HomeMy WebLinkAboutPA2024-0069_2025.10.17_Final EIRName of project
Document Title
Prepared For
Name of Client/Agency
Date
SNUG HARBOR SURF PARK PROJECT
SCH NO. 2024110238
FinalEnvironmentalImpact Report
Prepared for
City of Newport Beach100 Civic Center DriveNewport Beach, CA 92660
October 2025
Snug Harbor Surf Park Project Table of Contents
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Final EIR
October 2025
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Snug Harbor Surf Park Project Table of Contents
City of Newport Beach ii
Final EIR
October 2025
Table of Contents
1. Introduction ................................................................................................................................................ 1-1
2. Response to Comments ............................................................................................................................ 2-1
3. Revisions to the Draft EIR ........................................................................................................................ 3-1
4. Mitigation Monitoring and Reporting Summary ................................................................................. 4-1
Tables
TABLE 2-1: ENVIRONMENTAL COMMENTS RECEIVED ON THE DRAFT EIR ........................................................................... 2-1
TABLE 2-2: COMMENTS RECEIVED THAT DO NOT INVOLVE ENVIRONMENTAL EFFECTS OF THE PROJECT ......................... 2-5
TABLE 4-1: MITIGATION MONITORING AND REPORTING PROGRAM ................................................................................ 4-3
Appendices
APPENDIX A COMMENTS RECEIVED THAT DO NOT INVOLVE ENVIRONMENTAL EFFECTS OF THE PROJECT
APPENDIX B PRELIMINARY HYDROLOGY REPORT
APPENDIX C SURF LAGOON WATER SYSTEMS NARRATIVE
APPENDIX D SB 18 / AB 52 TRIBAL CONSULTATION LETTER
APPENDIX E LATE RESPONSE TO COMMENTS
APPENDIX F ALTERNATIVE 4 REDUCED AMENITIES ALTERNATIVE
Snug Harbor Surf Park Project Table of Contents
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Snug Harbor Surf Park Project 1. Executive Summary
City of Newport Beach 1-1
Final EIR
October 2025
1. Introduction
This Final Environmental Impact Report (Final EIR) has been prepared in conformance with the environmental
policy guidelines for the implementation of the California Environmental Quality Act (CEQA) to evaluate the
environmental effects that may result from construction and operation of the proposed Snug Harbor Surf
Park Project (proposed Project).
According to CEQA Guidelines Section 15132, the Final EIR shall consist of:
(a) The Draft Environmental Impact Report (Draft EIR) or a revision of the Draft EIR;
(b) Comments and recommendations received on the Draft EIR, either verbatim or in summary;
(c) A list of persons, organizations, and public agencies commenting on the Draft EIR;
(d) The responses of the lead agency to significant environmental points raised in the review and consultation
process;
(e) Any other information added by the lead agency.
This document contains responses to comments received on the Draft EIR during the public review period,
which began on May 23, 2025, and ended on July 7, 2025. A Notice of Availability of the Draft EIR was
published concurrently with distribution of the Draft EIR. This document has been prepared in accordance
with CEQA, the State CEQA Guidelines, and represents the independent judgment of the lead agency, which
is the City of Newport Beach. This document and the circulated Draft EIR comprise the Final EIR in accordance
with CEQA Guidelines, Section 15132.
1.1 FORMAT OF THE FINAL EIR
The following chapters are contained within this document:
Section 1.0, Introduction. This section describes the CEQA requirements and the content of the Final EIR.
Section 2.0, Response to Comments. This section provides a list of agencies and organizations who
commented on the Draft EIR, as well as copies of their comment letters received during and following the
public review period, and individual responses to their comments. Response to comment letters received after
the closing of the public review period can be found in Final EIR Appendix E, Late Response to Comments.
Section 3.0, Revisions to the Draft EIR. This section contains revisions made to the Draft EIR as a result of
the comments received by agencies and organizations as described in Section 2.0, and/or errors and
omissions discovered since release of the Draft EIR for public review.
The City of Newport Beach has determined that none of this material constitutes significant new information
that requires recirculation of the Draft EIR for further public comment under CEQA Guidelines Section
15088.5. The additional material clarifies existing information prepared in the Draft EIR and does not
present any new substantive information. None of this new material indicates that the Project would result in
a significant new environmental impact not previously disclosed in the Draft EIR. Additionally, none of this
material indicates that there would be a substantial increase in the severity of a previously identified
environmental impact that would not be mitigated, or that there would be any of the other circumstances
requiring recirculation described in Section 15088.5.
Section 4.0, Mitigation, Monitoring, and Reporting Program. This chapter includes the Mitigation
Monitoring and Reporting Program (MMRP). CEQA requires lead agencies to “adopt a reporting and
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mitigation monitoring program for the changes to the project which it has adopted or made a condition of
project approval in order to mitigate or avoid significant effects on the environment” (CEQA Section
21081.6, CEQA Guidelines Section 15097). The MMRP was prepared based on the mitigation measures
included in the Draft EIR and finalized in this Final EIR.
1.2 CEQA REQUIREMENTS REGARDING COMMENTS AND RESPONSES
CEQA Guidelines Section 15204(a) outlines parameters for submitting comments and reminds persons and
public agencies that the focus of review and comment of Draft EIRs should be “on the sufficiency of the
document in identifying and analyzing the possible impacts on the environment and ways in which the significant
effects of the project might be avoided or mitigated. Comments are most helpful when they suggest additional
specific alternatives or mitigation measures that would provide better ways to avoid or mitigate the significant
environmental effects. At the same time, reviewers should be aware that the adequacy of an EIR is determined
in terms of what is reasonably feasible … CEQA does not require a lead agency to conduct every test or perform
all research, study, and experimentation recommended or demanded by commenters. When responding to
comments, lead agencies need only respond to significant environmental issues and do not need to provide all
information requested by reviewers, as long as a good faith effort at full disclosure is made in the EIR.”
CEQA Guidelines Section 15204(c) further advises, “Reviewers should explain the basis for their comments,
and should submit data or references offering facts, reasonable assumptions based on facts, or expert opinion
supported by facts in support of the comments. Pursuant to Section 15064, an effect shall not be considered
significant in the absence of substantial evidence.” Section 15204 (d) also states, “Each responsible agency and
trustee agency shall focus its comments on environmental information germane to that agency’s statutory
responsibility.” Section 15204 (e) states, “This section shall not be used to restrict the ability of reviewers to
comment on the general adequacy of a document or of the lead agency to reject comments not focused as
recommended by this section.”
In accordance with CEQA, Public Resources Code (PRC) Section 21092.5, copies of the written responses to
public agencies are being forwarded to those agencies at least 10 days prior to certification of the Final
EIR, with copies of this Final EIR document, which conforms to the legal standards established for response to
comments on the Draft EIR pursuant to CEQA.
Snug Harbor Surf Park Project 2. Response to Comments
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October 2025
2. Response to Comments
This section of the Final Environmental Impact Report (FEIR; Final EIR) for the Snug Harbor Surf Park Project
(Project) includes a copy of all comment letters that were submitted during the public review period for the
Draft Environmental Impact Report (DEIR; Draft EIR), along with responses to comments in accordance with
California Environmental Quality Act (CEQA) Guidelines Section 15088. The 45-day review period for the
Draft EIR began on May 23, 2025, and ended on July 7, 2025. A total of 122 comment letters were received
in response to the Draft EIR during the 45-day public review period, and two comment letters were received
after the close of the public review period.
The responses amplify or clarify information provided in the Draft EIR and/or refer the reader to the
appropriate place in the document where the requested information can be found. Comments that are not
directly related to environmental issues (e.g., opinions on the merits of the Project unrelated to its
environmental impacts) are noted for the record. Where text changes in the Draft EIR are warranted based
on comments received, updated Project information, or other information provided by City staff, those
changes are noted in the response to comment and the reader is directed to Section 3.0, Revisions to the
Draft EIR, of this Final EIR. These changes to the analysis contained in the Draft EIR represent only minor
clarifications/amplifications and do not constitute significant new information. In accordance with CEQA
Guidelines Section 15088.5, recirculation of the Draft EIR is not required.
All written comments received on the Draft EIR are listed in Table 2-1. All comment letters received on the
Draft EIR have been coded with a number to facilitate identification and tracking. The comment letters were
reviewed and divided into individual comments, with each comment containing a single theme, issue, or
concern. Individual comments and the responses to them were assigned corresponding numbers. To aid
readers and commenters, electronically bracketed comment letters have been reproduced in this document
with the corresponding responses provided immediately following each comment letter.
Table 2-1: Environmental Comments Received on the Draft EIR
Comment Letter Agency/Organization/Name Date
Agencies
A1 City of Costa Mesa July 1, 2025
A2 Orange County Public Works July 3, 2025
A3 Orange County Sanitation District July 14, 2025*
Organizations
O1 California Cultural Resource Preservation Alliance June 18, 2025
O2 Newport Bay Conservancy July 7, 2025
O3 Orange County Coastkeeper July 7, 2025
O4 Save Newport Beach Golf Course July 28, 2025*
Individuals
I1 Samuel Anderson May 21, 2025
I2 Melissa Mcleod May 23, 2025
I3 Mike Smith May 29, 2025
I4 Lyle Brakob May 30, 2025
I5 Mike Smith June 5, 2025
I6 Bethany O’Connor June 13, 2025
I7 Niall Saunders June 14, 2025
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Comment Letter Agency/Organization/Name Date
I8 Eric Halverson June 14, 2025
I9 Patricia Pidgeon June 14, 2025
I10 Karen Mc-J June 14, 2025
I11 Bruce Carlin June 15, 2025
I12 Deborah Sheperd June 16, 2025
I13 Ted Norkunas June 16, 2025
I14 Bernard Feldman June 16, 2025
I15 Mike Smith June 16, 2025
I16 Brandy Kaminski June 17, 2025
I17 Jeff Smith June 17, 2025
I18 Amy Reverdy June 17, 2025
I19 Derek Sabori June 17, 2025
I20 Niki Parker June 17, 2025
I21 Eric Woods June 17, 2025
I22 Benny Hallock June 19, 2025
I23 Jordan Lissoy June 19, 2025
I24 Andrew Bowden June 19, 2025
I25 Pete Bower June 19, 2025
I26 Patricia Lynch June 19, 2025
I27 Brooke Braga June 23, 2025
I28 Melissa Lippand June 23, 2025
I29 Mindy Adamson June 24, 2025
I30 Dandy O’Shea June 24, 2025
I31 Rone Dales June 24, 2025
I32 Penny Rodheim June 24, 2025
I33 Sandy Isselin June 24, 2025
I34 Joe Jennings June 24, 2025
I35 Gay Holmes June 24, 2025
I36 Ron Armenta June 24, 2025
I37 Kaynanee Lussier June 24, 2025
I38 Sandy MacDougall June 24, 2025
I39 Isabel Lancaster June 25, 2025
I40 Lori Cheyne June 26, 2025
I41 Merlaina O’Conner June 26, 2025
I42 Nick Kaminski June 27, 2025
I43 Clarence Costa June 27,2025
I44 Christie Brockhage June 28, 2025
I45 Bill Finster June 29, 2025
I46 Kay Dalton Simpkins July 1, 2025
I47 Sherri Myers July 1, 2025
I48 Richard Zelner July 1, 2025
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Comment Letter Agency/Organization/Name Date
I49 Antony Chisholm July 3, 2025
I50 Shawn Maxwell Jully 3, 2025
I51 Mary Citrano July 4, 2025
I52 Jan Aspegren July 5, 2025
I53 Chip Long July 5, 2025
I54 Laurie Kelly July 5, 2025
I55 Greg Nelson July 5, 2025
I56 Julie Santa Rosa July 6, 2025
I57 Robert Meadows July 6, 2025
I58 Debra Frederickson July 6, 2025
I59 Kristi Jackson July 6, 2025
I60 Patti Ferguson July 6, 2025
I61 Diane Rinker July 6, 2025
I62 Scott Pickard July 6, 2025
I63 Shella Salvo July 6, 2025
I64 Steve Kalatschan July 6, 2025
I65 Allison Robar July 6, 2025
I66 Sandee Felix July 6, 2025
I67 Diane Moore July 6, 2025
I68 Michelle Clark July 7, 2025
I69 Micah Stovall July 7, 2025
I70 Moe Sim July 7, 2025
I71 Ryan Calderon July 7, 2025
I72 Mike Smith July 7, 2025
I73 Kerry Simpson July 7, 2025
I74 Scott Klein July 7, 2025
I75 Jim Auster July 7, 2025
I76 Richard Moriarty July 7, 2025
I77 Betsy Hall July 7, 2025
I78 Sue Garland July 7, 2025
I79 Linda Giedt July 7, 2025
I80 Matt Clark July 7, 2025
I81 Richard Dayton July 7, 2025
I82 Benny Hallock July 7, 2025
I83 Scott Wellwood July 7, 2025
I84 Nick Shaffer July 7, 2025
I85 Kyle Robar July 7, 2025
I86 Wade Womack July 7, 2025
I87 Jim Mosher July 7, 2025
I88 Suzan Beck July 8, 2025
*Received after close of the public review period.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-4
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October 2025
Master Reponses
Certain topics were raised several times in comments from interested persons regarding the Draft EIR. In
order to minimize duplication and provide a more comprehensive discussion, “Master Responses” have been
prepared. Each Master Response is intended to provide a general response to several comments on the
given subject and responses to individual comments reference these Master Responses as appropriate.
Master Response 1: Project Merits
Comments were received during the public review of the Draft EIR that indicated a preference for or
opposition to the proposed Project or elements of the Project. In accordance with Section 15088 of the CEQA
Guidelines, the City is required to “evaluate comments on environmental issues received from persons who
reviewed the Draft EIR and shall prepare a written response to comments raising significant environmental
issues received during the noticed comment period.” Comments related to the proposed Project or elements
of the Project, as well as the project’s merits, are not themselves considered comments on issues related to
physical environmental conditions or impacts disclosed and evaluated as part of the Draft EIR.
CEQA is an environmental protection statute that is concerned with the physical changes to the environment
(CEQA Guidelines Section 15358(b)). The environment includes land, air, water, minerals, flora, fauna,
ambient noise, and objects of historic or aesthetic significance (CEQA Guidelines Section 15360). Any
economic and social effects of the proposed project are not treated as effects on the environment (CEQA
Guidelines Sections 15064(e) and 15131(a)). Therefore, consistent with CEQA, the Draft EIR includes an
analysis of the Project’s potentially significant physical impacts on the environment and does not include a
discussion of the Project’s economic or social effects. Further, it is not the purpose of a CEQA document to
advocate for or against any specific project. Instead, environmental impact reports are objective and
technical documents, completed for the purpose of identifying and disclosing environmental impacts, to inform
both the public and the City’s decision makers. It is then up to the City’s decision makers to weigh the
environmental impacts identified in the environmental impact report, against the Project merits (which includes
its economic and social effects), in deciding whether to approve or disapprove a proposed Project.
CEQA Guidelines Section 15204(a) states that when responding to comments, lead agencies need only
respond to significant environmental issues and do not need to provide all information requested by
reviewers, and provides the following direction related to EIR comments and responses:
In reviewing draft EIRs, persons and public agencies should focus on the sufficiency of the
document in identifying and analyzing the possible impacts on the environment and ways in
which the significant effects of the project might be avoided or mitigated. Comments are most
helpful when they suggest additional specific alternatives or mitigation measures that would
provide better ways to avoid or mitigate the significant environmental effects. At the same
time, reviewers should be aware that the adequacy of an EIR is determined in terms of what is
reasonably feasible, in light of factors such as the magnitude of the project at issue, the severity
of its likely environmental impacts, and the geographic scope of the project. CEQA does not
require a lead agency to conduct every test or perform all research, study, and experimentation
recommended or demanded by commentors.
Thus, this Final EIR does not provide responses to comments that do not raise a significant environmental
question (Citizens for E. Shore Parks v. State Lands Commission (2011) 202 Cal.App.4th 549). Because
comments regarding project merits do not pertain to the potential for significant physical impacts, or the
objective analysis of the same, such comments are not responded to in this Final EIR. All of the comment letters
providing support for or opposition to the proposed Project based on Project merits or other reasons and do
not contain comments regarding environmental topics are provided in Appendix A of this Final EIR and are
listed in Table 2-2.
Snug Harbor Surf Park Project 2. Response to Comments
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October 2025
Even though the EIR does not consider and weigh the project’s economic and social effects, economic and
social effects are important, and the City of Newport Beach decision makers will consider all comments
regarding the Project merits in determining what action to take on the proposed Project. The Planning
Commission and City Council will hold publicly noticed hearings to consider action on the Project, which will
include consideration of the Project merits (including economic and social effects).
Table 2-2: Comments Received That Do Not Involve Environmental Effects of the Project
Comment Letter Name Date
1 Elliot Fad June 14, 2025
2 Rachelle Rooney June 16, 2025
3 Charles Spence June 16, 2025
4 David Clarke June 16, 2025
5 David Wooters June 16, 2025
6 Pat Lewis June 17, 2025
7 Erik Kristiansen June 17, 2025
8 Brain Barson June 18, 2025
9 Marshall Lally June 18, 2025
10 Sasha Lopez June 18, 2025
11 Cristina Tuer June 18, 2025
12 Victoria Lugo June 18, 2025
13 Cameron Sinclair June 18, 2025
14 Kathy Mader June 27, 2025
15 Ray Sanford July 2, 2025
Master Response 2: Loss of Existing Golf Course Use
The Project site consists of privately owned land within a portion of the Newport Beach Golf Course, which
is a commercial recreation facility that is not City/publicly owned (not a municipal golf course). Some
comments to the Draft EIR expressed concerns related to the loss of affordable golf recreation facilities in
the City. As stated in Draft EIR Section 5.13 Parks and Recreation, while the Newport Beach Golf Course is
open to the public, it is privately owned and is not a municipal golf course operated or maintained by the
City. Thus, implementation of the proposed Project would not result in the loss of any City-owned open space
or recreational facilities.
The Project site has a General Plan Land Use designation of Parks and Recreation, which is intended to
provide for a variety of both active and passive uses, including: golf courses, marina support facilities, tennis
clubs and courts, private recreation, and similar facilities. The Project site is zoned for Open Space and
Recreation within the Santa Ana Heights Specific Plan which, subject to a use permit, allows for outdoor
commercial recreation. Like the existing golf course, the proposed Project is a commercial recreation use that
is consistent with the intended uses for the site within the City’s General Plan and the Santa Ana Heights
Specific Plan.
Many commenters incorrectly believe that Project implementation would eliminate all existing golf operations
at the Newport Beach Golf Course. In fact, only holes 1, 2, and 9 along with the driving range would be
removed. The proposed Project would support the remaining 15-hole golf course and facilitate continued
golf by providing parking and a check-in station (starter) on the Project site, golf cart storage within the
basement level of the Project’s proposed clubhouse building, and maintenance of connection between all
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golf holes for a 15-hole golf track. Thus, although reduced, golf recreation would continue to be provided
to the north and south of the Project and supported by the Project. There are many examples of successful
golf courses that provide less than 18 holes, including Gable Sands (Quicksand) Course (13 holes), Brandon
Preserve (13 holes), Gravel Pit (13 holes), Gilroy Golf Course (11 holes), Monarch Dunes Golf Club (12
holes), and Woodside Golf Course (12 holes), among others. These courses have succeeded with less than
the traditional 18 holes, reflecting (a) a continued desire to play even with a non-standard number of holes,
and (b) that a lesser number of holes provides a golfing experience that can be accommodated on a shorter
schedule (requiring less time to complete a round).
Additionally, as detailed in Draft EIR Section 5.13, Parks and Recreation (Table 5.13-2), there are 11 other
publicly available golf courses within 10 miles of the Project site that provide golfing activities at a range
of costs, some of which are similar to those of the Newport Beach Golf Course. Likewise, Draft EIR Table
5.13-3 identifies that there are nine other public driving ranges within 10 miles of the Project site, and that
the cost of the other driving ranges are similar to the cost of the driving range on the Project site.
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. The physical impacts associated with provision of the proposed commercial recreational surf lagoon
facility are detailed within the Draft EIR. For example, impacts related to air quality, geology, greenhouse
gases, and noise, are detailed within the respective sections of the document. No further or additional
environmental impacts from implementation of the surf lagoon recreation would occur other than those
detailed herein.
Master Response 3: CEQA Piecemealing and Housing Opportunity Sites
A number of comments stated that the Draft EIR provides a “piecemeal” environmental review because the
residential designation of Housing Opportunity sites 23, 24, 25 and 26 (located across Mesa Drive to the
south of the Project site) was not analyzed in the Draft EIR. These comments incorrectly assume that
development of the parcels south of Mesa Drive for housing is part of the proposed Project.
Under CEQA, "piecemealing" refers to the improper division of a larger project into smaller, less impactful
components to avoid a comprehensive environmental review of the entire project's effects. CEQA Guidelines
Section 15378 states that a “project” is “an activity which may cause either a direct physical change in the
environment, or a reasonably foreseeable indirect physical change in the environment” and refers to “the
whole of an action.” Citing Laurel Heights Improvement Assn. v. Regents of University of California (1988) 47
Cal.3d 376, the court noted that an EIR must include an analysis of the environmental effects of future
expansion or other action if: (1) it is a reasonably foreseeable consequence of the initial project; and (2) the
future expansion or action will be significant in that it will likely change the scope or nature of the initial
project or its environmental effects. There is no piecemealing, however, when “projects have different
proponents, serve different purposes, or can be implemented independently.”
As detailed in Section 3.0, Project Description, the Project consists of the central portion of the Newport Beach
Golf Course as shown in Draft EIR Figures 3-2, Local Vicinity and 3-3, Aerial View, and does not include
development of areas to the south of Mesa Drive. The whole of the Project is detailed in Draft EIR Section
3.0, Project Description, where it is detailed that the portions of the golf course to the north of Irvine Avenue
(holes 10-18) and south of Mesa Drive (holes 3-8) are not a part of the Project site. 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 to support the adjacent golf course areas, but it does not expand the existing
golf course operations.
As detailed on page 5-6 of the Draft EIR, 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 “candidate” sites for possible future housing,
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along with 100 other candidate housing sites on 176 acres within the Airport Focus Area of the City, as
identified in the City Housing Implementation Program. These parcels are identified in Municipal Code
Sections 20.80.025 (Housing Opportunity Overlay Zoning Districts maps) and 20.28.050 (Housing
Opportunity (HO) Overlay Zoning Districts) and were previously evaluated in the Housing Implementation
Program EIR (State Clearinghouse [SCH] Number 2023060699). The Government Code section under which
the “candidate” sites were identified expressly recognizes that development is not guaranteed. (Govt. Code
§ 65583(a)(3) [a housing element shall include an “inventory of land suitable and available for residential
development, including vacant sites and sites having a realistic and demonstrates potential for redevelopment
during the planning period” to meet the City’s assigned regional housing needs assessment allocation]
[emphasis added].) The City’s assigned Regional Housing Needs Assessment was 4,845 units. To meet that
state-assigned need, and provide a buffer in the event housing is not developed consistent with the
assumptions in the Housing Element (given that the Housing Element does not “approve” any housing projects),
the City’s Housing Element (and Housing Opportunity Overlay Zoning Districts) identified hundreds of acres
of land, accommodating a theoretical 10,087 dwelling units (with an actual capacity of +23,000 units based
on new densities and acres zoned for housing). Those units are only theoretical, and no housing is currently
proposed across Mesa Drive from the Project site. No application for development of these parcels has been
submitted to the City nor is such development a reasonably foreseeable consequence of the Project, which
proposes a surf park that is designed to allow continued functioning of the existing golf course (by providing
access between holes, golf cart storage, etc.). (McCann v. City of San Diego (2021) 70 Cal.App.5th 51, 85
[city could separately consider different utility undergrounding projects because each project was separately
approved and independently functional of the other projects]; Banning Ranch Conservancy v. City of Newport
Beach (2012) 211 Cal.App.4th 1209, 1222 [no piecemealing because project was not a “reasonably
foreseeable consequence” of another project].) The Project does not propose improvements that facilitate
residential development, such as extending infrastructure, or otherwise cause or contribute to residential
development. Any future residential development is speculative, as is any development consistent with the
underlying zoning of the parcels across Mesa Drive. Any future proposed housing on parcels south of Mesa
Drive, or any other location, would be separate and independent from the proposed surf park Project, and
would be subject to environmental review as required by CEQA. Moreover, the Project does not result in or
cause any residential development. It has complete independent utility – it does not rely on or necessitate
future housing. Neither the proposed surf park or potential future housing would be needed for the other to
proceed, and any future proposed housing or other proposed development would require development
specific environmental analysis pursuant to CEQA and related permitting review.
