HomeMy WebLinkAboutPA2024-0069_2025.05.23_Draft EIRName of project
Document Title
Prepared For
Name of Client/Agency
Date
SNUG HARBOR SURF PARK PROJECT
SCH NO. 2024110238
Draft EnvironmentalImpact Report
Prepared for
City of Newport Beach100 Civic Center DriveNewport Beach, CA 92660
May 2025
Snug Harbor Surf Park Project Table of Contents
City of Newport Beach i
Draft EIR
May 2025
Table of Contents
1. Executive Summary .................................................................................................................................. 1-1
2. Introduction ................................................................................................................................................ 2-1
3. Project Description ................................................................................................................................... 3-1
4. Environmental Setting .............................................................................................................................. 4-1
5. Environmental Impact Analysis ............................................................................................................... 5-1
5.1 Aesthetics ............................................................................................................................................. 5.1-1
5.2 Air Quality ........................................................................................................................................... 5.2-1
5.3 Biological Resources ........................................................................................................................... 5.3-1
5.4 Cultural Resources .............................................................................................................................. 5.4-1
5.5 Energy .................................................................................................................................................. 5.5-1
5.6 Geology and Soils ............................................................................................................................. 5.6-1
5.7 Greenhouse Gas Emissions................................................................................................................ 5.7-1
5.8 Hazards and Hazardous Materials ................................................................................................ 5.8-1
5.9 Hydrology and Water Quality ....................................................................................................... 5.9-1
5.10 Land Use and Planning ................................................................................................................ 5.10-1
5.11 Noise ............................................................................................................................................... 5.11-1
5.12 Public Services ............................................................................................................................... 5.12-1
5.13 Parks and Recreation ................................................................................................................... 5.13-1
5.14 Transportation ............................................................................................................................... 5.14-1
5.15 Tribal Cultural Resources ............................................................................................................. 5.15-1
5.16 Utilities and Service Systems....................................................................................................... 5.16-1
6. Other CEQA Considerations .................................................................................................................. 6-1
7. Effects Found Not Significant ................................................................................................................. 7-1
8. Alternatives ............................................................................................................................................... 8-1
9. EIR Preparers and Persons Contacted ................................................................................................. 9-1
Snug Harbor Surf Park Project Table of Contents
City of Newport Beach ii
Draft EIR
May 2025
Figures
FIGURE 3-1: REGIONAL LOCATION.................................................................................................................................... 3-5
FIGURE 3-2: LOCAL VICINITY ............................................................................................................................................. 3-7
FIGURE 3-3: AERIAL VIEW.................................................................................................................................................. 3-9
FIGURE 3-4A: EXISTING SITE PHOTOS ............................................................................................................................ 3-11
FIGURE 3-4B: EXISTING SITE PHOTOS............................................................................................................................. 3-13
FIGURE 3-5: EXISTING GENERAL PLAN LAND USE DESIGNATIONS................................................................................. 3-15
FIGURE 3-6: EXISTING ZONING DESIGNATIONS ............................................................................................................ 3-17
FIGURE 3-7: COASTAL ZONE BOUNDARY ...................................................................................................................... 3-19
FIGURE 3-8: CONCEPTUAL SITE PLAN ............................................................................................................................. 3-25
FIGURE 3-9: AMENITY CLUBHOUSE BUILDING ELEVATION .............................................................................................. 3-27
FIGURE 3-10: ATHLETE ACCOMMODATION BUILDING ELEVATION ................................................................................. 3-29
FIGURE 3-11: PROPOSED SOLAR PV INSTALLATION ...................................................................................................... 3-31
FIGURE 3-12: GOLF COURSE OPERATIONS DURING CONSTRUCTION .......................................................................... 3-37
FIGURE 5-1: CUMULATIVE PROJECTS ................................................................................................................................. 5-7
FIGURE 5.1-1: DEVELOPMENT IN THE PROJECT SITE VIEWSHED .................................................................................... 5.1-9
FIGURE 5.1-2: VIEW SIMULATION LOCATIONS ........................................................................................................... 5.1-17
FIGURE 5.1-3: PROJECT VIEW A ................................................................................................................................. 5.1-19
FIGURE 5.1-4: PROJECT VIEW B ................................................................................................................................. 5.1-21
FIGURE 5.1-5: PROJECT VIEW C ................................................................................................................................. 5.1-23
FIGURE 5.1-6: PROJECT VIEW D ................................................................................................................................. 5.1-25
FIGURE 5.1-7: PROJECT VIEW E .................................................................................................................................. 5.1-27
FIGURE 5.1-8: PROJECT VIEW F .................................................................................................................................. 5.1-29
FIGURE 5.2-1: AIR QUALITY RECEPTOR LOCATIONS ................................................................................................... 5.2-17
FIGURE 5.3-1: PROJECT SITE VEGETATION .................................................................................................................... 5.3-5
FIGURE 5.6-1: LIQUEFACTION ZONE ............................................................................................................................. 5.6-9
FIGURE 5.8-1: JOHN WAYNE AIRPORT NOTIFICATION AREA ..................................................................................... 5.8-19
FIGURE 5.8-2: 2024 JOHN WAYNE AIRPORT NOISE CONTOURS ............................................................................ 5.8-21
FIGURE 5.8-3: JOHN WAYNE AIRPORT SAFETY ZONES FOR 2L/20R ....................................................................... 5.8-23
FIGURE 5.8-4: JOHN WAYNE AIRPORT SAFETY ZONES FOR 2R/20L ....................................................................... 5.8-25
FIGURE 5.8-5: FAA PART 77 OBSTRUCTION IMAGINARY SURFACES FOR RUNWAY 2L/20R .................................. 5.8-27
FIGURE 5.8-6: FAA PART 77 OBSTRUCTION IMAGINARY SURFACES FOR RUNWAY 2R/20L .................................. 5.8-29
FIGURE 5.8-7: HISTORICAL AVIATION ACCIDENTS SOUTH OF JOHN WAYNE AIRPORT ............................................. 5.8-31
FIGURE 5.10-1: PROPOSED IMPROVEMENTS WITHIN MESA DRIVE ............................................................................. 5.10-9
FIGURE 5.10-2: CITY PLANNING JOHN WAYNE AIRPORT NOISE CONTOURS ....................................................... 5.10-25
FIGURE 5.10-3: AELUP 1985 JOHN WAYNE AIRPORT NOISE CONTOURS .......................................................... 5.10-27
FIGURE 5.11-1: NOISE MEASUREMENT LOCATIONS ................................................................................................... 5.11-9
FIGURE 5.11-2: NOISE SENSITIVE RECEIVER LOCATIONS ......................................................................................... 5.11-13
FIGURE 5.11-3: CONSTRUCTION ACTIVITY AND RECEIVER LOCATIONS................................................................... 5.11-19
FIGURE 5.11-4: OPERATIONAL NOISE SOURCES ..................................................................................................... 5.11-23
FIGURE 5.14-1: OCTA TRANSIT ROUTES.................................................................................................................... 5.14-7
FIGURE 5.14-2: BIKE LANES IN PROJECT VICINITY ...................................................................................................... 5.14-9
Snug Harbor Surf Park Project Table of Contents
City of Newport Beach iii
Draft EIR
May 2025
Tables
TABLE 1-1: SUMMARY OF IMPACTS .................................................................................................................................... 1-5
TABLE 2-1: SUMMARY OF NOP COMMENT LETTERS ......................................................................................................... 2-3
TABLE 2-2: SUMMARY OF SCOPING MEETING COMMENTS ........................................................................................... 2-16
TABLE 3-1: EXISTING ONSITE BUILDING SQUARE FOOTAGE ............................................................................................. 3-1
TABLE 3-2: SURROUNDING EXISTING USES, GENERAL PLAN LAND USE, AND ZONING .................................................... 3-3
TABLE 3-3: AMENITY CLUBHOUSE BUILDING SUMMARY ................................................................................................. 3-22
TABLE 3-4: ATHLETE ACCOMMODATIONS BUILDING AND FREESTANDING ANCILLARY SQUARE FOOTAGE ................... 3-23
TABLE 3-5: CONSTRUCTION SCHEDULE AND EQUIPMENT ............................................................................................... 3-33
TABLE 5-1: CUMULATIVE PROJECTS LIST ............................................................................................................................ 5-5
TABLE 5.1-1: SANTA ANA HEIGHTS SPECIFIC PLAN DEVELOPMENT STANDARD CONSISTENCY .................................. 5.1-16
TABLE 5.2-1: AMBIENT AIR QUALITY STANDARDS FOR CRITERIA POLLUTANTS .............................................................. 5.2-2
TABLE 5.2-2: AIR QUALITY MONITORING SUMMARY 2021-2023 ........................................................................... 5.2-13
TABLE 5.2-3: ATTAINMENT STATUS OF CRITERIA POLLUTANTS IN THE BASIN .............................................................. 5.2-14
TABLE 5.2-4: EXISTING PROJECT SITE EMISSIONS ....................................................................................................... 5.2-15
TABLE 5.2-5: SCAQMD REGIONAL AIR QUALITY THRESHOLDS ................................................................................. 5.2-19
TABLE 5.2-6: SCAQMD LOCALIZED AIR QUALITY THRESHOLDS ................................................................................ 5.2-20
TABLE 5.2-7: MAXIMUM PEAK DAILY CONSTRUCTION EMISSIONS ............................................................................. 5.2-23
TABLE 5.2-8: MAXIMUM PEAK DAILY OPERATIONAL EMISSIONS ................................................................................ 5.2-24
TABLE 5.2-9: LOCALIZED EMISSIONS FROM PEAK CONSTRUCTION ACTIVITY ............................................................. 5.2-25
TABLE 5.3-1: SPECIAL-STATUS PLANT SPECIES PROBABILITY LIST .................................................................................. 5.3-7
TABLE 5.3-2: SPECIAL-STATUS WILDLIFE SPECIES PROBABILITY LIST ............................................................................ 5.3-11
TABLE 5.5-1: ESTIMATED CONSTRUCTION ELECTRICITY USAGE ..................................................................................... 5.5-7
TABLE 5.5-2: ESTIMATED CONSTRUCTION FUEL CONSUMPTION ................................................................................... 5.5-7
TABLE 5.5-3: ESTIMATED CONSTRUCTION WORKER FUEL CONSUMPTION (AUTOMOBILES) ........................................ 5.5-8
TABLE 5.5-4: ESTIMATED CONSTRUCTION VENDOR/HAULING FUEL CONSUMPTION................................................... 5.5-9
TABLE 5.5-5: CHANGE IN TRAFFIC GENERATED ANNUAL FUEL CONSUMPTION .......................................................... 5.5-10
TABLE 5.5-6: PROJECT ANNUAL OPERATIONAL NATURAL GAS AND ELECTRICITY SUMMARY ..................................... 5.5-11
TABLE 5.7-1: PROJECT CONSTRUCTION GREENHOUSE EMISSIONS ............................................................................ 5.7-12
TABLE 5.7-2: PROJECT OPERATION GREENHOUSE EMISSIONS ................................................................................... 5.7-13
TABLE 5.7-3: PROJECT CONSISTENCY WITH THE CARB 2022 SCOPING PLAN ACTIONS ......................................... 5.7-15
TABLE 5.8-1: PHASE I HAZARDOUS MATERIALS SITE DATABASE REVIEW .................................................................... 5.8-38
TABLE 5.9-1: CITY OF NEWPORT BEACH PROJECTED WATER SUPPLY PROJECTIONS (ACRE-FEET) ............................. 5.9-13
TABLE 5.9-2: 100-YEAR STORM RUNOFF RATE .......................................................................................................... 5.9-14
TABLE 5.10-1: EXISTING ONSITE BUILDING SQUARE FOOTAGE .............................................................................. 5.10-22
TABLE 5.10-2: CONSISTENCY WITH APPLICABLE SCAG 2024 CONNECT SOCAL REGIONAL PLANNING POLICIES ............
................................................................................................................................................................................... 5.10-30
TABLE 5.10-3: CONSISTENCY WITH JOHN WAYNE AIRPORT ENVIRONS LAND USE PLAN POLICIES ...................... 5.10-31
TABLE 5.10-4: GENERAL PLAN POLICY CONSISTENCY ANALYSIS ............................................................................ 5.10-37
TABLE 5.10-5: CITY COUNCIL POLICY MANUAL CONSISTENCY ANALYSIS .............................................................. 5.10-51
TABLE 5.10-6: SPECIFIC PLAN POLICY AND MUNICIPAL CODE CONSISTENCY ANALYSIS ........................................ 5.10-54
TABLE 5.11-1: GENERAL PLAN LAND USE NOISE COMPATIBILITY MATRIX (GP TABLE N2) ....................................... 5.11-5
TABLE 5.11-2: CITY OF NEWPORT BEACH NOISE STANDARDS................................................................................... 5.11-7
TABLE 5.11-3: AELUP LAND USE NOISE LIMITATIONS................................................................................................ 5.11-8
TABLE 5.11-4: SUMMARY OF 24-HOUR AMBIENT NOISE LEVEL MEASUREMENTS ................................................... 5.11-11
Snug Harbor Surf Park Project Table of Contents
City of Newport Beach iv
Draft EIR
May 2025
TABLE 5.11-5: SIGNIFICANCE CRITERIA SUMMARY................................................................................................... 5.11-16
TABLE 5.11-6: CONSTRUCTION REFERENCE NOISE LEVELS ...................................................................................... 5.11-18
TABLE 5.11-7: CONSTRUCTION ACTIVITY NOISE LEVELS ......................................................................................... 5.11-21
TABLE 5.11-8: INCREASES IN DAYTIME AMBIENT NOISE LEVELS FROM CONSTRUCTION ACTIVITY .......................... 5.11-21
TABLE 5.11-9: DAYTIME OPERATIONAL NOISE LEVELS ............................................................................................. 5.11-22
TABLE 5.11-10: NIGHTTIME OPERATIONAL NOISE LEVELS ....................................................................................... 5.11-25
TABLE 5.11-11: OPERATIONAL NOISE LEVEL COMPLIANCE ..................................................................................... 5.11-25
TABLE 5.11-12: OPERATIONAL DAYTIME NOISE LEVEL INCREASES .......................................................................... 5.11-26
TABLE 5.11-13: OPERATIONAL NIGHTTIME NOISE LEVEL INCREASES ...................................................................... 5.11-26
TABLE 5.11-14: VIBRATION SOURCE LEVELS FOR CONSTRUCTION EQUIPMENT ...................................................... 5.11-27
TABLE 5.11-15: CONSTRUCTION VIBRATION LEVELS ............................................................................................... 5.11-27
TABLE 5.12-1: FIRE STATIONS LOCATIONS AND DISTANCE FROM PROJECT SITE ........................................................ 5.12-4
TABLE 5.12-2: FIRE DEPARTMENT CALLS FOR SERVICES .............................................................................................. 5.12-5
TABLE 5.12-3: POLICE DEPARTMENT CALLS FOR SERVICES AND RESPONSE TIMES ..................................................... 5.12-6
TABLE 5.12-4: LIBRARY FACILITIES ............................................................................................................................... 5.12-6
TABLE 5.13-1: NEWPORT BEACH PARK AND RECREATION FACILITIES WITHIN TWO MILES OF THE PROJECT SITE ..... 5.13-4
TABLE 5.13-2: PUBLIC GOLF COURSE FACILITIES WITHIN TEN MILES OF THE PROJECT SITE ...................................... 5.13-5
TABLE 5.13-3: PUBLIC DRIVING RANGES WITHIN TEN MILES OF THE PROJECT SITE .................................................. 5.13-6
TABLE 5.14-1: EXISTING ROADWAY CHARACTERISTICS WITHIN PROJECT AREA ........................................................ 5.14-5
TABLE 5.14-2: PROJECT TRIP GENERATION .............................................................................................................. 5.14-13
TABLE 5.14-3: DAILY CONSTRUCTION VEHICLE TRIPS .............................................................................................. 5.14-14
TABLE 5.16-1: CITY OF NEWPORT BEACH 500 RESIDENTIAL UNIT WATER DEMAND ................................................ 5.16-2
TABLE 5.16-2: CITY OF NEWPORT BEACH WATER SUPPLY 2020 ............................................................................. 5.16-4
TABLE 5.16-3: CITY OF NEWPORT BEACH PROJECTED WATER SUPPLY (AF) ............................................................. 5.16-4
TABLE 5.16-4: CITY ACTUAL AND 2020 UWMP PROJECTED DEMANDS FOR WATER IN ACRE-FEET (AFS) ............. 5.16-5
TABLE 5.16-5: CITY ACTUAL 2021 THROUGH 2023 POTABLE WATER DEMAND IN ACRE-FEET (AFS) .................... 5.16-6
TABLE 5.16-6: EXISTING NEWPORT BEACH GOLF COURSE AND PROJECT SITE WATER DEMANDS ........................... 5.16-7
TABLE 5.16-7: PROPOSED SURF LAGOON WATER DEMANDS ................................................................................... 5.16-9
TABLE 5.16-8: PROPOSED CLUBHOUSE AND ATHLETE ACCOMMODATIONS WATER DEMANDS ................................ 5.16-9
TABLE 5.16-9: NET CHANGE IN WATER DEMANDS ................................................................................................. 5.16-10
TABLE 5.16-10: ESTIMATED WASTEWATER GENERATION FROM OPERATION OF CLUBHOUSE AND ACCOMMODATIONS
................................................................................................................................................................................... 5.16-14
TABLE 5.16-11: ESTIMATED WASTEWATER GENERATION FROM OPERATION OF SURF LAGOON .......................... 5.16-14
TABLE 5.16-12: SEWER FLOW CONDITIONS WITH THE PROPOSED PROJECT ......................................................... 5.16-15
TABLE 5.16-13: PUMP STATION FLOW AND CAPACITY .......................................................................................... 5.16-15
TABLE 5.16-14: PROJECT CHANGE TO 100-YEAR STORM RUNOFF RATE .............................................................. 5.16-19
TABLE 5.16-15: LANDFILL CAPACITY ........................................................................................................................ 5.16-21
TABLE 5.16-16: PROPOSED PROJECT SOLID WASTE GENERATION ........................................................................ 5.16-23
TABLE 8-1: TRIP GENERATION FOR THE ALTERNATIVE COMMERCIAL RECREATION USE ALTERNATIVE ............................. 8-19
TABLE 8-2: NET NEW TRIPS FROM THE ALTERNATIVE COMMERCIAL RECREATION USE ALTERNATIVE ............................. 8-20
TABLE 8-3: PROJECT TRIP GENERATION COMPARISON TO THE ALTERNATIVE COMMERCIAL RECREATION USE ALTERNATIVE
......................................................................................................................................................................................... 8-20
TABLE 8-4: IMPACT COMPARISON OF THE PROPOSED PROJECT AND ALTERNATIVES ..................................................... 8-23
TABLE 8-5: COMPARISON OF THE PROPOSED PROJECT AND ALTERNATIVES’ ABILITY TO MEET OBJECTIVES ................. 8-24
Snug Harbor Surf Park Project Table of Contents
City of Newport Beach v
Draft EIR
May 2025
Appendices
APPENDIX A NOTICE OF PREPARATION AND COMMENT LETTERS
APPENDIX B AIR QUALITY IMPACT ANALYSIS
APPENDIX C BIOLOGICAL TECHNICAL REPORT
APPENDIX D HISTORIC RESOURCES EVALUATION
APPENDIX E PHASE I ARCHAEOLOGICAL RESOURCES ASSESSMENT
APPENDIX F ENERGY TABLES
APPENDIX G ENGINEERING ANALYSIS REPORT
APPENDIX H GEOTECHNICAL EXPLORATION
APPENDIX I PALEONTOLOGICAL RESOURCES ASSESSMENT
APPENDIX J GREENHOUSE GAS ANALYSIS
APPENDIX K PHASE I ENVIRONMENTAL SITE ASSESSMENT
APPENDIX L PHASE II ENVIRONMENTAL SITE ASSESSMENT
APPENDIX M AIRCRAFT HAZARD AND LAND USE RISK ASSESSMENT
APPENDIX N SOLAR GLARE ANALYSIS
APPENDIX O PRELIMINARY WATER QUALITY MANAGEMENT PLAN
APPENDIX P PRELIMINARY HYDROLOGY REPORT
APPENDIX Q NOISE ANALYSIS
APPENDIX R TRIP GENERATION ASSESSMENT
APPENDIX S WATER SUPPLY EVALUATION
APPENDIX T WATER DEMAND REPORT
APPENDIX U SEWER ANALYSIS
Snug Harbor Surf Park Project Table of Contents
City of Newport Beach vi
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-1
Draft EIR
May 2025
1. Executive Summary
This Draft Environmental Impact Report (EIR) (State Clearinghouse [SCH] Number 2024110238) evaluates
the environmental effects that may result from the construction and operation of the Snug Harbor Surf Park
Project (proposed Project). This EIR has been prepared in conformance with State and City of Newport Beach
environmental policy guidelines for the implementation of the California Environmental Quality Act (CEQA).
This Draft EIR is being circulated for review and comment by the public and other interested parties, agencies,
and organizations for 45 days in accordance with Section 15087 and Section 15105 of the CEQA
Guidelines. During the 45-day review period, the Draft EIR will be available for public review at the City
of Newport Beach website http://www.newportbeachca.gov/ceqa.
Written comments related to environmental issues in the Draft EIR should be addressed to:
Joselyn Perez, Senior Planner
City of Newport Beach, Community Development Department
100 Civic Center Drive
Newport Beach, California 92660
JPerez@newportbeachca.gov
A Notice of Availability (NOA) of the Draft EIR was published concurrently with distribution of this document.
1.1 PROJECT LOCATION
The Project site is located in the northern portion of the City of Newport Beach at 3100 Irvine Avenue. The
site is located east of the intersection of Mesa Drive and Irvine Avenue within the Newport Beach Golf Course
(NB Golf Course), which is a privately owned commercial recreational facility. Regional access to the Project
site is provided via State Route (SR) 73, located 0.3-mile to the northeast, and SR-55, approximately 0.75
mile to the northwest. Local access to the site is provided by Irvine Avenue through an existing driveway that
provides both right of left turns to enter the site, and only right turns leaving the site. Additionally, existing
pedestrian and golf cart access to the site is provided along Mesa Drive. Regional location and local vicinity
maps are provided in Figure 3-1, Regional Location, and Figure 3-2, Local Vicinity.
The NB Golf Course is separated into three physically distinct land areas. The Project site consists of only the
central portion bounded by Irvine Avenue and Mesa Drive. The Project site includes a partially covered
synthetic turf driving range, a putting green, three holes of the golf course (holes 1, 2, and 9), a building
with a pro shop and a restaurant, and a surface parking lot. Figure 3-3, Aerial View, shows the Project site
and adjacent golf course areas. For a more detailed description of the existing setting, see Section 4.0,
Environmental Setting.
The Project site is identified by Assessor’s Parcel Number (APN) 119-200-41. Additionally, the site is located
within the Newport Beach USGS 7.5-Minute Quadrangle; Section 00, Township 6 South, Range 10 West,
San Bernardino Principal Meridian.
1.2 PROJECT DESCRIPTION SUMMARY
The Snug Harbor Surf Park Project (Project) would remove the existing improvements on the 15.38-acre
Project site and develop a 5.06-acre surf lagoon with warming pools, a spa, and seating areas; a three-
story amenity clubhouse; a two-story athlete accommodation building; ancillary storage and maintenance
areas; and associated parking areas. Solar panels would be installed on the roofs of the buildings and on
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-2
Draft EIR
May 2025
14 to 18-foot-high solar canopies in portions of the parking areas to provide onsite renewable energy
(included as Project Design Feature (PDF)-1). In addition, the Project landscaping does not include vegetation
that produces seeds, fruits, nuts, or berries, such as fruit bearing trees and shrubs (included as PDF-2) to limit
onsite bird attractants.
The portions of the golf course to the north of Irvine Avenue (holes 10-18) and south of Mesa Drive (holes 3-
8) would remain and golf cart path of travel between holes 3-8 and holes 10-18 would be provided. The
Project includes golf course parking, a starter shack for the golf course, and golf cart storage in the basement
level of the proposed amenity clubhouse.
The Project would install new onsite infrastructure that would connect to the existing adjacent utility systems.
In addition, the Project would upgrade the existing 6-inch onsite sewer lateral that extends approximately
42.5 feet offsite that is more than 50 years old to a 12-inch sewer line that would connect to the existing
12-inch sewer line in Mesa Drive.
The Project includes a General Plan Amendment (GPA), a Conditional Use Permit (CUP), a Modification
Permit, and a Major Site Development Review (SDR). Due to the Project’s location near John Wayne Airport
(SNA), the Project requires an aeronautical review by the Federal Aviation Administration (FAA), and an
Airport Environs Land Use Plan (AELUP) consistency review by the Orange County Airport Land Use
Commission (ALUC). Section 3.0, Project Description, provides a comprehensive description of the proposed
construction and operation of the proposed Project.
1.3 SUMMARY OF CEQA PROCESS
A project-level analysis has been provided pursuant to CEQA Guidelines Section 15161. To begin the CEQA
process, the City of Newport Beach issued a Notice of Preparation (NOP) for the Project, which was
distributed on November 7, 2024, for a public review period of 30 days through December 6, 2024. Per
CEQA Guidelines Section 15082, the NOP was submitted to the State Clearinghouse (SCH) within the Office
of Planning & Research (OPR), County Clerk, responsible and trustee agencies, counties and cities bordering
the site, adjacent properties, and organizations and individuals that have requested notification. The NOP
was posted on the Project site, on the City’s website, at City Hall and the City libraries. The City emailed a
“News Splash” to alert interested parties of the postings. In addition, pursuant to Senate Bill (SB) 18 and
Assembly Bill (AB 52), the City sent letters to 20 Native American tribal representatives.
Pursuant to Section 15082(c)(1) of the CEQA Guidelines, the City of Newport Beach hosted a public scoping
meeting on November 20, 2024, at 6:00 p.m. at the Friends Room in the Newport Beach Public Library
(Central Library Branch) for members of the public and public agencies to provide input as to the scope and
content of the environmental information and analysis to be included in the Draft EIR.
The Draft EIR has since been prepared and the City of Newport Beach has filed a Notice of Completion
(NOC) with the Governor’s Office of Planning and Research State Clearinghouse, indicating that this Draft
EIR has been completed and is available for review and comment. A Notice of Availability (NOA) of this
Draft EIR was published noticing that it is circulated for review and comment by the public, interested parties,
agencies, and organizations for 45 days in accordance with CEQA Guidelines Sections 15087 and 15105.
Written responses to all comments related to the environmental issues in the Draft EIR will be prepared and
incorporated into a Final EIR. The written responses to comments will be made available at least 10 days
prior to the public hearing at which the certification of the Final EIR will be considered by the City of Newport
Beach City Council. Notice of the availability of the Final EIR will be sent to all who comment on the Draft
EIR. Additional detail about the CEQA process is provided in Section 2.0, Introduction.
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-3
Draft EIR
May 2025
1.4 PROJECT OBJECTIVES
The intent of the Snug Harbor Surf Park Project is to develop and operate an alternative surfing facility to
provide consistent and predictable waves for training, lessons, and contests to enhance the Newport Beach
surf culture and recreation base, and to provide accommodations to support traveling athletes, coaches, and
surf park guests.
CEQA Guidelines Section 15124(b) states that an EIR shall contain a clearly written statement of objectives
to help the lead agency develop a reasonable range of alternatives to evaluate in the EIR; and that the
objectives should include the underlying purpose of the project and may discuss project benefits. The Project-
specific CEQA objectives have been carefully crafted in order to aid decision makers in their review of the
proposed Project and its associated environmental impacts. The CEQA Project objectives include the
following:
1. Provide an innovative, world-class, full-service, year-round outdoor recreational opportunity to serve a
wide range of guests.
2. Maintain consistency with the existing Santa Ana Heights Specific Plan (SP-7) and the Open Space and
Recreation (OSR) Specific Plan designation.
3. Expand the City’s tourism economy and expand transient occupancy tax revenues.
4. Utilize sustainable solar energy onsite that is consistent with the City’s sustainability goals.
1.5 SUMMARY OF ALTERNATIVES
Section 8.0, Alternatives, of this EIR analyzes a range of reasonable alternatives to the proposed Project.
The alternatives that are analyzed in detail in Section 8.0 are summarized below.
• Alternative 1: No Project/No Build Alternative. Pursuant to Section 15126.6(e)(2) of the CEQA
Guidelines, the EIR is required to “discuss the existing conditions at the time the notice of preparation is
published, or if no notice of preparation is published, at the time the environmental analysis is
commenced, as well as what would be reasonably expected to occur in the foreseeable future if the
project were not approved, based on current plans and consistent with available infrastructure and
community services.”
Therefore, under this alternative, no new development would occur on the Project site, and it would
remain in its existing condition with 3 holes of golf, a driving range, putting green, and the existing pro
shop and restaurant would remain operational. This alternative compares impacts of the proposed
Project with the existing buildings and golf facilities operating at full capacity.
• Alternative 2: Reduced Project Alternative. Under this alternative, the proposed Project would be
reduced by 50 percent on the same site. The surf lagoon would consist of one 5.1-million-gallon basin
on the site. The amenity clubhouse would provide the same for the same functions (although amenities,
storage, and golf support areas would be reduced) within a 50 percent smaller three-story building
structure. The athlete accommodations building would be a 50 percent smaller two-story structure that
would provide 10 units; with five units on each level. The Project would also provide for 50 percent less
parking on the site. The areas around the 50 percent smaller development footprint would be
landscaped. Hours of operation and operational activities would be the same as those proposed by
the Project. Consistent with the proposed Project all of the golf amenities would be removed from the
Project site and the nine holes of golf (holes 10-18) to the north of Irvine Avenue and the six holes of
golf (holes 3-8) to the south of Mesa Drive would remain.
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-4
Draft EIR
May 2025
• Alternative 3: Alternative Commercial Recreation Use Alternative. Under this alternative, the
proposed Project site would be developed with a multipurpose recreational facility. A multipurpose
recreational facility contains two or more of the following land uses combined at one site: miniature
golf, batting cages, video arcade, bumper boats, go-carts, and golf driving range. The Alternative
Commercial Recreation Use Alternative would include the development of a 20,000-square-foot family
entertainment building consisting of a snack bar, dining area, restrooms, and arcade gaming area; two
outdoor 18-hole miniature golf courses; a 4-acre outdoor area for attractions and rides; and a parking
lot. Hours of operation would be consistent with those proposed by the Project.
1.6 SUMMARY OF IMPACTS
Table 1-1 summarizes the conclusions of the environmental analysis contained in this Draft EIR. The level of
significance of impacts after the proposed mitigation measures are applied are identified as significant and
unavoidable, less than significant, and no impact. Section 7.0, Effects Found Not Significant, establishes that
the proposed Project would not result in impacts related to certain thresholds from CEQA Appendix G
including agriculture and forestry, mineral resources, population and housing, and wildfire. Thus, no further
assessment of those impacts was required in the Draft EIR.
Relevant standard regulatory requirements are identified, and mitigation measures are provided for all
potentially significant impacts.
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-5
Draft EIR
May 2025
Table 1-1: Summary of Impacts
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
5.1 Aesthetics
Impact AES-1: Would the Project
have a substantial adverse effect
on a scenic vista?
Less than significant None required Less than significant
Impact AES-2: Would the Project
substantially damage scenic
resources, including but not
limited to trees, rock
outcroppings, and historic
buildings within a State scenic
highway?
No Impact None required No Impact
Impact AES-3: Would the Project,
in a non-urbanized area,
substantially degrade the
existing visual character or
quality of public views of the site
and its surroundings (public views
are those that are experienced
from publicly accessible vantage
point), or in an urbanized area,
conflict with applicable zoning
and other regulations governing
scenic quality?
Less than significant None required Less than significant
Impact AES-4: Would the Project
create a new source of
substantial light or glare which
would adversely affect day and
nighttime views in the area?
Less than significant None required Less than significant
Cumulative Less than significant None required Less than significant
5.2 Air Quality
Impact AQ-1: Would the Project
conflict with or obstruct
implementation of the applicable
air quality plan?
Less than significant None required Less than significant
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-6
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
Impact AQ-2: Would the Project
result in a cumulatively
considerable net increase of any
criteria pollutant for which the
Project region is non-attainment
under an applicable federal or
State ambient air quality
standard?
Less than significant None required Less than significant
Impact AQ-3: Would the Project
expose sensitive receptors to
substantial pollutant
concentrations?
Less than significant None required Less than significant
Impact AQ-4: Would the Project
result in other emissions (such as
those leading to odors) adversely
affecting a substantial number of
people?
Less than significant None required Less than significant
Cumulative Less than significant None required Less than significant
5.3 Biological Resources
Impact BIO-1: 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?
Potentially significant Mitigation Measure BIO-1: Pre-
Construction Roosting Bat
Survey. Project plans and
construction permitting, including
tree removal permits, shall require
that in order to avoid and/or
minimize injury to roosting bats
and avoid maternity roosts until the
maternity roost is no longer in use,
a qualified biologist shall conduct
a pre-construction bat roost survey
for roosting bats no more than 14
days prior to site disturbance. The
pre-construction bat roost survey
shall consist of a minimum of two
emergent bat surveys (conducted
consecutively or as determined by
the biologist). The emergent
Less than significant
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-7
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
surveys shall begin 30 minutes
before dusk and extend to one
hour after dark.
If roosting bats are detected onsite
outside of the bat maternity season
(April 1 through August 31), the
roost tree shall be removed in a
manner to avoid and/or minimize
injury to roosting bats. This may
include using mechanical
equipment to gently nudge the tree
trunk multiple times prior to
removal or for palm trees and
other species, to de-frond or de-
branch the tree using a mechanical
lift and gently lower the cut fronds
or branches to the ground.
Regardless of the method, the
fallen tree and/or material shall
be left undisturbed overnight until
at least the next morning to give
roosting bats time to exit before
site disturbance.
If roosting bats are detected onsite
during the maternity season
(September 1 through March 31),
the Project shall avoid the subject
roost(s) and incorporate an
avoidance buffer (300 feet or as
determined by the qualified
biologist) until after the maternity
season or until a qualified biologist
determines no maternity roosting is
occurring. The qualified biologist
shall clearly delineate any bat
maternity roosts and any required
avoidance buffers, which shall be
clearly marked with flags and/or
fencing prior to the initiation of
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-8
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
construction activities. Once the
qualified biologist approves
removal of the subject roost tree(s),
the same tree removal procedures
as outlined above shall be
implemented prior to tree removal.
Impact BIO-2: 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?
No impact None required No impact
Impact BIO-3: 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?
No impact None required No impact
Impact BIO-4: 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?
Potentially significant Mitigation Measure BIO-2: Pre-
Construction Nesting Bird Survey.
Project plans and construction
permitting, including tree removal
permits, shall state that vegetation
removal should occur outside of the
nesting bird season (generally
between February 1 and August
31). If vegetation removal is
required during the nesting bird
season, the applicant shall conduct
take avoidance surveys for nesting
birds prior to initiating vegetation
removal/clearing. Surveys shall be
Less than significant
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-9
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
conducted by a qualified
biologist(s) within three days of
vegetation removal. If active nests
are observed, a qualified biologist
shall determine appropriate
minimum disturbance buffers and
other adaptive mitigation
techniques (e.g., biological
monitoring of active nests during
construction-related activities,
staggered schedules, etc.) to
ensure that impacts to nesting birds
are avoided until the nest is no
longer active. At a minimum,
construction activities shall stay
outside of a 200-foot buffer
around the active nests. The
approved buffer zone shall be
marked in the field with
construction fencing, within which
no vegetation clearing or ground
disturbance shall commence until
the qualified biologist and City of
Newport Beach Planning Division
verify that the nests are no longer
occupied, and the juvenile birds
can survive independently from the
nests. Once the young have
fledged and left the nest, or the
nest otherwise becomes inactive
under natural conditions, normal
construction activities may occur.
Impact BIO-5: Would the Project
conflict with any local policies or
ordinances protecting biological
No impact None required No impact
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-10
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
resources, such as a tree
preservation policy or ordinance?
Impact BIO-6: 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?
No impact None required No impact
Cumulative Potentially significant Mitigation Measure BIO-1: Pre-
Construction Roosting Bat
Survey. As listed previously.
Mitigation Measure BIO-2: Pre-
Construction Nesting Bird Survey.
As listed previously.
Less than significant
5.4 Cultural Resources
Impact CUL-1: Would the Project
cause a substantial adverse
change in the significance of a
historical resource pursuant to
§15064.5?
No impact None required No impact
Impact CUL-2: Would the Project
cause a substantial adverse
change in the significance of an
archaeological resource pursuant
to §15064.5?
Potentially significant Mitigation Measure CUL-1:
Cultural Resources Monitoring
Program. Prior to issuance of
grading permits the
applicant/developer shall provide
evidence to the City of Newport
Beach Planning Division that a
qualified professional archeologist
meeting the Secretary of Interior’s
PQS for Archaeology (as defined
in the Code of Federal
Regulations, 36 CFR Part 61) has
been retained to prepare a
Cultural Resource Monitoring
Less than significant
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-11
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
Program (CRMP) and to conduct
monitoring of rough grading
activities. The CRMP shall be
developed in coordination with the
consulting tribe(s) and address the
details of all activities and
provides procedures that must be
followed in order to reduce the
impacts to cultural, tribal cultural
and historic resources to a level
that is less than significant as well
as address potential impacts to
undiscovered buried
archaeological resources
associated with this project. The
Archaeologist shall conduct
Cultural Resource Sensitivity
Training, in conjunction with the
Tribe(s) designated Tribal
Representative. The training
session shall focus on the
archaeological and tribal cultural
resources that may be encountered
during ground-disturbing activities
as well as the procedures to be
followed in such an event.
The retained Qualified
archeologist and Consulting
Tribe(s) representative shall attend
the pre-grade meeting with the
grading contractors to explain and
coordinate the requirements of the
monitoring plan.
In the event that a resource is
inadvertently discovered during
ground-disturbing activities, work
shall be halted within 60 feet of
the find until it can be evaluated
by the qualified archaeologist.
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-12
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
Construction activities can continue
in other areas. If the find is
considered a “resource” the
archaeologist shall pursue either
protection in place or recovery,
salvage and treatment of the
deposits. Recovery, salvage and
treatment protocols shall be
developed in accordance with
applicable provisions of Public
Resource Code Section 21083.2
and State CEQA Guidelines
15064.5 and 15126.4 in
consultation with the City. Per
CEQA Guidelines Section
15126.4(b)(3), preservation in
place shall be the preferred means
to avoid impacts to archaeological
resources qualifying as historical
resources. Consistent with CEQA
Guidelines Section
15126.4(b)(3)(C), if unique
archaeological resources cannot
be preserved in place or left in an
undisturbed state, recovery,
salvage, and treatment shall be
required at the
developer/applicant’s expense. If
significant pre-contact and/or
historic-era cultural resources, as
defined by CEQA (as amended,
2015), are discovered and
avoidance cannot be ensured, the
archaeologist shall develop a
Monitoring and Treatment Plan,
the drafts of which shall be
provided to consulting tribe(s) for
review and comment. The
archaeologist shall monitor the
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-13
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
remainder of the project and
implement the Plan accordingly.
Mitigation Measure CUL-2:
Monitoring Report. A final
monitoring report shall be
prepared by the qualified
archaeologist prior to issuance of
any certificate of occupancy. The
final monitoring report(s) created
as a part of the Project (isolate
records, site records, survey
reports, testing reports, etc.) shall
be submitted to the Lead Agency
and Consulting Tribe(s) for review
and comment. After approval of
all parties, the final reports are to
be submitted to the South Central
Coastal Information Center, and
the Consulting Tribe(s).
Impact CUL-3: Would the Project
disturb any human remains,
including those interred outside of
formal cemeteries?
PPP CUL-1: Human Remains.
California Health and Safety
Code Section 7050.5, CEQA
Guidelines Section 15064.5, and
Public Resources Code Section
5097.98 mandate the process to
be followed in the event of an
accidental discovery of any
human remains in a location other
than a dedicated cemetery.
California Health and Safety
Code Section 7050.5 requires
that in the event that human
remains are discovered within the
project site, disturbance of the
site shall be halted until the
coroner has conducted an
investigation into the
Less than significant None required Less than significant
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-14
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
circumstances, manner and cause
of death, and the
recommendations concerning the
treatment and disposition of the
human remains have been made
to the person responsible for the
excavation, or to his or her
authorized representative, in the
manner provided in Section
5097.98 of the Public Resources
Code. 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.
Cumulative Potentially significant Mitigation Measure CUL-1:
Cultural Resources Monitoring
Program. As listed previously.
Mitigation Measure CUL-2:
Monitoring Report. As listed
previously.
Less than significant
5.5 Energy
Impact ENE-1: Would the Project
result in potentially significant
environmental impact due to
wasteful, inefficient, or
unnecessary consumption of
energy resources, during project
construction or operation?
PDF-1: Solar: The proposed
Project includes installation of
solar panels on the roofs of the
buildings and on 14 to 18-foot-
high solar canopies in portions of
the parking areas to provide
onsite renewable energy to
provide power to the proposed
Project.
Less than significant None required Less than significant
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-15
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
Impact ENE-2: Would the Project
conflict with or obstruct a State or
local plan for renewable energy
or energy efficiency?
No Impact None required No Impact
Cumulative PDF-1: Solar. As listed previously. Less than significant None required Less than significant
5.6 Geology and Soils
Impact GEO-1i: Would the
Project directly or indirectly cause
potential substantial adverse
effects, including the risk of loss,
injury, or death involving 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?
No impact None required No impact
Impact GEO-1ii: Would the
Project directly or indirectly cause
potential substantial adverse
effects, including the risk of loss,
injury, or death involving strong
seismic ground shaking?
PPP GEO-1: CBC Compliance.
The proposed Project is required
to comply with the California
Building Standards Code (CBC)
as included in the City’s Municipal
Code as Chapter 15.04, to
preclude significant adverse
effects associated with seismic
and soils hazards. As part of CBC
compliance, CBC related and
geologist and/or civil engineer
specifications for the proposed
Project shall be incorporated into
grading plans and building
specifications as a condition of
construction permit approval.
Less than significant None required Less than significant
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-16
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
Impact GEO-1iii: Would the
Project directly or indirectly cause
potential substantial adverse
effects, including the risk of loss,
injury, or death involving seismic-
related ground failure, including
liquefaction?
PPP GEO-1: CBC Compliance. As
listed previously.
Less than significant None required Less than significant
Impact GEO-1iv: Would the
Project directly or indirectly cause
potential substantial adverse
effects, including the risk of loss,
injury, or death involving
landslides?
PPP GEO-1: CBC Compliance. As
listed previously.
No impact None required No impact
Impact GEO-2: Would the
Project result in substantial soil
erosion or the loss of topsoil?
PPP WQ-1: NPDES/SWPPP. Prior
to issuance of any grading or
demolition permits, the applicant
shall provide the City Building
and Safety Division evidence of
compliance with the NPDES
(National Pollutant Discharge
Elimination System) requirement
to obtain a construction permit
from the State Water Resource
Control Board (SWRCB). The
permit requirement applies to
grading and construction sites of
one acre or larger. The Project
applicant/proponent shall
comply by submitting a Notice of
Intent (NOI) and by developing
and implementing a Stormwater
Pollution Prevention Plan
(SWPPP) and a monitoring
program and reporting plan for
the construction site.
PPP WQ-2: WQMP. Prior to the
approval of the Grading Plan
and issuance of Grading Permits
Less than significant None required Less than significant
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-17
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
a completed Water Quality
Management Plan (WQMP) shall
be submitted to and approved by
the City Public Works Agency.
The WQMP shall identify all Post-
Construction, Site Design, Source
Control, and Treatment Control
Best Management Practices
(BMPs) that will be incorporated
into the development project in
order to minimize the adverse
effects on receiving waters.
PPP WQ-3: WQMP. Prior to the
approval of the Grading Plan
and issuance of Grading Permits,
a completed Water Quality
Management Plan (WQMP) shall
be submitted to and approved by
the City Public Works
Department. The WQMP shall
identify all Post-Construction, Site
Design, Source Control, and
Treatment Control Best
Management Practices (BMPs)
that will be incorporated into the
development project in order to
minimize the adverse effects on
receiving waters.
Impact GEO-3: Would the
Project 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?
PPP GEO-1: CBC Compliance. As
listed previously.
Less than significant None required Less than significant
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-18
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
Impact GEO-4: Would the
Project 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?
PPP GEO-1: CBC Compliance. As
listed previously.
Less than significant None required Less than significant
Impact GEO-5: Would the
Project 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 None required No impact
Impact GEO-6: Would the
Project directly or indirectly
destroy a unique paleontological
resource or site or unique
geologic feature?
Potentially significant Mitigation Measure PAL-1: Prior
to commencement of any grading
activity on site, a paleontologist
shall be retained to develop a
Paleontological Resources Impact
Mitigation Program (PRIMP) for
this project. The PRIMP shall include
the methods that will be used to
protect paleontological resources
that may exist within the project
area as well as procedures for
monitoring, fossil preparation and
identification, curation into a
repository, and preparation of a
report at the conclusion of grading.
The PRIMP shall be consistent with
the guidelines of the Society of
Vertebrate Paleontology (SVP)
and include, but not be limited to,
the following:
• Excavation and grading
activities in deposits with high
paleontological sensitivity
(Young Axial Channel Deposits
Less than significant
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-19
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
below a depth of 10 feet and
Old Paralic Deposits Overlain
by Alluvial Fan Deposits) shall be
monitored by a paleontological
monitor following a PRIMP. No
monitoring is required for
excavations in deposits with no
paleontological sensitivity
(Artificial Fill).
• If paleontological resources are
encountered during the course of
ground disturbance, the
paleontological monitor shall
have the authority to
temporarily redirect construction
away from the area of the find
in order to assess its significance.
In the event that paleontological
resources are encountered when
a paleontological monitor is not
present, work in the immediate
area of the find shall be
redirected and a paleontologist
should be contacted to assess the
find for significance. If
determined to be significant, the
fossil shall be collected from the
field.
• Collected resources shall be
prepared to the point of
identification, identified to the
lowest taxonomic level possible,
cataloged, and curated into the
permanent collections of a
scientific institution.
• At the conclusion of the
monitoring program, a report of
findings shall be prepared to
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-20
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
document the results of the
monitoring program.
Cumulative PPP GEO-1: CBC Compliance.
As listed previously.
Potentially significant Mitigation Measure PAL-1: As
listed previously.
Less than significant
5.7 Greenhouse Gas Emissions
Impact GHG-1: Would the
Project generate greenhouse gas
emissions, either directly or
indirectly, that may have a
significant impact on the
environment?
PDF-1 Solar. As listed previously. Less than significant None required Less than significant
Impact GHG-2: Would the
Project conflict with an applicable
plan, policy, or regulation
adopted for the purpose of
reducing the emissions of
greenhouse gases?
Less than significant None required Less than significant
Cumulative PDF-1 Solar. As listed previously. Less than significant None required Less than significant
5.8 Hazards and Hazardous Materials
Impact HAZ-1: Would the
Project create a significant
hazard to the public or the
environment through the routine
transport, use, or disposal of
hazardous materials?
PPP WQ-1: NPDES/SWPPP. As
listed previously.
Less than significant None required Less than significant
Impact HAZ-2: Would the
Project 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?
PPP HAZ-1: SCAQMD Rule
1403. Prior to issuance of
demolition permits, the Project
applicant shall submit verification
to the City Building and Safety
Division that an asbestos survey
has been conducted at all existing
buildings located on the Project
site. If asbestos or asbestos
containing material is found, the
Project applicant shall follow all
Less than significant None required Less than significant
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-21
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
procedural requirements and
regulations of the South Coast Air
Quality Management District
(SCAQMD) Rule 1403. Rule 1403
regulations require that the
following actions be taken:
notification of SCAQMD prior to
construction activity, asbestos
removal in accordance with
prescribed procedures,
placement of collected asbestos
in leak-tight containers or
wrapping, and proper disposal.
PPP HAZ-2: Lead. Prior to
issuance of demolition permits,
the Project applicant shall submit
verification to the City Building
and Safety Division that a lead-
based paint survey has been
conducted at all existing buildings
located on the Project site. If
lead-based paint is found, the
Project applicant shall follow all
procedural requirements and
regulations for proper removal
and disposal of the lead-based
paint. CalOSHA has established
limits of exposure to lead
contained in dusts and fumes.
Specifically, CCR Title 8, Section
1532.1 provides for exposure
limits, exposure monitoring, and
respiratory protection, and
mandates good working
practices by workers exposed to
lead.
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-22
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
PPP WQ-1: NPDES/SWPPP. As
listed previously.
PPP WQ-3: WQMP. As listed
previously.
Impact HAZ-3: Would the
Project emit hazardous emissions
or handle hazardous or acutely
hazardous materials, substances,
or waste within one-quarter mile
of an existing or proposed
school?
PPP WQ-1: NPDES/SWPPP. As
listed previously.
Less than significant None required Less than significant
Impact HAZ-4: Would the
Project be located on a site which
is included on a list of hazardous
materials sites compiled pursuant
to Government Code §65962.5
and, as a result, create a
significant hazard to the public or
the environment?
No impact None required No impact
Impact HAZ-5: 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?
PDF-2 Vegetation: The proposed
Project does not include
landscaping or other vegetation
that produces seeds, fruits, nuts,
or berries, such as fruit bearing
trees and shrubs. Likewise, Project
site areas would be planted with
seed mixtures that do not contain
millet or any other large seed
producing grass.
Less than significant None required Less than significant
Impact HAZ-6: Would the
Project impair implementation of
or physically interfere with an
adopted emergency response
plan or emergency evacuation
plan?
No impact None required No impact
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-23
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
Impact HAZ-7: Would the
Project expose people or
structures, either directly or
indirectly, to a significant risk of
loss, injury, or death involving
wildland fires?
Less than significant None required Less than significant
Cumulative Less than significant None required Less than significant
5.9 Hydrology and Water Quality
Impact HYD-1: Would the Project
violate any water quality
standards or waste discharge
requirements or otherwise
substantially degrade surface or
groundwater quality?
PPP WQ-1: NPDES/SWPPP. As
listed previously.
PPP WQ-3: WQMP. As listed
previously.
Less than significant None required Less than significant
Impact HYD-2: Would the Project
substantially decrease
groundwater supplies or interfere
substantially with groundwater
recharge such that the Project
may impede sustainable
groundwater management of the
basin?
PPP WQ-2: Groundwater
Dewatering Permits. Prior to
initiation of excavation activities,
the Project applicant shall obtain
coverage under the Santa Ana
RWQCB General Waste
Discharge Requirements for
Discharges to Surface Waters
Resulting from De Minimis
Discharges or Groundwater
Dewatering Operations, and/or
Groundwater Cleanup/
Remediation Operations at Sites
within the Newport Bay
Watershed Permit (Order No.
R8-2019-0061, NPDES No.
CAG918002), or any other
subsequent permit for
dewatering activities, and
provide evidence of coverage to
the City of Newport Beach
designee. This shall include
submission of a Notice of Intent
Less than significant None required Less than significant
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-24
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
(NOI) for coverage under the
permit to the Santa Ana Regional
Water Quality Control Board
(RWQCB) at least 60 days prior
to the start of excavation
activities and anticipated
discharge of dewatered
groundwater to surface waters.
Groundwater dewatering
activities shall comply with all
applicable provisions in the
permit, including water sampling,
analysis, treatment (if required),
and reporting of dewatering-
related discharges. Upon
completion of groundwater
dewatering activities, a Notice of
Termination shall be submitted to
the Santa Ana RWQCB.
Impact HYD-3: Would the Project
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 result in
a substantial erosion or siltation
on- or off-site;
PPP WQ-1: NPDES/SWPPP. As
listed previously.
PPP WQ-3: WQMP. As listed
previously.
Less than significant None required Less than significant
Impact HYD-4: Would the Project
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
substantially increase the rate or
PPP WQ-1: NPDES/SWPPP. As
listed previously.
PPP WQ-3: WQMP. As listed
previously.
Less than significant None required Less than significant
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-25
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
amount of surface runoff in a
manner which would result in
flooding on- or off-site;
Impact HYD-5: Would the Project
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 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; or
PPP WQ-1: NPDES/SWPPP. As
listed previously.
PPP WQ-2: Groundwater
Dewatering Permits. As listed
previously.
Less than significant None required Less than significant
Impact HYD-6: Would the Project
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 impede
or redirect flood flows?
Less than significant None required Less than significant
Impact HYD-7: In flood hazard,
tsunami, or seiche zones, would
the Project risk release of
pollutants due to Project
inundation?
Less than significant None required Less than significant
Impact HYD-8: Would the Project
conflict with or obstruct
implementation of a water
quality control plan or
sustainable groundwater
management plan?
PPP WQ-1: NPDES/SWPPP. As
listed previously.
PPP WQ-2: Groundwater
Dewatering Permits. As listed
previously.
Less than significant None required Less than significant
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-26
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
PPP WQ-3: WQMP. As listed
previously.
Cumulative PPP WQ-1: NPDES/SWPPP. As
listed previously.
PPP WQ-2: Groundwater
Dewatering Permits. As listed
previously.
PPP WQ-3: WQMP. As listed
previously.
Less than significant None required Less than significant
5.10 Land Use and Planning
Impact LU-1: Would the Project
physically divide an established
community?
Less than significant None required Less than significant
Impact LU-2: Would the Project
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 None required Less than significant
Cumulative Less than significant None required Less than significant
5.11 Noise
Impact NOI-1: Would the Project
result in generation of a
substantial temporary or
permanent increase in ambient
noise levels in the vicinity of the
Project in excess of standards
established in the local general
plan or noise ordinance, or
applicable standards of other
agencies?
Less than significant None required Less than significant
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-27
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
Impact NOI-2: Would the Project
result in generation of excessive
groundborne vibration or
groundborne noise levels?
Less than significant None required Less than significant
Impact NOI-3: 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?
Less than significant None required Less than significant
Cumulative Less than significant None required Less than significant
5.12 Public Services
Impact PS-1: 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 fire
protection services?
(ii) Police protection?
(iii) Schools?
(v) Other public facilities?
Less than significant None required Less than significant
Impact PS-2: Would the Project
result in substantial adverse
physical impacts associated with
Less than significant None required Less than significant
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-28
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
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 police
protection services?
Impact PS-3: 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 school
services?
Less than significant None required Less than significant
Impact PS-4: 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
Less than significant None required Less than significant
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-29
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
performance objectives for other
public service facilities?
Cumulative Less than significant None required Less than significant
5.13 Parks and Recreation
Impact REC-1: Would the Project
result in substantial adverse
physical impacts associated with
the provision of ne or physically
altered park and recreation
facilities, need for new or
physically altered park or
recreation facilities, the
construction of which could cause
significant environmental impacts,
in order to maintain acceptable
park and recreation service
ratios?
Less than significant None required Less than significant
Impact REC-2: 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 None required Less than significant
Impact REC-3: 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 None required Less than significant
Cumulative Less than significant None required Less than significant
5.14 Transportation
Impact TRA-1: Would the Project
conflict with a program, plan,
Less than significant None required Less than significant
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-30
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
ordinance, or policy addressing
the circulation system, including
transit, roadway, bicycle, and
pedestrian facilities?
Impact TRA-2: Would the Project
conflict or be inconsistent with
CEQA Guidelines § 15064.3,
subdivision (b)?
Less than significant None required Less than significant
Impact TRA-3: Would the Project
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 None required Less than significant
Impact TRA-4: Would the Project
result in inadequate emergency
access?
Less than significant None required Less than significant
Cumulative Less than significant None required Less than significant
5.15 Tribal Cultural Resources
Impact TCR-1: Would the Project
cause a substantial adverse
change in the significance of a
tribal cultural resource, defined in
Public Resources Code § 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 listed or eligible for
listing in the California Register of
Historical Resources, or in a local
register of historical resources as
Potentially significant Mitigation Measure TCR-1: Retain
a Native American Monitors Prior
to Commencement of Ground-
Disturbing Activities
A. The Project plans, specifications,
and grading permits shall state
that the Project applicant shall
retain Native American
monitor(s). The monitor(s) shall
be retained prior to the
commencement of any “ground-
disturbing activity” for the
Project (both onsite and any
offsite locations that are
included in the Project
description and/or required in
Less than significant
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-31
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
defined in Public Resources Code
section 5020.1(k)?
connection with the proposed
Project, such as public
improvement work). “Ground-
disturbing activity” shall
include, but is not limited to,
demolition, pavement removal,
potholing, auguring, grubbing,
tree removal, boring, grading,
excavation, drilling, and
trenching.
B. A copy of the executed
monitoring agreement(s) shall
be submitted to the Lead
Agency prior to the earlier of
the commencement of any
ground-disturbing activity, or
the issuance of any permit
necessary to commence a
ground-disturbing activity.
C. The monitor(s) shall complete
daily monitoring logs that shall
provide descriptions of the
relevant ground-disturbing
activities, the type of construction
activities performed, locations of
ground-disturbing activities, soil
types, cultural-related materials,
and any other facts, conditions,
materials, or discoveries of
significance to the tribe(s).
Monitor logs shall identify and
describe any discovered TCRs,
including but not limited to,
Native American cultural and
historical artifacts, remains,
places of significance, etc.,
(collectively, tribal cultural
resources, or “TCR”), as well as
any discovered Native American
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-32
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
(ancestral) human remains and
burial goods. Copies of monitor
logs shall be provided to the
Project applicant upon written
request to the tribe(s).
D. Onsite tribal monitoring shall
conclude upon the earlier of the
following (1) written
confirmation to the monitoring
tribe(s) from a designated point
of contact for the Project
applicant or Lead Agency that
all ground-disturbing activities
and phases that may involve
ground-disturbing activities on
the Project site or in connection
with the Project are complete;
or (2) a determination and
written notification by the
monitoring tribe(s) to the Lead
Agency that no future, planned
construction activity and/or
development/construction
phase at the Project site
possesses the potential to
impact TCRs.
Mitigation Measure TCR-2:
Unanticipated Discovery of Tribal
Cultural Resource Objects (Non-
Funerary/Non-Ceremonial)
A. Upon discovery of any TCRs, all
construction activities in the
immediate vicinity of the
discovery shall cease (i.e., not
less than the surrounding 50
feet) and shall not resume until
the discovered TCR has been
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-33
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
fully assessed by a Native
American monitor in
consultation with a qualified
archaeologist. The monitoring
tribe(s) shall recover and retain
all discovered TCRs in the form
and/or manner the tribe(s)
deems appropriate, in the
tribe(s) sole discretion, and for
any purpose the tribe(s) deems
appropriate, including for
educational, cultural and/or
historic purposes.
Mitigation Measure TCR-3:
Unanticipated Discovery of
Human Remains and Associated
Funerary or Ceremonial Objects
A. Native American human
remains are defined in PRC
5097.98 (d)(1) as an
inhumation or cremation, and in
any state of decomposition or
skeletal completeness. Funerary
objects, called associated
grave goods in Public Resources
Code Section 5097.98, are
also to be treated according to
this statute.
B. If Native American human
remains and/or grave goods
are discovered or recognized
on the Project site, then Public
Resource Code 5097.9 as well
as Health and Safety Code
Section 7050.5 shall be
followed.
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-34
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
C. Human remains and
grave/burial goods shall be
treated alike per California
Public Resources Code section
5097.98(d)(1) and (2).
D. Preservation in place (i.e.,
avoidance) is the preferred
manner of treatment for
discovered human remains
and/or burial goods.
E. Any discovery of human
remains/burial goods shall be
kept confidential to prevent
further disturbance.
Impact TCR-2: Would the Project
cause a substantial adverse
change in the significance of a
tribal cultural resource, defined in
Public Resources Code § 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 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 § 5024.1, the
lead agency shall consider the
significance of the resource to a
California Native American tribe?
PPP CUL-1: Human Remains. As
listed previously.
Potentially significant Mitigation Measures TCR-1:
Retain a Native American
Monitor Prior to Commencement
of Ground-Disturbing Activities:
As listed previously.
Mitigation Measure TCR-2:
Unanticipated Discovery of Tribal
Cultural Resource Objects (Non-
Funerary/Non-Ceremonial): As
listed previously.
Mitigation Measure TCR-3:
Unanticipated Discovery of
Human Remains and Associated
Funerary or Ceremonial Objects:
As listed previously.
Less than significant
Cumulative Potentially significant Mitigation Measures TCR-1:
Retain a Native American
Less than significant
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-35
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
Monitor Prior to Commencement
of Ground-Disturbing Activities:
As listed previously.
Mitigation Measure TCR-2:
Unanticipated Discovery of Tribal
Cultural Resource Objects (Non-
Funerary/Non-Ceremonial): As
listed previously.
Mitigation Measure TCR-3:
Unanticipated Discovery of
Human Remains and Associated
Funerary or Ceremonial Objects.
As listed previously.
5.16 Utilities and Service Systems
Impact UT-1: Would the Project
require or result in the
construction of new water
facilities, or expansion of existing
facilities, the construction of which
could cause significant
environmental effects ?
Less than significant None required Less than significant
Impact UT-2: Would the Project
have sufficient water supplies
available to serve the Project and
reasonably foreseeable future
development during normal, dry,
and multiple dry years?
Less than significant None required Less than significant
Impact UT-3: Would the Project
require or result in the
construction of new wastewater
facilities, or expansion of existing
facilities, the construction of which
could cause significant
environmental effects?
Less than significant None required Less than significant
Impact UT-4: Would the Project
result in a determination by the
Less than significant None required Less than significant
Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-36
Draft EIR
May 2025
Impact
Applicable Plan, Program, or
Policies (PPP), or Project Design
Feature (PDF)
Level of Significance
Before Mitigation Mitigation Measures Level of Significance
After Mitigation
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?
Impact UT-5: Would the Project
require or result in the
construction of new stormwater
drainage facilities, or expansion
of existing facilities, the
construction of which could cause
significant environmental effects?
Less than significant None required Less than significant
Impact UT-6: Would the Project
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 None required Less than significant
Impact UT-7: Would the Project
comply with federal, State, and
local management and reduction
statutes and regulations related
to solid waste?
No impact None required No impact
Impact UT-8: Would the Project
require or result in the relocation
or construction of a new or
expanded electric power, natural
gas, or telecommunications
facilities, the construction of which
could cause significant
environmental effects?
Less than significant None required Less than significant
Cumulative Less than significant None required Less than significant
Snug Harbor Surf Park Project 2. Introduction
City of Newport Beach 2-1
Draft EIR
May 2025
2. Introduction
This Draft Environmental Impact Report (EIR) (State Clearinghouse [SCH] Number 2024110238) is an
informational document that evaluates the environmental effects that may result from the construction and
operation of the proposed Snug Harbor Surf Park Project (Project), as detailed in Chapter 3.0, Project
Description. This EIR has been prepared by the City of Newport Beach in its capacity as Lead Agency, as
that term is defined in Section 15367 of the California Environmental Quality Act (CEQA) Guidelines (14
California Code of Regulations Section 15000 et seq.) and in conformance with CEQA (Public Resources
Code Section 21000 et seq.). This EIR has been prepared to identify, analyze, and mitigate the potentially
significant environmental effects of the proposed Project.
CEQA requires each EIR to reflect the independent judgment of the Lead Agency, including but not limited
to the thresholds of significance used to analyze Project impacts, analyses and conclusions regarding the
level of significance of impacts both before and after mitigation, the identification and application of
mitigation measures to avoid or reduce Project-related impacts, and the consideration of alternatives to the
proposed Project. In preparing this Draft EIR, the City of Newport Beach has employed CEQA and
environmental technical specialists; however, the analyses and conclusions set forth in this Draft EIR reflect
the independent judgment of the City as Lead Agency.
2.1 PURPOSE OF THE CALIFORNIA ENVIRONMENTAL QUALITY ACT
CEQA requires that all State and local governmental agencies consider the environmental consequences of
projects over which they have discretionary authority prior to taking action on those projects. Pursuant to the
provisions of CEQA Guidelines Section 15121(a), this Draft EIR is intended as an informational document to
inform public agency decision makers and the general public of the significant environmental effects of the
proposed Project, identify possible ways to avoid or minimize those significant effects, and describe
reasonable alternatives to the Project that might avoid or lessen significant environmental effects. Thus, this
Draft EIR is intended to aid the review and decision-making process. The CEQA Guidelines provide the
following information regarding the purpose of an EIR:
• Project Information and Environmental Effects. An EIR is an informational document that will inform
public agency decision makers and the public generally of the potential significant environmental
effect(s) of a project, identify possible ways to minimize the significant effects, and describe reasonable
alternatives to the project. The public agency shall consider the information in the EIR along with other
information that may be presented to the agency (CEQA Guidelines Section 15121(a)).
• Standards for Adequacy of an EIR. An EIR should be prepared with a sufficient degree of analysis to
enable decision makers to make an intelligent decision that takes into account environmental
consequences. An evaluation of the environmental effects of a proposed project need not be exhaustive,
but the sufficiency of an EIR is to be reviewed in the light of what is reasonably feasible. Disagreement
among experts does not make an EIR inadequate, but the EIR should summarize the main points of
disagreement among the experts. The courts have looked not for perfection but for adequacy,
completeness, and a good faith effort at full disclosure (CEQA Guidelines Section 15151).
As a public disclosure document, the purpose of an EIR is not to recommend either approval or denial of a
project, but to provide information regarding the physical environmental changes that would result from an
action being considered by a public agency to aid in the agency’s decision-making process.
Snug Harbor Surf Park Project 2. Introduction
City of Newport Beach 2-2
Draft EIR
May 2025
2.2 LEGAL AUTHORITY
This Draft EIR has been prepared in accordance with all criteria, standards, and procedures of CEQA
(California Public Resource Code Section 21000 et seq.) and the CEQA Guidelines (California Code of
Regulations, Title 14, Division 6, Chapter 3, Section 15000 et seq.).
Lead Agency
Pursuant to CEQA Section 21067 and CEQA Guidelines Article 4 and Section 15367, the City of Newport
Beach is the Lead Agency under whose authority this Draft EIR has been prepared. “Lead Agency” refers to
the public agency that has the principal responsibility for carrying out or approving a project. Serving as
the Lead Agency and before taking action on any approvals for the Project, the City of Newport Beach has
the obligation to: (1) ensure that this Draft EIR has been completed in accordance with CEQA; (2) review and
consider the information contained in this Draft EIR as part of its decision-making process; (3) make a
statement that this Draft EIR reflects the City of Newport Beach’s independent judgment; (4) ensure that all
significant effects on the environment are eliminated or substantially lessened where feasible; and, if
necessary, (5) make written findings for each unavoidable significant environmental effect stating the reasons
why mitigation measures or Project alternatives identified in this Draft EIR are infeasible and citing the
specific benefits of the proposed Project that outweigh its unavoidable adverse effects (CEQA Guidelines
Sections 15090 through 15093).
Pursuant to CEQA Guidelines Sections 15040 through 15043, and upon completion of the CEQA review
process, the City of Newport Beach will have the legal authority to do any of the following:
• Approve the Project;
• Require feasible changes in any or all activities involved in the Project in order to substantially lessen or
avoid significant effects on the environment;
• Disapprove the Project, if necessary, in order to avoid one or more significant effects on the environment
that would occur if the Project was approved as proposed; or
• Approve the Project even though the Project would cause a significant effect on the environment if the
City of Newport Beach makes a fully informed and publicly disclosed decision that: (1) there is no
feasible way to lessen the effect or avoid the significant effect; and (2) expected benefits from the
Project will outweigh significant environmental impacts of the Project.
Responsible Agency
A responsible agency refers to a public agency other than the lead agency that has discretionary approval
over the project. Responsible agencies include the Regional Water Quality Control Board (RWQCB) for
review of the National Pollutant Discharge Elimination System (NPDES) Construction General Permit
application; the South Coast Air Quality Management District (SCAQMD) for review of project equipment
subject to SCAQMD Rule requirements and prohibitory rules; and the Orange County Health Care Agency
(OCHCA) for issuance of permits related to water safety and restaurant operations. Due to the Project’s
location near John Wayne Airport (SNA), the Project requires an aeronautical review by the (FAA) and an
Airport Environs Land Use Plan (AELUP) consistency review by the Orange County Airport Land Use
Commission (ALUC). The EIR will also be submitted to these agencies for review and comment.
Trustee Agency
A trustee agency refers to a State agency having jurisdiction by law over natural resources affected by a
project. Trustee agencies include the California Department of Fish and Wildlife (CDFW) for administering
the California Endangered Species Act (CESA) and other aspects of the California Fish and Game Code,
Snug Harbor Surf Park Project 2. Introduction
City of Newport Beach 2-3
Draft EIR
May 2025
and United States Fish and Wildlife Service (USFWS) for administering the federal Endangered Species Act
(ESA) and related permitting requirements.
2.3 ENVIRONMENTAL IMPACT REPORT PROCESS
A project-level analysis has been provided pursuant to CEQA Guidelines Section 15161. This Draft EIR meets
the content requirements discussed in CEQA Guidelines Article 9, beginning with CEQA Guidelines Section
15120.
2.3.1 Notice of Preparation
Pursuant to the requirements of CEQA, the City of Newport Beach issued a Notice of Preparation (NOP) for
the Project, which was distributed on November 7, 2024, for a public review period of 30 days through
December 6, 2024. Per CEQA Guidelines Section 15082, the NOP was submitted to the State Clearinghouse
(SCH) within the Office of Planning & Research (OPR), County Clerk, responsible and trustee agencies,
counties and cities bordering the site, adjacent properties, and organizations and individuals that have
requested notification. In addition, the NOP was posted on the Project site, on the City’s website, at City Hall
and the City libraries. The City emailed a “News Splash” to alert interested parties of the postings.
The purpose of the NOP was to solicit early comments from public agencies with expertise in subjects that
are discussed in this Draft EIR and to solicit comments from the public regarding potential Project
environmental impacts. In addition, the NOP provided notice of the EIR scoping meeting. As provided in the
NOP, the City of Newport Beach determined through the initial review process that impacts related to the
following topics are potentially significant and required a detailed level of analysis in this Draft EIR.
• Aesthetics
• Air quality
• Biological resources
• Cultural resources
• Energy
• Geology and soils
• Greenhouse gas emissions
• Hazards and hazardous materials
• Land use and planning
• Noise
• Hydrology and water quality
• Public services
• Parks and Recreation
• Transportation
• Tribal cultural resources
• Utilities and service systems
The NOP requested members of the public and public agencies to provide input on the scope and content
of environmental impacts that should be included in the EIR being prepared. Comments received on the NOP
are included in Appendix A and are summarized in Table 2-1, which also includes a reference to the Draft
EIR sections in which issues raised in the comment letters are addressed.
Table 2-1: Summary of NOP Comment Letters
Comment Letter and Commet Relevant Draft EIR Sections
State and Local Agencies
California Department of Fish and Wildlife, November 15, 2024
This comment letter requests that the DEIR provide a
discussion and full disclosure of potential environmental
impacts to special status species with potential to occur
on the Project site. The comment letter requests an
adequate biological resources assessment and lists
information regarding biological resources that should
be included in the DEIR. The comment letter also requests
5.3, Biological Resources
5.3.6, Environmental Impacts, Impact BIO-1
5.3.7, Cumulative Impacts
Snug Harbor Surf Park Project 2. Introduction
City of Newport Beach 2-4
Draft EIR
May 2025
Comment Letter and Commet Relevant Draft EIR Sections
focused surveys, mitigation, and permits (if applicable)
for those species. This letter requests a complete
analysis of direct, indirect, and cumulative impacts as it
relates to wildlife movement and biological resources.
California Coastal Commission, December 4, 2024
This comment letter states that the proposed Project site
is located adjacent to the Coastal Zone Boundary, and
that the City should request a boundary determination
from the Coastal Commission to determine if any portion
of the Project site is located within the Coastal Zone. If
the Project site is located within the Coastal Zone, a
Coastal Development Permit from the City of Newport
Beach would be required.
5.10, Land Use and Planning
5.10.6, Environmental Impacts. Impact LU-2
California Department of Transportation, December 6, 2024
This comment letter states that the Project site is within
the vicinity of State Route (SR) 55 and SR 73 which are
both owned and operated by Caltrans, making
Caltrans a responsible agency. The comment letter
recommends the design of complete streets with
pedestrian-oriented LED lighting as well as including
short-term bicycle parking due to the Project site’s
proximity to class II bike lanes on Mesa Drive and Irvine
Avenue. The comment also requests that the Draft EIR
discuss the Coastal Zone, and consider upgrading the
crosswalks at the nearby intersections. The letter further
states that a Traffic Impact Study, Level of Service
Assessment, and a Vehicle Miles Traveled Analysis at
road segments that could impact SR 73 &55 should be
completed as well as a Traffic Management Plan. The
comment concludes in stating that should any work be
performed within the Caltrans right-of-way, a
discretionary review and encroachment permit will be
required prior to construction.
5.14, Transportation
5.14.6, Environmental Impacts, Impact TRA-1
Orange County Airport Land Use Commission, December 6, 2024
The letter states that the proposed Project site is located
approximately 3,900 feet from the end of the runway
(2L) and is within the John Wayne Airport (JWA) Airport
Planning/Area/Notification Area. The comment further
states that the Project site is within the 65 dB CNEL
contour for JWA, and the EIR should address any
potential noise impacts of airport operations. The
Project site is also within the Federal Aviation
Administration (FAA) Notification Area as well as the
Federal Aviation Regulations (FAR) Part77, Obstruction
Imaginary Surfaces for JWA. The EIR should address
potential height restrictions and safety concerns related
to the Project vicinity to the airport. The letter concludes
in stating that because the Project would require a
General Plan Amendment, the Project is also required
to be submitted to the Airport Land Use Commission
prior to City Council adoption.
5.8, Hazards and Hazardous Materials
5.8.6, Environmental Impacts, Impact HAZ-5
5.11, Noise
5.11.6, Environmental Impacts, Impact NOI-3
Snug Harbor Surf Park Project 2. Introduction
City of Newport Beach 2-5
Draft EIR
May 2025
Comment Letter and Commet Relevant Draft EIR Sections
Organization
California Cultural Resource Preservation Alliance, November 20, 2024
The comment states that the Project site was historically
populated by the ancestors of the Juaneño/Acjachemen
and expresses concern over archaeological resources The
comment recommends that an archeological survey
should be conducted by a qualified archeologist.
5.4, Cultural Resources
5.4.6, Environmental Impacts, Impact CUL-2
5.15, Tribal Cultural Resources
5.15.6, Environmental Impacts, Impact TCR-1
Public Comments
Linda Giedt, November 7, 2024
When will Project plans be publicly available? 3.0, Project Description
Laurie Kelly, November 8, 2024
Proposed Project would bring outside visitors and not
serve residents. No road improvements are included
and Irvine Avenue, Bristol, and the 73 freeway will see
increased traffic and accidents. Additionally, cars
speed through the Bayview Heights community.
5.14, Transportation
5.14.2.1, State Regulations
5.14.6, Environmental Impacts, Impact TRA-3
Jeff Sue, November 8, 2024
This letter expresses opposition to the proposed Project
as it would result in the loss of the existing affordable
recreation provided by the Newport Beach Golf
Course.
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Michael Clayton, November 11, 2024
This letter requested information on how the remainder
of the golf course would operate as well as requested
any additional City discussions that were had about the
Project.
3.0, Project Description
3.8, Operations
Nancy Kreft, November 12, 2024
Opposes the proposed Project N/A
Jon Rosen, November 12, 2024
Supports the proposed Project. N/A
Danielle Dino, November 12, 2024
Loss of open space, increase in traffic 5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
5.14, Transportation
5.14.2.1, State Regulations
5.14.6, Environmental Impacts, Impact TRA-1
Vincent Capizzi, November 12, 2024
Opposes the proposed Project N/A
Lance Niederhaus, November 12, 2024
Supports the proposed Project. N/A
Mike Battin, November 12, 2024
This comment states that the Project does not fit the non-
commercial setting of the golf course and open space
currently onsite.
5.1, Aesthetics,
5.1.6, Environmental Impacts, Impact AES-3
5.10, Land Use and Planning
5.10.6, Environmental Impacts, Impact LU-2
Snug Harbor Surf Park Project 2. Introduction
City of Newport Beach 2-6
Draft EIR
May 2025
Comment Letter and Commet Relevant Draft EIR Sections
Laura Mulchay, November 12, 2024
This letter expresses opposition to the proposed Project
as it would result in the loss of the existing affordable
recreation provided by the Newport Beach Golf
Course. The comment also expresses concerns over the
viability of a surf park near the ocean and the increase
in water usage and disrupting wildlife.
5.3, Biological Resources.
5.3.6, Environmental Impacts
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
5.16, Utilities and Service Systems
5.16.6, Environmental Impacts, Impact UTIL-2
Kristen Panehal, November 12, 2024
This letter expresses concerns over noise as well as 8-
foot-tall retaining walls blocking views. The commenter
is also concerned about the loss of popular golf
recreation used by the community.
5.1, Aesthetics
5.1.6, Environmental Impacts, Impact AES-3
5.11, Noise
5.11.6 Environmental Impacts, Impact NOI-1
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Liz Maxson, November 12, 2024
Opposes the proposed Project N/A
Kristine Benson, November 12, 2024
Opposes the proposed Project due to such close
proximity to the beach.
N/A
Michael Hussey, November 12, 2024
Opposes the proposed Project N/A
Emily Norton, November 12, 2024
Supports the proposed Project. N/A
Laura Cleary, November 12, 2024
Supports the proposed Project. N/A
Susan Bubb, November 12, 2024
This commenter opposes the Project due to the potential
increased vehicle and bicycle traffic on already
congested roadways with young, inexperienced
drivers/riders. The commenter explains that there is no
reason to have a surf park near the beach.
5.14, Transportation
5.14.2.1, State Regulations
5.14.6, Environmental Impacts, Impact TRA-1
Mike Skibba, November 12, 2024
The comment expresses concerns over the viability of a
surf park near the ocean and the increase in traffic.
5.14, Transportation
5.14.2.1, State Regulations
5.14.6, Environmental Impacts, Impact TRA-1
Jon Langford, November 12, 2024
The comment requested information about who will be
running the Scoping meeting and if it will it be
livestreamed.
N/A
Alicia Downing, November 12, 2024
This comment expresses concern about the increased
traffic and tourists in the area. The letter points to
similar traffic impacts with the Lower Castaways Park
5.14, Transportation
5.14.2.1, State Regulations
5.14.6, Environmental Impacts, Impact TRA-1
Snug Harbor Surf Park Project 2. Introduction
City of Newport Beach 2-7
Draft EIR
May 2025
Comment Letter and Commet Relevant Draft EIR Sections
Community Pool Project will lead to increased traffic,
parking issues, trash, and crowds.
Mandy McDonnell, November 12, 2024
Supports the proposed Project. N/A
Lauryl and Andy Boyum, November 12, 2024
This comment expresses concern over the loss of the
affordable driving range and golf course. The letter
states that the Project would not contribute housing on a
site identified in the Housing Element. The comment also
expresses concerns over the viability of a surf park near
the ocean
5.10, Land Use and Planning
5.10.3.2, Existing General Plan Land Use and
Zoning Designations
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Lonnie and Marie Nadal, November 12, 2024
This comment expresses concern over the loss of the
affordable driving range and golf course. The comment
concludes in stating that the redevelopment is an
attempt to build apartments onsite, which the
commenter believes are located too close to the airport.
5.10, Land Use and Planning
5.10.6, Environmental Impact, Impact LU-2
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Macon Brock, November 12, 2024
Supports the proposed Project. N/A
Jami Sepulveda, November 12, 2024
This comment expresses concern over the loss of the
affordable driving range and golf course.
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Raegan Barry, November 12, 2024
The comment expresses concerns over the viability of a
surf park near the ocean.
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Brad Pence, November 12, 2024
Supports the proposed Project. N/A
Carolyn Scroggs, November 12, 2024
The commenter expresses concern over the increase in
vehicle and bicycle traffic on already congested
roadways with young, inexperienced drivers/riders. No
reason to have a surf park near the beach.
5.14, Transportation
5.14.2.1, State Regulations
5.14.6, Environmental Impacts, Impact TRA-1
Sandy MacDougall, November 12, 2024
This comment letter expresses concern over the potential
noise impacts from airport runways.
5.11, Noise
5.11.6 Environmental Impacts, Impact NOI-3
Brady McKelheer, November 12, 2024
Supports the proposed Project. N/A
Nancy Kreft, November 12, 2024
Opposes the proposed Project N/A
Joseph Kristofl, November 13, 2024
This comment expresses concern over the loss of the
affordable driving range and golf course.
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Snug Harbor Surf Park Project 2. Introduction
City of Newport Beach 2-8
Draft EIR
May 2025
Comment Letter and Commet Relevant Draft EIR Sections
Gary Dial, November 13, 2024
The comment expresses concern over the viability of a
surf park near the ocean.
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Ted Canedy. November 13, 2024
The comment letter expresses concern about the added
traffic in an already busy area as well as increasing
noise from traffic. The comment states that the Project
would result in the loss of an affordable driving range
and golf course used by community members.
5.11, Noise
5.11.6, Environmental Impacts, Impact NOI-1
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
5.14, Transportation
5.14.2.1, State Regulations
5.14.6, Environmental Impacts, Impact TRA-1
Adam Hutchinson, November 13, 2024
The comment letter expresses concern about the
potential increased congestion along Irvine Avenue,
which is already heavily congested. Traffic on the 73
and 405 freeways would also increase as well as
parking in the community due to overflow. Local
residents who already experience noise impacts from
the airport will be further impacted by the Project. The
letter concludes in stating that the proposed Project
prioritized out of town surfers over local residents.
5.11, Noise
5.11.6, Environmental Impacts, Impact NOI-3.
5.14, Transportation
5.14.2.1, State Regulations
5.14.6, Environmental Impacts, Impact TRA-1
Don Mowery, November 13, 2024
Supports the proposed Project. N/A
Gayle Eve, November 13, 2024
Opposes the proposed Project. The comment states that
roads are already congested in the area.
5.14, Transportation
5.14.2.1, State Regulations
5.14.6, Environmental Impacts, Impact TRA-1
David Clarke, November 13, 2024
This comment expresses concern over the loss of the
affordable driving range and golf course. The comment
also states that getting rid of the golf course could lead
to airport expansion.
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Nicholas Hahn, November 13, 2024
Supports the proposed Project. N/A
Sean Norton, November 13, 2024
Supports the proposed Project. N/A
Val Lyon, November 13, 2024
The comment expresses concern over the viability of a
surf park near the ocean.
5.13, Parks and Recreation
Kate and Nate Eaton, November 13, 2024
This comment expresses concern over the potential
increase in vehicle and bicycle traffic on already
congested roadways with young, inexperienced
drivers/riders. The comment concludes that there is no
5.14, Transportation
5.14.2.1, State Regulations
5.14.6, Environmental Impacts, Impact TRA-1
5.16, Utilities and Service Systems
Snug Harbor Surf Park Project 2. Introduction
City of Newport Beach 2-9
Draft EIR
May 2025
Comment Letter and Commet Relevant Draft EIR Sections
reason to have a surf park near the beach and
introduce a new use with increased water use.
5.16.6, Environmental Impacts, Impact UTIL-2
Jaclyn Hussey, November 12, 2024
Opposes the proposed Project N/A
Richard Rule II, November 12, 2024
Opposes the proposed Project N/A
Mac Posey. November 12, 2024
This comment expresses concern over the loss of the
affordable driving range and golf course
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Peter Dickey, November 13, 2024
This comment expresses concern over the loss of the
affordable driving range and golf course
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Catherine Lee, November 13, 2024
This comment expresses concern over the potential
increase in vehicle and bicycle traffic on already
congested roadways with young, inexperienced
drivers/riders. The comment concludes that there is no
reason to have a surf park near the beach.
5.14, Transportation
5.14.2.1, State Regulations
5.14.6, Environmental Impacts, Impact TRA-1
Caroline Colesworthy, November 13, 2024
The comment letter states that the proposed Project
would create excessive noise which would disturb
walkers and wildlife in the Back Bay. The commenter
states that the City needs affordable housing.
5.3, Biological Resources.
5.3.6, Environmental Impacts, Impact BIO-1
5.10, Land Use and Planning
5.10.3.2, Existing General Plan Land Use and
Zoning Designations
5.11, Noise
5.11.6, Environmental Impacts, Impact NOI-1
Steven Rivera, November 13, 2024
The comment letter states that the proposed Project
would result in increased noise levels in the area as well
as increased traffic.
5.11, Noise
5.11.6, Environmental Impacts, Impact NOI-1
5.14, Transportation
5.14.2.1, State Regulations
5.14.6, Environmental Impacts, Impact TRA-1
Brian Faust, November 14, 2024
The comment letter states that implementation of the
proposed Project would result in increased traffic.
5.14, Transportation
5.14.2.1, State Regulations
5.14.6, Environmental Impacts, Impact TRA-1
Ashley Cleary, November 14, 2024
Supports the proposed Project. N/A
Jeannine Vandertoll, November 14, 2024
The comment letter states that implementation of the
proposed Project would result in increased traffic,
specifically turning onto Irvine Avenue off of the 73
southbound.
5.14, Transportation
5.14.2.1, State Regulations
5.14.6, Environmental Impacts, Impact TRA-1
Snug Harbor Surf Park Project 2. Introduction
City of Newport Beach 2-10
Draft EIR
May 2025
Comment Letter and Commet Relevant Draft EIR Sections
Peter Jacks, November 14, 2024
The comment letter expresses concern over the amount
of disruption from construction occurring in the City and
the increase in traffic in the area. The existing golf
course has a charm that will be lost if this Project is
implemented.
5.1, Aesthetics
5.1.6, Environmental Impacts, Impact AES-3
5.14, Transportation
5.14.6, Environmental Impacts, Impact TRA-1
5.11, Noise
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
John Saroyan, November 14, 2024
The comment letter states that implementation of the
proposed Project would result in the loss of the
affordable driving range, golf course, and open green
space. Replacing the green space would result in
increased water usage, energy consumption, and noise
pollution. The Project would result in increased traffic
and strain local infrastructure
5.5, Energy
5.5.6, Environmental Impacts, Impact ENE-1
5.11, Noise
5.11.6, Environmental Impacts, Impact NOI-1.
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
5.14, Transportation
5.14.2.1, State Regulations
5.14.6, Environmental Impacts, Impact TRA-1
5.16, Utilities and Service Systems
5.16.6, Environmental Impacts, Impact UTIL-2
Rachelle Roony, November 14, 2024
Opposes the proposed Project. N/A
Nick Kelly, November 14, 2024
Supports the proposed Project. N/A
Kaelan Sizemore, November 14, 2024
This comment letter suggests that the proposed Project
should include a lake-style wave pool as opposed to
what is currently proposed.
N/A
Katerina Kurteeva, November 14, 2024
The comment letter expresses concern over the loss of
the affordable driving range and golf course.
Concerned about water use and where the water will
be coming from.
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
5.16, Utilities and Service Systems
5.16.6, Environmental Impacts, Impact UTIL-2
Garrett Bland, November 15, 2024
Supports the proposed Project. N/A
Sara White, November 15, 2024
Supports the proposed Project. N/A
Colleen Nelson, November 15, 2024
The comment letter expresses concern over potential
airport hazards, increased traffic congestion, and an
increase in water use.
5.8, Hazards and Hazardous Materials
5.8.6, Environmental Impacts, Impact HAZ-5.
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
Snug Harbor Surf Park Project 2. Introduction
City of Newport Beach 2-11
Draft EIR
May 2025
Comment Letter and Commet Relevant Draft EIR Sections
5.13.6, Environmental Impacts, Impact REC-1
5.14, Transportation
5.14.2.1, State Regulations
5.14.6, Environmental Impacts, Impact TRA-1
5.16, Utilities and Service Systems
5.16.6, Environmental Impacts, Impact UTIL-2
Janice Carsten, November 15, 2024
Opposes the proposed Project. N/A
Melissa Mcleod, November 15, 2024
Opposes the proposed Project. N/A
Kris Mitchel, November 15, 2024
This comment letter expresses concern over the noise
produced by the wave machine.
5.11, Noise
5.11.6, Environmental Impacts, Impact NOI-1
Janet Rosener, November 16, 2024
This comment letter expresses concern over noise
impacts related to hours of operation, maximum noise
levels, special event noises and hours, and the amount
of special events allowed. The comment also requests
information regarding special event traffic congestion
and potential redirect, how many parking spaces would
be private and whether remote parking with shuttles
would be available during special events. This comment
concludes by expressing concern about the loss of the
affordable driving range and golf course.
3.0, Project Description
3.8, Operations
5.11, Noise
5.11.6, Environmental Impacts, Impact NOI-1
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
5.14, Transportation
5.14.2.1, State Regulations
5.14.6, Environmental Impacts, Impact TRA-1
Teena Spindler, November 16, 2024
This comment letter expresses concern over increased
traffic in the area as well as coordination with the City
of Costa Mesa. In addition, the Project would generate
an increase in potable water use.
5.14, Transportation
5.14.2.1, State Regulations
5.16, Utilities and Service Systems
5.16.6, Environmental Impacts, Impact UTIL-2
Scott Wellwood, November 16, 2024
This comment letter expresses concern over the potential
loss of the affordable driving range, golf course, and
open green space. The commenter is concerned about
the potential impacts on climate change due to the loss
of green space.
5.7, Greenhouse Gas Emissions
5.7.6, Environmental Impacts, Impact GHG-1
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Catherine Lee, November 17, 2024
This comment expresses concern over the loss of the
affordable driving range and golf course.
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Randall Crockett, November 17, 2024
This comment expresses concern over the loss of the
affordable driving range and golf course
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Allison Robar, November 17, 2024
Opposes the proposed Project. N/A
Snug Harbor Surf Park Project 2. Introduction
City of Newport Beach 2-12
Draft EIR
May 2025
Comment Letter and Commet Relevant Draft EIR Sections
Niki Parker, November 17, 2024
This comment letter expresses concern about additional
traffic along the already busy Irvine Avenue, loss of
golf recreation opportunities, excessive water use,
unnecessary hotel rooms, and the siting of a surf park
so close to the ocean.
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
5.14, Transportation
5.14.2.1, State Regulations
5.14.6, Environmental Impacts, Table 5.14-2
5.16, Utilities and Service Systems
5.16.6, Environmental Impacts, Impact UTIL-2
Sandy Sewell, November 18, 2024
Supports the proposed Project. N/A
Mindy Adamson, November 18, 2024
This comment expresses concern over the loss of the
affordable driving range and golf course. The
proposed Project would be an eyesore to the local
area.
5.1, Aesthetics
5.1.6, Environmental Impacts, Impact AES-3
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Andrew Betz, November 19, 2024
Supports the proposed Project. N/A
Sharon MacDougall, November 19, 2024
This comment expresses concern over the loss of the
affordable driving range and golf course. The comment
also expresses concern over the viability of a surf park
near the ocean. The comment requests that the EIR
include analysis of optimal land use for air quality as
the proposed Project would result in a loss of carbon
sequestration and open space.
5.7, Greenhouse Gas Emissions
5.7.6, Environmental Impacts, Impact GHG-1
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
8.0, Alternatives
8.9, Environmentally Superior Alternative
Jeff Carsten, November 19, 2024
The comment expresses concern over the viability of a
surf park near the ocean as well as the potential impact
on local businesses near the beach.
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Marc Domenico, November 20, 2024
This comment expresses concern over the potential
increased traffic along Irvine Avenue.
5.14, Transportation
5.14.2.1, State Regulations
5.14.6, Environmental Impacts, Impact TRA-1
Roy Glauthier, November 20, 2024
The comment expresses concern over the loss of the
affordable driving range, golf course, open green
space and the potential increase in water use for surf
park. The comment concludes in stating that overnight
accommodation under JWA flightpath is dangerous.
5.8, Hazards and Hazardous Materials
5.8.6, Environmental Impacts, Impact HAZ-5
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
5.16, Utilities and Service Systems
5.16.6, Environmental Impacts, Impact UTIL-2
Snug Harbor Surf Park Project 2. Introduction
City of Newport Beach 2-13
Draft EIR
May 2025
Comment Letter and Commet Relevant Draft EIR Sections
Carrie Berg, November 22, 2024
The comment expresses concern over the loss of the
affordable driving range, golf course, open green
space and Pizza spot in addition to increased
traffic/accidents. The comment asks about the purpose
of the athlete accommodations.
3.0, Project Description
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Staci Rubin, November 23, 2024
Supports the proposed Project. N/A
Daniel Mendoza, November 23, 2024
Student N/A
Jim Auster, November 29, 2024
The commenter requests that the EIR analyze the
potential impacts from implementing 700 housing units
on the parcel to the south. The commenter suggests that
the Applicant should restrict any future housing
developments on the surrounding golf course parcels.
The commenter also requested that issues related to
land use, the neighborhood, loss of popular and well
used public recreation, loss of green open space, loss of
views of green open space from Mesa and Irvine, etc.
be analyzed within the EIR. The comment states that the
proposed use is high impact, has large new structures, is
completely unneeded, and wastes energy. The comment
also requests that the EIR analyze the impact on
elimination of the golf course on the center parcel and
the effect to golf on the adjoining Mesa parcel and
north back nine parcel.
3.0, Project Description
5.0, Environmental Impact Analysis
Cumulative Impacts
5.1, Aesthetics
5.1.6, Environmental Impacts, Impact AES-3
5.2, Air Quality
5.2.6, Environmental Impacts, Impact AQ-1
5.3, Biological Resources.
5.3.6, Environmental Impacts, Impact BIO-1
5.5, Energy
5.6.6, Environmental Impacts, Impact ENE-1
5.10, Land Use and Planning
5.10.6, Environmental Impact, Impact LU-2
5.10.7, Cumulative Impacts
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Jeremy Aston, December 1, 2024
Supports the proposed Project. N/A
Melody Jolly, December 3, 2024
The comment expresses concern over the potential
increase in noise pollution and traffic near the Back Bay
bird sanctuary. The comment states that the sanctuary is
a critical habitat and noise could potentially disrupt
natural behaviors. The comment also states that
increased traffic produces increased waste and runoff
into surrounding ecosystems.
5.3, Biological Resources.
5.3.6, Environmental Impacts, Impact BIO-1
5.9, Hydrology and Water Quality
5.10, Land Use and Planning
5.11, Noise
5.11.6 Environmental Impacts, Impact NOI-1
5.14, Transportation
5.14.2.1, State Regulations
5.14.6, Environmental Impacts, Impact TRA-1
Greg Stewart, December 4, 2024
This comment states that the real project includes 700
homes.
3.0, Project Description
5.0, Environmental Impact Analysis
Cumulative Impacts
Snug Harbor Surf Park Project 2. Introduction
City of Newport Beach 2-14
Draft EIR
May 2025
Comment Letter and Commet Relevant Draft EIR Sections
Patricia Pidgeon, December 4, 2024
The comment expresses concern over the potential
increase in traffic congestion and noise pollution. The
comment also states that there is no need for a surf park
so close to the beach.
5.11, Noise
5.11.6 Environmental Impacts, Impact NOI-1
5.14, Transportation
5.14.2.1, State Regulations
5.14.6, Environmental Impacts, Impact TRA-1
Bill Cope, December 4, 2024
Opposes the proposed Project. N/A
Matt Clark, December 4, 2024
The comment expresses concern over the loss of the
affordable driving range, golf course, and open green
space. The comment states the proposed Project creates
opportunities for development on surrounding golf holes
due to less viability of course.
3.0, Project Description
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Arleen Hasegawa, December 4, 2024
This comment letter states that traffic at the 73 exits to
Bristol/ Campus-Irvine is already dangerous and the
proposed Project would worsen conditions. The
commenter expresses concern over the potential impacts
to traffic in Dover shores area.
5.14, Transportation
5.14.2.1, State Regulations
5.14.6, Environmental Impacts, Impact TRA-1
Ron Armenta, December 4, 2024
The comment expresses concern over the loss of the
affordable driving range, golf course, and open green
space.
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Mike Smith, December 4, 2024
The comment expresses concern over the loss of the
affordable driving range, golf course, open green
space. The commenter requests that the EIR analyze the
potential impacts from implementing 700 housing units
on the parcel to the south. The comment also includes a
list of comments from the scoping meeting held on
November 20, 2024, including:
• Details on the operation of the golf course after
project buildout.
• Parking for the golf course.
• Traffic, Air Quality, Noise, Loss of Open Space,
Loss of Habitat, etc. among other things should all
be addressed in the EIR.
3.0, Project Description
5.0, Environmental Impact Analysis
Cumulative Impacts
5.2, Air Quality
5.3, Biological Resources.
5.3.6, Environmental Impacts, Impact BIO-1
5.10, Land Use and Planning
5.10.6 Environmental Impacts, Impact LU-2
5.10.7 Cumulative Impacts
5.11, Noise
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
5.14, Transportation
N/A
The comment letter states that owls and bats are
frequently seen onsite, and provides a link to a video
of an owl on the 18th hole of the golf course, not within
the Project site. The comment requests that the EIR
analyze the loss of the affordable driving range, golf
course, and open green space along with the loss of
cooling effect from green space and the loss of
3.0, Project Description
5.2, Air Quality
5.3, Biological Resources.
5.3.6, Environmental Impacts, Impact BIO-1
5.9, Hydrology and Water Quality
5.10, Land Use and Planning
Snug Harbor Surf Park Project 2. Introduction
City of Newport Beach 2-15
Draft EIR
May 2025
Comment Letter and Commet Relevant Draft EIR Sections
groundwater recharge. The commenter states that the
proposed Project would result in a large increase in
fresh water compared to reclaimed water used
currently used to water the golf course.
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
5.16, Utilities and Service Systems
5.16.6, Environmental Impacts, Impact UTIL-2
Jim Auster, December 4, 2024
This comment letter provides a list of potential impact
areas that should be analyzed in the EIR. The comment
includes topics such as aesthetics impacts from loss of
open space, traffic from new parking lot on Mesa Drive,
the feasibility of the golf course to continue operation,
increased energy use and greenhouse gas emissions,
impacts of implementing 690 housing units on the
southern golf course parcel, impacts of structures near
JWA, impacts on wildlife habitats, impacts to tribal
cultural resources, and noise increases.
3.0, Project Description
5.0, Environmental Impact Analysis
Cumulative Impacts
5.2, Air Quality
5.3, Biological Resources.
5.3.6, Environmental Impacts, Impact BIO-1
5.5, Energy
5.7, Greenhouse Gas Emissions
5.10, Land Use and Planning
5.10.7 Cumulative Impacts
5.11, Noise
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
5.15, Tribal Cultural Resources
5.15.6, Environmental Impacts, Impact TCR-1
Kathleen Torres, December 5, 2024
The comment letter expresses concern over the already
congested roadways near the proposed Project site.
The comment suggests instead to revitalize the existing
golf course use.
5.14, Transportation
5.14.2.1, State Regulations
5.14.6, Environmental Impacts, Impact TRA-1
8.0, Alternatives
Holly Jarvis, December 6, 2024
The comment letters asks about the height of the
proposed buildings compared to existing uses and if
any rezoning would be required for the proposed
Project. The commenter requests that the EIR analyze the
impact of tall walls instead of open greenspace. The
commenter also asks about the water use for the Project
and where the water would be coming from.
3.0, Project Description
5.1, Aesthetics
5.1.6, Environmental Impacts, Impact AES-3
5.9, Hydrology and Water Quality
5.9.6, Environmental Impacts, Impact HYD-1
5.16, Utilities and Service Systems
5.16.6, Environmental Impacts, Impact UTIL-2
Todd Becker, December 6, 2024
This comment letter provides the commenter’s concerns
regarding: the potential for tribal cultural resources
onsite, the potential impacts to water quality, wildlife
habitats, increased traffic, the loss of visual open space,
and effects on local businesses. The comment letter
provides a suggestion for development on an
alternative piece of land to reduce impacts.
5.1, Aesthetics
5.1.6, Environmental Impacts, Impact AES-3
5.3, Biological Resources.
5.3.6, Environmental Impacts, Impact BIO-1
5.4, Cultural Resources
5.4.6, Environmental Impacts, Impact CUL-2
5.9, Hydrology and Water Quality
5.9.6, Environmental Impacts, Impact HYD-1
5.14, Transportation
5.14.6, Environmental Impacts, Impact TRA-1
5.15, Tribal Cultural Resources
Snug Harbor Surf Park Project 2. Introduction
City of Newport Beach 2-16
Draft EIR
May 2025
Comment Letter and Commet Relevant Draft EIR Sections
5.15.6, Environmental Impacts, Impact TCR-1
8.0, Alternatives
8.4, Alternatives Considered But Rejected
Mike Smith, December 6, 2024
This comment requests the inclusion of a pedestrian
circulation plan.
5.14, Transportation
5.14.6, Environmental Impacts, Impact TRA-1
Dana and Benoit Courcelle, December 9, 2024
The comment letter expresses concern over the already
congested roadways near the proposed Project site.
The comment points to the loss of the affordable driving
range, golf course, and open green space and the
viability of a surf park near the ocean.
5.14, Transportation
5.14.2.1, State Regulations
5.14.6, Environmental Impacts, Impact TRA-1
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
2.3.2 Public Scoping Meeting
Pursuant to Section 15082(c)(1) of the CEQA Guidelines, the City of Newport Beach hosted a public scoping
meeting for members of the public and public agencies to provide input as to the scope and content of the
environmental information and analysis to be included in the Draft EIR for the Project. A scoping meeting
was held on November 20, 2024, at 6:00 p.m. at the Friends Room in the Newport Beach Public Library
(Central Library Branch) at 1000 Avocado Avenue, Newport Beach, California 92660.
Table 2-2: Summary of Scoping Meeting Comments
Comment Letter and Commet Relevant Draft EIR Sections
Comment #1
This commenter asks whether the EIR will evaluate impacts
to the surrounding area beyond the 300-foot NOP
notification radius. The commenter asks how the EIR will
analyze how many people would access the site on a
daily basis.
5.0, Environmental Impact Analysis
Cumulative Impacts
5.14, Transportation
5.14.2.1, State Regulations
5.14.6, Environmental Impacts, Impact TRA-1
Comment #2
This comment requests that the EIR analyze the impact of
eliminating the connectivity between the areas of the golf
course and to analyze any potential future projects that
may occur at the surrounding parcels.
5.0, Environmental Impact Analysis
Cumulative Impacts
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Comment #3
This comment asks whether the EIR would discuss golf
course operations and parking during construction and
operation of the proposed Project.
3.0, Project Description
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Comment #4
This commenter states that the parcel containing six other
holes of golf to the south are included in the City’s
Housing Element and should be analyzed in the EIR as a
future housing site.
5.0, Environmental Impact Analysis
Cumulative Impacts
5.10, Land Use and Planning
5.10.7 Cumulative Impact
Snug Harbor Surf Park Project 2. Introduction
City of Newport Beach 2-17
Draft EIR
May 2025
Comment Letter and Commet Relevant Draft EIR Sections
Comment #5
This commenter suggests that approval of this Project
should be contingent on the other parcels containing the
golf course remain in operation.
5.0, Environmental Impact Analysis
Cumulative Impacts
5.10, Land Use and Planning
5.10.7 Cumulative Impacts
Comment #6
This commenter requests that the EIR analyze the
potential impacts on the nearby bird sanctuary located
within the Newport Back Bay.
5.3, Biological Resources.
5.3.6, Environmental Impacts, Impact BIO-1
Comment #7
This commenter requests that the EIR analyze the loss of
affordable commercial recreation in the area as the
surf park would likely charge much higher prices
compared to the existing golf course.
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Comment #8
This commenter states that the northern parcel has been
planned for an airport runway extension for the nearby
John Wayne Airport and wants the EIR to analyze the
Project’s impacts on future airport planning efforts.
5.8, Hazards and Hazardous Materials
5.8.6 Environmental Impacts, Impact HAZ-5
5.11, Noise
5.11.6 Environmental Impacts, Impact NOI-3.
Comment #9
This commenter asks if City and or Applicant team has
reached out to potential Native American Tribes as the
Project site was previously a tribal site.
5.4, Cultural Resources
5.4.6, Environmental Impacts, Impact CUL-2
5.15, Tribal Cultural Resources
5.15.6, Environmental Impacts, Impact TCR-1
Comment #10
This commenter asked what a Project Alternative would
analyze.
8.0, Alternatives
Comment #11
This comment asks whether the EIR would discuss golf
course operations and parking during construction and
operation of the proposed Project.
3.0, Project Description
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Comment #12
This comment asks whether the proposed Project would
be consistent with the design guidelines within the Santa
Ana Heights Specific Plan.
3.0, Project Description
5.10, Land Use and Planning.
5.10.6, Environmental Impacts, Impact LU-2.
Comment #13
This comment requests that the EIR discuss the loss of views
of open space.
5.1, Aesthetics, Impact AES-3
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Comment #14
This comment requests information regarding the
overnight stay accommodations and the noise impacts
associated with them.
3.0, Project Description
5.11, Noise
Snug Harbor Surf Park Project 2. Introduction
City of Newport Beach 2-18
Draft EIR
May 2025
Comment Letter and Commet Relevant Draft EIR Sections
5.11.6 Environmental Impacts, Impact NOI-1
Comment #15
This comment asks when the golf course and pro shop
operation will cease on the Project site.
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
3.0, Project Description
Comment #16
This comment requests that the EIR analyze the change in
demographics of people utilizing the site due to the
change in commercial recreational uses at the site.
7.0, Effects Found Not Significant
7.3, Population and Housing
Comment #17
This comment states that the portion of the golf course in
which the Project is proposed is currently used as an
emergency landing location for small planes taking off
and landing at John Wayne Airport. The commenter
requests that the EIR analyze the potential safety impacts
of losing the large open space area for planes to land.
5.9, Hazards and Hazardous Materials
5.8.6 Environmental Impacts, Impact HAZ-5
5.11, Noise
5.11.6 Environmental Impacts, Impact NOI-1
Comment #18
This comment requests that the EIR analyzes the proposed
Project’s consistency with the applicable zoning code and
Santa Ana Heights Specific Plan and ensure that all
applicable approvals are noted.
5.1, Aesthetics, Impact AES-3
5.10, Land Use and Planning.
5.10.6, Environmental Impacts, Impact LU-2.
Comment #19
This commenter states that the existing golf course onsite
serves as a fire break for the nearby residences and that
the EIR should analyze that loss of fire break and how it
may impact nearby homes.
5.9, Hazards and Hazardous Materials
5.8.6 Environmental Impacts, Impact HAZ-7
7.0, Effects Found Not Significant
7.4, Wildfire
Comment #20
This commenter asks if FAA clearance is required due to
the Project its location near John Wayne Airport.
5.9, Hazards and Hazardous Materials
5.8.6 Environmental Impacts, Impact HAZ-5
5.10, Land Use and Planning.
5.10.6, Environmental Impacts, Impact LU-2.
Comment #21
This commenter asks if the loss of parkland onsite would
be replaced at another site.
5.13, Parks and Recreation
5.13.3.3, Golf Recreation
5.13.6, Environmental Impacts, Impact REC-1
Comment #22
This commenter requests that the EIR identify impacts to
migratory birds which currently utilize the site as well as
surrounding parcels.
5.3, Biological Resources.
5.3.6, Environmental Impacts, Impact BIO-4
Comment #23
This commenter requests that the EIR analyze the
potential increase in public service calls for police and
fire services due to the change in uses at the site.
5.12, Public Services
5.12.6, Environmental Impacts, Impact PS-1 and
PS-2
Snug Harbor Surf Park Project 2. Introduction
City of Newport Beach 2-19
Draft EIR
May 2025
2.3.3 Draft EIR
Topics requiring a detailed level of analysis that are evaluated in this Draft EIR have been identified based
upon the responses to both the NOP and a review of the Project by the City of Newport Beach. Pursuant to
CEQA Guidelines Section 15125.5(a) which states, “An EIR shall identify and focus on the significant effects
on the environment,” the City of Newport Beach determined that Project impacts on the below topics would
not be significant. Consequently, these topics are not analyzed in this Draft EIR, but are further discussed in
Section 7.0, Effects Found Not Significant.
• Agriculture and forest resources
• Mineral resources
• Population and housing
• Wildfire
The City of Newport Beach has filed a Notice of Completion (NOC) with the Governor’s Office of Planning
and Research State Clearinghouse, indicating that this Draft EIR has been completed and is available for
review and comment. The Project requires a City of Newport Beach General Plan Amendment, Federal
Aviation Administration (FAA) review and Orange County Airport Land Use Commission (ALUC) review; thus,
the Project meets the definition of a project of statewide, regional, or areawide significance pursuant to
Section 15206 of the CEQA Guidelines and is subject to noticing requirements accordingly. A Notice of
Availability (NOA) of the Draft EIR was published concurrently with distribution of this document. The Draft
EIR is being circulated for review and comment by the public and other interested parties, agencies, and
organizations for 45 days in accordance with CEQA Guidelines Sections 15087 and 15105. During the 45-
day review period, the Draft EIR is available for public review digitally on the City of Newport Beach’s
website at http://www.newportbeachca.gov/ceqa or physically at the following locations:
City of Newport Beach
Community Development Department
100 Civic Center Drive
Newport Beach, California 92660
Newport Beach Public Library
Central Library
1000 Avocado Avenue
Newport Beach, California 92660
Newport Beach Public Library
Mariners Branch
1300 Irvine Avenue
Newport Beach, California 92660
Newport Beach Public Library
Balboa Branch
100 East Balboa Boulevard Newport
Beach, California 92660
Newport Beach Public Library
Corona del Mar Branch
410 Marigold Avenue
Corona del Mar, California 92625
Written comments related to environmental issues in the Draft EIR should be addressed to:
Joselyn Perez, Senior Planner
City of Newport Beach
Community Development Department
100 Civic Center Drive
Newport Beach, California 92660
Email: JPerez@newportbeachca.gov
Phone: 949-644-3312
2.3.4 Final EIR
Upon completion of the 45-day review period, written responses to all comments related to the environmental
issues in the Draft EIR will be prepared and incorporated into a Final EIR. The written responses to comments
will be made available at least 10 days prior to the public hearing at which the certification of the Final EIR
will be considered by the City of Newport Beach City Council. These comments, and their responses, will be
Snug Harbor Surf Park Project 2. Introduction
City of Newport Beach 2-20
Draft EIR
May 2025
included in the Final EIR for consideration by the City of Newport Beach, as well as other responsible and
trustee agencies per CEQA. The Final EIR may also contain corrections and additions to the Draft EIR and
other information relevant to the environmental issues associated with the Project. The Final EIR will be
available for public review prior to its certification by the City. Notice of the availability of the Final EIR will
be sent to all who comment on the Draft EIR.
Mitigation Monitoring Reporting Program. When the lead agency makes findings on significant effects
identified in the Final EIR, it must adopt a reporting or monitoring program for mitigation measures that were
adopted or made conditions of project approval to mitigate significant effects. This will be part of the Final
EIR document.
2.3.5 Findings/Statement of Overriding Considerations
For each significant impact of the project identified in the EIR, the lead agency must find, based on substantial
evidence, that either: (a) the project has been changed to avoid or substantially reduce the magnitude of
the impact; (b) changes to the project are within another agency’s jurisdiction and such changes have or
should be adopted; or (c) specific economic, social, or other considerations make the mitigation measures or
project alternatives infeasible (CEQA Guidelines Section 15091). If an agency approves a project with
unavoidable significant environmental effects, it must prepare a written Statement of Overriding
Considerations (SOC) that sets forth the specific social, economic, or other reasons supporting the agency’s
decision.
2.3.6 Notice of Determination
The lead agency must file a Notice of Determination (NOD) after deciding to approve a project for which
an EIR is prepared (CEQA Guidelines Section 15094). A local agency must file the NOD with the County
Clerk. The NOD must be posted for 30 days and sent to anyone previously requesting notice. Posting of the
NOD starts a 30-day statute of limitations on CEQA legal challenges (Public Resources Code Section
21167[c]).
2.4 ORGANIZATION OF THIS DRAFT EIR
This Draft EIR is organized into the following Sections. To help the reader locate information of interest, a
brief summary of the contents of each chapter is provided.
• Section 1, Executive Summary: This section provides a brief summary of the Project area, the Project,
and alternatives. This section also provides a summary of the potential environmental impacts and
mitigation measures, applicable Project design features, applicable regulatory requirements, and the
level of significance after implementation of the mitigation measure. The level of significance after
implementation of the proposed mitigation measure(s) will be characterized as either less than significant
or significant and unavoidable.
• Section 2, Introduction: This section provides an overview of the purpose and use of the EIR, the scope
of this Draft EIR, a summary of the legal authority for the Draft EIR, a summary of the environmental
review process, and the general format of this document.
• Section 3, Project Description: This section provides a detailed description of the Project, its objectives,
and a list of Project-related discretionary actions.
• Section 4, Environmental Setting: This section provides a discussion of the existing conditions within the
Project area.
Snug Harbor Surf Park Project 2. Introduction
City of Newport Beach 2-21
Draft EIR
May 2025
• Section 5, Environmental Impact Analysis: This section is divided into sub-sections for each
environmental impact area. Each section includes a summary of the existing statutes, ordinances, and
regulations that apply to the environmental impact area being discussed; the analysis of the Project’s
direct and indirect environmental impacts on the environment, including potential cumulative impacts that
could result from the Project; applicable Project design features, standard conditions, and plans, policies,
and programs that could reduce potential impacts; and feasible mitigation measures that would reduce
or eliminate the significant adverse impacts identified. Impacts that cannot be mitigated to less than
significant are identified as significant and unavoidable.
• Section 6, Other CEQA Considerations: This section summarizes the significant and unavoidable impacts
that would occur from implementation of the Project and provides a summary of the environmental effects
of the implementation of the Project that were found not to be significant. Additionally, this section
provides a discussion of various CEQA-mandated considerations including growth-inducing impacts and
the identification of significant irreversible changes that would occur from implementation of the Project.
In addition, this section provides a discussion of impacts found not to be significant.
• Section 7, Effects Found Not Significant: This section summarizes the potential environmental effects
related to the Project that were determined not to be significant during preparation of this EIR.
• Section 8, Alternatives: This section describes and analyzes a reasonable range of alternatives to the
Project. The CEQA-mandated No Project Alternative is included along with alternatives that would
reduce one or more significant effects of the proposed Project. As required by the CEQA Guidelines,
the environmentally superior alternative is also identified.
• Section 9, EIR Preparers and Persons Contacted: This section lists authors of the Draft EIR and City of
Newport Beach staff that assisted with the preparation and review of this document. This section also
lists other individuals and/or organizations that were contacted for information that is included in this
Draft EIR document.
2.5 INCORPORATION BY REFERENCE
CEQA Guidelines Section 15150 allows for the incorporation “by reference all or portions of another
document… most appropriate for including long, descriptive, or technical materials that provide general
background but do not contribute directly to the analysis of a problem at hand.” The purpose of
incorporation by reference is to assist the Lead Agency in limiting the length of this Draft EIR. Where this
Draft EIR incorporates a document by reference, the document is identified in the body of the Draft EIR,
citing the appropriate section(s) of the incorporated document and describing the relationship between the
incorporated part of the referenced document and this Draft EIR.
The following documents are hereby incorporated by reference into this EIR. Information contained within
these documents is used for various sections of this EIR.
City of Newport Beach General Plan 2006 Update. The City’s General Plan was adopted on July 25, 2006,
and serves as the major framework for directing growth within the City. The General Plan presents a
comprehensive plan to accommodate the City’s growing needs and includes goals and policies related to
ten elements: Land Use, Harbor and Bay, Housing, Historical Resources, Circulation, Recreation, Arts and
Cultural, Natural Resources, Safety, and Noise. Each element of the General Plan Update includes goals,
policies, and policy actions that create a roadmap for new housing and job growth, provide guidance for
decision makers on allocating resources, and describe the utilization, management, and conservation of
natural resources, public services, and infrastructure. This document is available for viewing on the City’s
website at: https://newportbeachca.gov/government/departments/community-development/planning-
division/general-plan-codes-and-regulations/general-plan
Snug Harbor Surf Park Project 2. Introduction
City of Newport Beach 2-22
Draft EIR
May 2025
City of Newport Beach General Plan 2006 Update EIR. The City’s General Plan Final EIR for the City of
Newport Beach General Plan Update EIR consisted of three volumes: Volume I—City of Newport Beach
General Plan 2006 Update Draft EIR; Volume IA—Draft EIR Changes, Responses to Comments, and Final
EIR Report Preparers; and Volume II—Technical Appendices to the Draft EIR. The Draft EIR was distributed
for a 45-day public review from April 21 to June 5, 2006. The City Council found that the Final EIR was
complete and was prepared in compliance with CEQA and the EIR was certified by the City Council on July
25, 2006 and upheld by a vote of the electorate on November 7, 2006. The NOD for the EIR was filed on
July 26, 2006, at the Orange County Clerk. This document is available for viewing on the City’s website at:
https://www.newportbeachca.gov/government/departments/community-development/planning-
division/general-plan-codes-and-regulations/general-plan/general-plan-environmental-impact-repor
Santa Ana Heights Specific Plan. The purpose of the Santa Ana Heights specific plan is to provide for the
orderly and balanced development of the community consistent with the specific plan’s adopted land use
plan and with the stated goals and policies of the Land Use Element of the General Plan. The intent of the
Santa Ana Heights specific plan design guidelines is to promote a consistent, high quality character of
development that will result in the overall enhancement of the aesthetic character of the community. Use of
these guidelines in future project approvals will implement these objectives through the careful use of building
forms and materials, streetscape concepts, setback and buffer areas and a unifying landscape concept. The
Specific Plan requirements are available for viewing on the City’s website at:
https://www.codepublishing.com/CA/NewportBeach/html/NewportBeach20/NewportBeach2090.html
Newport Beach Municipal Code. The Newport Beach Municipal Code regulates land use and activities
within the City’s jurisdiction including through the Planning and Zoning Code (codified in Title 20). The Planning
and Zoning Code is the primary tool for implementing the City’s General Plan policies. The Municipal Code
is referenced in this EIR to establish the baseline requirements according to the City’s Municipal Code
regulations. The Newport Beach Municipal Code can be accessed online at:
https://www.codepublishing.com/CA/NewportBeach/
Snug Harbor Surf Park Project 3. Project Description
City of Newport Beach 3-1
Draft EIR
May 2025
3. Project Description
“Project,” as defined by the CEQA Guidelines, means “the whole of an action, which has a potential for
resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical
change in the environment, and that is any of the following: (1)… enactment and amendment of zoning
ordinances, and the adoption and amendment of local General Plans or elements thereof pursuant to
Government Code Sections 65100–65700.” (14 California Code of Regulations [CCR] Section 15378(a).)
The Project analyzed in this Draft EIR would be constructed over approximately 18 months and thereafter
operated. The Draft EIR analyzes buildout at a Project level of detail, based upon entitlement applications
being considered by the City of Newport Beach, compared to the existing conditions.
3.1 PROJECT LOCATION
The Project site is located in the northern portion of the City of Newport Beach at 3100 Irvine Avenue. The
site is located east of the intersection of Mesa Drive and Irvine Avenue within the Newport Beach Golf Course
(NB Golf Course). The City of Newport Beach is located approximately 20 miles southeast of Long Beach,
40 miles southwest of the City of Riverside, and 35 miles southeast of Downtown Los Angeles. Regional access
to the Project site is provided via State Route (SR) 73, located approximately 0.3-mile to the northeast, and
SR-55, located approximately 0.75 mile to the northwest. Local access to the site is provided by Irvine
Avenue through an existing driveway that provides both right or left turns to enter the site, and only right
turns leaving the site. Additionally, existing pedestrian and golf cart access to the site is provided along
Mesa Drive.
The Project site is identified by Assessor’s Parcel Number (APN) 119-200-41. Additionally, the site is located
within the Newport Beach USGS 7.5-Minute Quadrangle, Section 12, Township 6 South, Range 10 West,
San Bernardino Principal Meridian, and is located at latitude +33.65.85o, longitude -117.8819o. Regional
location and local vicinity maps are provided in Figure 3-1, Regional Location, Figure 3-2, Local Vicinity, and
Figure 3-3, Aerial View.
3.2 EXISTING SITE DEVELOPMENT AND OPERATIONS
The Project site is a portion of the NB Golf Course, which is a privately owned commercial recreational
facility. The NB Golf Course is separated into three physically distinct land areas and the Project site consists
of only the central portion bounded by Irvine Avenue and Mesa Drive. The Project site is comprised of one
parcel encompassing 15.38 acres that currently includes a 38-bay partially covered synthetic turf driving
range, a 1,050-square-foot (SF) putting green, a 8,975 SF building that includes a pro shop and a restaurant
that seats 233 people, a surface parking lot with 280 parking spaces, and three holes of the existing
Newport Beach Golf Course (holes 1, 2, and 9).
Table 3-1: Existing Onsite Building Square Footage
Existing Building Use Square Footage
Restaurant 7,200
Pro Shop 1,775
Driving Range Building 2,664
Total 11,639
Snug Harbor Surf Park Project 3. Project Description
City of Newport Beach 3-2
Draft EIR
May 2025
The majority of the site is covered in grass or artificial grass associated with the golf course. The remainder
of the site is paved and provides parking. The driving range is surrounded by approximately 40 net poles
that range in height from 25 to 80 feet depending on location. The poles and netting separating the driving
range from the buildings to the east are approximately 80 feet tall while the poles and netting separating
the driving range from the golf course on the west are approximately 50 feet tall and the poles and netting
separating the driving range from Mesa Drive to the south are between 62 and 65 feet tall. Some of the
poles are wood (telephone pole-like) while others are pipes. In addition, some of the poles have pipe
extensions to increase the overall height of the netting for safety purposes. The site also includes exterior
lighting provided by 30-foot-high light poles located in the golf course and near the driving range, and 20-
foot-high light poles in the parking area.
As detailed in the Geotechnical Exploration Report prepared for the Project, the site generally slopes to the
northwest and an existing 15- to 20-foot-high slope descends from the southeast edge of the site from an
elevation of approximately 58 feet above mean sea level (msl). The remainder of the site generally slopes
from approximately 50 feet above msl to approximately 15 feet above msl at the northwest corner of the
site. The Project site’s existing conditions are shown in Figure 3-4a-b, Existing Site Photos.
The existing hours of operation for the driving range and golf course are 6:30 a.m. to 9:00 p.m. from
December to February and 6:00 a.m. to 9:00 p.m. from March to November. The driving range and golf
course lighting is limited to between the hours of 7:00 a.m. and 10:00 p.m. The golf course has a total of 19
employees (including part-time) with approximately 8-10 employees onsite at a time during peak periods.
The hours of operation for the pro shop are generally 10:00 a.m. to 7:00 p.m. The shop employs four total
employees including two part-time employees. The restaurant generally operates from 8:00 a.m. to 10:00
p.m. and has a total of 24 employees; two of which are full-time employees. Overall, the Project site currently
provides 47 full and part-time jobs.
3.3 EXISTING PROJECT SITE LAND USE AND ZONING DESIGNATIONS
The 15.38-acre Project site is categorized as Parks and Recreation (PR) by the Land Use Element of the
General Plan, as shown on Figure 3-5, Existing General Plan Land Use Designations. The PR category is
intended to provide areas appropriate for the development of parks (both active and passive), golf courses,
marina support facilities, aquatic facilities, tennis clubs and courts, private recreation, and similar facilities.
The Project site is within the area designated as Anomaly Number 58 by Table LU2 of the Land Use Element
of the General Plan. The General Plan limits the development intensity of Anomaly No. 58 to 20,000 SF.
The Project site is zoned Santa Ana Heights Specific Plan (SP-7). The Santa Ana Heights Specific Plan
designates the site as Open Space and Recreation (OSR), as shown in Figure 3-6, Existing Zoning
Designations. Permitted uses within the OSR zone, subject to a use permit, include golf courses and/or outdoor
commercial recreation. Accessory uses and structures are permitted within the OSR zone when customarily
associated with and subordinate to a principal permitted use on the same building site.
The Project site is located adjacent to the Coastal Zone, the boundary of which is the northern boundary of
the Mesa Drive right-of-way, as shown in Figure 3-7, Coastal Zone Boundary.
3.4 SURROUNDING LAND USES
The Project site is center to the two other portions of the NB Golf Course. The 21.28-acre northern portion,
located northeast of the Project site across Irvine Avenue, serves as the back-nine holes of the golf course
(holes 10-18) and contains the 2,782 SF golf course maintenance building. The 14.51-acre southern portion,
located southwest of the Project site across Mesa Drive, provides six holes of the golf course (holes 3-8).
Snug Harbor Surf Park Project 3. Project Description
City of Newport Beach 3-3
Draft EIR
May 2025
Additionally, the Santa Ana-Delhi Channel is located along the northwesterly Project site boundary. The
surrounding land uses are shown on Figure 3-2, Local Vicinity, and Figure 3-3, Aerial View, and described
below in Table 3-2.
Table 3-2: Surrounding Existing Uses, General Plan Land Use, and Zoning
Direction Existing Use General Plan
Land Use Zoning Santa Ana Heights Specific Plan
Designation
Northwest
The Santa Ana-
Delhi Channel
followed by
Irvine Avenue
followed by
multifamily
residential
Multiple-Unit
Residential
Santa Ana
Heights Specific
Plan (SP-7)
Residential Multifamily
North
Irvine Avenue
followed by “The
Jetty” commercial
center and 9
holes of the NB
Golf Course
(holes 10-18)
General
Commercial;
Office Parks and
Recreation (City
of Newport
Beach);
Open Space
(Unincorporated
Orange County)
SP-7
Professional and Administrative
Office;
Open Space Recreation
(Unincorporated Orange County)
Northeast Commercial and
Office Uses
General
Commercial
Office
SP-7 Business Park
Southeast
Newport Beach
Fire Station 7 and
Fire Department
Training Center
Public Facilities SP-7 Business Park
South
Mesa Drive
followed by 6
holes of the NB
Golf Course
(holes 3-8)
Parks and
Recreation
SP-7
Housing
Opportunity
Overlay
Open Space Recreation
Southwest
The Santa Ana-
Delhi Channel
followed by
Mesa Drive,
followed by “The
Ranch” retail
shopping center
Community
Commercial
(Unincorporated
Orange County)
Commercial
Neighborhood
(Unincorporated
Orange County)
--
I
Snug Harbor Surf Park Project 3. Project Description
City of Newport Beach 3-4
Draft EIR
May 2025
This page intentionally left blank.
Figure 3-16QXJ+DUERU Surf Park Project
City of 1HZSRUW%HDFK
Regional Location
SANTA ANA
TINGTON BEACH
COSTA MESA
/
NEWPORT BEACH
D Project Site
iliifl
Snug Harbor Surf Park Project 3. Project Description
City of Newport Beach 3-6
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project
City of Newport Beach
/ocaO 9icinity
Figure 3-2
Ki
r
b
y
S
t
Ram ona ExpySobobaRdRamona Expy
Av
e
SobobaRdState
S
t
P
al
m
Cottonwood Ave
S
o
b
o
b
a
R
d
StateSt
Main St
Lyon Ave
Ca
w
s
t
o
n
A
v
e
7th St
Ramona Blvd Camino
l
o
s
B
a
n
o
s
Record RdOdell AveSanderson AveDeegan
S
t
Young StPotterRdWarren RdRamona
E
x
p
y
L a k e P ark D r79
y
Pa
l
m
A
v
e
Co
l
u
m
b
i
a
S
t
Ki
r
b
y
S
t
Gilman
S
p
r
i
n
g
s
R
d
St
a
t
e
S
t
Ly
o
n
A
v
e
Sa
n
d
e
r
s
o
n
A
v
e
Oakland Av
79
79 CITY OF SAN JACINTOGENERAL PLAN UPDATEFigure LU-2.General Plan Land Use Map
H E M E T
B E A U M O N T
0 1½
Miles
SanJacintoRiver SanJacintoRiver LegendCity of San JacintoSan Jacinto Sphere of InfluenceNeighboring CityLand Use DesignationVLDR: Very Low Density ResidentialLDR: Low Density ResidentialMDR: Medium Density ResidentialHDR: High Density ResidentialVHDR: Very High Density ResidentialMU: Mixed UseC: CommercialDV: Downtown VillageBP: Business ParkI: IndustrialPI: Public/InstitutionalOS: Open SpaceP: ParkSPA: Specific Plan AreaWater
Sources: City of San Jacinto; Riverside County. Adopted: November 15, 2022.
TRAILS SPSP 01-03VILLAGES SPSP 01-04COVE SPSP 01-01
ESPLANADE SP
SP 01-02
SOBOBASPRINGS SPSP 01-85
Ki
r
b
y
S
t
A
ve
Ramona
E
x
p
y
Washington
A
v
e
Cottonwood Ave
Esplanade Ave
Menlo Ave
H
ParkAve
Commonwealth
Ly
o
n
A
v
e
Ca
w
s
t
o
n
A
v
e
7th St
Od
e
l
l
A
v
e
Sa
n
d
e
r
s
o
n
A
v
e
Deegan
S
t
Potter Rd
Wa
r
r
e
n
R
d
Ramona
E
x
p
y
R
a
m
ona
Ex
p
y
Pa
l
m
A
v
e
Co
l
u
m
b
i
a
S
t
Ki
r
b
y
S
t
Gi
l
m
a
n
S
p
r
i
n
g
s
R
d
St
a
t
e
S
t
Ly
o
n
A
v
e
Sa
n
d
e
r
s
o
n
A
v
e
Oakland Ave
79
79
CITY OF SAN JACINTOGENERAL PLAN UPDATEFigure LU-2.General Plan Land Use Map
H E M E T
B E A U M O N T
SanJacintoRiver
Sources: City of San Jacinto; Riverside County. Adopted: November 15, 2022.
VILLAGES SP
SP 01-04
COVE SP
SP 01-01
ESPLANADE SP
SP 01-02
RANCHO
SAN JACINTO SP
SP 01-00
Legend
D Project Site
City Boundaries
D
D
D
D
Costa Mesa
lrviAe
COSTA MESA COUNTRY CLUB
GOLF COURSE
,.... .
,..,. _, / ,,
' ,# '/ • ' /
\ '
/' \( _____ _
................. ~~~:~ .....
•••• ,,,,\'<:;;;,,"'°"''
NEWPORT BACK BAY
JOHN WAYNE
AIRPORT
Snug Harbor Surf Park Project 3. Project Description
City of Newport Beach 3-8
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project
City of Newport Beach
$eriaO View
Figure 3-3
Ki
r
b
y
S
t
Ram ona ExpySobobaRd
ve
Ramona Expy
Av
e
SobobaRdState
S
t
P
al
m
Cottonwood Ave
S
o
b
o
b
a
R
d
StateSt
Main St
Lyon Ave
Ca
w
s
t
o
n
A
v
e
7th St
Ramona Blvd Camino
l
o
s
B
a
n
o
s
Record RdOdell AveSanderson AveDeegan
S
t
Young StPotterRdWarren RdRamona
E
x
p
y
L a k e P ark D r79
R
a
m
o
na
Ex
p
y
Pa
l
m
A
v
e
Co
l
u
m
b
i
a
S
t
Ki
r
b
y
S
t
Gilman
S
p
r
i
n
g
s
R
d
St
a
t
e
S
t
Ly
o
n
A
v
e
Sa
n
d
e
r
s
o
n
A
v
e
Oakland Ave
79
79 CITY OF SAN JACINTOGENERAL PLAN UPDATEFigure LU-2.General Plan Land Use Map
H E M E T
B E A U M O N T
0 1½
Miles
SanJacintoRiver SanJacintoRiver LegendCity of San JacintoSan Jacinto Sphere of InfluenceNeighboring CityLand Use DesignationVLDR: Very Low Density ResidentialLDR: Low Density ResidentialMDR: Medium Density ResidentialHDR: High Density ResidentialVHDR: Very High Density ResidentialMU: Mixed UseC: CommercialDV: Downtown VillageBP: Business ParkI: IndustrialPI: Public/InstitutionalOS: Open SpaceP: ParkSPA: Specific Plan AreaWater
Sources: City of San Jacinto; Riverside County. Adopted: November 15, 2022.
TRAILS SPSP 01-03VILLAGES SPSP 01-04COVE SPSP 01-01
ESPLANADE SP
SP 01-02
SOBOBASPRINGS SPSP 01-85
Ki
r
b
y
S
t
Ramona Expy
SobobaRd
M
o
u
n
t
ain
A
ve
Ramona
E
x
p
y
Av
e
S
o
b
o
b
a
R
d
St
a
t
e
S
t
Palm
Washington
A
v
e
Cottonwood Ave
Esplanade Ave
S
o
b
o
b
a
R
d
State
St
Menlo Ave
He
w
i
t
t
S
t
ParkAve
Main St
Commonwealth
Ly
o
n
A
v
e
Ca
w
s
t
o
n
A
v
e
7th St
Ramona Blvd
Ca
m
i
n
o
l
o
s
B
a
n
o
s
7th St
Record Rd
Od
e
l
l
A
v
e
Sa
n
d
e
r
s
o
n
A
v
e
Deegan
S
t
Youn
g
S
t
Potter Rd
Wa
r
r
e
n
R
d
Ramona
E
x
p
y
L a k e P ark D r
79
R
a
m
ona
Ex
p
y
Pa
l
m
A
v
e
Co
l
u
m
b
i
a
S
t
Ki
r
b
y
S
t
Gi
l
m
a
n
S
p
r
i
n
g
s
R
d
St
a
t
e
S
t
Ly
o
n
A
v
e
Sa
n
d
e
r
s
o
n
A
v
e
Oakland Ave
79
79
CITY OF SAN JACINTOGENERAL PLAN UPDATEFigure LU-2.General Plan Land Use Map
H E M E T
B E A U M O N T
0 1½
Miles
SanJacintoRiver
S
a
n
J
a
c
i
n
t
o
R
i
v
e
r
Sources: City of San Jacinto; Riverside County. Adopted: November 15, 2022.
TRAILS SP
SP 01-03
VILLAGES SP
SP 01-04
COVE SP
SP 01-01
ESPLANADE SP
SP 01-02
SOBOBA
SPRINGS SP
SP 01-85
RANCHO
SAN JACINTO SP
SP 01-00
Snug Harbor Surf Park Project 3. Project Description
City of Newport Beach 3-10
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project
City of Newport Beach
0' 20' 100'50'200'
SCALE: 1" = 100'-0"
PR
O
J
E
C
T
NO
R
T
H
PROJECT DATA
NET SITE AREA:
APN NUMBERS
TRUCK TRAILER STALLS
LANDSCAPE AREA
LANDSCAPE COVERAGE
811,760 SF
18.635 AC
7440-016-001
7440-016-002
7440-016-003
7412-024-007
PER CIVIL PLAN
316,373 SF
38.97 %
1. THE PROPOSED PROJECT SHALL COMPLY WITH THE PROVISIONS OF THE CITY OF LOS
ANGELES DEVELOPMENT GUIDELINES.
2. THE PROJECT DOES NOT PROPOSE ANY TENANT SIGNAGE AT THIS TIME.
3. THERE ARE NO PROTECTED TREES OR PLANTS ON SITE.
GENERAL NOTES
VICINITY MAP
SCALE =N.T.S.
SITE PLAN
Figure a
([iVting Site PhotoV
Views of the Project site from the Irvine Avenue, facing east.
Key
Viewpoint location
Direction of sight
City of Costa Mesa, City of
Newport Beach, County of Los
Snug Harbor Surf Park Project 3. Project Description
City of Newport Beach 3-12
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project
City of Newport Beach
0' 20' 100'50'200'
SCALE: 1" = 100'-0"
PR
O
J
E
C
T
NO
R
T
H
PROJECT DATA
NET SITE AREA:
APN NUMBERS
TRUCK TRAILER STALLS
LANDSCAPE AREA
LANDSCAPE COVERAGE
811,760 SF
18.635 AC
7440-016-001
7440-016-002
7440-016-003
7412-024-007
PER CIVIL PLAN
316,373 SF
38.97 %
1. THE PROPOSED PROJECT SHALL COMPLY WITH THE PROVISIONS OF THE CITY OF LOS
ANGELES DEVELOPMENT GUIDELINES.
2. THE PROJECT DOES NOT PROPOSE ANY TENANT SIGNAGE AT THIS TIME.
3. THERE ARE NO PROTECTED TREES OR PLANTS ON SITE.
GENERAL NOTES
VICINITY MAP
SCALE =N.T.S.
SITE PLAN
Figure b
([iVting Site PhotoV
Views of the Project site parking lot from Irvine Avenue, facing south.
City of Costa Mesa, City of
Newport Beach, County of Los
Key
Viewpoint location
Direction of sight
Snug Harbor Surf Park Project 3. Project Description
City of Newport Beach 3-14
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project
City of Newport Beach
Existing *eneraO POan Land Use 'eVignationV
Figure 3-5
Ki
r
b
y
S
t
Ram ona ExpySobobaRd
ve
Ramona Expy
Av
e
SobobaRdState
S
t
P
al
m
Cottonwood Ave
S
o
b
o
b
a
R
d
StateSt
Main St
Lyon Ave
Ca
w
s
t
o
n
A
v
e
7th St
Ramona Blvd Camino
l
o
s
B
a
n
o
s
Record RdOdell AveSanderson AveDeegan
S
t
Young StPotterRdWarren RdRamona
E
x
p
y
L a k e P ark D r79
R
a
m
o
na
Ex
p
y
Pa
l
m
A
v
e
Co
l
u
m
b
i
a
S
t
Ki
r
b
y
S
t
Gilman
S
p
r
i
n
g
s
R
d
St
a
t
e
S
t
Ly
o
n
A
v
e
Sa
n
d
e
r
s
o
n
A
v
e
Oakland Ave
79
79 CITY OF SAN JACINTOGENERAL PLAN UPDATEFigure LU-2.General Plan Land Use Map
H E M E T
B E A U M O N T
0 1½
Miles
SanJacintoRiver SanJacintoRiver LegendCity of San JacintoSan Jacinto Sphere of InfluenceNeighboring CityLand Use DesignationVLDR: Very Low Density ResidentialLDR: Low Density ResidentialMDR: Medium Density ResidentialHDR: High Density ResidentialVHDR: Very High Density ResidentialMU: Mixed UseC: CommercialDV: Downtown VillageBP: Business ParkI: IndustrialPI: Public/InstitutionalOS: Open SpaceP: ParkSPA: Specific Plan AreaWater
Sources: City of San Jacinto; Riverside County. Adopted: November 15, 2022.
TRAILS SPSP 01-03VILLAGES SPSP 01-04COVE SPSP 01-01
ESPLANADE SP
SP 01-02
SOBOBASPRINGS SPSP 01-85
Ki
r
b
y
S
t
Ramona Expy
SobobaRd
M
o
u
n
t
ain
A
ve
Ramona
E
x
p
y
Av
e
S
o
b
o
b
a
R
d
St
a
t
e
S
t
Palm
Washington
A
v
e
Cottonwood Ave
Esplanade Ave
S
o
b
o
b
a
R
d
State
St
Menlo Ave
He
w
i
t
t
S
t
ParkAve
Main St
Commonwealth
Ly
o
n
A
v
e
Ca
w
s
t
o
n
A
v
e
7th St
Ramona Blvd
Ca
m
i
n
o
l
o
s
B
a
n
o
s
7th St
Record Rd
Od
e
l
l
A
v
e
Sa
n
d
e
r
s
o
n
A
v
e
Deegan
S
t
Youn
g
S
t
Potter Rd
Wa
r
r
e
n
R
d
Ramona
E
x
p
y
L a k e P ark D r
79
R
a
m
ona
Ex
p
y
Pa
l
m
A
v
e
Co
l
u
m
b
i
a
S
t
Ki
r
b
y
S
t
Gi
l
m
a
n
S
p
r
i
n
g
s
R
d
St
a
t
e
S
t
Ly
o
n
A
v
e
Sa
n
d
e
r
s
o
n
A
v
e
Oakland Ave
79
79
CITY OF SAN JACINTOGENERAL PLAN UPDATEFigure LU-2.General Plan Land Use Map
H E M E T
B E A U M O N T
0 1½
Miles
SanJacintoRiver
S
a
n
J
a
c
i
n
t
o
R
i
v
e
r
Sources: City of San Jacinto; Riverside County. Adopted: November 15, 2022.
TRAILS SP
SP 01-03
VILLAGES SP
SP 01-04
COVE SP
SP 01-01
ESPLANADE SP
SP 01-02
SOBOBA
SPRINGS SP
SP 01-85
RANCHO
SAN JACINTO SP
SP 01-00
D Project Site
Land Uses
D Airport Office and Supporting Uses
-General Commercial
D General Commercial Office
• • ..
•
...... ./'
.If./. r.,,_,.,_,.,."-..,,
1',._
• ✓
/
~ .
•
•
~7
=M J'
l'
y,
/'. ,,, ,,,
D Mixed-Use Horizontal
-Multiple Residential
D Open Space
-Parks and Recreation
Private Institutions
D Public Facilities
D Single Unit Residential Attached
D Single Unit Residential Detached
-Visitor Serving Commercial
Snug Harbor Surf Park Project 3. Project Description
City of Newport Beach 3-16
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project
City of Newport Beach
Existing Zoning 'eVignationV
Figure 3-6
Ki
r
b
y
S
t
Ram ona ExpySobobaRd
ve
Ramona Expy
Av
e
SobobaRdState
S
t
P
al
m
Cottonwood Ave
S
o
b
o
b
a
R
d
StateSt
Main St
Lyon Ave
Ca
w
s
t
o
n
A
v
e
7th St
Ramona Blvd Camino
l
o
s
B
a
n
o
s
Record RdOdell AveSanderson AveDeegan
S
t
Young StPotterRdWarren RdRamona
E
x
p
y
L a k e P ark D r79
R
a
m
o
na
Ex
p
y
Pa
l
m
A
v
e
Co
l
u
m
b
i
a
S
t
Ki
r
b
y
S
t
Gilman
S
p
r
i
n
g
s
R
d
St
a
t
e
S
t
Ly
o
n
A
v
e
Sa
n
d
e
r
s
o
n
A
v
e
Oakland Ave
79
79 Zoning Map 2022
H E M E T
B E A U M O N T
0 1½
Miles
SanJacintoRiver SanJacintoRiver LegendSan Jacinto City LimitsSan Jacinto Sphere of InfluenceNeighboring CitySpecific Plan AreaRAAB Combining Overlay ZoneHousing OverlayResidential ZonesRE - Residential EstateRR - Rural ResidentialRL - Residential, Low DensityRM - Residential, Medium DensityRH - Residential, High DensityRVH - Residential, Very High DensityCommercial and Industrial ZonesCN - Commercial NeighborhoodCG - Commercial GeneralCR - Commercial RegionalBP - Business ParkOP - Office ParkIL - Industrial LightIH - Industrial HeavyMixed Use ZonesMU - Mixed UseMU-E - Mixed Use - EntertaintainmentDV - Downtown VillageSpecial Purpose ZonesOSG - Open Space GeneralOSR - Open Space RecreationPI - Public InstitutionalSP - Specific PlanW - Water SourceTRAILS SPSP 01-03VILLAGES SPSP 01-04COVE SPSP 01-01
ESPLANADE SP
SP 01-02
SOBOBASPRINGS SPSP 01-85 November 15, 2022
Ki
r
b
y
S
t
Ramona Expy
SobobaRd
M
o
u
n
t
ai
n
A
ve
Ramona
E
x
p
y
Av
e
S
o
b
o
b
a
R
d
St
a
t
e
S
t
Palm
Washington
A
v
e
Cottonwood Ave
Esplanade Ave
S
o
b
o
b
a
R
d
State
St
Menlo Ave
He
w
i
t
t
S
t
ParkAve
Main St
Commonwealth
Ly
o
n
A
v
e
Ca
w
s
t
o
n
A
v
e
7th St
Ramona Blvd
Ca
m
i
n
o
l
o
s
B
a
n
o
s
7th St
Record Rd
Od
e
l
l
A
v
e
Sa
n
d
e
r
s
o
n
A
v
e
Deegan
S
t
Youn
g
S
t
Potter Rd
Wa
r
r
e
n
R
d
Ramona
E
x
p
y
L a k e P ark D r
79
R
a
m
o
na
Ex
p
y
Pa
l
m
A
v
e
Co
l
u
m
b
i
a
S
t
Ki
r
b
y
S
t
G
i
l
m
a
n
S
p
r
i
n
g
s
R
d
St
a
t
e
S
t
Ly
o
n
A
v
e
Sa
n
d
e
r
s
o
n
A
v
e
Oakland Ave
79
79
Zoning Map 2022
H E M E T
B E A U M O N T
0 1½
Miles
SanJacintoRiver
S
a
n
J
a
c
i
n
t
o
R
i
v
e
r
TRAILS SP
SP 01-03
VILLAGES SP
SP 01-04
COVE SP
SP 01-01
ESPLANADE SP
SP 01-02
SOBOBA
SPRINGS SP
SP 01-85
RANCHO
SAN JACINTO SP
SP 01-00
November 15, 2022
D Project Site
Zoning Designation
-Commercial General
D Medium Density Re sidential
D Office-Airport
D Office-General
D Open Space
0
• • ..
•
"· +.
/':'
1/,
Private Institutions
• •
D Public Facilities
Re sidential-Agricultural
•
Santa Ana Heights Specific Plan
D Single-Unit Re sidential
Jo
)
/
✓' ~ '"J:i
• 0 ,
h, ... r ~
'1 a
,11,
~ ~ '0. r;
~
,.,,., ./' y , ...
/./
D Single-Unit Re sidential (6000 indicates minimum lot area)
D Single-Unit Residential (7200 indicates minimum lot area)
,,,
✓./
Planned Communities
D Bayview
D New port Place
D San Diego Creek North
D Upper New port Bay Regional Park -UP 3488
Snug Harbor Surf Park Project 3. Project Description
City of Newport Beach 3-18
Draft EIR
May 2025
This page intentionally left blank.
Figure 3-76QXJ+DUERU Surf Park Project
City of 1HZSRUW%HDFK
Coastal Zone Boundary
Snug Harbor Surf Park Project 3. Project Description
City of Newport Beach 3-20
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 3. Project Description
City of Newport Beach 3-21
Draft EIR
May 2025
3.5 PROJECT OVERVIEW
The Snug Harbor Surf Park Project (Project) would remove the existing improvements on the 15.38-acre
Project site and develop a 5.06-acre surf lagoon with warming pools, a spa, and seating areas; a three-
story amenity clubhouse; a two-story athlete accommodation building; ancillary storage and maintenance
areas; and associated parking areas. Solar panels would be installed on the roofs of the buildings and on
14 to 18-foot-high solar canopies in portions of the parking areas to provide onsite power.
The portions of the golf course to the north of Irvine Avenue (holes 10-18) and south of Mesa Drive (holes 3-
8) would remain, and golf cart path of travel between holes 3-8 and holes 10-18 would be provided. The
Project includes golf course parking, a starter shack for the golf course, and golf cart storage in the basement
level of the proposed amenity clubhouse.
The Project includes a General Plan Amendment (GPA), a Conditional Use Permit (CUP), a Modification
Permit, and a Major Site Development Review (SDR). Due to the Project’s location near John Wayne Airport
(SNA), the Project requires an aeronautical review by the Federal Aviation Administration (FAA), and an
Airport Environs Land Use Plan (AELUP) consistency review by the Orange County Airport Land Use
Commission (ALUC).
3.6 PROJECT FEATURES
3.6.1 Surf Lagoon
The proposed 5.06-acre (220,427 SF) surf lagoon would be divided into two 5.1-million-gallon basins that
would be hydrologically separated by wave making equipment forming a heart-shaped surf lagoon that
would be up to 13 feet deep. The two basins would provide four distinct surfing areas including two outside
surf breaks in the deeper part of the lagoon that produces larger waves and two inside surf breaks in the
shallower part of the lagoon that produces smaller waves. One basin would provide waves going to the
right and the other basin would provide waves going to the left. The wave machinery would bisect the two
basins and be located within a 40-foot-wide by 350-foot-long above- and below-grade continuous footing
structure. The machinery has various modes of operation to alter the waves of the lagoon to accommodate
a wide range of surfers and abilities.
The surf lagoon would be heated. Three warming pools and one spa ranging in size from 640 to 1,600 SF
with nine outdoor showers would be located adjacent to the surf lagoon. All areas of the surf lagoon and
warming pools would be monitored by trained lifeguard professionals from an operations center within the
clubhouse and water safety platforms to ensure proper use and safety.
The surf lagoon would be lit for evening use by 71-foot-high light poles that would be located adjacent to
the lagoon with lights focused down onto the surf lagoon. The additional lagoon equipment, such as the
lagoon heating equipment and storage areas, would have a height of approximately 15 feet and would
be located northeast of the surf lagoon near the north parking lot, as shown in Figure 3-8, Conceptual Site
Plan.
3.6.2 Amenity Clubhouse Building
The amenity clubhouse building would be a three-story, 50,341 net SF building and would wrap around the
northwestern border of the surf lagoon. The proposed building would have a maximum height of 50 feet.
The first floor would contain a reception area as well as a surf academy area, changing rooms, storage
lockers, and a surf themed retail store. There would also be a sit-down restaurant with a full-service bar in
Snug Harbor Surf Park Project 3. Project Description
City of Newport Beach 3-22
Draft EIR
May 2025
addition to a quick food service coffee bar/snack shack. The second floor would have a fitness facility,
locker room, spa, and yoga room. The third floor would contain administrative offices, an operations center,
and day use cabanas. Both the second and third floors would have a deck along the entire eastern frontage
of the building, providing views of the surf lagoon.
According to the City of Newport Beach General Plan, certain ancillary uses such as maintenance equipment,
supply equipment, and restrooms are considered incidental to the PR land use designation and are not
included in determining intensity limits. In addition to the net SF, the building would also include 18,137 SF
of ancillary areas that are exempt from the General Plan development limit calculation, which includes a
basement level for golf cart storage, surfboard storage, maintenance and equipment storage rooms, and a
freestanding restroom. A summary of the amenity clubhouse building is listed in Table 3-3 and a conceptual
elevation is shown in Figure 3-9, Amenity Clubhouse Building Elevation.
Table 3-3: Amenity Clubhouse Building Summary
Level Use General Plan
Square Footage
Ancillary
Square
Footage1
Gross
Square
Feet2
Basement Staff area, mechanical, golf cart storage1,
surfboard storage1, facility storage1 4,605 15,971 20,576
Level 1 Surf academy, change room and locker room,
restrooms, restaurant, surf shop, lobby,
surfboard storage1, freestanding restrooms1
19,127 2,166 21,293
Level 2 Fitness area, yoga room, restrooms, members
locker room and lounge, spa 16,922 0 16,922
Level 3 Mechanical wells, offices, restrooms, VIP suites,
music recording studio 9,687 0 9,687
Total SF 50,341 18,137 68,478
1Exempt from the General Plan development limit calculation, ancillary uses.
2Gross SF includes ancillary areas that the General Plan does not include in determining intensity limits.
3.6.3 Athlete Accommodation Building
The two-story athlete accommodation building would provide 20 accommodation units, 10 on each floor.
The building would be 9,432 net SF and have a maximum height of 40 feet. The units would be exclusively
for visiting surfers and surf park guests to stay while using the onsite amenities. Each unit would include a
bed, bathroom, closet, and a patio space facing the surf lagoon.
In addition to the net SF, the athlete accommodations would have a freestanding 1,624 SF storage/restroom
building that would be located to the northwest of the athlete accommodation structure, which would be
ancillary and exempt from the General Plan development limit calculation. A summary of the athlete
accommodations building is listed in Table 3-4 and a conceptual elevation is shown in Figure 3-10, Athlete
Accommodation Building Elevation.
Snug Harbor Surf Park Project 3. Project Description
City of Newport Beach 3-23
Draft EIR
May 2025
Table 3-4: Athlete Accommodations Building and Freestanding Ancillary Square Footage
Level Use
General Plan
Development Square
Feet
Freestanding
Ancillary
Square Feet1
Gross
Square
Feet2
Level 1 10 accommodation units 4,716 738 restroom
886 storage 6,340
Level 2 10 accommodation units 4,716 0 4,716
Total SF 9,432 1,624 11,056
1Exempt from the General Plan development limit calculation, ancillary uses located adjacent to the athlete accommodations.
2Gross SF includes incidental areas that the City does not include in determining intensity limits.
3.6.4 Circulation and Parking
As depicted in Figure 3-8, Conceptual Site Plan, the site would be accessed from an improved 26-foot-wide
driveway along Irvine Avenue in the same location as the existing driveway that would provide full turning
access. There is also an existing driveway to the Project site along Mesa Drive that is undersized and does
not meet City or accessibility standards. The Project would relocate the driveway approximately 200 feet
to the east, away from the Irvine Avenue intersection, and build it to current 26-foot-wide standards. The
driveway relocation includes closing the existing driveway within the right-of-way, converting the existing
curb returns to a curb and gutter, and resurfacing the sidewalk. The relocated driveway would include new
curb returns, resurfacing, and roadway striping to denote the driveway turn.
Parking would be provided at two parking areas to serve both the Project and golf course – one located
near the Irvine Avenue driveway that would contain 171 parking spots including EV stalls and ADA accessible
stalls, and one near the Mesa Drive driveway that would contain 180 parking spots including EV charging
stations, EV stalls, and ADA accessible stalls. A total of 351 parking spots are proposed. Both parking areas
would include 14 to 18-foot-high solar canopies over parking areas, as shown in Figure 3-11, Proposed
Solar PV Installation. Bicycle parking would be provided at two locations near the amenity clubhouse building
entrance. Additionally, a 26-foot-wide internal roadway would connect the two parking lots and site
driveways, and a designated drop-off and ride share area would be located on the west side of the
clubhouse building.
The golf cart path of travel between holes 3-8 and holes 10-18 would be maintained. Carts would continue
to utilize the tunnel under Irvine Avenue to access the Project site from the holes 3-8 then follow a cart path
adjacent to the Santa Ana-Delhi Channel that would lead down to holes 10-18.
3.6.5 Landscaping, Walls, and Fencing
The proposed Project would include approximately 143,844 SF of drought tolerant ornamental landscaping
that would cover approximately 20 percent of the site, as shown in Figure 3-8, Conceptual Site Plan.
Proposed landscaping would include 24-inch box trees, 15-gallon trees, various shrubs, and ground covers
to enhance views of the proposed Project and screen the proposed buildings, infiltration/detention basins,
and parking areas from offsite viewpoints. Landscaping would be located throughout the site, along the
Irvine Avenue and Mesa Drive right-of-way, and along the site boundary.
The Project landscaping plan specifically excludes trees that are known to attract birds. Vegetation that
produces seeds, fruits, nuts, or berries, such as fruit bearing trees and shrubs, would not be used. Likewise,
Project site areas would be planted with seed mixtures that do not contain millet or any other large seed
producing grass that could attract birds.
Snug Harbor Surf Park Project 3. Project Description
City of Newport Beach 3-24
Draft EIR
May 2025
Two terraced 8-foot-high retaining walls are proposed along the eastern property line, and a retaining wall
with a maximum height of 16-feet is proposed between the Santa Ana-Delhi Channel and the Project site
along Irvine Avenue to Mesa Drive. A 6-foot-high fence is proposed around the perimeter of the site, with
gated entrances at the driveways along Irvine Avenue and Mesa Drive.
A 6-foot-high wall is proposed along the northern boundary of the surf lagoon, between the surf lagoon
and the north parking lot. The pool service equipment area in the northeast corner of the site would be
surrounded by an 14-foot-tall concrete masonry unit (CMU) wall. A 5-foot-high pool fence is proposed in
front of both the athlete accommodations building and the amenity clubhouse building to separate the
respective areas from the surf lagoon, as shown on Figure 3-8, Conceptual Site Plan.
3.6.6 Open Space and Other Amenities
The proposed Project would include approximately 235,650 SF of open space including 5,014 SF of
synthetic turf coverage. The outdoor areas of the proposed Project would include surf school training lawn
area, seating and lounging areas around the surf lagoon, wave viewing platforms, and cabanas.
3.6.1 Infrastructure Improvements
Electricity
Solar panels would be installed on the building roofs. They would be less than 18-inches in height and be
below the 50-foot and 40-foot maximum building heights. Solar canopies would also be installed over
portions of both parking areas to produce renewable energy to provide power to the onsite operations. In
addition, the Project would connect to the existing electricity infrastructure located within Irvine Avenue and
Acacia Street.
Natural Gas
The proposed Project would install new, onsite, natural gas lines that would connect to the existing natural
gas lines within Irvine Avenue.
Water
The proposed Project would install new water lines within the Project site and public right-of-way to connect
to the existing 24-inch water line in Irvine Avenue served by the City of Newport Beach. The existing onsite
6-inch domestic water line would be upgraded to a 12-inch water line and would connect to the 24-inch
main line within Irvine Avenue.
Sewer
The proposed Project would construct new sewer lines to connect to the existing 12-inch sewer line in Mesa
Drive that currently serves the existing uses on the site. The existing 6-inch onsite sewer lateral that extends
approximately 42.5 feet offsite to the sewer main that is more than 50 years old would be upgraded to a
12-inch sewer line that would be installed in the location of the existing driveway and would connect to the
existing 12-inch sewer line in Mesa Drive at the existing manhole, which would accommodate on-going
maintenance.
Snug Harbor Surf Park Project
City of Newport Beach
Figure
Main St
C L
mb
i
a
S
t
St
a
t
e
S
t
and
79
Ki
r
b
y
S
t
M
o
u
n
t
ai
n
A
ve
wood Ave
Esplanade Ave
S
o
b
o
b
a
R
d
He
w
i
t
t
S
t
St 7th St
R
a
m
o
n
G
i
l
m
a
n
S
p
Zoning Map 2022
0 1½
MilesRANCHO
SAN JACINTO SP
Conceptual Site Plan
GENERAL LANDSCAPE AND CITY NOTES:
LANDSCAPE PLANTING AREA TABULATIONS:
ON-SITE LANDSCAPING - 140,803 SF (20%)
LAGOON AREA 217,409 SF
POOL/SPA AREA 4,054 SF
PROPOSED SYNTHETIC TURF - 5,014 SF (3.8%)
NO LIVE TURF AREAS ARE PROPOSED.
PARKING LOT LANDSCAPE TABULATIONS:
PROPOSED PARKING STALLS - 351
PROPOSED PARKING SHADE TREES - 0 (78 REQUIRED @ 1 TREE:5 STALLS)
*100% SHADE PROVIDED WITH SOLAR CANOPIES IN LIEU OF PARKING
LOT SHADE TREES
1. PLANT MATERIAL NOT LISTED MAY BE USED, SUBJECT TO APPROVAL BY THE CITY.
2. ALL LANDSCAPE PLANS AND INSTALLATIONS SHALL ADHERE TO CITY OF NEWPORT BEACH DESIGN
GUIDELINES, CODES AND REGULATIONS.
3. ALL LANDSCAPE AREAS SHALL RECEIVE AN AUTOMATIC IRRIGATION SYSTEM.
4. ALL LANDSCAPE INSTALLATIONS SHALL BE PERMANENTLY MAINTAINED BY OWNER.
5. LANDSCAPING SHALL BE PROTECTED WITH A MINIMUM 6-INCH HIGH CONCRETE CURB.
6. ALL LANDSCAPED AREAS (EXCEPT NATURALIZED HYDROZONES) SHALL BE PROVIDED WITH A SMART
AUTOMATIC IRRIGATION CONTROLLER.
7. THE MINIMUM INTERIOR WIDTH OF PLANTERS CONTAINING TREES SHALL BE FOUR FEET EXCLUSIVE OF
CURBS.
8. LANDSCAPE WITHIN TRAFFIC SAFETY VISIBILTY AREAS SHALL BE PLANTED IN ACCORDANCE WITH
CH.20.30.130.
9. TREES IN LANDSCAPE PLANTERS LESS THAN TEN FEET IN WIDTH OR LOCATED CLOSER THAN FIVE FEET
FROM A PERMANENT STRUCTURE SHALL BE PROVIDED WITH ROOT BARRIERS.
10. LANDSCAPE AREAS WILL BE IRRIGATED USING DOMESTIC WATER AVAILABLE FROM PUBLIC
INFRASTRUCTURE.
11. BIKE PARKING SHALL BE PROVIDED IN CONFORMANCE WITH CALGREEN 5.106.4.
5'-0" POOL FENCE
6'-0" FACILITY FENCE
6'-0" SITE PERIMETER FENCESTOPSTOP
STOPSTOP
IRVIN E AVE N UE
M
E
SA
D
R
IVE
SERVICEAREA
STO
RA
G
E/
RESTRO
O
M
ATHLETE
ACCOMMODATIONS
LOWER
DELTA
AMENITY
CLUBHOUSEDROP OFF
PROJECT ID
MONUMENT
SOUTH PARKING
(SOLAR CANOPIES @ STALLS)
NORTH PARKING
(SOLAR CANOPIES @ STALLS)
MESA DRIVE
GATED ENTRY
IRVINE AVE. GATED ENTRY
W A V E M A K I N G E Q U I P M E N T
(A B O V E G R A D E )
WATER TREATMENT
(BELOW GRADE)
TRANSFO R M ER
RO O M
LOAD
ING AREA
HEATING
EQUIPMENT
CHEMICAL
STORAGE AREA
CART
PATH
UPPER
DELTA
RESTAURANT
PATIO
MEMBERS POOL
MEMBERS
SPA
PENINSULA
M AINT.
BLD G
PENINSULA
POOL
DELTA
POOL
LOADING AREA
5'-0" POOL FENCE
6'-0" FACILITY FENCE
6'-0" SITE PERIMETER FENCE
----------~ ,_
-------~---"-=--~~-==-~---r=--=--~:-----------
C)
Snug Harbor Surf Park Project 3. Project Description
City of Newport Beach 3-26
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project
City of Newport Beach
Ki
r
b
y
S
t
Ram ona ExpySobobaRdRamona Expy
Av
e
SobobaRdState
S
t
P
al
m
Cottonwood Ave
S
o
b
o
b
a
R
d
StateSt
Main St
Lyon Ave
Ca
w
s
t
o
n
A
v
e
7th St
Ramona Blvd Camino
l
o
s
B
a
n
o
s
Record RdOdell AveSanderson AveDeegan
S
t
Young StPotterRdWarren RdRamona
E
x
p
y
L a k e P ark D r79
Pa
l
m
A
v
e
Co
l
u
m
b
i
a
S
t
Ki
r
b
y
S
t
Gilman
S
p
r
i
n
g
s
R
d
St
a
t
e
S
t
Ly
o
n
A
v
e
Sa
n
d
e
r
s
o
n
A
v
e
Oakland
79
79 Zoning Map 2022
H E M E T
B E A U M O N T
0 1½
Miles
SanJacintoRiver SanJacintoRiver LegendSan Jacinto City LimitsSan Jacinto Sphere of InfluenceNeighboring CitySpecific Plan AreaRAAB Combining Overlay ZoneHousing OverlayResidential ZonesRE - Residential EstateRR - Rural ResidentialRL - Residential, Low DensityRM - Residential, Medium DensityRH - Residential, High DensityRVH - Residential, Very High DensityCommercial and Industrial ZonesCN - Commercial NeighborhoodCG - Commercial GeneralCR - Commercial RegionalBP - Business ParkOP - Office ParkIL - Industrial LightIH - Industrial HeavyMixed Use ZonesMU - Mixed UseMU-E - Mixed Use - EntertaintainmentDV - Downtown VillageSpecial Purpose ZonesOSG - Open Space GeneralOSR - Open Space RecreationPI - Public InstitutionalSP - Specific PlanW - Water SourceTRAILS SPSP 01-03VILLAGES SPSP 01-04COVE SPSP 01-01
ESPLANADE SP
SP 01-02
SOBOBASPRINGS SPSP 01-85 November 15, 2022
Ki
r
b
y
S
t
M
o
u
n
t
ai
n
A
ve
Ramona
E
x
p
y
Washington
A
v
e
Cottonwood Ave
Esplanade Ave
S
o
b
o
b
a
R
d
Menlo Ave
He
w
i
t
t
S
t
ParkAve
Commonwealth
Ca
w
s
to
n
A
v
e
7th St 7th St
Od
e
l
l
A
v
e
Sa
n
d
e
r
s
o
n
A
v
e
Deegan
S
t
PoWa
r
r
e
n
R
d
Ramona
E
x
p
y
R
a
m
o
na
Ex
p
y
Pa
l
m
A
v
e
Co
l
u
m
b
i
a
S
t
Ki
r
b
y
S
t
G
i
l
m
a
n
S
p
r
i
St
a
t
e
S
t
Ly
o
n
A
v
e
Sa
n
d
e
r
s
o
n
A
v
e
Oakland Ave
79
79
Zoning Map 2022
H E M E T
0 1½
Miles
SanJacintoRiver
VILLAGES SP
SP 01-04
COVE SP
SP 01-01
ESPLANADE SP
SP 01-02
RANCHO
SAN JACINTO SP
SP 01-00
C
B ) C
B ) C
( B ) C
) B ) C
B
)
C
B
)
C
B
)
C
B
)
C
'
$
&
&
(
(
&
$
! B
)
C
( & $ "!B )""# ! C
C
B ) C
B ) C
( B ) C
) B ) C
B
)
C
B
)
C
B
)
C
B
)
C
'
$
&
&
(
(
&
$
! B
)
C
( & $ "!B )""# ! C
C
B ) C
B ) C
( B ) C
) B ) C
B
)
C
B
)
C
B
)
C
'
$
&
&
(
(
&
$
! B
)
C
( & $ "!B )""# ! C
C
B ) C
B ) C
( B ) C
) B ) C
B
)
C
B
)
C
B
)
C
'
$
&
&
(
(
&
$
! B
)
C
( & $ "!B )""# ! C
$ & )
$ & )
$ & ) $ & )
$Penity Clubhouse BuiOGing Elevation
)igure
r
r
r
r
n
f
f
f
f
j
f
◊ ◊
◊
◊
◊
◊ ◊ ◊
◊ ◊ ◊ ◊
i
i
i
i
i
i
I
1/
I
i
i
i
i
i
i
Snug Harbor Surf Park Project 3. Project Description
City of Newport Beach 3-28
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project
City of Newport Beach
Ki
r
b
y
S
t
Ram ona ExpySobobaRdRamona Expy
Av
e
SobobaRdState
S
t
P
al
m
Cottonwood Ave
S
o
b
o
b
a
R
d
StateSt
Main St
Lyon Ave
Ca
w
s
t
o
n
A
v
e
7th St
Ramona Blvd Camino
l
o
s
B
a
n
o
s
Record RdOdell AveSanderson AveDeegan
S
t
Young StPotterRdWarren RdRamona
E
x
p
y
L a k e P ark D r79
Pa
l
m
A
v
e
Co
l
u
m
b
i
a
S
t
Ki
r
b
y
S
t
Gilman
S
p
r
i
n
g
s
R
d
St
a
t
e
S
t
Ly
o
n
A
v
e
Sa
n
d
e
r
s
o
n
A
v
e
Oakland
79
79 Zoning Map 2022
H E M E T
B E A U M O N T
0 1½
Miles
SanJacintoRiver SanJacintoRiver LegendSan Jacinto City LimitsSan Jacinto Sphere of InfluenceNeighboring CitySpecific Plan AreaRAAB Combining Overlay ZoneHousing OverlayResidential ZonesRE - Residential EstateRR - Rural ResidentialRL - Residential, Low DensityRM - Residential, Medium DensityRH - Residential, High DensityRVH - Residential, Very High DensityCommercial and Industrial ZonesCN - Commercial NeighborhoodCG - Commercial GeneralCR - Commercial RegionalBP - Business ParkOP - Office ParkIL - Industrial LightIH - Industrial HeavyMixed Use ZonesMU - Mixed UseMU-E - Mixed Use - EntertaintainmentDV - Downtown VillageSpecial Purpose ZonesOSG - Open Space GeneralOSR - Open Space RecreationPI - Public InstitutionalSP - Specific PlanW - Water SourceTRAILS SPSP 01-03VILLAGES SPSP 01-04COVE SPSP 01-01
ESPLANADE SP
SP 01-02
SOBOBASPRINGS SPSP 01-85 November 15, 2022
Ki
r
b
y
S
t
M
o
u
n
t
ai
n
A
ve
Ramona
E
x
p
y
Washington
A
v
e
Cottonwood Ave
Esplanade Ave
S
o
b
o
b
a
R
d
Menlo Ave
He
w
i
t
t
S
t
ParkAve
Commonwealth
Ca
w
s
to
n
A
v
e
7th St 7th St
Od
e
l
l
A
v
e
Sa
n
d
e
r
s
o
n
A
v
e
Deegan
S
t
Wa
r
r
e
n
R
d
Ramona
E
x
p
y
R
a
m
o
na
Ex
p
y
Pa
l
m
A
v
e
Co
l
u
m
b
i
a
S
t
Ki
r
b
y
S
t
G
i
l
m
a
St
a
t
e
S
t
Ly
o
n
A
v
e
Sa
n
d
e
r
s
o
n
A
v
e
Oakland Ave
79
79
Zoning Map 2022
H E M E T
0 1½
Miles
SanJacintoRiver
VILLAGES SP
SP 01-04
COVE SP
SP 01-01
ESPLANADE SP
SP 01-02
RANCHO
SAN JACINTO SP
SP 01-00
)igure 10
ATHLETE ACCOMMODATIONS LEVEL
1
6' -0"
ATHLETE ACCOMMODATIONS LEVEL
2
22' -0"
ATHLETE ACCOMMODATIONS ROOF
38' -0"
16
'
-
0
"
16
'
-
0
"
MA
X
.
