Executive Summary

ReCAP PILOT PROJECT

Findings and Recommendations: Monterey Bay Region

California Coastal Commission Regional Cumulative Assessment Project

September 1995


ReCAP Project Staff and Principal Authors:
Dan Carl, Brian Escamilla, Lesley Ewing, Helmut Gieben, Rick Hyman, Zach Hymanson, Tania Pollak

With assistance from:
Greg Benoit
Karin Grobe
Les Strnad, Project Supervisor
Elizabeth Fuchs, AICP, Project Manager

Cartography and Graphics: Jonathan Van Coops, Mapping Program Manager
Erin Caughman, Cartographer
Brian Escamilla, Cartographer
Steven Hines, Cartographer
Allyson Hitt, Cartographer

This report was prepared with financial assistance from the Office of Ocean and Coastal Resource Management, National Oceanic and Atmospheric Administration, under the provisions of Section 309 of the Coastal Act Reauthorization Amendments of 1990.

For more information on the ReCAP project, please contact:
Elizabeth A. Fuchs, AICP
Manager, Land Use Unit
California Coastal Commission
45 Fremont Street, Suite 2000
San Francisco, CA 94105
(415) 904-5280

OR

Steve Monowitz
Coastal Planner
Central Coast District
725 Front Street, Suite 300
Santa Cruz, CA 95060
(831) 427-4863


SECTION 309 AND THE REGIONAL CUMULATIVE ASSESSMENT PROJECT

During the past two decades, recognition of, and concern over, the cumulative impacts from growth and development on resources has grown. Although the Commission considers cumulative impacts in many of the projects it reviews and through the local coastal planning process, the Commission and local governments lack a systematic approach to undertake an analysis of cumulative impacts to coastal resources. As a result, regulatory practices which focus on individual permits may result in incremental resources losses.

In Section 309 of the 1990 Amendments to the federal Coastal Zone Management Act, the U.S. Congress identified the cumulative impacts of growth and development as a priority area needing improved coastal management. In response to these amendments, the California Coastal Commission completed an Assessment of the California Coastal Management Program (CCMP). This Assessment suggested program needs and options for enhancing coastal management in several priority areas, including cumulative impacts, wetlands, coastal hazards, and public access. Following the Assessment, the Commission adopted a multi-year strategy designed to enhance the CCMP in these priority areas.


What are Cumulative Impacts? Cumulative impacts are the combined results of a series of development activities or natural effects. Although an individual project may not greatly affect the natural or human environment, the cumulative impacts created by many different projects over time may significantly alter these environments. For example, the conversion of coastal habitat to developed land from an individual project may not seem significant. However, twenty years of development projects may collectively degrade important habitat values.


The Regional Cumulative Assessment Project (ReCAP) comprises the core of this strategy. It is an effort to devise, through a pilot project, an integrated, regional cumulative impacts management process based on the Commission's current mandate; Section 30519.5 of the Coastal Act requires the Commission to periodically review the implementation of the CCMP through the Local Coastal Programs (LCPs). By enhancing the CCMP's regulatory program, technical assistance and LCP implementation processes, the Commission can play a vital role in improving management of adverse cumulative impacts in the coastal zone.

The ReCAP team defined the pilot region as the coastal zone from the San Mateo/Santa Cruz County line to, and including, Point Lobos State Reserve. With help from local governments, the ReCAP team determined how shoreline armoring, public access, and wetlands changed over time; identified factors contributing to those changes; determined possible trends given a continuation of existing policies; and developed recommendations for improvements to policies and procedures to better address cumulative impacts in the future. This report presents the findings of the pilot project; recommendations to enhance the CCMP's effectiveness in managing coastal hazards, public access, and wetlands follow the findings.

OVERVIEW OF REGIONAL CHANGES

Since 1970, the population in Santa Cruz and Monterey Counties grew by nearly one quarter of a million people, resulting in an increase of over 65% in the two county region. This increase in population was accompanied by significant new development in the region and has been a significant contributing factor in many of the impacts noted. The increase in development has contributed to a 43% increase in the urban and suburban landform and a corresponding decline in vegetated and agricultural areas in ReCAP's land use assessment area which encompasses all of Santa Cruz County and Monterey County through, and including, Point Lobos State Reserve.

Since 1983, the Commission and local governments approved approximately 3,005 coastal development permits in the ReCAP region, ranging from approvals for subdivisions and single family residences, to commercial and public recreational facilities. Additional development undertaken in the region's coastal zone was exempt from review under the CCMP. The coastal zone is defined under Section 30001 of the Coastal Act as a "distinct and valuable natural resource ... [which] exists as a delicately balanced ecosystem." Since most of the population in the two counties lies within a half-hour of the coastal zone, coastal resources are a critical element in meeting the needs of a growing population. These resources also draw visitors to the region, leading to an even greater demand for services and increasing pressure on coastal resources.

