To manage cumulative impacts more effectively, the Commission needs to be able to manage information more effectively than it has to date. Analysts reviewing projects under tight time requirements need to have quick and easy access to information about coastal resources and about other projects that have been proposed or already approved nearby. This capability does not currently exist, although the Commission is moving rapidly in the right direction, in part due to the efforts of ReCAP. Experience gained by ReCAP in its pilot cumulative analysis project has already been used to guide agency-wide investments in new technology, revise the basic permit application form, and develop new information management tools such as resource and permit tracking databases. The Commission should continue to distribute these new tools to its district offices, develop additional information management capabilities -- including links to the databases of local governments and other resource agencies, and eventually build its own Geographic Information System (GIS). The goal would be to make "big-picture", contextual information available to permit analysts as they review individual permits so that each project could be reviewed in light of its contribution to cumulative impacts on coastal resources.
Currently, much of the information about resources used by Commission analysts comes in bits and pieces from permit applications, the "institutional memory" of staff members, or contacts with outside experts. As a result, knowledge about the status of resources is patchy, with recent data only in areas that have recently seen permit activity. Moreover, once applications have been reviewed, the resource information available in them is usually filed away with the permit, where the information is essentially lost from the system. If that information were entered into a database, it could be used to help track resource trends and provide context for future permit decisions.
Better information management and a better information base would do more than just aid the Commission's permit review functions. They would also enable the Commission and its resource management partners to plan for and manage coastal resources more pro-actively, as envisioned by the Coastal Act and as suggested throughout this report. Without a complete picture of what is happening to the resources, the Commission too often finds itself in a position of reacting to the development proposals of applicants or the management initiatives of other agencies rather than advancing its own management objectives. With a better information base, the Commission could begin implementing better strategies for managing cumulative impacts, including helping local governments keep their LCPs up-to-date, and could play a bigger role in guiding the development of regional resource management plans, regardless of who initiates them. Instead of relying solely on permit applicants and other agencies to provide information about coastal resources, the Commission could track resource trends itself and assist local governments in developing pro-active programs to prevent and reverse resource degradation.
Management of information across agencies in the region also needs to be improved. Incompatible computer systems and database structures, along with data ownership issues, hamper data exchange. Regional information management initiatives are beginning to address the problem. The Commission should continue to support and, where necessary, initiate efforts to facilitate greater sharing of resource and regulatory information. This would help prevent duplication of effort in gathering data and assure that all agencies are able to consider regional and cumulative perspectives in their work.
Each agency in the ReCAP region collects information critical to its own mission. State Parks collects visitor use information, County Assessors collect land use and property value information, and the Commission and local governments collect information on development proposals and the resources they impact.
Once collected, the information is stored either within hard-copy documents -- for example, technical reports, management plans, and Environmental Impact Reports (EIRs) -- or, to a growing extent, in electronic form in computer databases and GIS systems. Santa Cruz County, Monterey County and the City of Santa Cruz each have permit tracking databases where they enter basic information about the permits they review. The County Assessors in both ReCAP counties keep tax code information in databases. Santa Cruz County and a few other agencies in the region have operational GISs and a number of others, including the Commission, are at various stages of developing GIS capability.
With the right equipment, this electronic information is much easier to access and analyze than information kept in hard-copy sources. However, because each agency has a different type of computer system and a unique structure to its database or GIS, sharing electronic information across agencies requires working out data transfer protocols which can sometimes be quite complicated. There are technological obstacles to overcome -- for example, translating data from one format to another and rectifying geographic reference points. In addition, there are often data ownership issues that need to be addressed through some kind of formal or informal agreement. In ReCAP's experience, most agencies are willing to provide data, but they look much more favorably on two-way data exchanges in which they get something they need in exchange for what they give. Collecting information is a costly endeavor, and even public agencies are reluctant to give away for free something which required an investment of their budget to obtain. Where information has been acquired from private companies, there may even be contractual restrictions on whether and how the information can be shared with others.