The Draft EIR makes it clear that the Project site is limited to the 15.38-acre central portion of the Newport
Beach Golf Course and that the only development proposed is the surf park facility and related
improvements. There are no other developments that are a prerequisite of the proposed Project, and the
proposed Project is separate and independent from any other future proposed Project outside of the 15.38-
acre Project site, including any future housing south of Mesa Drive. In addition, the proposed Project has
independent utility and a separate purpose to provide a commercial recreation surfing facility. The approval
or denial of the proposed Project is not dependent upon the existence of any other projects; and any future
housing project is not dependent upon the proposed surf park. The Project does not necessitate or compel
future housing south of Mesa Drive. (Aptos Council v. County of Santa Cruz (2017) 10 Cal.App.5th 266, 280
[“when each action has independent utility and does not subsume or necessitate each other, the actions may
properly undergo separate environmental review”].) Moreover, as explained above, the development of
housing is not a reasonably foreseeable consequence of the proposed surf park Project. Therefore, the Draft
EIR does not constitute piecemealing and has accurately evaluated the whole of the proposed Project.
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Master Response 4: Impacts Related to Vehicle Trips
Potential impacts related to transportation are evaluated as required by CEQA in Draft EIR Section 5.14
Transportation. As detailed on Draft EIR pages 5.14-5 and 5.14-13, the Newport Beach Golf Course
currently generates approximately 1,810 daily vehicular trips, with 136 a.m. peak hour trips and 165 p.m.
peak hour trips.
As detailed in Draft EIR Table 5.14-2, implementation of the proposed Project would result in a net reduction
of 73 a.m. peak hour trips and 10 p.m. peak hour trips compared to the existing uses. The daily vehicle trips
would increase by 186 at maximum capacity of the surf park and golf facilities, which is less than the 300
daily trip significance threshold per the City Traffic Phasing Ordinance (Municipal Code Title 15, Chapter
15.40). Thus, as detailed on page 5.14-13 of the Draft EIR, impacts related to roadways would be less than
significant. It should also be noted that automobile delay, including level of service (LOS), cannot legally be
an impact on the environment. (Ocean Street Extension Neighborhood Assn., supra, 73 Cal.App.5th at 1021
[challenges to EIR’s LOS analysis that compared project traffic to General Plan LOS goals were moot].) In
addition, Draft EIR page 5.14-15 details that pursuant to the City’s Vehicle Miles Traveled (VMT) screening
criteria and guidance from Governor’s Office of Planning and Research (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 result in a less than significant impact related to Vehicle Miles Traveled.
Draft EIR Section 3.8, Operations, describes that use of the surf lagoon would be limited by a reservation
system, with a maximum number of 72 people using the lagoon and an average hourly usage of 35-45
people. The facility also has associated amenities, as described in the Draft EIR’s project description, all of
which were considered for purposes of estimating trip generation. (Draft EIR Appendix R, Trip Generation
Assessment for Surf Farm [explaining that the trip generation analysis includes a comprehensive market
analysis of comparable case studies to validate the assumptions and the modeling included detailed
programmatic attendance reflective of the physical and operational parameters of the facility].) 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. The potential peak conditions that would occur with
implementation of the Project were evaluated and determined through comparison to numeric thresholds and
review by the City’s Traffic Engineering Department to be less than significant.
Master Response 5: Noise Impacts
Potential impacts related to noise are evaluated as required by CEQA in Draft EIR Section 5.11 Noise. As
detailed on page 5.11-8, existing ambient noise near the Project site is dominated by the overflight of
airplanes from John Wayne Airport and traffic noise from roadways. As shown on Draft EIR Figure 5.8-2,
the Project site is located within the John Wayne Airport 65 dBA CNEL noise contour. Existing measured
daytime noise levels range from 67.8 to 73.7 dBA in the Project area (Draft EIR Table 5.11-4). As listed in
Draft EIR Table 5.11-1, the General Plan Noise Element Table N2 identifies that commercial recreational
facilities are normally compatible with ambient noise levels up to 75 dBA CNEL. Thus, the existing ambient
noise levels are consistent with the proposed Project.
Traffic Noise. As detailed in the previous Master Response 4, the Project would generate a net increase of
186 average daily trips. This increase would not create a perceptible noise level increase compared to the
existing roadway volumes of 31,000 ADT and 6,000 ADT for Irvine Avenue and Mesa Drive respectively
(as detailed on page 5.11-21 of the Draft EIR). 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 (as detailed in the previous Master
Response and Draft EIR Table 5.14-2). Due to the low traffic volumes generated by the Project, the offsite
traffic noise levels generated by the Project would be inaudible and less than significant.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-9
Final EIR
October 2025
Wave Park Operational Noise. The Noise Analysis prepared for the Project (Draft EIR 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 the closest (most impacted) sensitive receiver locations. Draft EIR
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. would 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. Draft EIR Table 5.11-10
shows that the Project operational noise levels at the closest sensitive receivers during the nighttime hours of
10:00 p.m. to 7:00 a.m. would range from 40.0 to 45.7 dBA Leq, which is below the City’s 50 dBA Leq
nighttime noise standard at residential land uses.
The Draft EIR further evaluates operational noise by combining Project generated noise with existing ambient
noise at 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. Draft EIR 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 inaudible by humans and less than the
thresholds. Therefore, noise impacts related to Project operations would be less than significant.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-10
Final EIR
October 2025
Comment Letter A1: City of Costa Mesa (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-11
Final EIR
October 2025
Response to Comment Letter A1: City of Costa Mesa, July 1, 2025
Response to Comment A1.1: The comment does not include any environmental comments related to the
proposed Project or the Draft EIR. As requested, the City of Costa Mesa will remain on the notification list to
be kept informed of Project environmental review and development. No further comments were provided,
and no further response is warranted.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-12
Final EIR
October 2025
Comment Letter A2: Orange County Public Works (11 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-13
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-14
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-15
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-16
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-17
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-18
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-19
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-20
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-21
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-22
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-23
Final EIR
October 2025
Response to Comment Letter A2: Orange County Public Works, July 7, 2025
Response to Comment A2.1: It is understood that the proposed project could require an encroachment
permit related to construction in close proximity to County owned easements and rights-of-way and the
County has been listed with the encroachment permit requirement in Draft EIR Section 3.11, Discretionary
Actions Required, as shown in Section 3, Revisions to the Draft EIR, of this Final EIR.
Response to Comment A2.2: The proposed Project would not exert any weight or pressure on the walls of
the Santa Ana Delhi Channel. The proposed surf park basins have been specifically designed to not put any
lateral pressure on the side walls of the lagoon basins. As detailed in the civil engineering plans (included
below) the proposed lagoon basins would be set back a minimum of approximately 73.9 feet from the
existing channel walls and have been engineered to not exert pressure on the side walls of the basins.
A 1:1 influence line was added to Sections J, K, and L on the Project’s plan set Sheet C-05 (as included
below) to demonstrate the channel walls would not be impacted by the proposed improvements. In addition,
the geotechnical study that was prepared for the Project is provided as Appendix H of the Draft EIR, which
demonstrates the California Building Code requirements that would be implemented for design and
construction of the proposed Project, which would be verified during the City’s development review and
permitting process to ensure that the Project, including wave basins, would be designed to withstand seismic
movement.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-24
Final EIR
October 2025
Response to Comment A2.3: The proposed Project would not involve changes to any roadways. As detailed
in Draft EIR Section 3.0, Project Description, the Project would provide improved driveway entrances to the
Project site, which are located within the City of Newport Beach. Draft EIR page 3-23 describes that the
Project includes 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. The improved driveways would provide upgrades to the existing conditions in the City of
Newport Beach and would be approved by The City Traffic and Fire Departments.
As detailed in Master Response 4, Impacts Related to Vehicle Trips, the proposed Project would result in a
net reduction of 73 AM peak hour trips and 10 PM peak hour trips compared to the existing golf course
uses. The daily increase of 186 net trips is less than the 300 daily trip threshold per the City Traffic Phasing
Ordinance (Municipal Code Title 15, Chapter 15.40, Traffic Phasing Ordinance) and no roadway
improvements are required. Further, as shown in Draft EIR Table 5.14-3, the Project would result in a total
of 31 daily construction trips, which is less than the current operational trips in the existing condition. 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
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-25
Final EIR
October 2025
closures (as applicable). Thus, no Traffic Control or Traffic Management Plan would be prepared beyond
those required for typical construction permitting.
Response to Comment A2.4: The EIR has been updated to delete references to the site being located within
the Santa Ana River Watershed and the San Diego Creek sub-watershed. The EIR has been revised to state
that the Project is in only in the San Diego Creek Watershed, as shown in Section 3, Revisions to the Draft
EIR, of this Final EIR.
Response to Comment A2.5: Within Draft EIR Section, 5.9, Impact HYD-3, the discussion describes that
Project site does not include, and is not adjacent to, a stream or river and follows with analysis (on pages
5.9-13 through 5.9-15) regarding construction and operational activities and implementation of existing
regulations that would ensure that potential impacts are reduced to a less than significant level. It is detailed
that the Project would not alter the existing drainage pattern of the site or area in a manner which would
result in substantial erosion or siltation on- or off-site in both construction and operational conditions. Draft
EIR Page 5.9-13 details that 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. A Qualified SWPPP Practitioner (QSP) is required to ensure compliance with the SWPPP through
regular monitoring and visual inspections during construction activities.
Draft EIR page 5.9-14 details that 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. Draft EIR page 5.9-15 further details
that 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 provided
as Draft EIR Appendix O. As part of the City’s permitting approval process, the 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, as detailed in the Draft EIR, 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. No revisions to this
discussion is required.
Response to Comment A2.6: Within Draft EIR Section, 5.9, Impact HYD-4, it describes that Project site does
not include, and is not adjacent to, a stream or river and then it follows with analysis (on pages 5.9-15 and
5.9-16) regarding construction and operational activities and implementation of existing regulations that
would ensure that potential impacts are reduced to a less than significant level.
Similar to the previous response, the less than significant impact determination is based on an assessment of
whether the project alters the existing drainage pattern of the site in a manner which would result in
substantial increase the rate or amount of surface runoff that would result in flooding on-or off-site in both
construction and operational scenarios. Please refer to Draft EIR pages 5.9-15 and 5.9-16 where it is
detailed that Project construction 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.
The design of 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 for treatment.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-26
Final EIR
October 2025
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 pursuant to the MS4 Permit and DAMP requirements.
The Preliminary Water Quality Management Plan that was prepared for the proposed Project (Draft EIR
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 Draft EIR describes that as part of the permitting approval
process, the drainage design and engineering plans would be reviewed by the City to ensure that it would
accommodate the appropriate design flows. Overall, the Draft EIR details that the proposed drainage
system and adherence to the existing MS4 Permit and DAMP regulations and ensure that Project impacts
related to alteration of a drainage pattern or flooding from operational activities would be less than
significant. No revisions to this discussion is required.
Response to Comment A2.7: Similar to the previous response, Draft EIR Section, 5.9, Impact HYD-5,
describes on pages 5.9-16 and 5.9-17 that the Project does not alter the existing drainage pattern of the
site or area 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.
Page 5.9-16 describes that 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 Project
and include BMPs to eliminate the potential of polluted runoff and increased runoff during construction
activities. Page 5.9-17 also describes that as part of the permitting approval process the drainage design
and engineering plans would be reviewed by the City to ensure that the system would accommodate the
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. No revisions to this discussion is required.
Response to Comment A2.8: A Preliminary Water Quality Management Plan that was prepared for the
proposed Project (Draft EIR Appendix O). A Final Water Quality Management Plan would be prepared as
part of further design review as part of the City’s permitting process. As detailed in the Preliminary
Hydrology Report in the Draft EIR (Appendix P), two bioretention systems at the north parking lot and two
bioretention systems in the southern parking lot, have been designed to accommodate stormwater associated
with the proposed Project as required by the MS4 Permit and DAMP, and offsite flows would not increase.
The 100-year storm flows in Draft EIR Table 5.9-2 are accurate and show different discharge locations (A
through E). As detailed on page 5 of the Preliminary Hydrology Report (Draft EIR Appendix P) Q100 flow
rates at the various discharge locations do not exceed those of existing condition, except for a small increase
at the upstream reach, which has been confirmed to not adversely impact the channel hydraulics. The existing
and proposed drainage systems have capacities to provide drainage interception and conveyance for the
proposed Project. Due to the proposed 5.06-acre lagoon basins that would capture rainfall and would not
discharge into the storm drain system, a comparison of the same flow rates, discharge points, and area of
drainage is not an accurate representation of the anticipated flows. Thus, Draft EIR Table 5.9-2 providing a
summary of information from page 5 of the Preliminary Hydrology Report is not misleading and does not
require revision.
However, additional analysis has been added to the report to show comparisons of existing and proposed
discharge flowrates at the various Santa Ana Delhi Channel stations. The revised Preliminary Hydrology
Report (included as Appendix B to the Final EIR) identifies that an existing drainage flow which discharges
to a storm drain lateral on the north of the Santa Ana Delhi Channel, would be modified by the Project to
be redirected to the existing lateral on the south, which would result in an increase of 2.5 cubic feet per
second (cfs) within a 400-foot reach of the Santa Ana Delhi Channel in a 100-year storm flow condition,
which is less than a 0.03 percent increase. The existing flowrate of 8,550 cfs would become 8,553 cfs for
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-27
Final EIR
October 2025
the reach between 44+85 to 48+95, which would increase the depth of flows by 0.01 foot for this 400-
foot reach of channel during a 100-year storm flow condition, which is determined by the revised Preliminary
Hydrology Report to be a negligible increase. After the 400-foot channel reach, the overall runoff would
be reduced compared to existing conditions. The discharge amounts at each of the channel stations have
been evaluated and are listed in the following table, which has been included in the EIR as Table 5.9-3 (as
shown in Section 3.0, Revisions to the Draft EIR).
Table 5.9-3: Santa Ana – Delhi Channel Station 100-Year Storm Flow Rate Comparison (CFS)
Station Upstream Station
48+95 & 49+00
Middle Station
44+85
Downstream Station
40+79
Existing 30.9 11.1 19.8
Proposed 33.4 3.8 19.2
Difference +2.5 -7.3 -0.62
Source: Final EIR Appendix B, Preliminary Hydrology Report
Response to Comment A2.9: The discussion under Impact HYD-3 Operation describes that while
implementation of the proposed Project would result in a large increase in impermeable surfaces, 5.06 acres
of the area would consist of lagoons that would capture rainfall and the proposed bioretention basins are
sized to meet the MS4 and DAMP required storm flow.
Pursuant to the comment, it has been clarified in Section 3, Revisions to the Draft EIR, of this Final EIR that with
the proposed surf lagoon, landscaping areas, and drainage bioretention systems the total 100-year storm
discharge flows are shown in Draft EIR Table 5.9-2.
Response to Comment A2.10: The existing 20-footwide Irrevocable Offer to Dedicate (IOD) Easement
along the Santa Ana Delhi channel was recorded on June 30, 1975 (over 50 years ago) and has never been
requested or dedicated. The IOD specifically states that, although it is irrevocable, any easement that may
be created pursuant to the IOD terminates on January 31, 2027, which is prior to the planned operation of
the proposed Project. Thus, the IOD does not provide a right to encumber the property past January 31,
2027 with an easement. As the County has no existing planned uses for the IOD area, and any easement
would terminate prior to Project operations, an update to the Project plans is not needed.
Response to Comment A2.11: Refer to Response to Comment A2.2, which includes portions of the Project
Plan set that shows Project improvement setback distances from the Santa Ana Delhi Channel. Also, refer to
the previous response, IOD expressly states that any acquired “easement shall terminate on January 1,
2027”, prior to operation of the proposed Project; thus, no conflict would occur.
Response to Comment A2.12: The Draft EIR does describe long-term golf course operations following
construction of the surf park. Draft EIR Section 3.5, Project Overview, and Section 3.8, Operations, state that
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.
Response to Comment A2.13: In response to the request of this comment, the title report for the Project site
will be sent to OC Public Works staff.
Response to Comment A2.14: The water quality evaluation requested by the comment has been provided
in the Draft EIR in compliance with DAMP as detailed in Draft EIR Section 5.9 Hydrology and Water Quality,
and Draft EIR Appendix O, Preliminary Water Quality Management Plan and Appendix P, Preliminary
Hydrology Report. As detailed in the following table, the DAMP provisions listed by the comment are
provided and detailed in the Draft EIR.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-28
Final EIR
October 2025
Information Requested by Comment Location of Information Requested
A description of Project characteristics with respect to
water quality issues, such as project site location in a
given watershed, site acreage, change in percent
impervious surface area, and BMPs to be incorporated
into the Project design.
A complete description of water quality issues are
provided in Draft EIR Section 5.9 Hydrology and Water
Quality, including the Project location in the San Diego
Creek watershed, which drains to the Santa Ana–Delhi
Channel and then to the Upper Newport Back Bay (Draft
EIR page 5.9-7). The change in impervious surfaces and
site acreage is described on Draft EIR page 5.9-14
where it states 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 13.89 acres or 90
percent impermeable surfaces). However, this includes
the 5.06-acre surf lagoon, which would capture rainfall
and not result in runoff. In addition, the BMPs to be
incorporated into the Project design are detailed on
Draft EIR pages 5.9-11 and 5.9-12, and within the
Preliminary Water Quality Management Plan provided
as Appendix O of the Draft EIR, which include vegetated
biotreatment systems that utilize multi-stage treatment
processes including screening media filtration, settling,
and biofiltration.
A review of DAMP Exhibit 7.1 Table 7-I.1, Priority
Projects Categories. This project will require the
development of a Water Quality Management Plan.
A Preliminary Water Quality Management Plan with a
review of DAMP compliance requirements has been
prepared and is provided in Appendix O of the Draft
EIR.
Identification of receiving waters. The Project is located
in Newport Bay watershed, and the Draft
EIR should identify associated receiving waters that may
receive runoff from the project site.
Draft EIR Section 5.9 Hydrology and Water Quality,
provides identification of receiving waters and states on
page 5.9-7 that the site drains to the Santa Ana–Delhi
Channel and then to the Upper Newport Back Bay.
A description of the sensitivity of the receiving waters.
Given its location in Newport Bay watershed, the Draft
EIR should identify Areas of Special Biological
Significance, water bodies with Total Maximum Daily
Loads (TMDLs), 303(d) listed impaired water bodies, etc.
Draft EIR Section 5.9 Hydrology and Water Quality,
provides the sensitivity of the receiving waters on page
5.9-7, which states that the Project site drains to the
Santa Ana Delhi Channel and then to the Upper Newport
Back Bay. 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
(further details in Draft EIR Appendix O). Areas of
Special Biological Significance are described in Section
5.3, Biological Resources, on page 5.3-20 where it states
that the Upper Newport Bay Nature Preserve and
Ecological Reserve is located approximately 0.3 miles
south of the Project site and separated from the site by
developed land uses.
A characterization of the potential water quality impacts
from the proposed Project and identification of the
anticipated pollutants to be generated by the project.
A characterization of the potential water quality impacts
from the proposed Project including the anticipated
pollutants is provided in Draft EIR Section 5.9 Hydrology
and Water Quality, within Impact HYD-1 starting on
page 5.9-10 and Impact HYD-5 starting on page 5.9-
16.
An identification of hydrologic conditions of concern, such
as runoff volume and velocity; reduced infiltration, and
increased flow, frequency, duration, and peak of storm
runoff.
An identification of hydrologic conditions of concern
(HCOC) is provided on Draft EIR page 5.9-12 where it
states that a site is considered a HCOC if post-
development runoff flowrate for the two-year storm
event exceeds the predevelopment flowrate for the 2-
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-29
Final EIR
October 2025
Information Requested by Comment Location of Information Requested
year by more than ten percent. As shown in the
Hydrology Report, the proposed flowrate for the two-
year 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 (Draft
EIR Appendix P).
An assessment of Project impact significance to water
quality.
The Draft EIR provides an assessment of the Project’s
impacts to water quality in Section 5.9.6, Environmental
Impacts, which begins on page 5.9-10.
If the proposed Project has the potential to create a
major new stormwater discharge to a water body with
an established TMDL, the EIR should consider quantitative
analysis of the anticipated pollutant loads in the
stormwater discharges to the receiving waters.
As detailed in previous responses, the Project would not
create a major new stormwater discharge and
implementation of a WQMP including BMPs (with
vegetated biotreatment systems that utilize multi-stage
treatment processes of screening media filtration,
settling, and biofiltration) in compliance with MS4 Permit
and Orange County DAMP regulations would ensure that
impacts related to pollutant loads in stormwater
discharges would be less than significant.
A reasonable analysis of the cumulative impacts of the
proposed project together with past, present and
reasonably anticipated future projects (related projects)
that could produce cumulative impacts with the proposed
Project.
Draft EIR pages 5.9-18 and 5.9-19 provides a complete
evaluation of potential cumulative impacts. As detailed,
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 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.
Draft EIR page 5.9-19 also details that the proposed
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.
Response to Comment A2.15: As detailed in Draft EIR Section 5.9, Hydrology and Water Quality, and Draft
EIR Appendix O, Preliminary Water Quality Management Plan the Project would implement post construction
BMPs, including installation and maintenance of site design, source control and treatment control BMPs, such
as the vegetated biotreatment systems described in previous responses. Further, as detailed on Draft EIR
page 5.9-20, requirements for implementation of a Water Quality Management Plan have been included
as PPP WQ-3, where it specifies that prior to approval of the Grading Plan and issuance of Grading Permits,
a completed Water Quality Management Plan 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
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-30
Final EIR
October 2025
Control Best Management Practices (BMPs) that will be incorporated into the development project in order
to minimize the adverse effects on receiving waters.
Response to Comment A2.16: As detailed in Draft EIR Section 5.9, Hydrology and Water Quality, on pages
5.9-10 through 5.9-20, the Project would be required to comply with the State General Construction Permit,
which has been included in the Draft EIR as PPP WQ-1. As detailed on Draft EIR page 5.9-20, 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.
Response to Comment A2.17: The County of Orange will remain on the distribution list for future
notifications related to the Project. The title report information requested previously in the comment letter
will be provided to OC Public works.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-31
Final EIR
October 2025
Comment Letter A3: Orange County Sanitation District (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-32
Final EIR
October 2025
Response to Comment Letter A3: Orange County Sanitation District, July 14, 2025
Response to Comment A3.1: The comment does not include any environmental comments related to the
proposed Project. As requested, the EIR has been modified to describe coordination with the OC Sanitation
District and permitting from the OC Sanitation District for draining the surf basins, as shown in as shown in
Section 3, Revisions to the Draft EIR, of this Final EIR. No further comments were provided, and no further
response is warranted.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-33
Final EIR
October 2025
Comment Letter O1: California Cultural Resource Preservation Alliance (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-34
Final EIR
October 2025
Response to Comment Letter O1: California Cultural Resource Preservation Alliance, June 18, 2025
Response to Comment O1.1: It is understood that the Newport Beach area, including the proposed project,
was previously inhabited by Native American tribes. Therefore, the EIR includes mitigation measures for both
archaeological and tribal monitoring during construction related ground disturbance activities, which are
listed in Section 4.0, Mitigation Monitoring and Reporting Program, of this Final EIR. It is also understood that
the commenter agrees with the mitigation provided in the Draft EIR regarding tribal cultural and
archaeological resources. Thus, no response is warranted.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-35
Final EIR
October 2025
Comment Letter O2: Newport Bay Conservancy (4 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-36
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-37
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-38
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-39
Final EIR
October 2025
Response to Comment Letter O2: Newport Bay Conservancy, July 7, 2025
Response to Comment O2.1: The comment is introductory in nature and refers to later comments and
requests that the comments are carefully considered when preparing the Final EIR. No specific environmental
issue of concern was raised in this comment, and no further response is required.
Response to Comment O2.2: It is understood that the Newport Bay Conservancy (“NBC”) is focused on the
protection and preservation of Upper Newport Bay and that the comment refers to general environmental
risks related to three primary Project concerns. This comment does not identify a specific environmental issue
or EIR concern. The Draft EIR Section 5.3, Biological Resources, states on page 5.3-20 that the Upper Newport
Bay Nature Preserve and Ecological Reserve is located approximately 0.3 miles south of the Project site and
separated from the site by developed land uses. 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. The analysis within the Draft EIR determined that potential impacts to
biological resources, including those within the Upper Newport Bay, would be less than significant.
Response to Comment O2.3: The proposed Project would not be located directly adjacent to the Santa
Ana Delhi Channel. The proposed retaining wall would be located approximately 21.4 feet from the existing
channel fence line and the proposed lagoon basins would be set back a minimum of approximately 73.9
feet from the existing channel walls. As detailed on Draft EIR page 3-33, water from the surf lagoon would
drain to the sewer system and would not discharge into the Santa Ana Delhi Channel. The surf basins would
capture rainfall. The Surf Lagoon Water Systems Narrative, included as Appendix C to this Final EIR, details
that the lagoon is designed to have a water level of 11 inches below the adjacent pool deck and the lagoon
basin is capable of receiving over 11 inches of rainwater (1,511,499 gallons) above normal operating level
before overflowing. For every inch of excess water elevation contained in the lagoon, the equivalent volume
is approximately 137,409 gallons. Excess water in the lagoon (over 2-inches) would halt operation of the
wave generation machine and excess water would be discharged into the sewer. In addition, the surf lagoon
water management system includes meteorological monitoring to automatically restrict auto-filling of the
lagoon in anticipation of heavy rainfall. This system provides efficient use of water and reduces the likelihood
of water needing to be discharged to the sewer system due to a storm event. Overall, water from the surf
lagoon would not runoff into the Santa Ana Delhi Channel.