Analysis of land use patterns in the ReCAP region indicates that since 1987, most of the development within the coastal zone of Santa Cruz County was infill of existing developed areas, concentrated within or adjacent to the urban services lines. In particular, development occurred from the City of Santa Cruz south to La Selva Beach. This trend appears to reflect implementation of the Santa Cruz County LCP goal of concentrating development in already urbanized areas. In Monterey County, most of the development in the coastal zone since 1987 occurred in the semi-rural areas of Northern Monterey County through large lot residential zoning, thus expanding the urbanization of the area. Of particular concern is the amount of development concentrated around Elkhorn Slough, raising concerns of cumulative impacts on the Slough. The manner in which growth occurred may have different implications for how cumulative impacts are analyzed and managed.

As population growth and development continue, the impacts on resources will continue to increase, especially as development encroaches more onto sensitive resources and less open space is available to buffer impacts. By 2010, the two counties are expected to grow by nearly 150,000 people. In Santa Cruz County, with a large amount of additional growth already approved in the Seascape area along the southern boundary of the urban services line, there is the potential for development pressure to extend southward, impacting agriculture and public access. In Monterey County, development of rural and semi-rural lands is expected to continue, increasing the potential for cumulative impacts on watershed resources. Development is likely to continue in the Elkhorn Slough area, as much of the land is vacant and zoned for low density residential use. Other large areas of undeveloped land exist along the sensitive shoreline dunes of the cities of Marina and Sand City.

For areas of infill, additional development may lead to increased densities and congestion and increased demands on existing services. Large lot semi-rural development may increase development within watersheds, further reduce available open space and may require the development of new public services. Protection of resources under the Coastal Act may require different management techniques to address the manner in which growth is occurring.

Preliminary Findings of the ReCAP Pilot Project

COASTAL HAZARDS

Coastal hazards usually arise from the interaction between development and natural processes. Along an eroding coastline, as is typical of much of the pilot region, this interaction often leads to shoreline armoring in order to protect development. Frequently, policies, such as the Coastal Act, support the use of public resources to respond to the hazard and to protect private property. In addition, armoring impacts natural processes, such as sand supply, and the extent of beach available for public access.

Since 1978, the extent of armored shoreline in the ReCAP region increased by approximately 2.4 miles; approximately one-eighth of the ReCAP shoreline is now armored. Between 1983 and 1993, the Commission and local governments approved 96 permits for some type of shoreline protective device in the ReCAP region. In general, such devices are concentrated in developed areas with erosive shoreline material and a high incidence of storm wave attack. With continued implementation of existing policies, it is estimated that approximately one-third of the ReCAP coastline, or 27 miles, could be armored in the future.

Regional Consistency for Areas Prone to Shoreline Erosion Could Improve Hazards Management

One of the major findings of the ReCAP analysis is a need for regional analysis when addressing shoreline erosion. In the ReCAP area, there has been little attempt to design shoreline armoring to address regional resources and constraints. In particular, permits for shoreline protective devices seldom analyzed regional sand supplies, sand budgets, or sand processes.

While numerous techniques exist to stabilize an individual site, the effectiveness of each depends on the characteristics of the site. While shoreline characteristics (geology, wave climate, etc.) vary throughout the coast, small sections of the coast can often be identified that exhibit similar characteristics. Properties within such sections probably have similar shoreline problems and would respond similarly to various protective efforts. However, in the ReCAP region, strategies for arresting erosion generally differ greatly from one property to the next, even though the site characteristics are similar. For example, in the Live Oak area of Santa Cruz County, four different types of armoring have been approved along 3,000 feet of coastline with similar geologic conditions.

Given the existing approach to armoring based on site specific reviews and with armoring permitted by the Coastal Act if needed to protect existing development, the Commission and local governments respond to proposals for armoring, rather than guide the most effective solution for managing coastal erosion. These site specific proposals may respond to individual property owners' immediate needs, but they may not adequately address the regional concerns. Development of regional plans would help guide planning efforts to address these regional concerns and ensure full review of alternatives to shoreline protective devices.

Greater Attention Should be Given to Impacts to Public Access

Armoring along much of the coast in the ReCAP region has led to cumulative impacts to beach areas and public access opportunities. These impacts occur when shoreline protective devices are placed directly onto the beach and by affecting the sand supply and landward retreat of the beach. Such protection measures cover an estimated 25 acres of beach in the ReCAP region; permits granted since 1978 under California's coastal management program represent approximately 20% of this total, or 5 acres. Although a review of shoreline armoring over time indicates that armoring activities and encroachment has slowed under the coastal management program, the impacts from such encroachment may still be significant. Many of the armoring projects were approved in the popular beach recreational areas of Santa Cruz County.

Of the 96 permits approved for some form of shoreline protective device, only 36 required mitigation for access impacts. Thirty of the 96 armoring permits were for new shoreline devices; the remaining permits generally involved some form of repair, maintenance, or expansion to an existing shoreline structure. While some maintenance activities may not further impact access, new protective structures, as well as expansion and maintenance projects that push shoreline protective devices further seaward may have significant cumulative impacts. More consistent use of mitigation requirements for these projects will reduce the cumulative impacts on public access.

