Unplanned Beach Retreat - The Coastal Act and seawalls

The CCC annd authorized Local Coastal Plans should not permit seawall construction on an eroding coastline when it would threaten recreational access to the beach protected by Coastal Act Sections on Public Access 30210-30214 and Recreation, Sections 30220-30222 .

• Seawalls should not be approved on eroding coastlines unless it is clear that there is a viable mitigation plan.
• Seawalls fix the the back boundary of the beach. So long as the shoreline is experiencing a net retreat, a net sea level rise, or natural seacliff retreat, the width of the beach will decrease with the construction of a protective structure.
• Without mitigation that can be performed we have a de facto Unplanned Beach Retreat Policy - our beaches will shrink between wall and water.
• The Coastal Act provides several guiding and potentially conflicting principles on how to deal with this complex issue making regulation difficult. We want to address this conflict.
• 30007.5 states that when "...conflicts be resolved in a manner which on balance is the most protective of significant coastal resources."
• 30235 requires approval of seawalls "..to protect existing structures or public beaches in danger from erosion and when designed to eliminate or mitigate adverse impacts on local shoreline sand supply.
• Section 30604(c) requires that every coastal development permit (including for seawalls) issued for any development between the nearest public road and the sea include a specific finding that the development is in conformity with the public access and public recreation policies of [Coastal Act] Chapter 3.
• Coastal Act Sections 30210 through 30213, as well as Sections 30220 and 30221 specifically protect public access and recreation.
• Section 30210: references Section 4 of Article X of the California Constitution
• Section 30211: requires that "Development shall not interfere with the public's right of access to the sea..."
• Section 30212(a): Public access from the nearest public roadway to the shoreline and along the coast shall be provided in new development projects�
• Section 30213: Lower cost visitor and recreational facilities shall be protected, encouraged, and, where feasible, provided. Developments providing public recreational opportunities are preferred.
• Section 30220: Coastal areas suited for water-oriented recreational activities that cannot readily be provided at inland water areas shall be protected for such uses.
• Section 30221: Oceanfront land suitable for recreational use shall be protected for recreational use and development unless present and foreseeable future demand for public or commercial recreational activities that could be accommodated on the property is already adequately provided for in the area.
• The cumulative effects of seawalls on shoreline access along with the present approval policy and rate of seawall construction and approval makes the governing policies of maintaining access along the coast impossible to enforce
• We must use the Coastal Act policies to balance in favor of the environment per Section 30007.5, and per Section 4 of Article X of the California Constitution that "...give the most liberal construction to this provision, so that access to the navigable waters of this State shall be always attainable for the people thereof."

The importance of coastal bluffs in supplying San Diego area beaches with sand

Figure 10. Estimated percentage of beach-sediment contributions to the Oceanside Littoral Cell for the study area between April 1998 and April 2004 (a statistically dry period). (from Adam P. Young, Scott A. Ashford (2006) Application of Airborne LIDAR for Seacliff Volumetric Change and Beach-Sediment Budget Contributions. Journal of Coastal Research: Vol. 22, No. 2, pp. 307-318.)

I've been thinking a bunch about this topic over the past few weeks as a long string of larger than normal surf have coincided with some very high tides. Easily every beach I've seen in the past two weeks has shown signs of erosion. Also see Andrea's posts below which do a great job of documenting the problems in Oceanside. The addition of the heavy rains have complicated things even more, and where they are not restrained by seawalls, beach cliff erosion is very active. If you've been down the paved trail to Black's Beach, you can see this pretty clearly.

In 2005, UCSD grad student Adam Young and his advisor Scott Ashford published "Application of Airborne LIDAR for Seacliff Volumetric Change and Beach-Sediment Budget Contributions" in Journal of Coastal Research. The important result from this work is summed up in the figure above. Classical thinking had been that rivers provided up to 90% of beach sand in the Oceanside littoral cell. Young and Ashford's work found that seacliff (or bluff) erosion contributed 67% to beach sediment in the Oceanside cell.

The reception of this work was varied. Many who fight against seawalls, saw this as a concrete (pun intended) example of the detrimental effects of seawalls, which are blocking sediment into our littoral cells. Obviously, the seawall advocates were not so pleased and many were quick to dismiss the work.

"We think it's pure hogwash," countered Paul Santina, president of the Beach and Bluff Conservancy. (from Study: Bluffs contribute most of the sand on local beaches, By: Paul Sisson North County Times, Oct 16, 2005)

Most of the scientific criticism about Young and Ashford's study was based on the short period of time that their analysis included. They looked at a six year period of time, which also was during a dry period. Six years in the geological sense is short, but their methods are accepted as valid by many in the coastal research community.

To help put this academic research into a real life example, head down to Black's Beach or any of the beaches in front of non-armored bluffs. You're likely to see patches of large amount of sediment eroding off the bluffs (bluff failures), which will soon make it's way into our littoral cell.