Potential impacts related to water quality from the proposed Project are detailed in Draft EIR Section 5.9
Hydrology and Water Quality, that provides the sensitivity of the receiving waters on page 5.9-7, which
states that the Project site drains to the Santa Ana Delhi Channel and then to the Upper Newport Back Bay.
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 (further details in Draft EIR Appendix O). Areas of Special Biological Significance are described in
Section 5.3, Biological Resources, on page 5.3-20 where it describes the location of the Upper Newport Bay
Nature Preserve and Ecological Reserve.
Existing stormflows from the onsite parking lot, artificial turf areas, and golf course currently drain directly
into the Santa Ana Delhi Channel. Draft EIR page 5.9-14 details that the proposed Project would maintain
the existing drainage pattern and improve runoff water quality by 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 that would utilize multi-stage treatment processes including screening media filtration,
settling, and biofiltration in compliance with MS4 Permit and Orange County DAMP regulations prior to
discharge into the Santa Ana Delhi Channel and then to the Upper Newport Back Bay.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-40
Final EIR
October 2025
Draft EIR page 5.9-20 describes that implementation of a Water Quality Management Plan has been
included as PPP WQ-3, where it specifies that all Post-Construction, Site Design, Source Control, and
Treatment Control Best Management Practices (BMPs) would be incorporated into the development Project
in order to minimize the adverse effects on receiving waters. The Project specific Water Quality Management
Plan is required to be reviewed and approved by the City prior to issuance of grading permits to ensure
that NPDES and Orange County DAMP permit requirements have been met, which would reduce potential
water quality drainage impacts to biological resources to a less than significant level.
Response to Comment O2.4: As detailed in Draft EIR Section 5.3, Biological Resources, (page 5.3-4 and
Figure 5.3-1) the Project site consists of approximately 6.04 acres of turf grass with ornamental landscaping
and scattered trees and 9.4 acres of disturbed/developed area. No remnant native vegetation exists on
the site. The proposed Project would remove the existing ornamental landscaping and revegetate 143,844
SF (20 percent) of the site with drought tolerant ornamental landscaping including 24-inch box trees and
15-gallon trees as shown in Draft EIR Figure 3-8, Conceptual Site Plan. Proposed landscaping would increase
the area of tree coverage compared to the existing condition, as shown by comparison of Draft EIR Figures
3-3, Aerial View, and 3-8, Conceptual Site Plan. Thus, after implementing the Project birds would have
increased roosting locations on the site and the replacement of ornamental trees does not result in long-term
adverse impacts on regional avian biodiversity, and no habitat compensation is required. Draft EIR Section
5.3, Biological Resources, page 5.3-11 details that the existing site has been subject to decades of
anthropogenic disturbances, which has removed native habitat for sensitive avian species. The native birds
with potential to nest on the Project site are those that are common to the region and highly adapted to
human landscapes, including development.
The Draft EIR page 5.3-21 describes that onsite 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. Although, the native birds with potential to nest on the Project
site would be those that are common to the region and highly adapted to human landscapes, the Project
would be required to implement Mitigation Measure BIO-2, which requires a pre-construction nesting bird
survey (as detailed on Draft EIR pages 5.3-22 and 5.3-24). With implementation of Mitigation Measure
BIO-2, impacts to nesting birds would be less than significant.
Response to Comment O2.5: The Federal Aviation Administration (FAA) Advisory Circular (AC) 150/5200-
33C provides wildlife management protocols for land uses in the vicinity of airports is to avoid landscaping
that could become an attractant to wildlife, such as fruit bearing trees, nuts, and seed mixtures containing
millet or any large seed producing grass. These measures are applicable to all land uses on the Project site;
and based on FAA guidance have been included as part of the proposed Project.
Draft EIR page 5.3-20 describes that 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. As detailed on Draft EIR page 5.3-7 there is existing Brazilian pepper tree
(Schinus terebinthifolia) on the site. The existing landscaping would be removed and replaced with a new
landscape palette that does not include the Brazilian pepper tree (Schinus terebinthifolia). All of the Project
landscaping material would be reviewed and approved by the City as part of the development permitting
process to ensure compliance with landscape requirements.
Response to Comment O2.6: The Draft EIR details (as described previously in Response O2-3) that with
compliance with existing regulations that would be implemented through the City’s development review and
permitting process would ensure that impacts to water quality would be less than significant. This includes a
Project specific drainage design related to pollutant loading and runoff pursuant to the Orange County
DAMP requirements (Draft EIR Appendix O).
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-41
Final EIR
October 2025
The site does not contain native vegetation and the existing scattered trees on the site would be replaced
with trees and landscaping covering 20 percent of the site. Thus, long-term habitat loss for birds would not
occur from implementation of the Project. As detailed in the previous response, Draft EIR page 5.3-20
describes that the Project would implement the City’s landscaping requirements and not use plant species
listed as “Moderate” or “High” invasiveness by the California Invasive Plant Council; and that all of the
Project landscaping material would be reviewed and approved by the City.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-42
Final EIR
October 2025
Comment Letter O3: Orange County Coastkeeper (2 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-43
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-44
Final EIR
October 2025
Response to Comment Letter O3: Orange County Coastkeeper, July 7, 2025
Response to Comment O3.1: Refer to Master Response 1 regarding comments about the Project merits,
and CEQA’s requirements to respond to comments related to environmental impacts.
Orange County is not in a severe water deficit. The Orange County Water District, who manages the
Orange County Groundwater Basin, identifies that at the end of June 2025 the groundwater storage level
was 94 percent of the water district target (https://www.ocwd.com/).
The City’s 2020 Urban Water Management Plan is the most recently adopted plan, and provides water
projections through the year 2045, indicating that the use of groundwater would increase to about 82
Percent of the City’s water supply (Draft EIR Appendix S). In addition to the information from the 2020
Urban Water Management Plan, the Water Supply Evaluation (Draft EIR Appendix S) includes the City’s
actual water use for 2021 through 2023 (Draft EIR Table 5.16-5), which demonstrates reductions in water
demand and increased effectiveness of water conservation (Water Supply Evaluation pages 8 and 9). The
2020 Urban Water Management Plan is based on actual water demand, land uses, growth projections, and
implementation of the Water Conservation Act of 2009. The intent of Urban Water Management Plans is to
ensure adequate water supply in normal and multiple dry years.
As detailed in Draft EIR 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. This is conservative; as described in Draft EIR Table 5.16-5, 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. As such, the Draft EIR determined that adequate water supply would be available
to serve the Project and reasonably foreseeable future development during normal, dry, and multiple dry
years.
The comment does not provide any substantial evidence that Orange County if in a severe water deficit or
that impacts related to water supply would occur from the Project. Thus, no further response is required or
provided.
Response to Comment O3.2: The comment does not provide any substantial evidence that imported water
cannot be purchased. Draft EIR page 5.16-5 describes that in the 2020 Metropolitan 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 of
2045. In addition, Draft EIR page 5.9-12 details that by 2045 approximately 82.1 percent of water supply
would be from the Orange County Basin and 14.5 percent from imported purchases. Comparison of Draft
EIR Tables 5.16-2 and 5.16-3 identifies a 53 percent planned reduction in use of imported water between
2020 and 2045. Thus, the City does have the ability to purchase additional supplies of water, if necessary,
although the Draft EIR concludes that the Project would not trigger a need to purchase additional water.
Response to Comment O3.3: The comment does not provide any substantial evidence or provide specify
of the referred to local and regional damage to the environment. The infrastructure does not currently exist
within the City to serve the Project site from recycled water. However, as detailed on Draft EIR page 5.16-
10, 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 Groundwater
Replenishment System (GWRS) 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.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-45
Final EIR
October 2025
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.
The proposed Project is not a public project and would not be subsidized by public funding through
discounted water rates. As detailed in Master Response 1, CEQA is an environmental disclosure statute that
does not include evaluation of economic impacts. Thus, no further response is required or provided regarding
water rates.
Response to Comment O3.4: Draft EIR Section 5.8, Hazards and Hazardous Materials, pages 5.8-36 and
5.8-36 describe that the Project would use and store common hazardous materials such as paints, pool
cleaning chemicals, solvents, and cleaning products. The surf lagoon would use basic pool type cleaning
equipment and chemicals to maintain the pH levels for surfers. The Surf Lagoon Water Systems Narrative,
included as Appendix C to this Final EIR, details that sodium hypochlorite would be utilized as the primary
sanitizer and is one of the most common chemical compounds used to maintain a chlorine residual in traditional
swimming pool facilities. Muriatic acid would also be utilized for pH maintenance. Both chemicals would be
dosed to the lagoon water through automated feeders and the lagoon water quality would be continuously
monitored via an automated water chemistry control system, maintaining the following water quality
parameters at all times during operation:
• Water clarity/turbidity: < 5 NTU
• Oxidation Reduction Potential (ORP): minimum 650 mV - maximum 850 mV
• Sanitizer Residual: minimum 0.5 ppm FAC
• pH level: 7.0 to 7.6
The surf lagoon would require permitting from the Orange County Department of Health, which has
approved a variance for the levels of chlorine to be 0.5 ppm that is lower than the recreational pool
requirement of 1.0 ppm due to the low user load density to water volume ratio by nature of the surf lagoon.
An ultraviolet (UV) light system would be utilized as supplemental sanitation of the lagoon water. This system
would treat 100% of the recirculation flow rate of the lagoon filtration system and would inactivate chlorine
resistant pathogens such as cryptosporidium.
The lagoon water volume would be continuously filtered utilizing a perlite regenerative media filtration
system that would capture particulates and remove contaminants from the lagoon water to the 1-5 micron
range. Perlite filter media has been tested to be effective at removing pathogens such as cryptosporidium
from the filtered water and would be used as an additional method of sanitation for the lagoon water.
When the filter media is changed, wastewater would be generated containing spent perlite media, which
would be discharged into the sewer system. Perlite filter media is derived from naturally occurring volcanic
rock, is non-toxic, and generally permitted to be discharged into the sewer system (Appendix C of this Final
EIR).
As detailed int he Surf Lagoon Water Systems Narrative, included as Appendix C to this Final EIR, prior to
discharge of a surf basin, the water would be allowed to dechlorinate through natural dissipation during
days of non-use, or alternatively could be dechlorinated by dosing sodium thiosulfate prior to pumping the
water out to the sewer system. Approximately 575 lbs of sodium thiosulfate would be required to
dechlorinate the entire lagoon volume to a zero-chlorine residual. Thus, lagoon water that is discharged into
the sewer system would be safe to discharge into the sewer system.
Draft EIR Section 3.0, Project Description, page 3-34 describes that operation of the surf lagoons include
maintenance that would be coordinated via permit with the Costa Mesa Sanitary District (CMSD) that
provides sewer services to the site. In addition, due to the volume of wastewater that would be discharged
by the Project an Orange County Sanitation District Industrial Wastewater Discharge Permit would be
required, as is required for any discharge in excess of 25,000 gallons per day. The Industrial Wastewater
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-46
Final EIR
October 2025
Discharge Permit regulates wastewater discharges by limiting specific pollutants through establishing numeric
discharge standards, discharge requirements, monitoring and reporting requirements
(https://www.ocsan.gov/industrialdischarge/). The discharge standards of Industrial Wastewater Discharge
Permits are based on the National Pollutant Discharge Elimination System Permit and the wastewater
treatment facility.
Draft EIR Section 5.16, Utilities and Service Systems, pages 5.16-10 through 5.16-13, describe that the Costa
Mesa Sanitary District sewer conveys wastewater to the Orange County Sanitation District Wastewater
Treatment Plant No.1 for secondary treatment and then to the Orange County Water District GWRS system
that purifies secondary treated wastewater to levels that 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. Draft
EIR page 5.16-10 describes that 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.
Response to Comment O3.5: The environmental impacts related to stormwater discharge are evaluated
throughout Section 5.9, Hydrology and Water Quality. As detailed on Draft EIR page 5.9-14 the proposed
Project would improve runoff water quality by 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 that
would utilize multi-stage treatment processes including screening media filtration, settling, and biofiltration
in compliance with MS4 Permit and Orange County DAMP regulations.
Draft EIR page 5.9-20 describes that implementation of a Water Quality Management Plan has been
included as PPP WQ-3, where it specifies that all Post-Construction, Site Design, Source Control, and
Treatment Control Best Management Practices (BMPs) would be incorporated into the development Project
in order to minimize the adverse effects on receiving waters. The Project specific Water Quality Management
Plan is required to be reviewed and approved by the City prior to issuance of grading permits to ensure
that NPDES and Orange County DAMP permit requirements have been met, which would reduce potential
water quality drainage impacts to a less than significant level. Thus, the Draft EIR does evaluate potential
environmental impacts related to stormwater. In addition, refer to Master Response 1 regarding comments
related to Project merits.
Response to Comment O3.6: The comment raises concern about public access. As detailed in Master
Response 2, the Project site consists of privately owned land and the existing golf course facilities are
privately owned. Also, please refer to Master Response 1, CEQA is an environmental protection statute that
is concerned with the physical changes to the environment (CEQA Guidelines Section 15358(b)). Economic
and social effects of the proposed project are not treated as effects on the environment (CEQA Guidelines
Sections 15064(e) and 15131(a)). Therefore, consistent with CEQA, the Draft EIR includes an analysis of the
Project’s potentially significant physical impacts on the environment and does not include a discussion of the
Project’s economic or social effects.
Response to Comment O3.7: The Draft EIR accurately addresses all the environmental impacts from the
increase in water and the discharge of wastewater and stormwater in Draft EIR Sections 5.9, Hydrology and
Water Quality, and 5.16, Utilities and Service Systems. This comment does not provide a specific concern
related to these Draft EIR analyses. In addition, as detailed in Master Responses 1 and 2, the Project site
consists of privately owned land facilities; and comments regarding project merits do not pertain to the
potential for significant physical impacts, and are not responded to in this Final EIR.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-47
Final EIR
October 2025
Comment Letter O4: Save Newport Beach Golf Course (4 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-48
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-49
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-50
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-51
Final EIR
October 2025
Response to Comment Letter O4: Save Newport Beach Golf Course, July 28, 2025
Response to Comment O4.1: The comment is introductory in nature and refers to later comments related to
CEQA compliance and requests that the comments are carefully considered when preparing the Final EIR.
No specific environmental issue of concern was raised in this comment. Thus, no further response is warranted.
Response to Comment O4.2: This comment states that the full extent of the proposed Project was not
disclosed to the Gabrielino Band of Mission Indians during the AB 52 consultation process. This comment also
asserts that the EIR Project description is incomplete but does not identify what is missing. As discussed in
Draft EIR Section 5.15, Tribal Cultural Resources, 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 notification sent to the Gabrieleno Band of Mission Indians – Kizh Nation is included as Appendix
D to this Final EIR. As shown, the description of the proposed Project and the location of ground disturbance
that could impact tribal cultural resources, is consistent with what is described in Draft EIR Section 3.0, Project
Description. The proposed Project is thoroughly described within Draft EIR Section 3.0, Project Description,
where the Project location, Project site boundaries, a Conceptual Site Plan, Building Elevations, and a
Conceptual Landscape Plan are provided as Figures 3-2, 3-3, 3-8, 3-9, 3-10. Also, the Project is described
within Section 5.1, Aesthetics, and shown in Figures 5.1-3 through 5.1-8. The EIR descriptions are consistent
with the Project detailed in the SB 18/AB 52 letters to tribes, and the analysis within the Draft EIR have all
utilized consistent graphics and plans. As demonstrated by Citizens for a Sustainable Treasure Island v. City
& County of San Francisco (2014) 227 CA4th 1036, 1053, the EIR’s description of the proposed Project
should identify the Project’s main features and other information needed for an analysis of the Project’s
environmental impacts. For tribal cultural resources, potential impacts of the proposed Project are related to
the area of ground disturbance, which is consistently identified in the SB 18/AB 52 letters to tribes and the
Draft EIR. This comment does not provide any substantial evidence to support its claim that the Project
description provided was incomplete or inaccurate. Thus, no further response is warranted.
Response to Comment O4.3: As described above in Response to Comment O4.2, the City sent letters to 20
Native American representatives identified by the City and NAHC, notifying them of the proposed Project.
The notification sent to the Gabrieleno Band of Mission Indians – Kizh Nation is included as Appendix D to
this Final EIR. As shown, the description of the proposed Project is consistent with what is described in Draft
EIR Section 3.0, Project Description. This comment letter does not provide any substantial evidence to support
the claim that the Project description provided was incomplete or inaccurate. All actions resulting in
environmental changes are detailed within Draft EIR Section 3.0, Project Description, including construction,
operations, and the discretionary actions that are required (in Section 3.11). As discussed in Master Response
3: CEQA Piecemealing and Housing Opportunity Sites, the Project consists of the central portion of the Newport
Beach Golf Course as shown in Draft EIR Figures 3-2, Local Vicinity and 3-3, Aerial View, and does not
include development of areas to the north of Irvine Avenue or south of Mesa Drive. The whole of the Project
is described in Draft EIR Section 3.0, Project Description, where it is detailed that the portions of the golf
course to the north of Irvine Avenue (holes 10-18) and south of Mesa Drive (holes 3-8) are not a part of the
Project site. As no specifications or details of what is asserted to be missing were provided by the comment
and no substantial evidence to support the claim was provided, no further response is warranted.
Response to Comment O4.4: This comment provides no supporting evidence or specific examples of sites
that are within Orange County that are accessible or controlled by the applicant and/or would result in
reduced potential impacts. As detailed throughout the Draft EIR, the Project would implement mitigation
measures that would reduce potential impacts to a less than significant level. The potential impacts that were
identified are related to construction activities and involve biological resources, archaeological resources,
paleontological resources, and tribal cultural resources. No significant and unavoidable project or cumulative
impacts would result from the Project. The comment is incorrect by indicating that the Project site has not
experienced significant ground disturbance. As detailed in Draft EIR Sections 5.4, Cultural Resources, Section
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-52
Final EIR
October 2025
5.6, Geology and Soils, and Section 5.15, Tribal Cultural Resources, the Project site has been fully disturbed
and contains undocumented fill soils that are up to 15 feet in depth. Although this ground disturbance
previously occurred, the EIR includes mitigation in the case that any archaeological, paleontological, or tribal
buried resources are uncovered during construction activities, which would reduce potential impacts to a less
than significant level. It should be noted that the mitigation included for tribal cultural resources was provided
to the City by the Gabrieleno Band of Mission Indians – Kizh Nation during the tribal consultation process
for the proposed Project.
Due to the fact that the biological, archaeological, paleontological, and tribal cultural resources are regional
types of resources, a large majority of the City of Newport Beach and Orange County contain the same
potential to contain these resources; and may also contain native soils (not undocumented fill). As detailed in
the Draft EIR in Section 8.4, Alternatives Considered But Rejected (page 8-3), “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.” Consistent
with the previous comments, this comment makes allegations without any specifics. The comment does not
identify the location of a 15.38-acre site that assertedly could be developed for the proposed Project and
result in fewer impacts, and no substantial evidence to support the claim was provided. Thus, no further
response is warranted.
Response to Comment O4.5: This comment is incorrect. The City is not in possession of extensive information
that the proposed Project Site would disturb sacred ceremonial grounds, villages, and heavily traveled routes
of the Kizh Nation. This information was not provided by Kizh Nation during the tribal consultation. Instead,
the Kizh Nation provided mitigation measures for tribal monitoring during Project excavation and grading,
which have been modified to be applicable to all tribes with ancestorial affiliation to the Project area and
included in the Draft EIR. Also, as detailed in the previous response, the Project site is not undisturbed. The
Project site has been disturbed and contains undocumented fill soils that are up to 15 feet in depth. Further,
the Kizh Nation is not the only maritime tribe of southern California and is not the only tribe with potential
resources within site soils. The Gabrielino Tongva Indians of California tribe provided the City with substantial
evidence identifying that the Project area is within their Ancestral Tribal Territory. In addition, the Sacred
Lands File (SLF) search completed for the Project by the Native American Heritage Commission (NAHC)
resulted in a positive finding that the site is within traditional lands or cultural places for the
Gabrieleno/Tongva San Gabriel Band of Mission Indians. As recently as 2023, the NAHC identified the
Gabrielino Tongva Indians of California as a Native American Tribe that is traditionally or culturally
affiliated with Orange County and the Project area. As detailed in the previous response, the Draft EIR
describes that potential archaeological, paleontological, and tribal cultural resources could exist in site soils;
and therefore, mitigation has been included in the EIR to reduce potential impacts to a less than significant
level.
Response to Comment O4.6: This comment is conclusory in nature and does not provide any evidence to
support the statement that the Project is accelerating through the review process. As detailed in Draft EIR
Section 2.3, Environmental Impact Report Process, the City of Newport Beach issued the Notice of Preparation
(NOP) for the Project on November 7, 2024 for a public review period of 30 days, as directed by CEQA
Guidelines Section 15802. The Draft EIR was published for public review on May 23, 2025 (over 6.5 months
later) for a 45-day public review period per CEQA Guidelines Section 15105. During public review of the
EIR, the City held a Planning Commission study session to discuss the Project. The Project’s progress has been
in accordance with CEQA Guidelines and has not been accelerated.
Likewise, the comment does not provide specifics regarding the claim that there are prohibited conflicts of
interest between City officials and Project representatives and/or any related environmental effect. As
substantiated by the responses above, none of the comments constitute significant new information related
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-53
Final EIR
October 2025
to a potential significant environmental impact. In accordance with CEQA Guidelines Section 15088.5,
recirculation of the Draft EIR or a stay of the Project is not required and no further response is warranted.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-54
Final EIR
October 2025
Comment Letter I1: Samuel Anderson (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-55
Final EIR
October 2025
Response to Comment Letter I1: Samuel Anderson, May 21, 2025
Response to Comment I1.1: Please refer to Master Response 5: Noise Impacts as well as Draft EIR Section
5.11 Noise, for the discussion of the proposed Project’s noise impacts. Construction noise impacts are listed
in Draft EIR Tables 5.11-7 and 5.11-8 and operational noise impacts are shown on Tables 5.11-9 through
5.11-13.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-56
Final EIR
October 2025
Comment Letter I2: Melissa Mcleod (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-57
Final EIR
October 2025
Response to Comment Letter I2: Melissa Mcleod, May 23, 2025
Response to Comment I2.1: Please refer to Master Response 4: Impacts Related to Vehicle Trips, regarding
the generation of vehicle trips and the proposed Project’s impacts related to transportation.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-58
Final EIR
October 2025
Comment Letter I3: Mike Smith (2 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-59
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-60
Final EIR
October 2025
Response to Comment Letter I3: Mike Smith, May 29, 2025
Response to Comment I3.1: The continued operation of the remaining 15 holes of the Newport Beach Golf
Course are described in Draft EIR Section 3.0, Project Description, as well as in Section 5.13, Parks and
Recreation. As discussed above in Master Response 1: Project Merits, the leasing and management elements
of the proposed Project are not related to impacts on the environment and thus are not analyzed within the
Draft EIR. The remaining golf course holes would continue to be managed by the Newport Beach Golf Course,
and the proposed Project would support operation of the golfing facilities, as detailed in Draft EIR Section
3.8, Operations.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-61
Final EIR
October 2025
Comment Letter I4: Lyle Brakob (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-62
Final EIR
October 2025
Response to Comment Letter I4: Lyle Brakob, May 30, 2025
Response to Comment I4.1: Please refer to Master Response 1: Project Merits for the discussion of the
proposed Project’s fiscal impacts. As discussed in Master Response 2, the Newport Beach Golf Course is not
a municipal course, it is privately owned and the proposed Project is funded by a private developer, not the
City.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-63
Final EIR
October 2025
Comment Letter I5: Mike Smith (10 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-64
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-65
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-66
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-67
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-68
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-69
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-70
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-71
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-72
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-73
Final EIR
October 2025
Response to Comment Letter I5: Mike Smith, June 5, 2025
Response to Comment I5.1: Please refer to Master Response 3: CEQA Piecemealing and Housing
Opportunity Sites, for a response regarding the proposed Project impacts related to the Housing Element
sites located on the southern golf course parcel. The comment contains attachments of emailed questions to
the City and the Coastal Commission regarding the status of parcels to the south of the Project site, which
are not related to the Project. Thus, no further response beyond Master Response 3 is warranted.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-74
Final EIR
October 2025
Comment Letter I6: Bethany O’Connor (2 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-75
Final EIR
October 2025
Response to Comment Letter I6: Bethany O’Conor, June 13, 2025
Response to Comment I6.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use.