B
U
I
L
D
I
N
G
H
E
I
G
H
T
F
R
O
M
E
S
T
A
B
L
I
S
H
M
E
N
T
O
F
G
R
A
D
E
40
'
-
0
"
03 05 06
ESTABLISHMENT OF GRADE 41.975'
-77/256"
ATHLETE ACCOMMODATIONS BUILDING ELEVATION -1
ATHLETE ACCOMMODATIONS LEVEL
1
6' -0"
ATHLETE ACCOMMODATIONS LEVEL
2
22' -0"
ATHLETE ACCOMMODATIONS ROOF
38' -0"
16
'
-
0
"
16
'
-
0
"
MA
X
.
B
U
I
L
D
I
N
G
H
E
I
G
H
T
F
R
O
M
E
S
T
A
B
L
I
S
H
M
E
N
T
O
F
G
R
A
D
E
40
'
-
0
"
02 05
ESTABLISHMENT OF GRADE 41.975'
-77/256"
ATHLETE ACCOMMODATIONS BUILDING ELEVATION -2
ATHLETE ACCOMMODATIONS LEVEL
1
6' -0"
ATHLETE ACCOMMODATIONS LEVEL
2
22' -0"
ATHLETE ACCOMMODATIONS ROOF
38' -0"
16
'
-
0
"
16
'
-
0
"
MA
X
.
B
U
I
L
D
I
N
G
H
E
I
G
H
T
F
R
O
M
E
S
T
A
B
L
I
S
H
M
E
N
T
O
F
G
R
A
D
E
40
'
-
0
"
01 02
ESTABLISHMENT OF GRADE 41.975'
-77/256"
ATHLETE ACCOMMODATIONS BUILDING ELEVATION -3
ATHLETE ACCOMMODATIONS LEVEL
1
6' -0"
ATHLETE ACCOMMODATIONS LEVEL
2
22' -0"
ATHLETE ACCOMMODATIONS ROOF
38' -0"
16
'
-
0
"
16
'
-
0
"
MA
X
.
B
U
I
L
D
I
N
G
H
E
I
G
H
T
F
R
O
M
E
S
T
A
B
L
I
S
H
M
E
N
T
O
F
G
R
A
D
E
40
'
-
0
"
0106
ESTABLISHMENT OF GRADE 41.975'
-77/256"
ATHLETE ACCOMMODATIONS BUILDING ELEVATION -4
$thOete $FFRPRGDWLRQBuiOGing (OeYation
◊ ◊ ◊
i
i
i
i
i
i
i
i
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
~J
I
I
I
I
r
-
r
-
r
1
1 1
,
I
1-
r-
1
I
I
I
I
I
I
_
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
◊ ◊
◊ ◊
i
i
i
i
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
<
,
f
1
1
,
I
I
r-
r-
·
I
I
I
I
I
I
I
I
1
i
i
1
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
!
!~
I
I!
I
I I
I
I
!
!
,
11:
11
◊
I
I
I
I I
I
I
I
I
I
I
I
I
I
I
I
Snug Harbor Surf Park Project 3. Project Description
City of Newport Beach 3-30
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project
City of Newport Beach
PROJECT DATA
NET SITE AREA:
LANDSCAPE AREA
LANDSCAPE COVERAGE
811,760 SF
18.635 AC
7440-016-001
7440-016-002
7440-016-003
7412-024-007
PER CIVIL PLAN
316,373 SF
38.97 %
Figure -1
Proposed Solar PV InstallationFigure 2: Snug Harbor Project–Solar PV Installations
Placentia Avenue
Solar PV Arrays
North Carports 1-9
Solar PV Arrays
West Carports 10-29
Solar PV Arrays
Buildings 1-9
Snug Harbor Surf Park Project 3. Project Description
City of Newport Beach 3-32
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 3. Project Description
City of Newport Beach 3-33
Draft EIR
May 2025
Drainage
The proposed Project’s runoff would be collected by two bioretention basins at the north parking lot and
two bioretention basins in the southern parking lot. Water flowing through the bioretention basins would then
be treated within five onsite modular wetland systems. An 18-inch storm drain would be constructed to
connect to the existing storm drain line in the northwest corner of the site near the intersection of Mesa Drive
and Irvine Avenue as well as another existing 24-inch line within Irvine Avenue near the northern parking lot
driveway.
3.7 CONSTRUCTION
Project construction would take approximately 18 months and includes demolition, site preparation, grading,
installation of infrastructure and utilities, followed by building construction, pavement, and then architectural
coatings. Table 3-5 details the total working days and construction equipment used for each phase of
construction for analytical modeling purposes. Project grading is expected to reach depths of 15 feet below
the existing ground surface and result in a balanced site with 135,000 cubic yards of cut and 135,000 cubic
yards of fill. Construction is anticipated to start in the second quarter of 2026 and be completed by the
third quarter of 2027. Construction activities would be limited to the hours allowed by the Newport Beach
Municipal Code Section 10.28.040 that limits construction activities to the hours between 7:00 a.m. to 6:30
p.m. on weekdays and between 8:00 a.m. and 6:00 p.m. on Saturdays. No construction activity is allowed
on Sundays or national holidays.
Table 3-5: Construction Schedule and Equipment
Construction Phase Working Days Equipment
Demolition 20 Rubber Tired Dozer, Excavators, Concrete/Industrial Saws
Site Preparation 30 Tractors/Loaders/Backhoes, Crawler Tractor
Grading 50 Rubber Tired Loaders, Excavators, Graders, Rubber Tired Dozers,
Scrapers
Building Construction 300 Crane, Forklifts, Generator Sets, Tractors/Loaders/Backhoes,
Welder
Paving 60 Pavers, Paving Equipment, Rollers
Architectural Coating 40 Air Compressor
During Project construction, the golf course areas to the north of Irvine Avenue (holes 10-18) and south of
Mesa Drive (holes 3-8) would remain operational. Golf cart circulation between holes 3-8 and holes 10-18
would be maintained during construction. A temporary restroom and starter shack, along with golf course
parking would be provided near the existing driveway along Irvine Avenue, as shown in Figure 3-12, Golf
Course Operations During Construction.
3.8 OPERATIONS
The proposed hours of operation for the surf lagoon are 6:00 a.m. to 11:00 p.m., 7 days a week with
ancillary amenity hours varying based on demand. The maximum number of participants in the lagoon at
one time would be 72 people with an average hourly usage of 35-45 people. The wave lagoon would
operate on a reservation basis, and the facility is anticipated to host approximately 12 surf
events/competitions per year that would be ticketed events similar in scale to other local sporting events.
I I
Snug Harbor Surf Park Project 3. Project Description
City of Newport Beach 3-34
Draft EIR
May 2025
The Project would employ approximately 70 full-time and part-time employees with an average of
approximately 55 employees onsite at any given time.
Operations of the surf lagoon include each of the 5.1-million-gallon basins being drained every other year
into the sewer system. Annually one of the surf basins would be drained, facility maintenance would occur,
and then the basin would be refilled. The following year the same process would occur with the other basin.
The timing of which would be coordinated via permit with the Costa Mesa Sanitary District (CMSD) that
provides sewer services to the site, and the City of Newport Beach Utilities Department that provides water
to the Project site.
The portions of the golf course to the north of Irvine Avenue (holes 10-18) and south of Mesa Drive (holes 3-
8) would remain with implementation of the proposed Project. Access to the 15 holes of golf would be
provided via a starter shack that would be located in between the proposed parking lots near the northern
end of the amenity clubhouse building, and golf cart storage located on the basement level of the proposed
clubhouse. In addition, golf cart path of travel between holes 3-8 and holes 10-18 would remain.
3.9 PROJECT DESIGN FEATURES
The Project voluntarily incorporates measures that serve to reduce potentially significant impacts. These
measures are referred to as Project Design Features (PDFs). Because PDFs are incorporated into the Project,
they do not constitute mitigation measures. However, because they reduce the potential of impacts, PDFs
would be incorporated into the Project’s mitigation program to ensure that they are implemented as a part
of the Project. Where applicable PDFs are described in the analysis to identify how they would reduce
potential impacts. The proposed PDFs include the following:
• PDF-1 Solar: The proposed Project includes installation of solar panels on the roofs of the buildings and
on 14 to 18-foot-high solar canopies in portions of the parking areas to provide onsite renewable
energy to provide power to the proposed Project.
• PDF-2 Vegetation: The proposed Project does not include landscaping or other vegetation that produces
seeds, fruits, nuts, or berries, such as fruit bearing trees and shrubs. Likewise, Project site areas would be
planted with seed mixtures that do not contain millet or any other large seed producing grass.
3.10 PROJECT OBJECTIVES
The intent of the Snug Harbor Surf Park Project is to develop and operate an alternative surfing facility to
provide consistent and predictable waves for training, lessons, and contests to enhance the Newport Beach
surf culture and recreation base, and to provide accommodations to support traveling athletes, coaches, and
surf park guests.
CEQA Guidelines Section 15124(b) states that an EIR shall contain a clearly written statement of objectives
to help the lead agency develop a reasonable range of alternatives to evaluate in the EIR; and that the
objectives should include the underlying purpose of the project and may discuss project benefits. The Project-
specific CEQA objectives have been carefully crafted in order to aid decision makers in their review of the
proposed Project and its associated environmental impacts. The CEQA Project objectives include the
following:
1. Provide an innovative, world-class, full-service, year-round, outdoor recreational opportunity to serve a
wide range of guests.
2. Maintain consistency with the existing Santa Ana Heights Specific Plan (SP-7) and the Open Space and
Recreation (OSR) Specific Plan designation.
Snug Harbor Surf Park Project 3. Project Description
City of Newport Beach 3-35
Draft EIR
May 2025
3. Expand the City’s tourism economy and expand transient occupancy tax revenues.
4. Utilize sustainable solar energy onsite that is consistent with the City’s sustainability goals.
3.11 DISCRETIONARY ACTIONS REQUIRED
In accordance with Sections 15050 and 15367 of the CEQA Guidelines, the City is the designated Lead
Agency for the proposed Project and has principal authority and jurisdiction for CEQA actions and Project
approval. Responsible Agencies are those agencies that have jurisdiction or authority over one or more
aspects associated with the development of a proposed project and/or mitigation. Trustee Agencies are
State agencies that have jurisdiction by law over natural resources affected by a proposed project. These
include, but may not be limited to, the permits and approvals described below.
The discretionary actions to be considered by the City as part of the proposed Project include:
• General Plan Amendment: A General Plan Amendment is requested to increase the development
intensity for the site from the current limit of 20,000 SF to approximately 59,772 SF.
• Conditional Use Permit: A Conditional Use Permit (CUP) is required per Municipal Code
20.90.050(B)(3) for an outdoor commercial recreation use and to set the parking rate consistent with
per Municipal Code Section 20.40.040. In addition, the Santa Ana Heights Specific Plan requires a CUP
to allow for the construction of a building in excess of 18 feet in height.
• Modification Permit: A Modification Permit is required for the proposed Project because the proposed
retaining walls located along the south and western property lines would exceed 8 feet in height.
• Major Site Development Review: The Project will require a Major Site Development Review (SDR)
permit because the proposed building would be greater than 20,000 SF.
The responsible agencies, trustee agencies, and other public agencies which may be required to grant
approvals and permits or coordinate as part of implementation of the proposed Project include, but are not
limited to:
• Federal Aviation Administration (FAA): Based on the location of the Project site and the proposed
height of the buildings, the Applicant will file Form 7460-1, Notice of Actual Construction or Alteration,
with the FAA. The FAA will use information provided in Form 7460-1 and other data to conduct an
aeronautical review for the proposed Project.
• Orange County Airport Land Use Commission (ALUC): The Project site is within the Airport Environs Land
Use Plan (AELUP) Notification Area for John Wayne Airport and the Project will be submitted to the ALUC
for review.
• South Coast Air Quality Management District (SCAQMD): Issuance of any permits to construct or
permits to operate.
• Santa Ana Regional Water Quality Control Board (RWQCB): Issuance of a National Pollution Discharge
Elimination System (NPDES) Permit and Construction General Permit. The Santa Ana RWQCB would also
issue a Dewatering Permit consistent with the General Permit.
• Orange County Heath Care Agency: Issuance of permits related to water safety and restaurant
operations.
Snug Harbor Surf Park Project 3. Project Description
City of Newport Beach 3-36
Draft EIR
May 2025
This page intentionally left blank
Snug Harbor Surf Park Project
City of Newport Beach
Ki
r
b
y
S
t
Ram ona ExpySobobaRdRamona Expy
Av
e
SobobaRdState
S
t
P
al
m
Cottonwood Ave
S
o
b
o
b
a
R
d
StateSt
Main St
Lyon Ave
Ca
w
s
t
o
n
A
v
e
7th St
Ramona Blvd Camino
l
o
s
B
a
n
o
s
Record RdOdell AveSanderson AveDeegan
S
t
Young StPotterRdWarren RdRamona
E
x
p
y
L a k e P ark D r79
Pa
l
m
A
v
e
Co
l
u
m
b
i
a
S
t
Ki
r
b
y
S
t
Gilman
S
p
r
i
n
g
s
R
d
St
a
t
e
S
t
Ly
o
n
A
v
e
Sa
n
d
e
r
s
o
n
A
v
e
Oaklan
79
79 Zoning Map 2022
H E M E T
B E A U M O N T
0 1½
Miles
SanJacintoRiver SanJacintoRiver LegendSan Jacinto City LimitsSan Jacinto Sphere of InfluenceNeighboring CitySpecific Plan AreaRAAB Combining Overlay ZoneHousing OverlayResidential ZonesRE - Residential EstateRR - Rural ResidentialRL - Residential, Low DensityRM - Residential, Medium DensityRH - Residential, High DensityRVH - Residential, Very High DensityCommercial and Industrial ZonesCN - Commercial NeighborhoodCG - Commercial GeneralCR - Commercial RegionalBP - Business ParkOP - Office ParkIL - Industrial LightIH - Industrial HeavyMixed Use ZonesMU - Mixed UseMU-E - Mixed Use - EntertaintainmentDV - Downtown VillageSpecial Purpose ZonesOSG - Open Space GeneralOSR - Open Space RecreationPI - Public InstitutionalSP - Specific PlanW - Water SourceTRAILS SPSP 01-03VILLAGES SPSP 01-04COVE SPSP 01-01
ESPLANADE SP
SP 01-02
SOBOBASPRINGS SPSP 01-85 November 15, 2022
Ki
r
b
y
S
t
M
o
u
n
t
ai
n
A
ve
Ramona
E
x
p
y
Washington
A
v
e
Cottonwood
Esplanade Ave
o
b
o
b
a
R
d
Menlo Ave
He
w
i
t
t
S
t
ParkAve
Commonwealth
Ca
w
s
to
n
A
v
e
7th St
Od
e
l
l
A
v
e
Sa
n
d
e
r
s
o
n
A
v
e
Deegan
S
t
Wa
r
r
e
n
R
d
Ramona
E
x
p
y
R
a
m
o
na
Ex
p
y
Pa
l
m
A
v
e
Co
l
u
m
b
i
a
S
t
Ki
r
b
y
S
t
G
St
a
t
e
S
t
Ly
o
n
A
v
e
Sa
n
d
e
r
s
o
n
A
v
e
Oakland Ave
79
79
Zoning Map 2022
H E M E T
0 1½
Miles
SanJacintoRiver
VILLAGES SP
SP 01-04
COVE SP
SP 01-01
ESPLANADE SP
SP 01-02
RANCHO
SAN JACINTO SP
SP 01-00
)igure 12
Golf Course Operations During Construction
,rYine $Yenue
0
e
V
a
'
r
i
Y
e
Br
i
V
t
o
O
S
t
r
e
e
t
([iVting (ntry
7ePporary Parking
7ePporary 5eVtrooP
Starter
Path of 7raYeO
e[iVting
Path of 7raYeO
propoVeG
Path of 7raYeO 8nGer Street
e[iVting
Path of 7raYeO
e[iVting
([iVting conGition
to rePain
([iVting conGition
to rePain
([iVting conGition
to rePain
([iVting conGition
to rePain
'eOhi )OooG
C
h
a
n
n
e
O
'eOh
i
)
O
o
o
G
C
h
a
n
n
e
O
,rYine
$
Y
e
n
u
e
'e
O
h
i
)
O
o
o
G
C
h
a
n
n
e
O
([aPpOe of the 7ePporary 5eVtrooP Starter
__,I
• \
\
\ ___/
(
1
\
\
\
\
\
\
\
\
\
\
Snug Harbor Surf Park Project 3. Project Description
City of Newport Beach 3-38
Draft EIR
May 2025
This page intentionally left blank
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-1
Draft EIR
May 2025
4. Environmental Setting
The purpose of this section is to provide a description of the environmental setting of the Project site and
surrounding area as it existed at the time of the Notice of Preparation (NOP) was published from both a
local and regional perspective. In addition to the summary below, detailed environmental setting descriptions
are provided in each subsection of Section 5 of this Draft EIR.
4.1 REGIONAL SETTING
The Project site is located in the northern portion of the City of Newport Beach at 3100 Irvine Avenue. The
site is located east of the intersection of Mesa Drive and Irvine Avenue within the Newport Beach Golf Course
(NB Golf Course). The City of Newport Beach is located approximately 20 miles southeast of Long Beach,
40 miles southwest of the City of Riverside, and 35 miles southeast of Downtown Los Angeles. Regional access
to the Project site is provided via State Route (SR) 73, located approximately 0.3 mile to the northeast, and
SR-55, located approximately 0.75 mile to the northwest. Local access to the site is provided by Irvine
Avenue through an existing driveway that provides both right or left turns to enter the site, and only right
turns leaving the site. Additionally, existing pedestrian and golf cart access to the site is provided along
Mesa Drive.
4.2 LOCAL SETTING AND PROJECT LOCATION
The Project site is identified by Assessor’s Parcel Number (APN) 119-200-41. Additionally, the site is located
within the Newport Beach USGS 7.5-Minute Quadrangle, Section 12, Township 6 South, Range 10 West,
San Bernardino Principal Meridian, and is located at latitude +33.65.85 degrees, longitude -117.8819
degrees. Regional location and local vicinity maps are provided in Figure 3-1, Regional Location, Figure 3-
2, Local Vicinity, and Figure 3-3, Aerial View.
The Project site is a portion of the NB Golf Course. The NB Golf Course is separated into three physically
distinct land areas and the Project site consists of the central portion bounded by Irvine Avenue and Mesa
Drive. The Project site is comprised of one parcel encompassing 15.38 acres that currently includes a 38-
bay partially covered synthetic turf driving range, a 1,050-square-foot (SF) putting green, a 8,975 SF
building that includes a pro shop and a restaurant that seats 233 people, a surface parking lot with 280
parking spaces, and three holes of the existing NB Golf Course (holes 1, 2, and 9).
4.3 EXISTING LAND USE AND ZONING
The 15.38-acre Project site is categorized as Parks and Recreation (PR) by the Land Use Element of the
General Plan, as shown on Figure 3-5, Existing General Plan Land Use Designations. The PR category is
intended to provide areas appropriate for the development of parks (both active and passive), golf courses,
marina support facilities, aquatic facilities, tennis clubs and courts, private recreation, and similar facilities.
The Project site is within the area designated as Anomaly Number 58 by Table LU2 of the Land Use Element
of the General Plan. The General Plan limits the development intensity of Anomaly No. 58 to 20,000 SF.
The Project site is zoned Santa Ana Heights Specific Plan (SP-7). The Santa Ana Heights Specific Plan
designates the site as Open Space and Recreation (OSR), as shown in Figure 3-6, Existing Zoning
Designations. Permitted uses within the OSR zone, subject to a use permit, include golf courses and/or outdoor
commercial recreation. Accessory uses and structures are permitted within the OSR zone when customarily
associated with and subordinate to a principal permitted use on the same building site.
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-2
Draft EIR
May 2025
The Project site is located adjacent to the Coastal Zone, the boundary of which is the northern boundary of
the Mesa Drive right-of-way, as shown in Figure 3-7, Coastal Zone Boundary.
4.4 SURROUNDING LAND USES AND DEVELOPMENT
The Project site is in between the two other portions of the NB Golf Course. The 21.28-acre northern portion,
located northeast of the Project site across Irvine Avenue, serves as the back-nine holes of the golf course
(holes 10-18) and contains the 2,782 SF golf course maintenance building. The 14.51-acre southern portion,
located southwest of the Project site across Mesa Drive, provides six holes of the golf course (holes 3-8).
Additionally, the Santa Ana-Delhi Channel is located along the northwesterly Project site boundary. The
surrounding land uses are shown on Figure 3-2, Local Vicinity, and Figure 3-3, Aerial View, and described
previously in Table 3-2, Surrounding Existing Uses, General Plan Land Use, and Zoning.
4.5 PHYSICAL ENVIRONMENTAL CONDITIONS
CEQA Guidelines Section 15125(a)(1) states that the physical environmental condition in the vicinity of the
Project as it existed at the time the EIR’s NOP was released for public review normally be used as the
comparative baseline for the EIR. The NOP for this EIR was released for public review on [date]. The following
pages include a description of the physical environmental conditions (“existing conditions”) on a regional and
local basis at the approximate time the NOP was released. More information regarding the Project site’s
environmental setting is provided in the specific subsections of Draft EIR Section 5, Environmental Analysis.
4.5.1 Aesthetics
Project Site
The visual character of the Project site includes an urban golf course of open green space with scattered
trees, golf course tees and greens, adjacent to an artificial turf driving range, roadways, and a drainage
channel. Golf course (holes 1, 2, and 9) includes rolling terrain of green areas with scattered ornamental
landscaping, and golf cart paths that is surrounded by chained link fencing with openings for golfer and
golf cart crossing of Mesa Drive to the south. The area with holes 1, 2, and 9 is bound on the west by the
Santa Ana – Delhi Channel, which is a 55-foot-wide by 16-foot-high reinforced-concrete channel that runs
in a southerly direction adjacent to the site that is bound by chain link fencing.
The driving range is located on the east side of holes 1,2, and 9, and is covered by artificial turf and is
surrounded by netting held by approximately 40 net poles that range in height from 25 to 80 feet
depending on location (due to the rolling topography). The poles and netting separating the driving range
from the commercial buildings and fire station to the east are approximately 80 feet tall while the poles
and netting separating the driving range from the golf course on the west are approximately 50 feet tall
and the poles and netting separating the driving range from Mesa Drive to the south are between 62 and
65 feet tall. Some of the poles are wood (telephone pole-like) while others are pipes. In addition, some of
the poles have pipe extensions to increase the height of the netting. The driving range has 38 bays that are
located next to the parking lot and can be seen from Irvine Avenue. Some of the driving range bays are
covered with a gable-roof and canopies with Spanish barrel roof tile supported by metal poles and piers.
The bays are adjacent to light poles used for nighttime operation of the driving range.
The one-story 8,975 SF clubhouse building and 2,664 SF driving range building are ranch-style with a Tiki
influence. The clubhouse building is irregular in shape and has a complex flat, shed roof, and Spanish barrel
tiled gable roof and a central covered breezeway. The restaurant entrance, located northwest of the
breezeway, is deeply recessed and has a pair of paneled wood doors with paneling above that gives the
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-3
Draft EIR
May 2025
appearance of floor-to-ceiling doors. The driving range building and gable portions of the roof have large,
exposed rafters and wide eaves. The northeast elevation features a thick concrete and pebble stone accent
that is wider at the bottom than the top and extends beyond the side elevations.
The exterior walls of both the clubhouse and the driving range building consist of earth-toned textured stucco
and have board-and-batten accents, as well as concrete and pebble stone accent panels and faux
buttresses. The pebble stone accents are patterned after the flagstone-accent walls popular in the 1960s
and 1970s. Fenestration consists of metal-framed windows typical of retail/commercial businesses.
The Project site contains a surface parking lot in the northeast portion of the site that is accessed from a
driveway along Irvine Avenue and contains 280 parking spaces in 4 rows of parking, and limited
landscaping with scattered trees. Pole-mounted lighting is located in the parking lot. Entrances to both the
clubhouse and the driving range buildings are adjacent to the parking lot.
Surrounding Area
The existing visual character of the area surrounding the Project site is a mix of uses with no consistent
architectural or visual theme. The visual character is dominated by the open green space with scattered trees
associated with NB Golf Course holes 3-8 to the south across Mesa Drive and holes 10-18 to the north and
northeast across Irvine Avenue. Areas to the east of the site are developed with a fire station, two- and
three-story-high commercial office buildings, associated surface parking lots and ornamental landscaping
that provide a modern commercial character. Areas to the west of the site are developed with a two-story
retail shopping center, two-story residential apartments, and commercial office buildings that are two-stories
over ground level parking with ornamental landscaping that also provide a modern and urban character.
Both Irvine Avenue and Mesa Drive are arterial roadways that are adjacent to the site and provide a
pedestrian character with landscaping, sidewalks, and bicycle lanes. The general area surrounding the site
has a topography of rolling hills, whereby Irvine Avenue slopes to the southwest, and the land on the west
side of Irvine Avenue is higher than the land on the east side. Likewise, Mesa Drive slopes to the west and
existing retaining walls are located along portions of the perimeter of the site.
Scenic Highways
As detailed by the Caltrans State Scenic Highway Mapping Program (Caltrans, 2024), there are no State
Designated Scenic Highways within the City. According to the Scenic Highway System list, State Route (SR)
1, otherwise known as Pacific Coast Highway, is eligible for the State Scenic Highway System but is not
officially designated. SR-1 is located 3.4 miles southwest of the Project site and is not visible from the Project
site. The nearest officially designated State Scenic Highway is a portion of SR-91 east of SR-55, which is
located approximately 13 miles northeast of the Project site.
Light and Glare
Light and glare in the Project area are typical of what can be found in urban environments. Sources of light
in the City is generated from building interiors and exterior sources (i.e., golf course, driving range, putting
aera, building illumination, security lighting, parking lot lighting, street lighting, and landscape lighting)
associated with the existing site and adjacent land uses. The driving range and three golf course holes with
pole mounted lights allow for golf activities to continue after the last light. Existing hours of operation and
related light generation for the driving range and golf course are 6:00 a.m. to 9:00 p.m. The hours of
operation for the pro shop are generally 10:00 a.m. to 7:00 p.m.; and the restaurant generally operates
from 8:00 a.m. to 10:00 p.m. Thus, after 10:00 p.m., limited lighting related to security lighting and signage
is generated on the site. Other offsite sources of light and glare include vehicle headlights and streetlights.
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-4
Draft EIR
May 2025
Glare can emanate from many different sources, some of which include direct sunlight, sunlight reflecting
from cars or buildings, and bright outdoor or indoor lighting. Glare in the Project vicinity is generated by
building and vehicle windows reflecting light. However, there are no substantial buildings or structures near
the Project site that presently generate substantial glare since most of the buildings are limited to one-story
to two-story structures that are constructed of non-reflective materials and are not surfaced with a substantial
number of windows adjacent to one another that would create a large reflective area.
4.5.2 Air Quality
The Project area is located within the South Coast Air Basin (Basin), which is under the jurisdiction of the
SCAQMD. The Basin is a 6,600-square-mile coastal plain bounded by the Pacific Ocean to the southwest
and the San Gabriel, San Bernardino, and San Jacinto Mountains to the north and east. The Basin includes
the non-desert portions of Los Angeles, Riverside, and San Bernardino counties, and all of Orange County.
The existing air quality conditions in the area is reflective of natural factors as topography, meteorology,
and climate, in addition to the amount of emissions released by existing air pollutant sources. The topography
and climate of southern California combine to make the Basin an area of high air pollution potential. The
Basin is a coastal plain with connecting broad valleys and low hills, bounded by the Pacific Ocean to the
west and San Bernardino mountains around the rest of the perimeter.
The general region lies in the semi-permanent high-pressure zone of the eastern Pacific, resulting in a mild
climate tempered by cool sea breezes with light average wind speeds. The usually mild climatological
pattern is disrupted occasionally by periods of extremely hot weather, winter storms, or Santa Ana winds.
During the summer months, a warm air mass frequently descends over the cool, moist marine layer produced
by the interaction between the ocean’s surface and the lowest layer of the atmosphere. The warm upper
layer forms a cap over the cool marine layer and inhibits the pollutants in the marine layer from dispersing
upward. In addition, light winds during the summer further limit ventilation. Further, sunlight triggers the
photochemical reactions which produce ozone.
SCAQMD maintains monitoring stations within district boundaries, Source Receptor Areas (SRAs), that monitor
air quality and compliance with associated ambient standards. The Project site is located within the
monitoring boundary of the North Coastal Orange County monitoring area (SRA 18). However, there are
currently no monitoring stations within SRA 18. Therefore, the following is a list of data that was obtained
from nearby monitoring stations:
• SRA 19 (Saddleback Valley located 11.74 miles east of the Project site)
o O3 (2021 and 2022)
o CO (2021 and 2022)
o PM10 (2021 and 2022)
o PM2.5 (2021)
• SRA 17 (I-5 Near Road located 11.43 miles northwest of the Project site)
o CO (2023)
o NO2 (2021 and 2022)
• SRA 17 (Central Orange County located 12.32 miles northwest of the Project site)
o O3 (2023)
o NO2 (2023)
o PM10 (2023)
o PM2.5 (2022 and 2023)
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-5
Draft EIR
May 2025
The most recent three years of data identifies the number of days ambient air quality standards were
exceeded in the area. The federal PM10 and PM2.5 standards had no exceedances. The 1-hour ozone State
standard was exceeded two times in 2021, one time in 2022, and zero times in 2023. The 8-hour ozone
federal standard was eight times in 2021, six times in 2022, and two times in 2023. In addition, the CO,
SO2, and NO2 standards were not exceeded in this area during the 3-year period.
The closest sensitive receptors to the Project site are residential uses such as single-family homes located
approximately 169 feet northwest of the Project site and a medical spa that is located immediately adjacent
to the east of the site, within 25 meters.
4.5.3 Biological Resources
The Project site is currently developed with a driving range, putting green, pro shop and restaurant, service
building, surface parking lot, and three holes of the existing NB Golf Course. Vegetation consists of
ornamental turf, shrubs, and trees with no remnant native vegetation. The National Cooperative Soil Survey
has mapped the following soils as occurring within the Project site: Myford sandy loam, 2 to 9 percent slopes;
Myford sandy loam, 9 to 15 percent slopes; Myford sandy loam, thick surface, 0 to 2 percent slopes; and
thapto-histic fluvaquents (Appendix C).
Vegetation Communities
Two different vegetation/land covers were identified within the Project site. As shown on Figure 5.3-1, Project
Site Vegetation, in Section 5.3, Biological Resources, the Project site contains approximately 6.04 acres of
turf grass/ornamental landscaping. In addition, the Project site and offsite improvement areas contain
approximately 9.48 acres of disturbed/developed area with 9.4 acres being onsite and 0.08 acres being
offsite.
The golf course fairways and greens are primarily vegetated with manicured turn grasses including
bermudagrass (Cynodon dactylon) and Saint Augustine grass (Stenotaphrum secundatum), along with other
weedy non-native grasses and forbs including Dallis grass (Paspalum dilatatum) and bur clover (Medicago
polymorpha). Ornamental trees occur throughout the area, including Aleppo pine (Pinus halepensis), lemon
scented gum (Eucalyptus citriodora), shamel ash (Fraxinus uhdei), and whiteflower kurrajong (Brachychiton
populneum). Along the northwestern property boundary adjacent to the Santa Ana Delhi Channel are a few
disjunct patches of iceplant (Carpobrotus edulis) growing with Mexican fan palm (Washingtonia robusta).
Other component species include yellow nutgrass (Cyperus esculentus), flax-leaved horseweed (Erigeron
bonariensis), Canada horseweed (Erigeron canadensis), bristly ox-tongue (Helminthotheca echioides), spiny
sowthistle (Sonchus asper), common sowthistle (Sonchus oleraceus), cape honeysuckle (Tecoma capensis),
Virgina pepperweed (Lepidium virginicum), Australian saltbush (Atriplex semibaccata), alkali weed (Cressa
truxillensis), Asian ponysfoot (Dichondra micrantha), rattlesnake sandmat (Euphorbia albomarginata), bird’s
foot trefoil (Lotus corniculatus), shoeblackplant (Hibiscus rosa-sinensis), cheeseweed mallow (Malva parviflora),
common plantain (Plantago major), prostrate knotweed (Polygonum aviculare), curly dock (Rumex crispus),
Italian cypress (Cupressus sempervirens), Canary Island pine (Pinus canariensis), red-box gum (Eucalyptus
polyanthemos), and Japanese privet (Ligustrum japonicum).
The disturbed/developed areas contain a paved parking lot, a driving range with synthetic turf, other golf
course structures and amenities including a pro shop and restaurant, and a graded slope vegetated with
both ruderal and ornamental vegetation. Integrated planters within the parking lot contain olives (Olea
europaea), Mexican fan palm, queen palm (Syagrus romanzoffiana), whiteflower kurrajong, lemon scented
gum, blue gum (Eucalyptus globulus), and brush box (Lophostemon confertus). A graded slope on the
northeastern edge of the site supports both ruderal and ornamental vegetation, including Canary Island pine
(Pinus canariensis), Aleppo pine, lemon scented gum, slender oat (Avena barbata), iceplant, prickly lettuce
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-6
Draft EIR
May 2025
(Lactuca serriola), Mexican fan palm, carrotwood (Cupaniopsis anacardioides), and a single coast live oak
(Quercus agrifolia). Other component species include sago palm (Cycas revoluta), pygmy date palm (Phoenix
roebelenii), purple fountain grass (Pennisetum setaceum ‘Rubrum’), plumeria (Plumeria rubra), spider plant
(Chlorophytum comosum), Russian thistle, aeonium (Aeonium sp.), echeveria (Echeveria sp.), jade plant
(Crassula ovata), elephant bush (Portulacaria afra), and Brazilian pepper tree (Schinus terebinthifolia)
(Appendix C).
Special-Status Vegetation Communities
The California Natural Diversity Data Base (CNDDB) identifies the following seven special-status vegetation
communities for the Newport Beach, Seal Beach, Laguna Beach, Tustin, Orange, Anaheim, and Los Alamitos
quadrangle maps: southern dune scrub, southern foredunes, valley needlegrass grassland, southern coastal
salt marsh, southern sycamore alder riparian woodland, southern coast live oak riparian forest, and
California walnut woodland. The Project site does not contain any special-status vegetation communities,
including those identified by the CNDDB (Appendix C).
Special-Status Plant Species
According to the CNDDB and CNPS, 36 special-status plant species have been recorded in the Newport
Beach, Seal Beach, Laguna Beach, Tustin, Orange, Anaheim, and Los Alamitos quadrangles. No special-status
plant species were observed onsite during the field investigation conducted for the Biological Technical
Report (Appendix C). The site has been subject to decades of anthropogenic disturbances, which has removed
native plant communities that have historically occurred. Based on the habitat requirements for the species
with potential to exist in the quadrangles and the quality of the onsite habitat, the Biological Technical Report
determined that the Project site and offsite improvement areas do not have potential to support any of the
special-status plant species known to occur in the vicinity of the site and all are presumed to be absent.
Special-Status Wildlife Species
According to the CNDDB, 50 special-status wildlife species have been recorded in the Newport Beach, Seal
Beach, Laguna Beach, Tustin, Orange, Anaheim, and Los Alamitos quadrangles. No special-status animal
species were observed onsite during the field investigation conducted for the Biological Technical Report.
While not observed onsite during the general biological survey, great blue heron individuals may
occasionally occur onsite as a transient species but is not expected to occur onsite in a nesting colony due to
lack of suitable nesting trees and frequent human disturbance. Based on the focused surveys conducted within
the Project site, no overwintering monarch butterflies were detected in or around ornamental eucalyptus or
pine trees onsite. Further, the trees onsite occur individually and are not clustered in groves or exhibit the
microclimate typical for overwintering uses. As such, the Biological Technical Report concluded that
overwintering monarch butterflies are confirmed absent (Appendix C).
According to the Biological Technical Report, the western yellow bat has a low potential to roost in
ornamental trees, including palms, on the Project site; and the Big free-tailed bat is rare in southern California
– the only recorded Orange County occurrence in the CNDDB is from Corona del Mar in 1985, and if it
occurred, it would likely be a flyover/foraging and not roosting, as it typically roosts on cliffs. Further, the
Project site provides suitable foraging, breeding, and roosting habitat for a number of raptor species. No
raptor species were detected over the course of field studies; however, common, urban adapted species
may occasionally occur. The Project site lacks potential nesting habitat (e.g., mature trees, shrubs) for special-
status raptor species but is expected to provide marginal foraging habitat for common raptors that support
prey species such as insects, spiders, lizards, snakes, small mammals, and other birds.
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-7
Draft EIR
May 2025
The site has been subject to decades of anthropogenic disturbances, which has removed native habitat for
sensitive wildlife species. Based on the habitat requirements for the specific species with potential to exist in
the quadrangles and the quality of the onsite habitat, the Biological Technical Report (Appendix C)
determined that the Project site and offsite improvement areas do not have potential to support any of the
other special-status wildlife species known to occur in the vicinity of the site and all are presumed to be
absent
Jurisdictional Waters
Two drainage culverts are located near the western corner of the property that function to drain surface
runoff from upland areas of the golf course, including cart paths and fairways. Engineered depressions that
appear to capture and direct runoff into the culverts were determined to be non-jurisdictional due to the
lack of a defined bed and bank and lack of evidence of surface flow. Therefore, no jurisdictional drainage
features, riparian vegetation, or wetlands are present (Appendix C).
Wildlife Movement
The Project site is bound by Irvine Avenue to the north and west, Mesa Drive to the southwest, and commercial
and residential land uses to the north, east, and west. The adjacent Santa Ana Delhi Channel is a cement
lined channel that is likely used for local movement by small, urban adapted mammals and reptiles. Some
local wildlife movement may occur within the Project site; however, given the lack of connection to any native
open space, the Project site does not comprise or occur within a wildlife linkage or corridor.
Orange County Central Coastal NCCP/HCP
The Project site is located within the Orange County Central/Coastal Natural Community Conservation
Plan/Habitat Conservation Plan NCCP/HCP. Within the NCCP/HCP, the Project is located within the Coastal
Subarea. The Project site is not located within the Habitat Reserve System within the NCCP/HCP and is
identified as a development site under the Orange County Central/Coastal NCCP/HCP (Appendix C).
4.5.4 Cultural Resources
Historical Setting
Orange County contains prehistoric sites dating from 9,000 to 10,000 years ago that show signs of human
presence. Sites from 6,000 to 1,000 BC (Milling Stone period) are common in the coastal region of Southern
California and at many inland locations. Between 1,000 BC to 650 AD (Intermediate period), orientation of
sites shifted toward hunting, maritime subsistence, and acorn processing. The late prehistoric period from
650 AD until European contact in 1769 included the introduction of pottery, triangular arrow points, and
cremation practices (City of Newport Beach, 2006b).
In July of 1769, Orange County was explored by those of European descent during a Franciscan expedition
led by Don Gaspar Portola. In the 1800s, Spanish and Mexican land owners, whose holdings comprised
Newport Beach’s upper bay and lower bay, sold their tracts to American entrepreneurs by the names of
Flint, Bixby, Irvine, and McFadden. In 1870, a ship from San Diego made its first trip to a marshy lagoon to
exchange goods. James McFadden and James Irvine named the landing on the bay “Newport”. In 1888,
James McFadden modified the isolated settlement by building a wharf that extended from the shallower
bay to deeper water so that large steamers could dock, which drastically increased shipping activity. By
1890, Newport Beach was acknowledged as a vibrant shipping town. The Pacific Electric Railroad was
established in 1905, which connected the City of Newport Beach to Los Angeles. Rail travel brought new
visitors to the area and eventually West Newport, East Newport, Bay Island, Balboa, Corona del Mar,
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-8
Draft EIR
May 2025
Balboa Island, and Port Orange were subdivided. In 1906, residents voted to incorporate and Newport
Beach became the fifth City to incorporate in Orange County (City of Newport Beach, 2006b).
Between 1934 and 1936, the Federal government and Orange County dredged the lower bay and
extended jetties, creating the present day contour of Newport Beach. At the end of World War II, a housing
construction boom began, which increased in the 1950s with the construction of the Santa Ana Freeway. With
increased residential development, the City’s economic industry of fishing declined and was replaced with
new businesses and commercial centers. By the 1970s, the development of Fashion Island, hotels, restaurants,
offices, and new housing tracts led to the establishment of many active employment, retail, and residential
areas that characterize Newport Beach today (City of Newport Beach, 2006b).
Project Site
Based on historic maps and aerials of the Project site and vicinity, the Project site was initially disturbed by
mechanical disking as early as 1938 and the drainage adjacent to the site was constructed prior to 1938.
The current golf course and buildings were constructed in 1976 and are not yet 50 years old. The golf course
is one of more than 900 golf courses in California. The Historic Resources Evaluation (Appendix D) prepared
for the Project has evaluated the site and describes that the Project site is part of an 18-hole executive golf
course with a one-story Ranch-style clubhouse that has a Tiki influence and includes a pro shop, offices,
restrooms, and a restaurant. The clubhouse is irregular in plan and has a complex flat, shed, and gable roof.
The shed and gable portions of the roof are sheathed with what appears to be synthetic Spanish barrel tiles
and have large, exposed rafters (some notched) and wide eaves. The shed roof has a slightly extended
peak accentuated by a heavy, notched, exposed ridge beam. The exterior walls are covered with textured
stucco and have board-and-batten accents, as well as concrete and pebble stone accent panels and faux
buttresses. The pebble stone accents are patterned after the flagstone-accent walls popular in the 1960s
and 1970s. Fenestration consists of metal-framed windows typical of retail/commercial businesses.
The building has a central covered walkway on the northwest elevation of the pro shop that leads to a wide
breezeway between the pro shop and the restaurant. The restaurant entrance, located northwest of the
breezeway, is deeply recessed and has a pair of paneled wood doors with paneling above that gives the
appearance of floor-to-ceiling doors.
The driving range shack and canopies are located southwest of the clubhouse. They form a single structure
that is T-shaped in plan, with the gable-roofed shack in the center and the shed-roofed canopies flanking it.
The canopies are supported by metal poles and faux battered piers. The shack’s northeast gable-end peak
is slightly extended above a heavy ridge beam, and the fascia rests on two exposed rafters. The northwest
and southeast sides of the shack also have exposed rafters, and they support the eaves. The walls are
covered with textured stucco. The northeast elevation features a thick concrete and pebble stone accent that
is wider at the bottom than the top and extends beyond the side elevations. The southwest elevation was not
visible. In addition, the Project site contains a freestanding, wood-framed canopy over an outdoor dining
area west of the clubhouse; holes 1, 2, and 9 of the golf course; the driving range; and a parking lot.
Archaeological Setting
The chronology of coastal Southern California, which is inclusive of the Project site, is typically divided into
three general time periods: the Early Holocene (11,000 to 8,000 Before Present [B.P.]), the Middle Holocene
(8,000 to 4,000 B.P.), and the Late Holocene (4,000 B.P. to A.D. 1769). Sites dating from 9,000 to 10,000
years ago show evidence of human presence within the Orange County region. A review of geologic
mapping as detailed in the Phase I Archaeological Resources Assessment (Appendix E) indicates that the
Project area is underlain by Myford sandy loam and Thapto-Histic Fluvaquent deposits.
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-9
Draft EIR
May 2025
A total of 38 cultural resources studies have been performed within a 0.5-mile radius of the Project site. Of
these previous studies, three include the Project site. The records search conducted for the proposed Project
identified nine cultural resources, all of which are precontact/prehistoric. The nine resources primarily consist
of lithic scatters and habitation debris; however, resource P-30-000174, which is less than 0.25-mile
northwest of the Project site, also contained human remains (which were excavated in 1950). No
archaeological or historic resources have been previously recorded within the Project site. However, the
Project site near Upper Newport Bay (which would have served as a commonly and heavily used food source
for precontact populations in the area) indicates an elevated sensitivity for subsurface cultural resources
within the Project site.
4.5.5 Energy
Electricity
The Southern California Edison Company (SCE) is the electrical purveyor in the City of Newport Beach. SCE
provides electricity service to more than 14 million people in a 50,000-square-mile area of central, coastal
and Southern California. California utilities are experiencing increasing demands that require modernization
of the electric distribution grid to, among other things, accommodate two-way flows of electricity and
increase the grid’s capacity. SCE is in the process of implementing infrastructure upgrades to ensure the
ability to meet future demands. In addition, as described by the Edison International 2023 Annual Report,
the SCE electrical grid modernization effort supports implementation of California requirements to achieve
carbon neutrality by 2045. The State has set Renewables Portfolio Standards that require retail sellers of
electricity to provide 60 percent of power from renewable resources by 2030. The State also requires
sellers of electricity to deliver 100 percent of retail sales from carbon-free sources by 2045, including interim
targets of 90 percent by 2035 and 95 percent by 2040. In 2023 approximately 49 percent of power that
SCE delivered to customers came from carbon-free resources (SCE, 2024).
The Project site is currently served by the SCE electricity distribution systems that exist along the roadways
adjacent to the Project site. Overhead utilities lines currently exist along Mesa Drive, adjacent to the western
boundary of the Project site. The Project site is located approximately 1.45 miles from Bayside Substation,
which serves the Project area through the Pike 12kV Circuit that provides distribution (SCE, 2024).
Natural Gas
The Southern California Gas Company (SoCalGas) is the natural gas purveyor in the City of Newport Beach
and is the principal distributor of natural gas in Southern California. SoCalGas estimates that gas demand
will decline at an annual rate of 3.0 percent from 2024 to 2040 due to mandated energy efficiency
standards and programs, renewable electricity goals, and global warming). The gas supply available to
SoCalGas is regionally diverse and includes supplies from California (onshore and offshore), the
southwestern United States, the Rocky Mountains, and Canada. SoCalGas designs its facilities and supplies
to provide continuous service during extreme peak demands and has identified the ability to meet peak
demands through 2030 (CGEU, 2024). The Project site currently connects to an existing 2-inch gas line in
Irvine Avenue via a 1-inch line through the existing parking lot to the north. There is also a three-inch natural
gas line at the intersection of Irvine Avenue and Mesa Drive that exists within Mesa Drive to the west of Irvine
Avenue and within Irvine Avenue to the south of the site.
4.5.6 Geology and Soils
The Project region is located within the Los Angeles Basin which is part of the Peninsular Range physiographic
Province of California. The Peninsular Ranges are characterized by a series of northwest trending mountain
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-10
Draft EIR
May 2025
ranges separated by valleys. Range geology consists of granitic rock intruding the older metamorphic rocks.
Valley geology is characterized by shallow to deep alluvial basins consisting of gravel, sand, silt, and clay
(Appendix H).
The site is located northwest of the pediment of the San Joaquin Hills in the Santa Ana Heights area,
approximately 0.75-mile north of Upper Newport Bay. The Santa Ana Heights area consists of “old paralic
deposits overlain by alluvial-fan deposits” (Appendix H).
Fault Rupture
The City is located within the Peninsular Ranges Province that is exposed to risk from multiple earthquake
fault zones. The highest risks originate from the Newport-Inglewood fault zone, the Whittier fault zone, the
San Joaquin Hills fault zone, and the Elysian Park fault zone, each with the potential to cause moderate to
large earthquakes that would cause ground shaking in Newport Beach and nearby communities (City of
Newport Beach, 2006b).
The Project site is not located within an Alquist-Priolo Fault Zone and no active faults are known to cross the
site. The closest known active fault is a segment of the Newport-Inglewood-Rose Canyon Fault Zone
approximately 5.6 miles to the west (Appendix H). Inferred/buried strands of the Newport-Inglewood-Rose
Canyon Fault Zone are mapped trending south of the site but are not currently zoned as active. The closest
mapped trace is approximately 0.9-mile south of the site. No photo lineaments or other geomorphic evidence
of active or potentially active faults intersecting the site were observed or recognized as part of our review
of aerial photos and historic topographic maps; therefore, the Geotechnical Exploration (Appendix H)
determined that the potential for surface fault rupture at the site is expected to be low.
Ground Shaking
All of Southern California is seismically active. The amount of motion expected at a building site can vary
from none to forceful depending upon the distance to the fault, the magnitude of the earthquake, and the
local geology. Greater movement can be expected at sites located on poorly consolidated material such as
alluvium located near the source of the earthquake epicenter or in response to an earthquake of great
magnitude.
Onsite Soils
Based on geologic maps, the Project site is situated on undocumented fill, alluvium, and older terrace
deposits. The site contains variable thicknesses of man-made fill that vary from soft to stiff sandy lean clay,
and loose to dense silty sand and clayey sand that is generally moist. Quaternary alluvium (Qal) encountered
in site explorations consisted of layers of lean clay, sandy lean clay, clayey sand, silty sand, and poorly
graded sands. Also, Quaternary terrace deposits (Qt) encountered in site explorations consisted of layers
of lean clay, sandy lean clay, and fat clay with interlayers or intermixed zones of silty sand, poorly graded
sand, and silt. The materials were generally moist. Fine-grained soils varied from soft to hard while granular
soils encountered were logged as medium dense to very dense (Appendix H).
Groundwater
The Geotechnical Exploration (Appendix H) describes that the historic highest groundwater in the site vicinity
is at a depth of about 10 feet below ground surface (bgs). Information from the geotechnical site
investigation documents the presence of water-bearing zones and non-water bearing zones in the subsurface.
Measured groundwater depths bgs and elevations were variable, with data indicating perched water and
confined pressurized water-bearing zones present. Most recent measurements encountered groundwater in
a monitoring well as shallow as a depth of approximately 18.52 feet below top of casing. The groundwater
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-11
Draft EIR
May 2025
levels measured during the geotechnical investigation are a “snapshot” of the groundwater levels and do
not account for potential fluctuations levels due to seasonal and tidal variations (Appendix H).
Liquefaction
Liquefaction occurs when vibrations or water pressure within a mass of soil cause the soil particles to lose
contact with one another. As a result, the soil behaves like a liquid, has an inability to support weight, and
can flow down very gentle slopes. This condition is usually temporary and is most often caused by an
earthquake vibrating water-saturated fill or unconsolidated soil. Soils that are most susceptible to
liquefaction are clean, loose, saturated, and uniformly graded fine-grained sands that lie below the
groundwater table within approximately 50 feet below ground surface. Clayey (cohesive) soils or soils which
possess clay particles in excess of 20 percent are generally not considered to be susceptible to liquefaction,
nor are those soils which are above the historic static groundwater table. Lateral spreading refers to
spreading of soils in a rapid fluid-like flow movement similar to water.
As shown in Figure 5.6-1, Liquefaction Zone, in Section 5.6, Geology and Soils, the northwest portion of the
site is mapped by the California Geological Survey as being potentially susceptible to liquefaction.
However, the Geotechnical Exploration testing identified that the Project site has a low liquefaction potential
due to the underlying soil composition properties. The Geotechnical Exploration found that based on the soil
conditions onsite and a design groundwater level of 15 feet bgs, liquefaction hazards were deemed low
(Appendix H).
Settlement
Settlement is the vertical compression of soil due to load-bearing stress. The General Plan EIR describes that
potential hazards posed by seismic settlement and/or collapse in the City is greater in areas underlain by
late Quaternary unconsolidated sediments (City of Newport Beach, 2006b). Strong ground shaking can
cause settlement of alluvial soils and artificial fills if they are not adequately compacted.
Based on the onsite soils and groundwater conditions, the Geotechnical Exploration determined that static
and seismic settlement is not a potential concern of the Project site. The seismic settlement potential is
estimated to be less than 0.5 inch (Appendix H).
Lateral Spreading
Lateral spreading is a type of liquefaction induced ground failure associated with the lateral displacement
of surficial blocks of sediment resulting from liquefaction in a subsurface layer. Once liquefaction transforms
the subsurface layer into a fluid mass, gravity plus the earthquake inertial forces may cause the mass to
move downslope towards a free face (such as a river channel or an embankment). Lateral spreading may
cause large horizontal displacements and such movement typically damages pipelines, utilities, bridges, and
structures. As described previously, the Project site is not susceptible to liquefaction. Therefore, the site is not
at risk for lateral spreading (Appendix H).
Subsidence
Ground subsidence is the gradual settling or sinking of the ground surface with little or no horizontal
movement. Subsidence typically occurs in areas with subterranean oil, gas, or groundwater, and is most
commonly associated with overdraft of groundwater. Effects of subsidence include fissures, sinkholes,
depressions, and disruption of surface drainage. The Geotechnical Exploration (Appendix H) describes that
the Project site is not within an area with known significant subsidence associated with groundwater or
petroleum withdrawal, peat oxidation, or hydrocompaction.
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-12
Draft EIR
May 2025
Landslides
Landslides and other slope failures are secondary seismic effects that are common during or soon after
earthquakes. Areas that are most susceptible to earthquake induced landslides are steep slopes underlain
by loose, weak soils, and areas on or adjacent to existing landslide deposits.
The Geotechnical Exploration describes that the existing elevation of the Project site is approximately 58
feet above mean sea level (msl), and slopes to the northwest. An existing 15-20-foot-high slope descends
from the southeast edge of the site. The remainder of the site generally slopes from approximately 50 feet
msl to approximately 15 feet msl at the northwest corner of the site. The site is not located within a mapped
area considered potentially susceptible to seismically induced slope instability (Appendix H). In addition, the
Project site is not adjacent to any substantial hills or slopes that could be subject to a landslide.
Expansive Soils
Expansive soils are soils containing water-absorbing minerals that expand as they take in water. These soils
can damage buildings due to the force they exert as they expand. Expansive soils contain certain types of
clay minerals that shrink or swell as the moisture content changes; the shrinking or swelling can shift, crack,
or break structures built on such soils. Arid or semiarid areas with seasonal changes of soil moisture
experience a much higher frequency of problems from expansive soils than areas with higher rainfall and
more constant soil moisture. The proposed Project is in a semiarid region with marked seasonal changes in
precipitation; most rain falls in winter, and there is a long dry season in summer and autumn. Therefore, the
City’s climate is such that a relatively high incidence of soil expansion is expected where soils contain the
requisite clay minerals. The Geotechnical Exploration included expansion index testing on soil samples
collected from the Project site, which determined that very low to medium expansive soils are present onsite
(Appendix H).
Paleontological Resources
Paleontological resources include any fossilized remains, traces, or imprints of organisms preserved in or on
the earth’s crust that are of paleontological interest and that provide information about the history of life on
earth, except that the term does not include any materials associated with an archaeological resource or
any cultural item defined as Native American human remains. Significant paleontological resources are
defined as fossils or assemblages of fossils that are unique, unusual, rare, uncommon, or important to define
a particular time frame or geologic strata, or that add to an existing body of knowledge in specific areas,
in local formations, or regionally.
The City’s General Plan EIR describes that Newport Beach is underlain by Holocene-age alluvial sediments
and early Pleistocene marine deposits. Below these deposits lie Miocene and late Cretaceous sedimentary
rocks. Pleistocene sediments have a rich fossil history in Southern California. Local paleontological sites have
yielded fossils of horses, elephants, bison, antelopes, and dire wolves. In addition to illuminating the striking
differences between southern California in the Pleistocene and today, this abundant fossil record has been
vital in studies of extinction, ecology, and climate change. Throughout Orange County, extinct Pleistocene
animals are well known from alluvial sediments.
The Natural History Museum of Los Angeles County database search completed for the proposed Project
identified records of five recorded fossil localities in the general Project vicinity. None of these were
documented within the Project site. The localities in the vicinity are associated with units mapped from similar
geologic units as those found on the Project site (Appendix I). The recorded fossil localities include:
• Fossils located in the drainage channel north of Irvine Avenue in Costa Mesa that yielded invertebrate
fossils.
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-13
Draft EIR
May 2025
• Fossils in an unspecified location in Newport Beach, yielded Venerid bivalve.
• A locality at the southwest end of the Newport Freeway, between Santa Isabel Avenue and 23rd Street,
produced several fossils, including camel, sea turtle, uncatalogued fish and birds, and invertebrates.
• A locality near the intersection of Superior Avenue and Pacific Coast Highway, yielded horse, other
unspecified mammals, and invertebrates such as clams, scaphopod, and marine gastropods.
• A locality at the south side of a bluff south of Bayview School and west of the San Joaquin Gun Club,
several invertebrates were recovered.
The Project site contains artificial fill underlain with young axial channel deposits and old paralic deposits
overlain by alluvial fan deposits. These soils are assigned a low paleontological resource sensitivity to a
depth of approximately 10 feet. Soils below 10 feet include older alluvial fan and Pleistocene deposits that
have the potential to preserve both marine and terrestrial animals and are considered to have a high
paleontological sensitivity.
4.5.7 Greenhouse Gas Emissions
Gases that trap heat in the atmosphere are called greenhouse gases (GHGs). The major concern with GHGs
is that increases in their concentrations are contributing to global climate change. Global climate change is
a change in the average weather on Earth that can be measured by wind patterns, storms, precipitation,
and temperature. Although there is disagreement as to the rate of global climate change and the extent of
the impacts attributable to human activities, most in the scientific community agree that there is a direct link
between increased emissions of GHGs and long-term global temperature increases.
The principal GHGs are carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), sulfur hexafluoride (SF6),
perfluorocarbons (PFCs), and hydrofluorocarbons (HFCs). Because different GHGs have different warming
potential, and CO2 is the most common reference gas for climate change, GHG emissions are often quantified
and reported as CO2 equivalents (CO2e). For example, SF6 is a GHG commonly used in the utility industry
as an insulating gas in circuit breakers and other electronic equipment. SF6, while comprising a small fraction
of the total GHGs emitted annually world-wide, is a much more potent GHG, with 22,800 times the global
warming potential as CO2. Therefore, an emission of one metric ton (MT) of SF6 could be reported as an
emission of 22,800 MT of CO2e. Large emission sources are reported in million metric tons (MMT) of CO2e.
Large emission sources are reported in million metric tons (MMT) of CO2e. The principal GHGs are described
below, along with their global warming potential.
Carbon dioxide: Carbon dioxide (CO2) is an odorless, colorless, natural GHG. Carbon dioxide’s global
warming potential is 1. Natural sources include decomposition of dead organic matter; respiration of
bacteria, plants, animals, and fungus; evaporation from oceans; and volcanic outgassing. Anthropogenic
(manmade) sources are from burning coal, oil, natural gas, and wood.
Methane: Methane (CH4) is a flammable gas and is the main component of natural gas. It has a lifetime of
12 years, and its global warming potential is 28. Methane is extracted from geological deposits (natural
gas fields). Other sources are landfills, fermentation of manure, and decay of organic matter.
Nitrous oxide: Nitrous oxide (N2O) (laughing gas) is a colorless GHG that has a lifetime of 121 years, and
its global warming potential is 265. Sources include microbial processes in soil and water, fuel combustion,
and industrial processes.
Sulfur hexafluoride: Sulfur hexafluoride (SF6) is an inorganic, odorless, colorless, and nontoxic,
nonflammable gas that has a lifetime of 3,200 years and a high global warming potential of 23,500. This
gas is manmade and used for insulation in electric power transmission equipment, in the magnesium industry,
in semiconductor manufacturing, and as a tracer gas.
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-14
Draft EIR
May 2025
Perfluorocarbons: Perfluorocarbons (PFCs) have stable molecular structures and only break down by
ultraviolet rays about 60 kilometers above Earth’s surface. Because of this, they have long lifetimes, between
10,000 and 50,000 years. Their global warming potential ranges from 7,000 to 11,000. Two main sources
of perfluorocarbons are primary aluminum production and semiconductor manufacturing.
Hydrofluorocarbons: Hydrofluorocarbons (HFCs) are a group of GHGs containing carbon, chlorine, and at
least one hydrogen atom. Their global warming potential ranges from 100 to 12,000. Hydrofluorocarbons
are synthetic manmade chemicals used as a substitute for chlorofluorocarbons in applications such as
automobile air conditioners and refrigerants.
Some of the potential effects in California of global warming may include loss in snow pack, sea level rise,
more extreme heat days per year, more high ozone days, more forest fires, and more drought years.
Globally, climate change has the potential to impact numerous environmental resources through potential,
though uncertain, impacts related to future air temperatures and precipitation patterns. The projected effects
of global warming on weather and climate are likely to vary regionally, but are expected to include the
following direct effects:
• Higher maximum temperatures and more hot days over nearly all land areas;
• Higher minimum temperatures, fewer cold days and frost days over nearly all land areas;
• Reduced diurnal temperature range over most land areas;
• Increase of heat index over land areas; and
• More intense precipitation events.
The proposed Project is located in the northern portion of the City of Newport Beach east of the intersection
of Mesa Drive and Irvine Avenue within the Newport Beach Golf Course. The primary GHG emissions in the
City of Newport Beach result from on-road transportation, building energy, water use, and wastewater
generation.
The Project site encompasses approximately 15.38 acres and is comprised of one parcel. The Project site is
currently developed with a 38-bay partially covered synthetic turf driving range, a 1,050-square-foot (SF)
putting green, a 8,975 SF building that includes a pro shop and a restaurant that seats 233 people, a
surface parking lot with 280 parking spaces, and three holes of the existing NB Golf Course (holes 1, 2, and
9). Existing GHG emissions occur from operation of the site for commercial recreational activities and vehicle
trips associated with this use and total approximately 1,791.72 CO2e annually.
4.5.8 Hazards and Hazardous Materials
The Project site has been in use as a golf course and associated facilities since 1976. The Project site is
currently developed with a driving range, three golf holes, a practice putting green, and a clubhouse with
a bar/restaurant. Golf courses are known to require heavy application of pesticides and herbicides and
routine course maintenance may have resulted in a potential release of hazardous materials at the site. Thus,
the Phase I Environmental Site Assessment (Appendix K) identified one Recognized Environmental Condition
(REC) from the historic use of pesticides and herbicides at the Project site. In addition, fire training activities
are often associated with the application of polyfluoroalkyl substances (PFAS)-containing fire suppressants.
The adjacent Fire Station contains a training center, which is located uphill and upgradient of the Project site
(Appendix K). Therefore, a Phase II Environmental Site Assessment (Appendix L) conducted onsite soil and
groundwater testing throughout the site for the presence of herbicides, pesticides, and metals in the soil as
well as PFAS in groundwater from the fire training center. The laboratory test results were compared to
corresponding USEPA Regional Screening Levels (RSLs) for residential use and Department of Substances
Control Screening Levels (DTSC SLs) for commercial/industrial uses. The testing results showed no exceedance
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-15
Draft EIR
May 2025
of laboratory detection limits or RSLs. These results indicate there is no likely release of these compounds at
the Project site and a threat to human health or the environment is not present from these compounds.
John Wayne Airport
John Wayne Airport (SNA) is located approximately 0.4-mile northeast of the Project site. The Project site
is located within the airport planning boundaries and ALUC notification area as shown on Figure 5.8-1, John
Wayne Airport Notification Area. As shown on Figure 5.8-2, 2024 John Wayne Airport Noise Contours, in
Section 5.8, Hazards and Hazardous Materials, the Project site is located within the SNA 65 CNEL noise
contour, which indicates that noise from aircraft on the Project site is 65 dB CNEL and is within the noise
impact area related to SNA operations.
The airport has two runways: the shorter 2R/20L which is 2,887 feet long is used by general aviation prop-
powered aircraft and the longer 2L/20R which is 5,700 feet long is used by commercial aircraft. With winds
predominantly coming from the ocean, aircraft typically depart to the southwest and arrive from the
northeast about 95 percent of the time with slight variations from year to year. The reverse (depart to
northeast and arrive from southwest) occurs primarily when Santa Ana wind conditions occur, but there are
times when winds aloft, or other weather conditions may cause operations to go into reverse.
As shown on Figure 5.8-3, John Wayne Airport Safety Zones for 2L/20R, in Section 5.8, Hazards and
Hazardous Materials, the Project site is located within Safety Zone 2, the Inner Approach/Departure Zone;
Safety Zone 4, Outer Approach/Departure Zone; and Safety Zone 6, the Traffic Pattern Zone, for the
2L/20R runway that is used by commercial aircraft. The Project site is not located within any of the Safety
Zones for the 2R/20L runway that is used by general aviation prop-powered aircraft, as shown in Figure
5.8-4, John Wayne Airport Safety Zones for 2R/20L in Section 5.8, Hazards and Hazardous Materials.
Pursuant to the AELUP, Safety Zone 2, the Inner Approach/Departure Zone, poses a higher risk to persons in
the area for aircraft accidents. Aircraft are typically overflying this zone at lower altitudes and emergency
landings from straight out departures can be more prevalent in this zone than in other zones. Zone 4, the
Outer Approach/Departure Zone has moderate aircraft accident risk; aircraft emergencies can occur over
this area approximately two to six percent of the time. Zone 6, the Traffic Pattern Zone, has the lowest risk
for aircraft accidents (Appendix M).
The Project site is also located under the FAR Part 77 Obstruction Imaginary Surface area for both runways.
As shown on Figure 5.8-5, FAA Part 77 Obstruction Imaginary Surfaces for Runway 2L/20R, a majority of the
Project site is located under the Approach Surface and the westernmost portion of the site is located under
the Inner Transitional Surface for the 2L/20R runway that is used by commercial aircraft. Figure 5.8-6, FAA
Part 77 Obstruction Imaginary Surfaces for Runway 2R/20L, in Section 5.8, Hazards and Hazardous Materials,
shows that the Project site is under the Conical Surface for the 2R/20L runway.
In addition, the existing NB Golf Course contains trees, large grassy areas, and high poles that may provide
roost sites, migratory flyway stop-over sites, or other functions that may benefit wildlife; and therefore, is
considered a wildlife attractant (Appendix M).
4.5.9 Hydrology and Water Quality
Watershed
The Project site is in the Santa Ana River Watershed and in the San Diego Creek sub-watershed. The Santa
Ana River Watershed includes much of Orange County, much of western Riverside County, part of
southwestern San Bernardino County, and a small portion of Los Angeles County. The watershed is bounded
on the south by the Santa Margarita watershed, on the east by the Salton Sea and Southern Mojave
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-16
Draft EIR
May 2025
watersheds, and on the north and west by the Mojave and San Gabriel watersheds, respectively. The
watershed covers approximately 2,800 square miles in area with about 700 miles of rivers. The Santa Ana
River extends over 100 miles from the San Bernardino Mountains in San Bernardino County to the Pacific
Ocean at the boundary between the Cities of Huntington Beach and Newport Beach.
The San Diego Creek sub-watershed spans 112.2 square miles in central Orange County, with its main
tributary, San Diego Creek, draining into Upper Newport Bay. Smaller tributaries of this watershed include
Serrano Creek, Borrego Canyon Wash, Agua Chinon Wash, Bee Canyon Wash, Peters Canyon Wash, Sand
Canyon Wash, Bonita Canyon Creek, and the Santa Ana Delhi Channel. The Project site drains to the Santa
Ana–Delhi Channel and then to the Newport Back Bay.
Watershed Impairments: Section 303(d) of the Federal CWA requires states to identify water bodies that
are “impaired,” or those that do not meet water quality standards and are not supporting their beneficial
uses. Total Maximum Daily Loads (TMDLs) are then designed to serve as pollution control plans for these
specific pollutants.
The Upper and Lower Newport Back Bay are included on the Section 303(d) List of Water Quality
Impairments for: chlordane, copper, DDT, nutrients, PCBs, sedimentation, malathion, toxicity, and indicator
bacteria (Appendix O).
Groundwater Basin
The Project site is located within the Coastal Plain of Orange County Groundwater Basin No. 8-001. The
Coastal Plain of Orange County basin underlies a coastal alluvial plain in northwestern Orange County. The
basin is bounded on the northwest and the north by the Los Angeles-Orange County line; on the northeast
by the Whittier fault zone and consolidated rocks of the Puente Hills and Chino Hills; on the east by
consolidated rocks of the Santa Ana Mountains; on the south by consolidated rocks of the Laguna Hills and
San Joaquin Hills; and on the southwest by the Pacific Ocean. As described in the Phase I Environmental Site
Assessment, the groundwater basin is located in the lower Santa Ana River Watershed (Appendix K).
The Orange County Water District (OCWD) manages the Orange County Basin through a Basin Production
Percentage (BPP) that is determined each water year based on groundwater conditions, availability of
imported water supplies, water year precipitation, Santa Ana River runoff, and basin management
objectives. While there is no legal limit as to how much an agency pumps from the Orange County Basin,
there is a financial disincentive to pump above the BPP. For example, if the BPP is set at 75 percent, all
pumpers within the Basin, including the City, can supply 75 percent of their water needs from groundwater
supplies at a cost significantly less than the cost of imported water. If groundwater production is equal to or
less than the BPP (i.e., less than 75 percent in the example above), all producers within the Basin pay a
replenishment assessment (RA) fee which is used to fund groundwater replenishment and recharge programs
aimed at ensuring the long-term viability and stability of the Basin. In the 2021-22 water year, the BPP was
77 percent. The 2020 Newport Beach Urban Water Management Plan (UWMP) describes that OCWD
anticipates being able to sustain the BPP at 85 percent starting in 2025.
The golf course is currently irrigated via well water. The Water Supply Evaluation (Appendix S) prepared
for the Project, estimates that irrigation for the three golf course holes uses approximately 15,299 gallons
per day (GPD) or 17.14 acre-feet per year (AFY) of groundwater.
Storm Drain Facilities
The Santa Ana-Delhi Channel, maintained by the Orange County Flood Control District (OCFCD), is a 55-
foot-wide by 16-foot-high reinforced-concrete storm drain channel that runs in a southerly direction, along
the westerly boundary of the site along Irvine Avenue. As described in the Hydrology Report (included as
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-17
Draft EIR
May 2025
Appendix P), currently 3.4 acres of the site (22 percent) is impervious, as most of the site consists of three
holes of the golf course that is covered in grass and trees. The topography of the site slopes in a northwesterly
direction, toward the Santa Ana-Delhi Channel and Irvine Avenue. An existing 15- to 20-foot-high slope
descends from the southeast boundary of the site. The remainder of the site generally slopes more gently
toward the westerly boundary of the Project. There are currently five drainage discharge points to the Santa
Ana-Delhi Channel at or within the site. Two points in Irvine Avenue where drainage is conveyed to catch
basins and then discharged into the Sana Ana-Delhi Channel, and three pipes that discharge directly to the
Santa Ana-Delhi Channel (Appendix P).
There is currently offsite drainage from properties located along the easterly boundary of the Project site
that conveys to the Project site via surface gutter or pipes. The drainage is conveyed through the golf course,
combines with the onsite drainage, and then discharges into the Santa Ana-Delhi Channel (Appendix P). The
Santa Ana-Delhi Channel flows are conveyed to the Upper and Lower Newport Bay.
Soil Infiltration
The Geotechnical Exploration (Appendix H) describes that due to shallow groundwater and the presence of
thick clay layers underlying the Project site, soils are expected to have very low to no permeability making
stormwater infiltration infeasible.
Flood Zone, Tsunami, Seiche
According to the Flood Insurance Rate Map (FIRM), published by the Federal Emergency Management
Agency (FEMA) (06059C0267J), the Project site is within a “0.2 percent Annual Chance Flood Hazard, Zone
X” flood plain area defined as areas of 1 percent annual chance flood with average depth less than one
foot or with drainage areas of less than one square mile. In addition, Zone X flood plain areas are outside
the 100-year floodplain.
A tsunami is a series of ocean waves caused by a sudden displacement of the ocean floor, most often due
to earthquakes. The Project site is over 4.2 miles from the Pacific Ocean, and is adjacent to, but outside of
the Tsunami Hazard Zone identified by the California Department of Conservation (DOC, 2021).
A seiche is a surface wave created when a body of water is shaken, usually by earthquake activity. Seiches
are of concern relative to water storage facilities because inundation from a seiche can occur if the wave
overflows a containment wall, such as the wall of a reservoir, water storage tank, dam, or other artificial
body of water. There are no water bodies in the vicinity of the Project site, and no existing risks related to
seiche flood hazards exist on or near the site.
4.5.10 Land Use and Planning
Existing Uses Onsite
The Project site consists of a portion of the NB Golf Course. The golf course is separated into three physically
distinct land areas and the Project site consists of the central portion, which is bounded by Irvine Avenue and
Mesa Drive. The Project site is comprised of one parcel encompassing 15.38 acres that currently includes a
38-bay partially covered driving range, a 1,050 square foot (SF) putting green, a 8,975 SF building that
includes a pro shop and a restaurant, a 2,664 driving range building, parking lot with 280 parking spaces,
and three holes of the existing NB Golf Course (holes 1, 2, and 9). The existing total square footage of
existing building space on the site is 11,639 SF.
The majority of the site is covered in grass or artificial grass associated with the golf course and the paved
parking lot. The golf course and the driving range are lighted for nighttime play until 10:00 p.m., and the
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-18
Draft EIR
May 2025
driving range is surrounded by approximately 40 net poles that range in height from 25 to 80 feet
depending on location. The poles and netting separating the driving range from the buildings to the east
are approximately 80 feet tall, the poles and netting separating the driving range from the golf course on
the west are approximately 50 feet tall and the poles and netting separating the driving range from Mesa
Drive to the south are between 62 and 65 feet tall. Some of the poles are wood (telephone pole-like) while
others are pipes. In addition, some of the poles have pipe extensions to increase the overall height of the
netting for safety purposes. The Project site’s existing conditions are shown in Figure 3-4, Existing Site Photos.
Existing hours of operation for the driving range and golf course are 7:00 a.m. to 10:00 p.m. The hours of
operation for the pro shop are generally 10:00 a.m. to 7:00 p.m.; and the restaurant generally operates
from 8:00 a.m. to 10:00 p.m.
Existing General Plan Land Use and Zoning Designations
The 15.38-acre Project site has a General Plan Land Use designation of Parks and Recreation (PR), as shown
on Figure 3-5, Existing General Plan Land Use Designations. The General Plan states that the PR land use
permits parks (both active and passive), golf courses, marina support facilities, aquatic facilities, tennis clubs
and courts, private recreation, and similar facilities. The Project site is identified as Anomaly Number 58,
with a development limit of 20,000 SF.
The Project site is located within the Santa Ana Heights Specific Plan (SP-7), which provides zoning regulations
for the site. The Santa Ana Heights Specific Plan designates the site as Open Space and Recreation (OSR),
as shown in Figure 3-6, Existing Zoning Designations. Permitted uses within the OSR zone, subject to a use
permit, include golf courses and outdoor commercial recreation. Also, accessory uses and structures are
permitted when customarily associated with and subordinate to a principal permitted use on the same
building site.
Surrounding Land Uses
The Project site is located within an urban area that is fully developed. The Project site is adjacent to the two
other portions of the NB Golf Course; including: the 21.28-acre northern portion located northeast of the
Project site across Irvine Avenue that contains nine holes of golf (holes 10-18) and contains the 2,782 SF golf
course maintenance building. The 14.51-acre southern portion to the south of the Project site across Mesa
Drive that contains six holes of golf (holes 3-8). Additionally, the Santa Ana-Delhi Channel is located along
the northwesterly Project site boundary. The land uses immediately adjacent to the Project site include the
following:
• Northwest: The Santa Ana-Delhi Channel followed by Irvine Avenue followed by multifamily residential.
• North: Irvine Avenue followed by “The Jetty” commercial center and nine holes of the NB Golf Course
(holes 10-18).
• Northeast: Commercial and Office Uses.
• Southeast: Newport Beach Fire Station 7 and Fire Department Training Center.
• South: Mesa Drive followed by six holes of the NB Golf Course (holes 3-8).
• Southwest: The Santa Ana-Delhi Channel followed by Mesa Drive, followed by “The Ranch” retail
shopping center.
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-19
Draft EIR
May 2025
4.5.11 Noise
Existing Noise Levels
To assess the existing noise level environment within and near the Project site, 24-hour noise level
measurements were taken on Thursday, September 12, 2024, at eight locations. The noise level
measurements were positioned as close to the nearest sensitive receiver locations as possible to assess the
existing ambient hourly noise levels. The background ambient noise levels in the Project area are dominated
by the overflight of airplanes and transportation-related noise associated with surface streets. A description
of these locations and the existing noise levels are provided in Table 5.11-4, Summary of 24-Hour Ambient
Noise Level Measurements, in Section 5.11, Noise. As shown, existing daytime noise levels range from 67.8
to 73.7 dBA.
Existing Vibration
Aside from periodic construction work that may occur in the vicinity of the Project site, other sources of
groundborne vibration include heavy-duty vehicular travel (e.g., refuse trucks and delivery trucks) on area
roadways. Trucks traveling at a distance of 50 feet typically generate groundborne vibration velocity levels
of approximately 0.006 inch per second PPV and could reach approximately 0.016 inch per second PPV
when trucks pass over bumps in the road (FTA, 2018).
Existing Airport Noise
John Wayne Airport (SNA) is located approximately 0.4-mile northeast of the Project site. As shown in
Section 5.8, Hazards and Hazardous Materials, on Figure 5.8-2, 2024 John Wayne Airport 65 dBA CNEL
Noise Contour, the Project site is located within the 2024 SNA 65 CNEL noise contour, which indicates that
noise from aircraft on the Project site is currently 65 dB CNEL and is within the noise impact area related to
SNA operations.
According to the AELUP (as listed in Section 5.10.2.3), commercial development is considered normally
consistent with exterior noise levels of less than 70 dBA CNEL, and conditionally consistent with exterior noise
levels greater than 70 dBA CNEL. The AELUP contains airport noise contours from 1985 (shown in Figure
5.10-3), which identifies that a majority of the Project site is located within the 65 dBA CNEL and a small
area in the northwestern portion of the Project site would be in the 70 dBA CNEL aircraft noise level contours,
the Project site is exposed to normally acceptable noise levels from airport operations.
Sensitive Receivers
Noise sensitive receivers are generally defined as locations where people reside or where the presence of
unwanted sound could otherwise adversely affect the use of the land. Noise-sensitive land uses are generally
considered to include residences, schools, hospitals, and recreation areas. The noise sensitive receptors that
are in the vicinity of the Project site are described below and shown in Figure 5.11-2, Noise Sensitive Receiver
Locations, in Section 5.11, Noise.
R1: Location R1 represents a residence at 20352 Kline Drive, 399 feet northwest of the Project site.
Receiver R1 is placed at the use area (backyard) facing the Project site.
R2: Location R2 represents a residence at 1691 Mesa Drive, 256 feet northwest of the Project site.
Receiver R2 is placed at the use area (pool) facing the Project site.
R3: Location R3 represents a residence at 1691 Mesa Drive, 169 feet northwest of the Project site.
Receiver R3 is placed at the building façade facing the Project site.
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-20
Draft EIR
May 2025
R4: Location R4 represents a residence at 2698 Riverside Drive, 502 feet west of the Project site.
Receiver R4 is placed at the building façade facing the Project site.
R5: Location R5 represents a residence at 2916 Irvine Avenue, 284 feet southwest of the Project site.
Receiver R5 is placed at the building façade facing the Project site.
R6: Location R6 represents a residence at 2139 Anniversary Lane, 673 feet south of the Project site.
Receiver R6 is placed at the building façade facing the Project site.
R7: Location R7 represents a park at 2061 Mesa Drive, 797 feet southeast of the Project site. Receiver
R7 is placed at the use area facing the Project site.
R8: Location R8 represents a residence at 20250 SW Acacia Street, 386 feet east of the Project site.
Receiver R8 is placed at the building façade facing the Project site.
4.5.12 Public Services
Fire Protection Services
The Project site would be served by the Newport Beach Fire Department. The Fire Department is divided
into Fire Operations Division, Fire Prevention Division, Emergency Medical Services Division, Lifeguard
Operations Division, and Community Emergency Response Team (CERT). The Fire Department provides
response to fires, medical emergencies, marine safety, hazardous materials incidents, natural and man-made
disasters, automatic and mutual aid assistance to neighboring departments, and related emergencies in an
effort to protect life, property, and the environment. In addition, the Fire Department inspects businesses and
properties, assists with code enforcement, and conducts public education programs.
The Fire Department operates from eight fire stations and three lifeguard headquarters. The closest fire
station is the Santa Ana Heights Fire Station #7 that is located adjacent to the Project site. In addition, one
other station (Fire Station #6), is located within three miles of the Project site.
The Fire Department’s daily staffing, per shift, includes: one Battalion Chief, 10 Fire Apparatus Engineers,
10 Fire Captains, 17 Paramedics/Firefighters, and two Firefighters. The Fire Department has eight fire
engines (one at each fire station), two aerial ladder trucks (one on each side of the City), and four paramedic
rescue ambulances (Newport Beach Fire Department, n.d.). The City’s 2025 Adopted Budget states that in
fiscal year 2023 the City budgeted for 143.8 full-time fire personnel and 42.56 part-time personnel, which
increased to 151.80 full-time fire personnel and 40.96 part-time personnel in fiscal year 2024.
The City’s 2025 Adopted Budget states that the Fire Department’s performance measure is to have the first
unit on scene in 5 minutes 90 percent of the time, and states that the actual response time was 5 minutes 33
seconds in fiscal year 2022-23 and 5 minutes and 34 seconds in fiscal year 2023-24.
The Fire Department’s 2023 Annual Report details that in 2023 the department responded to a total of
12,417 calls for service from within the City boundaries, and that 75.6 percent of the calls were for medical
services and that 1.09 percent were for fire related services. In addition, the Fire Department responded to
880 calls from outside the City. Of these 71.6 percent were medical related and 10.7 percent were fire
related calls for services.
Police Services
The Newport Beach Police Department is responsible for law enforcement and public safety activities in the
City. The Police Department is located at 870 Santa Barbara Drive, which is 3.7 miles south of the Project
site. According to the City’s Development Impact Fee Nexus Study, the City is currently planning the
development of a new 77,000-square-foot police station in the City (City of Newport Beach, 2025).
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-21
Draft EIR
May 2025
Police Department provides citywide services in crime prevention and investigation, community awareness
programs, and other services such as traffic control. The Police Department is separated into four divisions:
Office of the Chief, Patrol and Traffic, Support Services, and Detectives. The Police Department has divided
the City into patrol areas. The Project site is located in Patrol Area 3, which also includes Eastbluff, Bonita
Canyon, Big Canyon, Newport Center, Harbor Cove, Bayside Village, Island Lagoon, Park Newport,
Promontory Point, and Balboa Island areas of the City.
The City’s 2025 Adopted Budget states that in fiscal year 2023 the City budgeted for 233 full-time Police
Department personnel and 14.87 part-time personnel, which increased to 234 full-time personnel and 13.43
part-time personnel in fiscal year 2024. The Fiscal Year 2025 includes 237 full-time personnel (which is a
three employee increase from 2024) and 13.43 part-time personnel.
As shown in Table 5.12-3, Police Department Calls for Services and Response Times, in fiscal year 2022-23
the Police Department had 101,169 total calls for service (dispatched and field-initiated), which increased
slightly to 101,969 in fiscal year 2023-24. The Police Department has a goal of responding to Priority 1
calls for service, which include things like violent crimes in progress, life threatening circumstances, and urgent
disturbances within an average of three minutes, 30 seconds and Priority 2 calls, which are the next most
serious and include events such as violent crimes that have just occurred, property crimes that are in progress
or have just occurred, and traffic collisions for service within six minutes.
School Services
The City of Newport Beach is served by three school districts, Newport-Mesa Unified School District, Santa
Ana Unified School District, and Laguna Beach Unified School District. The site is within the service area of
the Newport-Mesa Unified School District that provides education services to the majority of residents in
Newport Beach, Costa Mesa, and other unincorporated areas of Orange County (City of Newport Beach,
2006b). The Newport-Mesa Unified School District currently operates 32 public schools, including: 22
elementary schools, 2 junior high schools, five high schools, two alternative schools, and one adult school (City
of Newport Beach, 2006b). As of the 2023/2024 school year, the NMUSD had a total enrollment of 17,768
students (California Department of Education, 2024). The closest schools to the site are the Back Bay
Montessori School, located at 398 university Drive (approximately 0.26 miles southwest of the Project site),
Back Bay Alternative High School, located at 390 Monte Vista Avenue (approximately 0.4 miles southwest
of the Project site), and Eastbluff Elementary School, located at 2627 Vista Del Oro (approximately 1.1
miles south of the Project site).
Other Public Facilities
Other governmental services in the vicinity of the Project site include a variety of public and quasi-public
services including libraries, senior centers, and other facilities. The Newport Beach Public Library System
services the City with four public library branches and three book pick up and drop off facilities at local
community centers.
4.5.13 Parks and Recreation
Onsite Recreation
There are no existing public parks within the Project Site. The Project site consists of a portion of the NB Golf
Course, which is a commercial recreation executive golf course. The NB Golf Course is not a municipal course
owned by the City; it is privately owned and open to the public for commercial use. The Project site includes
three holes of the existing NB Golf Course (holes 1, 2, and 9), a 38-bay partially covered synthetic turf
driving range, a 1,050-square-foot (SF) putting green, a 8,975 SF building that includes a pro shop and a
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-22
Draft EIR
May 2025
restaurant, and a surface parking lot with 280 parking spaces. The existing hours of operation for the driving
range and golf course are 6:30 a.m. to 9:00 p.m. from December to February and 6:00 a.m. to 9:00 p.m.
from March to November. The driving range and golf course lighting is limited to between the hours of 7:00
a.m. and 10:00 p.m.
The Project site is adjacent to the two other portions of the NB Golf Course; including: the 21.28-acre northern
portion located northeast of the Project site across Irvine Avenue that contains nine holes of golf (holes 10-
18), and the 14.51-acre southern portion to the south of the Project site across Mesa Drive that contains six
holes of golf (holes 3-8). An existing golf cart path runs along the western portion of the Project site, along
the Santa Ana-Delhi Channel, and connects the three portions of the golf course, via a tunnel under Irvine
Avenue to the north, and across Mesa Drive to the south.
City Public Park and Recreational Facilities
The City has approximately 286 acres of passive and active parks as well as 90 acres of active beach
recreation. This total is exclusive of approximately 304 acres of undeveloped parkland associated with
Upper Buck Gully and Castaways Park (approximately 16.77 acres) (Newport Beach, n.d.-a). The City
currently has five parks that provide 149.98 acres of parkland within 2 miles of the Project site. Two parks,
Mesa Birch Park and Upper Newport Bay Regional Park, are within a 15-minute walking distance.
Golf Recreation
The NB Golf Course is an 18-hole executive golf course with 3,216 yards of golf from the longest tees for
a par of 59. Executive golf courses, sometimes also referred to as par-3 or beginner courses, are shorter
courses designed for beginners, high handicappers, and people who are short on time. These courses feature
more par-3 holes than a full-length course but may also mix in some par-4 and 5 holes. They may be 9 holes
or 18 holes and can usually be played in less than two hours (GolfLink, 2023).
There are three public golf courses in Newport Beach and 10 public courses within 10 miles of the Project
site (GolfLink, 1996–2024). All courses are privately owned as there is no municipal course within the City
of Newport Beach. Public courses refer to commercial courses that are available for anyone to pay to use
and do not require membership.
Nearby public golf courses that have driving ranges include the Rancho San Joaquin Golf Course located
on Ethel Coplen Way in Irvine that has a 64 station lighted driving range, Newport Back Bay Golf Course
on Jamboree Road in Newport Beach, Costa Mesa Country Club located on Golf Course Drive in Costa Mesa
which has two 18 hole golf courses and a driving range, and the Tustin Ranch Golf Club on Tustin Ranch
Road in Tustin.
Public Beaches
In addition to these park facilities, the City has and partially operates approximately eight miles of beaches
that extend from the Santa Ana River jetty to Crystal Cove State Park and border Newport Bay. City
beaches provide a wide range of recreational activities and amenities, which include but are not limited to
surfing, swimming, beach volleyball, fire rings for barbeques, beach trails for walking, running, and bicycling,
and other beach activities (City of Newport Beach, 2024b). There are three State beaches in the City:
Crystal Cove State Park – Moro Beach, Crystal Cove State Park – Little Treasure Cove, and Corona del Mar
State Beach.
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-23
Draft EIR
May 2025
Walking and Bike Trails
The City has over 18 miles of pedestrian and bicycle trails throughout the City that have been developed
for commuting and recreation. The longest trail is Upper Bay Trail, which is located around the northern edge
of the Upper Newport Bay Nature Preserve and connects to University Drive that leads to Irvine Avenue and
then the Project site.
4.5.14 Transportation
Existing Roadway Network
Regional access to the Project site is provided from State Route (SR) 73, Interstate 405 (I-405), and SR-55
via various roadways that interconnect in a grid. The Project site is adjacent to Irvine Avenue (a major
arterial) and Mesa Drive (a secondary arterial).
Existing Site Trips
Based on Trip Generation Manual, 11th Edition rates for golf course, driving range, and high-turnover sit-
down restaurant, the Trip Generation Assessment (Appendix R) determined that the existing uses on the
Project site generate approximately 1,810 daily vehicular trips, 136 a.m. peak hour trips (including 76
inbound trips and 60 outbound trips), and 165 p.m. peak hour trips (including 87 inbound trips and 78
outbound trips).
Transit Service
The Orange County Transportation Authority (OCTA) provides fixed route bus service and on-demand
paratransit service (such as the one at the Oasis Senior Center provided for seniors) to Orange County,
inclusive of Newport Beach. OCTA operates routes through the City. As shown on Figure 5.14-1, OCTA Transit
Routes, in Section 5.14, Transportation, OCTA Bus Route 178 provides service along Irvine Avenue with stops
adjacent to the Project site that occur between approximately 5:12 a.m. and 10:44 p.m. OCTA Bus Route
178 travels between Huntington Beach and Irvine with scheduled stops at the intersection of Irvine Avenue
and Mesa Drive, which is adjacent to the Project site. However, OCTA Bus Route 178 currently has no
weekend service (OCTA, 2025).
Walking and Bike Trails
The City has over 18 miles of pedestrian and bicycle trails throughout the City that have been developed
for commuting and recreation. The longest trail is Upper Bay Trail, which is located around the northern edge
of the Upper Newport Bay Nature Preserve and connects to University Drive that leads to Irvine Avenue and
then to the Project site.
Vehicle Miles Traveled
Based on the City’s SB 743 Vehicle Miles Traveled Implementation Guide, the Project site is not located
within a Transit Priority Area. Figure 3 of the City’s Vehicle Miles Traveled Implementation Guide describes
that the Project site has an existing VMT per employee that is higher than the Countywide average commute
VMT per employee (City of Newport Beach, 2020).
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-24
Draft EIR
May 2025
4.5.15 Tribal Cultural Resources
According to available ethnographic maps, ethnographic data, and Native American input, the City of
Newport Beach lies within an area on the border of the traditional lands of the Gabrieleño and the
Juaneño/Luiseño. As such, both are discussed below.
Gabrieleño
The traditional lands of the Gabrieleño at the time of Spanish contact covers much of current-day Los
Angeles, San Bernardino, and Orange Counties, which includes the Project site in the City of Newport Beach.
The southern region of this cultural area is bound by Aliso Creek, the eastern region is located east of San
Bernardino along the Santa Ana River, the northern region includes the San Fernando Valley, and the western
region includes portions of the Santa Monica Mountains. The Gabrieleño also occupied several Channel
Islands including Santa Barbara Island, Santa Catalina Island, San Nicholas Island, and San Clemente Island.
Because of their access to certain resources, including a steatite source from Santa Catalina Island, this group
was among the wealthiest and most populous aboriginal groups in Southern California. Trade of materials
and resources controlled by the Gabrieleño extended as far north as the San Joaquin Valley, as far east as
the Colorado River, and as far south as Baja California.
The Gabrieleño lived in permanent villages and smaller, resource-gathering camps occupied at various times
of the year depending upon the seasonality of the resource. Larger villages comprised of several families
or clans, while smaller, seasonal camps typically housed smaller family units. Gabrieleño houses were domed,
circular structures made of thatched vegetation. Houses varied in size, and could house from one to several
families. Sweathouses—semicircular, earth covered buildings—were public structures used in male social
ceremonies. Other structures included menstrual huts and a ceremonial structure called a yuvar, an open-air
structure built near the chief’s house.
Hunting implements included wooden clubs, sinew-backed bows, slings, and throwing clubs. Maritime
implements included rafts, harpoons, spears, hook and line, and nets. A variety of other tools included deer
scapulae saws, bone and shell needles, bone awls, scrapers, bone or shell flakers, wedges, stone knives and
drills, metates, mullers, manos, shell spoons, bark platters, and wooden paddles and bowls. Baskets were
made from rush (Juncus sp.), deer grass (Muhlenbergia rigens), and skunkbush (Rhus trilobata). Rivers and
streams were used as trading routes and travel routes as they provided resources. Thus, many tribal cultural
resources are found along rivers, streams, and other known travel or trade routes. Likewise, the Newport
Back Bay area would have been an area that provided resources to local tribes. Thus, areas in proximity to
the Back Bay have the potential to contain resources.
Juaneño/Luiseño
The traditional lands of the Juaneño Band of Mission Indians, Acjachemen Nation and Luiseño Indians covered
Orange County and parts of San Diego, Los Angeles, and Riverside Counties. The Acjachemen Nation refers
to the indigenous people native to the area. Their population is thought to have been upwards of 3,500
before contact with the Spanish. The Juaneño name came about once the local peoples were administered
by Mission San Juan Capistrano. Native population within the Mission has been recorded to reach over 1,000
residents. Cremation and burial of the dead were practiced in their society.
The Juaneño resided in permanent, well-defined villages with associated seasonal camps housing between
35 to 300 people. Smaller villages were primarily comprised of a single lineage, while larger villages were
a combination of the dominant clan and multiple families. In larger villages, the temple was the center of the
town, with housing for the captain or chief nearby. Additionally, residence within villages were typically
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-25
Draft EIR
May 2025
patrilocal. Each village was politically independent while maintaining contact with other groups in the region
through economic, religious, and social networks.
A majority of the traditional diet was comprised of plant foods; of those, acorns were the staple food source.
As a result, villages were typically located near abundant water to leach milled acorn products. Communities
closer to the coast relied heavily on fish and marine animal resources, while terrestrial game accounted for
the smallest portion of their diet. Thus, the Newport Back Bay area would have been an area that provided
resources for sustenance, and areas in proximity to the Back Bay have the potential to contain tribal cultural
resources.
Tribal Cultural Resources
Orange County contains prehistoric sites dating from 9,000 to 10,000 years ago that show signs of human
presence. Sites from 6,000 to 1,000 BC (Milling Stone period) are common in the coastal region of Southern
California and at many inland locations. Between 1,000 BC to 650 AD (Intermediate period), orientation of
sites shifted toward hunting, maritime subsistence, and acorn processing. The late prehistoric period from
650 AD until European contact in 1769 included the introduction of pottery, triangular arrow points, and
cremation practices (City of Newport Beach, 2006b).
A total of 38 cultural resources studies have been performed within a 0.5-mile radius of the Project site. Of
these previous studies, three include the Project site. The records search conducted for the proposed Project
identified nine cultural resources, all of which are precontact/prehistoric. The nine resources primarily consist
of lithic scatters and habitation debris; however, resource P-30-000174, which is less than 0.25-mile
northwest of the Project site, also contained human remains (which were excavated in 1950). No
archaeological or historic resources have been previously recorded within the Project site. However, the
Project site near Upper Newport Bay (which would have served as a commonly and heavily used food source
for precontact populations in the area) indicates an elevated sensitivity for subsurface cultural resources
within the Project site (Appendix E).
Sacred Lands File Search
Tribal cultural resources can include archaeological sites, built environment resources, locations of events or
ceremonies, resource procurement areas, and natural landscape features with special significance to one or
more indigenous groups. The City requested a Sacred Lands File (SLF) Search from the NAHC on May 31,
2024, and received the results on June 18, 2024. The SLF returned positive results, indicating that known
tribal resources and/or sacred sites are located within the Project vicinity.
4.5.16 Utilities and Service Systems
The Project site is located within the water service area of the City of Newport Beach, which provides potable
water, recycled water, and wastewater services to an area of approximately 11 square miles along the
Orange County of Southern California and covers most of the City’s boundaries with the remaining areas
served by Irvine Ranch Water District (IRWD) and Mesa Water District. The City’s water system includes a
wellfield with a total capacity of 10,900 gallons per minute (gpm), 15 recycled water connections, 6 inter-
agency emergency interconnections and manages about 300-mile water mains system with 26,765 service
connections. (City of Newport Beach, 2021).
The City of Newport Beach has a diverse portfolio of local and imported water supplies to deliver treated
water to its customers. Water supplies include recycled water, local groundwater, and imported water.
Imported water supplies are received from Colorado River and the State Water Project (SWP) provided
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-26
Draft EIR
May 2025
by the Metropolitan Water District of Southern California (MET) and delivered through the Municipal Water
District of Orange County (MWDOC).
Water Supply and Demand
The City of Newport Beach has three sources of water supply: imported water from the MET, local
groundwater, and recycled water (City of Newport Beach, 2021). The City’s water supply is a combination
of purchased or imported water, groundwater, and recycled water.
The 2020 UWMP anticipates that the City’s water supply will increase from 14,866 AF in 2025 to 15,645
AF in 2045 (increase of 779 AF) to meet the City’s anticipated growth in water demands. Projected demands
for the 2020 UWMP were developed using information about planned development, land use, and Southern
California Association of Governments (SCAG) projections. The City’s retail demand projections include the
water savings needed to meet the Water Conservation Act of 2009, SB X7-7 requirements.
The City has the ability to purchase additional supplies of water, if necessary. In addition, the City and other
regional water supply users have identified capital improvement program projects to support regional water
supply reliability, which include new water wells and pipelines, rehabilitated water wells, and treatment
systems to remove contaminants from water (Appendix S). The 2020 UWMP details the ability of the City
to meet the anticipated water demands through 2045 in a five consecutive dry year scenario.
Project Site Water Demand. Over the past four years (2020-2023), well production for the golf course
irrigation purposes has averaged approximately 91,796 gallons per day (GPD) or 103 AFY. These totals
represent the full water demand for the entire 18-hole golf course of which the proposed Project only
occupies three; and this assumed to be 16.7 percent of the total. During this same period, potable water
uses for commercial activities on the Project site buildings and amenities averaged 1,389 GPD or
approximately 1.6 AFY. Combined, the total water demand (irrigation and commercial) for the 18-hole golf
course and commercial averages about 93,786 GPD or 104 AFY.
Based on the average irrigation demand per hole, the three holes in the Project site have an average
irrigation demand of approximately 15,300 GPD or 17.2 AFY. The total existing demand from the three
holes and the commercial on the Project site is approximately 16,689 GPD or 18.7 AFY.
Water Infrastructure
The Project site is currently served by the City of Newport Beach’s water utility. The City‘s water infrastructure
includes a wellfield with a total capacity of 10,900 gallons per minute (GPM), 15 recycled water connections,
and six inter-agency emergency interconnections. The City’s water distribution network consists of
approximately 300 miles of pipelines, serving 26,765 connections. This distribution system is divided into
five main pressure zones (Zones 1 through 5) and 16 minor zones. Zones 1 and 2 are the largest and meet
the majority of City’s demands, while Zones 3, 4, and 5 are smaller pumped zones. The Project site is located
within Pressure Zone 2. Supporting this system are four wells, three storage reservoirs, five pump stations,
and 43 pressure-reducing stations (PRS) that manage water pressure across the network (Appendix S).
An existing 24-inch domestic water line is located in Irvine Avenue adjacent to the Project site. Additionally,
the golf course is currently irrigated via onsite well water.
Wastewater
Costa Mesa Sanitary District (CMSD) provides sewer system services throughout its service area, which
includes the City of Costa Mesa as well as portions of Unincorporated Orange County and the City of
Newport Beach including the Project site. The CMSD sewer system consists of sewer mains, manholes, laterals,
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-27
Draft EIR
May 2025
pumping stations and pressurized sewer lines (force mains). Sewage is conveyed by CMSD to the Orange
County Sanitation District (OC San) Wastewater Treatment Plant No.1 located in Fountain Valley, which has
a treatment capacity of 174 million gallons per day (gpd) (City of Newport Beach, 2006), with a typical
daily flow of 124 million gpd (OC San, 2025). Thus, the remaining daily capacity of Wastewater Treatment
Plant No.1 is approximately 50 million gpd.
The Project site is currently served by an onsite 6-inch sewer lateral that connects to the 12-inch CMSD sewer
main in Mesa Drive that drains westerly toward Irvine Avenue and discharges to a 21-inch sewer main and
then into the Tustin/Irvine Pump Station. From the Pump Station, the sewer is discharged via a force main to
the Eldon Avenue Pump Station, and then a 24-inch sewer main in Fair Drive that continues via gravity toward
Fairview Road and to Treatment Plant No.1.
The Sewer Study (Appendix U) prepared for the proposed Project monitored existing flows in Mesa Drive,
Irvine Avenue, the Tustin Pump Station, and Fair Drive and determined that the CMSD 12-inch sewer main in
Mesa Drive sewer that currently serves the Project site is 17.4 percent full and has an available peak
capacity of 838 gpm, CMSD 21-inch sewer line at Irvine Avenue is 27.0 percent full and has an available
peak capacity of 2,583 gpm, the CMSD 21-inch sewer line located upstream form the Tustin Pump Station
is 31.1 percent full and has an available peak capacity of 2,390 gpm, and the 24-inch sewer main in Fair
Drive is 47.1 percent full and has an available peak capacity of 1,551 gpm (Appendix U).
Solid Waste
The City of Newport Beach is currently served by eight licensed commercial solid waste haulers for
commercial uses in the City. Solid waste in the City is then brought to one of six transfer stations which sorts
trash from recyclable materials and then transfer the materials to landfills. Solid waste generated by the
Project would be disposed of at either the Frank R. Bowerman, Olinda Alpha, or Prima Deshecha Landfill
(City of Newport Beach, 2006b). Each landfill is located approximately 16.8, 25.5, and 23.2 roadway
miles from the site, respectively. Based on the maximum received tonnage in November 2024, the three
landfills have a combined remaining permitted capacity of approximately 3,094.2 tons per day.
4.6 REFERENCES
California Department of Conservation (DOC). (2021). Tsunami Hazard Area Map. Retrieved September
24, 2024, from: https://www.conservation.ca.gov/cgs/tsunami/maps.
California Department of Education. (2024). District Profile: Newport-Mesa Unified. Retrieved January 20,
2024 from: https://www.cde.ca.gov/sdprofile/details.aspx?cds=30665970000000
California Gas and Electric Utilities (CGEU). (2024). 2024 California Gas Report.
https://www.socalgas.com/sites/default/files/2024-08/2024-California-Gas-Report-Final.pdf
Caltrans. (2024). State Scenic Highway Mapping Program.
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e805
7116f1aacaa
Carl Kim Geotechnical, Inc. (2024). Geotechnical Exploration Proposed Wavegarden Cove, 3100 Irvine
Avenue, Newport Beach, California. (Appendix H)
City of Newport Beach. (n.d.). Parks and Facilities. Retrieved October 8, 2024, from:
https://nbgis.newportbeachca.gov/gispub/Dashboards/RecreationFacilitiesDash.htm
City of Newport Beach. (2001, January). Santa Ana Heights Specific Plan. Retrieved September 23, 2024,
from ocpublicworks.com.
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-28
Draft EIR
May 2025
City of Newport Beach. (2006a). General Plan. Retrieved September 23, 2024, from
newportbeachca.gov: https://www.newportbeachca.gov/government/departments/community-
development/planning-division/general-plan-codes-and-regulations/general-plan
City of Newport Beach. (2006b). General Plan Environmental Impact Report. Retrieved September 23,
2024, from newportbeachca.gov:
https://www.newportbeachca.gov/government/departments/community-development/planning-
division/general-plan-codes-and-regulations/general-plan/general-plan-environmental-impact-
report
City of Newport Beach. (2020). CEQA Transportation Thresholds of Significance Guide, Figure 3. Retrieved
March 3, 2025, from:
https://www.newportbeachca.gov/home/showpublisheddocument/66735/6372382943343300
00
City of Newport Beach. (2021). 2020 Urban Water Management Plan. Retrieved January 20, 2025, from:
https://www.newportbeachca.gov/home/showpublisheddocument/75001/6385792898623700
00
City of Newport Beach. (2024). Beach Information. Retrieved November 14, 2024, from:
https://www.newportbeachca.gov/how-do-i-/find/beach-information
City of Newport Beach. (2025). City of Newport Beach Adopted Fiscal Year 2025 Budget. Retrieved
January 20, 2024:
https://ecms.newportbeachca.gov/WEB/DocView.aspx?id=3063617&dbid=0&repo=CNB&cr=1
Federal Transit Administration. (2006). Transit Noise and Vibration Impact Assessment.
https://docs.vcrma.org/images/pdf/planning/ceqa/FTA_Noise_and_Vibration_Manual.pdf
Federal Aviation Administration (FAA). (2016). Aeronautical Study No. 2016-AWP-5961-OE, July 19,
2016.
Fuscoe Engineering, Inc. (2024a). Preliminary Hydrology Report. (Appendix P)
Fuscoe Engineering, Inc. (2024b). Preliminary Water Quality Management Plan (PWQMP). (Appendix O)
Fuscoe Engineering, Inc. (2024c). Water Supply Evaluation. (Appendix S)
Fuscoe Engineering, Inc. (2024d). Sewer Analysis Report. (Appendix U)
Gibson Transportation Consulting, Inc. (2025). Trip Generation Assessment for Surf Farm Newport Beach,
California. (Appendix R)
Glenn Lukos Associates. (2024). Phase I Archaeological Resources Assessment for the Surf Farm Project,
Located in the City of Newport Beach, Orange County, California. (Appendix E)
Glenn Lukos Associates, Inc. (2025). Biological Technical Report for the Snug Harbor Project. (Appendix C)
GolfLink. (1996-2024). Newport Beach, California, Golf Courses and Tee Times. Retrieved October 2024
from: https://www.golflink.com/golf-courses/ca/newport-
beach#:~:text=Newport%20Beach%2C%20California%20Golf%20Courses,municipal%2C%20a
nd%2023%20private%20courses.
GolfLink. (2023). What is an Executive Course? Retrieved November 2024 from:
https://www.golflink.com/lifestyle/what-is-an-executivecourse.
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-29
Draft EIR
May 2025
Johnson Aviation, Inc. (2024). Aircraft Hazard and Land Use Risk Assessment & Wildlife Hazard Management
Analysis. (Appendix M)
LSA Associates. (2024a). Historic Resources Evaluation for the Newport Beach Golf Course Clubhouse and
Driving Range Shack/Canopy in Newport Beach, Orange County, California. (Appendix D)
LSA Associates. (2024b). Paleontological Resources Assessment for the Snug Harbor Project in Newport
Beach, Orange County, California. (Appendix I)
Newport Beach Fire Department. (n.d.). Fact Sheet. Retrieved October 7, 2024, from
https://www.newportbeachca.gov/home/showpublisheddocument/61911/6367346477085300
00
Orange County Transportation Authority (OCTA). (2025). Routes and Schedules. Retrieved March 3, 2025,
from: https://www.octa.net/ebusbook/routePDF/Route178.pdf
Orion Environmental Inc. (2024a). Phase I Environmental Site Assessment. (Appendix K)
Orion Environmental Inc. (2024b). Phase II Environmental Site Assessment. (Appendix L)
Southern California Edison (SCE). (2024). 2023 Annual Report. Retrieved March 10, 2025, from:
https://download.edison.com/406/files/202403/2023-eix-sce-annual-
report.pdf?Signature=O1PyPfS603JRP3%2FJlancxIco7Mk%3D&Expires=1741986577&AWSAcc
essKeyId=AKIATACLJRQCT2IBV7MN&versionId=gKDVybNV5xy6ZD4A6Mk_7QipIn4o0KPs&resp
onse-content-disposition=attachment
Urban Crossroads. (2025a). Surf Farm Air Quality Impact Analysis. (Appendix B)
Urban Crossroads. (2025b). Surf Farm Greenhouse Gas Analysis. (Appendix J)
Urban Crossroads. (2025c). Surf Farm Noise Analysis. (Appendix Q)
Snug Harbor Surf Park Project 4. Environmental Setting
City of Newport Beach 4-30
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 5. Environmental Impact Analysis
City of Newport Beach 5-1
Draft EIR
May 2025
5. Environmental Impact Analysis
This Chapter focuses on evaluating the significant environmental effects of the proposed Project, which is
described in Chapter 3.0, Project Description. This Chapter describes the existing physical environmental
setting (also referred to as “baseline”) for each environmental topic, and the impacts that would result from
implementation of proposed Project. Because existing federal, State, and local regulations will also shape
how the proposed Project is implemented, and provide requirements for avoiding and reducing
environmental impacts, a discussion of relevant regulations, plans, programs, and policies pertinent to each
environmental issue addressed in each environmental topic section is provided. Additionally, as necessary,
feasible mitigation measures are identified to reduce the significant impacts of proposed
Project.
ENVIRONMENTAL TOPICS
The following sections in this chapter analyze the environmental topics listed below:
5.1 Aesthetics
5.2 Air Quality
5.3 Biological Resources
5.4 Cultural Resources
5.5 Energy
5.6 Geology and Soils
5.7 Greenhouse Gas Emissions
5.8 Hazards and Hazardous Materials
5.9 Hydrology and Water Quality
5.10 Land Use and Planning
5.11 Noise
5.12 Public Services
5.13 Parks and Recreation
5.14 Transportation
5.15 Tribal Cultural Resources
5.16 Utilities and Service Systems
This Draft EIR evaluates the direct and indirect impacts resulting from the construction and operations of the
proposed Project. Under CEQA, EIRs are intended to focus their discussion on significant impacts and may
limit discussion of other impacts to a brief explanation of why the impacts are not significant. The Notice of
Preparation (NOP) that was prepared for the proposed Project and the responses received were used to
help determine the scope of the environmental issues to be addressed in this Draft EIR and consistent with
CEQA Guidelines Section 15128, issues considered potentially significant are addressed.
Issues areas that would not be potentially impacted by the proposed Project (including agricultural and
forestry resources, mineral resources, population and housing, and wildfire), are not addressed beyond the
discussion contained in Section 2.3.3, Draft EIR, and Section 7.0, Effects Found Not Significant.
FORMAT OF ENVIRONMENTAL TOPIC SECTIONS
Each environmental topic section generally includes the following main subsections:
• Introduction. This describes the purpose of analysis for the environmental topic and referenced
documents used to complete the analysis. This subsection may define terms used.
• Regulatory Setting. This subsection describes applicable federal, State, and local plans, policies, and
regulations that the Project must address and may affect its implementation.
• Environmental Setting. This subsection describes the existing physical environmental conditions
(environmental baseline) related to the environmental topic being analyzed.
• Thresholds of Significance. This subsection sets forth the thresholds of significance (significance criteria)
used to determine whether impacts are “significant.” The thresholds of significance used to assess the
significant impacts are based on those provided in Appendix G of the CEQA Guidelines.
Snug Harbor Surf Park Project 5. Environmental Impact Analysis
City of Newport Beach 5-2
Draft EIR
May 2025
• Methodology. This subsection provides a description of the methods used to analyze the impact and
determine whether it would be significant or less than significant.
• Environmental Impacts. This subsection provides an analysis of the impact statements for each identified
significance threshold. The analysis of each impact statement is organized as follows:
o A statement of the CEQA threshold being analyzed;
o The Draft EIR’s conclusion as to the significance of the impact;
o An impact assessment that evaluates the changes to the physical environment that would result from
the Project; and
o An identification of significance comparing identified impacts of the Project to the significance
threshold with implementation of existing regulations, prior to implementation of any required
mitigation.
• Cumulative Impacts. This subsection describes the potential cumulative impacts that would occur from
the Project’s environmental effects in combination with other cumulative projects (See Table 5-1).
• Existing Regulations and Regulatory Requirements. A list of applicable laws and regulations that
would reduce potentially significant impacts.
• Project Design Features. A list of design features incorporated into the Project that contribute towards
minimizing potential environmental impacts.
• Level of Significance Before Mitigation. A determination of the significance of the impacts after the
application of applicable existing regulations and regulatory requirements.
• Mitigation Measures. For each impact determined to be potentially significant after the application of
applicable laws and regulations, feasible mitigation measure(s) to be implemented are provided.
Mitigation measures include enforceable actions to:
o Avoid a significant impact;
o Minimize the severity of a significant impact;
o Rectify an impact by repairing, rehabilitating, or restoring the effected physical environment;
o Reduce or eliminate the impact over time through preservation and/or maintenance operations
during the life of the Project; and/or
o Compensating for the impact by replacing or providing substitute resources or environmental
conditions.
• Level of Significance After Mitigation. This section provides the determination of the impact’s level of
significance after the application of regulations, regulatory requirements, and mitigation measures.
ENVIRONMENTAL SETTING/BASELINE
The State CEQA Guidelines Section 15125 provides that an EIR must include a description of the physical
environmental conditions in the vicinity of the project, as they exist at the time the Notice of Preparation
(NOP) is published, or if no notice of preparation is published, at the time environmental analysis is
commenced, from both a local and regional perspective. This environmental setting normally constitutes the
baseline physical conditions by which a lead agency determines whether an impact is significant. The
description of the environmental setting shall be no longer than is necessary to gain an understanding of the
significant effects of the proposed project and its alternatives.
CEQA Guidelines and case law recognize that the date for establishing an environmental baseline cannot
be rigid (see CEQA Guidelines Sections 15146, 15151, and 15204). In some instances, information is
presented in the environmental setting that differs from the precise time of the NOP. This information is
considered representative of baseline conditions. Furthermore, environmental conditions may vary from year
Snug Harbor Surf Park Project 5. Environmental Impact Analysis
City of Newport Beach 5-3
Draft EIR
May 2025
to year, and in some cases, it is necessary to consider conditions over a range of time periods. The intent of
this Draft EIR is to provide a conservative analysis that identifies the reasonable maximum potential impact.
Thus, this Draft EIR provides a range of conditions for certain topics, such as the 2021-2023 ambient air
quality conditions provided in Section 5.2, Air Quality, and the 2024 noise level measurements identified in
Section 5.11, Noise.
A NOP was prepared for the proposed Project, and was distributed on November 7, 2024, for a 30-day
public review and comment period that ended on December 6, 2024. The baseline conditions relevant to
the environmental issues being analyzed are described within Section 4.0, Environmental Setting, and within
each subsection of this section. In some cases, (such as in Section 5.11, Noise), discussion of baseline conditions
is also provided in the impacts analyses to provide context for the impact in the most reader-friendly format
and organization.
THRESHOLDS OF SIGNIFICANCE/SIGNIFICANCE CRITERIA
CEQA Guidelines Section 15382 defines a significant effect on the environment as “a substantial, or
potentially substantial, adverse change in any of the physical conditions within the area affected by the
project, including land, air, water, minerals, flora, fauna, ambient noise, and objects of historic significance.
An economic or social change by itself shall not be considered a significant effect on the environment. A
social or economic change related to a physical change may be considered in determining whether the
physical change is significant.”
The “Thresholds of Significance” subsections provide the specific thresholds of significance by which impacts
are judged to be significant or less than significant in this Draft EIR. These include identifiable quantitative
or qualitative standards or sets of criteria pursuant to which the significance of each given environmental
effect can be determined. Exceedance of a threshold of significance normally means the effect will be
determined to be “significant” (CEQA Guidelines Section 15064.7(a)). However, an iron-clad definition of a
“significant” effect is not always possible because the significance of an activity may vary with the setting
(CEQA Guidelines Section 15064(b)). Therefore, a Lead Agency has the discretion to determine whether to
classify an impact described in an EIR as “significant,” depending on the nature of the area affected. The
thresholds of significance used to assess the significance of impacts are based on those provided in Appendix
G of the CEQA Guidelines.
IMPACT SIGNIFICANCE CLASSIFICATIONS
The following classifications are used throughout the impact analysis in this Draft EIR to describe the level of
significance of environmental impacts:
• Significant Impact: A significant impact is defined by Section 15382 of the CEQA Guidelines as a
substantial, or potentially substantial, adverse change in any of the physical conditions within the area
affected by the project including land, air, water, minerals, flora, fauna, ambient noise, and objects of
historic or aesthetic significance. An economic or social change by itself “shall not be considered a
significant effect on the environment … [but] may be considered in determining whether the physical
change is significant.” As defined in this EIR, a significant impact exceeds the defined significance criteria
and therefore requires mitigation.
• No Impact: No adverse effect on the environment would occur, and mitigation measures are not
required.
• Less than Significant Impact: The impact does not reach or exceed the defined threshold (criterion) of
significance. Therefore, no mitigation is required.
Snug Harbor Surf Park Project 5. Environmental Impact Analysis
City of Newport Beach 5-4
Draft EIR
May 2025
• Less than Significant Impact with Mitigation Incorporated: The impact reaches or exceeds the defined
threshold (criterion) of significance, and mitigation is therefore required to reduce the significant impact
to a less-than-significant level.
• Significant and Unavoidable Impact: The impact reaches or exceeds the defined threshold (criterion)
of significance, and mitigation is therefore required. However, application of all feasible mitigation
measures, standard conditions of approval, and applicable plans, programs, and policies would not
reduce the impact to a less-than-significant level, and a significant and unavoidable impact would
remain.
While CEQA requires that an EIR identify all feasible mitigation to avoid or reduce the significant impacts
of a project, it also permits public agencies to approve a project even though it would result in one or more
significant unavoidable environmental effects. For a Lead Agency to approve a project with one or more
significant unavoidable impacts, it must first prepare a statement of overriding considerations, which
identifies the specific economic, legal, social, technological, or other benefits of the project, including region-
wide or statewide environmental benefits, that outweigh its significant unavoidable effects, and thereby
warrant its approval (Public Resources Code Section 21083; CEQA Guidelines Section 15093). The
statement of overriding considerations must be supported by substantial evidence in the record (CEQA
Guidelines Section 15093(a)).
CUMULATIVE IMPACTS
Cumulative impacts refer to the combined effect of the proposed Project’s impacts with the impacts of other
past, present, and reasonably foreseeable probable future projects. Both CEQA and the CEQA Guidelines
require that cumulative impacts be analyzed in an EIR. As set forth in the CEQA Guidelines Section 15130(b),
“the discussion of cumulative impacts shall reflect the severity of the impacts and their likelihood of
occurrence, but the discussion need not provide as great detail as is provided for the effects attributable to
the project alone.” The CEQA Guidelines direct that the discussion should be guided by practicality and
reasonableness and focus on the cumulative impacts that would result from the combination of the proposed
project and other projects, rather than the attributes of other projects which do not contribute to cumulative
impacts.
According to Section 15355 of the CEQA Guidelines, ‘cumulative impacts’ refer to two or more individual
effects which, when considered together, are considerable or which compound or increase other
environmental impacts.
a) The individual effects may be changes resulting from a single project or a number of separate projects.
b) The cumulative impact from several projects is the change in the environment which results from the
incremental impact of the project when added to other closely related past, present, and reasonably
foreseeable probable future projects. Cumulative impacts can result from individually minor but
collectively significant projects taking place over a period of time.
Therefore, the cumulative discussion in this Draft EIR focuses on whether the impacts of the proposed Project
are cumulatively considerable within the context of impacts caused by other past, present, and reasonably
foreseeable future projects.
Additionally, pursuant to the CEQA Guidelines Section 15130(a)(1), an EIR should not discuss cumulative
impacts that do not result at least in part from the project being evaluated in the EIR. Thus, cumulative impact
analysis is not provided for any environmental issue where the proposed Project would have no
environmental impact. Analysis of cumulative impacts is, however, provided for all Project impacts that are
evaluated within this Draft EIR.
Snug Harbor Surf Park Project 5. Environmental Impact Analysis
City of Newport Beach 5-5
Draft EIR
May 2025
CEQA Guidelines Section 15130(b)(1) states that the information utilized in an analysis of cumulative impacts
should come from one of the following, or a reasonable combination of the two:
• A list of past, present, and probable future projects producing related or cumulative impacts, including
those projects outside the control of the lead agency; or
• A summary of projections contained in an adopted local, regional, or statewide plan or related planning
document that describes or evaluates conditions contributing to the cumulative effect.
The cumulative analysis for public services, parks and recreation, transportation, and utilities and service
systems relies on projections contained in adopted local, regional, or statewide plans or related planning
documents, such as Southern California Regional Transportation Plan and relevant regional plans developed
by the Southern California Association of Governments (SCAG). The cumulative analyses for other
environmental issues use the list of projects approach, and identifies the list of past projects which have
recently been constructed, present projects which have recently been approved and are under construction,
and probable future projects that are under entitlement review that were known of at the time the NOP was
published. As described previously, the cumulative project list is part of the environmental setting/baseline
that includes past, present and probable future projects for which development applications were submitted
to lead agencies prior to publishing of the NOP.
Different types of cumulative impacts occur over different geographic areas. For example, the geographic
scope of the cumulative air quality analysis, where cumulative impacts occur over a large area, is different
from the geographic scope considered for cumulative analysis of aesthetic resources, for which cumulative
impacts are limited to project area viewsheds. Whereas cumulative public service impacts are based upon
all development within the area serviced. Because the geographic scope and other parameters of each
cumulative analysis discussion can vary, the cumulative geographic scope, and the cumulative projects
included in the geographic scope (when the list of projects approach is used), are described for each
environmental topic. Table 5-1 provides a list of projects considered in this cumulative environmental analysis,
which was compiled per information provided by each agency, and Figure 5-1 shows the locations.
Table 5-1: Cumulative Projects List
No. Project Land Use Size
City of Newport Beach
1 UCI North Campus Hospital Project
(West of Jamboree and Birch)
Hospital 350,000 SF
2 UCI North Campus Child Health/ Medical
Office (West of Jamboree and Birch)
Office Building 168,000 SF
3 1500 Quail Residences Residential and commercial 474 apartment units
and 5,077 SF of retail.
4 4631 Birch Street Residences Residential 75 apartment units
5 Newport Irvine Medical Office Conversion
(3300 Irvine Avenue)
Medical Office Building 78,229 SF
6 Checker Properties Mixed Use
(4667 MacArthur Boulevard)
Residential and commercial 90 apartment units
4,370 SF of retail.
7 Preliminary Application for Residential
Development (4685 MacArthur Court)
Residential 700 apartment units
8 1400 Bristol Residences Residential 229 apartment units
9 1600 Dove Residences Residential 249 apartment units
10 1300 Bristol Residences Residential 193 apartment units
Snug Harbor Surf Park Project 5. Environmental Impact Analysis
City of Newport Beach 5-6
Draft EIR
May 2025
No. Project Land Use Size
11 Residences at 4400 Von Karman Residential 312 apartment units
12 Newport Airport Village Mixed-Use
(4500 Campus Drive)
Residential and commercial 329 apartment units
13 Residences at Airport Village
(4647 MacArthur Boulevard)
Residential 444 apartment units
14 Newport Crossings
(1701 Corinthian Way)
Residential and commercial 350 apartment units
and 7,500 SF of
commercial use
15 Residences at 1401 Quail Residential 67 condominium units
City of Irvine
16 Irvine Planning Area 25 Residential (SE corner
of University Drive and MacArthur Boulevard)
Residential 2500 residential units
City of Costa Mesa
17 215-223 Mesa Drive Residential 6 residential units
18 2274 Newport Boulevard Residential 80 residential units
19 1400 Bristol Street Residential 78 residential units
Sources: City of Newport Beach, City of Irvine, and City of Costa Mesa Planning Departments
SF= square feet
In addition to the list of cumulative Projects in Table 5-1, it is noted that parcels (APNs 119 300 15, 16, 17
and APN 119-310-04) to the south of the site, across Mesa Drive have been identified as Housing
Opportunity sites 23, 24, 25 and 26 in the City of Newport Beach Housing Implementation Plan. These sites
have a General Plan land use designation of Parks and Recreation (PR) and are zoned SP-7 with a Housing
Opportunity Overlay. The PR land use designation applies to land used or proposed for active public or
private recreational use. Permitted uses include parks (both active and passive), golf courses, marina support
facilities, aquatic facilities, tennis clubs and courts, private recreation, and similar facilities.
As detailed in the City of Newport Beach General Plan Housing Implementation Program EIR (State
Clearinghouse [SCH] Number 2023060699) these sites were identified as candidate sites for future housing
within Municipal Code Sections 20.80.025 (Housing Opportunity Overlay Zoning Districts maps) and
20.28.050 (Housing Opportunity (HO) Overlay Zoning Districts). The site is within the Housing Implementation
Program Airport Focus Area, which includes 100 housing sites on 176 acres of land at an assumed unit yield
of 50 dwelling units per acre (du/ac). The Housing Opportunity sites 23, 24, 25 and 26, across Mesa Drive
to the south of the Project site, total approximately 13 acres.
However, no housing is currently proposed across Mesa Drive from the Project site. No application for
development of Housing Opportunity sites 23, 24, 25 and 26 has been submitted to the City. The Housing
Implementation Program EIR includes a conservative evaluation of the cumulative impact of 9,914 units
throughout the City, including future development capacity of up to 9,649 units on 247 housing sites, 25 units
of pipeline projects, and 240 ADUs, which is above the City’s 6th Cycle RHNA allocation of 4,845 housing
units to provide a buffer to assure that “no net loss” of housing sites would occur. This was evaluated within
the scope of the General Plan Land Use and Housing Element buildout projections, which are also applicable
to the cumulative impacts of the proposed Project. Any future proposed housing, or other development
projects would require development specific environmental analysis pursuant to CEQA and related
permitting review.
Cumulative Projects
Figure 5-1Snug Harbor Surf Park Project
City of Newport Beach
3 1
2
12
5
6 7
8
9
10
11
4
13
14
15
17
18
19
16
City of Newport Beach, City of Costa Mesa, Bureau of Land
Management, Esri, HERE, Garmin, INCREMENT P, Intermap, NGA,
USGS
0 0.5 1
Miles ±Legend
Project Boundary
Cumulative Project Locations
Snug Harbor Surf Park Project 5. Environmental Impact Analysis
City of Newport Beach 5-8
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-1
Draft EIR
May 2025
5.1 Aesthetics
5.1.1 INTRODUCTION
This section describes the aesthetic conditions in the Project region and potential impacts from Project
implementation. The analysis in this section is based, in part, on the following documents and resources.
• City of Newport Beach General Plan, 2006
• City of Newport Beach General Plan Environmental Impact Report (General Plan EIR), 2006
• Santa Ana Heights Specific Plan
• City of Newport Beach Municipal Code
• Solar Glare Analysis – Solar Photovoltaic (PV) Installation – Snug Harbor Project, prepared by Johnson
Aviation, Inc., 2024, included as Appendix N
Aesthetics Terminology
• Aesthetic Resources include a combination of numerous elements, such as landforms, vegetation, water
features, urban design, and/or architecture, that provide an overall visual impression that is pleasing to,
or valued by, its observers. Factors important in describing the aesthetic resources of an area include
visual character, scenic resources, and scenic vistas. These factors together not only describe the intrinsic
aesthetic appeal of an area, but also communicate the value placed upon a landscape or scene by its
observers.
• Scenic Resources are visually significant hillsides, ridges, water bodies, and buildings that are critical in
shaping the visual character and scenic identity of the area and surrounding region.
• Scenic Vistas are defined as panoramic views of important visual features, as seen from public viewing
areas. This definition combines visual quality with information about view exposure to describe the level
of interest or concern that viewers may have for the quality of a particular view or visual setting.
• Visual Character broadly describes the unique combination of aesthetic elements and scenic resources
that characterize a particular area. The quality of an area’s visual character can be qualitatively
assessed considering the overall visual impression or attractiveness created by the particular landscape
characteristics. In urban settings, these characteristics largely include land use type and density, urban
landscaping and design, architecture, topography, and background setting.
5.1.2 REGULATORY SETTING
5.1.2.1 Federal Regulations
There are no federal regulations concerning aesthetic impacts that are applicable to the Project.
5.1.2.2 State Regulations
California Scenic Highway Program
The California Scenic Highway Program created in 1963 is managed by the California Department of
Transportation (Caltrans) for the purpose of protecting the aesthetic significance of the State’s scenic
highways. The California Scenic Highways Program was created through the adoption of the Streets and
Highways Code (§§2260 through 2263). A highway may be designated as scenic based on certain criteria,
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-2
Draft EIR
May 2025
including how much of the natural landscape can be seen by travelers, the landscape’s scenic quality, and
the extent to which development intrudes on the traveler’s enjoyment of the view. The California Scenic
Highway Program’s Scenic Highway System List identifies scenic highways that are either eligible for
designation or have already been designated as such. The California Scenic Highway Program also includes
provisions for the Corridor Protection Program, which includes ordinances and planning policies required by
jurisdictions in order to maintain lands visible from the designated scenic highways.
According to Caltrans’ California State Scenic Highway System Map, the City does not have any roads or
highways that are designated within the California Scenic Highway Program. A portion of Pacific Coast
Highway (Coast Highway) from over the Santa Ana River to near Crystal Cove State Park that runs through
the City is eligible for “scenic” status. A State scenic highway changes from eligible to officially designated
when the local jurisdiction adopts a scenic corridor protection program, applies to Caltrans for scenic
highway approval, and receives notification from Caltrans that the highway has been designated as a Scenic
Highway. A city must also adopt ordinances to preserve the scenic quality of the corridor or document such
regulations that already exist in local codes.
Objective Design Standards
California Government Code Sections 65913.4 and 66300(a)(7) define “objective design standards” as
“standards that: involve no personal or subjective judgment by a public official and are uniformly verifiable
by reference to an external and uniform benchmark or criterion available and knowable by both the
development applicant or proponent and the public official before submittal.” The objective design
standards related to the Project are included in the City’s municipal code and are described below.
5.1.2.3 Local and Regional Regulations
City of Newport Beach General Plan 2006
The City of Newport Beach General Plan 2006 contains the following policies related to aesthetics that are
applicable to the Project:
Land Use Element
Policy LU 1.6 Public Views. Protect and, where feasible, enhance significant scenic and visual resources
that include open space, mountains, canyons, ridges, ocean, and harbor from public
vantage points.
Policy LU 3.1 Neighborhoods, Districts, Corridors, and Open Spaces. Maintain Newport Beach’s
pattern of residential neighborhoods, business and employment districts, commercial
centers, corridors, and harbor and ocean districts.
Policy LU 3.2 Growth and Change. Enhance existing neighborhoods, districts, and corridors, allowing
for re-use and infill with uses that are complementary in type, form, scale, and character.
Changes in use and/or density/intensity should be considered only in those areas that are
economically underperforming, are necessary to accommodate Newport Beach’s share of
projected regional population growth, improve the relationship and reduce commuting
distance between home and jobs, or enhance the values that distinguish Newport Beach
as a special place to live for its residents. The scale of growth and new development shall
be coordinated with the provision of adequate infrastructure and public services, including
standards for acceptable traffic level of service
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-3
Draft EIR
May 2025
Policy LU 5.6.2 Form and Environment. Require that new and renovated buildings be designed to avoid
the use of styles, colors, and materials that unusually impact the design character and
quality of their location such as abrupt changes in scale, building form, architectural style,
and the use of surface materials that raise local temperatures, result in glare and
excessive illumination of adjoining properties and open spaces, or adversely modify wind
patterns.
Policy LU 5.6.3 Ambient Lighting. Require that outdoor lighting be located and designed to prevent
spillover onto adjoining properties or significantly increase the overall ambient
illumination of their location.
Natural Resources Element
Policy NR 20.4 Public View Corridor Landscaping. Design and site new development, including
landscaping, on the edges of public view corridors, including those down public streets, to
frame, accent, and minimize impacts to public views.
Policy NR 23.1 Maintenance of Natural Topography. Preserve cliffs, canyons, bluffs, significant rock
outcroppings, and site buildings to minimize alteration of the site’s natural topography
and preserve the features as a visual resource.
Policy NR 23.7 New Development Design and Siting. Design and site new development to minimize the
removal of native vegetation, preserve rock outcroppings, and protect coastal resources.
City of Newport Beach Santa Ana Heights Specific Plan
The Santa Ana Heights Specific Plan includes design guidelines to promote a consistent, high-quality
character of development to result in the overall enhancement of the aesthetic character of the community.
The guidelines are for building forms and materials, streetscape concepts, setback and buffer areas, and to
provide a unifying landscape concept.
The Santa Ana Heights Specific Plan is included in the City’s Municipal Code as Chapter 20.90. The aesthetics
related Specific Plan regulations that are applicable to the proposed Project are listed below.
City of Newport Beach Municipal Code
Chapter 20.30: Property Development Standards. The Newport Beach Municipal Code (Municipal Code)
notes that the “purpose of this chapter is to ensure that development is consistent with the General Plan,
complies with the standards of this chapter, produces an environment that is harmonious with existing and
future development, and protects the use and enjoyment of neighboring properties.” The standards apply
to all zoning districts and are considered in combination with the standards for each zoning district.
Section 20.90.030, Design Guidelines. Municipal Code Section 20.90.030 provides design guidelines for
the Santa Ana Heights Specific Plan area to promote a consistent, high quality character of development
that will result in the overall enhancement of the aesthetic character. Use of these guidelines in project
approvals will implement these objectives through the careful use of building forms and materials,
streetscape concepts, setback and buffer areas and a unifying landscape concept. A majority of the design
guidelines apply to business park and residential projects, and not to commercial recreational; however, the
following hardscape and street furniture design standards are applicable to the proposed Project:
Hardscape and Street Furniture Design. Hardscape and street furniture design elements incorporated into
the overall design theme for development in the specific plan area shall include, but not be limited to: walls
and fences, paving, light fixtures, bollards, benches, trash receptacles and planters. Hardscape and street
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-4
Draft EIR
May 2025
furniture elements will function to allow a coordinated and consistent visual and physical connection between
buildings and landscape materials within the specific plan area.
Building materials to be used as key hardscape elements are specified below. All materials utilized for walls,
fences, paving, lighting and street furniture shall be coordinated with and be complementary to architectural
design details and materials.
a. Walls and Fences.
i. Concrete masonry: integral color, four-inch coursing maximum.
ii. Brick: either red or in earth tones.
iii. Concrete: textured, bush-hammered, rock salt, sandblasted, integral color in earth tones.
iv. Wrought iron (as accents).
v. Stucco: integral or painted color (same as building stucco color or approved alternative).
b. Project and Individual Site Entry Paving (Outside Public Right-of-Way).
i. Concrete: integral color, rock salt, exposed aggregate finish with brick or wood edges, or
stamped concrete.
ii. Paving brick: in earth tones.
iii. Paving brick tile: in earth tones.
iv. Textured concrete: in earth tones.
v. Precast rough-textured pavers: integral color.
vi. Quarry tile: in earth tones.
vii. Rough-textured granite.
viii. River-washed stones/cobblestones.
ix. Asphalt; use of asphalt with the above-noted materials as accent features is encouraged.
c. Lighting Fixtures. The following lighting elements may be incorporated into site plans for individual
development proposals:
i. Parking light standards.
ii. Pedestrian pathways (bollard lights).
iii. Pedestrian plaza/courtyards (bollard lights).
iv. Landscape lighting.
d. Miscellaneous Hardscape. Miscellaneous hardscape elements include bollards, benches, trash receptacles
and planters. All of these elements shall be designed and located so as to complement and enhance the
building.
Landscape Maintenance. All landscaping shall be maintained as follows:
i. All planting areas shall be kept free of weeds and debris.
ii. Lawn and groundcovers shall be kept trimmed and/or mowed regularly.
iii. All plantings shall be kept in a healthy and growing condition.
iv. Fertilization, cultivation and tree pruning shall be carried out as part of regular maintenance.
v. Irrigation systems shall be kept in working condition. Adjustment and cleaning of system shall be a
part of regular maintenance.
vi. Stakes, guys and ties on trees shall be checked regularly for correct function; ties shall be adjusted
to avoid creating abrasions or girdling to the stems.
vii. Damage to plantings created by vandalism, automobile or acts of nature shall be corrected within
thirty (30) days.
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-5
Draft EIR
May 2025
Section 20.90.050, Open Space and Recreation Districts. This Municipal Code section provides the design
guidelines including permitted uses and setback requirements for parcels designated for Open Space and
Recreation (OSR) within the Santa Ana Heights Specific Plan. The site development standards listed in
Municipal Code Section 20.90.050(E) include the following:
• Building Site Area: 1 acre minimum.
• Building Height: 18 feet maximum unless otherwise provided for by an approved use permit.
• Building Setbacks: 20 feet minimum from all property lines.
• Lighting: All lighting shall be designed and located so that direct light rays are confined to the premises.
Section 20.30.070, Outdoor Lighting. This Municipal Code section establishes outdoor lighting standards in
order to reduce the impacts of glare, light trespass, overlighting, sky glow, and poorly shielded or
inappropriately directed lighting fixtures, and promote safety and encourage energy conservation. The
following outdoor lighting standards are applicable to all new development in the City, including the
proposed Project:
“All outdoor lighting fixtures shall be designed, shielded, aimed, located, and maintained to shield adjacent
properties and to not produce glare onto adjacent properties or roadways. Parking lot light fixtures and
light fixtures on buildings shall be full cut-off fixtures” (Section 20.30.070.A.1).
“Spotlighting or floodlighting used to illuminate buildings, statues, signs, or any other objects mounted on a
pole, pedestal, or platform or used to accentuate landscaping shall consist of full cut-off or directionally
shielded lighting fixtures that are aimed and controlled so that the directed light shall be substantially
confined to the object intended to be illuminated to minimize glare, sky glow, and light trespass. The beam
width shall not be wider than that needed to light the feature with minimum spillover. The lighting shall not
shine directly into the window of a residence or directly into a roadway. Light fixtures attached to a building
shall be directed downward” (Section 20.30.070.C).
Section 20.30.100, Public View Protection. This municipal code provides regulations to preserve significant
visual resources (public views) from public view points and corridors. The provisions of this section shall apply
only to discretionary applications where a project has the potential to obstruct public views from public view
points and corridors, as identified on General Plan Figure NR 3, Coastal Views, to the Pacific Ocean, Newport
Bay and Harbor, offshore islands, the Old Channel of the Santa River (the Oxbow Loop), Newport Pier,
Balboa Pier, designated landmark and historic structures, parks, coastal and inland bluffs, canyons,
mountains, wetlands, and permanent passive open space.
The Project site is located farther inland than any of the public views points and corridors, identified on
General Plan Figure NR 3, Coastal Views; and therefore, does not have the potential to block coastal views
from these public view points and corridors. As a result, this section does not apply.
5.1.3 ENVIRONMENTAL SETTING
Aesthetic resources include a combination of numerous elements, such as landforms, vegetation, water
features, urban design, and/or architecture, that impart an overall visual impression that is pleasing to, or
valued by, its observers. Factors important in describing the aesthetic resources of an area include visual
character, scenic resources, and scenic vistas. These factors together not only describe the intrinsic aesthetic
appeal of an area, but also communicate the value placed upon a landscape or scene by its observers.
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-6
Draft EIR
May 2025
5.1.3.1 Scenic Vistas
Scenic vistas are panoramic views of important visual features, as seen from public viewing areas. The Project
site is located in an area primarily developed with residential and commercial uses, a golf course, and
roadways; and is not within a scenic vista. Likewise, the Project site is surrounded by urban development and
there are no long-range scenic vistas from the Project site. Although areas of open space are located to the
north and south of the Project site (associated with NB Golf Course holes 3-8 and 10-18), those golf course
areas are bound by the Santa Ana-Delhi Channel, residences, and roadways that do not provide scenic
views.
The City has identified the Pacific Ocean, the San Joaquin Corridor, Crystal Cove State Park, and Upper
Newport Bay as locally significant scenic vistas. In addition, the General Plan describes that scenic vistas
within the City consist of public coastal views from the roadway segments identified in the City’s Local Coastal
Program and from public viewpoints and corridors, identified on General Plan Figure NR 3, Coastal Views
(City of Newport Beach, 2006a). None of the listed roadway segments, viewpoints, or view corridors are
adjacent to the Project site, and are all located to the west, such that the Project site is behind the views, and
not encroaching into or blocking the views. The closest viewpoint is located approximately 0.3-mile southwest
of the Project site at Irvine Avenue south of University Drive, which contains views of the Upper Newport Bay
Preserve, and long-distance westward coastal views. The Project site is to the northeast and behind the
Upper Newport Bay Preserve and is not within the coastal scenic viewshed.
5.1.3.2 State Scenic Highways
As detailed by the Caltrans State Scenic Highway Mapping Program (Caltrans, 2024), there are no State
Designated Scenic Highways within the City. According to the Scenic Highway System List, State Route 1,
otherwise known as Pacific Coast Highway, is eligible for the State Scenic Highway System but is not officially
designated. The nearest Eligible State Scenic Highway is State Route (SR) 1, which is located 3.4 miles
southwest of the Project site and is not visible from the Project site. The nearest officially designated State
Scenic Highway is a portion of SR-91 east of SR-55, which is located approximately 13 miles northeast of
the Project site.
5.1.3.3 Visual Character and Quality of Site and Surrounding Area
Project Site
The visual character of the Project site includes an urban golf course of open green space with scattered
trees, golf course tees and greens, adjacent to an artificial turf driving range, roadways, and a drainage
channel. Golf course (holes 1, 2, and 9) includes rolling terrain of green areas with scattered ornamental
landscaping, and golf cart paths that is surrounded by chained link fencing with openings for golfer and
golf cart crossing of Mesa Drive to the south. The area with holes 1, 2, and 9 is bound on the west by the
Santa Ana – Delhi Channel, which is a 55-foot-wide by 16-foot-high reinforced-concrete channel that runs
in a southerly direction adjacent to the site that is bound by chain link fencing.
The driving range is located on the east side of holes 1,2, and 9, and is covered by artificial turf and is
surrounded by netting held by approximately 40 net poles that range in height from 25 to 80 feet
depending on location (due to the rolling topography). The poles and netting separating the driving range
from the commercial buildings and fire station to the east are approximately 80 feet tall while the poles
and netting separating the driving range from the golf course on the west are approximately 50 feet tall
and the poles and netting separating the driving range from Mesa Drive to the south are between 62 and
65 feet tall. Some of the poles are wood (telephone pole-like) while others are pipes. In addition, some of
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-7
Draft EIR
May 2025
the poles have pipe extensions to increase the height of the netting. The driving range has 38 bays that are
located next to the parking lot and can be seen from Irvine Avenue. Some of the driving range bays are
covered with a gable-roof and canopies with Spanish barrel roof tile supported by metal poles and piers.
The bays are adjacent to light poles used for nighttime operation of the driving range.
The one-story 8,975 SF clubhouse building and 2,664 SF driving range building are ranch-style with a Tiki
influence. The clubhouse building is irregular in shape and has a complex flat, shed roof, and Spanish barrel
tiled gable roof and a central covered breezeway. The restaurant entrance, located northwest of the
breezeway, is deeply recessed and has a pair of paneled wood doors with paneling above that gives the
appearance of floor-to-ceiling doors. The driving range building and gable portions of the roof have large,
exposed rafters and wide eaves. The northeast elevation features a thick concrete and pebble stone accent
that is wider at the bottom than the top and extends beyond the side elevations.
The exterior walls of both the clubhouse and the driving range building consist of earth-toned textured stucco
and have board-and-batten accents, as well as concrete and pebble stone accent panels and faux
buttresses. The pebble stone accents are patterned after the flagstone-accent walls popular in the 1960s
and 1970s. Fenestration consists of metal-framed windows typical of retail/commercial businesses.
The Project site contains a surface parking lot in the northeast portion of the site that is accessed from a
driveway along Irvine Avenue and contains 280 parking spaces in 4 rows of parking, and limited
landscaping with scattered trees. Pole-mounted lighting is located in the parking lot. Entrances to both the
clubhouse and the driving range buildings are adjacent to the parking lot.
Surrounding Area
The existing visual character of the area surrounding the Project site is a mix of uses with no consistent
architectural or visual theme. The visual character is dominated by the open green space with scattered trees
associated with NB Golf Course holes 3-8 to the south across Mesa Drive and holes 10-18 to the north and
northeast across Irvine Avenue. Areas to the east of the site are developed with a fire station, two- and
three-story-high commercial office buildings, associated surface parking lots and ornamental landscaping
that provide a modern commercial character. Areas to the west of the site are developed with a two-story
retail shopping center, two-story residential apartments, and commercial office buildings that are two-stories
over ground level parking with ornamental landscaping that also provide a modern and urban character.
Both Irvine Avenue and Mesa Drive are arterial roadways that are adjacent to the site and provide a
pedestrian character with landscaping, sidewalks, and bicycle lanes. The general area surrounding the site
has a topography of rolling hills, whereby Irvine Avenue slopes to the southwest, and the land on the west
side of Irvine Avenue is higher than the land on the east side. Likewise, Mesa Drive slopes to the west and
existing retaining walls are located along portions of the perimeter of the site. The development surrounding
the Project site is shown below in Figure 5.1-1, Development in the Project Site Viewshed.
5.1.3.4 Light and Glare
Light and glare in the Project vicinity is typical of what can be found in urban environments. Sources of light
near and on the site are generated from building interiors and exterior sources (i.e., golf course, driving
range, putting area, building illumination, security lighting, parking lot lighting, vehicle lights, street lighting,
and landscape lighting) associated with the existing site and adjacent land uses. The driving range and three
golf course holes feature pole-mounted lights to allow for golf activity to continue after the last light. The
driving range and golf course lighting is limited to between the hours of 7:00 a.m. and 10:00 p.m. The hours
of operation for the pro shop are generally 10:00 a.m. to 7:00 p.m.; and the restaurant generally operates
from 8:00 a.m. to 10:00 p.m. Thus, after 10:00 p.m., limited lighting related to security lighting and signage
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-8
Draft EIR
May 2025
is generated on the site. Other existing offsite sources of light and glare include vehicle headlights and
streetlights.
Glare can emanate from many different sources, some of which include direct sunlight, sunlight reflecting
from cars or buildings, and bright outdoor or indoor lighting. Glare in the Project vicinity is generated by
building and vehicle windows reflecting light. However, there are no substantial buildings or structures near
the Project site that presently generate substantial glare since most of the buildings are limited to one-story
to two-story structures that are constructed of non-reflective materials and are not surfaced with a substantial
number of windows adjacent to one another that would create a large reflective area.
5.1.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of the CEQA Guidelines indicates that a Project could have a significant effect if it were to:
AES-1 Have a substantial adverse effect on a scenic vista.
AES-2 Substantially damage scenic resources, including but not limited to trees, rock outcroppings, and
historic buildings within a State scenic highway.
AES-3 In nonurbanized areas, substantially degrade the existing visual character or quality of public
views of the site and its surroundings (public views are those that are experienced from a publicly
accessible vantage point), or if the project is in an urbanized area, conflict with applicable zoning
and other regulations governing scenic quality.
AES-4 Create a new source of substantial light or glare which would adversely affect day or nighttime
views in the area.
5.1.5 METHODOLOGY
Aesthetic resources were assessed based on the visual quality of the Project site and surrounding areas and
the changes that would occur from Project implementation. The significance determination for scenic vistas is
based on whether the vista can be viewed from public areas within or near the Project site and the potential
for the Project to either hinder views of the scenic vista or result in its visual degradation. As the Project site
is located within an urban area, the evaluation of aesthetic character identifies if the Project would conflict
with applicable zoning and other regulations governing scenic quality. Also, effects related to lighting and
glare are determined by analysis of the Project’s use of lighting and glare related materials and compliance
with related municipal code requirements.
5.1.6 ENVIRONMENTAL IMPACTS
IMPACT AES-1: THE PROJECT WOULD NOT HAVE A SUBSTANTIAL EFFECT ADVERSE EFFECT ON A
SCENIC VISTA.
Less than Significant Impact. Scenic vistas can be defined as views or vistas generally panoramic in nature
and identified as viewpoints or vistas (e.g., formal turnouts along roadways) or as identified in planning
documents. A substantial adverse effect on a scenic vista or view would occur where the majority of an
existing public view would be blocked or substantially interrupted. Although there are no officially
designated scenic vistas in the City, the General Plan has identified the Pacific Ocean, the San Joaquin
Corridor, Crystal Cove State Park, and Upper Newport Bay as locally significant scenic vistas.
Snug Harbor Surf Park Project
City of Newport Beach
PROJECT DATA
NET SITE AREA:
TRUCK TRAILER STALLS
APE AREA
APE COVERAGE
811,760 SF
18.635 AC
7440-016-001
7440-016-002
7440-016-003
7412-024-007
PER CIVIL PLAN
316,373 SF
38.97 %
POSED PROJECT SHALL COMPLY WITH THE PROVISIONS OF THE CITY OF LOS
EVELOPMENT GUIDELINES.
JECT DOES NOT PROPOSE ANY TENANT SIGNAGE AT THIS TIME.
RE NO PROTECTED TREES OR PLANTS ON SITE.
AL NOTES
ITY MAP
.S.
SITE
Figure .1-1
East-facing view from Irvine Avenue, across from the Project site.
View from Irvine Avenue, facing southeast towards the Project site.
View from Irvine Avenue at Mesa Drive, facing northwest away from the Project site.
Development in the Project Site Viewshed
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-10
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-11
Draft EIR
May 2025
A majority of the Project site is currently developed with a golf course, driving range, and other associated
uses. The Project site is within an area developed with commercial, residential, and golf course uses. The
Project site is not within a scenic vista. The Project site is surrounded by urban development and there are no
long-range scenic vistas from the Project site. Although areas of open space are located to the north and
south of the Project site (associated with NB Golf Course holes 3-8 and 10-18), those golf course areas are
bound by the Santa Ana-Delhi Channel, residences, and roadways that do not provide scenic views.
The Newport Beach General Plan specifies that scenic vistas within the City consist of public coastal views
from the roadway segments identified in the City’s Local Coastal Program (City of Newport Beach, 2006a).
None of the listed roadway segments are adjacent to the Project site. The closest view location is along Irvine
Avenue south of University Drive, which contains views of the Upper Newport Bay Preserve and is
approximately 0.3 miles southwest of the Project site. In addition, Bayview Park that is adjacent to Upper
Newport Bay Preserve is also listed as a public viewpoint. The Project site is to the northwest and behind the
Upper Newport Bay Preserve and Bayview Park that is to the southeast; thus, the Project site is not within
the coastal scenic viewshed from either of these viewpoints. As shown on Figures 5.1-3 through 5.1-8, none
of the adjacent roadways provide views of the Upper Newport Bay or the Pacific Ocean.
The proposed Project would result in the development of a 5.06-acre surf lagoon, a three-story amenity
clubhouse with a maximum height of 50 feet, and a two-story athlete accommodation building with a
maximum height of 40 feet. All development within the proposed Project site would be set back from
adjacent streets and would not encroach on the existing public views along the roadway corridors adjacent
to the site. The proposed buildings would have a minimum setback 20 feet from Mesa Drive, and 20 feet
from Irvine Avenue. Views looking towards the western Project boundary would feature retaining wall with
heights up to 16-feet, topped with 6-foot-high wrought iron vertical fencing, landscaping, and views of the
curved three-story amenity building, and the surf lagoon pole-mounted lighting. In addition, the eastern
border of the Project site would be set back 20 feet from the adjacent property and would feature 16-
foot-high terraced retaining wall with landscaping. The building setbacks would ensure that public views
along the nearby roadways (although not scenic vistas) would not be impacted. Overall, none of the
roadways adjacent to the Project provide long range views of scenic vistas such as the Upper Newport Bay
Preserve or Pacific Ocean; and the Project site is behind the General Plan-identified coastal viewpoints.
Therefore, the Project would not block or substantially interrupt any public scenic vistas. As such, potential
impacts would be less than significant.
IMPACT AES-2: THE PROJECT WOULD NOT SUBSTANTIALLY DAMAGE SCENIC RESOURCES,
INCLUDING BUT NOT LIMITED TO TREES, ROCK OUTCROPPINGS, AND HISTORIC
BUILDINGS WITHIN A STATE SCENIC HIGHWAY.
No Impact. As detailed previously, there are no State designated scenic highways within the City of Newport
Beach (Caltrans, 2024). According to the Scenic Highway System List, State Route 1, otherwise known as
Pacific Coast Highway, is eligible for the State Scenic Highway System but is not designated as a State
scenic highway. State Route 1 is located 3.4 miles southwest of the Project site and is not visible from the
Project site. Therefore, the Project would not result in impacts related to scenic resources within a State Scenic
Highway.
IMPACT AES-3: THE PROJECT WOULD NOT, IN NONURBANIZED AREAS, SUBSTANTIALLY
DEGRADE THE EXISTING VISUAL CHARACTER OR QUALITY OF PUBLIC VIEWS OF
THE SITE AND ITS SURROUNDINGS (PUBLIC VIEWS ARE THOSE THAT ARE
EXPERIENCED FROM A PUBLICLY ACCESSIBLE VANTAGE POINT), OR IF THE
PROJECT IS IN AN URBANIZED AREA, CONFLICT WITH APPLICABLE ZONING AND
OTHER REGULATIONS GOVERNING SCENIC QUALITY.
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-12
Draft EIR
May 2025
Less than Significant Impact. The proposed Project would change the public views of the Project site from
a golf course with a driving range and a clubhouse building and would construct a surf park with a 5.06-
acre (20,427 SF) surf lagoon, amenity clubhouse, athlete accommodations, parking lot, ornamental
landscaping, and associated infrastructure. The proposed structures would be set back a minimum of 20 feet
from adjacent streets (as shown in Figure 3-8, Conceptual Site Plan) and would not encroach into public views
along the roadway corridors adjacent to the site. In order to analyze the change to visual character and
public views of the Project site, visual simulations were prepared to demonstrate where the structures,
retaining walls, and changes to grade would be located, and the change to views of the site from six offsite
locations, shown in Figure 5.1-2, View Simulation Locations.
Project View A
Project View A is located at the southwest corner of the Irvine Avenue and Mesa Drive intersection looking
toward the Project site. As shown in Figure 5.1-3, Project View A, the existing view is dominated by mature
trees, overhead powerlines, in front of the golf course green space and the driving range poles and netting.
The view has an urban character. Views include the sidewalk along Irvine Avenue and Mesa Drive, chain link
fencing around the site, and the concrete lining of the Santa Ana-Delhi Channel between the golf course and
Irvine Avenue.
With implementation of the proposed Project, this view would change to provide a more urban and
developed character compared to the existing condition. Up to 16-foot-high retaining walls would be
located along the western Project boundary behind the existing chain link street fencing along both Irvine
Avenue and continues southeast towards the southern driveway on Mesa Drive. The retaining walls would be
topped with 6-foot-high wrought iron vertical fencing and landscaping. Views of the golf course green space
would be replaced with views of dense landscaping with varying heights and plant variety that would screen
the proposed parking lot with solar PV canopies, views of the proposed three-story amenity clubhouse
building, and longer distance views of the two-story athlete accommodation building. Although, the proposed
amenity clubhouse building would have a maximum height of 50 feet, which is the same height or lower than
the existing driving range poles and netting, the proposed building are solid structures; and therefore, would
have a larger visual mass than the existing views of the poles and nets. However, the proposed three-story
amenity clubhouse building would be consistent with the two-to three-story-high commercial office buildings
that are located to the north of this viewpoint on Irvine Avenue to the northwest of the site.
Overall, with implementation of the Project the character of views from this location would remain urban in
nature, but would change to a greater level of development and higher visual density.
Project View B
Project View B is located along Mesa Drive looking to the northeast toward the Project site. As shown in
Figure 5.1-4, Project View B, the existing view contains the open green space of the golf course with mature
trees and the driving range poles and netting that are between 62 and 65 feet tall along Mesa Drive. The
view shows the topography sloping up to the east, and the existing retaining wall along Mesa Drive. The
existing view has an urban character due to the retaining walls, chain link fencing surrounding the site,
streetlighting, and sidewalk along Mesa Drive, which is a five-lane arterial roadway.
With implementation of the proposed Project, this view would change to provide a more urban, developed,
and dense character compared to the existing condition. Views of the golf course green space would be
replaced with views of a site developed with buildings and associated parking. The existing retaining wall,
chain link fence, driving range poles and netting would be removed. The site would be graded to flatten the
topographical changes on the site from Project View B. Forefront views of the proposed site would include
layered landscaping consisting of groundcovers, shrubs, and trees that would be in front of wrought iron
vertical fencing, which would screen views of the parking lot and solar PV canopies. Views of the proposed
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-13
Draft EIR
May 2025
three-story amenity clubhouse building and two-story athlete accommodation building would be behind the
landscape screening and parking area with the upper floors viewable above treetops. Although the site
would be graded to be lower in elevation from this viewpoint and the proposed amenity clubhouse building
would have a maximum height of 50 feet, which is lower than the existing 62- to 65-foot-high driving range
poles and netting, the proposed building would have a greater visual mass than the existing view. The
proposed athlete accommodation building is within mid-range views; although it would result in a change
from open space surrounded by poles and nets to a developed two-story structure surrounded by
landscaping, it would provide the same type of modern visual character as surrounding residential,
commercial, and office development.
Overall, with implementation of the Project the character of views from this location would remain urban in
nature, but would change to a greater level of development and higher visual density that would be similar
to surrounding development.
Project View C
Project View C is located along Mesa Drive looking west toward the Project site from Mesa-Birch Park. As
shown in Figure 5.1-5, Project View C, the Project site is located behind Fire Station 7 (the red and stone
veneer building with both pitched and roof areas) that is in middle ground views from this viewpoint. Other
areas of the Project site that are not behind Fire Station 7 are screened from view by existing mature
ornamental landscaping. Views of the Project site from this view are limited to the poles and netting that
surround the driving range. The poles and netting behind the Fire Station 7 building are approximately 80
feet tall and the poles and netting separating the driving range from Mesa Drive seen within this view are
between 62 and 65 feet tall.
Implementation of the proposed Project would reduce views of urban development from this viewpoint. As
shown in Figure 5.1-5, Project View C, the existing views of 62- to 80-foot-high poles and netting would no
longer exist with implementation of the Project. The visual height of development within the view would be
reduced to the height of the Fire Station building, and the only portion of the proposed structures that would
be visible would be the top of two light poles that would be located by the surf lagoon. These Project light
poles would blend in and be visually indiscernible from the other light poles along Mesa Drive, Acacia Street,
and within the parking lot of the commercial office building within this view.
As a result, the Project would reduce the urban form and structures within this view and Project structures
would largely remain unseen. The urban and developed character of the view from Mesa-Birch Park would
remain with implementation of the Project.
Project View D
Project View D is located along Irvine Avenue at the eastern boundary of the site looking to the southwest
across the existing parking lot and toward the driving range and onsite restaurant/pro shop building. As
shown in Figure 5.1-6, Project View D, the existing forefront views consist of mature ornamental landscaping
and a parking lot of vehicles. The one-story restaurant/pro shop building is in middle-ground views behind
the parking lot. The driving range and driving range building are screened by existing trees on the site. The
50- to 65-foot-tall poles and netting on the south and west sides of the driving range are visible and screen
views of holes 1, 2, and 9, which are visible behind the restaurant/pro shop building from this view. The
topography of the site in this view slopes to the southwest. The existing view has a recreational open space
character with frontage parking adjacent to the arterial roadway.
Implementation of the Project would change this view to provide a higher density modern visual character
compared to the existing condition. New forefront views would consist of layered landscaping of
groundcovers, shrubs, and trees in front of wrought iron vertical fencing, which would screen views of the
parking lot and solar PV canopies. Views of the proposed three-story amenity clubhouse building and two-
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-14
Draft EIR
May 2025
story athlete accommodation building would be within middle ground views. The second and third floors of
the amenity clubhouse and the second floor of the athlete accommodations building are behind the landscape
screening. In addition, the 71-foot-high light poles that would be located adjacent to, and focused on, the
surf lagoon would be visible from this viewpoint. The proposed Project would result in higher density and
modern visual character of this viewshed.
Project View E
Project View E is located along Irvine Avenue looking to the southeast toward the Project site. As shown in
Figure 5.1-7, Project View E, the existing view provides an open space urban character. Behind the Santa
Ana-Delhi Channel wall and fencing along Irvine Avenue, the view consists largely of open green golf course
space with rolling topography, mature landscaping, golf cart paths, the poles and netting for the driving
range, and the side of the restaurant/pro shop building. The driving range lighting and the three-story fire
training tower (southeast of the site) can be seen above the building and past the poles and netting in the
existing view.
With implementation of the Project this view would change to one of a developed site with a higher density
modern visual character. Views beyond the Santa Ana-Delhi Channel wall would be of a retaining wall with
heights up to 16-feet topped with 6-foot-high wrought iron vertical fencing, landscaping, and views of the
curved three-story amenity building, and the surf lagoon pole-mounted lighting. The two-story athlete
accommodation building is in the background of the view, beyond the landscaping and light poles. The
proposed Project would result in a developed higher density and modern visual character of this viewshed.
Project View F
Project View F is located along Mesa Drive looking to the northeast toward the Project site. This view is
similar to Project View B and as shown in Figure 5.1-8, Project View F, the existing view contains a hill of golf
course green space with mature trees and the driving range poles and netting that are between 62 and 65
feet tall along Mesa Drive. The three-story Fire Station training tower is located in background views. The
view shows the topography sloping up to the east, and the existing retaining wall along Mesa Drive. The
existing view has an urban open space character due to the chain link fencing surrounding the open space
area, and the retaining walls, streetlighting, and sidewalk along Mesa Drive.
With implementation of the proposed Project, this view would change from generally a fenced and netted
open space area to one of a developed site with cohesive landscaping in front of buildings. The proposed
two- and three-story buildings would be consistent with the two- to three-story high commercial office
buildings that are located on Mesa Drive, Acacia, and Irvine Avenue to the northwest of the site; and the
three-story fire training tower that is adjacent to the site.
The golf course green space hill, retaining wall, chain link fence, driving range poles and netting would be
removed. The site would be graded flat and provide a slight slope to the west. Forefront views of the Project
would include the proposed site driveway next to layered landscaping consisting of groundcovers, shrubs,
and trees that would be in front of wrought iron vertical fencing, which would screen views of the parking
lot and proposed building structures. The Project would grade the site to eliminate the existing hill and lower
the ground elevation of the site from this viewpoint and the proposed amenity clubhouse building would
have a maximum height of 50 feet, which is lower than the existing driving range poles and netting, but the
proposed buildings would have a greater visual mass and the development density of the site would be
greater than that of the existing view. The proposed development provides the same type of modern visual
character as surrounding residential, commercial, and office development that surrounds the site.
Overall, with implementation of the Project the character of views from this viewpoint would change from
that of a largely fenced open space view to a view of a developed site with higher visual density, that
would be similar to surrounding commercial and office development.
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-15
Draft EIR
May 2025
Regulations Governing Scenic Quality
The Project site is located in an “urbanized area”. As defined by Public Resources Code Section 21071(a)
an “urbanized area” is an area within an incorporated city that meets one of the following criteria:
1. Has a population of at least 100,000 persons.
2. Has a population of less than 100,000 persons if the population of that city and not more than two
contiguous incorporated cities combined equals at least 100,000 persons.
The Project site is located within the City of Newport Beach, an incorporated city in Orange County.
According to the United States Census Bureau, the City of Newport Beach was estimated to have a population
of 82,637 in 2023. In addition, the City of Costa Mesa, which is contiguous to Newport Beach, had a
population of 108,354 in 2023 (Census Bureau, 2023). Therefore, based on these criteria, the Project is
located within an urbanized area, and a potential for impact could occur if the Project conflicts with
applicable zoning or other regulations governing scenic quality.
General Plan
The site has a City of Newport Beach General Plan land use designation of Parks and Recreation (PR). The
General Plan states that the PR land use permits parks (both active and passive), golf courses, marina support
facilities, aquatic facilities, tennis clubs and courts, private recreation, and similar facilities. Development on
the site is currently limited by General Plan Anomaly No. 58 to 20,000 SF. Accessory uses and structures are
permitted when customarily associated with and subordinate to a principal permitted use on the same
building site.
The Project includes a General Plan Amendment to increase the development intensity for the site from the
current development limit of 20,000 SF to approximately 59,773 SF (not including 18,137 SF of permitted
accessory structures). With approval of the General Plan Amendment, the Project would be consistent with
the allowable development intensity of the site.
As listed previously in Section 5.1.2.3, Local and Regional Regulations, the General Plan includes various
policies in the Land Use Element and the Natural Resources Element that are related to scenic quality. The
proposed Project alignment with these policies is evaluated in Table 5.10-4, General Plan Policy Consistency
Analysis, in Section 5.10, Land Use and Planning, (along with other General Plan policies related to avoiding
or mitigating environmental impacts) which determined that the Project would be consistent with the policies
of the General Plan that governs scenic quality.
Specific Plan/Zoning
The Project site has a Santa Ana Heights Specific Plan designation of Open Space and Recreation (OSR).
The Santa Ana Heights Specific Plan includes design guidelines that are largely related to residential and
business park developments to promote a consistent, high-quality character of development and result in the
overall enhancement of the aesthetic character of the community. The Santa Ana Heights Specific Plan is
included in the City’s Municipal Code as Chapter 20.90. Table 5.1-1 provides a comparison of the Project
consistency with the applicable Santa Ana Heights Specific Plan development standards. As detailed, the
Project would be consistent with the building site area, building setbacks, and the proposed building heights
would be consistent with a Conditional Use Permit.