Currently, access impacts from shoreline armoring are generally mitigated through provision of an offer to dedicate an access easement. When accepted and available for public use, these offers are generally effective in mitigating site-specific, immediate impacts. However, additional measures may be needed to fully address all impacts, including long-term effects on sand supply and the cumulative impacts on access. If existing practices are followed, future shoreline protective devices may cover a total of approximately 65 acres of beach. To more fully address impacts, the process to ensure recordation and acceptance of offers to dedicate should be improved; further, the use of other mechanisms, such as beach replenishment programs, should be considered to minimize the long-term impacts to access from shoreline armoring. Development of the regional plans discussed above could help address management of shoreline erosion while ensuring minimal impacts on access.

Improvements to the Emergency Shoreline Armoring Process Can Reduce Impacts

The need for a regional, long-term plan to address shoreline erosion is particularly evident under the emergency permit process. A significant amount of shoreline armoring in the ReCAP area has been put in place under emergency conditions. For example, in the Live Oak area, over 40% of armoring projects from 1983-1993 were approved through the emergency process. Because of the need for rapid response, armoring has been approved through the emergency process with little or no technical analysis, review of alternatives, or review of, and mitigation for, adverse impacts to resources. While current policies require that a subsequent, regular coastal development permit be obtained, many of the 24 emergency permits issued in the ReCAP area from 1983-1993 have no follow-up permit; therefore, full regulatory review did not occur and impacts from these projects have not been fully assessed or mitigated.

Emergency armoring projects generally occur in areas with a high likelihood of reoccurring storm driven events, leading to severe erosion. Since these areas of "on-going" high hazards are regional in nature, development of a regional management plan can ensure that effective protection techniques and resource mitigation measures will be planned before the emergency occurs. Until these regional plans are in place, the emergency process needs to complement the regular permit process by ensuring compliance with subsequent regulatory review, clearly defining emergency situations, and identifying standards for design and placement of shoreline protective devices that can be applied in emergency situations. ReCAP is currently developing a tracking system to ensure better follow-up review of emergency permits.

Existing Setback Methodology and Policy Framework Needs Revision

Section 30253 requires that new development should be stable without the construction of protective devices to minimize hazards. Section 30235 allows shoreline armoring when needed to protect existing structures. Setbacks are a common policy approach for ensuring the long-term safety of shoreline development without armoring.

Most setback regulations are developed based on long-term average erosion. However, in many locations erosion is often episodic in nature. For example, a portion of a seacliff in Santa Cruz which had shown little erosion for a number of years eroded 46 feet on a residential site in the 1983 storms. This represents almost the entire amount of setback determined adequate for the lifetime of structures on that site. Since erosion rates often do not adequately incorporate episodic events, actual erosion may exceed the setbacks established, leading to an increase in the future need for armoring. Further, many of the shoreline structures in the region continue to be used beyond their expected economic lifetime. In the pilot region, LCPs generally develop setbacks based on a 50 year economic lifetime for new development. Since the setback is based on that anticipated lifetime, those structures exceeding that lifetime will ultimately require armoring for long-term protection.

Although setbacks are a primary tool to reduce the amount of armoring, setbacks cannot address risks in all cases. In order to be used more effectively, setbacks must be considered at the subdivision stage of a project; if lots are created that are too small to support both an adequate setback and the development, the need for armoring will be likely. Further, setbacks cannot fully address risks to development on infill lots. In Santa Cruz County, ReCAP estimates that much of the future shoreline development will be infill; since requiring adequate setbacks will necessitate a different level of review on new development than the existing development, setbacks will probably not be utilized. These areas will likely see an increase in shoreline armoring to protect private development. For infill situations, ReCAP recommends that alternative methods be developed to address mitigation of hazards.

Setbacks also cannot address risks to existing development. However, one way to address these risks may be after existing structures are reconstructed due to damage from storms. Under Section 30610 of the Coastal Act, reconstruction of a structure damaged by a natural disaster is exempt from requiring a permit if reconstruction is in the same footprint and about the same size as the original structure. Not only does this exemption preclude any assessment of risk avoidance, an applicant seeking to reduce their dependence on a shoreline protective device by relocating the structure is penalized by being required to go through regulatory review. By changing this policy to encourage redevelopment landward of the existing footprint, the need for armoring may be decreased.

Further, once a structure is built, it is considered to be an 'existing' structure under the Coastal Act; under Section 30235, the Commission may approve a permit for shoreline armoring to protect such structures against erosion. Since the policy does not include a cutoff date for when a structure can be considered existing, even new development -- built in compliance with Section 30253 -- may later receive approval for armoring if erosion threatens the development. Ensuring adequate setbacks of 75-100 years will help minimize the need for a shoreline protective device for new development.

Future Planning

Since current policy does not restrict development in areas of high hazards, future development along high hazard shorelines is likely to continue. As discussed, many of the problems and impacts associated with shoreline armoring could be addressed through development of a regional plan. These plans would establish regional approaches to future armoring, lessen the dependence on emergency permits for armoring, and ensure that the best design and mitigation measures are considered before armoring occurs. In order to minimize impacts on coastal resources and the public costs involved in protecting private development, future reliance on armoring should be minimized. Planning new development using realistic long-term setbacks and encouraging alternatives to shoreline protective devices can greatly reduce the reliance on shoreline armoring. Regional plans can play an important role in achieving this.