As detailed in Section 3.0, Project Description, 15 holes of golf would be retained with implementation of
the proposed Project. The Draft EIR evaluation of potential impacts to aesthetics is based on Appendix G of
the CEQA Guidelines and the City’s General Plan guidance regarding visual resources in the City. Draft EIR
page 5.1-8 describes that as the Project site is located within an urban area, the evaluation of aesthetic
character identifies that the Project would not conflict with applicable zoning and other regulations governing
scenic quality. Draft EIR Section 5.1, Aesthetics, pages 5.1-12 through 5.1-16 describes that 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 surf lagoon, amenity clubhouse, athlete
accommodations, parking lot, ornamental landscaping, and associated infrastructure. As detailed in Draft
EIR Section 3.0, Project Description, on page 3-23, the proposed Project would include approximately
143,844 SF of drought tolerant ornamental landscaping that would cover approximately 20 percent of the
site that 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 Project structures 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. As discussed in Master Response 2, the Newport Beach Golf Course is not a
municipal course, it is privately owned and the proposed Project is funded by a private developer, not the
City.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-76
Final EIR
October 2025
Comment Letter I7: Naill Saunders (2 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-77
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-78
Final EIR
October 2025
Response to Comment Letter I7: Naill Saunders, June 14, 2025
Response to Comment I7.1: The commenter incorrectly states that the Project proposes a three-story parking
structure. As discussed in Draft EIR Section 3.0 Project Description, the proposed Project would include two
surface parking lots located on the northern and southern portions of the site. In regards to the loss of open
space, as discussed in Master Response 2: Loss of Existing Golf Course Use, and in Draft EIR Section 3.0,
Project Description, the Project site is privately owned and has a General Plan Land Use designation of Parks
and Recreation, which is intended to provide for a variety of both active and passive uses, including: golf
courses, marina support facilities, tennis clubs and courts, private recreation, and similar facilities. The Projects
is zoned for Open Space and Recreation within the Santa Ana Heights Specific Plan which, subject to a use
permit, allows for outdoor commercial recreation. The proposed Project is consistent with the intended uses
for the site within the City’s General Plan and the Santa Ana Heights Specific Plan, as detailed in Draft EIR
Section 5.10, Land Use and Planning.
The Draft EIR evaluation of potential impacts to aesthetics is based on Appendix G of the CEQA Guidelines
and the City’s General Plan guidance regarding visual resources in the City. Draft EIR page 5.1-8 describes
that 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. Draft EIR Section
5.1, Aesthetics, pages 5.1-12 through 5.1-16 describes that 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 surf lagoon, amenity clubhouse, athlete accommodations, parking lot,
ornamental landscaping, and associated infrastructure. As detailed in Draft EIR Section 3.0, Project
Description, on page 3-23, the proposed Project would include approximately 143,844 SF of drought
tolerant ornamental landscaping that would cover approximately 20 percent of the site that 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 Project structures 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.
Response to Comment I7.2: As detailed in Section 3.0, Project Description, 15 holes of golf would be
retained with implementation of the proposed Project. As described in Master Response 2, the Newport
Beach Golf Course is privately owned and is not a municipal golf course.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-79
Final EIR
October 2025
Comment Letter I8: Eric Halverson (2 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-80
Final EIR
October 2025
Response to Comment Letter I8: Eric Halverson, June 14, 2025
Response to Comment I8.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use. In addition, the proposed Project
would not operate as a theme park, as discussed in Draft EIR Section 3.8, Operations, 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 surf 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 and limited in capacity.
Thus, the proposed 351 parking stall would be able to accommodate the proposed operations using a
reservation system rather than first come first served.
In addition, as discussed in Draft EIR Section 5.12 Public Services, on page 5.12-8, 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.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-81
Final EIR
October 2025
Comment Letter I9: Patricia Pidgeon (2 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-82
Final EIR
October 2025
Response to Comment Letter I9: Patricia Pidgeon, June 14, 2025
Response to Comment I9.1: As detailed in Section 3.0, Project Description, 15 holes of golf would be
retained with implementation of the proposed Project. Please refer to Master Response 2: Loss of Existing
Golf Course Use, related to the change to the existing golf course use as well as Master Response 1: Project
Merits regarding focused environmental review and opinions regarding merits of the proposed Project.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-83
Final EIR
October 2025
Comment Letter I10: Karen Mc-J (2 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-84
Final EIR
October 2025
Response to Comment Letter I10: Karen Mc-J, June 14, 2025
Response to Comment I10.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, regarding
the change to the existing golf course use as well as Master Response 1: Project Merits for a response to
comments regarding the merits of the proposed Project. Regarding the loss of open space, as discussed in
Master Response 2: Loss of Existing Golf Course Use, and in Draft EIR Section 3.0, Project Description, the
Project site has a General Plan Land Use designation of Parks and Recreation, which is intended to provide
for a variety of both active and passive uses, including: golf courses, marina support facilities, tennis clubs
and courts, private recreation, and similar facilities. The Project site is zoned for Open Space and Recreation
within the Santa Ana Heights Specific Plan which, subject to a use permit, allows for outdoor commercial
recreation. The proposed Project is consistent with the intended uses for the site within the City’s General
Plan and the Santa Ana Heights Specific Plan, as detailed in Draft EIR Section 5.10, Land Use and Planning.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-85
Final EIR
October 2025
Comment Letter I11: Bruce Carlin (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-86
Final EIR
October 2025
Response to Comment Letter I11: Bruce Carlin, June 15, 2025
Response to Comment I11.1: As detailed in Section 3.0, Project Description, 15 holes of golf would be
retained with implementation of the proposed Project. Please refer to Master Response 2: Loss of Existing
Golf Course Use, related to the change to the existing golf course use as well as Master Response 1: Project
Merits regarding the opinions of merits of the proposed Project. Regarding the loss of open space, as
discussed in Master Response 2: Loss of Existing Golf Course Use, and in Draft EIR Section 3.0, Project
Description, the Project site has a General Plan Land Use designation of Parks and Recreation, which is
intended to provide for a variety of both active and passive uses, including: golf courses, marina support
facilities, tennis clubs and courts, private recreation, and similar facilities. The Projects is zoned for Open
Space and Recreation within the Santa Ana Heights Specific Plan which, subject to a use permit, allows for
outdoor commercial recreation. The proposed Project is consistent with the intended uses for the site within
the City’s General Plan and the Santa Ana Heights Specific Plan, as detailed in Draft EIR Section 5.10, Land
Use and Planning.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-87
Final EIR
October 2025
Comment Letter I12: Deborah Sheperd (2 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-88
Final EIR
October 2025
Response to Comment Letter I12: Deborah Sheperd, June 16, 2025
Response to Comment I12.1: As detailed in Section 3.0, Project Description, 15 holes of golf would be
retained with implementation of the proposed Project. Refer to Master Response 2: Loss of Existing Golf
Course Use, regarding the change to the existing golf course use as well as Master Response 1: Project Merits
for regarding comments about the merits of the proposed Project. Also, see Master Response 4: Impacts
Related to Vehicle Trips.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-89
Final EIR
October 2025
Comment Letter I13: Ted Norkunas (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-90
Final EIR
October 2025
Response to Comment Letter I13: Ted Norkunas, June 16, 2025
Response to Comment I13.1: As detailed in Section 3.0, Project Description, 15 holes of golf would be
retained with implementation of the proposed Project. Please refer to Master Response 2: Loss of Existing
Golf Course Use, regarding the proposed changes to the existing golf course.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-91
Final EIR
October 2025
Comment Letter I14: Bernard Feldman (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-92
Final EIR
October 2025
Response to Comment Letter I14: Bernard Feldman, June 16, 2025
Response to Comment I14.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, regarding
the change to the existing golf course use as well as Master Response 1: Project Merits for a response to
comments regarding the opinions of the proposed Project’s merits. The comment does not specify the
environmental effect of concern or analysis in the Draft EIR. Thus, no further response is warranted.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-93
Final EIR
October 2025
Comment Letter I15: Mike Smith (2 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-94
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-95
Final EIR
October 2025
Response to Comment Letter I15: Mike Smith, June 16, 2025
Response to Comment I15.1: This comment is related to the southern portion of the Newport Beach Golf
Course and its inclusion in the City’s Housing Element and is not related to the proposed Project. Please refer
to Master Response 3: CEQA Piecemealing and Housing Opportunity Sites, for a response to comments
regarding the Housing Opportunity Sites located on the southern portion of the Newport Beach Golf Course.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-96
Final EIR
October 2025
Comment Letter I16: Brandy Kaminski (2 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-97
Final EIR
October 2025
Response to Comment Letter I16: Brandy Kaminski, June 17, 2025
Response to Comment I16.1: As detailed in Section 3.0, Project Description, 15 holes of golf would be
retained with implementation of the proposed Project. Please refer to Master Response 2: Loss of Existing
Golf Course Use, for the response to comments related to the change to the existing golf course use.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-98
Final EIR
October 2025
Comment Letter I17: Jeff Smith (2 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-99
Final EIR
October 2025
Response to Comment Letter I17: Jeff Smith, June 17, 2025
Response to Comment I17.1: As detailed in Section 3.0, Project Description, 15 holes of golf would be
retained with implementation of the proposed Project. Please refer to Master Response 2: Loss of Existing
Golf Course Use, regarding the change to the existing golf course use. As stated in Master Response 2, while
the golf course is public and does not require membership to play, it is not a municipal course and is privately
owned. The proposed surf park would operate similarly in that anyone in the public can reserve time to
utilize the facility. The proposed membership associated with the facility would grant special access to certain
features and/or times; however, it would not be necessary to be access.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-100
Final EIR
October 2025
Comment Letter I18: Amy Reverdy (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-101
Final EIR
October 2025
Response to Comment Letter I18: Amy Reverdy, June 17, 2025
Response to Comment I18.1: As detailed in Section 3.0, Project Description, 15 holes of golf would be
retained with implementation of the proposed Project. Please refer to Master Response 2: Loss of Existing
Golf Course Use, for the response to comments related to the change to the existing golf course use as well
as Master Response 1: Project Merits for a response regarding the merits of the proposed Project.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-102
Final EIR
October 2025
Comment Letter I19: Derek Sabori (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-103
Final EIR
October 2025
Response to Comment Letter I19: Derek Sabori, June 17, 2025
Response to Comment I19.1: As detailed in Section 3.0, Project Description, the proposed Project would
include a restaurant/bar and surf shop. As detailed on page 6-1 of the Draft EIR, 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. Thus, the Project would result in the addition of 23 employees and
provide local employment. Please refer to Master Response 1: Project Merits for a response to comments
regarding the operational details of the proposed Project. While this is not a CEQA issue that needs to be
responded to within the Final EIR, this comment will be available to City decisionmakers as part of the Final
EIR.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-104
Final EIR
October 2025
Comment Letter I20: Niki Parker (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-105
Final EIR
October 2025
Response to Comment Letter I20: Niki Parker, June 17, 2025
Response to Comment I20.1: Please refer to Master Response 4: Impacts Related to Vehicle Trips for a
response regarding the traffic generated by the proposed Project.
Regarding water use, as discussed in Draft EIR Section 5.16, Utilities and Service Systems, 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 and would have sufficient supplies for the
proposed Project. Thus, the Draft EIR determined that impacts related to water supply 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 2. Response to Comments
City of Newport Beach 2-106
Final EIR
October 2025
Comment Letter I21: Eric Woods (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-107
Final EIR
October 2025
Response to Comment Letter I21: Eric Woods, June19, 2025
Response to Comment I21.1: As detailed in Section 3.0, Project Description, 15 holes of golf would be
retained with implementation of the proposed Project. Please refer to Master Response 2: Loss of Existing
Golf Course Use, for the response to comments related to the change to the existing golf course use.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-108
Final EIR
October 2025
Comment Letter I22: Benny Hallock (8 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-109
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-110
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-111
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-112
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-113
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-114
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-115
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-116
Final EIR
October 2025
Response to Comment Letter I22: Benny Hallock, June 19, 2025
Response to Comment I22.1: Please refer to Master Response 3: CEQA Piecemealing and Housing
Opportunity Sites, for a response to comments regarding the Housing Opportunity Sites located on the
southern portion of the Newport Beach Golf Course.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-117
Final EIR
October 2025
Comment Letter I23: Jordan Lissoy (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-118
Final EIR
October 2025
Response to Comment Letter I23: Jordan Lissoy, June 19, 2025
Response to Comment I23.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use as well as Master Response 3:
CEQA Piecemealing and Housing Opportunity Sites, for a response to comments regarding the Housing
Opportunity Sites located on the southern portion of the Newport Beach Golf Course.
As detailed in Draft EIR Section 5.13, Parks and Recreation, page 5.13-9, the Project proposes to redevelop
a portion of a golf course with a new commercial recreational surf park use. With the change to the golf
course to the 15-hole format 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 usage.
However, Draft EIR 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.
In addition, the Draft EIR page 5.13-10 details that the construction and operational 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 the 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. Hydrology and drainage are evaluated in Sections 5.9, Hydrology and Water Quality and Section
5.16, Utilities and Service Systems. Noise from construction is evaluated in Section 5.11, Noise, and vehicular
trips from construction of the Project are analyzed in Draft EIR Section 5.14, Transportation. Therefore, Project
impacts related to the construction or expansion of recreational facilities would be less than significant. The
comment does not describe a specific potential impact; thus, no further response is warranted.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-119
Final EIR
October 2025
Comment Letter I24: Andrew Bowden (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-120
Final EIR
October 2025
Response to Comment Letter I24: Andrew Bowden, June 19, 2025
Response to Comment I24.1: Please refer to Master Response 5: Noise Impacts as well as Draft EIR Section
5.11 Noise, for the discussion of the proposed Project’s noise impacts as well as Master Response 2: Loss of
Existing Golf Course Use, for the response to comments related to the change to the existing golf course uses.
Regarding the loss of open space, as discussed in Master Response 2: Loss of Existing Golf Course Use, and
in Draft EIR Section 3.0, Project Description, the Project site has a General Plan Land Use designation of
Parks and Recreation, which is intended to provide for a variety of both active and passive uses, including:
golf courses, marina support facilities, tennis clubs and courts, private recreation, and similar facilities. The
Projects is zoned for Open Space and Recreation within the Santa Ana Heights Specific Plan which, subject
to a use permit, allows for outdoor commercial recreation. The proposed Project is consistent with the intended
uses for the site within the City’s General Plan and the Santa Ana Heights Specific Plan.
The Draft EIR evaluation of potential impacts to aesthetics is based on Appendix G of the CEQA Guidelines
and the City’s General Plan guidance regarding visual resources in the City. Draft EIR page 5.1-8 describes
that 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. Draft EIR Section
5.1, Aesthetics, pages 5.1-12 through 5.1-16 describes that 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 surf lagoon, amenity clubhouse, athlete accommodations, parking lot,
ornamental landscaping, and associated infrastructure. As detailed in Draft EIR Section 3.0, Project
Description, on page 3-23, the proposed Project would include approximately 143,844 SF of drought
tolerant ornamental landscaping that would cover approximately 20 percent of the site that 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 Project structures 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.
In regard to the Project’s impact to wildlife, as discussed in Draft EIR Section 5.3, Biological Resources on
page 5.3-21, the Project site is comprised of disturbed/developed area and turf grass/ornamental
landscaping, which is not classified as a sensitive natural community (included as Appendix C to the Draft
EIR). 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 any substantial impacts to sensitive wildlife.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-121
Final EIR
October 2025
Comment Letter I25: Pete Bower (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-122
Final EIR
October 2025
Response to Comment Letter I25: Pete Bower, June 19, 2025
Response to Comment I25.1: Please refer to Master Response 1: Project Merits for a response to comments
regarding the merits of the proposed Project.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-123
Final EIR
October 2025
Comment Letter I26: Patricia Lynch (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-124
Final EIR
October 2025
Response to Comment Letter I26: Patricia Lynch, June 19, 2025
Response to Comment I26.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use as well as Master Response 1:
Project Merits for a response regarding the merits of the proposed Project. As discussed in Master Response
2: Loss of Existing Golf Course Use, and in Draft EIR Section 3.0, Project Description, the Project site has a
General Plan Land Use designation of Parks and Recreation, which is intended to provide for a variety of
both active and passive uses, including: golf courses, marina support facilities, tennis clubs and courts, private
recreation, and similar facilities. The Projects is zoned for Open Space and Recreation within the Santa Ana
Heights Specific Plan which, subject to a use permit, allows for outdoor commercial recreation. The proposed
Project is consistent with the intended uses for the site within the City’s General Plan and the Santa Ana
Heights Specific Plan.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-125
Final EIR
October 2025
Comment Letter I27: Brooke Braga (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-126
Final EIR
October 2025
Response to Comment Letter I27: Brooke Braga, June 23,, 2025
Response to Comment I27.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-127
Final EIR
October 2025
Comment Letter I28: Melissa Lippand (2 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-128
Final EIR
October 2025
Response to Comment Letter I28: Melissa Lippand, June 23, 2025
Response to Comment I28.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use as well as Master Response 1:
Project Merits for a response regarding the merits of the proposed Project. The proposed surf park would
operate similarly to the golf course as anyone in the public can reserve time to utilize the facility. The
proposed membership associated with the facility would grant special access to certain features and/or
times; however, it would not be necessary to be access the surf lagoon.
As discussed in Master Response 2: Loss of Existing Golf Course Use, and in Draft EIR Section 3.0, Project
Description, the Project site has a General Plan Land Use designation of Parks and Recreation, which is
intended to provide for a variety of both active and passive uses, including: golf courses, marina support
facilities, tennis clubs and courts, private recreation, and similar facilities. The Projects is zoned for Open
Space and Recreation within the Santa Ana Heights Specific Plan which, subject to a use permit, allows for
outdoor commercial recreation. The proposed Project is consistent with the intended uses for the site within
the City’s General Plan and the Santa Ana Heights Specific Plan.
The Draft EIR evaluation of potential impacts to aesthetics is based on Appendix G of the CEQA Guidelines
and the City’s General Plan guidance regarding visual resources in the City. Draft EIR page 5.1-8 describes
that 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. Draft EIR Section
5.1, Aesthetics, pages 5.1-12 through 5.1-16 describes that 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 surf lagoon, amenity clubhouse, athlete accommodations, parking lot,
ornamental landscaping, and associated infrastructure. As detailed in Draft EIR Section 3.0, Project
Description, on page 3-23, the proposed Project would include approximately 143,844 SF of drought
tolerant ornamental landscaping that would cover approximately 20 percent of the site that 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 Project structures 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.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-129
Final EIR
October 2025
Comment Letter I29: Mindy Adamson (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-130
Final EIR
October 2025
Response to Comment Letter I29: Mindy Adamson, June 24, 2025
Response to Comment I29.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-131
Final EIR
October 2025
Comment Letter I30: Dandy O’Shea (3 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-132
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-133
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-134
Final EIR
October 2025
Response to Comment Letter I30: Dandy O’Shea, June 24, 2025
Response to Comment I30.1: This comment is introductive in nature and does not provide comment about
the environmental analysis in the Draft EIR or provide any substantial evidence that the proposed Project
would result in a new significant environmental impact. Thus, no further response is warranted.
Response to Comment I30.2: As detailed on Draft EIR page 5.14-12, the vehicle 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 and surf park data, which were reviewed and approved by the City’s Traffic Engineering Division.
In addition, the Project was screened using the City’s VMT Analysis Methodology per City Council Policy K-
3. Using this methodology, the proposed Project was found to produce less than 300 net daily trips and
therefore results in a less than significant impact related to VMT.
Section 152049(c) of the CEQA Guidelines advises that comments should be accompanied by factual
support, stating “[r]eviewers should explain the basis for their comments and should submit data or references
offering facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of
the comments. Pursuant to Section 15064, an effect shall not be considered significant in the absence of
substantial evidence”. Where comments provide no facts or other substantial evidence to support an
assertion, or where comments do not explain why the evidence supporting a conclusion in the Draft EIR is not
substantial evidence. The comment does not provide supporting evidence that the transportation evaluation
prepared for the Project, included as Draft EIR Section 5.14, Transportation, and Appendix R, is inaccurate.
Thus, no further response is warranted.
Response to Comment I30.3: Construction details are listed in Section 3.7 Construction, within Draft EIR
Section 3.0, Project Description, which details that construction is anticipated to begin in the second quarter
of 2026 and complete by the third quarter of 2027. The construction timeline is provided in Draft EIR Table
3-5 on page 3-33. The section also discusses that Project grading is expected to result in a balanced site,
with 135,000 cubic yards of cut and 135,000 cubic yards of fill. In regard to construction traffic, as discussed
in Draft EIR Section 5.14, Transportation, on page 5.14-14, vendor delivery trucks would arrive and depart
throughout the day and a majority of construction crews would arrive and depart outside peak hours. As
shown in Draft EIR 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. This equates to approximately 16.7 percent of the net daily trips that would be generated from
operation of the Project (as shown in Draft EIR 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, and impacts would be less than
significant. 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). Thus, overall construction related transportation
impacts would be less than significant.
Response to Comment I30.4: As discussed on page 5.6-14 within Draft EIR Section 5.6 Geology and Soils,
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 California Building Code (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
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-135
Final EIR
October 2025
the configuration of the structure including the structural system and height. 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, including retaining walls, 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.
Response to Comment I30.5: Please refer to Master Response 5: Noise Impacts as well as Draft EIR Section
5.11 Noise, for the discussion of the proposed Project’s noise impacts. A noise study was completed for the
Project, which is included in the Draft EIR as Appendix Q. The comment does not provide any specific
comments related to the noise analysis in the EIR and does not provide substantial evidence to support the
statement that noise impacts have been understated in the Draft EIR. Thus, no further response is warranted.
Response to Comment I30.6: The City of Newport Beach is the Lead Agency for the proposed Project. As
discussed above in Response to comments I30.2 through I30.5, the Draft EIR provides a complete CEQA
compliant analysis of VMT, construction, geotechnical, and noise effects that would occur from the proposed
Project. Mitigation measures and other requirements to ensure that impacts would be reduced to a less than
significant level are provided throughout the Draft EIR, as summarized in Draft EIR Section 1.0, Executive
Summary, and here in this Final EIR as Section 4.0, Mitigation Monitoring and Reporting Program. The comment
does not provide substantial evidence of a new or increased significant environmental impact. Thus, no further
response is warranted.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-136
Final EIR
October 2025
Comment Letter I31: Rone Dales (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-137
Final EIR
October 2025
Response to Comment Letter I31: Rone Dales, June 24, 2025
Response to Comment I31.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use as well as Master Response 1:
Project Merits for a response to comments regarding the merits of the proposed Project. As listed in Draft EIR
Table 5.11-1, the General Plan Noise Element Table N2 identifies that commercial recreational facilities are
normally compatible with ambient noise levels up to 75 dBA CNEL and the existing daytime ambient noise
range from 67.8 to 73.7 dBA. Thus, the existing ambient noise levels are consistent with the proposed Project
commercial recreational uses.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-138
Final EIR
October 2025
Comment Letter I32: Penny Rodheim (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-139
Final EIR
October 2025
Response to Comment Letter I32: Penny Rodheim, June 24, 2025
Response to Comment I32.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-140
Final EIR
October 2025
Comment Letter I33: Sandy Isselin (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-141
Final EIR
October 2025
Response to Comment Letter I33: Sandy Isselin, June 24, 2025
Response to Comment I33.1: As detailed in Section 3.0, Project Description, 15 holes of golf would be
retained with implementation of the proposed Project. Please refer to Master Response 2: Loss of Existing
Golf Course Use, for the response to comments related to the change to the existing golf course use as well
as Master Response 1: Project Merits for a response to comments regarding the merits of the proposed
Project. In regard to potential noise impacts, please refer to Master Response 5: Noise Impacts as well as
Master Response 4: Impacts Related to Vehicle Trips for a response regarding increased traffic.
The Draft EIR evaluation of potential impacts to aesthetics is based on Appendix G of the CEQA Guidelines
and the City’s General Plan guidance regarding visual resources in the City. Draft EIR page 5.1-8 describes
that 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. As detailed in
Draft EIR Section 5.1, Aesthetics, pages 5.1-12 through 5.1-16 the proposed Project would change views of
the site to a more urban and developed character compared to the existing condition. However, it would
not conflict with applicable zoning and other regulations governing scenic quality and pursuant to CEQA
Guidelines criteria, impacts would be less than significant.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-142
Final EIR
October 2025
Comment Letter I34: Joe Jennings (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-143
Final EIR
October 2025
Response to Comment Letter I34: Joe Jennings, June 24, 2025
Response to Comment I34.1: As detailed in Section 3.0, Project Description, 15 holes of golf would be
retained with implementation of the proposed Project. Please refer to Master Response 2: Loss of Existing
Golf Course Use, for the response to comments related to the change to the existing golf course use as well
as Master Response 1: Project Merits for a response to comments regarding the merits of the proposed
Project.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-144
Final EIR
October 2025
Comment Letter I35: Gay Holmes (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-145
Final EIR
October 2025
Response to Comment Letter I35: Gay Holmes, June 24, 2025
Response to Comment I35.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use as well as Master Response 1:
Project Merits for a response to comments regarding the necessity of the proposed Project.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-146
Final EIR
October 2025
Comment Letter I36: Ron Armenta (3 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-147
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-148
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-149
Final EIR
October 2025
Response to Comment Letter I36: Ron Armenta, June 24, 2025
Response to Comment I36.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use as well as Master Response 1:
Project Merits for a response to comments regarding the merits of the proposed Project.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-150
Final EIR
October 2025
Comment Letter I37: Kaynanee Lussier (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-151
Final EIR
October 2025
Response to Comment Letter I37: Kayanee Lussier, June 24, 2025
Response to Comment I37.1: Please refer to Master Response 1: Project Merits for a response to comments
regarding the merits of the proposed Project as well as Master Response 4: Impacts Related to Vehicle Trips
for a response regarding traffic.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-152
Final EIR
October 2025
Comment Letter I38: Sandy MacDougall (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-153
Final EIR
October 2025
Response to Comment Letter I38: Sandy MacDougall, June 24, 2025
Response to Comment I1.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-154
Final EIR
October 2025
Comment Letter I39: Isabel Lancaster (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-155
Final EIR
October 2025
Response to Comment Letter I39: Isabel Lancaster, June 25, 2025
Response to Comment I39.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-156
Final EIR
October 2025
Comment Letter I40: Lori Cheyne (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-157
Final EIR
October 2025
Response to Comment Letter I40: Lori Cheyne, June 26, 2025
Response to Comment I40.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use.