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-16
Draft EIR
May 2025
Table 5.1-1: Santa Ana Heights Specific Plan Development Standard Consistency
Specific Plan Development Standard Project Consistency
Minimum Building Site Area 1 acre 15.38 acres
Maximum Building Height 18 feet unless otherwise provided
for by an approved use permit 50 feet1
Minimum Building Setback 20 feet from all property lines Building setbacks are greater than 20
feet along all property lines as shown in
Figure 3-8, Conceptual Site Plan.
1 Subject to a Conditional Use Permit.
Source: City of Newport Beach Municipal Code, Chapter 20.90.050
In addition, Municipal Code Section 20.90.030 provides design guidelines for hardscape elements, such as
fences, paving, light fixtures, bollards, benches, trash receptacles and planters. This includes requirements
for building materials, pavements, lighting fixtures, colors, and landscape maintenance (as detailed
previously in Section 5.1.2.3, Local and Regional Regulations). These have been incorporated into the
proposed Project and would be verified by the City during the development review and permitting process.
Therefore, impacts related to conflict with municipal code required design guidelines would not occur.
Overall, the Project would change the visual character of the site; however, it would not conflict with
applicable zoning and other regulations governing scenic quality and impacts would be less than significant.
Figure 5.1-26QXJ+DUERUSuUI 3aUN 3URMHFW
&LW\RI1HZSRUW%HDFK
9LHZ6LPXODWLRQ/RFDWLRQV
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-18
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project
City of Newport Beach
0' 20' 100'50'200'
SCALE: 1" = 100'-0"
PR
O
J
E
C
T
NO
R
T
H
PROJECT DATA
NET SITE AREA:
APN NUMBERS
TRUCK TRAILER STALLS
LANDSCAPE AREA
LANDSCAPE COVERAGE
811,760 SF
18.635 AC
7440-016-001
7440-016-002
7440-016-003
7412-024-007
PER CIVIL PLAN
316,373 SF
38.97 %
1. THE PROPOSED PROJECT SHALL COMPLY WITH THE PROVISIONS OF THE CITY OF LOS
ANGELES DEVELOPMENT GUIDELINES.
2. THE PROJECT DOES NOT PROPOSE ANY TENANT SIGNAGE AT THIS TIME.
3. THERE ARE NO PROTECTED TREES OR PLANTS ON SITE.
GENERAL NOTES
VICINITY MAP
SCALE =N.T.S.
SITE PLAN
Figure .1-3
Project View A
Existing
Proposed
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-20
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project
City of Newport Beach
0' 20' 100'50'200'
SCALE: 1" = 100'-0"
PR
O
J
E
C
T
NO
R
T
H
PROJECT DATA
NET SITE AREA:
APN NUMBERS
TRUCK TRAILER STALLS
LANDSCAPE AREA
LANDSCAPE COVERAGE
811,760 SF
18.635 AC
7440-016-001
7440-016-002
7440-016-003
7412-024-007
PER CIVIL PLAN
316,373 SF
38.97 %
1. THE PROPOSED PROJECT SHALL COMPLY WITH THE PROVISIONS OF THE CITY OF LOS
ANGELES DEVELOPMENT GUIDELINES.
2. THE PROJECT DOES NOT PROPOSE ANY TENANT SIGNAGE AT THIS TIME.
3. THERE ARE NO PROTECTED TREES OR PLANTS ON SITE.
GENERAL NOTES
VICINITY MAP
SCALE =N.T.S.
SITE PLAN
Figure .1-4
Project View B
Existing
Proposed
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-22
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project
City of Newport Beach
0' 20' 100'50'200'
SCALE: 1" = 100'-0"
PR
O
J
E
C
T
NO
R
T
H
PROJECT DATA
NET SITE AREA:
APN NUMBERS
TRUCK TRAILER STALLS
LANDSCAPE AREA
LANDSCAPE COVERAGE
811,760 SF
18.635 AC
7440-016-001
7440-016-002
7440-016-003
7412-024-007
PER CIVIL PLAN
316,373 SF
38.97 %
1. THE PROPOSED PROJECT SHALL COMPLY WITH THE PROVISIONS OF THE CITY OF LOS
ANGELES DEVELOPMENT GUIDELINES.
2. THE PROJECT DOES NOT PROPOSE ANY TENANT SIGNAGE AT THIS TIME.
3. THERE ARE NO PROTECTED TREES OR PLANTS ON SITE.
GENERAL NOTES
VICINITY MAP
SCALE =N.T.S.
SITE PLAN
Figure .1-5
Project View C
Existing
Proposed
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-24
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project
City of Newport Beach
0' 20' 100'50'200'
SCALE: 1" = 100'-0"
PR
O
J
E
C
T
NO
R
T
H
PROJECT DATA
NET SITE AREA:
APN NUMBERS
TRUCK TRAILER STALLS
LANDSCAPE AREA
LANDSCAPE COVERAGE
811,760 SF
18.635 AC
7440-016-001
7440-016-002
7440-016-003
7412-024-007
PER CIVIL PLAN
316,373 SF
38.97 %
1. THE PROPOSED PROJECT SHALL COMPLY WITH THE PROVISIONS OF THE CITY OF LOS
ANGELES DEVELOPMENT GUIDELINES.
2. THE PROJECT DOES NOT PROPOSE ANY TENANT SIGNAGE AT THIS TIME.
3. THERE ARE NO PROTECTED TREES OR PLANTS ON SITE.
GENERAL NOTES
VICINITY MAP
SCALE =N.T.S.
SITE PLAN
Figure .1-6
Project View D
Existing
Proposed
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-26
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project
City of Newport Beach
0' 20' 100'50'200'
SCALE: 1" = 100'-0"
PR
O
J
E
C
T
NO
R
T
H
PROJECT DATA
NET SITE AREA:
APN NUMBERS
TRUCK TRAILER STALLS
LANDSCAPE AREA
LANDSCAPE COVERAGE
811,760 SF
18.635 AC
7440-016-001
7440-016-002
7440-016-003
7412-024-007
PER CIVIL PLAN
316,373 SF
38.97 %
1. THE PROPOSED PROJECT SHALL COMPLY WITH THE PROVISIONS OF THE CITY OF LOS
ANGELES DEVELOPMENT GUIDELINES.
2. THE PROJECT DOES NOT PROPOSE ANY TENANT SIGNAGE AT THIS TIME.
3. THERE ARE NO PROTECTED TREES OR PLANTS ON SITE.
GENERAL NOTES
VICINITY MAP
SCALE =N.T.S.
SITE PLAN
Figure .1-7
Project View E
Existing
Proposed
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-28
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project
City of Newport Beach
0' 20' 100'50'200'
SCALE: 1" = 100'-0"
PR
O
J
E
C
T
NO
R
T
H
PROJECT DATA
NET SITE AREA:
APN NUMBERS
TRUCK TRAILER STALLS
LANDSCAPE AREA
LANDSCAPE COVERAGE
811,760 SF
18.635 AC
7440-016-001
7440-016-002
7440-016-003
7412-024-007
PER CIVIL PLAN
316,373 SF
38.97 %
1. THE PROPOSED PROJECT SHALL COMPLY WITH THE PROVISIONS OF THE CITY OF LOS
ANGELES DEVELOPMENT GUIDELINES.
2. THE PROJECT DOES NOT PROPOSE ANY TENANT SIGNAGE AT THIS TIME.
3. THERE ARE NO PROTECTED TREES OR PLANTS ON SITE.
GENERAL NOTES
VICINITY MAP
SCALE =N.T.S.
SITE PLAN
Figure .1-8
Project View F
Existing
Proposed
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-30
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-31
Draft EIR
May 2025
IMPACT AES-4: THE PROJECT WOULD NOT CREATE A NEW SOURCE OF SUBSTANTIAL LIGHT OR
GLARE WHICH WOULD ADVERSELY AFFECT DAY OR NIGHTTIME VIEWS IN THE
AREA.
Less than Significant Impact.
Light
Existing sources of light on the Project site include illumination from vehicle headlights in the parking lot, pole-
mounted parking lot lighting, building illumination through windows, exterior building lighting, security
lighting, signage lighting, and pole-mounted nighttime lighting for the golf course and driving range until
10:00 p.m. In addition, the Project site is located within an urban area that includes streetlighting, vehicle
headlights on adjacent roadways, interior lighting from nearby uses passing through windows, and exterior
security and signage lighting.
Development of the Project would introduce new sources of light from the new parking lot lighting, security
lighting, and outdoor lighting of the surf lagoon during operational hours. The proposed hours of operation
for the surf lagoon are 6:00 a.m. to 11:00 p.m., seven days a week. Similar to the existing condition and
continued lighting for operation of holes 3-8 to the south across Mesa Drive and holes 10-18 to the north
and northeast across Irvine Avenue, pole-mounted lighting would be installed around the recreational
amenity for nighttime use. The proposed building structures and landscaping would shield surf lagoon lighting
from spilling offsite. As required by Municipal Code Section 21.30.070, Outdoor Lighting, the outdoor
lighting fixtures for the Project have been designed, shielded, aimed, and located to shield adjacent
properties. Photometric plans have been submitted to the City detailing that the surf lagoon lighting would
not result in offsite spill light or the potential for glare.
The proposed clubhouse and athlete accommodations would generate limited lighting from security lighting,
entrance lighting, signage, and lighting from the interiors passing through windows. This is consistent with the
existing sources of lighting on and surrounding the Project site. Although an increase in lighting would occur
from the Project, as it would result in two-story structures (versus the existing one-story structures) that provide
a new source of lighting from a higher elevation, the lighting would be required to comply with Municipal
Code Section 21.30.070, Outdoor Lighting, through the City’s permitting process. Thus, the Project would not
result in a substantial increase of lighting levels in the surrounding area, and impacts related to lighting
would be less than significant.
Glare
Glare can be caused by the reflection of the sun off of reflective surfaces during the day (i.e., daytime
glare); or the reflection of artificial light sources (i.e., automobile headlights, direct building lighting) off of
reflective surfaces at night (i.e., nighttime glare). The generation of substantial amounts of glare is dependent
on structures consisting of reflective materials and light sources in highly visible areas without screening such
as vegetation.
As shown in Figures 3-9 and 3-10, in Section 3.0, Project Description, the building exteriors for both the
Amenity Clubhouse Building and the Athlete Accommodations would consist of a modern architectural design
with wood paneling and metal railing, and concrete would be used as accent materials. Additionally,
windows would be finished as blue clear glass. The exteriors of the proposed buildings would not include
large areas of reflective surfaces that could result in glare to surrounding areas. In addition, the Project
proposes landscaping both along the site perimeter and around the proposed buildings, which would further
reduce the potential for glare. Likewise, the proposed surf lagoon and surrounding lagoon deck surfaces
would not be constructed with reflective materials. During operating hours, the two lagoon basins would have
moving water from the wave equipment, which would hinder the ability of the lagoon to generate glare.
During non-operational hours, it would be nighttime and the lights surrounding the lagoon would be turned
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-32
Draft EIR
May 2025
off, and no glare would occur. Furthermore, the proposed lagoon is surrounded by the clubhouse building,
athlete accommodation building, wave machinery, and landscaping that would screen potential glare from
the lagoon waterbody. As described previously, the Project would be required through the City’s permitting
process to comply with Municipal Code Section 21.30.070, Outdoor Lighting, which would prevent lighting
from the Project to generate glare. Thus, impacts related to glare from the Project site onto adjacent uses
would be less than significant.
The proposed Project includes PV solar panels installed on parking canopies and the buildings’ roofs, as
shown in Figure 3-11, Proposed Solar PV Installation. Therefore, as further detailed in Section 5.8, Hazards
and Hazardous Materials, a solar glare analysis (included as Appendix N) was prepared to analyze the
potential for the solar panels to generate glare that could impact John Wayne Airport operations. The glare
modeling analysis found that the proposed Project would not produce any glare on the air traffic control
tower or in any of the final approach areas to the runways at John Wayne Airport (Appendix N). Thus, the
Project would not create a new source of substantial glare which would adversely affect day or nighttime
views in the area, and impacts would be less than significant.
5.1.7 CUMULATIVE IMPACTS
The cumulative aesthetics study area for the proposed Project includes public viewshed areas that can view
the Project site as well as locations that can be viewed from the Project site, which may include areas under
a different jurisdiction such as the City of Costa Mesa.
The only cumulative project within the viewshed of the proposed Project would be located across Orchard
Drive at the easterly corner of Orchard Drive and Southwest Acacia Street, approximately 527 feet from
the Project site. The cumulative project across Orchard Drive from the site is a renovation of the existing
office building and addition of a parking garage and would not include extensive redevelopment of the
area. Other future developments that may be proposed in the viewshed, including those on the Housing
Opportunity sites to the south of the Project site across Mesa Drive, would be required to comply with the
applicable City of Newport Beach General Plan policies and municipal code regulations to preserve scenic
vistas and important scenic resources such as views of the Pacific Ocean and the Upper Newport Bay
Preserve.
As detailed under Impact AES-1, the Project site is to the northeast and behind the Upper Newport Bay
Preserve and is not within the coastal scenic viewshed. Therefore, it would not have the potential to combine
with other projects to result in a cumulative impact to a scenic vista. Impacts to scenic vistas would be less
than cumulatively considerable.
As discussed under Impact AES-2, the Project site is not within proximity to any designated State scenic
highways, and is not within the viewshed of an eligible State scenic highway. In addition, cumulative Projects
within the cumulative study area for aesthetics would also not be within proximity to any designated State
scenic highways. Therefore, the Project has no potential to contribute to a cumulatively significant impact to
scenic resources within a State scenic highway.
The Project would not conflict with applicable regulations governing scenic quality, as detailed previously.
New development in the cumulative viewshed would be subject to applicable development regulations and
design standards imposed during the development review and permitting process, which would ensure that
development implements applicable regulations related to scenic quality. Therefore, cumulative impacts
related to regulations related to scenic quality would be less than significant.
With respect to potential cumulative light and glare impacts, the Project would be required to comply with
City of Newport Beach General Plan Policy LU 5.6.3 and the City of Newport Beach Municipal Code Section
20.30.070, which sets standards for exterior lighting/fixtures. Photometric plans have been submitted to the
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-33
Draft EIR
May 2025
City detailing that the Project lighting would not result in offsite spill light that could be cumulatively
considerable. Any development project in the cumulative visual area would be required to comply with the
light requirements. Although cumulative development in the Project’s surrounding area is likely to introduce
new sources of lighting and potentially reflective materials, the Project’s impacts would be less than
cumulatively considerable, and therefore, less than significant.
5.1.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES
The following would reduce potential impacts related to aesthetics.
Existing Regulations
• California Government Code Sections 65913.4 and 66300(a)(7)
• Municipal Code Chapter 20.30, Property Development Standards
• Municipal Code Chapter 20.90.030, Design Guidelines
• Municipal Code Section 20.90.050, Open Space and Recreation Districts
• Municipal Code Section 21.30.070, Outdoor Lighting
Plans, Programs, or Policies
None.
5.1.9 PROJECT DESIGN FEATURES
None.
5.1.10 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
The Project would result in no impact related to Impact AES-2 and less-than-significant impacts related to
Impact AES-1, Impact AES-3, and Impact AES-4.
5.1.11 MITIGATION MEASURES
No mitigation measures are required.
5.1.12 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts would be less than significant.
5.1.13 REFERENCES
Caltrans. (2024). California State Scenic Highway System Map. Retrieved March, 2025, from
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e805
7116f1aacaa
Census Bureau. (2023). Quick Facts. Retrieved March, 2025, from https://www.census.gov/quickfacts
City of Newport Beach. (2001). Santa Ana Heights Specific Plan. Retrieved September 23, 2024, from
ocpublicworks.com
Snug Harbor Surf Park Project 5.1 Aesthetics
City of Newport Beach 5.1-34
Draft EIR
May 2025
City of Newport Beach. (2005). Coastal Land Use Plan. Retrieved October 3, 2024, from
https://www.newportbeachca.gov/government/departments/community-development/planning-
division/general-plan-codes-and-regulations/local-coastal-program/coastal-land-use-plan
City of Newport Beach. (2006a). General Plan. Retrieved September 23, 2024, from
https://www.newportbeachca.gov/government/departments/community-development/planning-
division/general-plan-codes-and-regulations/general-plan
City of Newport Beach. (2006b). General Plan Environmental Impact Report. Retrieved September 23,
2024, https://www.newportbeachca.gov/government/departments/community-
development/planning-division/general-plan-codes-and-regulations/general-plan/general-plan-
environmental-impact-repor
City of Newport Beach. (2024). Newport Beach Municipal Code. Retrieved September 23, 2024, from
https://www.codepublishing.com/CA/NewportBeach/
Johnson Aviation, Inc. (2024). Solar Glare Analysis – Solar Photovoltaic (PV) Installation – Snug Harbor
Project. (Appendix N)
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-1
Draft EIR
May 2025
5.2 Air Quality
5.2.1 INTRODUCTION
This section describes the air quality conditions in the Project region and potential impacts from Project
implementation. The analysis in this section is based, in part, on the following documents and resources.
• City of Newport Beach General Plan, 2006
• City of Newport Beach General Plan Environmental Impact Report (General Plan EIR), 2006
• City of Newport Beach Municipal Code
• Surf Farm Air Quality Impact Analysis, prepared by Urban Crossroads, 2025, included as Appendix B
5.2.2 REGULATORY SETTING
5.2.2.1 Federal Regulation
United States Environmental Protection Agency
Criteria Air Pollutants
At the federal level, the United States Environmental Protection Agency (USEPA) has been charged with
implementing national air quality programs. The USEPA’s air quality mandates are drawn primarily from the
federal Clean Air Act, which was enacted in 1970. The most recent major amendments to the Clean Air Act
were made by Congress in 1990.
The Clean Air Act requires the USEPA to establish National Ambient Air Quality Standards. The USEPA has
established primary and secondary National Ambient Air Quality Standards for the following criteria air
pollutants: ozone, CO, NO2, SO2, PM10, PM2.5, and lead. Table 5.2-1 shows the National Ambient Air
Quality Standards for these pollutants. The Clean Air Act also requires each state to prepare an air quality
control plan, referred to as a State Implementation Plan (SIP). The Clean Air Act Amendments of 1990 added
requirements for states with nonattainment areas to revise their SIPs to incorporate additional control
measures to reduce air pollution. The SIP is modified periodically to reflect the latest emissions inventories,
planning documents, and rules and regulations of the air basins, as reported by their jurisdictional agencies.
The USEPA is responsible for reviewing all SIPs to determine whether they conform to the mandates of the
Clean Air Act and its amendments, and to determine whether implementing the SIPs will achieve air quality
goals. If the USEPA determines a SIP to be inadequate, a federal implementation plan that imposes
additional control measures may be prepared for the nonattainment area.
The USEPA also has regulatory and enforcement jurisdiction over emission sources beyond state waters (outer
continental shelf), and those that are under the exclusive authority of the federal government, such as aircraft,
locomotives, and interstate trucking. The USEPA’s primary role at the state level is to oversee state air quality
programs. The USEPA sets federal vehicle and stationary source emissions standards and provides research
and guidance in air pollution programs.
Hazardous Air Pollutants
The USEPA has programs for identifying and regulating hazardous air pollutants. Title III of the Clean Air
Act Amendments directed the USEPA to promulgate national emissions standards for hazardous air pollutants
(NESHAP). The NESHAP may differ for major sources than for area sources of hazardous air pollutants.
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-2
Draft EIR
May 2025
Major sources are defined as stationary sources with potential to emit more than 10 tons per year of any
hazardous air pollutant or more than 25 tons per year of any combination of hazardous air pollutants; all
other sources are considered area sources. The emissions standards are to be promulgated in two phases. In
the first phase (1992–2000), the USEPA developed technology-based emission standards designed to
produce the maximum emission reduction achievable. These standards are generally referred to as requiring
maximum achievable control technology. For area sources, the standards may be different, based on
generally available control technology. In the second phase (2001–2008), the USEPA promulgated health-
risk-based emissions standards that were deemed necessary to address risks remaining after implementation
of the technology-based NESHAP standards.
Table 5.2-1: Ambient Air Quality Standards for Criteria Pollutants
Pollutant Averaging Time State Standard National
Standard
Pollutant Health and Atmospheric
Effects Major Pollutant Sources
Ozone 1 hour 0.09 ppm --- High concentrations can directly
affect lungs, causing irritation.
Long-term exposure may cause
damage to lung tissue.
Formed when reactive organic gases
and nitrogen oxides react in the
presence of sunlight. Major sources
include on-road motor vehicles,
solvent evaporation, and
commercial/industrial mobile
equipment.
8 hours 0.07 ppm 0.075 ppm
Carbon
Monoxide
(CO)
1 hour 20 ppm 35 ppm Classified as a chemical
asphyxiant, carbon monoxide
interferes with the transfer of
fresh oxygen to the blood and
deprives sensitive tissues of
oxygen.
Internal combustion engines, primarily
gasoline-powered motor vehicles. 8 hours 9.0 ppm 9 ppm
Nitrogen
Dioxide
(NOx)
1 hour 0.18 ppm 0.100 ppm Irritating to eyes and respiratory
tract. Colors atmosphere reddish-
brown.
Motor vehicles, petroleum refining
operations, industrial sources, aircraft,
ships, and railroads. Annual Arithmetic
Mean 0.030 ppm 0.053 ppm
Sulfur
Dioxide (SO2) 1 hour 0.25 ppm 75 ppb Irritates upper respiratory tract;
injurious to lung tissue. Can yellow
the leaves of plants, destructive
to marble, iron, and steel. Limits
visibility and reduces sunlight.
Fuel combustion, chemical plants,
sulfur recovery plants, and metal
processing. 3 hours --- 0.50 ppm
24 hours 0.04 ppm 0.14 ppm
Annual Arithmetic
Mean --- 0.03 ppm
Respirable
Particulate
Matter
(PM10)
24 hours 50 µg/m3 150 µg/m3 May irritate eyes and respiratory
tract, decreases in lung capacity,
cancer and increased mortality.
Produces haze and limits
visibility.
Dust and fume-producing industrial
and agricultural operations,
combustion, atmospheric
photochemical reactions, and natural
activities (e.g., wind-raised dust and
ocean sprays).
Annual Arithmetic
Mean 20 µg/m3 ---
Fine
Particulate
Matter
(PM2.5)
24 hours --- 35 µg/m3 Increases respiratory disease,
lung damage, cancer, and
premature death. Reduces
visibility and results in surface
soiling.
Fuel combustion in motor vehicles,
equipment, and industrial sources;
residential and agricultural burning;
Also, formed from photochemical
reactions of other pollutants, including
nitrogen oxides, sulfur oxides, and
organics.
Annual Arithmetic
Mean 12 µg/m3 12 µg/m3
Lead (Pb) 30 Day Average 1.5 µg/m3 --- Disturbs gastrointestinal system,
and causes anemia, kidney
disease, and neuromuscular and
neurological dysfunction (in
severe cases).
Present source: lead smelters, battery
manufacturing and recycling facilities.
Past source: combustion of leaded
gasoline.
Calendar Quarter --- 1.5 µg/m3
Rolling 3-Month
Average --- 0.15 µg/m3
Hydrogen
Sulfide 1 hour 0.03 ppm … Nuisance odor (rotten egg smell),
headache and breathing
difficulties (higher concentrations)
Geothermal power plants, petroleum
production and refining
Sulfates (SO4) 24 hour 25 µg/m3 … Decrease in ventilatory functions;
aggravation of asthmatic
symptoms; aggravation of
cardio-pulmonary disease;
vegetation damage; degradation
of visibility; property damage.
Industrial processes.
Visibility
Reducing
Particles
8 hour Extinction of
0.23/km;
visibility of 10
miles or more
… Reduces visibility, reduced airport
safety, lower real estate value,
and discourages tourism.
See PM2.5.
ppm = parts per million; ppb = parts per billion; µg/m3 = micrograms per cubic meter.
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-3
Draft EIR
May 2025
The Clean Air Act Amendments also required the USEPA to promulgate vehicle or fuel standards containing
reasonable requirements that control toxic emissions of, at a minimum, benzene and formaldehyde.
Performance criteria were established to limit mobile-source emissions of toxics, including benzene,
formaldehyde, and 1,3-butadiene. In addition, Section 219 required the use of reformulated gasoline in
selected areas with the most severe ozone nonattainment conditions to further reduce mobile-source
emissions.
5.2.2.2 State Regulations
Criteria Air Pollutants
The California Air Resources Board (CARB), a department of the California Environmental Protection Agency,
oversees air quality planning and control throughout California. CARB is responsible for coordination and
oversight of State and local air pollution control programs in California and for implementation of the
California Clean Air Act. The California Clean Air Act, which was adopted in 1988, requires CARB to
establish the California Ambient Air Quality Standards. CARB has established ambient air quality standards
for sulfates, hydrogen sulfide, vinyl chloride, visibility-reducing particulate matter, and the above-mentioned
criteria air pollutants. Applicable California Ambient Air Quality Standards are shown in Table 5.2-1.
The California Clean Air Act requires all local air districts in the state to endeavor to achieve and maintain
the California Ambient Air Quality Standards by the earliest practical date. The act specifies that local air
districts shall focus particular attention on reducing the emissions from transportation and area-wide emission
sources and provides districts with the authority to regulate indirect sources.
Among CARB’s other responsibilities are overseeing compliance by local air districts with California and
federal laws, approving local air quality plans, submitting SIPs to the USEPA, monitoring air quality,
determining and updating area designations and maps, and setting emissions standards for new mobile
sources, consumer products, small utility engines, off-road vehicles, and fuels.
Diesel Regulations
CARB and the Ports of Los Angeles and Long Beach have adopted several iterations of regulations for diesel
trucks that are aimed at reducing diesel particulate matter. More specifically, the CARB Drayage Truck
Regulation, the CARB statewide On-road Truck and Bus Regulation, and the Ports of Los Angeles and Long
Beach “Clean Truck Program” require accelerated implementation of “clean trucks” into the statewide truck
fleet. In other words, older more polluting trucks will be replaced with newer, cleaner trucks as a function of
these regulatory requirements.
Moreover, the average statewide diesel particulate matter emissions for Heavy Duty Trucks, in terms of
grams of diesel particulate matter generated per mile traveled, will dramatically be reduced due to these
regulatory requirements. Diesel emissions identified in this analysis therefore overstate future diesel
particulate matter emissions because not all these regulatory requirements are reflected in the modeling.
Toxic Air Contaminants
Air quality regulations also focus on toxic air contaminants. In general, for those toxic air contaminants that
may cause cancer, there is no concentration that does not present some risk. In other words, there is no safe
level of exposure. This contrasts with the criteria air pollutants, for which acceptable levels of exposure can
be determined and for which the ambient standards have been established. Instead, the USEPA and CARB
regulate hazardous air pollutants and toxic air contaminants, respectively, through statutes and regulations
that generally require the use of the maximum achievable control technology or best available control
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-4
Draft EIR
May 2025
technology for toxics and to limit emissions. These statutes and regulations, in conjunction with additional rules
set forth by the districts, establish the regulatory framework for toxic air contaminants.
Toxic air contaminants in California are regulated primarily through the Tanner Air Toxics Act (Assembly Bill
[AB] 1807 [Chapter 1047, Statutes of 1983]) (Health and Safety Code Section 39650 et seq.) and the Air
Toxics Hot Spots Information and Assessment Act (Hot Spots Act) (AB 2588 [Chapter 1252, Statutes of 1987])
(Health and Safety Code Section 44300 et seq.). AB 1807 sets forth a formal procedure for CARB to
designate substances as toxic air contaminants. This includes research, public participation, and scientific peer
review before CARB can designate a substance as a toxic air contaminant. To date, CARB has identified
more than 21 toxic air contaminants and adopted the USEPA’s list of hazardous air pollutants as toxic air
contaminants. Most recently, diesel particulate matter was added to the CARB list of toxic air contaminants.
Once a toxic air contaminants is identified, CARB then adopts an airborne toxics control measure for sources
that emit that particular toxic air contaminant. If there is a safe threshold for a substance at which there is
no toxic effect, the control measure must reduce exposure below that threshold. If there is no safe threshold,
the measure must incorporate best available control technology to minimize emissions.
The Air Toxics Hot Spots Information and Assessment Act requires existing facilities emitting toxic substances
above a specified level to prepare a toxic-emission inventory, prepare a risk assessment if emissions are
significant, notify the public of significant risk levels, and prepare and implement risk reduction measures.
CARB published the Air Quality and Land Use Handbook: A Community Health Perspective (Handbook),
which provides guidance concerning land use compatibility with toxic air contaminant sources. Although it is
not a law or adopted policy, the Handbook offers advisory recommendations for the siting of sensitive
receptors near uses associated with toxic air contaminants, such as freeways and high-traffic roads,
commercial distribution centers, rail yards, ports, refineries, dry cleaners, gasoline stations, and industrial
facilities, to help keep children and other sensitive populations out of harm’s way. Based on CARB’s
Community Health Air Pollution Information System, no major toxic air contaminant sources are located in
proximity to the Project area. In addition, CARB has promulgated the following specific rules to limit toxic
air contaminants emissions:
CARB Rule 2485 (13 CCR, Chapter 10 Section 2485), Airborne Toxic Control Measure to Limit Diesel-Fueled
Commercial Motor Vehicle Idling
CARB Rule 2477 (13 CCR Section 2477 and Article 8), Airborne Toxic Control Measure for In-Use Diesel
Fueled Transport Refrigeration Units (TRU) and TRU Generator Sets and Facilities Where TRUs Operate
California Assembly Bill 1493– Pavley
In 2002, the California Legislature adopted AB 1493 requiring the adoption of regulations to develop fuel
economy standards for the transportation sector. In September 2004, pursuant to AB 1493, the CARB
approved regulations to reduce fuel use and emissions from new motor vehicles beginning with the 2009
model year (Pavley Regulations). CARB, USEPA, and the United States Department of Transportation’s
National Highway Traffic and Safety Administration (NHTSA) have coordinated efforts to develop fuel
economy standards for model 2017-2025 vehicles, which are incorporated into the “Low Emission Vehicle”
(LEV) Regulations.
California Code of Regulations (CCR) Title 13, Motor Vehicles, Section 2449(d)(3)
No vehicle or engines subject to this regulation may idle for more than 5 consecutive minutes. The idling limit
does not apply to:
• Idling when queuing;
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-5
Draft EIR
May 2025
• Idling to verify that the vehicle is in safe operating condition;
• Idling for testing, servicing, repairing or diagnostic purposes;
• Idling necessary to accomplish work for which the vehicle was designed (such as operating a crane);
• Idling required to bring the machine system to operating temperature; and
• Idling necessary to ensure safe operation of the vehicle.
Title 24 Energy Efficiency Standards and California Green Building Standards
California Code of Regulations (CCR) Title 24 Part 6: The California Energy Code was first adopted in 1978
in response to a legislative mandate to reduce California’s energy consumption. The standards are updated
periodically to allow consideration and possible incorporation of new energy efficient technologies and
methods. The most recently updated 2022 Energy Code encourages efficient electric heat pumps, establishes
electric-ready requirements for new homes, expands solar photovoltaic and battery storage standards, and
strengthens ventilation standards, among other requirements.
CCR, Title 24, Part 11: California Green Building Standards Code (CALGreen) is a comprehensive and
uniform regulatory code for all new construction and major renovations, and is administered by the California
Building Standards Commission. The purpose of CALGreen is to improve public health, safety, and general
welfare through enhanced design and construction of buildings using concepts which reduce negative impacts
and promote those principles which have a positive environmental impact and encourage sustainable
construction practices. It is also updated every three years. The most recent update is the 2022 CALGreen
Code that became effective January 1, 2023. It should be noted that the 2025 California Green Building
Code Standards are expected to be effective on January 1, 2026. The Project would be required to comply
with the applicable standards in place at the time plan check submittals are made.
The 2022 California Energy Code and CALGreen Building Standards Code mandatory measures for
nonresidential uses that reduce air pollutant emissions and are applicable to the proposed Project include,
but are not limited to, the following:
• Short-term bicycle parking. If the new project or an additional alteration is anticipated to generate
visitor traffic, provide permanently anchored bicycle racks within 200 feet of the visitors’ entrance,
readily visible to passers-by, for 5% of new visitor motorized vehicle parking spaces being added, with
a minimum of one two-bike capacity rack (5.106.4.1.1).
• Long-term bicycle parking. For new buildings with tenant spaces that have 10 or more tenant-occupants,
provide secure bicycle parking for 5% of the tenant-occupant vehicular parking spaces with a minimum
of one bicycle parking facility (5.106.4.1.2).
• EV charging stations. New construction shall facilitate the future installation of EV supply equipment. The
compliance requires empty raceways for future conduit and documentation that the electrical system has
adequate capacity for the future load. The number of spaces to be provided for is contained in Table
5.106. 5.3.3 (5.106.5.3). Additionally, Table 5.106.5.4.1 specifies requirements for the installation of
raceway conduit and panel power requirements for medium- and heavy-duty electric vehicle supply
equipment for warehouses, grocery stores, and retail stores.
• Outdoor light pollution reduction. Outdoor lighting systems shall be designed to meet the backlight, uplight
and glare ratings per Table 5.106.8 (5.106.8).
• Construction waste management. Recycle and/or salvage for reuse a minimum of 65% of the
nonhazardous construction and demolition waste in accordance with Section 5.408.1.1. 5.405.1.2,
or 5.408.1.3; or meet a local construction and demolition waste management ordinance, whichever
is more stringent (5.408.1).
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-6
Draft EIR
May 2025
• Excavated soil and land clearing debris. 100% of trees, stumps, rocks and associated vegetation
and soils resulting primarily from land clearing shall be reuse or recycled. For a phased project, such
material may be stockpiled on site until the storage site is developed (5.408.3).
• Recycling by Occupants. Provide readily accessible areas that serve the entire building and are identified
for the depositing, storage, and collection of non-hazardous materials for recycling, including (at a
minimum) paper, corrugated cardboard, glass, plastics, organic waste, and metals or meet a lawfully
enacted local recycling ordinance, if more restrictive (5.410.1).
• Water conserving plumbing fixtures and fittings. Plumbing fixtures (water closets and urinals) and
fittings (faucets and showerheads) shall comply with the following:
o Water Closets. The effective flush volume of all water closets shall not exceed 1.28 gallons per
flush (5.303.3.1)
o Urinals. The effective flush volume of wall-mounted urinals shall not exceed 0.125 gallons per
flush (5.303.3.2.1). The effective flush volume of floor- mounted or other urinals shall not exceed
0.5 gallons per flush (5.303.3.2.2).
o Showerheads. Single showerheads shall have a minimum flow rate of not more than 1.8 gallons
per minute and 80 psi (5.303.3.3.1). When a shower is served by more than one showerhead, the
combine flow rate of all showerheads and/or other shower outlets controlled by a single valve
shall not exceed 1.8 gallons per minute at 80 psi (5.303.3.3.2).
o Faucets and fountains. Nonresidential lavatory faucets shall have a maximum flow rate of not
more than 0.5 gallons per minute at 60 psi (5.303.3.4.1). Kitchen faucets shall have a maximum
flow rate of not more than 1.8 gallons per minute of 60 psi (5.303.3.4.2). Wash fountains shall
have a maximum flow rate of not more than 1.8 gallons per minute (5.303.3.4.3). Metering
faucets shall not deliver more than 0.20 gallons per cycle (5.303.3.4.4). Metering faucets for wash
fountains shall have a maximum flow rate not more than 0.20 gallons per cycle (5.303.3.4.5).
• Outdoor potable water uses in landscaped areas. Nonresidential developments shall comply with a local
water efficient landscape ordinance or the current California Department of Water Resources’ Model
Water Efficient Landscape Ordinance (MWELO), whichever is more stringent (5.304.1).
• Water meters. Separate submeters or metering devices shall be installed for new buildings or
additions in excess of 50,000 SF or for excess consumption where any tenant within a new building or
within an addition that is project to consume more than 1,000 gallons per day (GPD) (5.303.1.1 and
5.303.1.2).
• Outdoor water uses in rehabilitated landscape projects equal or greater than 2,500 SF. Rehabilitated
landscape projects with an aggregate landscape area equal to or greater than 2,500 SF requiring
a building or landscape permit (5.304.3).
• Commissioning. For new buildings 10,000 SF and over, building commissioning shall be included in the
design and construction processes of the building project to verify that the building systems and
components meet the owner’s or owner representative’s project requirements (5.410.2).
The 2022 Energy Code has been adopted by the City of Newport Beach Municipal Code Chapter 15.17,
and the 2022 CALGreen Building Standards Code in Municipal Code Chapter 15.11.
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-7
Draft EIR
May 2025
5.2.2.3 Local and Regional Regulations
South Coast Air Quality Management District
Criteria Air Pollutants
The South Coast Air Quality Management District (SCAQMD) attains and maintains air quality conditions in
the South Coast Air Basin (Basin) through a comprehensive program of planning, regulation, enforcement,
technical innovation, and promotion of the understanding of air quality issues. The clean air strategy of the
SCAQMD includes preparation of plans for attainment of ambient air quality standards, adoption and
enforcement of rules and regulations concerning sources of air pollution, and issuance of permits for
stationary sources of air pollution. The SCAQMD also inspects stationary sources of air pollution and responds
to citizen complaints; monitors ambient air quality and meteorological conditions; and implements programs
and regulations required by the Clean Air Act, the Clean Air Act Amendments, and the California Clean Air
Act. Air quality plans applicable to the proposed Project are discussed below.
Air Quality Management Plan
The SCAQMD and the Southern California Association of Governments (SCAG) are responsible for preparing
the air quality management plan (AQMP), which addresses federal and State Clean Air Act requirements.
The AQMP details goals, policies, and programs for improving air quality in the Basin.
The 2022 AQMP was adopted by the SCAQMD Governing Board on December 2, 2022. The 2022 AQMP
builds upon measures already in place from previous AQMPs. It also includes a variety of additional
strategies such as regulation, accelerated deployment of available cleaner technologies (e.g., zero emissions
technologies, when cost-effective and feasible, and low NOx technologies in other applications), best
management practices, co-benefits from existing programs (e.g., climate and energy efficiency), incentives,
and other Clean Air Act measures to achieve the 2015 federal 8-hour ozone standard. SCAQMD includes
a total of 49 control measures for the 2022 AQMP, including control measures focused on widespread
deployment of zero emission and low NOx technologies through a combination of regulatory approaches
and incentives.
SCAQMD Rules and Regulations
All projects are subject to SCAQMD rules and regulations. Specific rules that would be applicable to the
proposed Project include the following:
Rule 401 – Visible Emissions. A person shall not discharge into the atmosphere from any single source of
emission whatsoever any air contaminant for a period or periods aggregating more than three minutes in
any 1 hour that is as dark or darker in shade as that designated No. 1 on the Ringelmann Chart, as published
by the United States Bureau of Mines.
Rule 402 – Nuisance. A person shall not discharge from any source whatsoever such quantities of air
contaminants or other material that cause injury, detriment, nuisance, or annoyance to any considerable
number of persons or to the public, or that endanger the comfort, repose, health, or safety of any such
persons or the public, or that cause, or have a natural tendency to cause, injury or damage to business or
property. The provisions of this rule do not apply to odors emanating from agricultural operations necessary
for the growing of crops or the raising of fowl or animals.
Rule 403 – Fugitive Dust. SCAQMD Rule 403 governs emissions of fugitive dust during and after
construction. Compliance with this rule is achieved through application of standard Best Management
Practices, such as application of water or chemical stabilizers to disturbed soils, covering haul vehicles,
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-8
Draft EIR
May 2025
restricting vehicle speeds on unpaved roads to 15 miles per hour, sweeping loose dirt from paved site access
roadways, cessation of construction activity when winds exceed 25 mph, and establishing a permanent
ground cover on finished sites.
Rule 403 requires project applicants to control fugitive dust using the best available control measures such
that dust does not remain visible in the atmosphere beyond the property line of the emission source. In
addition, Rule 403 requires implementation of dust suppression techniques to prevent fugitive dust from
creating an offsite nuisance. Applicable Rule 403 dust suppression (and PM10 generation) techniques to
reduce impacts on nearby sensitive receptors may include, but are not limited to, the following:
• Apply nontoxic chemical soil stabilizers according to manufacturers’ specifications to all inactive
construction areas (previously graded areas inactive for 10 days or more).
• Water active sites at least three times daily. Locations where grading is to occur shall be thoroughly
watered prior to earthmoving.
• Cover all trucks hauling dirt, sand, soil, or other loose materials, or maintain at least 0.6 meters (2 feet)
of freeboard (vertical space between the top of the load and top of the trailer) in accordance with the
requirements of California Vehicle Code Section 23114.
• Reduce traffic speeds on all unpaved roads to 15 miles per hour (mph) or less.
• Suspend all grading activities when wind speeds (including instantaneous wind gusts) exceed 25 mph.
• Provide bumper strips or similar best management practices where vehicles enter and exit the
construction site onto paved roads, or wash off trucks and any equipment leaving the site each trip.
• Replant disturbed areas as soon as practical.
• Sweep onsite streets (and offsite streets if silt is carried to adjacent public thoroughfares) to reduce the
amount of particulate matter on public streets. All sweepers shall be compliant with SCAQMD Rule
1186.1, Less Polluting Sweepers.
Rule 445—Wood-Burning Devices. This rule prohibits permanently installed wood burning devices in any
new development. A wood burning device means any fireplace, wood burning heater, or pellet-fueled wood
heater, or any similarly enclosed, permanently installed, indoor or outdoor device burning any solid fuel for
aesthetic or space-heating purposes, which has a heat input of less than one million British thermal units per
hour.
Rule 481 – Spray Coating. This rule applies to all spray painting and spray coating operations and
equipment and states that a person shall not use or operate any spray painting or spray coating equipment
unless one of the following conditions is met:
• The spray coating equipment is operated inside a control enclosure, which is approved by the Executive
Officer. Any control enclosure for which an application for permit for new construction, alteration, or
change of ownership or location is submitted after the date of adoption of this rule shall be exhausted
only through filters at a design face velocity not less than 100 feet per minute nor greater than 300
feet per minute, or through a water wash system designed to be equally effective for the purpose of
air pollution control.
• Coatings are applied with high-volume low-pressure, electrostatic and/or airless spray equipment.
• An alternative method of coating application or control is used which has effectiveness equal to or
greater than the equipment specified in the rule.
Rule 1108 - Volatile Organic Compounds. This rule governs the sale, use, and manufacturing of asphalt
and limits the volatile organic compound (VOC) content in asphalt used in the Basin. This rule also regulates
the VOC content of asphalt used during construction. Therefore, all asphalt used during construction of the
Project must comply with SCAQMD Rule 1108.
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-9
Draft EIR
May 2025
Rule 1113 – Architectural Coatings. No person shall apply or solicit the application of any architectural
coating within the SCAQMD with VOC content in excess of the values specified in a table incorporated in
the Rule.
Rule 1143 – Paint Thinners and Solvents. This rule governs the manufacture, sale, and use of paint thinners
and solvents used in thinning of coating materials, cleaning of coating application equipment, and other
solvent cleaning operations by limiting their VOC content. This rule regulates the VOC content of solvents
used during construction. Solvents used during the construction phase must comply with this rule.
City of Newport Beach General Plan
The City of Newport Beach General Plan contains the following policies related to air quality that are
applicable to the Project:
Policy NR 7.1 Fuel Efficient Equipment. Support the use of fuel efficient heating equipment and other
appliances.
NR 7.2 Source Emission Reduction Best Management Practices. Require the use of Best
Management Practices (BMP) to minimize pollution and to reduce source emissions.
NR 7.3 Incentives for Air Pollution Reduction. Provide incentives to promote siting or to use clean
air technologies and building materials (e.g., fuel cell technologies, renewable energy
sources, UV coatings, hydrogen fuel).
NR 8.1 Management of Construction Activities to Reduce Air Pollution. Require developers to
use and operate construction equipment, use building materials and paints, and control dust
created by construction activities to minimize air pollutants.
City of Newport Beach Municipal Code
Chapter 15.19 Electric Vehicle Charging Stations. Municipal Code Chapter 15.19 aims to encourage the
use of electric vehicle charging stations by removing unreasonable barriers, minimizing costs to property
owners and the City, and expanding the ability of property owners to install electric vehicle charging stations.
Pursuant to Municipal Code Section 15.19.060, applications to install electric vehicle charging stations
through issuance of a building permit or similar nondiscretionary permit will be administratively reviewed
and approved by the Building Division.
5.2.3 ENVIRONMENTAL SETTING
5.2.3.1 Climate and Meteorology
The Project area is located within the South Coast Air Basin (Basin), which is under the jurisdiction of the
SCAQMD. The Basin is a 6,600-square-mile coastal plain bounded by the Pacific Ocean to the southwest
and the San Gabriel, San Bernardino, and San Jacinto Mountains to the north and east. The Basin includes
the non-desert portions of Los Angeles, Riverside, and San Bernardino counties, and all of Orange County.
The ambient concentrations of air pollutants are determined by the amount of emissions released by sources
and the atmosphere’s ability to transport and dilute such emissions. Natural factors that affect transport and
dilution include terrain, wind, atmospheric stability, and sunlight. Therefore, existing air quality conditions in
the area are determined by such natural factors as topography, meteorology, and climate, in addition to
the amount of emissions released by existing air pollutant sources.
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-10
Draft EIR
May 2025
Atmospheric conditions such as wind speed, wind direction, and air temperature gradients interact with the
physical features of the landscape to determine the movement and dispersal of air pollutants. The
topography and climate of southern California combine to make the Basin an area of high air pollution
potential. The Basin is a coastal plain with connecting broad valleys and low hills, bounded by the Pacific
Ocean to the west and San Bernardino mountains around the rest of the perimeter. The general region lies
in the semi-permanent high-pressure zone of the eastern Pacific, resulting in a mild climate tempered by cool
sea breezes with light average wind speeds. The usually mild climatological pattern is disrupted occasionally
by periods of extremely hot weather, winter storms, or Santa Ana winds. During the summer months, a warm
air mass frequently descends over the cool, moist marine layer produced by the interaction between the
ocean’s surface and the lowest layer of the atmosphere. The warm upper layer forms a cap over the cool
marine layer and inhibits the pollutants in the marine layer from dispersing upward. In addition, light winds
during the summer further limit ventilation. Furthermore, sunlight triggers the photochemical reactions which
produce ozone.
5.2.3.2 Criteria Air Pollutants
The California Air Resources Board (CARB) and the United States Environmental Protection Agency (USEPA)
currently focus on the following air pollutants as indicators of ambient air quality: ozone, Carbon monoxide
(CO), Nitrogen dioxide (NO2), Sulfur dioxide (SO2), particulate matter 10 microns or less in diameter (PM10),
particulate matter 2.5 microns or less in diameter (PM2.5), and lead. These pollutants are referred to as
“criteria air pollutants” because they are the most prevalent air pollutants known to be injurious to human
health. Extensive health-effects criteria documents regarding the effects of these pollutants on human health
and welfare have been prepared over the years.1 Standards have been established for each criteria
pollutant to meet specific public health and welfare criteria set forth in the federal Clean Air Act (CAA).
California has generally adopted more stringent ambient air quality standards for the criteria air pollutants
(referred to as State Ambient Air Quality Standards, or State standards) and has adopted air quality
standards for some pollutants for which there is no corresponding national standard, such as sulfates,
hydrogen sulfide, vinyl chloride, and visibility-reducing particles.
Ozone
Ozone, the main component of photochemical smog, is primarily a summer and fall pollution problem. Ozone
is not emitted directly into the air; but is formed through a complex series of chemical reactions involving
other compounds that are directly emitted. These directly emitted pollutants (also known as ozone precursors)
include reactive organic gases (ROGs) or volatile organic compounds (VOCs), and oxides of nitrogen (NOx).
While both ROGs and VOCs refer to compounds of carbon, ROG is a term used by CARB and is based on
a list of exempted carbon compounds determined by CARB. VOC is a term used by the USEPA and is based
on its own exempt list. The time period required for ozone formation allows the reacting compounds to
spread over a large area, producing regional pollution problems. Ozone concentrations are the cumulative
result of regional development patterns rather than the result of a few significant emission sources.
Once ozone is formed, it remains in the atmosphere for one or two days. Ozone is then eliminated through
reaction with chemicals on the leaves of plants, attachment to water droplets as they fall to earth (“rainout”),
or absorption by water molecules in clouds that later fall to earth with rain (“washout”).
1 Additional sources of information on the health effects of criteria pollutants can be found at CARB and USEPA’s websites at
http://www.arb.ca.gov/research/health/health.htm and http://www.epa.gov/air/airpollutants.html, respectively.
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-11
Draft EIR
May 2025
Short-term exposure to ozone can irritate the eyes and cause constriction of the airways. In addition to
causing shortness of breath, ozone can aggravate existing respiratory diseases such as asthma, bronchitis,
and emphysema.
Carbon Monoxide
CO is a colorless, odorless gas produced by the incomplete combustion of carbon-containing fuels, such as
gasoline or wood. CO concentrations tend to be the highest during the winter morning, when little to no wind
and surface-based inversions trap the pollutant at ground levels. Because CO is emitted directly from internal
combustion engines, unlike ozone, motor vehicles operating at slow speeds are the primary source of CO in
the Basin. The highest ambient CO concentrations are generally found near congested transportation
corridors and intersections.
Nitrogen Dioxide
NO2 is a reddish-brown gas that is a by-product of combustion processes. Automobiles and industrial
operations are the main sources of NO2. Combustion devices emit primarily nitric oxide (NO), which reacts
through oxidation in the atmosphere to form NO2. The combined emissions of NO and NO2 are referred to
as NOx, which are reported as equivalent NO2. Aside from its contribution to ozone formation, NO2 can
increase the risk of acute and chronic respiratory disease and reduce visibility. NO2 may be visible as a
coloring component of a brown cloud on high pollution days, especially in conjunction with high ozone levels.
Sulfur Dioxide
SO2 is a colorless, extremely irritating gas or liquid that enters the atmosphere as a pollutant mainly as a
result of burning high sulfur-content fuel oils and coal, and from chemical processes occurring at chemical
plants and refineries. When SO2 oxidizes in the atmosphere, it forms sulfur trioxide (SO3). Collectively, these
pollutants are referred to as sulfur oxides (SOx).
Major sources of SO2 include power plants, large industrial facilities, diesel vehicles, and oil-burning
residential heaters. Emissions of SO2 aggravate lung diseases, especially bronchitis. This compound also
constricts the breathing passages, especially in people with asthma and people involved in moderate to
heavy exercise. SO2 potentially causes wheezing, shortness of breath, and coughing. Long-term SO2
exposure has been associated with increased risk of mortality from respiratory or cardiovascular disease.
Particulate Matter
PM10 and PM2.5 consist of particulate matter that is 10 microns or less in diameter and 2.5 microns or less in
diameter, respectively (a micron is one-millionth of a meter). PM10 and PM2.5 represent fractions of particulate
matter that can be inhaled into the air passages and the lungs and can cause adverse health effects. Acute
and chronic health effects associated with high particulate levels include the aggravation of chronic
respiratory diseases, heart and lung disease, and coughing, bronchitis and respiratory illnesses in children.
Particulate matter can also damage materials and reduce visibility. One common source of PM2.5 is diesel
exhaust emissions.
PM10 consists of particulate matter emitted directly into the air (e.g., fugitive dust, soot, and smoke from
mobile and stationary sources, construction operations, fires, and natural windblown dust) and particulate
matter formed in the atmosphere by condensation and/or transformation of SO2 and ROG. Traffic generates
particulate matter emissions through entrainment of dust and dirt particles that settle onto roadways and
parking lots. PM10 and PM2.5 are also emitted by burning wood in residential wood stoves and fireplaces
and open agricultural burning. PM2.5 can also be formed through secondary processes such as airborne
reactions with certain pollutant precursors, including ROGs, ammonia (NH3), NOx, and SOx.
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-12
Draft EIR
May 2025
Lead
Lead is a metal found naturally in the environment and present in some manufactured products. There are a
variety of activities that can contribute to lead emissions, which are grouped into two general categories,
stationary and mobile sources. On-road mobile sources include light-duty automobiles; light-, medium-, and
heavy-duty trucks; and motorcycles.
Emissions of lead have dropped substantially over the past 40 years. The reduction before 1990 is largely
due to the phase-out of lead as an anti-knock agent in gasoline for on-road automobiles. Substantial emission
reductions have also been achieved due to enhanced controls in the metals processing industry. In the Basin,
atmospheric lead is generated almost entirely by the combustion of leaded gasoline and contributes less
than one percent of the material collected as total suspended particulates.
5.2.3.3 Toxic Air Contaminants
Concentrations of toxic air contaminants (TACs), or in federal parlance, hazardous air pollutants (HAPs), are
also used as indicators of ambient air quality conditions. A TAC is defined as an air pollutant that may cause
or contribute to an increase in mortality or in serious illness, or that may pose a hazard to human health.
TACs are usually present in minute quantities in the ambient air; however, their high toxicity or health risk
may pose a threat to public health even at low concentrations.
According to the California Almanac of Emissions and Air Quality, the majority of the estimated health risk
from TACs can be attributed to relatively few compounds, the most important being particulate matter from
diesel-fueled engines (DPM). DPM differs from other TACs in that it is not a single substance, but rather a
complex mixture of hundreds of substances. Although DPM is emitted by diesel-fueled internal combustion
engines, the composition of the emissions varies depending on engine type, operating conditions, fuel
composition, lubricating oil, and whether an emission control system is present.
Unlike the other TACs, no ambient monitoring data is available for DPM because no routine measurement
method currently exists. However, CARB has made preliminary concentration estimates based on a
particulate matter exposure method. This method uses the CARB emissions inventory’s PM10 database,
ambient PM10 monitoring data, and the results from several studies to estimate concentrations of diesel PM.
In addition to diesel PM, the TACs for which data are available that pose the greatest existing ambient risk
in California are benzene, 1,3-butadiene, acetaldehyde, carbon tetrachloride, hexavalent chromium, para-
dichlorobenzene, formaldehyde, methylene chloride, and perchloroethylene.
5.2.3.4 CO Hotspots
An adverse CO concentration, known as a “hot spot” is an exceedance of the State 1-hour standard of 20
ppm or the 8-hour standard of 9 ppm. It has long been recognized that CO hotspots are caused by vehicular
emissions, primarily when idling at congested intersections. In response, vehicle emissions standards have
become increasingly stringent in the last twenty years. Currently, the allowable CO emissions standard in
California is a maximum of 3.4 grams/mile for passenger cars (there are requirements for certain vehicles
that are more stringent). With the turnover of older vehicles, introduction of cleaner fuels, and implementation
of increasingly sophisticated and efficient emissions control technologies, CO concentration in the SCAB is
now designated as attainment, and CO concentrations in the Project vicinity have steadily declined
(Appendix B).
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-13
Draft EIR
May 2025
5.2.3.5 Odorous Emissions
Odors are generally regarded as an annoyance rather than a health hazard. However, manifestations of a
person’s reaction to foul odors can range from psychological (e.g., irritation, anger, or anxiety) to
physiological (e.g., circulatory and respiratory effects, nausea, vomiting, and headache). Offensive odors
are unpleasant and can lead to public distress generating citizen complaints to local governments. Although
unpleasant, offensive odors rarely cause physical harm. The occurrence and severity of odor impacts depend
on the nature, frequency, and intensity of the source, wind speed, direction, and the sensitivity of receptors.
5.2.3.6 Existing Conditions
SCAQMD maintains monitoring stations within district boundaries, Source/Receptor Areas (SRAs), that monitor
air quality and compliance with associated ambient standards. The Project site is located within the
monitoring boundary of the North Coastal Orange County monitoring area (SRA 18). However, there are
currently no monitoring stations within SRA 18. Therefore, the following is a list of data that was obtained
from nearby monitoring stations:
• SRA 19 (Saddleback Valley located 11.74 miles east of the Project site):
o O3 (2021 and 2022)
o CO (2021 and 2022)
o PM10 (2021 and 2022)
o PM2.5 (2021)
• SRA 17 (I-5 Near Road located 11.43 miles northwest of the Project site):
o CO (2023)
o NO2 (2021 and 2022)
• SRA 17 (Central Orange County located 12.32 miles northwest of the Project site):
o O3 (2023)
o NO2 (2023)
o PM10 (2023)
o PM2.5 (2022 and 2023)
The most recent three years of data is shown in Table 5.2-2 and identifies the number of days ambient air
quality standards were exceeded in the area. The federal PM10 and PM2.5 standards had no exceedances.
The 1-hour ozone State standard was exceeded two times in 2021, one time in 2022, and zero times in
2023. The 8-hour ozone federal standard was eight times in 2021, six times in 2022, and two times in 2023.
In addition, the CO, SO2, and NO2 standards were not exceeded in this area during the 3-year period.
Table 5.2-2: Air Quality Monitoring Summary 2021-2023
Pollutant Standard Year
2021 2022 2023
O3
Maximum Federal 1-Hour Concentration (ppm) 0.105 0.110 0.089
Maximum Federal 8-Hour Concentration (ppm) 0.081 0.088 0.076
Number of Days Exceeding State 1-Hour Standard > 0.09 ppm 2 1 0
Number of Days Exceeding State/Federal 8-Hour Standard > 0.070 ppm 8 6 2
CO
Maximum Federal 1-Hour Concentration > 35 ppm 1.0 1.2 2.4
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-14
Draft EIR
May 2025
Pollutant Standard Year
2021 2022 2023
Maximum Federal 8-Hour Concentration > 20 ppm 0.8 1.0 1.9
NO2
Maximum Federal 1-Hour Concentration > 0.100 ppm 0.072 0.062 0.058
Annual Federal Standard Design Value 0.019 0.019 0.020
PM10
Maximum Federal 24-Hour Concentration (µg/m3) > 150 µg/m3 35 31 146
Annual Federal Arithmetic Mean (µg/m3) 15.6 15.3 24.0
Number of Days Exceeding Federal 24-Hour Standard > 150 µg/m3 0 0 0
Number of Days Exceeding State 24-Hour Standard > 50 µg/m3 0 0 0
PM2.5
Maximum Federal 24-Hour Concentration (µg/m3) > 35 µg/m3 28.7 33.1 33.2
Annual Federal Arithmetic Mean (µg/m3) > 12 µg/m3 8.27 9.87 9.07
Number of Days Exceeding Federal 24-Hour Standard > 35 µg/m3 0 0 0
ppm = parts per million, µg/m3 = microgram per cubic meter, O3 = ozone, CO = carbon monoxide, NO2 = nitrogen dioxide,
PM10 = particulate matter 10 microns in diameter, PM2.5 = particulate matter 2.5 microns in diameter
Source: Air Quality Impact Analysis (Appendix B)
Both CARB and the USEPA use this type of monitoring data to designate areas according to their attainment
status for criteria air pollutants. The purpose of these designations is to identify the areas with air quality
problems and thereby initiate planning efforts for improvement. The three basic designation categories are
nonattainment, attainment, and unclassified. Nonattainment is defined as any area that does not meet (or
that contributes to ambient air quality in a nearby area that does not meet) the primary or secondary
ambient air quality standard for the pollutant. Attainment is defined as any area that meets the primary or
secondary ambient air quality standard for the pollutant. Unclassifiable is defined as any area that cannot
be classified on the basis of available information as meeting or not meeting the primary or secondary
ambient air quality standard for the pollutant. In addition, California designations include a subcategory of
nonattainment-transitional, which is given to nonattainment areas that are progressing and nearing
attainment. Table 5.2-3 shows the attainment status of criteria pollutants in the South Coast Air Basin.
Table 5.2-3: Attainment Status of Criteria Pollutants in the Basin
Criteria Pollutant State Designation Federal Designation
O3 – 1-hour standard Nonattainment --
O3 – 8-hour standard Nonattainment Nonattainment
PM10 Nonattainment Attainment
PM2.5 Nonattainment Nonattainment
CO Attainment Unclassifiable/Attainment
NO2 Attainment Unclassifiable/Attainment
SO2 Attainment Unclassifiable/Attainment
Pb2 Attainment Unclassifiable/Attainment
O3 = ozone, PM10 = particulate matter 10 microns in diameter, PM2.5 = particulate matter 2.5 microns in diameter, CO = carbon
monoxide, NO2 = nitrogen dioxide, SO2 = sulfur dioxide, Pb2 = lead
Source: Air Quality Impact Analysis (Appendix B)
2 The Federal nonattainment designation for lead is only applicable towards the Los Angeles County portion of the SCAB.
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-15
Draft EIR
May 2025
Existing Project Site Emissions from Onsite Uses. Emissions from the existing operations at the Project site
are generated from operation of the existing a 38-bay driving range, the pro shop, restaurant that seats
233 people, parking lot, and three holes of the existing NB Golf Course (holes 1, 2, and 9). Air quality
emissions are currently generated by the operation of these uses and the related vehicle trips. The estimated
operation-source emissions from the existing commercial recreation uses on the Project site are provided in
Table 5.2-4.
Table 5.2-4: Existing Project Site Emissions
Source Emissions (lbs/day)
VOC NOx CO SOx PM10 PM2.5
Summer
Mobile Source 5.62 4.08 48.10 0.13 12.50 3.21
Area Source 0.66 0.00 0.00 0.00 0.00 0.00
Energy Source1 0.13 0.24 0.20 0.00 0.02 0.02
Total Maximum Daily Emissions 6.41 4.32 48.30 0.13 12.52 3.23
Winter
Mobile Source 5.57 4.44 44.60 0.12 12.50 3.21
Area Source 0.66 0.00 0.00 0.00 0.00 0.00
Energy Source1 0.13 0.24 0.20 0.00 0.02 0.02
Total Maximum Daily Emissions 6.36 4.68 44.80 0.12 12.52 3.23
VOC = volatile organic compounds, NOx = nitrogen oxides, CO = carbon monoxide, SOx = sulfur oxides, PM10 = particulate
matter 10 microns in diameter, PM2.5 = particulate matter 2.5 microns in diameter
1Energy Source emissions are based on estimated natural gas usage of 900,000 kBtu per year for the existing facility.
Source: Air Quality Impact Analysis (Appendix B)
5.2.3.7 Sensitive Land Uses and Localized Emissions
Land uses such as schools, children’s daycare centers, hospitals, and convalescent homes are considered to
be more sensitive to poor air quality than the general public because the population groups associated with
these uses have increased susceptibility to respiratory distress. These locations typically include uses where
an individual can remain for 24 hours. Consistent with the SCAQMD LST methodology, the nearest land use
where an individual could remain for 24 hours to the Project site has been used to determine construction air
quality impacts for emissions of PM10 and PM2.5, since PM10 and PM2.5 thresholds are based on a 24-hour
averaging time.
LSTs apply, even for non-sensitive land uses, because SCAQMD LST methodology states that “LSTs based on
shorter averaging periods, such as the NO2 and CO LSTs, could also be applied to receptors such as industrial
or commercial facilities since it is reasonable to assume that a worker at these sites could be present for
periods of one to eight hours.” Therefore, any land use where an individual could remain for 1 or 8 hours,
that is located at a closer distance to the Project site than the receptor used for PM10 and PM2.5 analysis, is
considered to determine construction and operational LST air impacts for emissions of NO2 and CO since
these pollutants have an averaging time of 1 and 8 hours.
The closest receptors to the Project site are listed below and shown on Figure 5.2-1. All distances are
measured from the Project site boundary to the outdoor living areas (e.g., backyards) or to the building
façade, whichever is closer.
R1 Location R1 represents a residence at 20352 Kline Drive, 399 feet northwest of the Project
site. Receptor R1 is placed at the use area (backyard) facing the Project site.
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-16
Draft EIR
May 2025
R2 Location R2 represents a residence at 1691 Mesa Drive, 256 feet northwest of the Project
site. Receptor R2 is placed at the use area (pool) facing the Project site.
R3 Location R3 represents a residence at 1691 Mesa Drive, 169 feet northwest of the Project
site. Receptor R3 is placed at the building façade facing the Project site.
R4 Location R4 represents a residence at 2698 Riverside Drive, 502 feet west of the Project
site. Receptor R4 is placed at the building façade facing the Project site.
R5 Location R5 represents a residence at 2916 Irvine Avenue, 284 feet southwest of the Project
site. Receptor R5 is placed at the building façade facing the Project site.
R6 Location R6 represents a residence at 2139 Anniversary Lane, 673 feet south of the Project
site. Receptor R6 is placed at the building façade facing the Project site.
R7 Location R7 represents a park at 2061 Mesa Drive, 797 feet southeast of the Project site.
Receptor R7 is placed at the use area facing the Project site.
R8 Location R8 represents a residence at 20250 SW Acacia Street, 386 feet east of the Project
site. Receptor R8 is placed at the building façade facing the Project site
R9 Location R9 represents Newport Beach Fire Station #7 located at 20401 SW Acacia Street,
located immediately adjacent to the east of the Project site, within 25 meters.
R10 Location R10 represents the Beauty Hut Face and Body Sculpting medical spa at 20321
SW Acacia Street Suite 150, located immediately adjacent to the east of the Project site,
within 25 meters.
R11 Location R11 represents the Newport Montessori School located at 20221 SW Cypress
Street, approximately 1,531 feet east of the Project site.
R12 Location R12 represents the Newport-Mesa Family YMCA located at 2300 University Drive,
approximately 1,156 feet south of the Project site.
R13 Location R13 represents the Newport Beach International Montessori Academies located at
381 University Drive, approximately 1,246 feet southwest of the Project site.
R14 Location R14 represents the Bay Back Montessori School located at 398 University Drive,
approximately 1,502 feet southwest of the Project site.
Snug Harbor Surf Park Project
City of Newport Beach
Source: Urban Crossroads. 2025. Surf Farm Air Quality Impact Analysis.
Figure 5.2-1
Sensitive Receptor Locations
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-18
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-19
Draft EIR
May 2025
5.2.4 THRESHOLDS OF SIGNIFICANCE
Where available, the significance criteria established by the applicable air quality management district or
air pollution control district may be relied upon to make the following determinations. Appendix G of the
CEQA Guidelines indicates that a Project could have a significant effect if it were to:
AQ-1 Conflict with or obstruct implementation of the applicable air quality plan.
AQ-2 Result in a cumulatively considerable net increase of any criteria pollutant for which the project
region is non-attainment under an applicable federal or State ambient air quality standard.
AQ-3 Expose sensitive receptors to substantial pollutant concentrations.
AQ-4 Result in other emissions (such as those leading to odors) adversely affecting a substantial number
of people.
Regional Significance Thresholds
The SCAQMD’s regional significance thresholds are listed in Table 5.2-5. The SCAQMD’s CEQA air quality
methodology provides that any projects that result in daily emissions that exceed any of these thresholds would
have both an individually (project-level) and cumulatively significant air quality impact.
Table 5.2-5: SCAQMD Regional Air Quality Thresholds
Pollutant Construction Operations
NOx 100 lbs/day 55 lbs/day
VOC 75 lbs/day 55 lbs/day
PM10 150 lbs/day 150 lbs/day
PM2.5 55 lbs/day 55 lbs/day
SOx 150 lbs/day 150 lbs/day
CO 550 lbs/day 550 lbs/day
Pb 3 lbs/day 3 lbs/day
NOx = nitrogen oxides, VOC = volatile organic compounds, PM10 = particulate matter 10 microns in diameter, PM2.5 =
particulate matter 2.5 microns in diameter, CO = carbon monoxide, SOx = sulfur oxides, CO = carbon monoxide, Pb2 = lead
Source: Air Quality Impact Analysis, Appendix B.
Local Significance Thresholds
SCAQMD has also developed localized significance thresholds (LSTs) that represent the maximum emissions
from a project that are not expected to cause or contribute to an exceedance of the most stringent applicable
federal or State ambient air quality standards and thus would not cause or contribute to localized air quality
impacts. LSTs are developed based on the ambient concentrations of that pollutant for each of the 38 source
receptor areas (SRAs) in the Basin. The Project site is located within the North Coastal Orange County
monitoring area (SRA 18).
The localized thresholds (listed in Table 5.2-6) are from the SCAQMD’s CEQA Air Quality Significance
Thresholds (March 2023) and are only applicable to the following criteria pollutants: NOx, CO, PM10, and
PM2.5. These thresholds are for activities at 25 meters. SCAQMD LST methodology explicitly states that “It is
possible that a project may have receptors closer than 25 meters. Projects with boundaries located closer
than 25 meters (82 feet) to the nearest receptor should use the LSTs for receptors located at 25 meters (82
feet).” As such, for distances located less than 82 feet from the development sites, a 25-meter receptor
distance is used.
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-20
Draft EIR
May 2025
Table 5.2-6: SCAQMD Localized Air Quality Thresholds
Pollutant Construction Operations
NO2 0.18 ppm 0.18 ppm
CO (1-hour average) 20 ppm 20 ppm
CO (8-hour average) 9 ppm 9 ppm
PM10 10.4 µg/m3 2.5 µg/m3
PM2.5 10.4 µg/m3 2.5 µg/m3
NO2 = nitrogen dioxide, CO = carbon monoxide, PM10 = particulate matter 10 microns in diameter, PM2.5 = particulate matter
2.5 microns in diameter
Source: Air Quality Impact Analysis, Appendix B.
5.2.5 METHODOLOGY
This analysis focuses on the nature and magnitude of the change in the air quality environment due to
implementation of the proposed Project, based on the maximum development assumptions that are outlined
in Section 3.0, Project Description. Air pollutant emissions associated with the proposed Project would result
from construction equipment usage and from construction-related traffic. Additionally, emissions would be
generated from operations of the proposed surf lagoon, amenity clubhouse building, athlete
accommodations, and from traffic generated by the Project employees, customers, and other visitors. The
net increase in emissions generated by these activities and other secondary sources have been quantitatively
estimated and compared to the applicable thresholds of significance recommended by SCAQMD.
In addition, in order to estimate localized pollutant concentrations resulting from Project construction, the
SCAQMD-approved American Meteorological Society/EPA Regulatory Model (AERMOD) dispersion model
was utilized. In order to model worst-case conditions, the highest daily peak onsite emissions resulting from
overlapping construction activity were modeled.
AQMP Consistency
SCAQMD’s CEQA Handbook suggests an evaluation of the following two criteria to determine whether a
project involving a legislative land use action (such as the proposed General Plan land use and zoning
designation changes) would be consistent or in conflict with the AQMP:
1. The project would not generate population and employment growth that would be inconsistent with
SCAG’s growth forecasts.
2. The project would not result in an increase in the frequency or severity of existing air quality violations
or cause or contribute to new violations or delay the timely attainment of air quality standards or the
interim emissions reductions specified in the AQMP.
Consistency Criterion No. 1 refers to the SCAG’s growth forecast and associated assumptions included in the
AQMP. The future air quality levels projected in the AQMP are based on SCAG’s growth projections, which
are based, in part, on the general plans of cities located within the SCAG region. Therefore, if the level of
employment or housing related to a proposed Project is consistent with the applicable assumptions used in
the development of the AQMP, the proposed Project would not jeopardize attainment of the air quality
levels identified in the AQMP.
Consistency Criterion No. 2 refers to the California Ambient Air Quality Standards. An impact would occur
if the emissions associated with the proposed Project would exceed SCAQMD’s significance thresholds.
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-21
Draft EIR
May 2025
Construction
Short-term construction-generated emissions of criteria air pollutants and ozone precursors from development
of the proposed Project were assessed in accordance with methods recommended by SCAQMD. The
proposed Project’s regional emissions were modeled using the California Emissions Estimator Model
(CalEEMod), as recommended by SCAQMD. CalEEMod was used to determine whether short-term
construction-related emissions of criteria air pollutants would exceed applicable regional thresholds and
where mitigation would be required. Modeling was based on Project-specific data and predicted short-term
construction-generated emissions were compared with applicable SCAQMD regional thresholds for
determination of significance.
In addition, to determine whether or not construction activities associated with development of the proposed
Project would create significant adverse localized air quality impacts on nearby sensitive receptors, the
worst-case daily emissions contribution from the proposed Project were compared to SCAQMD’s LSTs that
are based on the pounds of emissions per day that can be generated by a project without causing or
contributing to adverse localized air quality impacts. The daily total onsite combustion, mobile, and fugitive
dust emissions associated with construction were evaluated against SCAQMD’s LSTs as appropriate for each
activity.
Operations
Long-term (i.e., operational) regional emissions of criteria air pollutants and precursors, including mobile-
and area-source emissions from the proposed Project, were also quantified using the CalEEMod computer
model. Area-source emissions were modeled according to the size and type of the land uses proposed. Mass
mobile-source emissions were modeled based on the increase in daily vehicle trips that would result from the
proposed Project. Trip generation rates were available from the transportation analysis prepared for the
proposed Project (see Appendix R). Predicted long-term operational emissions were compared with
applicable SCAQMD thresholds for determination of significance.
5.2.6 ENVIRONMENTAL IMPACTS
IMPACT AQ-1: THE PROJECT WOULD NOT CONFLICT WITH OR OBSTRUCT IMPLEMENTATION OF
THE APPLICABLE AIR QUALITY PLAN.
Less than Significant Impact.
The SCAQMD’s 2022 AQMP, which was adopted on December 2, 2022, is the applicable air quality plan
for the City of Newport Beach. Pursuant to SCAQMD Consistency Criterion No. 1, the SCAQMD AQMP is
the applicable air quality plan for the proposed Project. Projects that are consistent with the regional
population, housing, and employment forecasts identified by SCAG are considered to be consistent with the
AQMP growth projections, since the forecast assumptions by SCAG forms the basis of the land use and
transportation control portions of the AQMP. Additionally, because SCAG’s regional growth forecasts are
based upon, among other things, land uses designated in general plans, a project that is consistent with the
land use designated in a general plan would also be consistent with the SCAG’s regional forecast projections,
and thus also with the AQMP growth projections.
The Project site has a City of Newport Beach General Plan land use designation of Parks and Recreation
(PR). The General Plan states that the PR land use permits parks (both active and passive), golf courses,
marina support facilities, aquatic facilities, tennis clubs and courts, private recreation, and similar facilities.
Development on the site is currently limited by General Plan Anomaly No. 58 to 20,000 SF. Accessory uses
and structures are permitted when customarily associated with and subordinate to a principal permitted use
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-22
Draft EIR
May 2025
on the same building site. The Project includes a General Plan Amendment to increase the development
intensity for the site from the current development limit of 20,000 SF to approximately 59,773 SF (not
including 18,137 SF of permitted accessory structures). However, as discussed below, the Project would result
in a limited increase in onsite employment and would not exceed the AQMP’s projections regarding
population or employment.
In addition, the Project site is located within the Santa Ana Heights Specific Plan (SP-7), which provides zoning
regulations for the site. The Santa Ana Heights Specific Plan designates the site as Open Space/Recreation
(OS/R), that allows golf courses and outdoor commercial recreation and accessory uses and structures with
a use permit. The proposed surf park and golf course support facilities (including parking, starter shack, golf
cart storage, and golf cart paths) for the 15-hole golf course areas to the north and south of the proposed
Project would implement outdoor commercial recreation and accessory uses as intended by the OS/R
designation.
The Project site currently employs 47 full and part-time people at the golf course, pro-shop, and restaurant.
The proposed Project would employ approximately 70 full-time and part-time employees with an average
of approximately 55 employees onsite at any given time. The addition of 23 total employees from
implementation of the proposed Project would not result in additional jobs in the area that would result in
unplanned growth. Additionally, the 20 athlete accommodations would only be utilized for short time periods
by visiting surfers and related guests, and the athlete accommodations would not result in population growth
that is inconsistent with SCAG’s projections.
In addition, the proposed Project would utilize existing infrastructure such as roadways, drainage, sewer,
water, and other infrastructure, and would be consistent with the SCAG objective to “Encourage patterns of
urban development and land use that reduce costs in infrastructure construction and make better use of
existing facilities.” As a result, the proposed Project would be consistent with SCAQMD Consistency Criterion
No. 1.
Regarding Consistency Criterion No. 2, which evaluates the potential of the proposed Project to increase the
frequency or severity of existing air quality violations; an impact would occur if the emissions associated with
the proposed Project would exceed SCAQMD’s regional significance thresholds. As detailed below in Impact
AQ-2, construction and operation of the proposed Project would not exceed any of the SCAQMD threshold
of significance. Therefore, the proposed Project would be consistent with Consistency Criterion No. 2.
Overall, the proposed Project would be consistent with both Criterion No. 1 and Criterion No. 2. Thus, impacts
related to conflict with or obstruction of implementation of the applicable air quality plan would be less than
significant.
IMPACT AQ-2: THE PROJECT WOULD NOT RESULT IN A CUMULATIVELY CONSIDERABLE NET
INCREASE OF ANY CRITERIA POLLUTANT FOR WHICH THE PROJECT REGION IS
NON-ATTAINMENT UNDER AN APPLICABLE FEDERAL OR STATE AMBIENT AIR
QUALITY STANDARD.
Less than Significant Impact.
Construction
Construction activities associated with the Project would result in emissions of CO, VOC, NOx, SOx, PM10,
and PM2.5. Pollutant emissions associated with construction would be generated from the following
construction activities: (1) demolition, site preparation, grading, and excavation; (2) construction workers
traveling to and from the Project site; (3) delivery and hauling of construction supplies to, and debris from,
the Project site; (4) fuel combustion by onsite construction equipment; (5) building construction; application of
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-23
Draft EIR
May 2025
architectural coatings; and paving. These construction activities would temporarily create emissions of dust,
fumes, equipment exhaust, and other air contaminants.
Construction of the proposed Project would involve the demolition of the existing golf course uses, including
the 8,975 SF pro shop and restaurant building and the 2,664 SF driving range building and disposal of the
debris in landfills and recycling facilities, which was estimated to occur over a 20-day period. In addition,
construction of the Project would require 135,000 cubic yards of cut and 135,000 cubic yards of fill that
would generate emissions from grading equipment over an estimated 50-day period, as detailed in Table
3-5, Construction Schedule and Equipment, in Section 3.0, Project Description.
Construction emissions are short-term and temporary and would vary depending on the types of construction
activities occurring. The maximum daily construction emissions for the proposed Project were estimated using
CalEEMod and the modeling includes compliance with SCAQMD Rules 403 and 1113 (described above)
that would reduce air contaminants during construction. Table 5.2-7 provides the maximum daily emissions
of criteria air pollutants from construction of the Project assuming that each piece of construction equipment
would operate 8 hours per day, which is a conservative assumption that all equipment would be operating
throughout the entire workday. As shown, the daily emissions resulting from Project construction would not
exceed any of the SCAQMD thresholds. Thus, construction impacts would be less than significant.
Table 5.2-7: Maximum Peak Daily Construction Emissions
Year Emissions (lbs/day)
VOC NOx CO SOx PM10 PM2.5
Summer
2026 5.27 44.44 49.61 0.09 6.93 3.82
2027 14.02 19.39 28.36 0.05 1.38 0.82
Winter
2026 1.34 11.82 15.86 0.03 0.84 0.50
2027 14.02 19.41 28.05 0.05 1.38 0.82
Maximum Daily Emissions 14.02 44.44 49.61 0.09 6.93 3.82
SCAQMD Regional Threshold 75 100 550 150 150 55
Threshold Exceeded? No No No No No No
VOC = volatile organic compounds, NOx = nitrogen oxides, CO = carbon monoxide, SOx = sulfur oxides, PM10 = particulate
matter 10 microns in diameter, PM2.5 = particulate matter 2.5 microns in diameter
Source: Air Quality Impact Analysis, Appendix B.
Operation
Implementation of the proposed Project would result in long-term regional emissions of criteria air pollutants
and ozone precursors associated with area sources, such as natural gas consumption, landscaping,
applications of architectural coatings; consumer products from operation of the proposed amenity clubhouse,
athlete accommodations, and the surf lagoon. Additionally, the Project would utilize four Lochinvar FBN6001
boilers for pool and spa heating, each rated at 6.0 million British thermal units (MMBtu), which would
generate emissions. The Project also involves both the removal of existing trees and the addition of new
trees, which changes carbon sequestration. Mature trees store substantial carbon, and their removal can lead
to immediate emissions and reduced sequestration capacity. Conversely, while young trees initially sequester
less carbon, they can contribute significantly over time as they grow. The carbon sequestration associated
with the Project was also calculated by CalEEMod.
Operation of the proposed Project would include emissions from vehicles traveling to and from the surf park.
As described in Section 5.14, Transportation, the proposed Project would generate 186 “net” new daily
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-24
Draft EIR
May 2025
trips, with 73 fewer trips in the a.m. peak hour and 10 fewer trips in the p.m. peak hour. As detailed in the
air quality modeling completed for the Project (included as Appendix B), and summarized below in Table
5.2-8, Project operational activities would not exceed the numerical thresholds of significance established
by the SCAQMD for emissions of any criteria pollutant. As such, operational impacts would be less than
significant.
Table 5.2-8: Maximum Peak Daily Operational Emissions
Source Emissions (lbs/day)
VOC NOx CO SOx PM10 PM2.5
Summer
Mobile Source 4.98 3.62 42.68 0.11 11.06 2.85
Area Source 2.52 0.03 3.46 0.00 0.01 0.00
Energy Source 0.18 3.27 2.74 0.02 0.25 0.25
Sequestration -0.01 -0.04 0.00 -0.01 -0.03 -0.01
Project Maximum Daily Emissions 7.67 6.88 48.88 0.12 11.29 3.09
Holes to Remain 1.39 1.01 11.90 0.03 3.09 0.80
Total Maximum Daily Emissions 9.06 7.89 60.78 0.15 14.38 3.89
Existing -6.41 -4.32 -48.30 -0.13 -12.52 -3.23
Net New Total (Proposed – Existing) 2.65 3.57 12.48 0.02 1.86 0.66
SCAQMD Regional Threshold 55 55 550 150 150 55
Threshold Exceeded? No No No No No No
Winter
Mobile Source 4.94 3.94 39.62 0.11 11.06 2.85
Area Source 1.95 0.00 0.00 0.00 0.00 0.00
Energy Source 0.18 3.27 2.74 0.02 0.25 0.25
Sequestration -0.01 -0.04 0.00 -0.01 -0.03 -0.01
Project Maximum Daily Emissions 7.06 7.17 42.36 0.12 11.28 3.09
Holes to Remain 1.38 1.10 11.10 0.03 3.09 0.80
Total Maximum Daily Emissions 8.44 8.27 53.46 0.15 14.37 3.89
Existing -6.36 -4.68 -44.80 -0.12 -12.52 -3.23
Net New Total (Proposed – Existing) 2.08 3.59 8.66 0.03 1.85 0.66
SCAQMD Regional Threshold 55 55 550 150 150 55
Threshold Exceeded? No No No No No No
VOC = volatile organic compounds, NOx = nitrogen oxides, CO = carbon monoxide, SOx = sulfur oxides, PM10 = particulate
matter 10 microns in diameter, PM2.5 = particulate matter 2.5 microns in diameter
Source: Air Quality Impact Analysis, Appendix B.
IMPACT AQ-3: THE PROJECT WOULD NOT EXPOSE SENSITIVE RECEPTORS TO SUBSTANTIAL
POLLUTANT CONCENTRATIONS.
Less than Significant Impact.
Localized Emissions
As described previously and shown in Figure 5.2-1, the existing air quality receptors are located adjacent
to the Project site. Therefore, according to SCAQMD methodology, the LSTs for a receptor distance of 25
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-25
Draft EIR
May 2025
meters (82 feet) (the closest threshold) is used to evaluate LST emissions. The daily construction emissions
generated onsite by the proposed Project are evaluated against SCAQMD’s LSTs to determine whether the
emissions would cause or contribute to adverse localized air quality impacts.
The LST construction emissions for the proposed Project were modeled including compliance with SCAQMD
Rule 403 that would reduce PM air contaminants during construction. Additionally, the construction modeling
assumes that each piece of construction equipment would operate 8 hours per day, which is a conservative
assumption that all equipment would be operating throughout the entire workday.
Table 5.2-9 identifies the daily localized onsite emissions that are estimated to occur during construction of
the Project at a distance of 25-meters per SCAQMD methodology. As shown, emissions during the peak
construction activity would not exceed the SCAQMD’s localized significance thresholds. Therefore, localized
emissions impacts from construction would be less than significant.
Table 5.2-9: Localized Emissions from Peak Construction Activity
Peak Construction
CO NO2 PM10 PM2.5
Averaging Time
1-Hour 8-Hour 1-Hour 24-Hours 24-Hours
Peak Day Localized Emissions 0.03 0.01 1.68E-02 0.62 0.23
Background Concentration A 2.4 1.9 0.072
Total Concentration 2.43 1.91 0.09 0.62 0.23
SCAQMD Localized Significance Threshold 20 9 0.18 10.4 10.4
Threshold Exceeded? No No No No No
CO = carbon monoxide, NO2 = nitrogen dioxide, PM10 = particulate matter 10 microns in diameter, PM2.5 = particulate matter
2.5 microns in diameter.
A Highest concentration from the last three years of available data.
PM10 and PM2.5 concentrations are expressed in µg/m3. All others are expressed in ppm.
Source: Air Quality Impact Analysis, Appendix B.
CO Hotspots
A CO hotspot is defined as a localized concentration of carbon monoxide exceeding the State 1-hour
standard of 20 ppm or the 8-hour standard of 9 ppm. The Air Quality Impact Analysis for the Project
(Appendix B) details that the information from the 2003 AQMP provides that even at one of the busiest
intersections, only 0.7 ppm of CO is attributable to vehicular traffic and the remaining 7.7 ppm were due to
ambient background conditions. As shown in Table 5.2-2, the background 1-hour and 8-hour concentrations
are well below the applicable ambient air quality standards. In addition, Section 5.14, Transportation, details
that the proposed Project would generate 73 fewer trips in the a.m. peak hour and 10 fewer trips in the
p.m. peak hour than the existing condition, which would lower vehicular CO concentrations at intersections
compared to the existing condition. Therefore, no impacts related to CO hotspots would occur with
implementation of the Proposed Project.
IMPACT AQ-4: THE PROJECT WOULD NOT RESULT IN OTHER EMISSIONS (SUCH AS THOSE LEADING
TO ODORS) ADVERSELY AFFECTING A SUBSTANTIAL NUMBER OF PEOPLE.
Less than Significant Impact.
The proposed Project would not emit other emissions, such as those generating objectionable odors, that
would affect a substantial number of people. The threshold for odor is identified by SCAQMD Rule 402,
Nuisance, which states:
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-26
Draft EIR
May 2025
A person shall not discharge from any source whatsoever such quantities of air contaminants
or other material which cause injury, detriment, nuisance, or annoyance to any considerable
number of persons or to the public, or which endanger the comfort, repose, health or safety
of any such persons or the public, or which cause, or have a natural tendency to cause, injury
or damage to business or property. The provisions of this rule shall not apply to odors
emanating from agricultural operations necessary for the growing of crops or the raising of
fowl or animals.
The type of facilities that are considered to result in other emissions, such as objectionable odors, include
wastewater treatments plants, compost facilities, landfills, solid waste transfer stations, fiberglass
manufacturing facilities, paint/coating operations (e.g., auto body shops), dairy farms, petroleum refineries,
asphalt batch plants, chemical manufacturing, and food manufacturing facilities.
The proposed Project would remove the existing golf related facilities and buildings and develop the site
with a new surf lagoon park with, retail, restaurant, and accommodations. These land uses do not involve the
types of uses that would emit objectionable odors affecting a substantial number of people. In addition,
odors generated by non-residential land uses are required to be in compliance with SCAQMD Rule 402,
which would prevent nuisance odors.
During construction, emissions from construction equipment, architectural coatings, and paving activities may
generate odors. However, these odors would be temporary, intermittent in nature, limited to the City’s
allowable construction hours, and would not affect a substantial number of people. Any odors would be
confined to the immediate vicinity of the construction equipment. Also, the short-term construction-related
odors would cease upon the drying or hardening of the odor-producing materials.
In addition, all Project-generated solid waste would be stored in covered containers and removed at regular
intervals in compliance with solid waste regulations and would not generate objectionable odors. Therefore,
impacts associated with other operation- and construction-generated emissions, such as odors, would be less
than significant.
5.2.7 CUMULATIVE IMPACTS
The geographic area for analysis of cumulative air quality impacts is the Basin. As described previously, per
SCAQMD’s methodology, if an individual project would result in air emissions of criteria pollutants that
exceeds the SCAQMD’s thresholds for project-specific impacts, then it would also result in a cumulatively
considerable net increase of these criteria pollutants.
As described previously in Impacts AQ-2 and AQ-3, construction and operation of the proposed Project
would not exceed any of the SCAQMD thresholds of significance. Therefore, Project emissions would not be
cumulatively considerable, and impacts would be less than significant.
5.2.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES
The following would reduce potential impacts related to air quality.
Existing Regulations
• California Green Building Standards Code (Code of Regulations, Title 24 Part 11)
• SCAQMD Rule 401: Visible Emissions
• SCAQMD Rule 402: Nuisance Odors
• SCAQMD Rule 403: Fugitive Dust
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-27
Draft EIR
May 2025
• SCAQMD Rule 445: Wood Burning Devices
• SCAQMD Rule 481: Spray Coating
• SCAQMD Rule 1108: Volatile Organic Compounds
• SCAQMD Rule 1113: Architectural Coatings
• SCAQMD Rule 1143: Paint Thinners and Solvents
• Municipal Code Chapter 15.19, Electric Vehicle Charging Stations
Plans, Programs, or Policies
None.
5.2.9 PROJECT DESIGN FEATURES
None.
5.2.10 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Impacts AQ-1 through AQ-4 would be less than significant.
5.2.11 MITIGATION MEASURES
No mitigation measures are required.
5.2.12 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts would be less than significant.
5.2.13 REFERENCES
City of Newport Beach. (2001, January). Santa Ana Heights Specific Plan. Retrieved September 23, 2024,
from ocpublicworks.com.
City of Newport Beach. (2006a, July). General Plan. Retrieved September 23, 2024, from
newportbeachca.gov: https://www.newportbeachca.gov/government/departments/community-
development/planning-division/general-plan-codes-and-regulations/general-plan
City of Newport Beach. (2006b, July). General Plan Environmental Impact Report. Retrieved September 23,
2024, from newportbeachca.gov:
https://www.newportbeachca.gov/government/departments/community-development/planning-
division/general-plan-codes-and-regulations/general-plan/general-plan-environmental-impact-
repor
City of Newport Beach. (2024, May). Newport Beach Municipal Code. Retrieved September 23, 2024,
from codepublishing.com: https://www.codepublishing.com/CA/NewportBeach/
Urban Crossroads. (2025). Surf Farm Air Quality Impact Analysis. (Appendix B)
Snug Harbor Surf Park Project 5.2 Air Quality
City of Newport Beach 5.2-28
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 5.3 Biological Resources
City of Newport Beach 5.3-1
Draft EIR
May 2025
5.3 Biological Resources
5.3.1 INTRODUCTION
This section describes the biological resources conditions in the Project region and potential impacts from
Project implementation. The analysis in this section is based, in part, on the following documents and resources:
• City of Newport Beach General Plan, 2006
• City of Newport Beach General Plan Environmental Impact Report (General Plan EIR), 2006
• City of Newport Beach Municipal Code
• Biological Technical Report for the Snug Harbor Project, prepared by Glenn Lukos Associates, Inc.,
included as Appendix C
5.3.2 REGULATORY SETTING
5.3.2.1 Federal Regulations
Federal Endangered Species Act
The Federal Endangered Species Act (FESA) of 1973 defines an endangered species as “any species which
is in danger of extinction throughout all or a significant portion of its range.” A threatened species is defined
as “any species which is likely to become an Endangered species within the foreseeable future throughout
all or a significant portion of its range.” Under provisions of Section 9(a)(1)(B) of the FESA, unless properly
permitted, it is unlawful to “take” any endangered or threatened listed species. “Take” is defined in Section
3(18) of FESA as: “harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to
engage in any such conduct.” Further, the United States Fish and Wildlife Service (USFWS), through
regulation, has interpreted the terms “harm” and “harass” to include certain types of habitat modification as
forms of “take.” These interpretations, however, are generally considered and applied on a case-by-case
basis and often vary from species to species. In a case where a property owner seeks permission from a
federal agency for an action which could affect a federally listed plant or animal species, the property
owner and agency are required to consult with the USFWS pursuant to Section 7 of the FESA if there is a
federal nexus, or consult with the USFWS and potentially obtain a permit pursuant to Section 10 of the FESA
in the absence of a federal nexus. Section 9(a)(2)(b) of the FESA addresses the protections afforded to listed
plants.
Migratory Bird Treaty Act
The Migratory Bird Treaty Act (MBTA) (United States Code Title 33, Section 703 et seq.; see also Code of
Federal Regulations Title 50, Part 10) protects individuals as well as any part, nest, or eggs of any bird
listed as migratory. In practice, federal permits issued for activities that potentially impact migratory birds
typically have conditions that require pre-disturbance surveys for nesting birds. In the event nesting is
observed, a buffer area with a specified radius must be established, within which no disturbance or intrusion
is allowed until the young have fledged and left the nest, or it has been determined that the nest has failed.
If not otherwise specified in the permit, the size of the buffer area varies with species and local circumstances
(e.g., presence of busy roads, intervening topography, etc.), and is based on the professional judgment of a
monitoring biologist. A list of migratory bird species protected under the MBTA is published by the USFWS.
Snug Harbor Surf Park Project 5.3 Biological Resources
City of Newport Beach 5.3-2
Draft EIR
May 2025
5.3.2.2 State Regulations
California Endangered Species Act
Under the California Endangered Species Act (CESA) (Fish and Game Code § 2050 et seq.), California
Species of Special Concern are species designated as vulnerable to extinction due to declining population
levels, limited ranges, and/or continuing threats. Informally listed species are not protected per se but
warrant consideration in the preparation of biological resource assessments. For some species, the CESA is
only concerned with specific portions of the life history, such as roosts, rookeries, or nest areas. The California
Department of Fish and Wildlife (CDFW) administers the CESA and enforces relevant statutes from the
California Fish and Game Code and Title 14 of the California Code of Regulations.
California Rare Plant Ranks (CRPR)
The California Native Plant Society (CNPS) maintains a list of special-status plant species based on collected
scientific information. Although the CNPS’s designations have no legal status or protection under federal or
state endangered species legislation (CNPS 2015), three designations meet the criteria of Section 15380
of the State CEQA Guidelines—CRPR 1A, plants presumed extinct; CRPR 1B, plants rare, threatened, or
endangered in California and elsewhere; and CRPR 2, plants rare, threatened, or endangered in California,
but more numerous elsewhere.
California Fish and Game Code, Sections 3503.5, 3511, 3515
Section 3503.5 of the California Fish and Game Code states that it is “unlawful to take, possess, or destroy
any birds in the order Falconiformes or Strigiformes (birds of prey) or to take, possess, or destroy the nest
or eggs of any such bird except as otherwise provided by this code or any regulation adopted pursuant
thereto.” Activities that result in the abandonment of an active bird of prey nest may also be considered in
violation of this code. In addition, California Fish and Game Code, Section 3511 prohibits the taking of any
bird listed as fully protected, and California Fish and Game Code, Section 3515 states that is it unlawful to
take any non-game migratory bird protected under the MBTA.
Native Plant Protection Act of 1977
This act (Fish and Game Code § 1900 et seq.) directed the CDFW to “preserve, protect and enhance rare
and endangered plants in this State.” It gave the California Fish and Game Commission the power to
designate native plants as “endangered” or “rare” and protect endangered and rare plants from take. The
CESA, which came later, entered all “rare” animals as “threatened” species, but not rare plants. Thus, there
are three listings for plants in California: rare, threatened, and endangered. Because rare plants are not
included in the CESA, mitigation measures for impacts to rare plants are specified in a formal agreement
between the CDFW and the project proponent.
5.3.2.3 Local and Regional Regulations
Orange County Central/Coastal NCCP/HCP
The Project site is located within the Orange County Central/Coastal Natural Community Conservation
Plan/Habitat Conservation Plan (NCCP/HCP). The NCCP permit was issued by the California Department
of Fish and Wildlife (formerly the California Department of Fish and Game) in July 1996 and has a term of
75 years. The Implementation Agreement specifically authorizes disturbance of coastal sage scrub and take
of covered species within the Central/Coastal NCCP Subregion. The NCCP Reserve System adaptive
management program and other measures of the NCCP/HCP fully mitigate take of coastal sage scrub and
Snug Harbor Surf Park Project 5.3 Biological Resources
City of Newport Beach 5.3-3
Draft EIR
May 2025
disturbance of covered habitats resulting from development projects in compliance with the Implementation
Agreement. Direct, indirect, and cumulative impacts under CEQA and NEPA to the covered habitats and
covered species, except for conditionally covered species, resulting from development within designated
development areas owned by NCCP participating landowners are fully mitigated by the measures of the
NCCP/HCP.
City of Newport Beach General Plan 2006
The City of Newport Beach General Plan contains the following policies related to biological resources that
are applicable to the Project:
LU 1.3 Natural Resources. Protect the natural setting that contributes to the character and identify
of Newport Beach and the sense of place it provides for its residents and visitors. Preserve
open space resources, beaches, harbor, parks, bluffs, preserves, and estuaries as visual,
recreational and habitat resources.
LU 3.7 Natural Resource and Hazardous Areas. Require that new development is located and
designed to protect areas with high natural resource value and protect residents and visitors
from threats to life or property.
NR 10.2 Orange County Natural Communities Conservation Plan. Comply with the policies
contained within the Orange County Natural Communities Conservation Plan.
NR 10.3 Analysis of Environmental Study Areas. Require a site-specific survey and analysis
prepared by a qualified biologist as a filing requirement for any development permit
applications where development would occur within or contiguous to areas identified as
ESAs.
NR 10.4 New Development Siting and Design. Require that the siting and design of new
development, including landscaping and public access, protect sensitive or rare resources
against any significant disruption of habitat values.
NR 10.5 Development in Areas Containing Significant or Rare Biological Resources. Limit uses
within an area containing any significant or rare biological resources to only those uses that
are dependent on such resources, except where application of such a limitation would result
in a taking of private property. If application of this policy would likely constitute a taking
of private property, then a non-resource-dependent use shall be allowed on the property,
provided development is limited to the minimum amount necessary to avoid a taking and
the development is consistent with all other applicable resource protection policies. Public
access improvements and educational, interpretative and research facilities are considered
resource dependent uses.
NR 10.6 Use of Buffers. Maintain a buffer of sufficient size around significant or rare biological
resources, if present, to ensure the protection of these resources. Require the use of native
vegetation and prohibit invasive plant species within these buffer areas.
NR 10.7 Exterior Lighting. Shield and direct exterior lighting away from significant or rare
biological resources to minimize impacts to wildlife.
Newport Beach City Council Policy Manual
Policy G-1: Retention, Removal, and Maintenance of City Trees. This policy establishes standards for the
retention, removal, maintenance, reforestation, tree trimming standards, and supplemental trimming of City
Snug Harbor Surf Park Project 5.3 Biological Resources
City of Newport Beach 5.3-4
Draft EIR
May 2025
trees. The policy provides definitions of certain trees that should be protected and provisions for the removal
of such trees.
City of Newport Beach Municipal Code
Chapter 7.26: Protection of Natural Habitat for Migratory and Other Waterfowl. This Newport Beach
Municipal Code chapter recognizes the important natural habitat within the Newport Bay for migratory
waterfowl and other birds. The chapter further prohibits incubation of eggs produced by waterfowl and
feeding of waterfowl.
Chapter 13.08: Planting. Municipal Code Chapter 13.08 strives to control the planting, maintenance, and
removal of trees, shrubs, and plants in all public areas under the City’s control. Trees may not be trimmed,
cut down, damaged, removed, or destroyed from any public right-of-way, without prior written authorization
from the City Manager.
Chapter 21.30B: Habitat Protection. This Newport Beach Municipal Code chapter sets forth requirements
for site biological surveys for certain development projects, including those requiring a coastal development
permit; those within 100 feet of an Environment Study Area (ESA) in the Coastal Land Use Plan; those with
sites containing southern coastal foredune or southern dune scrub habitats; those containing or within 100
feet of a delineated wetland, designated Environmentally Sensitive Habitat Area (ESHA); ESHA buffer; or
wetland buffer; or those containing or within 100 feet of a habitat area where there is substantial evidence
of the presence of a wetland or ESHA. In addition, the chapter sets forth protection requirements for ESHAs,
wetlands, and coastal dunes. The chapter sets forth required mitigation ratios for disturbance to multiple
habitat types.
5.3.3 ENVIRONMENTAL SETTING
The Project site is currently developed with a driving range, putting green, pro shop and restaurant, service
building, surface parking lot, and three holes of the existing NB Golf Course. Vegetation consists of
ornamental turf, shrubs, and trees with no remnant native vegetation. The National Cooperative Soil Survey
has mapped the following soils as occurring within the Project site: Myford sandy loam, 2 to 9 percent slopes;
Myford sandy loam, 9 to 15 percent slopes; Myford sandy loam, thick surface, 0 to 2 percent slopes; and
thapto-histic fluvaquents (Appendix C).
5.3.3.1 Vegetation Communities
Two different vegetation/land covers were identified within the Project site. As shown on Figure 5.3-1, the
Project site contains approximately 6.04 acres of turf grass/ornamental landscaping. In addition, the Project
site and offsite improvement areas contain approximately 9.48 acres of disturbed/developed area with
9.4 acres being onsite and 0.08-acre being offsite.
The golf course fairways and greens are primarily vegetated with manicured turn grasses including
bermudagrass (Cynodon dactylon) and Saint Augustine grass (Stenotaphrum secundatum), along with other
weedy non-native grasses and forbs including Dallis grass (Paspalum dilatatum) and bur clover (Medicago
polymorpha). Ornamental trees occur throughout the area, including Aleppo pine (Pinus halepensis), lemon
scented gum (Eucalyptus citriodora), shamel ash (Fraxinus uhdei), and whiteflower kurrajong (Brachychiton
populneum). Along the northwestern property boundary adjacent to the Santa Ana Delhi Channel are a few
disjunct patches of iceplant (Carpobrotus edulis) growing with Mexican fan palm (Washingtonia robusta).
Other component species include yellow nutgrass (Cyperus esculentus), flax-leaved horseweed (Erigeron
bonariensis), Canada horseweed (Erigeron canadensis), bristly ox-tongue (Helminthotheca echioides), spiny
sowthistle (Sonchus asper), common sowthistle (Sonchus oleraceus), cape honeysuckle (Tecoma capensis),
Snug Harbor Surf Park Project
City of Newport Beach
Ki
r
b
y
S
t
Ram ona ExpySobobaRdRamona Expy
Av
e
SobobaRdState
S
t
P
al
m
Cottonwood Ave
S
o
b
o
b
a
R
d
StateSt
Main St
Lyon Ave
Ca
w
s
t
o
n
A
v
e
7th St
Ramona Blvd Camino
l
o
s
B
a
n
o
s
Record RdOdell AveSanderson AveDeegan
S
t
Young StPotterRdWarren RdRamona
E
x
p
y
L a k e P ark D r79
Pa
l
m
A
v
e
Co
l
u
m
b
i
a
S
t
Ki
r
b
y
S
t
Gilman
S
p
r
i
n
g
s
R
d
St
a
t
e
S
t
Ly
o
n
A
v
e
Sa
n
d
e
r
s
o
n
A
v
e
Oakland
79
79 Zoning Map 2022
H E M E T
B E A U M O N T
0 1½
Miles
SanJacintoRiver SanJacintoRiver LegendSan Jacinto City LimitsSan Jacinto Sphere of InfluenceNeighboring CitySpecific Plan AreaRAAB Combining Overlay ZoneHousing OverlayResidential ZonesRE - Residential EstateRR - Rural ResidentialRL - Residential, Low DensityRM - Residential, Medium DensityRH - Residential, High DensityRVH - Residential, Very High DensityCommercial and Industrial ZonesCN - Commercial NeighborhoodCG - Commercial GeneralCR - Commercial RegionalBP - Business ParkOP - Office ParkIL - Industrial LightIH - Industrial HeavyMixed Use ZonesMU - Mixed UseMU-E - Mixed Use - EntertaintainmentDV - Downtown VillageSpecial Purpose ZonesOSG - Open Space GeneralOSR - Open Space RecreationPI - Public InstitutionalSP - Specific PlanW - Water SourceTRAILS SPSP 01-03VILLAGES SPSP 01-04COVE SPSP 01-01
ESPLANADE SP
SP 01-02
SOBOBASPRINGS SPSP 01-85 November 15, 2022
Ki
r
b
y
S
t
M
o
u
n
t
ai
n
A
ve
Ramona
E
x
p
y
Washington
A
v
e
Cottonwood Ave
Esplanade Ave
S
o
b
o
b
a
R
d
Menlo Ave
He
w
i
t
t
S
t
ParkAve
Commonwealth
Ca
ws
t
o
n
A
v
e
7th St 7th St
Od
e
l
l
A
v
e
Sa
n
d
e
r
s
o
n
A
v
e
Deegan
S
t
Wa
r
r
e
n
R
d
Ramona
E
x
p
y
R
a
m
o
na
Ex
p
y
Pa
l
m
A
v
e
Co
l
u
m
b
i
a
S
t
Ki
r
b
y
S
t
G
i
l
m
a
St
a
t
e
S
t
Ly
o
n
A
v
e
Sa
n
d
e
r
s
o
n
A
v
e
Oakland Ave
79
79
Zoning Map 2022
H E M E T
0 1½
Miles
SanJacintoRiver
VILLAGES SP
SP 01-04
COVE SP
SP 01-01
ESPLANADE SP
SP 01-02
RANCHO
SAN JACINTO SP
SP 01-00
)eet
$eriaO Source NearPap 0ay
CoorGinate SyVteP State POane N$'
Projection /aPbert ConforPaO Conic
'atuP N$'
0ap PrepareG by B *aOe */$
'ate PrepareG 'ecePber
1 inch = 125 feet
Text
Irvine
A
v
e
n
u
e
M
e
s
a
D
r
i
v
e
SW
A
c
a
c
i
a
S
t
r
e
e
t
Project 2nVite
Project 2ffVite
7urf *raVV2rnaPentaO
'iVturbeG'eYeOopeG
Project Site Vegetation
Figure 5.3-1
Snug Harbor Surf Park Project 5.3 Biological Resources
City of Newport Beach 5.3-6
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 5.3 Biological Resources
City of Newport Beach 5.3-7
Draft EIR
May 2025
Virgina pepperweed (Lepidium virginicum), Australian saltbush (Atriplex semibaccata), alkali weed (Cressa
truxillensis), Asian ponysfoot (Dichondra micrantha), rattlesnake sandmat (Euphorbia albomarginata), bird’s
foot trefoil (Lotus corniculatus), shoeblackplant (Hibiscus rosa-sinensis), cheeseweed mallow (Malva parviflora),
common plantain (Plantago major), prostrate knotweed (Polygonum aviculare), curly dock (Rumex crispus),
Italian cypress (Cupressus sempervirens), Canary Island pine (Pinus canariensis), red-box gum (Eucalyptus
polyanthemos), and Japanese privet (Ligustrum japonicum).
The disturbed/developed areas contain a paved parking lot, a driving range with synthetic turf, other golf
course structures and amenities including a pro shop and restaurant, and a graded slope vegetated with
both ruderal and ornamental vegetation. Integrated planters within the parking lot contain olives (Olea
europaea), Mexican fan palm, queen palm (Syagrus romanzoffiana), whiteflower kurrajong, lemon scented
gum, blue gum (Eucalyptus globulus), and brush box (Lophostemon confertus). A graded slope on the
northeastern edge of the Property supports both ruderal and ornamental vegetation, including Canary Island
pine (Pinus canariensis), Aleppo pine, lemon scented gum, slender oat (Avena barbata), iceplant, prickly lettuce
(Lactuca serriola), Mexican fan palm, carrotwood (Cupaniopsis anacardioides), and a single coast live oak
(Quercus agrifolia). Other component species include sago palm (Cycas revoluta), pygmy date palm (Phoenix
roebelenii), purple fountain grass (Pennisetum setaceum ‘Rubrum’), plumeria (Plumeria rubra), spider plant
(Chlorophytum comosum), Russian thistle, aeonium (Aeonium sp.), echeveria (Echeveria sp.), jade plant
(Crassula ovata), elephant bush (Portulacaria afra), and Brazilian pepper tree (Schinus terebinthifolia)
(Appendix C).
5.3.3.2 Special-Status Vegetation Communities
The California Natural Diversity Data Base (CNDDB) identifies the following seven special-status vegetation
communities for the Newport Beach, Seal Beach, Laguna Beach, Tustin, Orange, Anaheim, and Los Alamitos
quadrangle maps: southern dune scrub, southern foredunes, valley needlegrass grassland, southern coastal
salt marsh, southern sycamore alder riparian woodland, southern coast live oak riparian forest, and
California walnut woodland. The Project site does not contain any special-status vegetation communities,
including those identified by the CNDDB (Appendix C).
5.3.3.3 Special-Status Plant Species
According to the CNDDB and CNPS, 36 special-status plant species have been recorded in the Newport
Beach, Seal Beach, Laguna Beach, Tustin, Orange, Anaheim, and Los Alamitos quadrangles. No special-status
plant species were observed onsite during the field investigation conducted for the Biological Technical
Report. The site has been subject to decades of anthropogenic disturbances, which has removed native plant
communities that have historically occurred. Based on the habitat requirements for the specific species with
potential to exist in the quadrangles and the quality of the onsite habitat, the Biological Technical Report
determined that the Project site and offsite improvement areas do not have potential to support any of the
special-status plant species known to occur in the vicinity of the site and all are presumed to be absent, as
shown in Table 5.3-1.
Table 5.3-1: Special-Status Plant Species Probability List
Species Name Status Habitat Potential to Occur
Allen’s pentachaeta
Pentachaeta aurea ssp. allenii
Federal: None
State: None
CRPR: Rank 1B.1
NCCP/HCP: Not covered
Openings in coastal
sage scrub, and valley
and foothill grasslands
Does not occur
Aphanisma
Aphanisma blitoides
Federal: None
State: None
Sandy soils in coastal
bluff scrub, coastal
Does not occur
Snug Harbor Surf Park Project 5.3 Biological Resources
City of Newport Beach 5.3-8
Draft EIR
May 2025
Species Name Status Habitat Potential to Occur
CRPR: Rank 1B.2
NCCP/HCP: Not covered
dunes, and coastal
scrub.
Big-leaved crownbeard
Verbesina dissita
Federal: FT
State: ST
CRPR: Rank 1B.1
NCCP/HCP: Not covered
Southern maritime
chaparral, coastal sage
scrub
Does not occur
Brand's star phacelia
Phacelia stellaris
Federal: None
State: None
CRPR: Rank 1B.1
NCCP/HCP: Not covered
Coastal dunes and
coastal sage scrub.
Does not occur
California Orcutt grass
Orcuttia californica
Federal: FE
State: SE
CRPR: Rank 1B.1
NCCP/HCP: Not covered
Vernal pools Does not occur
Chaparral ragwort Senecio
aphanactis
Federal: None
State: None
CRPR: Rank 2B.2
NCCP/HCP: Not covered
Chaparral, cismontane
woodland, coastal
scrub. Sometimes
associated with alkaline
soils.
Does not occur
Chaparral sand-verbena
Abronia villosa var. aurita
Federal: None
State: None
CRPR: Rank 1B.1
NCCP/HCP: Not covered
Sandy soils in
chaparral, coastal sage
scrub.
Does not occur
Cliff spurge Euphorbia misera Federal: None
State: None
CRPR: Rank 2B.2
NCCP/HCP: Covered
Coastal bluff scrub and
coastal sage scrub.
Occurring on rocky soils.
Does not occur
Coast woolly-heads
Nemacaulis denudata var.
denudata
Federal: None
State: None
CRPR: Rank 1B.2
NCCP/HCP: Not covered
Coastal dunes Does not occur
Coulter's goldfields Lasthenia
glabrata ssp. coulteri
Federal: None
State: None
CRPR: Rank 1B.1
NCCP/HCP: Not covered
Playas, vernal pools,
marshes and swamps
(coastal salt).
Does not occur
Coulter's saltbush Atriplex
coulteri
Federal: None
State: None
CRPR: Rank 1B.2
NCCP/HCP: Not covered
Coastal bluff scrub,
coastal dunes, coastal
sage scrub, valley and
foothill grassland.
Occurring on alkaline or
clay soils.
Does not occur
Davidson's saltscale Atriplex
serenana var. davidsonii
Federal: None
State: None
CRPR: Rank 1B.2
NCCP/HCP: Not covered
Alkaline soils in coastal
sage scrub, coastal
bluff scrub.
Does not occur
Decumbent goldenbush
Isocoma menziesii var.
decumbens
Federal: None State: None
CRPR: Rank 1B.2
NCCP/HCP: Not covered
Chaparral, coastal
scrub (sandy, often in
disturbed areas)
Does not occur
Estuary seablite Suaeda
esteroa
Federal: None
State: None
CRPR: Rank 1B.2
NCCP/HCP: Not covered
Coastal salt marsh and
swamps. Occurring in
sandy soils
Does not occur
Intermediate mariposa-lily
Calochortus weedii var.
intermedius
Federal: None
State: None
CRPR: Rank 1B.2
Rocky soils in chaparral,
coastal sage scrub,
Does not occur
Snug Harbor Surf Park Project 5.3 Biological Resources
City of Newport Beach 5.3-9
Draft EIR
May 2025
Species Name Status Habitat Potential to Occur
NCCP/HCP: Covered valley and foothill
grassland.
Laguna Beach dudleya
Dudleya stolonifera
Federal: FT
State: ST
CRPR: Rank 1B.1
NCCP/HCP: Covered
Chaparral, cismontane
woodland, coastal sage
scrub, valley and
foothill grassland.
Occurring on rocky soils.
Does not occur
Los Angeles sunflower
Helianthus nuttallii ssp.
parishii
Federal: None
State: None
CRPR: Rank 1A
NCCP/HCP: Not covered
Marshes and swamps
(coastal salt and
freshwater).
Does not occur
Lucky morning-glory
Calystegia felix
Federal: None
State: None
CRPR: Rank 1B.1
NCCP/HCP: Not covered
Historically associated
with wetland and
marshy places, but
possibly in drier
situations as well.
Possibly silty loam and
alkaline soils. Meadows
and seeps (sometimes
alkaline), riparian scrub
(alluvial).
Does not occur
Many-stemmed dudleya
Dudleya multicaulis
Federal: None
State: None
CRPR: Rank 1B.2
NCCP/HCP: Not covered
Chaparral, coastal
sage scrub, valley and
foothill grassland.
Often occurring in clay
soils.
Does not occur
Mesa horkelia Horkelia
cuneata var. puberula
Federal: None
State: None
CRPR: Rank 1B.1
NCCP/HCP: Not covered
Sandy or gravelly soils
in chaparral (maritime),
cismontane woodland,
and coastal scrub.
Does not occur
Mud nama Nama
stenocarpum
Federal: None
State: None
CRPR: Rank 2B.2
NCCP/HCP: Not covered
Marshes and swamps Does not occur
Nuttall's scrub oak Quercus
dumosa
Federal: None
State: None
CRPR: Rank 1B.1
NCCP/HCP: Covered
Closed-cone coniferous
forest, chaparral, and
coastal sage scrub.
Occurring on sandy,
clay loam soils.
Does not occur
Orcutt's pincushion
Chaenactis glabriuscula var.
orcuttiana
Federal: None
State: None
CRPR: Rank 1B.1
NCCP/HCP: Not covered
Coastal bluff scrub
(sandy soils) and
coastal dunes.
Does not occur
Parish's brittlescale Atriplex
parishii
Federal: None
State: None
CRPR: Rank 1B.1
NCCP/HCP: Not covered
Chenopod scrub,
playas, vernal pools.
Does not occur
Prostrate vernal pool
navarretia Navarretia
prostrata
Federal: None
State: None
CRPR: Rank 1B.2
NCCP/HCP: Not covered
Coastal sage scrub,
valley and foothill
grassland (alkaline),
vernal pools. Occurring
in mesic soils.
Does not occur
Snug Harbor Surf Park Project 5.3 Biological Resources
City of Newport Beach 5.3-10
Draft EIR
May 2025
Species Name Status Habitat Potential to Occur
Robinson's pepper grass
Lepidium virginicum var.
robinsonii
Federal: None
State: None
CRPR: Rank 4.3
NCCP/HCP: Not covered
Chaparral, coastal
sage scrub
Does not occur
Salt marsh bird's-beak
Chloropyron maritimum ssp.
maritimum
Federal: FE
State: SE
CRPR: Rank 1B.2
NCCP/HCP: Not covered
Coastal dune, coastal
salt marshes and
swamps.
Does not occur
Salt Spring checkerbloom
Sidalcea neomexicana
Federal: None
State: None
CRPR: Rank 2B.2
NCCP/HCP: Not covered
Mesic, alkaline soils in
chaparral, coastal sage
scrub, lower montane
coniferous forest,
Mojavean desert scrub,
and playas.
Does not occur
San Bernardino aster
Symphyotrichum defoliatum
Federal: None
State: None
CRPR: Rank 1B.2
NCCP/HCP: Not covered
Cismontane woodland,
coastal scrub, lower
montane coniferous
forest, meadows and
seeps, marshes and
swamps, valley and
foothill grassland
(vernally mesic).
Does not occur
San Diego button-celery
Eryngium aristulatum var.
parishii
Federal: FE
State: SE
CRPR: Rank 1B.1
NCCP/HCP: Not covered
Mesic soils in vernal
pools, valley and
foothill grasslands,
coastal sage scrub.
Does not occur
Sanford's arrowhead
Sagittaria sanfordii
Federal: None
State: None
CRPR: Rank 1B.2
NCCP/HCP: Not covered
Marshes and swamps
(assorted shallow
freshwater).
Does not occur
Santa Ana River woolly star
Eriastrum densifolium ssp.
sanctorum
Federal: FE
State: SE
CRPR: Rank 1B.1
NCCP/HCP: Not covered
Alluvial fan sage scrub,
chaparral. Occurring on
sandy or rocky soils.
Does not occur
South coast saltscale Atriplex
pacifica
Federal: None
State: None
CRPR: Rank 1B.2
NCCP/HCP: Not covered
Coastal bluff scrub,
coastal dunes, coastal
sage scrub, playas.
Does not occur
Southern tarplant
Centromadia parryi ssp.
australis
Federal: None
State: None
CRPR: Rank 1B.1
NCCP/HCP: Not covered
Disturbed habitats,
margins of marshes and
swamps, vernally mesic
valley and foothill
grassland, vernal pools.
Does not occur
Summer holly
Comarostaphylis diversifolia
ssp. diversifolia
Federal: None
State: None
CRPR: Rank 1B.2
NCCP/HCP: Not covered
Chaparral. Does not occur
Ventura Marsh milk-vetch
Astragalus pycnostachyus var.
lanosissimus
Federal: FE
State: SE
CRPR: Rank 1B.1
NCCP/HCP: Not covered
Coastal dunes, coastal
scrub, marshes and
swamps (edges, coastal
salt or brackish)
Does not occur
Source: Appendix C
Snug Harbor Surf Park Project 5.3 Biological Resources
City of Newport Beach 5.3-11
Draft EIR
May 2025
5.3.3.4 Special-Status Wildlife Species
According to the CNDDB, 50 special-status wildlife species have been recorded in the Newport Beach, Seal
Beach, Laguna Beach, Tustin, Orange, Anaheim, and Los Alamitos quadrangles. No special-status animal
species were observed onsite during the field investigation conducted for the Biological Technical Report.
While not observed onsite during the general biological survey, great blue heron individuals may
occasionally occur onsite as a transient species but is not expected to occur onsite in a nesting colony due to
lack of suitable nesting trees and frequent human disturbance. Based on the focused surveys conducted within
the Project site, no overwintering monarch butterflies were detected in or around ornamental eucalyptus or
pine trees onsite. Further, the trees onsite occur individually and are not clustered in groves or exhibit the
microclimate typical for overwintering uses. As such, the Biological Technical Report concluded that
overwintering monarch butterflies are confirmed absent (Appendix C).
According to the Biological Technical Report, the western yellow bat has a low potential to roost in
ornamental trees, including palms, on the Project site; and the Big free-tailed bat is rare in southern California
– the only recorded Orange County occurrence in the CNDDB is from Corona del Mar in 1985, and if it
occurred, it would likely be a flyover/foraging and not roosting, as it typically roosts on cliffs. Further, the
Project site provides suitable foraging, breeding, and roosting habitat for a number of raptor species. No
raptor species were detected over the course of field studies; however, common, urban adapted species
may occasionally occur. The Project site lacks potential nesting habitat (e.g., mature trees, shrubs) for special-
status raptor species but is expected to provide marginal foraging habitat for common raptors that support
prey species such as insects, spiders, lizards, snakes, small mammals, and other birds.
The site has been subject to decades of anthropogenic disturbances, which has removed native habitat for
sensitive wildlife species. Based on the habitat requirements for the specific species with potential to exist in
the quadrangles and the quality of the onsite habitat, the Biological Technical Report (Appendix C)
determined that the Project site and offsite improvement areas do not have potential to support any of the
other special-status wildlife species known to occur in the vicinity of the site and all are presumed to be
absent, as shown in Table 5.3-2.
Table 5.3-2: Special-Status Wildlife Species Probability List
Species Name Status Habitat Potential to Occur
Invertebrates
American bumble bee
Bombus pensylvanicus
Federal: None
State: None
State Rank: S2
NCCP/HCP: Not covered
Coastal prairie, great
basin grassland, and
valley & foothill
grassland. Forages on a
wide variety of flowers
including vetches
(Vicia), clovers
(Trifolium), thistles
(Cirsium), sunflowers
(Helianthus), etc. Nests
above ground under
long grass or
underground. Queens
overwinter in rotten
wood or underground.
Does not occur
Crotch’s bumble bee
Bombus crotchii
Federal: None
State: SCE
State Rank: S2
NCCP/HCP: Not covered
Relatively warm and
dry sites, including the
inner Coast Range of
Not expected to occur
Snug Harbor Surf Park Project 5.3 Biological Resources
City of Newport Beach 5.3-12
Draft EIR
May 2025
Species Name Status Habitat Potential to Occur
California and margins
of the Mojave Desert.
Dorothy's El Segundo Dune
weevil
Trigonoscuta dorothea
dorothea
Federal: None
State: None
State Rank: S1
NCCP/HCP: Not covered
Sand dunes in El
Segundo, CA.
Does not occur
Globose dune beetle
Coelus globosus
Federal: None
State: None
State Rank: S1S2
NCCP/HCP: Not covered
Burrows under
vegetation in coastal
sand dunes
Does not occur
Mimic tryonia (California
brackishwater snail)
Tryonia imitator
Federal: None
State: None
State Rank: S2
NCCP/HCP: Not covered
Coastal areas with
brackish waters.
Does not occur
Monarch butterfly
(California overwintering
population)
Danaus plexippus pop. 1
Federal: FPT
State: None
State Rank: S2
NCCP/HCP: Not covered
Roosts in winter in wind-
protected tree groves
along the California
coast from northern
Mendocino to Baja
California, Mexico.
Overwintering
population confirmed
absent
Riverside fairy shrimp
Streptocephalus woottoni
Federal: FE
State: None
State Rank: S2
NCCP/HCP: Not covered
Restricted to deep
seasonal vernal pools,
vernal pool-like
ephemeral ponds, and
stock ponds.
Does not occur
San Diego fairy shrimp
Branchinecta sandiegonensis
Federal: FE
State: None
State Rank: S1
NCCP/HCP: Not covered
Seasonal vernal pools Does not occur
San Gabriel chestnut
Glyptostoma gabrielense
Federal: None
State: None
State Rank: S3
NCCP/HCP: Not covered
Semi-arid areas, most
often under rocks,
debris, logs or cactus in
low elevation hills
Does not occur
Wandering (=saltmarsh)
skipper Panoquina errans
Federal: None
State: None
State Rank: S2
NCCP/HCP: Not covered
Ocean bluffs and other
open areas near the
ocean.
Does not occur
Western beach tiger beetle
Cicindela latesignata
latesignata
Federal: None
State: None
State Rank: S1
NCCP/HCP: Not covered
Forages in open
unvegetated areas such
as marsh plannes and
levees. Larvae burrow
in moist unvegetated
substrates.
Does not occur
Western tidal-flat tiger
beetle
Habroscelimorpha gabbii
Federal: None
State: None
State Rank: S1
NCCP/HCP: Not covered
Open, unvegetated
areas in or near salt
marshes.
Does not occur
Fish
Santa Ana sucker Catostomus
santaanae
Federal: FT
State: None
State Rank: S1
NCCP/HCP: Not covered
Small, shallow streams,
less than 7 meters in
width, with currents
ranging from swift in
the canyons to sluggish
in the bottom lands.
Does not occur
Snug Harbor Surf Park Project 5.3 Biological Resources
City of Newport Beach 5.3-13
Draft EIR
May 2025
Species Name Status Habitat Potential to Occur
Preferred substrates
are generally coarse
and consist of gravel,
rubble, and boulders
with growths of
filamentous algae, but
occasionally they are
found on sand/mud
substrates.
Southern steelhead -
southern California DPS
Oncorhynchus mykiss irideus
pop. 10
Federal: FE
State: CE
State Rank: S1
NCCP/HCP: Not covered
Clear, swift moving
streams with gravel for
spawning. Federal
listing refers to
populations from Santa
Maria river south to
southern extent of
range (San Mateo
Creek in San Diego
county.)
Does not occur
Tidewater goby
Eucyclogobius newberryi
Federal: FE
State: SSC
State Rank: S3
NCCP/HCP: Not covered
Occurs in shallow
lagoons and lower
stream reaches along
the California coast
from Agua Hedionda
Lagoon, San Diego Co.
to the mouth of the
Smith River.
Does not occur
Amphibians
Western spadefoot
Spea hammondii
Federal: FPT
State: SSC
State Rank: S3S4
NCCP/HCP: Covered
Seasonal pools in
coastal sage scrub,
chaparral, and
grassland habitats.
Does not occur
Reptiles
Coast horned lizard
Phrynosoma blainvillii
Federal: None
State: SSC
State Rank: S4
NCCP/HCP: Covered
Occurs in a variety of
vegetation types
including coastal sage
scrub, chaparral, annual
grassland, oak
woodland, and riparian
woodlands.
Does not occur
Green sea turtle
Chelonia mydas
Federal: FT
State: None
State Rank: S1
NCCP/HCP: Not covered
Inhabits the shallow
waters of lagoons,
bays, estuaries,
mangroves, eelgrass
and seaweed beds.
Prefers areas with
abundant aquatic
vegetation, such as
pastures of sea grasses
and algae, in shallow,
protected water.
Does not occur
Orange-throated whiptail
Aspidoscelis hyperythra
Federal: None
State: None
State Rank: S2S3
Coastal sage scrub,
chaparral, non-native
grassland, oak
Does not occur
Snug Harbor Surf Park Project 5.3 Biological Resources
City of Newport Beach 5.3-14
Draft EIR
May 2025
Species Name Status Habitat Potential to Occur
NCCP/HCP: Covered woodland, and juniper
woodland.
Red-diamond rattlesnake
Crotalus ruber
Federal: None
State: SSC
State Rank: S3
NCCP/HCP: Covered
Habitats with heavy
brush and rock
outcrops, including
coastal sage scrub and
chaparral.
Does not occur
Southern California legless
lizard Anniella stebbinsi
Federal: None
State: SSC
State Rank: S3
NCCP/HCP: Not covered
Broadleaved upland
forest, chaparral,
coastal dunes, coastal
scrub; found in a
broader range of
habitats that any of the
other species in the
genus. Often locally
abundant, specimens
are found in coastal
sand dunes and a
variety of interior
habitats, including
sandy washes and
alluvial fans
Does not occur
Southwestern pond turtle
Actinemys pallida
Federal: FPT
State: SSC
State Rank: S3
NCCP/HCP: Not covered
Slow-moving permanent
or intermittent streams,
small ponds and lakes,
reservoirs, abandoned
gravel pits, permanent
and ephemeral shallow
wetlands, stock ponds,
and treatment lagoons.
Abundant basking sites
and cover necessary,
including logs, rocks,
submerged vegetation,
and undercut banks.
Does not occur
Birds
American peregrine falcon
(nesting)
Falco peregrinus anatum
Federal: Delisted
State: Delisted
State Rank: S3S4
NCCP/HCP: Covered
Breeding habitat
consists of high cliffs,
tall buildings, and
bridges along the coast
and inland. Foraging
habitat primarily
includes open areas
near wetlands, marshes,
and adjacent urban
landscapes.
Not expected to occur
Belding's savannah sparrow
Passerculus sandwichensis
beldingi
Federal: None
State: SE
State Rank: S3
NCCP/HCP: Not covered
Coastal Marshes Does not occur
Black skimmer (nesting
colony)
Rynchops niger
Federal: None
State: SSC
State Rank: S2
NCCP/HCP: Not covered
Open sandy beaches,
gravel or shell bars with
sparse vegetation, mats
of sea wrack (tide-
Does not occur
Snug Harbor Surf Park Project 5.3 Biological Resources
City of Newport Beach 5.3-15
Draft EIR
May 2025
Species Name Status Habitat Potential to Occur
stranded debris) in
saltmarsh.
Burrowing owl (burrow sites
& some wintering sites)
Athene cunicularia
Federal: None
State: SC, SSC
State Rank: S2
NCCP/HCP: Not covered
Shortgrass prairies,
grasslands, lowland
scrub, agricultural lands
(particularly
rangelands), coastal
dunes, desert floors,
and some artificial,
open areas as a year-
long resident. Occupies
abandoned ground
squirrel burrows as well
as artificial structures
such as culverts and
underpasses.
Does not occur
California black rail
Laterallus jamaicensis
coturniculus
Federal: None
State: ST, FP
State Rank: S2
NCCP/HCP: Not covered
Nests in high portions of
salt marshes, shallow
freshwater marshes, wet
meadows, and flooded
grassy vegetation.
Does not occur
California least tern (nesting
colony)
Sterna antillarum browni
Federal: FE
State: SE, FP
State Rank: S2
NCCP/HCP: Not covered
Flat, vegetated
substrates near the
coast. Occurs near
estuaries, bays, or
harbors where fish is
abundant.
Does not occur
Coastal cactus wren (San
Diego & Orange County
only)
Campylorhynchus
brunneicapillus sandiegensis
Federal: None
State: SSC
State Rank: S2
NCCP/HCP: Covered
Occurs almost
exclusively in cactus
(cholla and prickly
pear) dominated
coastal sage scrub.
Does not occur
Coastal California
gnatcatcher
Polioptila californica
californica
Federal: FT
State: SSC
State Rank: S2
NCCP/HCP: Covered
Low elevation coastal
sage scrub and coastal
bluff scrub.
Does not occur
Grasshopper sparrow
(nesting)
Ammodramus savannarum
Federal: None
State: SSC
State Rank: S3
NCCP/HCP: Not covered
Open grassland and
prairies with patches of
bare ground.
Does not occur
Great blue heron (nesting
colony)
Ardea herodias
Federal: None
State: None
State Rank: S4
NCCP/HCP: Not covered
Saltwater and
freshwater habitats,
from open coasts,
marshes, sloughs,
riverbanks, and lakes to
backyards. Forages in
grasslands and
agricultural fields. Nests
in trees or high places.
Does not occur in a
nesting colony
Least Bell's vireo (nesting)
Vireo bellii pusillus
Federal: FE
State: SE
State Rank: S3
NCCP/HCP: Covered
Dense riparian habitats
with a stratified
canopy, including
southern willow scrub,
mule fat scrub, and
riparian forest.
Does not occur
Snug Harbor Surf Park Project 5.3 Biological Resources
City of Newport Beach 5.3-16
Draft EIR
May 2025
Species Name Status Habitat Potential to Occur
Light-footed Ridgway’s rail
Rallus obsoletus levipes
Federal: FE
State: SE, FP
State Rank: S1
NCCP/HCP: Not covered
Cordgrass-pickleweed
salt marsh.
Does not occur
Swainson's hawk (nesting)
Buteo swainsoni
Federal: None
State: ST
State Rank: S4
NCCP/HCP: Not covered
Summer in wide open
spaces of the American
West. Nest in
grasslands, but can use
sage flats and
agricultural lands. Nests
are placed in lone
trees.
Does not occur
Tricolored blackbird (nesting
colony)
Agelaius tricolor
Federal: None
State: ST, SSC
State Rank: S2
NCCP/HCP: Not covered
Breeding colonies
require nearby water,
a suitable nesting
substrate, and open-
range foraging habitat
of natural grassland,
woodland, or
agricultural cropland.
Does not occur
Western snowy plover
(nesting)
Charadrius alexandrinus
nivosus
Federal: FT
State: SSC
State Rank: S3
NCCP/HCP: Not covered
Sandy or gravelly
beaches along the
coast, estuarine salt
ponds, alkali lakes, and
at the Salton Sea.
Does not occur
White-tailed kite (nesting)
Elanus leucurus
Federal: None
State: FP
State Rank: S3S4
NCCP/HCP: Not covered
Low elevation open
grasslands, savannah-
like habitats,
agricultural areas,
wetlands, and oak
woodlands. Dense
canopies used for
nesting and cover.
Does not occur
Yellow rail
Coturnicops noveboracensis
Federal: None
State: SSC
State Rank: S2
NCCP/HCP: Not covered
Shallow marshes, and
wet meadows; in winter,
drier freshwater and
brackish marshes, as
well as dense, deep
grass, and rice fields.
Does not occur
Yellow warbler (nesting)
Setophaga petechia
Federal: None
State: SSC
State Rank: S3
NCCP/HCP: Not covered
Breed in lowland and
foothill riparian
woodlands dominated
by cottonwoods, alders,
or willows and other
small trees and shrubs
typical of low, open-
canopy riparian
woodland. During
migration, forages in
woodland, forest, and
shrub habitats.
Does not occur
Yellow-breasted chat
(nesting)
Icteria virens
Federal: None
State: SSC
State Rank: S4
NCCP/HCP: Not covered
Dense, relatively wide
riparian woodlands and
thickets of willows, vine
tangles, and dense
Does not occur
Snug Harbor Surf Park Project 5.3 Biological Resources
City of Newport Beach 5.3-17
Draft EIR
May 2025
Species Name Status Habitat Potential to Occur
brush with well-
developed understories.
Mammals
American badger
Taxidea taxus
Federal: None
State: SSC
State Rank: S3
NCCP/HCP: Not covered
Most abundant in drier
open stages of most
scrub, forest, and
herbaceous habitats,
with friable soils.
Does not occur
Big free-tailed bat
Nyctinomops macrotis
Federal: None
State: SSC State Rank: S3
WBWG: MH
NCCP/HCP: Not covered
Roost mainly in crevices
and rocks in cliff
situations; also rarely
utilizes buildings, caves,
and tree cavities.
Not expected to occur
Mexican long-tongued bat
Choeronycteris mexicana
Federal: None
State: SSC State Rank: S1
WBWG: H
NCCP/HCP: Not covered
Variety of habitats
ranging from desert,
montane, riparian, to
pinyon-juniper habitats.
Found roosting in desert
canyons, deep caves,
mines, or rock crevices.
Can use abandoned
buildings.
Does not occur
Pacific pocket mouse
Perognathus longimembris
pacificus
Federal: FE
State: SSC
State Rank: S2
NCCP/HCP: Covered
Fine, alluvial soils along
the coastal plain.
Scarcely in rocky soils
of scrub habitats.
Does not occur
Silver-haired bat
Lasionycteris noctivagans
Federal: None
State: None State Rank:
S3S4
WBWG: M
NCCP/HCP: Not covered
Temperate, northern
hardwoods with ponds
or streams nearby.
Roost in hollow snags
and bird nests.
Not expected to occur
South coast marsh vole
Microtus californicus stephensi
Federal: None
State: SSC
State Rank: S2
NCCP/HCP: Not covered
Tidal marshes in Los
Angeles, Orange and
southern Ventura
Counties.
Does not occur
Southern California
saltmarsh shrew
Sorex ornatus salicornicus
Federal: None
State: SSC
State Rank: S1
NCCP/HCP: Not covered
Coastal marshes.
Requires dense
vegetation and woody
debris for cover.
Does not occur
Western mastiff bat
Eumops perotis californicus
Federal: None
State: SSC State Rank: S3S4
WBWG: H
NCCP/HCP: Not covered
Occurs in many open,
semi-arid to arid
habitats, including
conifer and deciduous
woodlands, coastal
scrub, grasslands, and
chaparral. Roosts in
crevices in cliff faces,
high buildings, trees,
and tunnels.
Not expected to occur
Snug Harbor Surf Park Project 5.3 Biological Resources
City of Newport Beach 5.3-18
Draft EIR
May 2025
Species Name Status Habitat Potential to Occur
Western yellow bat
Lasiurus xanthinus
Federal: None
State: SSC State Rank: S3
WBWG: H
NCCP/HCP: Not covered
Found in valley foothill
riparian, desert
riparian, desert wash,
and palm oasis
habitats. Roosts in trees,
particularly palms.
Forages over water
and among trees.
Potential to occur
Source: Appendix C
5.3.3.5 Jurisdictional Waters
Two drainage culverts are located near the western corner of the property that function to drain surface
runoff from upland areas of the golf course, including cart paths and fairways. Engineered depressions that
appear to capture and direct runoff into the culverts were determined to be non-jurisdictional due to the
lack of a defined bed and bank and lack of evidence of surface flow. Therefore, no jurisdictional drainage
features, riparian vegetation, or wetlands are present (Appendix C).
5.3.3.6 Wildlife Movement
Wildlife corridors connect otherwise isolated pieces of habitat and allow movement or dispersal of plants
and animals. Corridors can be local or regional in scale. Their functions may vary temporally and spatially
based on conditions and species present. Local wildlife corridors allow access to resources such as food,
water, and shelter within the framework of their daily routine. Animals use these corridors, which are often
hillsides or tributary drainages, to move between different habitats. Regional corridors provide these
functions over a larger scale and link two or more large habitat areas, allowing the dispersal of organisms
and the consequent mixing of genes between populations.
The Project site is bound by Irvine Avenue to the north and west, Mesa Drive to the southwest, and commercial
and residential land uses to the north, east, and west. The adjacent Santa Ana Delhi Channel is a cement
lined channel that is likely used for local movement by small, urban adapted mammals and reptiles. Some
local wildlife movement may occur within the Project site; however, given the lack of connection to any native
open space, the Project site does not comprise or occur within a wildlife linkage or corridor.
5.3.3.7 Orange County Central Coastal NCCP/HCP
The Project site is located within the Orange County Central/Coastal NCCP/HCP. Within the NCCP/HCP,
the Project is located within the Coastal Subarea. The Project site is not located within the Habitat Reserve
System within the NCCP/HCP and is identified as a development site under the Orange County
Central/Coastal NCCP/HCP (Appendix C).
5.3.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a Project could have a significant effect if it were to:
BIO-1 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.
Snug Harbor Surf Park Project 5.3 Biological Resources
City of Newport Beach 5.3-19
Draft EIR
May 2025
BIO-2 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.
BIO-3 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.
BIO-4 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.
BIO-5 Conflict with any local policies or ordinances protecting biological resources, such as a tree
preservation policy or ordinance.
BIO-6 Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community
Conservation Plan, or other approved local, regional, or state habitat conservation plan.
5.3.5 METHODOLOGY
The analysis within this Draft EIR section is based on the Biological Technical Report completed for the Project
site, included as Appendix C. The Biological Technical Report is based on literature review of biological
resources occurring within the Project site and surrounding vicinity; vegetation mapping; habitat assessments
for special-status botanical and wildlife species; general biological surveys; and focused surveys for
overwintering western monarch butterfly. The literature review was based on the review of the following:
aerial photographs, topographic maps, and database searches of the CNDDB, the USFWS Endangered
Species Lists, and the CNPS rare plant lists. In addition, field surveys were conducted on September 10,
2024 to document existing conditions within the Project site and surrounding lands. A general biological field
survey, in-field habitat assessments, and focused surveys, vegetation mapping, and investigation of
jurisdictional waters and wetlands were conducted. Focused surveys for overwintering western monarch
butterfly were conducted on November 19 and December 11, 2024. Information obtained through the
research and site surveys were compared to the CEQA Guidelines Appendix G thresholds and existing
regulatory requirements and policies to determine whether a potentially significant impact could occur and
measures to reduce potential impacts.
5.3.6 ENVIRONMENTAL IMPACTS
IMPACT BIO-1: THE PROJECT WOULD NOT 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.
Less than Significant with Mitigation Incorporated. As described in the environmental setting, the Project
site and offsite improvement areas contain developed/disturbed land and turf grass/ornamental
landscaping.
Special-Status Plants
As shown in Table 5.3-1, 36 special-status plant species are associated with the Project region. None of the
special-status plant species were observed during the general biological surveys conducted in September
2024. The Project site and surrounding vicinity have been subject to decades of anthropogenic disturbances
Snug Harbor Surf Park Project 5.3 Biological Resources
City of Newport Beach 5.3-20
Draft EIR
May 2025
from development, which has removed native plant communities that have historically occurred in the area.
Therefore, the Biological Technical Report (Appendix C) concluded that no special-status plants have the
potential to occur within the Project site. Therefore, development within the Project site would result in no
impacts to special-status plant species.
Special-Status Animal Species
As shown in Table 5.3-2, a total of 50 special-status animal species have been identified with the potential
to occur within the Project region. No special-status wildlife species were observed during the field
investigation on September 10, 2024. While not observed onsite during the general biological survey, great
blue heron individuals may occasionally occur onsite as a transient species but is not expected to occur onsite
in a nesting colony due to lack of suitable nesting trees and frequent human disturbance. Based on the
focused surveys conducted within the Project site, no overwintering monarch butterflies were detected in or
around ornamental eucalyptus or pine trees onsite. Further, the trees onsite occur individually and are not
clustered in groves or exhibit the microclimate typical for overwintering uses. As such, the Biological Technical
Report (Appendix C) concluded that overwintering monarch butterflies are confirmed absent.
According to the Biological Technical Report, western yellow bat has a low potential to roost in ornamental
trees, including palms, on the Project site. Further, the Project site provides suitable foraging, breeding, and
roosting habitat for a number of raptor species. No raptor species were detected over the course of field
studies; however, common, urban adapted species may occasionally occur. The Project site lacks potential
nesting habitat (e.g., mature trees, shrubs) for special-status raptor species but is expected to provide
marginal foraging habitat for common raptors that support prey species such as insects, spiders, lizards,
snakes, small mammals, and other birds. The Biological Technical Report determined that the Project site does
not have the potential to support any of the other special-status species listed in Table 5.3-2 in a live-in
capacity.
Given the limited roosting habitat for western yellow bat onsite, Mitigation Measure BIO-1 is included to
require a pre-construction nesting bat survey. With implementation of Mitigation Measure BIO-1, impacts
would be less than significant.
Indirect Impacts
In the context of biological resources, indirect effects are those associated with developing areas adjacent
to native open space. The Project site is surrounded by residential, commercial, and golf course land uses.
There is no native open space adjacent to the Project site. The Upper Newport Bay Nature Preserve and
Ecological Reserve (“Upper Newport Bay”) is located approximately 0.3 miles south of the Project site. The
area between the Project site and Upper Newport Bay contains a hill with existing recreational and
residential land uses that is approximately 50 feet higher in elevation than the Project site and 40 to 50
feet higher in elevation than the northernmost portion of the Upper Newport Bay. The hill provides a natural
barrier to potential indirect effects to the Upper Newport Bay from the proposed Project. As such, the Project
would not result in substantial drainage, lighting, or noise impacts to the Upper Newport Bay. Furthermore,
the Project would implement the City’s landscaping requirements and not use invasive plant species including
plant species listed as “Moderate” or “High” invasiveness by the California Invasive Plant Council. Therefore,
the Project is not expected to result in significant indirect impacts to special-status biological resources and
impacts would be less than significant.
IMPACT BIO-2: THE PROJECT WOULD NOT 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.
Snug Harbor Surf Park Project 5.3 Biological Resources
City of Newport Beach 5.3-21
Draft EIR
May 2025
No Impact. The Biological Technical Report determined that the Project site does not contain any drainage,
riparian, or riverine features. There are no CDFW, United States Army Corps of Engineers, or Regional
Water Quality Control Board (RWQCB) jurisdictional waters within the Project site boundaries. The Project
site does not contain any wetlands or vernal pools. While the Project is adjacent to the Santa Ana Delhi
Channel, Project construction and operation would not result in any disturbance to the Channel. Furthermore,
during construction of the Project, the use of Best Management Practices (BMPs) during construction
implemented as part of a Stormwater Pollution Prevention Program (SWPPP) would ensure that sediments
from exposed soils do not flow into the Channel during storm events. In addition, the Project site is comprised
of disturbed/developed area and turf grass/ornamental landscaping, which is not classified as a sensitive
natural community (Appendix C). Therefore, the Project would not result in impacts related to riparian habitat
or other sensitive natural community.
IMPACT BIO-3: THE PROJECT WOULD NOT HAVE A SUBSTANTIAL ADVERSE EFFECT ON STATE OR
FEDERALLY PROTECTED WETLANDS (INCLUDING, BUT NOT LIMITED TO, MARSH,
VERNAL POOL, COASTAL, ETC.) THROUGH DIRECT REMOVAL, FILLING,
HYDROLOGICAL INTERRUPTION, OR OTHER MEANS.
No Impact. As previously described, the Project site does not include any wetlands or vernal pools. In
addition, there are no CDFW, Army Corps of Engineers, or RWQCB jurisdictional waters within the Project
site boundaries (Appendix C). While the Project is adjacent to the Santa Ana Delhi Channel, Project
construction and operation would not result in any disturbance to the Channel. Furthermore, during
construction of the Project, the use of BMPs during construction implemented as part of a SWPPP would
ensure that sediments from exposed soils do not flow into the Channel during storm events. Therefore, the
Project would not impact federally protected wetlands.
IMPACT BIO-4: THE PROJECT WOULD NOT INTERFERE SUBSTANTIALLY WITH THE MOVEMENT OF
ANY NATIVE RESIDENT OR MIGRATORY FISH OR WILDLIFE SPECIES, OR WITH
ESTABLISHED NATIVE RESIDENT OR MIGRATORY WILDLIFE CORRIDORS, OR IMPEDE
THE USE OF NATIVE WILDLIFE NURSERY SITES.
Less than Significant with Mitigation Incorporated.
Wildlife Movement
Wildlife corridors are linear features that connect areas of open space and provide avenues for the
migration of animals and access to additional areas of foraging. Typically, mountain canyons or riparian
corridors are used as corridors, and the Project site does not contain these features. The Project site is within
an urbanized setting. The adjacent Santa Ana Delhi Channel is likely used for local movement by small,
urban adapted mammals and reptiles. Project construction and operation would not result in any disturbance
to the Santa Ana Delhi Channel. Some local wildlife movement may occur within the Project site; however,
given the lack of connection to any native open space, the Project site does not comprise or occur within a
wildlife linkage or corridor. Development of the site would not result in impacts related to established native
resident or migratory wildlife corridor.
Migratory Birds
The Project site contains and is bordered by trees that can be utilized by nesting birds and raptors during
the nesting bird season that generally extends from February 1 through September 15 but may be extended
due to weather and drought conditions. Nesting birds are protected under the federal MBTA and Section
3503 of the California Fish and Game Code. Any activities that occur during the nesting/breeding season
of birds protected by the MBTA could result in a potentially significant impact if requirements of the MBTA
are not followed. Although impacts to native birds are prohibited by MBTA and similar provisions within the
California Fish and Game Code, the native birds with potential to nest on the Project site would be those
Snug Harbor Surf Park Project 5.3 Biological Resources
City of Newport Beach 5.3-22
Draft EIR
May 2025
that are common to the region and highly adapted to human landscapes. Nevertheless, the Project would be
required to implement Mitigation Measure BIO-2, which requires a pre-construction nesting bird survey. With
implementation of Mitigation Measure BIO-2, impacts to nesting birds would be less than significant.
Impact BIO-5: THE PROJECT WOULD NOT CONFLICT WITH ANY LOCAL POLICIES OR ORDINANCES
PROTECTING BIOLOGICAL RESOURCES, SUCH AS A TREE PRESERVATION POLICY OR
ORDINANCE.
No Impact. The Project would not conflict with any local policies or ordinances protecting biological
resources. See discussions under Impact BIO-6 regarding compliance with the Orange County
Central/Coastal NCCP/HCP.
The City of Newport Beach Council Policy G-1 (Retention or Removal of City Trees) and Municipal Code
Chapter 13.08, Planting, regulates the removal, severe trimming, planting, and maintenance of any trees
within a public right-of-way, city street, or city property. The proposed Project includes new landscaping
along the site frontages of Irvine Avenue and Mesa Drive that may extend into the public right-of-way
adjacent to the street. However, implementation of the City’s development review and permitting process
would ensure that any tree removal and proposed new landscaping would be consistent with the City Council
Policy and municipal code requirements. Thus, the Project would not conflict with a tree preservation policy
or ordinance.
Additionally, the Project would not conflict with Newport Beach Municipal Code Chapter 7.26, which sets
forth protections for migratory and nonmigratory waterfowl, as it would not impact any habitat for such
species. Therefore, the Project would not conflict with any local policies or ordinances protecting biological
resources, and no impacts would occur.
IMPACT BIO-6: THE PROJECT WOULD NOT CONFLICT WITH THE PROVISIONS OF AN ADOPTED
HABITAT CONSERVATION PLAN, NATURAL COMMUNITY CONSERVATION PLAN,
OR OTHER APPROVED LOCAL, REGIONAL, OR STATE HABITAT CONSERVATION
PLAN.
No Impact. The Project site is located within the Orange County Central/Coastal NCCP/HCP. Within the
NCCP/HCP, the Project is located within the Coastal Subarea. The Project site is not located within the
Habitat Reserve System within the NCCP/HCP and is identified as a development site under the Orange
County Central/Coastal NCCP/HCP (Appendix C). As the Project is designated as a development site, the
Project would not conflict with the Orange County Central/Coastal NCCP/HCP. As such, impacts related to
an adopted habitat conservation plan, natural community conservation plan, or other approved local,
regional, or state habitat conservation plan would not occur.
5.3.7 CUMULATIVE IMPACTS
The cumulative study area for purposes of biological resources encompasses the Coastal Subregion of the
Orange County Central/Coastal NCCP/HCP. This cumulative impact analysis considers development of the
Project in conjunction with other development projects in the vicinity of the Project site as well as the projects
identified in Table 5-1, Cumulative Projects List, in Section 5.0, Environmental Impact Analysis,. The Project
would not have significant impacts related to jurisdictional waters, wildlife movement, local ordinances or
regulations protecting biological resources, habitat conservation plans, plant communities, and habitat
fragmentation. In addition, Mitigation Measures BIO-1 and BIO-2 would reduce potential impacts to roosting
bats and nesting birds to a less than significant level that would not be cumulatively considerable.
As shown on Figure 5-1, Cumulative Projects, in Section 5.0, Environmental Impact Analysis, the majority of
cumulative projects consist of redevelopment of previously developed land, which generally does not contain
Snug Harbor Surf Park Project 5.3 Biological Resources
City of Newport Beach 5.3-23
Draft EIR
May 2025
substantial habitat resources. Likewise, the Housing Opportunity sites to the south of the Project site across
Mesa Drive are golf course areas that do not provide substantial natural habitat resources. Cumulative
projects would be required to comply with applicable survey requirements and NCCP/HCP requirements
and mitigation for biological resources, such as the Migratory Bird Treaty Act and focused surveys. Since all
projects would be required to implement their respective mitigation measures through the City’s development
review and permitting process, the contribution would not be cumulatively considerable. There are no projects
that would, in combination with the Project, produce a significant impact to biological resources. Therefore,
Project impacts would be less than cumulatively considerable and would be less than significant.
5.3.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES
The following would reduce potential impacts related to biological resources.
Existing Regulations
• Federal Endangered Species Act
• Clean Water Act
• Migratory Bird Treaty Act
• California’s Endangered Species Act
• California Fish and Game Code
• Municipal Code Chapter 7.26, Protection of Natural Habitat for Migratory and Other Waterfowl
• Municipal Code Chapter 13.08, Planting
• Municipal Code Chapter 21.30B, Habitat Protection
Existing City Council Policy Manual Policy
• City Council Policy Manual Policy G-1, Retention, Removal, and Maintenance of City Trees
Plans, Programs, or Policies
None.
5.3.9 PROJECT DESIGN FEATURES
None.
5.3.10 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Without mitigation, the following impacts would be potentially significant:
• Impact BIO-1: Impacts to special status species in local or regional plans, policies, or regulations.
• Impact BIO-4: Impacts to wildlife movement or native wildlife nursery sites.
The following would result in no impacts:
• Impact BIO-2: Impacts to riparian habitat or sensitive communities.
• Impact BIO-3: Impacts to State or federally protected wetlands.
• Impact BIO-5: Impacts related to conflict with local policies or ordinances.
• Impact BIO-6: Impacts related to conflict with provisions of the NCCP/HCP.
Snug Harbor Surf Park Project 5.3 Biological Resources
City of Newport Beach 5.3-24
Draft EIR
May 2025
5.3.11 MITIGATION MEASURES
Mitigation Measure BIO-1: Pre-Construction Roosting Bat Survey. Project plans and construction
permitting, including tree removal permits, shall require that in order to avoid and/or minimize injury to
roosting bats and avoid maternity roosts until the maternity roost is no longer in use, a qualified biologist
shall conduct a pre-construction bat roost survey for roosting bats no more than 14 days prior to site
disturbance. The pre-construction bat roost survey shall consist of a minimum of two emergent bat surveys
(conducted consecutively or as determined by the biologist). The emergent surveys shall begin 30 minutes
before dusk and extend to one hour after dark.
If roosting bats are detected onsite outside of the bat maternity season (April 1 through August 31), the roost
tree shall be removed in a manner to avoid and/or minimize injury to roosting bats. This may include using
mechanical equipment to gently nudge the tree trunk multiple times prior to removal or for palm trees and
other species, to de-frond or de-branch the tree using a mechanical lift and gently lower the cut fronds or
branches to the ground. Regardless of the method, the fallen tree and/or material shall be left undisturbed
overnight until at least the next morning to give roosting bats time to exit before site disturbance.
If roosting bats are detected onsite during the maternity season (September 1 through March 31), the Project
shall avoid the subject roost(s) and incorporate an avoidance buffer (300 feet or as determined by the
qualified biologist) until after the maternity season or until a qualified biologist determines no maternity
roosting is occurring. The qualified biologist shall clearly delineate any bat maternity roosts and any required
avoidance buffers, which shall be clearly marked with flags and/or fencing prior to the initiation of
construction activities. Once the qualified biologist approves removal of the subject roost tree(s), the same
tree removal procedures as outlined above shall be implemented prior to tree removal.
Mitigation Measure BIO-2: Pre-Construction Nesting Bird Survey. Project plans and construction permitting,
including tree removal permits, shall state that vegetation removal should occur outside of the nesting bird
season (generally between February 1 and August 31). If vegetation removal is required during the nesting
bird season, the applicant shall conduct take avoidance surveys for nesting birds prior to initiating vegetation
removal/clearing. Surveys shall be conducted by a qualified biologist(s) within three days of vegetation
removal. If active nests are observed, a qualified biologist shall determine appropriate minimum disturbance
buffers and other adaptive mitigation techniques (e.g., biological monitoring of active nests during
construction-related activities, staggered schedules, etc.) to ensure that impacts to nesting birds are avoided
until the nest is no longer active. At a minimum, construction activities shall stay outside of a 200-foot buffer
around the active nests. The approved buffer zone shall be marked in the field with construction fencing,
within which no vegetation clearing or ground disturbance shall commence until the qualified biologist and
City of Newport Beach Planning Division verify that the nests are no longer occupied, and the juvenile birds
can survive independently from the nests. Once the young have fledged and left the nest, or the nest
otherwise becomes inactive under natural conditions, normal construction activities may occur.
5.3.12 LEVEL OF SIGNIFICANCE AFTER MITIGATION
The mitigation measures listed above, as well as existing regulations, would reduce potential impacts
associated with biological resources for Impacts BIO-1 and BIO-4 to a level that is less than significant.
5.3.13 REFERENCES
City of Newport Beach. (2001, January). Santa Ana Heights Specific Plan. Retrieved September 23, 2024,
from ocpublicworks.com.
Snug Harbor Surf Park Project 5.3 Biological Resources
City of Newport Beach 5.3-25
Draft EIR
May 2025
City of Newport Beach. (2006a, July). General Plan. Retrieved September 23, 2024, from
newportbeachca.gov: https://www.newportbeachca.gov/government/departments/community-
development/planning-division/general-plan-codes-and-regulations/general-plan
City of Newport Beach. (2006b, July). General Plan Environmental Impact Report. Retrieved September 23,
2024, from newportbeachca.gov:
https://www.newportbeachca.gov/government/departments/community-development/planning-
division/general-plan-codes-and-regulations/general-plan/general-plan-environmental-impact-
repor
City of Newport Beach. (2024, May). Newport Beach Municipal Code. Retrieved September 23, 2024,
from codepublishing.com: https://www.codepublishing.com/CA/NewportBeach/
Glenn Lukos Associates, Inc. (2025). Biological Technical Report for the Snug Harbor Project. (Appendix C)
Snug Harbor Surf Park Project 5.3 Biological Resources
City of Newport Beach 5.3-26
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 5.4 Cultural Resources
City of Newport Beach 5.4-1
Draft EIR
May 2025
5.4 Cultural Resources
5.4.1 INTRODUCTION
This section describes the cultural resources conditions in the Project region and potential impacts from Project
implementation. The analysis in this section is based, in part, on the following documents and resources:
• City of Newport Beach General Plan, 2006
• City of Newport Beach General Plan Environmental Impact Report (General Plan EIR), 2006
• City of Newport Beach Municipal Code
• Historic Resources Evaluation for the Newport Beach Golf Course Clubhouse and Driving Range
Shack/Canopy in Newport Beach, Orange County, California, prepared by LSA Associates, 2024,
included as Appendix D
• Phase I Archaeological Resources Assessment for the Surf Farm Project, Located in the City of Newport
Beach, Orange County, California, prepared by Glenn Lukos Associates, 2024, included as Appendix E
In accordance with Public Resources Code Section 15120(d), certain information and communications that
disclose the location of archaeological sites and sacred lands are allowed to be exempt from public
disclosure.
Definitions
• Archaeological resources include any material remains of human life or activities that are at least 100
years of age, and that are of scientific interest. A unique or significant archaeological resource is an
archaeological artifact, object, or site about which it can be clearly demonstrated that, without merely
adding to the current body of knowledge, there is a high probability that it (1) contains information
needed to answer important scientific research questions and there is a demonstrable public interest in
that information; (2) has a special and particular quality, such as being the oldest of its type or the best
available example of its type; and (3) is directly associated with a scientifically recognized important
prehistoric or historic event or person.
• Cultural resources are defined as buildings, sites, structures, or objects, each of which may have historic,
architectural, archaeological, cultural, or scientific importance, according to CEQA .
• Historic building or site is one that is noteworthy for its significance in local, state, or national history or
culture, its architecture or design, or its works of art, memorabilia, or artifacts.
• Historic context refers to the broad patterns of historical development in a community or its region that
is represented by cultural resources. A historic context statement is organized by themes such as economic,
residential, and commercial development.
• Historic integrity is defined as “the ability of a property to convey its significance.”
• Historical resources are defined as “a resource listed or eligible for listing on the California Register of
Historical Resources” (CRHR) (Public Resources Code, Section 5024.1; 14 CCR 15064.5). Under CEQA
Guidelines Section 15064.5(a), the term “historical resources” includes the following:
(1) A resource listed in or determined to be eligible by the State Historical Resources Commission, for
listing in the California Register of Historical Resources (Public Resources Code, Section 5024.1).
(2) A resource included in a local register of historical resources, as defined in Section 5020.1(k) of the
Public Resources Code or identified as significant in a historical resource survey meeting the
requirements of Section 5024.1(g) of the Public Resources Code, will be presumed to be historically
Snug Harbor Surf Park Project 5.4 Cultural Resources
City of Newport Beach 5.4-2
Draft EIR
May 2025
or culturally significant. Public agencies must treat any such resource as significant unless the
preponderance of evidence demonstrates that it is not historically or culturally significant.
(3) Any object, building, structure, site, area, place, record, or manuscript which a lead agency
determines to be historically significant or significant in the architectural, engineering, scientific,
economic, agricultural, educational, social, political, military, or cultural annals of California may be
considered to be a historical resource, provided the lead agency’s determination is supported by
substantial evidence in light of the whole record. Generally, a resource shall be considered by the
lead agency to be “historically significant” if the resource meets the criteria for listing on the
California Register of Historical Resources (Public Resources Code Section 5024.1) including the
following:
(A) Is associated with events that have made a significant contribution to the broad patterns of
California’s history and cultural heritage;
(B) Is associated with the lives of persons important in California’s past;
(C) Embodies the distinctive characteristics of a type, period, region, or method of construction, or
represents the work of an important creative individual, or possesses high artistic values; or
(D) Has yielded, or may be likely to yield, information important in prehistory or history.
(4) The fact that a resource is not listed in, or determined to be eligible for listing in the California
Register of Historical Resources, not included in a local register of historical resources (pursuant to
Section 5020.1(k) of the Public Resources Code), or identified in a historical resources survey
(meeting the criteria in Section 5024.1(g) of the Public Resources Code) does not preclude a lead
agency from determining that the resource may be an historical resource as defined in Public
Resources Code Sections 5020.1(j) or 5024.1.
5.4.2 REGULATORY SETTING
5.4.2.1 Federal Regulations
National Historic Preservation Act
The National Historic Preservation Act of 1966 established the National Register of Historic Places (National
Register), which is the official register of designated historic places. The National Register is administered
by the National Park Service, and includes listings of buildings, structures, sites, objects, and districts that
possess historical, architectural, engineering, archaeological, or cultural significance at the national, state, or
local level.
To be eligible for the National Register, a property must be significant under one or more of the following
criteria per 36 Code of Federal Regulations Part 60:
A. Properties that are associated with events that have made a significant contribution to the broad patterns
of our history;
B. Properties that are associated with the lives of persons significant in our past;
C. Properties that embody the distinctive characteristics of a type, period or method of construction, or that
represent the work of a master, or that possess high artistic values, or that represent a significant and
distinguishable entity whose components may lack individual distinction; or
D. Properties that have yielded, or may be likely to yield, information important in prehistory or history.
In addition to meeting one or more of the aforementioned criteria, an eligible property must also possess
historic “integrity,” which is “the ability of a property to convey its significance.” The National Register criteria
Snug Harbor Surf Park Project 5.4 Cultural Resources
City of Newport Beach 5.4-3
Draft EIR
May 2025
recognize seven qualities that define integrity: location, design, setting, materials, workmanship, feeling, and
association.
Structures, sites, buildings, districts, and objects over 50 years of age can be listed in the National Register
as significant historical resources. Properties under 50 years of age that are of exceptional importance or
are contributors to a district can also be included in the National Register.
Properties listed in or eligible for listing in the National Register are also eligible for listing in the California
Register, and as such, are considered historical resources for CEQA purposes.
5.4.2.2 State Regulations
California Register of Historical Resources
Eligibility for inclusion in the California Register is determined by applying the following criteria:
1. It is associated with events that have made a significant contribution to the broad patterns of California’s
history and cultural heritage;
2. It is associated with the lives of persons important in California’s past;
3. embodies the distinctive characteristics of a type, period, region, or method of construction, or represents
the work of an important creative individual, or possesses high artistic value; or
4. It has yielded or is likely to yield information important in prehistory or history. The Register includes
properties which are listed or have been formally determined to be eligible for listing in the National
Register, State Historical Landmarks, and eligible Points of Historical Interest (PRC §5024.1).
In addition to meeting one or more of the above criteria, the California Register requires that sufficient time
has passed since a resource’s period of significance to “obtain a scholarly perspective on the events or
individuals associated with the resources.” (CCR 4852 [d][2]). The California Register also requires that a
resource possess integrity. This is defined as the ability for the resource to convey its significance through
seven aspects: location, setting, design, materials, workmanship, feeling, and association.
California Health and Safety Code Section 7050.5
Health and Safety Code Section 7050.5(b) and (c) provides that if human remains are discovered,
excavation or disturbance in the vicinity of human remains shall cease until the County Coroner is contacted
and has reviewed the remains. If the Coroner recognizes the human remains to be those of a Native American
or has reason to believe that they are those of a Native American, the Coroner is required to contact the
Native American Heritage Commission (NAHC) by telephone within 24 hours.
Public Resources Code Section 5097.98
Public Resources Code Section 5097.98 provides guidance on the appropriate handling of Native American
remains. Once the NAHC receives notification from the Coroner of a discovery of Native American human
remains, the NAHC is required to notify those persons it believes to be most likely descended from the
deceased Native American. The descendants may, with the permission of the owner of the land, or his or her
authorized representative, inspect the site of discovery of the Native American human remains and may
recommend to the owner or the person responsible for the excavation work means for treatment or
disposition, with appropriate dignity, of the human remains and any associated grave goods. The
descendants shall complete their inspection and make recommendations or preferences for treatment within
48 hours of being granted access to the site. According to Public Resources Code Section 5097.98(k), the
NAHC is authorized to mediate disputes arising between landowners and known descendants relating to the
Snug Harbor Surf Park Project 5.4 Cultural Resources
City of Newport Beach 5.4-4
Draft EIR
May 2025
treatment and disposition of Native American human burials, skeletal remains, and items associated with
Native American burials.
CEQA Guidelines Section 15064.5
Section 15064.5 of the CEQA Guidelines provides guidelines for determining the significance of impacts to
archaeological and historical resources. The section provides the definition of historical resources, and how
to analyze impacts to resources that are designated or eligible for designation as a historical resource.
Section 15064.5 additionally provides provisions for the accidental discovery or recognition of human
remains in any location other than a dedicated cemetery.
5.4.2.3 Local and Regional Regulations
City of Newport Beach General Plan 2006
The City of Newport Beach General Plan contains the following policies related to Cultural Resources that
are applicable to the Project:
HR 1.2 Reservation or Re-Use of Historical Structures. Encourage the preservation of structures
listed on the National Register of Historic Places and/or the list of California Historical
Landmarks, and/or the Newport Beach Register of Historical Property. Provide incentives,
such as grading reductions or waivers of application fees, permit fees, and/or any liens
placed by the City to properties listed in the National or State Register or the Newport
Beach Register of Historical Property in exchange for preservation easements.
HR 1.4 Adaptive Elements with New Projects. Require that proposed development that is
located on a historical site or structure incorporate a physical link to the past within the site
or structural design, if preservation or adaptive reuse is not a feasible option. For example,
incorporate historical photographs or artifacts within the proposed project or preserve the
location and structures of existing pathways, gathering places, seating areas, rail lines,
roadways, or viewing vantage points within the proposed site design.
HR 1.5 Historical Elements within New Projects. Require that proposed development that is
located on a historical site or structure incorporate a physical link to the past within the site
or structural design, if preservation or adaptive reuse is not a feasible option. For example,
incorporate historical photographs or artifacts within the proposed project or preserve the
location and structures of existing pathways, gathering places, seating areas, rail lines,
roadways, or viewing vantage points within the proposed site design.