Longer term plans should explore efforts to manage and expand existing sand resources to both reduce the need for shoreline armoring and to minimize the impacts from existing armoring. In addition, the regional plans for shoreline erosion and bluff retreat should be expanded to encompass other coastal hazards, such as tsunamis, earthquakes, and fires.

PUBLIC ACCESS

Public access to the coast has historically been an important issue for the Coastal Commission; much of the impetus for passing the Coastal Act was due to concerns over loss of shoreline access due to development. In the ReCAP region, the amount of physical access to the shore has increased dramatically since the early 1980s, including access for physically challenged users. Since the early 1980s, the Department of State Parks and Recreation added an estimated 7,000 acres of park land to their coastal parks in the pilot region. In addition, the Monterey Regional Park District purchased land in Monterey County to enhance public access to the coast. Based on standards in the pilot region's LCPs, approximately 75% of the ReCAP coastline that is physically suitable for public access currently provides such access.

During the same time, the pilot region has experienced an increase of approximately 50% in the amount of beach use and a growing diversity in the types of activities undertaken. Comparison of this increase in use with the growth in population indicates that beach use grew twice as fast as the population in the two counties during the same time period. This increase in use leads to additional pressures on existing facilities and the natural resources along the coast. To continue ensuring the availability and adequacy of access, California's management program must address the impacts of development not only on the physical supply of access, but on factors that affect actual use of, or ability to use, a site. These factors include ensuring adequate parking, transit alternatives to the coast, support facilities, and maintaining the quality of sites.

California's coastal management program has generally protected, and improved, coastal access through the use of mitigation measures for development that adversely affects access opportunities. ReCAP's analysis determined areas where improvements to the regulatory program could further enhance protection of access opportunities, as discussed below.

Improvements are Needed in the Implementation of Access Mitigation

Mitigating cumulative impacts to access through a project-by-project review of development proposals is often difficult. To require mitigation, the Commission or local governments need to show how the project impacts resources and the mitigation must address this impact. Since many of the impacts to access come from the overall increase in use and demand, quantifying a single project's contribution to these impacts can be challenging. In cases where development encroaches onto a beach or blocks accessways, the Commission and local governments often use access easements to mitigate the impacts. These easements are generally offers-to-dedicate land for public use (OTDs), which must be recorded and then accepted by an appropriate agency for management.

Of the 92 OTDs required by the Commission and local governments (52 lateral and 40 vertical), only 55 (approximately 60%) have been recorded (32 lateral and 23 vertical). Since the land is not actually available for public use until the OTDs are accepted by an agency and opened for use, recordation of the offer is not by itself adequate to fully mitigate impacts from development. To date, only one OTD, a vertical, is actually open and available for public use in the ReCAP area. Two major barriers which hinder acceptance of OTDs are concerns over potential liability and the costs associated with maintaining an offer, when opened. Until secure sources of funding are available and concerns over liability are resolved, this reluctance to accept offers will likely continue, preventing full mitigation of impacts. Developing mechanisms to ensure that OTDs are recorded and made available for use will greatly improve the effectiveness of these mitigation measures. Improvements in tracking what OTDs are required will help ensure offers are actually recorded.

Another factor to consider in improving the effectiveness of OTDs is the use of exemptions. Both the Commission and local governments often exempt development from mitigating impacts on access when another accessway is located nearby; of 291 permits exempted from access easements in the ReCAP area, 151 were due to a finding of adequate existing access. However, these findings generally do not consider the cumulative impacts of development on the existing accessway: findings of the impacts of multiple development projects on site quality, support facilities, and the need for parking all affect whether the existing nearby access is adequate, but are not discussed. Without considering these factors, analysis may not be able to truly determine whether the existing access opportunities are adequate, and whether the proposed development can be exempt from mitigation. Developing guidance for analyzing these cumulative impacts will improve this process.

In cases where OTDs are used, they provide mitigation only if they are recorded on land that is not already publicly owned. ReCAP, however, was unable to determine the extent to which OTDs were recorded on public rather than private land due to a lack of determinations by the State Lands Commission identifying the boundary between public and private land. Ensuring that State Lands determinations are made prior to filing will help ensure the appropriate location for mitigation easements.

Although demand for, and use of, coastal recreation areas will likely continue to increase, the number of cases where the Commission and local governments can use OTDs in the future to mitigate impacts is small, due to the small number of vacant shorefront lots. In order to more fully mitigate the impacts of development on public access, management programs must ensure that existing and future OTDs are recorded, on land not already available for public use, and offers are made available for use. Analysis of whether nearby access is adequate must also include an analysis of the cumulative impacts to the existing access. Where physical supply is adequate, and OTDs are not an appropriate mitigation technique for the resulting impacts, in-lieu fees or other alternatives should be considered and used to pay for support facilities, transit and parking, and the maintenance of accessways.