Response to Comment I40.2: In regard to the Project’s impact to plants and wildlife, as discussed in Draft
EIR Section 5.3, Biological Resources on page 5.3-21, the Project site is comprised of disturbed/developed
area and turf grass/ornamental landscaping, which is not classified as a sensitive natural community (included
as Appendix C to the Draft EIR). 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 any substantial impacts to sensitive wildlife.
In regard to air quality, as shown on Draft EIR Table 5.2-8, impacts related to regional air quality threshold
would be less than significant. The existing Project site is mostly developed with turf, structures, and parking
lot, with grass located on holes 1, 2 and 9 and ornamental landscaping. The proposed Project would result
in 143,844 SF of drought tolerant ornamental landscaping that would cover approximately 20 percent of
the site. 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.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-158
Final EIR
October 2025
Comment Letter I41: Merlaina O’Conner (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-159
Final EIR
October 2025
Response to Comment Letter I41: Merlaina O’Conner, June 26, 2025
Response to Comment I41.1: Please refer to Master Response 5: Noise Impacts as well as Draft EIR Section
5.11 Noise, for the discussion of the proposed Project’s noise impacts as well as Master Response 4: Impacts
Related to Vehicle Trips for a response regarding traffic.
In regard to the Project’s impact to wildlife, as discussed in Draft EIR Section 5.3, Biological Resources on
page 5.3-21, the Project site is comprised of disturbed/developed area and turf grass/ornamental
landscaping, which is not classified as a sensitive natural community. 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 any substantial
impacts to sensitive wildlife. In addition, as part of the Project new ornamental landscaping would be
installed, as detailed in Draft EIR Section 3.0, Project Description.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-160
Final EIR
October 2025
Comment Letter I42: Nick Kaminski (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-161
Final EIR
October 2025
Response to Comment Letter I42: Nick Kaminski, June 27, 2025
Response to Comment I1.1: As detailed in Section 3.0, Project Description, 15 holes of golf would be
retained with implementation of the proposed Project. Please refer to Master Response 2: Loss of Existing
Golf Course Use, for the response to comments related to the change to the existing golf course use.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-162
Final EIR
October 2025
Comment Letter I43: Clarence Costa (2 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-163
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-164
Final EIR
October 2025
Response to Comment Letter I43: Clarence Costa, June 27, 2025
Response to Comment I43.1: CEQA is an environmental protection statute that is concerned with a project’s
physical changes to the environment (CEQA Guidelines Section 15358(b)). The environment includes land,
air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic significance (CEQA
Guidelines Section 15360). Any economic and social effects of the proposed project are not treated as
effects on the environment (CEQA Guidelines Sections 15064(e) and 15131(a)). Therefore, consistent with
CEQA, the Draft EIR includes an analysis of the Project’s reasonably foreseeable and potentially significant
physical impacts on the environment and does not include a discussion of the Project’s economic or social
effects. Thus, impacts related to the proposed Project’s potential failure as a business and ability to be
redeveloped is not within the scope of CEQA and its speculative. Should the site be redeveloped for another
use in the future, further CEQA analysis would be needed to examine the scope and environmental impacts
of such a project. Because the comment does not express any specific concern or question regarding the
adequacy of the Draft EIR, no further response is warranted.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-165
Final EIR
October 2025
Comment Letter I44: Christie Brockhage (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-166
Final EIR
October 2025
Response to Comment Letter I44: Christie Brockhage, June 28, 2025
Response to Comment I44.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use.
The Draft EIR evaluation of potential impacts to aesthetics is based on Appendix G of the CEQA Guidelines
and the City’s General Plan guidance regarding visual resources in the City. Draft EIR page 5.1-8 describes
that 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. Draft EIR Section
5.1, Aesthetics, pages 5.1-12 through 5.1-16 describes that the proposed Project would change the public
views of the Project site to a more urban and developed character compared to the existing condition.
However, it would not conflict with applicable zoning and other regulations governing scenic quality and
pursuant to CEQA Guidelines criteria, and impacts would be less than significant.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-167
Final EIR
October 2025
Comment Letter I45: Bill Finster (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-168
Final EIR
October 2025
Response to Comment Letter I45: Bill Finster, June 29, 2025
Response to Comment I45.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use as well as Master Response 1:
Project Merits for a response to comments regarding the merits of the proposed Project.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-169
Final EIR
October 2025
Comment Letter I46: Kay Dalton Simpkins (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-170
Final EIR
October 2025
Response to Comment Letter I46: Kay Dalton Simpkins, July 1, 2025
Response to Comment I46.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use as well as Master Response 1:
Project Merits for a response to comments regarding the merits of the proposed Project. The proposed Project
does not include the transformation from open green space to high-density housing. The Draft EIR evaluation
of potential impacts to aesthetics is based on Appendix G of the CEQA Guidelines and the City’s General
Plan guidance regarding visual resources in the City. Draft EIR page 5.1-8 describes that 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. As detailed in Draft EIR Section 3.0,
Project Description, on page 3-23, the proposed Project would include approximately 143,844 SF of drought
tolerant ornamental landscaping that would cover approximately 20 percent of the site that 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 Project structures 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. As
detailed in Draft EIR Section 5.1, Aesthetics, pages 5.1-12 through 5.1-16 the proposed Project would
change views of the site to a more urban and developed character compared to the existing condition.
However, it would not conflict with applicable zoning and other regulations governing scenic quality and
pursuant to CEQA Guidelines criteria, impacts would be less than significant.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-171
Final EIR
October 2025
Comment Letter I47: Sherri Myers (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-172
Final EIR
October 2025
Response to Comment Letter I47: Sherri Myers, July 1, 2025
Response to Comment I47.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use, as well as Master Response 1:
Project Merits for a response to comments regarding the merits of the proposed Project.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-173
Final EIR
October 2025
Comment Letter I48: Richard Zelner (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-174
Final EIR
October 2025
Response to Comment Letter I48: Richard Zelner, July 1, 2025
Response to Comment I48.1: Please refer to Master Response 4: Impacts Related to Vehicle Trips, for a
response to comments regarding the proposed Project’s traffic effects.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-175
Final EIR
October 2025
Comment Letter I49: Antony Chisholm (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-176
Final EIR
October 2025
Response to Comment Letter I49: Antony Chisholm, July 3, 2025
Response to Comment I49.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use, as well as Master Response 1:
Project Merits for a response to comments regarding the merits of the proposed Project.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-177
Final EIR
October 2025
Comment Letter I50: Shawn Maxwell (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-178
Final EIR
October 2025
Response to Comment Letter I50: Shawn Maxwell, July 3, 2025
Response to Comment I50.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use, as well as Master Response 1:
Project Merits for a response to comments regarding the merits of the proposed Project. The Draft EIR
evaluation of potential impacts to aesthetics is based on Appendix G of the CEQA Guidelines and the City’s
General Plan guidance regarding visual resources in the City. Draft EIR page 5.1-8 describes that 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. Draft EIR Section 5.1,
Aesthetics, pages 5.1-12 through 5.1-16 describes that the proposed Project would change the public views
of the Project site to a more urban and developed character compared to the existing condition. However,
it would not conflict with applicable zoning and other regulations governing scenic quality and pursuant to
CEQA Guidelines criteria, impacts would be less than significant.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-179
Final EIR
October 2025
Comment Letter I51: Mary Citrano (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-180
Final EIR
October 2025
Response to Comment Letter I51: Mary Citrano, July 4, 2025
Response to Comment I51.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use, as well as Master Response 1:
Project Merits for a response to comments regarding the merits of the proposed Project.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-181
Final EIR
October 2025
Comment Letter I52: Jan Aspegren (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-182
Final EIR
October 2025
Response to Comment Letter I52: Jan Aspegren, July 5, 2025
Response to Comment I52.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use as well as Master Response 1:
Project Merits for a response to comments regarding the merits of the proposed Project.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-183
Final EIR
October 2025
Comment Letter I53: Chip Long (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-184
Final EIR
October 2025
Response to Comment Letter I53: Chip Long, July 5, 2025
Response to Comment I53.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-185
Final EIR
October 2025
Comment Letter I54: Laurie Kelly (9 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-186
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Response to Comment Letter I54: Laurie Kelly, July 5, 2025
Response to Comment I54.1: This comment asserts objection to any development on the Newport Beach
Golf Course and does not provide substantial evidence of a significant environmental impact or provide
specific comments related to the analysis within the EIR. Thus, no further response is warranted.
Response to Comment I54.2: This comment provides an image of the southern portion of the Newport Beach
Golf Course in support of the attached letter. As discussed in Master Response 1, Project Merits, this parcel
is not included as part of the proposed Project. Thus, no further response is warranted.
Response to Comment I54.3: This comment states that the Draft EIR ignores or underestimates significant
cumulative impacts and that the loss of the middle parcel of the Newport Beach Golf Course is a pivotal
factor making the remainder of the golf course unviable to allow for high density housing. However, the
comment provides no substantial evidence or data regarding these statements. As detailed in Section 3.0,
Project Description, on page 3-34, 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. There are ample examples of successful golf courses that are not the traditional 18-hole
format, including Gable Sands (Quicksand) Course (13 holes), Brandon Preserve (13 holes), Gravel Pit (13
holes), Gilroy Golf Course (11 holes), Monarch Dunes Golf Club (12 holes), and Woodside Golf Course (12
holes), among others. The success of such courses reflects a demand for a golf experience that is less time
consuming, making it more accessible. Refer to Master Response 3, CEQA Piecemealing and Housing
Opportunity Sites, regarding the City’s Housing Implementation Program and the housing opportunity sites.
Response to Comment I54.4: This comment provides an assumption that golf course holes 3-8 will be
redeveloped into high density housing and that the cumulative effect on open space, recreational amenities,
and community character is highly significant and has been ignored. As detailed in the previous response,
the proposed Project would keep golf course holes 3-8 and 10-18 and provide support for their continued
use, which would be consistent with the existing General Plan and Specific Plan land use designations for the
Project site. As detailed in Draft EIR Section 5.0, no housing is currently proposed across Mesa Drive from
the Project site, and the Newport Beach General Plan Housing Implementation Program EIR (State
Clearinghouse [SCH] Number 2023060699) provides a cumulative analysis regarding open space,
recreation amenities, and community character regarding potential development of the housing
implementation plan and housing opportunity sites. Refer to Master Response 3, CEQA Piecemealing and
Housing Opportunity Sites, regarding the City’s Housing Implementation Program and the housing opportunity
sites.
Response to Comment I54.5: Refer to Master Response 2: Loss of Existing Golf Course Use, as well as the
above responses. Additionally, as detailed in Draft EIR Section 5.13, Parks and Recreation, page 5.13-9, the
Project proposes to redevelop a portion of a golf course with a new commercial recreational surf park use.
Draft EIR 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. To
the extent people seek either an 18-hole course or a driving range, there are ample opportunities in the
vicinity. Moreover, as discussed above, shorter golf courses present a unique opportunity for a golf
experience, and courses are successfully designed with less than the standards 18-hole design.
Response to Comment I54.6: Refer to Master Response 3: CEQA Piecemealing and Housing Opportunity
Sites. As detailed in Draft EIR Section 3.0, Project Description, page 3-36, 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
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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.
The comment speculates that the proposed surf park would cause the remaining golf courses to fail. However,
the commenter provides no evidence to support that conclusion. In accordance with CEQA Guidelines Section
15145, Speculation, the Draft EIR is not required to consider issues that are too speculative for evaluation.
The Project proposes only the replacement of a few holes, which is evaluated in the EIR.
As detailed on page 5-6 of the Draft EIR (and Master Response 3), parcels (APNs 119 300 15, 16, 17 and
APN 119-310-04) to the south of the site (area of holes 3-8), across Mesa Drive have been identified as
candidate sites for future housing along with 100 housing sites on 176 acres within the Airport Focus Area
of the City, as identified in the City Housing Implementation Program. These parcels are identified in
Municipal Code Sections 20.80.025 (Housing Opportunity Overlay Zoning Districts maps) and 20.28.050
(Housing Opportunity (HO) Overlay Zoning Districts) and were previously evaluated in the Housing
Implementation Program EIR (State Clearinghouse [SCH] Number 2023060699).
However, no housing is currently proposed across Mesa Drive from the Project site. No application for
development of these parcels has been submitted to the City. Any future proposed housing on parcels south
of Mesa Drive, or any other location, would be separate and independent from the proposed surf park
Project. Any future proposed housing or other proposed development would require development specific
environmental analysis pursuant to CEQA and related permitting review.
Response to Comment I54.7: The proposed Project does not include the transformation from open green
space to high-density housing. The Draft EIR evaluation of potential impacts to aesthetics is based on
Appendix G of the CEQA Guidelines and the City’s General Plan guidance regarding visual resources in the
City. Draft EIR page 5.1-8 describes that 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. Draft EIR Section 5.1, Aesthetics, pages 5.1-12 through 5.1-16 describes that 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 surf lagoon, amenity clubhouse,
athlete accommodations, parking lot, ornamental landscaping, and associated infrastructure. As detailed in
Draft EIR Section 3.0, Project Description, on page 3-23, the proposed Project would include approximately
143,844 SF of drought tolerant ornamental landscaping that would cover approximately 20 percent of the
site that 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 Project structures 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. As detailed in Draft EIR Section 5.1, Aesthetics, pages 5.1-12 through 5.1-16
the proposed Project would change views of the site to a more urban and developed character compared
to the existing condition. However, it would not conflict with applicable zoning and other regulations
governing scenic quality and pursuant to CEQA Guidelines criteria, impacts would be less than significant.
Response to Comment I54.8: The proposed Project does not include development of housing on the Project
site. Refer to Master Response 3, regarding the housing opportunity sites, and Master Response 4, regarding
impacts related to vehicular trips.
Response to Comment I54.9: The Draft EIR evaluates cumulative impacts to ambient noise in Section 5.11,
Noise, pages 5.11-28 and 5.11-29, and also in Draft EIR Appendix Q, Surf Farm Noise Analysis. As detailed
above, the Project does not propose any housing. It proposes a surf park on a portion of the exiting golf
course, with 15-holes to remain. Therefore, the Project would not cumulatively increase noise together with
housing on Housing Opportunity sites 23, 24, 25 and 26, the development of which is speculative and not
related to the Project. The Project’s construction noise increase at R5 (near Housing Opportunity sites 23, 24,
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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.
Cumulative traffic noise was evaluated on Draft EIR page 5.11-29 where it is detailed that 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. Cumulative operational noise was also evaluated on Draft EIR page 5.11-29, which details that 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 increase in ambient noise
that could become cumulatively considerable.
The Draft EIR Section 5.11, Noise, details that the existing daytime ambient noise in the Project vicinity, which
ranges from 67.8 to 73.7 dBA, as listed in Draft EIR Table 5.11-4. Draft EIR page 5.11-4 states that the
General Plan land use noise compatibility matrix (shown in Table 5.11-1) identifies that commercial
recreation is clearly compatible with noise of up to 65 dBA CNEL and normally compatible with noise up to
75 dBA CNEL. As the ambient noise at the site ranges from 67.8 to 73.7 dBA it would be normally compatible
with the proposed commercial recreation uses.
Response to Comment I54.10: The proposed Project does not include development of housing on the Project
site. Refer to Master Response 3 regarding the housing opportunity sites. The Draft EIR air quality analysis
has been completed in compliance with the South Coast Air Quality Management District methodologies and
thresholds as detailed in Draft EIR Section 5.2, Air Quality, which details that emissions from construction and
operation of the proposed Project would not exceed thresholds and, therefore, would be less than significant.
The 186 daily additional vehicular trips that would be generated by the Project would not exceed air quality
thresholds, and the Project includes approximately 143,844 SF of drought tolerant ornamental landscaping
that would cover approximately 20 percent of the site that would include 24-inch box trees, 15-gallon trees,
various shrubs, and ground covers that would replace the existing landscaping on the site. Overall,
compliance with South Coast Air Quality Management District methodologies and thresholds determined that
impacts would be less than significant and the comment does not provide substantial evidence that a potential
impact could occur.
Response to Comment I54.11: As detailed on page 5.3-11 of the Draft EIR, the Project site has been subject
to decades of anthropogenic disturbances, which has removed native habitat for sensitive wildlife species.
The proposed landscaping would increase the area of tree coverage compared to the existing condition, as
shown by comparison of Draft EIR Figures 3-3, Aerial View, and 3-8, Conceptual Site Plan. Thus, after
implementing the Project birds and other wildlife would have similar locations on the site and the replacement
of ornamental trees does not result in long-term adverse impacts on biodiversity. As detailed in Draft EIR
Appendix C, Biological Technical Report, that was prepared by technical biological experts, with
implementation of the construction related mitigation measures, potential impacts related to biological
resources would be less than significant. This comment does not include substantial evidence of a significant
environmental impact related to biological resources. Thus, no further response is warranted.
Response to Comment I54.12: The Draft EIR evaluates hydrology and drainage in Section 5.9, Hydrology
and Water Quality. As detailed on page 5.9-14, the 5.06-acre surf lagoon would capture rainfall and not
result in runoff. As shown on Draft EIR Table 5.9-2, implementation of the proposed Project would result in a
reduction in the overall runoff rate in a 100-year, 24-hour storm condition. Draft EIR page 5.9-16 details
that the proposed Project would manage the runoff with vegetated biotreatment systems that have been
designed to accommodate the meet the design capture volume of 18,867 cubic feet and 3.419 cubic feet
per second (cfs) pursuant to the MS4 Permit and DAMP requirements. The proposed vegetated biotreatment
systems 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,
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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 (Draft EIR
page 5.9-11). 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 and water quality BMPs, which would reduce potential impacts to a less than
significant level. The potential impacts have been addressed in compliance with the CEQA Guidelines
Appendix G thresholds, and are adequately addressed in Draft EIR Section 5.9, Hydrology and Water
Quality.
Response to Comment I54.13: As detailed in Draft EIR Section 5.4, Cultural Resources, pages 5.4-14 and
5.4-15, prior to issuance of grading permits the applicant/developer shall provide evidence to the City 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) in coordination with the consulting tribe(s) and to conduct monitoring of rough
grading activities. The mitigation also provides that the archaeologist shall conduct Cultural Resource
Sensitivity Training, in conjunction with the Tribe(s) designated Tribal Representative, to 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 mitigation also details procedures in the event
that a resource is inadvertently discovered during ground-disturbing activities in accordance with Public
Resource Code Section 21083.2 and State CEQA Guidelines 15064.5 and 15126.4. All of these measures
would be required at the developer/applicant’s expense as part of construction costs of the proposed
Project. As detailed on Draft EIR page 5.4-15, implementation of the identified construction related
mitigation measures that were identified by archaeological professionals (in Draft EIR Appendix E) and
existing regulations would reduce potential impacts to a less than significant level. As detailed in Master
Response 1, economic effects of the proposed Project are not treated as effects on the environment and are
not evaluated within the EIR.
Response to Comment I54.14: The proposed Project does not include development of housing on the Project
site, and an increase in residential population would not occur (see Draft EIR Section 7.3, Population and
Housing. Refer to Draft EIR Section 5.5, Energy, Section 5.12, Public Services, and Section 5.16, Utilities and
Service Systems, which evaluate water, sewer, energy, and public services and detail that existing facilities
and public services would provide services to the proposed Project and that impacts related to infrastructure
would be less than significant and less than cumulatively considerable with implementation of existing
regulations and requirements that would be ensured through the development review and permitting process.
Response to Comment I54.15: The Draft EIR Section 5.5, Energy, details on page 5.5-10 that 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. In addition, adherence to California Building Code and
Energy Code standards would ensure that energy efficient technologies and practices are used for the
Project.
As detailed in Draft EIR Section 5.16, Utilities and Service Systems, page 5.16-27, the Project would connect
to the existing electricity powerlines within adjacent roadways. SCE prepared an Engineering Analysis
Report (included as Draft EIR 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. The Project would not require or result in the
construction of new facilities or the expansion of existing facilities, which could cause significant environmental
effects. Thus, the Draft EIR determined that impacts would be less than significant.
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Response to Comment I54.16: 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. As detailed in Draft EIR
Figures 5.1-3 through 5.1-8, views of solar panels on canopies in the parking lots would be screened by the
proposed landscaping. In addition, the Project would be required through the City’s permitting process to
comply with Municipal Code Section 21.30.070, Outdoor Lighting, which would limit glare from solar panels
on canopies in the parking areas.
As detailed in Draft EIR Sections 5.1, Aesthetics (page 5.1-32) and Section 5.8, Hazards and Hazardous
Materials (page 5.8-41), a solar glare analysis (included as Draft EIR 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 that was implemented pursuant to FAA criteria 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. Thus, the Project would not create a new source of substantial glare which
would adversely affect day or nighttime views in the area or impact operations of John Wayne Airport, and
impacts would be less than significant.
Response to Comment I54.17: The General Aviation Improvement Program for John Wayne Airport 1 and
the Airport Environs Land Use Plan for John Wayne Airport 2 do not include extension of any runway to
include the back 9 of the golf course. There are no other airport or airport land use plans to extend any
John Wayne Airport facilities to areas south of Bristol Street and State Route 73, which is located in between
the airport and golf course holes 10-18 (the back 9).
Draft EIR evaluates potential impacts related to operation of John Wayne Airport in Draft EIR Section 5.8,
Hazards and Hazardous Materials, and the Aircraft Hazard and Land Use Risk Assessment & Wildlife Hazard
Management Analysis, prepared by Johnson Aviation, Inc., included as Appendix M. 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. As detailed on Draft EIR page 5.8-40,
using the accident data in the California Airport Land Use Planning Handbook and from the NTSB database
for SNA, the aircraft hazard assessment 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. It should be noted that the existing golf course has a similar risk.
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, the Draft
EIR determined that potential impacts from aircraft accidents would be less than significant. As detailed in
Section 5.11, Noise, (and Response I54.9) the General Plan Land Use Noise Compatibility Matrix, identifies
that commercial recreation facilities are “normally compatible” up to 75 dBA CNEL.
1 https://files.ocair.com/media/2020-12/General-Aviation-Program-
FAQ_20200922.pdf?VersionId=pyXDNRUElrUqIxuFRtUBoMVJaxcTOLOa
2 https://files.ocair.com/media/2021-02/JWA_AELUP-April-17-
2008.pdf?VersionId=cB0byJjdad9OuY5im7Oaj5aWaT1FS.vD
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In addition, as detailed in Draft EIR details in Section 5.8, Hazards and Hazardous Materials, pages 5.8-15
and 5.8-40 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. Thus, the FAA has not blocked development within the Project site. The proposed Project does not
include housing, as detailed in Draft EIR Section 3.0, Project Description. It should be noted the Project site is
privately owned and the proposed Project does not involve expenses to the County.
Response to Comment I54.18: Refer to response I54.16 related to the solar panels potential for glare. A
complete evaluation of potential impacts related to John Wayn Airport has been included in the Draft EIR
as described in the previous response.
Response to Comment I54.19: As detailed in Master Response 1, CEQA is an environmental protection
statute that is concerned with a project’s physical changes to the environment (CEQA Guidelines Section
15358(b)). The environment includes land, air, water, minerals, flora, fauna, ambient noise, and objects of
historic or aesthetic significance (CEQA Guidelines Section 15360). Any economic and social effects of the
proposed Project are not treated as effects on the environment (CEQA Guidelines Sections 15064(e) and
15131(a)). Therefore, consistent with CEQA, the Draft EIR includes an analysis of the Project’s potentially
significant physical impacts on the environment and does not include a discussion of the Project’s economic or
social effects. The commenter is also referred to Responses to Comments I54.1-18.
Response to Comment I54.20: The comment is conclusionary in nature and summarizes previous concerns
related to the Draft EIR evaluation. The City disagrees with the commenter’s assertion. The Draft EIR provides
an accurate and thorough analysis of all of the Project’s potential environmental impacts pursuant to CEQA.
Refer to previous responses regarding the scope of the proposed Project and EIR evaluation related to land
use, recreation, aesthetics, infrastructure, and related cumulative impacts. This comment asserts concurrence
with Alterative 1, No Project No Build Alternative.
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Comment Letter I55: Greg Nelson (1 page)
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Response to Comment Letter I55: Greg Nelson, July 5, 2025
Response to Comment I55.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use. Please see Master Responses 3:
Piecemealing and Housing Opportunity Sites and 4: Impacts related to Vehicle Trips for responses regarding
the proposed Project’s traffic impacts and the Project’s relation to the Housing Opportunity Sites to the south
of the Project.