HR 1.6 Documentation. Require that, prior to the issuance of a demolition or grading permit,
developers of a property that contains an historic structure as defined by CEQA retain a
qualified consultant to record the structure in accordance with U.S. Secretary of Interior
guidelines (which includes drawings, photographs, and written data) and submit this
information to the Newport Beach Historical Society, Orange County Public Library, and
City Planning Department.
HR 1.7 Offer for Relocation of Historic Structures. Require that, prior to the demolition of a historic
structure, developers offer the structure for relocation by interested parties.
HR 2.1 New Development Activities. Require that, in accordance with CEQA, new development
protect and preserve paleontological and archaeological resources from destruction and
avoid and mitigate impacts to such resources. Through planning policies and permit
Snug Harbor Surf Park Project 5.4 Cultural Resources
City of Newport Beach 5.4-5
Draft EIR
May 2025
conditions, ensure the preservation of significant archeological and paleontological
resources and require that the impact caused by any development be mitigated in
accordance with CEQA.
HR 2.2 Grading and Excavation Activities. Maintain sources of information regarding
paleontological and archeological sites and the names and addresses of responsible
organizations and qualified individuals, who can analyze, classify, record, and preserve
paleontological or archeological findings. Require a qualified paleontologist/archeologist
to monitor all grading and/or excavation where there is a potential to affect cultural,
archeological or paleontological resources. If these resources are found, the applicant shall
implement the recommendations of the paleontologist/archeologist, subject to the approval
of the City Planning Department.
HR 2.4 Paleontological or Archaeological Materials. Require new development to donate
scientifically valuable paleontological or archaeological materials to a responsible public
or private institution with a suitable repository, located within Newport Beach, or Orange
County, whenever possible.
Newport Beach City Council Policy Manuel
Policy K-2: Places of Historical and Architectural Significance. The City Council may designate as historical
property any building or part thereof, object, structure, monument, or collection thereof having importance
to the history or architecture of the City of Newport Beach in accordance with the criteria set forth below.
1. Property may be designated as historical property if it meets any of the following standards of
architectural significance:
a. Structures or areas that embody distinguishing characteristics of an architectural style, period, or
method of construction, or of architectural development with the City.
b. Notable works of a master builder, designer, or architect whose style influenced the City’s
architectural development, or structures showing the evolution of an architect’s style.
c. Rare structures displaying a building type, design, or indigenous building form.
d. Structures which embody special architectural and design features.
e. Outstanding examples of structures displaying original architectural integrity, structurally or
stylistically, or both.
f. Unique structures or places that act as focal or pivotal points important as a key to the character or
visual quality of an area.
2. Property may be designated as historical property if it meets any of the following standards of historical
significance.
a. Sites and structures connected with events significant in the economic, cultural, political, social, or civic
history of the City of Newport Beach, the County of Orange, the State of California, or the United
States of America.
b. Structures or areas identified with the lives of historical personages of the City of Newport Beach,
the County of Orange, the State of California, or the United States of America.
c. Sites and groups of structures representing historical development patterns, including, but not limited
to, urbanization patterns, railroads, agricultural settlements, and canals.
Policy K-5: Paleontological and Archaeological Resource Protection Guidelines: The City will ensure that
potential impacts to paleontological and archaeological resources by public or private development are
properly evaluated and mitigated in accordance with the General Plan, Local Coastal Program and CEQA.
Snug Harbor Surf Park Project 5.4 Cultural Resources
City of Newport Beach 5.4-6
Draft EIR
May 2025
Procedures
A. During the preparation of an initial study for a project, staff or a qualified consultant shall determine if
paleontological or archaeological resources exist at or near a project site. If the site is located in the
Coastal Zone, the requirements and procedures provided in Newport Beach Municipal Code Section
21.30.105(A), or any successor statute, shall be implemented.
B. If resources are known to exist at or near a project site or that, the project could otherwise affect known
resources, a preliminary investigation report shall be prepared by a qualified professional
archaeologist or paleontologist.
C. If the preliminary investigation report concludes that resources are not likely to be at the present at the
project site or encountered during construction, no further analysis shall be required.
D. If the preliminary report concludes that resources are present at the site or are likely to be present at
the site or may be encountered by project construction, additional investigative work shall be prepared
to identify and disclose the potential impacts of the project. The impact assessment report shall make
every effort to identify the value of the resource and shall identify feasible design modifications or other
methods to avoid and/or minimize project-related impacts. The impact assessment report may include a
suggested excavation plan for assessing or mitigating the effect of the project on the qualities which
make the resource important if avoidance is considered infeasible. The impact assessment report shall
also identify feasible mitigation measures that can be either incorporated within project specifications
or applied as conditions of approval.
E. If paleontological or archaeological resources are discovered during construction, all construction
activities in the general area of the discovery shall be temporarily halted until the resource is examined
by a qualified monitor. The monitor shall the significance of the resource recommend next steps (i.e.
additional excavation, curation, preservation, etc.).
F. If human remains are discovered during construction, there shall be no further excavation or disturbance
of the site or any nearby area reasonably suspected to overlie adjacent remains until the coroner
determines that the remains are not subject to the provisions of Section 27491 of the Government Code,
or any successor statute, or any other related provisions of law concerning investigation of the
circumstances, manner and cause of any death, and the recommendations concerning the treatment and
disposition of the human remains have been made to the person responsible for the excavation, or their
authorized representative, in the manner provided in Section 5097.98 of the Public Resources Code, or
any successor statute. The coroner shall make his or her determination within two working days from the
time the person responsible for the excavation, or his or her authorized representative, notifies the
coroner of the discovery or recognition of the human remains. If the coroner determines that the remains
are not subject to his or her authority and if the coroner recognizes the human remains to be those of a
Native American, or has reason to believe that they are those of a Native American, he or she shall
contact, by telephone within 24 hours, the Native American Heritage Commission and the Newport Beach
Building Official.
5.4.3 ENVIRONMENTAL SETTING
Historical Setting
Orange County contains prehistoric sites dating from 9,000 to 10,000 years ago that show signs of human
presence. Sites from 6,000 to 1,000 BC (Milling Stone period) are common in the coastal region of Southern
California and at many inland locations. Between 1,000 BC to 650 AD (Intermediate period), orientation of
sites shifted toward hunting, maritime subsistence, and acorn processing. The late prehistoric period from
650 AD until European contact in 1769 included the introduction of pottery, triangular arrow points, and
cremation practices.
Snug Harbor Surf Park Project 5.4 Cultural Resources
City of Newport Beach 5.4-7
Draft EIR
May 2025
In July of 1769, Orange County was explored by those of European descent during a Franciscan expedition
led by Don Gaspar Portola. In the 1800s, Spanish and Mexican land owners, whose holdings comprised
Newport Beach’s upper bay and lower bay, sold their tracts to American entrepreneurs by the names of
Flint, Bixby, Irvine, and McFadden. In 1870, a ship from San Diego made its first trip to a marshy lagoon to
exchange goods. James McFadden and James Irvine named the landing on the bay “Newport”. In 1888,
James McFadden modified the isolated settlement by building a wharf that extended from the shallower
bay to deeper water so that large steamers could dock, which drastically increased shipping activity. By
1890, Newport Beach was acknowledged as a vibrant shipping town. The Pacific Electric Railroad was
established in 1905, which connected the City of Newport Beach to Los Angeles. Rail travel brought new
visitors to the area and eventually West Newport, East Newport, Bay Island, Balboa, Corona del Mar,
Balboa Island, and Port Orange were subdivided. In 1906, residents voted to incorporate and Newport
Beach became the fifth City to incorporate in Orange County (City of Newport Beach, 2006b).
Between 1934 and 1936, the Federal government and Orange County dredged the lower bay and
extended jetties, creating the present day contour of Newport Beach. At the end of World War II, a housing
construction boom began, which increased in the 1950s with the construction of the Santa Ana Freeway. With
increased residential development, the City’s economic industry of fishing declined and was replaced with
new businesses and commercial centers. By the 1970s, the development of Fashion Island, hotels, restaurants,
offices, and new housing tracts led to the establishment of many active employment, retail, and residential
areas that characterize Newport Beach today (City of Newport Beach, 2006b).
Golf in Southern California
The Historical Resources Evaluation (Appendix D) details that the first golf courses in southern California were
in Riverside at the Victoria Club and the Riverside Polo Club, both in 1893. In the 1890s, other courses were
established in Riverside, Redlands, Pasadena, Santa Monica, and Los Angeles. Golf course construction
boomed in the early 20th century. Although World War I led to a slowdown, the 1920s would become the
“Golden Age” for both golf course construction and for great amateur players in the southern California
region. In the 1930s, the number of public golf courses began to grow. However, golf was hit hard by the
Great Depression, and the number of clubs dropped significantly between 1930 and 1939. The game did
not fully recover until the post-World War II years (1945–1973). More than 150 golf courses were built in
southern California from 1960 to 1979, and another golf course building boom took place in the 1980s
(Appendix D).
Project Site
Based on historic maps and aerials of the Project site and vicinity, the Project site was initially disturbed by
mechanical disking as early as 1938 and the drainage adjacent to the site was constructed prior to 1938.
The current golf course and buildings were constructed in 1976 and are not yet 50 years old. The golf course
is one of more than 900 golf courses in California. The Historic Resources Evaluation (Appendix D) prepared
for the Project has evaluated the site and describes that the Project site is part of an 18-hole executive golf
course with a one-story Ranch-style clubhouse that has a Tiki influence and includes a pro shop, offices,
restrooms, and a restaurant. The clubhouse is irregular in plan and has a complex flat, shed, and gable roof.
The shed and gable portions of the roof are sheathed with what appears to be synthetic Spanish barrel tiles
and have large, exposed rafters (some notched) and wide eaves. The shed roof has a slightly extended
peak accentuated by a heavy, notched, exposed ridge beam. The exterior walls are covered with textured
stucco and have board-and-batten accents, as well as concrete and pebble stone accent panels and faux
buttresses. The pebble stone accents are patterned after the flagstone-accent walls popular in the 1960s
and 1970s. Fenestration consists of metal-framed windows typical of retail/commercial businesses.
Snug Harbor Surf Park Project 5.4 Cultural Resources
City of Newport Beach 5.4-8
Draft EIR
May 2025
The building has a central covered walkway on the northwest elevation of the pro shop that leads to a wide
breezeway between the pro shop and the restaurant. The restaurant entrance, located northwest of the
breezeway, is deeply recessed and has a pair of paneled wood doors with paneling above that gives the
appearance of floor-to-ceiling doors.
The driving range shack and canopies are located southwest of the clubhouse. They form a single structure
that is T-shaped in plan, with the gable-roofed shack in the center and the shed-roofed canopies flanking it.
The canopies are supported by metal poles and faux battered piers. The shack’s northeast gable-end peak
is slightly extended above a heavy ridge beam, and the fascia rests on two exposed rafters. The northwest
and southeast sides of the shack also have exposed rafters, and they support the eaves. The walls are
covered with textured stucco. The northeast elevation features a thick concrete and pebble stone accent that
is wider at the bottom than the top and extends beyond the side elevations. The southwest elevation was not
visible. In addition, the Project site contains a freestanding, wood-framed canopy over an outdoor dining
area west of the clubhouse; holes 1, 2, and 9 of the golf course; the driving range; and a parking lot.
Archaeological Setting
The chronology of coastal Southern California, which is inclusive of the Project site, is typically divided into
three general time periods: the Early Holocene (11,000 to 8,000 Before Present [B.P.]), the Middle Holocene
(8,000 to 4,000 B.P.), and the Late Holocene (4,000 B.P. to A.D. 1769). Sites dating from 9,000 to 10,000
years ago show evidence of human presence within the Orange County region. A review of geologic
mapping as detailed in the Phase I Archaeological Resources Assessment (Appendix E) indicates that the
Project area is underlain by Myford sandy loam and Thapto-Histic Fluvaquent deposits.
A total of 38 cultural resources studies have been performed within a 0.5-mile radius of the Project site. Of
these previous studies, three include the Project site. The records search conducted for the proposed Project
identified nine cultural resources, all of which are precontact/prehistoric. The nine resources primarily consist
of lithic scatters and habitation debris; however, resource P-30-000174, which is less than 0.25-mile
northwest of the Project site, also contained human remains (which were excavated in 1950). No
archaeological or historic resources have been previously recorded within the Project site. However, the
Project site near Upper Newport Bay (which would have served as a commonly and heavily used food source
for precontact populations in the area) indicates an elevated sensitivity for subsurface cultural resources
within the Project site.
5.4.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a Project could have a significant effect if it were to:
CUL-1 Cause a substantial adverse change in the significance of a historical resource pursuant to §
15064.5.
CUL-2 Cause a substantial adverse change in the significance of an archaeological resource pursuant to
§ 15064.5.
CUL-3 Disturb any human remains, including those interred outside of dedicated cemeteries.
Historical Resource Thresholds
Historical resources are usually 50 years old or older and must meet at least one of the criteria for listing in
the California Register (such as association with historical events, important people, or architectural
significance), in addition to maintaining a sufficient level of physical integrity (CEQA Guidelines Section
15064.5[a][3]). Additionally, CEQA Guidelines Section 15064.5(b), states that a project with an effect that
Snug Harbor Surf Park Project 5.4 Cultural Resources
City of Newport Beach 5.4-9
Draft EIR
May 2025
may cause a substantial adverse change in the significance of a historical resource is a project that would
have a significant effect on the environment. A substantial adverse change in the significance of a historical
resource means physical demolition, destruction, relocation, or alteration of the resource or its immediate
surroundings such that the significance of a historical resource would be materially impaired. The significance
of a historical resource is materially impaired when a project:
a) Demolishes or materially alters in an adverse manner those physical characteristics of an historical
resource that convey its historical significance and that justify its inclusion in, or eligibility for, inclusion in
the California Register of Historical Resources; or
b) Demolishes or materially alters in an adverse manner those physical characteristics that account for its
inclusion in a local register of historical resources pursuant to Section 5020.1(k) of the Public Resources
Code or its identification in an historical resources survey meeting the requirements of Section 5024.1(g)
of the Public Resources Code, unless the public agency reviewing the effects of the project establishes
by a preponderance of evidence that the resource is not historically or culturally significant; or
c) Demolishes or materially alters in an adverse manner those physical characteristics of a historical
resource that convey its historical significance and that justify its eligibility for inclusion in the California
Register of Historical Resources as determined by a lead agency for purposes of CEQA.
5.4.5 METHODOLOGY
Archaeological and Historic Records Search. An archaeological and historical records search was
conducted at the South Central Coastal Information Center (SCCIC) of the California Historical Resources
Inventory System (CHRIS), located at California State University, Fullerton on September 9, 2024. This search
included the Project site with an additional 0.5-mile buffer. In addition, archival research was done to obtain
historical development information. This archival research included review of the National Register, the
California Register, the Statewide Historical Resources Inventory, historical maps, historical aerial
photographs from 1938 to present, construction histories, and City Directories.
Archaeological and Historic Field Surveys. A pedestrian survey was conducted at the Project site on
September 10, 2024. At the time of the pedestrian survey, approximately 25 percent of ground sediments
were visible due to manicured landscaping and concrete. The active golf driving range was not surveyed as
it has no natural sediment and is covered by artificial turf and the paved portion of the parking lot was not
surveyed.
The historic (built-environment) survey consisted of inspection of the exterior of buildings and structures as
they were constructed over 45 years ago. The survey assessed the buildings’ current conditions and
documented evidence of renovations or alterations. Photographs were taken of each of the buildings as part
of the documentation process. A description of each structure’s style, design and method of construction was
recorded on California Department of Parks and Recreation (DPR) Series 523 forms.
Subsurface Archaeological Sensitivity Assessment. A desktop analysis was conducted to assess the
potential for subsurface archaeological resources within the Project area. Sources reviewed as part of the
desktop analysis include geologic maps and soil maps, the SCCIC records search results, the geotechnical
report for the proposed Project, and the historic map and aerial review.
5.4.6 ENVIRONMENTAL IMPACTS
IMPACT CUL-1: THE PROJECT WOULD NOT CAUSE A SUBSTANTIAL ADVERSE CHANGE IN THE
SIGNIFICANCE OF A HISTORICAL RESOURCE PURSUANT TO § 15064.5.
Snug Harbor Surf Park Project 5.4 Cultural Resources
City of Newport Beach 5.4-10
Draft EIR
May 2025
No Impact. According to the State CEQA Guidelines, a historical resource is defined as something that meets
one or more of the following criteria:
1. Listed in, or determined eligible for listing in, the California Register of Historical Resources;
2. Listed in a local register of historical resources as defined in Public Resources Code (PRC) Section
5020.1(k);
3. Identified as significant in a historical resources survey meeting the requirements of PRC Section
5024.1(g); or
4. Determined to be a historical resource by the project’s Lead Agency.
PRC Section 5024.1 directs evaluation of historical resources to determine their eligibility for listing on the
CRHR. The criteria for listing resources on the CRHR were expressly developed to be in accordance with
previously established criteria developed for listing on the NRHP, enumerated above, and require similar
protection to what NHPA Section 106 mandates for historic properties. According to PRC Section
5024.1(c)(1-4), a resource is considered historically significant if it meets at least one of the following criteria:
1. Associated with events that have made a significant contribution to the broad patterns of local or
regional history or the cultural heritage of California or the United States;
2. Associated with the lives of persons important to local, California or national history;
3. Embodies the distinctive characteristics of a type, period, region or method of construction or represents
the work of a master or possesses high artistic values; or
4. Has yielded, or has the potential to yield, information important to the prehistory or history of the local
area, California or the nation.
As described previously, the Project site is currently developed with a clubhouse; driving range shack and
canopies; holes 1, 2, and 9; the driving range; and parking lot. As previously discussed, the onsite structures
and improvements were constructed more than 45 years ago. Therefore, a Historical Resources Evaluation,
as included in Appendix D to this Draft EIR, was prepared for the Project.
According to the findings of the Historical Resources Evaluation, neither the 1976 Ranch-style clubhouse,
driving range shack, and canopies nor holes 1, 2, and 9 meet the criteria for listing in the National Register
(Criteria A-D), California Register of Historical Resources (Criteria 1-4), or designation under the City Council
policy Manual (Criteria 1a-f and 2a-c), as detailed below.
Criterion A/1 and City Criteria 2.a and 2.c: The improvements onsite do not retain a significant role in history
related to golf or the City of Newport Beach. The Historical Resources Evaluation details that the Newport
Beach Golf Course clubhouse, driving range shack, and holes 1 through 9 were completed in 1976. It is not
associated with Golf’s Golden Age (1910–1930) or the post-World War II (1945–1973) construction boom.
No evidence was found that it is associated with any other significant events in national, state, county, or
local history. The residential subdivisions around the Project site were all built more than a decade before
the golf course; and the golf course was not included in the planning process for those developments. Thus,
the site does not appear to be part of a historical development pattern. Therefore, the Historical Resources
Evaluation (Appendix D) determined that the onsite structures do not appear to meet the eligibility
requirements under National Register Criterion A, California Register Criterion 1, or City Council Policy
Manuel Criteria 2.a and 2.c.
Criterion B/2 and City Criteria 2.b: The onsite structures are not identified with historic individuals or events
of national, state, or local history and are not associated with significant individual owners or occupants. No
evidence was found that the Project site is associated with the productive lives of anyone significant in the
history of the nation, state, county, or City. Therefore, the Historical Resources Evaluation (Appendix D)
determined that the onsite structures do not appear to meet the eligibility requirements under National
Register Criterion B, California Register Criterion 2, or City historic criteria.
Snug Harbor Surf Park Project 5.4 Cultural Resources
City of Newport Beach 5.4-11
Draft EIR
May 2025
Criterion C/3 and City Criteria 1.a and 1.b: The onsite structures are not related to any historically significant
architects, construction companies, or developers. Although the buildings embody some characteristics of the
Ranch style such as the combination of wall cladding (stucco, board-and-batten, and stone) and the low and
moderately pitched roofs. The concrete and pebble stone accent panels and faux buttresses, heavy exposed
rafters and ridge beams, and extended gable peaks give the structures a Tiki influence. However, the
buildings do not express the ideals of either style more fully than others of a similar type, style, and vintage
and do not possess high artistic value. Thus, they were determined to not be significant for their architectural
design. No evidence was found that the designers of the buildings were master engineers or designers, or
that their style influenced the City’s architectural development. Thus, the buildings were determined to not
be a significant work of a master. Therefore, the Historical Resources Evaluation (Appendix D) determined
that the onsite structures do not appear to meet the eligibility requirements under National Register Criterion
C, California Register Criterion 3, or City historic criteria.
Criterion D/4: The onsite structures do not appear to yield significant information that would expand current
knowledge or theories of design, methods of construction, operation, or other information that is not already
known. The buildings were constructed in 1976 using modern methods and materials. Therefore, the Historical
Resources Evaluation determined that the onsite structures do not appear to meet the eligibility requirements
under National Register Criterion D, California Register Criterion 4, or City historic criteria.
Other Policy Manual Criteria: The Historical Resources Evaluation (Appendix D) determined that the onsite
structures do not meet any of the other requirements set forth by the City of Newport Beach City Council
Policy Manual criteria to be considered a historic resource, as described below.
City Criterion 1.c.: Rare structures displaying a building type, design, or indigenous building form. The 1976
Ranch-style clubhouse and driving range shack and canopies are not rare building structures, building types,
or indigenous building forms. Thus, they are not significant under this criterion.
City Criterion 1.d.: Structures which embody special architectural and design features. The Project site structures
do not embody any special architectural and design features. As detailed previously, although the buildings
embody some characteristics of the Ranch style such as the combination of wall cladding (stucco, board-and-
batten, and stone) and the low and moderately pitched roofs; the concrete and pebble stone accent panels
and faux buttresses, heavy exposed rafters and ridge beams, and extended gable peaks give the structures
a Tiki influence. However, the buildings do not express the ideals of either style more fully than others of a
similar type, style, and vintage and do not possess high artistic value. As a result, they were determined to
not be significant for their architectural design and are not significant under this criterion.
City Criterion 1.e.: Outstanding examples of structures displaying original architectural integrity, structurally or
stylistically, or both. The Project site buildings are not outstanding examples of a structural system or
architectural style. Thus, they are not significant under this criterion.
City Criterion 1.f.: Unique structures or places that act as focal or pivotal points important as a key to the
character or visual quality of an area. The golf course and related structures are not unique and are not a
focal point of the community or important to its visual character. There are 4 golf courses in Newport Beach
and another 57 courses within 20 miles of the City. Neither the nearby residential properties, which were
developed years before the Newport Beach Golf Course, nor the adjacent and nearby nonresidential
properties are oriented so that the golf course is their focal point. The Historical Resources Evaluation
(Appendix D) determined that the golf course is not a key visual feature that characterizes the area; and
that the Project site is not significant under this criterion.
Therefore, none of the existing buildings onsite meet any of the historic resource criteria and do not meet the
definition of a historical resource pursuant to CEQA or the City of Newport Beach. Thus, impacts related to
historic resources from implementation of the proposed Project would not occur.
Snug Harbor Surf Park Project 5.4 Cultural Resources
City of Newport Beach 5.4-12
Draft EIR
May 2025
IMPACT CUL-2: THE PROJECT WOULD NOT CAUSE A SUBSTANTIAL ADVERSE CHANGE IN THE
SIGNIFICANCE OF AN ARCHAEOLOGICAL RESOURCE PURSUANT TO § 15064.5.
Less than Significant with Mitigation Incorporated. As described previously, the Project has been disturbed
since at least 1938 from mechanical disking and onsite structures were constructed in 1976. Thus, the site has
been previously disturbed, including ground disturbance to depths for installation of the existing utility
infrastructure that serves the site. A Phase I Archaeological Resources Assessment was prepared for the
proposed Project to analyze the potential archaeological sensitivity of the Project site and the potential for
Project ground disturbance to result in impacts to archaeological resources.
Based on the SCCIC records search results and archaeological survey of the Project site, no archaeological
resources have been identified within or immediately adjacent to the proposed Project site. However, the
Phase I Archaeological Resources Assessment determined that due to the presence of known archaeological
resources, including human remains, within 0.25-mile from the Project site and the Project site’s proximity to
the Upper Newport Bay, the Project area is sensitive for prehistoric archaeological deposits (Appendix E).
As described in Section 3.0, Project Description, construction activities within the Project site include demolition
of existing buildings; removal of existing infrastructure and landscaping; and grading and excavation to
depths of 15 feet below ground surface to remove existing onsite undocumented fill. As the Project site is
sensitive for previously unknown archaeological resources, the Phase I Archaeological Resources Assessment
determined that the Project would be required to implement Mitigation Measures CUL-1 and CUL-2, which
requires an archaeologist to be retained for monitoring throughout proposed Project ground disturbing
activities and preparation of a monitoring report. With implementation of Mitigation Measure CUL-1 and
CUL-2, potential impacts related to archeological resources would be less than significant.
IMPACT CUL-3: THE PROJECT WOULD NOT DISTURB ANY HUMAN REMAINS, INCLUDING THOSE
INTERRED OUTSIDE OF DEDICATED CEMETERIES.
Less than Significant Impact. The Project site has been extensively disturbed, as described above, and has
not been previously used as a cemetery. Thus, impacts related to known human remains are less than
significant. However, in the unanticipated event that human remains are found during proposed Project
construction activities, compliance with California Health and Safety Code Section 7050.5 would ensure that
human remains are treated with dignity and as specified by law, which would reduce the impact to a less
than significant level.
As specified by California Health and Safety Code Section 7050.5, included as PPP CUL-1, if human remains
are found on the Project site, the County Coroner’s office shall be immediately notified and no further
excavation or disturbance of the discovery or any nearby area reasonably suspected to overlie adjacent
remains shall occur until the Coroner has made the necessary findings as to origin and disposition pursuant
to Public Resources Code 5097.98. If the Coroner recognizes the remains to be Native American, he or she
shall contact the Native American Heritage Commission (NAHC) within 24 hours. The NAHC will make a
determination as to the Most Likely Descendent. The existing California Health and Safety Code regulations
provide that impacts related to potential disturbance of human remains are less than significant.
5.4.7 CUMULATIVE IMPACTS
The cumulative study area for cultural resources includes the coastal region of Orange County.
Historic Resources: The Project’s contribution to cumulative impacts to historical resources was analyzed in
context with past projects in Orange County that were once similarly influenced by the golfing industry in
the region. The Historical Resources Evaluation determined the absence of historical resources. Therefore,
Snug Harbor Surf Park Project 5.4 Cultural Resources
City of Newport Beach 5.4-13
Draft EIR
May 2025
Project implementation would have no potential to contribute towards a significant cumulative impact to
historical sites and/or resources, and cumulatively considerable impacts would not occur.
Archaeological Resources: The Project’s impact to prehistoric archaeological resources was analyzed in the
context of the coastal region of Orange County, which is identified as sensitive for archaeological resources.
Construction activities within the Project site – as with other development projects in the region – may uncover
subsurface prehistoric archaeological resource that meet the CCR § 15064.5 definition. However, mitigation
has been included to reduce the potential of the Project to result in an impact to an archaeological resource
that could contribute to a significant cumulative impact. With compliance with project-specific mitigation, the
Project would result in a less than significant cumulatively considerable impact.
Disturbance of Human Remains: Mandatory compliance with the provisions of California Health and Safety
Code § 7050.5, Public Resources Code § 5097 et seq., and CEQA Guidelines Section 15064.5 would assure
that the Project, in addition to all development projects, treat human remains that may be uncovered during
development activities in accordance with prescribed, respectful, and appropriate practices, thereby
avoiding significant cumulative impacts.
5.4.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES
The following would reduce potential impacts related to cultural resources.
Existing Regulations
• California Health and Safety Code Section 7050.5
• Public Resources Code Section 5097.98
Existing City Council Policy Manual Policies
• City Council Policy Manual Policy K-2, Places of Historical and Architectural Significance
• City Council Policy Manual Policy K-5, Paleontological and Archaeological Resource Protection Guidelines
Plans, Programs, or Policies
PPP CUL-1: Human Remains. California Health and Safety Code Section 7050.5, CEQA Guidelines Section
15064.5, and Public Resources Code Section 5097.98 mandate the process to be followed in the event of
an accidental discovery of any human remains in a location other than a dedicated cemetery. California
Health and Safety Code Section 7050.5 requires that in the event that human remains are discovered within
the project site, disturbance of the site shall be halted until the coroner has conducted an investigation into
the circumstances, manner and cause of death, and the recommendations concerning the treatment and
disposition of the human remains have been made to the person responsible for the excavation, or to his or
her authorized representative, in the manner provided in Section 5097.98 of the Public Resources Code. 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.
5.4.9 PROJECT DESIGN FEATURES
None.
Snug Harbor Surf Park Project 5.4 Cultural Resources
City of Newport Beach 5.4-14
Draft EIR
May 2025
5.4.10 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Impact CUL-1 and CUL-3 would be less than significant.
Without mitigation, the following impacts would be potentially significant:
• Impact CUL-2: Implementation of the Project may impact an archaeological resource.
5.4.11 MITIGATION MEASURES
Mitigation Measure CUL-1: Cultural Resources Monitoring Program. Prior to issuance of grading permits
the applicant/developer shall provide evidence to the City of Newport Beach Planning Division that a
qualified professional archeologist meeting the Secretary of Interior’s PQS for Archaeology (as defined in
the Code of Federal Regulations, 36 CFR Part 61) has been retained to prepare a Cultural Resource
Monitoring Program (CRMP) and to conduct monitoring of rough grading activities. The CRMP shall be
developed in coordination with the consulting tribe(s) and address the details of all activities and provides
procedures that must be followed in order to reduce the impacts to cultural, tribal cultural and historic
resources to a level that is less than significant as well as address potential impacts to undiscovered buried
archaeological resources associated with this project. The Archaeologist shall conduct Cultural Resource
Sensitivity Training, in conjunction with the Tribe(s) designated Tribal Representative. The training session shall
focus on the archaeological and tribal cultural resources that may be encountered during ground-disturbing
activities as well as the procedures to be followed in such an event.
The retained Qualified archeologist and Consulting Tribe(s) representative shall attend the pre-grade
meeting with the grading contractors to explain and coordinate the requirements of the monitoring plan.
In the event that a resource is inadvertently discovered during ground-disturbing activities, work shall be
halted within 60 feet of the find until it can be evaluated by the qualified archaeologist. Construction
activities can continue in other areas. If the find is considered a “resource” the archaeologist shall pursue
either protection in place or recovery, salvage and treatment of the deposits. Recovery, salvage and
treatment protocols shall be developed in accordance with applicable provisions of Public Resource Code
Section 21083.2 and State CEQA Guidelines 15064.5 and 15126.4 in consultation with the City. Per CEQA
Guidelines Section 15126.4(b)(3), preservation in place shall be the preferred means to avoid impacts to
archaeological resources qualifying as historical resources. Consistent with CEQA Guidelines Section
15126.4(b)(3)(C), if unique archaeological resources cannot be preserved in place or left in an undisturbed
state, recovery, salvage, and treatment shall be required at the developer/applicant’s expense. If significant
pre-contact and/or historic-era cultural resources, as defined by CEQA (as amended, 2015), are discovered
and avoidance cannot be ensured, the archaeologist shall develop a Monitoring and Treatment Plan, the
drafts of which shall be provided to consulting tribe(s) for review and comment. The archaeologist shall
monitor the remainder of the project and implement the Plan accordingly.
Mitigation Measure CUL-2: Monitoring Report. A final monitoring report shall be prepared by the qualified
archaeologist prior to issuance of any certificate of occupancy. The final monitoring report(s) created as a
part of the Project (isolate records, site records, survey reports, testing reports, etc.) shall be submitted to
the Lead Agency and Consulting Tribe(s) for review and comment. After approval of all parties, the final
reports are to be submitted to the South Central Coastal Information Center, and the Consulting Tribe(s).
Snug Harbor Surf Park Project 5.4 Cultural Resources
City of Newport Beach 5.4-15
Draft EIR
May 2025
5.4.12 LEVEL OF SIGNIFICANCE AFTER MITIGATION
With implementation of Mitigation Measures CUL-1 through CUL-3 and compliance with regulatory
requirements, Project impacts to cultural resources would be less than significant.
5.4.13 REFERENCES
City of Newport Beach. (2001, January). Santa Ana Heights Specific Plan. Retrieved September 23, 2024,
from ocpublicworks.com.
City of Newport Beach. (2006a, July). General Plan. Retrieved September 23, 2024, from
newportbeachca.gov: https://www.newportbeachca.gov/government/departments/community-
development/planning-division/general-plan-codes-and-regulations/general-plan
City of Newport Beach. (2006b, July). General Plan Environmental Impact Report. Retrieved September 23,
2024, from newportbeachca.gov:
https://www.newportbeachca.gov/government/departments/community-development/planning-
division/general-plan-codes-and-regulations/general-plan/general-plan-environmental-impact-
repor
City of Newport Beach. (2024a). Newport Beach Municipal Code. Retrieved September 23, 2024, from
codepublishing.com: https://www.codepublishing.com/CA/NewportBeach/
City of Newport Beach. (2024b). Council Policy Manual.
https://www.newportbeachca.gov/government/city-council/council-policy-manual
City of Newport Beach. (2024c). Council Policy Manuel, K-2, Places of Historical and Arcitectural
Significance.
https://www.newportbeachca.gov/home/showpublisheddocument/2439/636385643927630000
City of Newport Beach. (n.d.). Ad Hoc Historic Preservation Advisory Committee Historic Resource Inventory.
Glenn Lukos Associates. (2024). Phase I Archaeological Resources Assessment for the Surf Farm Project,
Located in the City of Newport Beach, Orange County, California. (Appendix E)
LSA Associates. (2024). Historic Resources Evaluation for the Newport Beach Golf Course Clubhouse and
Driving Range Shack/Canopy in Newport Beach, Orange County, California. (Appendix D)
Snug Harbor Surf Park Project 5.4 Cultural Resources
City of Newport Beach 5.4-16
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 5.5 Energy
City of Newport Beach 5.5-1
Draft EIR
May 2025
5.5 Energy
5.5.1 INTRODUCTION
This section of the Draft EIR assesses the significance of the use of energy, including electricity, natural gas,
and gasoline and diesel fuels, that would result from implementation of the proposed Project. It discusses
existing energy use patterns and examines whether the proposed Project (including development and
operation) would result in the unnecessary consumption of large amounts of fuel or energy or use such
resources in a wasteful or inefficient manner, including the use of renewable energy resources. This section
of the EIR is based, in part, on the following documents and resources.
• City of Newport Beach General Plan, 2006
• City of Newport Beach General Plan Environmental Impact Report (General Plan EIR), 2006
• City of Newport Beach Municipal Code
• Surf Farm Energy Tables, prepared by Urban Crossroads, 2024, included as Appendix F
Refer to Section 5.7, Greenhouse Gas Emissions, for a discussion of the relationship between energy
consumption and greenhouse gas (GHG) emissions, and Section 5.16, Utilities and Service Systems, for a
discussion of utilities, including electric and natural gas utilities.
5.5.2 REGULATORY SETTING
5.5.2.1 Federal Regulations
Energy Independence and Security Act, Corporate Average Fuel Efficiency Standards
On December 19, 2007, the Energy Independence and Security Act of 2007 was signed into law, requiring
an increased Corporate Average Fuel Economy (CAFE) standard of 35 miles per gallon (mpg) for the
combined fleet of cars and light trucks by the 2020 model year.
In addition to setting increased CAFE standards for motor vehicles, the Energy Independence and Security
Act includes the following additional provisions:
• Renewable Fuel Standard (RFS) (Section 202)
• Appliance and Lighting Efficiency Standards (Sections 301–325)
• Building Energy Efficiency (Sections 411–441)
Additional provisions of the Act address energy savings in government and public institutions, promoting
research for alternative energy, additional research in carbon capture, international energy programs, and
the creation of green jobs.
5.5.2.2 State Regulations
California Code of Regulations (CCR) Title 13, Motor Vehicles, Section 2449(d)(3)
No vehicle or engines subject to this regulation may idle for more than 5 consecutive minutes. The idling limit
does not apply to:
• Idling when queuing;
Snug Harbor Surf Park Project 5.5 Energy
City of Newport Beach 5.5-2
Draft EIR
May 2025
• Idling to verify that the vehicle is in safe operating condition;
• Idling for testing, servicing, repairing or diagnostic purposes;
• Idling necessary to accomplish work for which the vehicle was designed (such as operating a crane);
• Idling required to bring the machine system to operating temperature; and
• Idling necessary to ensure safe operation of the vehicle.
Assembly Bill 1279
Assembly Bill (AB) 1279 requires the State to achieve net zero GHG emissions as soon as possible, but no
later than 2045, and achieve and maintain net negative greenhouse gas emissions thereafter. The bill also
requires California to reduce statewide GHG emissions by 85 percent compared to 1990 levels and directs
the California Air Resources Board to work with relevant State agencies to achieve these goals.
Title 24 Energy Efficiency Standards and California Green Building Standards
California Code of Regulations (CCR) Title 24 Part 6: The California Energy Code was first adopted in 1978
in response to a legislative mandate to reduce California’s energy consumption. The standards are updated
periodically to allow consideration and possible incorporation of new energy efficient technologies and
methods. The most recently updated 2022 Energy Code encourages efficient electric heat pumps, establishes
electric-ready requirements for new homes, expands solar photovoltaic and battery storage standards, and
strengthens ventilation standards, among other requirements.
CCR, Title 24, Part 11: California Green Building Standards Code (CALGreen) is a comprehensive and
uniform regulatory code for all new construction and major renovations and is administered by the California
Building Standards Commission. The purpose of CALGreen is to improve public health, safety, and general
welfare through enhanced design and construction of buildings using concepts which reduce negative impacts
and promote those principles which have a positive environmental impact and encourage sustainable
construction practices. It is also updated every three years. The most recent update is the 2022 CALGreen
Code that became effective January 1, 2023.
It should be noted that the 2025 California Green Building Code and Energy Efficiency Standards are
expected to be effective on January 1, 2026. The Project would be required to comply with the applicable
standards in place at the time plan check submittals are made.
The 2022 California Energy Code and CALGreen Building Standards Code mandatory measures for
nonresidential uses that reduce air pollutant emissions and are applicable to the proposed Project include,
but are not limited to, the following:
• Short-term bicycle parking. If the new project or an additional alteration is anticipated to generate
visitor traffic, provide permanently anchored bicycle racks within 200 feet of the visitors’ entrance,
readily visible to passers-by, for 5% of new visitor motorized vehicle parking spaces being added, with
a minimum of one two-bike capacity rack (5.106.4.1.1).
• Long-term bicycle parking. For new buildings with tenant spaces that have 10 or more tenant-occupants,
provide secure bicycle parking for 5% of the tenant-occupant vehicular parking spaces with a minimum
of one bicycle parking facility (5.106.4.1.2).
• EV charging stations. New construction shall facilitate the future installation of EV supply equipment. The
compliance requires empty raceways for future conduit and documentation that the electrical system has
adequate capacity for the future load. The number of spaces to be provided for is contained in Table
5.106. 5.3.3 (5.106.5.3). Additionally, Table 5.106.5.4.1 specifies requirements for the installation of
raceway conduit and panel power requirements for medium- and heavy-duty electric vehicle supply
equipment for warehouses, grocery stores, and retail stores.
Snug Harbor Surf Park Project 5.5 Energy
City of Newport Beach 5.5-3
Draft EIR
May 2025
• Outdoor light pollution reduction. Outdoor lighting systems shall be designed to meet the backlight, uplight
and glare ratings per Table 5.106.8 (5.106.8).
• Construction waste management. Recycle and/or salvage for reuse a minimum of 65% of the
nonhazardous construction and demolition waste in accordance with Section 5.408.1.1. 5.405.1.2,
or 5.408.1.3; or meet a local construction and demolition waste management ordinance, whichever
is more stringent (5.408.1).
• Excavated soil and land clearing debris. 100% of trees, stumps, rocks and associated vegetation
and soils resulting primarily from land clearing shall be reuse or recycled. For a phased project, such
material may be stockpiled on site until the storage site is developed (5.408.3).
• Recycling by Occupants. Provide readily accessible areas that serve the entire building and are identified
for the depositing, storage, and collection of non-hazardous materials for recycling, including (at a
minimum) paper, corrugated cardboard, glass, plastics, organic waste, and metals or meet a lawfully
enacted local recycling ordinance, if more restrictive (5.410.1).
• Water conserving plumbing fixtures and fittings. Plumbing fixtures (water closets and urinals) and
fittings (faucets and showerheads) shall comply with the following:
o Water Closets. The effective flush volume of all water closets shall not exceed
o 1.28 gallons per flush (5.303.3.1)
o Urinals. The effective flush volume of wall-mounted urinals shall not exceed
o 0.125 gallons per flush (5.303.3.2.1). The effective flush volume of floor- mounted or other urinals
shall not exceed 0.5 gallons per flush (5.303.3.2.2).
o Showerheads. Single showerheads shall have a minimum flow rate of not more than 1.8 gallons
per minute and 80 psi (5.303.3.3.1). When a shower is served by more than one showerhead, the
combine flow rate of all showerheads and/or other shower outlets controlled by a single valve
shall not exceed 1.8 gallons per minute at 80 psi (5.303.3.3.2).
o Faucets and fountains. Nonresidential lavatory faucets shall have a maximum flow rate of not
more than 0.5 gallons per minute at 60 psi (5.303.3.4.1). Kitchen faucets shall have a maximum
flow rate of not more than 1.8 gallons per minute of 60 psi (5.303.3.4.2). Wash fountains shall
have a maximum flow rate of not more than 1.8 gallons per minute (5.303.3.4.3). Metering
faucets shall not deliver more than 0.20 gallons per cycle (5.303.3.4.4). Metering faucets for wash
fountains shall have a maximum flow rate not more than 0.20 gallons per cycle (5.303.3.4.5).
• Outdoor potable water uses in landscaped areas. Nonresidential developments shall comply with a local
water efficient landscape ordinance or the current California Department of Water Resources’ Model
Water Efficient Landscape Ordinance (MWELO), whichever is more stringent (5.304.1).
• Water meters. Separate submeters or metering devices shall be installed for new buildings or
additions in excess of 50,000 SF or for excess consumption where any tenant within a new building or
within an addition that is project to consume more than 1,000 gallons per day (GPD) (5.303.1.1 and
5.303.1.2).
• Outdoor water uses in rehabilitated landscape projects equal or greater than 2,500 SF. Rehabilitated
landscape projects with an aggregate landscape area equal to or greater than 2,500 SF requiring
a building or landscape permit (5.304.3).
• Commissioning. For new buildings 10,000 SF and over, building commissioning shall be included in the
design and construction processes of the building project to verify that the building systems and
components meet the owner’s or owner representative’s project requirements (5.410.2).
The 2022 Energy Code has been adopted by the City of Newport Beach in Municipal Code Chapter 15.17,
and the 2022 CALGreen Code in Municipal Code Chapter 15.11.
Snug Harbor Surf Park Project 5.5 Energy
City of Newport Beach 5.5-4
Draft EIR
May 2025
5.5.2.3 Local and Regional Regulations
City of Newport Beach General Plan 2006
The City of Newport Beach General Plan 2006 contains the following policies related to energy that are
applicable to the Project:
Policy CE 7.1.8 Electric Vehicle (EV) Charging Stations. Install additional EV charging stations on City
properties, support existing private development to add new EV charging stations and
develop incentives for the installation of EV charging stations and other alternative fuels
systems as part of new development.
Policy NR 24.1 Incentives for Energy Conservation. Develop incentives that encourage the use of energy
conservation strategies by private and public developments.
Policy NR 24.2 Energy-Efficient Design Features. Promote energy-efficient design features.
Policy NR 24.3 Incentives for Green Building Program Implementation. Promote or provide incentives
for “Green Building” programs that go beyond the requirements of Title 24 of the
California Administrative Code and encourage energy efficient design elements as
appropriate to achieve “green building” status.
Policy NR 24.4 Incentives for Provision of LEED Certified Buildings. Provide incentives for implementing
Leadership in Environmental and Energy Design (LEED) certified building such as fee
waivers, bonus densities, and/or awards recognition programs.
City of Newport Beach Energy Action Plan
The City of Newport Beach’s Energy Action Plan outlines strategies to enhance energy efficiency, promote
renewable energy, and reduce GHG emissions. By implementing energy efficiency programs in residential
and commercial buildings, encouraging renewable energy sources like solar, and setting long-term
sustainability goals, the plan aims to mitigate climate change impacts. It also emphasizes community
engagement and collaboration with local organizations to foster a culture of energy conservation. Ultimately,
the plan directly contributes to reducing GHG emissions, improving air quality, and promoting a healthier,
more sustainable environment for residents. The Plan is focused on City buildings and facilities and does not
include any specific policies for new commercial recreational development projects.
City of Newport Beach Municipal Code
Section 15.11.010, Adoption of the California Green Building Standards Code. The City Council adopts
and incorporates by reference, as though set forth in full in this section, the 2022 Edition of the California
Green Building Standards Code.
Section 15.17.010, Adoption of the California Energy Code. The City Council adopts and incorporates by
reference, as though set forth in full in this section, the 2022 Edition of the California Energy Code, 24 CCR
and all national codes and standards referenced therein to the prescribed extent of each such reference.
Section 15.18.040, Solar Energy Requirements. This section of the Municipal Code sets the requirements
for solar energy systems with the City of Newport Beach.
Chapter 15.19, Electric Vehicle Charging Stations. Municipal Code Chapter 15.19 aims to encourage the
use of electric vehicle charging stations by removing unreasonable barriers, minimizing costs to property
owners and the City, and expanding the ability of property owners to install electric vehicle charging stations.
Snug Harbor Surf Park Project 5.5 Energy
City of Newport Beach 5.5-5
Draft EIR
May 2025
Pursuant to Municipal Code Section 15.19.060, applications to install electric vehicle charging stations
through issuance of a building permit or similar nondiscretionary permit will be administratively reviewed
and approved by the Building Division.
5.5.3 ENVIRONMENTAL SETTING
5.5.3.1 Electricity
The Southern California Edison Company (SCE) is the electrical purveyor in the City of Newport Beach. SCE
provides electricity service to more than 14 million people in a 50,000-square-mile area of central, coastal
and Southern California. California utilities are experiencing increasing demands that require modernization
of the electric distribution grid to, among other things, accommodate two-way flows of electricity and
increase the grid’s capacity. SCE is in the process of implementing infrastructure upgrades to ensure the
ability to meet future demands. In addition, as described by the Edison International 2023 Annual Report,
the SCE electrical grid modernization effort supports implementation of California requirements to achieve
carbon neutrality by 2045. The State has set Renewables Portfolio Standards that require retail sellers of
electricity to provide 60 percent of power from renewable resources by 2030. The State also requires
sellers of electricity to deliver 100 percent of retail sales from carbon-free sources by 2045, including interim
targets of 90 percent by 2035 and 95 percent by 2040. In 2023 approximately 49 percent of power that
SCE delivered to customers came from carbon-free resources (SCE, 2024).
The Project site is currently served by the SCE electricity distribution systems that exist along the roadways
adjacent to the Project site. The existing uses on the Project site currently use 96,160 kWh of electricity per
year (Appendix F).
5.5.3.2 Natural Gas
The Southern California Gas Company (SoCalGas) is the natural gas purveyor in the City of Newport Beach
and is the principal distributor of natural gas in Southern California. SoCalGas estimates that gas demand
will decline at an annual rate of 3.0 percent from 2024 to 2040 due to mandated energy efficiency
standards and programs, renewable electricity goals, and global warming). The gas supply available to
SoCalGas is regionally diverse and includes supplies from California (onshore and offshore), the
southwestern United States, the Rocky Mountains, and Canada. SoCalGas designs its facilities and supplies
to provide continuous service during extreme peak demands and has identified the ability to meet peak
demands through 2030 (CGEU, 2024).
The Project site currently connects to an existing 2-inch gas line in Irvine Avenue via a 1-inch line through the
existing parking lot to the north. The existing uses on the Project site currently use 900,000 kBTU of natural
gas per year (Appendix F).
5.5.3.3 Petroleum
The vehicular trips related to the existing golf course uses on the Project site generates the greatest existing
use of petroleum results is from Project-generated traffic and the vehicle fuel economies of vehicles. These
existing uses on the Project site are estimated to generate 5,282,945 vehicle miles traveled (VMT) that utilize
196,821 gallons of fuel annually (Appendix F).
Snug Harbor Surf Park Project 5.5 Energy
City of Newport Beach 5.5-6
Draft EIR
May 2025
5.5.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a Project could have a significant effect if it were to:
ENE-1 Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary
consumption of energy resources, during project construction or operation.
ENE-2 Conflict with or obstruct a State or local plan for renewable energy or energy efficiency.
5.5.5 METHODOLOGY
A number of factors are considered when weighing whether a project would use a proportionately large
amount of energy or whether the use of energy would be wasteful in comparison to other projects. Factors
such as the use of onsite renewable energy features, energy conservation features or programs, and relative
use of transit are considered.
According to Appendix F of the CEQA Guidelines, conserving energy is defined as decreasing overall per
capita energy consumption, decreasing reliance on natural gas and oil, and increasing reliance on renewable
energy sources. Neither Appendix F of the CEQA Guidelines nor Public Resources Code Section 21100(b)(3)
offer a numerical threshold of significance that might be used to evaluate the potential significance of energy
consumption of a project. Rather, the emphasis is on reducing “the wasteful, inefficient, and unnecessary
consumption of energy.”
Construction activities would result in wasteful, inefficient, or unnecessary use of energy if construction
equipment is old or not well maintained, if equipment is left to idle when not in use, if travel routes are not
planned to minimize vehicle miles traveled, or if excess lighting or water is used during construction activities.
Energy usage during project operation would be considered “wasteful, inefficient, and unnecessary” if the
project were to violate federal, State, and/or local energy standards, including Title 24 of the California
Code of Regulations, inhibit feasible opportunities to use alternative energy sources, such as solar energy,
or otherwise inhibit the conservation of energy.
5.5.6 ENVIRONMENTAL IMPACTS
IMPACT ENE-1: THE PROJECT WOULD NOT 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.
Construction
During construction of the proposed Project, energy would be consumed in three general forms:
1. Petroleum-based fuels used to power off-road construction vehicles and equipment, construction worker
travel to and from the Project site, as well as delivery truck trips;
2. Electricity associated with providing temporary power for lighting and electric construction equipment;
and
3. Energy used in the production of construction materials, such as asphalt, steel, concrete, pipes, and
manufactured or processed materials such as lumber and glass.
Construction activities related to the proposed Project and the associated infrastructure are not expected to
result in demand for fuel greater on a per-unit-of-development basis than any other development projects
Snug Harbor Surf Park Project 5.5 Energy
City of Newport Beach 5.5-7
Draft EIR
May 2025
in Southern California. Demolition of existing structures is limited and much of the demolition materials would
be recycled pursuant to the CALGreen Building Standards Code. Also, CCR Title 13, Motor Vehicles, Section
2449(d)(3), Idling, limits idling times of construction vehicles to no more than 5 minutes, thereby precluding
unnecessary and wasteful consumption of fuel due to unproductive idling of construction equipment. The
energy analysis modeling for construction of the Project (included as Appendix F) details that the total
construction would utilize 23,801 kWh of electricity as detailed in Table 5.5-1.
Table 5.5-1: Estimated Construction Electricity Usage
Land Use Cost per kWh Project Construction
Electricity Usage (kWh)
Clubhouse $0.16 20,492
Athlete Accommodation Building $0.16 3,309
Construction Electricity Usage 23,801
Source: Appendix F
Also, as shown in Table 5.5-2, construction of the Project is estimated to result in the need for 68,414 gallons
of diesel fuel.
Table 5.5-2: Estimated Construction Fuel Consumption
Construction
Activity
Duration
(Days) Equipment HP
Rating Quantity Usage
Hours
Load
Factor
HP-
hrs/day
Total Fuel
Consumption
20
Concrete/Industrial Saws 33 1 8 0.73 193 208
Excavators 36 2 8 0.38 219 237
Rubber Tired Dozers 367 1 0.40 1,174 1,270
Site
Preparation 30
Tractors/Loaders/
Backhoes 84 2 8 0.37 497 806
Crawler Tractors 87 1 8 0.43 299 485
Grading 50
Rubber Tired Loaders 150 2 8 0.36 864 2,335
Excavators 36 2 8 0.38 219 592
Graders 148 4 8 0.41 1,942 5,248
Rubber Tired Dozers 367 2 8 0.40 2,349 6,348
Scrapers 423 2 8 0.48 3,249 8,780
Building
Construction 300
Cranes 367 1 8 0.29 851 13,807
Forklifts 82 3 8 0.20 394 6,383
Generator Sets 14 2 8 0.74 166 2,688
Tractors/Loaders/
Backhoes 84 3 0.37 746 12,096
Welders 46 1 8 0.45 166 2,685
Paving 60
Pavers 81 2 8 0.42 544 1,765
Paving Equipment 89 2 8 0.36 513 1,663
Rollers 36 2 8 0.38 219 710
Architectural
Coating 40 Air Compressors 37 1 8 0.48 142 307
Construction Fuel Demand (Gallons Diesel Fuel) 68,414
Source: Appendix F
Snug Harbor Surf Park Project 5.5 Energy
City of Newport Beach 5.5-8
Draft EIR
May 2025
Table 5.5-3 shows that construction workers would use approximately 6,973 gallons of fuel in automobiles
during construction of the Project.
Table 5.5-3: Estimated Construction Worker Fuel Consumption (Automobiles)
Year Construction Activity Duration
(Days)
Worker
Trips/Day
Trip
Length
(miles)
VMT
Average
Vehicle Fuel
Economy
(mpg)
Estimated
Fuel
Consumption
(gallons)
2026
LDA
Demolition 20 5 18.5 1,850 34.81 53
Site Preparation 30 4 18.5 2,220 34.81 64
Grading 50 15 18.5 13,875 34.81 399
Building Construction 97 13 18.5 23,329 34.81 670
LDT1
Demolition 20 3 18.5 1,110 26.28 42
Site Preparation 30 2 18.5 1,110 26.28 42
Grading 50 8 18.5 7,400 26.28 282
Building Construction 97 7 18.5 12,562 26.28 478
LDT2
Demolition 20 3 18.5 1,110 26.07 43
Site Preparation 30 2 18.5 1,110 26.07 43
Grading 50 8 18.5 7,400 26.07 284
Building Construction 97 7 18.5 12,562 26.07 482
2027
LDA
Building Construction 203 13 18.5 48,822 35.67 1,369
Paving 60 8 18.5 8,880 35.67 249
Architectural Coating 40 3 18.5 2,220 35.67 62
LDT1
Building Construction 203 7 18.5 26,289 26.76 982
Paving 60 4 18.5 4,440 26.76 166
Architectural Coating 40 2 18.5 1,480 26.76 55
LDT2
Building Construction 203 7 18.5 26,289 26.65 987
Paving 60 4 18.5 4,440 26.65 167
Architectural Coating 40 2 18.5 1,480 26.65 56
Total Construction Worker Fuel Consumption 6,973
Notes: LDA = light-duty auto vehicles. LDT1 = light-duty trucks with equivalent test weight less than or equal to 3,750 lbs. LDT2 =
light-duty trucks with equivalent test weight between 3,751 and 5,750 lbs.
Source: Appendix F
Snug Harbor Surf Park Project 5.5 Energy
City of Newport Beach 5.5-9
Draft EIR
May 2025
Table 5.5-4 shows that approximately 4,035 gallons of fuel would be used by vendor trucks for construction
of the Project.
Table 5.5-4: Estimated Construction Vendor/Hauling Fuel Consumption
Year Construction Activity Duration
(Days)
Vendor
Trips/Day
Trip
Length
(miles)
VMT
Average
Vehicle Fuel
Economy
(mpg)
Estimated
Fuel
Consumption
(gallons)
2026
MHDT
Demolition 20 1 10.2 204 7.76 26
Site Preparation 30 1 10.2 306 7.76 39
Grading 50 1 10.2 510 7.76 66
Building Construction 97 4 10.2 3,958 7.76 510
HHDT (Vendor)
Demolition 20 1 10.2 204 6.20 33
Site Preparation 30 1 10.2 306 6.20 49
Grading 50 1 10.2 510 6.20 82
Building Construction 97 4 10.2 3,958 6.20 638
HHDT (Hauling)
Demolition 20 9 8 1,440 6.20 232
2026
MHDT
Building Construction 203 4 10.2 8,282 7.91 1,048
HHDT
Building Construction 203 4 10.2 8,282 6.32 1,311
Total Construction Vendor/Hauling Fuel Consumption 4,035
Notes: MHDT = medium-heavy-duty trucks. HHDT = heavy-heavy-duty trucks.
Source: Appendix F
Construction contractors are required to demonstrate compliance with applicable California Air Resources
Board (CARB) regulations governing the accelerated retrofitting, repowering, or replacement of heavy-duty
diesel on- and off-road equipment. In addition, compliance with existing CARB idling restrictions and the use
of newer engines and equipment would reduce fuel combustion and energy consumption. Overall,
construction activities would require limited energy consumption as construction of the Project would only last
18 months, and would comply with all existing regulations, and would therefore not be expected to use
large amounts of energy or fuel in a wasteful manner. Thus, impacts related to construction energy usage
would be less than significant.
Operation
Once operational, the proposed Project would generate demand for electricity, gasoline for motor vehicle
trips, and natural gas for the proposed restaurant uses and to heat the lagoon, warming pools, and spa
water. Operational use of energy also includes the heating, cooling, and lighting of the buildings, building
water heating, operation of electrical systems and plug-in appliances within the buildings, parking lot and
outdoor lighting, and the transport of electricity and water to the areas where they would be consumed. This
use of energy is typical for urban development and no operational activities or land uses would occur that
would result in extraordinary energy consumption. In addition, as shown in Figure 3-11, Proposed Solar PV
Installation, the Project proposes the use of solar PV panels on canopies in the parking lot areas and on top
Snug Harbor Surf Park Project 5.5 Energy
City of Newport Beach 5.5-10
Draft EIR
May 2025
of both proposed buildings in order to implement renewable energy and reduce the need for electricity
from the electric grid. The proposed solar PV panels are included as Project Design Feature (PDF) -1.
As detailed by the energy modeling that was prepared for the Project (Appendix F), fuel consumed by
Project-generated traffic is a function of total vehicle miles traveled (VMT) and the estimated vehicle fuel
economies of vehicles. As detailed in Table 5.5-5, operation of the Project is estimated to result in an annual
VMT of 5,997,818 miles and a fuel consumption of 223,454 gallons per year. This would be a 26,633
gallon per year increase in fuel consumption compared to the existing golf course uses onsite, as shown in
Table 5.5-5.
Table 5.5-5: Change in Traffic Generated Annual Fuel Consumption
Vehicle Type Average Vehicle Fuel
Economy (mpg) Annual VMT Estimated Annual Fuel
Consumption (gallons)
LDA 35.67 2,966,844 83,183
LDT1 26.76 239,837 8,962
LDT2 26.65 1,415,427 53,116
MDV 21.86 871,057 39,850
LHDT1 17.30 166,959 9,649
LHDT2 16.21 43,783 2,701
MHDT 7.91 93,154 11,782
HHDT 6.32 34,590 5,473
OBUS 6.48 3,597 555
UBUS 3.79 2,133 563
MCY 42.49 133,077 3,132
SBUS 6.65 5,795 872
MH 5.96 21,568 3,616
Total (All Vehicles) 5,997,818 223,454
Existing 5,282,945 196,821
Net Total (All Vehicles) 714,837 26,633
Notes: LDA = light-duty auto vehicles. LDT1 = light-duty trucks with equivalent test weight less than or equal to 3,750 lbs. LDT2 =
light-duty trucks with equivalent test weight between 3,751 and 5,750 lbs. MHDT = medium-heavy-duty trucks. HHDT = heavy-
heavy-duty trucks. OBUS = Other Bus. UBUS = Urban Bus. MCY =Motorcycle. SBUS = School Bus. MH = Motorhome.
Source: Appendix F
Project buildings operations, lagoon and pools operations, and site maintenance activities would result in the
consumption of electricity and natural gas. As shown on Table 5.5-6, the Project would result in a net increase
of 9,559,556 kWh per year of electricity and 11,258,880 kBTU per year of natural gas.
The Project buildings and parking lot canopies would be covered in solar PV panels (included as PDF-1) that
would generate renewable energy that would be used for operation of the Project. As shown below in Table
5.5-5, the proposed solar PV panels would provide approximately 2,375,568 kWh per year of energy,
which equates to 20 percent of the Project’s annual energy demand.
Snug Harbor Surf Park Project 5.5 Energy
City of Newport Beach 5.5-11
Draft EIR
May 2025
Table 5.5-6: Project Annual Operational Natural Gas and Electricity Summary
Land Use Natural Gas Demand
(kBTU/year)
Electricity
(kWh/year)
Project 12,158,880 12,031,284
Proposed Onsite Solar Generation - 2,375,568
Total Project Energy Demand 12,158,880 9,655,716
Existing 900,000 96,160
Total Net Project Energy Demand 11,258,880 9,559,556
Source: Appendix F
Because this use of energy is typical for urban development and onsite renewable energy would be utilized,
no operational activities or land uses would occur that would result in wasteful, inefficient, or unnecessary
consumption of energy resources. In addition, adherence to current California Building Code and Energy
Code standards and maximizing the use of renewable energy sources (see PDF-1) will ensure the most
energy efficient technologies and practices are used for the development and operation of the Project.
Therefore, impacts related to operational energy consumption would be less than significant.
IMPACT ENE-2: THE PROJECT WOULD NOT CONFLICT WITH OR OBSTRUCT A STATE OR LOCAL PLAN
FOR RENEWABLE ENERGY OR ENERGY EFFICIENCY.
No Impact. As described previously, the proposed Project would be required to meet the CCR Title 24
energy efficiency standards in effect during permitting of the proposed Project. The City’s administration of
the CCR Title 24 requirements includes review of design components and energy conservation measures that
occur during the permitting process, which ensures that all requirements are met. In addition, the proposed
Project would not conflict with or obstruct opportunities to use renewable energy, such as solar energy. The
proposed Project incorporates the use of solar energy (included as PDF-1) and EV charging stations and EV
parking. Through the City’s development permitting process, the proposed Project would be required to
comply with most current Title 24 Building Energy Efficiency Standards, which provide minimum efficiency
standards related to various building features, including water and space heating and cooling equipment,
building insulation and roofing, and lighting. As shown in Table 5.10-4, General Plan Policy Consistency
Analysis, in Section 5.10, Land Use and Planning, the proposed Project would be consistent with the General
Plan policies related to energy conservation such as policies NR 24.2 and NR 24.3. Thus, the proposed
Project would not conflict with or obstruct a State or local plan for renewable energy or energy efficiency,
and impacts would not occur.
5.5.7 CUMULATIVE IMPACTS
The geographic context for analysis of cumulative impacts regarding energy includes past, present, and
future development within Southern California because energy supplies (including electricity, natural gas,
and petroleum) are generated and distributed throughout the southern California region.
As discussed under Impact ENE-1, construction- and operation-related energy impacts resulting from
implementation of the proposed Project would not be considered inefficient, wasteful, or unnecessary. All
development projects throughout the region would be required to comply with the energy efficiency
standards in the Title 24 requirements. Additionally, like the proposed Project, some of the developments
could provide for additional reductions in energy consumption by use of solar panels, sky lights, or other
LEED type energy efficiency infrastructure. As of 2023 approximately 49 percent of power that SCE
delivered to customers came from carbon-free resources (SCE 2024), and as detailed previously, the State
Renewables Portfolio Standards requires that to increase through 2045. With implementation of the
Snug Harbor Surf Park Project 5.5 Energy
City of Newport Beach 5.5-12
Draft EIR
May 2025
proposed solar PV panels (included as PDF-1) and other required features, such as EV charging, and existing
Title 24 and CALGreen energy conservation regulations, cumulative electricity and natural gas consumption
would not be cumulatively wasteful, inefficient, or unnecessary. As discussed under Impact E-2, the Project
would not conflict with or obstruct a State or local plan for renewable energy or energy efficiency. Other
cumulative development projects would also be required to demonstrate compliance with CCR Title 24
energy efficiency standards.
Petroleum consumption associated with the proposed Project would be primarily attributable to vehicle trips
from employees, vendors, and patrons. However, State fuel efficiency standards and alternative fuels
policies (per AB 1007 Pavely) would contribute to a reduction in fuel use, and the Federal Energy
Independence and Security Act and the State Long Term Energy Efficiency Strategic Plan would reduce
reliance on non-renewable energy resources cumulatively for all projects. Further, the Project includes EV
charging and EV parking that would promote electric vehicle use and reduce the use of petroleum. Thus,
cumulative impacts related to petroleum would be less than significant. For these reasons, the consumption of
energy resources by the Project would not occur in a wasteful, inefficient, or unnecessary manner and would
be less than cumulatively considerable. Thus, cumulative impacts would be less than significant.
5.5.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES
The following would reduce potential impacts related to energy.
Existing Regulations
• California Energy Code (Code of Regulations, Title 24 Part 6)
• California Green Building Standards Code (CALGreen; Code of Regulations, Title 24 Part 11)
• Municipal Code Section 15.11.010, Adoption of the California Green Building Standards Code
• Municipal Code Section 15.17.010, Adoption of the California Energy Code
• Municipal Code Section 15.18.040, Solar Energy Requirements
• Municipal Code Section Chapter 15.19, Electric Vehicle Charging Stations
Plans, Programs, or Policies
None.
5.5.9 PROJECT DESIGN FEATURES
The proposed Project includes the following PDF that reduces potential impacts related to energy:
PDF-1 Solar: The proposed Project includes installation of solar panels on the roofs of the buildings and on
14 to 18-foot-high solar canopies in portions of the parking areas to provide onsite renewable energy to
provide power to the proposed Project.
5.5.10 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
The Project would result in less-than-significant impacts for both Impacts ENE-1and ENE-2.
5.5.11 MITIGATION MEASURES
No mitigation measures are required.
Snug Harbor Surf Park Project 5.5 Energy
City of Newport Beach 5.5-13
Draft EIR
May 2025
5.5.12 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts would be less than significant.
5.5.13 REFERENCES
California Gas and Electric Utilities (CGEU). (2024). 2024 California Gas Report.
https://www.socalgas.com/sites/default/files/2024-08/2024-California-Gas-Report-Final.pdf
California Energy Commission (CEC). (2023). 2022 Building Energy Efficiency Standards.
https://www.energy.ca.gov/programs-and-topics/programs/building-energy-efficiency-
standards/2022-building-energy-efficiency
City of Newport Beach. (2001, January). Santa Ana Heights Specific Plan. Retrieved September 23, 2024,
from ocpublicworks.com.
City of Newport Beach. (2006a, July). General Plan. Retrieved September 23, 2024, from
newportbeachca.gov: https://www.newportbeachca.gov/government/departments/community-
development/planning-division/general-plan-codes-and-regulations/general-plan
City of Newport Beach. (2006b, July). General Plan Environmental Impact Report. Retrieved September 23,
2024, from https://www.newportbeachca.gov/government/departments/community-
development/planning-division/general-plan-codes-and-regulations/general-plan/general-plan-
environmental-impact-repor
City of Newport Beach. (2024, May). Newport Beach Municipal Code. Retrieved September 23, 2024,
from codepublishing.com: https://www.codepublishing.com/CA/NewportBeach/
Southern California Edison (SCE). (2024). 2023 Annual Report. Retrieved March 10, 2025, from:
https://download.edison.com/406/files/202403/2023-eix-sce-annual-
report.pdf?Signature=O1PyPfS603JRP3%2FJlancxIco7Mk%3D&Expires=1741986577&AWSAcc
essKeyId=AKIATACLJRQCT2IBV7MN&versionId=gKDVybNV5xy6ZD4A6Mk_7QipIn4o0KPs&resp
onse-content-disposition=attachment
Urban Crossroads. (2025). Surf Farm Energy Tables. (Appendix F)
Snug Harbor Surf Park Project 5.5 Energy
City of Newport Beach 5.5-14
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 5.6 Geology and Soils
City of Newport Beach 5.6-1
Draft EIR
May 2025
5.6 Geology and Soils
5.6.1 INTRODUCTION
This section describes the geology and soil conditions in the Project region and potential impacts from Project
implementation. The analysis in this section is based, in part, on the following documents and resources.
• City of Newport Beach General Plan, 2006
• City of Newport Beach General Plan Environmental Impact Report (General Plan EIR), 2006
• City of Newport Beach Municipal Code
• Geotechnical Exploration, prepared by Carl Kim Geotechnical, Inc., 2024, included as Appendix H
• Paleontological Resources Assessment for the Snug Harbor Project in Newport Beach, Orange County,
California, prepared by LSA Associates, 2024, included as Appendix I
5.6.2 REGULATORY SETTING
5.6.2.1 Federal Regulations
Earthquake Hazards Reduction Act
The Earthquake Hazards Reduction Act (Act) was enacted in 1997 to “reduce the risks to life and property
from future earthquakes in the United States through the establishment and maintenance of an effective
earthquake hazards and reduction program.” To accomplish this, the Act established the National Earthquake
Hazards Reduction Program that provides characterization, and prediction of hazards and vulnerabilities;
improvement of building codes and land use practices; risk reduction through post-earthquake investigations
and education; development and improvement of design and construction techniques; improvement of
mitigation capacity; and accelerated application of research results. Programs under this Act provide
building code requirements such as emergency evacuation responsibilities and seismic code standards such
as those to which development under the proposed Project would be required to adhere.
5.6.2.2 State Regulations
Alquist-Priolo Earthquake Fault Zoning Act
The Alquist-Priolo Earthquake Fault Zoning Act (Act) requires the State Geologist to establish “Earthquake
Fault Zones” and publish appropriate maps that depict these zones. The boundary of an Earthquake Fault
Zone is generally about 500 feet from major active faults and 200 to 300 feet from well-defined minor
faults. The Act also requires local agencies to regulate development within Earthquake Fault Zones. Before
a development project can be permitted within an Earthquake Fault Zone, a geologic investigation is
required to demonstrate that proposed buildings would not be constructed across active faults. A site-specific
evaluation and written report must be prepared by a licensed geologist. If an active fault is found, a structure
for human occupancy cannot be placed over the trace of the fault and must be set back a minimum of 50
feet from the fault.
Seismic Hazards Mapping Act
The Seismic Hazards Mapping Act (Act) addresses earthquake hazards related to liquefaction and
seismically induced landslides. Under the Act, seismic hazard zones are mapped by the State Geologist to
Snug Harbor Surf Park Project 5.6 Geology and Soils
City of Newport Beach 5.6-2
Draft EIR
May 2025
assist local governments in land use planning. The Act states “it is necessary to identify and map seismic
hazard zones in order for cities and counties to adequately prepare the safety element of their general
plans and to encourage land use management policies and regulations to reduce and mitigate those hazards
to protect public health and safety.” Section 2697(a) of the Act states that “cities and counties shall require,
prior to the approval of a project located in a seismic hazard zone, a geotechnical report defining and
delineating any seismic hazard.”
California Building Code
The California Building Code (CBC) is included in Title 24 of the California Code of Regulations. The current
CBC was adopted by the City of Newport Beach and is included in Chapter 15.04 of the Municipal Code.
The code provides standards to protect property and public safety. The CBC regulates the design and
construction of excavations, foundations, building frames, retaining walls, and other building elements, and
thereby mitigate the effects of seismic shaking and adverse soil conditions. The code also regulates grading
activities, including drainage and erosion control.
California Construction General Permit
The State of California adopted a Statewide National Pollutant Discharge Elimination System (NPDES) Permit
for General Construction Activity (Construction General Permit) that regulates construction site storm water
management. Dischargers whose projects disturb one or more acres of soil, or whose projects disturb less
than one acre but are part of a larger common plan of development that in total disturbs one or more acres,
are required to obtain coverage under the general permit for discharges of storm water associated with
construction activity.
To obtain coverage under this permit, project operators must electronically file Permit Registration
Documents, which include a Notice of Intent (NOI), a Storm Water Pollution Prevention Plan (SWPPP), and
other compliance-related documents, including a risk-level assessment for construction sites, an active storm
water effluent monitoring and reporting program during construction, rain event action plans, and numeric
action levels (NALs) for pH (potential of hydrogen) and turbidity, as well as requirements for qualified
professionals to prepare and implement the plan. The Construction General Permit requires the SWPPP to
identify best management practices (BMPs) that will be implemented to reduce soil erosion. Types of BMPs
include preservation of vegetation and sediment control (e.g., fiber rolls). The SWPPP must contain a visual
monitoring program; a chemical monitoring program for “non-visible” pollutants to be implemented if there
is a failure of BMPs; and a monitoring plan if the site discharges directly to a water body listed on the
State’s 303(d) list of impaired waters.
Requirements for Geotechnical Investigations
Requirements for geotechnical investigations are included in CBC Appendix J, Grading, Section J104;
additional requirements for subdivisions requiring tentative and final maps and for other specified types of
structures are in the California Health and Safety Code Sections 17953 to 17955 and in CBC Section 1803.
Testing of samples from subsurface investigations is required, such as from borings or test pits. Studies must
be done as needed to evaluate site geology, slope stability, soil strength, position and adequacy of load-
bearing soils, the effect of moisture variation on load-bearing capacity, compressibility, liquefaction,
differential settlement, and expansiveness. CBC Section J105 sets forth requirements for inspection and
observation during and after grading.
Snug Harbor Surf Park Project 5.6 Geology and Soils
City of Newport Beach 5.6-3
Draft EIR
May 2025
Public Resources Code (PRC) Section 5097.5
Requirements for paleontological resource management are included in the PRC Division 5, Chapter 1.7,
Section 5097.5, and Division 20, Chapter 3, Section 30244, which states that no person shall knowingly and
willfully excavate upon, or remove, destroy, injure or deface any historic or prehistoric ruins, burial grounds,
archaeological or vertebrate paleontological site, including fossilized footprints, inscriptions made by human
agency, or any other archaeological, paleontological or historical feature, situated on public lands, except
with the express permission of the public agency having jurisdiction over such lands. Violation of this section
is a misdemeanor. These statutes prohibit the removal, without permission, of any paleontological site or
feature from lands under the jurisdiction of the State or any city, county, district, authority, or public
corporation, or any agency thereof. As a result, local agencies are required to comply with PRC Section
5097.5 for their own activities, including construction and maintenance, as well as for permit actions (e.g.,
encroachment permits) undertaken by others. PRC Section 5097.5 also establishes the removal of
paleontological resources as a misdemeanor and requires reasonable mitigation of adverse impacts to
paleontological resources from developments on public (state, county, city, and district) lands.
5.6.2.3 Local and Regional Regulations
City of Newport Beach General Plan 2006
The City of Newport Beach General Plan 2006 contains the following goals and policies related to geology
and soils that are applicable to the Project:
Safety Element
Goal S 4 Adverse effects caused by seismic and geologic hazards are minimized by reducing
the known level of risk to loss of life, personal injury, public and private property
damage, economic and social dislocation, and disruption of essential services.
Policy S 4.7 New Development. Conduct further seismic studies for new development in areas where
potentially active faults may occur.
Natural Resources Element
Goal NR 3 Enhancement and protection of water quality of all natural water bodies, including
coastal waters, creeks, bays, harbors, and wetlands.
Policy NR 3.4 Storm Drain Sewer System Permit. Require all development to comply with the
regulations under the City’s municipal separate storm drain system permit under the
National Pollutant Discharge Elimination System.
Policy NR 3.9 Water Quality Management Plan. Require new development applications to include a
Water Quality Management Plan (WQMP) to minimize runoff from rainfall events during
construction and post-construction.
Policy NR 3.10 Best Management Practices. Implement and improve upon Best Management Practices
(BMPs) for residences, businesses, development projects, and City operations.
Policy NR 3.11 Site Design and Source Control. Include site design and source control BMPs in all
developments. When the combination of site design and source control BMPs are not
sufficient to protect water quality as required by the National Pollutant Discharge
Elimination System (NPDES), structural treatment BMPs will be implemented along with site
design and source control measures.
Snug Harbor Surf Park Project 5.6 Geology and Soils
City of Newport Beach 5.6-4
Draft EIR
May 2025
Policy NR 3.12 Reduction of Infiltration. Include equivalent BMPs that do not require infiltration, where
infiltration of runoff would exacerbate geologic hazards.
Policy NR 3.14 Runoff Reduction on Private Property. Retain runoff on private property to prevent the
transport of pollutants into natural water bodies, to the maximum extent practicable.
Policy NR 3.19 Natural Drainage Systems. Require incorporation of natural drainage systems and
stormwater detention facilities into new developments, where appropriate and feasible,
to retain stormwater in order to increase groundwater recharge.
Policy NR 3.20 Impervious Surfaces. Require new development and public improvements to minimize the
creation of and increases in impervious surfaces, especially directly connected impervious
areas, to the maximum extent practicable. Require redevelopment to increase area of
pervious surfaces, where feasible.
Policy NR 4.4 Erosion Minimization. Require grading/erosion control plans with structural BMPs that
prevent or minimize erosion during and after construction for development on steep slopes,
graded, or disturbed areas.
Goal NR 18 Protection and preservation of important paleontological and archaeological
resources.
Policy NR 18.1 New Development. Require new development to protect and preserve paleontological
and archaeological resources from destruction and avoid and minimize impacts to such
resources in accordance with the requirements of CEQA. Through planning policies and
permit conditions, ensure the preservation of significant archeological and paleontological
resources and require that the impact caused by any development be mitigated in
accordance with CEQA.
Policy NR 18.4 Donation of Materials. Require new development, where on-site preservation and
avoidance are not feasible, to donate scientifically valuable paleontological or
archaeological materials to a responsible public or private institution with a suitable
repository, located within Newport Beach or Orange County, whenever possible.
Historical Resources Element
Goal HR 2 Identification and protection of important archaeological and paleontological
resources within the City.
Policy HR 2.1 New Development Activities. Require that, in accordance with CEQA, new development
protect and preserve paleontological and archaeological resources from destruction and
avoid and mitigate impacts to such resources. Through planning policies and permit
conditions, ensure the preservation of significant archeological and paleontological
resources and require that the impact caused by any development be mitigated in
accordance with CEQA.
Policy HR 2.2 Grading and Excavation Activities. Maintain sources of information regarding
paleontological and archeological sites and the names and addresses of responsible
organizations and qualified individuals, who can analyze, classify, record, and preserve
paleontological or archeological findings. Require a qualified paleontologist/
archeologist to monitor all grading and/or excavation where there is a potential to affect
cultural, archeological or paleontological resources. If these resources are found, the
Applicant shall implement the recommendations of the paleontologist/ archaeologist,
subject to the approval of the City Planning Department.
Snug Harbor Surf Park Project 5.6 Geology and Soils
City of Newport Beach 5.6-5
Draft EIR
May 2025
Policy HR 2.4 Paleontological and Archaeological Materials. Require new development to donate
scientifically valuable paleontological or archaeological materials to a responsible public
or private institution with a suitable repository, located within Newport Beach, or Orange
County, whenever possible.
Newport Beach City Council Policy Manual
Policy K-5: Paleontological and Archaeological Resource Protection Guidelines. The City will ensure that
potential impacts to paleontological and archaeological resources by public or private development are
properly evaluated and mitigated in accordance with the General Plan, Local Coastal Program and CEQA.
Procedures
A. During the preparation of an initial study for a project, staff or a qualified consultant shall determine if
paleontological or archaeological resources exist at or near a project site. If the site is located in the
Coastal Zone, the requirements and procedures provided in Newport Beach Municipal Code Section
21.30.105(A), or any successor statute, shall be implemented.
B. If resources are known to exist at or near a project site or that, the project could otherwise affect known
resources, a preliminary investigation report shall be prepared by a qualified professional
archaeologist or paleontologist.
C. If the preliminary investigation report concludes that resources are not likely to be at the present at the
project site or encountered during construction, no further analysis shall be required.
D. If the preliminary report concludes that resources are present at the site or are likely to be present at
the site or may be encountered by project construction, additional investigative work shall be prepared
to identify and disclose the potential impacts of the project. The impact assessment report shall make
every effort to identify the value of the resource and shall identify feasible design modifications or other
methods to avoid and/or minimize project-related impacts. The impact assessment report may include a
suggested excavation plan for assessing or mitigating the effect of the project on the qualities which
make the resource important if avoidance is considered infeasible. The impact assessment report shall
also identify feasible mitigation measures that can be either incorporated within project specifications
or applied as conditions of approval.
E. If paleontological or archaeological resources are discovered during construction, all construction
activities in the general area of the discovery shall be temporarily halted until the resource is examined
by a qualified monitor. The monitor shall assess the significance of the resource and recommend next
steps (i.e. additional excavation, curation, preservation, etc.).
F. If human remains are discovered during construction, there shall be no further excavation or disturbance
of the site or any nearby area reasonably suspected to overlie adjacent remains until the coroner
determines that the remains are not subject to the provisions of Section 27491 of the Government Code,
or any successor statute, or any other related provisions of law concerning investigation of the
circumstances, manner and cause of any death, and the recommendations concerning the treatment and
disposition of the human remains have been made to the person responsible for the excavation, or their
authorized representative, in the manner provided in Section 5097.98 of the Public Resources Code, or
any successor statute. The coroner shall make his or her determination within two working days from the
time the person responsible for the excavation, or his or her authorized representative, notifies the
coroner of the discovery or recognition of the human remains. If the coroner determines that the remains
are not subject to his or her authority and if the coroner recognizes the human remains to be those of a
Native American, or has reason to believe that they are those of a Native American, he or she shall
contact, by telephone within 24 hours, the Native American Heritage Commission and the Newport Beach
Building Official.
Snug Harbor Surf Park Project 5.6 Geology and Soils
City of Newport Beach 5.6-6
Draft EIR
May 2025
City of Newport Beach Municipal Code
Chapter 15.04, Building Code. This municipal code section adopts the California Building Code, as amended
by the City, which provides seismic safety regulations that are required for all development.
Chapter 15.10, Excavation and Grading Code. This municipal code section sets forth regulations to control
grading, excavation, and draining conditions, hazardous conditions, and related construction components.
5.6.3 ENVIRONMENTAL SETTING
5.6.3.1 Regional Setting
The Project region is located within the Los Angeles Basin which is part of the Peninsular Range physiographic
Province of California. The Peninsular Ranges are characterized by a series of northwest trending mountain
ranges separated by valleys. Range geology consists of granitic rock intruding the older metamorphic rocks.
Valley geology is characterized by shallow to deep alluvial basins consisting of gravel, sand, silt, and clay
(Appendix H).
The site is located northwest of the pediment of the San Joaquin Hills in the Santa Ana Heights area,
approximately 0.75-mile north of Upper Newport Bay. The Santa Ana Heights area consists of “old paralic
deposits overlain by alluvial-fan deposits” (Appendix H).
5.6.3.2 Fault Rupture
In 1972, the Alquist-Priolo Special Studies Zones Act was signed into law. In 1994, it was renamed the
Alquist-Priolo Earthquake Fault Zoning Act (A-P Act). The primary purpose of the A-P Act is to mitigate the
hazard of fault rupture by prohibiting the location of structures for human occupancy across the trace of an
active fault. The A-P Act requires the State Geologist (Chief of the California Geology Survey) to delineate
“Earthquake Fault Zones” along with faults that are “sufficiently active” and “well-defined.” The boundary
of an “Earthquake Fault Zone” is generally about 500 feet from major active faults and 200 to 300 feet
from well-defined minor faults. The A-P Act dictates that cities and counties withhold development permits
for sites within an Alquist-Priolo Earthquake Fault Zone until geologic investigations demonstrate that the site
zones are not threatened by surface displacements from future faulting. Seismic activity has been known to
cause surface rupture, or ground displacement, along a fault or within the general vicinity of a fault zone.
The City is located within the Peninsular Ranges Province that is exposed to risk from multiple earthquake
fault zones. The highest risks originate from the Newport-Inglewood fault zone, the Whittier fault zone, the
San Joaquin Hills fault zone, and the Elysian Park fault zone, each with the potential to cause moderate to
large earthquakes that would cause ground shaking in Newport Beach and nearby communities (City of
Newport Beach, 2006b).
The Project site is not located within an Alquist-Priolo Fault Zone and no active faults are known to cross the
site. The closest known active fault is a segment of the Newport-Inglewood-Rose Canyon Fault Zone
approximately 5.6 miles to the west (Appendix H). Inferred/buried strands of the Newport-Inglewood-Rose
Canyon Fault Zone are mapped trending south of the site but are not currently zoned as active. The closest
mapped trace is approximately 0.9-mile south of the site. No photo lineaments or other geomorphic evidence
of active or potentially active faults intersecting the site were observed or recognized as part of our review
of aerial photos and historic topographic maps; therefore, the Geotechnical Exploration (Appendix H)
determined that the potential for surface fault rupture at the site is expected to be low.
Snug Harbor Surf Park Project 5.6 Geology and Soils
City of Newport Beach 5.6-7
Draft EIR
May 2025
5.6.3.3 Ground Shaking
All of Southern California is seismically active. The amount of motion expected at a building site can vary
from none to forceful depending upon the distance to the fault, the magnitude of the earthquake, and the
local geology. Greater movement can be expected at sites located on poorly consolidated material such as
alluvium located near the source of the earthquake epicenter or in response to an earthquake of great
magnitude.
5.6.3.4 Onsite Soils
Based on geologic maps, the Project site is situated on undocumented fill, alluvium, and older terrace
deposits. The site contains variable thicknesses of man-made fill that vary from soft to stiff sandy lean clay,
and loose to dense silty sand and clayey sand that is generally moist. Quaternary alluvium (Qal) encountered
in site explorations consisted of layers of lean clay, sandy lean clay, clayey sand, silty sand, and poorly
graded sands. Also, Quaternary terrace deposits (Qt) encountered in site explorations consisted of layers
of lean clay, sandy lean clay, and fat clay with interlayers or intermixed zones of silty sand, poorly graded
sand, and silt. The materials were generally moist. Fine-grained soils varied from soft to hard while granular
soils encountered were logged as medium dense to very dense (Appendix H).
5.6.3.5 Groundwater
The Geotechnical Exploration (Appendix H) describes that based on a regional scale study the historic highest
groundwater in the site vicinity is at a depth of about 10 feet below ground surface (bgs). Information from
the geotechnical site investigation documents the presence of water-bearing zones and non-water bearing
zones in the subsurface. Measured groundwater depths bgs and elevations were variable, with data
indicating perched water and confined pressurized water-bearing zones present. Most recent measurements
encountered groundwater in a monitoring well as shallow as a depth of approximately 18.52 feet below
top of casing. The groundwater levels measured during the geotechnical investigation are a “snapshot” of
the groundwater levels and do not account for potential fluctuations levels due to seasonal and tidal
variations (Appendix H).
5.6.3.6 Liquefaction
Liquefaction occurs when vibrations or water pressure within a mass of soil cause the soil particles to lose
contact with one another. As a result, the soil behaves like a liquid, has an inability to support weight, and
can flow down very gentle slopes. This condition is usually temporary and is most often caused by an
earthquake vibrating water-saturated fill or unconsolidated soil. Soils that are most susceptible to
liquefaction are clean, loose, saturated, and uniformly graded fine-grained sands that lie below the
groundwater table within approximately 50 feet below ground surface. Clayey (cohesive) soils, or soils
which possess clay particles in excess of 20 percent, are generally not considered to be susceptible to
liquefaction, nor are those soils which are above the historic static groundwater table. Lateral spreading
refers to spreading of soils in a rapid fluid-like flow movement similar to water.
As shown in Figure 5.6-1, Liquefaction Zone, the northwest portion of the site is mapped by the California
Geological Survey as being potentially susceptible to liquefaction. However, the Geotechnical Exploration
testing identified that the Project site has a low liquefaction potential due to the underlying soil composition
and properties. The Geotechnical Exploration found that based on the soil conditions onsite, and a design
groundwater level of 15 feet bgs, liquefaction hazards were deemed low (Appendix H).
Snug Harbor Surf Park Project 5.6 Geology and Soils
City of Newport Beach 5.6-8
Draft EIR
May 2025
This page intentionally left blank.
Liquefaction Zone
Figure 5.6-1Snug Harbor Surf Park Project
City of Newport Beach
City of Costa Mesa, City of Newport Beach, County of Los Angeles,
Bureau of Land Management, Esri, HERE, Garmin, INCREMENT P,
USGS, EPA, USDA
0 250 500
Feet ±Legend
Project Boundary
Liquefaction Zones
Snug Harbor Surf Park Project 5.6 Geology and Soils
City of Newport Beach 5.6-10
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 5.6 Geology and Soils
City of Newport Beach 5.6-11
Draft EIR
May 2025
5.6.3.7 Settlement
Settlement is the vertical compression of soil due to load-bearing stress. The General Plan Final EIR describes
that potential hazards posed by seismic settlement and/or collapse in the City is greater in areas underlain
by late Quaternary unconsolidated sediments (City of Newport Beach, 2006b). Strong ground shaking can
cause settlement of alluvial soils and artificial fills if they are not adequately compacted.
Based on the onsite soils and groundwater conditions, the Geotechnical Exploration determined that static
and seismic settlement is not a potential concern of the Project site. The seismic settlement potential is
estimated to be less than 0.5 inch (Appendix H).
5.6.3.8 Lateral Spreading
Lateral spreading is a type of liquefaction induced ground failure associated with the lateral displacement
of surficial blocks of sediment resulting from liquefaction in a subsurface layer. Once liquefaction transforms
the subsurface layer into a fluid mass, gravity plus the earthquake inertial forces may cause the mass to
move downslope towards a free face (such as a river channel or an embankment). Lateral spreading may
cause large, horizontal displacements, and such movement typically damages pipelines, utilities, bridges,
and structures. As described previously, the Project site is not susceptible to liquefaction. Therefore, the site
is not at risk for lateral spreading (Appendix H).
5.6.3.9 Subsidence
Ground subsidence is the gradual settling or sinking of the ground surface with little or no horizontal
movement. Subsidence typically occurs in areas with subterranean oil, gas, or groundwater, and is most
commonly associated with overdraft of groundwater. Effects of subsidence include fissures, sinkholes,
depressions, and disruption of surface drainage. The Geotechnical Exploration describes that the Project site
is not within an area with known significant subsidence associated with groundwater or petroleum
withdrawal, peat oxidation, or hydrocompaction.
5.6.3.10 Landslides
Landslides and other slope failures are secondary seismic effects that are common during or soon after
earthquakes. Areas that are most susceptible to earthquake induced landslides are steep slopes underlain
by loose, weak soils, and areas on or adjacent to existing landslide deposits.
The Geotechnical Exploration describes that the existing elevation of the Project site is approximately 58
feet above mean sea level (msl), and slopes to the northwest. An existing 15-20-foot-high slope descends
from the southeast edge of the site. The remainder of the site generally slopes from approximately 50 feet
msl to approximately 15 feet msl at the northwest corner of the site.
The site is not located within a mapped area considered potentially susceptible to seismically induced slope
instability (Appendix H). In addition, the Project site is not adjacent to any substantial hills or slopes that
could be subject to a landslide.
5.6.3.11 Expansive Soils
Expansive soils are soils containing water-absorbing minerals that expand as they take in water. These soils
can damage buildings due to the force they exert as they expand. Expansive soils contain certain types of
clay minerals that shrink or swell as the moisture content changes; the shrinking or swelling can shift, crack,
Snug Harbor Surf Park Project 5.6 Geology and Soils
City of Newport Beach 5.6-12
Draft EIR
May 2025
or break structures built on such soils. Arid or semiarid areas with seasonal changes of soil moisture
experience a much higher frequency of problems from expansive soils than areas with higher rainfall and
more constant soil moisture. The proposed Project is in a semiarid region with marked seasonal changes in
precipitation; most rain falls in winter, and there is a long dry season in summer and autumn. Therefore, the
City’s climate is such that a relatively high incidence of soil expansion is expected where soils contain the
requisite clay minerals.
The General Plan Environmental Impact Report describes that due to the presence of fine-grained
components in the City with some potential for expansive soils throughout Newport Beach, expansive soils
testing prior to grading is required as part of a soil engineering report, per the CBC and the City of Newport
Beach development and permitting requirements.
The Geotechnical Exploration included expansion index testing on soil samples collected from the Project
site, which determined that very low to medium expansive soils are present onsite (Appendix H).
5.6.3.12 Paleontological Resources
Paleontological resources include any fossilized remains, traces, or imprints of organisms preserved in or on
the earth’s crust that are of paleontological interest and that provide information about the history of life on
earth, except that the term does not include any materials associated with an archaeological resource or
any cultural item defined as Native American human remains. Significant paleontological resources are
defined as fossils or assemblages of fossils that are unique, unusual, rare, uncommon, or important to define
a particular time frame or geologic strata, or that add to an existing body of knowledge in specific areas,
in local formations, or regionally.
The City’s General Plan EIR describes that Newport Beach is underlain by Holocene-age alluvial sediments
and early Pleistocene marine deposits. Below these deposits lie Miocene and late Cretaceous sedimentary
rocks. Pleistocene sediments have a rich fossil history in Southern California. Local paleontological sites have
yielded fossils of horses, elephants, bison, antelopes, and dire wolves. In addition to illuminating the striking
differences between southern California in the Pleistocene and today, this abundant fossil record has been
vital in studies of extinction, ecology, and climate change. Throughout Orange County, extinct Pleistocene
animals are well known from alluvial sediments.
The Natural History Museum of Los Angeles County database search completed for the proposed Project
identified records of five recorded fossil localities in the general Project vicinity. None of these were
documented within the Project site. The localities in the vicinity are associated with units mapped from similar
geologic units as those found on the Project site (Appendix I). The recorded fossil localities include:
• Fossils located in the drainage channel north of Irvine Avenue in Costa Mesa that yielded invertebrate
fossils.
• Fossils in an unspecified location in Newport Beach, yielded Venerid bivalve.
• A locality at the southwest end of the Newport Freeway, between Santa Isabel Avenue and 23rd Street,
produced several fossils, including camel, sea turtle, uncatalogued fish and birds, and invertebrates.
• A locality near the intersection of Superior Avenue and Pacific Coast Highway, yielded horse, other
unspecified mammals, and invertebrates such as clams, scaphopod, and marine gastropods.
• A locality at the south side of a bluff south of Bayview School and west of the San Joaquin Gun Club,
several invertebrates were recovered.
The Project site contains man-made artificial fill underlain with young axial channel deposits and old paralic
deposits overlain by alluvial fan deposits. These soils are assigned a low paleontological resource sensitivity
to a depth of approximately 10 feet. Soils below 10 feet include older alluvial fan and Pleistocene deposits
Snug Harbor Surf Park Project 5.6 Geology and Soils
City of Newport Beach 5.6-13
Draft EIR
May 2025
that have the potential to preserve both marine and terrestrial animals and are considered to have a high
paleontological sensitivity.
5.6.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of the CEQA Guidelines indicates that a Project could have a significant effect if it were to:
GEO-1 Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury,
or death involving:
i) 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);
ii) Strong seismic ground shaking;
iii) Seismic-related ground failure, including liquefaction; or
iv) Landslides.
GEO-2 Result in substantial soil erosion or the loss of topsoil.
GEO-3 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.
GEO-4 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.
GEO-5 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.
GEO-6 Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.
5.6.5 METHODOLOGY
A Geotechnical Exploration was prepared for the Project site (Appendix H), which included field exploration,
exploratory soil borings, acquisition of representative soil samples, laboratory testing, engineering analysis,
and pertinent geological literature review. The laboratory testing determined the characteristics of the
geology and soils that underlie the site. These subsurface conditions were then analyzed to identify potential
significant impacts resulting from Project construction and operation in relation to geology and soils.
In determining whether a geotechnical-related impact would result from the proposed Project, the analysis
includes consideration of State law, including the California Building Code that is integrated into the City’s
Municipal Code, and implemented/verified during Project permitting approvals. In general, existing State
law, building codes, and municipal codes that are implemented by the approving agency provide for an
adequate level of safety or reduction of potential effects such that projects developed and operated to
code reduce potential of impacts.
In determining whether a paleontological-related impact would result from the proposed Project, the analysis
includes consideration of the types of soils that exist on the Project site, the paleontological sensitivity of
those soils, the past disturbance on the site, and the proposed excavation. Existing conditions and sensitivity
were also determined through a fossil locality search conducted at the Natural History Museum of Los Angeles
County in October 2024. The purpose of the locality search was to identify previously recorded or otherwise
Snug Harbor Surf Park Project 5.6 Geology and Soils
City of Newport Beach 5.6-14
Draft EIR
May 2025
known fossil localities in or adjacent to the Project area. The analysis combines these factors to identify the
potential of Project construction to impact any unknown paleontological resources on the site.
5.6.6 ENVIRONMENTAL IMPACTS
IMPACT GEO-1: THE PROJECT WOULD NOT DIRECTLY OR INDIRECTLY CAUSE POTENTIAL
SUBSTANTIAL ADVERSE EFFECTS, INCLUDING THE RISK OF LOSS, INJURY, OR
DEATH INVOLVING:
(I) 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);
No Impact. As described previously, the Project site is not located within an Alquist-Priolo Earthquake Fault
Zone and no active faults are known/recorded to cross the site. The closest known active faults are associated
with the Newport-Inglewood-Rose Canyon Fault Zone approximately 5.6 miles to the west (Appendix H).
Inferred/buried strands of the Newport-Inglewood-Rose Canyon Fault Zone are mapped trending 0.9-mile
south of the site but are not currently zoned as active (Appendix H). Because no known faults exist on or
adjacent to the site, the proposed Project would not expose people or structures to potential substantial
adverse effects from rupture of a known earthquake fault that is delineated on an Alquist-Priolo Earthquake
Fault Zoning Map or other evidence of a fault, and impacts would not occur.
(II) SEISMIC-RELATED GROUND SHAKING; OR
Less than Significant. The proposed Project site is within a seismically active region, with numerous faults
capable of producing significant ground motions. The closest known active faults are associated with the
Newport-Inglewood-Rose Canyon Fault Zone approximately 5.6 miles to the west (Appendix H). Therefore,
Project implementation could subject people and structures to hazards from ground shaking. However, seismic
shaking is a risk throughout Southern California, and the Project site is not at greater risk of seismic activity
or impacts as compared to other areas within the region.
The CBC includes provisions to reduce impacts caused by major structural failures or loss of life resulting from
earthquakes or other geologic hazards. For example, Chapter 16 of the CBC contains requirements for
design and construction of structures to resist loads, including earthquake loads. The CBC provides procedures
for earthquake-resistant structural design that include considerations for onsite soil conditions, occupancy,
and the configuration of the structure including the structural system and height.
As described previously, the City of Newport Beach has adopted the CBC as part of the Municipal Code
Chapter 15.04, which regulates all building and construction projects within the City and implements a
minimum standard for building design and construction that includes specific requirements for seismic safety,
excavation, foundations, retaining walls and site demolition. Structures built in the City are required to be
built in compliance with the CBC. The proposed Project would be required to adhere to the provisions of the
CBC as part of the building plan check and development review process. Compliance with the requirements
of the CBC for structural safety would reduce hazards from strong seismic ground shaking. Because the
proposed Project would be required to be constructed in compliance with the CBC and the City’s Municipal
Code, which would be verified through the City’s plan check and permitting process and is included as PPP
GEO-1, the proposed Project would result in a less than significant impact related to strong seismic ground
shaking.
Snug Harbor Surf Park Project 5.6 Geology and Soils
City of Newport Beach 5.6-15
Draft EIR
May 2025
(III) SEISMIC-RELATED GROUND FAILURE, INCLUDING LIQUEFACTION; OR
Less than Significant. As described by the Geotechnical Exploration (Appendix H), a portion of the site is
identified by mapping as being potentially liquifiable, and the Project site consists of subsurface soils that
consist of man-made fill, alluvium, and older terrace deposits. Underlying soils include layers of lean clay,
sandy lean clay, clayey sand, silty sand, and poorly graded sands. The highest historic groundwater on the
Project site was encountered at approximately 10 feet bgs. The highest groundwater encountered within
recent onsite borings was at a depth of 18.52 feet bgs. However, using a design high groundwater level of
15 feet bgs, the Geotechnical Exploration determined that the liquefaction potential is considered low
(Appendix H).
As described previously, structures built in the City are required to be built in compliance with the CBC, as
included in the City’s Municipal Code as Chapter 15.04 (and herein as PPP GEO-1), which regulates all
building and construction projects within the City and implements a minimum standard for building design
and construction that includes specific requirements for seismic safety, excavation, foundations, retaining
walls, and site demolition. Compliance with the CBC (included as PPP GEO-1) would require proper
construction of building footings and foundations so that it would withstand the effects of potential ground
movement, including liquefaction and settlement. The CBC also includes provisions to reduce impacts caused
by potential major structural failures or loss of life resulting from geologic hazards. For example, the CBC
requires that a California Certified Engineering Geologist or California-licensed civil engineer provide site-
specific engineering data to demonstrate the satisfactory performance of proposed structures. The City
requires the Project-specific engineering design recommendations be incorporated into grading plans and
building specifications as a condition of construction permit approval. Therefore, the development of the
proposed Project would be required to conform to the seismic design parameters of the CBC, as included as
PPP GEO-1, which are reviewed by the City for appropriate inclusion as part of the building plan check
and development review process. Compliance with the requirements of the CBC and City’s Municipal Code
for structural safety (included as PPP GEO-1) would reduce hazards from seismic-related ground failure,
including liquefaction and settlement to a less than significant level.
(IV) LANDSLIDES.
No Impact. The proposed Project site is located in a seismically active region subject to strong ground
shaking. As described previously, the Geotechnical Exploration describes that the Project site has an existing
15-20-foot-high slope that descends from the southeast edge of the site; and the remainder of the site
generally slopes from approximately 50 feet msl to approximately 15 feet msl to the northwest corner of
the site. However, there are no substantial hills or slopes and the site is not within a seismically induced
landslide hazard zone area and is not considered potentially susceptible to seismically-induced slope
instability as shown on Figure 4.5-2 of the General Plan Environmental Impact Report (City of Newport
Beach, 2006b) and as determined by the Geotechnical Exploration (Appendix H). Thus, the Project site is
not located within or adjacent to an earthquake-induced landslide area. In addition, the Project would grade
the site pursuant to the CBC requirements, which are included in the City’s Municipal Code as Chapter 15.04.
Compliance would be verified during the City’s construction review and permitting process, and has been
included as PPP GEO-1. Therefore, the proposed Project would not expose people or structures to substantial
adverse effects involving landslides, and impacts related to landslides would not occur.
Snug Harbor Surf Park Project 5.6 Geology and Soils
City of Newport Beach 5.6-16
Draft EIR
May 2025
IMPACT GEO-2: THE PROJECT WOULD NOT RESULT IN SUBSTANTIAL SOIL EROSION OR THE LOSS
OF TOPSOIL.
Less than Significant.
Construction
Construction of the proposed Project has the potential to contribute to soil erosion and the loss of topsoil.
Grading and excavation activities that would be required for the proposed Project would expose and loosen
topsoil, which could be eroded by wind or water.
All projects in the City are required to conform to the permit requirements, which include installation of BMPs
in compliance with the NPDES permit, which establishes minimum stormwater management requirements and
controls that are required to be implemented for the proposed Project in compliance with General Plan
Policies NR 3.10, NR 3.11, and NR 3.12. To reduce the potential for soil erosion and the loss of topsoil, a
SWPPP is required by the Regional Water Quality Control Board (RWQCB) regulations to be developed
by a QSD (Qualified SWPPP Developer) included as PPP WQ-1. The SWPPP is required to address site-
specific conditions related to specific grading and construction activities. The SWPPP is required to identify
potential sources of erosion and sedimentation loss of topsoil during construction, identify erosion control
BMPs to reduce or eliminate the erosion and loss of topsoil, such as use of silt fencing, fiber rolls, or gravel
bags, stabilized construction entrance/exit, hydroseeding. With compliance with RWQCB requirements, and
the BMPs in the SWPPP that are required to be prepared to implement the proposed Project, construction
impacts related to erosion and loss of topsoil would be less than significant.
Operation
The proposed Project includes installation of landscaping, such that during operation of the proposed Project
substantial areas of loose topsoil that could erode would not exist. In addition, as described in Section 5.7,
Hydrology and Water Quality, the onsite drainage features that would be installed by the proposed Project
have been designed to slow, filter, and slowly discharge stormwater into the offsite drainage system, which
would also reduce the potential for stormwater to erode topsoil during Project operations. Furthermore,
implementation of the proposed Project requires City approval of a site-specific Water Quality
Management Plan (WQMP) (included as PPP WQ-3), which would ensure that the City’s General Plan,
RWQCB requirements, and appropriate operational BMPs would be implemented to minimize or eliminate
the potential for soil erosion or loss of topsoil to occur. As a result, potential impacts related to substantial
soil erosion or loss of topsoil would be less than significant.
IMPACT GEO-3: THE PROJECT WOULD NOT 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. As described previously, the site contains a 15-20-foot-high slope that descends from
the southeast edge of the site, and the remainder of the site generally slopes to the northwest from
approximately 50 feet msl to approximately 15 feet msl at the northwest corner of the site. However, there
are no substantial hills or slopes and the site is not within a seismically induced landslide hazard zone area
and is not considered potentially susceptible to seismically-induced slope instability, and potential impacts
related to landslides would not be significant. In addition, the Project would grade the site pursuant to the
CBC requirements, which are included in the City’s Municipal Code as Chapter 15.04. Compliance would be
verified during the City’s construction review and permitting process and has been included as PPP GEO-1.
As described previously, although a portion of the site is identified as within a potentially liquifiable area,
the Geotechnical Exploration determined that the liquefaction potential is considered low. As a result, the
Snug Harbor Surf Park Project 5.6 Geology and Soils
City of Newport Beach 5.6-17
Draft EIR
May 2025
potential for lateral spreading on the site is low (Appendix H). Thus, impacts related to lateral spreading
would be less than significant. In addition, the Geotechnical Exploration describes that the Project site is not
within an area with known significant subsidence associated with groundwater or petroleum withdrawal,
peat oxidation, or hydrocompaction. Therefore, impacts related to subsidence would not occur.
The Geotechnical Exploration identified that seismically-induced settlement onsite could be 0.5 inch or less
and recommends that the Project implement CBC seismic structural design criteria that are specific to the
onsite soils, including excavation and recompaction of soils, and development of foundation systems to reduce
potential settlement. Likewise, the CBC requires that a California Certified Engineering Geologist or
California-licensed civil engineer provide site-specific engineering data for the proposed structures, which
are reviewed by the City for appropriate inclusion as part of the building plan check and development
review process. In addition to CBC requirements, all Project excavations would comply with the current
California and Federal Occupational Safety and Health Administration (CALOSHA) requirements (29 CFR-
Part 1926, Subpart P), related to onsite safety. Thus, impacts related to geologic unit or soils instability or
collapse would also be less than significant.
IMPACT GEO-4: THE PROJECT WOULD NOT 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.
Less than Significant. Expansive soils shrink and swell as the moisture content in soil changes, which causes
shifting, cracking, and damage to structures built on these soils. Fine-grained soils, such as silts and clays,
may contain variable amounts of expansive clay minerals. Most of the Newport Mesa and Corona del Mar
areas are underlain by marine terrace deposits and young alluvial fan sediments that are composed
primarily of granular soils (silty sand, sand, and gravel) (City of Newport Beach, 2006b).
The Geotechnical Exploration describes that the Project site’s near-surface soils consist of undocumented fill
with soft to stiff sandy lean clay, and loose to dense and silty sand and clayey sand. The Project site soils
were determined to have a very low to medium potential for expansion due to the clay content (Appendix
H). The Geotechnical Exploration describes that excavation and recompaction of soils, and design of
foundation systems would reduce potential effects of expansive soils to a less than significant level.
Prior to approval of construction, an engineering level design geotechnical report is required to be prepared
and submitted to the City that details the project designs that have been included to address potential
geotechnical and soil conditions pursuant to the CBC requirements that are included in the City’s Municipal
Code Chapter 15.04 and implemented by PPP GEO-1. Compliance with the CBC, through design level
geotechnical specifications, including those related to expansive soils that would be reviewed and approved
by the City, would ensure that potential impacts related to expansive soils would be less than significant.
IMPACT GEO-5: THE PROJECT WOULD NOT 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 site is currently connected to the City’s sewer system. As detailed in Chapter 3.0,
Project Description, the Project would install a new onsite sewer system that would connect to the existing 12-
inch sewer in Mesa Drive. The proposed Project would not use septic tanks or alternative wastewater disposal
systems. As a result, no impacts related to septic tanks or alternative wastewater disposal systems would
occur from implementation of the proposed Project.
Snug Harbor Surf Park Project 5.6 Geology and Soils
City of Newport Beach 5.6-18
Draft EIR
May 2025
IMPACT GEO-6: THE PROJECT WOULD NOT DIRECTLY OR INDIRECTLY DESTROY A UNIQUE
PALEONTOLOGICAL RESOURCE OR SITE OR UNIQUE GEOLOGIC FEATURE.
Less than Significant with Mitigation Incorporated. The proposed Project consists of the development of a
surf park, amenity clubhouse, athlete accommodations, and associated infrastructure improvements.
Earthmoving activities, including grading and trenching activities, have the potential to disturb previously
unknown paleontological resources. The Paleontological Resources Assessment (Appendix I) describes that
the Project site consists of non-sensitive artificial fill and young axial channel deposits to 10 feet in depth,
which are underlain by old paralic deposits and other Pleistocene deposits. Due to the occurrence of
terrestrial and marine fossils at shallow depths from late Pleistocene alluvial fan sediments across Orange
County, the sediments underlying the Project site are considered as having high paleontological sensitivity
(Appendix I). Also, based on the presence of nearby significant fossil localities, the Project site is considered
to have a high potential to yield significant paleontological resources below 10 feet in depth. As such, the
Paleontological Resources Assessment concluded that the Project site has a high sensitivity for paleontological
resources (Appendix I).
As a result, Mitigation Measure PAL-1 is included to require preparation of a Paleontological Resources
Impact Mitigation Program (PRIMP) that would require ground disturbing activities below 10 feet bgs in
areas of young axial channel deposits and in of old paralic deposits overlain by alluvial fan deposits to be
monitored to identify and recover any significant fossil remains. Any collected resources shall be prepared
to the point of identification, identified to the lowest taxonomic level possible, cataloged, and curated into
the permanent collections of a scientific institution. With implementation of Mitigation Measure PAL-1,
potential impacts to paleontological resources would be less than significant.
5.6.7 CUMULATIVE IMPACTS
Geology and Soils. The potential cumulative exposure of people or structures to unstable geologic units
and/or expansive soils that have the potential to result in onsite or offsite landslides, lateral spreading,
subsidence, liquefaction, movement, or collapse tend to be localized in nature, as each site-specific
development has unique geologic considerations. For geology and soils, the cumulative study area consists
of the area that could be affected by proposed Project activities and the areas affected by other projects
whose activities could directly or indirectly affect the geology and soils of the project site.
Site-specific development projects within Newport Beach and adjacent areas within the County of Orange
and Cities of Costa Mesa and Irvine are subject to uniform site-development policies and construction
standards of the CBC and site-specific geotechnical studies prepared to define site-specific conditions that
might pose a risk to safety, such as those described previously for the proposed Project. While increases in
the number of people and structures subject to unstable geologic units and soils would increase in the
proposed Project and with cumulative development, given the application of CBC requirements by the City
through the construction permitting process, the cumulative effects would be less than significant.
Paleontological Resources. The geographic area of potential cumulative impacts related to paleontological
resources includes areas that are underlain by similar geologic units from the same time period, which includes
the Orange County region. A cumulative impact could occur if development projects incrementally result in
the loss of the same types of unique paleontological resources. As detailed in the City’s General Plan EIR,
and the Paleontological Resources Assessment (Appendix I), the City, including the Project site, varies in
paleontological sensitivity from low to high sensitivity increasing with depth. However, incorporation of
Mitigation Measure PAL-1, which requires paleontological monitoring in paleontologically sensitive soils and
provides procedures for fossil recovery which would preserve the quality and integrity of these resources,
would reduce the potential for the proposed Project to result in cumulatively considerable impacts to a less
than significant level. Therefore, paleontological resource impacts would be less than cumulatively significant.
Snug Harbor Surf Park Project 5.6 Geology and Soils
City of Newport Beach 5.6-19
Draft EIR
May 2025
5.6.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES
The following would reduce potential impacts related to geology and soils.
Existing Regulations
• California Building Code, Title 24 of the California Code of Regulations
• Public Resources Code (PRC) Section 5097.5
• Municipal Code Chapter 15.04, Building Code
• Municipal Code Chapter 15.10, Excavation and Grading Code
Existing City Council Policy Manual Policy
• City Council Policy Manual Policy K-5, Paleontological and Archaeological Resource Protection Guidelines
Plans, Programs, or Policies
The following Plans, Programs, and Policies (PPP) related to geology and soils are incorporated into the
proposed Project and would reduce potential impacts. These actions will be included in the proposed Project’s
mitigation monitoring and reporting program (MMRP):
PPP GEO-1: CBC Compliance. The proposed Project is required to comply with the California Building
Standards Code (CBC) as included in the City’s Municipal Code as Chapter 15.04, to preclude significant
adverse effects associated with seismic and soils hazards. As part of CBC compliance, CBC related and
geologist and/or civil engineer specifications for the proposed Project shall be incorporated into grading
plans and building specifications as a condition of construction permit approval.
PPP WQ-1: SWPPP. As included in Section 5.9, Hydrology and Water Quality.
PPP WQ-3: WQMP. As included in Section 5.9, Hydrology and Water Quality.
5.6.9 PROJECT DESIGN FEATURES
None.
5.6.10 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Upon implementation of regulatory requirements Impacts GEO-1i-iv, GEO-2, GEO-3, GEO-4, and GEO-5
would be less than significant or have no impact.
Without mitigation, the following impact would be potentially significant:
• Impact GEO-6: Project implementation could uncover subsurface paleontological resources.
5.6.11 MITIGATION MEASURES
Mitigation Measure PAL-1: Prior to commencement of any grading activity on site, a paleontologist shall
be retained to develop a Paleontological Resources Impact Mitigation Program (PRIMP) for this project. The
PRIMP shall include the methods that will be used to protect paleontological resources that may exist within
the project area as well as procedures for monitoring, fossil preparation and identification, curation into a
Snug Harbor Surf Park Project 5.6 Geology and Soils
City of Newport Beach 5.6-20
Draft EIR
May 2025
repository, and preparation of a report at the conclusion of grading. The PRIMP shall be consistent with the
guidelines of the Society of Vertebrate Paleontology (SVP) and include, but not be limited to, the following:
• Excavation and grading activities in deposits with high paleontological sensitivity (Young Axial Channel
Deposits below a depth of 10 feet and Old Paralic Deposits Overlain by Alluvial Fan Deposits) shall be
monitored by a paleontological monitor following a PRIMP. No monitoring is required for excavations
in deposits with no paleontological sensitivity (Artificial Fill).
• If paleontological resources are encountered during the course of ground disturbance, the
paleontological monitor shall have the authority to temporarily redirect construction away from the area
of the find in order to assess its significance. In the event that paleontological resources are encountered
when a paleontological monitor is not present, work in the immediate area of the find shall be redirected
and a paleontologist should be contacted to assess the find for significance. If determined to be
significant, the fossil shall be collected from the field.
• Collected resources shall be prepared to the point of identification, identified to the lowest taxonomic
level possible, cataloged, and curated into the permanent collections of a scientific institution.
• At the conclusion of the monitoring program, a report of findings shall be prepared to document the
results of the monitoring program.
5.6.12 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Compliance with existing regulatory programs and implementation of Mitigation Measure PAL-1 would
reduce potential impacts associated with unique paleontological resources to a level that is less than
significant.
5.6.13 REFERENCES
Carl Kim Geotechnical, Inc. (2024). Geotechnical Exploration Proposed Wavegarden Cove, 3100 Irvine
Avenue, Newport Beach, California. (Appendix H)
City of Newport Beach. (2001, January). Santa Ana Heights Specific Plan. Retrieved September 23, 2024,
from ocpublicworks.com.
City of Newport Beach. (2006a, July). General Plan. Retrieved September 23, 2024, from
newportbeachca.gov: https://www.newportbeachca.gov/government/departments/community-
development/planning-division/general-plan-codes-and-regulations/general-plan
City of Newport Beach. (2006b, July). General Plan Environmental Impact Report. Retrieved September 23,
2024, from https://www.newportbeachca.gov/government/departments/community-
development/planning-division/general-plan-codes-and-regulations/general-plan/general-plan-
environmental-impact-repor
City of Newport Beach. (2024a). Newport Beach Municipal Code. Retrieved September 23, 2024, from
codepublishing.com: https://www.codepublishing.com/CA/NewportBeach/
City of Newport Beach. (2024b). Council Policy Manual.
https://www.newportbeachca.gov/government/city-council/council-policy-manual
City of Newport Beach. (2024c). Council Policy Manual, K-5, Paleontological and Archaeological Resource
Protection Guidelines.
https://www.newportbeachca.gov/home/showpublisheddocument/2437/636385647487800000
LSA Associates. (2024). Paleontological Resources Assessment for the Snug Harbor Project in Newport Beach,
Orange County, California. (Appendix I)
Snug Harbor Surf Park Project 5.7 Greenhouse Gas Emissions
City of Newport Beach 5.7-1
Draft EIR
May 2025
5.7 Greenhouse Gas Emissions
5.7.1 INTRODUCTION
This section of the Draft EIR evaluates greenhouse gas (GHG) emissions associated with the proposed Project
and its contribution to global climate change. Specifically, this section evaluates the extent to which GHG
emissions from the Project contribute to elevated levels of GHGs in the Earth’s atmosphere and consequently
contribute to climate change. This section also addresses the Project’s consistency with applicable plans,
policies, and public agency regulations adopted for the purpose of reducing the emissions of GHGs. The
analysis within this section is based on the following City documents and technical reports:
• City of Newport Beach General Plan, 2006
• City of Newport Beach General Plan Environmental Impact Report (General Plan EIR), 2006
• City of Newport Beach Municipal Code
• Surf Farm Greenhouse Gas Analysis, prepared by Urban Crossroads, 2025, included as Appendix J
5.7.2 REGULATORY SETTING
5.7.2.1 Federal Regulations
Energy Independence and Security Act, Corporate Average Fuel Efficiency Standards
On December 19, 2007, the Energy Independence and Security Act of 2007 was signed into law, requiring
an increased Corporate Average Fuel Economy (CAFE) standard of 35 miles per gallon (mpg) for the
combined fleet of cars and light trucks by the 2020 model year.
In addition to setting increased CAFE standards for motor vehicles, the Energy Independence and Security
Act includes the following additional provisions:
• Renewable Fuel Standard (RFS) (Section 202)
• Appliance and Lighting Efficiency Standards (Sections 301–325)
• Building Energy Efficiency (Sections 411–441)
Additional provisions of the Act address energy savings in government and public institutions, promoting
research for alternative energy, additional research in carbon capture, international energy programs, and
the creation of green jobs.
5.7.2.2 State Regulations
California Assembly Bill 1493– Pavley
In 2002, the California Legislature adopted Assembly Bill (AB) 1493 requiring the adoption of regulations
to reduce GHG emissions in the transportation sector. In September 2004, pursuant to AB 1493, the
California Air Resources Board (CARB) approved regulations to reduce GHG emissions from new motor
vehicles beginning with the 2009 model year (Pavley Regulations). In September 2009, CARB adopted
amendments to the Pavley Regulations to reduce GHG emissions from 2009 to 2016. CARB, the United
States Environmental Protection Agency (USEPA), and the United States Department of Transportation’s
National Highway Traffic and Safety Administration have coordinated efforts to develop fuel economy and
Snug Harbor Surf Park Project 5.7 Greenhouse Gas Emissions
City of Newport Beach 5.7-2
Draft EIR
May 2025
GHG standards for model 2017-2025 vehicles. The GHG standards are incorporated into the “Low Emission
Vehicle” (LEV) Regulations.
California Executive Order S-3-05 – Statewide Emission Reduction Targets
Executive Order S-3-05 was signed by Governor Arnold Schwarzenegger in June 2005. Executive Order
S-3-05 establishes statewide emission reduction targets through the year 2050:
• By 2010, reduce GHG emissions to 2000 levels;
• By 2020, reduce GHG emissions to 1990 levels; and
• By 2050, reduce GHG emissions to 80 percent below 1990 levels.
California Assembly Bill 32 (AB 32), Global Warming Solutions Act of 2006 (Chapter 488, Statutes of
2006)
In 2006, the California Legislature passed the California Global Warming Solutions Act of 2006 (AB 32),
which created a comprehensive, multi-year program to reduce GHG emissions in California. AB 32 required
CARB to develop a Scoping Plan that describes the approach California will take to reduce GHGs to achieve
the goal of reducing emissions to 1990 levels by 2020. The Scoping Plan was first approved by CARB in
2008 and must be updated at least every five years. Since 2008, there have been two updates to the
Scoping Plan. Each of the Scoping Plans have included a suite of policies to help the State achieve its GHG
targets, in large part leveraging existing programs whose primary goal is to reduce harmful air pollution.
The 2017 Scoping Plan identifies how the State can reach the 2030 climate target to reduce GHG emissions
by 40 percent from 1990 levels, and substantially advance toward the 2050 climate goal to reduce GHG
emissions by 80 percent below 1990 levels.
The AB 32 Scoping Plan also anticipates that local government actions will result in reduced GHG emissions
because local governments have the primary authority to plan, zone, approve, and permit development to
accommodate population growth and the changing needs of their jurisdictions. The Scoping Plan also relies
on the requirements of Senate Bill 375 (discussed below) to align local land use and transportation planning
for achieving GHG reductions.
The Scoping Plan must be updated every five years to evaluate AB 32 policies and ensure that California
is on track to achieve the GHG reduction goals. On December 15, 2022, CARB adopted the 2022 Scoping
Plan. The 2022 Scoping Plan builds on the previous Scoping Plans as well as the requirements set forth by
AB 1279, which directs the state to become carbon neutral no later than 2045. To achieve this statutory
objective, the 2022 Scoping Plan lays out how California can reduce GHG emissions by 85 percent below
1990 levels and achieve carbon neutrality by 2045. The Scoping Plan scenario to do this is to “deploy a
broad portfolio of existing and emerging fossil fuel alternatives and clean technologies, and align with
statutes, Executive Orders, Board direction, and direction from the governor.” The 2022 Scoping Plan sets
one of the most aggressive approaches to reach carbon neutrality in the world.
Senate Bill 375 (Chapter 728, Statutes of 2008)
In August 2008, the California Legislature passed, and on September 30, 2008, Governor Schwarzenegger
signed, Senate Bill (SB) 375, which addresses GHG emissions associated with the transportation sector
through regional transportation and sustainability plans. Regional GHG reduction targets for the automobile
and light-truck sector for 2020 and 2035, as determined by CARB, are required to consider the emission
reductions associated with vehicle emission standards (see SB 1493), the composition of fuels (see Executive
Order S-1-07), and other CARB-approved measures to reduce GHG emissions. Regional metropolitan
planning organizations will be responsible for preparing a Sustainable Communities Strategy within their
Snug Harbor Surf Park Project 5.7 Greenhouse Gas Emissions
City of Newport Beach 5.7-3
Draft EIR
May 2025
Regional Transportation Plan. The goal of the Sustainable Communities Strategy is to establish a
development plan for the region, which, after considering transportation measures and policies, will achieve,
if feasible, the GHG reduction targets. If a Sustainable Communities Strategy is unable to achieve the GHG
reduction target, a metropolitan planning organization must prepare an Alternative Planning Strategy
demonstrating how the GHG reduction target would be achieved through alternative development patterns,
infrastructure, or additional transportation measures or policies. SB 375 provides incentives for streamlining
CEQA requirements by substantially reducing the requirements for “transit priority projects,” as specified in
SB 375, and eliminating the analysis of the impacts of certain residential projects on global warming and
the growth-inducing impacts of those projects when the projects are consistent with the Sustainable
Communities Strategy or Alternative Planning Strategy. On September 23, 2010, CARB adopted the SB
375 targets for the regional metropolitan planning organizations.
Executive Order B-30-15 – 2030 Statewide Emission Reduction Target
Executive Order B-30-15 was signed by Governor Jerry Brown on April 29, 2015, establishing an interim
statewide GHG reduction target of 40 percent below 1990 levels by 2030, which is necessary to guide
regulatory policy and investments in California in the midterm, and put California on the most cost-effective
path for long-term emission reductions. Under this Executive Order, all State agencies with jurisdiction over
sources of GHG emissions are required to continue to develop and implement emissions reduction programs
to reach the State’s 2050 target and attain a level of emissions necessary to avoid dangerous climate
change. According to the Governor’s Office, this Executive Order is in line with the scientifically established
levels needed in the United States to limit global warming below 2°C - the warming threshold at which
scientists say there will likely be major climate disruptions such as super droughts and rising sea levels.
Senate Bill 32 (Chapter 249, Statutes of 2016)
Senate Bill 32 was signed on September 8, 2016, by Governor Jerry Brown. SB 32 requires the State to
reduce statewide GHG emissions to 40 percent below 1990 levels by 2030, a reduction target that was
first introduced in Executive Order B-30-15. The new legislation builds upon the AB 32 goal of 1990 levels
by 2020 and provides an intermediate goal to achieving S-3-05, which sets a statewide GHG reduction
target of 80 percent below 1990 levels by 2050. A related bill that was also approved in 2016, AB 197
(Chapter 250, Statutes of 2016) creates a legislative committee to oversee regulators to ensure that CARB
is not only responsive to the Governor, but also the Legislature.
AB 398 – Extension of Cap and Trade Program to 2030 (Chapter 617, Statutes of 2017)
AB 398 was signed by Governor Brown on July 25, 2017 and became effective immediately as urgency
legislation. AB 398, among other things, extending the cap and trade program through 2030.
Senate Bill 97 (Chapter 185, Statutes of 2007)
SB 97 (Health and Safety Code Section 21083.5) was adopted in 2007 and required the Office of Planning
and Research to prepare amendments to the State CEQA Guidelines for the mitigation of GHG impacts. The
amendments became effective on March 18, 2010. The CEQA Amendments provide guidance to public
agencies regarding the analysis and mitigation of the effects of GHG emissions in CEQA documents. A new
section, State CEQA Guidelines Section 15064.4, was added to assist agencies in determining the
significance of GHG emissions. The State CEQA Guidelines Section gives discretion to the lead agency
whether to: (1) use a model of methodology to quantify GHG emissions resulting from a project, and which
model or methodology to use; or (2) rely on a qualitative analysis or performance-based standards. CEQA
does not provide guidance to determine whether the project’s estimated GHG emissions are significant or
cumulatively considerable.
Snug Harbor Surf Park Project 5.7 Greenhouse Gas Emissions
City of Newport Beach 5.7-4
Draft EIR
May 2025
Also amended were State CEQA Guidelines Sections 15126.4 and 15130, which address mitigation
measures and cumulative impacts respectively. However, GHG mitigation measures are referenced in
general terms, and no specific measures are identified. Additionally, the revision to the cumulative impact
discussion requirement (Section 15130) simply directs agencies to analyze GHG emissions in an EIR when a
project’s incremental contribution of emissions may be cumulatively considerable, however it does not answer
the question of when emissions are cumulatively considerable.
Section 15183.5 permits programmatic GHG analysis and later project-specific tiering, as well as the
preparation of Greenhouse Gas Reduction Plans. Compliance with such plans can support a determination
that a project’s cumulative effect is not cumulatively considerable, according to Section 15183.5(b).
California Air Resources Board Scoping Plan
On December 15, 2022, CARB adopted the 2022 Scoping Plan for Achieving Carbon Neutrality (2022
Scoping Plan). The 2022 Scoping Plan builds on the previous 2017 Scoping Plan as well as the requirements
set forth by AB 1279, which directs the State to become carbon neutral no later than 2045. To achieve this
statutory objective, the 2022 Scoping Plan lays out how California can reduce GHG emissions by 85 percent
below 1990 levels and achieve carbon neutrality by 2045. The Scoping Plan scenario to do this is to “deploy
a broad portfolio of existing and emerging fossil fuel alternatives and clean technologies, and align with
statutes, Executive Orders, Board direction, and direction from the governor.” The 2022 Scoping Plan sets
one of the most aggressive approaches to reach carbon neutrality in the world. Unlike the 2017 Scoping
Plan, CARB no longer includes a numeric per capita threshold and instead advocates for compliance with a
local GHG reduction strategy (CAP) consistent with CEQA Guidelines Section 15183.5.
The key elements of the 2022 CARB Scoping Plan focus on transportation; the regulations that affect this
sector are adopted and enforced by CARB on vehicle manufacturers and outside the jurisdiction and control
of local governments. As stated in the Plan’s executive summary:
“The major element of this unprecedented transformation is the aggressive reduction of fossil
fuels wherever they are currently used in California, building on and accelerating carbon
reduction programs that have been in place for a decade and a half. That means rapidly moving
to zero-emission transportation; electrifying the cars, buses, trains, and trucks that now
constitute California’s single largest source of planet-warming pollution.”
“[A]pproval of this plan catalyzes a number of efforts, including the development of new
regulations as well as amendments to strengthen regulations and programs already in place,
not just at CARB but across state agencies.”
Under the 2022 Scoping Plan, the 2045 carbon neutrality goal is to be implemented by the following
objectives:
• Reimagine roadway projects that increase VMT in a way that meets community needs and reduces the
need to drive.
• Double local transit capacity and service frequencies by 2030.
• Complete the High-Speed Rail (HSR) System and other elements of the intercity rail network by 2040.
• Expand and complete planned networks of high-quality active transportation infrastructure.
• Increase availability and affordability of bikes, e-bikes, scooters, and other alternatives to light-duty
vehicles, prioritizing needs of underserved communities.
• Shift revenue generation for transportation projects away from the gas tax into more durable sources
by 2030.
• Authorize and implement roadway pricing strategies and reallocate revenues to equitably improve
transit, bicycling, and other sustainable transportation choices.
Snug Harbor Surf Park Project 5.7 Greenhouse Gas Emissions
City of Newport Beach 5.7-5
Draft EIR
May 2025
• Prioritize addressing key transit bottlenecks and other infrastructure investments to improve transit
operational efficiency over investments that increase VMT.
• Develop and implement a statewide transportation demand management (TDM) framework with VMT
mitigation requirements for large employers and large developments.
• Prevent uncontrolled growth of autonomous vehicle (AV) VMT, particularly zero-passenger miles.
• Channel new mobility services towards pooled use models, transit complementarity, and lower VMT
outcomes.
• Establish an integrated statewide system for trip planning, booking, payment, and user accounts that
enables efficient and equitable multimodal systems.
• Provide financial support for low-income and disadvantaged Californians’ use of transit and new
mobility services.
• Expand universal design features for new mobility services.
• Accelerate infill development in existing transportation-efficient places and deploy strategic resources
to create more transportation-efficient locations.
• Encourage alignment in land use, housing, transportation, and conservation planning in adopted regional
plans (RTP/SCS and RHNA) and local plans (e.g., general plans, zoning, and local transportation plans).
• Accelerate production of affordable housing in forms and locations that reduce VMT and affirmatively
further fair housing policy objectives.
• Reduce or eliminate parking requirements (and/or enact parking maximums, as appropriate) and
promote redevelopment of excess parking, especially in infill locations.
• Preserve and protect existing affordable housing stock and protect existing residents and businesses
from displacement and climate risk.
Title 24 Energy Efficiency Standards and California Green Building Standards
California Code of Regulations (CCR) Title 24 Part 6: The California Energy Code was first adopted in 1978
in response to a legislative mandate to reduce California’s energy consumption. The standards are updated
periodically to allow consideration and possible incorporation of new energy efficient technologies and
methods. The most recently updated 2022 Energy Code encourages efficient electric heat pumps, establishes
electric-ready requirements for new homes, expands solar photovoltaic and battery storage standards, and
strengthens ventilation standards, among other requirements.
CCR, Title 24, Part 11: California Green Building Standards Code (CALGreen) is a comprehensive and
uniform regulatory code for all new construction and major renovations, and is administered by the California
Building Standards Commission. The purpose of CALGreen is to improve public health, safety, and general
welfare through enhanced design and construction of buildings using concepts which reduce negative impacts
and promote those principles which have a positive environmental impact and encourage sustainable
construction practices. It is also updated every three years. The most recent update is the 2022 CALGreen
Code that became effective January 1, 2023.
It should be noted that the 2025 California Energy Code and CALGreen Building Code Standards are
expected to be effective on January 1, 2026. The Project would be required to comply with the applicable
standards in place at the time plan check submittals are made.
The 2022 California Energy Code and CALGreen Code mandatory measures for nonresidential uses that
reduce air pollutant emissions and are applicable to the proposed Project include, but are not limited to, the
following:
• Short-term bicycle parking. If the new project or an additional alteration is anticipated to generate
visitor traffic, provide permanently anchored bicycle racks within 200 feet of the visitors’ entrance,
Snug Harbor Surf Park Project 5.7 Greenhouse Gas Emissions
City of Newport Beach 5.7-6
Draft EIR
May 2025
readily visible to passers-by, for 5% of new visitor motorized vehicle parking spaces being added, with
a minimum of one two-bike capacity rack (5.106.4.1.1).
• Long-term bicycle parking. For new buildings with tenant spaces that have 10 or more tenant-occupants,
provide secure bicycle parking for 5% of the tenant-occupant vehicular parking spaces with a minimum
of one bicycle parking facility (5.106.4.1.2).
• EV charging stations. New construction shall facilitate the future installation of EV supply equipment. The
compliance requires empty raceways for future conduit and documentation that the electrical system has
adequate capacity for the future load. The number of spaces to be provided for is contained in Table
5.106. 5.3.3 (5.106.5.3). Additionally, Table 5.106.5.4.1 specifies requirements for the installation of
raceway conduit and panel power requirements for medium- and heavy-duty electric vehicle supply
equipment for warehouses, grocery stores, and retail stores.
• Outdoor light pollution reduction. Outdoor lighting systems shall be designed to meet the backlight, uplight
and glare ratings per Table 5.106.8 (5.106.8).
• Construction waste management. Recycle and/or salvage for reuse a minimum of 65% of the
nonhazardous construction and demolition waste in accordance with Section 5.408.1.1. 5.405.1.2,
or 5.408.1.3; or meet a local construction and demolition waste management ordinance, whichever
is more stringent (5.408.1).
• Excavated soil and land clearing debris. 100% of trees, stumps, rocks and associated vegetation
and soils resulting primarily from land clearing shall be reuse or recycled. For a phased project, such
material may be stockpiled on site until the storage site is developed (5.408.3).
• Recycling by Occupants. Provide readily accessible areas that serve the entire building and are identified
for the depositing, storage, and collection of non-hazardous materials for recycling, including (at a
minimum) paper, corrugated cardboard, glass, plastics, organic waste, and metals or meet a lawfully
enacted local recycling ordinance, if more restrictive (5.410.1).
• Water conserving plumbing fixtures and fittings. Plumbing fixtures (water closets and urinals) and
fittings (faucets and showerheads) shall comply with the following:
o Water Closets. The effective flush volume of all water closets shall not exceed 1.28 gallons per
flush (5.303.3.1)
o Urinals. The effective flush volume of wall-mounted urinals shall not exceed 0.125 gallons per
flush (5.303.3.2.1). The effective flush volume of floor- mounted or other urinals shall not exceed
0.5 gallons per flush (5.303.3.2.2).
o Showerheads. Single showerheads shall have a minimum flow rate of not more than 1.8 gallons
per minute and 80 psi (5.303.3.3.1). When a shower is served by more than one showerhead, the
combine flow rate of all showerheads and/or other shower outlets controlled by a single valve
shall not exceed 1.8 gallons per minute at 80 psi (5.303.3.3.2).
o Faucets and fountains. Nonresidential lavatory faucets shall have a maximum flow rate of not
more than 0.5 gallons per minute at 60 psi (5.303.3.4.1). Kitchen faucets shall have a maximum
flow rate of not more than 1.8 gallons per minute of 60 psi (5.303.3.4.2). Wash fountains shall
have a maximum flow rate of not more than 1.8 gallons per minute (5.303.3.4.3). Metering
faucets shall not deliver more than 0.20 gallons per cycle (5.303.3.4.4). Metering faucets for wash
fountains shall have a maximum flow rate not more than 0.20 gallons per cycle (5.303.3.4.5).
• Outdoor potable water uses in landscaped areas. Nonresidential developments shall comply with a local
water efficient landscape ordinance or the current California Department of Water Resources’ Model
Water Efficient Landscape Ordinance (MWELO), whichever is more stringent (5.304.1).
• Water meters. Separate submeters or metering devices shall be installed for new buildings or
additions in excess of 50,000 SF or for excess consumption where any tenant within a new building or
Snug Harbor Surf Park Project 5.7 Greenhouse Gas Emissions
City of Newport Beach 5.7-7
Draft EIR
May 2025
within an addition that is project to consume more than 1,000 gallons per day (GPD) (5.303.1.1 and
5.303.1.2).
• Outdoor water uses in rehabilitated landscape projects equal or greater than 2,500 SF. Rehabilitated
landscape projects with an aggregate landscape area equal to or greater than 2,500 SF requiring
a building or landscape permit (5.304.3).
• Commissioning. For new buildings 10,000 SF and over, building commissioning shall be included in the
design and construction processes of the building project to verify that the building systems and
components meet the owner’s or owner representative’s project requirements (5.410.2).
The City of Newport Beach has adopted the 2022 Energy Code in Municipal Code Chapter 15.17 and the
2022 CALGreen Code in Municipal Code Chapter 15.11.
5.7.2.3 Local and Regional Regulations
City of Newport Beach General Plan 2006
The City of Newport Beach General Plan 2006 contains the following policies related to greenhouse gas
emissions that are applicable to the Project:
Policy CE 7.1.8 Electric Vehicle (EV) Charging Stations. Install additional EV charging stations on City
properties, support existing private development to add new EV charging stations and
develop incentives for the installation of EV charging stations and other alternative fuels
systems as part of new development.
Policy NR 6.1 Walkable Neighborhoods. Provide for walkable neighborhoods to reduce vehicle trips
by siting amenities such as services, parks, and schools in close proximity to residential
areas.
Policy NR 24.2 Energy-Efficient Design Features. Promote energy-efficient design features.
Policy NR 24.3 Incentives for Green Building Program Implementation. Promote or provide incentives
for “Green Building” programs that go beyond the requirements of Title 24 of the
California Administrative Code and encourage energy efficient design elements as
appropriate to achieve “green building” status.
City of Newport Beach Energy Action Plan
The City of Newport Beach’s Energy Action Plan outlines strategies to enhance energy efficiency, promote
renewable energy, and reduce GHG emissions. By implementing energy efficiency programs in residential
and commercial buildings, encouraging renewable energy sources like solar, and setting long-term
sustainability goals, the plan aims to mitigate climate change impacts. It also emphasizes community
engagement and collaboration with local organizations to foster a culture of energy conservation. Ultimately,
the plan directly contributes to reducing GHG emissions, improving air quality, and promoting a healthier,
more sustainable environment for residents. The Plan is focused on City buildings and facilities and does not
include any specific policies for new commercial recreational development projects.
City of Newport Beach Municipal Code
Section 15.11.010, Adoption of the California Green Building Standards Code. The City Council adopts
and incorporates by reference, as though set forth in full in this section, the 2022 Edition of the California
Green Building Standards Code.
Snug Harbor Surf Park Project 5.7 Greenhouse Gas Emissions
City of Newport Beach 5.7-8
Draft EIR
May 2025
Section 15.17.010, Adoption of the California Energy Code. The City Council adopts and incorporates by
reference, as though set forth in full in this section, the 2022 Edition of the California Energy Code, 24 CCR
and all national codes and standards referenced therein to the prescribed extent of each such reference.
Section 15.18.040, Solar Energy Requirements. This section of the Municipal Code sets the requirements
for solar energy systems with the City of Newport Beach.
Chapter 15.19, Electric Vehicle Charging Stations. Municipal Code Chapter 15.19 aims to encourage the
use of electric vehicle charging stations by removing unreasonable barriers, minimizing costs to property
owners and the City, and expanding the ability of property owners to install electric vehicle charging stations.
Pursuant to Municipal Code Section 15.19.060, applications to install electric vehicle charging stations
through issuance of a building permit or similar nondiscretionary permit will be administratively reviewed
and approved by the Building Division.
5.7.3 ENVIRONMENTAL SETTING
5.7.3.1 Greenhouse Gases Overview
Gases that trap heat in the atmosphere are called greenhouse gases (GHGs). The major concern with GHGs
is that increases in their concentrations are contributing to global climate change. Global climate change is
a change in the average weather on Earth that can be measured by wind patterns, storms, precipitation,
and temperature. Although there is disagreement as to the rate of global climate change and the extent of
the impacts attributable to human activities, most in the scientific community agree that there is a direct link
between increased emissions of GHGs and long-term global temperature increases.
The principal GHGs are carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), sulfur hexafluoride (SF6),
perfluorocarbons (PFCs), and hydrofluorocarbons (HFCs). Because different GHGs have different warming
potential, and CO2 is the most common reference gas for climate change, GHG emissions are often quantified
and reported as CO2 equivalents (CO2e). For example, SF6 is a GHG commonly used in the utility industry
as an insulating gas in circuit breakers and other electronic equipment. SF6, while comprising a small fraction
of the total GHGs emitted annually world-wide, is a much more potent GHG, with 22,800 times the global
warming potential as CO2. Therefore, an emission of one metric ton (MT) of SF6 could be reported as an
emission of 22,800 MT of CO2e. Large emission sources are reported in million metric tons (MMT) of CO2e.
The principal GHGs are described below, along with their global warming potential.
Carbon dioxide: Carbon dioxide (CO2) is an odorless, colorless, natural GHG. Carbon dioxide’s global
warming potential is 1. Natural sources include decomposition of dead organic matter; respiration of
bacteria, plants, animals, and fungus; evaporation from oceans; and volcanic outgassing. Anthropogenic
(manmade) sources are from burning coal, oil, natural gas, and wood.
Methane: Methane (CH4) is a flammable gas and is the main component of natural gas. It has a lifetime of
12 years, and its global warming potential is 28. Methane is extracted from geological deposits (natural
gas fields). Other sources are landfills, fermentation of manure, and decay of organic matter.
Nitrous oxide: Nitrous oxide (N2O) (laughing gas) is a colorless GHG that has a lifetime of 121 years, and
its global warming potential is 265. Sources include microbial processes in soil and water, fuel combustion,
and industrial processes.
Sulfur hexafluoride: Sulfur hexafluoride (SF6) is an inorganic, odorless, colorless, and nontoxic,
nonflammable gas that has a lifetime of 3,200 years and a high global warming potential of 23,500. This
gas is manmade and used for insulation in electric power transmission equipment, in the magnesium industry,
in semiconductor manufacturing, and as a tracer gas.
Snug Harbor Surf Park Project 5.7 Greenhouse Gas Emissions
City of Newport Beach 5.7-9
Draft EIR
May 2025
Perfluorocarbons: Perfluorocarbons (PFCs) have stable molecular structures and only break down by
ultraviolet rays about 60 kilometers above Earth’s surface. Because of this, they have long lifetimes, between
10,000 and 50,000 years. Their global warming potential ranges from 7,000 to 11,000. Two main sources
of perfluorocarbons are primary aluminum production and semiconductor manufacturing.
Hydrofluorocarbons: Hydrofluorocarbons (HFCs) are a group of GHGs containing carbon, chlorine, and at
least one hydrogen atom. Their global warming potential ranges from 100 to 12,000. Hydrofluorocarbons
are synthetic manmade chemicals used as a substitute for chlorofluorocarbons in applications such as
automobile air conditioners and refrigerants.
Some of the potential effects in California of global warming may include loss in snow pack, sea level rise,
more extreme heat days per year, more high ozone days, more forest fires, and more drought years.
Globally, climate change has the potential to impact numerous environmental resources through potential,
though uncertain, impacts related to future air temperatures and precipitation patterns. The projected effects
of global warming on weather and climate are likely to vary regionally, but are expected to include the
following direct effects:
• Higher maximum temperatures and more hot days over nearly all land areas;
• Higher minimum temperatures, fewer cold days and frost days over nearly all land areas;
• Reduced diurnal temperature range over most land areas;
• Increase of heat index over land areas; and
• More intense precipitation events.
There are also many secondary effects that are projected to result from global warming, including global
rise in sea level, impacts to agriculture, changes in disease vectors, and changes in habitat and biodiversity.
While the possible outcomes and the feedback mechanisms involved are not fully understood and much
research remains to be done, the potential for substantial environmental, social, and economic consequences
over the long term may be great.
GHGs are produced by both direct and indirect emissions sources. Direct emissions include consumption of
natural gas, heating and cooling of buildings, landscaping activities and other equipment used directly by
land uses. Indirect emissions include the consumption of fossil fuels for vehicle trips, electricity generation,
water usage, and solid waste disposal.
5.7.3.2 Project Site Conditions
The proposed Project is located in the northern portion of the City of Newport Beach east of the intersection
of Mesa Drive and Irvine Avenue within the Newport Beach Golf Course. The primary GHG emissions in the
City of Newport Beach result from on-road transportation, building energy, water use, and wastewater
generation.
The Project site encompasses approximately 15.38 acres and is comprised of one parcel. The Project site is
currently developed with a 38-bay partially covered synthetic turf driving range, a 1,050-square-foot (SF)
putting green, a 8,975 SF building that includes a pro shop and a restaurant that seats 233 people, a
surface parking lot with 280 parking spaces, and three holes of the existing NB Golf Course (holes 1, 2, and
9). Existing GHG emissions occur from operation of the site for commercial recreational activities and vehicle
trips associated with this use and total approximately 1,839.59 CO2e annually.
5.7.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a Project could have a significant effect if it were to:
Snug Harbor Surf Park Project 5.7 Greenhouse Gas Emissions
City of Newport Beach 5.7-10
Draft EIR
May 2025
GHG-1 Generate greenhouse gas emissions, either directly or indirectly, that may have a significant
impact on the environment.
GHG-2 Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the
emissions of greenhouse gases.
CEQA Guidelines Section 15064.4 provides discretion to the lead agency whether to: (1) use a model of
methodology to quantify GHG emissions resulting from a project, and which model or methodology to use;
or (2) rely on a qualitative analysis or performance-based standards. In addition, CEQA does not provide
guidance to determine whether the project’s estimated GHG emissions are significant, but recommends that
lead agencies consider several factors that may be used in the determination of significance of project
related GHG emissions, including:
• The extent to which the project may increase or reduce GHG emissions as compared to the existing
environmental setting.
• Whether the project emissions exceed a threshold of significance that the lead agency determines
applies to the project.
• The extent to which the project complies with regulations or requirements adopted to implement a
statewide, regional, or local plan for the reduction or mitigation of GHG emissions.
CEQA Guidelines Section 15130(f) describes that the effects of GHG emissions are by their very nature
cumulative and should be analyzed in the context of CEQA’s requirements for cumulative impact analysis.
Additionally, CEQA Guidelines Section 15064(h)3 states that 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 requirements to avoid or lesson the cumulative problem.
The SCAQMD formed a working group to identify greenhouse gas emissions thresholds for land use projects
that could be used by local lead agencies in the Basin in 2008. The working group developed several
different options that are contained in the SCAQMD Draft Guidance Document – Interim CEQA Greenhouse
Gas Significance Threshold, that could be applied by lead agencies, which includes the following tiered
approach:
• Tier 1 consists of evaluating whether or not the project qualifies for any applicable exemption under
CEQA.
• Tier 2 consists of determining whether the project is consistent with a greenhouse gas reduction plan. If
a project is consistent with a qualifying local greenhouse gas reduction plan, it does not have significant
greenhouse gas emissions.
• Tier 3 consists of screening values, which the lead agency can choose, but must be consistent with all
projects within its jurisdiction. A project’s construction emissions are averaged over 30 years and are
added to the project’s operational emissions. If a project’s emissions are below one of the following
screening thresholds, then the project is less than significant:
o All land use types: 3,000 MTCO2e per year
o Based on land use type:
Residential: 3,500 MTCO2e per year
Commercial: 1,400 MTCO2e per year
Mixed use: 3,000 MTCO2e per year
Industrial use: 10,000 MTCO2e per year when SCAQMD is the lead agency
Snug Harbor Surf Park Project 5.7 Greenhouse Gas Emissions
City of Newport Beach 5.7-11
Draft EIR
May 2025
SCAQMD used the Executive Order S-3-05-year 2050 goal as the basis for the Tier 3 screening level.
Achieving the Executive Order’s objective would contribute to worldwide efforts to cap CO2 concentrations
at 450 ppm, thus stabilizing global climate.
The City of Newport Beach has not adopted its own numeric threshold of significance for determining impacts
concerning GHG emissions, but uses a screening threshold of 3,000 MTCO2e/yr. This approach is a widely
accepted screening threshold used by the City of Newport Beach and numerous cities in the South Coast Air
Basin (SCAB) and is based on the SCAQMD staff’s proposed GHG screening threshold for stationary source
emissions for non-industrial projects.
Thus, and based on guidance from the SCAQMD, if the Project would emit GHGs less than 3,000
MTCO2e/yr, the Project is not considered a substantial GHG emitter and the GHG impact is less than
significant. Conversely, if the Project would emit GHGs in excess of 3,000 MTCO2e/yr, then the Project could
be considered a substantial GHG emitter, and mitigation would be required.
5.7.5 METHODOLOGY
The California Emissions Estimator Model (CalEEMod) v2022 is the most recent version and has been used to
determine construction and operational GHG emissions from the proposed Project. The purpose of this model
is to calculate construction-source and operational-source GHG emissions from direct and indirect sources;
and quantify applicable air quality and GHG reductions achieved from mitigation measures, if applied.
Construction emissions are quantified and per SCAQMD methodology, the total GHG emissions for
construction activities are divided by 30-years and then added to the annual operational phase of GHG
emissions.
In addition, CEQA requires the lead agency to consider the extent to which the proposed Project complies
with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction
or mitigation of GHG emissions. Therefore, this section addresses whether the proposed Project complies with
various programs and measures designed to reduce GHG emissions. There is no statewide program or
regional program or plan that has been adopted with which all new development must comply; thus, this
analysis has identified the most relevant to the City of Newport Beach and the proposed Project.
5.7.6 ENVIRONMENTAL IMPACTS
IMPACT GHG-1: THE PROJECT WOULD NOT GENERATE GREENHOUSE GAS EMISSIONS, EITHER
DIRECTLY OR INDIRECTLY, THAT MAY HAVE A SIGNIFICANT IMPACT ON THE
ENVIRONMENT.
Less than Significant Impact.
Construction
As described in Section 3.0, Project Description, construction of the proposed Project is anticipated to occur
over approximately 18 months. The construction-related activities involve the following: demolition, site
preparation, excavation, grading, paving, construction of the surf lagoon, pools, spa, building structures,
parking lots, infrastructure, landscape installation, and architectural coatings. These construction activities
would result in the emission of GHGs from equipment exhaust, construction-related vehicular activity and
construction worker automobile trips. The maximum emissions of GHGs from construction of the Project was
based on the assumption that each piece of construction equipment would operate 8 hours per day, which is
a conservative assumption that all equipment would be operating throughout the entire workday. The total
Snug Harbor Surf Park Project 5.7 Greenhouse Gas Emissions
City of Newport Beach 5.7-12
Draft EIR
May 2025
estimated construction related GHG emissions from construction of the proposed Project were amortized
over 30 years per SCAQMD methodology.
As shown on Table 5.7-1, construction of the proposed Project would result in the generation of
approximately 25.93 MTCO2e.
Table 5.7-1: Project Construction Greenhouse Emissions
Year Emissions (MT/yr)
CO2 CH4 N2O Refrigerants Total CO2e 1
2026 418.88 0.02 0.01 0.06 421.20
2027 354.19 0.01 0.01 0.07 356.64
Total GHG Emissions 773.07 0.03 0.01 0.13 777.84
Amortized Construction Emissions 25.77 1.01E-03 0.00 0.00 25.93
CO2 = carbon dioxide, CH4 = methane, N2O = nitrous oxide, CO2e = carbon dioxide equivalent, MT/yr = metric tons per year
Source: Appendix J
Operation
Operation of the proposed Project would generate GHG emissions from vehicle trips, electricity and natural
gas consumption, water, and wastewater transport (the energy used to pump water), and solid waste
generation. The GHG generated by Project vehicular trips would be limited. As detailed in Section 5.14,
Transportation, the proposed Project would result in a net increase of 186 daily trips. GHG emissions from
electricity consumed by the proposed Project would be generated off site by fuel combustion at the electricity
provider. The Project is expected to consume 9,655,716 kWh of electricity per year. The Project includes
installation of solar panels on building roofs and on canopies in the parking lots (Project Design Feature
(PDF) -1 Solar). These solar panels would generate approximately 2,375,568 kWh or 24 percent of the
Projects yearly energy demand. Additionally, it is estimated that the Project would consume 12,158,880
kBtu of natural gas per year for kitchen and water heating purposes. GHG emissions associated with natural
gas usage in kitchens and water heaters was calculated using CalEEMod (Appendix J).
GHG emissions from water transport are also indirect emissions resulting from the energy required to
transport water from its source. The Project is expected to consume 28.85 million gallons of water per year,
and approximately 53,351 gallons per day of wastewater. GHG emissions from solid waste disposal (of
approximately 17.91 tons per year) are associated with the anaerobic breakdown of material. Additionally,
the Project involves both the removal of existing trees and the addition of new ones, which may affect carbon
sequestration at the site. Mature trees store substantial carbon, and their removal can lead to immediate
emissions and reduced sequestration capacity. Conversely, while young trees initially sequester less carbon,
they can contribute significantly over time as they grow. Sequestration associated with the Project was
calculated and included in the estimated GHGs that would be generated from the Project.
As shown in Table 5.7-2, construction and operation of the Project would generate approximately 2,433.05
MTCO2e/yr, which would not exceed the screening threshold of 3,000 MTCO2e per year. Therefore,
construction and operation of the proposed Project would be less than significant.
1 CalEEMod reports the most common GHGs emitted which include CO2, CH4, N2O, and Refrigerants. These GHGs are then converted
into the CO2e by multiplying the individual GHG by the global warming potential (GWP).
Snug Harbor Surf Park Project 5.7 Greenhouse Gas Emissions
City of Newport Beach 5.7-13
Draft EIR
May 2025
Table 5.7-2: Project Operation Greenhouse Emissions
Emission Source Emissions (MT/yr)
CO2 CH4 N2O Refrigerants Total CO2e
Annual construction-related emissions
amortized over 30 years 25.77 1.00E-03 0.00 0.00 25.93
Mobile Source 1,546.00 0.07 0.06 2.15 1,568.00
Area Source 1.61 < 0.005 < 0.005 0.00 1.62
Energy Source 2,161.41 0.20 0.02 0.00 2,172.03
Water Usage Source 19.20 < 0.005 < 0.005 0.00 19.30
Waste Source 13.50 1.35 0.00 0.00 47.20
Refrigeration Source 0.00 0.00 0.00 0.01 0.01
Sequestration -0.45 0.00 0.00 0.00 -0.45
Project CO2e (All Sources) 3,833.64
Holes to Remain1 439.00
Total CO2e (All Sources) 4,272.64
Existing -1,839.59
Net Emissions (Proposed – Existing) 2,433.05
CO2 = carbon dioxide, CH4 = methane, N2O = nitrous oxide, CO2e = carbon dioxide equivalent, MT/yr = metric tons per year
Source: Appendix J
1Per the Trip Generation Assessment for proposed Project included as Table 5.14-2, the Project would retain 15 holes of the
existing 18-hole Newport Beach Golf Course.
IMPACT GHG-2: THE PROJECT WOULD NOT CONFLICT WITH AN APPLICABLE PLAN, POLICY OR
REGULATION ADOPTED FOR THE PURPOSE OF REDUCING THE EMISSIONS OF
GREENHOUSE GASES.
Less than Significant Impact.
The proposed Project consists of redevelopment of an existing commercial golf course recreation area with
a new and different commercial recreation use. The Project site is adjacent to arterial roadways that connect
to nearby freeways. The existing pedestrian and bicycle infrastructure, proposed bicycle racks, and site
location adjacent to an OCTA bus route would promote non-vehicular transportation to the site and reduce
the vehicle miles traveled and related GHG emissions. Providing a recreation development in such a location
is consistent with the intent of the AB 32 Scoping Plan and SB 375, which is focused on infill land use patterns
and improving transportation alternatives.
The proposed Project would be implemented pursuant to the CALGreen Building/Title 24 requirements and
would provide new land uses in a sustainable manner. The City’s administration of the Title 24 requirements
includes review of proposed energy conservation measures during the permitting process, which ensures that
all requirements are met. Typical Title 24 measures include insulation; use of energy-efficient heating,
ventilation, and air conditioning equipment; energy-efficient indoor and outdoor lighting systems;
reclamation of heat rejection from refrigeration equipment to generate hot water; and incorporation of
skylights, and solar infrastructure. In complying with the Title 24 standards, the proposed Project would be
implementing regulations that reduce GHG emissions. As detailed in Section 3.0, Project Description, the
proposed Project includes installation of solar panels on the proposed buildings and on canopies in the
parking lots. The Project would provide EV charging stations and EV parking.
The Project would also be consistent with the following existing regulatory requirements:
Snug Harbor Surf Park Project 5.7 Greenhouse Gas Emissions
City of Newport Beach 5.7-14
Draft EIR
May 2025
• Pavley emissions standard and Low Carbon Fuel Standard: Pavley emissions standards (AB 1493)
apply to all new passenger vehicles starting with model year 2009, and the Low Carbon Fuel Standard
became effective in 2010 and regulates the transportation fuel used. The second phase of
implementation of the Pavley regulations per AB 1493 is referred to as the Advanced Clean Car
program, which combines the control of smog-causing pollutants and GHG emissions into a single
coordinated package of requirements for model years 2017 through 2025. The regulation reduces
GHGs from new cars by 34 percent from 2016 levels by 2025. The Project would be consistent with
these requirements as they apply to all new passenger vehicles and vehicle fuel purchased in California.
• Medium/Heavy-Duty Vehicle Regulations: Medium/heavy-duty vehicle regulations are implemented
by the State to reduce emissions from trucks. Since the proposed Project has a large truck component,
these regulations would aid in reducing GHG emissions from the Project. The Project is consistent with this
measure and its implementation as medium and heavy-duty vehicles associated with construction of the
Project would be required to comply with the requirements of this regulation.
• Tractor-Trailer Greenhouse Gas Regulation: Tractor-trailers subject to this State regulation are
primarily 53-foot or longer box-type trailers, are required to be either use USEPA SmartWay certified
tractors and trailers or retrofit their existing fleet with SmartWay verified technologies. The Project is
consistent with this regulation, as it applies to specific trucks that are used throughout the State.
• Renewable Portfolio Standard: As a customer of Southern California Edison, the Project would purchase
from an increasing supply of renewable energy sources and more efficient baseload generations, reduce
GHG emissions, and be consistent with this requirement.
• Million Solar Roofs Program: The Project is consistent with this scoping plan measure as the Project
would provide solar panels on building roofs and on canopies in the parking lots.
• Water Efficiency and Waste Diversion: Development and operation of the Project would be
implemented in consistency with water conservation requirements (as included in Title 24) and solid waste
recycling and landfill diversion requirements of the State.
AB 32 & SB 32
The Project is consistent with AB 32 and SB 32 through implementation of measures that address GHG
emissions related to building energy, solid waste management, wastewater, and water conveyance. The
proposed Project would not interfere with the State’s implementation of Executive Order B-30-15 and SB
32’s target of reducing statewide GHG emissions to 40 percent below 1990 levels by 2030; Executive
Order S-3-05’s target of reducing statewide GHG emissions to 80 percent below 1990 levels by 2050; or
AB 1279’s target of achieving carbon neutrality by 2045 because it would not result in a substantial increase
in GHG emissions and would not exceed thresholds. Therefore, a conflict with AB 32 and SB 32 would not
occur.
CARB Scoping Plan
As detailed in Section 5.7.2, Regulatory Setting, the CARB Scoping Plan recommends actions for achieving
carbon neutrality through reduced GHG emissions levels. The proposed Project would include energy-
efficient/energy-conserving design features and would not interfere with the State’s implementation of AB
1279’s target of 85 percent below 1990 levels and carbon neutrality by 2045 because it is consistent with
the GHG reductions listed in CARB’s most recent Scoping Plan (2022) and would not exceed GHG thresholds.
Therefore, a conflict with the CARB Scoping Plan would not occur. As demonstrated in Table 5.7-3, the Project
is consistent with the CARB 2022 Scoping Plan Actions.
Snug Harbor Surf Park Project 5.7 Greenhouse Gas Emissions
City of Newport Beach 5.7-15
Draft EIR
May 2025
Table 5.7-3: Project Consistency with the CARB 2022 Scoping Plan Actions
Action Consistency
GHG Emissions Reductions Relative to the SB 32 Target
40 percent below 1990 levels by 2030. Consistent. Development pursuant to the proposed
Project would comply with the Title 24, Part 6, building
energy requirements along with other local and State
initiatives that aim to achieve the 40 percent below 1990
levels by 2030 goal. This would be ensured through the
City’s existing development permitting process. As
detailed previously, implementation of the Project would
result in GHG emissions from energy and mobile needs
that would not exceed thresholds and impacts would be
less than significant.
Smart Growth/Vehicle Miles Traveled VMT
VMT per capita reduced 25 percent below 2019 levels
by 2030, and 30 percent below 2019 levels by 2045.
Consistent. As discussed in Section 5.14, Transportation,
the proposed Project would result in redevelopment of a
commercial recreation area that is located near existing
arterial roadways, bike lanes, sidewalks, and bus stops,
which meet smart growth and reduced VMT criteria. In
addition, the Project would meet the City’s VMT screening
criteria and would result in a less than significant impact
related to VMT.
Light-Duty Vehicle (LDV) Zero-Emission Vehicles (ZEVs)
100 percent of LDV sales are ZEV by 2035. Consistent. Development Projects would be designed and
constructed in accordance with the Title 24 Part 6 and Part
11 requirements, which includes EV parking and EV
charging stations in the parking lot.
Truck ZEVs
100 percent of medium-duty (MDV)/HDC sales are ZEV
by 2040 (AB 74 University of California Institute of
Transportation Studies [ITS] report).
Consistent. The new development pursuant to the
proposed Project would be designed and constructed in
accordance with the most updated Title 24 regulations
and would implement an EV charging station in the
parking lot. The Project does not involve regular truck
transportation for operation and does not involve truck
ZEVs.
Aviation
20 percent of aviation fuel demand is met by electricity
(batteries) or hydrogen (fuel cells) in 2045. Sustainable
aviation fuel meets most or the rest of the aviation fuel
demand that has not already transitioned to hydrogen
or batteries.
Not Applicable. Development and operation of the
proposed Project would not utilize aviation fuel.
Ocean-going Vessels (OGV)
2020 OGV At-Berth regulation fully implemented, with
most OGVs utilizing shore power by 2027.
25 percent of OGVs utilize hydrogen fuel cell electric
technology by 2045.
Not Applicable. Development and operation of the
proposed Project would not utilize any OGVs.
Port Operations
100 percent of cargo handling equipment is zero-
emission by 2037. 100 percent of drayage trucks are
zero emission by 2035.
Not Applicable. Development and operation of the
proposed Project would not impact any operations at any
ports.
Snug Harbor Surf Park Project 5.7 Greenhouse Gas Emissions
City of Newport Beach 5.7-16
Draft EIR
May 2025
Action Consistency
Freight and Passenger Rail
100 percent of passenger and other locomotive sales
are ZEV by 2030. 100 percent of line haul locomotive
sales are ZEV by 2035. Line haul and passenger rail
rely primarily on hydrogen fuel cell technology, and
others primarily utilize electricity.
Not Applicable. Development and operation of the
proposed Project would not involve any rail operations.
Oil and Gas Extraction
Reduce oil and gas extraction operations in line with
petroleum demand by 2045.
Not Applicable. The proposed Project would not involve
any oil or gas extraction.
Petroleum Refining
CCS on majority of operations by 2030, beginning in
2028. Production reduced in line with petroleum
demand.
Not Applicable. The proposed Project would not involve
any petroleum refining.
Electricity Generation
Sector GHG target of 38 million metric tons of carbon
dioxide equivalent (MTCO2e) in 2030 and 30 MTCO2e
in 2035. Retail sales load coverage of 20 gigawatts
(GW) of offshore wind by 2045. Meet increased
demand for electrification without new fossil gas-fired
resources.
Consistent. The proposed Project would comply with the
Title 24, Part 6 building requirements, including related to
renewable energy generation requirements as well as
improved insulation reducing energy consumption. The
Project includes installation of solar panels on buildings
and on canopies in the parking lots. In addition, the Project
includes EV charging station in the parking lot.
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 proposed Project would comply with the
Title 24, Part 6 building energy requirements.
Existing Residential Buildings
80 percent of appliance sales are electric by 2030 and
100 percent of appliance sales are electric by 2035.
Appliances are replaced at end of life such that by
2030 there are 3 million all-electric and electric-ready
homes—and by 2035, 7 million homes—as well as
contributing to 6 million heat pumps installed statewide
by 2030.
Consistent. The proposed Project does not involve the
operation of any existing residential buildings. However,
appliances within Project buildings would comply with the
Title 24, Part 6 building energy requirements.
Existing Commercial Buildings
80 percent of appliance sales are electric by 2030,
and 100 percent of appliance sales are electric by
2045. Appliances are replaced at end of life,
contributing to 6 million heat pumps installed statewide
by 2030.
Consistent. The proposed Project does not involve the
continued operations of existing commercial buildings.
However, appliances within Project buildings would
comply with the Title 24, Part 6 building energy
requirements and would utilize energy efficient
appliances.
Energy Demand
7.5 percent of energy demand electrified directly
and/or indirectly by 2030; 75 percent by 2045.
Consistent. The proposed Project would comply with the
Title 24, Part 6 building energy requirements, including
renewable energy generation requirements from onsite
solar, as well as improved insulation reducing energy
consumption.
Construction Equipment
25 percent of energy demand electrified by 2030 and
75 percent electrified by 2045.
Consistent. Through City permitting, the proposed Project
would be required to use construction equipment that is
registered by CARB and meet CARB’s standards. CARB
Snug Harbor Surf Park Project 5.7 Greenhouse Gas Emissions
City of Newport Beach 5.7-17
Draft EIR
May 2025
Action Consistency
sets its standards to be in line with the goal of reducing
energy demand by 25 percent in 2030 and 75 percent
in 2045.
Energy Generation
Electrify 0 percent of boilers by 2030 and 100 percent
of boilers by 2045. Hydrogen for 25 percent of process
heat by 2035 and 100 percent by 2045. Electrify 100
percent of other energy demand by 2045.
Consistent. The proposed Project would comply with the
Title 24, Part 6 building energy requirements, including
installing electrical wiring for all built in appliances,
electric outlets for landscape equipment, solar panels, and
provision of electric charging stations.
Stone, Clay, Glass, and Cement
CCS on 40 percent of operations by 2035 and on all
facilities by 2045. Process emissions reduced through
alternative materials and CCS.