Improving Mitigation of Shoreline Protective Devices

As discussed previously, the use of shoreline protective devices in the ReCAP region leads to significant cumulative impacts on coastal access. In general, current policies in LCPs seek to minimize access impacts by requiring that shoreline protective devices should not reduce lateral access or adversely affect shoreline processes. However, the LCPs generally lack specific criteria to assess and reduce impacts from armoring projects. Further, two LCPs encourage the use of revetments, which encroach onto beaches more than other types of protection measures. Since these plans were certified, new information on shoreline processes may indicate more appropriate approaches. One LCP does not have language specifying that armoring projects should minimize impacts on public access.

In the ReCAP region, shoreline protective devices have significantly affected public access opportunities through encroachment onto beach areas; as noted, approximately 25 acres of beach have been physically covered by shoreline protective devices. If existing trends continue, a total of 65 acres of beach could be lost. Although many armoring projects required mitigation for this encroachment, that mitigation was usually in the form of an offer to dedicate a public access easement. As discussed previously, until OTDs are actually available for public use, impacts are not fully mitigated. Further, impacts on those projects that did not require an OTD have also not been mitigated. Modifying LCP policies to ensure that shoreline protective devices are designed to encroach the least amount possible onto beaches and improving the process by which offers are recorded and accepted will help reduce losses to access opportunities.

Placement of a shoreline protective device may ultimately lead to a complete loss of a beach, unless beach nourishment is undertaken. With the placement of such a device, a beach can no longer migrate landward; as erosion continues, and the sand is not replaced, the beach continues to erode away. During this process, the mean high tide line is moved landward; since public land, and therefore public beaches, is defined by the mean high tide line, its movement landward reduces the amount of land in public ownership and available for public use. Over time, the cumulative loss of beach area may be significant.

Minimizing the amount of future armoring through methods discussed under the hazards section, and encouraging beach replenishment, will reduce impacts to access and help protect the supply of recreational access.

Conflicts Between Public Access and the Protection of Sensitive Resources are Increasing

Many areas of the coast in the ReCAP region support sensitive habitat or species. In many cases, these are also areas with current or potential future recreational use. As recreational use grows, impacts to sensitive resources become more evident, especially if management measures are not in place. While many access locations currently manage access to minimize impacts on habitat, such impacts have been noted at a number of coastal dune and wetland areas in the ReCAP region. Seven wetlands currently show impacts from access, including erosion, vegetation loss, and disturbance of wildlife. Several of the dune areas have been successfully restored; however, resources will be better managed if impacts are prevented from occurring in the first place.

While the Coastal Act requires protection of sensitive habitat and species, and many LCPs have policies designed to minimize impacts on habitat from public use, monitoring programs have not been established, nor have criteria or methods to evaluate if impacts are occurring. Without monitoring sensitive resources, attention is not given to an area until the impacts have already occurred. Several LCPs have policies that seek to manage access according to a site's carrying capacity. However, use of this policy will require defining the site capacity and monitoring to ensure the protection of resources.

In addition, enforcement of policies protecting resources is often inadequate. For example, a lack of adequate enforcement has been cited as a reason for continuing impacts on sensitive resources at Wilder Beach and in the dunes in Monterey County.

Preventing impacts through the enforcement of policies, monitoring, and ensuring that protection measures are in place before recreational use occurs in sensitive areas will better protect resources in the long term, while still ensuring public access. Development of access management plans and access components in wetland management plans can help ensure that these issues are addressed.

Cumulative Impacts to Reaching the Coast

Accessibility to the coast, whether through adequate parking or through transit, is a vital element of ensuring public access. As use of sites increases, so will congestion, competition for parking, and demand for additional support facilities. Although the Commission approved an increase in parking spaces of approximately 3,115 spaces in the ReCAP region, ReCAP found that accessibility to the coast has not necessarily improved. While an increase in overall parking will help reduce competition for spaces between beach use and other uses, it may not be sufficient to address the direct increases in use at beach areas, and the resulting increased demand for parking. Of the new spaces the Commission approved, approximately 450 are dedicated to beach use.

The growing competition for parking is evident in several instances in the ReCAP area. In spite of an increase in parking spaces in the beach area in Santa Cruz City between 1980-1987, studies found that parking shortages worsened. A second indication of inadequate parking supply is the emergence of several preferential parking programs in the ReCAP area. With inadequate parking for both recreational and residential use, competition for available parking increases, leading to the desire for residents to establish preferential parking programs. These parking programs, and an overall lack of adequate parking, hinders the ability of the public to reach and use coastal access sites. Even when parking is available, the rising cost of parking further impacts the ability of the public to reach the coast.

To increase accessibility, the Commission and local governments could increase the availability of upland sites for parking. Though the Coastal Act requires land to be reserved for upland support facilities, such as parking, few LCPs specifically designate such areas. To provide additional parking for recreational use, LCPs should also encourage joint-use programs, whereby businesses that are closed on weekends and holidays make their lots available for visitor parking.