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Comment Letter I56: Julie Santa Rosa (1 page)
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Response to Comment Letter I56: Julie Santa Rosa, July 6, 2025
Response to Comment I56.1: The Project site is privately owned. Refer to Master Response 2: Loss of Existing
Golf Course Use, for the response to comments related to the change to the existing golf course use. Refer
to Master Responses 3: CEQA Piecemealing and Housing Opportunity Sites, and 4: Impacts related to Vehicle
Trips, for responses regarding the proposed Project’s traffic impacts and the Project’s relation to the Housing
Opportunity Sites to the south of the Project.
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Comment Letter I57: Robert Meadows (8 pages)
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Response to Comment Letter I57: Robert Meadows, July 6, 2025
Response to Comment I57.1: This comment is introductive in nature and provides the commenter’s opinion
on the proposed Project and does not provide a comment on specific environmental analysis within the Draft
EIR or any substantial evidence of a significant environmental impact. Thus, no further response is warranted.
Response to Comment I57.2: This comment is a copy of the letter provided in Comment I54. Please see
responses I54.3 to I54.20 for responses to this comment letter.
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Comment Letter I58: Debra Frederickson (1 page)
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Response to Comment Letter I58: Debra Frederickson, July 6, 2025
Response to Comment I58.1: Please refer to Master Response 4: Impacts Related to Vehicle Trips, for a
response to comments regarding the proposed Project’s traffic impacts. In regard to impacts related to water
use, as discussed in Draft EIR Section 5.16, Utilities and Service Systems, 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 and the City would have sufficient supplies for the proposed
Project. Thus, impacts related to water supply 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.
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Comment Letter I59: Kristi Jackson (2 pages)
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Response to Comment Letter I59: Kristi Jackson, July 6, 2025
Response to Comment I59.1: As detailed in Draft EIR Section 5.1, Aesthetics, pages 5.1-12 through 5.1-16
the proposed Project would change views of the site to a more urban and developed character compared
to the existing condition. However, it would not conflict with applicable zoning and other regulations
governing scenic quality and pursuant to CEQA Guidelines criteria, impacts would be less than significant.
This comment does not provide any substantial evidence that the proposed Project would result in a new
significant environmental impact. Thus, no further response is warranted.
Response to Comment I59.2: Please refer to Master Response 1: Project Merits for a response to comments
regarding the necessity and fiscal impacts of the proposed Project.
In regard to the Projects components, Draft EIR Section 3.0, Project Description, provides an accurate
description of the Project components and their operational functions. The athlete accommodations are
described as units which 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.”
About the Project’s impact to wildlife, as discussed in Draft EIR Section 5.3, Biological Resources on page 5.3-
21, the Project site is comprised of disturbed/developed area and turf grass/ornamental landscaping, which
is not classified as a sensitive natural community (also discussed in Appendix C to the Draft EIR). 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 any substantial impacts to sensitive wildlife. The Project would not result in a reduction in trees.
As detailed in Draft EIR Section 3.0, Project Description, on page 3-23, the proposed Project would include
approximately 143,844 SF of drought tolerant ornamental landscaping that would cover approximately
20 percent of the site that would include 24-inch box trees, 15-gallon trees, various shrubs, and ground
covers. Trees are shown in Draft EIR Figure 3-8, Conceptual Site Plan.
On the chlorine runoff from the proposed lagoon, Draft EIR Section 5.8, Hazards and Hazardous Materials,
pages 5.8-36 and 5.8-36 describe that the Project would use and store common hazardous materials such
as paints, pool cleaning chemicals, solvents, and cleaning products. The surf lagoon would use basic pool
type cleaning equipment and chemicals to maintain the pH levels for surfers. The Surf Lagoon Water Systems
Narrative, included as Appendix C to this Final EIR, details that sodium hypochlorite would be utilized as the
primary sanitizer and is one of the most common chemical compounds used to maintain a chlorine residual in
traditional swimming pool facilities. Muriatic acid would also be utilized for pH maintenance. Both chemicals
would be dosed to the lagoon water through automated feeders and the lagoon water quality would be
continuously monitored via an automated water chemistry control system, maintaining the following water
quality parameters at all times during operation:
• Water clarity/turbidity: < 5 NTU
• Oxidation Reduction Potential (ORP): minimum 650 mV - maximum 850 mV
• Sanitizer Residual: minimum 0.5 ppm FAC
• pH level: 7.0 to 7.6
The surf lagoon would require permitting from the Orange County Department of Health, which has
approved a variance for the levels of chlorine to be 0.5 ppm that is lower than the recreational pool
requirement of 1.0 ppm due to the low user load density to water volume ratio by nature of the surf lagoon.
Thus, lagoon water that is discharged into the sewer system would have a low level of chlorine and potentially
a limited volume of cleaning agents, which is similar to other commercial recreational facilities. An ultraviolet
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-218
Final EIR
October 2025
(UV) light system would be utilized as supplemental sanitation of the lagoon water. This system would treat
100% of the recirculation flow rate of the lagoon filtration system and would inactivate chlorine resistant
pathogens such as cryptosporidium.
The lagoon water volume would be continuously filtered utilizing a perlite regenerative media filtration
system that would capture particulates and remove contaminants from the lagoon water to the 1-5 micron
range. Perlite filter media has been tested to be effective at removing pathogens such as cryptosporidium
from the filtered water and would be used as an additional method of sanitation for the lagoon water.
When the filter media is changed, wastewater would be generated containing spent perlite media, which
would be discharged into the sewer system. Perlite filter media is derived from naturally occurring volcanic
rock, is non-toxic, and generally permitted to be discharged into the sewer system (Appendix C of this Final
EIR).
As detailed in the Surf Lagoon Water Systems Narrative, included as Appendix C to this Final EIR, prior to
discharge of a surf basin, the water would be allowed to dechlorinate through natural dissipation during
days of non-use, or alternatively could be dechlorinated by dosing sodium thiosulfate prior to pumping the
water out to the sewer system. Approximately 575 lbs of sodium thiosulfate would be required to
dechlorinate the entire lagoon volume to a zero-chlorine residual. Thus, lagoon water that is discharged into
the sewer system would be safe to discharge into the sewer system.
Draft EIR Section 3.0, Project Description, page 3-34 describes that operation of the surf lagoons include
maintenance that would be coordinated via permit with the Costa Mesa Sanitary District (CMSD) that
provides sewer services to the site. In addition, due to the volume of wastewater that would be discharged
by the Project an Orange County Sanitation District Industrial Wastewater Discharge Permit would be
required, as is required for any discharge in excess of 25,000 gallons per day. The Industrial Wastewater
Discharge Permit regulates wastewater discharges by limiting specific pollutants through establishing numeric
discharge standards, discharge requirements, monitoring and reporting requirements
(https://www.ocsan.gov/industrialdischarge/). The discharge standards of Industrial Wastewater Discharge
Permits are based on the National Pollutant Discharge Elimination System Permit and the wastewater
treatment facility.
Response to Comment I59.3: This comment does not provide any substantial evidence that the Project would
result in a significant environmental impact. Section 152049(c) of the CEQA Guidelines advises that comments
should be accompanied by factual support, stating “[r]eviewers should explain the basis for their comments
and should submit data or references offering facts, reasonable assumptions based on facts, or expert
opinion supported by facts in support of the comments. Pursuant to Section 15064, an effect shall not be
considered significant in the absence of substantial evidence.”
Although, 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 surf lagoon, amenity
clubhouse, athlete accommodations, parking lot, and associated infrastructure, the Project would not cause a
significant aesthetic impact. The proposed structures would be set back a minimum of 20 feet from adjacent
streets (as shown in Draft EIR Figure 3-8, Conceptual Site Plan) and would not encroach into public views
along the roadway corridors adjacent to the site. As detailed in Draft EIR Section 3.0, Project Description, on
page 3-23, the proposed Project would include approximately 143,844 SF of drought tolerant ornamental
landscaping that would cover approximately 20 percent of the site that 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 Project structures 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. Therefore, views along the
adjacent roadways would provide green landscaping that would provide screening to the proposed
structures.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-219
Final EIR
October 2025
Response to Comment I59.4: As detailed on Draft EIR page 5.14-12, the vehicle trips generated by the
existing uses on the site and 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 and surf park data, which were reviewed and approved by
the City’s Traffic Engineering Division. Also, refer to Master Response 4: Impacts Related to Vehicle Trips, for
a response to comments regarding the proposed Project’s traffic impacts.
Response to Comment I59.5: The comment speculates that the proposed surf park would cease to operate
in the future. It would be speculative to make assumptions regarding how long the surf park would operate
and what would occur with the infrastructure thereafter. The EIR properly evaluates the potential
environmental impacts associated with construction and operation of the proposed Project. In accordance
with CEQA Guidelines Section 15145, Speculation, the Draft EIR is not required to consider circumstances
that are too speculative for evaluation. Further CEQA Guidelines Section 15146, Degree of Specificity, states
that the degree of specificity required for an EIR will correspond to the degree of specificity in the activity.
The specificity of future activities beyond construction and operation of the proposed Project are unknown.
Further, as detailed in Master Response 1, economic effects of the proposed Project are not treated as
effects on the environment and are not evaluated within the EIR.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-220
Final EIR
October 2025
Comment Letter I60: Patti Ferguson (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-221
Final EIR
October 2025
Response to Comment Letter I60: Patti Ferguson, July 6, 2025
Response to Comment I60.1: Please refer to Master Response 1: Project Merits for a response to comments
regarding the Project merits and fiscal impacts of the proposed Project.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-222
Final EIR
October 2025
Comment Letter I61: Diane Rinker (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-223
Final EIR
October 2025
Response to Comment Letter I61: Diane Rinker, July 6, 2025
Response to Comment I61.1: Please refer to Master Response 4: Impacts Related to Vehicle Trips, for a
response to comments regarding the proposed Project’s traffic impacts. As discussed in Master Response 3,
there is no high density housing included as part of the proposed Project.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-224
Final EIR
October 2025
Comment Letter I62: Scott Pickard (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-225
Final EIR
October 2025
Response to Comment Letter I62: Scott Pickard, July 6, 2025
Response to Comment I62.1: As detailed in Section 3.0, Project Description, 15 holes of golf would be
retained with implementation of the proposed Project. Refer to Master Response 2: Loss of Existing Golf
Course Use, for the response to comments related to the change to the existing golf course use as well as
Master Response 1: Project Merits for a response to comments regarding the merits of the proposed Project.
As discussed in Draft EIR Section 5.3, Biological Resources, and in Appendix C to the Draft EIR, 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 supports prey species such as insects, spiders,
lizards, snakes, small mammals, and other birds. Impacts related to nesting birds onsite would be mitigated
with the implementation of Mitigation Measure BIO-2 which requires nesting bird surveys to take place prior
to ground disturbance to ensure that no nesting birds are disturbed during construction. In addition, the
proposed Project would include landscaping on 143,844 SF (20 percent) of the site with 24-inch box trees
and 15-gallon trees, including palms, as shown in Draft EIR Figure 3-8, Conceptual Site Plan. Proposed
landscaping would provide new trees for roosting and nesting common bird species.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-226
Final EIR
October 2025
Comment Letter I63: Shella Salvo (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-227
Final EIR
October 2025
Response to Comment Letter I63: Shella Salvo, July 6, 2025
Response to Comment I63.1: Cumulative transportation impacts were discussed on page 5.14-7 in Draft
EIR Section 5.14, Transportation, which determined that impacts would be less than significant upon
implementation of the City’s traffic engineering design standards. For an additional response related to
traffic impacts, refer to Master Response 4: Impacts Related to Vehicle Trips. As discussed in Master Response
3, there is no high-density housing included as part of the proposed Project.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-228
Final EIR
October 2025
Comment Letter I64: Steve Kalatschan (2 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-229
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-230
Final EIR
October 2025
Response to Comment Letter I64: Steve Kalatschan, July 6, 2025
Response to Comment I64.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use as well as Master Response 1:
Project Merits for a response to comments regarding the merits of the proposed Project.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-231
Final EIR
October 2025
Comment Letter I65: Allison Robar (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-232
Final EIR
October 2025
Response to Comment Letter I65: Allison Robar, July 6, 2025
Response to Comment I65.1: Refer to Master Response 1: Project Merits, for a response to comments
regarding the merits of the proposed Project. As discussed in Master Response 2: Loss of Existing Golf Course
Use, and in Draft EIR Section 3.0, Project Description, the Project site has a General Plan Land Use designation
of Parks and Recreation, which is intended to provide for a variety of both active and passive uses, including:
golf courses, marina support facilities, tennis clubs and courts, private recreation, and similar facilities. The
Project site is zoned for Open Space and Recreation within the Santa Ana Heights Specific Plan which, subject
to a use permit, allows for outdoor commercial recreation. The proposed Project is consistent with the intended
uses for the site within the City’s General Plan and the Santa Ana Heights Specific Plan.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-233
Final EIR
October 2025
Comment Letter I66: Sandee Felix (2 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-234
Final EIR
October 2025
Response to Comment Letter I66: Sandee Felix, July 6, 2025
Response to Comment I66.1: Please refer to Master Responses 3: Piecemealing and Housing Opportunity
Sites and 4: Impacts related to Vehicle Trips for responses regarding the proposed Project’s traffic impacts
and the lack of relationship between the Project and the City’s decision to rezone the sites to the south for
possible housing. Implementation of the Project would result in a reduction in AM and PM peak hour traffic
and would not increase congestion. As detailed in Draft EIR Section 5.14, Transportation, page 5.14-16, the
new site circulation, including driveway designs, would be approved by the City’s transportation engineering.
Sight distance at the Project’s access points would be reviewed with respect to City standards prior to receipt
of permits. 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, which would provide safe
access to and from the Project site.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-235
Final EIR
October 2025
Comment Letter I67: Diane Moore (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-236
Final EIR
October 2025
Response to Comment Letter I67: Diane Moore, July 6, 2025
Response to Comment I67.1: Please refer to Master Responses 3: Piecemealing and Housing Opportunity
Sites and 4: Impacts related to Vehicle Trips for responses regarding the proposed Project’s traffic impacts
and the Project’s relation to the Housing Opportunity sites to the south. Implementation of the Project would
result in a reduction in AM and PM peak hour traffic and would not increase congestion. As detailed in Draft
EIR page 5.14-16, the new site circulation, including driveway designs, would be approved by the City’s
transportation engineering. Sight distance at the Project’s access points would be reviewed with respect to
City standards prior to receipt of permits. 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, which would provide safe access to and from the Project site.
As discussed in Draft EIR Section 5.11, Noise, on page 5.11-22, 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. Draft EIR 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. Please refer to Master Response 5:
Noise Impacts, as well as Draft EIR Section 5.11 Noise, for additional discussion of the proposed Project’s
noise impacts.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-237
Final EIR
October 2025
Comment Letter I68: Michelle Clark (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-238
Final EIR
October 2025
Response to Comment Letter I68: Michelle Clark, July 7, 2025
Response to Comment I68.1: As discussed on page 7-3 within Section 7.0, Effects Found Not Significant, 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, as discussed in Master Response 3. In regards
to congestion impacts, refer to Master Response 4: Impacts Related to Vehicle Trips.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-239
Final EIR
October 2025
Comment Letter I69: Micah Stovall (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-240
Final EIR
October 2025
Response to Comment Letter I69: Micah Stovall, July 19, 2025
Response to Comment I69.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use as well as Master Response 1:
Project Merits for a response to comments regarding the merits of the proposed Project.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-241
Final EIR
October 2025
Comment Letter I70: Moe Sim (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-242
Final EIR
October 2025
Response to Comment Letter I70: Moe Sim, July 7, 2025
Response to Comment I70.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use as well as Master Response 1:
Project Merits for a response to comments regarding the merits of the proposed Project.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-243
Final EIR
October 2025
Comment Letter I71: Ryan Calderon (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-244
Final EIR
October 2025
Response to Comment Letter I71: Ryan Calderon, July 7, 2025
Response to Comment I71.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use as well as Master Response 1:
Project Merits for a response to comments regarding the necessity of the proposed Project.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-245
Final EIR
October 2025
Comment Letter I72: Mike Smith (22 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-246
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-247
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-248
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-249
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-250
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-251
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-252
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-253
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-254
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-255
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-256
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-257
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-258
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-259
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-260
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-261
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-262
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-263
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-264
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-265
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-266
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-267
Final EIR
October 2025
Response to Comment Letter I72: Mike Smith, July 7, 2025
Response to Comment I72.1: This comment does not provide substantial evidence of a significant
environmental impact or provide comments related to the analysis within the EIR, except for concurrence with
Alterative 1, No Project No Build Alternative. Refer to Master Response 1, Project Merits, regarding comments
about the Project merits, and CEQA’s requirements to respond to comments related to environmental impacts.
The commenter’s preference for the No Project/No Build Alternative is noted. As no specific comment related
to the environmental analysis was provided, no further response is required.
Response to Comment I72.2: Although the Project would result in view changes from removal of the golf
course amenities from the Project site and develop a surf park facility, Draft EIR Section 5.1, Aesthetics,
details that the Project would not result in significant impacts to a scenic vista. The comment does not provide
any substantial evidence that an impact to a scenic vista would occur, other than noting the change from
green space to developed areas. Section 152049(c) of the CEQA Guidelines advises that comments should
be accompanied by factual support, stating “[r]eviewers should explain the basis for their comments and
should submit data or references offering facts, reasonable assumptions based on facts, or expert opinion
supported by facts in support of the comments. Pursuant to Section 15064, an effect shall not be considered
significant in the absence of substantial evidence.”
Draft EIR page 5.1-6 describes that 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 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 Draft EIR 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 development that 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. In
addition, the eastern border of the Project site would be set back 20 feet from the adjacent property. 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.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-268
Final EIR
October 2025
Response to Comment I72.3: This comment does not provide substantial evidence of a significant
environmental impact related to bats or provide specific comments related to the analysis related to bats
within the Draft EIR. Consistent with the comment that outside independent experts in this field should be
consulted, Draft EIR Appendix C, Biological Technical Report, was prepared by Glen Lukos Associates, Inc.
who are technical biological experts. As detailed on page 33 of the report, the western yellow bat does
not have a federal designation but is a California Department Fish Wildlife ranked high priority species,
indicating that it is rare to uncommon. The western yellow bat preferentially roosts in trees, generally palms
in the southern U.S, and often encountered among dead fronds of Washingtonia fan palms and has a low
potential to roost in ornamental palm trees on the Project site. As detailed on page 38 of the Biological
Technical Report, due to the limited habitat for this species on the Project site, potential impacts to habitat
for this species would be less than significant. However, the Draft EIR includes Mitigation Measure BIO-1 that
requires implementation of emergent bat surveys to detect roosting bats be completed prior to removal of
trees, and measures to implement in the case that bats are identified. As detailed in Mitigation Measure
BIO-1, a qualified biologist (as determined by the City), would implement the bat protection measures, which
would reduce potential impacts to a less than significant level, as detailed in Draft EIR Section 5.3, Biological
Resources, page 5.3-20 and 5.3-24.
Response to Comment I72.4: This comment does not provide substantial evidence of a significant
environmental impact related to birds or provide specific comments related to the analysis related to birds
within the Draft EIR. Consistent with the comment that outside independent experts in this field should be
consulted, Draft EIR Appendix C, Biological Technical Report, was prepared by Glen Lukos Associates, Inc.
who are technical biological experts.
As detailed on page 5.3-11 of the Draft EIR, the Project site has been subject to decades of anthropogenic
disturbances, which has removed native habitat for sensitive wildlife species. 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. Draft EIR Table 5.3-2, Special Status Wildlife Species Probably List,
identifies each special status bird species and their lack of potential to occur on the Project site. Draft EIR
page 5.3-21 details that common bird species may nest in the existing trees on the site and that nesting
birds are protected by the federal Migratory Bird Treaty Act (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 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.
In addition, the proposed Project would include landscaping on 143,844 SF (20 percent) of the site with 24-
inch box trees and 15-gallon trees, including palms, as shown in Draft EIR Figure 3-8, Conceptual Site Plan.
Proposed landscaping would provide new trees for roosting and nesting common bird species.
Response to Comment I72.5: This comment does not provide substantial evidence of a significant
environmental impact related to cumulative impacts on biological resources. The comment states that the EIR
is inaccurate and wrong but does not provide an explanation of how or why. As detailed in Draft EIR Section
5.3, Biological Resources, pages 5.3-22 and 5.3-23, with implementation of existing regulations and
Mitigation Measures BIO-1 and BIO-2 potential impacts from the Project would be less than cumulatively
considerable. As no specific comment related to the environmental analysis was provided, no further response
is required.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-269
Final EIR
October 2025
Response to Comment I72.6: This comment identifies specific procedures related to reduced potential
impacts to archaeological resources, which are similar to those identified by the professional archaeological
analysis that is provided in Draft EIR Appendix E, Phase I Archaeological Resources Assessment. The Draft EIR
identifies mitigation measures to be implemented to ensure that no significant impacts occur regarding
archaeological resources. As detailed in Draft EIR Section 5.4, Cultural Resources, pages 5.4-14 and 5.4-15,
prior to issuance of grading permits the applicant/developer shall provide evidence to the City 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) in coordination with the consulting tribe(s) and to conduct monitoring of rough
grading activities. The mitigation also provides that the archaeologist shall conduct Cultural Resource
Sensitivity Training, in conjunction with the Tribe(s) designated Tribal Representative, to 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 mitigation also details procedures in the event
that a resource is inadvertently discovered during ground-disturbing activities in accordance with Public
Resource Code Section 21083.2 and State CEQA Guidelines 15064.5 and 15126.4. All of these measures
would be required at the developer/applicant’s expense as part of construction costs of the proposed
Project. As detailed on EIR page 5.4-15, implementation of the identified construction related mitigation
measures that were identified by archaeological professionals (in Draft EIR Appendix E) and existing
regulations would reduce potential impacts to a less than significant level. The comment does not provide
any detail or substantive evidence to support its statement that the determination of less than significant is
wrong or, how impacts could be significant. Thus, based on the expert technical study determination provided
in Draft EIR Appendix E, impacts related to archaeological resources would be less than significant with
implementation of existing regulations and the Draft EIR mitigation measures.
Response to Comment I72.7: As detailed in Draft EIR Section 5.6, Geology and Soils, the proposed Project
site is within a seismically active region, with numerous faults capable of producing significant ground motions.
The Project has been evaluated through implementation of site-specific testing as detailed in Draft EIR
Appendix H, Geotechnical Exploration. In addition, as described in page 5.6-14, the Project would be
required to be constructed in compliance with the California Building Code, as adopted by the City of
Newport Beach in Municipal Code Chapter 15.04, and as verified through the City’s plan check and
permitting process.
Basin water movement and safety related to seismic movement is discussed in Section 5.9, Hydrology and
Water Quality, on pages 5.9-17 and 5.9-18, where it is described that the two proposed surf basins would
be seismically designed to contain waves from the moving water. The perimeter walls and deck around the
lagoon would be 11 inches higher than the water level and are designed to contain waves. Thus, water
movement generated by seismic movement would stay within the lagoon. The Surf Lagoon Water Systems
Narrative, included as Appendix C to this Final EIR, details that the lagoon is designed to have a water level
of 11 inches below the adjacent pool deck and would be maintained during operation as excess water in
the lagoon (over 2-inches) would halt operation of the wave generation machine. In a worst case seismic
scenario, wave energy may be directed toward the southwest where the sloshing action akin to a rogue
wave could theoretically splash onto the hardscape surrounding the lagoon and drain to the sewer.
Therefore, the Draft EIR determined that potential impacts related to seiche and/or seismic related flooding
would be less than significant.
Potential Project impacts related to emergency exit routes are described in Draft EIR Section 5.14,
Transportation, on page 5.14-17, where it describes that the proposed two 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
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-270
Final EIR
October 2025
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 emergency access would be less than significant.
Response to Comment I72.8: This comment expresses concurrence with Alterative 1, No Project No Build
Alternative, and provides an opinion to implement Alternative 1. Refer to Master Response 1 regarding
comments about the Project merits, and CEQA’s requirements to respond to comments related to
environmental impacts. As no specific comment related to the environmental analysis was provided, no further
response is required.
Response to Comment I72.9: As detailed in Master Response 1, Project Merits, CEQA is an environmental
protection statute that is concerned with the physical changes to the environment (CEQA Guidelines Section
15358(b)) that are associated with a project. Here, the Project is the construction and operation of a surf
lagoon in the location of certain golf course holes. While the remaining 15 holes would continue to operate,
the Project does not control that operation, which would continue to be the responsibility of the golf course
itself. The environment includes land, air, water, minerals, flora, fauna, ambient noise, and objects of historic
or aesthetic significance (CEQA Guidelines Section 15360). Any economic and social effects of the proposed
Project are not treated as effects on the environment (CEQA Guidelines Sections 15064(e) and 15131(a)).
Therefore, consistent with CEQA, the Draft EIR includes an analysis of the Project’s potentially significant
physical impacts on the environment and does not include a discussion of the Project’s economic or social
effects.
As detailed in Section 3.0, Project Description, on page 3-34, 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. Draft EIR Section 5.10, Land Use and Planning, details
that the Project would be consistent with the City General Plan and Santa Ana Specific Plan designated uses
for the Project site.