Not Applicable. Uses proposed do not involve
manufacturing or storage of stone, clay, glass, or cement.
Other Industrial Manufacturing
0 percent energy demand electrified by 2030 and 50
percent by 2045.
Not Applicable. The proposed Project would comply with
the Title 24, Part 6, including increases in renewable
energy generation requirements as well as improved
insulation reducing energy consumption.
Combined Heat and Power
Facilities retire by 2040. Not Applicable. The proposed Project does not involve
any existing combined heat and power facilities.
25 percent energy demand electrified by 2030 and 75
percent by 2045.
Not Applicable. The proposed Project does not involve
generation of energy; but Project buildings would comply
with the Title 24 renewable energy generation
requirements, including installation of solar on buildings
and parking lot canopies.
Low Carbon Fuels for Transportation
Biomass supply is used to produce conventional and
advanced biofuels, as well as hydrogen.
Not Applicable. The proposed Project does not involve
any production of biofuels.
Low Carbon Fuels for Buildings and Industry
In 2030s, biomethane135 blended in pipeline
Renewable hydrogen blended in fossil gas pipeline at
7 percent energy (~20 percent by volume), ramping up
between 2030 and 2040. In 2030s, dedicated
hydrogen pipelines constructed to serve certain
industrial clusters
Not Applicable. The proposed Project does not involve
any production of fuels for buildings and industry.
Non-combustion Methane Emissions
Increase landfill and dairy digester methane capture.
Some alternative manure management deployed for
smaller dairies.
Moderate adoption of enteric strategies by 2030.
Divert 75 percent of organic waste from landfills by
2025.
Oil and gas fugitive methane emissions reduced 50
percent by 2030 and further reductions as
infrastructure components retire in line with reduced
fossil gas demand.
Not Applicable. The proposed Project does not involve
any landfill and/or dairy uses.
Snug Harbor Surf Park Project 5.7 Greenhouse Gas Emissions
City of Newport Beach 5.7-18
Draft EIR
May 2025
Action Consistency
High Global Warming Potential (GWP) Potential Emissions
Low GWP refrigerants introduced as building
electrification increases, mitigating HFC emissions.
Consistent. The new development pursuant to the
proposed Project would comply with the Title 24, Part 6,
building energy requirements, including use of low GWP
refrigerants, which would be verified through the City’s
existing development permitting process.
Overall, the proposed Project would not interfere with the State’s implementation of Executive Order B-30-
15 and SB 32’s target of reducing statewide GHG emissions to 40 percent below 1990 levels by 2030;
Executive Order S-3-05’s target of reducing statewide GHG emissions to 80 percent below 1990 levels by
2050; AB 1279’s target of achieving carbon neutrality by 2045, or CARB’s 2022 Scoping Plan because it
does not interfere with implementation of the GHG reduction measures as the Project results in a less than
significant impact that does not exceed thresholds.
City of Newport Beach General Plan
As listed previously in Section 5.7.2.3, Local and Regional Regulations, the General Plan includes various
policies in the Circulation Element and the Natural Resources Element that are related to reduction of GHG
emissions. The proposed Project consistency with these policies (along with other General Plan policies related
to avoiding or mitigating environmental impacts) is evaluated in Table 5.10-4, General Plan Policy Consistency
Analysis, in Section 5.10, Land Use and Planning, which determined that the Project would be consistent with
the policies of the General Plan related to GHG reductions, which include provision of EV charging stations,
walkable environment, energy efficient design measures, and implementation of green building measures.
Thus, the proposed Project would not conflict with an applicable General Plan policy adopted for the
purpose of reducing GHGs.
City of Newport Beach Energy Action Plan
The City’s Energy Action Plan is not directly applicable to the proposed Project because the goals and
policies in the plan are focused on energy efficiency and sustainability of City facilities. However, because
the Project is required to comply CALGreen and Title 24 standards, the Project would not conflict with the
community-wide energy use goals of the Energy Action Plan.
5.7.7 CUMULATIVE IMPACTS
GHG emissions impacts are assessed in a cumulative context since no single project can cause a discernible
change to climate. Climate change impacts are the result of incremental contributions from natural processes,
and past and present human-related activities. Therefore, the area in which a proposed project in
combination with other past, present, or future projects, could contribute to a significant cumulative climate
change impact would not be defined by a geographical boundary such as a project site or combination of
sites, city or air basin. GHG emissions have high atmospheric lifetimes and can travel across the globe over
a period of 50 to 100 years or more. Even though the emissions of GHGs cannot be defined by a geographic
boundary and are effectively part of the global issue of climate change, CEQA places a boundary for the
analysis of impacts at the state’s borders. Thus, the geographic area for analysis of cumulative GHG
emissions impacts is the State of California.
Executive Order S-3-05, Executive Order B-30-15, AB 32, and SB 32 recognizes that California is the source
of substantial amounts of GHG emissions and recognizes the significance of the cumulative impact of GHG
emissions from sources throughout the state and sets performance standards for reduction of GHGs.
Snug Harbor Surf Park Project 5.7 Greenhouse Gas Emissions
City of Newport Beach 5.7-19
Draft EIR
May 2025
The analysis of GHG emission impacts under CEQA contained in this Draft EIR effectively constitutes an
analysis of the Project’s contribution to the cumulative impact of GHG emissions. As described previously, the
City’s evaluation of impacts using the SCAQMD’s 3,000 MTCO2e/year threshold. As shown in Table 5.7-2,
the estimated GHG emissions from development and operation of the Project would not exceed the
SCAQMD’s threshold and includes sustainable features such as solar panels on the proposed buildings and
canopies in the parking lot, included as PDF-1 Solar. The Project would not generate GHG emissions that
would be cumulatively considerable. Therefore, cumulative impacts related to GHG emissions would be less
than significant.
5.7.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES
The following would reduce potential impacts related to GHGs.
Existing Regulations
• Clean Car Standards – Pavley Assembly Bill 1493
• California Executive Order S-3-05
• Assembly Bill 32 (Global Warming Solutions Act of 2006)
• Senate Bill 375
• California Executive Order B-30-15
• Senate Bill 32
• California Green Building Standards Code (Code of Regulations, Title 24 Part 6)
• Assembly Bill 1279
• California Energy Code (Code of Regulations, Title 24 Part 6)
• California Green Building Standards Code (CALGreen; Code of Regulations, Title 24 Part 11)
• Municipal Code Section 15.11.010, Adoption of the California Green Building Standards Code
• Municipal Code Section 15.17.010, Adoption of the California Energy Code
• Municipal Code Section 15.18.040, Solar Energy Requirements
• Municipal Code Section Chapter 15.19, Electric Vehicle Charging Stations
Plans, Programs, or Policies
None.
5.7.9 PROJECT DESIGN FEATURES
The proposed Project includes the following PDF that reduces potential impacts related to GHGs:
PDF-1 Solar: The proposed Project includes installation of solar panels on the roofs of the buildings and on
14 to 18-foot-high solar canopies in portions of the parking areas to provide onsite renewable energy to
provide power to the proposed Project.
5.7.10 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Impact GHG-1 and GHG-2 would be less than significant.
Snug Harbor Surf Park Project 5.7 Greenhouse Gas Emissions
City of Newport Beach 5.7-20
Draft EIR
May 2025
5.7.11 MITIGATION MEASURES
No mitigation measures are required.
5.7.12 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts would be less than significant.
5.7.13 REFERENCES
City of Newport Beach. (2001, January). Santa Ana Heights Specific Plan. Retrieved September 23, 2024,
from ocpublicworks.com.
City of Newport Beach. (2006a, July). General Plan. Retrieved September 23, 2024, from
newportbeachca.gov: https://www.newportbeachca.gov/government/departments/community-
development/planning-division/general-plan-codes-and-regulations/general-plan
City of Newport Beach. (2006b, July). General Plan Environmental Impact Report. Retrieved September 23,
2024, from newportbeachca.gov:
https://www.newportbeachca.gov/government/departments/community-development/planning-
division/general-plan-codes-and-regulations/general-plan/general-plan-environmental-impact-
repor
City of Newport Beach. (2013). City of Newport Beach Energy Action Plan. Retrieved March 12, 2025,
from
https://www.newportbeachca.gov/home/showpublisheddocument/16576/6356824932021000
00
City of Newport Beach. (2024, May). Newport Beach Municipal Code. Retrieved September 23, 2024,
from codepublishing.com: https://www.codepublishing.com/CA/NewportBeach/
Urban Crossroads. (2025). Surf Farm Greenhouse Gas Analysis. (Appendix J)
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-1
Draft EIR
May 2025
5.8 Hazards and Hazardous Materials
5.8.1 INTRODUCTION
This section considers the nature and range of foreseeable hazardous materials and physical hazards
impacts that would result from implementation of the proposed Project. It identifies the ways that hazardous
materials and other types of hazards could expose people and the environment to various health and safety
risks during construction activities and operation of proposed Project.
This section describes routine hazardous materials that are likely to be used, handled, or processed within
the Project area, and the potential for upset and accident conditions in which hazardous materials could be
released. The impact analysis identifies ways in which hazardous materials might be routinely used, stored,
handled, processed, or transported, and evaluates the extent to which existing and future populations could
be exposed to hazardous materials. Additionally, the section evaluates potential hazards related to
operation of airport facilities in the Project vicinity.
The term “hazardous material” is defined as any material that, because of quantity, concentration, or
physical or chemical characteristics, poses a significant present or potential hazard to human health and
safety or to the environment if released into the workplace or the environment.1
The analysis in this section is based, in part, on the following documents and resources.
• City of Newport Beach General Plan, 2006
• City of Newport Beach General Plan Environmental Impact Report (General Plan EIR), 2006
• City of Newport Beach Municipal Code
• Phase I Environmental Site Assessment, prepared by Orion Environmental Inc., 2024, included as
Appendix K
• Phase II Environmental Site Assessment, prepared by Orion Environmental Inc., 2024, included as
Appendix L
• Aircraft Hazard and Land Use Risk Assessment & Wildlife Hazard Management Analysis, prepared by
Johnson Aviation, Inc., 2024, included as Appendix M
• Solar Glare Analysis, prepared by Johnson Aviation, Inc., 2024, included as Appendix N
5.8.2 REGULATORY SETTING
5.8.2.1 Federal Regulations
Resource Conservation and Recovery Act of 1976
Federal hazardous waste regulations are generally promulgated under the Resource Conservation and
Recovery Act (RCRA). Pursuant to the RCRA, the United States Environmental Protection Agency (USEPA)
regulates the generation, transportation, treatment, storage, and disposal of hazardous waste in a “cradle
to grave” manner. The RCRA was designed to protect human health and the environment, reduce/eliminate
the generation of hazardous waste, and conserve energy and natural resources. The USEPA has largely
1State of California, Health and Safety Code, Chapter 6.95, Section 25501(o).
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-2
Draft EIR
May 2025
delegated responsibility for implementing the RCRA program in California to the State, which implements
this program through the California Hazardous Waste Control Law.
The RCRA regulates landfill siting, design, operation, and closure (including identifying liner and capping
requirements) for licensed landfills. In California, the RCRA landfill requirements are delegated to the
California Department of Resources Recycling and Recovery (CalRecycle), which is discussed in detail below.
The RCRA allows the USEPA to oversee the closure and post-closure of landfills. Additionally, the federal
Safe Drinking Water Act, 40 CFR Part 141, gives the EPA the power to establish water quality standards
and beneficial uses for waters from below- or above-ground sources of contamination. For the Project area,
water quality standards are administered by the Regional Water Quality Control Board (RWQCB).
The RCRA also allows the USEPA to control risk to human health at contaminated sites. Vapor intrusion presents
a significant risk to human populations overlying contaminated soil and groundwater and is considered when
conducting human health risk assessments and developing Remedial Action Objectives.
Occupational Safety and Health Act of 1970
Federal and state occupational health and safety regulations also contain provisions regarding hazardous
waste management through the Occupational Safety and Health Act of 1970 (amended), which is
implemented by the United States Department of Labor Occupational Safety and Health Administration
(OSHA). Title 29 of the Code of Federal Regulations (29 CFR) requires special training of handlers of
hazardous materials; notification to employees who work in the vicinity of hazardous materials; acquisition
from the manufacturer of material safety data sheets, which describe the proper use of hazardous materials;
and training of employees to remediate any hazardous material accidental releases. OSHA regulates the
administration of 29 CFR.
OSHA also establishes standards regarding safe exposure limits for chemicals to which construction workers
may be exposed. Safety and Health Regulations for Construction (29 CFR Part 1926.65 Appendix C)
contains requirements for construction activities, which include occupational health and environmental controls
to protect worker health and safety. The guidelines describe the health and safety plan(s) that must be
developed and implemented during construction, including associated training, protective equipment,
evacuation plans, chains of command, and emergency response procedures.
Adherence to applicable hazard-specific OSHA standards is required to maintain worker safety. For
example, methane is regulated by OSHA under 29 CFR Part 1910.146 with regard to worker exposure to
a “hazardous atmosphere” within confined spaces where the presence of flammable gas vapor or mist is in
excess of 10 percent of the lower explosive limit. Title 49 of the CFR governs the manufacture of packaging
and transport containers, packing and repacking, labeling, and the marking of hazardous material transport.
Title 42, Part 82 governs solid waste disposal and resource recovery.
Hazardous Materials Transportation Act
The transportation of hazardous materials is regulated by the Hazardous Materials Transportation Act, which
is administered by the Research and Special Programs Administration of the United States Department of
Transportation (USDOT). The Hazardous Materials Transportation Act provides the USDOT with a broad
mandate to regulate the transport of hazardous materials, with the purpose of adequately protecting the
nation against risk to life and property, which is inherent in the commercial transportation of hazardous
materials. The USDOT has regulations that govern the transportation of hazardous materials are applicable
to any person who transports, ships, causes to be transported or shipped, or are involved in any way with
the manufacture or testing of hazardous materials packaging or containers. The USDOT regulations
pertaining to the actual movement govern every aspect of the movement, including packaging, handling,
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-3
Draft EIR
May 2025
labeling, marking, placarding, operational standards, and highway routing. Additionally, the USDOT is
responsible for developing curriculum to train for emergency response and administers grants to states and
Indian tribes for ensuring the proper training of emergency responders. Hazardous Materials Transportation
Act was enacted in 1975 and was amended and reauthorized in 1990, 1994, and 2005.
Federal Regulation 49 Code of Federal Regulation Part 77
The Federal Aviation Agency (FAA) is the federal agency that identifies potential impacts related to air
traffic and related safety hazards. The Federal Regulation 49 Code of Federal Regulation (CFR) Part 77
establishes standards and notification requirements for objects affecting navigable airspace. This notification
serves as the basis for:
• Evaluating the effect of the proposed construction or alteration on operating procedures,
• Determining the potential hazardous effect of the proposed construction on air navigation,
• Identifying mitigating measures to enhance safe air navigation, and
• Charting of new objects.
FAA Federal Aviation Regulations (FAR) Part 77 includes the establishment of imaginary surfaces (airspace
that provides clearance of obstacles for runway operation) that allows the FAA to identify potential
aeronautical hazards in advance, thus preventing or minimizing adverse impacts to the safe and efficient
use of navigable airspace. The regulations identify three-dimensional imaginary surfaces through which no
object should penetrate. The imaginary surface for SNA consists of a 100:1 slope extending outward for
20,000 feet from the nearest runway. Section 77.17 (Obstruction Standards) also states that an object would
be an obstruction to air navigation if it is higher than 200 feet above ground level. Exceedance of 200 feet
above ground level or the 100:1 imaginary surface requires notification to FAA (per FAR Part 77). An object
that would be constructed or altered within the height restriction or imaginary surface area of the airport is
not necessarily incompatible (ALUP 2008) but would be subject to FAA notification and an FAA aeronautical
study to determine whether the proposed structures would constitute a hazard to air navigation.
5.8.2.2 State Regulations
Hazardous Materials Management and Waste Handling
In the regulation of hazardous waste management, California law often mirrors or is more stringent than
federal law. The California Environmental Protection Agency (CalEPA) and California Occupational Safety
and Health Administration (CalOSHA) are the primary State agencies responsible for hazardous materials
management. Additionally, the California Emergency Management Agency administers the California
Accidental Release Prevention program. The California Department of Toxic Substances Control (DTSC),
which is a branch of CalEPA, regulates the generation, transportation, treatment, storage, and disposal
hazardous waste, as well as the investigation and remediation of hazardous waste sites. The California DTSC
program incorporates the provisions of both federal (RCRA) and State hazardous waste laws. The California
Department of Pesticide Regulation, which is a branch of CalEPA, regulates the sale, use, and cleanup of
pesticides (CCR, Title 3).
Excavated soil containing hazardous substances and hazardous building materials would be classified as a
hazardous waste if they exhibit the characteristics of ignitability, corrosivity, reactivity, or toxicity (CCR, Title
22, Division 4.5, Chapter 11, Article 3). State and federal laws require detailed planning to ensure that
hazardous materials are properly handled, used, stored, and disposed of, and in the event that such
materials are accidentally released, to prevent or to mitigate injury to health or the environment. These laws
and regulations are overseen by a variety of State and local agencies. The California Integrated Waste
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-4
Draft EIR
May 2025
Management Board and the RWQCB specifically address management of hazardous materials and waste
handling in their adopted regulations (CCR, Title 14 and CCR, Title 27).
The primary local agency with responsibility for implementing federal and State laws and regulations
pertaining to hazardous materials management within a region is known as the Certified Unified Program
Agency (CUPA). The Unified Program is the consolidation of six State environmental regulatory programs
into one program under the authority of a CUPA, which is a local agency that has been certified by CalEPA
to implement the Unified Program within the local agency's jurisdiction. This program was established under
the amendments to the California Health and Safety Code made by SB 1082 in 1994. The six consolidated
programs are:
• Hazardous Materials Release Response Plan and Inventory (Business Plans)
• California Accidental Release Prevention
• Hazardous Waste (including Tiered Permitting)
• Underground Storage Tanks
• Above Ground Storage Tanks (Spill Prevention Control and Countermeasures requirements)
• Uniform Fire Code (UFC) Article 80 Hazardous Material Management Program and Hazardous Material
Identification System
The Certified Unified Program Agency for the Project area is the Orange County Environmental Health
Division.
Hazardous Waste Control Act
The Hazardous Waste Control Act was passed in 1972 and established the California Hazardous Waste
Control Program within the Department of Health Services. California’s hazardous waste regulatory effort
became the model for the federal RCRA. California’s program, however, was broader and more
comprehensive than the federal system, regulating wastes and activities not covered by the federal program.
California’s Hazardous Waste Control Law was followed by emergency regulations in 1973 that clarified
and defined the hazardous waste program, as follows:
• Included definitions of what was a waste and what was hazardous as well as what was necessary for
appropriate handling, processing, and disposal of hazardous and extremely hazardous waste in a
manner that would protect the public, livestock, and wildlife from hazards to health and safety.
• The early regulations also established a tracking system for the handling and transportation of
hazardous waste from the point of waste generation to the point of ultimate disposition, as well as a
system of fees to cover the costs of operating the hazardous waste management program.
• Advancing the newly developing awareness of hazardous waste management issues, the program
established a technical reference center for public and private use dealing with all aspects of hazardous
waste management.
California Government Code Section 65962.5
Government Code Section 65962.5 (commonly referred to as the Cortese List) includes DTSC-listed
hazardous waste facilities and sites, Department of Health Services lists of contaminated drinking water
wells, sites listed by the State Water Resources Control Board as having underground storage tank leaks
and which have had a discharge of hazardous wastes or materials into the water or groundwater, and lists
from local regulatory agencies of sites that have had a known migration of hazardous waste/material.
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-5
Draft EIR
May 2025
California Code of Regulations (CCR), Title 22 - Hazardous Waste Control Law, Chapter 6.5
The DTSC regulates the generation, transportation, treatment, storage, and disposal of hazardous waste
under the RCRA and the California Hazardous Waste Control Law. Both laws impose “cradle-to-grave”
regulatory systems for handling hazardous waste in a manner that protects human health and the
environment. CalEPA has delegated some of its authority under the Hazardous Waste Control Law to county
health departments and other Certified Unified Program Agencies.
CCR, Title 23, Chapter 16 – Underground Storage Tanks
Title 23, Chapter 16 of the CCR establishes construction requirements for new underground storage tanks;
establishes separate monitoring requirements for new and existing underground storage tanks; establishes
uniform requirements for unauthorized release reporting and for repair, upgrade, and closure of
underground storage tanks; and specifies variance request procedures.
CCR, Title 27 – Solid Waste
Title 27 of the CCR contains a waste classification system that applies to solid wastes that cannot be
discharged directly or indirectly to waters of the State and which therefore must be discharged to waste
management sites for treatment, storage, or disposal. CalRecycle and its certified Local Enforcement Agency
regulate the operation, inspection, permitting, and oversight of maintenance activities at active and closed
solid waste management sites and operations.
California Human Health Screening Levels
The California Human Health Screening Levels (CHHSLs or “Chisels”) are concentrations of 54 hazardous
chemicals in soil or soil gas that CalEPA considers to be below thresholds of concern for risks to human health.
The CHHSLs were developed by the Office of Environmental Health Hazard Assessment on behalf of CalEPA.
The CHHSLs were developed using standard exposure assumptions and chemical toxicity values published
by the EPA and CalEPA. The CHHSLs can be used to screen sites for potential human health concerns where
releases of hazardous chemicals to soils have occurred. Under most circumstances, the presence of a chemical
in soil, soil gas, or indoor air at concentrations below the corresponding CHHSL can be assumed to not pose
a significant health risk to people who may live or work at the site. There are separate CHHSLs for residential
and commercial/industrial sites.
CCR, Title 8 – Occupational Safety
CalOSHA administers federal occupational safety requirements and additional State requirements in
accordance with CCR, Title 8. CalOSHA requires preparation of an Injury and Illness Prevention Program
(IIPP), which is an employee safety program of inspections, procedures to correct unsafe conditions, employee
training, and occupational safety communication. This program is administered via inspections by the local
CalOSHA enforcement unit.
CalOSHA regulates lead exposure during construction activities under CCR Title 8, Section 1532.1, Lead,
which establishes the rules and procedures for conducting demolition and construction activities such that
worker exposure to lead contamination is minimized or avoided.
Compliance with CalOSHA regulations and associated programs would be required for the Project due to
the potential hazards posed by onsite construction activities and contamination from former uses.
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-6
Draft EIR
May 2025
Emergency Response to Hazardous Materials Incidents
California has developed an emergency response plan to coordinate emergency services provided by
federal, State, and local government, and private agencies. The plan is administered by the California
Emergency Management Agency and includes response to hazardous materials incidents. The California
Emergency Management Agency coordinates the response of other agencies, including CalEPA, the
California Highway Patrol, the California Department of Fish and Wildlife, the Regional Water Quality
Control Board, the South Coast Air Quality Management District, and the City of Newport Beach Fire
Department.
California Emergency Services Act
The California Emergency Services Act (Government Code Section 8550 et seq.) was adopted to establish
the State’s roles and responsibilities during human-made or natural emergencies that result in conditions of
disaster and/or extreme peril to life, property, or the resources of the State. This act is intended to protect
health and safety by preserving the lives and property of the people of the State.
California Public Utilities Code, Section 21676, Airport Land Use Commission
Prior to the amendment of a general plan or specific plan, or the adoption or approval of a zoning ordinance
or building regulation within the planning boundary established by the Airport Land Use Commission (ALUC),
the local agency first refers the proposed action to the ALUC. If the ALUC determines that the proposed
action is inconsistent with the Airport Land Use Plan, the referring agency is notified. The local agency may,
after a public hearing, propose to overrule the ALUC by a two-thirds vote of its governing body if it makes
specific findings that the proposed action is consistent with the purposes of this article, which are to protect
public health, safety, and welfare by ensuring the orderly expansion of airports and the adoption of land
use measures that minimize the public's exposure to excessive noise and safety hazards within areas around
public airports to the extent that these areas are not already devoted to incompatible uses.
At least 45 days prior to the decision to overrule the ALUC, the local agency governing body must provide
the ALUC a copy of the proposed decision and findings. The ALUC may provide comments to the local agency
governing body within 30 days of receiving the proposed decision and findings. If the ALUC’s comments are
not available within this time limit, the local agency governing body may act without them. The comments by
the ALUC are advisory to the local agency governing body. The local agency governing body shall include
comments from the ALUC in the public record of any final decision to overrule the ALUC, which may only be
adopted by a two-thirds vote of the governing body.
5.8.2.3 Regional Regulations
South Coast Air Quality Management District Rule 1403
SCAQMD Rule 1403 governs the demolition of buildings containing asbestos materials. Rule 1403 specifies
work practices to minimize asbestos emissions during building demolition and renovation activities, including
the removal and associated disturbance of asbestos containing materials. The requirements for demolition
and renovation activities include asbestos surveying, notification, asbestos containing materials removal
procedures and time schedules, handling and cleanup procedures, storage, and disposal requirements for
asbestos containing waste materials.
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-7
Draft EIR
May 2025
Airport Environs Land Use Plan for John Wayne Airport
John Wayne Airport (SNA) is within the oversight of the Orange County ALUC. The ALUC is required to
prepare and adopt an airport land use plan for each of the airports within its jurisdiction. The ALUC
prepared the Airport Environs Land Use Plan (AELUP) for SNA (amended April 17, 2008). The AELUP intends
“to safeguard the general welfare of the inhabitants within the vicinity of the airport and to ensure the
continued operation of the airport. Specifically, the plan seeks to protect the public from the adverse effects
of aircraft noise, to ensure that people and facilities are not concentrated in areas susceptible to aircraft
accidents, and to ensure that no structures or activities adversely affect navigable airspace.”
Land uses within the AELUP planning area boundaries are required to conform to safety, noise, and height
restrictions. Public Utilities Code Section 21675(c) requires that area surrounding any airport which affects,
or is affected by, aircraft operations be embraced by the boundaries of its compatibility plan (i.e., AELUP).
The planning area sets limits of the area within which proposed land use projects are to be referred to the
ALUC for review. Planning area boundaries are determined by the location and configuration of the airport
included in the plan, and the extent of the noise and safety impacts associated with that airport, with certain
exceptions. The overall planning area is the furthest extent of the 60 CNEL contour, the FAR Part 77
Notification Imaginary Surface area, and the runway safety zones associated with the airport. In most
instances, the airport influence area is designated by the ALUC as its planning area boundary for the airport
and the two terms can be considered synonymous.
Pursuant to California Public Utilities Code Section 21676, local governments are required to submit all
general plans, specific plans, general plan amendments, and zone changes that occur in the ALUC planning
areas for consistency review by the ALUC. If such an amendment or change is deemed inconsistent with the
ALUC plan, a local government may override the ALUC decision by a two-thirds vote of its governing body,
if it makes specific findings that the proposed action is consistent with the purposes stated in Section
21670(a)(2) of the Public Utilities Code: “to protect public health, safety, and welfare by ensuring the
orderly expansion of airports and the adoption of land use measures that minimize the public’s exposure to
excessive noise and safety hazards in areas around public airports to the extent that these areas are not
already devoted to incompatible uses.”
Aircraft Noise Sources: The AELUP has identified land uses that are consistent with different levels of aircraft
noise, which are listed below.
• Residential land uses are consistent with aircraft noise at 60 dBA Community Noise Equivalent Level
(CNEL) or below and conditionally consistent at 65 dBA CNEL or below.
• Community facility land uses are consistent with aircraft noise at 65 dBA CNEL or below and normally
inconsistent with aircraft noise higher than 65 dBA CNEL.
• Commercial, retail, and office land uses are consistent with aircraft noise at 65 dBA CNEL or below and
conditionally consistent with aircraft noise higher than 65 dBA CNEL.
Safety Zones: The AELUP and the California Airport Land Use Planning Handbook identifies safety and
compatibility zones that depict which land uses are acceptable and unacceptable, which include Safety
Zones 1 through 6: Zone 1 that are described below.
• Safety Zone 1: Runway Protection Zone is defined as “a trapezoidal area off each end of a runway
used to enhance the protection of people and property on the ground. The innermost of the safety
zones.” Aircraft in this area are on very close final approach or departure and are less than 200 feet
above the runway.
• Safety Zone 2: Inner Approach/Departure Zone would extend beyond the Runway Protection Zone.
Aircraft in this area are overflying at low altitudes on final approach and straight-out departures and
are between 200 and 400 feet above the runway.
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-8
Draft EIR
May 2025
• Safety Zone 3: Inner Turning Zone “encompasses locations where aircraft are typically turning from the
base to final approach legs of the standard traffic pattern and are descending from traffic pattern
altitude.” The “zone also includes the area where departing aircraft normally complete the transition
from takeoff power and flap settings to a climb mode and have begun to turn to their en route heading.”
Aircraft in this area are less than 500 feet above the runway.
• Safety Zone 4: Outer Approach/Departure Zone is situated along the extended runway centerline
beyond Zone 3. Aircraft in this area are less than 1,000 feet above the runway.
• Safety Zone 5: Sideline Zone encompasses close-in areas lateral to runways. These areas are not
normally overflown. This area is on airport property. Limited to airport related uses.
• Safety Zone 6: includes all other portions of regular traffic patterns and pattern entry routes. Residential
uses are allowed. Aircraft in this area are between 1,000 to 1,500 feet above the runway.
Obstructions to Air Navigation: The ALUC has adopted the FAR Part 77 as the criteria for determining
height restrictions in Orange County. These regulations are the only definitive standard available and the
standard most generally used (AELUP 2008). The allowable height of structures surrounding an airport is
described in FAR Part 77 as the allowable height at which safe movement of aircraft occurs. The regulation
requires that notice be given to the FAA if there is a proposal to construct a structure that would exceed a
100:1 slope of an imaginary surface extending outward for 20,000 feet from the nearest runway at SNA.
Beyond the 100:1 imaginary surface, FAR Part 77 requires notification to FAA for any project that will be
more than 200 feet in height above the ground level.
According to the provisions set forth in FAR Part 77, an object is an “Obstruction to Air Navigation” if it is of
greater height than any imaginary surface established under the regulation. Imaginary surfaces exist
primarily to prevent existing or proposed manmade objects, objects of natural growth or terrain from
extending upward into navigable airspace.
There are five imaginary surfaces which the FAA applies to public use airports for the purpose of determining
obstructions to air navigation. These imaginary surfaces either slope out and up from all sides and ends of
runways or are a horizontal plane or a sloping plain above public use airports. As detailed by the California
Airport Land Use Planning Handbook, the imaginary surfaces include:
• Primary Surface: A surface longitudinally centered on a runway that extends 200 feet from each runway
end.
• Approach Surface: Longitudinally centered with the runway and extends beyond the primary surface
and extends outward and upward for a horizontal distance of 4,000 feet. Height limits for the surface
range from 150 feet above the airport elevation at the inner edge to 350 feet at the outer edge.
• Transitional Surface: A surface extending outward and upward at right angles to the runway centerline
and extends at a slope of 7:1 from the edge of the Primary and Approach Surfaces.
• Horizontal Surface: A horizontal plane 150 feet above the established airport elevation and
encompasses an area from the transitional surface to the conical surface.
• Conical Surface: A 20:1 sloped surface extending upward and outward beyond the horizontal surface
for a distance of 4,000 feet.
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-9
Draft EIR
May 2025
AELUP Policies: The following policies in the ALUC Airport Environs Land Use Plan are relevant to the
proposed Project:
Policy 3.2.1 Within the boundaries of the AELUP, any land use may be found to be inconsistent with the
AELUP which:
1. Places people so that they are affected adversely by aircraft noise,
2. Concentrates people in areas susceptible to aircraft accidents,
3. Permits structures of excessive height in areas which would affect adversely the
continued operation of the airport, or
4. Permits activities or facilities that would affect adversely aeronautical operations.
Policy 3.2.3 Noise Impact Zone "1" - High Noise Impact (65 dB CNEL and above). Noise impact in
this zone is sufficient to warrant restrictions on residential uses and to require sound
attenuation measures on other uses. The ALUC does not support residential development
within the 65 dB CNEL noise contour. All residential units are inconsistent in this area unless
it can be shown conclusively that such units are sufficiently sound attenuated for present and
projected noise exposures, which shall be the energy sum of all noise impacting the project,
so as not to exceed an interior standard of 45 dB CNEL, with an accompanying dedication
of an avigation easement for noise to the airport proprietor applicable to single family
residences, multi-family residences and mobile homes. Furthermore, all residential units are
to be sufficiently indoor oriented so as to preclude noise impingement on outdoor living
areas, as defined in Section 1.7.
Noise-sensitive institutional uses such as schools, churches, hospitals, libraries, and other noise-
sensitive uses may also be inconsistent in this zone. All noise-sensitive uses are inconsistent in
this area unless it can be shown conclusively that such units are sufficiently sound attenuated
for present and projected noise exposures, which shall be the energy sum of all noise
impacting the project, so as not to exceed an interior standard of 45 dB CNEL, and may
require the dedication of an avigation easement for noise to the airport proprietor.
Commercial, industrial, and recreational uses may be acceptable in this zone providing that
commercial and industrial structures are sufficiently sound attenuated to allow normal work
activities to be conducted. Said structures shall be sound attenuated against the combined
input of all present and projected exterior noise to meet the following criteria:
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-10
Draft EIR
May 2025
Typical Use Level L (eq)
Private office1, church sanctuary, board room, conference room, etc. 45 dB(A)
General office2, reception, clerical etc. 50 dB(A)
Bank lobby, retail store, restaurant, typing pool, etc. 55 dB(A)
Manufacturing, kitchen, warehousing, etc. 60 dB(A)
*L(eq) is the equivalent sound level for a specified time period in dB(A).
**Measures from 7:00 a.m. to 7:00 p.m. or other appropriate, approved time period.
1An enclosed office intended for use by an individual
2 An open office intended to have more than one work station
Policy 3.2.4 Noise Impact Zone "2" - Moderate Noise Impact (60 dB CNEL or greater, less than 65
dB CNEL). Noise impacts in this area are sufficient to require sound attenuation as set forth
in the California Noise Insulation Standards, Title 25, California Code of Regulations. Single
noise events in this area create serious disturbances to many inhabitants. Even though the
ALUC would not find residential units incompatible in this area, the ALUC strongly
recommends that residential units be limited or excluded from this area unless sufficiently
sound attenuated. The residential use interior sound attenuation requirement shall be a CNEL
value not exceeding an interior level of 45 dB. In addition, it is recommended that
designated outdoor common or recreational areas within Noise Impact Zone 2 provide
outdoor signage informing the public of the presence of operating aircraft.
Policy 3.2.5 Runway Protection Zone “RPZ,” Extreme Crash Hazard. The severe potential for loss of
life and property due to accidents prohibits most land uses in this area. Only airport related
uses and open space uses, including agriculture and certain types of transportation and
utility uses are permitted. No buildings intended for human habitation are permitted in the
RPZ. Furthermore, because of the proximity to aeronautical operations, uses in this area must
not attract birds nor emit excessive glare or light, nor produce or cause steam, smoke, dust,
or electronic interference so as to interfere with, or endanger, aeronautical operations.
Policy 3.2.6 Height Restriction Zone. Any object, which by reason of its height or location would
interfere with the established, or planned, airport flight procedures, patterns, or
navigational systems, is unacceptable. This will ensure the stability of local air transportation,
as well as promote land uses that are compatible with the airport environs. However, any
object which rises above the height of surrounding development, or which is located in close
proximity to any of the various flight paths, must be clearly visible during hours of twilight
or darkness and must not threaten, endanger, or interfere with aeronautical operations.
Policy 3.2.7 Airspace/Airport Inconsistency. Any structure, either within or outside of the planning area,
is inconsistent with this AELUP if it:
1. Is determined to be a "Hazard" by the FAA;
2. Would raise the ceiling or visibility minimums at an airport for an existing or planned
instrument procedure (i.e., a procedure consistent with the FAA approved airport layout
plan or a proposed procedure formally on file with the FAA);
3. Would result in a loss in airport utility, e.g. in a diminution of the established operational
efficiency and capacity of the airport, such as by causing the usable length of the
runway (s) to be reduced; or
4. Would conflict with air space used for the airport traffic pattern or enroute navigation
to and from the airport.
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-11
Draft EIR
May 2025
5.8.2.4 Local Regulations
City of Newport Beach Local Hazard Mitigation Plan
The 2016 Local Hazard Mitigation Plan is a FEMA-approved document that identifies the natural and human-
caused hazards of concern within the planning area and the potential actions identified by the City to
mitigate these hazards. This document complies with the Federal Disaster Mitigation Act of 2000, which
requires an update every five years to ensure jurisdictions remain eligible for FEMA mitigation grant
opportunities. The Local Hazards Mitigation Plan describes and analyzes issues of concern to the City
including earthquakes, floods, tsunamis, wildfires, unstable slopes, and strong winds.
City of Newport Beach Emergency Operations Plan
Pursuant to Municipal Code Section 2.20.050, Emergency Operations Plan, the City of Newport Beach
maintains an Emergency Operations Plan (EOP) that guides the City through the mitigation, preparedness,
response, and recovery phases of emergency management. The plan’s purpose is to establish policies and
procedures that will assure the most effective utilization of all resources in the City to minimize potential loss
of life and protect the environment and property. The City adopted the EOP in 2022, which identifies
evacuation routes, emergency facilities, and City personnel and describes the overall responsibilities of
federal, State, regional, Operational Area, and City entities. The EOP contains strategies and programs for
implementation to better prepare the public for natural and human caused disasters. The EOP continues the
City’s compliance with the Standardized Emergency Management System (SEMS), the National Incident
Management System (NIMS), the Incident Command System (ICS), the National Response Framework (NRF),
and the National Preparedness Guidelines, including Comprehensive Preparedness Guide 101: Developing
and Maintaining Emergency Operations Plans (CPG-101).
City of Newport Beach Emergency Response Organization
The activities identified in the EOP are carried out by the City’s Emergency Response Organization, which is
made up of assigned representatives from City departments. The Emergency Response Organization is
formed per Municipal Code Section 2.20.080, Emergency Organization, and maintains a readiness condition
24 hours per day, seven days per week.
In substantial emergency situations, the City also may choose to activate its Emergency Operations Center,
which is responsible for directing, coordinating, and supporting the various City departments and other
agencies in their emergency response activities. The Emergency Operations Center is a stand-alone facility,
located in the Newport Beach Police Department, with resources necessary to facilitate an effective
emergency response. When the Emergency Response Organization is activated, representatives from City
departments report to the Emergency Operations Center and fill their assigned roles. The Emergency
Operations Center allows for face-to-face coordination among personnel who must create policy, set
priorities, inform the public, and support first responders.
City of Newport Beach General Plan
The City of Newport Beach General Plan 20062 contains the following policies related to hazards and
hazardous materials that are applicable to the Project:
2 The City of Newport Beach General Plan 2022 Housing Element and Noise Element have updated policies related to airport compatibility noise
levels, which are not applicable to the proposed project and are not identified herein.
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-12
Draft EIR
May 2025
Policy LU 3.7 Natural Resource and Hazardous Areas. Require that new development is located and
designed to protect areas with high natural resource value and protect residents and
visitors from threats to life or property.
Policy LU 6.15.3 Airport Compatibility. Require that all development be constructed in conformance with
the height restrictions set forth by the Federal Aviation Administration (FAA), Federal
Aviation Regulations (FAR) Part 77, and Caltrans Division of Aeronautics, and that
residential development shall be allowed only on parcels with noise levels of less than
John Wayne Airport 65 dBA CNEL noise contour area as shown in Figure N5 of the Noise
Element of the General Plan unless and until the City determines, based on substantial
evidence, that the sites wholly within the 65 dBA CNEL noise contour shown in Figure N5
are needed for the City to satisfy its Sixth Cycle RHNA mandate. Nonresidential uses are,
however, encouraged on parcels located wholly within the 65 dBA CNEL contour area.
Policy S 5.2 Facility Use or Storage of Hazardous Materials Standards. Require that all new facilities
storing, using, or otherwise involved with substantial quantities of onsite hazardous
materials within flood zones comply with standards of elevation, anchoring, and flood
proofing, and hazardous materials are stored in watertight containers.
Policy S 6.2 Development in Interface Areas. Apply hazard reduction, fuel modification, and other
methods to reduce wildfire hazards to existing and new development in urban wildland
interface areas.
Policy S 6.4 Use of City-Approved Plant List. Use fire-resistive, native plant species from the City-
approved plant list in fuel modification zones abutting sensitive habitats.
Policy S 7.1 Known Areas of Contamination. Require proponents of projects in known areas of
contamination from oil operations or other uses to perform comprehensive soil and
groundwater contamination assessments in accordance with American Society for Testing
and Materials standards, and if contamination exceeds regulatory action levels, require
the proponent to undertake remediation procedures prior to grading and development
under the supervision of the County Environmental Health Division, County Department of
Toxic Substances Control, or Regional Water Quality Control Board (depending upon the
nature of any identified contamination).
Policy S 7.2 Development Design within Methane Gas Districts. Ensure that any development within
identified methane gas districts be designed consistent with the requirements of the
Newport Beach Municipal Code.
Policy S 8.6 John Wayne Airport Traffic Pattern Zone. Use the most currently available John Wayne
Airport (JWA) Airport Environs Land Use Plan (AELUP) as a planning resource for
evaluation of land use compatibility and land use intensity in areas affected by JWA
operations. In particular, future land use decisions within the existing JWA Clear
Zone/Runway Protection Zone (Figure S5) should be evaluated to minimize the risk to life
and property associated with aircraft operations.
Policy N 1.5A Airport Area Infill Projects. Allow infill residential projects proximate to John Wayne
Airport to have a higher exterior noise level standard (65-70 dBA CNEL) if it can be
shown that there are no practical mechanisms or designs to meet the exterior noise levels.
The interior standard of 45 dBA CNEL shall be enforced for any residential component of
projects. No residential units may be located on parcels wholly within the John Wayne
Airport 65 dBA CNEL noise contour area as shown in Figure N5, of the Noise Element of
the General Plan, unless and until the City determines, based on substantial evidence, that
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-13
Draft EIR
May 2025
the sites wholly within such contour area are needed for the City to satisfy its Sixth Cycle
RHNA mandate. Nonresidential uses are encouraged on parcels located wholly within the
65 dBA CNEL contour area, shown in Figure N5.
Policy N 3.1 New Development. Ensure new development is compatible with the noise environment
proximate to John Wayne Airport by not allowing residential units on parcels located
wholly within the John Wayne Airport 65 dBA CNEL noise contour, as shown in Figure N5
of the Noise Element of the General Plan, unless and until the City determines, based on
substantial evidence, that the sites wholly within such contour area are needed for the City
to satisfy its Sixth Cycle RHNA mandate.
City of Newport Beach Municipal Code
Chapter 2.20 Emergency Services. This chapter provides for the preparation and implementation of plans
to provide services within this City in the event of an emergency and for the coordination of the emergency
service functions with all other public agencies and affected private persons, corporations, and organizations.
Municipal Code Section 2.20.050 requires City Council to adopt an Emergency Operations Plan.
Chapter 9.04 Fire Code. The City of Newport Beach has adopted the 2022 California Fire Code with City
amendments and some exceptions. Chapter 9.04, also called the Fire Code, establishes a variety of
regulations related to hazards such as: recommendations for development on land containing or emitting
toxic substances, hazardous materials documentation procedures, hazardous materials management plan,
storage tank regulations, etc. The Newport Beach Fire Department (NBFD) enforces locally developed fire
regulations which reduce the amount and continuity of fuel (vegetation) available, firewood storage, debris
clearing, proximity of vegetation to structures and other measures aimed at “Hazard Reduction.”
Chapter 15.55, Methane Overlay Zone. This Municipal Code chapter establishes a methane gas mitigation
district that requires property owners to test for and mitigate the presence of methane gas prior to significant
new construction. The methane gas mitigation district may be applied to those areas of the City where studies
have shown there is a distinct possibility of high concentrations of methane gas in soil close to ground surface.
Chapter 30, Section 080 (F), Airport Environs Land Use Plan. This section of the Municipal Code establishes
the standards for the regulations of noise levels pursuant to health, safety, and welfare within the City. The
Municipal Code incorporates the AELUP requirements and allows residential uses on parcels wholly or
partially outside the John Wayne Airport 65 dBA CNEL noise contour as shown in Figure N5 of the Noise
Element of the General Plan and consistent with Title 21 of the California Code of Regulations, subject to
conditions of this section of the Municipal Code that apply to all residential projects within the John Wayne
Airport 60 dBA CNEL or higher CNEL noise as shown in Figures N4 and N5 of the Noise Element of the
General Plan.
5.8.3 ENVIRONMENTAL SETTING
The Project site has been in use as a golf course and associated facilities since 1976. The Project site is
currently developed with a driving range, three golf holes, a practice putting green, and a clubhouse with
a bar/restaurant. Golf courses are known to require heavy application of pesticides and herbicides and
routine course maintenance may have resulted in a potential release of hazardous materials at the site. Thus,
the Phase I Environmental Site Assessment (Appendix K) identified one Recognized Environmental Condition
(REC) from the historic use of pesticides and herbicides at the Project site. In addition, fire training activities
are often associated with the application of polyfluoroalkyl substances (PFAS)-containing fire suppressants.
The adjacent Fire Station contains a training center, which is located uphill and upgradient of the Project site
(Appendix K). Therefore, a Phase II Environmental Site Assessment (Appendix L) conducted onsite soil and
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-14
Draft EIR
May 2025
groundwater testing throughout the site for the presence of herbicides, pesticides, and metals in the soil as
well as PFAS in groundwater from the fire training center. The laboratory test results were compared to
corresponding USEPA Regional Screening Levels (RSLs) for residential use and Department of Substances
Control Screening Levels (DTSC SLs) for commercial/industrial uses. The testing results showed no exceedance
of laboratory detection limits or RSLs. These results indicate there is no likely release of these compounds at
the Project site and a threat to human health or the environment is not present from these compounds.
5.8.3.1 Methane
Methane is hazardous and flammable at high concentrations. Generally, methane forms in areas such as
swamps, landfills, or areas associated with petroleum deposits. Five methane gas mitigation districts have
been identified in the City, and natural seepages of gas occur in the western and southwestern portions of
the City. Special development regulations (Municipal Code Chapter 15.55 – Methane Overlay Zone),
intended to prevent gases from accumulating, apply to projects located in methane overlay districts.
The Project site and vicinity are not located within a methane gas mitigation district and is not identified
within an area of methane gas seepage.
5.8.3.2 Asbestos
Asbestos is a naturally occurring fibrous material that was used as a fireproofing and insulating agent in
building construction before such uses were banned by the USEPA in the 1970s, although some nonfriable3
use of asbestos in roofing materials still exists. The presence of asbestos can be found in materials such as
ducting insulation, wallboard, shingles, ceiling tiles, floor tiles, insulation, plaster, floor backing, and many
other building materials. The OSHA regulation 29 CFR 1926.1101 requires certain construction materials to
be presumed to contain asbestos, for purposes of this regulation. All thermal system insulation, surfacing
material, and asphalt/vinyl flooring that are present in a building constructed prior to 1981 and have not
been appropriately tested are “presumed asbestos-containing material”.
Asbestos and asbestos-containing materials (ACMs) are considered both a hazardous air pollutant and a
human health hazard. The risk to human health is from inhalation of airborne asbestos, which commonly occurs
when ACMs are disturbed during such activities as demolition and renovation. The buildings within the Project
site were constructed between 1974 and 1981. Therefore, there is potential that the existing buildings on
the Project site contain ACMs.
5.8.3.3 Lead
In 1978, the Consumer Product Safety Commission set the allowable lead levels in paint at 0.06 percent by
weight in a dry film of newly applied paint. In the 1970s, the chief concern for lead-based paint was its
cumulative effect on body systems, primarily when paint chips containing lead were ingested by children.
Research in the early 1980s showed that lead dust is of special concern because the smaller particles are
more easily absorbed by the body. Common methods of paint removal, such as sanding, scraping, and
burning, create excessive amounts of dust. Lead dust is especially hazardous to young children because they
play on the floor and engage in a great deal of hand-to-mouth activity, increasing their potential for
exposure. The Phase II Environmental Site Assessment (Appendix L) completed soils testing, which identified
that levels of lead in the soil do not exceed health risk screening levels.
3 Nonfriable asbestos refers to ACMs that contain asbestos fibers in a solid matrix that does not allow for them to be easily released.
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-15
Draft EIR
May 2025
5.8.3.4 John Wayne Airport
John Wayne Airport (SNA) is located approximately 0.4-mile northeast of the Project site. The Project site
is located within the airport planning boundaries and ALUC notification area as shown on Figure 5.8-1, John
Wayne Airport Notification Area. As shown on Figure 5.8-2, 2024 John Wayne Airport Noise Contours, the
airport’s noise monitoring program shows that the Project site is located within the SNA 65 CNEL noise contour,
which indicates that noise from aircraft on the Project site is 65 dB CNEL and is within the noise impact area
related to SNA operations.
The airport has two runways: the shorter 2R/20L which is 2,887 feet long is used by general aviation prop-
powered aircraft and the longer 2L/20R which is 5,700 feet long is used by commercial aircraft. With winds
predominantly coming from the ocean, aircraft typically depart to the southwest and arrive from the
northeast about 95 percent of the time with slight variations from year to year. The reverse (depart to
northeast and arrive from southwest) occurs primarily when Santa Ana wind conditions occur, but there are
times when winds aloft, or other weather conditions may cause operations to go into reverse.
As shown on Figure 5.8-3, John Wayne Airport Safety Zones for 2L/20R, the Project site is located within
Safety Zone 2, the Inner Approach/Departure Zone; Safety Zone 4, Outer Approach/Departure Zone; and
Safety Zone 6, the Traffic Pattern Zone, for the 2L/20R runway that is used by commercial aircraft. The
Project site is not located within any of the Safety Zones for the 2R/20L runway that is used by general
aviation prop-powered aircraft, as shown in Figure 5.8-4, John Wayne Airport Safety Zones for 2R/20L.
Pursuant to the AELUP, Safety Zone 2, the Inner Approach/Departure Zone, poses a higher risk to persons in
the area for aircraft accidents. Aircraft are typically overflying this zone at lower altitudes and emergency
landings from straight out departures can be more prevalent in this zone than in other zones. Zone 4, the
Outer Approach/Departure Zone has moderate aircraft accident risk; aircraft emergencies can occur over
this area approximately two to six percent of the time. Zone 6, the Traffic Pattern Zone, has the lowest risk
for aircraft accidents (Appendix M).
The Project site is also located under the FAR Part 77 Obstruction Imaginary Surface area for both runways.
As shown on Figure 5.8-5, FAA Part 77 Obstruction Imaginary Surfaces for Runway 2L/20R, a majority of the
Project site is located under the Approach Surface and the westernmost portion of the site is located under
the Inner Transitional Surface for the 2L/20R runway that is used by commercial aircraft. Figure 5.8-6, FAA
Part 77 Obstruction Imaginary Surfaces for Runway 2R/20L, shows that the Project site is under the Conical
Surface for the 2R/20L runway.
FAR Part 77 requires notification to FAA for any project that would be more than 200 feet in height above
ground level or within the imaginary surface of a 100:1 slope extending outward for 20,000 feet from the
nearest runway, as this area may result in aeronautical hazards. The Project site has previously undergone
FAA Park 77 evaluation as part of installation of poles on the existing driving range, which determined that
structures on the site that are below 162 feet above mean sea level (amsl) would not have a significant
adverse impact related to aeronautical hazards (FAA, 2016).
Because the Project site is located within the AELUP Notification area for SNA and within the SNA planning
area boundary, and the Project proposes a General Plan Amendment, the City is required to refer the
proposed Project to the ALUC for review, pursuant to the California Public Utilities Code Section 21676, as
listed previously.
Aircraft Accident Hazards. A review of aircraft accidents at John Wayne Airport in the National
Transportation Safety Board (NTSB) database (Appendix M) identified 66 accidents investigated by the
NTSB at SNA between 1982 and 2024 (through October 9th, 2024). Of the accidents investigated, 14
were fatal and 57 (90%) occurred during the takeoff, climb, approach, landing or traffic pattern phase of
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-16
Draft EIR
May 2025
flight. Of the fatal accidents, one person on the ground sustained minor injuries. Nine accidents (9%) were
caused by wake turbulence.
Over the 42-year review period between 1982 and 2024, five fatal accidents involving aircraft using SNA
were generally located south of the airport and within 3.5 miles. During this same period, over 15 million
aircraft operations took place at SNA (0.033 fatal accidents per 100,000 aircraft operations). The location
of the five fatal accident sites south of the airport are shown in Figure 5.8-7, Historical Aviation Accidents
South of John Wayne Airport, and the accidents are described below.
• On January 30, 2018, a private helicopter pilot departed with three passengers on a cross-country
flight. The helicopter reached a maximum altitude of 500 feet amsl before it entered a rapid descent
and impacted homes in Newport Beach (Egret Court near Shearwater Place in the Bayview Terrace
community) and the ground less than one mile from SNA on a southeasterly heading. There were three
fatalities, one person seriously injured and one person on the ground sustained minor injuries.
• On November 21, 2010, during a cross-country flight at night, the pilot contacted air traffic control
(ATC) that the aircraft had run out of fuel. The pilot was unable to reach the airport and landed in an
ecological reserve at “Back Bay”, south of the airport, in about three feet of water. The accident resulted
in three fatalities.
• On March 31, 1989, a Piper aircraft took off from the airport with a trail of black smoke, as per several
witnesses. The aircraft staggered off the ground and never got above 100 feet above ground level.
The pilot contacted ATC that the aircraft was coming back to the runway, but shortly thereafter entered
a steep left turn, stalled and crashed into tennis courts (Newport Beach Tennis Club) approximately two
nautical miles from the airport. The accident resulted in five fatalities.
• On December 19, 1985, a Piper aircraft on a flight from San Diego to Torrance declared an emergency
because the engine had quit and requested vectors to the airport. The pilot received clearance to land
on either runway but three minutes later told ATC that he did not think he was going to reach the airport.
The aircraft subsequently collided with trees, a house, and a fence in a residential area approximately
three miles from the airport. The accident resulted in one fatality.
• On October 7, 1984, shortly after takeoff, the propeller separated from an aircraft. The aircraft
continued to climb straight ahead and then was observed in a steep left turn and crashed into the roof
of a building approximately one quarter mile southeast of the airport. There was one fatality.
The aircraft hazard assessment included in Appendix M, determined that the history of accidents at SNA are
consistent with the California Airport Land Use Planning Handbook study findings regarding typical aircraft
accidents and airport hazard risks.
Airport Wildlife Hazards. The 2011 California Airport Land Use Planning Handbook recognizes that “A
variety of land uses, facilities, and structures on and near airports can create wildlife hazard attractants that
pose a threat to aircraft operations. Examples of these include sanitary landfills, water management
facilities, ponds built for recreational use, wetlands, agricultural areas, natural areas, and landscaping.”
These areas may provide food and drinking sources, wildlife corridors, roost sites, migratory flyway stop
over sites or numerous other functions that may benefit wildlife, while creating a hazard to aircraft
operations. Parks and golf courses, with their large grassy areas and water features, may also act as
attractants to wildlife.
FAA Advisory Circular 150/5200-33C, Hazardous Wildlife Hazard Attractants on and near Airports,
recommends minimum separation criteria for land uses that attract wildlife to the vicinity of airports; into, or
across the airport’s approach or departure paths or aircraft operations areas. Generally, the FAA
recommends a distance of five miles between an airport’s aircraft operations area and a wildlife attractant.
For airports serving turbine-powered aircraft, the FAA recommends a separation distance of 10,000 feet
between an airport’s operations area and a wildlife attractant. These recommended separation standards
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-17
Draft EIR
May 2025
are used to determine whether a development plan has the potential to impact aircraft operations by
attracting wildlife, whether design changes should be made, and whether any mitigation measures need to
be enacted.
The existing NB Golf Course contains trees, large grassy areas, and high poles that may provide roost sites,
migratory flyway stop-over sites, or other functions that may benefit wildlife; and therefore, is considered
a wildlife attractant (Appendix M).
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-18
Draft EIR
May 2025
This page intentionally left blank.
Figure 5.8-16QXJ+DUERU6XUI3DUN3URMHFW
&LW\RI1HZSRUW%HDFK
John Wayne Airport Notification Area
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-20
Draft EIR
May 2025
This page intentionally left blank.
Figure 5.8-26QXJ+DUERU6XUI3DUN3URMHFW
&LW\RI1HZSRUW%HDFK
2024
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-22
Draft EIR
May 2025
This page intentionally left blank.
Figure 5.8-36QXJ+DUERU6XUI3DUN3URMHFW
&LW\RI1HZSRUW%HDFK
Legend
Project Boundary
JWA Safety Zones 2L/20R
Safety Zone 5: Sideline Zone
Safety Zone 6: Traffic Pattern Zone
Safety Zone 1: Runway Protection Zone
Safety Zone 4: Outer Approach / Departure Zone
Safety Zone 3: Inner Turning Zone
Safety Zone 2: Inner Approach / Departure Zone
John Wayne Airport Safety Zone VIRU 2L20R
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-24
Draft EIR
May 2025
This page intentionally left blank.
Figure 5.8-46QXJ+DUERU6XUI3DUN3URMHFW
&LW\RI1HZSRUW%HDFK
Legend
Project Boundary
JWA Safety Zones 2L/20R
Safety Zone 5: Sideline Zone
Safety Zone 6: Traffic Pattern Zone
Safety Zone 1: Runway Protection Zone
Safety Zone 4: Outer Approach / Departure Zone
Safety Zone 3: Inner Turning Zone
Safety Zone 2: Inner Approach / Departure Zone
John Wayne Airport Safety Zone IRU 2R20L
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-26
Draft EIR
May 2025
This page intentionally left blank.
Figure 5.8-56QXJ+DUERU6XUI3DUN3URMHFW
&LW\RI1HZSRUW%HDFK
John Wayne Airport - FAA Part 77 Obstruction
Imaginary SurfacesIRU5XQZD\/5
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-28
Draft EIR
May 2025
This page intentionally left blank.
Figure 5.8-66QXJ+DUERU6XUI3DUN3URMHFW
&LW\RI1HZSRUW%HDFK
John Wayne Airport - FAA Part 77 Obstruction
Imaginary SurfacesIRU5XQZD\5/
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-30
Draft EIR
May 2025
This page intentionally left blank.
Historical Aviation Accidents South of John Wayne Airport
Figure 5.8-7Snug Harbor Surf Park Project
City of Newport Beach
ACC 10071984
ACC 12191985
ACC 03311989
ACC 11212010
ACC 01302018
City of Costa Mesa, City of Newport Beach, County of Los Angeles,
Bureau of Land Management, Esri, HERE, Garmin, INCREMENT P,
USGS, METI/NASA, EPA, USDA
0 0.5 1
Miles ±Legend
Project Boundary
Historical Accident Sites
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-32
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-33
Draft EIR
May 2025
5.8.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of the CEQA Guidelines indicates that a Project could have a significant effect if it were to:
HAZ-1 Create a significant hazard to the public or the environment through the routine transport, use, or
disposal of hazardous materials.
HAZ-2 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.
HAZ-3 Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or
waste within one-quarter mile of an existing or proposed school.
HAZ-4 Be located on a site which is included on a list of hazardous materials sites compiled pursuant to
Government Code § 65962.5 and, as a result, would it create a significant hazard to the public
or the environment.
HAZ-5 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.
HAZ-6 Impair implementation of or physically interfere with an adopted emergency response plan or
emergency evacuation plan.
HAZ-7 Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death
involving wildland fires.
5.8.5 METHODOLOGY
This evaluation of the significance of potential impacts related to hazards and hazardous materials considers
both direct effects to the resource and indirect effects in a local or regional context. Potentially significant
impacts would generally result in the loss or degradation of public health and safety or conflict with local,
State, or federal agency regulations. Information for this section was obtained, in part, from review of
mapping of potential hazards and site testing that was completed as part of the Phase I and Phase II
Environmental Site Assessments, which are included as Appendix K and L.
The methodology for the evaluation of potential Project impacts related to the operation of SNA focuses on
potential hazards associated with development of structures on the Project site, onsite persons, and ongoing
operation of SNA. The proposed Project was evaluated for compliance with existing FAA, California Division
of Aeronautic, and AELUP planning guidelines and regulations related to airport hazards and land uses. The
Project was also evaluated for aircraft accident hazards based on the National Transportation Safety Board
(NTSB) and California Airport Land Use Planning Handbook data. Also, the glare analysis implements the
FAA criteria of no potential for glint or glare in the airport traffic control tower cab, and no potential for
pilot glare or “low potential for after-image” along the final approach path.
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-34
Draft EIR
May 2025
5.8.6 ENVIRONMENTAL IMPACTS
IMPACT HAZ-1: THE PROJECT WOULD NOT CREATE A SIGNIFICANT HAZARD TO THE PUBLIC OR THE
ENVIRONMENT THROUGH THE ROUTINE TRANSPORT, USE, OR DISPOSAL OF
HAZARDOUS MATERIALS.
Less than Significant.
Construction
The proposed construction activities, as detailed in Chapter 3.0, Project Description, would involve the routine
transport, use, and disposal of hazardous materials such as paints, solvents, oils, grease, and caulking during
construction activities. In addition, hazardous materials would routinely be needed for fueling and servicing
construction equipment on the site. These types of materials are not acutely hazardous, and all storage,
handling, use, and disposal of these materials are regulated by federal and State regulations that are
implemented by the City of Newport Beach during building permitting for construction activities.
Construction contractors would be required through City permitting to comply with federal, State, and local
laws and regulations regarding the transport, use, and storage of hazardous materials. Applicable laws and
regulations include, but are not limited to, CFR, Title 29 - Hazardous Waste Control Act; CFR, Title 49,
Chapter I; and Hazardous Materials Transportation Act requirements as imposed by the USDOT, CalOSHA,
CalEPA, DTSC, and the Fire Department. Additionally, construction activities would require a Stormwater
Pollution Prevention Plan (SWPPP) (and included as PPP WQ-1), which is mandated by the National Pollution
Discharge Elimination System (NPDES) General Construction Permit and enforced by the Santa Ana RWQCB.
The SWPPP would include strict onsite handling rules and best management practices (BMPs) to minimize
potential adverse effects to workers, the public, and the environment during construction, including, but not
limited to:
• Establishing a dedicated area for fuel storage and refueling activities that includes secondary
containment protection measures and spill control supplies;
• Following manufacturers’ recommendations on the use, storage, and disposal of chemical products used
in construction;
• Avoiding overtopping construction equipment fuel tanks;
• Properly containing and removing grease and oils during routine maintenance of equipment; and
• Properly disposing of discarded containers of fuels and other chemicals.
Implementation of the SWPPP, as confirmed through the City’s permitting process, would limit potentially
significant hazards from runoff of contaminated materials during construction to a less-than-significant level.
Operation
Operation of the proposed Project includes activities related to a recreational surf park, amenity clubhouse,
and athlete accommodations. The surf lagoon would use basic pool cleaning equipment and chemicals to
maintain the pH levels for surfers. Project hazardous materials usage would be limited to small amounts.
Furthermore, cleaning and degreasing solvents, fertilizers, pesticides, and other materials used in the regular
maintenance of mechanical equipment, buildings, and landscaping would be utilized. The quantities stored
at the site would be comparable to typical commercial recreation uses, and would be regulated by State
and local law, including Fire Department regulations requiring proper storage and inspection and City
operational permitting. Normal routine use of these products pursuant to existing regulations would not result
in a significant hazard to the environment, residents, or workers in the vicinity of the proposed Project.
Therefore, operational impacts related to routine transport, use, and disposal of hazardous materials during
operation of the proposed Project would be less than significant.
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-35
Draft EIR
May 2025
IMPACT HAZ-2: THE PROJECT WOULD NOT 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.
Construction
Accidental Releases. While the routine use, storage, transport, and disposal of hazardous materials in
accordance with applicable regulations during demolition, excavation, grading, and construction activities
would not pose health risks or result in significant impacts; improper use, storage, transportation and disposal
of hazardous materials and wastes could result in accidental spills or releases, posing health risks to workers,
the public, and the environment. Thus, implementation of the proposed Project could potentially result in the
accidental release of hazardous materials. The use of BMPs during construction implemented as part of a
SWPPP as required by the NPDES General Construction Permit (and included as PPP WQ-1) would minimize
potential adverse effects to workers, the public, and the environment. Construction contract specifications
would include strict onsite handling rules and BMPs that include, but are not limited to:
• Establishing a dedicated area for fuel storage and refueling activities that includes secondary
containment protection measures and spill control supplies;
• Following manufacturers’ recommendations on the use, storage, and disposal of chemical products used
in construction;
• Avoiding overtopping construction equipment fuel tanks;
• Properly containing and removing grease and oils during routine maintenance of equipment; and
• Properly disposing of discarded containers of fuels and other chemicals.
Contaminated Soils. As described previously, the Phase 1 Environmental Site Assessment (included as
Appendix K) identified one REC which includes the historic use of pesticides and herbicides at the Project site.
In addition, the potential use of PFAS at the adjacent fire station for fire suppression training was identified
as an EC. The Phase II Environmental Site Assessment (Appendix L) conducted onsite soils and groundwater
testing throughout the site to test for the presence of herbicides, pesticides, and metals in the soil as well as
PFAS from the fire training center.
The laboratory test results were compared to corresponding USEPA RSLs for residential use and DTSC SLs
for commercial/industrial uses. Soil herbicides, organochlorine pesticides, and PFAs did not exceed
laboratory detection limits or RSLs. As none of these compounds are present at the site beyond USEPA and
DTSC SLs, any release of these compounds at the site would not pose a threat to human health or the
environment. Thus, any excavation of soils as part of Project construction activity is not expected to result in
the release of any hazardous materials beyond USEPA and DTSC SLs, and impacts would be less than
significant.
Asbestos Containing Materials. Buildings on the Project site were constructed in the 1970s when many structures
were constructed with what are now recognized as hazardous building materials, such as lead and asbestos.
Demolition of these structures could result in the release of hazardous materials. However, asbestos
abatement contractors must follow State regulations contained in California Code of Regulations Sections
1529, and 341.6 through 341.14 as implemented by SCAQMD Rule 1403 to ensure that asbestos removed
during demolition or redevelopment of the existing buildings is transported and disposed of at an
appropriate facility. The contractor and hauler of the material are required to file a Hazardous Waste
Manifest which details the hauling of the material from the site and the disposal of it. Section 19827.5 of
the California Health and Safety Code requires that local agencies not issue demolition permits until an
applicant has demonstrated compliance with notification requirements under applicable federal regulations
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-36
Draft EIR
May 2025
regarding hazardous air pollutants, including asbestos. These requirements are included as PPP HAZ-1 to
ensure that the Project applicant submits verification to the City that the appropriate activities related to
asbestos have occurred, which would reduce the potential of impacts related to asbestos to a less than
significant level.
Lead Based Materials. Lead-based materials may also be located within existing structures on the Project site.
The lead exposure guidelines provided by the United States Department of Housing and Urban Development
provide regulations related to the handling and disposal of lead-based products. Federal regulations to
manage and control exposure to lead-based paint are described in Code of Federal Regulations Title 29,
Section 1926.62, and State regulations related to lead are provided in the California Code of Regulations
Title 8 Section 1532.1, as implemented by CalOSHA. These regulations cover the demolition, removal,
cleanup, transportation, storage and disposal of lead-containing material. The regulations outline the
permissible exposure limit, protective measures, monitoring, and compliance to ensure the safety of
construction workers exposed to lead-based materials. CalOSHA’s Lead in Construction Standard requires
project applicants to develop and implement a lead compliance plan when lead-based paint would be
disturbed during construction or demolition activities. The plan must describe activities that could emit lead,
methods for complying with the standard, safe work practices, and a plan to protect workers from exposure
to lead during construction activities. In addition, CalOSHA requires 24-hour notification if more than 100
SF of lead-based paint would be disturbed. These requirements are included as PPP HAZ-2 to ensure that
the Project applicant submits verification to the City that the appropriate activities related to lead have
occurred, which would reduce the potential of impacts related to lead-based materials to a less than
significant level.
Undocumented Hazardous Materials. As described previously, the Project site has a history of various uses that
include use and storage of hazardous materials, such as golf course maintenance with the use of pesticides
and herbicides. As a result, there is the potential for undocumented hazardous material to exist on site.
However, the existing federal and State regulations related to hazardous materials and construction include
procedures to follow in the case hazardous materials are uncovered during construction activities.
Excavated soil containing hazardous substances and hazardous building materials would be classified as a
hazardous waste if they exhibit the characteristics of ignitability, corrosivity, reactivity, or toxicity (CCR, Title
22, Division 4.5, Chapter 11, Article 3). State and federal laws require detailed planning to ensure that
hazardous materials are properly handled, used, stored, and disposed of, and in the event that such
materials are accidentally released, to prevent or to mitigate injury to health or the environment. These
regulations are detailed previously and include, but are not limited to, the Federal Resource Conservation
and Recovery Act, the Occupational Safety and Health Act that is implemented by OSHA, and the Hazardous
Materials Transportation Act. Additionally, the California Integrated Waste Management Board and the
RWQCB specifically address management of hazardous materials and waste handling in their adopted
regulations (CCR, Title 14 and CCR, Title 27). Thus, with implementation of existing regulations, impacts
related to upset or accident conditions involving the release of hazardous materials into the environment
would be less than significant.
Operation
As described above, the risks related to upset or accident conditions involving the release of hazardous
materials into the environment would be adequately addressed through compliance with existing federal,
State, and local regulations. Development under the proposed Project would involve commercial recreation
uses that would use and store common hazardous materials such as paints, pool cleaning chemicals, solvents,
and cleaning products. As stated previously, the surf lagoon would use basic cleaning equipment and
chemicals to maintain the pH levels for surfers. Also, building and lagoon mechanical systems and
grounds/landscape maintenance could also use a variety of products formulated with hazardous materials,
including fuels, cleaners, lubricants, adhesives, sealers, and pesticides/herbicides.
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-37
Draft EIR
May 2025
As described previously, normal routine use of these products pursuant to existing regulations would not result
in a significant hazard to the environment, residents, or workers in the vicinity of the proposed Project. In
addition, a Water Quality Management Plan (WQMP) is required to be implemented for the proposed
Project (as further discussed in Section 5.9, Hydrology and Water Quality (included as PPP WQ-3)). The BMPs
that would be implemented as part of the WQMP would protect human health and the environment should
any accidental spills or releases of hazardous materials occur during operation of the proposed Project. As
a result, operation of the proposed Project would not result in 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, and impacts would be less than significant.
IMPACT HAZ-3: THE PROJECT WOULD NOT EMIT HAZARDOUS EMISSIONS OR HANDLE
HAZARDOUS OR ACUTELY HAZARDOUS MATERIALS, SUBSTANCES, OR WASTE
WITHIN ONE-QUARTER MILE OF AN EXISTING OR PROPOSED SCHOOL.
Less than Significant. The Project site is located 0.3-mile west of the closest school, which is the Newport
Montessori School, located at 20221 SW Cypress Street, Newport Beach. Thus, the proposed Project would
not be within 0.25 mile of an existing school.
Construction
As described in the previous responses, Project construction would involve the use and disposal of various
hazardous materials. However, all storage, handling, use, and disposal of these materials are regulated by
federal and State regulations that are implemented by the City of Newport Beach during construction
permitting. In addition, the use of BMPs during construction implemented as part of a SWPPP as required by
the NPDES General Construction Permit (and included as PPP WQ-1) would minimize potential adverse
effects to workers, the public, and the environment. Construction contract specifications would include strict
onsite handling rules and BMPs that include, but are not limited to:
• Establishing a dedicated area for fuel storage and refueling activities that includes secondary
containment protection measures and spill control supplies;
• Following manufacturers’ recommendations on the use, storage, and disposal of chemical products used
in construction;
• Avoiding overtopping construction equipment fuel tanks;
• Properly containing and removing grease and oils during routine maintenance of equipment; and
• Properly disposing of discarded containers of fuels and other chemicals.
Operation
As described in response to Impact HAZ-1, operation of the proposed Project includes activities related to
commercial recreational development, which generally uses common hazardous materials, including: solvents,
cleaning agents, paints, pesticides, batteries, and aerosol cans. Normal routine use of these products pursuant
to existing regulations would not result in a significant hazard to the environment or school facilities in the
vicinity of the proposed Project. Therefore, operational impacts related to nearby schools would be less than
significant.
IMPACT HAZ-4: THE PROJECT WOULD NOT BE LOCATED ON A SITE WHICH IS INCLUDED ON A LIST
OF HAZARDOUS MATERIALS SITES COMPILED PURSUANT TO GOVERNMENT CODE
§ 65962.5 AND, AS A RESULT, WOULD IT CREATE A SIGNIFICANT HAZARD TO THE
PUBLIC OR THE ENVIRONMENT.
No Impact. The Phase I Environmental Site Assessment that was conducted included database searches to
determine if the Project area or any nearby properties are identified as currently having hazardous
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-38
Draft EIR
May 2025
materials and is included in Table 5.8-1. The record searches determined that although the site has a history
of various uses and identified as previously generating hazardous wastes and clean-up activities, the Project
site is not located on or near a site which is included on a Cortese List of hazardous materials sites pursuant
to Government Code Section 65962.5 (Appendix K).
Table 5.8-1: Phase I Hazardous Materials Site Database Review
Property Address1
Direction
Relative to
Subject
Property
Groundwater
Gradient
Distance
from
Subject
Property
(miles)
Database2 Notes
Subject Property
Newport
Beach Golf
Course
3100 Irvine
Avenue
-- -- -- CERS HAZ Chemical storage
facility, hazardous
chemical
management;
multiple violations
for training, business
plans, and timely
waste disposal;
Active USEPA ID;
Former leaking
underground
storage tank cleanup
adjacent to the
Project site, case
closed in 2006
DELISTED TNK
FINDS/FRS
HAZ GEN
HAZNET
HW ORANGE
LOP ORANGE
LUST
RCRA NON
GEN
RCRA NON
GEN
UST SWEEPS
Surrounding Properties
No Name
Listed
20321
Acacia, Santa
Ana Heights
E Cross gradient 0.02 HIST
MANIFEST
Photochemical &
photo processing
waste
Newport
Bay Terrace
Apartments
1691 Mesa
Drive
W Downgradient 0.04 RCRA NON
GEN
No records or
compliance
monitoring violations
as of October 2023
Newport
Beach Fire
Department
20401
Acacia St
SSE Upgradient 0.04 CERS TANK Chemical storage
facility; AST; history
of violations related
to record keeping
AST
Back Bay
Cleaners
2675 Irvine
Ave, Costa
Mesa
W Cross
Gradient
0.07 CLEANUP
SITES
Former dry cleaner;
open cleanup site;
small quantity
generator DRY
CLEANERS
EMISSIONS
FED
DRYCLEANERS
ICP ORANGE
RCRA NON
GEN
RCRA SQG
Source: Appendix K.
1 All addresses are in Newport Beach unless noted
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-39
Draft EIR
May 2025
2Database abbreviations are defined as follows:
AST – Statewide list of ASTs
CERS HAZ – California Environmental Reporting System (CERS) Hazardous Waste Sites
CERS TANK – California Environmental Reporting System (CERS) Tanks
CLEANUP SITES – List of Cleanup Program sites in the state of California made available through the SWRCB
DELISTED TNK – Delisted Storage Tanks
DRY CLEANERS – A list of drycleaners related to facilities that have USEPA ID numbers
EMISSIONS – Toxic pollutant emissions facilities
FED DRYCLEANERS – A list of drycleaner facilities from Enforcement and Compliance History Online
FINDS/FRS – Facility Registry Service/Facility Index
HAZ GEN – List of handlers listed as having generated waste from the facilities and manifest data
HAZNET – Hazardous Waste Manifest Data
HIST MANIFEST – List of historical waste manifest received by the DTSC from the year 1980 to 1992
HW ORANGE – List of Hazardous Waste Facilities in Orange County
ICP ORANGE – Orange County Industrial Cleanup Program (ICP) overseeing the voluntary cleanup of contaminated properties
LOP ORANGE – Orange County Local Oversight Program (LOP) of leaking USTs
LUST – Leaking Underground Storage Tank (LUST)
RCRA NON GEN – Resource Conservation and Recovery Act (RCRA) verified non-generator
RCRA SQG – RCRA Small Quantity Generator (SQG)
UST SWEEPS – Statewide Environmental Evaluation and Planning System historical list of USTs
Gasoline was identified as a potential chemical of concern beneath the golf course parcel to the north of
the Project site across Irvine Avenue. Three groundwater monitoring wells were installed in 1990 and
monitored until 2004. Petroleum hydrocarbons, including gasoline, benzene, toluene, ethylbenzene, xylenes,
and oxygenates, have not been detected since 1995 (Appendix K). The case was closed, and a No Further
Action (NFA) letter was issued in 2006.
Also, although the Phase I Environmental Site Assessment (Appendix K) identified offsite sources of
contamination, such as LUSTs, it did not identify any onsite or surrounding area sites that are included on a
Cortese List of hazardous materials sites compiled pursuant to Government Code Section 65962.5. In
addition, none of the listings for the adjacent properties were identified as a REC or HREC for the proposed
Project. As a result, impacts related to hazards from being located on or adjacent to a hazardous materials
site would not occur from implementation of the proposed Project.
IMPACT HAZ-5: THE PROJECT WOULD NOT, 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, RESULT IN A SAFETY HAZARD OR
EXCESSIVE NOISE FOR PEOPLE RESIDING OR WORKING IN THE PROJECT AREA.
Less than Significant. As described previously, SNA is located approximately 0.4 mile northeast of the
Project site. The Project site is located within the Safety Zone 2, the Inner Approach/Departure Zone; Safety
Zone 4, Outer Approach/Departure Zone; and Safety Zone 6, the Traffic Pattern Zone, for the 2L/20R
runway that is used by commercial aircraft as shown on Figure 5.8-3, John Wayne Airport Safety Zones for
2L/20R. In addition, the Project site is located within the FAR Part 77 Obstruction Imaginary Surface area
for both runways (shown on Figures 5.8-5 and 5.8-6).
The proposed Project involves redevelopment that would result in a surf lagoon; a three-story, amenity
clubhouse; a two-story 20-unit athlete accommodation building; ancillary maintenance buildings, outdoor
seating/lounging areas, warming pools, spas and associated parking. The three-story amenity clubhouse
building would have a maximum height of 50 feet and the two-story athlete accommodations building would
have a maximum height of 40 feet. In addition, the exterior lighting poles would be 71 feet in height.
The existing elevation of the site slopes to the northwest and is between approximately 58 feet amsl and
15 feet amsl. The proposed grading plan would modify onsite elevations resulting in an elevation of
approximately 42 feet amsl at the location of the proposed amenity clubhouse building that would be up
to 50 feet in height. Thus, the top of the proposed amenity clubhouse building structure would be
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-40
Draft EIR
May 2025
approximately 92 feet amsl. The proposed two-story 40-foot-high athlete accommodation building would
be constructed at a ground elevation of 43 feet; and the top of the structure would be 83 feet amsl. In
addition, the proposed 71-foot-tall lighting poles would be located on areas that are 37 feet amsl or less,
which would result in maximum light pole heights of 108 feet amsl.
As described previously, the Project site has previously undergone FAA evaluation, which determined that
structures on the site that are below 162 feet amsl would not have a significant adverse impact related to
aeronautical hazards (FAA, 2016). As the tallest building structure would be 92 feet amsl and the light poles
would be a maximum of 108 feet amsl, both would be below 162 feet amsl; therefore, the Project structures
would not have a significant adverse impact related to aeronautical hazards.
Aircraft Accident Hazards
Due to the prevailing ocean winds at SNA, the predominant direction of aircraft departing SNA is to the
southwest and aircraft arriving into SNA is from the northeast (about 95 percent of the time), the Project site
is mostly exposed to overflight by aircraft departing SNA to the southwest. Therefore, the accident risk over
the Project site is also predominantly from aircraft departing SNA.
As per accident trends, there is generally a lower rate of accidents that occur during takeoff (departure)
versus during landing (on approach). At SNA, 10 of the 66 accidents reported by the NTSB between 1982
and 2024 occurred during the takeoff phase of flight. All of those ten accidents, except for one, were
attributed to general aviation operations.
Using the accident data in the California Airport Land Use Planning Handbook and from the NTSB database
for SNA, the aircraft hazard assessment (Appendix M) developed a rough order of magnitude estimate of
accident risk at the Project site. Over the most recent ten-year period (2014-2024), SNA had 11 accidents
listed in the NTSB database. Two occurred during the takeoff or departure phase of the flight. During this
same time period there were over 3 million aircraft operations at SNA. This results in a risk rate of 0.067
accidents per 100,000 aircraft operations. Combining these two figures (0.3 accidents per year) provides
an estimate of the chances of an accident on the Project site as 0.035% per year. The additional factor that
aircraft typically depart to the southwest about 95 percent of the time brings the chances of an accident on
the Project site to 0.033% per year.
In terms of the annual risk to an individual on the Project site, if there is a 0.033% chance of an onsite
accident per year, and as per the California Airport Land Use Planning Handbook, approximately, 0.11%
of general aviation aircraft accidents result in fatalities to people on the ground, this yields a 0.000036%
chance of a fatality per year, or an approximate risk of 0.036 in 100,000 operations. Therefore, impacts
from potential aircraft accidents would be less than significant.
Airport Wildlife Hazards
The proposed surf lagoon would be a body of water that could have the potential to attract wildlife hazards.
Water in general, is considered a wildlife attractant. However, the wave lagoon would have no food sources
or resting or nesting sites like those found in an ocean or the nearby Upper Newport Bay ecological preserve.
Also, movement of staff, lifeguards, and surfers in the lagoon would reduce most of the risk associated with
attracting wildlife.
The SNA Geneal Aviation Noise Ordinance prohibits commercial departures between 10:00 p.m. and 7:00
a.m. (8:00 a.m. on Sundays) and commercial arrivals between 11:00 p.m. and 7:00 a.m. (8:00 a.m. on
Sundays). The proposed hours of operation for the surf lagoon are 6:00 a.m. to 11:00 p.m., 7 days a week.
The times that no commercial SNA departures and arrivals occur would coincide with the hours that the surf
park would be closed. Therefore, the lack of surfer, lifeguard, and water movement when the lagoon is
closed would not present a hazard due to birds who may be attracted to the times of limited movement and
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-41
Draft EIR
May 2025
standing/still water. In addition, as detailed in Section, 3.0, Project Description, and in PDF-2, the Project
would not include trees or other vegetation that produces seeds, fruits, nuts, or berries providing food for
birds that would be an attractant. Therefore, Project impacts related to generation of wildlife hazards to
airport operations would be less than significant.
Further, in reviewing the 66 accidents at SNA between 1982 and 2024, none were caused by a wildlife
strike. In reviewing the FAA’s wildlife strike database, there were 669 wildlife strike incidents reported for
SNA between 1990 and June 2024. There was a total of 305,523 wildlife strike incidents across airports
in the United States during the same time frame.
Airport Noise Hazards
As shown on Figure 5.8-2, the Project site is located within the SNA 65 CNEL noise contour as measured by
the airport in 2024, which indicates that noise from aircraft on the Project site is 65 dB CNEL and is within
the noise impact area related to SNA operations. As detailed in Section 5.11, Noise, the General Plan Land
Use Noise Compatibility Matrix, identifies that commercial recreation facilities are “normally compatible” up
to 75 dBA CNEL. Therefore, the proposed Project would be consistent with the 2024 noise contours, and
impacts related to excessive noise would be less than significant.
Also, as detailed in Section 5.10, Land Use and Planning, AELUP contains airport noise contours from 1985
(shown in Figure 5.10-3 in Section 5.10, Land Use and Planning), which identifies that a majority of the Project
site is located within the 65 dBA CNEL and a small area in the northeastern portion of the Project site that is
planned for parking and wave lagoon machinery is in the 70 dBA CNEL airport noise contour.
The AELUP for SNA states that community facilities and commercial land uses are “normally consistent” within
the 70 CNEL contour. Therefore, the proposed community related commercial recreation facilities that are
proposed for the site would be consistent with the AELUP aircraft noise land use planning. Thus, impacts
related to hazardous noise conditions from the operation of SNA would be less than significant.
Airport Other Hazards
The proposed Project would not result in hazards related to excessive glare, light, steam, smoke, dust, or
electronic interference. Exterior lighting fixtures and security lighting would be installed in accordance with
Municipal Code Section 20.30.070, which requires that all outdoor lighting fixtures be designed to shield
adjacent properties and roadways from glare.
The proposed parking canopies and building roofs would be covered in PV solar panels, as shown in Figure
3-11, Proposed Solar PV Installation. Solar PV reflections of sunlight glint and glare have the potential to
affect pilots’ vision, particularly on final approach to runways, and can also impact air traffic controllers’
vision when controlling aircraft near airports. Therefore, a solar glare analysis (included as Appendix N)
was prepared using an FAA developed a computer analysis tool to measure the potential impact of reflected
glint and glare from Solar PV installation.
The solar analysis modeling (included as Appendix N) was prepared based on the location of the
approximately 70,908 square feet of proposed rooftop and carport installed solar PV arrays and analyzed
the potential impacts of the proposed solar PV installation on John Wayne Airport operations. The analysis
determined that the proposed Project would not produce any glare on the air traffic control tower or in any
of the final approach areas to the runways at John Wayne Airport. Thus, the proposed solar panels would
not result in glare impacts to operation of SNA. In addition, the proposed Project would not use highly
reflective surfaces and does not include large areas of glass on the buildings, as shown in the Project
elevations, included in Chapter 3.0, Project Description. Therefore, the proposed Project would not generate
substantial sources of glare and impacts would be less than significant.
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-42
Draft EIR
May 2025
As described in Section 5.2, Air Quality, operation of the proposed commercial recreation uses would not
generate substantial quantities of smoke or dust emissions. As described, dust emissions are regulated by
SCAQMD requirements and construction related air quality emissions that could include steam, smoke, and
dust emissions would be less than significant with implementation of the standard SCAQMD Rules listed in
Section 5.2, Air Quality.
The proposed Project consists of a surf park that would include the use of typical electronics, such as
computers, televisions, screens at the lagoons, and other electronics with wireless capability. These types of
electronics are similar to those currently being used by the existing golf course and restaurant uses on the
site, and other uses in the vicinity of the site. The new surf park use on the site would use similar technology
that does not cause electronic interference that could affect aircraft. Thus, impacts related to electronic
interference with operations of the SNA would not occur.
The proposed Project would comply with this ALUC notification and all other applicable rules and regulations
as they pertain to SNA and airport safety. ALUCs are not implementing agencies in the manner of local
governments, and nor do they do not issue project permits. However, due to the nature of the required City
approvals (i.e., the proposed General Plan Amendment), the City of Newport Beach is required, pursuant to
Public Utilities Code Section 21676, to refer the proposed Project to the ALUC for ALUC review. If the project
is deemed inconsistent with the ALUC plan, a local government may override the ALUC decision by a two-
thirds vote of its governing body, if it makes specific findings that the proposed action is consistent with the
purposes stated in Section 21670(a)(2) of the Public Utilities Code: “to protect public health, safety, and
welfare by ensuring the orderly expansion of airports and the adoption of land use measures that minimize
the public’s exposure to excessive noise and safety hazards in areas around public airports to the extent
that these areas are not already devoted to incompatible uses.” Therefore, an inconsistency finding from the
ALUC for John Wayne Airport would not preclude the City from approving the Project and it being
implemented.
Overall, the proposed Project would not introduce a safety hazard associated with airport operations for
people residing, working, and visiting the Project site. Thus, Project-related hazard impacts associated with
SNA operations would be less than significant.
IMPACT HAZ-6: THE PROJECT WOULD NOT IMPAIR IMPLEMENTATION OF OR PHYSICALLY
INTERFERE WITH AN ADOPTED EMERGENCY RESPONSE PLAN OR EMERGENCY
EVACUATION PLAN.
No Impact. The City of Newport Beach adopted the City of Newport Beach Local Hazard Mitigation Plan,
prepared by the City of Newport Beach in 2016. The Local Hazard Mitigation Plan does not identify any
specific requirements for the Project site, nor is the site identified by the Plan as being part of an emergency
evacuation route, nor is the site directly adjacent to an emergency evacuation route. Irvine Boulevard, south
of 23rd Street, is the nearest designated tsunami evacuation route identified in the City’s Local Hazard
Mitigation Plan (City of Newport Beach, 2016).
The City has adopted and implemented programs to reduce and prevent risks associated with wildfire
including Municipal Code Section 2.20.050 (Emergency Operations Plan), Municipal Code Chapter 9.04
(Fire Code), and Municipal Code Chapter 15.04 (Building Code). Municipal Code Sections 9.04.110 through
9.04.160 require compliance with emergency access design standards as part of new construction of roads
to provide sufficient access for emergency equipment. The Fire Code also sets standards for road dimension,
design, grades, and other fire safety features. Although temporary lane closures on surrounding streets may
be required during short periods of the Project’s construction period in order to construct the Project and
connect the Project to the existing utility facilities within the existing roadways, the construction of the Project
would not require the complete closure of any public or private streets or roadways during construction. For
all temporary closures, which may include single lanes and sidewalk segments, the Project Applicant would
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-43
Draft EIR
May 2025
be required to obtain a Temporary Street and Sidewalk Closure Permit from the City of Newport Beach
Public Works Department. Therefore, there is no potential for the Project to impair implementation of or
physically interfere with an adopted emergency response plan or emergency evacuation plan. No impact
would occur.
IMPACT HAZ-7: THE PROJECT WOULD NOT EXPOSE PEOPLE OR STRUCTURES, EITHER DIRECTLY OR
INDIRECTLY, TO A SIGNIFICANT RISK OF LOSS, INJURY OR DEATH INVOLVING
WILDLAND FIRES.
Less than Significant. The Project site is located within an urban developed area and is not located within
an identified wildland fire hazard area and is not an area where residences are intermixed with wildlands.
The City’s GPU FEIR and the CalFire High Fire Hazard Severity Zones map shows that the site is located
within a low fire susceptibility area (City of Newport Beach, 2006b) (Cal Fire, 2024). In addition,
implementation of the proposed Project would be required to adhere to the following chapters of the City’s
Municipal Code to reduce potential fire hazards: Chapter 15.04 Uniform Building Code, Chapter 9.04.110
Fire Code, and Chapter 2.20.050 Emergency Operations Plan. Additionally, the proposed Project would be
developed in compliance with any further guidelines from the Fire Department related to fire prevention
and is subject to approval by the City’s Building Division. Therefore, the proposed Project would not expose
people or structures to a significant risk of loss, injury, or death from wildfires.
5.8.7 CUMULATIVE IMPACTS
The proposed Project’s contribution to cumulative impacts to hazards and hazardous was analyzed in context
with past and foreseeably future projects in the City of Newport Beach and adjacent areas in the Cities of
Costa Mesa and Irvine that are similarly affected by hazardous soil conditions, LUST conditions, asphalt
contamination, and asbestos and lead containing building materials. Cumulative redevelopment and land
use changes within the City would have the potential to expose future area residents, employees, and visitors
to chemical hazards through redevelopment of sites and structures that may be contaminated from either
historic or ongoing uses. The severity of potential hazards for individual projects would depend upon the
location, type, and size of development and the specific hazards associated with individual sites. As shown
on Figure 5-1, Cumulative Projects, in Section 5.0, Environmental Impact Analysis, the closest cumulative
development project is located across Orchard Drive at the easters corner of Orchard Drive and Southwest
Acacia Street, approximately 527 feet from the Project site. The cumulative project across Orchard Drive is
a renovation of the existing office building and addition of a parking garage and would not include
extensive redevelopment of the area. It is unlikely that similar construction activities involving hazardous
materials would occur simultaneously that could have the potential to cumulatively contribute to an impact.
All hazardous materials users and transporters, as well as hazardous waste generators and disposers are
subject to regulations that require proper transport, handling, use, storage, and disposal of such materials
to ensure public safety, which are verified by the City during the construction and development permitting
process. Thus, if hazardous materials are found to be present on present or future project sites appropriate
remediation activities would be required pursuant to standard federal, State, and regional regulations that
would reduce the potential for hazard related impacts to occur; and have the potential to cumulatively
combine. Further, Project compliance with the relevant federal, State, and local regulations during the
construction and operation would ensure that the Project would not result in impacts that have the potential
to cumulative. Thus, cumulative impacts related to hazardous materials and emergency response/evacuation
would be less than significant.
Regarding airport related hazards, as detailed previously, the proposed structures would not encroach into
any obstruction imaginary surfaces for SNA; therefore, they would not have the potential to cumulatively
result in aeronautical hazards. Likewise, exterior lighting would be installed in accordance with Municipal
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-44
Draft EIR
May 2025
Code Section 20.30.070 to not cumulatively combine, and the Project would comply with ALUC notification
and all other applicable rules and regulations as they pertain to SNA and airport safety. As a result,
cumulative impacts related to airport hazards would be less than significant.
5.8.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES
The following would reduce potential impacts related to hazards and hazardous materials.
Existing Regulations
• United States Code of Federal Regulations Title 42, Sections 6901 et seq.: Resource Conservation and
Recovery Act
• United States Code of Federal Regulations Title 42, Sections 11001 et seq.: Emergency Planning &
Community Right to Know Act
• United States Code of Federal Regulations Title 49, Parts 101 et seq.: Regulations implementing the
Hazardous Materials Transportation Act (United States Code of Federal Regulations Title 49 Sections
5101 et seq.)
• United States Code of Federal Regulations Title 15, Sections 2601 et seq.: Toxic Substances Control Act
• US Environmental Protection Agency Asbestos Hazard Emergency Response Act, 40 United States Code
of Regulations Section 763
• California Occupational Safety and Health Administration Regulation 29, CFR Standard 1926.62
• California Code of Regulations Title 24, Part 2: California Building Code
• California Code of Regulations Title 24, Part 9: California Fire Code
• California Code of Regulations Title 8, Section 1532.1: Lead in Construction Standard
• California Code of Regulations Title 8, Section 1529: Asbestos
• Title 8 of the California Code of Regulations, Section 1532.1: Lead
• Municipal Code Chapter 2.20, Emergency Services
• Municipal Code Chapter 9.04, Fire Code
• Municipal Code Chapter 15.55, Methane Overlay Zone
• Municipal Code Chapter 30, Section 080 (F), Airport Environs Land Use Plan
Plans, Programs, or Policies
The following Plans, Programs, and Policies (PPP) related to hazards and hazardous materials are
incorporated into the proposed Project and would reduce potential impacts. These actions will be included
in the proposed Project’s mitigation monitoring and reporting program (MMRP):
PPP HAZ-1: SCAQMD Rule 1403. Prior to issuance of demolition permits, the Project applicant shall submit
verification to the City Building and Safety Division that an asbestos survey has been conducted at all existing
buildings located on the Project site. If asbestos or asbestos containing material is found, the Project applicant
shall follow all procedural requirements and regulations of the South Coast Air Quality Management District
(SCAQMD) Rule 1403. Rule 1403 regulations require that the following actions be taken: notification of
SCAQMD prior to construction activity, asbestos removal in accordance with prescribed procedures,
placement of collected asbestos in leak-tight containers or wrapping, and proper disposal.
PPP HAZ-2: Lead. Prior to issuance of demolition permits, the Project applicant shall submit verification to
the City Building and Safety Division that a lead-based paint survey has been conducted at all existing
buildings located on the Project site. If lead-based paint is found, the Project applicant shall follow all
procedural requirements and regulations for proper removal and disposal of the lead-based paint.
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-45
Draft EIR
May 2025
CalOSHA has established limits of exposure to lead contained in dusts and fumes. Specifically, CCR Title 8,
Section 1532.1 provides for exposure limits, exposure monitoring, and respiratory protection, and mandates
good working practices by workers exposed to lead.
PPP WQ-1: SWPPP. As included in Section 5.9, Hydrology and Water Quality.
PPP WQ-3: WQMP. As included in Section 5.9, Hydrology and Water Quality.
5.8.9 PROJECT DESIGN FEATURES
The proposed Project includes the following PDF that reduces potential impacts related to hazards:
PDF-2 Vegetation: The proposed Project does not include landscaping or other vegetation that produces
seeds, fruits, nuts, or berries, such as fruit bearing trees and shrubs. Likewise, Project site areas would be
planted with seed mixtures that do not contain millet or any other large seed producing grass.
5.8.10 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Upon implementation of regulatory requirements Impacts HAZ-1, HAZ-2, HAZ-3, HAZ-4, HAZ-5, HAZ-6, and
HAZ-7 would be either less than significant or have no potential impact.
5.8.11 MITIGATION MEASURES
No mitigation measures are required.
5.8.12 LEVEL OF SIGNIFICANCE AFTER MITIGATION
No mitigation measures are required. Impacts would be less than significant with compliance with existing
regulations.
5.8.13 REFERENCES
CAL FIRE. (2024). Fire Hazard Severity Zone Viewer. Retrieved September 30, 2024 from
https://experience.arcgis.com/experience/03beab8511814e79a0e4eabf0d3e7247/.
Caltrans. (2011). California Airport Land Use Planning Handbook. Retrieved February 5, 2025 from
https://dot.ca.gov/-/media/dot-
media/programs/aeronautics/documents/californiaairportlanduseplanninghandbook-a11y.pdf
City of Newport Beach. (2001, January). Santa Ana Heights Specific Plan. Retrieved September 23, 2024,
from ocpublicworks.com.
City of Newport Beach. (2006a). General Plan. Retrieved September 23, 2024, from
newportbeachca.gov: https://www.newportbeachca.gov/government/departments/community-
development/planning-division/general-plan-codes-and-regulations/general-plan
City of Newport Beach. (2006b). General Plan Environmental Impact Report. Retrieved September 23,
2024, from newportbeachca.gov:
https://www.newportbeachca.gov/government/departments/community-development/planning-
division/general-plan-codes-and-regulations/general-plan/general-plan-environmental-impact-
report
Snug Harbor Surf Park Project 5.8 Hazards and Hazardous Materials
City of Newport Beach 5.8-46
Draft EIR
May 2025
City of Newport Beach. (2016). Local Hazards Mitigation Plan. Retrieved January 20, 2024 from
https://ecms.newportbeachca.gov/WEB/DocView.aspx?id=2867550&dbid=0&repo=CNB
City of Newport Beach. (2024, May). Newport Beach Municipal Code. Retrieved September 23, 2024,
from codepublishing.com: https://www.codepublishing.com/CA/NewportBeach/
Federal Aviation Administration (FAA). (2016). Aeronautical Study No. 2016-AWP-5961-OE, July 19,
2016.
Federal Aviation Administration (FAA). (2020). Advisory Circular 150/5200-33C - Hazardous Wildlife
Attractants on or near Airports. Retrieved on February 6, 2025, from:
https://www.faa.gov/airports/resources/advisory_circulars/index.cfm/go/document.information/
documentID/1037215
John Wayne Airport. (n.d.). General Aviation Noise Ordinance. Retrieved on March 4, 2025 from
https://www.ocair.com/about/administration/access-noise/reports-resources/
Johnson Aviation, Inc. (2024a). Aircraft Hazard and Land Use Risk Assessment & Wildlife Hazard
Management Analysis. (Appendix M)
Johnson Aviation, Inc. (2024b). Solar Glare Analysis – Solar Photovoltaic (PV) Installation – Snug Harbor
Project. (Appendix N)
Orange County Airport Land Use Commission (OCALUC). (2008). Airport Environs Land Use Plan for John
Wayne Airport. Retrieved January 25, 2024 from https://files.ocair.com/media/2021-
02/JWA_AELUP-April-17-2008.pdf?VersionId=cB0byJjdad9OuY5im7Oaj5aWaT1FS.vD
Orion Environmental Inc., (2024a). Phase I Environmental Site Assessment. (Appendix K).
Orion Environmental Inc., (2024b). Phase II Environmental Site Assessment. (Appendix L).
Snug Harbor Surf Park Project 5.9 Hydrology and Water Quality
City of Newport Beach 5.9-1
Draft EIR
May 2025
5.9 Hydrology and Water Quality
5.9.1 INTRODUCTION
This section describes the hydrology and water quality conditions in the Project region and potential impacts
from Project implementation. The analysis in this section is based, in part, on the following documents and
resources.
• City of Newport Beach General Plan, 2006
• City of Newport Beach General Plan Environmental Impact Report (General Plan EIR), 2006
• City of Newport Beach Municipal Code
• Geotechnical Exploration, prepared by Carl Kim Geotechnical, Inc., 2024, included as Appendix H
• Preliminary Water Quality Management Plan (WQMP), prepared by Fuscoe Engineering, Inc., 2024,
included as Appendix O
• Preliminary Hydrology Report, prepared by Fuscoe Engineering, Inc., 2024, included as Appendix P
• Water Supply Evaluation, prepared by Fuscoe Engineering, Inc., 2024, included as Appendix S
5.9.2 REGULATORY SETTING
5.9.2.1 Federal Regulations
Clean Water Act
The Clean Water Act established the basic structure for regulating discharges of pollutants into “waters of
the U.S.” The Act specifies a variety of regulatory and non-regulatory tools to sharply reduce direct pollutant
discharges into waterways, finance municipal wastewater treatment facilities, and manage polluted runoff.
Key components of the Clean Water Act that are relevant to the Project are:
• Sections 303 and 304, which provide water quality standards, criteria, and guidelines. Section 303(d)
requires the state to develop lists of water bodies that do not attain water quality objectives (are
impaired) after implementation of required levels of treatment by point-source dischargers
(municipalities and industries). Section 303(d) also requires that the state develop a Total Maximum
Daily Loads for each of the listed pollutants. The Total Maximum Daily Load is the amount of pollutant
loading that the water body can receive and still be in compliance with water quality objectives. After
implementation of the Total Maximum Daily Load, it is anticipated that the contamination that led to the
303(d) listing would be remediated. Preparation and management of the Section 303(d) list is
administered by the Regional Water Quality Control Boards (RWQCBs).
• Section 401 requires activities that may result in a discharge to a federal water body to obtain a water
quality certification to ensure that the proposed activity would comply with applicable water quality
standards.
• Section 402 regulates point- and nonpoint-source discharges to surface waters through the National
Pollutant Discharge Elimination System (NPDES) program. In California, the State Water Resources
Control Board (SWRCB) oversees the NPDES program, which is administered by the local RWQCBs. The
NPDES program provides both general permits (those that cover a number of similar or related activities)
and individual permits.
Snug Harbor Surf Park Project 5.9 Hydrology and Water Quality
City of Newport Beach 5.9-2
Draft EIR
May 2025
National Pollutant Discharge Elimination System
The NPDES Permit program under the Clean Water Act controls water pollution by regulating point- and
nonpoint-sources that discharge pollutants into “waters of the U.S.” California has an approved state NPDES
program. The United States Environmental Protection Agency (USEPA) has delegated authority for NPDES
permitting to the SWRCB, which has nine regional boards. The Santa Ana RWQCB regulates water quality
in the City of Newport Beach. Discharge of stormwater runoff from construction areas of one acre or more
requires either an individual permit issued by the RWQCB or coverage under the statewide Construction
General Stormwater Permit for stormwater discharges (discussed below). Specific industries and public
facilities, including wastewater treatment plants that have direct stormwater discharges to navigable waters,
are also required to obtain either an individual permit or obtain coverage under the statewide General
Industrial Stormwater Permit.
5.9.2.2 State Regulations
Porter-Cologne Act
The Porter-Cologne Water Quality Control Act of 1969, codified as Division 7 of the California Water
Code, authorizes the SWRCB to provide comprehensive protection for California’s waters through water
allocation and water quality protection. The SWRCB implements the requirements of the Clean Water Act
and establishes water quality standards that have to be set for certain waters by adopting water quality
control plans under the Porter-Cologne Act. The Porter-Cologne Act establishes the responsibilities and
authorities of the nine RWQCBs, including preparing water quality plans for areas in the region, and
identifying water quality objectives and waste discharge requirements. Water quality objectives are
defined as limits or levels of water quality constituents and characteristics established for reasonable
protection of beneficial uses or prevention of nuisance. Beneficial uses consist of all the various ways that
water can be used for the benefit of people and/or wildlife.
The City of Newport Beach is within the Santa Ana River Basin, Region 8, in the San Diego Creek sub-
watershed. The Water Quality Control Plan for this region was adopted in 1995. This Basin Plan gives
direction on the beneficial uses of the state waters within Region 8, describes the water quality that must be
maintained to support such uses, and provides programs, projects, and other actions necessary to achieve
the established standards.
California Anti-Degradation Policy
A key policy of California’s water quality program is the State’s Anti-Degradation Policy. This policy,
formally known as the Statement of Policy with Respect to Maintaining High Quality Waters in California
(SWRCB Resolution No. 68-16), restricts degradation of surface and ground waters. In particular, this policy
protects water bodies where existing quality is higher than necessary for the protection of beneficial uses.
Under the Anti-Degradation Policy, any actions that can adversely affect water quality in all surface and
ground waters must (1) be consistent with maximum benefit to the people of the state; (2) not unreasonably
affect present and anticipated beneficial use of the water; and (3) not result in water quality less than that
prescribed in water quality plans and policies (i.e., will not result in exceedances of water quality
objectives).
California Construction General Permit
The State of California adopted a Statewide NPDES Permit for General Construction Activity (Construction
General Permit) on September 2, 2009 (Order No. 2009-0009-DWQ, as amended by 2010-0014-DWQ,
2012-0006-DWQ, and 2022-0057-DWQ). The latest Construction General Permit amendment became
Snug Harbor Surf Park Project 5.9 Hydrology and Water Quality
City of Newport Beach 5.9-3
Draft EIR
May 2025
effective September 1, 2023. The Construction General Permit regulates construction site stormwater
management. Dischargers whose projects disturb one or more acres of soil, or whose projects disturb less
than one acre, but are part of a larger common plan of development that in total disturbs one or more acres,
are required to obtain coverage under the Construction General Permit for discharges of stormwater
associated with construction activity. Construction activity subject to this permit includes clearing, grading,
and disturbances to the ground, such as stockpiling or excavation, but does not include regular maintenance
activities performed to restore the original line, grade, or capacity of the facility.
To obtain coverage under this permit, project operators must electronically file Permit Registration
Documents, which include a Notice of Intent, a Stormwater Pollution Prevention Plan (SWPPP), and other
compliance-related documents, including a risk-level assessment for construction sites, an active stormwater
effluent monitoring and reporting program during construction, rain event action plans, and numeric action
levels for pH and turbidity, as well as requirements for qualified professionals to prepare and implement
the plan.
The Construction General Permit requires project applicants to file a Notice of Intent with the SWRCB to
discharge stormwater, and to prepare and implement a SWPPP for projects that disturb one or more acres
of soil. The SWPPP would include a site map, description of stormwater discharge activities, and best
management practices (BMPs) taken from the menu of BMPs set forth in the California Stormwater Quality
Association (CASQA) BMP Handbook that will be employed to prevent water pollution. It must describe BMPs
that will be used to control soil erosion and discharges of other construction-related pollutants (e.g., petroleum
products, solvents, paints, cement) that could contaminate nearby water bodies. It must demonstrate
compliance with local and regional erosion and sediment control standards, identify responsible parties,
provide a detailed construction timeline, and implement a BMP monitoring and maintenance schedule. The
Construction General Permit requires the SWPPP to identify BMPs that will be implemented to reduce
controlling potential chemical contaminants from impacting water quality. Types of BMPs include erosion
control (e.g., preservation of vegetation), sediment control (e.g., fiber rolls), non-stormwater management
(e.g., water conservation), and waste management. The SWPPP also includes descriptions of BMPs to reduce
pollutants in stormwater discharges after all construction phases have been completed at the site (post-
construction BMPs).
California Water Resources Control Board Low Impact Development Policy
The SWRCB adopted the Low Impact Development Policy which, at its core, promotes the idea of
“sustainability” as a key parameter to be prioritized during the design and planning process for future
development. The SWRCB has directed its staff to consider sustainability in all future policies, guidelines,
and regulatory actions. The Low Impact Development Policy is a proven approach to manage stormwater.
The RWQCBs are advancing Low Impact Development in California in various ways, including provisions for
Low Impact Development requirements in renewed NPDES Phase I Municipal Separate Storm Sewer System
(MS4) permit.
5.9.2.3 Local and Regional Regulations
Santa Ana Regional Water Quality Control Board Water Quality Control Plan (Basin Plan)
The City of Newport Beach is within the jurisdiction of the Santa Ana RWQCB. The RWQCB sets water quality
standards for all ground and surface waters within its region through implementation of a Water Quality
Control Plan (Basin Plan). The Basin Plan describes existing water quality conditions and establishes water
quality goals and policies. The Basin Plan is also the basis for the Regional Board’s regulatory programs. To
this end, the Basin Plan establishes water quality standards for all the ground and surface waters of the
region. The term “water quality standards,” as used in the Federal Clean Water Act, includes both the
Snug Harbor Surf Park Project 5.9 Hydrology and Water Quality
City of Newport Beach 5.9-4
Draft EIR
May 2025
beneficial uses of specific water bodies and the levels of quality which must be met and maintained to
protect those uses. The Basin Plan includes an implementation plan describing the actions that are necessary
to achieve and maintain target water quality standards. The Santa Ana Basin Plan has been in place since
1995, (with updates in 2008, 2011, 2016, and 2019) with the goal of protecting public health and welfare
and maintaining or enhancing water quality potential beneficial uses of the water.
Santa Ana Regional Municipal Separate Storm Sewer System Permit
The Municipal Separate Storm Sewer System (MS4) Permit for the Santa Ana Region, NPDES Permit No.
CAS618030 (Order R8-2009-0030 as amended by Order No. R8-2010-0062) regulates urban runoff
from areas under jurisdiction of the Permit’s various permittees, which include Orange County, Orange
County Flood Control District, and the incorporated cities within Orange County including the City of Newport
Beach. When discharged, urban runoff (or stormwater) has the potential to mix with and carry various
pollutants into receiving waters. The MS4 Permit lists allowable and unallowable discharges and requires
implementation of LID infrastructure, which are engineered facilities that are designed to retain and/or
biotreat runoff on the project site. Developments that qualify as a development or redevelopment project,
which includes the proposed project as specified by criteria in the MS4 Permit, are required to develop a
site specific water quality management plan (WQMP), which includes site design, source control and
treatment control elements to reduce the discharge of pollutants in runoff. The WQMP is required to be
approved prior to the issuance of a building or grading permit, and post-construction BMPs are required to
be implemented. The MS4 Permit requires priority projects to infiltrate, harvest and use, evapotranspire, or
biotreat/biofilter, the 85th percentile of a 24-hour storm event (Design Capture Volume). The MS4 Permit
also requires the evaluation and use of LID features using the following hierarchy of treatment: infiltration,
evapotranspiration, harvest/reuse, and biotreatment.
Biotreatment BMPs are a broad class of LID BMPs that reduce stormwater volume to the maximum extent
practicable, treat stormwater using a suite of treatment mechanisms characteristic of biologically active
systems, and discharge water to the downstream storm drain system or directly to receiving waters.
Treatment mechanisms include media filtration (though biologically-active media), vegetative filtration
(straining, sedimentation, interception, and stabilization of particles resulting from shallow flow through
vegetation), general sorption processes (i.e., absorption, adsorption, ion exchange, precipitation, surface
complexation), biologically-mediated transformations, and other processes to address both suspended and
dissolved constituents. Examples of biotreatment BMPs include bioretention with underdrains, vegetated
swales, constructed wetlands, and proprietary biotreatment systems.
Santa Ana Regional Water Quality Control Board Dewatering Permit
On December 6, 2019, the Santa Ana RWQCB issued the General Waste Discharge Requirements for
Discharges to Surface Waters Resulting from De Minimis Discharges or Groundwater Dewatering
Operations, and/or Groundwater Cleanup/Remediation Operations at Sites within the Newport Bay
Watershed Permit (Newport Bay, NPDES No. CAG918002) (Groundwater Discharge Permit). This Permit
regulates construction dewatering and discharges of groundwater to surface waters during excavation. This
permit specifies the discharge prohibitions, receiving water limitations, monitoring and reporting program
requirements, and general compliance determination criteria for groundwater dewatering during
construction activities. Dischargers are required to collect and analyze representative groundwater samples
for all constituents listed in the Groundwater Discharge Permit. Based on the results, dischargers would be
required to provide treatment for any toxic compounds detected above the applicable screening levels. To
obtain coverage under the Groundwater Discharge Permit, each permittee must submit a Notice of Intent to
begin the application process.
Snug Harbor Surf Park Project 5.9 Hydrology and Water Quality
City of Newport Beach 5.9-5
Draft EIR
May 2025
County of Orange Drainage Area Management Plan
The Drainage Area Management Plan (DAMP) is the primary policy, planning and implementation document
for NPDES Stormwater Permit compliance throughout Orange County, including the City of Newport Beach.
The DAMP describes the agreements, structures and programs that:
• Provide the framework for the program management activities and plan development;
• Provide the legal authority for prohibiting unpermitted discharges into the storm drain system and for
requiring BMPs in new development and significant redevelopment;
• Ensure that all new development and significant redevelopment incorporates appropriate Site Design,
Source Control, and Treatment Control BMPs to address specific water quality issues;
• Ensure that construction sites implement control practices that address construction related pollutants
including erosion and sediment control and onsite hazardous materials and waste management.
The DAMP requires that new development and significant redevelopment projects (or priority projects), such
as the proposed Project, develop and implement a Preliminary WQMP that includes BMPs and LID design
features that would provide onsite treatment of stormwater to prevent pollutants from onsite uses from
leaving the site.
City of Newport Beach General Plan 2006
The City of Newport Beach General Plan 2006 contains the following policies related to hydrology and
water quality that are applicable to the Project:
LU 2.8 Adequate Infrastructure. Accommodate the types, densities, and mix of land uses that can
be adequately supported by transportation and utility infrastructure (water, sewer, storm
drainage, energy, and so on) and public services (schools, parks, libraries, seniors, youth,
police, fire, and so on).
NR 1.1 Water Conservation in New Development. Enforce water conservation measures that limit
water usage, prohibit activities that waste water or cause runoff, and require the use of
water–efficient landscaping and irrigation in conjunction with new construction projects.
NR 1.2 Use of Water Conserving Devices. Establish and actively promote use of water conserving
devices and practices in both new construction and major alterations and additions to
existing buildings. This can include the use of rainwater capture, storage, and reuse facilities.
NR 3.4 Storm Drain Sewer System Permit. Require all development to comply with the regulations
under the City’s municipal separate storm drain system permit under the National Pollutant
Discharge Elimination System.
NR 3.5 Natural Water Bodies. Require that development does not degrade natural water bodies.
Require new development applications to include a Water Quality Management Plan
(WQMP) to minimize runoff from rainfall events during construction and post-construction.
NR 3.9 Water Quality Management Plan. Require new development applications to include a
Water Quality Management Plan (WQMP) to minimize runoff from rainfall events during
construction and post-construction.
NR 3.10 Best Management Practices. Implement and improve upon Best Management Practices
(BMPs) for residences, businesses, development projects, and City operations.
Snug Harbor Surf Park Project 5.9 Hydrology and Water Quality
City of Newport Beach 5.9-6
Draft EIR
May 2025
NR 3.11 Site Design and Source Control. Include site design and source control BMPs in all
developments. When the combination of site design and source control BMPs are not
sufficient to protect water quality as required by the National Pollutant Discharge
Elimination System (NPDES), structural treatment BMPs will be implemented along with site
design and source control measures.
NR 3.12 Reduction of Infiltration. Include equivalent BMPs that do not require infiltration, where
infiltration of runoff would exacerbate geologic hazards.
NR 3.14 Runoff Reduction on Private Property. Retain runoff on private property to prevent the
transport of pollutants into natural water bodies, to the maximum extent practicable.
NR 3.15 Street Drainage Systems. Require all street drainage systems and other physical
improvements created by the City, or developers of new subdivisions, to be designed,
constructed, and maintained to minimize adverse impacts on water quality. Investigate the
possibility of treating or diverting street drainage to minimize impacts to water bodies.
NR 3.16 Siting of New Development. Require that development be located on the most suitable
portion of the site and designed to ensure the protection and preservation of natural and
sensitive site resources that provide important water quality benefits.
NR 3.19 Natural Drainage Systems. Require incorporation of natural drainage systems and
stormwater detention facilities into new developments, where appropriate and feasible, to
retain stormwater in order to increase groundwater recharge.
NR 3.20 Impervious Surfaces. Require new development and public improvements to minimize the
creation of and increases in impervious surfaces, especially directly connected impervious
areas, to the maximum extent practicable. Require redevelopment to increase area of
pervious surfaces, where feasible.
NR 4.3 Restore Natural Hydrologic Conditions. Preserve, or where feasible, restore natural
hydrologic conditions such that downstream erosion, natural sedimentation rates, surface
flow, and groundwater recharge function near natural equilibrium states.
S 5.3 Minimization of Flood Mazard Risk. Require stormwater detention basins, where
appropriate, to reduce the potential risk of flood hazards.
City of Newport Beach Municipal Code
Chapter 14.17 Water Efficient Landscape Requirement. This municipal code establishes standards for water
efficiency without waste by setting maximum applied water allowances and to encourage economic
incentives to promote efficient use of landscaping water.
Chapter 14.36 Water Quality. This municipal code addresses improvements to water quality to comply with
federal requirements for the control of urban pollutants to storm water runoff and requires that all new
development within the City shall be completed in accordance with the DAMP and conditions identified by
the City to reduce or eliminate pollutants in stormwater runoff.
Snug Harbor Surf Park Project 5.9 Hydrology and Water Quality
City of Newport Beach 5.9-7
Draft EIR
May 2025
5.9.3 ENVIRONMENTAL SETTING
5.9.3.1 Watershed
The Project site is in the Santa Ana River Watershed and in the San Diego Creek sub-watershed. The Santa
Ana River Watershed includes much of Orange County, much of western Riverside County, part of
southwestern San Bernardino County, and a small portion of Los Angeles County. The watershed is bounded
on the south by the Santa Margarita watershed, on the east by the Salton Sea and Southern Mojave
watersheds, and on the north and west by the Mojave and San Gabriel watersheds, respectively. The
watershed covers approximately 2,800 square miles in area with about 700 miles of rivers. The Santa Ana
River extends over 100 miles from the San Bernardino Mountains in San Bernardino County to the Pacific
Ocean at the boundary between the Cities of Huntington Beach and Newport Beach.
The Santa Ana Watershed is subdivided into several smaller watersheds, and as mentioned above, the
Project site is in the San Diego Creek sub-watershed. The San Diego Creek sub-watershed spans 112.2
square miles in central Orange County, with its main tributary, San Diego Creek, draining into Upper
Newport Bay. Smaller tributaries of this watershed include Serrano Creek, Borrego Canyon Wash, Agua
Chinon Wash, Bee Canyon Wash, Peters Canyon Wash, Sand Canyon Wash, Bonita Canyon Creek, and the
Santa Ana Delhi Channel.
The Project site drains to the Santa Ana–Delhi Channel and then to the Upper Newport Back Bay.
Watershed Impairments. Section 303(d) of the Federal CWA requires states to identify water bodies that
are “impaired,” or those that do not meet water quality standards and are not supporting their beneficial
uses. Total Maximum Daily Loads (TMDLs) are then designed to serve as pollution control plans for these
specific pollutants.
The Upper and Lower Newport Back Bay are included on the Section 303(d) List of Water Quality
Impairments for: chlordane, copper, DDT, nutrients, PCBs, sedimentation, malathion, toxicity, and indicator
bacteria (Appendix O).
5.9.3.2 Groundwater Basin
The Project site is located within the Coastal Plain of Orange County Groundwater Basin No. 8-001. The
Coastal Plain of Orange County basin underlies a coastal alluvial plain in northwestern Orange County. The
basin is bounded on the northwest and the north by the Los Angeles-Orange County line; on the northeast
by the Whittier fault zone and consolidated rocks of the Puente Hills and Chino Hills; on the east by
consolidated rocks of the Santa Ana Mountains; on the south by consolidated rocks of the Laguna Hills and
San Joaquin Hills; and on the southwest by the Pacific Ocean. As described in the Phase I Environmental Site
Assessment, the groundwater basin is located in the lower Santa Ana River Watershed (Appendix K).
The Orange County Water District (OCWD) manages the Orange County Basin through a Basin Production
Percentage (BPP) that is determined each water year based on groundwater conditions, availability of
imported water supplies, water year precipitation, Santa Ana River runoff, and basin management
objectives. While there is no legal limit as to how much an agency pumps from the Orange County Basin,
there is a financial disincentive to pump above the BPP. For example, if the BPP is set at 75 percent, all
pumpers within the Basin, including the City, can supply 75 percent of their water needs from groundwater
supplies at a cost significantly less than the cost of imported water. If groundwater production is equal to or
less than the BPP (i.e., less than 75 percent in the example above), all producers within the Basin pay a
replenishment assessment (RA) fee which is used to fund groundwater replenishment and recharge programs
aimed at ensuring the long-term viability and stability of the Basin. In the 2021-22 water year, the BPP was
Snug Harbor Surf Park Project 5.9 Hydrology and Water Quality
City of Newport Beach 5.9-8
Draft EIR
May 2025
77 percent. The 2020 Newport Beach Urban Water Management Plan (UWMP) describes that OCWD
anticipates being able to sustain the BPP at 85 percent starting in 2025 (City of Newport Beach, 2021).
5.9.3.3 Groundwater Supply
The City of Newport Beach 2020 UWMP describes that the City produces potable groundwater from the
Orange County Groundwater Basin, which is managed by the OCWD. The Basin is classified as a medium
priority basin, due to the regional reliance on the Basin’s groundwater supplies. The Basin is not currently
experiencing overdraft conditions. The City pumps groundwater through four wells found in the City.
The City’s access to groundwater allows the City to shift its reliance to groundwater during single dry years
and consecutive dry years. The local groundwater basins act as a large reservoir, storing water during wet
years and allowing the City to meet its demands during dry periods.
The golf course is currently irrigated via well water. The Water Supply Evaluation (Appendix S) prepared
for the Project, estimates that irrigation water usage for the three golf course holes that would be eliminated
by the Project is approximately 15,299 gallons per day (GPD) or 17.14 acre-feet per year (AFY) of
groundwater.
5.9.3.4 Groundwater Conditions
Per the Preliminary Geotechnical Exploration (Appendix H), the highest historic groundwater at the site has
been mapped at a depth of about 10 feet below ground surface (bgs). Groundwater in May 2024 was
encountered between a depth of 14 feet and 20 feet bgs.
5.9.3.5 Storm Drain Facilities
The Santa Ana – Delhi Channel, maintained by the Orange County Flood Control District (OCFCD), is a 55-
foot-wide by 16-foot-high reinforced-concrete storm drain channel that runs in a southerly direction, along
the westerly boundary of the site along Irvine Avenue.
As described in the Hydrology Report (included as Appendix P), currently 3.4 acres of the site (22 percent)
is impervious, as most of the site consists of three holes of the golf course that is covered in grass and trees.
The topography of the site slopes in a northwesterly direction, toward OCFCD’s Santa Ana – Delhi Channel
and Irvine Avenue. An existing 15- to 20-foot-high slope descends from the southeast boundary of the site.
The remainder of the site generally slopes more gently toward the westerly boundary of the Project. There
are currently five drainage discharge points to the Santa Ana – Delhi Channel at or within the site. Two
points in Irvine Avenue where drainage is conveyed to catch basins and then discharged into the Sana Ana
– Delhi Channel, and three pipes that discharge directly to the Santa Ana – Delhi Channel (Appendix P).
There is currently offsite drainage from properties located along the easterly boundary of the Project site
that conveys to the golf course via surface gutter or pipes. The drainage is conveyed through the golf course,
combines with the onsite drainage, and then discharges into the Santa Ana – Delhi Channel (Appendix P).
The Santa Ana-Delhi Channel flows are conveyed to the Upper and Lower Newport Bay.
5.9.3.6 Soil Infiltration
The Geotechnical Exploration (Appendix H) describes that due to shallow groundwater and the presence of
thick clay layers underlying the Project site, soils are expected to have very low to no permeability, making
stormwater infiltration infeasible.
Snug Harbor Surf Park Project 5.9 Hydrology and Water Quality
City of Newport Beach 5.9-9
Draft EIR
May 2025
5.9.3.7 Flood Zone, Tsunami, Seiche
According to the Flood Insurance Rate Map (FIRM), published by the Federal Emergency Management
Agency (FEMA) (06059C0267J), the Project site is within a “0.2 Percent Annual Chance Flood Hazard, Zone
X” flood plain area defined as areas of 1 percent annual chance flood with average depth less than one
foot or with drainage areas of less than one square mile. In addition, Zone X flood plain areas are outside
the 100-year floodplain.
A tsunami is a series of ocean waves caused by a sudden displacement of the ocean floor, most often due
to earthquakes. The Project site is over 4.2 miles from the Pacific Ocean, and adjacent to, but outside of the
Tsunami Hazard Zone identified by the California Department of Conservation (DOC, 2023).
A seiche is a surface wave created when a body of water is shaken, usually by earthquake activity. Seiches
are of concern relative to water storage facilities because inundation from a seiche can occur if the wave
overflows a containment wall, such as the wall of a reservoir, water storage tank, dam, or other artificial
body of water. There are no water bodies in the vicinity of the Project site, and no existing risks related to
seiche flood hazards exist on or near the site.
5.9.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of the CEQA Guidelines indicates that a Project could have a significant effect if it were to:
HYD-1 Violate any water quality standards or waste discharge requirements or otherwise substantially
degrade surface or ground water quality.
HYD-2 Substantially decrease groundwater supplies or interfere substantially with groundwater recharge
such that the project may impede sustainable groundwater management of the basin.
HYD-3 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 result in a substantial erosion or siltation on- or off-site.
HYD-4 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 substantially increase the rate or amount of surface runoff in a manner which
would result in flooding on- or offsite.
HYD-5 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 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.
HYD-6 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 impede or redirect flood flows.
HYD-7 In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation.
HYD-8 Conflict with or obstruct implementation of a water quality control plan or sustainable
groundwater management plan.
Snug Harbor Surf Park Project 5.9 Hydrology and Water Quality
City of Newport Beach 5.9-10
Draft EIR
May 2025
5.9.5 METHODOLOGY
This evaluation of the significance of potential impacts related to hydrology and water quality is based on
a review of published information and reports regarding regional hydrology and surface water quality. The
potential impacts on hydrology and water quality were evaluated by considering the general type of
pollutants that the Project would generate during construction and operation. In determining the level of
significance, the analysis recognizes that development under the proposed Project would be required to
comply with relevant federal, State, and regional laws and regulations that are designed to ensure
compliance with applicable water quality standards and waste discharge requirements. The regional and
local regulations related to water quality standards have been developed to reduce the potential of
pollutants in the water resources (as described in Section 5.9.2, Regulatory Setting, above), and are
implemented to specific waterbodies, such as 303(d) TMDL requirements, or development projects such as
grading and construction permit regulations to reduce hydrology and water quality impacts.
5.9.6 ENVIRONMENTAL IMPACTS
IMPACT HYD-1: THE PROJECT WOULD NOT VIOLATE ANY WATER QUALITY STANDARDS OR WASTE
DISCHARGE REQUIREMENTS OR OTHERWISE SUBSTANTIALLY DEGRADE SURFACE
OR GROUND WATER QUALITY.
Less than Significant Impact.
Construction
The nearest surface water to the Project site is the Santa Ana-Delhi Channel that is adjacent to the site. Santa
Ana-Delhi Channel is the main receiving water for the Project site and is not classified as an impaired water
body and has not been placed on the 303(d) list. However, the Santa Ana-Delhi Channel conveys flows into
the Upper and Lower Newport Bay that is on the 303(d) list of impairments for nutrients, as detailed
previously.
The Project proposes construction of a commercial recreation surf park with a 5.06-acre (220,427 SF) surf
lagoon, amenity clubhouse building, athlete accommodation, associated internal driveways and drive aisles,
parking, landscaping, utility connections, stormwater infrastructure, and sidewalks. Implementation of the
Project would include demolition of the existing golf course facilities and buildings, site preparation, grading,
and construction of the surf lagoon, new buildings, and infrastructure on the Project site. Grading, stockpiling
of materials, excavation and the import/export of building materials, construction of new structures, and
landscaping activities would expose and loosen sediment and building materials, which may have the
potential to mix with stormwater and urban runoff and degrade surface and receiving water quality.
Additionally, construction generally requires the use of heavy equipment and construction-related materials
and chemicals, such as concrete, cement, asphalt, fuels, oils, antifreeze, transmission fluid, grease, solvents,
and paints. In the absence of proper controls, these potentially harmful materials could be accidentally
spilled or improperly disposed of during construction activities and could wash into and pollute surface
waters or groundwater, resulting in a significant impact to water quality.
Pollutants of concern during construction activities generally include sediments, trash, petroleum products,
concrete waste (dry and wet), sanitary waste, and chemicals. Each of these pollutants on its own or in
combination with other pollutants can have a detrimental effect on water quality. In addition, chemicals,
liquid products, petroleum products (such as paints, solvents, and fuels), and concrete-related waste may be
spilled or leaked during construction, which would have the potential to be transported via storm runoff into
nearby receiving waters and eventually may affect surface or groundwater quality. During construction
Snug Harbor Surf Park Project 5.9 Hydrology and Water Quality
City of Newport Beach 5.9-11
Draft EIR
May 2025
activities, excavated soil would be exposed, thereby increasing the potential for soil erosion and
sedimentation to occur compared to existing conditions. In addition, during construction, vehicles and
equipment are prone to tracking soil and/or spoil from work areas to paved roadways, which is another
form of erosion that could affect water quality. However, the use of Best Management Practices (BMPs)
during construction implemented as part of a SWPPP as required by the City of Newport Beach and the
MS4 permit would serve to ensure that Project impacts related to construction activities resulting in a
degradation of water quality would be less than significant. Compliance with these requirements included
as PPP WQ-1 would be verified during the City’s construction permitting process to ensure that impacts
related to construction activities resulting in a degradation of water quality would be less than significant.
Operation
Project operations would introduce the potential for pollutants such as chemicals from lagoon chlorine
products, cleaning products, pesticides, sediment from landscaping, trash and debris, and oil and grease
from vehicles in the parking lots. As described previously, the Upper and Lower Newport Back Bay, to which
the Project site ultimately drains, are listed as impaired on the USEPA’s 303(d) list for various pollutants.
Therefore, additional pollutant discharge could create new or exacerbate existing impairments within these
waterbodies, which could result in a significant impact related to water quality. In accordance with State
Water Resources Board Order R8-2010-0062, NPDES No. CAS618030, the proposed Project would be
required to incorporate a WQMP with post-construction (or permanent) Low Impact Development (LID) site
design, source control, and treatment control BMPs, included as PPP WQ-3. As stated in the Project WQMP,
(Appendix O) the Santa Ana Regional MS4 Permit and Orange County DAMP was used as a guide for the
design of drainage facilities and to establish criteria for water quality for the Project. In addition, the Orange
County Hydrology Manual was used for hydrological data (Appendix P).
The two surf lagoon basins would be drained once every two years into the sewer system, alternating
between basins. One of the surf basins would be drained annually, facility maintenance would occur, and
then the basin would be refilled. This process would be coordinated via permit with the Costa Mesa Sanitary
District (CMSD) that provides sewer services to the site, and the City of Newport Beach Utilities Department
that provides water to the Project site. Therefore, because the basin water would drain directly to the sewer
system, no impacts to surface water or groundwater would occur as part of operation and maintenance of
the surf lagoons.
The MS4 Permit identifies the use of infiltration BMPs to assist in recharge of groundwater. However, as
described previously, the onsite soils have a low infiltration rate and are considered infeasible to support
drainage on the Project site (Appendix O). Therefore, the proposed Project would install vegetated
biotreatment systems for water quality treatment via bio-filtration that have been sized to treat runoff from
the Design Capture Storm (85th percentile, 24-hour) from the proposed Project. The vegetated biotreatment
systems are devices that are manufactured to mimic natural systems such as bioretention areas by
incorporating plants, soil, and microbes engineered to provide treatment at higher flow rates or volumes
and with smaller footprints than their natural counterparts.
The vegetated biotreatment systems proposed for the Project consist of Modular Wetlands Systems that
utilize multi-stage treatment processes including screening media filtration, settling, and biofiltration. The
pre-treatment chamber contains a filter to capture trash, debris, gross solids and sediments, a settling
chamber for separating out larger solids, and a media filter cartridge for capturing fine silts, metals,
nutrients, and bacteria. Runoff then flows through the wetland chamber where treatment of the water is done
through a variety of physical, chemical, and biological processes. As stormwater passes down through the
planting soil, pollutants are filtered, absorbed, biodegraded, and sequestered by the soil and plants,
functioning similar to bioretention systems. Similar to existing conditions, the offsite runoff would continue to
be collected on the Project site and flow northwest through the proposed northern parking lot and eventually
into the Santa Ana-Delhi Channel. The discharge chambers at the end of the units collect treated flows and
Snug Harbor Surf Park Project 5.9 Hydrology and Water Quality
City of Newport Beach 5.9-12
Draft EIR
May 2025
discharge it into the existing storm drains with a maximum outlet flow rate equal or less than the existing
condition.
The Project site is located within a hydrological conditions of concern (HCOC) susceptible area due to
potential for downstream flooding, erosion, and pollution. The Project site is considered a HCOC if post-
development runoff volume for the two-year, 24-hour storm event exceeds the predevelopment volume for
the 2-year, 24-hour storm by more than five percent. As shown in the Hydrology Report, the proposed
flowrate for the two-year, 24-hour storm event would be 14.1 cfs, which is only 1.4 percent higher than the
existing flow rate of 13.9. Thus, the proposed Project is not considered a HCOC (Appendix P).
As described previously, a WQMP is required to be approved prior to the issuance of a building or grading
permit. The Project’s WQMP would be reviewed and approved by the City to ensure it complies with the
Santa Ana RWQCB MS4 Permit and Orange County DAMP regulations. In addition, the City’s permitting
process would ensure that all BMPs in the WQMP would be implemented with the proposed Project. Overall,
implementation of the WQMP pursuant to the existing regulations would ensure that operation of the
proposed Project would not violate any water quality standards, waste discharge requirements, or otherwise
degrade water quality; and impacts would be less than significant.
IMPACT HYD-2: THE PROJECT WOULD NOT 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. As described previously, the golf course is currently irrigated via well water.
The Water Supply Evaluation (Appendix S) prepared for the Project, estimates that irrigation water usage
for the three golf course holes that would be eliminated by the Project is approximately 15,299 gallons per
day (GPD) or 17.14 acre-feet per year (AFY) of groundwater. Implementation of the Project would convert
this three-hole golf course area, and the use of the onsite well water would be eliminated.
Construction
Due to the existing high groundwater there is a potential for groundwater to be encountered during
construction. Any groundwater dewatering would be temporary and limited to the excavation area. Because
of the relative size of the Project site, as compared to the water basin, and the limited scope of excavation
that would be deep enough to encroach into groundwater, the volume of groundwater removed would not
be substantial and would not decrease groundwater supplies or impede groundwater management. The
proposed Project would comply with the requirements of a Groundwater Discharge Permit, including testing
and treatment, if necessary, that would be implemented through the RWQCB and the City’s permitting
process (and included as PPP WQ-2). Thus, any dewatering activities during construction would result in less
than significant impacts to groundwater.
Operation
According to the 2020 UWMP, in 2020, approximately 76 percent of the City’s water supply came from
groundwater from the Orange County Groundwater Basin. The remaining supply comes from the
Metropolitan Water District (28.5 percent) and recycled water (3.5 percent) (City of Newport Beach, 2021).
The OCWD manages basin water supply through the Basin Production Percentage (BPP), which is set based
on groundwater conditions, availability of imported supplies, and precipitation. As shown on Table 5.9-1,
the City’s UWMP shows that the anticipated production of groundwater would remain steady from 2025
through 2045 and that in 2045, approximately 82.1 percent of supply would be from the Orange County
Basin and 14.5 percent from imported/purchased sources.
Snug Harbor Surf Park Project 5.9 Hydrology and Water Quality
City of Newport Beach 5.9-13
Draft EIR
May 2025
Table 5.9-1: City of Newport Beach Projected Water Supply Projections (acre-feet)
Source 2025 2030 2035 2040 2045 2045 Percentage
OC Groundwater Basin 12,175 12,605 12,729 12,869 12,838 82.1%
Imported/Purchased 2,149 2,224 2,246 2,271 2,265 14.5%
Recycled 542 542 542 542 542 3.5%
Total 14,866 15,371 15,517 15,682 15,645 100%
Source: City of Newport Beach. (2021). 2020 Urban Water Management Plan.
As detailed in Section 5.16, Utilities and Service Systems, the supply of water listed in Table 5.9-1 would be
sufficient during both normal years and multiple dry year conditions between 2025 and 2045 to meet all
of the City’s estimated needs, including the proposed Project. Based on population growth projections and
planned land uses, the UWMP projected an increase in water supply from 14,866 AF in 2025 to 15,371
AF in 2030 (per Table 5.9-1), which is an increase of 505 AF. The Project’s annual net demand of 87 AF of
potable water (as detailed in Table 5.16-9, Net Change in Water Demands, in Section 5.16, Utilities and
Service Systems) would be 17.2 percent of the anticipated increase in water supply between 2025 and
2030. Therefore, the proposed Project would not result in a demand for water that could result in changes
to the projected groundwater pumping that would decrease groundwater supplies. The UWMP also notes
that additional water may be purchased from the Metropolitan Water District of Southern California. Thus,
impacts related to groundwater supplies would be less than significant.
In addition, as described previously the onsite soils have a low infiltration rate and do not currently provide
onsite infiltration. As such, infiltration of water to the existing groundwater basin is neither currently occurring,
nor would occur by the proposed Project. Therefore, impacts related to interference with groundwater
recharge would be less than significant.
IMPACT HYD-3: THE PROJECT WOULD NOT 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 RESULT IN A SUBSTANTIAL EROSION OR
SILTATION ON- OR OFF-SITE.
Less than Significant Impact. The Project site does not include, and is not adjacent to, a stream or river.
Construction
Construction of the proposed Project would require demolition of the existing building structures, including
foundations and floor slabs, removal of pavement and existing infrastructure, and excavation for construction
of the subterranean basement that would expose and loosen building materials and sediment, which has the
potential to mix with storm water runoff and result in erosion or siltation offsite.
The NPDES Construction General Permit and Orange County DAMP require preparation and implementation
of a SWPPP by a Qualified SWPPP Developer for the proposed construction activities (included as PPP
WQ-1). The SWPPP is required to address site-specific conditions related to potential sources of
sedimentation and erosion and would list the required BMPs that are necessary to reduce or eliminate the
potential of erosion or alteration of a drainage pattern during construction activities. Common types of
construction BMPs include:
• Silt fencing, fiber rolls, or gravel bags
• Street sweeping and vacuuming
• Storm drain inlet protection
Snug Harbor Surf Park Project 5.9 Hydrology and Water Quality
City of Newport Beach 5.9-14
Draft EIR
May 2025
• Stabilized construction entrance/exit
• Vehicle and equipment maintenance, cleaning, and fueling
• Hydroseeding
• Material delivery and storage
• Stockpile management
• Spill prevention and control
• Solid waste management
• Concrete waste management
In addition, a Qualified SWPPP Practitioner (QSP) is required to ensure compliance with the SWPPP through
regular monitoring and visual inspections during construction activities. The SWPPP would be amended and
BMPs revised, as determined necessary through field inspections, in order to protect against substantial soil
erosion, the loss of topsoil, or alteration of the drainage pattern. Compliance with the Construction General
Permit and a SWPPP prepared by a QSD and implemented by a QSP (per PPP WQ-1) would prevent
construction-related impacts related to potential alteration of a drainage pattern or erosion from
development activities. Overall, with implementation of the existing construction regulations that would be
verified by the City during the permitting approval process, impacts related to alteration of an existing
drainage pattern during construction that could result in substantial erosion, siltation, and increases in
stormwater runoff would be less than significant.
Operation
The Project-specific Preliminary WQMP describes that the Project site currently includes 3.40 acres of
impermeable surfaces, which equates to 22 percent of the site. After completion of Project construction, the
site would have a significant increase in impermeable surfaces (i.e., 13.89 acres or 90 percent of the site
would have impermeable surfaces). However, this includes the 5.06-acre (20,427 SF) surf lagoon, which
would capture rainfall and not result in runoff. As shown on Table 5.9-2, while implementation of the
proposed Project would result in a large increase in impermeable surfaces, the 100-year, 24-hour storm
volume would decrease by approximately 11 percent.
Table 5.9-2: 100-Year Storm Runoff Rate
Sub Area Existing Condition (CFS) Proposed Condition (CFS)
A 10.6 19.2
B 0.5 3.8
C 3.2 16.2
D 11.1 1.0
E (Lagoon) 19.8 0
Totals 45.2 40.2
Change -11.1%
Source: Preliminary Hydrology Report, Appendix P
The proposed Project would maintain the existing drainage pattern. The Project includes installation of an
onsite storm drainage system that includes two bioretention basins at the north parking lot and two
bioretention basins in the southern parking lot, and an 18-inch storm drain that would connect to the existing
storm drain line at the intersection of Mesa Drive and Irvine Avenue and the existing drain within Irvine
Avenue near the existing site driveway.
Snug Harbor Surf Park Project 5.9 Hydrology and Water Quality
City of Newport Beach 5.9-15
Draft EIR
May 2025
The runoff from the Project buildings and hardscape would be collected by roof drains, surface flow
designed pavement, curbs, and area drains and conveyed to vegetated biotreatment systems (described
previously) for treatment. Similar to existing conditions, the offsite runoff would continue to flow northwest
through the proposed northern parking lot and eventually into the Santa Ana-Delhi Channel. Treated runoff
would be conveyed to the Santa Ana-Delhi Channel with a maximum outlet flow rate equal or less than the
existing condition. From there, flows would travel to the Delhi Channel that drains to Upper Newport Bay.
The Project-related runoff conditions (flow rates) would decrease from existing conditions (shown in Table
5.9-2), and the proposed Project would manage the runoff with vegetated biotreatment systems that have
been designed to accommodate stormwater associated with the proposed Project. As described previously,
the vegetated biotreatment systems contain catch basin inlet filters to capture trash, debris, gross solids and
sediments, a settling chamber for separating out larger solids, and a media filter cartridge for capturing
fine silts, metals, nutrients, and bacteria.
The MS4 Permit and DAMP require new development projects to prepare a WQMP (included as PPP WQ-
3) that is required to include BMPs to reduce the potential of erosion and/or sedimentation through site
design and structural treatment control BMPs. The Preliminary WQMP has been completed and is included
as Appendix O. As part of the permitting approval process, the proposed drainage and water quality
design and engineering plans would be reviewed by the City to ensure that the site specific BMPs limit the
potential for erosion and siltation. Overall, the proposed drainage system and adherence to the existing
regulations would ensure that Project impacts related to alteration of a drainage pattern and
erosion/siltation from operational activities would be less than significant.
IMPACT HYD-4: THE PROJECT WOULD NOT 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 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. The Project site does not include, and is not adjacent to, a stream or river.
Construction
Construction of the proposed Project would require demolition of the existing building structures, including
foundations, floor slabs, and utilities systems. In addition, excavation for subterranean parking structures
would occur. These activities could temporarily alter the existing drainage pattern of the site and could result
in flooding on- or offsite if drainage is not properly controlled. However, as described previously,
implementation of the proposed Project requires a SWPPP (included as PPP WQ-1) that would address site-
specific drainage issues related to construction of the proposed Project and include BMPs to eliminate the
potential of flooding or alteration of a drainage pattern during construction activities. This includes regular
monitoring and visual inspections during construction activities. Compliance with the Construction General
Permit and a SWPPP prepared by a QSD and implemented by a QSP (per PPP WQ-1) as verified by the
City through the construction permitting process would prevent construction-related impacts related to
potential alteration of a drainage pattern or flooding onsite or offsite from development activities.
Therefore, impacts would be less than significant.
Operation
As described previously, and detailed in Table 5.9-2, while the proposed Project would result in an increase
of impervious surfaces, buildout of the proposed Project would result in a decrease of the 100-year storm
runoff flowrate by 11.1 percent and the proposed Project would maintain the existing drainage pattern by
collecting runoff via roof drains, curbs, and area drains and conveying it to vegetated biotreatment systems
Snug Harbor Surf Park Project 5.9 Hydrology and Water Quality
City of Newport Beach 5.9-16
Draft EIR
May 2025
(described previously) for treatment. Treated runoff would be conveyed to the Santa Ana-Delhi Channel
adjacent to the site with a maximum outlet flow rate equal or less than the existing condition.
The Project-related runoff conditions (flow rates) would decrease from existing conditions (shown in Table
5.9-2), and the proposed Project would manage the runoff with the vegetated biotreatment systems that
have been designed to accommodate the proposed Project pursuant to the MS4 Permit and DAMP
requirements. The Preliminary Water Quality Management Plan that was prepared for the proposed Project
(Appendix O) details that the biotreatment system would meet the design capture volume of 18,867 cubic
feet and 3.419 cubic feet per second (cfs). The vegetated biotreatment systems would filter and discharge
runoff into the existing offsite storm drains, or directly into the Santa Ana-Delhi Channel. As part of the
permitting approval process, the proposed drainage design and engineering plans would be reviewed by
the City to ensure that the proposed drainage would accommodate the appropriate design flows. Overall,
the proposed drainage system and adherence to the existing MS4 Permit and DAMP regulations would
ensure that Project impacts related to alteration of a drainage pattern or flooding from operational activities
would be less than significant.
IMPACT HYD-5: THE PROJECT WOULD NOT 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 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.
Less than Significant Impact. The Project site does not include, and is not adjacent to, a stream or river.
Construction
As described in the previous response, construction of the proposed Project would require demolition and
excavation activities that could temporarily alter the existing drainage pattern of the site and could result
in increased runoff and polluted runoff if drainage is not properly controlled. However, as described
previously, implementation of the proposed Project requires a SWPPP (included as PPP WQ-1) that would
address site-specific pollutant and drainage issues related to construction of the proposed Project and
include BMPs to eliminate the potential of polluted runoff and increased runoff during construction activities.
This includes regular monitoring and visual inspections during construction activities. Compliance with the
Construction General Permit and a SWPPP prepared by a QSD and implemented by a QSP (per PPP WQ-
1) as verified by the City through the construction permitting process would prevent construction-related
impacts related to increases in run-off and pollution from development activities.
In addition, any groundwater extracted during groundwater dewatering activities that is discharged to
surface waters would be tested and treated (if necessary) to ensure that any discharges meet the water
quality limits specified in the required Groundwater Discharge Permit (as specified in PPP WQ-2). The
Groundwater Discharge Permit would prevent substantial additional sources of polluted runoff being
discharged to the storm drain system through implementation of construction BMPs that target pollutants of
concern in runoff from the Project site as well as testing and treatment (if required) of groundwater prior to
its discharge to surface waters. Therefore, impacts would be less than significant.
Operation
As described previously and detailed in Table 5.9-2, the proposed Project would result in a decrease of the
100-year, 24-hour storm runoff flowrate by 11.1 percent and the proposed Project would manage runoff
with vegetated biotreatment systems that have been designed to accommodate the proposed Project design
Snug Harbor Surf Park Project 5.9 Hydrology and Water Quality
City of Newport Beach 5.9-17
Draft EIR
May 2025
pursuant to the MS4 Permit and DAMP requirements. The units would filter, treat, and discharge runoff into
the Santa Ana-Delhi Channel with a maximum outlet flow rate equal or less than the existing condition.
As part of the permitting approval process, the proposed drainage design and engineering plans would be
reviewed by the City to ensure that the proposed drainage would accommodate the appropriate design
flows. Additionally, the City permitting process would ensure that the drainage system specifications adhere
to the existing MS4 Permit and DAMP regulations, which would ensure that pollutants are removed prior to
discharge. Overall, with compliance to the existing regulations as verified by the City’s permitting process,
Project impacts related to the capacity of the drainage system and polluted runoff would be less than
significant.
IMPACT HYD-6: THE PROJECT WOULD NOT 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 IMPEDE OR REDIRECT FLOOD FLOWS.
Less than Significant Impact. As described previously, the Project site does not include, and is not adjacent
to, a stream or river. Implementation of the proposed Project would not alter the course of a stream or river.
In addition, according to the FEMA FIRM for the Project area (06059C0267J), the Project site is located
within “Zone X,” which is an area determined to be outside of the 0.2 percent annual chance flood. Therefore,
the Project site is not located within a flood hazard area that could be inundated with flood flows.
As detailed previously, implementation of the proposed Project would result in an increase of impermeable
surfaces from 22 percent of the site to 90 percent of the site. However, because the surf lagoon would
capture rainfall, the proposed Project would result in an 11.1 percent decrease of the 100-year, 24-hour
storm runoff flowrate. Also, the proposed Project would maintain the existing drainage pattern and drainage
would be accommodated by vegetated biotreatment systems that have been sized to accommodate the
DAMP required design storm. Therefore, the proposed Project would impede or redirect flood flows by the
addition of the impervious surfaces. As detailed previously, the City’s permitting process would ensure that
the drainage system specifications adhere to the existing MS4 Permit and DAMP regulations, and compliance
with existing regulations would ensure that impacts would be less than significant.
IMPACT HYD-7: THE PROJECT WOULD NOT, IN FLOOD HAZARD, TSUNAMI, OR SEICHE ZONES, RISK
RELEASE OF POLLUTANTS DUE TO PROJECT INUNDATION.
Less than Significant Impact. As described previously, the FEMA FIRM for the Project area (06059C0267J)
shows that the Project site is located within “Zone X,” which is an area of minimal flood hazard potential
outside of the 0.2 percent annual chance flood. Thus, the Project site is not located within a flood hazard
area that could be inundated with flood flows and result in release of pollutants. Impacts related to flood
hazards and pollutants would not occur from the proposed Project.
Also, as detailed previously, the Project site is over 4.2 miles from the Pacific Ocean, and adjacent to, but
outside of the Tsunami Hazard Zone identified by the California Department of Conservation (DOC 2023).
Thus, the Project site would not be inundated by a tsunami that could result in the release of pollutants, and
impacts would not occur.
The Project is proposing to build a lagoon with two, 5.1-million-gallon surf basins with adjacent structures.
This Project site is also in a seismically active region where strong seismic waves could cause oscillations in
the lagoon, flooding nearby structures. Seismically induced oscillations in the lagoon could cause water to
spill over the sides of the lagoon.
However, the proposed 5.06-acre (220,427 SF) acre surf lagoon comprised of two, 5.1-million-gallon basins
of water would be designed to contain waves from the moving water and would have perimeter walls that
Snug Harbor Surf Park Project 5.9 Hydrology and Water Quality
City of Newport Beach 5.9-18
Draft EIR
May 2025
would contain most waves generated by seismic movement; such that the sloshing of water would stay within
the lagoon. In a worst case, wave energy may be directed toward the southwest where the sloshing action
akin to a rogue wave could theoretically breach the basin wall and splash onto the hardscape surrounding
the lagoon and drain to the Project’s bioretention basins where the water would be treated and discharged
into the Santa Ana-Delhi Channel (CKG Geology, 2025). Because of the planned shape of the lagoon and
configuration of the walls, walkways, etc., seiche energy is expected to attenuate rapidly, posing a low to
moderate hazard to a localized area. Any chemicals or other potential pollutants would be kept on site as
required by existing regulations and the WQMP would be implemented to reduce the potential for any
pollutants to enter waterbodies. Therefore, due to the limited risk related to seiche and limited potential
pollutants, impacts related to the release of pollutants on the Project site resulting from a seiche inundation
would be less than significant.
IMPACT HYD-8: THE PROJECT WOULD NOT CONFLICT WITH OR OBSTRUCT IMPLEMENTATION OF A
WATER QUALITY CONTROL PLAN OR SUSTAINABLE GROUNDWATER
MANAGEMENT PLAN.
Less than Significant Impact. As described previously, use of BMPs during construction implemented as part
of a SWPPP as required by the NPDES Construction General Permit (implemented through PPP WQ-1) and
a RWQCB Groundwater Discharge Permit (implemented through PPP WQ-2) would serve to ensure that
Project impacts related to construction activities resulting in a degradation of water quality would be less
than significant. Thus, construction of the proposed Project would not conflict with or obstruct implementation
of a water quality control plan.
Also, as described previously, development projects are required to implement a WQMP (per the Regional
MS4 Permit and PPP WQ-3) that would comply with the Orange County DAMP. The WQMP and applicable
BMPs are verified as part of the City’s permitting approval process, and construction plans would be
required to demonstrate compliance with these regulations. Therefore, operation of the proposed Project
would not conflict with or obstruct implementation of a water quality control plan.
In addition, as detailed previously, the OCWD manages basin water supply through the BPP, such that the
anticipated production of groundwater would remain steady from 2025 through 2045 (as shown in Table
5.9-1). The Project’s annual net demand of 87 AF of potable water (as detailed in Table 5.16-9, Net Change
in Water Demands, in Section 5.16, Utilities and Service Systems) would be 17.2 percent of the UWMP
anticipated increase in water supply between 2025 and 2030. Therefore, the proposed Project would be
consistent with the groundwater management plan and would not conflict with or obstruct its implementation.
Thus, impacts related to conflict with a water quality control plan or sustainable groundwater management
plan would be less than significant.
5.9.7 CUMULATIVE IMPACTS
Water Quality. The geographic scope for cumulative impacts related to hydrology and water quality
includes the Santa Ana Watershed and the Newport Back Bay because cumulative projects and
developments pursuant to the proposed Project could incrementally exacerbate the existing impaired
conditions and could result in new pollutant-related impairments.
Related developments within the watershed would be required to implement water quality control measures
pursuant to the same NPDES General Construction Permit that requires implementation of a SWPPP (for
construction), a WQMP (for operation) and BMPs to eliminate or reduce the discharge of pollutants in
stormwater discharges, reduce runoff, reduce erosion and sedimentation, and increase filtration and
infiltration, in areas permitted. The NPDES permit requirements have been set by the State Water Board
and implemented by the RWQCB and the Orange County DAMP to reduce incremental effects of individual
Snug Harbor Surf Park Project 5.9 Hydrology and Water Quality
City of Newport Beach 5.9-19
Draft EIR
May 2025
projects so that they would not become cumulatively considerable. Therefore, overall potential impacts to
water quality associated with present and future development in the watershed would not be cumulatively
considerable upon compliance with all applicable laws, permits, ordinances and plans. As detailed
previously, the proposed Project would be implemented in compliance with all regulations, as would be
verified during the permitting process. Therefore, cumulative impacts related to water quality would be less
than significant.
Drainage. The geographic scope for cumulative impacts related to stormwater drainage includes the
geographic area served by the existing stormwater infrastructure for the Project area, from capture of
runoff through final discharge points. As described above, the proposed Project would result in a reduction
in storm water runoff and includes installation of vegetated biotreatment systems that would filter and
discharge runoff through storm drain connections to the offsite drainage infrastructure. The vegetated
biotreatment systems would retain runoff and control drainage, pursuant to the required design storm. As a
result, the proposed Project would not generate runoff that could combine with additional runoff from
cumulative projects that could cumulatively combine to impact drainage. Thus, cumulative impacts related to
drainage would be less than significant.
Groundwater Basin. The geographic scope for cumulative impacts related to the groundwater basin is the
Orange County Basin. The cumulative impacts are evaluated in light of development projections in the recent
City General Plan Update and General Plan EIR that evaluates conditions contributing to the cumulative
effects to the groundwater basin. As described previously, the volume of water that would be needed by
the proposed Project is within the UWMP anticipated groundwater pumping volumes. Therefore, the
proposed Project would not result in changes to the projected groundwater pumping that would decrease
groundwater supplies. As a result, the proposed Project would not require additional supply pumped from
the groundwater basin that could have the potential to combine with effects from other projects to become
cumulatively considerable. Therefore, cumulative impacts related to the groundwater basin would be less
than significant.
5.9.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES
The following would reduce potential impacts related to hydrology and water quality.
Existing Regulations
• Construction General Permit, Order No. 2009-0009-DWQ, as amended by 2010-0014-DWQ, 2012-
0006-DWQ, and 2022-0057-DWQ
• California Water Resources Control Board Low Impact Development (LID) Policy
• Santa Ana Region MS4 Permit; NPDES Permit No. CAS618030 (Order R8-2009-0030 as amended by
Order No. R8-2010-0062)
• Orange County Drainage Area Management Plan (DAMP)
• Municipal Code Chapter 14.17, Water Efficient Landscape Requirement
• Municipal Code Chapter 14.36, Water Quality
Plans, Programs, or Policies
The following Plans, Programs, and Policies (PPP) related to hydrology and water quality are incorporated
into the proposed Project and would reduce potential impacts. These actions will be included in the proposed
Project’s mitigation monitoring and reporting program (MMRP):
Snug Harbor Surf Park Project 5.9 Hydrology and Water Quality
City of Newport Beach 5.9-20
Draft EIR
May 2025
PPP WQ-1: NPDES/SWPPP. Prior to issuance of any grading or demolition permits, the applicant shall
provide the City Building and Safety Division evidence of compliance with the NPDES (National Pollutant
Discharge Elimination System) requirement to obtain a construction permit from the State Water Resource
Control Board (SWRCB). The permit requirement applies to grading and construction sites of one acre or
larger. The Project applicant/proponent shall comply by submitting a Notice of Intent (NOI) and by
developing and implementing a Stormwater Pollution Prevention Plan (SWPPP) and a monitoring program
and reporting plan for the construction site.
PPP WQ-2: Groundwater Dewatering Permits. Prior to initiation of excavation activities, the Project
applicant shall obtain coverage under the Santa Ana RWQCB General Waste Discharge Requirements for
Discharges to Surface Waters Resulting from De Minimis Discharges or Groundwater Dewatering
Operations, and/or Groundwater Cleanup/Remediation Operations at Sites within the Newport Bay
Watershed Permit (Order No. R8-2019-0061, NPDES No. CAG918002), or any other subsequent permit
for dewatering activities, and provide evidence of coverage to the City of Newport Beach designee. This
shall include submission of a Notice of Intent (NOI) for coverage under the permit to the Santa Ana Regional
Water Quality Control Board (RWQCB) at least 60 days prior to the start of excavation activities and
anticipated discharge of dewatered groundwater to surface waters. Groundwater dewatering activities
shall comply with all applicable provisions in the permit, including water sampling, analysis, treatment (if
required), and reporting of dewatering-related discharges. Upon completion of groundwater dewatering
activities, a Notice of Termination shall be submitted to the Santa Ana RWQCB.
PPP WQ-3: WQMP. Prior to the approval of the Grading Plan and issuance of Grading Permits, a completed
Water Quality Management Plan (WQMP) shall be submitted to and approved by the City Public Works
Department. The WQMP shall identify all Post-Construction, Site Design, Source Control, and Treatment
Control Best Management Practices (BMPs) that will be incorporated into the development project in order
to minimize the adverse effects on receiving waters.
5.9.9 PROJECT DESIGN FEATURES
None.
5.9.10 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Upon implementation of regulatory requirements, Impacts HYD-1 through HYD-8 would be less than
significant.
5.9.11 MITIGATION MEASURES
No mitigation measures are required.
5.9.12 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts would be less than significant.
Snug Harbor Surf Park Project 5.9 Hydrology and Water Quality
City of Newport Beach 5.9-21
Draft EIR
May 2025
5.9.13 REFERENCES
California Department of Conservation. (2021). Tsunami Hazard Area Map. Retrieved September 24, 202,
from: https://www.conservation.ca.gov/cgs/tsunami/maps.
California Water Boards. (2019). California Regional Water Quality Control Board Santa Ana Region
Order NO. R-8-2019-0061 NPDES NO. CAG918002. Retrieved March 6, 2025 from:
https://water.waterboards.ca.gov/santaana/board_decisions/adopted_orders/orders/2019/r8
-2019-0061.pdf
California Water Boards. (2025). Orange County MS4 Permit, Order No. R8-2009-0030, NPDES Permit
No. CAS618030, as amended by Order No. R8-2010-0062. Retrieved March 6, 2025 from:
https://www.waterboards.ca.gov/santaana/water_issues/programs/stormwater/
Carl Kim Geotechnical, Inc. (2024). Geotechnical Exploration Proposed Wavegarden Cove, 3100 Irvine
Avenue, Newport Beach, California. (Appendix H)
City of Newport Beach. (2001, January). Santa Ana Heights Specific Plan. Retrieved September 23, 2024,
from ocpublicworks.com.
City of Newport Beach. (2006a, July). General Plan. Retrieved September 23, 2024, from
newportbeachca.gov: https://www.newportbeachca.gov/government/departments/community-
development/planning-division/general-plan-codes-and-regulations/general-plan
City of Newport Beach. (2006b, July). General Plan Environmental Impact Report. Retrieved September 23,
2024, from newportbeachca.gov:
https://www.newportbeachca.gov/government/departments/community-development/planning-
division/general-plan-codes-and-regulations/general-plan/general-plan-environmental-impact-
repor
City of Newport Beach. (2021). 2020 Urban Water Management Plan.
https://www.newportbeachca.gov/home/showpublisheddocument/75001/638579289862370000
City of Newport Beach. (2024, May). Newport Beach Municipal Code. Retrieved September 23, 2024,
from codepublishing.com: https://www.codepublishing.com/CA/NewportBeach/
Fuscoe Engineering, Inc. (2024a). Preliminary Hydrology Report. (Appendix P)
Fuscoe Engineering, Inc. (2024b). Preliminary Water Quality Management Plan (PWQMP). (Appendix O)
Fuscoe Engineering, Inc. (2024c). Water Supply Evaluation. (Appendix S)
Snug Harbor Surf Park Project 5.9 Hydrology and Water Quality
City of Newport Beach 5.9-22
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-1
Draft EIR
May 2025
5.10 Land Use and Planning
5.10.1 INTRODUCTION
In accordance with CEQA Guidelines Section 15125(d), this section provides a summary of the plans, policies,
and regulations of the City of Newport Beach, and regional, State, and federal agencies that have policy
and regulatory control over the Project site and proposed Project. Policy conflicts do not, in and of themselves,
indicate a significant environmental effect within the meaning of CEQA. To the extent that physical
environmental impacts may result from such conflicts, those impacts are analyzed in this EIR in the specific
topical sections to which the impact pertains (e.g., noise, air quality, greenhouse gas emissions, or
transportation).
More specifically, this section examines the potential for the proposed Project to physically divide an
established community and/or conflict with any applicable land use plan, policy, or regulation of an agency
with jurisdiction over the Project adopted for the purpose of avoiding or mitigating an environmental effect,
including relevant goals and policies of the City of Newport Beach General Plan, the Santa Ana Heights
Specific Plan, the City’s municipal code, the Airport Environs Land Use Plan (AELUP) for John Wayne Airport
(SNA), and the Southern California Association of Governments’ (SCAG) Regional Transportation
Plan/Sustainable Communities Strategy (RTP/SCS), “Connect SoCal 2024.”
5.10.2 REGULATORY SETTING
5.10.2.1 Federal Regulations
Federal Regulation 49 Code of Federal Regulation Part 77
The Federal Aviation Agency (FAA) is the federal agency that identifies potential impacts related to air
traffic and related safety hazards. The Federal Regulation 49 Code of Federal Regulation (CFR) Part 77
establishes standards and notification requirements for objects affecting navigable airspace. This notification
serves as the basis for:
• Evaluating the effect of the proposed construction or alteration on operating procedures;
• Determining the potential hazardous effect of the proposed construction on air navigation;
• Identifying mitigating measures to enhance safe air navigation; and
• Charting of new objects.
FAA Federal Aviation Regulations (FAR) Part 77 includes the establishment of imaginary surfaces (airspace
that provides clearance of obstacles for runway operation) that allows the FAA to identify potential
aeronautical hazards in advance, thus preventing or minimizing adverse impacts to the safe and efficient
use of navigable airspace. The regulations identify three-dimensional imaginary surfaces through which no
object should penetrate. The imaginary surface for SNA consists of a 100:1 slope extending outward for
20,000 feet from the nearest runway. Section 77.17 (Obstruction Standards) also states that an object would
be an obstruction to air navigation if it is higher than 200 feet above ground level. Exceedance of 200 feet
above ground level or the 100:1 imaginary surface requires notification to FAA (per FAR Part 77). An object
that would be constructed or altered within the height restriction or imaginary surface area of the airport is
not necessarily incompatible (ALUP 2008) but would be subject to FAA notification and an FAA aeronautical
study to determine whether the proposed structures would constitute a hazard to air navigation.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-2
Draft EIR
May 2025
5.10.2.2 State Regulations
California Public Utilities Code, Section 21676, Airport Land Use Commission
Prior to the amendment of a general plan or specific plan, or the adoption or approval of a zoning ordinance
or building regulation within the planning boundary established by the Airport Land Use Commission (ALUC),
the local agency shall first refer the proposed action to the ALUC. If the ALUC determines that the proposed
action is inconsistent with the airport land use plan, the referring agency shall be notified. The local agency
may, after a public hearing, propose to overrule the ALUC by a two-thirds vote of its governing body if it
makes specific findings that the proposed action is consistent with the purposes of this article, which are to
protect public health, safety, and welfare by ensuring the orderly expansion of airports and the adoption
of land use measures that minimize the public's exposure to excessive noise and safety hazards within areas
around public airports to the extent that these areas are not already devoted to incompatible uses.
At least 45 days prior to the decision to overrule the determination of the ALUC the local agency governing
body shall provide the ALUC and the Caltrans Division of Aeronautics (Division) with a copy of the proposed
decision and findings. The ALUC and the Division may provide comments to the local agency governing body
within 30 days of receiving the proposed decision and findings. If the ALUC’s or the Division’s comments are
not available within this time limit, the local agency governing body may act without them. The comments by
the ALUC or Division are advisory to the local agency governing body. The local agency governing body
shall include comments from the ALUC and the Division in the public record of any final decision to overrule
the ALUC, which may only be adopted by a two-thirds vote of the governing body.
California Coastal Act
The California Coastal Act of 1976 (Coastal Act; Public Resources Code [PRC] Section 30000) and the
California Coastal Commission, which is the State’s coastal protection and planning agency, were established
by voter initiative to plan for and regulate new development and create strong policies to protect public
access to and along the shoreline. To ensure maximum public access to the coast and public recreation areas,
the Coastal Act directs each local government lying within the coastal zone to prepare a Local Coastal
Program (LCP) consistent with Section 30501 of the Coastal Act in consultation with the Coastal Commission
and with public participation.
Until an LCP has been adopted by the local jurisdiction and certified compliant with the Coastal Act, the
Coastal Commission retains permitting authority within the local jurisdiction. Regardless of State or local
jurisdiction, a coastal development permit is required for development in the coastal zone that results in
changes to the density or intensity of the use of land, impacts to environmentally sensitive habitat areas,
and/or impacts to coastal access. The City of Newport Beach has an adopted LCP that was approved by
the Coastal Commission and was implemented in 2017. The Project site is adjacent to areas that are within
the Coastal Zone and subject to the California Coastal Act.