Currently, few formal mechanisms exist in the ReCAP region for exchanging either hard-copy or electronic information between agencies. Although a good deal of information is exchanged on an informal "request-reply" basis, formal information exchanges are generally limited to those required for multi-agency permit review tasks (for example, review of wetland permits by federal, state and local agencies), program oversight tasks (for example, when local governments send the Commission copies of their coastal development permits), or specific regional planning efforts (for example, transportation or water supply planning).
The need for better regional information management in the Monterey Bay area has recently received attention. Spurred in part by the designation of the Monterey Bay Marine Sanctuary in 1992, the Commission launched its "Monterey Bay Initiative" with the goal of encouraging greater coordination among coastal planning and management authorities in the region. A key objective is sharing information and support resources between agencies. The Initiative operates through such mechanisms as inter-agency meetings where program managers discuss ongoing projects and data collection efforts in the region and explore opportunities for collaboration, data sharing and program integration. This work has also led to the Integrated Coastal Management process -- discussed earlier in the wetland section of this report -- which includes efforts to collect, synthesize and distribute information.
The other major effort towards regional information management is the Coastal Aquatic and Marine Projects Information Transfer System (CAMPITS), initiated by the Association of Monterey Bay Area Governments (AMBAG) with technical assistance from the Naval Postgraduate School's Cooperative Institute for Research in the Integrated Ocean Sciences. CAMPITS is envisioned as a regional information management entity that will keep track of what information is collected by which agencies, how the information is kept and how agencies can access the information. Eventually, CAMPITS will be a repository of environmental, land use and population data from throughout the region, utilizing a GIS to integrate diverse information from the region's resource agencies. Because it is funded largely through grants under the Federal Clean Water Act, CAMPITS has focused on water quality data so far. However, CAMPITS has laid the foundation for a regional GIS by surveying the region's agencies, finding out what information they have, how it is formatted, and what data "layers" each agency would like to see in a regional GIS. CAMPITS is also coordinating the establishment of data standards so that information from throughout the region can be shared more easily.
Database vs. GIS
Databases are a vast improvement over hard-copy sources in terms of accessing information quickly and doing such analytical tasks as sorting data into categories, summing and averaging. Such capability is crucial for cumulative impact assessment.
The next step up from a database is a Geographic Information System (GIS). A GIS is a database which allows information to be displayed in a mapped form. (Databases display information in tables or lists.)
For many aspects of a cumulative analysis, tabular data is sufficient. But for analyzing spatial relationships, such as the distribution of permits within a region, a GIS is better than a database.
With a database, locational information can be entered as text into a table, but the analyst must translate that into a "mental map" before the locational information means anything. A GIS does that as part of its function, and, unlike a "mental map", the GIS can handle millions of separate data points and make complex calculations that quantify the spatial relationships between those data points.
A GIS also serves as a communication tool because it can display the results of analysis in a mapped form that is easier for most people to understand.
The down side to GISs is that they are more complex and therefore more expensive to develop and operate than databases.
In spite of the greater cost, most resource agencies that can afford to are investing in GIS technology; however, none of them are throwing out their databases. The best option seems to be to have both, starting with a database and later building a GIS that can link to the database. This is the course ReCAP recommends for the Commission.
Achieving management goals of the Coastal Act requires knowing what is happening to coastal resources, but the CCMP has not had the resources to implement a systematic monitoring program. Basic resource data was collected as part of developing the original LCPs, but for some jurisdictions that was five to ten years ago, and not all areas in the ReCAP region are covered by LCPs. Since then, information about coastal resources has come primarily from permit applicants, in EIRs and other technical documents filed with an application or as a result of project monitoring requirements initiated through permit conditions.
As stated earlier, information management at the Commission occurs mostly through hard-copy means. Permits are tracked primarily using hand-written log books. This makes it difficult and time-consuming to retrieve information about specific permits. In the Central Coast office, each analyst tracks the progress of the permits under his or her review. However, there is no systematic method to ensure that conditions which require future follow-up, such as monitoring requirements, are tracked. Analysts each have their own system for monitoring permits, such as lists, card files, or memory, none of which will actively alert the analyst if a condition deadline is missed. This somewhat informal system also suffers when staff changes occur.
