To:

The City of Huntington Beach

City Council, Planning Commission, and City Attorney

Regarding:

Conditional Use Permit No. 22-011 / Coastal Development Permit No. 22-009

Huntington Club – Bungalows & Lofts (Agenda Item 26-039)

We, the undersigned residents and stakeholders of the City of Huntington Beach, respectfully petition the City to deny or require further lawful review of the proposed Huntington Club Bungalows & Lofts project, as currently proposed, based on the following concerns:

1. Improper Use of a Conditional Use Permit (CUP)

The project proposes four bungalows and two loft units intended for overnight stays of less than 30 days. This constitutes a lodging or quasi-hotel use, which is not a conditionally permitted use within the Open Space–Recreation (OS-PR) zoning district.

A Conditional Use Permit may not lawfully be used to authorize a new or intensified land use that exceeds the zoning code. Approval of paid overnight lodging through a CUP would exceed the City’s administrative authority.

2. CEQA Class 32 Exemption Is Legally Inapplicable

The City’s reliance on a Class 32 (In-Fill) CEQA exemption is inappropriate because:

The addition of overnight lodging materially intensifies the use of the property
The removal of four tennis courts alters the functional character of the site
Proximity to residential uses creates potential environmental impacts
The project may involve unusual circumstances under CEQA Guidelines §15300.2

CEQA requires evaluation of the whole of the action, based on how the project will actually operate, not how it is characterized.

3. Unequal Treatment Under Local Short-Term Rental Law

Huntington Beach Municipal Code §5.120 prohibits residents from renting homes for periods of less than 30 days, except under narrow, express authorization.

Allowing a private landowner or club to operate paid overnight accommodations under a CUP—while residents are prohibited from similar activity—creates unequal treatment under the law and undermines consistent enforcement of municipal regulations.

4. Risk of Ultra Vires Approval

If the bungalows and lofts are constructed and monetized as paid overnight accommodations, approval through a CUP would constitute an ultra vires act—an action taken beyond the City’s legal authority—exposing the City to legal and CEQA challenge.

PETITION REQUEST

We respectfully request that the City of Huntington Beach:

Deny the current CUP and CEQA exemption for the bungalows and lofts; or
Require the applicant to pursue the appropriate zoning amendment or legislative entitlement; and
Ensure any future consideration complies fully with CEQA, zoning law, and equal treatment principles.

This petition is submitted to preserve the integrity of the City’s land use process, protect lawful zoning authority, and ensure fair and consistent application of municipal law.