Here are some additional links regarding Adam Young's work:

• "Application of Airborne LIDAR for Seacliff Volumetric Change and Beach-Sediment Budget Contributions"(JCR paper)


• Coastal bluffs provide more sand to California beaches than previously believed (UCSD press release)


• Coastal Bluffs Provide More Sand To California Beaches Than Previously Believed (Science Daily)

Beaches in Oceanside in Trouble

Just to give you an idea of how windy it was at the beach during Tuesday's storm. Storms expected Wednesday, Thursday, and Friday should have more wind and rain.

A combination of wave action and sand erosion is creating havoc on the beach. Fire pits along the beach are breaking apart and washing away. Crews that come to clean up the beach after storms have not moved these items. They must be waiting for the fire pits to just wash away.


Playground at the pier has become a hazard for children as sand is washed away from concrete. Again, crews that were at the beach cleaning up after the storm did nothing about the hazard- no warning signs posted, no shoveling of sand back in the area, and the playground is not closed. Click on images to enlarge.



Perhaps when the road gets covered with so much sand after every storm, the problem is not sand on the road, but the road built on the beach. With the added surge from the wind and swell, waves even at lower tides wash up and over the road, leaving sand and seaweed in the road. This morning, crews were out scraping the sand off the road and putting back on the beach. The trouble is that the heavy machinery damage the road and curbs. All along the strand, the worst erosion of sand is in areas where the curb is missing. It doesn't seem that the clean up effort is helping the life span of the road, or the homes. The problem is that the road and the homes are ON THE BEACH. Moving around the sand does not change that fact.


The other reason that developing west of the bluff is a bad idea- bluff erosion. A natural process that creates beaches and happens every time it rains. Most of the homes are protected by retaining walls to prevent mudslides like this (that concrete curb surrounds a concrete platform now covered by mud). A few more inches of rain in the next 3 days ought to soak the bluffs even more.

Wether it was a good idea 50 years ago to build in this area, it is no longer a good idea. The road was taken out and homes destroyed in 1980 because of a storm. Nothing has been done to remedy the problems pointed out to the city in studies done after that failure except some beach fills. It is sad that the city was not able to learn from the last catastrophe and address the issues of the dynamic coastline and development on the beach and has allowed more development along the Strand without repairing the road or rip-rap, or even having a plan to do so. It seems like the city is acting foolishly by just ignoring the problem and hoping it won't happen again. Well, look out, because we are in the midst of the biggest storm in decades.

Oceanside Failure of the Strand 1980

For those of you who would like to do a little more reading about the last time the Strand failed in Oceanside in 1980 after a storm event that never produced waves over 6 feet, look here. For those of you that might like to watch the next failure, head down to the Strand on Weds, Jan 20, 2010. NOAA is predicting the largest wind, rain, and tidal surge event in decades. I will post photos from my morning walks.

Was there erosion first or development first?

Institutional memory is a wonderful tool. If we forget our history we are doomed to repeat its mistakes and will not learn from them. The picture above shows the condominiums at the southern end of Solana Beach around the time of its construction in 1974. Note the bluff is already eroding and the bluffs were eroding during construction. You can learn more about this by reading:

Kuhn, Gerald G., and Francis P. Shepard, "Sea Cliffs, Beaches, and Coastal Valleys of San Diego County: Some Amazing Histories and Some Horrifying Implications". Berkeley: University of California Press, c1984. The picture above and many others are from that text. It is available online at http://ark.cdlib.org/ark:/13030/ft0h4nb01z/. The picture is on page 73.

One of the key elements of our campaign is to show the public and the policymakers that the baseline condition of our coast is a naturally eroding condition impacted by complex factors including the geology of the coast, sea level rise, wave energy and the presence of sand. In the above example, the bluff material is extremely susceptible to erosion since it is composed of sediment that was carried to the coast via an ancient river. Between 1971 and 1978 the area experienced 10 feet of erosion according to Kuhn and Shepard. No El Nino or lack of sand caused this erosion. It was simply the lack of due diligence by the developer in building in this location.

Unfortunately, a seawall now exists at the subject site. It was built immediately after the development was completed at this location. The seawall collapsed soon after it was built (above) and was rebuilt at the same site(below). It still exists today.

How much wider would the beach have been had this wall never been built given that the bluff eroded 10 feet in 7 years? In this case, we will never know, but we do know that lack of sand and El Nino storms did not cause this seawall to be needed thanks to the work of Kuhn and Shepard.

January 2010 at the Coastal Commission

Today at the Coastal Commission Hearing two big things happened:

1. A mitigation fee was imposed for a seawall at the Li residence in Encinitas to mitigate the loss of recreational beach. The fee will be charged for the area of land occupied by the seawall and the future loss of beach caused by the seawall fixing the back of the beach. You can read the staff report for this project at this link. Since 2001 I have been working tirelessly to make the loss of recreational beach part of the mitigation fees. The fact that are charging mitigation fees for the occupation of beach space and limiting the permit to 20years is related to work I started at that time. Please see this presentation and paper for a 2001 presentation I gave at RESTORING THE BEACH - Science, Policy and FundingCalifornia Shore and Beach Preservation Association (CSBPA)and California Coastal Coalition (CalCoast) Joint Conference with local sponsorSan Diego Association of Governments (SANDAG)
   San Diego, CA November 8-10, 2001. I have given additional papers in similar conferences since that time and also commented on numerous permits to have this mitigation included. The first such mitigation in San Diego was for the Las Brisas project. You can read that Staff Report here.
2. A resolution to support world designation of surfing reserves. You can read the staff report and resolution here. Why is this important - Surf breaks have not been studied for environmental impacts in most sand replenishment or seawall projects and definitely not in Army Corps projects. This is a huge move in the right direction.