Another problem with the current information system is that access to past staff reports depends on knowing the specific permit numbers to look for. This often requires a manual hunt through the log books or past Commission meeting agendas if the only known piece of information about the permit is the applicant's name or the project location. Every district office has identified as a priority for better information management the ability to easily find permit information based not just on permit number but on applicant's name, project street address, and/or assessors parcel number.
Section 30343, added to the Coastal Act in 1982, called for the creation of a Coastal Resource Information Center (CRIC). With the establishment of the CRIC, the Commission began to improve its information management: the library was reorganized and a computerized cataloging system was developed to allow easier access to scientific studies and technical data in the library. In the late 1980's the Commission also attempted to develop a computerized permit tracking database as part of CRIC. While the Commission's existing computer technology was not adequate to support the kind of system envisioned by CRIC, a great deal was learned about how permit information could be managed more efficiently in the agency, and ReCAP was able to benefit from that work in designing the databases used for its cumulative assessment.
This past year, the Commission has begun to augment its existing computer system with high-speed desktop personal computers. The new computers support database software that is much more flexible and user-friendly than anything available even a few years ago. With better technology available, the Commission is in a good position to benefit from the experience gained through the CRIC effort and by ReCAP's database design and development work.
At the local level, electronic databases are used more extensively and have been important components of information management for a number of years in several jurisdictions. The three jurisdictions with databases -- Santa Cruz and Monterey Counties and the City of Santa Cruz -- account for approximately 90% of the local coastal permits issued to date. These databases are used to track permits through the review process so that statutory deadlines are not missed; however, their usefulness for cumulative impact analysis is limited because environmental impact information -- for example, whether a wetland or a public access site was affected or what length of seawall was erected -- is not entered. Instead, the project description is entered as a single, generally worded text string which makes sorting into categories or extracting particular descriptors very difficult. [1] The incorporation of cumulative perspectives in day-to-day permit review remains elusive in spite of the permit tracking databases currently available in part because the databases are not being used to track impact information.
Santa Cruz County has a fully functional GIS -- the first in the region -- which shows the development constraints and opportunities for each parcel in the County. Because the impacts of projects are not entered into the GIS, the ability to analyze cumulative impacts for each project is somewhat limited. However, the GIS does allow projects to be reviewed within a broader context and could be expanded to support cumulative impact analysis. Monterey County is in the early stages of developing a GIS. Because financial assistance is coming from the Ft. Ord re-use program, data "layers" have been developed mostly for the Ft. Ord area. However, the County plans to expand the system to cover the entire County in the future.
Information about coastal resources and about previous or on-going regulatory activities and their impacts is not readily available to the Commission's permit analysts. As a result, cumulative impact management strategies are very difficult to include in the Commission's day-to-day permit review activities.
Part of the problem is that up-to-date resource trend information is scarce in the region. Although resource information was collected as part of the LCP development process, much of that information is now out of date. Few formal mechanisms (i.e., resource monitoring programs) exist in the region to systematically update the LCPs with new data. Thus, the kind of trend information that ReCAP found to be important for doing a cumulative assessment is often lacking. For example, beach use figures were available only for State Parks and one city beach, leaving out some of the most popular beaches in the region. Up-to-date information about wetlands, such as acreage and habitat types, is not available for most wetlands. When new information is available, the old is often discarded because it is no longer seen as useful for day-to-day decisions. Yet the older information is crucial for assessing resource trends over time. When basic resource, use, and development trends are sketchy, cumulative impacts are very difficult to analyze and the conclusions derived from that analysis are less reliable than they should be.
Because the Commission does not independently monitor resources, current information about coastal resources is received primarily from permit applicants -- in EIRs and other technical reports filed with permit applications or as a result of project monitoring requirements initiated through permit conditions. This presents several problems: (1) the information available about any resource is patchy both geographically and temporally; (2) the information is collected in different ways by different permit applicants, making it difficult to analyze trends over time; (3) the information is presented to elicit favorable consideration of a project, and may not accurately document long-term adverse changes in resources over time; and (4) the information is tailored to the project and its impacts and may not comprehensibly address the site's resources.