California Code of Regulations Section 13050.5(a)
For a development located inside and outside the coastal zone, including any structure, similar integrated
physical construction, or division of land, a coastal development permit shall be required for only those
portions of the development located within the coastal zone.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-3
Draft EIR
May 2025
5.10.2.3 Regional and Local Regulations
SCAG 2024 Regional Transportation Plan/Sustainable Communities Strategy
The Southern California Association of Governments (SCAG) is designated by federal law as a Metropolitan
Planning Organization (MPO) and under State law as a Regional Transportation Planning Agency and a
Council of Governments. The SCAG region encompasses six counties (Imperial, Los Angeles, Orange,
Riverside, San Bernardino, and Ventura) and 191 cities in an area covering more than 38,000 square miles.
SCAG develops transportation and housing strategies for Southern California as a whole.
SCAG’s Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) includes long range
regional transportation plans, regional transportation improvement programs, regional housing needs
allocations, and other plans for the region. Most of the plan’s goals are related to regional transportation
infrastructure and the efficiency of transportation in the region. SCAG is required by federal law (23 U.S.C.
Section 134 et seq.) to prepare and update a long-range RTP/SCS every four years in order to readjust its
vision for the future, assess challenges, and rearticulate goals.
The most recent RTP/SCS “Connect SoCal” was approved by SCAG on April 4, 2024 that provided updated
growth projections and forecasting for the region. The Connect SoCal 2024 reflects a continuation of the
shift toward more efficient resource management. This refers to transportation infrastructure, land resources,
and environmental resources. The 2024 Connect SoCal projects that 66 percent of new households and 54
percent of new jobs between 2019–2050 will be located in Priority Development Areas, which are either
near transit or in walkable communities.
The 2024 Connect SoCal includes regional planning policies to provide guidance for integrating land use
and transportation planning, which include the following topical areas:
Mobility Policies Support
• Circulation System Preservation and Resilience
• Development of Complete Streets
• Transit and Multimodal Integration
• Transportation System Management
• Transportation Demand Management
• Technology Integration
• Safety
• Funding the System/User Fees
Communities Policies Support
• Priority Development Areas
• Housing the Region
• 15-Minute Communities
• Equitable Engagement and Decision Making
Environmental Policies Support
• Sustainable Development
• Air Quality
• Clean Transportation
• Natural and Agricultural Lands Preservation
• Climate Resilience
Economy Policies Support
• Goods Movement
• Broadband
• Universal Basic Mobility
• Workforce Development
• Tourism
Airport Environs Land Use Plan for John Wayne Airport
John Wayne Airport (SNA) is within the oversight of the Orange County Airport Land Use Commission (ALUC).
The ALUC is required to prepare and adopt an airport land use plan for each of the airports within its
jurisdiction. The ALUC prepared the Airport Environs Land Use Plan (AELUP) for SNA (amended April 17,
2008). The AELUP intends “to safeguard the general welfare of the inhabitants within the vicinity of the
airport and to ensure the continued operation of the airport. Specifically, the plan seeks to protect the public
from the adverse effects of aircraft noise, to ensure that people and facilities are not concentrated in areas
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-4
Draft EIR
May 2025
susceptible to aircraft accidents, and to ensure that no structures or activities adversely affect navigable
airspace.”
The AELUP identifies standards for development in the airport’s planning area based on noise contours,
accident potential zone, and building heights and identifies safety and compatibility zones that depict which
land uses are acceptable and unacceptable in various portions of AELUP Safety Zones 1 through 6, as
detailed in Section 5.8, Hazards and Hazardous Materials.
ALUC is an agency authorized under State law to assist local agencies in ensuring compatible land uses near
airports. Primary areas of concern for ALUC are noise, safety hazards, and airport operational integrity.
ALUCs are not implementing agencies in the manner of local governments, nor do they issue permits for a
project such as those required by local governments. However, pursuant to California Public Utilities Code
Section 21676, local governments are required to submit all general plan amendments and zone changes
that occur in the ALUC planning areas for consistency review by the ALUC.
If such an amendment or change is deemed inconsistent with the ALUC plan, a local government may override
the ALUC decision by a two-thirds vote of its governing body, if it makes specific findings that the proposed
action is consistent with the purposes stated in Section 21670(a)(2) of the Public Utilities Code: “to protect
public health, safety, and welfare by ensuring the orderly expansion of airports and the adoption of land
use measures that minimize the public’s exposure to excessive noise and safety hazards in areas around
public airports to the extent that these areas are not already devoted to incompatible uses.”
Building Height Restrictions: The ALUC has adopted the FAR Part 77 as the criteria for determining height
restrictions in Orange County. These regulations are the only definitive standard available and the standard
most generally used (AELUP 2008). The allowable height of structures surrounding an airport is described in
FAR Part 77 as the allowable height at which safe movement of aircraft occurs. The regulation requires that
notice be given to the FAA if there is a proposal to construct a structure that would exceed a 100:1 slope of
an imaginary surface extending outward for 20,000 feet from the nearest runway at SNA. Beyond the
100:1 imaginary surface, FAR Part 77 requires notification to FAA for any project that will be more than
200 feet in height above the ground level pursuant to FAR Part 77 Section 77.13. Additional details
regarding FAR Part 77 criteria are provided in Section 5.8, Hazards and Hazardous Materials.
Airport Environs Land Use Plan Policies: The following policies in the AELUP for SNA are relevant to the
proposed Project:
Policy 3.2.1 Within the boundaries of the AELUP, any land use may be found to be inconsistent with
the AELUP which:
1. Places people so that they are affected adversely by aircraft noise,
2. Concentrates people in areas susceptible to aircraft accidents,
3. Permits structures of excessive height in areas which would affect adversely the
continued operation of the airport, or
4. Permits activities or facilities that would affect adversely aeronautical operations.
Policy 3.2.3 Noise Impact Zone "1" - High Noise Impact (65 dB CNEL and above). Noise impact in
this zone is sufficient to warrant restrictions on residential uses and to require sound
attenuation measures on other uses. The ALUC does not support residential development
within the 65 dB CNEL noise contour. All residential units are inconsistent in this area unless
it can be shown conclusively that such units are sufficiently sound attenuated for present
and projected noise exposures, which shall be the energy sum of all noise impacting the
project, so as not to exceed an interior standard of 45 dB CNEL, with an accompanying
dedication of an avigation easement for noise to the airport proprietor applicable to
single family residences, multi-family residences and mobile homes. Furthermore, all
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-5
Draft EIR
May 2025
residential units are to be sufficiently indoor oriented so as to preclude noise impingement
on outdoor living areas, as defined in Section 1.7.
Noise-sensitive institutional uses such as schools, churches, hospitals, libraries, and other
noise-sensitive uses may also be inconsistent in this zone. All noise-sensitive uses are
inconsistent in this area unless it can be shown conclusively that such units are sufficiently
sound attenuated for present and projected noise exposures, which shall be the energy
sum of all noise impacting the project, so as not to exceed an interior standard of 45 dB
CNEL, and may require the dedication of an avigation easement for noise to the airport
proprietor. Commercial, industrial, and recreational uses may be acceptable in this zone
providing that commercial and industrial structures are sufficiently sound attenuated to
allow normal work activities to be conducted. Said structures shall be sound attenuated
against the combined input of all present and projected exterior noise to meet the
following criteria:
Private office1, church sanctuary, board room, conference room, etc. 45 dB(A)
General office2, reception, clerical etc. 50 dB(A)
Bank lobby, retail store, restaurant, typing pool, etc. 55 dB(A)
Manufacturing, kitchen, warehousing, etc. 60 dB(A)
*L(eq) is the equivalent sound level for a specified time period in dB(A).
**Measures from 7:00 a.m. to 7:00 p.m. or other appropriate, approved time period.
1An enclosed office intended for use by an individual.
2 An open office intended to have more than one work station.
Policy 3.2.4 Noise Impact Zone "2" - Moderate Noise Impact (60 dB CNEL or greater, less than 65
dB CNEL). Noise impacts in this area are sufficient to require sound attenuation as set
forth in the California Noise Insulation Standards, Title 25, California Code of Regulations.
Single noise events in this area create serious disturbances to many inhabitants. Even
though the ALUC would not find residential units incompatible in this area, the ALUC
strongly recommends that residential units be limited or excluded from this area unless
sufficiently sound attenuated. The residential use interior sound attenuation requirement
shall be a CNEL value not exceeding an interior level of 45 dB. In addition, it is
recommended that designated outdoor common or recreational areas within Noise Impact
Zone 2 provide outdoor signage informing the public of the presence of operating
aircraft.
Policy 3.2.5 Runway Protection Zone “RPZ,” Extreme Crash Hazard. The severe potential for loss
of life and property due to accidents prohibits most land uses in this area. Only airport
related uses and open space uses, including agriculture and certain types of transportation
and utility uses are permitted. No buildings intended for human habitation are permitted
in the RPZ. Furthermore, because of the proximity to aeronautical operations, uses in this
area must not attract birds nor emit excessive glare or light, nor produce or cause steam,
smoke, dust, or electronic interference so as to interfere with, or endanger, aeronautical
operations.
Policy 3.2.6 Height Restriction Zone. Any object, which by reason of its height or location would
interfere with the established, or planned, airport flight procedures, patterns, or
navigational systems, is unacceptable to the Commission. Similarly, any proposal which
would cause a diminution in the utility of an airport is unacceptable to the Commission.
The standards, criteria, and procedures promulgated by the FAA for the thorough
evaluation of development projects are designed to ensure the safe and efficient use of
the navigable airspace. The application of these principles by the Commission will ensure
the stability of local air transportation, as well as promote land uses that are compatible
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-6
Draft EIR
May 2025
with the airport environs. However, any object which rises above the height of surrounding
development, or which is located in close proximity to any of the various flight paths, must
be clearly visible during hours of twilight or darkness and must not threaten, endanger,
or interfere with aeronautical operations. Such objects, even if within the above height
restrictions, are not acceptable to the Commission unless they are clearly marked or
lighted according to FAA standards.
Policy 3.2.7 Airspace/Airport Inconsistency. Any structure, either within or outside of the planning
area, is inconsistent with this AELUP if it:
1. Is determined to be a "Hazard" by the FAA;
2. Would raise the ceiling or visibility minimums at an airport for an existing or planned
instrument procedure (i.e., a procedure consistent with the FAA approved airport
layout plan or a proposed procedure formally on file with the FAA);
3. Would result in a loss in airport utility, e.g. in a diminution of the established
operational efficiency and capacity of the airport, such as by causing the usable
length of the runway(s) to be reduced; or
4. Would conflict with air space used for the airport traffic pattern or enroute navigation
to and from the airport.
City of Newport Beach Local Coastal Program – Coastal Land Use Plan and Implementation Plan
The Coastal Land Use Plan (LUP) of the City’s LCP was derived from the City’s General Plan Land Use Element
and is intended to identify the distribution of land uses in the coastal zone. The City of Newport Beach has
an adopted LCP that was approved by the Coastal Commission and was implemented in 2017 with approval
of the Implementation Plan (IP). The LUP sets forth goals, objectives, and policies that govern the use of land
and water in the coastal zone within the City of Newport Beach and its Sphere of Influence, with the exception
of Newport Coast and Banning Ranch. As shown in Figure 3-7, Coastal Zone Boundary, in Section 3.0, Project
Description, the Project site is adjacent to areas that are within the Coastal Zone. The IP is the primary tool
used by the City to carry out the goals, objectives, and policies of the LUP.
The Project site is not located within the Coastal Zone and is not within the LUP. Mesa Drive is located within
the Coastal Zone and limited infrastructure improvements are proposed within the right-of-way as detailed
below and shown in Figure 5.10-1, Proposed Improvements within Mesa Drive. However, the following LCP IP
Sections are appliable to the proposed Project.
LCP IP Section 21.52.035
This section provides a list of projects exempt from Coastal Development Permit Requirements.
LCP IP Section 21.52.035(C)(4)(a-d)
4. Repair and Maintenance. Repair or maintenance activities, with the exception of the following activities
that involve a risk of substantial adverse environmental impacts:
a. Any method of repair or maintenance of a seawall revetment, bluff retaining wall, breakwater,
groin, culvert, outfall, or similar shoreline work that involves:
i. Repair or maintenance involving substantial alteration of the foundation of the protective work
including pilings and other surface or subsurface structures; or
ii. The placement, whether temporary or permanent, of riprap, or artificial berms of sand, or any
other form of solid material, on a beach or in coastal waters, streams, wetlands, estuaries, or on
shoreline protective works; or
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-7
Draft EIR
May 2025
iii. The replacement of twenty (20) percent or more of the materials of an existing structure with
materials of a different kind; or
iv. The presence, whether temporary or permanent, of mechanized construction equipment or
construction materials on any sand area or bluff or within twenty (20) feet of coastal waters or
streams.
b. Any method of routine maintenance dredging that involves:
i. The dredging of one hundred thousand (100,000) cubic yards or more within a twelve (12)
month period; or
ii. The placement of dredged spoils of any quantity within an environmentally sensitive habitat
area, or any sand area, or within fifty (50) feet of the edge of a coastal bluff or environmentally
sensitive habitat area, or within twenty (20) feet of coastal waters or streams; or
iii. The removal, sale, or disposal of dredged spoils of any quantity that would be suitable for
beach nourishment in an area the Coastal Commission has declared by resolution to have a
critically short sand supply that must be maintained for protection of structures, coastal access
or public recreational use.
c. Any repair or maintenance to facilities or structures or work located in an environmentally sensitive
habitat area, or any sand area, within fifty (50) feet of the edge of a coastal bluff or
environmentally sensitive habitat area; or within twenty (20) feet of any coastal waters and streams
that include:
i. The placement or removal, whether temporary or permanent, of riprap, rocks, sand or other
beach materials or any other forms of solid materials;
ii. The presence, whether temporary or permanent, of mechanized equipment or construction
materials, except that the use of such equipment solely for routine beach cleaning and park
maintenance shall not require a coastal development permit;
iii. All repair and maintenance activities governed by this subsection (C)(4) shall be subject to the
permit regulations promulgated pursuant to the Coastal Act, including but not limited to the
regulations governing administrative and emergency permits. The provisions of this subsection
(C)(4) shall not be applicable to those activities specifically in the document entitled Repair,
Maintenance and Utility Hookups, adopted by the Commission on September 5, 1978, unless a
proposed activity will have a risk of substantial adverse impact on public access, environmentally
sensitive habitat area, wetlands, or public views to the ocean.
d. Unless destroyed by disaster, the replacement of fifty (50) percent or more of a single-family
residence, seawall, revetment, bluff retaining wall, breakwater, groin or any other structure is not
repair and maintenance under California Public Resources Code Section 30610(d) but instead
constitutes a replacement structure requiring a coastal development permit.
In any particular case, even though an improvement falls into one of the classes set forth in this subsection
(C)(4), the Director may, upon finding that the impact of the development on coastal resources or coastal
access to be insignificant, waive the requirement of a permit pursuant to Section 21.52.055 (Waiver for De
Minimis Development).
LCP IP Section 21.52.035(C)(5)
Utility Connections. The installation, testing and placement in service or the replacement of any necessary
utility connection between an existing service facility and any development approved pursuant to the Coastal
Act or the certified LCP; provided, however, that the City or the Coastal Commission may, where necessary,
require reasonable conditions to mitigate any adverse impacts on coastal resources, including scenic
resources.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-8
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project
City of Newport Beach
PROJECT DATA
NET SITE AREA:
APN NUMBERS
TRUCK TRAILER STALLS
AREA
811,760 SF
18.635 AC
7440-016-001
7440-016-002
7440-016-003
7412-024-007
PER CIVIL PLAN
316,373 SF
38.97 %
L COMPLY WITH THE PROVISIONS OF THE CITY OF LOS
NES.
OSE ANY TENANT SIGNAGE AT THIS TIME.
ES OR PLANTS ON SITE.
Figure .10-1
Proposed Improvements within Mesa Drive
STOPSTOP
M
E
S
A
D
R
I
V
E
LEGEND
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-10
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-11
Draft EIR
May 2025
City of Newport Beach General Plan 2006
The City of Newport Beach General Plan 2006 is the City’s principal long-range policy and planning
document that consists of ten elements that serve as a guide for City decision-making related to land uses
and the physical development of the City. The General Plan policies that are relevant to the proposed
Project and related to environmental impacts are listed below by General Plan Element.
Land Use Element
Policy LU 1.6 Public Views. Protect and, where feasible, enhance significant scenic and visual resources
that include open space, mountains, canyons, ridges, ocean, and harbor from public
vantage points.
Policy LU 2.1 Resident-Serving Land Uses. Accommodate uses that support the needs of Newport
Beach’s residents including housing, retail, services, employment, recreation, education,
culture, entertainment, civic engagement, and social and spiritual activity that are in
balance with community natural resources and open spaces.
Policy LU 2.2 Sustainable and Complete Community. Emphasize and support the development of uses
that enable Newport Beach to be a complete community that maintains the ability to
provide locally accessible opportunities for retail, goods and services, and employment.
Policy LU 2.5 Visitor Serving Uses. Provide uses that serve visitors to Newport Beach’s ocean, harbor,
open spaces, and other recreational assets, while integrating them to protect
neighborhoods and residents.
Policy LU 2.8 Adequate Infrastructure. Accommodate the types, densities, and mix of land uses that
can be adequately supported by transportation and utility infrastructure (water, sewer,
storm drainage, energy, and so on) and public services (schools, parks, libraries, seniors,
youth, police, fire, and so on).
Policy LU 3.1 Neighborhoods, Districts, Corridors, and Open Spaces. Maintain Newport Beach’s
pattern of residential neighborhoods, business and employment districts, commercial
centers, corridors, and harbor and ocean districts.
Policy LU 3.2 Growth and Change. Enhance existing neighborhoods, districts, and corridors, allowing
for re-use and infill with uses that are complementary in type, form, scale, and character.
Changes in use and/or density/intensity should be considered only in those areas that are
economically underperforming, are necessary to accommodate Newport Beach’s share of
projected regional population growth, improve the relationship and reduce commuting
distance between home and jobs, or enhance the values that distinguish Newport Beach
as a special place to live for its residents. The scale of growth and new development shall
be coordinated with the provision of adequate infrastructure and public services, including
standards for acceptable traffic level of service.
Policy LU 3.3 Opportunities for Change. Support opportunities for new development and improved
physical environments for residents, businesses, and visitors in the following districts and
corridors, as specified in Polices 6.3.1 through 6.22.7:
• Santa Ana Heights: Support continued implementation of the adopted Specific Plan
and Redevelopment Plan.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-12
Draft EIR
May 2025
Policy LU 3.7 Natural Resource and Hazardous Areas. Require that new development is located and
designed to protect areas with high natural resource value and protect residents and
visitors from threats to life or property.
Policy LU 3.8 Project Entitlement Review with Airport Land Use Commission. Refer the adoption or
amendment of the General Plan, Zoning Code, specific plans, and Planned Community
development plans for land within the John Wayne Airport planning area, as established
in the JWA Airport Environs Land Use Plan (AELUP), to the Airport Land Use Commission
(ALUC) for Orange County for review, as required by Section 21676 of the California
Public Utilities Code. In addition, refer all development projects that include buildings with
a height greater than 200 feet above ground level to the ALUC for review.
Policy LU 4.1 Land Use Diagram. Support land use development consistent with the Land Use Plan.
Figure LU1 depicts the general distribution of uses throughout the City and Figure LU2
through Figure LU15 depict specific use categories for each parcel within defined
Statistical Areas. Table LU1 (Land Use Plan Categories) specifies the primary land use
categories, types of uses, and, for certain categories, the densities/intensities to be
permitted. The permitted densities/intensities or amount of development for land use
categories for which this is not included in Table LU1, are specified on the Land Use Plan,
Figure LU4 through Figure LU15. These are intended to convey maximum and, in some
cases, minimums that may be permitted on any parcel within the designation or as
otherwise specified by Table LU2 (Anomaly Locations). The density/intensity ranges
exclude increases allowed through the applications of density bonus laws and are
calculated based on actual land area, actual number of dwelling units in fully developed
residential areas, and development potential in areas where the General Plan allows
additional development.
To determine the permissible development, the user should:
a. Identify the parcel and the applicable land use designation on the Land Use Plan,
Figure LU4 through Figure LU15
b. Refer to Figure LU4 through Figure LU15 and Table LU1 to identify the permitted uses
and permitted density or intensity or amount of development for the land use
classification. Where densities/intensities are applicable, the maximum amount of
development shall be determined by multiplying the area of the parcel by the
density/intensity.
c. For anomalies identified on the Land Use Map by a symbol, refer to Table LU2 to
determine the precise development limits.
d. For residential development in the Airport Area, refer to the policies prescribed by
the Land Use Element that define how development may occur.
Policy LU 5.6.2 Form and Environment. Require that new and renovated buildings be designed to avoid
the use of styles, colors, and materials that unusually impact the design character and
quality of their location such as abrupt changes in scale, building form, architectural style,
and the use of surface materials that raise local temperatures, result in glare and
excessive illumination of adjoining properties and open spaces, or adversely modify wind
patterns.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-13
Draft EIR
May 2025
Policy LU 5.6.3 Ambient Lighting. Require that outdoor lighting be located and designed to prevent
spillover onto adjoining properties or significantly increase the overall ambient
illumination of their location.
Historical Resources Element
Policy HR 2.1 New Development Activities. Require that, in accordance with CEQA, new development
protect and preserve paleontological and archaeological resources from destruction, and
avoid and mitigate impacts to such resources. Through planning policies and permit
conditions, ensure the preservation of significant archeological and paleontological
resources and require that the impact caused by any development be mitigated in
accordance with CEQA.
Policy HR 2.2 Grading and Excavation Activities. Maintain sources of information regarding
paleontological and archeological sites and the names and addresses of responsible
organizations and qualified individuals, who can analyze, classify, record, and preserve
paleontological or archeological findings. Require a qualified paleontologist/
archeologist to monitor all grading and/or excavation where there is a potential to affect
cultural, archeological or paleontological resources. If these resources are found, the
applicant shall implement the recommendations of the paleontologist/archeologist, subject
to the approval of the City Planning Department.
Policy HR 2.3 Cultural Organizations. Notify cultural organizations, including Native American
organizations, of proposed developments that have the potential to adversely impact
cultural resources. Allow representatives of such groups to monitor grading and/or
excavation of development sites.
Policy HR 2.4 Paleontological or Archaeological Materials. Require new development to donate
scientifically valuable paleontological or archaeological materials to a responsible public
or private institution with a suitable repository, located within Newport Beach, or Orange
County, whenever possible.
Circulation Element
Policy CE 2.2.1 Safe Roadways. Provide for safe roadway conditions by adhering to nationally
recognized improvement standards and uniform construction and maintenance practices.
Policy CE 2.2.4 Traffic Control. Design traffic control measures to ensure City streets and roads function
with safety and efficiency for vehicles, bicycles, and pedestrians.
Policy CE 2.2.5 Driveway and Access Limitations. Limit driveway and local street access on arterial
streets to maintain a desired quality of traffic flow and limit hazards to active
transportation modes. Wherever possible, consolidate and/or reduce the number of
driveways and implement access controls during redevelopment of adjacent parcels.
Policy CE 2.2.7 Emergency Access. Provide all residential, commercial, and industrial areas with efficient
and safe access for emergency vehicles. An emergency evacuation map shall be
prepared as part of an updated Safety Element.
Policy CE 5.2.6 Pedestrian Improvements in New Development Projects. Require new development
projects to include safe and attractive sidewalks, walkways, and bike lanes in accordance
with the Master Plan, and, if feasible, trails.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-14
Draft EIR
May 2025
Policy CE 5.2.12 Bicycle Supporting Amenities. Require bicycle facilities such as bike racks, bike stations,
or lockers according to national standards for long-term and short-term bicycle utilization
on City property and with new development and encourage the addition of such bicycle
facilities within existing development.
Policy CE 7.1.1 Vehicle Miles Traveled (VMT) Analysis. Follow the analysis methodology for vehicle
miles traveled according to the Newport Beach VMT thresholds policy and as required in
Senate Bill 743 and the revised California Environmental Quality Act (CEQA) Guidelines.
Policy CE 7.1.2 VMT Mitigation Measures. Require implementation of CEQA project related VMT
mitigation measures when warranted and monitor reductions in VMT from new
development.
Policy CE 7.1.5 Support Facilities for Alternative Modes. Require new development projects to provide
facilities commensurate with development type and intensity to support alternative modes,
such as preferential parking for carpools, bike racks, bike stations, bicycle lockers,
showers, commuter information areas, rideshare vehicle loading areas, water
transportation docks, and bus stop improvements.
Policy CE 7.1.7 Project Site Design Supporting Alternative Modes. Encourage increased use of public
transportation by requiring project site designs that facilitate the use of public
transportation and walking.
Policy CE 7.1.8 Electric Vehicle (EV) Charging Stations. Install additional EV charging stations on City
properties, support existing private development to add new EV charging stations and
develop incentives for the installation of EV charging stations and other alternative fuels
systems as part of new development.
Policy CE 9.1.10 Development Requirements. Require development to provide the needed roadway
improvements adjacent to a site, commensurate with project impact and in accordance
with the Master Plan of Streets and Highways.
Recreation Element
Policy R 1.12 Aircraft Overflight and Noise. Require that all public parks located within the noise
impact zones as defined in the 1985 JWA Master Plan for John Wayne Airport be posted
with a notification to users regarding aircraft overflight and noise.
Policy R 4.1 Provision of Recreation Services. Provide high quality recreational services through
professionally-trained recreational personnel to program participants.
Policy R 4.2 Compatible Recreation Activities. Provide a variety of compatible recreational activities
within a given location.
Policy R 4.3 Variety of Programs. Provide a variety of quality programs offered in safe and secure
environments for the community’s youth that enhance and extend the learning day,
promote health and wellness, encourage expansion of skills, and reinforce self esteem,
good character, and positive behavior.
Policy R 4.5 Variety of Adult Recreational Programs. Provide a variety of quality enrichment and
recreational programs for the adult population that promote health and wellness;
development and/or enhancement of skills and talents; extend learning opportunities;
promote sportsmanship; and provide unique opportunities to engage in new activities.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-15
Draft EIR
May 2025
Natural Resources Element
Policy NR 1.1 Water Conservation in New Development. Enforce water conservation measures that
limit water usage, prohibit activities that waste water or cause runoff, and require the use
of water–efficient landscaping and irrigation in conjunction with new construction projects.
Policy NR 1.2 Use of Water Conserving Devices. Establish and actively promote use of water
conserving devices and practices in both new construction and major alterations and
additions to existing buildings. This can include the use of rainwater capture, storage, and
reuse facilities.
Policy NR 3.4 Storm Drain Sewer System Permit. Require all development to comply with the
regulations under the City’s municipal separate storm drain system permit under the
National Pollutant Discharge Elimination System.
Policy NR 3.5 Natural Water Bodies. Require that development does not degrade natural water bodies.
Policy NR 3.9 Water Quality Management Plan. Require new development applications to include a
Water Quality Management Plan (WQMP) to minimize runoff from rainfall events during
construction and post-construction.
Policy NR 3.10 Best Management Practices. Implement and improve upon Best Management Practices
(BMPs) for residences, businesses, development projects, and City operations.
Policy NR 3.11 Site Design and Source Control. Include site design and source control BMPs in all
developments. When the combination of site design and source control BMPs are not
sufficient to protect water quality as required by the National Pollutant Discharge
Elimination System (NPDES), structural treatment BMPs will be implemented along with site
design and source control measures.
Policy NR 3.12 Reduction of Infiltration. Include equivalent BMPs that do not require infiltration, where
infiltration of runoff would exacerbate geologic hazards. (Policy HB 8.12)
Policy NR 3.14 Runoff Reduction on Private Property. Retain runoff on private property to prevent the
transport of pollutants into natural water bodies, to the maximum extent practicable.
(Policy HB 8.14).
Policy NR 3.16 Siting of New Development. Require that development be located on the most suitable
portion of the site and designed to ensure the protection and preservation of natural and
sensitive site resources that provide important water quality benefits. (Policy HB 8.16).
Policy NR 3.17 Parking Lots and Rights-of-Way. Require that parking lots and public and private rights-
of-way be maintained and cleaned frequently to remove debris and contaminated
residue. (Policy HB 8.17)
Policy NR 3.19 Natural Drainage Systems. Require incorporation of natural drainage systems and
stormwater detention facilities into new developments, where appropriate and feasible,
to retain stormwater in order to increase groundwater recharge. (Policy HB 8.19)
Policy NR 3.20 Impervious Surfaces. Require new development and public improvements to minimize the
creation of and increases in impervious surfaces, especially directly connected impervious
areas, to the maximum extent practicable. Require redevelopment to increase area of
pervious surfaces, where feasible. (Policy HB 8.20)
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-16
Draft EIR
May 2025
Policy NR 4.3 Restore Natural Hydrologic Conditions. Preserve, or where feasible, restore natural
hydrologic conditions such that downstream erosion, natural sedimentation rates, surface
flow, and groundwater recharge function near natural equilibrium states.
Policy NR 4.4 Erosion Minimization. Require grading/erosion control plans with structural BMPs that
prevent or minimize erosion during and after construction for development on steep slopes,
graded, or disturbed areas.
Policy NR 6.1 Walkable Neighborhoods. Provide for walkable neighborhoods to reduce vehicle trips
by siting amenities such as services, parks, and schools in close proximity to residential
areas.
Policy NR 6.4 Transportation Demand Management Ordinance. Implement the Transportation
Demand Management (TDM) Ordinance, which promotes and encourages the use of
alternative transportation modes and provides those facilities such as bicycle lanes that
support such alternate modes.
Policy NR 7.2 Source Emission Reduction Best Management Practices. Require the use of Best
Management Practices (BMP) to minimize pollution and to reduce source emissions.
Policy NR 8.1 Management of Construction Activities to Reduce Air Pollution. Require developers to
use and operate construction equipment, use building materials and paints, and control
dust created by construction activities to minimize air pollutants.
Policy NR 10.2 Orange County Natural Communities Conservation Plan. Comply with the policies
contained within the Orange County Natural Communities Conservation Plan.
Policy NR 10.3 Analysis of Environmental Study Areas. Require a site-specific survey and analysis
prepared by a qualified biologist as a filing requirement for any development permit
applications where development would occur within or contiguous to areas identified as
ESAs.
Policy NR 10.4 New Development Siting and Design. Require that the siting and design of new
development, including landscaping and public access, protect sensitive or rare resources
against any significant disruption of habitat values.
Policy NR 10.5 Development in Areas Containing Significant or Rare Biological Resources. Limit uses
within an area containing any significant or rare biological resources to only those uses
that are dependent on such resources, except where application of such a limitation would
result in a taking of private property. If application of this policy would likely constitute
a taking of private property, then a non-resource-dependent use shall be allowed on the
property, provided development is limited to the minimum amount necessary to avoid a
taking and the development is consistent with all other applicable resource protection
policies. Public access improvements and educational, interpretative and research facilities
are considered resource dependent uses.
Policy NR 10.6 Use of Buffers. Maintain a buffer of sufficient size around significant or rare biological
resources, if present, to ensure the protection of these resources. Require the use of native
vegetation and prohibit invasive plant species within these buffer areas.
Policy NR 10.7 Exterior Lighting. Shield and direct exterior lighting away from significant or rare
biological resources to minimize impacts to wildlife.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-17
Draft EIR
May 2025
Policy NR 18.1 New Development. Require new development to protect and preserve paleontological
and archaeological resources from destruction, and avoid and minimize impacts to such
resources in accordance with the requirements of CEQA. Through planning policies and
permit conditions, ensure the preservation of significant archeological and paleontological
resources and require that the impact caused by any development be mitigated in
accordance with CEQA.
Policy NR 18.3 Potential for New Development to Impact Resources. Notify cultural organizations,
including Native American organizations, of proposed developments that have the
potential to adversely impact cultural resources. Allow qualified representatives of such
groups to monitor grading and/or excavation of development sites.
Policy NR 18.4 Donation of Materials. Require new development, where on site preservation and
avoidance are not feasible, to donate scientifically valuable paleontological or
archaeological materials to a responsible public or private institution with a suitable
repository, located within Newport Beach or Orange County, whenever possible.
Policy NR 20.1 Enhancement of Significant Resources. Protect and, where feasible, enhance significant
scenic and visual resources that include open space, mountains, canyons, ridges, ocean,
and harbor from public vantage points, as shown in Figure NR3.
Policy NR 20.2 New Development Requirements. Require new development to restore and enhance the
visual quality in visually degraded areas, where feasible, and provide view easements
or corridors designed to protect public views or to restore public views in developed
areas, where appropriate.
Policy NR 20.4 Public View Corridor Landscaping. Design and site new development, including
landscaping, on the edges of public view corridors, including those down public streets, to
frame, accent, and minimize impacts to public views.
Policy NR 23.1 Maintenance of Natural Topography. Preserve cliffs, canyons, bluffs, significant rock
outcroppings, and site buildings to minimize alteration of the site’s natural topography
and preserve the features as a visual resource.
Policy NR 23.7 New Development Design and Siting. Design and site new development to minimize the
removal of native vegetation, preserve rock outcroppings, and protect coastal resources.
Policy NR 24.2 Energy-Efficient Design Features. Promote energy-efficient design features.
Policy NR 24.3 Incentives for Green Building Program Implementation. Promote or provide incentives
for “Green Building” programs that go beyond the requirements of Title 24 of the
California Administrative Code and encourage energy efficient design elements as
appropriate to achieve “green building” status.
Safety Element
Policy S 4.7 New Development. Conduct further seismic studies for new development in areas where
potentially active faults may occur.
Policy S 5.1 New Development Design within 100-year Floodplains. Require that all new
development within 100-year floodplains incorporate sufficient measures to mitigate
flood hazards including the design of onsite drainage systems that are connected with the
City’s storm drainage system, gradation of the site such that runoff does not impact
adjacent properties, and buildings are elevated.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-18
Draft EIR
May 2025
Policy S 5.2 Facility Use or Storage of Hazardous Materials Standards. Require that all new facilities
storing, using, or otherwise involved with substantial quantities of onsite hazardous
materials within flood zones comply with standards of elevation, anchoring, and flood
proofing, and hazardous materials are stored in watertight containers.
Policy S 5.3 Minimization of Flood Hazard Risk. Require stormwater detention basins, where
appropriate, to reduce the potential risk of flood hazards.
Policy S 7.1 Known Areas of Contamination. Require proponents of projects in known areas of
contamination from oil operations or other uses to perform comprehensive soil and
groundwater contamination assessments in accordance with American Society for Testing
and Materials standards, and if contamination exceeds regulatory action levels, require
the proponent to undertake remediation procedures prior to grading and development
under the supervision of the County Environmental Health Division, County Department of
Toxic Substances Control, or Regional Water Quality Control Board (depending upon the
nature of any identified contamination).
Policy S 7.2 Development Design within Methane Gas Districts. Ensure that any development within
identified methane gas districts be designed consistent with the requirements of the
Newport Beach Municipal Code.
Policy S 7.4 Implementation of Remediation Efforts. Minimize the potential risk of contamination to
surface water and groundwater resources and implement remediation efforts to any
resources adversely impacted by urban activities.
Noise Element
Policy N 1.1 Noise Compatibility of New Development. Require that all proposed projects are
compatible with the noise environment through use of Table N2 and enforce the interior
and exterior noise standards shown in Table N3.
Policy N 1.7 Commercial/ Entertainment Uses. Limit hours and/or require attenuation of
commercial/entertainment operations adjacent to residential and other noise sensitive
uses in order to minimize excessive noise to these receptors.
Policy N 1.8 Significant Noise Impacts. Require the employment of noise mitigation measures for
existing sensitive uses when a significant noise impact is identified. A significant noise
impact occurs when there is an increase in the ambient CNEL produced by new
development impacting existing sensitive uses. The CNEL increase is shown in the table
below.
Policy N 4.2 New Uses. Require that new uses such as restaurants, bars, entertainment, parking
facilities, and other commercial uses where large numbers of people may be present
adjacent to sensitive noise receptors obtain a use permit that is based on compliance with
the noise standards in Table N3 and the City’s Municipal Code.
Policy N 4.6 Maintenance of Construction Activities. Enforce the Noise Ordinance noise limits and
limits on hours of maintenance or construction activity in or adjacent to residential areas,
including noise that results from in-home hobby or work related activities.
Policy N 5.1 Limiting Hours of Activity. Enforce the limits on hours of construction activity.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-19
Draft EIR
May 2025
City of Newport Beach City Council Policy Manual
The City of Newport Beach City Council Policy Manual contains the following policies related to land use,
planning, and mitigating an environmental effect.
Policy G-1 Retention, Removal, and Maintenance of City Trees. This policy establishes standards
for the retention, removal, maintenance, reforestation, tree trimming standards, and
supplemental trimming of City trees. The policy provides definitions of certain trees that
should be protected and provisions for the removal of such trees.
Policy K-2 Places of Historical and Architectural Significance: The City Council may designate as
historical property any building or part thereof, object, structure, monument, or collection
thereof having importance to the history or architecture of the City of Newport Beach in
accordance with the criteria set forth below.
1. Property may be designated as historical property if it meets any of the following
standards of architectural significance:
a. Structures or areas that embody distinguishing characteristics of an architectural
style, period, or method of construction, or of architectural development with the
City.
b. Notable works of a master builder, designer, or architect whose style influenced
the City’s architectural development, or structures showing the evolution of an
architect’s style.
c. Rare structures displaying a building type, design, or indigenous building form.
d. Structures which embody special architectural and design features.
e. Outstanding examples of structures displaying original architectural integrity,
structurally or stylistically, or both.
f. Unique structures or places that act as focal or pivotal points important as a key
to the character or visual quality of an area.
2. Property may be designated as historical property if it meets any of the following
standards of historical significance.
a. Sites and structures connected with events significant in the economic, cultural,
political, social, or civic history of the City of Newport Beach, the County of
Orange, the State of California, or the United States of America.
b. Structures or areas identified with the lives of historical personages of the City of
Newport Beach, the County of Orange, the State of California, or the United
States of America.
c. Sites and groups of structures representing historical development patterns,
including, but not limited to, urbanization patterns, railroads, agricultural
settlements, and canals.
Policy K-3 Implementation Procedures for the California Environmental Quality Act: The intent of
this policy statement is to protect the environment of the City of Newport Beach, to comply
with the California Environmental Quality Act (“CEQA"), and to implement the basic
principles, objectives, and criteria contained in the Guidelines adopted by the Secretary
for Resources pursuant to the provisions of CEQA, as amended. The following general
policies shall apply:
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-20
Draft EIR
May 2025
1. The City, in implementing the requirements of CEQA, shall, wherever possible,
integrate these procedures into the existing planning and review procedures of the
City.
2. In reviewing and assessing the significance of environmental impacts, the City shall be
guided by the applicable General Plan and Local Coastal Program policies and
standards.
Policy K-5 Paleontological and Archaeological Resource Protection Guidelines: The City will
ensure that potential impacts to paleontological and archaeological resources by public
or private development are properly evaluated and mitigated in accordance with the
General Plan, Local Coastal Program and CEQA.
Procedures
A. During the preparation of an initial study for a project, staff or a qualified consultant
shall determine if paleontological or archaeological resources exist at or near a
project site. If the site is located in the Coastal Zone, the requirements and procedures
provided in Newport Beach Municipal Code Section 21.30.105(A), or any successor
statute, shall be implemented.
B. If resources are known to exist at or near a project site or that, the project could
otherwise affect known resources, a preliminary investigation report shall be
prepared by a qualified professional archaeologist or paleontologist.
C. If the preliminary investigation report concludes that resources are not likely to be at
the present at the project site or encountered during construction, no further analysis
shall be required.
D. If the preliminary report concludes that resources are present at the site or are likely
to be present at the site or may be encountered by project construction, additional
investigative work shall be prepared to identify and disclose the potential impacts of
the project. The impact assessment report shall make every effort to identify the value
of the resource and shall identify feasible design modifications or other methods to
avoid and/or minimize project-related impacts. The impact assessment report may
include a suggested excavation plan for assessing or mitigating the effect of the
project on the qualities which make the resource important if avoidance is considered
infeasible. The impact assessment report shall also identify feasible mitigation
measures that can be either incorporated within project specifications or applied as
conditions of approval.
E. If paleontological or archaeological resources are discovered during construction, all
construction activities in the general area of the discovery shall be temporarily halted
until the resource is examined by a qualified monitor. The monitor shall the significance
of the resource recommend next steps (i.e. additional excavation, curation,
preservation, etc.).
F. If human remains are discovered during construction, there shall be no further
excavation or disturbance of the site or any nearby area reasonably suspected to
overlie adjacent remains until the coroner determines that the remains are not subject
to the provisions of Section 27491 of the Government Code, or any successor statute,
or any other related provisions of law concerning investigation of the circumstances,
manner and cause of any death, and the recommendations concerning the treatment
and disposition of the human remains have been made to the person responsible for
the excavation, or their authorized representative, in the manner provided in Section
5097.98 of the Public Resources Code, or any successor statute. The coroner shall
make his or her determination within two working days from the time the person
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-21
Draft EIR
May 2025
responsible for the excavation, or his or her authorized representative, notifies the
coroner of the discovery or recognition of the human remains. If the coroner
determines that the remains are not subject to his or her authority and if the coroner
recognizes the human remains to be those of a Native American, or has reason to
believe that they are those of a Native American, he or she shall contact, by telephone
within 24 hours, the Native American Heritage Commission and the Newport Beach
Building Official.
City of Newport Beach Santa Ana Heights Specific Plan
Santa Ana Heights is an area roughly bounded by Upper Newport Bay to the south, Santa Ana Avenue to
the west, Bristol Street to the north, and the Bayview Terrace area (near the Marriott Suites) to the east.
Santa Ana Heights was annexed from the County of Orange to the City of Newport Beach in two segments
– the area east of Irvine Avenue became part of the City in January of 2002 and the area west of Irvine
Avenue was added on January 1, 2008. The County of Orange prepared and adopted the Specific Plan
for the area prior to it becoming part of the City to improve the area and plan for development that is
consistent with the noise generated by John Wayne Airport.
The Santa Ana Heights Specific Plan is included in the City’s Municipal Code as Chapter 20.90. The Specific
Plan includes design guidelines and land use regulations that are applicable to the proposed Project that
are listed in the municipal code discussion below.
City of Newport Beach Municipal Code
Municipal Code Sections 20.90.040.D.3 and 20.90.040.D.4 provide the following requirements related to
John Wayne Airport:
3. Prior to the issuance of a building permit for a structure that penetrates the 100:1 Notice Surface
pursuant to FAR Part 77.13, the project applicant shall submit a “Notice of Proposed Construction” to
the Federal Aviation Administration (FAA), which will initiate an Aeronautical Study of the project by the
FAA. Upon completion of the FAA Aeronautical Study, the project applicant shall submit evidence to the
Community Development Director that restrictions and conditions, if any, imposed on the project by the
FAA have been incorporated into the design of the project.
4. All projects including, but not limited to, General Plan amendments and zone changes within the project
area pertinent to the Airport Land Use Commission’s (ALUC) John Wayne Airport “Airport Environs Land
Use Plan” shall be referred to ALUC until such time as the City becomes a “Consistent Local Agency” as
defined by ALUC. For purposes of this requirement, the term “project” shall include those applications
requiring discretionary approvals, tentative tract map or parcel map approvals or modifications, and/or
condominium conversions. Such projects shall not include minor modifications, such as remodels and
additions to single-family dwelling units with no intensification of development.
Municipal Code Section 20.90.050, Open Space and Recreation District SP-7 (OSR) states that the principal
permitting uses include golf courses and outdoor commercial recreation; and accessory uses include detached
buildings, fences and walls, restrooms, and any other structure or use that is consistent with the purpose and
intent of the land use. The site development standards listed in Municipal Code Section 20.90.050(E) include
the following:
• Building Site Area. One acre minimum.
• Building Height. Eighteen feet maximum unless otherwise provided for by an approved use permit.
• Building Setbacks. Twenty feet minimum from all property lines.
• Lighting. All lighting shall be designed and located so that direct light rays are confined to the premises.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-22
Draft EIR
May 2025
5.10.3 ENVIRONMENTAL SETTING
5.10.3.1 Existing Uses Onsite
The Project site consists of a portion of the NB Golf Course. The golf course is separated into three physically
distinct land areas and the Project site consists of the central portion, which is bounded by Irvine Avenue and
Mesa Drive. The Project site is comprised of one parcel encompassing 15.38 acres that currently includes a
38-bay partially covered driving range, a 1,050-square-foot (SF) putting green, a 8,975 SF building that
includes a pro shop and a restaurant, a 2,664 driving range building, parking lot with 280 parking spaces,
and three holes of the existing NB Golf Course (holes 1, 2, and 9). The existing total square footage of
existing building space on the site is 11,639 SF, as listed in Table 5.10-1 below.
Table 5.10-1: Existing Onsite Building Square Footage
Existing Building Use Square Footage
Restaurant 7,200
Pro Shop 1,775
Driving Range Building 2,664
Total 11,639
The majority of the site is covered in grass or artificial grass associated with the golf course and the paved
parking lot. The golf course and the driving range are lighted for nighttime play until 10:00 p.m., and the
driving range is surrounded by approximately 40 net poles that range in height from 25 to 80 feet
depending on location. The poles and netting separating the driving range from the buildings to the east
are approximately 80 feet tall, the poles and netting separating the driving range from the golf course on
the west are approximately 50 feet tall and the poles and netting separating the driving range from Mesa
Drive to the south are between 62 and 65 feet tall. Some of the poles are wood (telephone pole-like) while
others are pipes. In addition, some of the poles have pipe extensions to increase the overall height of the
netting for safety purposes. The Project site’s existing conditions are shown in Figure 3-4, Site Photos.
Existing hours of operation for the driving range and golf course are 7:00 a.m. to 10:00 p.m. The hours of
operation for the pro shop are generally 10:00 a.m. to 7:00 p.m.; and the restaurant generally operates
from 8:00 a.m. to 10:00 p.m.
5.10.3.2 Existing General Plan Land Use and Zoning Designations
The 15.38-acre Project site has a General Plan Land Use designation of Parks and Recreation (PR), as shown
on Figure 3-5, Existing General Plan Land Use Designations. The General Plan states that the PR land use
permits parks (both active and passive), golf courses, marina support facilities, aquatic facilities, tennis clubs
and courts, private recreation, and similar facilities. The Project site is identified as Anomaly Number 58,
with a development limit of 20,000 SF.
The Project site is located within the Santa Ana Heights Specific Plan (SP-7), which provides zoning regulations
for the site. The Santa Ana Heights Specific Plan designates the site as Open Space and Recreation (OSR),
as shown in Figure 3-6, Existing Zoning Designations. Permitted uses within the OSR zone, subject to a use
permit, include golf courses and outdoor commercial recreation. Also, accessory uses and structures are
permitted when customarily associated with and subordinate to a principal permitted use on the same
building site.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-23
Draft EIR
May 2025
5.10.3.3 Surrounding Land Uses
The Project site is located within an urban area that is fully developed. The Project site is adjacent to the two
other portions of the NB Golf Course; including: the 21.28-acre northern portion located northeast of the
Project site across Irvine Avenue that contains nine holes of golf (holes 10-18) and contains the 2,782 SF golf
course maintenance building. The 14.51-acre southern portion to the south of the Project site across Mesa
Drive that contains six holes of golf (holes 3-8). Additionally, the Santa Ana-Delhi Channel is located along
the northwesterly Project site boundary. The land uses immediately adjacent to the Project site include:
• Northwest: The Santa Ana-Delhi Channel followed by Irvine Avenue followed by multifamily residential.
• North: Irvine Avenue followed by “The Jetty” commercial center and nine holes of the NB Golf Course
(holes 10-18).
• Northeast: Commercial and Office Uses.
• Southeast: Newport Beach Fire Station 7 and Fire Department Training Center.
• South: Mesa Drive followed by six holes of the NB Golf Course (holes 3-8).
• Southwest: The Santa Ana-Delhi Channel followed by Mesa Drive, followed by “The Ranch” retail
shopping center.
5.10.3.4 John Wayne Airport
John Wayne Airport (SNA) is located approximately 0.4 miles northeast of the Project site. The Project site
is located within the airport planning boundaries and ALUC notification area as shown in Section 5.8, Hazards
and Hazardous Materials, on Figure 5.8-1, John Wayne Airport Notification Area. Also, as shown in Figure
5.8-2, 2024 John Wayne Airport Noise Contours, the Project site is located within the SNA 65 CNEL noise
contour, as measured by the airport, which indicates that noise from aircraft on the Project site is 65 dB CNEL
and is within the noise impact area related to SNA operations.
The City uses the 2014 airport noise contours for planning purposes, which are shown in Figure 5.10-2, City
Planning John Wayne Airport Noise Contours. As detailed, the City’s planning contours show the Project site
largely within the 65 CNEL noise contour with the southwestern portion of the site within the 60 CNEL noise
contour. Additionally, the AELUP includes noise contours for SNA that are based on volumes from airport
operations in 1985. As shown in Figure 5.10-3, AELUP 1985 John Wayne Airport Noise Contours, the AELUP
contours identify that a majority of the Project site is located within the 65 dBA CNEL and a small area in
the northeastern portion of the Project site is in the 70 dBA CNEL noise contour.
The airport has two runways: the shorter 2R/20L which is 2,887 feet long is used by general aviation prop-
powered aircraft and the longer 2L/20R which is 5,700 feet long is used by commercial aircraft. With winds
predominantly coming from the ocean, aircraft typically depart to the southwest and arrive from the
northeast about 95 percent of the time with slight variations from year to year. The reverse (depart to
northeast and arrive from southwest) occurs primarily when Santa Ana wind conditions occur, but there are
times when winds aloft, or other weather conditions may cause operations to go into reverse.
As detailed previously in Section 5.8, Hazards and Hazardous Materials, the Project site is also located under
the FAR Part 77 Obstruction Imaginary Surface area for both runways. As shown on Figure 5.8-5, FAA Part
77 Obstruction Imaginary Surfaces for Runway 2L/20R, a majority of the Project site is located under the
Approach Surface and the westernmost portion of the site is located under the Inner Transitional Surface for
the 2L/20R runway that is used by commercial aircraft. Figure 5.8-6, FAA Part 77 Obstruction Imaginary
Surfaces for Runway 2R/20L, shows that the Project site is under the Conical Surface for the 2R/20L runway.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-24
Draft EIR
May 2025
FAR Part 77 requires notification to FAA for any project that would be more than 200 feet in height above
ground level or within the imaginary surface of a 100:1 slope extending outward for 20,000 feet from the
nearest runway, as this area may result in aeronautical hazards. The Project site has previously undergone
FAA Park 77 evaluation as part of installation of poles on the existing driving range, which determined that
structures on the site that are below 162 feet above mean sea level (amsl) would not have a significant
adverse impact related to aeronautical hazards (FAA, 2016).
Because the Project site is located within the AELUP Notification area for SNA and within the SNA planning
area boundary, and the Project proposes a General Plan Amendment, the City is required to refer the
proposed Project to the ALUC for review, pursuant to the California Public Utilities Code Section 21676, as
listed previously.
City Planning John Wayne Airport Noise Contours
Figure 5-10.2Snug Harbor Surf Park Project
City of Newport Beach
65
0 200 400
Feet ±
Legend
Project Boundary
JWA 2014 CNEL Noise Contours
CNEL 60
CNEL 65
Sources: Esri, TomTom, Garmin, FAO, NOAA,
USGS, (c) OpenStreetMap contributors, and the
GIS User Community, Sources: Esri, Maxar, Airbus
DS, USGS, NGA, NASA, CGIAR, N Robinson,
NCEAS, NLS, OS, NMA, Geodatastyrelsen,
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-26
Draft EIR
May 2025
This page intentionally left blank.
AELUP 1985 John Wayne Airport Noise Contours
Figure 5-10.3Snug Harbor Surf Park Project
City of Newport Beach
6
5
70
0 200 400
Feet ±
Legend
Project Boundary
JWA 1985 CNEL Noise Contours
60
65
70
City of Costa Mesa, City of Newport Beach, County of
Los Angeles, Bureau of Land Management, Esri,
HERE, Garmin, INCREMENT P, USGS, EPA, USDA
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-28
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-29
Draft EIR
May 2025
5.10.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a Project could have a significant effect if it were to:
LU-1 Physically divide an established community.
LU-2 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.
5.10.5 METHODOLOGY
The analysis of physically dividing an established community identifies the existing land uses of the Project
site and adjacent areas prior to and after implementation of the proposed Project to determine if a potential
physical division would occur, including establishment of a new and inconsistent land use within or through an
existing established community and implementation of new streets or other infrastructure that has the
potential to result in a physical division.
The analysis of land use consistency impacts considers whether the proposed Project would be inconsistent
with (or conflict with) regional and local plans, policies, and regulations that are applicable to the proposed
Project, including the SCAG RTP/SCS, the AELUP for SNA, the City of Newport Beach General Plan, City of
Newport Beach City Council Policy Manual, City of Newport Beach Santa Ana Heights Specific Plan, and
the City’s Municipal Code. Consistent with the scope and purpose of this Draft EIR, this discussion primarily
focuses on those goals and policies that relate to avoiding or mitigating environmental impacts, and an
assessment of whether any inconsistency with these standards creates a significant physical impact on the
environment. Thus, a project’s inconsistency with a policy is only considered significant if such inconsistency
would cause significant physical environmental impacts (as defined by CEQA Guidelines Section 15382).
CEQA Guidelines Section 15125(d) requires that an EIR discuss inconsistencies with applicable plans that the
decision-makers should address. A project need not be consistent with each and every policy and objective
in a planning document. Rather, a project is considered consistent with the provisions of the identified regional
and local plans if it meets the general intent of the plans and would not preclude the attainment of the
primary goals of the land use plan or policy.
5.10.6 ENVIRONMENTAL IMPACTS
IMPACT LU-1: THE PROJECT WOULD NOT PHYSICALLY DIVIDE AN ESTABLISHED COMMUNITY.
Less than Significant Impact.
The physical division of an established community could occur if a major road (expressway or freeway, for
example) were built through an existing community or neighborhood, or if a major development were built
that was inconsistent with the land uses in the community such that it divided the community.
As described previously, the Project site has long been developed with a golf course, driving range, parking
lot, restaurant, and similar golf course facilities. The site is bound by roadways, the Santa Ana-Delhi Channel,
and commercial office development and Fire Department facilities. Although the Project site consists of the
central portion of the NB Golf Course (holes 1, 2, and 9), the site is currently physically separated from holes
10-18 to the north by Irvine Avenue and physically separated from holes 3-8 by Mesa Drive.
The Project would modify the site to provide a different type of commercial recreation facility, while
maintaining the portions of the commercial recreational golf course to the north (holes 10-18) and the south
(holes 3-8) of the site and the golf cart connectivity between the two golf course areas. The Project would
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-30
Draft EIR
May 2025
maintain a driveway location along Irvine Avenue and would provide a new 26-foot-wide driveway along
Mesa Drive. A 26-foot-wide internal roadway would connect the parking areas and the two driveways and
would provide additional connectivity. The Project would continue to support the golf course holes to the
north and south of the site by providing a starter shack, golf course parking, and golf cart storage. The
residential, commercial, and office communities that surround the Project site would remain the same. Although
a change to the existing golf course uses would occur as the number of holes would be reduced and the
driving range removed, a physical division of an established community would not occur.
In addition, the proposed Project would not change offsite roadways or install any infrastructure that would
result in a physical division. As detailed in Section 3.0, Project Description, the Project includes installation of
new infrastructure on the site that would connect to existing infrastructure that is adjacent to the site and
would not result in any physical division. Thus, the proposed Project would result in less-than-significant
impacts related to physical division of an established community.
IMPACT LU-2: THE PROJECT WOULD NOT 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.
SCAG Regional Transportation Plan/Sustainable Communities Strategy
The 2024 Connect SoCal regional planning policies provide guidance for integrating land use and
transportation planning. The proposed Project provides for redevelopment of a commercial recreation area
to provide a different type of recreational use in an already developed urban area that would make use
of the existing circulation and utility infrastructure, which is consistent with Connect SoCal policies related to
infill and redevelopment within urban areas. In addition, green building measures, such as water efficiency,
Low Impact Development (LID), and renewable energy sources would be implemented by the proposed
Project to reduce Project energy demands and GHG emissions.
The proposed Project would be consistent with the applicable 2024 Connect SoCal regional planning
policies, as detailed below in Table 5.10-2. Due to the consistency of the Project with the applicable policies,
implementation of the proposed Project would not result in conflict with SCAG 2024 Connect SoCal.
Table 5.10-2: Consistency with Applicable SCAG 2024 Connect SoCal Regional Planning Policies
2024 Connect SoCal Planning Policy Proposed Project Consistency with Policy
Mobility Policies Support
• Circulation System Preservation and
Resilience
• Development of Complete Streets
• Transit and Multimodal Integration
• Transportation System Management
• Transportation Demand Management
• Technology Integration
• Safety
• Funding the System/User Fees
Consistent. The Project does not propose any circulation changes
or roadway improvements. The Project site is adjacent to existing
sidewalks and bike paths and would provide bicycle parking
onsite. In addition, OCTA Bus Route 178 provides service along
Irvine Avenue with stops adjacent to the Project site. Thus, the
Project would not result in an inconsistency with the provision of
complete streets, use of transit, or multimodal integration. Project
visitors would be able to use existing sidewalks, bike paths, and
transit to use the proposed facilities. Thus, the Project is consistent,
and does not conflict with the 2024 Connect SoCal mobility policies.
Communities Policies Support
• Priority Development Areas
• Housing the Region
• 15-Minute Communities
• Equitable Engagement and Decision
Making
Consistent. The 2024 Connect document describes that
Communities policies support growth within areas of existing and
planned urban infrastructure, such as transit; with a focus on future
housing and population growth within a 15-minute walk, bike ride
or roll from their home. The Project would provide new surf-related
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-31
Draft EIR
May 2025
2024 Connect SoCal Planning Policy Proposed Project Consistency with Policy
recreational amenities within the existing recreational area that is
served by transit. The Project does not involve housing, and the site
has not been planned for housing. Thus, the Project is consistent, and
does not conflict, with the 2024 Connect SoCal communities policies.
Environmental Policies Support
• Sustainable Development
• Air Quality
• Clean Transportation
• Natural and Agricultural Lands
Preservation
• Climate Resilience
Consistent. The Project would be required to comply with
applicable Title 24/CALGreen requirements for sustainable
development and clean transportation. As detailed previously in
Section 5.2, Air Quality, Tables 5.2-7 and 5.2-8 identify that
neither construction nor operation of the Project would exceed any
thresholds for air quality emissions. The Project involves installation
of solar panels on the building roofs and parking lot canopies. As
detailed in Section 5.14, Transportation, impacts related to VMT
and clean transportation (from use of existing sidewalks, bike
paths, and bus routes). In addition, the proposed Project does not
include any agricultural land and does not involve conversion of
natural land uses into other uses. Therefore, the proposed Project is
consistent, and does not conflict, with the 2024 Connect SoCal
environmental policies.
Economy Policies Support
• Goods Movement
• Broadband
• Universal Basic Mobility
• Workforce Development
• Tourism
Consistent. The proposed Project supports workforce development
in the sports, entertainment, hospitality, and tourism industries. In
addition, the surf park and athlete accommodations support tourism
in Newport Beach. Therefore, the proposed Project is consistent and
does not conflict with the 2024 Connect SoCal economy policies.
Airport Environs Land Use Plan for John Wayne Airport
As described previously, SNA is located approximately 0.4 miles north/northeast of the Project site within
the airport planning boundaries, AELUP notification area, and under the FAR Part 77 Obstruction Imaginary
Surface area for both runways. Additionally, the AELUP includes noise contours for SNA that are based on
noise volumes from airport operations in 1985. As shown in Figure 5.10-3, AELUP 1985 John Wayne Airport
Noise Contours, the AELUP contours identify that a majority of the Project site is located within the 65 dBA
CNEL and a small area in the northeastern portion of the Project site is in the 70 dBA CNEL noise contour.
Table 5.10-3 provides an assessment of the proposed Project’s consistency with the AELUP policies for SNA.
As detailed, the proposed Project would be consistent with AELUP policies and the proposed Project would
not conflict with the AELUP for SNA.
Table 5.10-3: Consistency with John Wayne Airport Environs Land Use Plan Policies
AELUP Policy Proposed Project Consistency with Applicable Policy
Policy 3.2.1: Within the boundaries of the AELUP, any
land use may be found to be inconsistent with the AELUP
which:
1. Places people so that they are affected adversely
by aircraft noise,
2. Concentrates people in areas susceptible to
aircraft accidents,
3. Permits structures of excessive height in areas
which would affect adversely the continued
operation of the airport, or
Consistent. As shown and Figure 5.8-2, 2024 John
Wayne Airport Noise Contour, the Project site is located
within the SNA 65 CNEL noise contour, per most recent
noise measurements completed by the airport. In
addition, the AELUP noise contours shown in Figure 5.10-
3, identify that a majority of the Project site is located
within the 65 dBA CNEL and a small area in the
northeastern portion of the Project site is in the 70 dBA
CNEL noise contour. As detailed in Section 5.11, Noise,
the General Plan Land Use Noise Compatibility Matrix
(Table 5.11-1), identifies that commercial recreation
facilities are “normally compatible” up to 75 dBA CNEL,
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-32
Draft EIR
May 2025
AELUP Policy Proposed Project Consistency with Applicable Policy
4. Permits activities or facilities that would affect
adversely aeronautical operations.
and the AELUP for SNA states that community facilities
and commercial land uses are “conditionally consistent”
within the 70 CNEL contour (Table 5.11-3) with interior
sound attenuation. There are no proposed structures
proposed within the 70 CNEL contour. Only parking and
lagoon equipment would be located in the area.
Therefore, the proposed community related commercial
recreation facilities that are proposed for the site would
be consistent with the AELUP aircraft noise land use
planning, and people would not be adversely affected
by aircraft noise.
The Project would be operated through a reservation
and ticketing system and would not concentrate people
on the site. The maximum number of participants in the
lagoon at one time would be 72 people with an average
hourly usage of 35-45 people. In addition Section 5.8,
Hazards and Hazardous Materials, details that there is a
0.033% chance of an onsite accident per year, and as
per the California Airport Land Use Planning Handbook,
approximately, 0.11% of general aviation aircraft
accidents result in fatalities to people on the ground, this
yields a 0.000036% chance of a fatality per year, or
an approximate risk of 0.036 in 100,000 operations.
Thus, the site has limited susceptibility to aircraft
accidents. It should also be noted that the existing uses,
a golf course, driving range and restaurant, likewise
bring visitors to the Project site.
Section 5.8, Hazards and Hazardous Materials, also
details that the Project site has previously undergone
FAA evaluation, which determined that structures on the
site that are below 162 feet amsl would not have a
significant adverse impact related to aeronautical
hazards. As the tallest building structure would be 92
feet amsl and the light poles would be a maximum of
108 feet amsl, both would be below 162 feet amsl;
therefore, the Project structures would not have excessive
heights in areas which would adversely affect the
continued operation of the airport or adversely affect
aeronautical operations. Therefore, the proposed Project
is consistent with Policy 3.2.1.
Policy 3.2.3: Noise Impact Zone "1" - High Noise
Impact (65 dB CNEL and above). Noise impact in this
zone is sufficient to warrant restrictions on residential uses
and to require sound attenuation measures on other uses.
The ALUC does not support residential development
within the 65 dB CNEL noise contour. All residential units
are inconsistent in this area unless it can be shown
conclusively that such units are sufficiently sound
attenuated for present and projected noise exposures,
which shall be the energy sum of all noise impacting the
project, so as not to exceed an interior standard of 45
dB CNEL, with an accompanying dedication of an
avigation easement for noise to the airport proprietor
applicable to single family residences, multi-family
residences and mobile homes. Furthermore, all residential
units are to be sufficiently indoor oriented so as to
Consistent. As shown and Figure 5.10-3, the 1985
AELUP noise contours identify that a majority of the
Project site is located within the 65 dBA CNEL and a small
area in the northeastern portion of the Project site that is
planned for parking and wave lagoon machinery is in
the 70 dBA CNEL noise contour. This indicates that noise
from aircraft on a majority of the Project site is 65 dB
CNEL and that a small area of the parking lot and wave
equipment area is within the 70 dB CNEL noise impact
area related to SNA operations. However, as detailed
in Section 5.11, Noise (Table 5.11-3), the AELUP for SNA
states that community facilities and commercial land uses
are “conditionally consistent” within the 70 CNEL contour
with interior sound attenuation. There are no proposed
structures proposed within the 70 CNEL contour. Only
parking and lagoon equipment would be located in the
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-33
Draft EIR
May 2025
AELUP Policy Proposed Project Consistency with Applicable Policy
preclude noise impingement on outdoor living areas, as
defined in Section 1.7.
Noise-sensitive institutional uses such as schools, churches,
hospitals, libraries, and other noise-sensitive uses may
also be inconsistent in this zone. All noise-sensitive uses
are inconsistent in this area unless it can be shown
conclusively that such units are sufficiently sound
attenuated for present and projected noise exposures,
which shall be the energy sum of all noise impacting the
project, so as not to exceed an interior standard of 45
dB CNEL, and may require the dedication of an avigation
easement for noise to the airport proprietor. Commercial,
industrial, and recreational uses may be acceptable in
this zone providing that commercial and industrial
structures are sufficiently sound attenuated to allow
normal work activities to be conducted. Said structures
shall be sound attenuated against the combined input of
all present and projected exterior noise to meet the
following criteria:
Private office1, church sanctuary,
board room, conference room, etc.
45 dB(A)
General office2, reception, clerical etc. 50 dB(A)
Bank lobby, retail store, restaurant,
typing pool, etc.
55 dB(A)
Manufacturing, kitchen, warehousing,
etc.
60 B(A)
*L(eq) is the equivalent sound level for a specified
time period in dB(A).
**Measures from 7:00 a.m. to 7:00 p.m. or other
appropriate, approved time period.
1An enclosed office intended for use by an individual
2 An open office intended to have more than one
work station.
area. Therefore, the proposed community related
commercial recreation facilities that are proposed for the
site would be consistent with the AELUP aircraft noise
land use planning.
The Project does not include typical noise sensitive uses,
such as residential, schools, or churches. The Project does
include 20 athlete accommodation units, which would
provide short-term lodging for surfers and related
visitors. As detailed in Section 5.11, Noise, existing
ambient noise levels near the site range from 67.8 to
73.7 dBA. Additionally, as described in Section 5.11,
Noise, the proposed Project would comply with
California Noise Insulation Standards, Title 24 California
Code of Regulations that require interior noise levels to
not exceed 45 dBA CNEL.
Therefore, the proposed Project is consistent with Policy
3.2.3.
Policy 3.2.4: Noise Impact Zone “2” – Moderate Noise
Impact (60 dB CNEL or greater, less than 65 dB CNEL).
Noise impacts in this area are sufficient to require sound
attenuation as set forth in the California Noise Insulation
Standards, Title 25, California Code of Regulations.
Single noise events in this area create serious
disturbances to many inhabitants. Even though the
Commission would not find residential units incompatible
in this area, the Commission strongly recommends that
residential units be limited or excluded from this area
unless sufficiently sound attenuated. The residential use
interior sound attenuation requirement shall be a CNEL
value not exceeding an interior level of 45 dB. In
addition, it is recommended that designated outdoor
common or recreational areas within Noise Impact Zone
2 provide outdoor signage informing the public of the
presence of operating aircraft.
Consistent. The Project site is not located within Noise
Impact Zone 2. As shown in Figure 5.10-3, the Project site
is identified by the AELUP as being located within the
SNA 65 and 70 CNEL noise contours, which indicates that
noise from aircraft on the Project site is 65 to 70 dB CNEL
and is within the noise impact area related to SNA
operations.
However, as detailed in Section 5.11, Noise, the AELUP
for SNA states that community facilities and commercial
land uses are “conditionally consistent” within the 70
CNEL contour with interior sound attenuation. There are
no proposed structures proposed within the 70 CNEL
contour. Only parking and lagoon equipment would be
located in the area. Therefore, the proposed community
related commercial recreation facilities that are
proposed for the site would be consistent with the AELUP
aircraft noise land use planning.
Additionally, as described in Section 5.11, Noise, the
proposed Project would comply with California Noise
Insulation Standards, Title 24 California Code of
Regulations that require interior noise levels to not
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-34
Draft EIR
May 2025
AELUP Policy Proposed Project Consistency with Applicable Policy
exceed 45 dBA CNEL. Therefore, the proposed Project
is consistent with Policy 3.2.4.
Policy 3.2.5: Runway Protection Zone “RPZ,” Extreme
Crash Hazard. The severe potential for loss of life and
property due to accidents prohibits most land uses in this
area. Only airport related uses and open space uses,
including agriculture and certain types of transportation
and utility uses are permitted. No buildings intended for
human habitation are permitted in the RPZ. Furthermore,
because of the proximity to aeronautical operations, uses
in this area must not attract birds nor emit excessive glare
or light, nor produce or cause steam, smoke, dust, or
electronic interference so as to interfere with, or
endanger, aeronautical operations.
Consistent. The Project site is not located within the
Runway Protection Zone, as detailed in Section 5.8,
Hazards and Hazardous Materials. Therefore, the
proposed Project is consistent with Policy 3.2.5.
Policy 3.2.6: Height Restriction Zone. Any object, which
by reason of its height or location would interfere with
the established, or planned, airport flight procedures,
patterns, or navigational systems, is unacceptable. This
will ensure the stability of local air transportation, as well
as promote land uses that are compatible with the
airport environs. However, any object which rises above
the height of surrounding development, or which is
located in close proximity to any of the various flight
paths, must be clearly visible during hours of twilight or
darkness and must not threaten, endanger, or interfere
with aeronautical operations.
Consistent. The Project site is within the SNA FAR Part
77 Notification Imaginary Surface area, which requires
notification to FAA for any project that would exceed a
100:1 slope of an imaginary surface extending outward
for 20,000 feet from the nearest runway at SNA or
would be more than 200 feet in height above the ground
level. Section 5.8, Hazards and Hazardous Materials,
details that the Project site has previously undergone
FAA evaluation, which determined that structures on the
site that are below 162 feet amsl would not have a
significant adverse impact related to aeronautical
hazards. The tallest proposed building structure would
be 92 feet amsl and the proposed light poles would be
a maximum of 108 feet amsl. Thus, both would be below
162 feet amsl, and the Project structures would not have
excessive heights in areas which would adversely affect
the continued operation of the airport or adversely
affect aeronautical operations. Therefore, the Project is
consistent with Policy 3.2.6.
Policy 3.2.7: Airspace/Airport Inconsistency. Any
structure, either within or outside of the planning area, is
inconsistent with this AELUP if it:
1. Is determined to be a “Hazard” by the FAA;
2. Would raise the ceiling or visibility minimums at an
airport for an existing or planned instrument
procedure (i.e., a procedure consistent with the FAA
approved airport layout plan or a proposed
procedure formally on file with the FAA);
3. Would result in a loss in airport utility, e.g. in a
diminution of the established operational efficiency
and capacity of the airport, such as by causing the
usable length of the runway(s) to be reduced; or
4. Would conflict with air space used for the airport
traffic pattern or enroute navigation to and from
the airport.
Consistent. Section 5.8, Hazards and Hazardous
Materials, details that the Project site has previously
undergone FAA evaluation, which determined that
structures on the site that are below 162 feet amsl would
not have a significant adverse impact related to
aeronautical hazards. The tallest proposed building
structure would be 92 feet amsl and the proposed light
poles would be a maximum of 108 feet amsl. Thus, both
would be below 162 feet amsl, and the Project structures
would not have excessive heights in areas which would
adversely affect the continued operation of the airport
or adversely affect aeronautical operations. Thus, the
Project would not be a hazard, raise the visibility
minimums, result in a loss of airport utility, or conflict with
air space.
Overall, the proposed structures would not adversely
affect SNA aeronautical operations and would comply
with AELUP and FAR Part 77 notification requirements.
Therefore, the proposed Project is consistent with Policy
3.2.7.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-35
Draft EIR
May 2025
City of Newport Beach Local Coastal Program – Coastal Land Use Plan and Implementation Plan
As described previously and shown in Figure 3-7, Coastal Zone Boundary, in Section 3.0, Project Description,
the Project site is adjacent to areas that are within the Coastal Zone. The Project site is not located within the
Coastal Zone and is not within the jurisdiction of the LUP. The proposed Project would result in the replacement
of existing onsite infrastructure with new offsite connections to the existing infrastructure within Mesa Drive
adjacent to the site and install new roadway striping within Mesa Drive.
The Project proposes three improvements within the Mesa Drive right-of-way, as depicted on Figure 5.10-1,
Proposed Improvements within Mesa Drive. These improvements include a driveway relocation, roadway
striping (i.e., paint), and a sewer line improvement. These improvements are exempt from the need for a
CDP, consistent with the City’s LCP IP Section 21.52.035 (Projects Exempt from Coastal Development Permit
Requirements).
Driveway Relocation and Roadway Striping. The existing driveway to the Project site along Mesa Drive is
undersized and does not meet City or accessibility standards. The Project includes relocation of the driveway
approximately 200 feet to the east, away from the Irvine Avenue intersection, and build it to current 26-
foot-wide driveway standards. The driveway relocation includes closing the existing driveway within the
right-of-way, converting the existing curb returns to a curb and gutter, and resurfacing the sidewalk. The
relocated driveway would include new curb returns, resurfacing, and roadway striping to denote the
driveway turn. The City’s LCP IP Section 21.52.035(C)(4) allows for repair and maintenance activities, except
for activities that involve a risk of substantial adverse environmental impacts. The driveway relocation is
within developed paved areas and, as detailed below, does not involve any of the activities listed in
21.52.035(C)(4)(a-d), and would not result in substantial adverse environmental impacts for the following
reasons:
a. Any method of repair or maintenance of a seawall revetment, bluff retaining wall, breakwater, groin,
culvert, outfall, or similar shoreline work…
The driveway relocation and striping does not involve any repair or maintenance to a seawall, bluff retaining
wall, breakwater, groin, culvert, outfall or similar shoreline work. The driveway relocation is not sited
proximate to any of the features identified in subsection a above.
b. Any method of routine maintenance dredging…
The driveway relocation and striping does not involve any dredging. This section is not applicable.
c. Any repair or maintenance to facilities or structures or work located in an environmentally sensitive habitat
area, or any sand area, within fifty (50) feet of the edge of a coastal bluff or environmentally sensitive
habitat area; or within twenty (20) feet of any coastal waters and streams…
The driveway relocation is on the inland side of Mesa Drive and is not located in proximity to any of the
areas identified in subsection (c) above. Mesa Drive is not located within 50 feet of the edge of a coastal
bluff or environmentally sensitive habitat area or within 20 feet of coastal waters or streams. Mesa Drive is
an existing paved street with a curb, gutter, sidewalk and roadway striping. The Biological Technical Report
for the Snug Harbor Project, included as Appendix C, concludes that there is no environmentally sensitive
habitat area and the driveway relocation would not impact any of the areas identified in subsection c above.
d. Unless destroyed by disaster, the replacement of fifty (50) percent or more of a single-family residence,
seawall, revetment, bluff retaining wall, breakwater, groin or any other structure is not repair and
maintenance under California Public Resources Code Section 30610(d) but instead constitutes a replacement
structure requiring a coastal development permit.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-36
Draft EIR
May 2025
The driveway relocation and striping would not constitute replacement of more than 50 percent of any
structure and subsection d is not applicable.
Sewer Line Replacement. The existing 6-inch sewer line in Mesa Drive that extends approximately 42.5
feet offsite to the 12-inch sewer main would be upgraded with a new 12-inch sewer line in an easterly
direction approximately 20 feet away from the Irvine Avenue intersection. The replacement would be
installed in the location of the existing driveway and would connect to the existing 12-inch sewer line in Mesa
Drive in the location of the existing manhole, which would accommodate on-going maintenance. The existing
6-inch sewer line is more than 50 years old and needs to be replaced to accommodate the proposed Project.
IP Section 21.52.035(C)(5) Utility Connections. The installation, testing and placement in service or the
replacement of any necessary utility connection between an existing service facility and any development
approved pursuant to the Coastal Act or the certified LCP; provided, however, that the City or the Coastal
Commission may, where necessary, require reasonable conditions to mitigate any adverse impacts on coastal
resources, including scenic resources…
The sewer line replacement would not result in any impacts to coastal resources including scenic resources
because the work would occur within the existing paved portion of Mesa Drive and would be located
underground. The work would require a temporary lane closure on Mesa Drive but would not result in closure
of Mesa Drive or result in any impact to coastal resources as there is no coastal access in the immediate
area, no environmentally sensitive habitat area, and no other coastal resources in the immediate vicinity of
the Project site, as further detailed in Section 5.3, Biological Resources.
IP Section 21.52.035(C)(5) exempts utility connections, including the replacement of any necessary utility
connection between an existing service facility and any development approved pursuant to the Coastal Act
or certified LCP. In this case, the Project site is located adjacent to and outside of the Coastal Zone boundary,
and does not require a CDP. Consistent with California Code of Regulations Section 13050.5(a), for a
development located inside and outside the coastal zone, including any structure, similar integrated physical
construction, or division of land, a CDP shall be required for only those portions of the development located
within the coastal zone. As such, it is not necessary for the development, which is outside of the Coastal Zone,
to secure a CDP.
City of Newport Beach General Plan
The Project site has a General Plan land use designation of Parks and Recreation (PR), permits parks (both
active and passive), golf courses, marina support facilities, aquatic facilities, tennis clubs and courts, private
recreation, and similar facilities. The proposed Project would remove the existing golf-related facilities on
the site and redevelop the site with surf park facilities, while continuing to provide parking, a starter shack,
golf cart storage, and golf cart paths for the remaining golf course areas to the north and south of the
proposed Project. The proposed surf park would implement the existing land use designation providing both
active and passive (spectator) recreation. The PR land use designation allows for both aquatic facilities and
private recreation. Thus, the proposed Project would be consistent with the existing PR land use designation.
The Project site currently has a General Plan identification as Anomaly Number 58, with a development limit
of 20,000 SF related to the existing golf course uses on the site. The proposed Project would change the
existing uses and includes a General Plan Amendment to increase the development limit to 59,772 net SF to
accommodate the proposed clubhouse, athletic facilities, and athlete accommodations. The existing and
proposed development limit is specific to the Project site and implementation of the Project would not result
in a conflict related to avoiding or mitigating an environmental effect.
A detailed analysis of the proposed Project’s consistency with the applicable General Plan policies that serve
to avoid or mitigate environmental impacts is provided in Table 5.10-4. As described, the proposed Project
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-37
Draft EIR
May 2025
would be consistent with the relevant policies, and impacts related to conflict with a General Plan policy
related to an environmental effect would be less than significant.
Table 5.10-4: General Plan Policy Consistency Analysis
Relevant General Plan Policies Project Consistency
Land Use Element
LU 1.6 Public Views. Protect and, where feasible,
enhance significant scenic and visual resources that
include open space, mountains, canyons, ridges, ocean,
and harbor from public vantage points.
Consistent. As discussed in Section 5.1, Aesthetics, all
development within the proposed Project site would be
set back from adjacent streets and would not encroach
on the existing public long-distance views. The proposed
buildings would have a minimum setback 20 feet from
Mesa Drive, and 20 feet from Irvine Avenue. These
setbacks would protect, and the proposed landscaping
along the roadways would enhance public views.
Therefore, the Project is consistent with Policy LU 1.6.
LU 2.1 Resident-Serving Land Uses. Accommodate uses
that support the needs of Newport Beach’s residents
including housing, retail, services, employment,
recreation, education, culture, entertainment, civic
engagement, and social and spiritual activity that are in
balance with community natural resources and open
spaces.
Consistent. As discussed in Section 3.0, Project
Description, the proposed Project would develop a
commercial recreational facility including a surf lagoon,
amenity clubhouse, and athlete accommodations. The
proposed uses would provide employment, recreation,
culture, entertainment, and social activity in balance with
community natural resources and open spaces. Therefore,
the Project is consistent with Policy LU 2.1.
LU 2.2 Sustainable and Complete Community.
Emphasize and support the development of uses that
enable Newport Beach to be a complete community that
maintains the ability to provide locally accessible
opportunities for retail, goods and services, and
employment.
Consistent. As discussed in Section 3.0, Project
Description, the proposed Project would develop a
commercial recreational facility including a surf lagoon,
amenity clubhouse, and athlete accommodations that
would provide retail goods and services, and
employment. Therefore, the Project is consistent with
Policy LU 2.2.
LU 2.5 Visitor Serving Uses. Provide uses that serve
visitors to Newport Beach’s ocean, harbor, open spaces,
and other recreational assets, while integrating them to
protect neighborhoods and residents.
Consistent. As discussed in Section 3.0, Project
Description, the proposed Project would develop a
commercial recreational facility including a surf lagoon,
amenity clubhouse, and athlete accommodations that
would be integrated between golf course holes 10-8 to
the north of the site across Irvine Avenue and holes 3-8
to the south of the site across Mesa Drive. The Project
would be integrated into the existing development,
between the existing roadways and the Santa Ana-Delhi
Channel, along an arterial roadway near freeway
access. Therefore, the Project is consistent with Policy LU
2.5.
LU 2.8 Adequate Infrastructure. Accommodate the
types, densities, and mix of land uses that can be
adequately supported by transportation and utility
infrastructure (water, sewer, storm drainage, energy,
and so on) and public services (schools, parks, libraries,
seniors, youth, police, fire, and so on).
Consistent. As discussed in Section 5.14, Transportation,
the proposed Project would result in 186 net new vehicle
trips that would be accommodated by the existing street
system. As discussed in Section 5.16, Utilities and Service
Systems, implementation of the proposed Project would
not result in the need for expanded utility infrastructure
or provision of services. The proposed Project would be
served by the existing infrastructure that is adequate to
serve the Project and surrounding areas. Also, as
detailed in Section 5.12, Public Services, the proposed
Project would not require expansion or construction of
new public facilities to serve the Project along with other
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-38
Draft EIR
May 2025
Relevant General Plan Policies Project Consistency
service needs. Therefore, the Project is consistent with
Policy LU 2.8.
LU 3.1 Neighborhoods, Districts, Corridors, and Open
Spaces. Maintain Newport Beach’s pattern of residential
neighborhoods, business and employment districts,
commercial centers, corridors, and harbor and ocean
districts.
Consistent. As discussed in Section 3.0, Project
Description, the proposed Project would develop a
commercial recreational facility including a surf lagoon,
amenity clubhouse, and athlete accommodations on the
Project site, which would change the type of commercial
recreation provided on the site. The Project would
maintain and support the golf course holes 10-18 to the
north of the site, across Irvine Avenue, and holes 3-8 to
the south of the site across Mesa Drive. The Project would
not modify the street system that surrounds the site and
would not change the pattern of development within the
area. Therefore, the Project is consistent with Policy LU
3.1.
LU 3.2 Growth and Change. Enhance existing
neighborhoods, districts, and corridors, allowing for re-
use and infill with uses that are complementary in type,
form, scale, and character. Changes in use and/or
density/intensity should be considered only in those
areas that are economically underperforming, are
necessary to accommodate Newport Beach’s share of
projected regional population growth, improve the
relationship and reduce commuting distance between
home and jobs, or enhance the values that distinguish
Newport Beach as a special place to live for its residents.
The scale of growth and new development shall be
coordinated with the provision of adequate
infrastructure and public services, including standards for
acceptable traffic level of service.
Consistent. As discussed in Section 3.0, Project
Description, the proposed Project would redevelop the
site to provide a different type of commercial
recreational use; changing the existing golf-related
facilities to a surf lagoon, amenity clubhouse, and athlete
accommodations that would result in approximately the
same number of employees on the site (as detailed in
Section 3.0, Project Description). Thus, unplanned growth
would not occur. Also, as discussed in Sections 5.12, Public
Services, and 5.14, Transportation, the proposed Project
would not result in impacts related to the street system or
public services. Therefore, the Project is consistent with
Policy LU 3.2.
LU 3.3 Opportunities for Change. Support opportunities
for new development and improved physical
environments for residents, businesses, and visitors in the
following districts and corridors, as specified in Polices
6.3.1 through 6.22.7:
Santa Ana Heights: Support continued implementation
of the adopted Specific Plan and Redevelopment Plan.
Consistent. As discussed in Section 3.0, Project
Description, the proposed Project would redevelop the
existing golf-related facilities to a surf lagoon, amenity
clubhouse, and athlete accommodations. As detailed
within this section, the Project would implement the Santa
Ana Heights Specific Plan land use designation for the
site. The proposed Project would result in a new
development with an improved physical environment and
the facility would be available to residents and visitors,
and would support local visitor and surf recreation
related businesses. Therefore, the Project is consistent
with Policy LU 3.3.
LU 3.7 Natural Resource and Hazardous Areas.
Require that new development is located and designed
to protect areas with high natural resource value and
protect residents and visitors from threats to life or
property.
Consistent. The proposed Project is located on a site that
is currently developed and surrounded by developed
urban uses. The Project is not located within or adjacent
to areas of high resource value; and as detailed in
Section 5.8, Hazards and Hazardous Materials, the
Project would not result in threats to life or property.
Therefore, the Project is consistent with Policy LU 3.7.
LU 3.8 Project Entitlement Review with Airport Land
Use Commission. Refer the adoption or amendment of
the General Plan, Zoning Code, specific plans, and
Planned Community development plans for land within
the John Wayne Airport planning area, as established in
the JWA Airport Environs Land Use Plan (AELUP), to the
Consistent. As discussed in Section 5.8, Hazards and
Hazardous Materials, because the Project site is located
within the AELUP Notification area for SNA and within
the SNA planning area boundary, and the Project
proposes a General Plan Amendment, the City is
required to refer the proposed Project to the ALUC for
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-39
Draft EIR
May 2025
Relevant General Plan Policies Project Consistency
Airport Land Use Commission (ALUC) for Orange County
for review, as required by Section 21676 of the
California Public Utilities Code. In addition, refer all
development projects that include buildings with a height
greater than 200 feet above ground level to the ALUC
for review.
review, pursuant to the California Public Utilities Code
Section 21676. Therefore, the Project is consistent with
Policy LU 3.8.
LU 4.1 Land Use Diagram. Support land use
development consistent with the Land Use Plan. Figure
LU1 depicts the general distribution of uses throughout
the City and Figure LU2 through Figure LU15 depict
specific use categories for each parcel within defined
Statistical Areas. Table LU1 (Land Use Plan Categories)
specifies the primary land use categories, types of uses,
and, for certain categories, the densities/intensities to be
permitted. The permitted densities/intensities or amount
of development for land use categories for which this is
not included in Table LU1, are specified on the Land Use
Plan, Figure LU4 through Figure LU15. These are
intended to convey maximum and, in some cases,
minimums that may be permitted on any parcel within the
designation or as otherwise specified by Table LU2
(Anomaly Locations). The density/intensity ranges
exclude increases allowed through the applications of
density bonus laws and are calculated based on actual
land area, actual number of dwelling units in fully
developed residential areas, and development potential
in areas where the General Plan allows additional
development.
To determine the permissible development, the user
should:
a. Identify the parcel and the applicable land use
designation on the Land Use Plan, Figure LU4
through Figure LU15
b. Refer to Figure LU4 through Figure LU15 and Table
LU1 to identify the permitted uses and permitted
density or intensity or amount of development for the
land use classification. Where densities/intensities
are applicable, the maximum amount of
development shall be determined by multiplying the
area of the parcel by the density/intensity.
c. For anomalies identified on the Land Use Map by a
symbol, refer to Table LU2 to determine the precise
development limits.
b. d. For residential development in the Airport Area.,
refer to the policies prescribed by the Land Use
Element that define how development may occur.
Consistent. As discussed above, the proposed Project
would be consistent with the site’s current General Plan
Land Use Designation of Parks and Recreation which
permits parks (both active and passive), golf courses,
marina support facilities, aquatic facilities, tennis clubs
and courts, private recreation, and similar facilities (City
of Newport Beach, 2006). The proposed Project would
require a General Plan Amendment in order to modify
Anomaly Number 58 that currently limits the allowable
increase in development on the site to 20,000 SF. With
implementation of the General Plan Amendment,
development of the proposed Project would be consistent
with the Geneal Plan development allowances for the
site. Therefore, the Project is consistent with Policy LU 4.1.
Policy LU 5.6.2. Form and Environment. Require that
new and renovated buildings be designed to avoid the
use of styles, colors, and materials that unusually impact
the design character and quality of their location such as
abrupt changes in scale, building form, architectural
style, and the use of surface materials that raise local
temperatures, result in glare and excessive illumination
of adjoining properties and open spaces, or adversely
modify wind patterns.
Consistent. As discussed in Section 5.1, Aesthetics, the
proposed two- and three-story buildings would be
consistent with the two- to three-story high commercial
office buildings that are located on Mesa Drive, Acacia,
and Irvine Avenue to the northwest of the site; and the
three-story fire training tower that is adjacent to the site.
The proposed development provides the same type of
modern visual character as surrounding residential,
commercial, and office development that surrounds the
site.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-40
Draft EIR
May 2025
Relevant General Plan Policies Project Consistency
In addition, the Project lighting would be required to
comply with Municipal Code Section 21.30.070,
Outdoor Lighting, through the City’s permitting process to
ensure that it would not result in glare and excessive
illumination of adjoining properties. Therefore, the
Project is consistent with Policy LU 5.6.2.
Policy LU 5.6.3. Ambient Lighting. Require that outdoor
lighting be located and designed to prevent spillover
onto adjoining properties or significantly increase the
overall ambient illumination of their location.
Consistent. As discussed in Section 5.1, Aesthetics, the
Project lighting would be required to comply with
Municipal Code Section 21.30.070, Outdoor Lighting,
through the City’s permitting process to ensure that it
would not result in glare and excessive illumination of
adjoining properties. Therefore, the Project is consistent
with Policy LU 5.6.3.
Historical Resources Element
HR 2.1 New Development Activities. Require that, in
accordance with CEQA, new development protect and
preserve paleontological and archaeological resources
from destruction, and avoid and mitigate impacts to such
resources. Through planning policies and permit
conditions, ensure the preservation of significant
archeological and paleontological resources and require
that the impact caused by any development be
mitigated in accordance with CEQA.
Consistent. As discussed in Section 5.4, Cultural
Resources, and Section 5.6, Geology and Soils, both
archeological and paleontological resources studies
were conducted (included as Appendix E and I,
respectively). Mitigation Measures CUL-1, CUL-2, and
PAL-1 have been included to ensure that no significant
impacts to either archeological or paleontological
resources would occur. Therefore, the Project is consistent
with Policy HR 2.1.
HR 2.2 Grading and Excavation Activities. Maintain
sources of information regarding paleontological and
archeological sites and the names and addresses of
responsible organizations and qualified individuals, who
can analyze, classify, record, and preserve
paleontological or archeological findings. Require a
qualified paleontologist/archeologist to monitor all
grading and/or excavation where there is a potential to
affect cultural, archeological or paleontological
resources. If these resources are found, the applicant
shall implement the recommendations of the
paleontologist/archeologist, subject to the approval of
the City Planning Department.
Consistent. As discussed in Section 5.4, Cultural
Resources, and Section 5.6, Geology and Soils, both
archeological and paleontological resources studies
were conducted (included as Appendix E and I,
respectively). Mitigation Measures CUL-1, CUL-2, and
PAL-1 have been included to provide for archeological
and paleontological monitoring on the site during
grading and excavation activities to ensure that
significant impacts to archeological and paleontological
resources would not occur. Therefore, the Project is
consistent with Policy HR 2.2.
HR 2.3 Cultural Organizations. Notify cultural
organizations, including Native American organizations,
of proposed developments that have the potential to
adversely impact cultural resources. Allow
representatives of such groups to monitor grading
and/or excavation of development sites.
Consistent. In accordance with AB 52 and SB 18, the
City sent letters to 20 Native American representatives
identified by NAHC, notifying them of the proposed
Project. Agency to agency consultation occurred between
the City and two tribes who stated that they have cultural
affiliation with the Project region. While none of the
tribes presented substantial evidence indicating that
tribal cultural resources are present on the site,
Mitigation Measures TCR-1 through TCR-3 have been
included to provide for Native American monitoring on
the site during grading and excavation activities to
ensure that significant impacts to tribal cultural resources
would not occur. Therefore, the Project is consistent with
Policy HR 2.3.
HR 2.4 Paleontological or Archaeological Materials.
Require new development to donate scientifically
valuable paleontological or archaeological materials to
a responsible public or private institution with a suitable
Consistent. As discussed in Section 5.4, Cultural
Resources, and Section 5.6, Geology and Soils, both
archeological and paleontological resources studies
were conducted (included as Appendix E and I,
respectively). Mitigation Measures CUL-1, CUL-2, and
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-41
Draft EIR
May 2025
Relevant General Plan Policies Project Consistency
repository, located within Newport Beach, or Orange
County, whenever possible.
PAL-1 would ensure that there would be no significant
impacts on either archeological or paleontological
resources. Therefore, the Project is consistent with Policy
HR 2.4.
Circulation Element
CE 2.2.1 Safe Roadways. Provide for safe roadway
conditions by adhering to nationally recognized
improvement standards and uniform construction and
maintenance practices.
Consistent. As discussed in Section 5.14, Transportation,
the proposed Project does not include improvements to
public roadways. However, the new driveways that
would provide vehicular access to the site and the onsite
circulation would be required to adhere to the City’s
public works and engineering recognized improvement
standards and uniform construction and maintenance
practices that would be verified through the City’s
construction permitting process. Therefore, the Project is
consistent with Policy CE 2.2.1.
CE 2.2.4 Traffic Control. Design traffic control measures
to ensure City streets and roads function with safety and
efficiency for vehicles, bicycles, and pedestrians.
Consistent. As discussed in Section 5.14, Transportation,
the proposed Project does not include traffic control
measures for public roadways. However, the new
driveways that would provide vehicular access to the site
and the onsite circulation would be required to adhere
to the City’s public works and engineering recognized
traffic control standards that would be verified through
the City’s construction permitting process. Therefore, the
Project is consistent with Policy CE 2.2.4.
CE 2.2.5 Driveway and Access Limitations. Limit
driveway and local street access on arterial streets to
maintain a desired quality of traffic flow and limit
hazards to active transportation modes. Wherever
possible, consolidate and/or reduce the number of
driveways and implement access controls during
redevelopment of adjacent parcels.
Consistent. As discussed in Section 5.14, Transportation,
the proposed Project would provide two driveway
locations to access the site from two sides. In addition,
City permitting would ensure that ingress and egress is
consistent with the City of Newport Beach General Plan
Circulation Element and development standards.
Therefore, the Project is consistent with Policy CE 2.2.5.
CE 2.2.7 Emergency Access. Provide all residential,
commercial, and industrial areas with efficient and safe
access for emergency vehicles. An emergency evacuation
map shall be prepared as part of an updated Safety
Element.
Consistent. As discussed in Section 5.14, Transportation,
the proposed Project would provide two driveway
locations to access the site from two sides. In addition,
City permitting would ensure that ingress and egress is
consistent with the requirements in Section 503 of the
California Fire Code (Title 24, California Code of
Regulations, Part 9). Therefore, the Project would
provide efficient and safe access for emergency vehicles
and would be consistent with Policy CE 2.2.7.
CE 5.2.6 Pedestrian Improvements in New
Development Projects. Require new development
projects to include safe and attractive sidewalks,
walkways, and bike lanes in accordance with the Master
Plan, and, if feasible, trails.
Consistent. As discussed in Section 5.14, Transportation,
bike lanes and sidewalks currently exist adjacent to the
Project site. The Project would provide onsite pedestrian
walkways that would connect to the offsite sidewalks and
bicycle parking facilities. Therefore, the Project provides
onsite pedestrian and bicycle related improvements and
is consistent with Policy CE 5.2.6.
CE 5.2.12 Bicycle Supporting Amenities. Require
bicycle facilities such as bike racks, bike stations, or
lockers according to national standards for long-term
and short-term bicycle utilization on City property and
with new development and encourage the addition of
such bicycle facilities within existing development.
Consistent. As discussed in Section 3.0, Project
Description, and Section 5.14, Transportation, the
proposed Project would include installation of both
temporary and long-term bicycle parking areas.
Therefore, the Project is consistent with Policy CE 5.2.12.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-42
Draft EIR
May 2025
Relevant General Plan Policies Project Consistency
CE 7.1.1 Vehicle Miles Traveled (VMT) Analysis.
Follow the analysis methodology for vehicle miles
traveled according to the Newport Beach VMT
thresholds policy and as required in Senate Bill 743 and
the revised California Environmental Quality Act (CEQA)
Guidelines.
Consistent. As detailed in Section 5.14, Transportation,
the analysis of VMT for the proposed Project follows the
City’s VMT thresholds policy and as required in SB 743
and CEQA. Therefore, the Project is consistent with Policy
CE 7.1.1.
CE 7.1.2 VMT Mitigation Measures. Require
implementation of CEQA project related VMT mitigation
measures when warranted and monitor reductions in VMT
from new development.
Consistent. As discussed in Section 5.14, Transportation,
the proposed Project would not result in a potentially
significant impact related to VMT and mitigation
measures are not warranted. Therefore, the Project is
consistent with Policy CE 7.1.1.
CE 7.1.5 Support Facilities for Alternative Modes.
Require new development projects to provide facilities
commensurate with development type and intensity to
support alternative modes, such as preferential parking
for carpools, bike racks, bike stations, bicycle lockers,
showers, commuter information areas, rideshare vehicle
loading areas, water transportation docks, and bus stop
improvements.
Consistent. As discussed in Section 3.0, Project
Description, and Section 5.14, Transportation, the
proposed Project supports alternative modes of travel
and includes a drop-off and pick-up area for carpools
and ride-shares, bicycle parking, and onsite pedestrian
walkways that would complement the existing offsite
sidewalks and bike paths. Therefore, the Project is
consistent with Policy CE 7.1.5.
CE 7.1.7 Project Site Design Supporting Alternative
Modes. Encourage increased use of public transportation
by requiring project site designs that facilitate the use of
public transportation and walking.
Consistent. As discussed in Section 3.0, Project
Description, and Section 5.14, Transportation, the
proposed Project supports alternative modes of travel
and includes onsite pedestrian walkways that would
complement the existing offsite sidewalks on Irvine
Avenue with bus stops for OCTA Bus Route 178.
Therefore, the Project facilitates the use of public
transportation and walking and is consistent with Policy
CE 7.1.7.
CE 7.1.8 Electric Vehicle (EV) Charging Stations. Install
additional EV charging stations on City properties,
support existing private development to add new EV
charging stations and develop incentives for the
installation of EV charging stations and other alternative
fuels systems as part of new development.
Consistent. As discussed in Section 3.0, Project
Description and Section 5.14, Transportation, the
proposed Project includes installation of EV charging
stations and EV parking spots on the Project site.
Therefore, the Project is consistent with Policy CE 7.1.8.
CE 9.1.10 Development Requirements. Require
development to provide the needed roadway
improvements adjacent to a site, commensurate with
project impact and in accordance with the Master Plan
of Streets and Highways.
Consistent. As discussed in Section 5.14, Transportation,
the proposed Project would not require or include any
roadway improvements. However, the proposed
driveways and onsite vehicular circulation would be
required to adhere to the City’s public works and
engineering recognized traffic control standards that
would be verified through the City’s construction
permitting process. Therefore, the Project is consistent
with Policy CE 9.1.10.
Recreation Element
R 1.12 Aircraft Overflight and Noise. Require that all
public parks located within the noise impact zones as
defined in the 1985 JWA Master Plan for John Wayne
Airport be posted with a notification to users regarding
aircraft overflight and noise.
Consistent. The proposed Project is a commercial
recreation facility and would not be a public park. The
Project site is located within the SNA 65 CNEL noise
contour, which indicates that noise from aircraft on the
Project site is 65 dB CNEL and is within the noise impact
area related to SNA operations. However, as detailed
in Section 5.8, Hazards and Hazardous Materials, and
Section 5.11, Noise, the AELUP for SNA states that
community facilities and commercial land uses are
“normally consistent” within the 65 CNEL contour.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-43
Draft EIR
May 2025
Relevant General Plan Policies Project Consistency
Therefore, the proposed Project would not result in an
impact related to aircraft overflight and noise and would
be consistent with Policy R 1.12.
R 4.1 Provision of Recreation Services. Provide high
quality recreational services through professionally-
trained recreational personnel to program participants.
Consistent. The proposed Project would provide high
quality surf-related recreational services through
professionally-trained recreational personnel to
program participants. Therefore, the Project is consistent
with Policy R 4.1.
R 4.2 Compatible Recreation Activities. Provide a
variety of compatible recreational activities within a
given location.
Consistent. The proposed Project would add to the
variety of recreation activities in the area and the surfing
activities would be compatible with the City’s location
near the ocean. Therefore, the Project is consistent with
Policy R 4.2.
R 4.3 Variety of Programs. Provide a variety of quality
programs offered in safe and secure environments for
the community’s youth that enhance and extend the
learning day, promote health and wellness, encourage
expansion of skills, and reinforce self-esteem, good
character, and positive behavior.
Consistent. The proposed Project would provide surf-
related recreational services in a safe and secure
environment that would promote health and wellness,
encourage expansion of skills, and reinforce self-esteem,
good character, and positive behavior. Therefore, the
Project is consistent with Policy R 4.3.
R 4.5 Variety of Adult Recreational Programs. Provide
a variety of quality enrichment and recreational
programs for the adult population that promote health
and wellness; development and/or enhancement of skills
and talents; extend learning opportunities; promote
sportsmanship; and provide unique opportunities to
engage in new activities.
Consistent. The proposed Project would provide surf-
related recreational services in a safe and secure
environment that would promote health and wellness,
enhancement of skills, extend learning opportunities;
promote sportsmanship; and provide unique
opportunities to engage in a new activity. Therefore, the
Project is consistent with Policy R 4.5.
Natural Resources Element
NR 1.1 Water Conservation in New Development.
Enforce water conservation measures that limit water
usage, prohibit activities that waste water or cause
runoff, and require the use of water–efficient
landscaping and irrigation in conjunction with new
construction projects.
Consistent. The proposed Project would be constructed
according to Title 24 requirements of the 2022
California administrative code for water conservation
and landscaping would be implemented throughout the
Project site, including implementation of bioretention
basins that would limit runoff. BMPs for stormwater
management would also be implemented to direct
stormwater into landscape areas to use for irrigation.
Therefore, the Project is consistent with Policy N 1.1.
NR 1.2 Use of Water Conserving Devices. Establish and
actively promote use of water conserving devices and
practices in both new construction and major alterations
and additions to existing buildings. This can include the
use of rainwater capture, storage, and reuse facilities.
Consistent. As discussed in Section 5.16, Utilities and
Service Systems, the proposed Project would be required
to implement the CALGreen Code for efficient use of
water. Additionally, as discussed in Section 5.9,
Hydrology and Water Quality, development and
construction of the Project site would require preparation
and adherence to a Stormwater Pollution Prevention Plan
(SWPPP) and Water Quality Management Plan
(WQMP). Therefore, the Project would use water
conserving devices and would be consistent with Policy
NR 1.2.
NR 3.4 Storm Drain Sewer System Permit. Require all
development to comply with the regulations under the
City’s municipal separate storm drain system permit
under the National Pollutant Discharge Elimination
System.
Consistent. As discussed in Section 5.9, Hydrology and
Water Quality, construction of the Project site and
operation of the proposed Project would require
preparation and adherence to a SWPPP and a WQMP.
Therefore, the Project is consistent with Policy NR 3.4.
NR 3.5 Natural Water Bodies. Require that development
does not degrade natural water bodies.
Consistent. As discussed in Section 5.3, Biological
Resources, there are no natural bodies of water within
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-44
Draft EIR
May 2025
Relevant General Plan Policies Project Consistency
the Project site. In addition, as discussed in Section 5.9,
Hydrology and Water Quality, a SWPPP and WQMP
would be required to be implemented to ensure that the
Project would not degrade offsite natural water bodies.
Therefore, the Project is consistent with Policy NR 3.5.
NR 3.9 Water Quality Management Plan. Require new
development applications to include a Water Quality
Management Plan (WQMP) to minimize runoff from
rainfall events during construction and post-construction.
Consistent. As discussed in Section 5.9, Hydrology and
Water Quality, construction of the Project site and
operation of the proposed Project would require
preparation and adherence to a SWPPP and a WQMP.
Therefore, the Project is consistent with Policy NR 3.9.
NR 3.10 Best Management Practices. Implement and
improve upon Best Management Practices (BMPs) for
residences, businesses, development projects, and City
operations.
Consistent. As discussed in Section 5.9, Hydrology and
Water Quality, the proposed Project would implement
SWPPP and a WQMP, both of which would provide
BMPs to reduce or eliminate soil erosion and pollution.
During operation, onsite drainage features would include
BMPs that have been designed to slow, filter, and slowly
discharge stormwater into the offsite drainage system.
Therefore, the Project is consistent with Policy NR 3.10.
NR 3.11 Site Design and Source Control. Include site
design and source control BMPs in all developments.
When the combination of site design and source control
BMPs are not sufficient to protect water quality as
required by the National Pollutant Discharge Elimination
System (NPDES), structural treatment BMPs will be
implemented along with site design and source control
measures.
Consistent. As discussed in Section 5.9, Hydrology and
Water Quality, the proposed Project would implement a
WQMP that would be approved by the City and
includes design and source control BMPs to protect water
quality, which include landscaping and drainage
features that have been designed to slow, filter, and
slowly discharge stormwater into the offsite drainage
system. Therefore, the Project is consistent with Policy NR
3.11.
NR 3.12 Reduction of Infiltration. Include equivalent
BMPs that do not require infiltration, where infiltration of
runoff would exacerbate geologic hazards. (Policy HB
8.12)
Consistent. As discussed in Section 5.9, Hydrology and
Water Quality, infiltration is not feasible for the Project
site. Thus, the Project would utilize modular wetland
systems and bioretention basins which would collect
flows, filter, and then direct runoff into the Santa Ana
Delhi Channel, which is adjacent to the site. Therefore,
the Project is consistent with Policy NR 3.12.
NR 3.14 Runoff Reduction on Private Property. Retain
runoff on private property to prevent the transport of
pollutants into natural water bodies, to the maximum
extent practicable. (Policy HB 8.14).
Consistent. As discussed in Section 5. 9, Hydrology and
Water Quality, the proposed Project would implement a
SWPPP and a WQMP that would provide BMPs to
reduce or eliminate transport of pollutants into natural
water bodies. Onsite drainage features would be
installed that have been designed to slow and filter
stormwater prior to discharge to reduce runoff and
prevent transport of pollutants. Therefore, the Project is
consistent with Policy NR 3.14.
NR 3.16 Siting of New Development. Require that
development be located on the most suitable portion of
the site and designed to ensure the protection and
preservation of natural and sensitive site resources that
provide important water quality benefits. (Policy HB
8.16).
Consistent. The Project site is a developed site that is
used for golf-related recreation. The site does not
contain a natural or sensitive site resource as detailed in
Section 5.3, Biological Resources, and the site does not
provide important water quality benefits. As discussed in
Section 5.9, Hydrology and Water Quality, the proposed
Project would require preparation and adherence to a
SWPPP and a WQMP that would protect water quality.
Therefore, the Project is consistent with Policy NR 3.16.
NR 3.17 Parking Lots and Rights-of-Way. Require that
parking lots and public and private rights-of-way be
Consistent. As discussed in the Preliminary WQMP
(included as Appendix O), operation of the Project shall
include sweeping all onsite streets, drive aisles, and/or
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-45
Draft EIR
May 2025
Relevant General Plan Policies Project Consistency
maintained and cleaned frequently to remove debris
and contaminated residue. (Policy HB 8.17)
uncovered parking areas at minimum of a quarterly
basis. Therefore, the Project is consistent with Policy NR
3.17.
NR 3.19 Natural Drainage Systems. Require
incorporation of natural drainage systems and
stormwater detention facilities into new developments,
where appropriate and feasible, to retain stormwater in
order to increase groundwater recharge. (Policy HB
8.19)
Consistent. As discussed in Section 5.9, Hydrology and
Water Quality, infiltration and groundwater recharge is
not feasible at the Project site. Thus, the Project would
utilize modular wetland systems and bioretention basins
which would collect flows, filter, and then direct runoff
into the Santa Ana Delhi Channel, which is adjacent to
the site. Therefore, the Project is consistent with Policy NR
3.19.
NR 3.20 Impervious Surfaces. Require new
development and public improvements to minimize the
creation of and increases in impervious surfaces,
especially directly connected impervious areas, to the
maximum extent practicable. Require redevelopment to
increase area of pervious surfaces, where feasible.
(Policy HB 8.20)
Consistent. As discussed in Section 5.9, Hydrology and
Water Quality, while the proposed Project would result
in an increase of impervious surfaces, buildout of the
proposed Project would result in a decrease the 100-
year storm runoff flowrate by 11.1 percent and the
proposed Project would maintain the existing drainage
pattern by collecting runoff via roof drains, curbs, and
area drains and conveying it to vegetated biotreatment
systems utilizing permeable landscaping for treatment.
Therefore, the Project is consistent with Policy NR 3.20.
NR 4.3 Restore Natural Hydrologic Conditions.
Preserve, or where feasible, restore natural hydrologic
conditions such that downstream erosion, natural
sedimentation rates, surface flow, and groundwater
recharge function near natural equilibrium states.
Consistent. As discussed in Section 5.9, Hydrology and
Water Quality, infiltration and groundwater recharge is
not feasible at the Project site. Thus, the Project would
utilize modular wetland systems and bioretention basins
which would collect flows, filter, and then direct runoff
into the Santa Ana Delhi Channel, which is adjacent to
the site. The Project would not impact hydrologic
conditions, sedimentation, or erosion. Therefore, the
Project is consistent with Policy NR 4.3.
NR 4.4 Erosion Minimization. Require grading/erosion
control plans with structural BMPs that prevent or
minimize erosion during and after construction for
development on steep slopes, graded, or disturbed
areas.
Consistent. As discussed in Section 5.6, Geology and
Soils, the proposed Project would implement a SWPPP
and provide BMPs to reduce or eliminate soil erosion and
the loss of topsoil during construction. During operation,
onsite drainage features would be installed that have
been designed to slow, filter, and slowly discharge
stormwater into the offsite drainage system. Therefore,
the Project would minimize erosion and would be
consistent with Policy NR 4.3.
NR 6.1 Walkable Neighborhoods. Provide for
walkable neighborhoods to reduce vehicle trips by siting
amenities such as services, parks, and schools in close
proximity to residential areas.
Consistent. As discussed in Section 5.14, Transportation,
existing sidewalks are located adjacent to the Project
site, and the Project would install onsite walkways that
would provide for pedestrian access to and from the site.
The Project is located at the existing NB Golf Course,
which is a commercial recreation land use that is located
along an arterial roadway near the freeways, but also,
in close proximity to retail services (across Irvine Avenue)
and residential areas within the City. Therefore, the
Project is consistent with Policy NR 6.1.
NR 6.4 Transportation Demand Management
Ordinance. Implement the Transportation Demand
Management (TDM) Ordinance, which promotes and
encourages the use of alternative transportation modes
and provides those facilities such as bicycle lanes that
support such alternate modes.
Consistent. As discussed in Section 5.14, Transportation,
bike lanes and sidewalks currently exist adjacent to the
Project site. The Project would provide onsite pedestrian
walkways that would connect to the offsite sidewalks and
bicycle parking facilities. Therefore, the Project supports
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-46
Draft EIR
May 2025
Relevant General Plan Policies Project Consistency
these alternative modes of transportation and is
consistent with Policy NR 6.4.
NR 7.2 Source Emission Reduction Best Management
Practices. Require the use of Best Management Practices
(BMP) to minimize pollution and to reduce source
emissions.
Consistent. As discussed in Section 5.2, Air Quality,
construction of the Project would implement all related
SCAQMD Rules for reduction of source emissions.
Therefore, the Project is consistent with Policy NR 7.2.
NR 8.1 Management of Construction Activities to
Reduce Air Pollution. Require developers to use and
operate construction equipment, use building materials
and paints, and control dust created by construction
activities to minimize air pollutants.
Consistent. As discussed in Section 5.2, Air Quality, the
proposed Project would implement SCAQMD Rule 403
regarding construction dust and Rule 1113 regarding the
use of low VOC architectural coatings. Therefore, the
Project is consistent with Policy NR 8.1.
NR 10.2 Orange County Natural Communities
Conservation Plan. Comply with the policies contained
within the Orange County Natural Communities
Conservation Plan.
Consistent. As discussed in Section 5.3, Biological
Resources, the proposed Project would be consistent with
the Orange County Natural Communities Conservation
Plan as the Project site is listed as a development site
and is not located within a Habitat Reserve System.
Therefore, the Project is consistent with Policy NR 10.2.
NR 10.3 Analysis of Environmental Study Areas.
Require a site-specific survey and analysis prepared by
a qualified biologist as a filing requirement for any
development permit applications where development
would occur within or contiguous to areas identified as
ESAs.
Consistent. As discussed in Section 5.3, Biological
Resources, a biological resources assessment was
conducted and is included as Appendix C which included
a survey for ESA listed species on the Project site. The
Project site does not contain and is not adjacent to any
ESAs. Therefore, the Project is consistent with Policy NR
10.3.
NR 10.4 New Development Siting and Design. Require
that the siting and design of new development, including
landscaping and public access, protect sensitive or rare
resources against any significant disruption of habitat
values.
Consistent. As discussed in Section 5.3, Biological
Resources, the Project site does not include any sensitive
or rare resources. However, the western yellow bat has
a low potential to roost in ornamental trees, including
palms, on the Project site. Also, the Project site provides
suitable foraging, breeding, and roosting habitat for
bird and raptor species. Therefore, Mitigation Measures
BIO-1 and BIO-2 would ensure that there are no
significant impacts to nesting birds or roosting bats onsite.
Therefore, the Project is consistent with Policy NR 10.4.
NR 10.5 Development in Areas Containing Significant
or Rare Biological Resources. Limit uses within an area
containing any significant or rare biological resources to
only those uses that are dependent on such resources,
except where application of such a limitation would result
in a taking of private property. If application of this
policy would likely constitute a taking of private
property, then a non-resource-dependent use shall be
allowed on the property, provided development is
limited to the minimum amount necessary to avoid a
taking and the development is consistent with all other
applicable resource protection policies. Public access
improvements and educational, interpretative and
research facilities are considered resource dependent
uses.
Consistent. As discussed in Section 5.3, Biological
Resources, the Project site does not include any significant
or rare biological resources. However, the western
yellow bat has a low potential to roost in ornamental
trees, including palms, on the Project site. Also, the Project
site provides suitable foraging, breeding, and roosting
habitat for birds and raptor species. Therefore,
Mitigation Measure BIO-1 and BIO-2 would ensure that
there are no significant impacts to biological resources.
Therefore, the Project is consistent with Policy NR 10.4.
NR 10.6 Use of Buffers. Maintain a buffer of sufficient
size around significant or rare biological resources, if
present, to ensure the protection of these resources.
Require the use of native vegetation and prohibit
invasive plant species within these buffer areas.
Consistent. As discussed in Section 5.3, Biological
Resources, the Upper Newport Bay Nature Preserve and
Ecological Reserve (“Upper Newport Bay”) is located
approximately 0.3 miles south of the Project site. The
area between the Project site and Upper Newport Bay
contains a hill with existing recreational and residential
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-47
Draft EIR
May 2025
Relevant General Plan Policies Project Consistency
land uses which provides a buffer. Therefore, the Project
would not result in substantial drainage, lighting, or noise
impacts to the Upper Newport Bay. Therefore, the
Project is consistent with Policy NR 10.6.
NR 10.7 Exterior Lighting. Shield and direct exterior
lighting away from significant or rare biological
resources to minimize impacts to wildlife.
Consistent. While there are no significant or rare
biological resources on or adjacent to the site, the
proposed Project would shield and direct light away
from potential offsite sensitive species through
compliance with Municipal Code Section 20.30.070
(Outdoor Lighting). Therefore, the Project is consistent
with Policy NR 10.7.
NR 18.1 New Development. Require new development
to protect and preserve paleontological and
archaeological resources from destruction, and avoid
and minimize impacts to such resources in accordance
with the requirements of CEQA. Through planning policies
and permit conditions, ensure the preservation of
significant archeological and paleontological resources
and require that the impact caused by any development
be mitigated in accordance with CEQA.
Consistent. As discussed in Section 5.4, Cultural
Resources, and Section 5.6, Geology and Soils, both
archeological and paleontological resource studies were
conducted (included as Appendix E and I, respectively).
Mitigation Measures CUL-1, CUL-2, and PAL-1 were
included to provide for monitoring during construction
and excavation activities that would reduce potential
impacts to archeological and paleontological resources
to a less than significant level. Therefore, the Project is
consistent with Policy NR 18.1.
NR 18.3 Potential for New Development to Impact
Resources. Notify cultural organizations, including
Native American organizations, of proposed
developments that have the potential to adversely
impact cultural resources. Allow qualified representatives
of such groups to monitor grading and/or excavation of
development sites.
Consistent. In accordance with AB 52 and SB 18, the
City sent letters to 20 Native American representatives
identified by NAHC, notifying them of the proposed
Project. Agency to agency consultation occurred between
the City and two tribes. who stated that they have
cultural affiliation with the Project region. While none of
the tribes presented substantial evidence indicating that
tribal cultural resources are present on the site,
Mitigation Measures TCR-1 through TCR-3 have been
included to provide for Native American monitoring on
the site during grading and excavation activities to
ensure that significant impacts to tribal cultural resources
would not occur. Therefore, the Project is consistent with
Policy NR 18.3.
NR 18.4 Donation of Materials. Require new
development, where on site preservation and avoidance
are not feasible, to donate scientifically valuable
paleontological or archaeological materials to a
responsible public or private institution with a suitable
repository, located within Newport Beach or Orange
County, whenever possible.
Consistent. As discussed in Section 5.4, Cultural
Resources, and Section 5.6, Geology and Soils, Mitigation
Measures CUL-1, CUL-2, and PAL-1 provide for
archeological and paleontological monitoring on the site
during grading and excavation activities, which includes
potential donation of materials and curation at scientific
institutions. Therefore, the Project is consistent with Policy
NR 18.4.
NR 20.1 Enhancement of Significant Resources. Protect
and, where feasible, enhance significant scenic and visual
resources that include open space, mountains, canyons,
ridges, ocean, and harbor from public vantage points, as
shown in Figure NR3.
Consistent. As discussed in Section 5.1, Aesthetics, none
of the adjacent roadways feature long range view of
scenic vistas such as the Upper Newport Bay Preserve.
The Upper Newport Bay Preserve can be seen from
Irvine Avenue south of University Drive, as shown in
General Plan Figure NR-3. The Project would not result
in significant impacts to significant scenic and visual
resources from public vantage points. Therefore, the
Project is consistent with Policy NR 20.1.
NR 20.2 New Development Requirements. Require
new development to restore and enhance the visual
quality in visually degraded areas, where feasible, and
Consistent. As discussed in Section 5.1, Aesthetics, the
proposed Project site is developed with the NB Golf
Course and is mostly covered with both natural and
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-48
Draft EIR
May 2025
Relevant General Plan Policies Project Consistency
provide view easements or corridors designed to protect
public views or to restore public views in developed
areas, where appropriate.
artificial grasses and ornamental vegetation. The
proposed Project would include landscaping that utilizes
native draught tolerant vegetation and would provide
new landscaping along the Irvine Avenue and Mesa
Drive right-of-way. The proposed Project would not
encroach upon public view corridors. Therefore, the
Project is consistent with Policy NR 20.2.
Policy NR 20.4. Public View Corridor Landscaping.
Design and site new development, including landscaping,
on the edges of public view corridors, including those
down public streets, to frame, accent, and minimize
impacts to public views.
Consistent. As discussed in Section 3.0, Project
Description and Section 5.1, Aesthetics, the Project
includes installation of new landscaping along the Irvine
Avenue and Mesa Drive right-of-way and along both
driveway entrances to the site. The new landscaping
would frame and accent driveway entrances, and would
screen views of the proposed parking areas, PV solar
canopies, and proposed building structures to minimize
impacts to public views. Therefore, the Project is
consistent with Policy NR 20.4.
Policy NR 23.1 Maintenance of Natural
Topography. Preserve cliffs, canyons, bluffs, significant
rock outcroppings, and site buildings to minimize
alteration of the site’s natural topography and preserve
the features as a visual resource.
Consistent. As discussed in Section 5.1, Aesthetics, the
Project site does not include any cliffs, canyons, bluffs,
significant rock outcroppings; and thus, these types of
natural topographic features would not be impacted
from implementation of the Project. The Project does
involve grading of the site; however, as detailed in
Section 5.1, Aesthetics, the natural southwestward slope
of the site would as viewed from Mesa Drive would
remain with implementation of the Project. Therefore, the
Project is consistent with Policy NR 23.1.
Policy NR 23.7 New Development Design and
Siting. Design and site new development to minimize the
removal of native vegetation, preserve rock
outcroppings, and protect coastal resources.
Consistent. As discussed in Section 5.1, Aesthetics, the
Project site does not include any native vegetation, rock
outcroppings, or coastal resources. The Project site is
developed and contains ornamental vegetation, and no
native vegetation, rock outcroppings, or coastal
resources would be removed as part of the Project.
Therefore, the Project is consistent with Policy NR 23.7.
NR 24.2 Energy-Efficient Design Features. Promote
energy-efficient design features.
Consistent. As discussed in Section 5.5, Energy, the
proposed Project would implement energy efficient
practices as outlined in Part 6 of Title 24 of the California
Code of Regulations, adopted by the City in Municipal
Code Chapter 15.17, which includes installation of solar
panels on canopies in the parking areas and on building
rooftops to maximize the use of renewable energy.
Therefore, the Project is consistent with Policy NR 24.2.
NR 24.3 Incentives for Green Building Program
Implementation. Promote or provide incentives for
“Green Building” programs that go beyond the
requirements of Title 24 of the California Administrative
Code and encourage energy efficient design elements
as appropriate to achieve “green building” status.
Consistent. As discussed in Section 3.0, Project
Description, solar panels would be installed on building
tops and solar canopies over portions of the parking
areas to produce renewable energy to provide power
to the proposed onsite operations. Therefore, the Project
is consistent with Policy NR 24.2.
Safety Element
S 4.7 New Development. Conduct further seismic studies
for new development in areas where potentially active
faults may occur.
Consistent. As discussed in Section 5.6, Geology and
Soils, a Geotechnical Exploration was prepared for the
Project site and is included as Appendix H, which
determined that there are no potentially active fault lines
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-49
Draft EIR
May 2025
Relevant General Plan Policies Project Consistency
within 500 feet of the Project site. Therefore, the Project
would be consistent with Policy S 4.7.
S 5.1 New Development Design within 100-year
Floodplains. Require that all new development within
100-year floodplains incorporate sufficient measures to
mitigate flood hazards including the design of onsite
drainage systems that are connected with the City’s storm
drainage system, gradation of the site such that runoff
does not impact adjacent properties, and buildings are
elevated.
Consistent. The Project site is not located within a 100-
year floodplain. The Federal Emergency Management
Agency (FEMA) Flood Zone Map 06059C0267J
identifies that the Project site is located in Flood Zone X,
which are areas that are determined to be outside of the
0.2% annual chance of flooding. In addition, the
proposed Project would install an onsite drainage system
that would be connected to the existing drainage channel
that is adjacent to the site. Therefore, the Project would
be consistent with Policy S 5.1.
S 5.2 Facility Use or Storage of Hazardous Materials
Standards. Require that all new facilities storing, using,
or otherwise involved with substantial quantities of onsite
hazardous materials within flood zones comply with
standards of elevation, anchoring, and flood proofing,
and hazardous materials are stored in watertight
containers.
Consistent. As discussed in the previous response, the
Project site is not located within a flood zone. Section 5.8,
Hazards and Hazardous Materials, details that the
proposed Project would not use or store substantial
quantities of hazardous materials and would comply with
all required standards regarding the use, storage, and
transportation of the limited quantities of hazardous
materials that would be used by the Project. Therefore,
the Project would be consistent with Policy S 5.2.
S 5.3 Minimization of Flood Mazard Risk. Require
stormwater detention basins, where appropriate, to
reduce the potential risk of flood hazards.
Consistent. As discussed in Section 5.9, Hydrology and
Water Quality, the Project would utilize modular wetland
systems and bioretention basins which would collect
flows, filter, and then direct runoff into the Santa Ana
Delhi Channel, which is adjacent to the site. The Project
would not result in a potential flood risk, and the Project
is consistent with Policy S 5.3.
S 7.1 Known Areas of Contamination. Require
proponents of projects in known areas of contamination
from oil operations or other uses to perform
comprehensive soil and groundwater contamination
assessments in accordance with American Society for
Testing and Materials standards, and if contamination
exceeds regulatory action levels, require the proponent
to undertake remediation procedures prior to grading
and development under the supervision of the County
Environmental Health Division, County Department of
Toxic Substances Control, or Regional Water Quality
Control Board (depending upon the nature of any
identified contamination).
Consistent. As discussed in Section 5.8, Hazards and
Hazardous Materials, a Phase II Environmental Site
Assessment (Appendix L) was conducted on the Project
site, which included soils sampling, determined that there
were no levels of herbicides, organochlorine pesticides,
or Per- and polyfluoroalkyl substances (PFAS) detected
above laboratory reporting limits. Therefore, the Project
would be consistent with Policy S 7.1.
S 7.2 Development Design within Methane Gas
Districts. Ensure that any development within identified
methane gas districts be designed consistent with the
requirements of the Newport Beach Municipal Code.
Consistent. As detailed in Section 5.8, Hazards and
Hazardous Materials, the Project site is not located within
the Methane Gas Mitigation District as defined and listed
in Municipal Code Section 15.55.030. Therefore, the
Project is consistent with Policy S 7.2.
S 7.4 Implementation of Remediation Efforts. Minimize
the potential risk of contamination to surface water and
groundwater resources and implement remediation
efforts to any resources adversely impacted by urban
activities.
Consistent. As discussed in Section 5.9, Hydrology and
Water Quality, the proposed Project would implement a
SWPPP and a WQMP that would provide BMPs to
reduce or eliminate contamination to surface water or
groundwater resources. Onsite drainage features would
be installed that have been designed to slow and filter
stormwater prior to discharge to reduce runoff and
prevent transport of pollutants. Therefore, the Project is
consistent with Policy S 7.4.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-50
Draft EIR
May 2025
Relevant General Plan Policies Project Consistency
Noise Element
N 1.1 Noise Compatibility of New Development.
Require that all proposed projects are compatible with
the noise environment through use of Table N2 and
enforce the interior and exterior noise standards shown
in Table N3.
Consistent. As discussed in Section 5.11, Noise, the
proposed Project is compatible with the exterior noise
environment and would not require implementation of
mitigation measures. In addition, the City’s development
permitting process would ensure enforcement of the
interior noise standards shown in Table N3. Therefore,
the Project is consistent with Policy N 1.1.
N 1.7 Commercial/ Entertainment Uses. Limit hours
and/or require attenuation of commercial/entertainment
operations adjacent to residential and other noise
sensitive uses in order to minimize excessive noise to these
receptors.
Consistent. As discussed in Section 5.11, Noise, the
Project site is not directly adjacent to sensitive receptors
and would not result in excessive noise to sensitive
receptors, would not exceed noise thresholds, and would
not result in a substantial increase in ambient noise, as
detailed in Section 5.11, Noise. Therefore, the Project is
consistent with Policy N 1.7.
N 1.8 Significant Noise Impacts. Require the
employment of noise mitigation measures for existing
sensitive uses when a significant noise impact is identified.
A significant noise impact occurs when there is an
increase in the ambient CNEL produced by new
development impacting existing sensitive uses. The CNEL
increase is shown in the table below.
Consistent. As discussed in Section 5.11, Noise, the
proposed Project would not result in significant impacts
related to an increase in ambient noise. Table 5.11-10
and Table 5.11-11 identify that the Project would
generate daytime ambient noise level increases ranging
from less than 0.1 to 0.8 dBA Leq and nighttime noise
level increases ranging from less than 0.1 to 2.0 dBA Leq
at the nearby receiver locations, which are less than the
thresholds. Therefore, noise impacts related to Project
operations would be less than significant and the Project
is consistent with Policy N 1.8.
N 4.2 New Uses. Require that new uses such as
restaurants, bars, entertainment, parking facilities, and
other commercial uses where large numbers of people
may be present adjacent to sensitive noise receptors
obtain a use permit that is based on compliance with the
noise standards in Table N3 and the City’s Municipal
Code.
Consistent. The Project site is not directly adjacent to
sensitive receptors and would not result in an exceedance
of noise thresholds or a substantial increase in ambient
noise, as detailed in Section 5.11, Noise. In addition, the
Project would be in compliance with the City’s municipal
code, as verified through the City’s development review
and permitting process, and would obtain use permits as
required, per the detail in Section 3.0, Project
Description. Therefore, the Project is consistent with Policy
N 4.2.
N 4.6 Maintenance of Construction Activities. Enforce
the Noise Ordinance noise limits and limits on hours of
maintenance or construction activity in or adjacent to
residential areas, including noise that results from in-
home hobby or work related activities.
Consistent. As discussed in Section 5.11, Noise,
construction of the proposed Project would comply with
the City of Newport Beach Municipal Code Section
10.28.040 requiring construction activities to take place
between 7:00 a.m. and 6:30 p.m. on weekdays and 8:00
a.m. and 6:00 p.m. on Saturdays. Therefore, the Project
is consistent with Policy N 4.6.
N 5.1 Limiting Hours of Activity. Enforce the limits on
hours of construction activity.
Consistent. As discussed in Section 5.11, Noise,
construction of the proposed Project would comply with
the City of Newport Beach Municipal Code Section
10.28.040 requiring construction activities to take place
between 7:00 a.m. and 6:30 p.m. on weekdays and 8:00
a.m. and 6:00 p.m. on Saturdays. Therefore, the Project
is consistent with Policy N 5.1.
Source: City of Newport Beach General Plan
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-51
Draft EIR
May 2025
As described previously, the City of Newport Beach City Council Policy Manual contains policies related to
land use, planning, and mitigating an environmental effect. Therefore, a detailed analysis of the proposed
Project’s consistency with the City Council Policy Manual policies was prepared. As detailed in Table 5.10-
5, the proposed Project would be consistent with the policies, and impacts related to conflict with a City
Council Policy Manual policy related to an environmental effect would not occur.
Table 5.10-5: City Council Policy Manual Consistency Analysis
City Council Policy Manual Policy Project Consistency
Policy G-1: Retention, Removal, and Maintenance of
City Trees. This policy establishes standards for the
retention, removal, maintenance, reforestation, tree
trimming standards, and supplemental trimming of City
trees. The policy provides definitions of certain trees that
should be protected and provisions for the removal of
such trees.
Consistent. As detailed in Section 5.3, Biological
Resources, the proposed Project includes new
landscaping along the site frontages of Irvine Avenue
and Mesa Drive that may extend into the public right-of-
way adjacent to the street. However, implementation of
the City’s development review and permitting process
would ensure that any tree removal and proposed new
landscaping would be consistent with the City Council
Policy and municipal code requirements. Thus, the Project
would be consistent with Policy G-1.
Policy K-2 Places of Historical and Architectural
Significance: The City Council may designate as
historical property any building or part thereof, object,
structure, monument, or collection thereof having
importance to the history or architecture of the City of
Newport Beach in accordance with the criteria set forth
below.
1. Property may be designated as historical property
if it meets any of the following standards of
architectural significance:
a. Structures or areas that embody distinguishing
characteristics of an architectural style, period,
or method of construction, or of architectural
development with the City.
b. Notable works of a master builder, designer, or
architect whose style influenced the City’s
architectural development, or structures showing
the evolution of an architect’s style.
c. Rare structures displaying a building type,
design, or indigenous building form.
d. Structures which embody special architectural
and design features.
e. Outstanding examples of structures displaying
original architectural integrity, structurally or
stylistically, or both.
f. Unique structures or places that act as focal or
pivotal points important as a key to the
character or visual quality of an area.
2. Property may be designated as historical property
if it meets any of the following standards of historical
significance.
a. Sites and structures connected with events
significant in the economic, cultural, political,
social, or civic history of the City of Newport
Consistent. As detailed in Section 5.4, Cultural Resources,
the Historical Resources Evaluation (Appendix D)
determined that the onsite structures do not meet any of
the criteria set forth by the City of Newport Beach City
Council Policy Manual to be considered a historic
resource. Thus, the Project site does not contain any
buildings or structures that meet the criteria of Policy K-
2.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-52
Draft EIR
May 2025
City Council Policy Manual Policy Project Consistency
Beach, the County of Orange, the State of
California, or the United States of America.
b. Structures or areas identified with the lives of
historical personages of the City of Newport
Beach, the County of Orange, the State of
California, or the United States of America.
c. Sites and groups of structures representing
historical development patterns, including, but
not limited to, urbanization patterns, railroads,
agricultural settlements, and canals.
Policy K-5 Paleontological and Archaeological
Resource Protection Guidelines: The City will ensure
that potential impacts to paleontological and
archaeological resources by public or private
development are properly evaluated and mitigated in
accordance with the General Plan, Local Coastal
Program and CEQA.
Procedures
A. During the preparation of an initial study for a
project, staff or a qualified consultant shall
determine if paleontological or archaeological
resources exist at or near a project site. If the site is
located in the Coastal Zone, the requirements and
procedures provided in Newport Beach Municipal
Code Section 21.30.105(A), or any successor statute,
shall be implemented.
B. If resources are known to exist at or near a project
site or that, the project could otherwise affect known
resources, a preliminary investigation report shall be
prepared by a qualified professional archaeologist
or paleontologist.
C. If the preliminary investigation report concludes that
resources are not likely to be at the present at the
project site or encountered during construction, no
further analysis shall be required.
D. If the preliminary report concludes that resources are
present at the site or are likely to be present at the
site or may be encountered by project construction,
additional investigative work shall be prepared to
identify and disclose the potential impacts of the
project. The impact assessment report shall make
every effort to identify the value of the resource and
shall identify feasible design modifications or other
methods to avoid and/or minimize project-related
impacts. The impact assessment report may include
a suggested excavation plan for assessing or
mitigating the effect of the project on the qualities
which make the resource important if avoidance is
considered infeasible. The impact assessment report
shall also identify feasible mitigation measures that
can be either incorporated within project
specifications or applied as conditions of approval.
E. If paleontological or archaeological resources are
discovered during construction, all construction
Consistent. As discussed in Section 5.4, Cultural
Resources, and Section 5.6, Geology and Soils, both
archeological and paleontological resources studies
were conducted (included as Appendix E and I,
respectively). Mitigation Measures CUL-1, CUL-2, and
PAL-1 have been included to provide for archeological
and paleontological monitoring on the site during
grading and excavation activities to ensure that
significant impacts to archeological and paleontological
resources would not occur.
Further, if human remains are found on the Project site,
California Health and Safety Code Section 7050.5
requires that the County Coroner’s office be immediately
notified and no further excavation or disturbance of the
discovery or any nearby area occur until the Coroner has
made the necessary findings as to origin and disposition
pursuant to Public Resources Code 5097.98. Therefore,
the Project is consistent with Policy K-5.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-53
Draft EIR
May 2025
City Council Policy Manual Policy Project Consistency
activities in the general area of the discovery shall
be temporarily halted until the resource is examined
by a qualified monitor. The monitor shall the
significance of the resource recommend next steps
(i.e. additional excavation, curation, preservation,
etc.).
F. If human remains are discovered during construction,
there shall be no further excavation or disturbance
of the site or any nearby area reasonably suspected
to overlie adjacent remains until the coroner
determines that the remains are not subject to the
provisions of Section 27491 of the Government
Code, or any successor statute, or any other related
provisions of law concerning investigation of the
circumstances, manner and cause of any death, and
the recommendations concerning the treatment and
disposition of the human remains have been made to
the person responsible for the excavation, or their
authorized representative, in the manner provided
in Section 5097.98 of the Public Resources Code, or
any successor statute. The coroner shall make his or
her determination within two working days from the
time the person responsible for the excavation, or his
or her authorized representative, notifies the coroner
of the discovery or recognition of the human remains.
If the coroner determines that the remains are not
subject to his or her authority and if the coroner
recognizes the human remains to be those of a
Native American, or has reason to believe that they
are those of a Native American, he or she shall
contact, by telephone within 24 hours, the Native
American Heritage Commission and the Newport
Beach Building Official.
City of Newport Beach Santa Ana Heights Specific Plan and Municipal Code
The Project site is located within the Santa Ana Heights Specific Plan (SP-7), which provides zoning regulations
for the site. The Santa Ana Heights Specific Plan designates the site as Open Space/Recreation (OS/R), that
allows golf courses and outdoor commercial recreation and accessory uses and structures with a use permit.
The proposed surf park and golf course support facilities (including parking, starter shack, golf cart storage,
and golf cart paths) for the remaining golf course areas to the north and south of the proposed Project would
implement outdoor commercial recreation and accessory uses as intended by the OS/R designation and
would not result in a conflict related to avoiding or mitigating an environmental effect. The proposed project
is consistent with the Santa Ana Heights Specific Plan and an amendment to SP-7 is not required.
A detailed analysis of the proposed Project’s consistency with the Santa Ana Heights Specific Plan regulations
(per Municipal Code Chapter 20.90) that serve to avoid or mitigate environmental impacts is provided in
Table 5.10-6. As described, the proposed Project would be consistent with the relevant requirements and
impacts from conflict with a Specific Plan policy or municipal code requirement related to an environmental
effect would be less than significant.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-54
Draft EIR
May 2025
Table 5.10-6: Specific Plan Policy and Municipal Code Consistency Analysis
Specific Plan Policy/Municipal Code Requirement Project Consistency
Prior to the issuance of a building permit for a structure
that penetrates the 100:1 Notice Surface pursuant to
FAR Part 77.13, the project applicant shall submit a
“Notice of Proposed Construction” to the Federal
Aviation Administration (FAA), which will initiate an
Aeronautical Study of the project by the FAA. Upon
completion of the FAA Aeronautical Study, the project
applicant shall submit evidence to the Community
Development Director that restrictions and conditions, if
any, imposed on the project by the FAA have been
incorporated into the design of the project.
Consistent. As discussed in Section 5.8, Hazards and
Hazardous Materials, the Project site has previously
undergone FAA evaluation as part of implementation of
poles on the existing driving range, which determined
that structures on the site that are below 162 feet amsl
would not have a significant adverse impact related to
aeronautical hazards (FAA, 2016). As the tallest
proposed building structure would be 92 feet amsl and
the proposed light poles would be a maximum of 108
feet amsl, both would be below 162 feet amsl, and
would not result in impacts related to FAR 77 compliance.
All projects including, but not limited to, General Plan
amendments and zone changes within the project area
pertinent to the Airport Land Use Commission’s (ALUC)
John Wayne Airport “Airport Environs Land Use Plan”
shall be referred to ALUC until such time as the City
becomes a “Consistent Local Agency” as defined by
ALUC. For purposes of this requirement, the term
“project” shall include those applications requiring
discretionary approvals, tentative tract map or parcel
map approvals or modifications, and/or condominium
conversions. Such projects shall not include minor
modifications, such as remodels and additions to single-
family dwelling units with no intensification of
development.
Consistent. As discussed in Section 5.8, Hazards and
Hazardous Materials, because the Project site is located
within the AELUP Notification area for SNA and within
the SNA planning area boundary, and the Project
proposes a General Plan Amendment, the City is
required to refer the proposed Project to the ALUC for
review, pursuant to the California Public Utilities Code
Section 21676. Thus, the Project would be consistent with
this requirement.
Building Site Area. One acre minimum. Consistent. The Project site is 15.38 acres and exceeds
the one acre minimum, and therefore, is consistent with
this requirement.
Building Height. Eighteen feet maximum unless
otherwise provided for by an approved use permit.
Consistent. The proposed clubhouse would have a
maximum height of 50 feet and the athlete
accommodation building would have a maximum height
of 40 feet. Therefore, consistent with this requirement, the
Project includes a CUP to allow for the construction of
buildings in excess of 18 feet in height.
Building Setbacks. Twenty feet minimum from all
property lines.
Consistent. All buildings would be set back 20 feet from
all property lines as shown in Figure 3-8, Conceptual Site
Plan, in Section 3.0, Project Description.
Lighting. All lighting shall be designed and located so
that direct light rays are confined to the premises.
Consistent. The Photometric Plan that has been
submitted to the City shows that spillover light would not
reach over 0.6 footcandles of light. The City’s
development review and permitting process would
ensure that onsite lighting is consistent with the
Photometric Plan and that direct light rays are confined
to the Project site.
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-55
Draft EIR
May 2025
5.10.7 CUMULATIVE IMPACTS
The cumulative study area for land use and planning includes the City of Newport Beach and areas nearby
the Project site in the City of Costa Mesa, City of Irvine, and County of Orange. As shown in Table 5-1 and
Figure 5-1 in Section 5.0, Environmental Impact Analysis, the vicinity of the Project site includes numerous
nearby development projects within the City of Newport Beach, City of Costa Mesa, and City of Irvine. A
large portion of the cumulative projects consist of redevelopment of existing developed parcels for multi-
family residential, commercial, and office developments, which are different but complementary to the
proposed surf park Project. In addition, as detailed in Section 5.0, future housing could be developed on
any of the 247 Housing Opportunity sites within the City including Housing Opportunity sites 23, 24, 25 and
26, across Mesa Drive from the Project site that totals approximately 13 acres. However, no existing
application for development of Housing Opportunity sites 23, 24, 25 and 26 has been submitted to the City.
As described previously, the proposed Project would not physically divide an established community.
Therefore, the proposed Project would not have the potential to have a cumulatively considerable impact
related to physically dividing communities. In addition, the cumulative projects involve redevelopment of land
for new community uses, such as commercial, office, and housing, and do not involve physical division of
established community areas.
The proposed Project would implement new commercial recreation uses on the Project site that are consistent
with the General Plan land use designation and the Santa Ana Heights Specific Plan. The proposed Project
is consistent with the SCAG’s 2024 Connect RTP/SCS as detailed in Table 5.10-2. The proposed Project is
consistent with the SNA AELUP policies as detailed in Table 5.10-3. Also, as detailed in Tables 5.10-4 through
5.10-6, the proposed Project would not result in a conflict with any General Plan policies, City Council Policy
Manual policies, Santa Ana Heights Specific Plan policies, or municipal code regulations adopted for the
purpose of mitigating an environmental effect. The proposed General Plan Amendment would modify an
existing anomaly related to the Project site and the existing use for recreation to provide for the proposed
new surf park. The resulting development allowance is specific to the Project site, which is evaluated herein,
and would not result in an impact that could cumulatively combine with other projects to create a significant
environmental impact. Future development Projects would be evaluated for plan, policy, and regulation
consistency. However, because the proposed Project would not result in conflicts with an applicable land use
plan, policy, or regulation of an agency with jurisdiction over the proposed Project, which has the purpose
of avoiding or mitigating an environmental effect, the proposed Project would not cumulatively contribute to
such an impact that could occur from related projects. As a result, cumulative impacts related to land use and
planning from the proposed Project would not be cumulatively considerable.
5.10.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES
Existing Regulations
• FAA FAR Part 77
• California Code of Regulations Section 13050.5(a)
• AELUP for SNA
• City of Newport Beach General Plan
• City of Newport Beach Local Coastal Program – Coastal Land Use Plan and Implementation Plan
• City of Newport Beach Santa Ana Heights Specific Plan
• Municipal Code Section 20.90.040.D
• Municipal Code Section 20.90.050
Snug Harbor Surf Park Project 5.10 Land Use and Planning
City of Newport Beach 5.10-56
Draft EIR
May 2025
Existing City Council Policy Manual Policy
• City Council Policy Manual Policy G-1, Retention, Removal, and Maintenance of City Trees
• City Council Policy Manual Policy K-2, Places of Historical and Architectural Significance
• City Council Policy Manual Policy K-5, Paleontological and Archaeological Resource Protection Guidelines
Plans, Programs, or Policies
None.
5.10.9 PROJECT DESIGN FEATURES
None.
5.10.10 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Without mitigation, Impacts LU-1 and LU-2 would be less than significant.
5.10.11 MITIGATION MEASURES
No mitigation measures are required.
5.10.12 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts would be less than significant.
5.10.13 REFERENCES
City of Newport Beach. (2001, January). Santa Ana Heights Specific Plan. Retrieved September 23, 2024,
from ocpublicworks.com.
City of Newport Beach. (2006a, July). General Plan. Retrieved September 23, 2024, from
newportbeachca.gov: https://www.newportbeachca.gov/government/departments/community-
development/planning-division/general-plan-codes-and-regulations/general-plan
City of Newport Beach. (2006b, July). General Plan Environmental Impact Report. Retrieved September 23,
2024, from https://www.newportbeachca.gov/government/departments/community-
development/planning-division/general-plan-codes-and-regulations/general-plan/general-plan-
environmental-impact-repor
City of Newport Beach. (2024, May). Newport Beach Municipal Code. Retrieved September 23, 2024,
from codepublishing.com: https://www.codepublishing.com/CA/NewportBeach/
Federal Aviation Administration (FAA). (2016). Aeronautical Study No. 2016-AWP-5961-OE, July 19, 2016.
Orange County Airport Land Use Commission. (2008). Airport Environs Land Use Plan for John Wayne
Airport. http://www.ocair.com/commissions/aluc/docs/JWA_AELUP-April-17-2008.pdf
SCAG. (2024). Connect SoCal: Regional Transportation Plan/Sustainable Communities Strategy. Retrieved
October 31, 2024, from https://scag.ca.gov/sites/main/files/file-attachments/23-2987-connect-
socal-2024-final-complete-040424.pdf?1714175547
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-1
Draft EIR
May 2025
5.11 Noise
5.11.1 INTRODUCTION
This section describes the noise conditions in the Project region and potential impacts from Project
implementation. The analysis in this section is based, in part, on the following documents and resources.
• City of Newport Beach General Plan, 2006
• City of Newport Beach General Plan Environmental Impact Report (General Plan EIR), 2006
• City of Newport Beach Municipal Code
• Surf Farm Noise Analysis, prepared by Urban Crossroads, 2025, included as Appendix Q
Noise and Vibration Terminology
Various noise descriptors are utilized in this Draft EIR analysis, and are summarized as follows:
dB: Decibel, the standard unit of measurement for sound pressure level.
dBA: A-weighted decibel, an overall frequency-weighted sound level in decibels that approximates the
frequency response of the human ear.
Leq: The equivalent sound level, which is used to describe noise over a specified period of time, typically 1
hour, in terms of a single numerical value. The Leq of a time-varying signal and that of a steady signal are
the same if they deliver the same acoustic energy over a given time. The Leq may also be referred to as the
average sound level.
Lmax: The instantaneous maximum noise level experienced during a given period of time.
CNEL: The Community Noise Equivalent Level is the average A-weighted noise level during a 24-hour day
that is obtained after an addition of 5 dBA to measured noise levels between the hours of 7:00 p.m. to
10:00 p.m. and after an addition of 10 dBA to noise levels between the hours of 10:00 p.m. to 7:00 a.m.
to account for noise sensitivity in the evening and nighttime, respectively.
The “ambient noise level” is the background noise level associated with a given environment at a specified
time and is usually a composite of sound from many sources from many directions.
Effects of Noise
Noise is generally loud, unpleasant, unexpected, or undesired sound that is typically associated with human
activity that is a nuisance or disruptive. The effects of noise on people can be placed into four general
categories:
• Subjective effects (e.g., dissatisfaction, annoyance)
• Interference effects (e.g., communication, sleep, and learning interference)
• Physiological effects (e.g., startle response)
• Physical effects (e.g., hearing loss)
Although exposure to high noise levels has been demonstrated to cause physical and physiological effects,
the principal human responses to typical environmental noise exposure are related to subjective effects and
interference with activities. Interference effects refer to interruption of daily activities and include
interference with human communication activities, such as normal conversations, watching television, telephone
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-2
Draft EIR
May 2025
conversations, and interference with sleep. Sleep interference effects can include both awakening and
arousal to a lesser state of sleep. With regard to the subjective effects, the responses of individuals to similar
noise events are diverse and are influenced by many factors, including the type of noise, the perceived
importance of the noise, the appropriateness of the noise to the setting, the duration of the noise, the time of
day and the type of activity during which the noise occurs, and individual noise sensitivity.
In general, the more a new noise level exceeds the previously existing ambient noise level, the less
acceptable the new noise level will be by those hearing it. With regard to increases in A-weighted noise
levels, the following relationships generally occur:
• Except in carefully controlled laboratory experiments, a change of 1 dBA cannot be perceived.
• Outside of the laboratory, a 3-dBA change in noise levels is considered to be a barely perceivable
difference.
• A change in noise levels of 5 dBA is considered to be a readily perceivable difference.
• A change in noise levels of 10 dBA is subjectively heard as doubling of the perceived loudness.
Noise Attenuation
Stationary point sources of noise, including mobile sources such as idling vehicles, attenuate (lessen) at a rate
of 6 dBA per doubling of distance from the source over hard surfaces to 7.5 dBA per doubling of distance
from the source over hard surfaces, depending on the topography of the area and environmental conditions
(e.g., atmospheric conditions, noise barriers [either vegetative or manufactured]). Thus, a noise measured at
90 dBA 50 feet from the source would attenuate to about 84 dBA at 100 feet, 78 dBA at 200 feet, 72 dBA
at 400 feet, and so forth. Widely distributed noise, such as a large industrial facility spread over many
acres or a street with moving vehicles, would typically attenuate at a lower rate, approximately 4 to 6 dBA
per doubling of distance from the source.
Hard sites are those with a reflective surface between the source and the receiver, such as asphalt or concrete
surfaces or smooth bodies of water. No excess ground attenuation is assumed for hard sites and the changes
in noise levels with distance (drop-off rate) is simply the geometric spreading of the noise from the source.
Soft sites have an absorptive ground surface such as soft dirt, grass, or scattered bushes and trees. In addition
to geometric spreading, an excess ground attenuation value of 1.5 dBA (per doubling distance) is normally
assumed for soft sites. Line sources (such as traffic noise from vehicles) attenuate at a rate between 3 dBA
for hard sites and 4.5 dBA for soft sites for each doubling of distance from the reference measurement.
Fundamentals of Vibration
Vibration is energy transmitted in waves through the ground or man-made structures. These energy waves
generally dissipate with distance from the vibration source. There are several different methods that are
used to quantify vibration. The peak particle velocity (PPV) is defined as the maximum instantaneous peak
of the vibration signal. The PPV is most frequently used to describe vibration impacts to buildings but is not
always suitable for evaluating human response (annoyance) because it takes some time for the human body
to respond to vibration signals. Instead, the human body responds to average vibration amplitude often
described as the root mean square (RMS). The RMS amplitude is defined as the average of the squared
amplitude of the signal and is most frequently used to describe the effect of vibration on the human body.
Decibel notation (VdB) is commonly used to measure RMS. VdB serves to reduce the range of numbers used
to describe human response to vibration. Typically, ground-borne vibration generated by man-made
activities attenuates rapidly with distance from the source of the vibration. Sensitive receivers for vibration
include structures (especially older masonry structures), people (especially residents, the elderly, and sick),
and vibration-sensitive equipment.
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-3
Draft EIR
May 2025
The background vibration-velocity level in residential areas is generally 50 VdB. Ground-borne vibration is
normally perceptible to humans at approximately 65 VdB. For most people, a vibration-velocity level of 75
VdB is the approximate dividing line between barely perceptible and distinctly perceptible levels. Typical
outdoor sources of perceptible ground-borne vibration are construction equipment, steel-wheeled trains, and
traffic on rough roads. If a roadway is smooth, the ground-borne vibration is rarely perceptible. The range
of interest is from approximately 50 VdB, which is the typical background vibration-velocity level, to 100
VdB, which is the general threshold where minor damage can occur in fragile buildings.
5.11.2 REGULATORY SETTING
5.11.2.1 Federal Regulations
There are no federal regulations concerning noise impacts that are applicable to the Project.
5.11.2.2 State Regulations
California Green Building Standards Code
The State of California’s Green Building Standards Code (CALGreen) contains mandatory measures for non-
residential building construction in Section 5.507 on Environmental Comfort. These noise standards are
applied to new construction in California for controlling interior noise levels resulting from exterior noise
sources. The regulations specify that acoustical studies must be prepared when non-residential structures are
developed in areas where the exterior noise levels exceed 65 dBA CNEL, such as within a noise contour of
an airport, freeway, railroad, and other areas where noise contours are not readily available. If the
development falls within an airport or freeway 65 dBA CNEL noise contour, the combined sound transmission
class (STC) rating of the wall and roof-ceiling assemblies shall be constructed to provide an interior noise
environment attributable to exterior sources that does not exceed an hourly equivalent noise level of 50 dBA
Leq in occupied areas during any hour of operation (Section 5.507.4.2).
5.11.2.3 Local and Regional Regulations
City of Newport Beach General Plan 2006
The City of Newport Beach General Plan 2006 contains the following policies related to noise that are
applicable to the Project:
R 1.12 Aircraft Overflight and Noise. Require that all public parks located within the noise impact
zones as defined in the 1985 JWA Master Plan for John Wayne Airport be posted with a
notification to users regarding aircraft overflight and noise.
N 1.1 Noise Compatibility of New Development. Require that all proposed projects are
compatible with the noise environment through use of Table N2, and enforce the interior
and exterior noise standards shown in Table N3.
N 1.7 Commercial/ Entertainment Uses. Limit hours and/or require attenuation of
commercial/entertainment operations adjacent to residential and other noise sensitive uses
in order to minimize excessive noise to these receptors.
N 1.8 Significant Noise Impacts. Require the employment of noise mitigation measures for
existing sensitive uses when a significant noise impact is identified. A significant noise impact
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-4
Draft EIR
May 2025
occurs when there is an increase in the ambient CNEL produced by new development
impacting existing sensitive uses. The CNEL increase is shown in the table below.
CNEL (dBA) dBA increase
55 3
60 2
65 1
70 1
Over 75 Any increase is considered significant
N 4.2 New Uses. Require that new uses such as restaurants, bars, entertainment, parking facilities,
and other commercial uses where large numbers of people may be present adjacent to
sensitive noise receptors obtain a use permit that is based on compliance with the noise
standards in Table N3 and the City’s Municipal Code.
N 4.3 New Commercial Developments. Require that new commercial developments abutting
residentially designated properties be designed to minimize noise impacts generated by
loading areas, parking lots, trash enclosures, mechanical equipment, and any other noise
generating features specific to the development to the extent feasible.
N 4.6 Maintenance of Construction Activities. Enforce the Noise Ordinance noise limits and limits
on hours of maintenance or construction activity in or adjacent to residential areas, including
noise that results from in-home hobby or work related activities.
N 5.1 Limiting Hours of Activity. Enforce the limits on hours of construction activity.
General Plan Noise Land Use Compatibility
The noise criteria identified in Table N2 of the General Plan Noise Element (included as Table 5.11-1 below)
are guidelines to evaluate the land use compatibility of transportation related noise. The compatibility
criteria, shown below, provides the City with a planning tool to gauge the compatibility of land uses relative
to existing and future exterior noise levels and prevent noise/land use conflicts.
This General Plan land use noise compatibility matrix identifies that commercial recreation is clearly
compatible with noise of up to 65 dBA CNEL, normally compatible with noise up to 75 dBA CNEL, and clearly
incompatible with noise over 75 dBA CNEL.
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-5
Draft EIR
May 2025
Table 5.11-1: General Plan Land Use Noise Compatibility Matrix (GP Table N2)
City of Newport Beach Santa Ana Heights Specific Plan
The Project site is located within Santa Ana Heights Specific Plan, which is an area roughly bounded by
Upper Newport Bay to the south, Santa Ana Avenue to the west, Bristol Street to the north, and the Bayview
Terrace area (near the Marriott Suites) to the east. The Santa Ana Heights Specific Plan is included in the
City’s Municipal Code as Chapter 20.90. The Specific Plan includes noise regulations that are applicable to
the proposed Project, which are listed below.
Municipal Code Section 20.90.040.D, Noise Mitigation
1. All new or entirely reconstructed structures with habitable rooms (e.g., dwelling units, hotels, motels,
convalescent homes and hospitals) shall be sound attenuated against present and projected noise, which
shall be the sum of all noise impacting the structure, so as not to exceed a standard of forty-five (45)
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-6
Draft EIR
May 2025
dB CNEL in all habitable rooms. In conjunction with this construction, all associated outdoor living areas
shall be sound attenuated, if necessary, against present and projected highway noise so as not to exceed
a standard of sixty-five (65) dB CNEL. Prior to the issuance of any building permits for such development,
an acoustical analysis report describing the sound attenuation measures required to satisfy the noise
standards shall be prepared by a City-approved acoustical consultant and submitted to the Community
Development Director for approval. The report shall include satisfactory evidence indicating that the
sound attenuation measures have been incorporated into the design of the project.
2. All nonresidential structures shall be sound attenuated against the combined impact of all present and
projected noise from exterior noise sources as necessary to meet the interior noise criteria of the General
Plan Noise Element. Prior to the issuance of any building permits, evidence prepared by a City-approved
acoustical consultant that these standards will be satisfied in a manner consistent with applicable zoning
regulations shall be submitted to the Community Development Director in the form of an acoustical
analysis report describing in detail the exterior noise environment and the acoustical design features
required to achieve the interior noise standard and which indicate that the sound attenuation measures
specified have been incorporated into the design of the project.
3. Prior to the issuance of a building permit for a structure that penetrates the 100:1 Notice Surface
pursuant to FAR Part 77.13, the project applicant shall submit a “Notice of Proposed Construction” to
the Federal Aviation Administration (FAA), which will initiate an Aeronautical Study of the project by the
FAA. Upon completion of the FAA Aeronautical Study, the project applicant shall submit evidence to the
Community Development Director that restrictions and conditions, if any, imposed on the project by the
FAA have been incorporated into the design of the project.
4. All projects including, but not limited to, General Plan amendments and zone changes within the project
area pertinent to the Airport Land Use Commission’s (ALUC) John Wayne Airport “Airport Environs Land
Use Plan” shall be referred to ALUC until such time as the City becomes a “Consistent Local Agency” as
defined by ALUC. For purposes of this requirement, the term “project” shall include those applications
requiring discretionary approvals, tentative tract map or parcel map approvals or modifications, and/or
condominium conversions. Such projects shall not include minor modifications, such as remodels and
additions to single-family dwelling units with no intensification of development. (Ord. 2023-22 § 940,
2023; Ord. 2010-21 § 1 (Exh. A)(part), 2010)
City of Newport Beach Municipal Code
Chapter 10.26 Community Noise Control. This municipal code establishes the permissible exterior noise
levels that may intrude into a neighboring property. According to Section 10.26.025(A) exterior noise levels
at single-, two or multiple-family residential land uses (Noise Zone 1) shall not exceed 55 dBA Leq during
the daytime hours (7:00 a.m. to 10:00 p.m.) and 50 dBA Leq during the nighttime hours (10:00 p.m. to 7:00
a.m.). For commercial uses, exterior noise levels shall not exceed 65 dBA Leq during the daytime hours (7:00
a.m. to 10:00 p.m.) and 60 dBA Leq during the nighttime hours (10:00 p.m. to 7:00 a.m.).
According to Section 10.26.025(C), in the event the ambient noise level exceeds the noise standard, the
maximum allowable noise level under said category shall be increased to reflect the maximum ambient noise
level. The City of Newport Beach Municipal Code, Chapter10.26 Community Noise Control exterior noise
level standards are shown in Table 5.11-2.
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-7
Draft EIR
May 2025
Table 5.11-2: City of Newport Beach Noise Standards
City Land
Use
Time
Period
Base Exterior Noise
Level Standards
(dBA Leq)2
Newport
Beach1
Residential
(Noise Zone I)
Daytime 55
Nighttime 50
Commercial
(Noise Zone II)
Daytime 65
Nighttime 60
1 Source: City of Newport Beach Municipal Code, Section 10.26.025 (Appendix 3.1).
2 Base exterior noise level standards. If the ambient level exceeds allowable exterior Leq noise level, the ambient shall be the
standard per Section 10.26.025 (C) of the City of Newport Beach Municipal Code.
“Daytime” = 7:00 a.m. to 10:00 p.m.; “Nighttime” = 10:00 p.m. to 7:00 a.m.
Municipal Code Section 10.28.040 Construction Activity - Noise Regulations. This municipal code limits
the hours of allowable construction activity to between the hours of 7:00 a.m. - 6:30 p.m. on weekdays and
8:00 a.m. - 6:00 p.m. on Saturdays; with no construction work allowed on Sundays or Federal holidays.
John Wayne Airport Land Use Plan
The Airport Environs Land Use Plan (AELUP) prepared by the Orange County Airport Land Use Commission
(ALUC), identifies noise compatibility policies to safeguard the general welfare of the inhabitants within the
vicinity of the airport and to ensure the continued operation of the airport. The AELUP establishes aircraft
noise exposure exterior noise level compatibility thresholds for new developments by land use category.
According to the AELUP exterior noise thresholds included below, commercial development is considered
normally consistent with exterior noise levels of less than 65 dBA CNEL, and conditionally consistent with
exterior noise levels greater than 65 dBA CNEL (see Table 5.11-3, below).
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-8
Draft EIR
May 2025
Table 5.11-3: AELUP Land Use Noise Limitations
5.11.3 ENVIRONMENTAL SETTING
5.11.3.1 Existing Ambient Noise
To assess the existing noise level environment within and near the Project site, 24-hour noise level
measurements were taken on Thursday, September 12, 2024, at eight locations which are shown in Figure
5.11-1. The noise level measurements were positioned as close to the nearest sensitive receiver locations as
possible to assess the existing ambient hourly noise levels. The background ambient noise levels in the Project
area are dominated by the overflight of airplanes and transportation-related noise associated with surface
streets. A description of these locations and the existing noise levels are provided in Table 5.11-4. As shown,
existing daytime noise levels range from 67.8 to 73.7 dBA.
Snug Harbor Surf Park Project
City of Newport Beach
Figure 5.11-1
Noise Measurement Locations
Source: Urban Crossroads. 2025. Surf Farm Noise Analysis.
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-10
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-11
Draft EIR
May 2025
Table 5.11-4: Summary of 24-Hour Ambient Noise Level Measurements
Location Description
Energy Average
Noise Level
(dBA Leq)
Daytime Nighttime
L1 Located northwest of the site near the residence at 20352
Kline Drive 71.3 50.9
L2 Located west of the site near the pool at 1619 Mesa Drive 67.8 51.8
L3 Located west of the site near the residence at 1691 Mesa
Drive 72.4 62.5
L4 Located southwest of the site near the residence at 2698
Riverside Drive 69.1 54.2
L5 Located southwest of the site near the residence at 2503
Anniversary Lane 73.4 65.6
L6 Located south of the site near the residence at 2139
Anniversary Lane 68.3 44.2
L7 Located southeast of the site near the park at 2081 Mesa
Drive 70.6 50.0
L8 Located east of the site near the residence at 20250 SW
Acacia Street 73.7 53.5
Source: Appendix Q
“Daytime” = 7:00 a.m. to 7:00 p.m.; “Nighttime” = 10:00 p.m. to 7:00 a.m.
5.11.3.2 Existing Vibration
Aside from periodic construction work that may occur in the vicinity of the Project site, other sources of
groundborne vibration include heavy-duty vehicular travel (e.g., refuse trucks and delivery trucks) on area
roadways. Trucks traveling at a distance of 50 feet typically generate groundborne vibration velocity levels
of approximately 0.006 inch per second PPV and could reach approximately 0.016 inch per second PPV
when trucks pass over bumps in the road (FTA, 2018).
5.11.3.3 John Wayne Airport
John Wayne Airport (SNA) is located approximately 0.4-mile northeast of the Project site. As shown on
Figure 5.8-2, 2024 John Wayne Airport Noise Contours, in Section 5.8, Hazards and Hazardous Materials,
the Project site is located within the 2024 SNA 65 CNEL noise contour, which indicates that noise from aircraft
on the Project site is currently 65 dB CNEL and is within the noise impact area related to SNA operations.
According to the AELUP (as listed previously in Section 5.11.2.3), commercial development is considered
normally consistent with exterior noise levels of less than 65 dBA CNEL, and conditionally consistent with
exterior noise levels greater than 65 dBA CNEL. The AELUP contains airport noise contours from 1985 (shown
in Figure 5.10-3), which identifies that a majority of the Project site is located within the 65 dBA CNEL and
a small area in the northeastern portion of the Project site would be in the 70 dBA CNEL aircraft noise level
contours.
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-12
Draft EIR
May 2025
5.11.3.4 Sensitive Receivers
Noise sensitive receivers are generally defined as locations where people reside or where the presence of
unwanted sound could otherwise adversely affect the use of the land. Noise-sensitive land uses are generally
considered to include: residences, schools, hospitals, and recreation areas. The noise sensitive receptors that
are in the vicinity of the Project site are described below and shown in Figure 5.11-2. Other sensitive land
uses in the Project site vicinity that are located at greater distances than those identified in this noise study
will experience lower noise levels than those presented for these locations due to the additional attenuation
from distance and the shielding of intervening structures.
R1: Location R1 represents a residence at 20352 Kline Drive, 399 feet northwest of the Project
site. Receiver R1 is placed at the use area (backyard) facing the Project site.
R2: Location R2 represents a residence at 1691 Mesa Drive, 256 feet northwest of the Project
site. Receiver R2 is placed at the use area (pool) facing the Project site.
R3: Location R3 represents a residence at 1691 Mesa Drive, 169 feet northwest of the Project
site. Receiver R3 is placed at the building façade facing the Project site.
R4: Location R4 represents a residence at 2698 Riverside Drive, 502 feet west of the Project
site. Receiver R4 is placed at the building façade facing the Project site.
R5: Location R5 represents a residence at 2916 Irvine Avenue, 284 feet southwest of the Project
site. Receiver R5 is placed at the building façade facing the Project site.
R6: Location R6 represents a residence at 2139 Anniversary Lane, 673 feet south of the Project
site. Receiver R6 is placed at the building façade facing the Project site.
R7: Location R7 represents a park at 2061 Mesa Drive, 797 feet southeast of the Project site.
Receiver R7 is placed at the use area facing the Project site.
R8: Location R8 represents a residence at 20250 SW Acacia Street, 386 feet east of the Project
site. Receiver R8 is placed at the building façade facing the Project site.
Snug Harbor Surf Park Project
City of Newport Beach
Source: Urban Crossroads. 2025. Surf Farm Noise Analysis.
Figure 5.11-2
Noise Sensitive Receiver Locations
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-14
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-15
Draft EIR
May 2025
5.11.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of the CEQA Guidelines indicates that the Project could have a significant effect if it were to
result in:
NOI-1 Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity
of the project in excess of standards established in the local general plan or noise ordinance, or
applicable standards of other agencies.
NOI-2 Generation of excessive groundborne vibration or groundborne noise levels.
NOI-3 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,
expose people residing or working in the project area to excessive noise levels.
Construction Noise
The City of Newport Beach has not adopted any specific construction noise standards. Therefore, the
thresholds based on Occupational Safety and Health Administration (CalOSHA) information related to
exposure to noise levels are construction noise limits generating a temporary noise level increase above the
existing daytime ambient noise levels of up to 12 dBA Leq and not to exceed 80 dBA Leq.