As use of sites increases, and the increase in additional parking becomes more limited, transit will need to play an increasing role in providing access to the coast. Several beach shuttles currently run in the ReCAP area. The availability of transit to effectively serve recreation needs will depend on ensuring that access needs are planned for in transit programs and on ensuring adequate funding for those programs. Further, much of the need for transit occurs from outside the immediate ReCAP area, leading to the need for regional transit systems. Developing a program of in-lieu fees for such transit projects can help ensure that accessibility to the coast is maintained.

Responding to Changing Access Demands and Demographics

Inherent in the Coastal Act objectives is the goal to maximize access for all people. As such, the Coastal Management Program needs to continue to be responsive to changing demographics. Meeting the needs of all potential users is dependent on determining who those users are, what types of facilities are wanted, and what, if anything, hinders access to the coast. While the regions' demographics have changed dramatically over the past several decades, it is not known whether, and how, this change has affected the demand for access and for various types of facilities. Although ReCAP attempted to research this issue through a survey, such survey research fell beyond ReCAP's ability. In order to fully maximize access, the Commission should pursue additional research on this matter.

Future Management of Cumulative Impacts to Access

ReCAP's research indicates that current access management is generally effective in mitigating losses to the physical supply of access. However, evidence also indicates that cumulative impacts are still occurring to access opportunities -- primarily to the availability of upland support (discussed above), loss of access opportunities through increasing restrictions on use, and degradation of site quality. Many of the impacts occur from an overall increase in use of sites. Management of these types of issues needs to focus more on intergovernmental coordination and day-to-day management of access sites; the existing framework for coastal access is not geared to address these types of management issues. Development of beach management plans and regional access plans could address the range of issues leading to the ongoing cumulative impacts to access.

WETLANDS

The most significant adverse impacts to wetlands in the ReCAP region pre-date the Coastal Act. Although exact figures are not available for the ReCAP region, estimates for the State as a whole suggest that at least 90% of the original wetlands were destroyed before their value was appreciated. As more information has become available, there has been a greater understanding of the ecological importance of wetlands and a greater appreciation of the functions wetlands provide for society -- for example, flood control, purifying drinking water, and providing nursery areas for commercially important fish.

Environmental laws enacted in the 1970s -- including the Coastal Act -- have gone a long way in preventing further direct loss of wetlands from new development. However, there is growing recognition that these laws need to more effectively manage secondary and cumulative impacts, especially those caused by new and ongoing activities occurring outside of wetlands. For example, the hydrology of a wetland -- the amount and timing of water flowing through a wetland -- is critical to the health of that wetland. Activities occurring upstream, such as water diversions, dams, and paved surfaces, cumulatively change a wetland's hydrology, creating impacts in the wetland that are often not considered when individual upstream projects are evaluated. The recommendations in this report focus on ways of improving the management of cumulative and secondary impacts and reversing some of the damage done to the region's wetlands in the past.

ReCAP identified 99 wetlands of various types and sizes within the project area, totaling approximately 6,200 acres. Analysis of aerial photographs suggests that, for the region as a whole, there has not been an appreciable change in total wetland acreage over the last 16 years. Some acreage changes within a few individual wetlands were noted, as were chronic adverse impacts to hydrology and water quality caused by upstream development. Without more active and effective management of cumulative and secondary impacts, these trends are likely to continue in the future, resulting in continued declines in the ability of the region's wetlands to provide ecological and social functions, even if net acreage remains fairly constant.

Direct Loss of Acreage, Fragmentation, and Habitat Change

Both natural and human processes have affected wetlands in the ReCAP region for some time. Natural processes include droughts, floods, earthquakes, and seasonal berm formation at the mouths of coastal lagoons. Human-induced changes include conversion of wetlands to urban and agricultural uses, upstream water projects such as dams and diversions, and construction of transportation corridors that restrict water circulation within wetlands. Altogether, the human-induced changes have had, and continue to have, more damaging effects in the region's wetlands than natural events.

As noted above, large portions of the study area's wetlands disappeared before environmental regulations were enacted in the 1970s. Not only were wetlands reduced in size, but they were broken up and separated by roads, pastures, cultivated fields, and urban development. This fragmentation degraded the quality of remaining wetlands by restricting water circulation and severing ecological links between wetlands. All of these processes directly affect the vitality of wetlands within the region. Other wetlands experienced fundamental changes in habitat type as a result of human activities. For example, coastal lagoons were turned into marinas or fresh water lakes and many sloughs were reduced to drainage channels. In addition, the human-induced changes may be exacerbating the adverse affects of natural events.

As a result of more protective laws, wholesale destruction of wetlands has largely stopped. However, direct incursions into wetlands are allowed under the Coastal Act -- for ports, coastal-dependent industrial facilities, mineral extraction, or "incidental public service purposes" -- where less environmentally damaging alternatives are not feasible and where mitigation is provided to avoid, minimize, or compensate adverse impacts. Mitigation usually involves replacement of lost wetland acreage. This interpretation of mitigation under the Coastal Act mirrors federal and statewide "no net loss" policies: a loss of wetland acreage in one area must be offset by a gain somewhere else.