Here is the letter I sent CCC staff (Gary Cannon) with respect to the Li project above:

Dear Gary,

As a followup to our phone conversation, I would like to go on record as an
advisor to the San Diego County chapter of the Surfrider Foundation and as VP of
CalBeach Advocates, that we object to the issuance of a permit for a new seawall
or for an after the fact approval of the existing seawall for the following
agenda item to be heard on Friday:

Application No. 6-07-133 (Li, Encinitas) Application of Bernard Li to remove 6
ft. of concrete footing from seaward side of unpermitted seawall, construct 10
ft. high addition to unpermitted seawall, install 35 ft. high tied-back concrete
columns between existing ones and add 1.5 ft. thick colored and textured facing
over seawall, on public beach below 680 Neptune Avenue, Encinitas, San Diego
County. (GDC-SD)

At p13 of the staff report it states:

"When the residential duplex at the top of the bluff was constructed in
approximately 1975, the property owner submitted documentation certifying that
the residence would not be threatened by erosion if sited 25 feet inland of the
bluff edge. "

Coastal Act requires that "New Development" per 30253..."(b) Assure stability
and structural integrity, and neither create nor contribute significantly to
erosion, geologic instability, or destruction of the site or surrounding area or
in any way require the construction of protective devices that would
substantially alter natural landforms along bluffs and cliffs... "

We strongly believe the applicant was required to provide the 1975 documentation
certifying no threat from erosion in order to comply with 30253. Is there
institutional memory for this? Or because they put in an un-permitted wall,
will they get a free pass on complying with 30253?

At the October 2009 Coastal Commission Hearing, in the following matter,

Permit No. A-3-CAP-99-023-A1 (Swan and Green Valley Corporation, Capitola).
Request by Richard and Nancy Swan and the Green Valley Corporation to amend
permit to eliminate the existing condition prohibiting future shoreline armoring
(that applies to the Green Valley Corporation property) and to construct
approximately 115-ft. section of contoured concrete seawall fronting that Green
Valley Corporation property and adjacent to existing seawall on adjacent
property (on Swan property) on beach and bluffs fronting 4840 and 4850 Cliff
Drive in Capitola, Santa Cruz County. (SC-SC)

In the above matter, the Commission took a strong position that development
completed under a Coastal Development Permit that should not require shoreline
protection must not subsequently get that shoreline protection. We strongly
believe the principal structure in the Li residence is not entitled to
protection and urge denial of the permit and an enforcement action to remove the
unpermitted seawall and relocate threatened areas of the principal structure.

If the Commission makes findings that the principal structure is threatened and
is entitled to shoreline protection, which we are on record as strongly
objecting to, we agree with the staff's proposed mitigation fees based on
property values. This fee is meant to mitigate for the impact of placement loss,
fixing the beach and the associated loss of beach area and recreation. We feel
this fee will mitigate the impacts in the immediate area but will underestimate
the complete impact in that this seawall will eventually block lateral access to
the beach and impact up and downcoast beach access. We hope mitigation for this
impact may be added to the fee in some way.

As it is not likely we will be able to appear at the hearing we hope that you
can summarize our concerns to the Commission and place this on the record for
their review.

Best regards,

Jim Jaffee
VP CalBeach Advocates
Advisor to the San Diego County Chapter of the Surfrider Foundation

More Trouble in Oceanside

I went on a walk with my camera again. These new photos are only 3 weeks after the first set of photos from my last blog. Frank Quan said that the seawall goes down 30 feet. See in the first two photos that a cave is forming behind the seawall right where it last failed. The horizontal bit of cement you see in the top portion of this photo is the bottom of the road.

The last photo shows the now complete loss of sand from last summer's dredge and beach fill, which was level with the street. Also you can see a hole forming in the seawall. The wall is only as thick as my hand. This hole goes from the tip of my fingers to my knuckles, leaving only 2 inches until it really is a hole. Judging by the previous photos, when that happens, a cave will form behind the wall.

Oceanside does not have a plan in place to address the eroding and dynamic coastline. It is obvious that the rip-rap is no longer doing its job, the initial repair of the failed road is failing, and the seawall is being damaged by the surf. Oceanside's big hope lies in a SANDAG study that is being done that will determine an extensive $50 million sand replenishment project to start in about a year and a half. Until then, they will fill the beach with sand from the dredge the Army Corps of Engineers does every year on the harbor mouth.

I think Oceanside needs some science behind the next beach fill. It seems that just dumping dredged sand on the beach does not help preserve the beach. In fact, without science, how do we know that the problems facing the Strand were not made WORSE by the fill? I also think planned retreat is something that Oceanside needs to start discussing. The homes west of the bluff from Tyson to Wisconsin are on the beach, and soon new measures will need to be enacted to "save" them from the encroaching tide.