Response to Comment I72.10: As detailed in Master Response 2, the Project site consists of privately owned
land within a portion of the Newport Beach Golf Course, which is a commercial recreation facility that is not
City/publicly owned (not a municipal golf course). As detailed in Draft EIR Section 5.13 Parks and Recreation
(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 Newport
Beach Golf Course. Likewise, Draft EIR Table 5.13-3 identifies 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
driving range on the Project site. As detailed in the previous response and Master Response 1, Project Merits,
CEQA is an environmental protection statute that is concerned with the physical changes to the environment
that do not include economic or social effects, or other Project merits. Although the comment states that the
Draft EIR is incorrect and that site golfers would use other facilities, the comment does not identify any
physically altered golf facilities that would be required by the proposed Project or any other substantial
evidence of a potential significant impact. Thus, no further response is warranted.
Response to Comment I72.11: This comment asserts concurrence with Alterative 1, No Project No Build
Alternative and that the Project would result in an impact related to Impact REC-3 by removing a green
open space and installing a concrete structure. The comment does not provide any substantial evidence to
support the statement. As detailed in Draft EIR Section 5.13, Parks and Recreation, page 5.13-9, the Project
proposes to redevelop a portion of a golf course with a new commercial recreational surf park use. With
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-271
Final EIR
October 2025
the change to the Golf Course to the 15-hole format 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 usage. However, Draft EIR 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.
In addition, the Draft EIR page 5.13-10 details that the construction and operational 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 the 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. Hydrology and drainage are evaluated in Sections 5.9, Hydrology and Water Quality and Section
5.16, Utilities and Service Systems. Noise from construction is evaluated in Section 5.11, Noise, and vehicular
trips from construction of the Project are analyzed in Draft EIR Section 5.14, Transportation. Therefore, Project
impacts related to the construction or expansion of recreational facilities would be less than significant. The
comment does not describe a specific potential impact; thus, no further response is warranted.
Response to Comment I72.12: This comment asserts that the vehicle trip generation information prepared
by traffic engineers and approved by the City’s transportation engineering division is inaccurate but does
not provide any substantial evidence to support the opinion provided. As detailed in Draft EIR Appendix R,
the trip generation was prepared through a comprehensive review of detailed programmatic attendance
information and operational modeling data based on maximum attendance and was reviewed and
approved by the City’s traffic engineer. Trip generation was also based on a comprehensive market analysis
that include a review of comparable case studies to validate the demand assumptions. As noted by many
commenters, the Project’s surf lagoon is not the ocean, and it cannot be assumed that demand/trip styles
would be the same. The daily visitor allocations for the individual land use categories, as detailed in Draft
EIR Appendix R, are related to primary destination person trips and do not reflect any additional internally
captured visitor activity (i.e., trips to secondary destinations by individuals already on-site). As such, it can
be reasonably assumed that the total amount of daily visitors projected for the restaurant facility could
include both the 240 primary destination visitors and approximately 280 additional internally captured
visitors from the other land use categories (i.e., 25% of the remaining 1,160 primary destination person
trips), which would total 520 daily visitors and is generally consistent with the patronage of a standalone
restaurant of similar size. The comment does not provide any data to support a different trip generation by
the proposed Project. Refer to Master Response 4, Impacts Related to Vehicle Trips.
Response to Comment I72.13: As detailed in Draft EIR Section 5.14, Transportation, page 5.14-13, the
proposed Project would result in a net reduction of 73 AM peak hour trips and 10 PM peak hour trips
compared to the existing golf course uses. Therefore, the Project would result in a reduction in peak hour
congestion compared to the existing conditions and reduce potential for accident conditions related to
congestion. Similarly, the Project would not contribute to traffic conditions of other projects during the AM
and PM peak hours. The overall daily number of vehicle trips would increase by 186 (Draft EIR Table 5.14-
2 on page 5.14-13); however, this would be less than the 300 daily trip threshold identified by the City
Traffic Phasing Ordinance (Municipal Code Title 15, Chapter 15.40, Traffic Phasing Ordinance) and would
be less than significant and would not combine with traffic from other projects to become cumulatively
considerable (Draft EIR page 5.14-17). In addition, the medical office building project located at 3300
Irvine Avenue is included in the cumulative projects that were evaluated and is listed on Draft EIR Table 5-
1, Cumulative Projects List, on page 5-5 and shown on Figure 5-1, Cumulative Project (page 5-7). The City’s
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-272
Final EIR
October 2025
Fire and Police Departments were consulted regarding potential public service and safety impacts as part
of preparation of the Draft EIR, as detailed in Draft EIR Section 5.12, Public Services.
Response to Comment I72.14: As detailed in the previous response, implementation of the Project would
result in a reduction in AM and PM peak hour traffic and would not increase congestion. As detailed in Draft
EIR page 5.14-16, the new site circulation, including driveway designs, would be approved by the City’s
transportation engineering. Sight distance at the Project’s access points would be reviewed with respect to
City standards prior to receipt of permits. 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, which would provide safe access to and from the Project site.
Response to Comment I72.15: As detailed in Draft EIR Section 3.0, Project Description, page 3-36, 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.
As detailed on page 5-6 of the Draft EIR, parcels (APNs 119 300 15, 16, 17 and APN 119-310-04) to the
south of the site (area of holes 3-8), across Mesa Drive have been identified as candidate sites for future
housing along with 100 housing sites on 176 acres within the Airport Focus Area of the City, as identified in
the City Housing Implementation Program. These parcels are identified in Municipal Code Sections
20.80.025 (Housing Opportunity Overlay Zoning Districts maps) and 20.28.050 (Housing Opportunity (HO)
Overlay Zoning Districts) and were previously evaluated in the Housing Implementation Program EIR (State
Clearinghouse [SCH] Number 2023060699). However, no housing is currently proposed across Mesa Drive
from the Project site. No application for development of these parcels has been submitted to the City. Any
future proposed housing on parcels south of Mesa Drive, or any other location, would be separate and
independent from the proposed surf park Project. Any future proposed housing or other proposed
development would require development specific environmental analysis pursuant to CEQA and related
permitting review. The commenter is incorrect in stating that the golf club could stop golf course operations
and then start construction the following day. To the extent any future project is proposed for the other
portions of the golf course that are retained by the Project – which is unforeseeable – such future project
would require discretionary review by the City. Further, refer to Master Response 1 regarding comments
about Project merits, such as opinion regarding future uses of adjacent parcels.
Response to Comment I72.16: This comment does not provide comments related to a Project potential
significant environmental impact or provide comments related to the analysis within the EIR. As detailed in
the previous response, the parcels to the south of Mesa Drive from the Project site (that include holes 3-8)
are identified in Municipal Code Sections 20.80.025 (Housing Opportunity Overlay Zoning Districts maps)
and 20.28.050 (Housing Opportunity (HO) Overlay Zoning Districts). The addition of the overlay to this
area is not part of or related to the proposed Project. It was an independent act of the City, which does not
require or trigger the construction of housing. Further, refer to Master Response 1 regarding comments about
Project merits, such as opinion regarding future uses of adjacent parcels. Refer to Master Response 3, CEQA
Piecemealing and Housing Opportunity Sites, regarding the City’s Housing Implementation Program and these
housing opportunity sites.
Response to Comment I72.17: This comment does not provide substantial evidence of a significant
environmental impact or provide comments related to the analysis within the EIR, except for concurrence with
Alterative 1, No Project No Build Alternative. Refer to Master Response 1 regarding comments about the
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-273
Final EIR
October 2025
Project merits, and CEQA’s requirements to respond to comments related to environmental impacts. As no
specific comment related to the environmental analysis was provided, no further response is required.
Response to Comment I72.18: This comment provides an LA Times article about the proposed
redevelopment project located at 3300 Irvine Avenue, across the street to the northwest of the Project site.
This project is included in the cumulative projects that were evaluated and is listed on Draft EIR Table 5-1,
Cumulative Projects List, on page 5-5 and shown on Figure 5-1, Cumulative Project (page 5-7). This comment
does not provide substantial evidence of a significant environmental impact or provide comments related to
the analysis within the EIR. Thus, no further response is required.
Response to Comment I72.19: This comment provides a 2021email to the City related to the Housing
Element Update, concepts for potential housing development on the parcels to the south of Mesa Drive from
the Project site (that includes holes 3-8), and information related to the John Wayne Airport Safety Zone 4.
This comment is not related to the proposed Project’s discretionary actions or potential environmental impacts
of the proposed Project. Refer to Master Response 3, CEQA Piecemealing and Housing Opportunity Sites,
regarding the City’s Housing Implementation Program and these housing opportunity sites.
Response to Comment I72.20: This comment is a copy of the letter provided in Comment I54. Please see
responses I54.3 to I54.20 for responses to this comment.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-274
Final EIR
October 2025
Comment Letter I73: Kerry Simpson (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-275
Final EIR
October 2025
Response to Comment Letter I73: Kerry Simpson, July 7, 2025
Response to Comment I73.1: As detailed in Section 3.0, Project Description, 15 holes of golf would remain
with implementation of the proposed Project, and the Project would not require those who wish to play golf
to drive farther. Also, refer to Master Response 2: Loss of Existing Golf Course Use. As detailed in Draft EIR
Section 5.13 Parks and Recreation (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 Newport Beach Golf Course. Draft EIR Table 5.13-3 identifies 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 driving range on the Project site. Further, as detailed in Master Response 1, Project
Merits, economic and social effects of the proposed Project are not treated as effects on the environment
and are not evaluated within the EIR.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-276
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October 2025
Comment Letter I74: Scott Klein (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-277
Final EIR
October 2025
Response to Comment Letter I74: Scott Klein, July 7, 2025
Response to Comment I74.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-278
Final EIR
October 2025
Comment Letter I75: Jim Auster (9 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-279
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-280
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-281
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-282
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-283
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-284
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-285
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-286
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-287
Final EIR
October 2025
Response to Comment Letter I75: Jim Auster, July 7, 2025
Response to Comment I75.1: This comment is introductive in nature and does not provide any substantial
evidence that the proposed Project would result in a new significant environmental impact. Thus, no further
response is warranted.
Response to Comment I75.2: This comment is a copy of the letter provided in Comment I54. Please see
responses I54.3 to I54.20 for responses to this comment letter.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-288
Final EIR
October 2025
Comment Letter I76: Richard Moriarty (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-289
Final EIR
October 2025
Response to Comment Letter I76: Richard Moriarty, July 7, 2025
Response to Comment I31.1: The proposed Project does not include housing. Please refer to Master
Response 3: CEQA Piecemealing and Housing Opportunity Sites, for a response regarding the proposed
Project impacts related to the Housing Opportunity sites located to the south of the proposed Project. With
respect to flooding, the Draft EIR thoroughly analyzes the potential impacts to hydrology associated with
the Project, in Draft EIR Section 5.9, Hydrology and Water Quality, concluding that no significant impacts
would result.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-290
Final EIR
October 2025
Comment Letter I77: Betsy Hall (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-291
Final EIR
October 2025
Response to Comment Letter I77: Betsy Hall, July 7, 2025
Response to Comment I77.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use as well as Master Response 1:
Project Merits for a response to comments regarding the necessity of the proposed Project.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-292
Final EIR
October 2025
Comment Letter I78: Sue Garland (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-293
Final EIR
October 2025
Response to Comment Letter I78: Sue Garland, July 7, 2025
Response to Comment I78.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use as well as Master Response 1:
Project Merits for a response to comments regarding the merits of the proposed Project. Also refer to Draft
EIR Figure 3-8, Conceptual Site Plan; the proposed Project site would largely consist of the water surf basins,
landscaping areas, and solar canopies shaded parking areas, which would not increase heat in the area.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-294
Final EIR
October 2025
Comment Letter I79: Linda Giedt (12 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-295
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-296
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-297
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-298
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-299
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-300
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-301
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-302
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-303
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-304
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-305
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-306
Final EIR
October 2025
Response to Comment Letter I79: Linda Giedt, July 7, 2025
Response to Comment I79.1: Please refer to Master Response 1: Project Merits for a response to comments
regarding the necessity of the proposed Project. In addition, the proposed surf park would operate similarly
to the existing golf course in that anyone in the public can reserve time to utilize the facility. The membership
associated with the facility would grant special access to certain features and/or times; however, it would
not be necessary to access the surf lagoon.
Response to Comment I79.2: This comment does not provide any substantial evidence that the Project would
result in additional employees that could result in a significant environmental impact. Section 152049(c) of
the CEQA Guidelines advises that comments should be accompanied by factual support, stating “[r]eviewers
should explain the basis for their comments and should submit data or references offering facts, reasonable
assumptions based on facts, or expert opinion supported by facts in support of the comments. Pursuant to
Section 15064, an effect shall not be considered significant in the absence of substantial evidence.”
As detailed in Draft EIR Section 3.8, Operations, the Project would have a limited capacity and operation
through a reservation and/or ticketing system. The maximum number of participants in the lagoon at one
time would be 72 people with an average hourly usage of 35-45 people. This includes surfing competitions,
surf camps, and all other Project activities. The onsite surf amenities (other than the restaurant/bar, and pro
shop) would be limited to members. Also, the existing pro shop and restaurant on the Project site total 8,975
SF, and the proposed surf shop, restaurant/bar would total 9,108 SF, which is an increase of 133 SF over
existing conditions. Thus, a substantial increase of employees is not anticipated.
Response to Comment I79.3: As discussed above in response I79.2, Section 152049(c) of the CEQA
Guidelines advises that comments should be accompanied by factual support, stating “[r]eviewers should
explain the basis for their comments and should submit data or references offering facts, reasonable
assumptions based on facts, or expert opinion supported by facts in support of the comments. Pursuant to
Section 15064, an effect shall not be considered significant in the absence of substantial evidence.” This
comment does not provide any supporting evidence to its claim that the daily attendance of 1,400 people
is too low.
The trip generation provided in Draft EIR Appendix R states that an average of 1,400 visits per day would
be generated on a weekday during the high season. As detailed in Draft EIR Appendix R, the trip generation
was prepared through a comprehensive review of detailed programmatic attendance information and
operational modeling data based on maximum attendance and was reviewed and approved by the City’s
traffic engineer. In addition, only the restaurant/bar, and surf shop would be open to the public, the other
amenities such as the yoga and fitness areas would be reserved for members. As shown in the Trip
Generation Analysis included as Appendix R to the Draft EIR, 50% of the trip demand would be related to
the surf lagoon and 50% would be demand for the other associated amenities. The Trip Generation Analysis
(Appendix R to the Draft EIR) was reviewed and approved by the City’s traffic engineer. The daily visitor
allocations for the individual land use categories, as detailed in Appendix R, are related to primary
destination person trips and do not reflect any additional internally captured visitor activity (i.e., trips to
secondary destinations by individuals already on-site). As such, it can be reasonably assumed that the total
amount of daily visitors projected for the restaurant facility could include both the 240 primary destination
visitors and approximately 280 additional internally captured visitors from the other land use categories
(i.e., 25% of the remaining 1,160 primary destination person trips), which would total 520 daily visitors and
is generally consistent with the patronage of a standalone restaurant of similar size. It should also be noted
that the URBNSURF facility referenced by the commenter is located in Sydney, Australia, a significant
metropolitan area with proximity to the ocean and surfing (like Newport Beach and Orange County
generally). URBNSURF also includes two restaurants among other amenities.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-307
Final EIR
October 2025
Response to Comment I79.4: As part of the 2019 amendments to the CEQA Guidelines, SB 743 directed
that the revised CEQA Guidelines “shall promote the reduction of greenhouse gas emissions, the development
of multimodal transportation networks, and a diversity of land uses” (Public Resources Code Section
21099[b][1]); and that “automobile delay, as described solely by level of service or similar measures of
vehicular capacity or traffic congestion, shall not be considered a significant impact on the environment”
(Public Resources Code Section 21099[b][2]). As such, pursuant to Public Resources Code Section
21099(b)(2), the Draft EIR is not required to analyze impacts related to traffic congestion as it shall not be
considered an impact on the environment.
As discussed in further detail under Master Response 4: Impacts Related to Vehicle Trips, the proposed Project
would result in a reduction in AM and PM peak hour traffic and in a net increase of 186 daily trips, which
would have a less than significant transportation impact per City of Newport Beach traffic analysis guidelines
because its less than the threshold of 300 daily trips. As detailed by the comment, the Traffic Impact Analysis
for 3300 Irvine Avenue describes that the medical center project would add 1,496 new daily trips, which
exceeds the City’s 300 daily trip threshold; and therefore, a different analysis is required pursuant to the
City’s City Traffic Phasing Ordinance (Municipal Code Title 15, Chapter 15.40) and Transportation
Engineering Division Requirements.
Response to Comment I79.5: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use as well as Master Response 1:
Project Merits, for a response to comments regarding the merits of the proposed Project.
Response to Comment I79.6: This comment is a copy of the letter provided in Comment I54. Please see
responses I54.3 to I54.20 for responses to this comment letter.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-308
Final EIR
October 2025
Comment Letter I80: Matt Clark (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-309
Final EIR
October 2025
Response to Comment Letter I80: Matt Clark, July 7, 2025
Response to Comment I80.1: Please refer to Master Response 1: Project Merits, for a response to comments
regarding the merits of the proposed Project, Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use as well as Master Response 3:
CEQA Piecemealing and Housing Opportunity Sites, for a response to comments regarding the Housing
Opportunity Sites located to the south portion of the Project site. The medical office building project located
at 3300 Irvine Avenue is included in the cumulative projects that were evaluated and is listed on Draft EIR
Table 5-1, Cumulative Projects List, on page 5-5 and shown on Figure 5-1, Cumulative Project (page 5-7).
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-310
Final EIR
October 2025
Comment Letter I81: Richard Dayton (2 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-311
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-312
Final EIR
October 2025
Response to Comment Letter I81: Richard Dayton, July 7, 2025
Response to Comment I81.1: In accordance with CEQA Guidelines Section 21092, the Notice of Availability
of the Draft EIR for the proposed Project was mailed on May 23, 2025 to owners and occupants within a
300-foot radius of the Project site, posted physically onsite, posted on the City’s website, and published in
the Newport Harbor News Press Combined With Daily Pilot. Additionally, prior to circulation of the EIR, the
Notice of Preparation was similarly noticed on November 7, 2024 to the radius list, onsite, as well as on the
City’s website which notified about a public scoping meeting held in the Newport Beach Civic Center on
November 20, 2024 where public comments regarding the scope and content of the Draft EIR were heard.
Thus, sufficient notice was provided per CEQA Guidelines.
Response to Comment I81.2: The City of Newport Beach Municipal Code regulates how floor area is
calculated. Municipal Code Section 20.70.020(F)(2) states that:
“a.---For multi-unit residential, mixed-use, and nonresidential structures, the following areas shall be included
in calculations of gross floor area:
i. The area within and including the surrounding exterior walls; and
ii. Any interior portion of a structure that is accessible and that measures more than four feet from
floor to ceiling.
b. The following areas shall be excluded:
i. Stairwells and elevator shafts above the first level;
ii. Outdoor dining areas associated with an eating and drinking establishment, and
iii. Parking structures associated with an allowed use within the same development.”
Thus, pursuant to thus municipal code regulation, the storage areas, restrooms, and maintenance rooms are
not included in the calculation of the General Plan square footage.
Regarding access and operation, carts would be brought up from the storage basement by a staff member
to the parking lot level and then driven by golfers to the golf course. As stated on Draft EIR page 4.14-16,
the proposed Project would include golf cart circulation, separate from vehicular circulation. As shown on
Draft EIR Figure 5.1-4, the driveway along Mesa Drive would be graded to be level with the existing grade
of Mesa Drive. As stated on Draft EIR page 5.14-16, 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, which would reduce potential sighting hazards to a less than significant level.
Response to Comment I81.3: Refer to Master Response 1, Project Merits, and Master Response 2: Loss of
Existing Golf Course Use, for the response to comments related to the change to the existing golf course use.
Response to Comment I81.4: Please refer to Master Response 3: CEQA Piecemealing and Housing
Opportunity Sites, for a response regarding the proposed Project impacts related to the Housing Element
sites located on the southern golf course parcel.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-313
Final EIR
October 2025
Comment Letter I82: Benny Hallock (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-314
Final EIR
October 2025
Response to Comment Letter I82: Benny Hallock, June 24, 2025
Response to Comment I82.1: Please refer to Master Response 3: CEQA Piecemealing and Housing
Opportunity Sites, for a response regarding the proposed Project impacts related to the Housing Opportunity
sites located to the south of the proposed Project. The City of Costa Mesa was consulted regarding cumulative
impacts from the proposed Project, as detailed in the list of sources below Table 5-1, Cumulative Projects
List. As detailed in Master Response 4, Impacts Related to Vehicle Trips, the proposed Project would result in
a reduction in vehicular trips during the AM and PM peak hour and would not result in impacts related to
transportation, including streets within the City of Costa Mesa. Further, the City of Costa Mesa has reviewed
the Draft EIR and has no comments on the proposed Project, as shown in Comment Letter A1, herein. This
comment does not provide substantial evidence of a significant impact or other reason for EIR recirculation.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-315
Final EIR
October 2025
Comment Letter I83: Scott Wellwood (10 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-316
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-317
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-318
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-319
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-320
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-321
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-322
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-323
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-324
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-325
Final EIR
October 2025
Response to Comment Letter I83: Scott Wellwood, July 7, 2025
Response to Comment I83.1: Refer to Master Response 1, Project Merits. This comment is introductive in
nature and does not provide any substantial evidence that the Proposed Project would result in a new
significant environmental impact. Thus, no further response is warranted.
Response to Comment I83.1: This comment is a copy of the letter provided in Comment I54. Please see
responses to comments I54.3 to I54.20 for responses to this comment letter.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-326
Final EIR
October 2025
Comment Letter I84: Nick Shaffer (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-327
Final EIR
October 2025
Response to Comment Letter I84: Nick Shaffer, July 7, 2025
Response to Comment I84.1: The Draft EIR Section 5.5, Energy, details on page 5.5-10 that 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. As shown on Draft EIR Table 5.5-6, the Project would result
in a net increase of 9,559,556 kWh per year of electricity. Adherence to California Building Code and
Energy Code standards, which would be required by development permitting, would ensure that energy
efficient technologies and practices are used for the Project.
As detailed in Draft EIR Section 5.16, Utilities and Service Systems, page 5.16-27, the Project would connect
to the existing electricity powerlines within adjacent roadways. SCE prepared an Engineering Analysis
Report (included as Draft EIR 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. The Project would not require or result in the
construction of new facilities or the expansion of existing facilities, which could cause significant environmental
effects. Thus, the Draft EIR determined that impacts would be less than significant.
Response to Comment I84.2: The Draft EIR Section 5.11, Noise, details that the existing daytime ambient
noise in the Project vicinity ranges from 67.8 to 73.7 dBA, as listed in Draft EIR Table 5.11-4. Draft EIR page
5.11-4 states that the General Plan land use noise compatibility matrix (shown in Draft EIR Table 5.11-1)
identifies that commercial recreation is clearly compatible with noise of up to 65 dBA CNEL and normally
compatible with noise up to 75 dBA CNEL. As the ambient noise at the site ranges from 67.8 to 73.7 dBA, it
would be normally compatible with the proposed commercial recreation uses.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-328
Final EIR
October 2025
Comment Letter I85: Kyle Robar (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-329
Final EIR
October 2025
Response to Comment Letter I85: Kyle Robar, July 7, 2025
Response to Comment I85.1: Please refer to Master Response 4: Impacts Related to Vehicle Trips, for a
response to comments regarding the proposed Project’s traffic impacts.
Response to Comment I85.2: Please refer to Master Response 1: Project Merits for a response to comments
regarding the merits of the proposed Project.
Response to Comment I85.3: Please refer to Master Response 3: CEQA Piecemealing and Housing
Opportunity Sites, for a response regarding the proposed Project impacts related to the Housing Opportunity
sites located on the southern golf course parcel.
Response to Comment I85.4: In this case, the Project site is located adjacent to and outside of the Coastal
Zone boundary and does not require a Coastal Development Permit (CDP). As discussed on page 5.10-35
in Draft EIR Section 5.10, Land Use, and shown on Draft EIR Figure 3-7, Coastal Zone Boundary, the Project
site is adjacent to, but outside of, areas that are within the Coastal Zone. The proposed Project would include
offsite connections to the existing infrastructure within Mesa Drive and install new roadway striping within
Mesa Drive, within the coastal zone. However, the Coastal Land Use Plan Implementation Plan Section
21.52.035(C)(5) exempts the need for a CDP for utility connections and roadway striping. Thus, no permitting
from the Coastal Commission is required for the proposed Project.
Response to Comment I85.5:As discussed on page 5.9-14 within Draft EIR Section 5.9 Hydrology and Water
Quality and within the Hydrology Report included as Appendix P to the Draft EIR, While the proposed
Project includes an increase in impermeable surfaces compared to existing condition, the total 100 year, 24-
hour storm runoff volume would decrease by 11 percent as the proposed 5.06 acres surf lagoon would
capture rainfall and would not result in runoff. The drainage design would accommodate the proposed
Project within bioretention basins pursuant to the County DAMP and MS4 requirements that would be verified
during permitting of the proposed Project; and flooding from the Project would not occur.