In spite of the overall effectiveness of such policies, deficiencies in the regulatory framework have allowed some wetland losses and degradation to occur in the ReCAP area. One problem is that mitigation efforts often turn out to be unsuccessful, resulting in an unmitigated loss of wetland habitat. Even if mitigation is successful, it often creates a different habitat type than that which was lost, making it possible to lose certain habitat types over time, even if overall acreage remains constant.

Reliance on mitigation points to the need for effective design, implementation and monitoring of mitigation projects. In its assessment, ReCAP found a wide range in the quality and detail of mitigation plans. Some lacked criteria for measuring success or did not specify remediation measures. For about a third of the projects, monitoring reports that were called for in the permit could not be found. The Commission is in the process of addressing this problem by developing technical guidance that explains what should be included in mitigation plans and help to determine how to monitor and evaluate success of mitigation projects. This guidance should be incorporated formally into the coastal management program to help the effectiveness of current wetland policies.

Another problem is the lack of consistency in delineating wetlands between various local governments, state and federal regulatory agencies, and even within the Commission itself. Wetland losses have occurred in the ReCAP region when wetlands were labeled something else (e.g., "seasonally flooded grassland") that does not receive the same degree of protection as wetlands. A consistent method for identifying and delineating wetlands would help assure that all wetlands are protected and reduce confusion about what is or is not a wetland.

Another regulatory gap ReCAP found was the allowance of agricultural uses and grazing where these activities have occurred in the past. In their natural state, wetlands typically expand and contract from one year to another in response to climatic variation. Under current policies, if a wetland gets smaller during a period of prolonged drought, farmers can (and do) expand their fields into what were formerly wetlands. Once established, such agricultural use is allowed to continue even if the area becomes wet again. This occurred in a number of places in the ReCAP pilot area, representing a cumulative loss of wetland areas.

Finally, ReCAP found several cases where a lack of adequate monitoring allowed wetland losses to occur in the region. Improvements in systematic monitoring programs will help avoid unpermitted wetland losses. For example, parts of Moro Cojo Slough were diked off and converted to agriculture around 1977 without a permit; this development was only recently discovered during ReCAP's review of aerial photos. Implementing even a rudimentary monitoring program such as annual review of aerial photos would help reduce losses like these that otherwise might go unnoticed.

Policies Requiring Buffer Areas are Inadequate and Inconsistent

Undeveloped areas adjacent to wetlands have diminished over time, leading to a chronic loss of transitional habitat immediately adjacent to wetlands and a hardening of wetland edges. Many wetland species spend part of their lives in these transition zones; the loss of these areas severs the ecological connections between the wetland and the surrounding landscape. In addition, the hardening of wetland edges limits the ability of wetlands to evolve in response to both natural and anthropogenic alterations. Cumulatively, the loss of transition zone habitat and the hardening of wetland edges have resulted in major adverse impacts to wetlands in the project region, including an overall degradation of the resource and a loss in biodiversity.

Both urban development and agricultural development are continuing sources of impacts to transitional zones and wetland edges. Agricultural development adjacent to wetlands often includes a cultivation area extending through the transition zone up to the wetland edge. In urban areas, transition zones adjacent to wetlands have been used to provide additional public facilities (e.g. lawns, picnic benches, barbecues, and tennis courts) to enhance recreational opportunities. In addition, wetland banks are often armored where roads and railways occur.

To minimize impacts from development and safeguard transition zones, buffer areas are incorporated into a significant number of coastal development permits. However, the conditions requiring the establishment of buffers and restrictions for uses within buffers are not consistent, and in some cases the resulting buffer area is too small to be effective. ReCAP found that of the 97 projects permitted adjacent to wetlands, 38 projects (40%) included buffer areas as a permit condition. In those 38 projects, buffer widths ranged from 5 to 500 feet. In many cases, existing activities (e.g. agriculture) and development encroach into what should be a buffer area. ReCAP noted adverse impacts to the wetland edge and/or transition zones at 14 of 20 wetlands (70%) inspected. For example, at Neary Lagoon, development obliterated much of the transitional zone and hardened the edges of this wetland, a scenario common to many wetlands surrounded by urban development.

Although statewide guidelines recommend a buffer width of 100 feet, wetland buffer width required by the region's LCPs and LUPs are determined on a case-by-case basis with widely disparate results. Since the scientific information necessary to determine the proper size of a buffer is lacking, ReCAP could not determine if any of the LCP/LUP buffer provisions are truly adequate. Until more definitive criteria are developed, a minimum buffer width of 100 feet should be implemented consistently throughout the region. Otherwise, transitional zones and wetland edges will continue to be adversely affected and the ability of wetlands to perform their ecological roles will continue to decline.

Development is Impacting Wetland Hydrology

While natural factors such as droughts and earthquakes influence the hydrology of wetlands, ReCAP's findings suggest that the hydrology of virtually all wetlands within the project area has been altered by human activities. These activities include dam building, road construction, urban development, and agricultural development. Review of the management program in the ReCAP area shows that increased attention is needed for projects with the potential to alter the hydrology of wetlands.

