Summary
The proposed project is for a CDP that would fill an existing notch in a coastal bluff with an erodible concrete mixture colored and sculpted to resemble the natural bluff. The notch is located on a city-owned beach fronting two existing single family residences in the City of Solana Beach. The two bluff-top residences are at not at risk from bluff collapse at this time. In numerous past actions, the Commission has found that the filling of sea caves or notch overhangs as a preemptive measure has fewer impacts upon coastal resources and public access than the construction of seawalls and upper bluff structures. The City’s certified Land Use Plan (LUP) allows for pre-emptive construction of erodible concrete sea cave/notch infills, even when a bluff top structure is not imminently threatened.
Surfrider Foundation objected that erodible concrete does erode at the same rate as the surrounding natural bluffs and thus constitutes a seawall, which is not a permitted use as a preemptive measure. The staff report concedes that historically, erodible concrete has not eroded at the same rate as the bluffs. Non-erodible concrete is not permitted to be installed preemptively and has many of the same adverse impacts as seawalls and would likely require mitigation for impacts to sand supply and public access and recreation. Therefore, the LUP does not allow for pre-emptive infill unless there is evidence that the infill will erode at the same rate as the bluff. Surfrider contested that this technology cannot be utilized with robust data proving its erodibility.
After much discussion, Commissioners agreed and voted to deny the proposed erodible concrete seawall.
Why You Should Care
This permit would perpetuate a type of coastal armoring that has not been proven to erode as claimed by the applicant. The CDP proposes testing the supposed “erodible concrete” after installation, without proper assurances for the public, and would allow a seawall where one would not otherwise be allowed if it does not erode as claimed and would lead to beach erosion.
Outcome
Pro-Coast Vote
Anti-Coast Vote
Commissioners engaged in a substantial discussion about this item and the concept of erodible concrete. The applicant proposed their project as an ultimatum – either permit this erodible concrete seawall or see the bluff collapse and have to permit a larger, permanent seawall. Many Commissioners did not see it as so black and white.
Commissioner Sara Aminzadeh pointed out that despite the applicant’s claims that this is not a preventative measure, we won’t be able to avoid the ultimate harm of sea level rise. If erodible concrete does not erode it becomes a seawall, if it does, the home will eventually be threatened.
Commissioner Donne Brownsey admitted that the proposal is not a perfect solution and then motioned to approve staff’s recommendation and conditions. Commissioner Steve Padilla seconded the motion. Commissioner Aaron Peskin turned the tide by stating that he would vote against this motion, stating, “What we’re doing here is furthering this opportunity to move toward shoreline armoring and more obtrusive shoreline armoring.” Commissioner Mary Luevano also astutely noted that we don’t have much time to adapt to sea level rise.
Commissioners voted to deny the proposed development.
Organizations Opposed
Surfrider Foundation
Decision Type
CDP
Staff Recommendation
Approval with Conditions