Not only is basic information scarce, but what is available is often inaccessible to Commission analysts. In spite of the growing availability of electronic information, ReCAP found that most of the resource-related information the Commission has access to (given its current technological capabilities) is still found in hard-copy sources. Many of the most important source documents are located only in permit files. Typically, once information has been used to review a project, the documents are filed away with the permit and rarely used again, partly because people forget they are there and partly because of the difficulty of retrieving the documents from permit files. Thus, the current system of information management is cumbersome and relies heavily on the memory of long-term staff members to locate basic information needed for cumulative impact assessment.
A primary deficiency that makes cumulative impact analysis difficult is that project impact information -- descriptive measures of how a project will impact coastal resources -- is not kept by local governments or the Commission in a form that is easily retrieved. Project impacts are evaluated with each project, but the information is not recorded anywhere outside the staff report or permit, so it can not be easily combined with the impacts of other projects to make a cumulative assessment. Even the local governments that have computerized permit tracking databases do not use them to store impact information. As a result, neither the local governments nor the Commission can, for example, provide a running total of how many acres of wetlands were disturbed this year or how many square feet of beach was covered by rip-rap revetments this year. That kind of information needs to be easily available to permit analysts when the next wetland or rip-rap proposal comes in, otherwise cumulative impacts are too difficult to include in permit review. Analysts usually do not have time to search for information buried in permit files.
As noted above, the Commission does not currently have a GIS. Yet, as ReCAP found out, regional or cumulative impact assessment cannot be done without some sort of geographic analysis. Looking at tables of data simply does not provide an adequate representation of the relationships among development projects. Because the Commission does not have a GIS, ReCAP had to map much of its information by hand on maps that cannot easily be reproduced or distributed to other agencies seeking similar information. With a GIS, mapping the information would have been much easier, and the results could have been shared much more easily with other agencies.
Thanks to the cooperative efforts of Santa Cruz County, ReCAP had the chance to gain some valuable experience using the County's GIS as an analytical tool. The County Assessor's office uses a database to keep track of how each property in the County is used. Although the information is collected for tax assessment purposes, ReCAP asked the County to plot the data on its GIS, with different colors for different categories of land use (e.g., residential, commercial, visitor accommodations, vacant, etc.). The result was a map of current land uses that proved very useful in analyzing land use patterns and identifying where future development might occur. Because the analysis was performed using the GIS, it can be easily repeated in years to come, allowing planners to visually track changes in land use patterns over time and even to quantify those changes. The maps could be used, for example, to compare how changes occurring inside the Coastal Zone may differ from what is happening outside.
The joint venture with Santa Cruz County demonstrated to ReCAP the power of GIS as an analytical tool. But GIS is also increasingly becoming the preferred format for storing resource information. Without a GIS, Commission analysts will have no way to access the growing body of resource information that is available only in GIS format.
The Commission has no automated system for tracking permit conditions. As a result, certain types of permit conditions -- especially those that call for future actions such as monitoring reports -- are easily overlooked.
Permit conditions are a primary tool used to manage the impacts of development under the CCMP. Most permit conditions call for some action to be completed before a final development permit is issued. These are relatively easy to track because the official permit is not issued until such conditions are signed off by the analyst.
Other permit conditions can be more difficult to track under the current system. For example, projects affecting wetlands may receive a permit on the condition that mitigation be performed at the same time that the project is being built. In such cases, the permit usually requires monitoring reports to be submitted periodically to monitor the progress of the mitigation and to substantiate its success at offsetting the impacts of the project. Some types of projects -- such as seawalls -- might call for periodic monitoring reports that assess the continued proper functioning and public safety of a structure.