Operational Noise
The City of Newport Beach General Plan Policy N 1.8 states that a significant noise increase occurs when
there is an increase in the ambient CNEL produced by new development impacting existing sensitive uses.
General Plan Policy N 1.8 identifies a threshold of 3 dBA in areas with an ambient CNEL of less than 60
dBA, a threshold of 2 dBA in areas with an ambient CNEL between 60 and 65 dBA, and a threshold of 1
dBA in areas with an ambient CNEL between 65 dBA and 75 dBA.
The Municipal Code, Chapter 10.26 Community Noise Control exterior noise level standards identifies a 55
dBA Leq daytime and 50 dBA Leq (or existing ambient level if higher) nighttime noise standard for
residential properties; and a 65 dBA Leq daytime and 60 dBA Leq (or existing ambient level if higher)
nighttime noise standard for commercial uses, including the Project site.
Vibration
The City of Newport Beach has not adopted any specific vibration level standards. Therefore, the Caltrans
Transportation and Construction Vibration Guidance Manual, Table 19, vibration levels are used to assess
potential temporary construction-related impacts at adjacent building locations. This criteria is appropriate
as vibration impacts are only assessed within structures, vibrations in outdoor environments are generally not
an environmental concern, and temporary annoyance is not generally considered a substantial effect on the
environment. The nearest vibration-sensitive buildings to the Project site are “older residential structures” with
a maximum acceptable continuous vibration threshold of 0.3 PPV (in/sec).
Noise and vibration impacts may be considered significant if any of the following occur as a result of the
proposed Project. Table 5.11-5 provides a summary of the noise significance criteria.
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-16
Draft EIR
May 2025
Table 5.11-5: Significance Criteria Summary
Analysis Receiving
Land Use Condition(s) Significance Criteria
Daytime Nighttime
Operational
Noise
Residential1 Exterior Noise Level Standards 55 dBA Leq 50 dBA Leq
Commercial1 Exterior Noise Level Standards 65 dBA Leq 60 dBA Leq
Noise-
Sensitive3
If ambient is < 60 dBA CNEL ≥ 3 dBA CNEL Project Increase
If ambient is 60 - 65 dBA CNEL ≥ 2 dBA CNEL Project Increase
If ambient is 65 - 75 dBA CNEL ≥ 1 dBA CNEL Project Increase
If ambient is > 75 dBA CNEL Any Project Increase
Construction
All Noise Level Threshold4 80 dBA Leq
Noise Level Increase ≥ 12 dBA CNEL Project Increase
All4 Vibration Level Threshold4 0.3 PPV
(in/sec) n/a
1 City of Newport Beach General Plan Noise Element Policy N 1.5.
2 City of Newport Beach Municipal Code, Section 10.26.025 (Appendix 3.1).
3 City of Newport Beach General Plan Policy N 1.8
4 Caltrans Transportation and Construction Vibration Guidance Manual, 2020.
“Daytime” = 7:00 a.m. to 10:00 p.m.; “Nighttime” = 10:00 p.m. to 7:00 a.m.
“VdB” = Vibration Decibels
5.11.5 METHODOLOGY
Construction Noise
To identify the temporary construction noise contribution to the existing ambient noise environment, the
construction noise levels anticipated from usage of construction equipment needed to implement the proposed
Project were combined with the existing ambient noise level measurements at the sensitive receiver locations.
The City’s Municipal Code limits construction hours to reduce noise, and based on CalOSHA standards, a
numeric maximum acceptable construction source noise levels threshold at potentially affected receivers has
been identified to provide a quantified determination of what CEQA constitutes a substantial temporary or
periodic noise increase. The construction noise levels at sensitive receptors are compared against the
thresholds to assess the level of significance associated with temporary construction noise level impacts.
Operational Noise
The primary sources of noise associated with the operation of the proposed Project would be from vehicular
trips, roof-top air conditioning units, satellite speakers, main announcement speakers, wave machine activity,
lagoon activity, spectator activity, trash enclosure activity, loading activity, and parking lot vehicle
movements.
The expected roadway noise level increases from vehicular traffic were calculated based on the average
daily traffic volumes from the Trip Generation Assessment, included as Appendix R, prepared for the
proposed Project. As detailed in Section 5.14, Transportation, the proposed Project is anticipated to
generate a net increase of 186 new trips per day, with a reduction of 73 a.m. peak hour trips and a
reduction of 10 p.m. peak hour trips. The increase in noise levels generated by the vehicular trips have been
quantitatively estimated and compared to the applicable noise standards and thresholds of significance
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-17
Draft EIR
May 2025
listed previously. The increase in noise levels generated by these activities has been quantitatively estimated
and compared to the applicable noise standards listed previously.
Vibration
Aside from noise levels, groundborne vibration would also be generated during construction of the Project
by various construction-related activities and equipment; and could be generated by truck traffic traveling
to and from the Project site. The potential ground-borne vibration levels resulting from construction activities
occurring from the proposed Project were estimated by data published by the FTA. Thus, the groundborne
vibration levels generated by these sources have also been quantitatively estimated and compared to the
applicable thresholds of significance listed previously.
5.11.6 ENVIRONMENTAL IMPACTS
IMPACT NOI-1: THE PROJECT WOULD NOT RESULT IN GENERATION OF A SUBSTANTIAL
TEMPORARY OR PERMANENT INCREASE IN AMBIENT NOISE LEVELS IN THE VICINITY
OF THE PROJECT IN EXCESS OF STANDARDS ESTABLISHED IN THE LOCAL GENERAL
PLAN OR NOISE ORDINANCE, OR APPLICABLE STANDARDS OF OTHER AGENCIES.
Less than Significant Impact.
Construction
Noise generated by construction equipment would include a combination of trucks, power tools, concrete
mixers, and portable generators that when combined can reach high levels. Construction is expected to occur
in the following stages: site preparation, grading, building construction, paving, architectural coating.
To describe construction noise activities, a construction noise analysis was prepared using reference
construction equipment noise levels from the Federal Highway Administration (FHWA) published the
Roadway Construction Noise Model (RCNM), which includes a national database of construction equipment
reference noise emission levels. The RCNM equipment database provides a comprehensive list of the noise-
generating characteristics of specific types of construction equipment. In addition, the database provides an
acoustical usage factor to estimate the fraction of time each piece of construction equipment is operating at
full power (i.e., its loudest condition) during a construction operation.
According to the EPA, FTA, and FHWA, the overall construction noise level is governed primarily by the
noisiest pieces of equipment. The quieter pieces do not affect the overall level, but they do reduce the
magnitude of the fluctuations in the noise level. Therefore, a rough estimate of the noise level need only
include the noisiest pieces of equipment expected at the site (Appendix Q). Consistent with FHWA and FTA
guidance for detailed construction noise assessment, Table 5.11-6 provides the combined noise levels for the
loudest construction activities expected for each stage, assuming all equipment operates simultaneously. As
shown, noise levels generated by heavy construction equipment range from approximately 76 dBA Lmax to
84.4 dBA Lmax at 50 feet from the noise source, as shown on Table 5.11-6.
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-18
Draft EIR
May 2025
Table 5.11-6: Construction Reference Noise Levels
Construction
Stage
Reference
Construction
Equipment
Reference Noise
Level @ 50 Feet
(dBA Leq)
Composite Reference
Noise Level
(dBA Leq)
Reference
Power Level
(dBA Lw)
Demolition
Concrete Saw 83.0
84.4 116.0 Excavator 77.0
Backhoe 74.0
Site
Preparation
Tractor 80.0
82.9 114.5 Front End Loader 75.0
Dozer 78.0
Grading
Tractor 80.0
84.2 115.9 Grader 81.0
Compactor (ground) 76.0
Building
Construction
Crane 73.0
82.1 113.7 Generator 78.0
Gradall 79.0
Paving
Paver 74.0
77.8 109.5 Dump Truck 72.0
Roller 73.0
Architectural
Coating
Man Lift 68.0
76.2 107.8 Compressor (air) 74.0
Generator (<25kVA) 70.0
Source: Appendix Q
Per Municipal Code Section 10.28.020, noise sources associated with construction activities shall not take
place between the hours of 6:30 p.m. and 7:00 a.m. during the week, before 8:00 a.m. or after 6:00 p.m.
on Saturdays; with no construction work allowed on Sundays or Federal holidays. The proposed Project’s
construction activities would occur pursuant to these regulations. Thus, the construction activities would comply
with the City’s construction-related noise standards.
Construction noise would be temporary in nature as the operation of each piece of construction equipment
would not be constant throughout the construction day, and equipment would be turned off when not in use.
The Project construction would involve various stages, and activities frequently shift from one location to
another. For example, during site preparation and grading, noise-generating activities may concentrate in
an area for a short period to remove an obstruction, while the majority of the grading involves the equipment
moving back and forth in a predictable pattern throughout the site; building construction and foundation
work generally concentrates near the building footprint, while paving generally involves a predictable
pattern of movement throughout the site. Therefore, construction activities were modeled as multiple moving
point sources within the construction area, and to provide a conservative analysis the modeling was based
on the loudest activity and the highest noise level calculated at each receiver location. As shown in Table
5.11-7, the construction noise levels are expected to range from 50.0 to 63.8 dBA Leq at the nearby receiver
locations, which are shown on Figure 5.11-3. This is below the threshold of 80 dBA Leq. In addition, the
construction noise is below the existing daytime noise levels that range from 67.8 to 73.7 dBA. Therefore,
impacts related to construction noise levels would be less than significant.
Snug Harbor Surf Park Project
City of Newport Beach
Source: Urban Crossroads. 2025. Surf Farm Air Quality Impact Analysis.
Figure 5.11-3
Construction Activity and Receiver Locations
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-20
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-21
Draft EIR
May 2025
Table 5.11-7: Construction Activity Noise Levels
Receiver
Location
Construction Noise Levels (dBA Leq)
Demolition Site
Preparation Grading Building
Construction Paving Architectural
Coating
Highest
Levels1
R1 62.0 60.8 59.2 59.4 55.5 54.4 62.0
R2 62.5 61.3 59.7 59.9 56.0 54.9 62.5
R3 63.8 62.6 61.0 61.2 57.3 56.2 63.8
R4 58.7 57.5 55.9 56.1 52.2 51.1 58.7
R5 61.3 60.1 58.5 58.7 54.8 53.7 61.3
R6 57.7 56.5 54.9 55.1 51.2 50.1 57.7
R7 57.6 56.4 54.8 55.0 51.1 50.0 57.6
R8 60.3 59.1 57.5 57.7 53.8 52.7 60.3
Source: Appendix Q
1Construction noise level calculations are measured from the Project site boundary to the nearest receiver locations.
To describe the temporary Project construction noise level contributions to the existing ambient noise
environment, the Project construction noise levels were combined with the existing ambient noise level
measurements at the nearest offsite receiver locations. The difference between the combined Project-
construction and ambient noise levels is used to describe the construction noise level contributions. As shown
in Table 5.11-8, noise from Project construction would increase existing ambient noise levels between 0.2 to
1.1 dBA Leq during the daytime hours at the nearest receiver locations, which would not exceed the threshold
of either 80 dBA or a 12 dBA increase in ambient noise. Therefore, impacts related to the increase in ambient
noise from construction activities would be less than significant.
Table 5.11-8: Increases in Daytime Ambient Noise Levels from Construction Activity
Receiver
Location
Total Project
Construction
Noise Level
Measurement
Location
Reference
Ambient
Noise Levels
Combined
Project and
Ambient
Project
Increase
Increase
Criteria
Increase
Criteria
Exceeded?
R1 62.0 L1 71.3 71.8 0.5 12 No
R2 62.5 L2 67.8 68.9 1.1 12 No
R3 63.8 L3 72.4 73.0 0.6 12 No
R4 58.7 L4 69.1 69.5 0.4 12 No
R5 61.3 L5 73.4 73.7 0.3 12 No
R6 57.7 L6 68.3 68.7 0.4 12 No
R7 57.6 L7 70.6 70.8 0.2 12 No
R8 60.3 L8 73.7 73.9 0.2 12 No
Source: Appendix Q
Operation
Operational Traffic Noise
The expected Project is anticipated to generate a net increase of 186 average daily trips (ADT), which
would represent an incremental increase to the existing roadway volumes of 31,000 ADT and 6,000 ADT
for Irvine Avenue and Mesa Drive respectively, and is not expected to double traffic or generate a
perceptible noise level increase (i.e., less than 3 dBA CNEL) at nearby sensitive land uses adjacent to study
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-22
Draft EIR
May 2025
area roadways. Further, the Project would result in a reduction of 73 a.m. peak hour trips and 10 p.m. peak
hour trips compared to the existing uses. Due to the low traffic volumes generated by the Project, the offsite
traffic noise levels generated by the Project would be less than significant.
Onsite Operational Noise
Operation of the proposed surf park would generate onsite noise from typical commercial activity such as
roof-top air conditioning units that produce 57.4 dBA Leq at 50 feet, parking lot activity that is
approximately 63 dBA, trash enclosure activity that is approximately 57.3 dBA Leq at 50 feet, and loading
of trucks for operational services and supplies that is approximately 69.8 dBA Leq at 50 feet.
The Project would include satellite speakers located near the seating and surf lagoon areas. To describe the
worst-case reference noise level conditions, a reference noise level of 66.4 Leq at a distance of 50 feet (4
times louder than the typical raised human voice) is used. The Project also includes speakers located
throughout the facility as shown in Figure 5.11-4, Operational Noise Sources, to provide announcements as
well as music during outdoor events. A conservative reference noise level of 71.4 Leq at a distance of 50
feet (4 times louder than the typical shouting human voice) is used to identify any potential speaker noise
related impacts. The use of all speakers would be limited to the hours of 7:00 a.m. to 10:00 p.m.
Based on the manufacturer’s specifications for the wave generator, the proposed wave machinery would
generate a peak wave noise event of 61.4 Leq at a distance of 50 feet, which would be limited to the hours
of 6:00 a.m. to 11:00 p.m. In addition, the noise from the surf lagoon, warming pools, and spa activities
resulted in approximately 57.8 dBA Leq at 50 feet, and surf lagoon spectators result in approximately 43.4
dBA Leq. at 50 feet, as further detailed in the Noise Analysis, included as Appendix Q.
Using these reference noise levels, the Noise Analysis (Appendix Q) calculated the operational source noise
levels that are expected to be generated by the Project and the Project-related noise level increases at
each of the sensitive receiver locations. Table 5.11-9 shows that the Project operational noise levels during
the daytime hours of 7:00 a.m. to 10:00 p.m. are expected to range from 53.8 to 64.1 dBA Leq at the
offsite receiver locations. This is less than the existing daytime ambient noise in the Project vicinity, which
ranges from 67.8 to 73.7 dBA, as listed previously in Table 5.11-4.
Table 5.11-9: Daytime Operational Noise Levels
Noise Source Operational Noise Levels by Receiver Location (dBA Leq)
R1 R2 R3 R4 R5 R6 R7 R8
Roof-Top Air Conditioning
Unit 41.5 42.5 43.3 38.7 40.8 37.1 36.1 37.7
Parking Lot Vehicle
Movements 25.1 27.1 29.1 21.9 24.5 17.7 15.8 20.1
Trash Enclosure Activity 4.8 9.7 14.7 17.0 23.0 12.5 7.6 18.6
Loading Activity 41.0 39.0 39.0 36.2 30.0 34.7 33.2 43.3
Satellite Speakers 43.5 40.1 40.2 37.0 34.0 41.4 42.4 42.8
Main Announcement
Speaker 58.9 55.6 53.9 50.0 48.3 55.1 56.0 58.5
Wave Machine Activity 37.6 33.5 32.1 28.0 25.5 33.5 34.3 36.2
Water Heater Activity 22.2 20.7 20.8 18.2 12.7 19.1 20.3 28.0
Pool Activity 34.5 25.6 25.3 25.3 31.3 33.5 34.5 34.3
Spectator Activity 34.2 25.9 24.0 24.1 32.6 32.0 35.9 36.0
Total (All Noise Sources) 64.1 60.8 59.3 55.1 53.8 60.1 61.0 63.7
Source: Appendix Q
Snug Harbor Surf Park Project
City of Newport Beach
Source: Urban Crossroads. 2025. Surf Farm Air Quality Impact Analysis.
Figure 5.11-4
Operational Noise Sources
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-24
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-25
Draft EIR
May 2025
Table 5.11-10 shows that the Project operational noise levels during the nighttime hours of 10:00 p.m. to
7:00 a.m. are expected to range from 40.0 to 45.7 dBA Leq. The differences between the daytime and
nighttime noise levels are largely related to the duration of noise activity.
Table 5.11-10: Nighttime Operational Noise Levels
Noise Source Operational Noise Levels by Receiver Location (dBA Leq)
R1 R2 R3 R4 R5 R6 R7 R8
Roof-Top Air Conditioning Unit 38.3 39.3 40.0 35.5 37.6 33.8 32.8 34.4
Parking Lot Vehicle Movements 24.2 26.1 28.1 20.9 23.5 16.7 14.8 19.1
Trash Enclosure Activity 3.8 8.8 13.7 16.0 22.0 11.5 6.6 17.6
Loading Activity 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Satellite Speakers 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Main Announcement Speaker 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Wave Machine Activity 36.6 32.6 31.1 27.1 24.6 32.5 33.4 35.2
Water Heater Activity 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Pool Activity 30.6 21.6 21.4 21.3 27.3 29.6 30.5 30.3
Spectator Activity 33.2 24.9 23.0 23.1 31.6 31.0 34.9 35.0
Total (All Noise Sources) 45.7 44.1 44.5 40.0 42.9 41.8 43.0 44.1
Source: Appendix Q
To identify if the Project would comply with local noise regulations, the Project-only operational noise levels
are evaluated against the exterior noise level standards at the nearest noise-sensitive receiver locations. For
noise-sensitive residential land uses, the City has established exterior noise level standards of 55 dBA Leq
during the daytime hours (7:00 a.m. to 10:00 p.m.) and 50 dBA Leq during the nighttime hours (10:00 p.m.
to 7:00 a.m.). In the event the ambient noise level exceeds the noise standard, the maximum allowable noise
level under said category shall be increased to reflect the maximum ambient noise level (Section
10.26.025(C)). Noise level limits in Table 5.11-11 have been adjusted based on the 24-hour noise level
measurements in Table 5.11-4. Table 5.11-11 shows that the operational noise levels associated with the
Project would be within the exterior noise level standards at the receiver locations. Therefore, the operational
noise impacts would be less than significant.
Table 5.11-11: Operational Noise Level Compliance
Receiver
Location
Project Operational
Noise Levels (dBA Leq)
Noise Level Standards
(dBA Leq)
Noise Level Standards
Exceeded?
Daytime Nighttime Daytime Nighttime Daytime Nighttime
R1 64.1 45.7 71.3 50.0 No No
R2 60.8 44.1 67.8 50.0 No No
R3 59.3 44.5 72.4 62.5 No No
R4 55.1 40.0 69.1 50.0 No No
R5 53.8 42.9 73.4 65.6 No No
R6 60.1 41.8 68.3 50.0 No No
R7 61.0 43.0 70.6 50.0 No No
R8 63.7 44.1 73.7 50.0 No No
Source: Appendix Q
“Daytime” = 7:00 a.m. to 7:00 p.m.; “Nighttime” = 10:00 p.m. to 7:00 a.m.
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-26
Draft EIR
May 2025
To describe the operational noise level increase, the Project operational noise levels are combined with the
existing ambient noise level measurements for the nearest receiver locations. The difference between the
combined Project and ambient noise levels describes the Project noise level increase to the existing ambient
noise environment. Table 5.11-12 and Table 5.11-13 identifies that the Project would generate daytime
operational noise level increases ranging from less than 0.1 to 0.8 dBA Leq and nighttime noise level
increases ranging from less than 0.1 to 2.0 dBA Leq at the nearby receiver locations, which are less than the
thresholds. Therefore, noise impacts related to Project operations would be less than significant.
Table 5.11-12: Operational Daytime Noise Level Increases
Receiver
Location
Total Project
Operational
Noise Level
Measurement
Location
Reference
Ambient
Noise Levels
Combined
Project and
Ambient
Project
Increase
Increase
Criteria
Increase
Criteria
Exceeded?
R1 64.1 L1 71.3 72.1 0.8 1.0 No
R2 60.8 L2 67.8 68.6 0.8 1.0 No
R3 59.3 L3 72.4 72.6 0.2 1.0 No
R4 55.1 L4 69.1 69.3 0.2 1.0 No
R5 53.8 L5 73.4 73.4 0.0 1.0 No
R6 60.1 L6 68.3 68.9 0.6 1.0 No
R7 61.0 L7 70.6 71.1 0.5 1.0 No
R8 63.7 L8 73.7 74.1 0.4 1.0 No
Source: Appendix Q
Table 5.11-13: Operational Nighttime Noise Level Increases
Receiver
Location
Total Project
Operational
Noise Level
Measurement
Location
Reference
Ambient
Noise Levels
Combined
Project and
Ambient
Project
Increase
Increase
Criteria
Increase
Criteria
Exceeded?
R1 45.7 L1 50.9 52.0 1.1 3.0 No
R2 44.1 L2 51.8 52.5 0.7 3.0 No
R3 44.5 L3 62.5 62.6 0.1 2.0 No
R4 40.0 L4 54.2 54.4 0.2 3.0 No
R5 42.9 L5 65.6 65.6 0.0 1.0 No
R6 41.8 L6 44.2 46.2 2.0 3.0 No
R7 43.0 L7 50.0 50.8 0.8 3.0 No
R8 44.1 L8 53.5 54.0 0.5 3.0 No
Source: Appendix Q
IMPACT NOI-2: THE PROJECT WOULD NOT RESULT IN GENERATION OF EXCESSIVE GROUNDBORNE
VIBRATION OR GROUNDBORNE NOISE LEVELS.
Less than Significant Impact.
Construction
Construction activities for development of the Project would include demolition, site preparation, grading,
building construction, paving, architectural coating, which have the potential to generate low levels of
groundborne vibration that diminish with distance. People working in close proximity to the construction could
be exposed to the generation of excessive groundborne vibration or groundborne noise levels related to
construction activities. The results from vibration can range from no perceptible effects at the lowest vibration
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-27
Draft EIR
May 2025
levels, to low rumbling sounds and perceptible vibrations at moderate levels, to slight structural damage at
the highest levels. Site ground vibrations from construction activities very rarely reach the levels that can
damage structures, but they can be perceived in the audible range and be felt in buildings very close to a
construction site.
Excavation and grading activities are required for implementation of the Project and can result in varying
degrees of ground vibration, depending on the equipment and methods used, distance to the affected
structures and soil type. Based on the reference vibration levels provided by Caltrans, a large bulldozer
represents the peak source of vibration with a reference velocity of 0.089 PPV in/sec at 25 feet, as shown
in Table 5.11-14.
Table 5.11-14: Vibration Source Levels for Construction Equipment
Equipment Vibration Decibels (VdB)
at 25 feet
Small bulldozer 0.003
Jackhammer 0.035
Loaded Trucks 0.076
Large bulldozer 0.089
Source: Appendix Q
The Project’s potential vibration impacts were determined based on the construction vibration assessment
methodology published by Caltrans. Table 5.11-15 identifies the expected Project-related vibration levels
at the nearby receiver locations that range from 169 to 797 feet from Project construction activities. As
shown, construction vibration velocity levels are estimated to range from 0.00 to 0.01 PPV in/sec, which
would not exceed the 0.30 PPV in/sec threshold. Therefore, impacts related to construction vibration would
be less than significant.
Table 5.11-15: Construction Vibration Levels
Receiver
Location
Distance to
Construction
Activity
(Feet)
Receiver Vibration Levels (PPV in/sec) Threshold
(PPV
in/sec)
Threshold
Exceeded? Small
Bulldozer
Jack-
hammer
Loaded
Trucks
Large
Bulldozer
Highest
Vibration
Levels
R1 399' 0.00 0.00 0.00 0.00 0.00 0.30 No
R2 256' 0.00 0.00 0.01 0.01 0.01 0.30 No
R3 169' 0.00 0.00 0.01 0.01 0.01 0.30 No
R4 502' 0.00 0.00 0.00 0.00 0.00 0.30 No
R5 284' 0.00 0.00 0.01 0.01 0.01 0.30 No
R6 673' 0.00 0.00 0.00 0.00 0.00 0.30 No
R7 797' 0.00 0.00 0.00 0.00 0.00 0.30 No
R8 386' 0.00 0.00 0.00 0.00 0.00 0.30 No
Source: Appendix Q
Operation
Operation of the proposed Project would include heavy trucks for deliveries, moving trucks, and garbage
trucks for solid waste disposal. Truck vibration levels are dependent on vehicle characteristics, load, speed,
and pavement conditions. According to the FTA Transit Noise Impact and Vibration Assessment, trucks traveling
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-28
Draft EIR
May 2025
at a distance of 50 feet typically generate groundborne vibration velocity levels of approximately 0.006
inch per second PPV and could reach approximately 0.016 inch per second PPV when trucks pass over
bumps in the road (FTA, 2018). Since the trucks on the site would be travelling at low speeds on smooth
surfaces, it is expected that truck vibrations at nearby receiver locations would be less than the vibration
threshold of 0.30 PPV; and therefore, would be less than significant.
IMPACT NOI-3: THE PROJECT WOULD NOT, 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, EXPOSE PEOPLE RESIDING OR WORKING IN THE PROJECT AREA TO
EXCESSIVE NOISE LEVELS.
Less than Significant Impact.
As described previously, SNA is located approximately 0.4-mile northeast of the Project site. As shown in
Section 5.8, Hazards and Hazardous Materials, on Figure 5.8-2, 2024 John Wayne Airport Noise Contours,
the Project site is located within the SNA 65 CNEL noise contour as identified by the airport in 2024. As
shown in Table 5.11-4, the existing daytime noise levels range from 67.8 to 73.7 dBA, which is largely
generated from both airport operations and traffic along both Irvine Avenue and Mesa Drive.
The AELUP contains airport noise contours from 1985 (shown in Figure 5.10-3 in Section 5.10, Land Use and
Planning), which identifies that a majority of the Project site is located within the 65 dBA CNEL and a small
area in the northeastern portion of the Project site that is planned for parking and wave lagoon machinery
is in the 70 dBA CNEL airport noise contour. The AELUP for SNA states that community facilities and
commercial land uses are “conditionally consistent” within the 70 CNEL contour with interior sound attenuation.
There are no proposed structures proposed within the 70 CNEL contour. Only parking and lagoon equipment
would be located in the area. In addition, the General Plan Land Use Noise Compatibility Matrix (GP Table
N2), included as Table 5.11-1, identifies that commercial recreation facilities are “normally compatible” up
to 75 dBA CNEL.
Therefore, the proposed community related commercial recreation facilities that are proposed for the site
would be consistent with the aircraft noise from operation of SNA pursuant to both the AELUP and City’s
General Plan. Impacts related to exposure of people within the Project area to excessive airport-related
noise levels would be less than significant.
5.11.7 CUMULATIVE IMPACTS
Cumulative noise assessment considers development of the proposed Project in combination with ambient
growth and other development projects within the vicinity of the proposed Project. As noise is a localized
phenomenon and drastically reduces in magnitude as distance from the source increases, only projects and
ambient growth in the immediate vicinity could combine with the proposed Project to result in cumulative
noise impacts.
Construction Noise
Construction noise is localized in nature and decreases substantially with distance. Consequently, in order to
achieve a substantial cumulative increase in construction noise levels, more than one source emitting high
levels of construction noise would need to be in close proximity to the proposed Project. The nearest
development project, and the only project within potential hearing distance is Project Number 5 listed in
Table 5-1, Cumulative Projects List, in Section 5.0, Environmental Impact Analysis, which is the Newport Irvine
Medical parking garage project located at 3300 Irvine Avenue, which is beyond receiver location R8 shown
on Figure 5.11-2, and thus farther from the Project site. As detailed in Table 5.11-8, the increase in ambient
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-29
Draft EIR
May 2025
noise from construction activity at R8 is 0.2 dBA. Because the Newport Irvine Medical parking garage project
is beyond, and farther than R8, construction noise would be lower at the cumulative project location. In
addition, no application for development of Housing Opportunity sites 23, 24, 25, and 26 to the south of
Mesa Drive has been submitted to the City; therefore, cumulative construction noise is not anticipated.
However, the Project’s construction noise increase at R5 (near Housing Opportunity sites 23, 24, 25, and 26)
would be 0.3 dBA, which is less than cumulatively significant. Therefore, construction noise generated from
the proposed Project would not combine to become cumulatively considerable, and cumulative noise impacts
associated with Project construction activities would be less than significant.
Operational Traffic Noise
Cumulative traffic source noise impacts would occur primarily as a result of increased traffic on local
roadways due to proposed development projects and related projects within a study area. Therefore,
cumulative traffic-generated noise impacts has been assessed based on the contribution of the proposed
Project to traffic volumes on the roadways in the Project vicinity. As detailed previously, the Project would
result in a reduction of 73 a.m. peak hour trips and 10 p.m. peak hour trips compared to the existing uses.
The reduced vehicular trips during peak hours would result in less than cumulatively considerable vehicle
noise.
Onsite Operational Noise
As detailed previously, impacts associated with onsite noise sources would be less than significant. Other
projects would be required to evaluate onsite noise sources and, if necessary, mitigate for such impacts. the
Project would generate daytime operational noise level increases ranging from less than 0.2 to 0.8 dBA Leq
and nighttime noise level increases ranging from less than 0.1 to 2.0 dBA Leq at the nearby receiver
locations, which are less than the thresholds. Thus, the Project would not result in an exceedance that could
have a cumulatively considerable contribution to an increase in ambient noise. Stationary noise is a localized
phenomenon and there is very limited potential for cumulative noise impacts to occur. Each related project
in the Project vicinity would require noise assessments and compliance with noise-related municipal codes, as
part of permitting requirements that would address potential noise impacts and identify necessary
attenuation measures, where appropriate. The closest cumulative project consists of a medical office building
and parking garage use, which is consistent with the uses in the Project site vicinity and is not anticipated to
result in cumulative impacts related to operational noise. Housing Opportunity sites 25 and 26, across Mesa
Drive from the Project site, that total 8.82 acres, have been identified for potential future residential uses
by the City’s Housing Implementation Program. However, the Project would result in between 0.0 to a 0.6
dBA noise increase to the south from operations, which is less than cumulatively considerable, and no
applications for development of the site has been submitted to the City. Any future projects would require
compliance with noise related municipal codes. As such, the Project, in conjunction with other projects, would
not have a cumulatively considerable impact related to onsite operational noise. Cumulative onsite
operational noise impacts from the Project would be less than significant.
Construction Vibration
Cumulative construction could also result in the exposure of people to or the generation of excessive
groundborne vibration. As described above, the proposed Project would result in limited vibration from
construction activities. Cumulatively significant construction vibration would only have the potential to occur
when construction activities generating high vibration levels occur in close proximity to one another in a way
that concentrates the vibration. The farther construction activities occur from one another on each respective
project site, the quicker the vibration dissipates by the time it reaches a sensitive receptor. Additionally,
because heavy construction equipment moves around a project site it would only occur for limited durations
at receptors. Both the proposed Project and related projects would be required to comply with the limitations
on allowable hours of construction that limit potential construction vibration impacts. Due to the limited
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-30
Draft EIR
May 2025
vibration generated by Project construction (listed in Table 5.11-15) that would be in temporary locations
throughout the site, and the locations of cumulative projects (as shown in Figure 5-1, Cumulative Projects, in
Section 5.0, Environmental Impact Analysis) impacts related to groundborne vibration would be less than
cumulatively considerable.
Operational Vibration
As detailed previously, operational vibration from the Project would be limited to trucks on nearby roadways
and on site that would be travelling at low speeds on smooth surfaces and would generate vibration below
the threshold of 78 VdB. Because the vibration would be limited and would further diminish with distance,
the Project vibration would not combine to become cumulatively considerable, and cumulative operational
vibration would be less than significant.
5.11.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES
Existing Regulations
• CALGreen Section 5.507, Environmental Comfort
• Municipal Code Chapter 10.26, Community Noise Control
• Municipal Code Section 10.28.040, Construction Activity - Noise Regulations
• Municipal Code Section 20.90.040.D, Noise Mitigation
5.11.9 PROJECT DESIGN FEATURES
None.
5.11.10 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Impacts NOI-1 through NOI-3 would be less than significant.
5.11.11 MITIGATION MEASURES
No mitigation measures are required.
5.11.12 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts would be less than significant.
5.11.13 REFERENCES
City of Newport Beach. (2001, January). Santa Ana Heights Specific Plan. Retrieved September 23, 2024,
from ocpublicworks.com.
City of Newport Beach. (2006a, July). General Plan. Retrieved September 23, 2024, from
newportbeachca.gov: https://www.newportbeachca.gov/government/departments/community-
development/planning-division/general-plan-codes-and-regulations/general-plan
City of Newport Beach. (2006b, July). General Plan Environmental Impact Report. Retrieved September 23,
2024, from newportbeachca.gov:
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-31
Draft EIR
May 2025
https://www.newportbeachca.gov/government/departments/community-development/planning-
division/general-plan-codes-and-regulations/general-plan/general-plan-environmental-impact-
repor
City of Newport Beach. (2024, May). Newport Beach Municipal Code. Retrieved September 23, 2024,
from codepublishing.com: https://www.codepublishing.com/CA/NewportBeach/
City of Newport Beach. (n.d.-a). City of Newport Beach General Plan Environmental Impact Report Section
4.13.
City of Newport Beach. (n.d.-b). Municipal Code, Chapter 10.26 Community Noise Control.
John Wayne Airport Orange County. (2022). 2022 Annual Community Noise Eqivalent Level (CNEL)
Contours. HMMH, Inc. Retrieved from https://files.ocair.com/media/2023-
03/311880_JWA_2022_Annual_CNEL_Contour.pdf?VersionId=grgr4FqqOeVvg9UJzJOatnWHg
bcdOsUK
Federal Transit Administration (FTA). (2018). Transit Noise and Vibration Impact Assessment.
https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/transit-
noise-and-vibration-impact-assessment-manual-fta-report-no-0123_0.pdf
Urban Crossroads. (2025). Surf Farm Noise Analysis. (Appendix Q)
Snug Harbor Surf Park Project 5.11 Noise
City of Newport Beach 5.11-32
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 5.12 Public Services
City of Newport Beach 5.12-1
Draft EIR
May 2025
5.12 Public Services
5.12.1 INTRODUCTION
This section describes the existing fire protection, police protection, schools, and library facilities that serve
the Project site and vicinity and evaluates the potential for implementation of the proposed Project to result
in an impact. This section of the EIR addresses whether there are physical environmental effects of new or
expanded facilities that are necessary to maintain acceptable service levels related to fire, police, schools,
and library services. Park services are addressed in Section 5.13, Parks and Recreation. Public utilities and
service systems, including water, wastewater, drainage, and solid waste, are addressed in Section 5.16,
Utilities and Service Systems. The analysis in this section is based, in part, on the following documents and
resources.
• City of Newport Beach General Plan, 2006
• City of Newport Beach General Plan Environmental Impact Report (General Plan EIR), 2006
• City of Newport Beach Municipal Code
Because CEQA focuses on physical environmental effects, this section analyzes whether any physical changes
resulting from an increase in service demands from development pursuant to the proposed Project could
result in significant adverse environmental effects. Thus, an increase in staffing associated with public services,
or an increase in calls for services, would not, by itself, be considered a physical change in the environment.
However, physical changes in the environment resulting from the construction of new facilities or an expansion
of existing facilities to accommodate the increased staff or equipment needs resulting from the proposed
Project could constitute a significant impact.
5.12.2 REGULATORY SETTING
5.12.2.1 Federal Regulations
There are no federal regulations pertaining to public services that would be applicable to the Project.
5.12.2.2 State Regulations
California Building Code
The California Building Code includes fire safety requirements, including the installation of sprinklers in all
commercial and residential buildings; the establishment of fire resistance standards for fire doors, building
materials, and particular types of construction; and the clearance of debris and vegetation within a
prescribed distance from occupied structures in wildfire hazard areas.
California Fire Code
California Code of Regulations (CCR) Title 24, Part 9 (California Fire Code) contains regulations relating to
construction and maintenance of buildings, the use of premises, and the management of wildland-urban
interface areas, among other issues. The California Fire Code is updated every three years by the California
Building Standards Commission and was last updated in 2022 (effective January 1, 2023).
The Fire Code sets forth regulations regarding building standards, fire protection and notification systems,
fire protection devices such as fire extinguishers and smoke alarms, high-rise building standards, and fire
Snug Harbor Surf Park Project 5.12 Public Services
City of Newport Beach 5.12-2
Draft EIR
May 2025
suppression training. It contains regulations relating to construction, maintenance, and use of buildings. Topics
addressed in the code also include fire department access, fire hydrants, automatic sprinkler systems, fire
alarm systems, fire and explosion hazards safety, hazardous materials storage and use, provisions intended
to protect and assist fire responders, industrial processes, and many other general and specialized fire-
safety requirements for new and existing buildings and the surrounding premises. Development under the
Project would be subject to applicable regulations of the California Fire Code.
California Occupational Safety and Health Administration
In accordance with the California Code of Regulations, Title 8 Sections 1270 “Fire Prevention” and 6773
“Fire Protection and Fire Fighting Equipment,” California Occupational Safety and Health Administration
(Cal/OSHA) has established minimum standards for fire suppression and emergency medical services. The
standards include, but are not limited to, guidelines on the handling of highly combustible materials, fire
house sizing requirements, restrictions on the use of compressed air, access roads, and the testing,
maintenance, and use of all firefighting and emergency medical equipment.
Mitigation Fee Act (California Government Code Sections 66000 et seq.)
Enacted as Assembly Bill (AB) 1600, the Mitigation Fee Act requires a local agency, such as the City of
Newport Beach to establish, increase, or impose an impact fee as a condition of development to identify the
purpose of the fee and the use to which the fee is to be put. The agency must also demonstrate a reasonable
relationship between the fee and the purpose for which it is charged, and between the fee and the type of
development Project on which it is to be levied. This Act became enforceable on January 1, 1989.
California Government Code (Section 65995(b)) and Education Code (Section 17620)
California Senate Bill 50 (SB 50), which passed in 1998, amended California Government Code Sections
65995.5 through 65998, which contains limitations on Education Code Section 17620. The statute authorizes
school districts to assess development fees within school district boundaries. Government Code Section
65995(b)(3) requires the maximum square footage assessment for development to be increased every two
years, according to inflation adjustments.
According to California Government Code Section 65995(3)(h), the payment of statutory fees is “deemed
to be full and complete mitigation of the impacts of any legislative or adjudicative act, or both, involving,
but not limited to, the planning, use, or development of real property, or any change in governmental
organization or reorganization... on the provision of adequate school facilities.” The school district is
responsible for implementing the specific methods for mitigating school impacts under the Government Code.
5.12.2.3 Local and Regional Regulations
City of Newport Beach General Plan 2006
The City of Newport Beach General Plan 2006 contains the following policies related to public services that
are applicable to the Project:
Land Use Element
Policy LU 2.8 Adequate Infrastructure. Accommodate the types, densities, and mix of land uses that
can be adequately supported by transportation and utility infrastructure (water, sewer,
storm drainage, energy, and so on) and public services (schools, parks, libraries, seniors,
youth, police, fire, and so on).
Snug Harbor Surf Park Project 5.12 Public Services
City of Newport Beach 5.12-3
Draft EIR
May 2025
Policy LU 3.2 Growth and Change. Enhance existing neighborhoods, districts, and corridors, allowing
for re-use and infill with uses that are complementary in type, form, scale, and character.
Changes in use and/or density/intensity should be considered only in those areas that are
economically underperforming, are necessary to accommodate Newport Beach’s share of
projected regional population growth, improve the relationship and reduce commuting
distance between home and jobs, or enhance the values that distinguish Newport Beach
as a special place to live for its residents. The scale of growth and new development shall
be coordinated with the provision of adequate infrastructure and public services, including
standards for acceptable traffic level of service.
Goal LU 6.1 A diversity of governmental service, institutional, educational, cultural, social,
religious, and medical facilities that are available for and enhance the quality of life
for residents and are located and designed to complement Newport Beach’s
neighborhoods.
Policy LU 6.1.1 Adequate Community Supporting Uses. Accommodate schools, government
administrative and operational facilities, fire stations and police facilities, religious
facilities, schools, cultural facilities, museums, interpretative centers, and hospitals to serve
the needs of Newport Beach’s residents and businesses.
Circulation Element
Policy CE 2.2.7 Emergency Access. Provide all residential, commercial, and industrial areas with efficient
and safe access for emergency vehicles. An emergency evacuation map shall be
prepared as part of an updated Safety Element.
City of Newport Beach Municipal Code
Municipal Code Chapter 3.12: Property Development Tax. Chapter 3.12 of the Municipal Code identifies
that the “rapid development of land in the City of Newport Beach has created a need for public
improvements and facilities consisting of fire stations and fire-fighting equipment, public City libraries and
public City parks, which cannot be met by the ordinary revenues of the City. The need for such improvements
results directly from the increase in density in the City by the development of land that has heretofore been
vacant and by construction of additional residential, commercial and industrial units on land heretofore
developed.” Therefore, the City imposes an excise tax upon the construction and occupancy of residential,
commercial and industrial units or buildings in the City. Per Municipal Code Section 3.12.110 (Disposition of
Proceeds – Funds Created), all tax proceeds are to be used for acquiring, building, improving, expanding,
and equipping City fire stations, City libraries, and City parks.
Municipal Code Section 9.04.010 Adoption of the California Fire Code. City Council adopts and
incorporates by reference, those certain codes known as the “California Fire Code 2022 Edition,” and the
whole thereof including the matrix adoption tables for each chapter, and Appendices B, BB, C, CC, E, F, G,
I and N therein, errata issued during and after publishing date, save and except such portions as are
hereinafter deleted, added or amended.
Municipal Code Chapter 11.03 Special Events. Provides regulations allowing for special events while
mitigating impacts on residents, visitors and businesses, maintaining traffic circulation, and ensuring public
safety. The regulations apply to recreation and sporting events.
Snug Harbor Surf Park Project 5.12 Public Services
City of Newport Beach 5.12-4
Draft EIR
May 2025
5.12.3 ENVIRONMENTAL SETTING
5.12.3.1 Fire Services
The Project site would be served by the Newport Beach Fire Department. The Fire Department is divided
into Fire Operations Division, Fire Prevention Division, Emergency Medical Services Division, Lifeguard
Operations Division, and Community Emergency Response Team (CERT). The Fire Department provides
response to fires, medical emergencies, marine safety, hazardous materials incidents, natural and man-made
disasters, automatic and mutual aid assistance to neighboring departments, and related emergencies in an
effort to protect life, property, and the environment. In addition, the Fire Department inspects businesses and
properties, assists with code enforcement, and conducts public education programs.
The Fire Department operates from eight fire stations and three lifeguard headquarters. The closest fire
station is the Santa Ana Heights Fire Station #7 that is located adjacent to the Project site. In addition, one
other station (Fire Station #6) is located within three miles of the Project site. Table 5.12-1 identifies the fire
stations in the City (City of Newport Beach, 2024a).
Table 5.12-1: Fire Stations Locations and Distance from Project Site
Fire Station Location Distance from Site
Balboa Peninsula Fire Station #1 110 E. Balboa Boulevard, Newport Beach, CA 7.4 miles
Lido Fire Station #2 2807 Newport Boulevard, Newport Beach, CA 5.6 miles
Fashion Island Fire Station #3 868 Santa Barbara Drive, Newport Beach, CA 3.7 miles
Balboa Island Fire Station #4 124 Marine Avenue, Newport Beach, CA 5.3 miles
Corona Del Mar Fire Station #5 410 Marigold Avenue, Newport Beach, CA 6.4 miles
Mariners Fire Station #6 1348 Irvine Avenue, Newport Beach, CA 2.9 miles
Santa Ana Heights Fire Station #7 20401 Acacia Street, Newport Beach, CA Adjacent
Newport Coast Fire Station #8 6502 Ridge Park Road, Newport Beach, CA 5.9 miles
Source: City of Newport Beach, 2024a, and Google Maps, 2024
The Fire Department’s daily staffing, per shift, includes: one Battalion Chief, 10 Fire Apparatus Engineers,
10 Fire Captains, 17 Paramedics/Firefighters, and two Firefighters. The Fire Department has eight fire
engines (one at each fire station), two aerial ladder trucks (one on each side of the City), and four paramedic
rescue ambulances (Newport Beach Fire Department, n.d.-a). The City’s 2025 Adopted Budget states that in
fiscal year 2023, the City budgeted for 143.8 full-time fire personnel and 42.56 part-time personnel, which
increased to 151.80 full-time fire personnel and 40.96 part-time personnel in fiscal year 2024 (City of
Newport Beach, 2025).
The City’s 2025 Adopted Budget states that the Fire Department’s performance measure is to have the first
unit on scene in 5 minutes 90 percent of the time, and states that the actual response time was 5 minutes 33
seconds in fiscal year 2022-23 and 5 minutes and 34 seconds in fiscal year 2023-24.
The Fire Department’s 2023 Annual Report details that in 2023 the department responded to a total of
12,417 calls for service from within the City boundaries, and that 75.6 percent of the calls were for medical
services and that 1.09 percent were for fire-related services. In addition, the Fire Department responded to
880 calls from outside the City. Of these, 71.6 percent were medical-related and 10.7 percent were fire-
related calls for services.
Snug Harbor Surf Park Project 5.12 Public Services
City of Newport Beach 5.12-5
Draft EIR
May 2025
Table 5.12-2: Fire Department Calls for Services
Service Type 2022 in City 2022 Outside of City 2023 in City 2023 Outside of City
Fire 231 115 230 94
Medical 9,942 642 9,390 630
Hazardous Materials 118 14 96 14
Other Emergencies 1,642 78 1,715 86
Service 1,098 61 986 53
Regional Emergencies 0 12 0 3
Area Totals 13,031 928 12,417 880
Response Total 13,959 13,297
Source: Newport Beach Fire Department Annual Report 2023 (Newport Beach Fire Department, 2023).
5.12.3.2 Law Enforcement Services
The Newport Beach Police Department is responsible for law enforcement and public safety activities in the
City. The Police Department is located at 870 Santa Barbara Drive, which is 3.7 miles south of the Project
site. According to the City’s Development Impact Fee Nexus Study, the City is currently planning the
development of a new 77,000-square-foot police station in the City (City of Newport Beach, 2025).
The Police Department provides citywide services in crime prevention and investigation, community
awareness programs, and other services such as traffic control. The Police Department is separated into four
divisions: Office of the Chief, Patrol and Traffic, Support Services, and Detectives. The Police Department
has divided the City into patrol areas. The Project site is located in Patrol Area 3, which also includes
Eastbluff, Bonita Canyon, Big Canyon, Newport Center, Harbor Cove, Bayside Village, Island Lagoon, Park
Newport, Promontory Point, and Balboa Island areas of the City.
The City’s 2025 Adopted Budget states that in fiscal year 2023, the City budgeted for 233 full-time Police
Department personnel and 14.87 part-time personnel, which increased to 234 full-time personnel and 13.43
part-time personnel in fiscal year 2024. The Fiscal Year 2025 includes 237 full-time personnel (which is a
three-employee increase from 2024) and 13.43 part-time personnel.
As shown in Table 5.12-3, in fiscal year 2022-23 the Police Department had 101,169 total calls for service
(dispatched and field-initiated), which increased slightly to 101,969 in fiscal year 2023-24. The Police
Department has a goal of responding to Priority 1 calls for service, which include things like violent crimes in
progress, life-threatening circumstances, and urgent disturbances within an average of three minutes, 30
seconds and Priority 2 calls, which are the next most serious and include events such as violent crimes that
have just occurred, property crimes that are in progress or have just occurred, and traffic collisions for service
within six minutes. Table 5.12-3 identifies that the Police Department meets these service targets. In regard
to existing specific services to the Project site, the Police Department has had 7 non-priority calls for service
from the NB Golf Course in both years 2023 and 2024 (Dave Miner, Newport Beach Police Department
Police Chief, personal communication, March 4, 2025).
Snug Harbor Surf Park Project 5.12 Public Services
City of Newport Beach 5.12-6
Draft EIR
May 2025
Table 5.12-3: Police Department Calls for Services and Response Times
Fiscal Year 2022-23 Fiscal Year 2023-24 Target
Percentage of all 911 calls answered within 15
seconds
99.8% 99.8% 95%
Average response time for Priority 1 calls 3:21 3:00 3:30
Average response time for Priority 2 calls 5:40 5:57 6:00
Number of phone calls handled in Dispatch 172,614 169,371 -
Total calls for service (dispatched and field-
initiated)
101,169 101,946 -
Source: City of Newport Beach Adopted Budget 2025
5.12.3.3 School Services
The City of Newport Beach is served by three school districts: Newport-Mesa Unified School District (NMUSD),
Santa Ana Unified School District, and Laguna Beach Unified School District. The Newport-Mesa Unified
School District provides education services to the majority of residents in Newport Beach, Costa Mesa, and
other unincorporated areas of Orange County (City of Newport Beach, 2006b). The Newport-Mesa Unified
School District currently operates 32 public schools, including: 22 elementary schools, two junior high schools,
five high schools, two alternative schools, and one adult school (City of Newport Beach, 2006b). As of the
2023/2024 school year, the NMUSD had a total enrollment of 17,768 students (California Dept. of
Education, 2024). The closest schools to the site are the Back Bay Montessori School, located at 398 University
Drive (approximately 0.26 mile southwest of the Project site), Back Bay Alternative High School, located at
390 Monte Vista Avenue (approximately 0.4 mile southwest of the Project site), and Eastbluff Elementary
School, located at 2627 Vista Del Oro (approximately 1.1 miles south of the Project site).
5.12.3.4 Other Public Facilities
Other governmental services include a variety of public and quasi-public services including libraries, senior
centers, and other facilities. The Newport Beach Public Library System services the City with four public
library branches and three book pick-up and drop-off facilities at local community centers. Table 5.12-4:
Library Facilities shows that library closest to the Project site is the Crean Mariners Library, located
approximately 2.5 miles from the Project site.
Table 5.12-4: Library Facilities
Facility Location Distance from Project Site
Central Library 1000 Avocado Avenue 5.9 miles
Balboa Library 100 East Balboa Boulevard 7.0 miles
Crean Mariners Library 1300 Irvine Avenue 2.5 miles
Corona Del Mar Library 410 Marigold Avenue 5.9 miles
Newport Coast Community Center
Concierge Service only (drop off books, pick up holds,
search the library catalogue)
6401 San Joaquin Hills
Road
6.5 miles
OASIS Senior Center
Concierge Service only (drop off books, pick up holds)
801 Narcissus Avenue 5.8 miles
Marina Park
Concierge Service only (drop off books, pick up holds)
1600 West Balboa
Boulevard
6.1 miles
Source: Newport Beach Public Library, n.d.
Snug Harbor Surf Park Project 5.12 Public Services
City of Newport Beach 5.12-7
Draft EIR
May 2025
5.12.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of the CEQA Guidelines indicates that a Project could have a significant effect if it were to
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:
PS-1 Fire protection services;
PS-2 Police protection services;
PS-3 Schools; or
PS-4 Other public facilities.
Potential impacts to park and recreational facilities are addressed in Section 5.13, Parks and Recreation.
5.12.5 METHODOLOGY
The evaluation of impacts to public services is based on whether the existing public services can meet the
demands of the Project based on established thresholds, including maintaining acceptable service ratios,
staffing levels, adequate equipment, response times, or other performance objectives that may result in the
need for new or expanded services and facilities; the construction of which could result in a significant
environmental impact.
5.12.6 ENVIRONMENTAL IMPACTS
IMPACT PS-1: THE PROJECT WOULD NOT 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
FIRE PROTECTION SERVICES:
Less than Significant Impact. Operation of the Project would result in a net increase of three employees
onsite. The existing restaurant, pro-shop, driving range, and golf uses generate approximately 47
employees and the proposed Project is expected to generate 70 total employees including both full-time
and part-time, with an average of approximately 55 employees onsite at any given time. The addition of
23 total employees from implementation of the proposed Project is not expected to increase employment
and result in an influx of new residents in the City. However, the 20 athlete accommodation units proposed
for the site would result in a limited 24-hour population on the site that could result in the need for fire
protection services. Also, the Project would increase the number of structures on the Project site. Thus, there
would be a potential for the Project to increase the demand for fire protection and emergency medical
services.
The Project site is adjacent to Station 7, which is located at 20401 Acacia Street, at the southeastern border
of the Project site. The Project would incorporate fire safety features. The buildings would be equipped with
fire extinguishers, wet and dry sprinkler systems, pre-action sprinkler systems, fire alarm systems, fire pumps,
backflow devices, and clean agent waterless fire suppression systems pursuant to the California Fire Code
Snug Harbor Surf Park Project 5.12 Public Services
City of Newport Beach 5.12-8
Draft EIR
May 2025
adopted under Chapter 9, Section 04 of the Municipal Code. Adherence to fire code requirements would
be verified during the City’s development review and permitting process and would minimize the demand
upon fire stations, personnel, and equipment.
The surf lagoon would include lifeguard facilities, including a lifeguard tower positioned between the two
basins with visibility over all parts of the lagoon. All areas of the surf lagoon, warming pools, and spa would
be monitored by trained lifeguard professionals who would be trained in how to perform first aid to ensure
proper use and safety, which would avoid medical incidents, reducing potential medical calls to the Fire
Department.
As discussed in Section 3.0, Project Description, the proposed Project is expected to host approximately 12
special events per year that would be ticketed events within the permitted operational capacity of the
facility. The special events would be similar to other sporting competitions, such as golf tournaments, and the
capacity at the surf lagoon would be limited. Overall, it is possible that the Project could result in additional
Fire Department services (particularly medical calls for services); however, any increase in demand would
be incremental and would not result in the need for a new or expanded fire facility. Thus, Project impacts
related to fire services would be less than significant.
Further, the Project would be required to pay Property Development Tax pursuant to Municipal Code
Chapter 3.12.110 or Development Impact Fees pursuant to Resolution No. 2024-83, as applicable. These
fees can be applied to the purchase of equipment, maintenance of existing facilities, and the construction of
facilities as needed. Impacts to fire services would be less than significant.
IMPACT PS-2: THE PROJECT WOULD NOT 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
POLICE PROTECTION SERVICES.
Less than Significant Impact. As discussed previously, operation of the Project is estimated to result in
approximately 35 employees and the 20 athlete accommodation units would result in a limited 24-hour
population onsite. As detailed in Section 3.0, Project Description, the maximum number of participants in the
lagoon at one time would be 72 people, with an average hourly usage of 35-45 people. The wave lagoon
would operate on a reservation basis, and the facility is anticipated to host approximately 12 events per
year. The Project could result in an incremental increase in demands on law enforcement services but would
not be significant when compared to the current Police Department demand levels. It is possible that increases
in demand for police services could result related to vehicle burglaries, damage to vehicles, traffic-related
incidents, and crimes against persons, which are typical in the City and do not represent unique law
enforcement issues specific to the proposed Project. In addition, the proposed Project would address typical
security concerns by providing low-intensity security lighting, security cameras, and 24-hour security
personnel. Pursuant to the City’s existing permitting process, the Police Department would review the site
plans to ensure that the City’s safety features are incorporated.
As discussed in Section 3.0, Project Description, the proposed Project is expected to host approximately 12
special events per year that would be ticketed events within the permitted operational capacity of the
facility. The special events would be similar to other sporting competitions, such as golf tournaments, and
capacity would be limited. In addition, trained security personnel would be employed onsite to minimize
needs for Police Department services.
Snug Harbor Surf Park Project 5.12 Public Services
City of Newport Beach 5.12-9
Draft EIR
May 2025
The Newport Beach Police Department headquarters is located approximately 3.7 miles south of the Project
site in Patrol Area 3. Also, as described previously, the City is planning development of a new 77,000
square foot police station; the exact location is not known at this time. The Project would be required to pay
Property Development Tax pursuant to Municipal Code, Chapter 3.12.110 or Development Impact Fees
pursuant to Resolution No. 2024-83, as applicable. These fees would provide funds towards Police
Department equipment and facilities. As the site would implement security measures and the number of
persons on site at any one time would be limited, the Project would not result in the need for new or expanded
Police Department facilities to support the Project. Therefore, Project impacts to police services would be less
than significant.
IMPACT PS-3: THE PROJECT WOULD NOT 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
SCHOOL SERVICES.
Less than Significant Impact. The Project site is within the NMUSD boundary. As discussed previously, the
Project would result in the development of a surf lagoon with warming pools, spas and seating areas; a
three-story amenity clubhouse; a two-story athlete accommodation building; ancillary storage and
maintenance areas, and associated parking areas. No residential development is planned as a part of this
Project. As such, the Project would not result in a direct demand for new or expanded school services within
the area. As described previously, the proposed Project is not anticipated to generate a new population, as
the number of employees needed to operate the Project would be similar to those currently onsite, as
discussed in Section 7.0, Effects Found Not Significant, and substantial in-migration of employees that could
generate new students is not anticipated to occur.
Additionally, under State law, development projects are required to pay school impact fees in accordance
with Senate Bill 50 (SB 50) at the time of building permit issuance. The funding program established by SB
50 allows school districts to collect fees from new developments to offset the costs associated with increasing
school capacity needs and has been found by the legislature to constitute “full and complete mitigation of
the impacts of any legislative or adjudicative act… on the provision of adequate school facilities”
(Government Code Section 65995[h]). The school impact fees would offset any costs associated with an
increase in school capacity due to the Project. As such, impacts on school services would be less than
significant.
IMPACT PS-4: THE PROJECT WOULD NOT 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
OTHER PUBLIC FACILITIES.
Less than Significant Impact. As discussed above in Section 5.12.3.4, Other Public Facilities, the City is
served by the Newport Beach Public Library System, which consists of four public libraries and three book
pick-up and drop-off locations. The nearest public library to the Project site is Crean Mariners Library,
located approximately 2.5 miles from the Project site. Demand placed on libraries is based on the generation
of a resident population associated with a person’s place of residence, and not typically their place of
employment. As discussed above and in Section 7.0, Effects Found Not Significant, the proposed Project does
not include any residential uses that would directly increase demand for new or expanded public services.
Snug Harbor Surf Park Project 5.12 Public Services
City of Newport Beach 5.12-10
Draft EIR
May 2025
In addition, the Project would generate a net increase of 3 employees compared to the existing uses onsite,
and the employees are expected to come from within the Project region and substantial in-migration of
employees would not occur. As such, the proposed Project would not directly create a demand for public
library facilities or other governmental public facilities, nor would it directly result in the need to modify
existing or construct new public service facilities. Additionally, the proposed Project would adhere to the
requirement to pay a Property Development Tax as outlined in Municipal Code Chapter 3.12.110 or
Development Impact Fees pursuant to Resolution No. 2024-83 as applicable, which provides funding for
new and expanded public facilities, including library facilities. Therefore, the Project would result in a less
than significant impact related to governmental public facilities.
5.12.7 CUMULATIVE IMPACTS
The cumulative setting for public services is areas that are served by the Newport Beach Fire Department,
Newport Beach Police Department, school districts, and library. The Project would not significantly increase
the need for public services in the Project area, in the cities surrounding the Project site, or within the region.
As discussed above, the Project would not generate a substantial number of new employees, and no new
residents would be generated by the Project. Although the Project includes 20 athlete accommodations, this
would result in a limited number of persons onsite that would not result in the need for new or expanded
public facilities. In addition, the Project applicant would pay the required development impact fees. Related
projects in the City would be required to demonstrate their level of impact on public services and also pay
development impact fees. Therefore, the proposed Project would not combine with past, present, and future
projects to result in a cumulative impact related to the provision of public services. Project impacts would be
less than cumulatively considerable.
5.12.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES
The following would reduce potential impacts related to public services.
Existing Regulations
• California Fire Code (CFC; California Code of Regulations, Title 24, Part 9)
• California Government Code Section 65995(b)
• California Government Code Sections 66000 et seq.
• Municipal Code Chapter 3.12: Property Development Tax
• Municipal Code Section 9.04.010, Adoption of the California Fire Code
• Municipal Code Chapter 11.03, Special Events
Plans, Programs, or Policies
None.
5.12.9 PROJECT DESIGN FEATURES
None.
5.12.10 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Impacts PS-1, PS-2, PS-3, and PS-4 would be less than significant.
Snug Harbor Surf Park Project 5.12 Public Services
City of Newport Beach 5.12-11
Draft EIR
May 2025
5.12.11 MITIGATION MEASURES
No mitigation measures are required.
5.12.12 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts would be less than significant.
5.12.13 REFERENCES
California Dept. of Education. (2024). District Profile: Newport-Mesa Unified. Retrieved January 20, 2024
from: https://www.cde.ca.gov/sdprofile/details.aspx?cds=30665970000000
City of Newport Beach. (2025). City of Newport Beach Adopted Fiscal Year 2025 Budget. Retrieved
January 20, 2024:
https://ecms.newportbeachca.gov/WEB/DocView.aspx?id=3063617&dbid=0&repo=CNB&cr=1
City of Newport Beach. (2023). City of Newport Beach Fire Department Annual Report.
https://www.newportbeachca.gov/home/showpublisheddocument/75712/638676838862600000
City of Newport Beach. (2001). Santa Ana Heights Specific Plan. Retrieved September 23, 2024, from
ocpublicworks.com.
City of Newport Beach. (2006a). General Plan. Retrieved September 23, 2024, from
newportbeachca.gov: https://www.newportbeachca.gov/government/departments/community-
development/planning-division/general-plan-codes-and-regulations/general-plan
City of Newport Beach. (2006b). General Plan Environmental Impact Report. Retrieved September 23,
2024, from https://www.newportbeachca.gov/government/departments/community-
development/planning-division/general-plan-codes-and-regulations/general-plan/general-plan-
environmental-impact-repor
City of Newport Beach. (2024a). Fire Department. Retrieved October 7, 2024, from newportbeachca.gov:
https://www.newportbeachca.gov/government/departments/fire-department
City of Newport Beach. (2024b). Newport Beach Municipal Code. Retrieved September 23, 2024, from
codepublishing.com: https://www.codepublishing.com/CA/NewportBeach/
Newport Beach Fire Department. (2023). Annual Report 2023.
https://www.newportbeachca.gov/home/showpublisheddocument/75712/638676838862600000
Newport Beach Fire Department. (n.d.-a). Fact Sheet. Retrieved October 7, 2024, from
https://www.newportbeachca.gov/home/showpublisheddocument/61911/636734647708530000
Newport Beach Police Department. (n.d.-b). Response Times. Retrieved October 7, 2024, from NBPD.org:
https://www.nbpd.org/what-we-do/information/response-times
Newport Beach Public Library. (n.d.). Hours and Locations. Retrieved November 21, 2024:
https://www.newportbeachlibrary.org/about/hours-and-locations
Snug Harbor Surf Park Project 5.12 Public Services
City of Newport Beach 5.12-12
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 5.13 Parks and Recreation
City of Newport Beach 5.13-1
Draft EIR
May 2025
5.13 Parks and Recreation
5.13.1 INTRODUCTION
Pursuant to the requirements of CEQA, this section of the EIR analyzes whether the proposed Project would
result in adverse impacts related to the provision of parks, require development of new parks and recreation
facilities, increase the use of existing parks and recreational facilities such that substantial physical
deterioration or degradation of the facilities would occur or be accelerated or that new or expanded
facilities would be required, result in substantial adverse construction-related effects associated with the
provision of new or physically altered parks and recreational facilities, whether on site or offsite; and/or
adversely affect existing recreational facilities. The analysis in this section is based, in part, on the following
documents and resources.
• City of Newport Beach General Plan, 2006
• City of Newport Beach General Plan Environmental Impact Report (General Plan EIR), 2006
• City of Newport Beach Municipal Code
Because CEQA focuses on physical environmental effects, this section analyzes whether any physical changes
resulting from an increase in demands for park and recreation facilities from the proposed Project could
result in significant adverse environmental effects. Thus, an increase in use of parks and recreation facilities
would not, by itself, be considered a physical change in the environment. However, physical changes in the
environment resulting from the construction of new facilities or an expansion of existing facilities to
accommodate the increased staff or equipment needs related to substantial physical deterioration could
constitute a significant impact.
5.13.2 REGULATORY SETTING
5.13.2.1 Federal Regulations
No federal laws, regulations, or executive orders apply to the Project.
5.13.2.2 State Regulations
Mitigation Fee Act
The California Mitigation Fee Act, Government Code Sections 66000, et seq., allows cities to establish fees
to be imposed upon development projects for the purpose of mitigating the impact that the development
projects have upon the city’s ability to provide specified public facilities. In order to comply with the
Mitigation Fee Act, the city must follow four primary requirements:
1. Make certain determinations regarding the purpose and use of a fee and establish a nexus or connection
between a development project or class of project and the public improvement being financed with the
fee;
2. Segregate fee revenue from the General Fund in order to avoid commingling of capital facilities fees
and general funds.
3. For fees that have been in the possession of the city for five years or more and for which the dollars
have not been spent or committed to a project the city must make findings each fiscal year describing
the continuing need for the money; and
Snug Harbor Surf Park Project 5.13 Parks and Recreation
City of Newport Beach 5.13-2
Draft EIR
May 2025
4. Refund any fees with interest for developer deposits for which the findings noted above cannot be made.
5.13.2.3 Local and Regional Regulations
City of Newport Beach General Plan 2006
The City of Newport Beach General Plan 2006 contains the following policies related to recreation that are
applicable to the Project:
Land Use Element
Policy LU 2.1 Resident-Serving Land Uses. Accommodate uses that support the needs of Newport Beach’s
residents including housing, retail, services, employment, recreation, education, culture,
entertainment, civic engagement, and social and spiritual activity that are in balance with
community natural resources and open spaces.
Policy LU 2.5 Visitor Serving Uses. Provide uses that serve visitors to Newport Beach’s ocean, harbor,
open spaces, and other recreational assets, while integrating them to protect neighborhoods
and residents.
Recreation Element
Goal R 1 Provision of Facilities—Provision of adequate park and recreation facilities that meet
the recreational needs of existing and new residents of the community.
Policy R 1.1 Provision of Parkland. Require future development to dedicate land or pay in-lieu fees at
a minimum of 5 acres of parkland per 1,000 persons.
Policy R 3.1 Adequate Access Ensure that parks and recreation facilities include provisions for adequate
access for persons with disabilities and that existing facilities are appropriately 4.12-22
Chapter 4 Environmental Analysis City of Newport Beach General Plan Update EIR
retrofitted to include such access as required by the Americans with Disabilities Act.
Policy R 4.1 Provision of Recreation Services. Provide high quality recreational services through
professionally-trained recreational personnel to program participants.
Policy R 4.2 Compatible Recreation Activities. Provide a variety of compatible recreational activities
within a given location.
Policy R 4.5 Variety of Adult Recreational Programs. Provide a variety of quality enrichment and
recreational programs for the adult population that promote health and wellness;
development and/or enhancement of skills and talents; extend learning opportunities;
promote sportsmanship; and provide unique opportunities to engage in new activities.
Policy R 6.3 Recreational Commercial Uses. Allow recreational commercial uses in commercial areas
adjacent to beaches and the bay.
City of Newport Beach Municipal Code
Municipal Code Chapter 3.12: Property Development Tax. Chapter 3.12 of the Municipal Code identifies
that the “rapid development of land in the City of Newport Beach has created a need for public
improvements and facilities consisting of fire stations and fire-fighting equipment, public City libraries and
public City parks, which cannot be met by the ordinary revenues of the City. The need for such improvements
Snug Harbor Surf Park Project 5.13 Parks and Recreation
City of Newport Beach 5.13-3
Draft EIR
May 2025
results directly from the increase in density in the City by the development of land that has heretofore been
vacant and by construction of additional residential, commercial and industrial units on land heretofore
developed.” Therefore, the City imposes an excise tax upon the construction and occupancy of residential,
commercial and industrial units or buildings in the City. Per Municipal Code Section 3.12.110 (Disposition of
Proceeds – Funds Created), all tax proceeds are to be used for acquiring, building, improving, expanding,
and equipping City fire stations, City libraries, and City parks.
Municipal Code Chapter 11.03 Special Events. Provides regulations allowing for special events while
mitigating impacts on residents, visitors and businesses, maintaining traffic circulation, and ensuring public
safety. The regulations apply to recreation and sporting events.
5.13.3 ENVIRONMENTAL SETTING
5.13.3.1 Onsite Recreation
There are no existing public parks within the Project Site. The Project site consists of a portion of the Newport
Beach (NB) Golf Course, which is a commercial recreation executive golf course. The NB Golf Course is not
a municipal course owned by the City, it is privately owned and open to the public for commercial use. The
Project site includes three holes of the existing NB Golf Course (holes 1, 2, and 9), a 38-bay partially
covered synthetic turf driving range, a 1,050-square-foot (SF) putting green, a 8,975 SF building that
includes a pro shop and a restaurant, and a surface parking lot with 280 parking spaces. The existing hours
of operation for the driving range and golf course are 6:30 a.m. to 9:00 p.m. from December to February
and 6:00 a.m. to 9:00 p.m. from March to November. The driving range and golf course lighting is limited
to between the hours of 7:00 a.m. and 10:00 p.m.
The Project site is adjacent to the two other portions of the NB Golf Course; including: the 21.28-acre northern
portion located northeast of the Project site across Irvine Avenue that contains nine holes of golf (holes 10-
18), and the 14.51-acre southern portion to the south of the Project site across Mesa Drive that contains six
holes of golf (holes 3-8). An existing golf cart path runs along the western portion of the project site, along
the Santa Ana-Delhi Channel, and connects the three portions of the golf course, via a tunnel under Irvine
Avenue to the north, and across Mesa Drive to the south.
5.13.3.2 City Public Park and Recreation Facilities
The City has approximately 286 acres of passive and active parks as well as 90 acres of active beach
recreation. This total is exclusive of approximately 304 acres of undeveloped parkland associated with
Upper Buck Gully and Castaways Park (approximately 16.77 acres) (Newport Beach, n.d.-a). The closest
existing public park and recreation facilities to the Project site (within 2 miles) in the City of Newport Beach
are listed in Table 5.13-1. As shown, the City currently has five parks that provide 149.98 acres of parkland
within 2 miles of the Project site. Two parks, Mesa Birch Park and Upper Newport Bay Regional Park, are
within a 15-minute walking distance.
Snug Harbor Surf Park Project 5.13 Parks and Recreation
City of Newport Beach 5.13-4
Draft EIR
May 2025
Table 5.13-1: Newport Beach Park and Recreation Facilities Within Two Miles of the Project Site
Park and Address Amenities Acreage Distance from
Project Site
Travel Time from
Project Site1
Mesa Birch Park
2081 Mesa Drive
Benches, Picnic Tables,
Water Fountian
0.73 0.25 mile Driving: 1 minute
Walking: 5 minutes
Bayview Park
Mesa Drive and Bay
View Avenue
Barbeques, Basketball
Court, Playground, Bay
View
2.20 0.70 mile Driving: 5 minutes
Walking: 17 minutes
Upper Newport Bay
Regional Park
Irvine Avenue and
University Drive
Parking Lot, Bay View,
Walking Paths
135 0.60 mile Driving: 3 minutes
Walking: 11 minutes
Uptown Park
4201 Uptown Newport
Drive
Barbeque, Picnic
Table, Playground,
Restrooms
1.03 1.7 miles Driving: 6 minutes
Walking: 45 minutes
Bonita Creek Park &
Community Center
3010 La Vida
Athletic Field,
Baseball/Softball
Diamonds, Basketball
Court, Community
Room, Picnic Tables,
Playground, Restrooms
11.02 1.8 miles Driving: 5 minutes
Walking: 38 minutes
Total Acreage of Parkland 149.98
Source: City of Newport Beach, n.d.-a
1Per Google Maps
5.13.3.3 Golf Recreation
The NB Golf Course is an 18-hole executive golf course with 3,216 yards of golf from the longest tees for
a par of 59. Executive golf courses, sometimes also referred to as par-3 or beginner courses, are shorter
courses designed for beginners, high handicappers, and people who are short on time. These courses feature
more par-3 holes than a full-length course but may also mix in some par-4 and 5 holes. They may be 9 holes
or 18 holes and can usually be played in less than two hours (GolfLink, 2023).
There are three public golf courses in Newport Beach and 10 public courses within 10 miles of the Project
site (GolfLink, 1996–2024). All courses are privately owned as there is no municipal course within the City
of Newport Beach. Public courses refer to commercial courses that are available for anyone to pay to use
and do not require membership.
Nearby public golf courses that have driving ranges include the Rancho San Joaquin Golf Course located
on Ethel Coplen Way in Irvine that has a 64 station lighted driving range, Newport Back Bay Golf Course
on Jamboree Road in Newport Beach, Costa Mesa Country Club located on Golf Course Drive in Costa Mesa
which has two 18 hole golf courses and a driving range, and the Tustin Ranch Golf Club on Tustin Ranch
Road in Tustin. Table 5.13-2 shows the existing golf courses within 10 miles of the Project site and their
amenities. Table 5.13-3 shows all of the public driving ranges within 10 miles of the Project site.
Snug Harbor Surf Park Project 5.13 Parks and Recreation
City of Newport Beach 5.13-5
Draft EIR
May 2025
Table 5.13-2: Public Golf Course Facilities Within Ten Miles of the Project Site
Course Amenities Price for 18
Holes of Golf
Distance from
Project Site
Travel Time from
Project Site1
Newport Beach Golf
Course
3100 Irvine Ave,
Newport Beach
18-hole executive golf
course with driving
range, pro shop, and
practice area
$32 - -
Hyatt Regency Newport
Back Bay Golf Course
1107 Jamboree Rd,
Newport Beach
9-hole executive golf
course $321 4.2 miles 11 minutes
Pelican Hill Golf Club
22800 S Pelican Hill
Rd, Newport Coast
Two 18-hole golf
courses with a driving
range and pro shop
$415 7.9 miles 12 minutes
Costa Mesa Country
Club
1701 Golf Course Dr,
Costa Mesa
Two 18-hole golf
courses with a driving
range, pro shop, and
practice area
$82 4.1 miles 12 minutes
Rancho San Juaquin
Golf Course
1 Ethel Coplen Way,
Irvine
18-hole golf course with
a driving range, pro
shop, and practice area
$82 4.6 miles 12 minutes
Strawberry Farms Golf
Club
11 Strawberry Farm
Rd, Irvine
18-hole golf course with
a driving range, pro
shop, and practice area
$185 6.6 miles 16 minutes
Oak Creek Golf Club
1 Golf Club Dr, Irvine
18-hole golf course with
a driving range, pro
shop, and practice area
$210 6.1 miles 18 minutes
Mile Square Golf
Course
10401 Warner Ave,
Fountain Valley
Two 18-hole golf
courses with a driving
range, pro shop, and
practice area
$87 5.15 miles 14 minutes
David L. Baker Golf
Course
10410 Edinger Ave,
Fountain Valley
18-hole executive golf
course with driving
range and practice
area
$48 5.5 miles 16 minutes
Willowick Golf Course
3017 W 5th St, Santa
Ana
18-hole golf course with
a driving range, pro
shop, and practice area
$43 8.6 miles 19 minutes
River View Golf Course
1800 W Santa Clara
Ave, Santa Ana
18-hole golf course with
a driving range, pro
shop, and putting course
$53 9.2 miles 24 minutes
Meadowlark Golf
Course
16782 Graham St,
Huntington Beach
18-hole golf course with
a driving range, pro
shop, and practice area
$68 9.5 miles 21 minutes
Source: (GolfLink, 1994-2016) and (Google Earth, 2024)
1Price for 9 holes
Snug Harbor Surf Park Project 5.13 Parks and Recreation
City of Newport Beach 5.13-6
Draft EIR
May 2025
Table 5.13-3: Public Driving Ranges Within Ten Miles of the Project Site
Course Driving Range Stations Price for a Large
Bucket of Golf Balls
Distance from
Project Site
Travel Time from
Project Site1
Newport Beach Golf
Course
3100 Irvine Ave,
Newport Beach
38 matted stations with
nighttime lighting $15 - -
Pelican Hill Golf Club
22800 S Pelican Hill
Rd, Newport Coast
24 grass stations - 7.9 miles 12 minutes
Costa Mesa Country
Club
1701 Golf Course Dr,
Costa Mesa
30 matted and 15
grass stations with
nighttime lighting
$17 4.1 miles 12 minutes
Rancho San Juaquin
Golf Course
1 Ethel Coplen Way,
Irvine
64 matted stations with
nighttime lighting $20 4.6 miles 12 minutes
Strawberry Farms Golf
Club
11 Strawberry Farm
Rd, Irvine
24 matted stations $20 6.6 miles 16 minutes
Oak Creek Golf Club
1 Golf Club Dr, Irvine
52 grass stations with
nighttime lighting $24 6.1 miles 18 minutes
Mile Square Golf
Course
10401 Warner Ave,
Fountain Valley
40 matted stations with
nighttime lighting $16 5.15 miles 14 minutes
David L. Baker Golf
Course
10410 Edinger Ave,
Fountain Valley
32 matted stations with
nighttime lighting $12 5.5 miles 16 minutes
Willowick Golf Course
3017 W 5th St, Santa
Ana
14 grass stations with
nighttime lighting $12 8.6 miles 19 minutes
River View Golf Course
1800 W Santa Clara
Ave, Santa Ana
24 matted stations with
nighttime lighting $13 9.2 miles 24 minutes
Meadowlark Golf
Course
16782 Graham St,
Huntington Beach
30 matted stations with
nighttime lighting $14 9.5 miles 21 minutes
Source: (GolfLink, 1994-2016) and (Google Earth, 2024)
Snug Harbor Surf Park Project 5.13 Parks and Recreation
City of Newport Beach 5.13-7
Draft EIR
May 2025
5.13.3.4 Public Beaches
In addition to these park facilities, the City has and partially operates approximately eight miles of beaches
that extend from the Santa Ana River jetty to Crystal Cove State Park and border Newport Bay. City
beaches provide a wide range of recreational activities and amenities, which include but are not limited to
surfing, swimming, beach volleyball, fire rings for barbeques, beach trails for walking, running, and bicycling,
and other beach activities (City of Newport Beach, 2024c). There are three State beaches in the City: Crystal
Cove State Park – Moro Beach, Crystal Cove State Park – Little Treasure Cove, and Corona del Mar State
Beach.
5.13.3.5 Walking and Bike Trails
The City has over 18 miles of pedestrian and bicycle trails throughout the City that have been developed
for commuting and recreation. The longest trail is Upper Bay Trail, which is located around the northern edge
of the Upper Newport Bay Nature Preserve and connects to University Drive that leads to Irvine Avenue and
then the Project site.
5.13.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of the CEQA Guidelines indicates that a Project could have a significant effect if it were to:
REC-1 Result in a substantial adverse physical impact associated with the provision of new or physically
altered park/recreation facilities, need for new or physically altered park/recreation facilities,
the construction of which could cause significant environmental impacts, in order to maintain
acceptable service ratios, response times, or other performance objectives for park and recreation
services.
REC-2 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.
REC-3 Include recreational facilities or require the construction or expansion of recreational facilities
which might have an adverse physical effect on the environment.
5.13.5 METHODOLOGY
The analysis below considers the increase in use of parks and recreation facilities that would be generated
by the proposed Project in relation to the ability of existing public park and recreation facilities to
accommodate the increased use. The analysis considers whether an increase in use would result in the
substantial physical deterioration of existing recreational facilities, such as accelerated wear on sports
facilities and fields, or in the need for new or expanded facilities.
The EIR evaluates the recreational uses that would be provided by the proposed Project and the extent of
increased usage of existing City parks and recreational facilities that might result in the substantial physical
deterioration of existing recreational facilities. In addition, the analysis of construction impacts associated
with the development of proposed recreational facilities are considered as part of the overall Project.
Snug Harbor Surf Park Project 5.13 Parks and Recreation
City of Newport Beach 5.13-8
Draft EIR
May 2025
5.13.6 ENVIRONMENTAL IMPACTS
IMPACT REC-1: THE PROJECT WOULD NOT RESULT IN SUBSTANTIAL ADVERSE PHYSICAL IMPACTS
ASSOCIATED WITH THE PROVISION OF NEW OR PHYSICALLY ALTERED PARK AND
RECREATION FACILITIES, NEED FOR NEW OR PHYSICALLY ALTERED PARK OR
RECREATION FACILITIES, THE CONSTRUCTION OF WHICH COULD CAUSE
SIGNIFICANT ENVIRONMENTAL IMPACTS, IN ORDER TO MAINTAIN ACCEPTABLE
PARK AND RECREATION SERVICE RATIOS.
Less than Significant Impact. Typically, residential development increases the need for new parks and
increases the use of existing citywide park and recreation facilities. The proposed commercial recreational
development would not involve new housing opportunities and would not involve the addition of residents
that would use existing park and recreational facilities. While the Athlete Accommodation building would
provide 20 units for visitors, these units would be for athletes and their guests who are there to use the surf
park for recreational activity and not the surrounding neighborhood or regional parks. In addition, the 20
Athlete Accommodation units would have limited capacity, and the Project would not generate a substantial
number of visitors that would require additional park and recreational facilities.
The closest parks to the Project site include Mesa Birch Park, a 0.73-acre park located 0.25 mile from the
site at 2081 Mesa Drive; Bayview Park, a 2.20-acre park located 0.70 mile from the site at Mesa Drive
and Bay View Avenue; and Upper Newport Bay Regional Park, a 135-acre park located 0.60 mile from
the site and accessible from the site via trail. Should visitors to the Project use these existing park and
recreation facilities, the use would be limited in comparison to the size and existing use of these facilities.
Also, as discussed in Chapter 7.0, Effects Found Not Significant, implementation of the proposed Project
would not increase employment in a manner that could result in an influx of new residents in the City. The
Project site currently provides 47 full and part-time jobs. The proposed Project would employ approximately
70 full-time and part-time employees with an average of approximately 55 employees onsite at any given
time. The increase of 23 total employees from implementation of the proposed Project would not result in an
substantial increase in the number of residents that would use City park and recreation facilities.
Although the Project employees may occasionally use local parks, such an increase in use would be limited
and would not result in deterioration of the facilities such that the construction or expansion of recreational
facilities would be necessary. As detailed previously, the three existing parks within 0.6-mile of the Project
site (Mesa Birch Park, Bayview Park, and Upper Newport Bay Regional Park) provide approximately
137.93 of park and recreation facilities. Any additional use of City park and recreation facilities by Project
site employees would be less than significant.
As described in Section 3.0, Project Description, the proposed Project would remove three holes from the golf
course and remove the driving range from the golf recreation activities on the site. Changing the NB Golf
Course from an 18-hole course to a 15-hole course would reduce the number of holes to play in the executive
golf course. However, the proposed Project would support the 15-hole golf course by providing parking and
a check-in station on the site, and by providing golf cart storage within the basement level of the proposed
clubhouse building. Golf cart maintenance and landscaping facilities are currently located on the northern
golf course parcel near holes 10-18 and would therefore not be affected by the proposed Project. Thus,
although reduced, golf recreation would continue to be provided to the north and south of the site and
supported on the site.
In addition, as detailed in Table 5.13-2, there are 11 other publicly available golf courses within 10 miles
of the Project site that provide a range of golfing activities at a range of costs, some of which are similar to
those of the NB Golf Course. Likewise, Table 5.13-3 details that there are nine other public driving ranges
within 10 miles of the Project site, and the cost of the other driving ranges are similar to the cost of the
Snug Harbor Surf Park Project 5.13 Parks and Recreation
City of Newport Beach 5.13-9
Draft EIR
May 2025
driving range on the Project site. Because the 15-hole executive golf course would be supported by the
proposed Project, and due to the number of other golf courses and driving ranges within the vicinity of the
site, the proposed Project would not result in the need for new or physically altered golf facilities.
The physical impacts associated with provision of the proposed commercial recreational surf lagoon facility
are detailed within this EIR. For example, impacts related to air quality, geology, greenhouse gases, and
noise, are detailed within the previous respective sections of this document. No further or additional
environmental impacts from implementation of the surf lagoon recreation would occur other than those
detailed herein.
Instead of requiring additional recreation facilities, the proposed Project would provide a new commercial
recreational facility that would complement both the commercial golf recreation to the north and south of
the site, and the City’s nearby park and recreation areas. As detailed previously, the Upper Bay Trail is
located around the northern edge of the Upper Newport Bay Nature Preserve and connects to University
Drive that leads to Irvine Avenue and then the Project site; thus, connecting a variety of park and recreational
uses within the City. Overall, the Project would not result in the need for new or physically altered public
park or recreation facilities and Project impacts related to park and recreation service ratios would be less
than significant.
IMPACT REC-2: THE PROJECT WOULD NOT 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 discussed in Chapter 7.0, Effects Found Not Significant, the Project does not
propose any residences and would not cause an increase in the residential population. The Project also would
not generate a substantial increase in employees that could result in an increase in use of existing park and
recreational facilities. As detailed in Section 3.0, Project Description, the Project site currently provides 47
full and part-time jobs, and the proposed Project would result in 70 full and part-time jobs with an average
of approximately 55 employees onsite at any given time. The increase of 23 total employees would not
result in substantial increase in residents or employees that would cause an increase in demand for existing
parks or other recreational facilities, and the Project would not cause nor accelerate physical deterioration
of existing park or recreational facilities.
Implementation of the proposed Project would result in a smaller NB Golf Course (3-hole reduction) without
a driving range. Holes 2 through 8 and 10 through 18 would remain operational through the construction
and operation of the proposed Project. Golf course parking during construction would be provided on the
site, along with a temporary restroom and check-in station that would be located near the existing Project
site driveway along Irvine Avenue. Golf cart maintenance and landscaping facilities are currently located
on the northern golf course parcel near holes 10-18 and would therefore not be affected by the proposed
Project.
The course would be revised to the new 15-hole format, with holes 1 through 9 located in the northern parcel
and holes 10 through 15 on the southern parcel. Golfers would continue to utilize the existing golf cart path
and tunnel that takes golfers under Irvine Avenue to a joint-use path located along the south side of the
Santa-Ana-Delhi Flood channel to provide golfers circulation between both parcels.
Once the Project is operational, a permanent golf check-in station would be located adjacent to the Amenity
Clubhouse to the northwest for golfers to get their carts. The basement golf cart storage area would include
a ramp on the western side of the building that leads to the golf check-in area and into the parking lot and
the cart path on the northern end of the site.
With the change to the Golf Course and removal of the driving range, it is likely that existing users of the
driving range and golf course would use other nearby golf facilities that would incrementally increase their
Snug Harbor Surf Park Project 5.13 Parks and Recreation
City of Newport Beach 5.13-10
Draft EIR
May 2025
usage. However, Tables 5.13-2 and 5.13-3 details that there are 11 other publicly available golf courses
and nine other public driving ranges within 10 miles of the Project site that provide a range of golfing
activities, and the incrementally increased usage would be spread amongst the other existing golf facilities.
These are commercial recreational facilities that users pay to use. The increase in fees from the increased
usage would provide funding for increased maintenance to offset the increase in use. Thus, substantial
physical deterioration of other nearby golf course and driving range facilities would not occur.
The proposed Project would provide a different type of commercial recreational facility in place of the
existing driving range and three holes of golf on the site. The proposed surf lagoon and related recreational
services would provide a new use to complement the site proximity to the ocean and the local surf culture.
The provision of onsite surf-related recreation would not result in a substantial increase in the use of other
recreational facilities. While the Athlete Accommodation building would provide 20 units for traveling
athletes and visitors, visitors staying at the surf park would be there to use the surf park for recreational
activity and not the surrounding neighborhood or regional parks. Any increase in use of the three existing
parks within 0.6-mile of the Project site (Mesa Birch Park, Bayview Park, and Upper Newport Bay Regional
Park) that total approximately 137.93 acres, by site visitors or employees would be limited and less than
significant. Thus, impacts related to an increase in the use of existing neighborhood and regional parks
resulting in physical deterioration would be less than significant.
IMPACT REC-3: THE PROJECT WOULD NOT 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. As discussed above and in Chapter 7.0, Effects Found Not Significant,
development of the proposed Project is not expected to result in an increase in residents or employment that
would necessitate the need for the expansion of park and recreation facilities. The Project proposes to
redevelop a portion of a golf course with a new commercial recreational surf park use. In addition, the
remaining 15-hole NB Golf Course would remain operational through the construction and operation of the
proposed Project. As stated above, visitors staying at or just visiting the surf park would be athletes there to
use the surf park for recreational activity and not the surrounding neighborhood or regional parks. Any use
of nearby park and recreation facilities by Project site visitors or employees would be limited and minimal
in comparison to the existing park and recreation areas within 0.6-mile from the site (as detailed in Impact
REC-1). Therefore, the Project would not require the construction or expansion of other recreational facilities.
The construction activities related to the proposed commercial recreational facilities are included as part of
the Project and would not result in any physical environmental effects beyond those identified throughout
this Draft EIR. Emissions due to the construction of the surf park facility are included in Sections 5.2, Air
Quality, and 5.7, Greenhouse Gas Emissions. Noise from construction is evaluated in Section 5.11, Noise, and
vehicular trips from construction of the Project are analyzed in Section 5.14, Transportation. Therefore, Project
impacts related to the construction or expansion of recreational facilities would be less than significant.
5.13.7 CUMULATIVE IMPACTS
The geographic scope for the park and recreation cumulative impact analysis is the greater Newport Beach
area where residents, visitors, and employees utilize local recreation facilities. Past, present, and reasonably
foreseeable future projects located in the vicinity of the proposed Project, such as those listed in Table 5-1,
Cumulative Projects List, in Section 5.0, Environmental Impact Analysis, may generate an increase in residents
and employees that may use recreation facilities. However, as detailed above, the proposed Project would
not generate any new residents or a substantial increase in employees that would generate the need for
parks and recreation that has the potential to cumulatively combine. The Project proposes a different type
of commercial recreational use and would not increase the use of existing recreational facilities in a manner
Snug Harbor Surf Park Project 5.13 Parks and Recreation
City of Newport Beach 5.13-11
Draft EIR
May 2025
that would cumulatively combine such that physical deterioration would occur. Therefore, cumulative impacts
related to increased needs for park and recreational facilities would be less than significant.
5.13.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES
The following would reduce potential impacts related to parks and recreation.
Existing Regulations
• California Government Code Sections 66000 et seq.
• Municipal Code Chapter 3.12: Property Development Tax
• Municipal Code Chapter 11.03, Special Events
Plans, Programs, or Policies
None.
5.13.9 PROJECT DESIGN FEATURES
None.
5.13.10 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Impacts REC-1 through REC-3 would be less than significant.
5.13.11 MITIGATION MEASURES
No mitigation measures are required.
5.13.12 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts would be less than significant.
5.13.13 REFERENCES
City of Newport Beach. (2001). Santa Ana Heights Specific Plan. Retrieved September 23, 2024, from
ocpublicworks.com.
City of Newport Beach. (2006a). General Plan. Retrieved September 23, 2024, from
newportbeachca.gov: https://www.newportbeachca.gov/government/departments/community-
development/planning-division/general-plan-codes-and-regulations/general-plan
City of Newport Beach. (2006b). General Plan Environmental Impact Report. Retrieved September 23,
2024, from newportbeachca.gov:
https://www.newportbeachca.gov/government/departments/community-development/planning-
division/general-plan-codes-and-regulations/general-plan/general-plan-environmental-impact-
repor
Snug Harbor Surf Park Project 5.13 Parks and Recreation
City of Newport Beach 5.13-12
Draft EIR
May 2025
City of Newport Beach. (2024a). Newport Beach Municipal Code. Retrieved September 23, 2024, from
codepublishing.com: https://www.codepublishing.com/CA/NewportBeach/
City of Newport Beach. (2024b). General Plan Housing Implementation Program Draft Program
Environmental Impact Report. Retrieved November 14, 2024 from:
https://files.ceqanet.opr.ca.gov/289030-2/attachment/7GBIM1v2XgT2VoJ3u-
IxpcilSReM0ng2Y7YhGBnzvQwIDgDqE7JKFKtbTjXX3fSUirHZ_R4CBBnnEdCk0
City of Newport Beach. (2024c). Beach Information. Retrieved November 14, 2024, from:
https://www.newportbeachca.gov/how-do-i-/find/beach-information
City of Newport Beach. (n.d.-a). Parks and Facilities. Retrieved October 8, 2024, from:
https://nbgis.newportbeachca.gov/gispub/Dashboards/RecreationFacilitiesDash.htm
City of Newport Beach. (n.d.-b). Upper Bay Trail [map]. Retrieved November 14, 2024, from:
https://nbgis.newportbeachca.gov/gispub/recreation/walkingtrails/images/Upper%20Bay%20T
rail.pdf
GolfLink. (1996-2024). Newport Beach, California, Golf Courses and Tee Times. Retrieved October 2024
from: https://www.golflink.com/golf-courses/ca/newport-
beach#:~:text=Newport%20Beach%2C%20California%20Golf%20Courses,municipal%2C%20a
nd%2023%20private%20courses.
GolfLink. (2023). What is an Executive Course? Retrieved November 2024 from:
https://www.golflink.com/lifestyle/what-is-an-executivecourse.
Snug Harbor Surf Park Project 5.14 Transportation
City of Newport Beach 5.14-1
Draft EIR
May 2025
5.14 Transportation
5.14.1 INTRODUCTION
This section addresses potential transportation impacts that may result from implementation of the proposed
Project. The following discussion addresses the existing transportation conditions in the Project area, identifies
applicable regulations, evaluates the proposed Project’s consistency with applicable goals and policies,
identifies and analyzes environmental impacts, and, if necessary, recommends measures to reduce or avoid
adverse impacts anticipated from implementation of the proposed Project. This analysis has been prepared
in accordance with CEQA requirements to evaluate potential transportation impacts based on vehicle miles
traveled (VMT). Information within this section is based on the following:
•City of Newport Beach General Plan, 2006
•City of Newport Beach General Plan Environmental Impact Report (General Plan EIR), 2006
•City of Newport Beach General Plan Circulation Element, 2022;
•City of Newport Beach Municipal Code
•Trip Generation Assessment for Surf Farm, Newport Beach, California, Gibson Transportation Consulting,
Inc., March 2025, included as Appendix R
5.14.2 REGULATORY SETTING
5.14.2.1 State Regulations
Senate Bill 743 (Steinberg, 2013)
On September 27, 2013, Senate Bill (SB) 743 was signed into State law. The California legislature found
that with the adoption of the Sustainable Communities and Climate Protection Act of 2008 (SB 375), the
State had signaled its commitment to encourage land use and transportation planning decisions and
investments that reduce vehicle miles traveled (VMT) and thereby contribute to the reduction of greenhouse
gas (GHG) emissions, as required by the California Global Warming Solutions Act of 2006 (Assembly Bill
32).
SB 743 required the California Governor’s Office of Planning and Research to amend the CEQA Guidelines
to provide an alternative to level of service (LOS) as the metric for evaluating transportation impacts under
CEQA. Particularly within areas served by transit, SB 743 requires the alternative criteria to promote the
reduction of greenhouse gas emissions, development of multimodal transportation networks, and diversity of
land uses. The alternative metric for transportation impacts detailed in the CEQA Guidelines is VMT.
Jurisdictions had until July 1, 2020, to adopt and begin implementing VMT thresholds for traffic analysis.
AB 1358: California Complete Streets Act
The California Complete Streets Act was implemented on January 1, 2011, which required circulation
elements to address the transportation system from a multimodal perspective. The bill states that streets,
roads, and highways must “meet the needs of all users… in a manner suitable to the rural, suburban, or
urban context of the general plan.” This bill requires a circulation element to plan for all modes of
transportation where appropriate—including walking, biking, car travel, and transit. The Complete Streets
Act also requires circulation elements to consider the multiple users of the transportation system, including
children, adults, seniors, and the disabled. The proposed Project would implement the City’s complete streets
Snug Harbor Surf Park Project 5.14 Transportation
City of Newport Beach 5.14-2
Draft EIR
May 2025
planning of the Mobility Element by providing new and improved pedestrian and bicycle circulation facilities
near existing bus routes.
California Fire Code
The California Fire Code sets requirements pertaining to fire safety and life safety, including for emergency
access and evacuation (California Code of Regulations Title 24 Part 9). The California Fire Code is
incorporated by reference in Section 9.0.010 of the Newport Beach Municipal Code.
5.14.2.2 Local and Regional Regulations
Regional Transportation Plan/Sustainable Communities Strategy
The Southern California Association of Governments (SCAG) is the designated metropolitan planning
organization for six Southern California counties (Ventura, Los Angeles, San Bernardino, Riverside, Orange,
and Imperial). As the designated metropolitan planning organization, SCAG is mandated by the federal
and State governments to prepare plans for regional transportation and air quality conformity.
SCAG’s Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) includes long range
regional transportation plans and regional transportation improvement programs. Most of the plan’s goals
are related to regional transportation infrastructure and the efficiency of transportation in the region. SCAG
is required by federal law (23 U.S.C. Section 134 et seq.) to prepare and update a long-range RTP/SCS
every four years in order to readjust its vision for the future, assess challenges, and rearticulate goals.
The most recent RTP/SCS “Connect SoCal” was approved by SCAG on April 4, 2024 that provided updated
growth projections and forecasting for the region. The 2024 Connect SoCal includes regional planning
policies (listed in Section 5.10, Land Use and Planning) which provide guidance for integrating land use and
transportation planning. The 2024 Connect SoCal mobility policies support:
• Circulation System Preservation and Resilience
• Development of Complete Streets
• Transit and Multimodal Integration
• Transportation System Management
• Transportation Demand Management
• Technology Integration
• Safety
• Funding the System/User Fees
Connect SoCal is a planning document for the region, allowing public agencies to implement transportation
projects in a coordinated manner while qualifying for federal and State funding. Connect SoCal also
supports local jurisdictions in making informed land use planning and development decisions.
City of Newport Beach General Plan Circulation Element 2022
The City of Newport Beach General Plan Circulation Element contains the following policies related to
transportation that are applicable to the Project:
CE 2.1.1 Level of Service Standards. Plan the arterial roadway system to accommodate projected
traffic at the following level of service standards:
A. Level of Service (LOS) “D” throughout the City, unless otherwise noted
Snug Harbor Surf Park Project 5.14 Transportation
City of Newport Beach 5.14-3
Draft EIR
May 2025
B. LOS “E” at any intersection in the Airport Area shared with Irvine, and in Corona del
Mar (subject to findings of the most recent General Plan update traffic study)
CE 2.2.1 Safe Roadways. Provide for safe roadway conditions by adhering to nationally recognized
improvement standards and uniform construction and maintenance practices.
CE 2.2.5 Driveway and Access Limitations. Limit driveway and local street access on arterial streets
to maintain a desired quality of traffic flow and limit hazards to active transportation
modes. Wherever possible, consolidate and/or reduce the number of driveways and
implement access controls during redevelopment of adjacent parcels.
CE 2.2.7 Emergency Access. Provide all residential, commercial, and industrial areas with efficient
and safe access for emergency vehicles. An emergency evacuation map shall be prepared
as part of an updated Safety Element.
CE 7.1.1 Vehicle Miles Traveled (VMT) Analysis. Follow the analysis methodology for vehicle miles
traveled according to the Newport Beach VMT thresholds policy and as required in Senate
Bill 743 and the revised California Environmental Quality Act (CEQA) Guidelines.
CE 7.1.2 VMT Mitigation Measures. Require implementation of CEQA project related VMT
mitigation measures when warranted and monitor reductions in VMT from new development.
CE 7.1.5 Support Facilities for Alternative Modes. Require new development projects to provide
facilities commensurate with development type and intensity to support alternative modes,
such as preferential parking for carpools, bike racks, bike stations, bicycle lockers, showers,
commuter information areas, rideshare vehicle loading areas, water transportation docks,
and bus stop improvements.
CE 7.1.7 Project Site Design Supporting Alternative Modes. Encourage increased use of public
transportation by requiring project site designs that facilitate the use of public transportation
and walking.
CE 7.1.8 Electric Vehicle (EV) Charging Stations. Install additional EV charging stations on City
properties, support existing private development to add new EV charging stations and
develop incentives for the installation of EV charging stations and other alternative fuels
systems as part of new development.
CE 9.1.10 Development Requirements. Require development to provide the needed roadway
improvements adjacent to a site, commensurate with project impact and in accordance with
the Master Plan of Streets and Highways.
City of Newport Beach Municipal Code
Chapter 9.04 Fire Code. The City has adopted the 2022 California Fire Code including subsequent
amendments and appendices. Newport Beach Municipal Code (Municipal Code) 9.04.110 – 160 include
amendments to Section 503.2 of the Fire Code, which includes minimum dimensions for fire apparatus access
roads, turning radius, dead ends, and grades.
Chapter 15.40 Traffic Phasing Ordinance. The City of Newport Beach adopted a Traffic Phasing Ordinance
(Municipal Code Title 15, Chapter 15.40, Traffic Phasing Ordinance) to meet the following objectives: (1) to
provide a uniform method of analyzing the traffic impacts of projects that generate a substantial number of
average daily trips and/or trips during the morning or evening peak hour period; (2) to identify the specific
and near-term impacts of a project’s traffic as well as circulation system improvements that will accommodate
project traffic and ensure that development is phased with identified circulation system improvements; (3) to
Snug Harbor Surf Park Project 5.14 Transportation
City of Newport Beach 5.14-4
Draft EIR
May 2025
ensure that project proponents make or fund circulation system improvements that mitigate the specific
impacts of project traffic on primary intersections at or near the time the project is ready for occupancy;
and (4) to provide a mechanism for ensuring that a project’s cost of mitigating traffic impacts is roughly
proportional to project impacts.
These requirements differ from CEQA requirements. VMT is the CEQA significance criteria for the assessment
of potential traffic impacts. Level of service (LOS) is used by the City for non-transportation projects where
construction of all phases is anticipated to be complete within 60 months of project approval and where the
project would generate 300 or more daily trips or increase trips by one percent or more on any leg of any
primary intersection.
Chapter 20.44 Transportation Demand Management Requirements. The purpose of Chapter 20.44 is to
implement the requirements of Orange County’s Congestion Management Program. The City’s Transportation
Demand Management (TDM) Ordinance was established to help mitigate potential impacts of development
projects on mobility, congestion, and air quality, as well as to promote TDM strategies. The City uses the
TDM Ordinance to encourage changes in individual travel behavior, where certain TDM activities are made
mandatory by the ordinance.
Newport Beach City Council Policy Manual
Policy L-26: Traffic Management Policy. Local roadways are planned to accommodate traffic circulating
the local village or neighborhood they serve. Keeping regional traffic off of local streets preserves right-of-
way for its intended use and for use by other transportation modes. In recognition of the need to discourage
non-local cut-through traffic from using residential streets, the City Council adopted Policy L-26 (Traffic
Management Policy). This policy provides tools and a process for managing the speed and volume of vehicles
on residential streets and implementing considered responses that do not simply shift cut-through traffic from
one residential street to another.
City of Newport Beach Bicycle Master Plan
The City Council adopted the City of Newport Beach Bicycle Master Plan in October 2014, which provides
a broad vision, as well as strategies and actions, to improve conditions for bicycling throughout the City. The
Bicycle Master Plan provides guidance for expanding the existing bikeway network, connecting gaps within
the City, and connecting to adjacent cities. In addition, the Master Plan provides recommendations for
education, encouragement, enforcement, and evaluation programs.
5.14.3 ENVIRONMENTAL SETTING
5.14.3.1 Roadways
Regional access to the Project site is provided from State Route (SR) 73, Interstate 405 (I-405), and SR-55
via various roadways that interconnect in a grid. The Project site is adjacent to Irvine Avenue and Mesa
Drive. Table 5.14-1, Existing Roadway Characteristics within Project Vicinity, shows the roadway
characteristics within the vicinity of the Project.
Snug Harbor Surf Park Project 5.14 Transportation
City of Newport Beach 5.14-5
Draft EIR
May 2025
Table 5.14-1: Existing Roadway Characteristics within Project Area
Roadway Classification1 Direction Existing
Travel Lanes
Speed Limit
(mph)
On-Street
Parking Sidewalk Bike Lane
Irvine
Avenue Major Arterial North-South 6 50 Western
Side
Both
Sides
Class II,
Both Sides
Mesa Drive Secondary
Arterial East-West 4 45 None Both
Sides
Class II,
Both Sides
1 City of Newport Beach Circulation Element (2022)
5.14.3.2 Existing Site Trips
As detailed in Section 3.0, Project Description, the Project site is developed with a 38-bay partially covered
driving range, a 1,050-square-foot (SF) putting green, a 8,975 SF building that includes a pro shop and a
restaurant that seats 233 people, a 2,782 SF service building, a surface parking lot with 280 parking
spaces, and three holes of the existing Newport Beach Golf Course (holes 1, 2, and 9). Based on Trip
Generation Manual, 11th Edition rates for golf course, driving range, and high-turnover sit-down restaurant,
the Trip Generation Assessment (Appendix R) determined that the existing uses on the Project site generate
approximately 1,810 daily vehicular trips, 136 a.m. peak hour trips (including 76 inbound trips and 60
outbound trips), and 165 p.m. peak hour trips (including 87 inbound trips and 78 outbound trips).
5.14.3.3 Transit Service
The Orange County Transportation Authority (OCTA) provides fixed route bus service and on-demand
paratransit service (such as the one at the Oasis Senior Center provided for seniors) to Orange County,
inclusive of Newport Beach. OCTA operates routes through the City. As shown on Figure 5.14-1, OCTA Transit
Routes, OCTA Bus Route 178 provides service along Irvine Avenue with stops adjacent to the Project site that
occur between approximately 5:12 a.m. and 10:44 p.m. OCTA Bus Route 178 travels between Huntington
Beach and Irvine with scheduled stops at the intersection of Irvine Avenue and Mesa Drive, which is adjacent
to the Project site. However, OCTA Bus Route 178 currently has no weekend service (OCTA, 2025).
5.14.3.4 Walking and Bike Trails
The City has over 18 miles of pedestrian and bicycle trails throughout the City that have been developed
for commuting and recreation. The longest trail is Upper Bay Trail, which is located around the northern edge
of the Upper Newport Bay Nature Preserve and connects to University Drive that leads to Irvine Avenue and
then to the Project site. Figure 5.14-2, Bike Lanes in Project Vicinity, shows the bicycle lanes in the Project
vicinity.
5.14.3.5 Vehicle Miles Traveled
Based on the City’s SB 743 Vehicle Miles Traveled Implementation Guide, the Project site is not located
within a Transit Priority Area. Figure 3 of the Vehicle Miles Traveled Implementation Guide describes that
the Project site has an existing VMT per employee that is higher than the Countywide average commute VMT
per employee (City of Newport Beach, 2020a).
Snug Harbor Surf Park Project 5.14 Transportation
City of Newport Beach 5.14-6
Draft EIR
May 2025
This page intentionally left blank.
OCTA Transit Routes
Figure 5.14-1Snug Harbor Surf Park Project
City of Newport Beach
City of Newport Beach, City of Costa Mesa, Bureau of Land
Management, Esri, HERE, Garmin, INCREMENT P, Intermap, NGA,
USGS
0 1,000 2,000
Feet±
Legend
Project Boundary
City of Newport Beach
Bus Stops
OCTA Route Number
57
59
79
178
400
472
I r v i n e Ave
Birc
h
S
t
Bri
s
t
o
l
S
t
r
e
e
t
N
Br
i
s
t
o
l
S
t
r
e
e
t
S
Jam
b
o
r
e
e
R
d
U n i v e r s i t y D r S
Snug Harbor Surf Park Project 5.14 Transportation
City of Newport Beach 5.14-8
Draft EIR
May 2025
This page intentionally left blank.
Bike Lanes in Project Vicinity
Figure 5.14-2Snug Harbor Surf Park Project
City of Newport Beach
City of Newport Beach, City of Costa Mesa, Bureau of Land
Management, Esri, HERE, Garmin, INCREMENT P, NGA, USGS
0 250 500
Feet ±
Legend
Project Boundary
Bike Lane Class
I
II
III
I r v i n e A v e
M
e
s
a
D
r
Snug Harbor Surf Park Project 5.14 Transportation
City of Newport Beach 5.14-10
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 5.14 Transportation
City of Newport Beach 5.14-11
Draft EIR
May 2025
5.14.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of the CEQA Guidelines indicates that a Project could have a significant effect if it were to:
TRA-1 Conflict with a program, plan, ordinance, or policy addressing the circulation system, including
transit, roadway, bicycle, and pedestrian facilities.
TRA-2 Conflict or be inconsistent with CEQA Guidelines § 15064.3, subdivision (b).
TRA-3 Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm equipment).
TRA-4 Result in inadequate emergency access.
Vehicle Miles Traveled Significance Criteria
CEQA Guidelines Section 15064.3(b)(1) provides that for land use projects:
VMT traveled exceeding an applicable threshold of significance may indicate a significant
impact. Generally, projects within 0.5 mile of either an existing major transit stop or a stop
along an existing high quality transit corridor should be presumed to cause a less than
significant transportation impact. Projects that decrease vehicle miles traveled in the project
area compared to existing conditions should be presumed to have a less than significant
transportation impact.
The City of Newport Beach VMT analysis screening criteria is adopted as Council Policy K-3, and states that
a land use project that meets one or more of the criteria provided below are considered to have a less-
than-significant impact on transportation/traffic and no further VMT analysis is required:
I. The land use project is located within 0.5 mile of an existing Major Transit Stop or a High Quality
Transit Corridor unless the Land Use Project is inconsistent with the Regional Transportation
Plan/Sustainable Transportation Communities plan, has a floor area ratio (FAR) of less than 0.75,
provides parking in excess of the Newport Beach Municipal Code requirements, or reduces the
number of affordable residential units.
II. The land use project is located in areas with lower than 85 percent of the countywide average VMT
per capita trips for residential projects or lower than 85 percent of the countywide average VMT
per employee for office or other employee-based land use projects average.
III. Locally serving retail space of less than 50,000 square feet (SF)
IV. The land use project has a high level of affordable housing units, as determined by the Community
Development Department.
V. The land use project generates a net increase of 300 or less daily trips, utilizing the most current
Institute of Transportation Engineers (ITE) Trip Generation Manual. Credit may apply for existing uses
generating traffic on the site, as outlined in Chapter 15.40 (Traffic Phasing Ordinance) of the
Newport Beach Municipal Code.
VI. Institutional/Government and public service uses including, but not limited to, police stations, fire
stations, community centers, and refuse centers.
Projects that do not meet one or more of the criteria identified above would require a more detailed VMT
analysis.
Snug Harbor Surf Park Project 5.14 Transportation
City of Newport Beach 5.14-12
Draft EIR
May 2025
5.14.5 METHODOLOGY
To determine whether the proposed Project would result in a significant impact related to conflict with a
program, plan, ordinance, or policy related to the effectiveness of the circulation system, the extent to which
the proposed Project would provide facilities to enhance the use of public transit, pedestrian, and bicycle
mobility, the proposed Project was compared to adopted plans for public transit, pedestrian mobility, and
bicycle facilities. A significant impact would result if the proposed Project resulted in a conflict that could
result in an impact on the environment.
As outlined in CEQA Guidelines Section 15064.3, except as provided for roadway capacity transportation
projects, a project’s effect on automobile delay shall not constitute a significant environmental impact.
Therefore, this analysis has been prepared in accordance with CEQA requirements to evaluate potential
transportation impacts based on VMT. The City Newport Beach Council Policy K-3 provides criteria for
projects that would be considered to have a less than significant impact on VMT and therefore could be
screened out from further analysis; and those that would have the potential to result in a VMT impact and
therefore require a VMT analysis based on VMT reduction thresholds.
Consistent with the City Guidelines, the VMT screening thresholds were used to identify if the proposed
Project could have an impact on VMT, which is detailed below. If the proposed Project meets one of the
screening criteria set forth by Council Policy K-3, it can be presumed that the proposed Project would result
in a less than significant impact. Trips generated by the proposed Project have been estimated based on
trip generation rates provided by the Institute of Transportation Engineers (ITE) Trip Generation Manual, 11th
Edition, 2021. Where generation rates were not detailed within the ITE Trip Generation Manul, rates were
derived from attendance data observed at the Project site, which were reviewed and approved by the City.
5.14.6 ENVIRONMENTAL IMPACTS
IMPACT TRA-1: THE PROJECT WOULD NOT CONFLICT WITH A PROGRAM, PLAN, ORDINANCE, OR
POLICY ADDRESSING THE CIRCULATION SYSTEM, INCLUDING TRANSIT, ROADWAY,
BICYCLE, AND PEDESTRIAN FACILITIES.
Less than Significant Impact.
Transit, Bicycle, and Pedestrian Facilities
Transit: As described previously, the Project vicinity is served by OCTA Route 128. This existing transit service
would continue to serve its ridership in the area and may also serve visitors and employees of the Project.
There is an existing bus stop for Route 128 with 50-minute headways during weekdays on Irvine Avenue.
The Project would not alter the existing bus stop or sidewalk providing access to the bus stop. The proposed
Project would not alter or conflict with existing transit stops and schedules, and potential impacts related to
transit services would not occur.
Bicycle Facilities: As detailed previously, within the Project vicinity, Irvine Avenue and Mesa Drive have Class
II bike lanes on both sides of the roadway. As described in Section 3.0, Project Description, the Project would
not include any offsite roadway improvements or changes to the existing bicycle lanes. As a result, the Project
would not result in any conflicts with City’s existing and planned bike lanes. Thus, impacts related to bicycle
facilities would not occur.
Pedestrian Facilities: As detailed previously, sidewalks currently exist along both sides of Irvine Avenue and
Mesa Drive. As discussed in Section 3.0, Project Description, the proposed driveway along Irvine Avenue
would be in the same location as the existing driveway. The Project would include new curb cuts for the
proposed driveway along Mesa Drive. During construction of the driveway along Mesa Drive, the existing
Snug Harbor Surf Park Project 5.14 Transportation
City of Newport Beach 5.14-13
Draft EIR
May 2025
sidewalk along the northern portion of the roadway would be closed; however, once construction is complete,
the sidewalk would continue to be available to pedestrians in its existing configuration. As a result, the Project
would not result in any conflicts with the existing and planned pedestrian network. Thus, impacts related to
pedestrian facilities would not occur.
Roadway Facilities
Vehicular traffic to and from the Project site would utilize the existing network of regional and local
roadways that currently serve the Project vicinity, as envisioned by the General Plan Circulation Element. As
discussed in Section 3.0, Project Description, access to the Project site would be provided from two driveways,
one along Irvine Avenue and one along Mesa Drive. As detailed in Appendix R, the average vehicle ridership
(AVR) for employees was conservatively assumed to be 1.0 persons/vehicle (i.e., 70 vehicles for 70
employees), resulting 140 daily vehicle trips (70 inbound and 70 outbound). As it concerns the visitors, the
AVR was conservatively assumed to be 2.0 persons per vehicle (i.e., 700 vehicles for 1,400 visitors), resulting
in 1,400 daily vehicle trips (700 inbound and 700 outbound).
Table 5.14-2 identifies the number of trips that would be generated by the Project. As shown in Table 5.14-
2, the Project and the 15 golf holes to remain within the golf course would generate approximately 1,996
average daily trips including 63 AM peak hour and 155 PM peak hour trips. Therefore, the Project would
result in approximately 186 net new daily trips with a net reduction of 73 AM peak hour trips and 10 PM
peak hour trips compared to the existing golf course uses. This is less than the 300 daily trip threshold
identified by the City Traffic Phasing Ordinance (Municipal Code Title 15, Chapter 15.40, Traffic Phasing
Ordinance) that requires evaluation of potential circulation system improvements. Thus, operational roadway
impacts would be less than significant.
Table 5.14-2: Project Trip Generation
AM Peak Hour PM Peak Hour
Land Use Daily In Out Total In Out Total
Surf Park
Surf Lagoon & Amenities – Visitors 1,400 visitors 1,400 35 2 37 56 55 111
Surf Lagoon & Amenities – Employees 70 employees 140 - - - - - -
Golf Course (Offsite Holes to Remain) 15 holes 456 21 5 26 23 21 44
1,996 56 7 63 79 76 155
Existing Golf Course
Golf Course 18 holes 547 25 7 32 28 25 52
Driving Range 38 positions 519 9 6 15 21 26 48
Internal Capture 25% (137) (6) (2) (8) (7) (6) (13)
Restaurant 233 seats 1,018 55 50 105 52 39 91
Internal Capture 25% (137) (6) (2) (8) (7) (6) (13)
1,810 76 60 136 87 78 165
Net New Trips 186 (20) (53) (73) (8) (2) (10)
Source: Trip Generation Assessment (Appendix R)
Construction
Construction of the proposed Project is anticipated to occur over an 18-month period. Construction-related
trips generated on a daily basis throughout various construction activities would be derived from construction
workers and delivery of materials. It is anticipated Project construction would generate haul trips distributed
throughout the day. During construction, there would also be passenger car construction trips associated with
construction crew arrivals and departures. The weekday a.m. peak period is 7:00 a.m. to 9:00 a.m., and the
Snug Harbor Surf Park Project 5.14 Transportation
City of Newport Beach 5.14-14
Draft EIR
May 2025
weekday p.m. peak period is 4:00 p.m. to 6:00 p.m. As Newport Beach Municipal Code Section 10.28.040
allowable construction hours begin at 7:00 a.m., it is anticipated that the majority of construction crews would
arrive and depart outside the peak hours, while delivery trucks would arrive and depart throughout the day.
As shown in Table 5.14-3, the grading phase of construction would generate the most vehicular trips per
day from approximately 30 worker trips and 1 vendor trip per day, which would result in a total of 31
daily trips.
Table 5.14-3: Daily Construction Vehicle Trips
Construction Activity Workers Per Day Vendors Per Day Hauling Trips Per Day
Demolition 10 1 9
Site Preparation 8 1 0
Grading 30 1 0
Building Construction 11 3 0
Paving 15 0 0
Architectural Coating 2 0 0
Source: Air Quality Impact Analysis (Appendix B)
This equates to approximately 16.7 percent of the net daily trips that would be generated from operation
of the Project (as shown in Table 5.14-2). Therefore, 16.7 percent of the daily trips would also not result in
an inconsistency with the City’s traffic criteria. Additionally, as described above, vendor delivery trucks would
arrive and depart throughout the day and a majority of construction crews would arrive and depart outside
the peak hours. Furthermore, the construction traffic would be temporary and intermittent depending on the
phase of construction, and haul and vendor trucks would be required to utilize City truck routes.
All construction equipment, including construction worker vehicles, would be staged on the Project site for the
duration of the construction period. In addition, as part of the grading plan and building plan review
processes, the City permits would require appropriate measures to facilitate the passage of persons and
vehicles through/around any required road closures (as applicable). Therefore, construction impacts related
to conflict with an applicable plan, ordinance, or policy establishing measures of effectiveness for the
performance of the circulation system would be less than significant.
Overall, the Project would not conflict with the circulation system, and potential impacts related to transit,
bicycle, pedestrian, and roadway facilities would be less than significant.
IMPACT TRA-2: THE PROJECT WOULD NOT CONFLICT OR BE INCONSISTENT WITH CEQA GUIDELINES
§ 15064.3, SUBDIVISION (B).
Less than Significant Impact. As described previously, CEQA Guidelines Section 15064.3(b) focuses on
determining the significance of VMT-related transportation impacts. The City of Newport Beach’s SB 743
Vehicle Miles Traveled Methodology – Council Policy K-3 was adopted in June 2020 and contain the following
screening thresholds to assess whether further VMT analysis is required. If the project meets any of the
following screening thresholds, then the VMT impact of the project is considered less than significant and
further VMT analysis is not required.
I. The Land Use Project is located within 0.5-mile of an existing Major Transit Stop or a High Quality
Transit Corridor unless the Land Use Project is inconsistent with the Regional Transportation
Plan/Sustainable Transportation Communities plan, has a floor area ratio (FAR) of less than 0.75,
provides parking in excess of the Newport Beach Municipal Code requirements, or reduces the
number of affordable residential units.
Snug Harbor Surf Park Project 5.14 Transportation
City of Newport Beach 5.14-15
Draft EIR
May 2025
II. The Land Use Project is located in areas with lower than 85 percent of the countywide average VMT
per capita trips for residential projects or lower than 85 percent of the countywide average VMT
per employee for office or other employee -based Land Use Projects average.
III. Locally serving retail space of less than 50,000 square feet (SF)
IV. The Land Use Project has a high level of affordable housing units, as determined by the Community
Development Department.
V. The Land Use Project generates a net increase of 300 or less daily trips, utilizing the most current
Institute of Transportation Engineers (ITE) Trip Generation Manual. Credit may apply for existing uses
generating traffic on the site, as outlined in Chapter 15.40 (Traffic Phasing Ordinance) of the
Newport Beach Municipal Code.
VI. Institutional/ Government and public service uses including, but not limited to, police stations, fire
stations, community centers, and refuse centers.
The applicability of each screening criteria in comparison to the proposed Project is discussed below.
Screening Criteria I – Within 0.5-mile of Major Transit Stop or a High Quality Transit Corridor: Per Public
Resources Code, Section 21064.3, “‘Major transit stop’ means a site containing an existing rail transit station,
a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus
routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak
commute periods.” Per Public Resources Code, Section 21155, a high quality transit corridor means a
“corridor with fixed route bus service with service intervals no longer than 15 minutes during peak commute
hours.” The Project site is not located within one half mile of a major transit stop or a high quality transit
corridor; therefore, the Project does not satisfy the requirements of screening criteria I.
Screening Criteria II – Low VMT Area: The City’s guidelines define a low VMT generating area as traffic
analysis zones with a total daily VMT lower than 85 percent of the countywide average VMT per employee.
Figure 3 of the Vehicle Miles Traveled Implementation Guide describes that the Project site has an existing
VMT per employee that is higher than the Countywide average commute VMT per employee (City of
Newport Beach, 2020a). Therefore, the Project does not satisfy the requirements of screening criteria II.
Screening Criteria III – Local Serving Retail: The Project would develop a recreational surf park with over
50,000 square feet of building area. Therefore, the Project does not satisfy the requirements of screening
criteria III.
Screening Criteria IV – Affordable Housing: The Project does not include any residential development;
therefore, the Project does not satisfy the requirements of screening criteria IV.
Screening Criteria V – Net Daily Trips Less than 300 Daily Trips: Table 5.14-2 shows that the Project would
result in approximately 186 net new daily trips compared to the existing onsite uses and a net reduction of
73 a.m. peak hour trips and 10 p.m. peak hour trips. Therefore, the Project would result in fewer than 300
net daily trips and the Project would meet the requirements of Screening Criteria V.
Screening Criteria VI – Institutional/Government and Public Service Uses: The Project does not include any
government or public service uses; therefore, the Project does not satisfy the requirements of screening
criteria IV.
Overall, pursuant to the City’s VMT screening criteria and guidance from OPR and CEQA Guidelines Section
15064.3(b)(1), based on the Project’s net trip generation of less than 300 daily trips, the proposed Project
would screen from a full VMT analysis and impacts can be presumed to be less than significant. Therefore,
the proposed Project would not conflict or be inconsistent with CEQA Guidelines § 15064.3, subdivision (b),
and impacts would be less than significant.
Snug Harbor Surf Park Project 5.14 Transportation
City of Newport Beach 5.14-16
Draft EIR
May 2025
IMPACT TRA-3: THE PROJECT WOULD NOT 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.
Construction
The Project proposes construction of the Project to last approximately 18 months. During construction,
construction worker vehicles, haul trucks, and vendor trucks would be staged on the portion of the Project site
under construction for the duration of the construction period. As part of the grading plan and building plan
review processes, City permits would require appropriate measures to facilitate the passage of persons and
vehicles through/around any required road closures and measures to properly route heavy-duty construction
vehicles entering and leaving the site (as applicable). As a result, impacts related to vehicular circulation
design features and incompatible uses during construction of the proposed Project would be less than
significant.
Operation
The Project does not include incompatible uses. The proposed recreational surf park and operation of the
proposed parking lots would not be incompatible with the existing recreational golf parking on the site. The
proposed Project would provide for both golf related and surf related circulation needs on the site. Access
to the Project site would be provided from two driveways, including: one driveway along Irvine Avenue
providing full access and one driveway along Mesa Driveway with left-in and right-in and right-out only
access. Vehicular traffic to and from the Project site would utilize the existing network of regional and local
roadways that currently serve the Project area. As stated in Section 3.0, Project Description, the Project would
include provide for golf cart circulation, separate from vehicular circulation. In addition, the Project would
not modify the existing sidewalks or bike lanes.
Onsite traffic signing and striping, as approved by the City’s transportation engineering. Additionally, sight
distance at the Project’s access points would be reviewed with respect to City standards at the time of final
grading, landscape, and street improvement plan reviews. The Project frontage improvements and site access
points would be constructed to be consistent with the identified roadway classifications and respective cross-
sections in accordance with the Newport Beach General Plan Circulation Element, and traffic engineering
safety standards. Compliance with existing regulations would be ensured through the City’s construction
permitting process. As a result, potential impacts related to vehicular circulation design features would be
less than significant.
IMPACT TRA-4: THE PROJECT WOULD NOT RESULT IN INADEQUATE EMERGENCY ACCESS.
Less than Significant Impact.
Construction
The installation of driveways and connections to existing utility systems in roadways that would be
implemented during construction of the proposed Project could require the temporary closure of travel lanes.
No full roadway closures are anticipated to be needed as part of construction of the proposed Project.
However, construction activities would be required to implement measures to facilitate the passage of
persons and vehicles through/around any required temporary road restrictions and ensure the safety of
passage in accordance with Section 503 of the California Fire Code (Title 24, California Code of
Regulations, Part 9), which would be ensured through the City’s construction permitting process. Thus,
implementation of the proposed Project through the City’s permitting process would ensure existing
regulations are adhered to and would reduce potential construction related emergency access impacts to a
Snug Harbor Surf Park Project 5.14 Transportation
City of Newport Beach 5.14-17
Draft EIR
May 2025
less than significant level. Therefore, Project impacts related to emergency access during construction would
be less than significant.
Operation
The proposed Project would not result in inadequate emergency access to or from the Project site for
emergency vehicles. The Project would not interfere with the circulation of emergency vehicles along public
streets, and the proposed driveways would provide emergency access from both adjacent roadways and
through the site. The Project would be required to design and construct internal access and provide fire
suppression facilities (e.g., hydrants and sprinklers) in conformance with the City’s Municipal Code Chapter
9.04. This also includes compliance with emergency access design standards to provide sufficient access for
emergency equipment. The Fire Code sets minimum standards for site driveway and access dimension, design,
grades, and other fire safety features. The Newport Beach Fire Department would review the development
plans as part of the construction permitting process to ensure that emergency access is provided pursuant to
the requirements of the Uniform Fire Code and Section 503 of the California Fire Code (Title 24, California
Code of Regulations, Part 9). Therefore, impacts related to inadequate emergency access would be less
than significant.
5.14.7 CUMULATIVE IMPACTS
The cumulative traffic study area for the proposed Project includes the City of Newport Beach and the
information utilized in this cumulative analysis is based on the potential to combine with impacts from projects
in the vicinity of the proposed Project, as listed in Table 5-1, and the projections contained within the Newport
Beach General Plan and Orange County Transportation Analysis Model (OCTAM).
Circulation System
The evaluation of Impact TRA-1 concluded that the proposed Project would utilize the existing circulation
system and implement the City’s traffic engineering design standards for the onsite circulation system. The
proposed Project would result in a reduction in a.m. and p.m. peak hour trips and would not conflict with a
plan, ordinance, or policy addressing circulation that could be cumulatively considerable. In addition,
cumulative development in the City and surrounding jurisdictions would be subject to site-specific reviews,
including reviews of sidewalk, bike lane, and bus stop designs that would not allow potential cumulatively
considerable impacts related to alternative transportation. Therefore, the proposed Project would not
cumulatively combine with other projects to result in impacts.
Vehicle Miles Traveled
The cumulative traffic study area for the proposed Project includes the City of Newport Beach. As detailed
previously under Impact TRA-2, based on City and CEQA Guidelines screening criteria, the proposed Project
would not exceed the vehicular trip threshold (300 ADT) and would be less than significant. Therefore, VMT
impacts from the proposed Project would be less than cumulatively considerable. Further, cumulative
development within the City (including those related to the City’s Housing Implementation Program) would
be subject to review pursuant to the City of Newport Beach’s SB 743 Vehicle Miles Traveled Methodology –
Council Policy K-3 to determine their potential for VMT impacts. Cumulative projects that do not screen out
of a VMT analysis pursuant to the City’s screening criteria, would be required to conduct a VMT analysis and
mitigate any potentially significant impacts. Therefore, cumulative impacts related to VMT would be less than
significant.
Snug Harbor Surf Park Project 5.14 Transportation
City of Newport Beach 5.14-18
Draft EIR
May 2025
Design and Emergency Access Hazards
The evaluation of Impact TRA-3 and Impact TRA-4 concluded that the proposed Project would not result in
impacts related to incompatible uses, hazards due to roadway design, or emergency access. The proposed
circulation layout would be required to be installed in conformance with City design standards that would
be ensured through the City’s development permitting process to provide that no potentially hazardous
design features or inadequate emergency access would be introduced by the proposed Project that could
combine with potential hazards from other nearby projects. As the Project’s proposed improvements would
be implemented in compliance with City traffic engineering design standards, it would not result in an impact
that could become cumulatively considerable. In addition, cumulative development in the City and
surrounding jurisdictions would be subject to site-specific reviews, including reviews by building and fire
protection authorities that would require compliance with existing building and fire code standards that limit
the potential of other projects to result in cumulatively considerable design hazards. Therefore, potential
impacts related to circulation design features and emergency access would not be cumulatively considerable.
5.14.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES
The following would reduce potential impacts related to transportation.
Existing Regulations
• Municipal Code Chapter 9.04, Fire Code
• Municipal Code Chapter 15.40, Traffic Phasing Ordinance
• Municipal Code Chapter 20.44, Transportation Demand Management Requirements
Existing City Council Policy Manual Policy
• City Council Policy Manual Policy L-26, Traffic Management Policy
Plans, Programs, or Policies
None.
5.14.9 PROJECT DESIGN FEATURES
None.
5.14.10 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Impacts TRA-1 through TRA-4 would be less than significant.
5.14.11 MITIGATION MEASURES
No mitigation measures are required.
5.14.12 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts would be less than significant.
Snug Harbor Surf Park Project 5.14 Transportation
City of Newport Beach 5.14-19
Draft EIR
May 2025
5.14.13 REFERENCES
City of Newport Beach. (2001, January). Santa Ana Heights Specific Plan. Retrieved September 23, 2024,
from ocpublicworks.com.
City of Newport Beach. (2006a, July). General Plan. Retrieved September 23, 2024, from
newportbeachca.gov: https://www.newportbeachca.gov/government/departments/community-
development/planning-division/general-plan-codes-and-regulations/general-plan
City of Newport Beach. (2006b, July). General Plan Environmental Impact Report. Retrieved September 23,
2024, from newportbeachca.gov:
https://www.newportbeachca.gov/government/departments/community-development/planning-
division/general-plan-codes-and-regulations/general-plan/general-plan-environmental-impact-
repor
City of Newport Beach. (2022). General Plan Circulation Element. Retrieved April 7, 2025, from
https://www.newportbeachca.gov/home/showpublisheddocument/72126/6379694919466700
00
City of Newport Beach. (2020a). CEQA Transportation Thresholds of Significance Guide, Figure 3.
Retrieved March 3, 2025, from:
https://www.newportbeachca.gov/home/showpublisheddocument/66735/6372382943343300
00
City of Newport Beach. (2020b). SB 743 Vehicle Miles Traveled Methodology – Council Policy K-3.
Retrieved March 11, 2025, from:
https://www.newportbeachca.gov/home/showpublisheddocument/66989/6372746034571000
00
City of Newport Beach. (2020c). CEQA Transportation Thresholds of Significance Guide, Figure 2. Retrieved
March 3, 2025, from:
https://www.newportbeachca.gov/home/showpublisheddocument/66733/6372382943316700
00
City of Newport Beach. (2024, May). Newport Beach Municipal Code. Retrieved September 23, 2024,
from codepublishing.com: https://www.codepublishing.com/CA/NewportBeach/
Gibson Transportation Consulting, Inc. (2025, March). Trip Generation Assessment for Surf Farm Newport
Beach, California. (Appendix R)
Orange County Transportation Authority. (2025). Routes and Schedules. Retrieved March 3, 2025, from:
https://www.octa.net/ebusbook/routePDF/Route178.pdf
Southern California Association of Governments (SCAG). (2024). Connect SoCal. Retrieved March 3, 2025,
from: scag.ca.gov: https://scag.ca.gov/connect-socal
Urban Crossroads (2025). Surf Farm Air Quality Impact Analysis. (Appendix B)
Snug Harbor Surf Park Project 5.14 Transportation
City of Newport Beach 5.14-20
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 5.15 Tribal Cultural Resources
City of Newport Beach 5.15-1
Draft EIR
May 2025
5.15 Tribal Cultural Resources
5.15.1 INTRODUCTION
This section describes the tribal cultural resource conditions in the Project region and potential impacts from
Project implementation. The analysis in this section is based, in part, on the following documents and resources:
•City of Newport Beach General Plan, 2006
•City of Newport Beach General Plan Environmental Impact Report (General Plan EIR), 2006
•City of Newport Beach Municipal Code
•Phase I Archaeological Resources Assessment for the Surf Farm Project, Located in the City of Newport
Beach, Orange County, California, prepared by Glenn Lukos Associates, 2024, included as Appendix E
5.15.2 REGULATORY SETTING
5.15.2.1 Federal Regulations
Archaeological Resources Protection Act
The Archaeological Resources Protection Act (ARPA) of 1979 regulates the protection of archaeological
resources and sites on federal and Native American lands. ARPA regulates authorized archaeological
investigations on federal lands; increased penalties for looting and vandalism of archaeological resources;
required that the locations and natures of archaeological resources be kept confidential in most cases. In
1988, amendments to ARPA included a requirement for public awareness programs regarding
archaeological resources.
Native American Graves Protection and Repatriation Act
The Native American Graves Protection and Repatriation Act is a federal law passed in 1990 that mandates
museums and federal agencies to return certain Native American cultural items—such as human remains,
funerary objects, sacred objects, or objects of cultural patrimony—to lineal descendants or culturally
affiliated Indian tribes.
5.15.2.2 State Regulations
California Senate Bill 18
Senate Bill (SB) 18 (California Government Code Section 65352.3) sets forth requirements for local
governments to consult with California Native American tribes identified by the Native American Heritage
Commission (NAHC) to aid in the protection of tribal cultural resources. The intent of SB 18 is to provide
California Native American tribes an opportunity to participate in local land use decisions at an early stage
of planning to protect or mitigate impacts on tribal cultural resources. The California Governor’s Office of
Planning and Research’s 2005 Tribal Consultation Guidelines: Supplement to General Plan Guidelines identifies
the following contact and notification responsibilities of local governments:
•Prior to the adoption or any amendment of a general plan or specific plan, a local government must
notify the appropriate tribes (on the contact list maintained by the NAHC) of the opportunity to conduct
consultations for the purpose of preserving, or mitigating impacts to, cultural places located on land
Snug Harbor Surf Park Project 5.15 Tribal Cultural Resources
City of Newport Beach 5.15-2
Draft EIR
May 2025
within the local government’s jurisdiction that is affected by the proposed plan adoption or amendment.
Tribes have 90 days from the date on which they receive notification to request consultation, unless a
shorter timeframe has been agreed to by the tribe (Government Code Section 65352.3).
• Prior to the adoption or substantial amendment of a general plan or specific plan, a local government
must refer the proposed action to those tribes that are on the NAHC contact list and have traditional
lands located within the city or county’s jurisdiction. The referral must allow a 45-day comment period
(Government Code Section 65352). Notice must be sent regardless of whether prior consultation has
taken place. Such notice does not initiate a new consultation process.
• Local government must send a notice of a public hearing, at least 10 days prior to the hearing, to tribes
who have filed a written request for such notice (Government Code Section 65092).
California Assembly Bill 52
Assembly Bill (AB) 52 established a requirement under CEQA to consider “tribal cultural values, as well as
scientific and archaeological values when determining impacts and mitigation.” Public Resources Code (PRC)
Section 21074(a) defines “tribal cultural resources” as “[s]ites, features, places, cultural landscapes, sacred
places, and objects with cultural value to a California Native American tribe” that are either “[i]ncluded or
determined to be eligible for inclusion in the California Register of Historical Resources” or “in a local register
of historical resources.” Additionally, defined cultural landscapes, historical resources, and archaeological
resources may be considered tribal cultural resources (PRC Sections 21074(b), (c)). The lead agency may
also in its discretion treat a resource as a tribal cultural resource if it is supported with substantial evidence.
In order to protect tribal cultural resources, lead agencies are required to offer consultation on CEQA
documents to California Native American tribes traditionally and culturally affiliated with the project area
prior to release of the CEQA document. PRC Section 21080.3.1(b) defines “consultation” as “the meaningful
and timely process of seeking, discussing, and considering carefully the views of others, in a manner that is
cognizant of all parties’ cultural values and, where feasible, seeking agreement.” Consultation must “be
conducted in a way that is mutually respectful of each party’s sovereignty [and] recognize the tribes’
potential needs for confidentiality with respect to places that have traditional tribal cultural significance.”
The consultation process is outlined as follows:
1. California Native American tribes traditionally and culturally affiliated with the project area submit
written requests to participate in consultations.
2. Lead agencies are required to provide formal notice to the California Native American tribes that
requested to participate within 14 days of the lead agency’s determination that an application package
is complete or decision to undertake a project.
3. California Native American tribes have 30 days from receipt of notification to request consultation on a
project.
4. Lead agencies initiate consultations within 30 days of receiving a California Native American tribe’s
request for consultation on a project.
5. Consultations are complete when the lead agencies and California Native tribes participating have
agreed on measures to mitigate or avoid a significant impact on a tribal cultural resource, or after a
reasonable effort in good faith has been made and a party concludes that a mutual agreement cannot
be reached (PRC Sections 21082.3(a), (b)(1)-(2); 21080.3.1(b)(1)).
AB 52 requires that the CEQA document disclose significant impacts on tribal cultural resources and discuss
feasible alternatives or mitigation to avoid or lessen an impact.
Snug Harbor Surf Park Project 5.15 Tribal Cultural Resources
City of Newport Beach 5.15-3
Draft EIR
May 2025
California Health and Safety Code, Section 7050.5
This code requires that if human remains are discovered on a project site, disturbance of the site shall halt
and remain halted until the coroner has conducted an investigation into the circumstances, manner, and cause
of any death, and the recommendations concerning the treatment and disposition of the human remains have
been made 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 recognizes or has reason to
believe the human remains are those of a Native American, he or she shall contact, by telephone within 24
hours, the NAHC.
California Public Resources Code, Sections 5097.9 to 5097.991
PRC Sections 5097.9 to 5097.991 provide protection to Native American historical and cultural resources
and sacred sites and identify the powers and duties of the NAHC. These sections also require notification to
descendants of discoveries of Native American human remains and provide for treatment and disposition of
human remains and associated grave goods.
5.15.2.3 Local Regulations
City of Newport Beach General Plan 2006
The City of Newport Beach General Plan contains the following policies related to tribal cultural resources
that are applicable to the Project:
HR 2.1 New Development Activities. Require that, in accordance with CEQA, new development
protect and preserve paleontological and archaeological resources from destruction, and
avoid and mitigate impacts to such resources. Through planning policies and permit
conditions, ensure the preservation of significant archeological and paleontological
resources and require that the impact caused by any development be mitigated in
accordance with CEQA.
HR 2.2 Grading and Excavation Activities. Maintain sources of information regarding
paleontological and archeological sites and the names and addresses of responsible
organizations and qualified individuals, who can analyze, classify, record, and preserve
paleontological or archeological findings. Require a qualified paleontologist/archeologist
to monitor all grading and/or excavation where there is a potential to affect cultural,
archeological or paleontological resources. If these resources are found, the applicant shall
implement the recommendations of the paleontologist/archeologist, subject to the approval
of the City Planning Department.
HR 2.3 Cultural Organizations. Notify cultural organizations, including Native American
organizations, of proposed developments that have the potential to adversely impact
cultural resources. Allow representatives of such groups to monitor grading and/or
excavation of development sites.
HR 2.4 Paleontological or Archaeological Materials. Require new development to donate
scientifically valuable paleontological or archaeological materials to a responsible public
or private institution with a suitable repository, located within Newport Beach, or Orange
County, whenever possible.
Snug Harbor Surf Park Project 5.15 Tribal Cultural Resources
City of Newport Beach 5.15-4
Draft EIR
May 2025
NR 18.1 New Development. Require new development to protect and preserve paleontological and
archaeological resources from destruction, and avoid and minimize impacts to such resources
in accordance with the requirements of CEQA. Through planning policies and permit
conditions, ensure the preservation of significant archeological and paleontological
resources and require that the impact caused by any development be mitigated in
accordance with CEQA.
NR 18.3 Potential for New Development to Impact Resources. Notify cultural organizations,
including Native American organizations, of proposed developments that have the potential
to adversely impact cultural resources. Allow qualified representatives of such groups to
monitor grading and/or excavation of development sites.
NR 18.4 Donation of Materials. Require new development, where on site preservation and
avoidance are not feasible, to donate scientifically valuable paleontological or
archaeological materials to a responsible public or private institution with a suitable
repository, located within Newport Beach or Orange County, whenever possible.
5.15.3 ENVIRONMENTAL SETTING
5.15.3.1 Native American Tribes
According to available ethnographic maps, ethnographic data, and Native American input, the City of
Newport Beach lies within an area on the border of the traditional lands of the Gabrieleño and the
Juaneño/Luiseño. As such, both are discussed below.
Gabrieleño
The traditional lands of the Gabrieleño at the time of Spanish contact covers much of current-day Los
Angeles, San Bernardino, and Orange Counties, which includes the Project site in the City of Newport Beach.
The southern region of this cultural area is bound by Aliso Creek, the eastern region is located east of San
Bernardino along the Santa Ana River, the northern region includes the San Fernando Valley, and the western
region includes portions of the Santa Monica Mountains. The Gabrieleño also occupied several Channel
Islands including Santa Barbara Island, Santa Catalina Island, San Nicholas Island, and San Clemente Island.
Because of their access to certain resources, including a steatite source from Santa Catalina Island, this group
was among the wealthiest and most populous aboriginal groups in Southern California. Trade of materials
and resources controlled by the Gabrieleño extended as far north as the San Joaquin Valley, as far east as
the Colorado River, and as far south as Baja California.
The Gabrieleño lived in permanent villages and smaller, resource-gathering camps occupied at various times
of the year depending upon the seasonality of the resource. Larger villages comprised of several families
or clans, while smaller, seasonal camps typically housed smaller family units. Gabrieleño houses were domed,
circular structures made of thatched vegetation. Houses varied in size, and could house from one to several
families. Sweathouses—semicircular, earth covered buildings—were public structures used in male social
ceremonies. Other structures included menstrual huts and a ceremonial structure called a yuvar, an open-air
structure built near the chief’s house.
Hunting implements included wooden clubs, sinew-backed bows, slings, and throwing clubs. Maritime
implements included rafts, harpoons, spears, hook and line, and nets. A variety of other tools included deer
scapulae saws, bone and shell needles, bone awls, scrapers, bone or shell flakers, wedges, stone knives and
drills, metates, mullers, manos, shell spoons, bark platters, and wooden paddles and bowls. Baskets were
made from rush (Juncus sp.), deer grass (Muhlenbergia rigens), and skunkbush (Rhus trilobata).
Snug Harbor Surf Park Project 5.15 Tribal Cultural Resources
City of Newport Beach 5.15-5
Draft EIR
May 2025
The social structure of the Gabrieleño is little known; however, there appears to have been at least three
social classes: (1) the elite, which included the rich, chiefs, and their immediate family; (2) a middle class,
which included people of relatively high economic status or long-established lineages; and (3) a class of
people that included most other individuals in the society. Villages were politically autonomous units
comprised of several lineages. During times of the year when certain seasonal resources were available, the
village would divide into lineage groups and move out to exploit them, returning to the village between
forays.
Each lineage had its own leader, with the village chief coming from the dominant lineage. Several villages
might be allied under a paramount chief. Chiefly positions were of an ascribed status, most often passed to
the eldest son. Chiefly duties included providing village cohesion, leading warfare and peace negotiations
with other groups, collecting tribute from the village(s) under his jurisdiction, and arbitrating disputes within
the village(s). The status of the chief was legitimized by his safekeeping of the sacred bundle, a
representation of the link between the material and spiritual realms and the embodiment of power. Shamans
were leaders in the spirit realm. The duties of the shaman included conducting healing and curing ceremonies,
guarding of the sacred bundle, locating lost items, identifying and collecting poisons for arrows, and making
rain. Marriages were made between individuals of equal social status and, in the case of powerful lineages,
marriages were arranged to establish political ties between the lineages. Men conducted the majority of the
heavy labor, hunting, fishing, and trading with other groups. Women’s duties included gathering and
preparing plant and animal resources, and making baskets, pots, and clothing.
Rivers and streams were used as trading routes and travel routes as they provided resources. Thus, many
tribal cultural resources are found along rivers, streams, and other known travel or trade routes. Likewise,
the Newport Back Bay area would have been an area that provided resources to local tribes. Thus, areas
in proximity to the Back Bay have the potential to contain resources.
Juaneño/Luiseño
The traditional lands of the Juaneño Band of Mission Indians, Acjachemen Nation and Luiseño Indians covered
Orange County and parts of San Diego, Los Angeles, and Riverside Counties. The Acjachemen Nation refers
to the indigenous people native to the area. Their population is thought to have been upwards of 3,500
before contact with the Spanish. The Juaneño name came about once the local peoples were administered
by Mission San Juan Capistrano. Native population within the Mission has been recorded to reach over 1,000
residents. Cremation and burial of the dead were practiced in their society.
The Juaneño resided in permanent, well-defined villages with associated seasonal camps housing between
35 to 300 people. Smaller villages were primarily comprised of a single lineage, while larger villages were
a combination of the dominant clan and multiple families. In larger villages, the temple was the center of the
town, with housing for the captain or chief nearby. Additionally, residence within villages were typically
patrilocal. Each village was politically independent while maintaining contact with other groups in the region
through economic, religious, and social networks.
Social structure was clearly defined into three hierarchies: 1) an elite class of chiefly families, lineage heads,
and ceremonial specialists; 2) a middle class of established and successful families; and 3) the lower class
of wandering peoples and war captives. The Nota, or the hereditary village chief, held authority over
religious, economic, and warfare powers. Aiding the Nota was a council of elder assistants, ritual specialists,
and shamans called the puuplem. These people, also chosen within the dominant lineage, contributed to
community decisions and governing religious duties.
A majority of the traditional diet was comprised of plant foods; of those, acorns were the staple food source.
As a result, villages were typically located near abundant water to leach milled acorn products. Communities
closer to the coast relied heavily on fish and marine animal resources, while terrestrial game accounted for
Snug Harbor Surf Park Project 5.15 Tribal Cultural Resources
City of Newport Beach 5.15-6
Draft EIR
May 2025
the smallest portion of their diet. Thus, the Newport Back Bay area would have been an area that provided
resources for sustenance, and areas in proximity to the Back Bay have the potential to contain tribal cultural
resources.
5.15.3.2 Tribal Cultural Resources
Orange County contains prehistoric sites dating from 9,000 to 10,000 years ago that show signs of human
presence. Sites from 6,000 to 1,000 BC (Milling Stone period) are common in the coastal region of Southern
California and at many inland locations. Between 1,000 BC to 650 AD (Intermediate period), orientation of
sites shifted toward hunting, maritime subsistence, and acorn processing. The late prehistoric period from
650 AD until European contact in 1769 included the introduction of pottery, triangular arrow points, and
cremation practices (City of Newport Beach, 2006b).
A total of 38 cultural resources studies have been performed within a 0.5-mile radius of the Project site. Of
these previous studies, three include the Project site. The records search conducted for the proposed Project
identified nine cultural resources, all of which are precontact/prehistoric. The nine resources primarily consist
of lithic scatters and habitation debris; however, resource P-30-000174, which is less than 0.25-mile
northwest of the Project site, also contained human remains (which were excavated in 1950). No
archaeological or historic resources have been previously recorded within the Project site. However, the
Project site near Upper Newport Bay (which would have served as a commonly and heavily used food source
for precontact populations in the area) indicates an elevated sensitivity for subsurface tribal cultural
resources (Appendix E).
5.15.3.3 Sacred Lands File Search
Tribal cultural resources can include archaeological sites, built environment resources, locations of events or
ceremonies, resource procurement areas, and natural landscape features with special significance to one or
more indigenous groups. The City requested a Sacred Lands File (SLF) Search from the NAHC on May 31,
2024, and received the results on June 18, 2024. The SLF returned positive results, indicating that known
tribal resources and/or sacred sites are located within the Project vicinity.
5.15.4 THRESHOLDS OF SIGNIFICANCE
Appendix G of State CEQA Guidelines indicates that a Project could have a significant effect if it were to:
TCR-1 Cause a substantial adverse change in the significance of a tribal cultural resource, defined in
Public Resources Code § 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 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
TCR-2 Cause a substantial adverse change in the significance of a tribal cultural resource, defined in
Public Resources Code § 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 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 § 5024.1. In applying the criteria
set forth in subdivision (c) of Public Resource Code § 5024.1, the lead agency shall consider the
significance of the resource to a California Native American tribe.
Snug Harbor Surf Park Project 5.15 Tribal Cultural Resources
City of Newport Beach 5.15-7
Draft EIR
May 2025
5.15.5 METHODOLOGY
The tribal cultural resources analysis is based on the Phase I Archaeological Resources Assessment and
consultation carried out by the City of Newport Beach pursuant to SB 18 and AB 52 (Appendix E). The Phase
I Cultural Resources Assessment included an archaeological and historical records search, completed at the
South Central Coastal Information Center for the Project site. Pedestrian surveys were conducted at the
Project site; see Section 5.4.5 in Section 5.4, Cultural Resources, for details on the methodology. The NAHC
was contacted to perform a Sacred Lands File search; and local Native American tribes were contacted to
elicit local knowledge of cultural resource issues related to the Project.
5.15.6 ENVIRONMENTAL IMPACTS
IMPACT TCR-1: THE PROJECT WOULD NOT CAUSE A SUBSTANTIAL ADVERSE CHANGE IN THE
SIGNIFICANCE OF A TRIBAL CULTURAL RESOURCE, DEFINED IN PUBLIC RESOURCES
CODE § 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 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).
Less than Significant Impact with Mitigation Incorporated. SB 18 and AB 52 require meaningful
consultation between lead agencies and California Native American tribes regarding potential impacts on
TCRs. As described above, TCRs are sites, features, places, cultural landscapes, sacred places, and objects
with cultural value to a California Native American tribe that are either eligible or listed in the California
Register of Historical Resources or local register of historical resources (PRC Section 21074). In accordance
with SB 18 and AB 52, the City sent letters to 20 Native American representatives identified by the City and
NAHC, notifying them of the proposed Project.
The City received responses from the Gabrieleño Band of Mission Indians – Kizh Nation and the Gabrieleño
Tongva Indians of California requesting consultation. The City consulted with both of the tribes that requested
consultation. The Gabrieleño Band of Mission Indians – Kizh Nation provided detail that the Project location
is within the Tribe’s ancestral tribal territory where resources have previously been found and provided
recommended mitigation measures. The Gabrieleño Tongva Indians of California stated that Newport Beach
is situated within two village sites, and that the Newport Bay flat areas with saltwater and fresh marshes
(apuchan) provided an abundance of food sources and favorable living conditions for the Tongva year-
round. Both Tribes indicated that the Project site is sensitive for potential TCRs and that Tribal monitoring
during excavation and grading should be required by the City.
During the course of the tribal consultation process, no Native American tribe provided the City with
substantial evidence indicating that tribal cultural resources, as defined in PRC Section 21074, are present
on the Project site or have been found previously on the Project site. However, due to the Project site’s
location in an area where Native American tribes are known to have a cultural affiliation, and a positive
SLF search results in the Project vicinity, there is the possibility that archaeological resources, including tribal
cultural resources, could be encountered during ground disturbing construction activities. As such, Project-
specific Mitigation Measures TCR-1 through TCR-3 would be implemented to require Native American
monitoring during any ground disturbing activities on the Project site and to avoid potential impacts to tribal
cultural resources that may be unearthed by Project construction activities. With implementation of Mitigation
Measures TCR-1 through TCR-3, impacts to tribal cultural resources would be less than significant.
Snug Harbor Surf Park Project 5.15 Tribal Cultural Resources
City of Newport Beach 5.15-8
Draft EIR
May 2025
IMPACT TCR-2: THE PROJECT WOULD NOT CAUSE A SUBSTANTIAL ADVERSE CHANGE IN THE
SIGNIFICANCE OF A TRIBAL CULTURAL RESOURCE, DEFINED IN PUBLIC RESOURCES
CODE § 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 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 § 5024.1. IN APPLYING THE CRITERIA SET FORTH
IN SUBDIVISION (C) OF PUBLIC RESOURCE CODE § 5024.1, THE LEAD AGENCY SHALL
CONSIDER THE SIGNIFICANCE OF THE RESOURCE TO A CALIFORNIA NATIVE
AMERICAN TRIBE.
Less than Significant Impact with Mitigation Incorporated. As described in the previous response, the
Project site has been heavily disturbed for construction of the existing buildings, golf course, and
infrastructure. The proposed Project involves excavation. As discussed in Impact TCR-1, no substantial
evidence exists that TCRs are present in the Project site. Although, no TCRs have been identified, during the
SB 18/AB 52 consultation, the Gabrieleño Band of Mission Indians – Kizh Nation detailed that the proposed
Project lies within its ancestral tribal territory within a potentially sensitive area and the Gabrieleño Tongva
Indians of California stated that the Project location is within sensitive Tribal area. Therefore, to avoid
potential adverse effects to tribal cultural resources, Mitigation Measures TCR-1 through TCR-3 have been
included to provide for Native American resource sensitivity training, monitoring, and to prescribe activities
should any inadvertent discoveries of tribal cultural resources be unearthed by Project construction activities.
Additionally, as described previously, California Health and Safety Code, Section 7050.5, included as PPP
CUL-1, requires that if human remains are discovered in the Project site, disturbance of the site shall halt and
remain halted until the coroner has conducted an investigation. If the coroner determines that the remains
are those of a Native American, he or she shall contact, by telephone within 24 hours, the NAHC. With
implementation of Mitigation Measures TCR-1 through TCR-3 and California Health and Safety Code Section
7050.5, impacts to tribal cultural resources would be less than significant.
5.15.7 CUMULATIVE IMPACTS
The cumulative study area for tribal cultural resources includes the Southern California region, which contains
the same general tribal historic setting of the Gabrieleño and Juaneño/Luiseño Tribes, as detailed previously
in Section 5.15.3, Environmental Setting. Other projects in the vicinity of the proposed Project would involve
ground disturbances that could reveal buried tribal cultural resources.
Cumulative impacts to tribal cultural resources would be reduced by compliance with applicable regulations
and consultations required by SB 18 and AB 52. As described above, the Project site and vicinity is not
known to contain tribal cultural resources; however, Mitigation Measures TCR-1 through TCR-3 would be
implemented to ensure that impacts would not occur in the case of an inadvertent discovery of a potential
tribal cultural resource. This mitigation measure would ensure that the proposed Project would not contribute
to a cumulative loss of tribal cultural resources. Therefore, cumulative impacts would be less than significant.
5.15.8 EXISTING REGULATIONS AND PLANS, PROGRAMS, OR POLICIES
The following would reduce potential impacts related to tribal cultural resources.
Snug Harbor Surf Park Project 5.15 Tribal Cultural Resources
City of Newport Beach 5.15-9
Draft EIR
May 2025
Existing Regulations
• California Government Code Sections 5097.9-5097.99
• California Health and Safety Code Section 7050.5
• California Public Resources Code Sections 21073 et seq. (AB 52)
Plans, Programs, or Policies
PPP CUL-1: Human Remains. California Health and Safety Code Section 7050.5, CEQA Guidelines Section
15064.5, and Public Resources Code Section 5097.98 mandate the process to be followed in the event of
an accidental discovery of any human remains in a location other than a dedicated cemetery. California
Health and Safety Code Section 7050.5 requires that in the event that human remains are discovered within
the project site, disturbance of the site shall be halted until the coroner has conducted an investigation into
the circumstances, manner and cause of death, and the recommendations concerning the treatment and
disposition of the human remains have been made to the person responsible for the excavation, or to his or
her authorized representative, in the manner provided in Section 5097.98 of the Public Resources Code. 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.
5.15.9 PROJECT DESIGN FEATURES
None.
5.15.10 LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Upon implementation of regulatory requirements, Impacts TCR-1and TCR-2 would be potentially significant.
5.15.11 MITIGATION MEASURES
Mitigation Measure TCR-1: Retain Native American Monitors Prior to Commencement of Ground-
Disturbing Activities
A. The Project plans, specifications, and grading permits shall state that the Project applicant shall retain
Native American monitor(s). The monitor(s) shall be retained prior to the commencement of any “ground-
disturbing activity” for the Project (both onsite and any offsite locations that are included in the Project
description and/or required in connection with the proposed Project, such as public improvement work).
“Ground-disturbing activity” shall include, but is not limited to, demolition, pavement removal, potholing,
auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching.
B. A copy of the executed monitoring agreement(s) shall be submitted to the Lead Agency prior to the
earlier of the commencement of any ground-disturbing activity, or the issuance of any permit necessary
to commence a ground-disturbing activity.
C. The monitor(s) shall complete daily monitoring logs that shall provide descriptions of the relevant ground-
disturbing activities, the type of construction activities performed, locations of ground-disturbing
activities, soil types, cultural-related materials, and any other facts, conditions, materials, or discoveries
of significance to the tribe(s). Monitor logs shall identify and describe any discovered TCRs, including
but not limited to, Native American cultural and historical artifacts, remains, places of significance, etc.,
(collectively, tribal cultural resources, or “TCR”), as well as any discovered Native American (ancestral)
Snug Harbor Surf Park Project 5.15 Tribal Cultural Resources
City of Newport Beach 5.15-10
Draft EIR
May 2025
human remains and burial goods. Copies of monitor logs shall be provided to the Project applicant upon
written request to the tribe(s).
D. Onsite tribal monitoring shall conclude upon the earlier of the following (1) written confirmation to the
monitoring tribe(s) from a designated point of contact for the Project applicant or Lead Agency that all
ground-disturbing activities and phases that may involve ground-disturbing activities on the Project site
or in connection with the Project are complete; or (2) a determination and written notification by the
monitoring tribe(s) to the Lead Agency that no future, planned construction activity and/or
development/construction phase at the Project site possesses the potential to impact TCRs.
Mitigation Measure TCR-2: Unanticipated Discovery of Tribal Cultural Resource Objects (Non-
Funerary/Non-Ceremonial)
A. Upon discovery of any TCRs, all construction activities in the immediate vicinity of the discovery shall
cease (i.e., not less than the surrounding 50 feet) and shall not resume until the discovered TCR has been
fully assessed by a Native American monitor in consultation with a qualified archaeologist. The
monitoring tribe(s) shall recover and retain all discovered TCRs in the form and/or manner the tribe(s)
deems appropriate, in the tribe(s) sole discretion, and for any purpose the tribe(s) deems appropriate,
including for educational, cultural and/or historic purposes.
Mitigation Measure TCR-3: Unanticipated Discovery of Human Remains and Associated Funerary or
Ceremonial Objects
A. Native American human remains are defined in PRC 5097.98 (d)(1) as an inhumation or cremation, and
in any state of decomposition or skeletal completeness. Funerary objects, called associated grave goods
in Public Resources Code Section 5097.98, are also to be treated according to this statute.
B. If Native American human remains and/or grave goods are discovered or recognized on the Project
site, then Public Resource Code 5097.9 as well as Health and Safety Code Section 7050.5 shall be
followed.
C. Human remains and grave/burial goods shall be treated alike per California Public Resources Code
section 5097.98(d)(1) and (2).
D. Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human
remains and/or burial goods.
E. Any discovery of human remains/burial goods shall be kept confidential to prevent further disturbance.
5.15.12 LEVEL OF SIGNIFICANCE AFTER MITIGATION
With implementation of Mitigation Measures TCR-1 through TCR-3, impacts would be less than significant.
5.15.13 REFERENCES
City of Newport Beach. (2001, January). Santa Ana Heights Specific Plan. Retrieved September 23, 2024,
from ocpublicworks.com.
City of Newport Beach. (2006a, July). General Plan. Retrieved September 23, 2024, from
newportbeachca.gov: https://www.newportbeachca.gov/government/departments/community-
development/planning-division/general-plan-codes-and-regulations/general-plan
City of Newport Beach. (2006b, July). General Plan Environmental Impact Report. Retrieved September 23,
2024, from newportbeachca.gov:
https://www.newportbeachca.gov/government/departments/community-development/planning-
division/general-plan-codes-and-regulations/general-plan/general-plan-environmental-impact-
repor
Snug Harbor Surf Park Project 5.15 Tribal Cultural Resources
City of Newport Beach 5.15-11
Draft EIR
May 2025
City of Newport Beach. (2024, May). Newport Beach Municipal Code. Retrieved September 23, 2024,
from codepublishing.com: https://www.codepublishing.com/CA/NewportBeach/
Glenn Lukos Associates. (2024, October). Phase I Archaeological Resources Assessment for the Surf Farm
Project. (Appendix E)
Snug Harbor Surf Park Project 5.15 Tribal Cultural Resources
City of Newport Beach 5.15-12
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-1
Draft EIR
May 2025
5.16 Utilities and Service Systems
5.16.1 INTRODUCTION
This section of the Draft EIR evaluates the potential effects on utilities and service systems from implementation
of the proposed Project by identifying anticipated demand and existing and planned utility availability.
This includes water supply and infrastructure, wastewater, drainage, and solid waste, electric power, natural
gas, and telecommunications. Information in this section is based, in part, on the following documents and
resources:
• City of Newport Beach General Plan, 2006
• City of Newport Beach General Plan Environmental Impact Report (General Plan EIR), 2006
• City of Newport Beach Municipal Code
• Water Supply Evaluation, prepared by Fuscoe Engineering, Inc., 2024, included as Appendix S
• Water Demand Report, prepared by Fuscoe Engineering, Inc., 2024, included as Appendix T
• Sewer Analysis Report, prepared by Fuscoe Engineering, Inc., 2024, included as Appendix U
• Preliminary Hydrology Report, prepared by Fuscoe Engineering, Inc., 2024, included as Appendix P
• Engineering Analysis Report, prepared by Southern California Edison, 2024, included as Appendix G
Because CEQA focuses on physical environmental effects, this section analyzes whether increases in demand
for utilities as a result of implementation of the Project would result in significant adverse physical
environmental effects. For example, an increase in wastewater generation, by itself, would not be considered
a physical change in the environment; however, physical changes in the environment resulting from the
construction of new facilities or an expansion of existing wastewater facilities could constitute a significant
impact under CEQA.
5.16.2 WATER
5.16.2.1 Water Regulatory Setting
State Regulations
California Urban Water Management Planning Act
Section 10610 of the California Water Code established the California Urban Water Management Planning
Act (CUWMPA), which requires urban water suppliers to initiate planning strategies to ensure an appropriate
level of reliability in its water service. CUWMPA states that every urban water supplier that provides water
to 3,000 or more customers, or that annually provides more than 3,000 acre-feet of water service, should
make every effort to ensure the appropriate level of reliability in its water service to meet the needs of its
various categories of customers during normal, dry, and multiple-dry years. The CUWMPA describes the
contents of UWMP’s as well as methods for urban water suppliers to adopt and implement the plans.
Water Conservation Act of 2009, Senate Bill X7-7
The Water Conservation Act of 2009 (Senate Bill [SB] X7-7) was enacted in November 2009 and requires
that all water suppliers increase their water use efficiency. SB X7-7 set the goal of achieving a 20 percent
reduction in urban per capita water use statewide by 2020. Retail water agencies were required to set
targets and track progress toward decreasing daily per capita urban water use in their service areas, in
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-2
Draft EIR
May 2025
order to assist the State in meeting its 20 percent reduction goal by 2020. The City of Newport Beach is
responsible for preparing a UWMP in compliance with SB X7-7.
Senate Bill 610
Senate Bill (SB) 610 requires public urban water suppliers with 3,000 or more service connections to identify
existing and planned sources of water for planned developments of a certain size. It further requires the
public water system to prepare a specified water supply assessment (WSA) for projects that meet the
following criteria:
1. A proposed residential development of more than 500 dwelling units;
2. A proposed shopping center employing more than 1,000 persons or having more than 500,000 square
feet of floor space;
3. A commercial office building employing more than 1,000 persons or having more than 250,000 square
feet of floor space;
4. A hotel or motel, or both, with more than 500 rooms;
5. An industrial, manufacturing, or processing plant, or industrial park planned to house more than 1,000
persons, occupying more than 40 acres of land, or having more than 650,000 sf of floor area;
6. A mixed-use project that includes one or more of the projects above; and
7. A project that would demand an amount of water equivalent to, or greater than, the amount of water
required by a 500-dwelling unit project.
The components of a WSA include existing water demand, future water demand by the project, and must
ensure that water is available for the project during normal years, a single dry year, and multiple dry years
during a 20-year future projection period. The WSA must also describe whether the project’s water demand
is accounted for in the water supplier’s UWMP. Supplies of water for future water supply must be
documented in the WSA.
The Project does not require preparation of a WSA under the WSA criteria (1) through (6) above. As
described below, the Project also does not meet WSA criteria (7) because it would not demand an amount
of water equivalent to or greater than the amount required by a 500-dwelling unit project.
As detailed in Table 5.16-1, the water demand for 500-dwelling units in Newport Beach in 2024 is estimated
to be 120.49 acre-feet yearly (AFY), which is more than the net water demand of the proposed Project (87
AFY), as determined in Table 5.16-9, below. Thus, a WSA for the proposed Project is not required. However,
a Water Supply Evaluation (included as Appendix S) was prepared to ensure the City’s water supplies are
adequate to serve the Project.
Table 5.16-1: City of Newport Beach 500 Residential Unit Water Demand
Average Residential
Water Demand
(AFY/Person)
Average Persons Per
Residential Unit
Water Use Factor
(AFY/DU)
Water Demand –
500 DUs
(AFY)
0.11 2.13 0.24 120.49
Source: Water Supply Evaluation, Appendix S
CALGreen Building Code
California Code of Regulations Title 24, Part 11, establishes the California Green Building Standards Code,
or “CALGreen.” The CALGreen Code is updated every three years. It was recently updated in 2022 and
became effective January 1, 2023. CALGreen sets forth water efficiency standards (i.e., maximum flow
rates) for all new plumbing and irrigation fittings and fixtures. The City of Newport Beach has adopted
CALGreen within Municipal Code Chapter 15.11.