Response to Comment I85.6: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-330
Final EIR
October 2025
Comment Letter I86: Wade Womack (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-331
Final EIR
October 2025
Response to Comment Letter I86: Wade Womack, July 7, 2025
Response to Comment I86.1: Please refer to Master Response 2: Loss of Existing Golf Course Use, for the
response to comments related to the change to the existing golf course use. Although Municipal Code Section
20.90.050 states that the District is intended to ensure the long-term use and viability of the golf course,
Draft EIR Section 5.10, Land Use and Planning, details that the permitted uses include other outdoor
commercial recreation and accessory structures, which is consistent with the proposed Project.
As detailed in Section 3.0, Project Description, on page 3-34, 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. Draft EIR Section 5.10, Land Use and Planning, details
that the Project would be consistent with the City General Plan and Santa Ana Specific Plan designated uses
for the Project site.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-332
Final EIR
October 2025
Comment Letter I87: Jim Mosher (4 pages)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-333
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-334
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-335
Final EIR
October 2025
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-336
Final EIR
October 2025
Response to Comment Letter I87: Jim Mosher, July 7, 2025
Response to Comment I87.1: Pursuant to CEQA Guidelines Section 15123 the EIR Section 1.0, Executive
Summary, includes a brief summary of the proposed actions in Section 1.2, Project Description Summary, and
its consequences in Section 1.6, Summary of Impacts, that lists each significant effect with mitigation measures,
as necessary. The alternatives are listed in Section 1.5, Summary of Alternatives, and the issues to be resolved
include the potential impacts that are listed in Table 1-1, Summary of Impacts. Areas of known controversy,
including issues raised by agencies and the public are listed in Table 2-1, Summary of NOP Comment Letters,
and Table 2-2, Summary of Scoping Meeting Comments, which are on pages 2-3 through 2-18. Table 1-1,
Summary of Impacts, lists the CEQA impact areas, the level of potential impacts from implementation of the
Project, and any mitigation measures that are required. The Draft EIR Table of Contents identifies that a
complete description of onsite biological resources and analysis of potential impacts (including those related
to bats) is provided in Section 5.3, Biological Resources, which begins on page 5.3-1, and within Appendix
C, Biological Technical Report. The CEQA Guidelines Section 15123 does not limit the length of the EIR
summary. The proposed Project Draft EIR includes detailed mitigation measures to ensure that potential
environmental impacts would be reduced to a less than significant level and details the Project Design
Features and applicable existing regulations that would reduce potential environmental impacts, which make
the summary longer, but provide clear detail of required measures.
Response to Comment I87.2: CEQA Guidelines Section 15141 does not limit the number of pages in an
EIR. As detailed in the comment the guideline states that “draft EIRs should normally be less than 150 pages
and for proposals of unusual scope or complexity should normally be less than 300 pages.” As Lead Agency,
the City of Newport Beach, determined that a complete analysis of all of the CEQA environmental topics
should be completed for the proposed Project and that multiple technical studies should be completed,
resulting in a document of more than 300 pages. The Draft EIR Table of Contents identifies the location of
environmental analysis, and Section 2.4, Organization of this Draft EIR, provides a brief summary of the
contents of each chapter.
Response to Comment I87.3: The Draft EIR evaluation of potential impacts to aesthetics is based on
Appendix G of the CEQA Guidelines and the City’s General Plan guidance regarding visual resources in the
City. Draft EIR page 5.1-8 describes that 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. Draft EIR Section 5.1, Aesthetics, pages 5.1-12 through 5.1-16 describes that 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 surf lagoon, amenity clubhouse,
athlete accommodations, parking lot, ornamental landscaping, and associated infrastructure. As detailed in
Draft EIR Section 3.0, Project Description, on page 3-23, the proposed Project would include approximately
143,844 SF of drought tolerant ornamental landscaping that would cover approximately 20 percent of the
site that 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 Project structures 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. As detailed in Draft EIR Section 5.1, Aesthetics, pages 5.1-12 through 5.1-16
the proposed Project would change views of the site to a more urban and developed character compared
to the existing condition. However, it would not conflict with applicable zoning and other regulations
governing scenic quality and pursuant to CEQA Guidelines criteria, impacts would be less than significant. It
is true that the aesthetics section of the Draft EIR is 34 pages; however, a complete analysis including six
visual simulations was prepared to show the change in views from each of the primary offsite view locations.
Response to Comment I87.4: The Draft EIR page 5.10-21 describes that the Santa Ana Heights Specific
Plan area was annexed to the City in two parts. There is no relevance to Project impacts whether the Project
site was annexed from the County in 2002 or 2008. The Santa Ana Heights Specific Plan is included in the
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-337
Final EIR
October 2025
City’s Municipal Code as Chapter 20.90 and is applicable to the proposed Project. As detailed on Draft EIR
page 3-35, 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. No amendments to the Santa Ana
Heights Specific Plan would be required; however, the Specific Plan requires a CUP to allow for the
construction of a building in excess of 18 feet in height, which would be reviewed and approved by the City
of Newport Beach, and no County approvals are required.
Response to Comment I87.5: The commenter compares the Project’s noise monitoring data in Appendix Q
of the Draft EIR to data collected by John Wayne Airport (JWA). While the hourly equivalent noise levels
(Leq) recorded for the Project closely match those from the JWA system, the comment notes some
discrepancies in maximum sound levels (Lmax) during specific time periods and suggests that this may indicate
incorrect meter settings as reported in the Project analysis.
The differences in reported Lmax between the two sound level meters (SLMs) are most likely attributable to
differences in exposure to the noise source, not incorrect meter settings. Due to access limitations on private
property, the SLM used for the Project’s environmental monitoring was placed at approximately 5 feet
above ground in publicly accessible areas, rather than at 20 feet above ground in a private backyard
setting. This placement can significantly influence Lmax measurements, as this metric is highly sensitive to the
exact timing and position of the noise source, atmospheric conditions, and the presence of reflections,
shielding, and terrain features.
In this case, the Project’s SLM was likely partially shielded from aircraft noise by nearby structures,
depending on the aircraft’s orientation relative to the meter. In contrast, the permanent monitoring equipment
used by John Wayne Airport is above ground and likely maintains a clear and consistent line of sight to
overhead aircraft, resulting in higher recorded Lmax values.
While the commenter suggests that meter settings may not match those described in the noise study prepared
for the Project, the strong consistency in Leq levels and the similar pattern of peaks and valleys in Lmax
levels between both datasets suggest that both meters captured the same events and were similarly
configured. Therefore, the observed Lmax differences are best explained by variations in location and
exposure, rather than inconsistencies in meter settings.
Importantly, Lmax was not used as a significance criterion in the CEQA noise impact analysis. The analysis
relies on hourly Leq for construction and stationary sources, and community noise level equivalent (CNEL) for
traffic noise and land use compatibility, in accordance with the City of Newport Beach’s Noise Element and
CEQA guidelines. Lmax is included only to help characterize the existing noise environment, not to determine
impact significance. As such, the Lmax discrepancies do not affect the conclusions of the analysis.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-338
Final EIR
October 2025
Comment Letter I88: Suzan Beck (1 page)
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-339
Final EIR
October 2025
Response to Comment Letter I88: Suzan Beck, July 8, 2025
Response to Comment I88.1: Please refer to Master Response 1: Project Merits, for the discussion of the
proposed Project’s fiscal impacts.
Snug Harbor Surf Park Project 2. Response to Comments
City of Newport Beach 2-340
Final EIR
October 2025
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Snug Harbor Surf Park Project 3. Revisions to the Draft EIR
City of Newport Beach 3-1
Final EIR
October 2025
3. Revisions to the Draft EIR
3.1 INTRODUCTION
As provided in Section 15088(c) of the CEQA Guidelines, responses to comments may take the form of a
revision to a Draft EIR or may be a separate section in the Final EIR. This section complies with the latter
option and provides changes to the Draft EIR shown as strikethrough text (e.g., strikethrough) to signify
deletions and double-underlined text (e.g., double-underlined) to signify additions. These changes are meant
to provide clarification, corrections, or minor revisions made to the Draft EIR initiated by the Lead Agency,
the City of Newport Beach, reviewing agencies, the public, and/or consultants based on their review. Text
changes are presented in the section and page order in which they appear in the Draft EIR. None of the
corrections or additions constitute significant new information or substantial project changes that, in
accordance with CEQA Guidelines Section 15088.5, would trigger the need to recirculate portions or all of
the Draft EIR.
3.2 CHANGES TO THE DRAFT ENVIRONMENTAL IMPACT REPORT
The following text, organized by Draft EIR Sections, has been revised in response to comments received on
the Draft EIR and corrections identified after the Public Draft EIR was released.
Section 2.0, Introduction
The paragraph on page 2-16, in Section 2.3.2, Public Scoping Meeting, is revised as follows:
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 Community Room in the Newport Beach Public
Library (Central Library Branch) at 1000 Avocado Avenue, Newport Beach, California 92660.
Section 3.0, Project Description
The last paragraph on page 3-35, in Section 3.11, Discretionary Actions Required, is revised as follows:
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.
Snug Harbor Surf Park Project 3. Revisions to the Draft EIR
City of Newport Beach 3-2
Final EIR
October 2025
• 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.
• County of Orange: The Project may require an encroachment permit from the County of Orange Public
Works Department for access or construction work within County owned easements and rights-of-way.
• Costa Mesa Sanitary District (CMSD): Issuance of permits for wastewater discharges into the sewer
system.
• Orange County Sanitation District: Issuance of Industrial Wastewater Discharge Permits for wastewater
discharges into Wastewater Treatment Plant No.1.
Section 5.1, Aesthetics
The first paragraph on page 5.1-12, in Section 5.1.6, Environmental Impacts, under Impact AES-3 is revised
as follows:
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 (220,427 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.
Section 5.3, Biological Resources
The second and third full paragraphs on page 5.3-20, in Section 5.3.6, Environmental Impacts, under
Impact BIO-1 is revised as follows:
According to the Biological Technical Report, western yellow bat has a low potential to roost in the limited
habitat for this species ornamental trees, including palms, on the Project site. The Biological Technical Report
(Draft EIR Appendix C) determined that due to the limited habitat for this species on the Project site, impacts
to habitat for the western yellow bat would be less than significant.
Further, tThe 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.
Although the Biological Technical Report (Draft EIR Appendix C) determined that impacts would be less than
significant Ggiven the limited roosting habitat for western yellow bat onsite, Mitigation Measure BIO-1 is
included as a precautionary measure to require a pre-construction nesting bat roost surveys including a
minimum of two emergent bat surveys to avoid injury to roosting bats and avoid maternity roosts until the
maternity roost is no longer in use. With implementation of Mitigation Measure BIO-1, impacts would be less
than significant.
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City of Newport Beach 3-3
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October 2025
Mitigation Measure BIO-1 in Section 5.3.11, Mitigation Measures, is revised as follows:
Mitigation Measure BIO-1: Pre-Construction Roosting Bat Surveys. 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 twoa pre-construction emergent bat roost surveys for roosting bats utilizing acoustic detection.
The first survey shall be conducted no more than 14 days prior to site disturbance, and the second survey
shall be conducted no more than three 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 the pre-construction survey determines that no active roosts are present, then trees/suitable habitat shall
be removed within three days following the pre-construction survey. All potential roost trees shall be removed
in a manner approved by a qualified bat biologist, which may include presence of a biological monitor.
If roosting bats are detected onsite outside of the bat maternity season (outside of March 1April 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 (March through August 31September 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 for roosts of special-status bat species, the buffer width
shall be 300 feet or as determined by the qualified biologist in consultation with California Department of
Fish and Wildlife (CDFW)) 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. All construction activity in the vicinity of an active roost shall be limited to
daylight hours. 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.
Section 5.9, Hydrology and Water Quality
The third paragraph on page 5.9-2 is revised as follows:
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.
The first two paragraphs on page 5.9-7 are revised as follows:
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
Snug Harbor Surf Park Project 3. Revisions to the Draft EIR
City of Newport Beach 3-4
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October 2025
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 sixth paragraph on page 5.9-7 is revised as follows:
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 first paragraph in Section 5.9.7, Cumulative Impacts, on page 5.9-18 is revised as follows:
Water Quality. The geographic scope for cumulative impacts related to hydrology and water quality
includes the Santa Ana San Diego Creek 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.
The second paragraph on page 5.9-14 is revised as follows:
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 surf lagoon, landscaping areas, and drainage bioretention systems Project would result in a large
increase in impermeable surfaces, the total 100-year, 24-hour storm volume would discharge to decrease
by approximately 11 percent.
Impact HYD-4 has been augmented to include the following additional analysis as the first full
paragraph on page 5.9-16:
The existing drainage flow which discharges to a storm drain lateral on the north of the Santa Ana Delhi
Channel, would be modified to be redirected to the existing lateral on the south, which would result in an
increase of 2.5 cubic feet per second (cfs) within a 400-foot reach of the Santa Ana – Delhi Channel in a
100-year storm flow condition, which is less than 0.03 percent. The existing flowrate of 8,550 cfs would
become 8,553 cfs for the reach between 44+85 to 48+95, which would increase the depth of flows by
0.01 feet for this 400-foot reach of channel during a 100-year storm flow condition, which is determined by
the Hydrology Report to be a negligible increase. After the 400-foot channel reach, the overall runoff would
be reduced compared to existing conditions. The discharge amounts at each of the channel stations have
been evaluated and are listed in Table 5.9-3.
Table 5.9-3: Santa Ana – Delhi Channel Station 100-Year Storm Flow Rate Comparison (CFS)
Station Upstream Station Middle Station Downstream Station
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City of Newport Beach 3-5
Final EIR
October 2025
48+95 & 49+00 44+85 40+79
Existing 30.9 11.1 19.8
Proposed 33.4 3.8 19.2
Difference +2.5 -7.3 -0.62
Source: Final EIR Appendix B, Revised Preliminary Hydrology Report
Section 5.16, Utilities and Service Systems
The first paragraph on page 5.16-14, in Section 5.16.3.4, Wastewater Environmental Impacts, is revised as
follows:
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 63,759 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.
The last paragraph on page 5.16-14, in Section 5.16.3.4, Wastewater Environmental Impacts, is revised as
follows:
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. Also, due to the volume of wastewater that
would be discharged during draining of the surf basins, an Orange County Sanitation District Industrial
Wastewater Discharge Permit would be required, as is required for any discharge in excess of 25,000
gallons per day. The Industrial Wastewater Discharge Permit regulates wastewater discharges by limiting
specific pollutants through establishing numeric discharge standards, discharge requirements, monitoring and
reporting requirements. Thus, permits from both CMSD and the Orange County Sanitation District would be
required for draining the surf basins.
The first paragraph in Impact UTIL-4 on page 5.16-16, in Section 5.16.3.4, Wastewater Environmental
Impacts, is revised as follows:
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 63,759 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
63,759 gpd of wastewater. Daily operation of the proposed Project would utilize less than 0.01 percent of
the daily available treatment capacity.
Section 8.0, Alternatives
Page 8-21, in Section 8.8.2, Conclusion, is revised as follows:
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
Snug Harbor Surf Park Project 3. Revisions to the Draft EIR
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October 2025
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.
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).
Section 9.0, EIR Preparers and Persons Contacted
Page 9-2, Persons Contacted, is revised as follows:
PERSONS CONTACTED
Newport Beach Police Department – Chief Dave Miner
Newport Beach Fire Department – Chief Jeff Boyles
City of Irvine Community Development Department – Justin Equina, Senior Planner
City of Costa Mesa Economic Development and Services Department – Michelle Halligan, Senior Planner
Snug Harbor Surf Park Project 4. Mitigation Monitoring and Reporting Program
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October 2025
4. Mitigation Monitoring and Reporting Summary
4.1 INTRODUCTION
The California Environmental Quality Act (CEQA) requires a lead or public agency that approves or carries
out a project for which an Environmental Impact Report (EIR) has been certified, which identifies one or more
significant adverse environmental effects and where findings with respect to changes or alterations in the
project have been made, to adopt a “…reporting or monitoring program for the changes to the project
which it has adopted or made a condition of project approval in order to mitigate or avoid significant effects
on the environment” (CEQA, Public Resources Code Sections 21081, 21081.6).
A Mitigation Monitoring and Reporting Program (MMRP) is required to ensure that adopted mitigation
measures are successfully implemented. The City of Newport Beach is the Lead Agency for the Project and
is responsible for implementation of the MMRP. This report describes the MMRP for the Project and identifies
the parties that will be responsible for monitoring implementation of the individual mitigation measures in
the MMRP.
4.2 MITIGATION MONITORING AND REPORTING PROGRAM
The MMRP for the Project will be active through all phases of the Project, including design, construction, and
operation. The attached table identifies the mitigation program required to be implemented by the City for
the Project. The table identifies mitigation measures required by the City to mitigate or avoid significant
impacts associated with the implementation of the Project, the timing of implementation, and the responsible
party or parties for monitoring compliance.
The MMRP also includes a column that will be used by the compliance monitor (individual responsible for
monitoring compliance) to document when implementation of the measure is completed. As individual Plans,
Programs, and Policies (PPPs), Project Design Features (PDFs), and mitigation measures are completed, the
compliance monitor will sign and date the MMRP, indicating that the required actions have been completed.
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Table 4-1: Mitigation Monitoring and Reporting Program
Plan, Program, or Policy (PPP), Project Design
Feature (PDF), or Mitigation Measure Implementation Timing Responsible Party Verification Method Date Completed
and Initials
BIOLOGICAL RESOURCES
Mitigation Measure BIO-1: Pre-Construction
Roosting Bat Surveys. 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 two pre-construction emergent bat
surveys utilizing acoustic detection. The first survey
shall be conducted no more than 14 days prior to site
disturbance, and the second survey shall be conducted
no more than three days prior to site disturbance. The
emergent surveys shall begin 30 minutes before dusk
and extend to one hour after dark.
If the pre-construction survey determines that no active
roosts are present, then trees/suitable habitat shall be
removed within three days following the pre-
construction survey. All potential roost trees shall be
removed in a manner approved by a qualified bat
biologist, which may include presence of a biological
monitor.
If roosting bats are detected onsite outside of the bat
maternity season (outside of March 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 (March 1 through August 31), the
Project shall avoid the subject roost(s) and incorporate
In Project plans and
construction permitting.
Prior to ground
disturbing activity.
City of Newport Beach
Community Development
Department
Project plans and
construction permits
shall include that
roosting bat survey be
completed as specified.
If roosting bats are
encountered, a
biological monitoring
report shall be
submitted to the City of
Newport Beach
Planning Division and
coordination with the
California Department
of Fish and Wildlife
(CDFW) if special status
species are identified.
Initials: ______
Date: ______
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Plan, Program, or Policy (PPP), Project Design
Feature (PDF), or Mitigation Measure Implementation Timing Responsible Party Verification Method Date Completed
and Initials
an avoidance buffer (300 feet or as determined by
the qualified biologist for roosts of special-status bat
species, the buffer width shall be 300 feet or as
determined by the qualified biologist in consultation
with CDFW) 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. All construction activity in the
vicinity of an active roost shall be limited to daylight
hours. 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
Prior to issuance of
grading permits.
City of Newport Beach
Community Development
Department
Verify that nesting bird
survey has been
completed as specified.
If nests are
encountered, monitoring
report shall be
submitted to the City of
Newport Beach
Planning Division.
Initials: ______
Date: ______
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and Initials
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.
CULTURAL RESOURCES
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.
If human remains are
found during subsurface
excavation.
Archaeological and
Tribal Monitors, City of
Newport Beach
Community Development
Department
Confirmation of coroner
and NAHC contact and
submittal of Report of
Findings, if applicable.
Initials: ______
Date: ______
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
Prior to the issuance of
grading permits.
During construction.
City of Newport Beach
Community Development
Department
Verify that
archaeologist has been
retained and contracted
for specified work.
Verify that Native
American tribal
agreement has been
signed.
Submittal of Report of
Findings.
Initials: ______
Date: ______
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Plan, Program, or Policy (PPP), Project Design
Feature (PDF), or Mitigation Measure Implementation Timing Responsible Party Verification Method Date Completed
and Initials
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.
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).
Prior to issuance of
certificate of occupancy.
City of Newport Beach
Community Development
Department
Submittal of Monitoring
Report to the City of
Newport Beach
Planning Division and
Consulting Tribe(s).
Initials: ______
Date: ______
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.
Shown on building plans.
Prior to certificates of
occupancy, as
applicable.
Project Applicant
Initials: ______
Date: ______
GEOLOGY AND SOILS
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
Prior to issuance of
grading and building
permits.
City of Newport Beach
Community Development
Department
Compliance with Project
Conditions of Approval
Initials: ______
Date: ______
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and Initials
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: 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.
Prior to issuance of a
demolition or grading
permits.
City of Newport Beach
Community Development
Department
Compliance with Project
Conditions of Approval
Initials: ______
Date: ______
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.
Prior to issuance of a
grading permit.
City of Newport Beach
Community Development
Department
Compliance with Project
Conditions of Approval
Initials: ______
Date: ______
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
Prior to the issuance of
grading permits.
During subsurface
excavation.
City of Newport Beach
Community Development
Department
Verify that PRIMMP has
been prepared and
implemented.
Initials: ______
Date: ______
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and Initials
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.
GREENHOUSE GAS EMISSIONS
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.
Shown on building plans.
Prior to certificates of
occupancy, as
applicable.
Project Applicant
Initials: ______
Date: ______
HAZARDS AND HAZARDOUS MATERIALS
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and Initials
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.
Shown on building plans.
Prior to certificates of
occupancy, as
applicable.
Project Applicant
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.
Prior to issuance of
demolition permits.
City of Newport Beach
Community Development
Department
Compliance with Project
Conditions of Approval
Initials: ______
Date: ______
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.
Prior to issuance of
demolition permits.
City of Newport Beach
Community Development
Department
Compliance with Project
Conditions of Approval
Initials: ______
Date: ______
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
Prior to issuance of a
demolition or grading
permits.
City of Newport Beach
Community Development
Department
Compliance with Project
Conditions of Approval
Initials: ______
Date: ______
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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-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.
Prior to issuance of a
grading permit.
City of Newport Beach
Community Development
Department
Compliance with Project
Conditions of Approval
Initials: ______
Date: ______
HYDROLOGY AND WATER QUALITY
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.
Prior to issuance of a
demolition or grading
permits.
City of Newport Beach
Community Development
Department
Compliance with Project
Conditions of Approval
Initials: ______
Date: ______
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
Prior to issuance of a
grading permit.
City of Newport Beach
Community Development
Department
Compliance with Project
Conditions of Approval
Initials: ______
Date: ______
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Feature (PDF), or Mitigation Measure Implementation Timing Responsible Party Verification Method Date Completed
and Initials
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.
Prior to issuance of a
grading permit.
City of Newport Beach
Community Development
Department
Compliance with Project
Conditions of Approval
Initials: ______
Date: ______
TRIBAL CULTURAL RESOURCES
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
If human remains are
found during subsurface
excavation.
City of Newport Beach
Community Development
Department
Compliance with Project
Conditions of Approval
Initials: ______
Date: ______
Snug Harbor Surf Park Project 4. Mitigation Monitoring and Reporting Program
City of Newport Beach 4-12
Final EIR
October 2025
Plan, Program, or Policy (PPP), Project Design
Feature (PDF), or Mitigation Measure Implementation Timing Responsible Party Verification Method Date Completed
and Initials
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.
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
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
Prior to issuance of
permits associated with
ground-disturbing
activities.
Monitoring during
ground-disturbing
activities.
City of Newport Beach
Community Development
Department
Compliance with Project
Conditions of Approval
Initials: ______
Date: ______
Snug Harbor Surf Park Project 4. Mitigation Monitoring and Reporting Program
City of Newport Beach 4-13
Final EIR
October 2025
Plan, Program, or Policy (PPP), Project Design
Feature (PDF), or Mitigation Measure Implementation Timing Responsible Party Verification Method Date Completed
and Initials
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) 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.
Snug Harbor Surf Park Project 4. Mitigation Monitoring and Reporting Program
City of Newport Beach 4-14
Final EIR
October 2025
Plan, Program, or Policy (PPP), Project Design
Feature (PDF), or Mitigation Measure Implementation Timing Responsible Party Verification Method Date Completed
and Initials
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.
During ground disturbing
activities.
City of Newport Beach
Community Development
Department
Compliance with Project
Conditions of Approval
Initials: ______
Date: ______
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.
In construction plans and
specifications.
During all ground
disturbing activities.
City of Newport Beach
Community Development
Department
Compliance with Project
Conditions of Approval
Initials: ______
Date: ______
Snug Harbor Surf Park Project 4. Mitigation Monitoring and Reporting Program
City of Newport Beach 4-15
Final EIR
October 2025
Plan, Program, or Policy (PPP), Project Design
Feature (PDF), or Mitigation Measure Implementation Timing Responsible Party Verification Method Date Completed
and Initials
E. Any discovery of human remains/burial goods
shall be kept confidential to prevent further
disturbance.
Snug Harbor Surf Park Project 4. Mitigation Monitoring and Reporting Program
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October 2025
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