These monitoring reports serve several important functions. First, they provide a way of making sure that impacts are truly mitigated and structures continue to perform as required by the permit. If a monitoring report reveals problems, corrective measures can be taken; otherwise such problems may go unnoticed. Second, they provide a means for the Commission to learn which mitigation and structural techniques work best. This knowledge can be used to improve the success and reduce the costs of future mitigation. Third, because the Commission does not monitor resources itself, these monitoring reports serve as an important source of information about the affected resources.
During ReCAP's investigations, monitoring reports could not be found for half of the seawall permits that required monitoring as a condition of the permit and a third of the wetland mitigation projects that required monitoring.[2] The inconsistent follow-up on these permit conditions seems to be due to the difficulty of tracking them once a permit is issued. Sometimes monitoring reports are due years after a permit is issued. Although each analyst has his or her own system for tracking permit conditions, none are designed to actively notify the analyst when a permit condition compliance item -- such as a monitoring report -- is due. With hundreds of permits issued each year, it is not surprising that some of these post-permit conditions go unnoticed.
ReCAP has already begun to address this problem by designing a computerized permit tracking system. It is intended that, when complete, the system will track permit conditions and whether compliance was achieved for each permit condition. This should provide an easy, efficient means of ensuring that permit conditions are fulfilled and helping to assure that the impacts of development projects are mitigated properly.
Information about resources and regulatory activities occurring in one jurisdiction are not easily shared with other jurisdictions. As a result, resources are often managed without a regional perspective. Sometimes the same information is collected by more than one agency, unnecessarily duplicating effort. Resource agencies in the region are not always aware of what information is available from other agencies and are not able to access information that is available because of technical and political obstacles.
Managing resources regionally will require development of data transfer protocols that address both technological issues and ownership issues. For cumulative impact management to become an everyday reality of coastal permit processing, quick and easy access to information from all available sources will be necessary. Individual agencies simply can't afford to spend money on collecting information that they could get from someone else for less. Fortunately, there are universal computer languages that enable transfer of data between most systems. With a little effort, ReCAP was able to transfer electronic data from other agencies' databases in almost every case where such data was available.[3] For example, ReCAP received use figures from the State Department of Parks and Recreation and the Monterey Bay Aquarium; permit data from several local governments, the California Department of Fish and Game and the federal Office of Ocean and Coastal Resource Management; water quality data from the Surfrider Foundation; and information about access offers-to-dedicate from the Commission's old computers -- all via electronic data transfer. Development of data transfer protocols takes time, but it is usually a one-time, front-end investment and once the protocols are developed, data exchange can become a routine affair. The costs associated with exchanging information are minimal compared to the costs of collecting such information initially.
The data ownership issues can be a bit more difficult to work out. As noted in the Background section above, data is rarely given away for free because it costs so much to collect and put into a useful form. Most agencies are willing to engage in data sharing provided they get something useful in exchange for what they provide. Alternately, some jurisdictions have "production shops" where they will digitize information from hard-copy maps into a GIS format or provide a novel synthesis of their data for a fee. Santa Cruz County is an example of such a jurisdiction. For less expensive data sets -- for example, raw tabular data from an agency's permit tracking database -- an informal agreement is usually sufficient. For more expensive data sets -- for example, GIS data layers -- more formal arrangements may be necessary.
Additional staffing and/or training is needed to support the modern information management tools currently being developed by the Commission. In addition, adequate staff time needs to be set aside for training analysts and support staff in how to use these tools efficiently and effectively.
In conducting its assessment, ReCAP found that a considerable obstacle to improved information management for the project was the initial investment in staff time required to set up the computers and software so they worked properly, to train analysts and support staff in how to use the equipment, and to keep the equipment working properly. ReCAP analysts spent a significant portion of their time performing these functions, some of which should more properly have been performed by information management specialists. One of the important lessons to be learned from the ReCAP pilot is not to underestimate the commitment of staff resources needed to get a good information management system up and running -- and to keep it running.
By following the recommendations listed above, the Commission could greatly improve its information management and make it possible to incorporate cumulative impact management into the day-to-day permit review process.
ENDNOTES
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Chapter 5: Wetlands.
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