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-3
Draft EIR
May 2025
Local and Regional Regulations
City of Newport Beach General Plan 2006
The City of Newport Beach General Plan contains the following policies related to water resources that are
applicable to the Project:
Policy LU 2.8 Adequate Infrastructure. Accommodate the types, densities, and mix of land uses that can
be adequately supported by transportation and utility infrastructure (water, sewer, storm
drainage, energy, and so on) and public services (schools, parks, libraries, seniors, youth,
police, fire, and so on).
Policy NR 1.1 Water Conservation in New Development. Enforce water conservation measures that limit
water usage, prohibit activities that waste water or cause runoff, and require the use of
water–efficient landscaping and irrigation in conjunction with new construction projects.
Policy NR 1.2 Use of Water Conserving Devices. Establish and actively promote use of water conserving
devices and practices in both new construction and major alterations and additions to
existing buildings. This can include the use of rainwater capture, storage, and reuse facilities.
Municipal Code
Chapter 14.16 Water Conservation and Water Supply Shortage Program. This chapter establishes a water
conservation and supply shortage program. The water conservation and supply program aims to complete
the following: reduce water consumption within the City, enable water supply planning, ensure reasonable
and beneficial use of water, complement the City’s water quality regulations and urban runoff reduction
efforts, minimize the effect and hardship of water shortages, and implement the City’s Water Shortage
Contingency Plan. The chapter establishes permanent water conservation requirements and water supply
shortage response actions during times of a declared water shortage.
Chapter 14.17 Water-Efficient Landscaping. This chapter establishes reasonable procedures and standards
for the design, installation, and maintenance of water-efficient landscapes in conjunction with new construction
projects within the City to promote the conservation and efficient use of water in the City and prevent the
waste of available water resources.
5.16.2.2 Water Environmental Setting
The Project site is located within the water service area of the City of Newport Beach, which provides potable
water, recycled water, and wastewater services to an area of approximately 11 square miles along the
Orange County of Southern California and covers most of the City’s boundaries with the remaining areas
served by Irvine Ranch Water District (IRWD) and Mesa Water District. The City’s water system includes a
wellfield with a total capacity of 10,900 gallons per minute (gpm), 15 recycled water connections, 6 inter-
agency emergency interconnections and manages about 300-mile water mains system with 26,765 service
connections. (City of Newport Beach, 2021).
The City of Newport Beach has a diverse portfolio of local and imported water supplies to deliver treated
water to its customers. Water supplies include recycled water, local groundwater, and imported water.
Imported water supplies are received from Colorado River and the State Water Project (SWP) provided
by the Metropolitan Water District of Southern California (MET) and delivered through the Municipal Water
District of Orange County (MWDOC).
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-4
Draft EIR
May 2025
Water Supply and Demand
The City of Newport Beach has three sources of water supply: imported water from the MET, local
groundwater, and recycled water (City of Newport Beach, 2021). The City’s water supply is a combination
of purchased or imported water, groundwater, and recycled water. As shown on Table 5.16-2, in 2020 the
City obtained the majority of its potable water supply from groundwater from the Orange County
Groundwater Basin.
Table 5.16-2: City of Newport Beach Water Supply 2020
Water Supply Source Volume
(acre-feet)
Groundwater (not desalinated) Orange County Groundwater Basin 10,237
Purchased or Imported Water MWDOC 4,255
Recycled Water Orange County Water District (OCWD) 513
Retail Total 15,005
Source: (City of Newport Beach, 2021)
Table 5.16-3 summarizes the City of Newport Beach’s projected water supplies. As shown, the City water
supplies are anticipated to be obtained through a similar mix of purchased or imported water, groundwater,
and recycled water through 2045.
Table 5.16-3: City of Newport Beach Projected Water Supply (AF)
Water Supply Source 2025 2030 2035 2040 2045
Groundwater
(not desalinated)
Orange County
Groundwater Basin
12,175 12,605 12,729 12,869 12,838
Purchased or Imported
Water MWDOC 2,149 2,224 2,246 2,271 2,265
Recycled Water Orange County Water
District (OCWD)
542 542 542 542 542
Retail Total 14,866 15,371 15,517 15,682 15,645
Source: (City of Newport Beach, 2021)
As shown in Table 5.16-3, the 2020 UWMP anticipates that the City’s water supply will increase from
14,866 AF in 2025 to 15,645 AF in 2045 (increase of 779 AF) to meet the City’s anticipated growth in
water demands. Projected demands for the 2020 UWMP were developed using information about planned
development, land use, and Southern California Association of Governments (SCAG) projections. The City’s
retail demand projections include the water savings needed to meet the Water Conservation Act of 2009,
SB X7-7 requirements.
The City has the ability to purchase additional supplies of water, if necessary. In addition, the City and other
regional water supply users have identified capital improvement program projects to support regional water
supply reliability, which include new water wells and pipelines, rehabilitated water wells, and treatment
systems to remove contaminants from water (Appendix S).
The 2020 UWMP details the ability of the City to meet the anticipated water demands through 2045 in a
five consecutive dry year scenario. Existing and projected water demands by different uses in the City are
listed in Table 5.16-4.
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-5
Draft EIR
May 2025
Table 5.16-4: City Actual and 2020 UWMP Projected Demands for Water in Acre-Feet (AFs)
Use Type Actual
2020
Projected
2025
Projected
2030
Projected
2035
Projected
2040
Projected
2045
Single-Family 6,750 6,385 6,294 6,202 6,111 6,077
Multi-Family 1,782 1,729 1,691 1,653 1,615 1,614
Commercial 2,463 2,762 3,334 3,584 3,853 3,853
Institutional/Governmental 173 194 234 251 270 270
Landscape1 2,629 2,616 2,616 2,616 2,616 2,616
Losses 603 638 661 667 675 673
Other Potable 91 0 0 0 0 0
Potable Total 14,492 14,324 14,829 14,975 15,140 15,103
Recycled Water 513 542 542 542 542 542
Total 15,005 14,866 15,371 15,517 15,682 15,645
1 Represents large landscape (with irrigation meters) served by potable water and not recycled water
Source: (City of Newport Beach, 2021)
Groundwater. The City of Newport Beach produces potable groundwater from the Orange County
Groundwater Basin, which is managed by the Orange County Water District (OCWD). The Basin is classified
as a medium priority basin, due to the regional reliance on the Basin’s groundwater supplies. The Basin is not
currently experiencing overdraft conditions. The City pumps groundwater through four wells found in the
City. Additionally, the golf course is currently irrigated via well water.
The City’s access to groundwater allows the City to shift its reliance to groundwater during single dry years
and consecutive dry years. The local groundwater basins act as a large reservoir, storing water during wet
years and allowing the City to meet its demands during dry periods.
Imported Water. The City of Newport Beach is a member agency of Metropolitan Water District of Southern
California (MET) and relies on MET to provide approximately 28.5 percent of its water supply and a small
percent of its non-potable water supply.
In the 2020 MET UWMP, the reliability of water deliveries from the State Water Project and the Colorado
River Aqueduct were assessed by Metropolitan. Metropolitan determined that its water sources will continue
to provide a reliable supply to its member agencies during normal, single dry, and multiple-dry years during
the UWMP planning horizon. Unprecedented shortages are addressed in the Water Shortage Contingency
Analysis and Catastrophic Supply Interruption Planning portions of the MET UWMP.
Recycled Water. The City has over 3,200 catch basins and over 95 miles of storm drain pipe that divert
stormwater to the wastewater system. Wastewater is treated at OCWD’s Green Acres Project (GAP) and/or
Groundwater Replenishment System (GWRS) to produce recycled water that is used for irrigation and
groundwater recharge purposes. OCWD’s GWRS allows the region to decrease its dependency on imported
water and creates a local and reliable source of water. OCWD’s GWRS purifies secondary treated
wastewater from the Orange County Sanitation District (OC San) Wastewater Treatment Plant No.1 located
in Fountain Valley to levels that meet and exceed all State and federal drinking water standards. After
purification, treated water from GWRS is injected into the Talbert Seawater Barrier and into the
groundwater basin (City of Newport Beach, 2021). The GWRS provides for a continuous loop of water re-
use.
The GWRS has a current production capacity of 130 million gallons of water per day. Approximately 30
million gallons per day (MGD) of GWRS water is pumped into injection wells in Huntington Beach and
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-6
Draft EIR
May 2025
Fountain Valley to create a seawater intrusion barrier. Approximately 10 MGD are piped to the Mid-Basin
injection wells in Santa Ana, and 90 MGD are pumped daily to percolation basins in Anaheim where the
GWRS water naturally filters through sand and gravel to the deep aquifers of the groundwater basin to
increase the drinking water supply (OCWD 2025).
In 2020, approximately 85 AFY of recycled water was used in the City’s service area for landscape
irrigation and 428 AFY for golf course irrigation, about 3.5 percent of the City’s annual water demand (City
of Newport Beach, 2021).
Demand. The City only delivers water to retail customers. The City’s primary retail customers can be divided
into residential, commercial, institutional, and landscape sectors with the single-family residential sector being
the City’s largest customer segment. In Fiscal Year (FY) 2019-20, the City’s total water use was 15,005 AF,
which included 14,492 AF of potable water and 513 AF of direct recycled water for landscape irrigation.
During this time, the potable water use profile consisted of 58.9 percent residential consumption, 18.2
percent commercial, institutional, and industrial uses, and 18.1 percent for large landscape irrigation.
The City also tracks its annual calendar year (CY) water use under varying land use categories and for CY
2021 through 2023 potable water use ranged from approximately 13,960 AF in 2021 to 11,830 AF in
2023. Table 5.16-5 outlines the City’s actual potable water demand by land use from 2021 to 2023.
Table 5.16-5: City Actual 2021 through 2023 Potable Water Demand in Acre-Feet (AFs)
Use 2021 2022 2023
Single-Family 6,820 6,339 5,732
Multi-Family 1,850 1,735 1,634
Commercial 2,260 2,322 2,231
City Meter 209 213 169
Sprinkler 2,220 2,199 1,617
City Sprinkler 514 476 374
Boat Dock 18 15 12
Fire 6 6 5
Pool 61 57 55
Pump Station 1 0 0
Total Potable 13,960 13,363 11,830
Source: Water Supply Evaluation, Appendix S
Table 5.16-5 demonstrates that the City’s actual water use between 2021 through 2023 was 1,045 AF less
than the actual use in 2020 and 906 AF less than the projected use in 2025.
Project Site Water Demand. Over the past four years (2020-2023), well production for the golf course
irrigation purposes has averaged approximately 91,796 gallons per day (GPD) or 103 AFY. These totals
represent the full water demand for the entire 18-hole golf course of which the proposed Project only
occupies three; and thus, assumed to be 16.7 percent of the total. During this same period, potable water
uses for commercial activities on the Project site buildings and amenities averaged 1,389 GPD or
approximately 1.6 AFY. Combined, the total water demand (irrigation and commercial) for the 18-hole golf
course and commercial averages about 93,786 GPD or 104 AFY, as shown on Table 5.16-6.
Based on the average irrigation demand per hole, the three holes in the Project site have an average
irrigation demand of approximately 15,300 GPD or 17.2 AFY. The total existing demand from the three
holes and the commercial on the Project site is approximately 16,689 GPD or 18.7 AFY (Appendix S).
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-7
Draft EIR
May 2025
Table 5.16-6: Existing Newport Beach Golf Course and Project Site Water Demands
Existing Irrigation Demand – Groundwater Well Production
2020 29,750,000 gallons
2021 34,787,764 gallons
2022 36,267,270 gallons
2023 33,823,328 gallons
Average Demand 2020-2023
(18-Hole Course)
91,796 GPD
103 AFY
Estimated Project Site Demand 2020-2023
(3-Hole Course)
15,300 GPD
17.2 AFY
Existing Commercial Demands – Potable Water
July 2022 - June 2023 529,584 gallons
July 2023- June 2024 484,704 gallons
Average Demand FY 22-23 & 23-24 1,389 GPD
1.6 AFY
Total Existing Demand (Irrigation + Commercial)
18-Hole Course + Commercial Demands 93,786 GPD
104 AFY
Project Site Demand (3-Hole Course + Commercial) 16,689 GPD
18.7 AFY
Source: Water Supply Evaluation, Appendix S
Water Infrastructure
The Project site is currently served by the City of Newport Beach’s water utility. The City‘s water infrastructure
includes a wellfield with a total capacity of 10,900 gallons per minute (GPM), 15 recycled water connections,
and six inter-agency emergency interconnections. The City’s water distribution network consists of
approximately 300 miles of pipelines, serving 26,765 connections. This distribution system is divided into
five main pressure zones (Zones 1 through 5) and 16 minor zones. Zones 1 and 2 are the largest and meet
the majority of City’s demands, while Zones 3, 4, and 5 are smaller pumped zones. The Project site is located
within Pressure Zone 2. Supporting this system are four wells, three storage reservoirs, five pump stations,
and 43 pressure-reducing stations (PRS) that manage water pressure across the network (Appendix S).
An existing 24-inch domestic water line is located in Irvine Avenue adjacent to the Project site. Additionally,
the golf course is currently irrigated via onsite well water.
5.16.2.3 Water Thresholds of Significance
Appendix G of the CEQA Guidelines indicates that a Project could have a significant effect if it were to:
UTIL-1 Require or result in the construction of new water facilities, or expansion of existing facilities, the
construction of which could cause significant environmental effects; or
UTIL-2 Have sufficient water supplies available to serve the project and reasonably foreseeable future
development during normal, dry, and multiple dry years.
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-8
Draft EIR
May 2025
5.16.2.4 Water Service Methodology
The evaluation of water supply quantifies the amount of water that would be required to support operation
of the proposed Project and compares the demand to the City of Newport Beach’s available water supply
to identify if sufficient water supplies are available to serve the proposed Project and reasonably
foreseeable development during normal, dry, and multiple dry years. Additionally, the existing water supply
infrastructure that serves the Project site was identified and evaluated to ensure design capacity would be
adequate to supply the proposed Project, or to identify if expansions would be required to serve the
proposed development.
5.16.2.5 Water Environmental Impacts
IMPACT UTIL-1: THE PROJECT WOULD NOT REQUIRE OR RESULT IN THE RELOCATION OR
CONSTRUCTION OF NEW WATER FACILITIES, OR EXPANSION OF EXISTING
FACILITIES, THE CONSTRUCTION OF WHICH COULD CAUSE SIGNIFICANT
ENVIRONMENTAL EFFECTS.
Less than Significant Impact.
The proposed Project would construct onsite water lines to connect to the existing 24-inch water line in Irvine
Avenue that are served by the City of Newport Beach. Fire flow calculations were prepared as part of the
Water Demand Report (Appendix T) to determine if the existing City water infrastructure is sufficient to
provide adequate fire flows, pressure, and hydrant operation for the proposed Project. The existing 24-inch
waterline in Irvine Avenue provides domestic water and fire suppression services to the Project site through
three fire hydrants on Irvine Avenue, adjacent to the Project site. Fire hydrant test results show that the
existing 24-inch waterline has an available calculated flow of 5,969 gpm at 20 psi, which would be
available for fire suppression operations. This available flow is higher than the required fire flow of 2,500
gpm at 20 psi (Appendix T). Therefore, the Water Demand Report determined that the existing water
infrastructure and fire flow is adequate to serve the proposed Project, and no extensions or offsite new
water facilities would be required.
The construction activities related to the new onsite water infrastructure for the proposed lagoon, restrooms,
athlete accommodations, and clubhouse are included as part of the Project and would not result in any
physical environmental effects beyond those identified throughout this Draft EIR. For example, construction
emissions for excavation and installation of the water infrastructure is included in Sections 5.2, Air Quality,
and 5.7, Greenhouse Gas Emissions. Therefore, the proposed Project would not result in the construction of
additional new water facilities or expansion of existing facilities, the construction of which could cause
significant environmental effects. Impacts would be less than significant.
IMPACT UTIL-2: THE PROJECT WOULD 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 Water Supply Evaluation for the proposed Project describes that the daily operations of the proposed
surf lagoon would require refilling of water from water evaporation that occurs naturally from the surface
of the wave lagoon due to surrounding temperature, humidity, pressure, surface area, and wind conditions.
In Newport Beach, the annual mean temperature is 66 degrees Fahrenheit, thus evaporation is a major factor
in the Project’s water demand. Other water losses in the system can occur from various sources including
spillage from wave splash, losses in pipes, basin leakages, users carrying water out, water treatment
housekeeping, filter cleaning, and filter backwash.
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-9
Draft EIR
May 2025
In addition, annual needs for water supplies would occur from re-filling one of the 5.1-million-gallon basins.
One of the surf basins would be drained annually, facility maintenance would occur, and then the basin
would be refilled. This timing would be coordinated via permit with the City of Newport Beach Utilities
Department that provides water to the Project site. A limited volume of rainfall would also provide water to
supplement the lagoon water. The total annual water demand for the surf lagoon is 22.7 million gallons per
year or 69.8 AFY as detailed in Table 5.16-7.
Table 5.16-7: Proposed Surf Lagoon Water Demands
Water Requirements for Routine Surf Lagoon Maintenance
Gallons/Year Gallons/Day AFY
Draining of the Lagoon
(Frequency Annually) 5,100,000 13,973 15.65
Filter Cleaning of the Lagoon
(Frequency 77 times per year) 45,067 123 0.14
Total Water Requirements for Routine Maintenance 5,145,067 14,096 15.79
Water Requirements for Lagoon Operation
Average Temperature 66°F
Open Water Evaporation Estimate (gal/year) 12,966,764 35,525 39.79
Wave Operation Factor 1.45
Backwash losses (gal/year) 192,867 528 0.59
Average Evaporation Water Loss (gal/year) 51,572 141 0.16
Operating Water Loss (gal/year) 18,994,674 52,040 58.29
Annual Rainfall (11 inches) 1,396,018 3,825 4.28
Total Water Requirement for Annual Operation 17,598,655 48,215 54.01
Total Water Requirement
Routine Maintenance + Annual Operation 22,743,722 62,312 69.80
Source: Water Supply Evaluation, Appendix S
The Water Supply Evaluation (Appendix S) for the proposed Project also describes that community
commercial uses have a water demand of 175 gallons per 1,000 square feet per day and that hotels have
a water demand of approximately 160 gallons per room per day. Table 5.15-8 shows that based on these
rates, the proposed clubhouse and athlete accommodations would result in a water demand of 16,733 GPD
or 18.74 AFY.
Table 5.16-8: Proposed Clubhouse and Athlete Accommodations Water Demands
Use Amount Average Unit Flow Average Flow
(GPD)
Average Flow
(AFY)
Clubhouse and Standalone Restrooms 69,216 SF 0.175 GPD/SF 12,113 13.57
Athlete Accommodations 20 units 160 GPD/unit 3,200 3.58
Showers for Lagoon 9 showers 54 GPD/Shower 486 0.54
Pools and Spa 3 pools
1 spa Based on size 931 1.04
Total 16,733 18.74
Source: Water Supply Evaluation, Appendix S
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-10
Draft EIR
May 2025
Net Change In Water Demands. The redevelopment of the Project site would reduce the golf course use of
groundwater for irrigation; however, use of potable water would increase. As shown in Table 5.16-9, the
net increase in water demand from the Project is estimated at 79,045 GPD or 85 AFY, while the existing
water use for the golf course (from wells) and current commercial amenities (potable water) total
approximately 16,689 GPD or 18.7 AFY. This would result in a net increase in water demand of 62,356
GPD or 70 AFY. However, assuming the Project uses all potable water (and no well water), the net change
in potable water demand would be an increase of approximately 77,656 GPD or 87 AFY.
Table 5.16-9: Net Change in Water Demands
Use GPD AFY
Proposed Water Use
Surf Lagoon 62,312 69.80
Clubhouse and Accommodations 16,733 18.74
Total Project Water Demands 79,046 88.54
Existing Water Use
Golf Course 3 Holes 15,299 17.14
Pro Shop, Clubhouse, and Restaurant 1,389 1.56
Total Existing Water Demands 16,689 18.70
Net Change in Overall Water Demand 62,356 70
Net Increase in Potable Water Demand 77,656 87
Source: Water Supply Evaluation, Appendix S
As detailed previously in Table 5.16-3, the City’s 2020 UWMP projects an increase in water demand from
14,866 AF in 2025 to 15,371 AF in 2030, which is an increase of 505 AF. The 2020 UWMP bases water
demand projections on population growth projections from the Center for Demographic Research at
California State Fullerton and planned land uses based on zoning designations. The Project’s annual demand
if 87 AF of potable water would be 17.2 percent of the anticipated increase in water demand between
2025 and 2030. The UWMP also notes that additional water may be purchased from the Metropolitan
Water District of Southern California without the need to construct new infrastructure or sources.
This is conservative; as described previously, Table 5.16-5 demonstrates that the City’s actual water use
between 2021 through 2023 was 1,045 AF less than the water used in 2020 and 906 AF less than the
projected use in 2025. Thus, the increase in water demand from the Project is within projected increases in
needed water supplies that the City will be able to provide in normal, dry, and multiple dry years. In
addition, the 2020 UWMP details the City’s ability to access groundwater resources and purchase additional
supplies of water, if necessary (Appendix S). Therefore, the City would have sufficient water supplies
available to serve the project and reasonably foreseeable future development during normal, dry, and
multiple dry years, and impacts would be less than significant.
In addition, the majority of water used by the Project would become wastewater that would be conveyed
to the OC San Wastewater Treatment Plan No.1 that is treated and then conveyed to the OCWD GWRS
system that further purifies water to meet all State and federal drinking water standards and then injects it
into the groundwater basin providing a loop of water supply and re-use. Therefore, a majority of the water
used by the Project (except for irrigation water and evaporation) would become wastewater that would be
purified and then reinjected into the groundwater basin for reuse.
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-11
Draft EIR
May 2025
5.16.2.6 Water Cumulative Impacts
Cumulative water supply impacts are considered on a water purveyor basis based on growth projections
and are associated with the capacity of the infrastructure system and the adequacy of the water purveyor’s
infrastructure and primary sources of water that include groundwater, surface water, and purchased or
imported water.
As described previously, the Project site would connect to the existing water infrastructure that is adjacent to
the site in Irvine Avenue and would not require construction of any expanded or new City infrastructure to
serve the Project. The construction activities related to the proposed onsite water infrastructure are included
as part of the Project and would not result in any physical environmental effects beyond those identified
throughout this Draft EIR. Thus, potential cumulative impacts from offsite water system expansions would not
be generated by the Project.
As discussed above, the Project would result in a net annual water demand of 87AF, which is within the
projected demand calculated for the Project site by the 2020 UWMP. As determined by the 2020 UWMP,
it is anticipated that existing and future water entitlements from groundwater, surface water, and purchased
or imported water sources, plus recycling and conservation, would be sufficient to meet the Project's demand
in addition to forecast demand for the City's entire service area. Further, a majority of the water used by
the Project would become wastewater that would be recycled for re-use by the OCWD GWRS system and
injected back into the groundwater basin. Therefore, the Project would not result in a cumulatively
considerable increase in water supply demands that would require new or expanded water sources that
could result in an environmental impact. Therefore, cumulative impacts would be less than significant.
5.16.2.7 Water Existing Regulations
The following standard regulations would reduce potential impacts related to water:
• California Code of Regulations Title 24, Part 11, the California Green Building Standards Code
• Municipal Code Chapter 14.16, Water Conservation and Water Supply Shortage Program
• Municipal Code Chapter 14.17, Water-Efficient Landscaping
5.16.2.8 Water Project Design Features
None.
5.16.2.9 Water Level of Significance Before Mitigation
Impacts UTIL-1 and UTIL-2 would be less than significant.
5.16.2.10 Water Mitigation Measures
No mitigation measures are required.
5.16.2.11 Water Level of Significance After Mitigation
Impacts would be less than significant.
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-12
Draft EIR
May 2025
5.16.3 WASTEWATER
5.16.3.1 Wastewater Regulatory Setting
Local and Regional Regulations
City of Newport Beach General Plan 2006
The City of Newport Beach General Plan contains the following policies related to wastewater that are
applicable to the Project:
Land Use Element
Policy LU 2.8 Adequate Infrastructure. Accommodate the types, densities, and mix of land uses that can
be adequately supported by transportation and utility infrastructure (water, sewer, storm
drainage, energy, and so on) and public services (schools, parks, libraries, seniors, youth,
police, fire, and so on).
Policy LU 3.2 Growth and Change. Enhance existing neighborhoods, districts, and corridors, allowing for
re-use and infill with uses that are complementary in type, form, scale, and character.
Changes in use and/or density/intensity should be considered only in those areas that are
economically underperforming, are necessary to accommodate Newport Beach’s share of
projected regional population growth, improve the relationship, and reduce commuting
distance between home and jobs, or enhance the values that distinguish Newport Beach as
a special place to live for its residents. The scale of growth and new development shall be
coordinated with the provision of adequate infrastructure and public services, including
standards for acceptable traffic level of service.
Natural Resources Element
Policy NR 5.1 City Sewer Management and Master Plans. Implement the Sewer System Management
Plan and the Sewer Master Plan.
Policy NR 5.2 Waste Discharge Permits. Require waste discharge permits for all food preparation
facilities that produce grease.
Policy NR 5.4 Waste Discharge Permits. Comply with the RWQCB’s Waste Discharge Requirements
(WDRs) associated with the operation and maintenance of the City’s sewage collection
system.
5.16.3.2 Wastewater Environmental Setting
Costa Mesa Sanitary District (CMSD) provides sewer system services throughout its service area, which
includes the City of Costa Mesa as well as portions of Unincorporated Orange County and the City of
Newport Beach, including the Project site. The CMSD sewer system consists of sewer mains, manholes, laterals,
pumping stations and pressurized sewer lines (force mains). Sewage is conveyed by CMSD to the Orange
County Sanitation District (OC San) Wastewater Treatment Plant No.1 located in Fountain Valley, which has
a treatment capacity of 174 million gallons per day (gpd) (City of Newport Beach, 2006), with a typical
daily flow of 124 million gpd (OC San, 2025). Thus, the remaining daily capacity of Wastewater Treatment
Plant No.1 is approximately 50 million gpd.
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-13
Draft EIR
May 2025
As described previously in the recycled water discussion, treated wastewater from the OC San Wastewater
Treatment Plant No.1 is conveyed to the OCWD GWRS system that purifies secondary treated wastewater
to levels that meet all State and federal drinking water standards and then injects it into the Talbert
Seawater Barrier and into the groundwater basin, which creates a loop of water re-use. The GWRS has a
current production capacity of 130 million gallons of water per day. Of this approximatley10 MGD are
piped to the Mid-Basin injection wells in Santa Ana, and 90 MGD are pumped daily to percolation basins
in Anaheim where the GWRS water naturally filters through sand and gravel to the deep aquifers of the
groundwater basin to increase the drinking water supply (OCWD 2025).
The Project site is currently served by an onsite 6-inch sewer lateral that connects to the 12-inch CMSD sewer
main in Mesa Drive that drains westerly toward Irvine Avenue and discharges to a 21-inch sewer main and
then into the Tustin/Irvine Pump Station. From the pump station, the sewer is discharged via a force main to
the Eldon Avenue Pump Station, and then a 24-inch sewer main in Fair Drive that continues via gravity toward
Fairview Road and to Treatment Plant No.1.
The Sewer Study (Appendix U) prepared for the proposed Project monitored existing flows in Mesa Drive,
Irvine Avenue, the Tustin Pump Station, and Fair Drive and determined that the CMSD 12-inch sewer main in
Mesa Drive sewer that currently serves the Project site is 17.4 percent full and has an available peak
capacity of 838 gpm; the CMSD 21-inch sewer line at Irvine Avenue is 27.0 percent full and has an available
peak capacity of 2,583 gpm; the CMSD 21-inch sewer line located upstream form the Tustin Pump Station
is 31.1 percent full and has an available peak capacity of 2,390 gpm; and the 24-inch sewer main in Fair
Drive is 47.1 percent full and has an available peak capacity of 1,551 gpm (Appendix U).
5.16.3.3 Wastewater Thresholds of Significance
Appendix G of the CEQA Guidelines indicates that a Project could have a significant effect if it were to:
UTIL-3 Require or result in the construction of new wastewater facilities, or expansion of existing facilities,
the construction of which could cause significant environmental effects; or
UTIL-4 Result in a determination by the wastewater treatment provider that would serve the project that
it has adequate capacity to serve the project’s projected demand in addition to the provider’s
existing commitments.
5.16.3.4 Wastewater Service Methodology
The evaluation of wastewater infrastructure quantifies the amount of wastewater that would be generated
from operation of the proposed Project and compares the demand to the existing and planned sewer
infrastructure and wastewater treatment plants. The evaluation identifies if expansions would be required
to serve the proposed development, and if those expansions have the potential to result in an environmental
impact.
5.16.3.5 Wastewater Environmental Impacts
IMPACT UTIL-3: THE PROJECT WOULD NOT REQUIRE OR RESULT IN THE RELOCATION OR
CONSTRUCTION OF NEW WASTEWATER FACILITIES, OR EXPANSION OF EXISTING
FACILITIES, THE CONSTRUCTION OF WHICH COULD CAUSE SIGNIFICANT
ENVIRONMENTAL EFFECTS.
Less than Significant Impact. The Project site is currently served by an onsite 6-inch sewer line that connects
to the 12-inch CMSD sewer main in Mesa Drive that drains westerly to a CMSD 21-inch sewer main in Irvine
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-14
Draft EIR
May 2025
Avenue, and then to a 24-inch sewer main in Fair Drive. The existing 6-inch lateral that extends
approximately 42.5 feet offsite to the sewer main would be upgraded to a 12-inch sewer line that would
connect to the existing 12-inch sewer line in Mesa Drive.
A Sewer Analysis Report (Appendix U) was prepared to determine whether the sewer system would be able
to adequately handle the wastewater flows from the proposed Project in addition to existing flows. The
Project would generate wastewater daily from the proposed clubhouse, 20 athlete accommodations,
standalone restrooms, and the nine outdoor showers. As shown on Table 5.16-10, the clubhouse,
accommodations, and outdoor showers would generate 10,408 gpd at full capacity. Table 5.16-11 shows
that operation of the wave lagoon would generate 53,351 gpd. In total, regular operation of the proposed
buildings, restrooms, and outdoor showers would result in a total average wastewater flow of 63,79 gpd
(44.3 gpm) (Appendix U). Using the CMSD peaking factor, the Sewer Analysis Report determined that the
peak wastewater flows would be 111 gpm.
Table 5.16-10: Estimated Wastewater Generation from Operation of Clubhouse and Accommodations
Proposed Clubhouse and
Accommodations
Size (SF) or
Number of Rooms
or Showers
Average Flow
(gpd/Ksf) of
(gpd/key or shower)
Average Flow
(gal/day (gpd))
Average Flow
(mgd)
Clubhouse (sf)
Athlete Accommodations (Rms)
Restroom Building
Showers for Pools/Lagoons
68,478
20
738
9
0.10
150
0.10
54
6,848
3,000
74
486
0.006848
0.003000
0.000074
0.000486
Totals 10,408 0.01041
Source: Sewer Analysis Report, Appendix U
Table 5.16-11: Estimated Wastewater Generation from Operation of Surf Lagoon
Proposed Lagoon, Pools, Spa, Filter Backwash Avg Flow
(m3/year)
Avg Flow
(gal/year)
Avg Flow
(gal/day (gpd))
Avg Flow
(mgd)
Backwash Losses
Lagoon Operation (Filter Clean & Splash out)
Spa (0.1% of lagoon area)
Pools (1.4% of lagoon area)
730
71,895
192,846
18,992,650
19,185
268,597
528
52,035
53
736
0.000528
0.052035
0.000053
0.000736
Total 53,351 0.053351
Source: Sewer Analysis Report, Appendix U
As detailed previously, the 12-inch sewer main in Mesa Drive is 17.4 percent full and has an available peak
capacity of 838 gpm. The 111 gpm peak wastewater flow from the Project is 13.2 percent of the available
capacity. Without the peaking factor, the Project’s operational wastewater flow of 44.3 gpm would be 5.3
percent of the available capacity in the Mesa Drive sewer, which has the least available capacity of the
system leading to the wastewater treatment plant. Thus, under operational conditions, the flows from the
Project would be within the capacity of the existing sewer system.
In addition to typical daily operational wastewater generating conditions, each of the 5.1-million-gallon
basins would be drained once every two years into the sewer system. The two 5.1-million-gallon basins are
hydrologically separate. Each year one of the surf basins would be drained; the timing of which would be
coordinated with CMSD and approved by CMSD permitting.
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-15
Draft EIR
May 2025
As shown on Table 5.16-12, the sewer analysis found that draining a basin at a rate of 727 gpm would be
within the capacity of the existing sewer line in Mesa Drive and take approximately 4.9 days to drain one
basin.
Table 5.16-12: Sewer Flow Conditions with the Proposed Project
Reach Street Pipe
Size
Capacity
@ ¾
full (21-
24”) or
half full
(12”)
(gpm)
Existing
Peak
Flow
(gpm)
Project
Peak
Flow
(gpm)
Total
Proposed
Flow
(gpm)
Proposed
Flow
Depth
Proposed
% Full
Available
Capacity
in Sewer
Pipe
(Proposed)
(gpm)
Number
of Days
to Drain
a 5.1
million
gallon
lagoon
1 Mesa Drive 12” 966 128 111 239 2.85” 23.7% 727 4.9 days
2 Irvine Avenue/
Mesa Drive
21” 3,144 561 111 672 6.23” 29.7% 2,472 1.4 days
3 Irvine Avenue/
Upstream of
Irvine/Tustin
Pump Station
21” 3,110 720 111 831 7.04” 33.5% 2,279 1.6 days
4 Fair Drive 24” 3,071 1,520 111 1,631 11.78” 49.1% 1,440 2.5 days
Source: Sewer Analysis Report, Appendix U
The Irvine Avenue Pump Station and the Eldon Avenue Pump Station (off Fair Drive) would accept wastewater
flows from the site. As shown below in Table 5.16-13, the pump stations have a remaining capacity to
adequately serve the proposed Project which would have a peak flow rate of 111 gpm.
The allowable rate of discharge for the lagoon draining is calculated below by comparing the individual
pump design flow capacity to the total proposed flow to the pump station. Table 5.16-13 shows that it
would take 5.5 days to drain a 5.1-million-gallon basin based on the flow rates at the Irvine Pump Station,
and 3.1 days based on the total flow rates at the Eldon Avenue Pump Station.
Table 5.16-13: Pump Station Flow and Capacity
Pump Station Pump Station
Desing Flow
Total Flow to Pump
Station (Existing &
Proposed) (gpm)
Allowable Discharge
from Wave Lagoon
(Pump Design Capacity
– Total Flow to Pump
Station) (gpm)
Number of Days to
Drain a 5.1 Million
Gallon Basin
Irvine Avenue 1,480 831 649 5.5
Eldon Avenue 2,760 1,631 1,129 3.1
Source: Sewer Analysis Report, Appendix U
The existing sewer pipelines would not be adversely impacted by the wastewater flows associated with the
proposed Project. No upgrades to the existing sewer infrastructure are proposed or required as part of the
proposed Project, other than installing onsite sewers that would connect to the existing offsite system. The
construction activities related to the new onsite sewer system are included as part of the proposed Project
and would not result in any physical environmental effects beyond those identified throughout this EIR. For
example, an analysis of construction emissions for excavation and installation of the sewer infrastructure is
included in Sections 5.2, Air Quality, and 5.7, Greenhouse Gas Emissions, and noise volumes from these
activities are evaluated in Section 5.11, Noise.
As the proposed Project includes facilities to serve the proposed Project and connect to sewers that would
have capacity for the Project, it would not result in the need for construction of other new wastewater facilities
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-16
Draft EIR
May 2025
or expansions, the construction of which could cause significant environmental effects. In addition, the
proposed Project would be required to pay Development Impact Fees which would be used towards
cumulative improvements to the existing sewer system to ensure it continues to meet expected demands.
Therefore, potential impacts related to wastewater infrastructure would be less than significant.
IMPACT UTIL-4: THE PROJECT WOULD NOT RESULT IN A DETERMINATION BY THE WASTEWATER
TREATMENT PROVIDER THAT WOULD SERVE THE PROJECT THAT IT DOES NOT
ADEQUATE CAPACITY TO SERVE THE PROJECT’S PROJECTED DEMAND IN
ADDITION TO THE PROVIDER’S EXISTING COMMITMENTS.
Less than Significant Impact. The proposed Project would result in an increase of wastewater generation
from the site. As discussed above, the proposed Project is expected to result in an increase from 1,409 gpd
to 63,729 gpd of wastewater. Under existing conditions, the OC San Wastewater Treatment Plan No.1,
which serves the Project site, has treatment capacity for approximately 50 million gallons per day of
additional flow, and would have capacity to accommodate the proposed Project’s operational 63,729 gpd
of wastewater. Daily operation of the proposed Project would utilize less than 0.01 percent of the daily
available treatment capacity.
As detailed previously, draining one basin per year (each basin every two years) would be done at a rate
of 649 gpm based on existing infrastructure capacity. This equates to 934,560 gallons per day of
wastewater, which is 1.9 percent of the daily available treatment capacity. Thus, the wastewater treatment
plant has ample capacity, and the proposed Project would result in less than significant impacts related to
wastewater treatment capacity.
5.16.3.6 Wastewater Cumulative Impacts
Cumulative wastewater infrastructure impacts are considered on a systemwide basis and are associated with
the overall capacity of existing and planned infrastructure. The cumulative system evaluated includes the
CMSD sewer system that serves the Project site and conveys wastewater to the OCSD wastewater treatment
and disposal system.
As described previously, with the proposed Project, the sewer system would have sufficient capacity to
handle the increased flows resulting from implementation of the proposed Project. The continued regular
assessment, maintenance, and upgrades of the sewer system by the City and OCSD through DIF would
reduce the potential of cumulative development projects to result in a cumulatively substantial increase in
wastewater such that new or expanded facilities would be required. Thus, increases in wastewater in the
sewer system would result in a less than significant cumulative impact.
5.16.3.7 Wastewater Existing Regulations
The following standard regulations would reduce potential impacts related to wastewater:
• California Code of Regulations Title 24, Part 11, the California Green Building Standards Code
5.16.3.8 Wastewater Project Design Features
None.
5.16.3.9 Wastewater Level of Significance Before Mitigation
Impacts UTIL-3 and UTIL-4 would be less than significant.
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-17
Draft EIR
May 2025
5.16.3.10 Wastewater Mitigation Measures
No mitigation measures are required.
5.16.3.11 Wastewater Level of Significance After Mitigation
Impacts would be less than significant.
5.16.4 STORMWATER DRAINAGE
5.16.4.1 Stormwater Drainage Regulatory Setting
Federal Regulations
National Pollution Discharge Elimination System
Section 402 of the Clean Water Act established the National Pollution Discharge Elimination System (NPDES)
regulates the discharge of pollutants from point sources. The United States Environmental Protection Agency
(USEPA) has authorized California to administer its NPDES permitting program. The NPDES permitting
program prohibits the unauthorized discharge of pollutants from a point source (e.g., pipe, ditch, well) to
waters of the United States. The permitting program addresses municipal, commercial, and industrial
wastewater discharges and discharges from large animal feeding operations. Permittees must verify
compliance with permit requirements by monitoring their effluent, maintaining records, and filing periodic
reports. The program is administered at the local level by the RWQCBs. In California, the federal
requirements are administered by the State Water Resources Control Board (SWRCB), and individual NPDES
permits are issued by the California Regional Water Quality Control Boards (RWQCBs).
Local and Regional Regulations
Orange County Stormwater Program: Drainage Area Management Plan (DAMP)
Section 402(p) of the Clean Water Act requires that municipal NPDES Permits include requirements (1) to
essentially prohibit non-storm water discharges into municipal storm sewers and (2) to control the discharge
of pollutants from municipal storm drains to the maximum extent practicable. In response to this requirement,
the Orange County Drainage Area Management Plan (DAMP) was developed in 1993, which has been
updated several times in response to requirements associated with NPDES permit renewals. The City of
Newport Beach is a member of the Orange County Stormwater Program, which coordinates all cities and
the county government to regulate and control storm water and urban runoff into all Orange County
waterways, and ultimately, into the Pacific Ocean. The Orange County Stormwater Program administers the
current NPDES MS4 Permit and the DAMP for the County of Orange and the 34 incorporated cities within
the region.
City of Newport Beach General Plan 2006
The City of Newport Beach General Plan contains the following policies related to water resources that are
applicable to the Project:
Policy NR 3.4 Storm Drain Sewer System Permit. Require all development to comply with the regulations
under the City’s municipal separate storm drain system permit under the National Pollutant
Discharge Elimination System.
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-18
Draft EIR
May 2025
Policy NR 3.11 Site Design and Source Control. Include site design and source control BMPs in all
developments. When the combination of site design and source control BMPs are not
sufficient to protect water quality as required by the National Pollutant Discharge
Elimination System (NPDES), structural treatment BMPs will be implemented along with site
design and source control measures.
Policy NR 3.15 Street Drainage Systems. Require all street drainage systems and other physical
improvements created by the City, or developers of new subdivisions, to be designed,
constructed, and maintained to minimize adverse impacts on water quality. Investigate the
possibility of treating or diverting street drainage to minimize impacts to water bodies.
City of Newport Beach Municipal Code
Section 19.28.080: Storm Drains. of the City’s Municipal Code requires developers to design and construct
all drainage facilities necessary for the removal of surface water from the site (e.g., open/closed channels,
catch basins, manholes, junction structures), and to protect offsite properties from a project’s water runoff.
The storm drain system must be designed in accordance with the standards of the Orange County Flood
Division. A drainage fee is also charged to fund improvements to the City’s drainage facilities.
5.16.4.2 Stormwater Drainage Environmental Setting
The Santa Ana – Delhi Channel, maintained by the Orange County Flood Control District (OCFCD), is a 55-
foot-wide by 16-foot-high reinforced-concrete channel that runs in a southerly direction, along the westerly
boundary of the site along Irvine Avenue.
The Project site currently is developed with three holes of the NB Golf Course, a driving range,
clubhouse/restaurant building and associated parking. As described in the Hydrology Report (included as
Appendix P), currently 3.4 acres of the site (22 percent) is impervious, as most of the site consists of three
holes of the golf course that is covered in grass and trees. The topography of the site slopes in a northwesterly
direction, toward OCFCD’s Santa Ana – Delhi Channel and Irvine Avenue. An existing 15- to 20-foot-high
slope descends from the southeast boundary of the site. The remainder of the site generally slopes more
gently toward the westerly boundary of the Project. There are currently five drainage discharge points to
the Santa Ana – Delhi Channel: two points in Irvine Avenue where drainage is conveyed to catch basins and
then discharged into the Sana Ana – Delhi Channel, and three points to pipes that discharge directly to the
Santa Ana – Delhi Channel (Appendix P).
There is currently offsite drainage from properties located along the easterly boundary of the golf course
that conveys to the golf course via surface gutter or pipes. The drainage is conveyed through the golf course,
combines with the onsite drainage, and then discharges into the Santa Ana – Delhi Channel (Appendix P).
5.16.4.3 Stormwater Drainage Thresholds of Significance
Appendix G of the CEQA Guidelines indicates that a Project could have a significant effect if it were to:
UTIL-5 Require or result in the construction of new stormwater drainage facilities, or expansion of existing
facilities, the construction of which could cause significant environmental effects.
5.16.4.4 Stormwater Drainage Service Methodology
The evaluation of stormwater drainage infrastructure quantifies the amount of stormwater runoff that would
be generated from the proposed Project and identifies if runoff from the Project would be accommodated
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-19
Draft EIR
May 2025
by the existing stormwater drainage infrastructure. The evaluation identifies if expansions would be required
to serve the proposed development, and if those expansions have the potential to result in an environmental
impact.
5.16.4.5 Stormwater Drainage Environmental Impacts
IMPACT UTIL-5: THE PROJECT WOULD NOT REQUIRE OR RESULT IN THE RELOCATION OR
CONSTRUCTION OF NEW DRAINAGE FACILITIES, OR EXPANSION OF EXISTING
FACILITIES, THE CONSTRUCTION OF WHICH COULD CAUSE SIGNIFICANT
ENVIRONMENTAL EFFECTS.
Less than Significant Impact. As described previously, the Project site currently drains either to storm drains
within Irvine Avenue or directly into the Santa Ana-Delhi Channel. The Project-specific Preliminary WQMP
describes that the Project site currently includes 3.40 acres of impermeable surfaces, which equates to 22
percent of the site. After completion of Project construction, the site would have an increase in impermeable
surfaces (i.e., 13.89 acres or 90 percent of the site would be impermeable surfaces). However, this includes
the 5.06-acre (20,427 SF) surf lagoon, which would capture rainfall and not result in runoff. As shown on
Table 5.16-14, while implementation of the proposed Project would result in a large increase in impermeable
surfaces, the 100-year, 24-hour storm volume would decrease by approximately 11 percent.
Table 5.16-14: Project Change to 100-Year Storm Runoff Rate
Sub Area Existing Condition (CFS) Proposed Condition (CFS)
A 10.6 19.2
B 0.5 3.8
C 3.2 16.2
D 11.1 1.0
E (Lagoon) 19.8 0
Totals 45.2 40.2
Change -11.1%
Source: Preliminary Hydrology Report, Appendix P
The proposed Project would maintain the existing drainage pattern. The Project includes installation of an
onsite storm drainage system that includes two bioretention basins at the north parking lot and two
bioretention basins in the southern parking lot, and an 18-inch storm drain that would connect to the existing
storm drain line at the intersection of Mesa Drive and Irvine Avenue and the existing drain within Irvine
Avenue near the existing site driveway.
The runoff from the Project area would be collected by roof drains, surface flow designed pavement, curbs,
and area drains and conveyed to the bioretention basins. Treated runoff would be conveyed to the existing
storm drain line at the intersection of Mesa Drive and Irvine Avenue, at Irvine Avenue near the existing
driveway, or into the Santa Ana-Delhi Channel with a maximum outlet flow rate that has been designed to
be equal or less than the existing condition, pursuant to existing DAMP requirements. Due to the decrease in
onsite stormwater runoff that would occur from implementation of the proposed Project, no new or expanded
drainage facilities would be required.
Similar to existing conditions, the offsite runoff that flows onto the site would continue to be collected on the
Project site and flow northwest through the proposed northern parking lot and into the Santa Ana-Delhi
Channel. No change in volumes to offsite flows would occur. Therefore, impacts related to drainage facilities
would be less than significant.
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-20
Draft EIR
May 2025
5.16.4.6 Stormwater Drainage Cumulative Impacts
The geographic scope for cumulative impacts related to stormwater drainage includes the geographic area
served by the existing stormwater infrastructure for the Project area, from capture of runoff through final
discharge points. As described above, the proposed Project would result in a reduction in stormwater runoff
from the Project site. As a result, the proposed Project would not generate additional runoff that could
combine with runoff from cumulative projects that could cumulatively combine to impact drainage. Thus,
cumulative impacts related to drainage would be less than significant.
5.16.4.7 Stormwater Drainage Existing Regulations
The following standard regulations would reduce potential impacts related to stormwater drainage:
• California Water Resources Control Board Low Impact Development (LID) Policy
• Santa Ana Region MS4 Permit; NPDES Permit No. CAS618030 (Order R8-2009-0030 as amended by
Order No. R8-2010-0062)
• Municipal Code Section 19.28.080, Storm Drains
5.16.4.8 Stormwater Drainage Project Design Features
None.
5.16.4.9 Stormwater Drainage Level of Significance Before Mitigation
Impacts UTIL-5 would be less than significant.
5.16.4.10 Stormwater Drainage Mitigation Measures
No mitigation measures are required.
5.16.4.11 Stormwater Drainage Level of Significance After Mitigation
Impacts would be less than significant.
5.16.5 SOLID WASTE
5.16.5.1 Solid Waste Regulatory Setting
State Regulations
California Assembly Bill (AB) 341
On October 6, 2011, Governor Brown signed AB 341 establishing a State policy goal that no less than 75
percent of solid waste generated be source reduced, recycled, or composted by 2020, and requiring
CalRecycle to provide a report to the Legislature that recommends strategies to achieve the policy goal.
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-21
Draft EIR
May 2025
California Green Building Standards
Section 5.408.1 Construction waste diversion. Recycle and/or salvage for reuse a minimum of 65 percent
of the nonhazardous construction and demolition waste.
Section 5.410.1 Recycling by occupants. Provide readily accessible areas that serve the entire building
and are identified for the depositing, storage and collection of non-hazardous materials for recycling,
including (at a minimum) paper, corrugated cardboard, glass, plastics, organic waste, and metals, or meet
a lawfully enacted local recycling ordinance, if more restrictive.
Local and Regional Regulations
City of Newport Beach Municipal Code
Section 20.30.120 Solid Waste and Recyclable Materials Storage. This section provides the standards for
the provision of solid waste and recyclable materials storage areas in compliance with the California Solid
Waste Reuse and Recycling Access Act (PRC §42900) and Municipal Code Chapters 6.04 and 6.06. All
existing and new development projects that require building permits must provide adequate enclosed areas
with solid roofs for collecting and loading solid waste and recyclable materials.
5.16.5.2 Solid Waste Environmental Setting
The City of Newport Beach is currently served by eight licensed commercial solid waste haulers for
commercial uses in the City. Solid waste in the City is then brought to one of six transfer stations which sorts
trash from recyclable materials and then transfers the materials to landfills. Solid waste generated by the
Project would be disposed of at either the Frank R. Bowerman, Olinda Alpha, or Prima Deshecha Landfill
(City of Newport Beach, 2006b). Each landfill is located approximately 16.8, 25.5, and 23.2 roadway
miles from the site, respectively. Table 5.16-15 below summarizes the characteristics of each landfill. Based
on the maximum received tonnage in November 2024, the three landfills have a combined remaining
permitted capacity of approximately 3,094.2 tons per day.
Table 5.16-15: Landfill Capacity
Name Max Daily
Permitted (tpd)
Highest Daily
Tonnage (tpd)1
Available Daily
Disposal (tpd) Closure Date
Frank R. Bowerman Landfill 11,500 9,081.11 2,418.89 12/31/2053
Olinda Alpha Landfill 8,000 7,207 793 12/31/2036
Prima Deshecha Landfill 4,000 3,583.81 416.19 12/31/2102
Total 3,628.08
Source: CalRecycle, 2024a; CalRecycle, 2024b, CalRecycle, 2024c
1 Highest Daily Tonnage in November 2024
5.16.5.3 Solid Waste Thresholds of Significance
Appendix G of the CEQA Guidelines indicates that a Project could have a significant effect if it were to:
UTIL-6 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.
UTIL-7 Comply with federal, state, and local management and reduction statutes and regulations related
to solid waste.
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-22
Draft EIR
May 2025
5.16.5.4 Solid Waste Methodology
Solid waste generation from construction and operation of the Project was estimated using a construction
and waste generation factor from the Environmental Protection Agency (EPA) and an operational generation
factor from CalEEMod version 2022.1.1, respectively. Solid waste volumes were then compared with recent
estimates of remaining disposal capacity of the landfill serving the City. As described below in Impact UT-
6, potential impacts related to compliance with solid waste regulations were evaluated by identifying how
the proposed Project would implement the relevant requirements.
5.16.5.5 Solid Waste Environmental Impacts
IMPACT UTIL-6: THE PROJECT WOULD NOT 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. The proposed Project would result in new development that would generate
an increased amount of solid waste. All solid waste-generating activities within the City are subject to the
requirements set forth in the 2022 California Green Building Standards Code, which requires demolition and
construction activities to recycle or reuse a minimum of 65 percent of the nonhazardous construction and
demolition waste, as well as AB 341, which requires diversion of a minimum of 75 percent of operational
solid waste to be recycled. Implementation of the proposed Project would be consistent with all State
regulations, as ensured through the City’s development permitting process.
As discussed above, solid waste generated by the Project would be disposed of at either the Frank R.
Bowerman Landfill, the Olinda Alpha Landfill, and/or the Prima Deshecha Landfill. These landfills are Class
III municipal solid waste landfills.
Construction
Construction of proposed Project would involve the demolition of the existing golf course uses, including the
8,975 SF pro shop and restaurant building, and a 2,664 SF driving range building which would result in
approximately 700 tons of material being demolished and disposed of in landfills. As detailed in Table 3-
5, demolition would occur over approximately 20 days during construction. The 2022 California Green
Building Standards Code requires that a minimum of 65 percent of the nonhazardous demolition debris be
recycled or reused. Therefore, the demolition would generate approximately 245 tons of solid waste to be
disposed of at the landfills over approximately 20 days, which is approximately 12.25 tons of waste per
day, which is within the landfills capacity of 3,628.08 tons per day.
After the demolition phase, Project construction would generate solid waste from construction packaging and
discarded materials. Utilizing a construction waste factor of 3.89 pounds per square foot (EPA, 1998),
construction of the Project would generate approximately 154.69 tons of waste during construction from
packaging and discarded materials. The 2022 California Green Building Standards Code requires
construction activities to recycle or reuse a minimum of 65 percent of the nonhazardous construction waste.
Thus, the construction solid waste that would be disposed of at the landfill would be approximately 35
percent of the waste generated. Therefore, construction activities would generate approximately 54.14 tons
of solid waste to be disposed of at the landfill. As shown in Section 3.0, Project Description, construction
activities would occur over a 300-day period. This equates to approximately 0.18 tons of debris per day.
As described above in Table 5.16-15, Frank R. Bowerman Landfill is permitted to accept 11,500 tons per
day, Olinda Alpha Landfill is permitted to accept 8,000 tons per day, and Prima Deshecha Landfill is
permitted to accept 4,000 tons per day. Based on disposal rates in November 2024, Frank R. Bowerman
Landfill had a highest tonnage received of 9,081.11 tons per day with a remaining capacity of 2,418.89
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-23
Draft EIR
May 2025
tons per day, the Olinda Alpha Landfill had a highest tonnage received of 7,207 tons per day with a
remaining capacity of 793 tons per day, and Prima Deshecha Landfill had a highest tonnage received of
3,583.81 tons with a remaining capacity of 416.19 tons (CalRecycle, 2024a, b, c). Thus, the facilities'
remaining capacities would be able to accommodate the addition of 0.18 tons of waste per day during
construction of the proposed Project.
Operation
Operation of the proposed Project would include a 5.06-acre (20,427 SF) surf lagoon with warming pools,
spas and seating areas; a three-story, 68,478 gross SF amenity clubhouse; a two-story athlete
accommodation building; ancillary storage and maintenance areas, and associated parking areas. The
Newport Beach General Plan EIR uses a solid waste generation factor of 5 pounds per 1,000 SF per day
for commercial uses and 2.5 pounds per room per day for visitor serving uses. As shown on Table 5.16-16,
based on these generation factors, operation of the proposed Project would generate approximately 71.62
tons of solid waste per year or 0.20 tons per day. AB 341 requires diversion of a minimum of 75 percent
of operational solid waste, which would reduce the volume of landfilled solid waste to approximately 17.91
tons per year, or approximately 0.05 ton per day.
Table 5.16-16: Proposed Project Solid Waste Generation
Land Use Category Generation Factor1 Solid Waste Generation
(tons per year)
Commercial (68,478 SF) 5 pounds/1,000 SF/day 62.49
Visitor Serving (20 rooms) 2.5 pounds/room/day 9.13
Total - 71.62
1 City of Newport Beach General Plan EIR Table 4.14-14
As shown in Table 5.16-15, Frank R. Bowerman Landfill had a highest tonnage received of 9,081.11 tons
per day with a remaining capacity of 2,418.89 tons per day, the Olinda Alpha Landfill had a highest
tonnage received of 7,207 tons per day with a remaining capacity of 793 tons per day, and Prima Deshecha
Landfill had a highest tonnage received of 3,583.81 tons per day with a remaining capacity of 416.19 tons
per day. The Project’s solid waste (17.91 tons per year, or approximately 0.05 ton per day), would
represent less than 0.01 percent of any of the landfill’s daily remaining permitted capacity. The Frank R.
Bowerman Landfill has a permitted capacity until 2053, Olinda Alpha Landfill has a permitted capacity until
2036, and the Prima Deshecha Landfill has a permitted capacity until 2102. Thus, the proposed Project
would be served by a landfill with sufficient permitted capacity to accommodate the Project’s solid waste
disposal needs and the Project would not impair the attainment of solid waste reduction goals. Impacts
related to landfill capacity would be less than significant.
IMPACT UTIL-7: THE PROJECT WOULD COMPLY WITH FEDERAL, STATE, AND LOCAL MANAGEMENT
AND REDUCTION STATUTES AND REGULATIONS RELATED TO SOLID WASTE.
No Impact. The proposed Project would result in new development that would generate solid waste. All solid
waste-generating activities within the City are subject to the requirements set forth in the 2022 California
Green Building Standards Code that requires demolition and construction activities to recycle or reuse a
minimum of 65 percent of the nonhazardous construction and demolition waste, and AB 341 that requires
diversion of a minimum of 75 percent of operational solid waste.
As detailed previously, Municipal Code Section 20.30.120 provides standards for the provision of solid
waste and recyclable materials storage areas in compliance with the California Solid Waste Reuse and
Recycling Access Act (PRC §42900). Implementation of the proposed Project would be consistent with all
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-24
Draft EIR
May 2025
State and City regulations, as ensured through the City’s development review and permitting process.
Therefore, the proposed Project would comply with all solid waste statutes and regulations; and impacts
would not occur.
5.16.5.6 Solid Waste Cumulative Impacts
The geographic scope of cumulative analysis for landfill capacity is the service area for the Frank Bowerman
Sanitary Landfill, the Olinda Alpha Landfill, and the Prima Deshecha Landfill, which serves the Project area
and the City of Newport Beach. The projections of future landfill capacity based on the entire projected
waste stream going to these landfills is used for cumulative impact analysis. Based on tonnage rates from
November 2024, the Frank R. Bowerman Landfill had a highest tonnage received of 9,081.11 tons with a
remaining capacity of 2,418.89 tons, the Olinda Alpha Landfill had a highest tonnage received of 7,207
tons with a remaining capacity of 793 tons, and Prima Deshecha Landfill had a highest tonnage received of
3,583.81 tons with a remaining capacity of 416.19 tons in (CalRecycle, 2024a, b, c). The 0.05 tons of solid
waste per day from operation of the proposed Project would be less than 0.01 percent of the remaining
daily capacity of the landfill. Due to this small percentage, the increase in solid waste from the proposed
Project would be less than cumulatively considerable and would be less than significant.
5.16.5.7 Solid Waste Existing Regulations
The following standard regulations would reduce potential impacts related to solid waste:
• Assembly Bill 341 (Chapter 476, Statues of 2011)
• California Code of Regulations Title 24, Part 11, the California Green Building Standards Code
• Municipal Code Section 20.30.120, Solid Waste and Recyclable Materials Storage
5.16.5.8 Solid Waste Project Design Features
None.
5.16.5.9 Solid Waste Level of Significance Before Mitigation
Impacts UTIL-6 and UTIL-7 would be less than significant.
5.16.5.10 Solid Waste Mitigation Measures
No mitigation measures are required.
5.16.5.11 Solid Waste Level of Significance After Mitigation
Impacts would be less than significant.
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-25
Draft EIR
May 2025
5.16.6 DRY UTILITIES
5.16.6.1 Dry Utilities Regulatory Setting
State Regulations
Title 24 Energy Efficiency Standards and California Green Building Standards
California Code of Regulations (CCR) Title 24 Part 6: The California Energy Code was first adopted in 1978
in response to a legislative mandate to reduce California’s energy consumption. The standards are updated
periodically to allow consideration and possible incorporation of new energy efficient technologies and
methods. The most recently updated 2022 Energy Code encourages efficient electric heat pumps, establishes
electric-ready requirements for new homes, expands solar photovoltaic and battery storage standards, and
strengthens ventilation standards, among other requirements.
CCR, Title 24, Part 11: California Green Building Standards Code (CALGreen) is a comprehensive and
uniform regulatory code for all new construction and major renovations, and is administered by the California
Building Standards Commission. The purpose of CALGreen is to improve public health, safety, and general
welfare through enhanced design and construction of buildings using concepts which reduce negative impacts
and promote those principles which have a positive environmental impact and encourage sustainable
construction practices. It is also updated every three years. The most recent update is the 2022 CALGreen
Code that became effective January 1, 2023. The 2022 CALGreen standards that are applicable to the
proposed Project include, but are not limited to, the following:
Electric Vehicle (EV) charging stations. New construction shall facilitate the future installation of EV supply
equipment. The compliance requires empty raceways for future conduit and documentation that the electrical
system has adequate capacity for the future load. The number of spaces to be provided is contained in
Table 5.106.5.3.3 (5.106.5.3). Additionally, Table 5.106.5.4.1 specifies requirements for the installation of
raceway conduit and panel power requirements for medium- and heavy-duty electric vehicle supply
equipment for warehouses, grocery stores, and retail stores.
Local and Regional Regulations
City of Newport Beach General Plan 2006
The City of Newport Beach General Plan contains the following policies related to water resources that are
applicable to the Project:
Policy LU 2.8 Adequate Infrastructure. Accommodate the types, densities, and mix of land uses that
can be adequately supported by transportation and utility infrastructure (water, sewer,
storm drainage, energy, and so on) and public services (schools, parks, libraries, seniors,
youth, police, fire, and so on).
Policy NR 21.3 Overhead Utilities. Support programs to remove and underground overhead utilities, in
new development as well as existing neighborhoods.
Policy NR 24.2 Energy Efficient Design Features. Promote energy efficiency design features.
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-26
Draft EIR
May 2025
5.16.6.2 Dry Utilities Environmental Setting
Electricity
The proposed Project is within the service area of Southern California Edison (SCE). SCE provides electric
power to more than 15 million persons within its 50,000 square mile service area, which covers the counties
of Mono, Tulare, Inyo, Kern, Ventura, Los Angeles, Orange, Riverside, and San Bernardino. Based on SCE’s
2021 Power Content Label Mix, SCE derives electricity from varied energy resources including: natural gas,
solar power generation, wind farms, nuclear power plants, hydroelectric generators, and geothermal power
plants. SCE also purchases power from open market transactions, which do not have identifiable sources
(California Energy Commission, 2023).
Overhead utilities lines currently exist along Mesa Drive, adjacent to the western boundary of the Project
site. The Project site is located approximately 1.45 miles from Bayside Substation, which serves the Project
area through the Pike 12kV Circuit that provides distribution (SCE, 2024).
Natural Gas
The Southern California Gas Company (SoCalGas) is the natural gas purveyor in the City of Newport Beach
and is the principal distributor of natural gas in Southern California. The site is currently served by a two-
inch service line within Irvine Avenue that connects to a two-inch line in Bristol Street to the north. There is also
a three-inch natural gas line at the intersection of Irvine Avenue and Mesa Drive that exists within Mesa Drive
to the west of Irvine Avenue and within Irvine Avenue to the south of the site.
Telecommunications
Telecommunications would be provided to the proposed Project by a privately owned telecommunication
company. Overhead utility lines currently exist on Mesa Drive, adjacent to the Project site.
5.16.6.3 Dry Utilities Thresholds of Significance
Appendix G of the CEQA Guidelines indicates that a Project could have a significant effect if it were to:
UTIL-8 Require or result in the relocation or construction of a new or expanded electric power, natural
gas, or telecommunications facilities, the construction of which could cause significant environmental
effects.
5.16.6.4 Dry Utilities Methodology
The evaluation of utilities identifies if utility demand from the proposed Project would be accommodated via
existing utility infrastructure that would also be available to the proposed Project. The evaluation identifies
if expansions would be required to serve the proposed development, and if those expansions have the
potential to result in an environmental impact.
5.16.6.5 Dry Utilities Environmental Impacts
IMPACT UTIL-8: THE PROJECT WOULD NOT REQUIRE OR RESULT IN THE RELOCATION OR
CONSTRUCTION OF A NEW OR EXPANDED ELECTRIC POWER, NATURAL GAS, OR
TELECOMMUNICATIONS FACILITIES, THE CONSTRUCTION OF WHICH COULD CAUSE
SIGNIFICANT ENVIRONMENTAL EFFECTS.
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-27
Draft EIR
May 2025
Less than Significant Impact. The Project site is currently developed with a 38-bay partially covered driving
range, a 1,050 SF putting green, a 8,975 SF building that includes a pro shop and a restaurant, surface
parking lot with 280 parking spaces, and three holes of the existing Newport Beach Golf Course (holes 1,
2, and 9). Therefore, the site currently generates a limited demand for electricity, natural gas, and other
dry utilities.
The proposed Project would generate an increased demand for electricity, natural gas, and
telecommunication systems.
Electricity
Electricity would be provided to the Project site by SCE. The Project would connect to the existing electricity
powerlines within roadways. SCE prepared an Engineering Analysis Report (included as Appendix G) which
determined that the Project’s electricity demand would be adequately served by SCE’s existing distribution
system, and that the existing electrical lines, Pike 12kV Circuit, and Bayside Substation can accommodate
the Project (SCE, 2024).
The Project would not require or result in the construction of new facilities or the expansion of existing
facilities. The Project would be constructed in compliance with Title 24 requirements. In addition, the Project
includes solar photovoltaic panels on the rooftops and parking canopies, which would reduce the Project’s
electricity demand on the grid. Overall, the Project would not require or result in the relocation or construction
of new or expanded electric facilities, which could cause significant environmental effects. Thus, impacts
would be less than significant.
Natural Gas
As described in the setting, natural gas services are currently provided to Project site by SoCal Gas. The
proposed Project would install new onsite natural gas lines that would connect to one of the existing natural
gas distribution lines in Irvine Avenue. The Project would not require or result in the construction of new natural
gas facilities or expansion of existing facilities. There are currently two natural gas lines adjacent to the site
that would serve the Project and continue to serve surrounding land uses. Adequate natural gas supplies are
presently available to meet the increase in demand attributed to the Project. The SoCal Gas Company has
provided a Will Serve letter confirming the ability to serve the Project. Thus, potential impacts related to the
provisions of natural gas supplies or natural gas infrastructure would be less than significant.
Telecommunications
The proposed Project would connect to the existing telecommunication lines along Mesa Drive, which would
be provided by a private telecommunication company on an as-needed basis. The proposed Project is not
anticipated to require or result in the construction of new communications facilities or the expansion of existing
facilities. Impacts would be less than significant.
The Project Applicant would be responsible for coordinating with each utility company to ensure the
connection of utilities occurs according to standard construction and operation procedures administered by
the California Public Utilities Commission. Each of the utility systems is available within roadways, and onsite
lines would be constructed to connect the existing offsite lines for the proposed development. The construction
activities related to dry utility connections are included as a part of the Project and therefore have been
addressed throughout this EIR. Construction emissions resulting from excavation activities are analyzed in
Sections 5.2, Air Quality, and 5.7, Greenhouse Gas Emissions. Therefore, potential impacts associated with
utilities, including electricity, natural gas and other dry utilities would be less than significant.
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-28
Draft EIR
May 2025
5.16.6.6 Dry Utilities Cumulative Impacts
Cumulative dry utilities assessment considers development of the Project in combination with the other
development projects within the vicinity of the Project area, as listed in Section 5.0 of this EIR. Cumulative
impacts related to the provision of facilities for electricity and communications systems have been evaluated
throughout this EIR, primarily associated with the emissions resulting from construction. Mitigation measures
have been recommended in cases where cumulatively considerable impacts associated with utilities
infrastructure were identified. In addition, existing dry utility lines are present along Mesa Drive. Therefore,
cumulatively considerable impacts associated with the provision of utility facilities to serve the proposed
Project would be less than significant.
5.16.6.7 Dry Utilities Existing Regulations
The following standard regulations would reduce potential impacts related to dry utilities:
• California Code of Regulations Title 24, Part 11, the California Green Building Code
5.16.6.8 Dry Utilities Project Design Features
None.
5.16.6.9 Dry Utilities Level of Significance Before Mitigation
Impact UTIL-8 would be less than significant.
5.16.6.10 Dry Utilities Mitigation Measures
No mitigation measures are required.
5.16.6.11 Dry Utilities Level of Significance After Mitigation
Impacts would be less than significant.
5.16.7 REFERENCES
California Energy Commission. (2023). 2023 Integrated Energy Policy Report.
https://www.energy.ca.gov/data-reports/reports/integrated-energy-policy-report-iepr/2023-
integrated-energy-policy-report
CalRecycle. (2024a). SWIS Facility/Site Activity Details – Frank R. Bowerman Landfill (30-AB-0360).
Retrieved January 23, 2025, from
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/2767?siteID=2103
CalRecycle. (2024b). SWIS Facility/Site Activity Details – Olinda Alpha Landfill (30-AB-0035). Retrieved
January 23, 2025, from
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/2757?siteID=2093
CalRecycle. (2024c). SWIS Facility/Site Activity Details – Prima Deshecha Landfill (30-AB-0019). Retrieved
January 23, 2025, from
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/2750?siteID=2085
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-29
Draft EIR
May 2025
City of Newport Beach. (2001, January). Santa Ana Heights Specific Plan. Retrieved September 23, 2024,
from ocpublicworks.com.
City of Newport Beach. (2006a, July). General Plan. Retrieved September 23, 2024, from
newportbeachca.gov: https://www.newportbeachca.gov/government/departments/community-
development/planning-division/general-plan-codes-and-regulations/general-plan
City of Newport Beach. (2006b, July). General Plan Environmental Impact Report. Retrieved September 23,
2024, from newportbeachca.gov:
https://www.newportbeachca.gov/government/departments/community-development/planning-
division/general-plan-codes-and-regulations/general-plan/general-plan-environmental-impact-
repor
City of Newport Beach. (2021). 2020 Urban Water Management Plan. Retrieved January 20, 2025, from:
https://www.newportbeachca.gov/home/showpublisheddocument/75001/6385792898623700
00
City of Newport Beach. (2024, May). Newport Beach Municipal Code. Retrieved September 23, 2024,
from codepublishing.com: https://www.codepublishing.com/CA/NewportBeach/
Fuscoe Engineering, Inc. (2024a). Water Supply Evaluation. (Appendix S)
Fuscoe Engineering, Inc. (2024b). Water Demand Report. (Appendix T)
Fuscoe Engineering, Inc. (2024c). Sewer Analysis Report. (Appendix U)
Fuscoe Engineering, Inc. (2024d). Preliminary Hydrology Report. (Appendix P).
Orange County Water District GWRS. (2025). Retrieved April 9, 2025, from
https://www.ocwd.com/gwrs/the-process/
Southern California Edison (SCE). (2024). Proposed Project Engineering Analysis Report. (Appendix G).
Southern California Gas Company (SoCalGas). (2024). Maps & Will Serve – Will Serve and Map Request
for 3100 Irvine Ave, Newport Beach.
USEPA. (June 1998). Characterization of Building-Related Construction and Demolition Debris in the United
States. Retrieved January 23, 2025 from https://www.epa.gov/sites/default/files/2016-
03/documents/charact_bulding_related_cd.pdf
Snug Harbor Surf Park Project 5.16 Utilities and Service Systems
City of Newport Beach 5.16-30
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 6. Other CEQA Considerations
City of Newport Beach 6-1
Draft EIR
May 2025
6. Other CEQA Considerations
6.1 SIGNIFICANT AND UNAVOIDABLE ENVIRONMENTAL EFFECTS
CEQA Guidelines Section 15126.2(c) requires an EIR to describe “any significant impacts, including those
which can be mitigated but not reduced to a level of insignificance.” The analysis throughout Section 5 of
this Draft EIR determined that the Project would reduce potential environmental impacts to a level below
significance by implementation of Project design features; regulatory requirements; plans, programs,
policies; and mitigation measures. The Draft EIR determined that potentially significant impacts would be
mitigated to a level below significance and that no significant and unavoidable environmental effects would
occur from implementation of the proposed Project.
6.2 GROWTH INDUCEMENT
CEQA Guidelines Section 15126.2(e), Growth Inducing Impact of the Proposed Project, requires that an EIR
“discuss the ways in which the proposed project could foster economic or population growth, or the
construction of additional housing, either directly or indirectly, in the surrounding environment.” The CEQA
Guidelines also indicate that it must not be assumed that growth in any area is necessarily beneficial,
detrimental, or of little significance to the environment. In general terms, a project may foster spatial,
economic, or population growth in a geographic area, if it meets any one of the following criteria:
1. Directly or indirectly foster economic or population growth, or the construction of additional housing, in
the surrounding environment;
2. Remove obstacles to population growth;
3. Require the construction of new or expanded facilities that could cause significant environmental effects;
or
4. Encourage and facilitate other activities that could significantly affect the environment, either individually
or cumulatively.
1. Does the Project directly or indirectly foster economic or population growth or the construction of
additional housing?
Growth-inducing potential of a project would be considered significant if it fosters growth or a concentration
of population in excess of what is assumed in master plans, land use plans, or in projections made by regional
planning agencies, such as the Southern California Association of Governments (SCAG). The Project site
currently employs 47 full and part-time people at the golf course, pro-shop, and restaurant. The proposed
Project would employ approximately 70 full-time and part-time employees with an average of
approximately 55 employees onsite at any given time. The addition of 23 total employees from
implementation of the proposed Project would not result in additional jobs in the area that would result in
unplanned growth. Additionally, the 20 athlete accommodations would only be utilized for short time periods
by visiting surfers and related guests, and the athlete accommodations would not result in unplanned
population growth.
The proposed Project may cause indirect economic growth as it would generate revenue for the City through
taxes generated by the development. Additionally, visiting athletes and their guests would purchase goods
and services in the region; however, this would be a limited demand from the 20 athlete accommodations
and daily park visitors, which are limited by the Project capacity and reservation system. The Project would
also facilitate approximately 12 ticketed surf events/competitions per year that would expand the City’s
tourism economy and expand transient occupancy tax revenues generated by hotel stays by spectators
Snug Harbor Surf Park Project 6. Other CEQA Considerations
City of Newport Beach 6-2
Draft EIR
May 2025
traveling from out of town. This potential increase could be accommodated by existing commercial and retail
services near the Project site. The Project is highly unlikely to result in the need for additional commercial or
retail services to meet Project demands. Further, the Project would not directly or indirectly foster economic
or population growth that could result in the construction of additional housing.
2. Does the Project remove obstacles to population growth?
The elimination of a physical obstacle to growth is considered to be a growth inducing impact. A physical
obstacle to growth typically involves the lack of public service infrastructure. The proposed Project would
induce growth if it would provide public services or infrastructure with excess capacity to serve lands that
would otherwise not be developable or to expand the development potential of redevelopment areas.
As detailed in Section 5.16, Utilities and Service Systems, the Project site and adjacent areas are currently
served by existing infrastructure. The proposed Project would install new onsite water, sewer, and stormwater
drainage infrastructure systems that would provide increased capacity to serve the proposed Project and
would connect to existing infrastructure adjacent to the site, which has the capacity to serve the Project in
addition to existing and anticipated demands. The proposed sewer line upgrade is limited to 42.5 feet of
offsite line that extends from the Project site boundary to the existing 12-inch line in Mesa Drive and would
not provide for additional capacity that would induce growth. The Project does not provide infrastructure to
serve any other lands than the Project site, and it would not expand development areas or the development
potential of area.
In addition, a project could remove obstacles to growth through changes to existing regulations related to
land development. The Project site is categorized as Parks and Recreation (PR) by the Land Use Element of
the General Plan and is zoned Santa Ana Heights Specific Plan (SP-7). The Santa Ana Heights Specific Plan
designates the site as Open Space and Recreation (OSR). The proposed Project would implement the existing
General Plan and zoning designations. Although, the Project includes a General Plan Amendment to increase
the development intensity for the site from the current limit of 20,000 SF to approximately 59,772 SF, this
would not result in employment or residential growth, as described in response to number 1, previously.
3. Does the proposed Project require the construction of new or expanded facilities that could cause
significant environmental effects?
Growth induced by a project is considered a significant impact if it directly or indirectly affects the ability
of agencies to provide needed public services that requires the construction of new public service facilities,
or if it can be demonstrated that the potential growth significantly affects the environment in some other
way. The proposed Project could slightly increase the demand for fire protection, emergency response, and
police services. However, as described in Section 5.12, Public Services, the proposed Project would not
require development of additional facilities or expansion of existing facilities to maintain existing levels of
service for public services. Based on service ratios and build out projections, the proposed Project would not
create a demand for services beyond the capacity of existing facilities.
The closest fire station is the Santa Ana Heights Fire Station #7 that is located adjacent to the Project site.
Section 5.12, Public Services, describes that it is possible that the Project could result in additional Fire
Department services (particularly medical calls for services); however, any increase in demand would be
incremental and would not result in the need for a new or expanded fire facility. Likewise, the proposed
Project would address typical security concerns by providing low-intensity security lighting, security cameras,
and 24-hour security personnel and would not result in the need for new or expanded Police Department
facilities. Additionally, as the number of employees needed to operate the Project would be similar to those
currently onsite, an in-migration of employees would not occur that could require additional school, library,
or other governmental services. Therefore, the proposed Project would not require the construction of new
or expanded facilities that could cause significant environmental effects.
Snug Harbor Surf Park Project 6. Other CEQA Considerations
City of Newport Beach 6-3
Draft EIR
May 2025
4. Does the Project encourage or facilitate other activities that could significantly affect the
environment, either individually or cumulatively?
The proposed Project involves a General Plan Amendment, which is specific to the allowable recreational
land uses on the Project site itself. The proposed Project does not propose changes to any of the City’s
building safety standards (i.e., building, grading, plumbing, mechanical, electrical, or fire codes). The
proposed Project would comply with all applicable City plans, policies, and ordinances. In addition, Project
features and mitigation measures have been identified within this EIR to ensure that the proposed Project
minimizes environmental impacts. The proposed Project would not involve any precedent-setting action that
could encourage and facilitate other activities that significantly affect the environment.
Environmental Impacts of Induced Growth
All physical environmental effects from construction of the proposed Project have been analyzed in all
technical sections of this EIR. For example, activities such as excavation, grading, construction, and operational
vehicular trips of the proposed Project were analyzed in Sections 5.2, Air Quality, 5.7, Greenhouse Gas
Emissions, 5.11, Noise, and 5.14, Transportation. Therefore, construction and operation of the proposed
Project has been analyzed in this EIR and would be adequately mitigated to a less than significant level, as
detailed within Chapter 5 of this EIR. Overall, construction and operation of the Project would not result in
significant and unavoidable impacts; likewise, potential impacts related to growth from implementation of
the proposed Project would be less than significant.
6.3 SIGNIFICANT IRREVERSIBLE EFFECTS
The CEQA Guidelines require the EIR to consider whether “uses of nonrenewable resources during the initial
and continued phases of the project may be irreversible since a large commitment of such resources makes
removal or nonuse thereafter unlikely…. Also, irreversible damage can result from environmental accidents
associated with the project. Irretrievable commitments of resources should be evaluated to assure that such
current consumption is justified.” (CEQA Guidelines Section 15126.2(d)). “Nonrenewable resource” refers to
the physical features of the natural environment, such as land, waterways, mineral resources, etc. These
irreversible environmental changes may include current or future uses of nonrenewable resources, and
secondary or growth-inducing impacts that commit future generations to similar uses.
Generally, a project would result in significant irreversible environmental changes if:
• The primary and secondary impacts would generally commit future generations to similar uses;
• The project would involve a large commitment of nonrenewable resources;
• The project would involve uses in which irreversible damage could result from any potential
environmental accidents associated with the project; or
• The proposed irretrievable commitments of nonrenewable resources is not justified (e.g., the project
involves the wasteful use of energy).
The Project would result in or contribute to the following irreversible environmental changes:
• Lands in the Project area that are currently developed with golf course recreation uses would be
committed to surf lagoon and supporting golf recreation and ancillary uses once the proposed lagoon,
buildings, parking, etc., is constructed. Secondary effects associated with this irreversible commitment of
land resources include:
o Increased vehicle trips on surrounding roadways during operation of the proposed Project (see
Section 5.14, Transportation).
Snug Harbor Surf Park Project 6. Other CEQA Considerations
City of Newport Beach 6-4
Draft EIR
May 2025
o Emissions of air pollutants associated with Project construction and operation (see Section 5.2, Air
Quality).
o Consumption of non-renewable energy associated with construction and operation of the proposed
Project due to the operation of lagoon and building operational systems; and use of automobiles,
lighting, heating and cooling systems, appliances, and the like (see Section 5.5, Energy).
o Increased ambient noise associated with an increase in activities and traffic from the Project (see
Section 5.11, Noise).
• Construction of the proposed Project as described in Section 3.0, Project Description, would require the
use of energy produced from non-renewable resources and construction materials.
In regard to energy usage from the proposed Project, as demonstrated in the analyses contained in Section
5.5, Energy, the proposed Project would not involve wasteful or unjustifiable use of non-renewable resources,
and conservation efforts would be enforced during construction and operation of proposed development.
Solar panels would be installed on building rooftops and on canopies in the parking areas to produce
renewable energy for onsite operations. The proposed development would incorporate energy-generating
and conserving project design features, including those required by Title 24, the California Building
Standards Code, specifically Part 11: California Green Building Standards Code (CALGreen), which
specifies green building standards for new developments.
6.4 REFERENCES
City of Newport Beach. (2001, January). Santa Ana Heights Specific Plan. Retrieved September 23, 2024,
from ocpublicworks.com.
City of Newport Beach. (2006a, July). General Plan. Retrieved September 23, 2024, from
newportbeachca.gov: https://www.newportbeachca.gov/government/departments/community-
development/planning-division/general-plan-codes-and-regulations/general-plan
City of Newport Beach. (2006b, July). General Plan Environmental Impact Report. Retrieved September 23,
2024, from newportbeachca.gov:
https://www.newportbeachca.gov/government/departments/community-development/planning-
division/general-plan-codes-and-regulations/general-plan/general-plan-environmental-impact-
repor
City of Newport Beach. (2024, May). Newport Beach Municipal Code. Retrieved September 23, 2024,
from codepublishing.com: https://www.codepublishing.com/CA/NewportBeach/
Snug Harbor Surf Park Project 7. Effects Found Not Significant
City of Newport Beach 7-1
Draft EIR
May 2025
7. Effects Found Not Significant
CEQA Guidelines Section 15126.2(a) states that “[a]n EIR shall identify and focus on the significant effects
on the environment”. During the preparation of this EIR, the Project was determined to have no potential to
result in significant impacts under four environmental issue areas: agriculture and forestry resources, mineral
resources, population and housing, and wildfire. Therefore, these issue areas were not required to be
analyzed in detail in EIR Section 5.0, Environmental Impact Analysis.
CEQA Guidelines Section 15128 requires that an EIR contain a statement briefly indicating the reasons that
various possible effects of a project were determined not to be significant and were therefore not discussed
in detail in the EIR. As allowed by CEQA Guidelines Section 15128, statements related to the above listed
topic areas are presented below. The analysis in this section is based, in part, on the following documents
and resources:
• City of Newport Beach General Plan, 2006
• City of Newport Beach General Plan Environmental Impact Report (General Plan EIR), 2006
• City of Newport Beach Municipal Code
• Geotechnical Exploration, prepared by Carl Kim Geotechnical, Inc., 2024, included as Appendix H
7.1 AGRICULTURE AND FORESTRY
a) Would the Project convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance,
as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the
California Resources Agency, to non-agricultural use?
The Project site is developed for golf course uses and located in an area that is developed for urban uses.
The California Department of Conservation (CDC) Farmland Mapping and Monitoring Program identifies the
Project site as Urban and Built-Up land (CDC, 2025). No areas of Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance would be affected by the proposed Project or converted to a non-
agricultural use. Thus, impacts would not occur.
b) Would the Project conflict with existing zoning for agricultural use, or a Williamson Act contract?
The Project site is developed for golf related uses and located in an area that is developed for urban uses.
The Project site is zoned Santa Ana Heights Specific Plan (SP-7). The Santa Ana Heights Specific Plan
designates the site as Open Space and Recreation (OSR), which does not include agricultural uses. The site
is not in a Williamson Act contract, and the vicinity is void of agricultural uses. Thus, impacts would not occur.
c) Would the Project conflict with existing zoning for, or cause rezoning of, forest land (as defined in
Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section
4526), or timberland zoned Timberland Production (as defined by Government Code section
51104(g))?
The Project site is developed for golf and related uses and located in an area that is developed for urban
and golf uses. The Project site and vicinity is void of forest land or timberland and is not zoned for forest
land or timberland. Thus, impacts would not occur.
Snug Harbor Surf Park Project 7. Effects Found Not Significant
City of Newport Beach 7-2
Draft EIR
May 2025
d) Would the Project result in the loss of forest land or conversion of forest land to non-forest use?
The Project site is developed for golf and related urban uses and located in an area that is developed for
recreation and urban uses. The Project site and vicinity is void of forest land or timberland. Thus, impacts
would not occur.
e) Would the Project involve other changes in the existing environment which, due to their location or
nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land
to non-forest use?
As the Project site and vicinity do not include agricultural or forest resources, no other changes to the existing
environment would occur from implementation of the proposed Project that could result in conversion of
farmland to nonagricultural use or forest/timberland land to non-forest or non-timberland use. Thus, impacts
related to agriculture and forestry resources would not occur.
7.2 MINERAL RESOURCES
a) Would the Project 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?
The California Department of Conservation identifies sites to which continuing access is important to satisfying
mineral production needs of the region and the State. The relative importance of potential mineral resource
sites is indicated by inclusion in one of four Mineral Resource Zones (MRZ):
• MRZ 1: No mineral resources
• MRZ 2: Significant resource area (quality and quantity known)
• MRZ 3: Significant resource area (quality and quantity unknown)
• MRZ 4: No information (applies primarily to high-value ores)
The City of Newport Beach General Plan Environmental Impact Report details that there is no land within
the City of Newport Beach that is designated as Mineral Resource Zone 2 (MRZ 2), which indicates a presence
of mineral resources (City of Newport Beach, 2006b). As such, there are no known mineral resources within
the City. Historical uses of the Project site and adjacent areas have not included mineral extraction, nor does
the Project site currently support mineral extraction. In addition, the Project does not propose any mineral
extraction activities. Additionally, there are no mineral resource recovery near the Project site. Therefore,
the proposed Project would not result in the loss of availability of a known mineral resource that would be
of value to the region and residents of the State. No impact to availability of mineral resources would occur
from implementation of the Project.
b) Would the Project result in the loss of availability of a locally-important mineral resource recovery
site delineated on the general plan, specific plan or other land use plan?
No known valuable mineral resources exist on or near the Project site, and no mineral resource recovery
activities occur on or near the site. The Project site is currently developed with golf course facilities, buildings,
and a paved parking lot. Additionally, the Project site is designated as Parks and Recreation (PR) by the
Land Use Element of the General Plan. Therefore, no impacts related to the loss of availability of a locally
important mineral resource recovery site, as delineated on a local general plan, specific plan, or other land
use plan, would occur as a result of Project implementation.
Snug Harbor Surf Park Project 7. Effects Found Not Significant
City of Newport Beach 7-3
Draft EIR
May 2025
7.3 POPULATION AND HOUSING
a) Would the Project induce substantial unplanned population growth in an area, either directly (for
example, by proposing new homes and businesses) or indirectly (for example, through extension
of roads or other infrastructure)?
The Project site currently includes three holes of the Newport Beach (NB) Golf Course, a 38-bay driving
range, a putting green, a pro shop, a restaurant, and a service building. The golf course has a total of 19
employees (including part-time) with approximately 8-10 employees on site at a time during peak periods.
The restaurant has a total of 24 employees; two of which are full-time employees. Overall, the Project site
currently provides 47 full and part-time jobs.
The Project would employ approximately 70 full-time and part-time employees with an average of
approximately 55 employees onsite at any given time. The addition of 23 total employees from
implementation of the proposed Project would not result in additional jobs in the area that would result in
unplanned growth. Additionally, the 20 athlete accommodations would only be utilized for short time periods
by visiting surfers and related guests, and the athlete accommodations would not result in unplanned
population growth. No housing units are included in the Project. Any future development projects (including
both housing and recreation) on other parcels within the City, including Housing Opportunity sites, would go
through separate project specific review. In addition, indirect growth related to the expansion of
infrastructure, such as water, sewer, or street systems would not occur because the Project would only install
utility systems that would connect between the site and offsite infrastructure. Therefore, there would be no
impacts related to unplanned population growth from the Project.
b) Would the Project displace substantial numbers of existing people or housing, necessitating the
construction of replacement housing elsewhere?
The Project site is currently developed with golf course facilities, buildings, and a paved parking lot. There
is no existing housing located on the site. The Project site is designated as Parks and Recreation (PR) by the
Land Use Element of the General Plan, which is not a residential land use. Therefore, the Project would not
displace substantial numbers of existing people or housing and would not necessitate the construction of
replacement housing elsewhere. No impacts to housing would occur.
7.4 WILDFIRE
a) If located in or near state responsibility areas or lands classified as very high fire hazard severity
zones, would the Project substantially impair an adopted emergency response plan or emergency
evacuation plan?
The Project site is not located in or near a State Responsibility Area or lands classified as very high fire
hazard severity zones (CAL FIRE, 2025). The Project site is located within a developed area, surrounded by
roadways, drainage facilities, commercial and office uses, open space golf course uses, and Newport Beach
Fire Station #7.
In addition, the proposed Project would be built in compliance with the California Building and Fire Code,
as adopted by the City in Municipal Code Section 9.04.010. Project plans would be reviewed by the City’s
Building Division and the Newport Beach Fire Department during the permitting process to ensure that the
Project meets fire protection requirements. Therefore, implementation of the Project would not exacerbate
wildfire hazard risks or expose people or the environment to adverse environmental effects related to
wildfires. Therefore, the Project would not result in any impacts related to wildfire.
Snug Harbor Surf Park Project 7. Effects Found Not Significant
City of Newport Beach 7-4
Draft EIR
May 2025
b) If located in or near state responsibility areas or lands classified as very high fire hazard severity
zones, would the Project 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?
The Project site is not located in or near a State Responsibility Area or lands classified as very high fire
hazard severity zones (CAL FIRE, 2025). The Project site is located within a developed area, surrounded by
roadways, drainage facilities, commercial and office uses, open space golf course uses, and Newport Beach
Fire Station #7. The Project site does not contain substantial slopes. The Project would grade, landscape,
and pave the site. The Project includes installation of a drainage system that would capture and filter
pollutants, as detailed in Section 5.9, Hydrology and Water Quality.
In addition, typical coastal wind conditions occur at the Project site, which are the same as occur throughout
the City and surrounding coastal areas. The Project includes development and operation of a wave lagoon
and structures that would be developed consistent with the California Building and Fire Code, as adopted
by the City in Municipal Code Section 9.04.010. Thus, the Project does not involve slopes, prevailing winds,
or other factors, that could exacerbate wildfire risks; and would not expose people to pollutant
concentrations from a wildfire or the uncontrolled spread of a wildfire. Therefore, no impact would occur.
c) If located in or near state responsibility areas or lands classified as very high fire hazard severity
zones, would the Project 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?
As described previously, the Project site is not located in or near a State Responsibility Area or lands
classified as very high fire hazard severity zones (CAL FIRE, 2025). The Project does not require the
installation or maintenance of roads, fuel breaks, emergency water sources, power lines or other utilities. As
detailed in Section 3.0, Project Description, the Project would install onsite infrastructure, such as vehicle
circulation, water lines, power lines, and other utilities that would connect to existing offsite infrastructure. ,
These utility improvements would be on the ground or underground and would not exacerbate fire risk.
Project design and implementation of utility improvements would be reviewed and approved by the City as
part of the Project construction permitting process to ensure the proposed Project is compliant with all
applicable design standards and regulations. Therefore, the proposed Project would not include
infrastructure (such as roads, fuel breaks, emergency water sources, power lines, or other utilities), that would
exacerbate fire risk or that would result in impacts to the environment. No impacts would occur.
d) If located in or near state responsibility areas or lands classified as very high fire hazard severity
zones, would the Project 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?
As described previously, the Project site is not located in or near a State Responsibility Area or lands
classified as very high fire hazard severity zones (CAL FIRE, 2025). The Project site does not contain
substantial slopes. The Project would grade, landscape, and pave the site. The site is not within a landslide
hazard zone area and is not considered potentially susceptible to slope instability as shown on Figure 4.5-
2 of the General Plan Environmental Impact Report (City of Newport Beach, 2006b) and as determined by
the Geotechnical Exploration (Appendix H).The Project includes installation of a drainage system that would
capture stormwater runoff as detailed in Section 5.9, Hydrology and Water Quality. Thus, the Project would
not expose people or structures to risks, including downslope or downstream flooding or landslides, as a
result of runoff, post-fire slope instability, or drainage changes. No impacts would occur.
Snug Harbor Surf Park Project 7. Effects Found Not Significant
City of Newport Beach 7-5
Draft EIR
May 2025
7.5 REFERENCES
California Department of Conservation (CDC). (2025). Farmland Mapping & Monitoring Program.
https://www.conservation.ca.gov/dlrp/fmmp
California Department of Forestry and Fire Protection (CAL FIRE). (2025). Fire Hazard Severity Zone Maps.
Retrieved February 14, 2025, from https://osfm.fire.ca.gov/what-we-do/community-wildfire-
preparedness-and-mitigation/fire-hazard-severity-zones
Carl Kim Geotechnical, Inc. (2024). Geotechnical Exploration, Proposed Wavegarden Cove, 3100 Irvine
Avenue, Newport Beach, California. (Appendix H)
City of Newport Beach. (2001, January). Santa Ana Heights Specific Plan. Retrieved September 23, 2024,
from ocpublicworks.com.
City of Newport Beach. (2006a, July). General Plan. Retrieved September 23, 2024, from
newportbeachca.gov: https://www.newportbeachca.gov/government/departments/community-
development/planning-division/general-plan-codes-and-regulations/general-plan
City of Newport Beach. (2006b, July). General Plan Environmental Impact Report. Retrieved September 23,
2024, from newportbeachca.gov:
https://www.newportbeachca.gov/government/departments/community-development/planning-
division/general-plan-codes-and-regulations/general-plan/general-plan-environmental-impact-
repor
City of Newport Beach. (2024, May). Newport Beach Municipal Code. Retrieved September 23, 2024,
from codepublishing.com: https://www.codepublishing.com/CA/NewportBeach/
Snug Harbor Surf Park Project 7. Effects Found Not Significant
City of Newport Beach 7-6
Draft EIR
May 2025
This page intentionally left blank.
Snug Harbor Surf Park Project 8. Alternatives
City of Newport Beach 8-1
Draft EIR
May 2025
8. Alternatives
This section addresses alternatives to the proposed Project and describes the rationale for including them in
the Draft EIR. The section also discusses the environmental impacts associated with each alternative and
compares the relative impacts of each alternative to those of the proposed Project. In addition, this section
describes the extent to which each alternative meets the Project objectives.
8.1 INTRODUCTION
The identification and analysis of alternatives to a project is a fundamental part of the environmental review
process pursuant to CEQA. Public Resources Code (PRC) Section 21002.1(a) establishes the need to address
alternatives in an EIR by stating that in addition to determining a project’s significant environmental impacts
and indicating potential means of mitigating or avoiding those impacts, “the purpose of an environmental
impact report is to identify alternatives to the project.”
Pursuant to CEQA Guidelines Section 15126.6(a), an EIR must describe a reasonable range of alternatives
to the proposed project or to the project’s location that would feasibly avoid or lessen its significant
environmental impacts while attaining most of the proposed project’s objectives. CEQA Guidelines Section
15126.6(b) emphasizes that the selection of project alternatives be based primarily on the ability to reduce
impacts relative to the proposed project. In addition, CEQA Guidelines Section 15126.6(e)(2) requires the
identification and evaluation of an “Environmentally Superior Alternative”.
Pursuant to CEQA Guidelines Section 15126.6(d), discussion of each alternative presented in this EIR Section
is intended “to allow meaningful evaluation, analysis, and comparison with the proposed project.” As
permitted by CEQA, the significant effects of each alternative are discussed in less detail than those of the
proposed Project, but in enough detail to provide perspective and allow for a reasoned choice among
alternatives to the proposed Project.
In addition, the “range of alternatives” to be evaluated is governed by the “rule of reason” and feasibility,
which requires the EIR to set forth only those alternatives that are feasible and necessary to permit an
informed and reasoned choice by the lead agency and to foster meaningful public participation (CEQA
Guidelines Section 15126.6(f)). CEQA generally defines “feasible” to mean an alternative that is capable
of being accomplished in a successful manner within a reasonable period of time, taking into account
economic, environmental, social, technological, and legal factors and other considerations (CEQA Guidelines
Sections 15091(a)(3), 15364).
Based on the CEQA requirements described above, the alternatives addressed in this EIR were selected in
consideration of one or more of the following factors:
• The extent to which the alternative could avoid or substantially lessen any of the identified significant
environmental effects of the proposed Project;
• The extent to which the alternative could accomplish the objectives of the proposed Project;
• The potential feasibility of the alternative;
• The appropriateness of the alternative in contributing to a “reasonable range” of alternatives that would
allow an informed comparison of relative advantages and disadvantages of the proposed Project and
potential alternatives to it; and
• The requirement of the CEQA Guidelines to consider a “no project” alternative; and to identify an
“environmentally superior” alternative in addition to the no project alternative (CEQA Guidelines Section
15126.6(e)).
Snug Harbor Surf Park Project 8. Alternatives
City of Newport Beach 8-2
Draft EIR
May 2025
Neither the CEQA statute, the CEQA Guidelines, nor recent court cases specify a specific number of
alternatives to be evaluated in an EIR. Rather, “the range of alternatives required in an EIR is governed by
the rule of reason that sets forth only those alternatives necessary to permit a reasoned choice” (CEQA
Guidelines 15126(f)).
8.2 SIGNIFICANT ENVIRONMENTAL EFFECTS
CEQA requires the alternatives selected for comparison in an EIR to avoid or substantially lessen one or more
significant effects of the project being evaluated. The analysis in Section 5 of this Draft EIR determined that
no significant and unavoidable impacts would result from implementation of the proposed Project, and all
potentially significant impacts of the Project can be mitigated to a less-than-significant level. Therefore, the
analysis of alternatives in this EIR is intended to identify alternatives that would avoid or substantially lessen
the need for mitigation, or to further reduce less-than-significant environmental impacts of the Project.
Biological Resources
As detailed in Section 5.3, Biological Resources, the Project contains trees and shrubs that can support nesting
songbirds or raptors as well as western yellow bats. Mitigation measures would lessen impacts associated
with Impacts BIO-1 and BIO-4 to a less-than-significant level. Mitigation Measure BIO-1 requires a pre-
construction bat roost survey. Mitigation Measure BIO-2 requires compliance with the Federal Migratory Bird
Treaty Act by requiring a nesting bird survey should construction commence during nesting season, which
ensures implementation of a regulatory requirement. With implementation of Mitigation Measures BIO-1
and BIO-2, potential impacts to biological resources would be less than significant.
Cultural Resources
As detailed in Section 5.4, Cultural Resources, earthmoving activities, including grading and trenching
activities, are expected to result in excavation to 15 feet below ground surface to remove and recompact
undocumented fill soils. As the Project site is sensitive for archaeological resources, the Project would be
required to implement Mitigation Measures CUL-1 and CUL-2, which require an archaeologist to be retained
for monitoring throughout proposed Project ground disturbing activities, implementation of appropriate
activities should potential resources are found, and preparation of a monitoring report. With implementation
of Mitigation Measures CUL-1 and CUL-2, impacts to archaeological resources would be less than significant.
Geology and Soils
As discussed in Section 5.6, Geology and Soils, while no paleontological resources were identified during the
field survey, there is a potential to disturb previously unknown paleontological resources. The Project site is
underlain by fill soils and young axial channel deposits to 10 feet in depth, which are underlain by old
paralic deposits and other Pleistocene deposits. Due to the occurrence of terrestrial and marine fossils at
shallow depths from late Pleistocene alluvial fan sediments across Orange County, the sediments underlying
the Project site are identified as having high paleontological sensitivity. Mitigation Measure PAL-1 is included
to require preparation of a Paleontological Resources Impact Mitigation Program (PRIMP) and that
excavation activities below 10 feet below ground surface (bgs) be monitored by a qualified professional
paleontologist to identify and recover any potentially significant fossil remains identified during earthmoving
activities. With implementation of Mitigation Measure PAL-1, potential impacts to paleontological resources
would be less than significant.
Snug Harbor Surf Park Project 8. Alternatives
City of Newport Beach 8-3
Draft EIR
May 2025
Tribal Cultural Resources
As discussed in Section 5.15, Tribal Cultural Resources, the Project site has been previously disturbed for
construction of the existing buildings, golf course, and infrastructure. Although no TCRs have been identified,
during the SB 18/AB 52 consultation it was detailed that the proposed Project lies within ancestral tribal
territory within a potentially sensitive area. Therefore, to avoid potential adverse effects to tribal cultural
resources, Mitigation Measures TCR-1 through TCR-3 have been included to provide for Native American
resource monitoring and to prescribe activities should any inadvertent discoveries of tribal cultural resources
be unearthed by Project construction activities. With implementation of Mitigation Measures TCR-1 through
TCR-3, impacts to tribal cultural resources would be less than significant.
8.3 PROJECT OBJECTIVES
The intent of the Snug Harbor Surf Park Project is to develop and operate an alternative surfing facility to
provide consistent and predictable waves for training, lessons, and contests to enhance the Newport Beach
surf culture and recreation base, and to provide accommodations to support traveling athletes, coaches, and
surf park guests.
CEQA Guidelines Section 15124(b) states that an EIR shall contain a clearly written statement of objectives
to help the lead agency develop a reasonable range of alternatives to evaluate in the EIR; and that the
objectives should include the underlying purpose of the project and may discuss project benefits. The Project-
specific CEQA objectives have been carefully crafted in order to aid decision makers in their review of the
proposed Project and its associated environmental impacts. The CEQA Project objectives include the
following:
1. Provide an innovative, world-class, full-service, outdoor recreational opportunity to serve a wide range
of guests.
2. Maintain consistency with the existing Santa Ana Heights Specific Plan (SP-7) and the Open Space and
Recreation (OSR) Specific Plan designation.
3. Expand the City’s tourism economy and expand transient occupancy tax revenues.
4. Utilize sustainable solar energy onsite that is consistent with the City’s sustainability goals.
8.4 ALTERNATIVES CONSIDERED BUT REJECTED
Alternate Site. An alternate site for the proposed Project was eliminated from further consideration. Based
on a review of available sites for sale and the City of Newport Beach General Plan land use map, there
are no other available properties of similar size (15.38 developable acres) that are zoned for commercial
recreational uses that could accommodate the site with fewer potential impacts. There are no suitable sites
within the control of the Project Applicant; however, in the event land could be purchased of suitable size,
due to the built-out nature of the City of Newport Beach, development of a recreational surf park would
likely require demolition of structures, removal of existing vegetation, and require similar excavation that
would require the same, and potentially additional, mitigation. CEQA specifies that the key question
regarding alternative site consideration is whether the basic Project objectives would be attained and if any
of the significant effects of the proposed Project would be avoided or substantially lessened by having the
proposed Project at another location. Given these reasons, it would be infeasible to develop and operate
the proposed Project on an alternate site with fewer environmental impacts while meeting Project objectives.
Therefore, the Alternate Site Alternative was rejected from further consideration.
Snug Harbor Surf Park Project 8. Alternatives
City of Newport Beach 8-4
Draft EIR
May 2025
8.5 ALTERNATIVES SELECTED FOR FURTHER ANALYSIS
Three alternatives to the proposed Project have been identified for further analysis as representing a
reasonable range of alternatives that attain most of the objectives of the Project, may avoid or substantially
lessen any of the already less than significant effects of the proposed Project, and are feasible from a
development perspective. These alternatives have been developed based on the criteria identified in Section
8.1, and are described below:
Alternative 1: No Project/No Build Alternative. Pursuant to Section 15126.6(e)(2) of the CEQA Guidelines,
the EIR is required to include a “no project” alternative that shall “discuss the existing conditions at the time
the notice of preparation is published, or if no notice of preparation is published, at the time the
environmental analysis is commenced, as well as what would be reasonably expected to occur in the
foreseeable future if the project were not approved, based on current plans and consistent with available
infrastructure and community services.”
Therefore, under this alternative, no new development would occur on the Project site, and it would remain
in its existing condition with three holes of golf, a driving range, putting green, and the existing pro shop
and restaurant. This alternative compares impacts of the proposed Project with the existing buildings and
golf facilities operating at full capacity.
Alternative 2: Reduced Project Alternative. Under the Reduced Project Alternative, the proposed
development of the Project would be reduced by 50 percent on the same site. The surf lagoon would consist
of one 5.1-million-gallon basin on the site. The amenity clubhouse would provide for the same functions
(although amenities, storage, and golf support areas would be reduced) within a 50 percent smaller (34,239
square feet) three-story building structure. The athlete accommodations building would be a 50 percent
smaller, two-story structure that would provide 10 units, with five units on each level. The Reduced Project
Alternative would also provide for 50 percent less parking on the site. The additional space provided by
the 50 percent smaller development footprint would be landscaped. Hours of operation and operational
activities would be the same as those proposed by the Project. Consistent with the proposed Project all of
the golf amenities would be removed from the Project site and the nine holes of golf (holes 10-18) to the
north of Irvine Avenue and the six holes of golf (holes 3-8) to the south of Mesa Drive would remain.
Alternative 3: Alternative Commercial Recreation Use Alternative. Under this alternative, the proposed
Project site would be developed with a multipurpose recreational facility. A multipurpose recreational facility
contains two or more of the following land uses combined at one site: miniature golf, batting cages, video
arcade, bumper boats, go-carts, and golf driving range.
The Alternative Commercial Recreation Use Alternative would include the development of a 20,000-square-
foot family entertainment building consisting of a snack bar, dining area, restrooms, and arcade gaming
area; two outdoor 18-hole miniature golf courses; a 4-acre outdoor area for attractions and rides; and a
parking lot. Hours of operation would be consistent with those proposed by the Project.
8.6 ALTERNATIVE 1: NO PROJECT/NO BUILD
Under this alternative, the proposed Project would not be approved, and no development would occur. The
existing three holes of golf, driving range, pro shop, restaurant, and parking lot would remain and would
be operational. In accordance with the CEQA Guidelines, the No Project/No Build Alternative for a
development project on an identifiable property consists of the circumstance under which the project does
not proceed. Section 15126.6(e)(3)(B) of the CEQA Guidelines states that, “In certain instances, the no project
alternative means ‘no build’ wherein the existing environmental setting is maintained.” In addition, the no
Snug Harbor Surf Park Project 8. Alternatives
City of Newport Beach 8-5
Draft EIR
May 2025
project includes what would be reasonably expected to occur in the foreseeable future if the project were
not approved, based on current plans and consistent with available infrastructure and community services.
Therefore, under this alternative, no new development would occur on the Project site, and it would remain
in its existing condition where the golf facilities, restaurant, and pro shop would remain operational with the
same number of employees that currently exist. Accordingly, Alternative 1: No Project/No Build provides a
comparison between the environmental impacts of the proposed Project in contrast to the result from not
approving, or instead denying, the proposed Project. Thus, this alternative is intended to meet the
requirements of CEQA Guidelines Section 15126.6(e) for evaluation of a no project alternative.
8.6.1 Environmental Impacts
Aesthetics
Under this alternative, the Project site would remain in its existing condition with three holes of golf, a driving
range, putting green, pro shop and restaurant. Existing views of nets, poles, existing trees, parking lot, site
buildings, and golf course areas would be visible from offsite locations. No new structures or landscaping
would be introduced, and this alternative would not introduce any structures to the Project site. This alternative
would not create new sources of light and glare. However, this alternative would also not provide new
landscaping along the perimeter of the site. Overall, this alternative would not change the existing visual
character and quality; and therefore, impacts would be less than the Project’s less-than-significant impacts.
Air Quality
Under this alternative, the Project site would remain in its existing condition with three holes of golf, a driving
range, putting green, pro shop, and restaurant. Although both the proposed Project and the No Project/No
Build Alternative would be consistent with the South Coast Air Quality Management District (SCAQMD) Air
Quality Management Plan (AQMP), this alternative would reduce emissions compared to the proposed
Project because no new development would occur, no construction would occur, and no increases in vehicular
trips would occur. The construction and operational air quality emissions from the Project would be below
applicable SCAQMD regional, local, and health risk thresholds; however, the No Project/No Build
Alternative would not increase emissions of criteria pollutants or diesel particulate matter (DPM) over existing
conditions. Therefore, this alternative would result in reduced impacts to regional air quality and sensitive
receptors compared to the proposed Project. This alternative would also not generate any additional or new
odors. Therefore, the No Project/No Build Alternative would have less-than-significant impacts and result in
less impacts than the proposed Project.
Biological Resources
Under this alternative, no vegetation removal or grading would occur, and there would be no potential
impacts to special-status plants, animals, or sensitive vegetation communities in the Project site. Although
mitigation measures required of the proposed Project would reduce biological resource impacts from
construction activities to less-than-significant levels, this alternative would generate no impacts to biological
resources as compared with the proposed Project and would not require mitigation. Therefore, the No
Project/No Build Alternative would result in less impacts than the proposed Project.
Cultural Resources
Under this alternative, the onsite buildings would remain the same. No grading for construction would occur,
and there would be no potential impacts to archaeological resources or human remains that may be buried
below ground. Although existing regulations and mitigation measures required of the proposed Project would
Snug Harbor Surf Park Project 8. Alternatives
City of Newport Beach 8-6
Draft EIR
May 2025
reduce cultural resource impacts to less-than-significant levels, this alternative would avoid potential impacts
to archaeological resources and human remains associated with the proposed Project and would not require
mitigation. Therefore, the No Project/No Build Alternative would result in less impacts than the proposed
Project.
Energy
Under the No Project/No Build Alternative no construction activities would occur at the Project site, and no
new operation of structures would occur that could increase consumption of energy sources. The existing golf
facilities, pro-shop, and restaurant onsite would continue standard operation. Electricity and natural gas
usage would be lower under the No Project/No Build Alternative than for the proposed Project. While
Project impacts to energy would be less than significant, energy use associated with this alternative would
not increase. Therefore, the No Project/No Build Alternative would result in less impacts than the proposed
Project.
Geology and Soils
Under the No Project/No Build Alternative, no construction activities, including grading, would occur under
this alternative. Thus, there would be no potential for additional workers, building, and structures to
experience seismic ground shaking, liquefaction, lateral spreading, subsidence, or collapse within the Project
site. Additionally, as no grading activities would occur under this alternative, potential impacts from erosion,
loss of topsoil, or to paleontological resources would not occur. While the proposed Project impacts would
be less than significant with implementation of existing regulations and mitigation, this alternative would
result in no impacts and no mitigation measures would be required. Therefore, the No Project/No Build
Alternative would result in less impacts than the proposed Project.
Greenhouse Gas Emissions
Under the No Project/No Build Alternative, no new construction activities would occur at the Project site, and
no operation of new structures that would generate greenhouse gas (GHG) emissions would occur under this
alternative. Operation and maintenance of the existing golf course, driving range, putting green, pro shop,
and restaurant would continue. These activities would continue to generate small levels of GHG emissions
from onsite activities. Therefore, this alternative would result in less GHG emissions compared to the proposed
Project; but both would be less than significant.
Hazards and Hazardous Materials
Under the No Project/No Build Alternative, no new construction activities would occur at the Project site or
and no new operations would occur that could generate, use, or result in transport of, hazardous materials.
The No Project/No Build Alternative would not include any construction activities that would use typical
construction-related hazardous materials. Thus, potential impacts related to use, disposal, and transport of
hazardous materials would be avoided by this alternative. While the Project’s impacts related to hazards
and hazardous materials would be less than significant, this alternative would result in less impacts because
no grading, construction, or use of new hazardous substances would occur. Therefore, the No Project/No
Build Alternative would result in less potential impacts than the proposed Project.
Hydrology and Water Quality
Existing water quality conditions, groundwater supplies, drainage patterns, and runoff water amounts would
remain “as is” under this alternative as no new development would occur. The No Project/No Build Alternative
would not introduce new sources of water pollutants from either the construction or operation phases of
Snug Harbor Surf Park Project 8. Alternatives
City of Newport Beach 8-7
Draft EIR
May 2025
development to the Project site, because no new development would occur. Additionally, this alternative
would not require the storm drain facility improvements that would be necessary with the Project. This
alternative would maintain a 90 percent pervious surface area of the Project site. However, this alternative
would not include installation of new low-impact development (LID) treatment control best management
practices (BMPs) to minimize runoff, which would be included with the Project. The No Project/No Build
Alternative would result in similar impacts related to hydrology and water quality, compared to those that
would occur from the proposed Project.
Land Use and Planning
The No Project/No Build Alternative would not result in new development, and as such, there would be no
potential for land uses to be introduced that would physically divide a community or indirectly result in
environmental impacts due to a conflict with an existing land use plan. The No Project/No Build Alternative
would not require a General Plan Amendment (GPA), a Conditional Use Permit (CUP), a Modification Permit,
or a Major Site Development Review (SDR). The alternative does not require an aeronautical review by the
FAA or an Airport Environs Land Use Plan (AELUP) consistency review by the Orange County Airport Land
Use Commission (ALUC). Overall, the No Project/No Build Alternative would result in no impacts to land use
and planning, and therefore, would be less than the Project’s less-than-significant impacts.
Noise
Under the No Project/No Build Alternative, no development would occur onsite, and no new sources of noise
would be introduced at the Project site. Since no new development would occur and no traffic trips would
be generated, this alternative would not contribute to any increase in existing area-wide traffic noise levels
or additional ambient noise. In addition, this alternative would not result in construction onsite and no
construction noise or vibration would occur. Therefore, the No Project/No Build Alternative would result in
less impacts than the proposed Project’s less-than-significant impacts.
Public Services
The No Project/No Build Alternative would not result in new development, and as such, would not result in
increased demand for public services such as fire and police services, school services, library services, or
other services that could requires new construction of public facilities. Therefore, while the proposed Project’s
impacts would be less than significant through compliance with existing regulations, the No Project/No Build
Alternative would result in no new impacts.
Parks and Recreation
The No Project/No Build Alternative would not result in new development, and as such would not result in
any new people on the site and no potential impact nearby parks or require the development of additional
park resources. Therefore, impacts from the No Project/No Build Alternative would be less than those of the
proposed Project.
Transportation
The No Project/No Build Alternative would not result in new development, and as such, would not result in
any change to existing vehicle trips, traffic, or vehicle miles traveled (VMT). This alternative would also not
affect existing transit services, sidewalks, or bicycle routes. As the existing site operations would remain,
under the No Project/No Build Alternative fewer average daily trips would be generated than those of the
proposed Project (refer to Section 5.14, Transportation). Therefore, the No Project/No Build Alternative
would result in less impacts than the proposed Project’s less-than-significant impacts.
Snug Harbor Surf Park Project 8. Alternatives
City of Newport Beach 8-8
Draft EIR
May 2025
Tribal Cultural Resources
Under the No Project/No Build Alternative, existing conditions would remain, and no land disturbances, such
as excavation or grading would occur. Thus, no potential impacts to tribal cultural resources that may be
buried below ground would occur. This alternative would avoid the potential impacts to tribal cultural
resources that would occur by the Project and would not require mitigation. Therefore, the No Project/No
Build Alternative would avoid the need for mitigation and result in less impacts than the proposed Project.
Utilities and Service Systems
Under this alternative, existing conditions would remain, and no new development would occur. No additional
domestic water, wastewater, stormwater drainage, electric power, or natural gas facilities would be needed
under this alternative, and there would be no change in the demand for domestic water or wastewater
treatment services. This alternative would also not result in increased demand for solid waste collection and
disposal. While the proposed Project would result in less-than-significant impacts, this alternative would result
in less impacts, as no increase in needs for utilities and service systems would occur. Therefore, the No
Project/No Build Alternative would result in less impacts than the proposed Project.
8.6.2 Conclusion
Ability to Reduce Impacts
The No Project/No Build Alternative would result in continuation of the existing golf, restaurant, and pro-
shop related uses within the Project site, and no new commercial recreational uses on the site would occur.
This alternative would result in fewer potential impacts and would not require mitigation for biological
resources, cultural resources, paleontological resources, and tribal cultural resources because no ground
disturbance or other construction activities would occur. As a result, the mitigation measures that are identified
in Section 5 of this EIR would not be required for implementation of the No Project/No Build Alternative.
Ability to Achieve Project Objectives
As shown in Table 8-5 at the end of this section, the No Project/No Build Alternative would not meet most of
the proposed Project objectives. Although this alternative would maintain consistency with the SP-7 and OSR
Specific Plan designation, this alternative would not provide an innovative, world-class outdoor recreational
opportunity. This alternative would not expand the City’s tourism economy and expand transient tax
occupancy tax revenue. Furthermore, sustainable solar energy would not be installed onsite. Thus, the No
Project/No Build Alternative would not meet most of the proposed Project objectives.
8.7 ALTERNATIVE 2: REDUCED PROJECT ALTERNATIVE
Under the Reduced Project Alternative, the proposed Project would be reduced by 50 percent on the same
site. The surf lagoon would consist of one 5.1-million-gallon basin on the site. The amenity clubhouse would
provide the same functions (although amenities, storage, and golf support areas would be reduced) within
a 50 percent smaller (34,239 square feet) three-story building structure. The athlete accommodations
building would be a 50 percent smaller two-story structure that would provide 10 units with five units on
each level. The alternative would also provide for 50 percent less parking on the site. The additional space
provided by the 50 percent smaller development footprint would be landscaped. Hours of operation and
operational activities would be the same as those proposed by the Project. Consistent with the proposed
Project all of the golf amenities would be removed from the Project site and the nine holes of golf (holes 10-
Snug Harbor Surf Park Project 8. Alternatives
City of Newport Beach 8-9
Draft EIR
May 2025
18) to the north of Irvine Avenue and the six holes of golf (holes 3-8) to the south of Mesa Drive would
remain.
8.7.1 Environmental Impacts
Aesthetics
Under the Reduced Project Alternative, the Project site would be developed with a single, 5.1-million-gallon
surf basin, a 34,239-square-foot three-story amenity clubhouse building, and a two-story, 10-unit athlete
accommodation building. Development under the Reduced Project Alternative would reduce the proposed
development footprint by approximately 50 percent. This alternative would remove the existing structures,
poles, and netting on the site and develop two new buildings and one surf basin that would be visually less
dense than the proposed Project with increased setbacks and a larger percentage of landscaped area. The
Reduced Project Alternative would be consistent with the Santa Ana Heights Specific Plan design guidelines;
but, consistent with the Project, would require a GPA and Major Site Development Review for development
of over 20,000 square feet on the site, and a CUP for parking and construction of buildings in excess of 18
feet. This alternative would also introduce new sources of light and glare like the proposed Project (although
from a smaller area from the reduction of development) and would be similarly subject to the Newport
Beach Municipal Code lighting requirements that would be verified during the development review and
permitting process. Overall, the Reduced Project Alternative would result in a smaller development with less
visual mass but would result in similar less-than-significant impacts as the proposed Project.
Air Quality
Under the Reduced Project Alternative, the proposed Project would be reduced by 50 percent. The Project
site would be developed with one 5.1-million-gallon surf basin, a 34,239-square-foot amenity clubhouse
building, and a two-story, 10-unit athlete accommodation building. The Reduced Project Alternative would
incrementally reduce the amount and duration of construction activities compared to the proposed Project,
which in turn would result in less overall construction-related air quality emissions. However, as air quality
emissions are based on peak day emissions pursuant to SCAQMD guidance, the daily grading and
construction activities would have similar levels of maximum daily emissions that would be less than significant.
Under this alternative, operational air quality emissions would be approximately 50 percent of those that
would be generated by the proposed Project because only one surf basin and 10 accommodation units
would be operational. Likewise, the Reduced Project Alternative would generate a reduction in the number
of vehicle trips compared to the proposed Project. As the Project would result in operational emissions below
SCAQMD thresholds, the Reduced Project Alternative would result in emissions that would be further below
SCAQMD thresholds. Therefore, this alternative would result in less overall air quality impacts compared to
the Project; however, impacts under both scenarios would be less than significant.
Biological Resources
Under the Reduced Project Alternative, the proposed Project would be reduced by 50 percent. However,
development of this alternative would continue to require demolition of the existing structures and removal
of existing vegetation, including trees and shrubs, which could provide nesting habitat for migratory bird
and bat species. As such, the impacts to biological resources at the Project site would be similar to the Project
and require Mitigation Measures BIO-1 and BIO-2 to reduce potential impacts to nesting birds and roosting
bats. These mitigation measures would reduce potential impacts from this alternative to a less-than-significant
level, which is consistent with the proposed Project. Thus, under both the Reduced Project Alternative and the
proposed Project, impacts would be less than significant with mitigation incorporated.
Snug Harbor Surf Park Project 8. Alternatives
City of Newport Beach 8-10
Draft EIR
May 2025
Cultural Resources
Under the Reduced Project Alternative, the proposed Project would be reduced by 50 percent. Consistent
with the findings for the proposed Project, no impacts related to historic resources would occur under this
alternative scenario. However, development of this alternative would continue to require excavation and
grading that could impact potential archaeological resources or human remains. Thus, potential impacts
would be similar to the Project and the same mitigation (Mitigation Measures CUL-1 and CUL-2) would be
required to reduce potential impacts related to inadvertent discovery of an archeological resource during
construction to a less-than-significant level. Further, like the proposed Project, in the unanticipated event that
human remains are found during construction activities compliance with California Health and Safety Code
Section 7050.5 would ensure that human remains are treated with dignity and as specified by law and
provide that the impact is less than significant. Therefore, although the area and depth of
excavation/grading would be less under the Reduced Project Alternative, potential impacts would be similar
to those under the proposed Project and mitigation measures would be required. Under both the Reduced
Project Alternative and the proposed Project, impacts would be less than significant with compliance with
existing regulations and mitigation incorporated.
Energy
Under the Reduced Project Alternative, approximately 50 percent less building area and only one surf basin
would be developed within the Project site. This would result in an approximately 50 percent less demand
for energy in comparison to the proposed Project, which was determined to be less than significant. This
alternative would also be required to be in compliance with Title 24 requirements and would include similar
features to reduce energy usage, such as EV charging stations, solar panels on building roofs, and solar
panels on canopies in the parking area to implement onsite renewable energy. Therefore, impacts to energy
from the Reduced Project Alternative would be less than significant, which is consistent with the proposed
Project.
Geology and Soils
The Reduced Project Alternative would develop the Project site with one 5.1-million-gallon surf basin, a
34,239-square-foot amenity clubhouse building, and a two-story, 10-unit athlete accommodation building
that would result in approximately 50 percent less development than the proposed Project. Although the
structures and capacity of the site would be less under the Reduced Project Alternative, the same potential
risks related to seismic ground shaking, liquefaction, lateral spreading, subsidence, or collapse within the
Project site would occur, and the same California Building Code requirements would apply. Likewise, the
same potential soil erosion impacts would be less than significant with compliance with NPDES water quality
standards which would be verified through the City’s permitting process.
Although the area of excavation that would occur by the Reduced Project Alternative would be smaller than
that of the proposed Project, the same mitigation measures regarding paleontological resources would be
required. Overall, this alternative would also result in the same type of potential impacts and would be
required to comply with the same regulations and mitigation measures. Therefore, impacts under the Reduced
Project Alternative would be the same as those of the proposed Project.
Greenhouse Gas Emissions
Under the Reduced Project Alternative, the proposed Project would be reduced by 50 percent. The Project
site would be developed with one 5.1-million-gallon surf basin, a 34,239-square-foot amenity clubhouse
building, and a two-story, 10-unit athlete accommodation building. Therefore, a reduced volume of
construction activities and related production of GHG emissions would occur. In addition, the reduced amount
Snug Harbor Surf Park Project 8. Alternatives
City of Newport Beach 8-11
Draft EIR
May 2025
of development by this alternative would result in less stationary source emissions from onsite equipment,
and less vehicular trips associated GHG emissions would occur compared to the proposed Project. Therefore,
the overall volume of GHG emissions would be reduced in comparison to the proposed Project and would
also be below the SCAQMD’s 3,000 MTCO2e threshold. While GHG emissions associated with the Project
were determined to be less than significant, this alternative would result in less overall GHG emissions.
Impacts under both the proposed Project and the Reduced Project Alternative would be less than significant.
Hazards and Hazardous Materials
Under the Reduced Project Alternative, the proposed Project would be reduced by 50 percent. The Project
site would be developed with one 5.1-million-gallon surf basin, a 34,239-square-foot amenity clubhouse
building, and a two-story, 10-unit athlete accommodation building. The Reduced Project Alternative would
involve use, storage, and transport of the same types of hazardous materials for construction and operation.
Like the proposed Project, this alternative would be required to comply with existing regulations regarding
hazardous materials such as fuel, paints, solvents, chlorine, and other similar substances that would reduce
potential impacts to a less-than-significant level. Likewise, California Code of Regulations Sections 1529 and
341.6 through 341.14 as implemented by SCAQMD Rule 1403 (included as PPP HAZ-1) ensure that asbestos
removed during demolition of the existing buildings is transported and disposed of at an appropriate
facility. Demolition and disposal of lead-based materials are regulated by the Code of Federal Regulations
Title 29, Section 1926.62, and the California Code of Regulations Title 8 Section 1532.1, as implemented
by CalOSHA (and included as PPP HAZ-2), which would also be implemented under this alternative to reduce
potential impacts and would be consistent with the proposed Project.
The Reduced Project Alternative and the proposed Project would result in the same less-than-significant
hazard impacts related to operations at John Wayne Airport (SNA), which is located 0.4 miles northeast of
the Project site. The Reduced Project Alternative would include PDF-2, that would ensure onsite landscaping
does not produce seeds, fruits, nuts, or berries providing food for birds that would be an attractant and
wildlife hazards to airport operations would be less than significant.
The Project site is within the AELUP Notification Area, FAR Part 77 Notification Imaginary Surface area,
within airport safety zones, and is within the 65 CNEL noise contour. Like the proposed Project, the Reduced
Project Alternative would require AELUP review and an FAA Park 77 evaluation. However, both the
proposed Project and the Reduced Project Alternative would result in less-than-significant impacts related to
SNA operational hazards. Overall, this alternative would result in the same less-than-significant impacts to
hazards and hazardous materials as the proposed Project; and therefore, would be consistent with the
proposed Project.
Hydrology and Water Quality
Under the Reduced Project Alternative, the proposed Project would be reduced by 50 percent. Due to the
decrease in development, this alternative would result in a decrease in impermeable surfaces and an
increase in pervious landscaping areas compared to the Project. Consistent with the Project, construction of
the alternative would require implementation of a SWPPP and operational stormwater drainage would be
managed through implementation of a WQMP that would detail the design of vegetated biotreatment
systems for water quality that would be sized to treat runoff from the Design Capture Storm (85th percentile,
24-hour) as required by the Orange County DAMP. Thus, consistent with the Project these construction and
operational impacts to site runoff, hydrology, and water quality from the Reduced Project Alternative would
be less than significant.
The Reduced Project Alternative would result in a reduction in water demand, as only one surf basin would
be developed, the amenity clubhouse would be 50 percent smaller, and 50 percent fewer athlete
Snug Harbor Surf Park Project 8. Alternatives
City of Newport Beach 8-12
Draft EIR
May 2025
accommodation units would be developed. As the Project water demand would consist of approximately
17.2 percent of the anticipated increase in water supply between 2025 and 2030, the Reduced Project
Alternative would be approximately half. Although a greater volume of landscaping irrigation may occur
from the larger setback onsite, the Reduced Project Alternative would generate a reduction in overall water
demand. Consistent with the Project, impacts related to groundwater recharge and groundwater
management would be less than significant under the Reduced Project Alternative.
Land Use
Under the Reduced Project Alternative, the Project site would be developed with a single 5.1-million-gallon
surf basin, a 34,239-square-foot three-story amenity clubhouse building, and a two-story, 10-unit athlete
accommodation building. Development under the Reduced Project Alternative would reduce the proposed
development footprint by approximately 50 percent. This alternative would result in the same onsite uses
with less capacity and increased setbacks compared to the proposed Project. This alternative would not
physically disrupt or divide the arrangement of an established community. The Reduced Project Alternative
would be consistent with the General Plan policies and Santa Ana Heights Specific Plan design guidelines;
but, consistent with the Project, the alternative would require a General Plan Amendment and Major Site
Development Review for development of over 20,000 square feet on the site, and a CUP for parking and
construction of buildings in excess of 18 feet. In addition, this alternative would be less consistent with the
intent of the General Plan Land Use designation of Parks and Recreation (PR) because it would provide less
recreation facilities. Overall, the Reduced Project Alternative would require the same planning approvals
and impacts related to land use and planning from the Reduced Project Alternative would be less than
significant, which is consistent with the proposed Project.
Noise
Under the Reduced Project Alternative, the proposed Project would be reduced by 50 percent. The Project
site would be developed with one 5.1-million-gallon surf basin, a 34,239-square-foot amenity clubhouse
building, and a two-story, 10-unit athlete accommodation building. The Reduced Project Alternative would
involve the same types of noise sources, although construction noise would be over a shorter timeframe, and
operation of this alternative would result in approximately one half of the daily trips in comparison to the
proposed Project. Therefore, this alternative would result in a decrease in roadway noise when compared
to the proposed Project and impacts would similarly be less than significant. Short-term noise and vibration
impacts during construction would be similar to the Project. Like the Project, long-term operational noise
would not expose nearby sensitive receivers to noise levels over the City’s daytime noise standards. Due to
the reduction in development on site under this alternative, noise impacts would be reduced in comparison
to the Project, but impacts would be less than significant under both scenarios.
Public Services
Under the Reduced Project Alternative, the proposed Project would be reduced by 50 percent, which would
likely result in a reduction in employees and a 50 percent reduction in onsite surfers and visitors. The same
fire, police, schools, and other public facilities would serve the Reduced Project Alternative and the same
development impact fees (based on square footage/amount of development) would be required. However,
the decrease in employees, surfers, and visitors to the site would likely decrease the number of fire and
police service calls compared to the proposed Project. Although impacts would be less than significant under
the proposed Project, the need for public services would be reduced under the Reduced Project Alternative.
Snug Harbor Surf Park Project 8. Alternatives
City of Newport Beach 8-13
Draft EIR
May 2025
Parks and Recreation
Under the Reduced Project Alternative, the proposed Project would be reduced by 50 percent, which would
likely result in a reduction in employees and a 50 percent reduction in onsite surfers and visitors. However,
the overall provision of commercial recreation under the Reduced Project Alternative would be with less
without the onsite golf facilities and with only one surf basin and, as described previously, this alternative
would be less consistent with the intent of the PR General Plan Land Use designation because it would provide
less recreation facilities with the land area. The overall provision of commercial recreation would be less
under this alternative compared to the proposed Project and there would be a reduced benefit related to
meeting overall commercial park and recreation needs.
The same public park and recreation facilities would serve the Reduced Project Alternative. The decrease in
employees, surfers, and visitors to the site could decrease the number of park and recreation facility users
compared to the proposed Project. However, the decrease in both golf and surf commercial recreation could
increase the need for parks and recreation at other park and recreation facilities. Overall, impacts related
to parks and recreation would be less than significant under the Reduced Project Alternative, which is
consistent with the proposed Project.
Transportation
Under the Reduced Project Alternative, the proposed Project would be reduced by 50 percent. This would
result in a reduction in employees and a 50 percent reduction in onsite surfers and visitors. This alternative
would continue to provide EV parking, bicycle parking, and be access from existing sidewalks and bicycle
lanes. Approximately half of the daily vehicle trips would occur from implementation of the Reduced Project
Alternative. As the proposed Project would result in 186 new average daily trips, the reduced trips from the
Reduced Project Alternative would be even further below the 300 daily trip threshold identified by the City’s
Traffic Phasing Ordinance (Municipal Code Title 15, Chapter 15.40) and VMT threshold. Thus, consistent with
the proposed Project, impacts from the Reduced Project Alternative would be less than significant.
Also, consistent with the proposed Project, the Reduced Project Alternative would not introduce an
incompatible use, increase hazard due to a geometric design feature, or result in inadequate emergency
access. The City’s development review and permitting process would ensure that transportation hazard and
access impacts would not occur. Overall, this alternative would result in similar less-than-significant impacts
in comparison to the proposed Project.
Tribal Cultural Resources
Under the Reduced Project Alternative, the proposed Project would be reduced by 50 percent. However,
development of this alternative would continue to require excavation and grading that could impact potential
tribal cultural resources. Thus, potential impacts would be similar to the Project and the same mitigation
measures would be required to reduce potential impacts related to inadvertent discovery of a tribal cultural
resource during construction to a less-than-significant level. Therefore, although the area and depth of
excavation/grading would be less under the Reduced Project Alternative, potential impacts would be similar
to those the Project and mitigation measures would be required. Under both the Reduced Project Alternative
and the proposed Project, impacts would be less than significant with mitigation incorporated.
Utilities and Service Systems
Under the Reduced Project Alternative, the proposed Project would be reduced by 50 percent. Both the
Project and this alternative would require the construction of water, wastewater, stormwater drainage,
electric power, natural gas, and telecommunication facilities on the site that would connect to existing offsite
Snug Harbor Surf Park Project 8. Alternatives
City of Newport Beach 8-14
Draft EIR
May 2025
systems. The Reduced Project Alternative would also require draining of the basin every other year, and
therefore, consistent with the Project, the sewer line improvement would also be included.
As detailed previously in the hydrology and water quality discussion, the Reduced Project Alternative would
generate approximately half of the water demand as the proposed Project; and consistent with the Project,
impacts related to water supply in normal, dry, and multiple dry years would be less than significant.
Regarding wastewater treatment, the average annual generation of wastewater would be reduced in
comparison to the proposed Project but impacts under both scenarios would be less than significant.
Consistent with the proposed Project, the Reduced Project Alternative would include installation of a drainage
system that would be sized to treat runoff from the 85th percentile, 24-hour storm as required by the Orange
County DAMP. Thus, consistent with the Project, potential impacts to site drainage from the Reduced Project
Alternative would be less than significant.
As the Reduced Project Alternative would be 50 smaller and have 50 percent less capacity, it is anticipated
that solid waste generated by the alternative would also be approximately half. In addition, this alternative
would be subject to State recycling and solid waste regulations. Thus, the alternative would not result in the
generation of solid waste in excess of landfill capacity and would be required to comply with existing
regulations through the City’s permitting process. Further, the Reduced Project Alternative would require a
reduced volume of natural gas and electricity for operations. Overall, the Reduced Project Alternative would
result in a reduced demand for utilities and service systems, and, consistent with the Project, impacts would
be less than significant.
8.7.2 Conclusion
Ability to Reduce Impacts
Under the Reduced Project Alternative, the proposed Project would be reduced by 50 percent and would
include one 5.1-million-gallon surf basin, a 34,239-square-foot, three-story amenity clubhouse building, and
a two-story, 10-unit athlete accommodation building. The Reduced Project Alternative would result in less
development on the site, but it would continue to require a General Plan Amendment and Major Site
Development Review for development of over 20,000 square feet on the site, and a CUP for parking and
construction of buildings in excess of 18 feet. The same mitigation measures related to biological resources,
archaeological resources, paleontological resources, and tribal cultural resources would be required for
implementation of the Reduced Project Alternative. Similarly, a reduced volume of noise, air quality, and
greenhouse gas emissions would occur from the Reduced Project Alternative; however, impacts under both
the Project and the alternative would be less than significant.
Overall, the Reduced Project Alternative would reduce potential impacts related to six topic areas; however,
all of the mitigation measures required for the Project would continue to be required for the Reduced Project
Alternative (see Table 8-4).
Ability to Achieve Project Objectives
As shown in Table 8-5, the Reduced Project Alternative would meet the Project objectives, but not to the
same extent as the proposed Project. This alternative would develop an innovative outdoor recreational
opportunity; however, it would not offer the full services of the proposed Project including both surf basins
and the same amount of amenities, in the 50 percent smaller amenity clubhouse building. This alternative
would expand the City’s tourism economy, but not the extent or intensity of the proposed Project. The
alternative would utilize sustainable solar energy onsite and would be consistent with SP-7 and the OSR
Snug Harbor Surf Park Project 8. Alternatives
City of Newport Beach 8-15
Draft EIR
May 2025
designation. Overall, the Reduced Project Alternative would not meet all of the Project objectives to the
same extent as the proposed Project.
8.8 ALTERNATIVE 3: ALTERNATIVE COMMERCIAL RECREATION USE
ALTERNATIVE
Under this alternative, the proposed Project site would be developed with a multipurpose recreational
facility. A multipurpose recreational facility contains two or more of the following land uses combined at one
site: miniature golf, batting cages, video arcade, bumper boats, go-carts, and golf driving range. A
refreshment area may also be provided.
The Alternative Commercial Recreation Use Alternative would include the development of a 20,000-square-
foot family entertainment building consisting of a snack bar, dining area, restrooms, and arcade gaming
area; two outdoor 18-hole miniature golf courses; a 4-acre outdoor area for attractions and rides; and a
parking lot. Hours of operation would be consistent with those proposed by the Project.
8.8.1 Environmental Impacts
Aesthetics
The Alternative Commercial Recreation Use Alternative would change the views of the site to those of a
20,000-square-foot family entertainment building, outdoor miniature golf courses, and entertainment
attractions and rides with landscaping along the perimeter of the site. The visual mass of the proposed
building structures would be less under the Alternative Commercial Recreation Use Alternative compared to
the Project’s 68,478 gross square foot amenity clubhouse and two-story athlete accommodations building.
However, the Alternative Commercial Recreation Use Alternative would include attractions and rides that
would be visible from offsite locations and would reach heights of 50 feet above the ground, which is the
same height as the proposed amenity clubhouse building. Consistent with the Project, the Alternative
Commercial Recreation Use Alternative would implement the Santa Ana Heights Specific Plan design
guidelines and other Municipal Code development requirements.
The Alternative Commercial Recreation Use Alternative would have the same hours of operation as the
proposed Project and would also introduce new sources of light and glare. This alternative would be subject
to the same Municipal Code lighting requirements as the Project, that would be verified during the
development review and permitting process. Overall, the Alternative Commercial Recreation Use Alternative
would result in a less-than-significant impact, consistent with the proposed Project.
Air Quality
The Alternative Commercial Recreation Use Alternative would require less excavation and grading than the
proposed Project because two surf basins would not be constructed. Also, a reduction in building square
footage that would be developed under this alternative would result in less construction overall. The
remainder of the construction of this alternative (demolition, building construction, paving, and architectural
coatings) would require a similar amount, type, and length of construction activities as the proposed Project.
Thus, daily construction-related air quality emissions from this alternative would not exceed, and could be
less than, the less-than-significant construction emissions that would be generated by the proposed Project.
Operation of the Alternative Commercial Recreation Use Alternative would result in the same type of
stationary source emissions as the Project from operation of the multipurpose recreational facility. As detailed
below, operation of the Alternative Commercial Recreation Use Alternative would result in 163 fewer daily
Snug Harbor Surf Park Project 8. Alternatives
City of Newport Beach 8-16
Draft EIR
May 2025
vehicular trips than the proposed Project; and therefore, would result in a reduction in daily vehicular
emissions compared to the proposed Project. However, the daily operational emissions from both the
Alternative Commercial Recreation Use Alternative and the proposed Project would not exceed SCAQMD
thresholds, and impacts related to criteria pollutants would be less than significant. The Alternative
Commercial Recreation Use Alternative would also result in less-than-significant impacts related to consistency
with the AQMP, and impacts related to odors would be less than significant under both the proposed Project
and this alternative.
Biological Resources
The Alternative Commercial Recreation Use Alternative includes demolition of the existing structures and
removal of existing vegetation, including trees and shrubs, which could provide nesting habitat for migratory
bird and bat species. As such, the impacts to biological resources at the Project site would be similar to the
Project and require Mitigation Measures BIO-1 and BIO-2 to reduce potential project impacts to nesting
birds and rooting bats. These mitigation measures would reduce potential impacts from this alternative to a
less-than-significant level, which is consistent with the proposed Project. Thus, under both the Alternative
Commercial Recreation Use Alternative and the proposed Project, impacts would be less than significant with
mitigation incorporated.
Cultural Resources
Consistent with the findings for the proposed Project, no impacts related to historic resources would occur
under this alternative scenario. However, the Alternative Commercial Recreation Use Alternative would
redevelop the site that would include excavation and grading that could impact potential archaeological
resources or human remains. Thus, potential impacts would be similar to the Project and the same mitigation
(Mitigation Measures CUL-1 and CUL-2) would be required to reduce potential impacts related to
inadvertent discovery of an archeological resource during construction to a less-than-significant level.
Therefore, potential impacts would be similar to those the Project and mitigation measures would be
required. Further, like the proposed Project, in the unanticipated event that human remains are found during
construction activities compliance with California Health and Safety Code Section 7050.5 would ensure that
human remains are treated with dignity and as specified by law and provide that the impact is less than
significant. Under both the Alternative Commercial Recreation Use Alternative and the proposed Project,
impacts would be less than significant with compliance with existing regulations and mitigation incorporated.
Energy
The Alternative Commercial Recreation Use Alternative would redevelop the Project site to provide a
20,000-square-foot family entertainment building, outdoor miniature golf courses, entertainment attractions
and rides that would require energy supplies. Like the proposed Project, the Alternative Commercial
Recreation Use Alternative would be developed in compliance with the CALGreen/Title 24 requirements
related to energy. Solar panels would be included on the building roof and operation of the onsite amenities
would not use energy in a wasteful or inefficient manner.
As detailed below, operation of the Alternative Commercial Recreation Use Alternative would result in 163
fewer daily vehicular trips than the proposed Project; and therefore, would result in a reduction in vehicular
fuel usage compared to the proposed Project. This would result in an incremental decrease in fuel usage
over that of the proposed Project. The alternative would also include EV charging stations and parking
spaces to provide for electric vehicle usage and renewable energy from solar panels on the site and the
increase in fuel use under the Alternative Commercial Recreation Use Alternative would also not be wasteful,
inefficient, or unnecessary. Therefore, both the proposed Project and the Alternative Commercial Recreation
Use Alternative would result in less-than-significant impacts related to energy.
Snug Harbor Surf Park Project 8. Alternatives
City of Newport Beach 8-17
Draft EIR
May 2025
Geology and Soils
The Alternative Commercial Recreation Use Alternative would redevelop the site with a family entertainment
center/amusement park. This alternative would include the development of a 20,000-square-foot family
entertainment building consisting of a snack bar, dining area, restrooms and arcade gaming area; two
outdoor18-hole miniature golf courses; an outdoor area for attractions and rides; and a parking lot. The
same potential risks related to seismic ground shaking, liquefaction, lateral spreading, subsidence, or
collapse within the Project site would occur, and the same California Building Code requirements would
apply. Likewise, the same potential soil erosion impacts would be less than significant with compliance with
NPDES water quality standards that would be verified through the City’s permitting process.
Although the locations and depths of excavation that would occur by the Alternative Commercial Recreation
Use Alternative would be different than the proposed Project, the same mitigation measures regarding
paleontological resources would be required. Therefore, this alternative would result in the same type of
potential impacts and would be required to comply with the same regulations and mitigation measures.
Therefore, impacts related to geology and soils under the Alternative Commercial Recreation Use Alternative
would be the same as those of the proposed Project.
Greenhouse Gas Emissions
The Alternative Commercial Recreation Use Alternative would require less excavation and grading than the
proposed Project because two surf basins would not be constructed. Also, a reduction in building spare
footage that would be developed under this alternative would result in less construction overall. The
remainder of the construction of this alternative (demolition, building construction, paving, and architectural
coatings) would require a similar amount and type of construction activities as the proposed Project. Thus,
the overall construction-related GHG emissions from this alternative would be less than the construction
emissions that would be generated by the proposed Project.
The Alternative Commercial Recreation Use Alternative would include solar panels on rooftops and canopies
in the parking areas, and EV charging stations to provide for onsite renewable energy generation and
electric vehicle usage. As detailed below, operation of the Alternative Commercial Recreation Use
Alternative would result in 163 fewer daily vehicular trips than the proposed Project, and therefore, would
result in a decrease in vehicular GHG emissions compared to the proposed Project. Thus, operational GHG
emissions from the Alternative Commercial Recreation Use Alternative would be less than those generated
by the proposed Project and would also be below the 3,000 MTCO2e per year threshold. Therefore, the
Alternative Commercial Recreation Use Alternative would result in similar less-than-significant GHG impacts
as the proposed Project.
Hazards and Hazardous Materials
Under the Alternative Commercial Recreation Use Alternative a family entertainment center/amusement park
would be developed and operated on the site that would include a 20,000-square-foot family entertainment
building, two outdoor18-hole miniature golf courses, and an outdoor area for attractions and rides. The
Alternative Commercial Recreation Use Alternative would involve the same types of airport hazards and the
attractions and rides could reach heights of 50 feet above the ground, which is the same height as the
proposed amenity clubhouse building. Thus, the Alternative Commercial Recreation Use Alternative would
require FAA notification and review by the ALUC.
In addition, operation of the Alternative Commercial Recreation Use Alternative would involve use of oils,
lubricants, fuels, cleaners, and other types of hazardous materials for construction and operation, which are
regulated by existing laws. Like the proposed Project, this alternative would not use, or store substantial
quantities of hazardous substances and would be required to comply with existing regulations regarding the
Snug Harbor Surf Park Project 8. Alternatives
City of Newport Beach 8-18
Draft EIR
May 2025
transport, use, and disposal of hazardous materials such as fuel, paints, solvents, chlorine, and other such
substances. Overall, this alternative would result in the same less-than-significant impacts to hazards and
hazardous materials as the proposed Project, and therefore, would be consistent with the Project’s impact.
Hydrology and Water Quality
The Alternative Commercial Recreation Use Alternative would result in a similar amount of impermeable
surfaces as the proposed the Project. Consistent with the Project, the alternative would require
implementation of a SWPPP and operational stormwater drainage would be managed through
implementation of a WQMP that would include biotreatment systems that would be sized to treat runoff as
required by the Orange County DAMP. Thus, consistent with the Project, construction and operational impacts
to site runoff, hydrology, and water quality would be less than significant.
The Alternative Commercial Recreation Use Alternative would result in a reduction in water demand
compared to the proposed Project, as no surf basins or overnight accommodations would be developed.
Although it is possible that the Alternative Commercial Recreation Use Alternative could include an attraction
or ride containing water, it would be less than that of the proposed Project. Consistent with the Project,
impacts related to groundwater recharge and groundwater management would be less than significant.
Land Use and Planning
The Alternative Commercial Recreation Use Alternative would develop and operate a 20,000-square-foot
family entertainment building, outdoor miniature golf courses, entertainment attractions and rides with
landscaping along the perimeter of the site. This alternative would provide a different type of commercial
recreation use that is consistent with the OSR Specific Plan designation.
This alternative would not physically disrupt or divide the arrangement of an established community. The
Alternative Commercial Recreation Use Alternative would be consistent with the General Plan policies and
Santa Ana Heights Specific Plan design guidelines; and would not require a General Plan Amendment or a
Major Site Development Review because the entertainment building would not be over 20,000 square feet
in size. A CUP (as required for the Project) may be required for this alternative if the entertainment building
is over 18 feet in height. Overall, the Alternative Commercial Recreation Use Alternative would not require
a General Plan Amendment and would require fewer planning approvals. However, impacts related to land
use and planning from the Alternative Commercial Recreation Use Alternative would be less than significant,
which is consistent with the proposed Project.
Noise
The Alternative Commercial Recreation Use Alternative would require less excavation and grading than the
proposed Project because two surf basins would not be constructed. Also, a reduction in building spare
footage that would be developed under this alternative would result in less construction and the length of
construction related noise. The remainder of the construction of this alternative (demolition, building
construction, paving, and architectural coatings) would require a similar amount and type of construction
activities as the proposed Project that would result in similar construction-related noise and vibration that
would occur pursuant to Municipal Code allowable timelines, and like the proposed Project, would not
exceed thresholds. Thus, consistent with the proposed Project, construction noise and vibration impacts would
be less than significant under the Alternative Commercial Recreation Use Alternative.
Operational noise sources from the Alternative Commercial Recreation Use Alternative would be similar to
that of the proposed Project and would include rooftop air conditioning, parking lot noise, loading activities,
speaker noise, and spectator activity that would be less than significant and compliant with the City’s noise
standards, which is consistent with the proposed Project. Likewise, the site would be within the 2024 John
Snug Harbor Surf Park Project 8. Alternatives
City of Newport Beach 8-19
Draft EIR
May 2025
Wayne Airport 65 dBA noise contour, which would not result in noise impacts related to the Alternative
Commercial Recreation Use Alternative.
In addition, the number of vehicular trips generated by the Alternative Commercial Recreation Use
Alternative during the a.m. peak hour would be reduced by 9 trips, and during the p.m. peak hour would
be reduced by 28 trips, compared to the proposed Project (Table 8-3) and would generate slightly less
traffic noise compared to the proposed Project. However, traffic noise impacts from both the Alternative
Commercial Recreation Use Alternative and the proposed Project would be less than significant. Overall,
noise impacts from the Alternative Commercial Recreation Use Alternative would be less than significant,
which is consistent with the proposed Project.
Public Services
Under the Alternative Commercial Recreation Use Alternative, the proposed Project would be used for
different types of commercial recreation activities than the proposed Project. This alternative would result in
a reduction in daily vehicle trips to the site compared to the Project; however, the employees and visitors to
the Alternative Commercial Recreation Use Alternative would continue to generate the need for the same
fire, police, schools, and other public facilities. Therefore, although the volume of services needed could be
less due to the reduction in trips and people onsite, impacts of the Alternative Commercial Recreation Use
Alternative would continue to be less than significant.
Parks and Recreation
The Alternative Commercial Recreation Use Alternative would have a similar number of employees but a
potentially reduced number of daily visitors, as detailed by the trip generation in Table 8-1. Because the
Alternative Commercial Recreation Use Alternative would provide entertainment type of recreation, any
ancillary use of nearby park and recreation facilities by site visitors is anticipated to be limited and would
not require expansion or construction of new park and recreation facilities. Thus, impacts related to parks
and recreation from the Alternative Commercial Recreation Use Alternative would be less than significant,
which is consistent with the proposed Project.
Transportation
The Alternative Commercial Recreation Use Alternative would include the development of the 15.38-acre
Project site with a family entertainment building, two outdoor 18-hole miniature golf courses, an outdoor
area for attractions and rides; and a parking lot. As shown on Table 8-1, the Alternative Commercial
Recreation Use Alternative would generate approximately 1,377 daily trips with 28 occurring in the a.m.
peak hour and 83 occurring in the p.m. peak hour.
Table 8-1: Trip Generation for the Alternative Commercial Recreation Use Alternative
AM Peak Hour PM Peak Hour
Land Use Units Daily In Out Total In Out Total
Trip Rates
Multipurpose Recreational Facility¹ Acres 90 0.9 0.9 1.8 2.7 2.7 5.4
Alternative Trip Generation
Multipurpose Recreational Facility¹ 15.3002 Acres 1,377 14 14 28 42 42 83
Total Alternative Trip Generation 1,377 14 14 28 42 42 83
1 SANDAG Land Use Code 435 - Multipurpose Recreational Facility (Average Rate)
2 To provide a conservative analysis this assumes a 15.3-acre site instead of a 15.38-acre site.
Snug Harbor Surf Park Project 8. Alternatives
City of Newport Beach 8-20
Draft EIR
May 2025
As described in Section 5.14, Transportation, the existing development on the site generates 1,810 daily
trips and the remaining 15 golf course holes would generate 456 daily trips. Thus, as detailed in Table 8-
2, the Alternative Commercial Recreation Use Alternative would result in approximately 23 net new daily
trips with a net reduction of 82 a.m. peak hour trips and net reduction of 38 p.m. peak hour trips compared
to the existing golf course uses.
Table 8-2: Net New Trips from the Alternative Commercial Recreation Use Alternative
AM Peak Hour PM Peak Hour
Land Use Daily In Out Total In Out Total
Multipurpose Recreational Facility
Alternative Commercial Recreation Use Alternative¹ 15.3 Acres 1,377 14 14 28 42 42 83
Golf Course (Offsite Holes to Remain) 15 holes 456 21 5 26 23 21 44
Total 1,833 35 19 54 65 63 127
Existing Golf Course2 1,810 76 60 136 87 78 165
Net New Trips with Alternative 23 (41) (41) (82) (22) (15) (38)
¹ Table 8-1
2 Table 5.14-2
Source: Trip Generation Assessment (Appendix R)
As described in Section 5.14, Transportation (Table 5.14-2), the proposed Project would result in
approximately 186 net new daily trips with a net reduction of 73 a.m. peak hour trips and 10 p.m. peak
hour trips compared to the existing golf course uses. As shown in Table 8-3, the Alternative Commercial
Recreation Use Alternative would generate 163 fewer daily trips, 9 fewer a.m. peak hour trips, and 28
fewer p.m. peak hour trips compared to the proposed Project. However, both the proposed Project and the
Alternative Commercial Recreation Use Alternative would generate less than the 300 daily trip threshold
identified by the City Traffic Phasing Ordinance (Municipal Code Chapter 15.40) and the City’s VMT
threshold. Therefore, impacts from both the proposed Project and the Alternative Commercial Recreation
Use Alternative would be less than significant.
Table 8-3: Project Trip Generation Comparison to the Alternative Commercial Recreation Use
Alternative
AM Peak Hour PM Peak Hour
Land Use Daily In Out Total In Out Total
Net New Trips from Proposed Project¹ 186 (20) (53) (73) (8) (2) (10)
Net New Trips from Alternative Commercial Recreation Use2 23 (41) (41) (82) (22) (15) (38)
Change in Trips with Alternative Commercial Recreation Use (163) (21) 12 (9) (14) (13) (28)
¹Table 5.14-2
2Table 8-2
This alternative would also provide EV parking, bicycle parking, and be accessed from existing sidewalks
and bicycle lanes. Consistent with the proposed Project, the Alternative Commercial Recreation Use
Alternative would not introduce an in compatible use, increase hazard due to a geometric design feature,
or result in inadequate emergency access. The City’s development review and permitting process would
ensure that potential transportation hazard and access impacts would not occur. Overall, this alternative
would result in similar less-than-significant impacts as the proposed Project.
Snug Harbor Surf Park Project 8. Alternatives
City of Newport Beach 8-21
Draft EIR
May 2025
Tribal Cultural Resources
The Alternative Commercial Recreation Use Alternative would redevelop the site which would include
excavation and grading that could impact potential tribal cultural resources. Thus, potential impacts would
be similar to the Project and the same mitigation measures would be required to reduce potential impacts
related to inadvertent discovery of a tribal cultural resource during construction to a less-than-significant
level. Therefore, potential impacts would be similar to those the Project and mitigation measures would be
required. Under both the Alternative Commercial Recreation Use Alternative and the proposed Project,
impacts would be less than significant with mitigation incorporated.
Utilities and Service Systems
The Alternative Commercial Recreation Use Alternative would redevelop the Project site with a 20,000-
square-foot family entertainment building, outdoor miniature golf courses, entertainment attractions and
rides and landscaping. Like the proposed Project, this alternative would include installation of new utility
systems that would connect to existing offsite infrastructure in adjacent roadways. As this alternative does
not include two surf basins that would be drained and the volume of water and wastewater generated by
this alternative would be substantially less than that of the proposed Project. An upgrade to the 50-year-
old offsite 6-inch sewer lateral would not be required for capacity; however, due to the age of the sewer
lateral it may be included in this alternative.
Consistent with the proposed Project, the Alternative Commercial Recreation Use Alternative would include
installation of a drainage system that would be sized to treat runoff from the 85th percentile, 24-hour storm
as required by the Orange County DAMP. Thus, consistent with the Project potential impacts to site drainage
from the Alternative Commercial Recreation Use Alternative would be less than significant. This alternative
would not generate a substantial volume of solid waste and would be subject to State recycling and solid
waste regulations. Thus, the alternative would not result in the generation of solid waste in excess of landfill
capacity and solid waste impacts would be less than significant.
The other utility demand factors, such as electrical and gas utilities would be less, as a smaller building and
no lagoon heating would be needed, and a 24-hour onsite population would not exist under the Alternative
Commercial Recreation Use Alternative. Therefore, an overall decreased demand for utilities and service
systems would occur from this alternative. Thus, impacts related to utilities and service systems would be less
than significant, which is consistent with the proposed Project.
8.8.2 Conclusion
Ability to Reduce Impacts
The Alternative Commercial Recreation Use Alternative would include the development of a 20,000-square-
foot family entertainment building consisting of a snack bar, dining area, restrooms, and arcade gaming
area; two outdoor 18-hole miniature golf courses; a 4-acre outdoor area for attractions and rides on the
site.
The Alternative Commercial Recreation Use Alternative would not require a General Plan Amendment or
Major Site Development Review as the onsite building would not be over 20,000 square feet. A CUP may
be required if the building is in excess of 18 feet. The same mitigation measures related to biological
resources, archaeological resources, paleontological resources, and tribal cultural resources would be
required for implementation of the Alternative Commercial Recreation Use Alternative. In addition, an
increase of noise, air quality emissions, and greenhouse gas emissions would occur from the alternative.
Snug Harbor Surf Park Project 8. Alternatives
City of Newport Beach 8-22
Draft EIR
May 2025
Overall, the Alternative Commercial Recreation Use Alternative would reduce potential impacts related to
three topic areas but all of the mitigation measures required for the Project would continue to be required
for the Alternative Commercial Recreation Use Alternative (see Table 8-4).
Ability to Achieve Project Objectives
As shown in Table 8-5, the Alternative Commercial Recreation Use Alternative would meet the Project
objectives, but not to the same extent as the proposed Project. This alternative would partially meet the first
objective by developing an outdoor recreational opportunity; however, it would not be innovative or world-
class. This alternative would expand the City’s tourism economy, but would not expand transient occupancy
tax revenues. The alternative would utilize sustainable solar energy onsite and would be consistent with SP-
7 and the OSR designation. Overall, the Alternative Commercial Recreation Use Alternative would not meet
all of the Project objectives to the same extent as the proposed Project.
8.9 ENVIRONMENTALLY SUPERIOR ALTERNATIVE
CEQA requires a lead agency to identify the “environmentally superior alternative” when significant
environmental impacts result from a proposed Project. The Environmentally Superior Alternative for the
proposed project would be the No Project/No Build Alternative. The No Project/No Build Alternative would
avoid all of the potential construction impacts, reduce many of the operational impacts, and would not be
required to implement the mitigation measures related to biological resources, cultural resources,
paleontological resources, or tribal cultural resources. Although less than significant under the proposed
Project, no additional air quality emissions, greenhouse gas emissions, use of energy, hazardous materials,
water resources, utilities, or services would occur by the No Project/No Build Alternative.
However, the objectives of the proposed Project would also not be realized by the No Project/No Build
Alternative. This alternative would not provide a new innovative, world-class, full-service, outdoor
recreational opportunity; expand the City’s tourism economy and expand transient occupancy tax revenues;
and would not utilize sustainable solar energy onsite. In addition, the No Project/No Build Alternative would
not improve the existing sewer lateral that serves the site and is over 50 years old and would not install
CALGreen infrastructure or storm water filtration features in accordance with DAMP guidelines to filter and
slow the volume and rate of runoff to improve stormwater quality.
Additionally, State CEQA Guidelines Section 15126.6(3)(1) states:
The “no project” analysis shall discuss the existing conditions at the time the notice of
preparation is published, or if no notice of preparation is published, at the time environmental
analysis is commenced, as well as what would be reasonably expected to occur in the
foreseeable future if the project were not approved, based on current plans and consistent with
available infrastructure and community services. If the environmentally superior alternative is
the “no project” alternative, the EIR shall also identify an environmentally superior alternative
among the other alternatives.
Therefore, pursuant to CEQA, because the No Project/No Build Alternative has been identified as the
Environmentally Superior Alternative, the Environmentally Superior Alternative among the other alternatives
would be the Reduced Project Alternative, which would reduce the proposed Project by 50 percent. The surf
lagoon would consist of one 5.1-million-gallon basin. The amenity clubhouse would be 50 percent smaller,
and the athlete accommodations building would provide 10 units; with five units on each level. The alternative
would also provide for 50 percent less parking on the site. The additional space provided by the 50 percent
smaller development footprint would be landscaped.
Snug Harbor Surf Park Project 8. Alternatives
City of Newport Beach 8-23
Draft EIR
May 2025
The Reduced Project Alternative would result in less development on the site, but it would continue to require
a General Plan Amendment and Major Site Development Review for development of over 20,000 square
feet on the site, and a CUP for parking and construction of buildings in excess of 18 feet. The same mitigation
measures related to biological resources, archaeological resources, paleontological resources, and tribal
cultural resources would be required for implementation of the Reduced Project Alternative. Similarly, a
reduced volume of noise, air quality, and greenhouse gas emissions would occur from the Reduced Project
Alternative; however, impacts under both the Project and this alternative would be less than significant.
Overall, the Reduced Project Alternative would reduce potential impacts related to six topic areas; however,
all of the mitigation measures required for the Project would also be required for the Reduced Project
Alternative.
In addition, the Reduced Project Alternative would meet the Project objectives but not to the same extent as
the proposed Project. This alternative would develop an innovative outdoor recreational opportunity;
however, it would not offer the full services of the proposed Project including both surf basins and the same
amount of amenities in the 50 percent smaller amenity clubhouse building and would also result in the removal
of onsite golf facilities. Overall resulting in a reduction in commercial recreation. This alternative would
expand the City’s tourism economy, but not the extent or intensity of the proposed Project. The alternative
would utilize sustainable solar energy onsite and would be consistent with SP-7 and the OSR designation.
Overall, the Reduced Project Alternative would not meet all of the Project objectives to the same extent as
the proposed Project.
Table 8-4 provides, in summary format, a comparison between the level of impacts for each alternative and
the proposed Project. In addition, Table 8-5 provides a comparison of the ability of each of the alternatives
to meet the objectives of the proposed Project.
Table 8-4: Impact Comparison of the Proposed Project and Alternatives
Proposed Project Alternative 1
No Project/No Build
Alternative 2
Reduced Project
Alternative 3
Alternative
Commercial
Recreation Use
Aesthetics Less than significant Less than Project Same as Project Same as Project
Air Quality Less than significant Less than Project Reduced, but still
less than significant
Reduced, but still
less than significant
Biological Resources Less than significant
with mitigation
Less than Project,
and no mitigation
Same as Project,
mitigation required
Same as Project,
mitigation required
Cultural Resources Less than significant
with mitigation
Less than Project,
and no mitigation
Same as Project,
mitigation required
Same as Project,
mitigation required
Energy Less than significant Less than Project Same as Project Same as Project
Geology and Soils Less than significant
with mitigation
Less than Project,
and no mitigation
Same as Project,
mitigation required
Same as Project,
mitigation required
Greenhouse Gases Less than significant Less than Project Reduced, but still
less than significant
Reduced, but still
less than significant
Hazards and
Hazardous Materials
Less than significant Less than Project Same as Project Same as Project
Hydrology and
Water Quality
Less than significant Same as Project Same as Project Same as Project
Land Use and
Planning
Less than significant Less than Project Same as Project Reduced, but still
less than significant
Noise Less than significant Less than Project Reduced, but still
less than significant
Same as Project
Snug Harbor Surf Park Project 8. Alternatives
City of Newport Beach 8-24
Draft EIR
May 2025
Proposed Project Alternative 1
No Project/No Build
Alternative 2
Reduced Project
Alternative 3
Alternative
Commercial
Recreation Use
Public Services Less than significant Less than Project Reduced, but still
less than significant
Same as Project
Parks and Recreation Less than significant Less than Project Reduced, but still
less than significant
Same as Project
Transportation Less than significant Less than Project Same as Project Same as Project
Tribal Cultural
Resources
Less than significant
with mitigation
Less than Project,
and no mitigation
Same as Project,
mitigation required
Same as Project,
mitigation required
Utilities and Service
Systems
Less than significant Less than Project Reduced, but still
less than significant
Same as Project
Reduce Impacts of the Project? Yes Yes No
Areas of Reduced Impacts Compared to the
Project
15
6 3
Areas of Reduced Mitigation Compared to
the Project
4
No mitigation
required
0
Same mitigation
measures required
0
Same mitigation
measures required
Table 8-5: Comparison of the Proposed Project and Alternatives’ Ability to Meet Objectives
Project Alternative 1
No Project
Alternative 2
Reduced
Project
Alternative 3
Alternative
Commercial
Recreation Use
1. Provide an innovative, world-class,
full-service, outdoor recreational
opportunity to serve a wide range
of guests.
Yes No Yes, but to a
lesser extent Partially
2. Maintain consistency with the
existing Santa Ana Heights Specific
Plan (SP-7) and the Open Space
and Recreation (OSR) Specific Plan
designation.
Yes Yes Yes Yes
3. Expand the City’s tourism economy
and expand transient occupancy
tax revenues.
Yes No Yes, but to a
lesser extent Partially
4. Utilize sustainable solar energy
onsite that is consistent with the
City’s sustainability goals.
Yes No Yes Yes, but to a
lesser extent
Snug Harbor Surf Park Project 9. EIR Preparers and Persons Contacted
City of Newport Beach 9-1
Draft EIR
May 2025
9. EIR Preparers and Persons Contacted
EIR PREPARERS
City of Newport Beach
Joselyn Perez, Senior Planner
EPD Solutions, Inc.
Jeremy Krout, AICP
Konnie Dobreva, JD
Renee Escario
Meaghan Truman
Brady Connolly
Tiffany Dang, Graphics
Abby Pal, Technical Services
Urban Crossroads, Air Quality Impact Analysis, Energy Analysis, and Greenhouse Gas Analysis
Haseeb Qureshi
Alyssa Barnett
Glenn Lukos Associates Inc., Biological Technical Report
Erin Trung
Hannah Craddock
Glenn Lukos Associates Inc., Phase I Archeological Resources Assessment
Kerrie Collison, M.A., RPA 28731436
LSA Associates, Historical Resources Evaluation
Casey Tibbet, M.A.
LSA Associates, Paleontological Resources Assessment
Kelly Vreeland
Carl Kim Geotechnical, Geotechnical Exploration
Andrew Hillstrand
Carl C. Kim
Orion Environmental Inc., Phase I Environmental Site Assessment
Adair Johnson
Michael Purchase, P.E.
Snug Harbor Surf Park Project 9. EIR Preparers and Persons Contacted
City of Newport Beach 9-2
Draft EIR
May 2025
Orion Environmental Inc., Phase II Environmental Site Assessment
Adair Johnson
Michael Purchase, P.E.
Urban Crossroads, Noise and Vibration Impact Analysis
William Maddux, INCE
Noah Johnson
Gibson Transportation Consulting, Inc., Trip Generation Assessment
Sean Mohn
Fuscoe Engineering, Preliminary WQMP
Oriana Slasor, P.E.
Fuscoe Engineering, Preliminary Hydrology Report
Oriana Slasor, P.E.
Fuscoe Engineering, Water Supply Evaluation
Oriana Slasor, P.E.
Fuscoe Engineering, Sewer Analysis Report
Oriana Slasor, P.E.
Johnson Aviation Consulting, Solar Glare Analysis
Nick Johnson
Johnson Aviation Consulting, Aircraft Hazard and Land Use Risk Assessment & Wildlife Hazard
Management Analysis
Nick Johnson
PERSONS CONTACTED
Newport Beach Police Department – Chief Dave Miner
Newport Beach Fire Department – Chief Jeff Boyles