localities and sensitivity of the project area.

The project is subject to CEQA review; the City of San Clemente (City) is the lead agency. Methods, results, and recommendations are summarized below.

PROJECT DESCRIPTION
The project proposes development of the Hanson Hotel, a three-story, 61-room boutique hotel featuring a pool, café, rooftop restaurant with amplified music, and a subterranean parking garage with 104 parking stalls. The project includes 16 affordable hotel rooms (25 percent) 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.

Discretionary Design Review is currently in process with the City of San Clemente, in order to ensure that the project does not have an adverse effect on the North Beach Historic District, or, with mitigation, will mitigate the effects to a less than significant level if they exist.

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. The rooftop restaurant would offer full-service alcohol and ambient amplified music.

Public amenities include 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, 541

MICHAEL BAKER INTERNATIONAL
RE: CULTURAL AND PALEONTOLOGICAL RESOURCES IDENTIFICATION MEMORANDUM FOR THE

HANSON HOTEL CEQA REVIEW PROJECT, CITY OF SAN CLEMENTE, ORANGE COUNTY, CALIFORNIA

Page 2 ends

San Clemente City CouncilMay 19, 2026

San Clemente City Council
May 19, 2026