Changes in a wetland's hydrology affect habitat and water quality, thereby affecting the types and abundance of organisms a wetland can support. Although most of the human-induced changes to wetland hydrology occurred prior to the Coastal Act, the cumulative effects continue to impact wetland resources. These alterations tend to compound the effects of natural processes, leading to synergistic cumulative impacts, including reductions in water quality, changes in habitat composition, reductions in habitat size, and reductions in biodiversity. For example, tidal exchange was severely decreased (Bennett Slough and Corcoran Lagoon) or completely severed (Upper Watsonville Slough and Schwann Lagoon) when roads and railways were built prior to implementation of the Coastal Act; adverse impacts to the wetlands' water quality continue today.

Alterations due to development have also affected the hydrology of several coastal lagoons in the ReCAP area. These lagoons, including Waddell Creek Marsh, Soquel Creek, Salinas River Lagoon, and Carmel River Lagoon, are subject to closure through the formation of berms at the lagoon mouths. The opening and closing of a lagoon mouth is fundamentally a natural process; however alterations such as upstream diversion of freshwater, excess siltation, or reconfiguration of the mouth have led to unnatural alteration of the timing and extent of this process. Extended closure of a lagoon mouth can increase the potential for flooding, lead to extreme changes in water quality, and block fish migration. Due to the impact on the hydrology of the wetlands, maintaining the lagoon ecosystems in the ReCAP region has been at substantial costs to the public and the natural resources.

Excess erosion or sedimentation also impacts a number of wetlands in the region. With regard to these physical processes, Elkhorn Slough is the most well studied wetland in the ReCAP area, and provides an example of the impacts associated with erosion and sedimentation. The construction of Moss Landing Harbor in 1946 dramatically altered the Slough's hydrology and initiated ongoing erosion within Elkhorn Slough. The rate of erosion is increasing, resulting in the loss of intertidal salt marsh and an increase in open water area. This chronic change in habitat will directly influence the types and abundance of plants and animals that can utilize this wetland.

Agricultural development in upper Elkhorn Slough has led to excessive sedimentation, affecting resident plants and animals. Two-thirds of the total sediment entering Elkhorn Slough is due to erosion from strawberry farms, even though strawberry farms comprised only eight percent of the land use within the watershed. Since existing Coastal Act policies emphasize the protection of agricultural lands, regulatory alternatives for controlling excessive sedimentation are limited. However, developing a nonpoint source pollution program may provide additional tools for addressing cumulative impacts from agricultural runoff.

Many of the hydrologic impacts affecting wetlands in the coastal zone are derived from activities occurring outside the coastal zone, and cannot be addressed solely through changes to the Coastal Act. Substantial portions of many watersheds associated with the project area have been developed; this development has increased the amount of impervious surface within the watershed, leading to increased runoff rates and channelization. Since jurisdictional boundaries and regulations are generally not developed or enforced on a watershed basis, cumulative impacts will likely continue to occur within the ReCAP project area. Developing a watershed planning approach that crosses political jurisdictions, as discussed in more detail later, could substantially address many of these impacts.

Impacts to Wetland Water Quality

Water quality is defined here as the physical, chemical, and biological integrity of a water body. Maintaining water quality is important to maintaining high quality habitat. While little is known about much of the water quality in the ReCAP region, available data does indicate some areas of concern, particularly due to nonpoint source pollution. Review of the management program in the ReCAP area revealed that few pollution controls are explicitly required; only one of the LCPs/LUPs[1] imposed such requirements.

The introduction of pesticides, heavy metals, and other pollutants into wetlands in the project area is of ongoing concern, although long term monitoring data are generally not available to determine the impacts on wetlands. The few studies completed show that pesticides do exist in Moro Cojo Slough, Elkhorn Slough, Moss Landing Harbor, and the Salinas River Lagoon. Pesticides are thought to enter these wetlands with nonpoint source runoff from surrounding agricultural areas.

In contrast, heavy metals and other pollutants such as domestic sewage are thought to enter wetlands with urban runoff. Thus, these pollutants would be most prevalent in wetlands surrounded by urban areas and large developments such as central Santa Cruz County, the City of Marina, and Spanish Bay. Urban runoff into some of these wetlands can be substantial given their size. For example, 28% of the watershed draining into Majella Slough (approximately 25 acres) is now part of the Spanish Bay development. In Marina, the Marina Vernal Pond #1 (approximately 10 acres) receives runoff from approximately 13 acres of an adjacent stretch of Highway One.

Point source discharges also exist within the project area. A review of current waste discharge permits shows 13 active discharges into streams that flow directly into local wetlands and five active discharges that flow directly into wetlands.

As with the hydrologic impacts, many of the factors affecting wetland water quality occur in the watershed, outside the coastal zone. Development of watershed plans could improve policies and management measures to improve water quality.

Impacts to Wetland Biodiversity are Unknown

The plants and animals that exist in or rely on wetlands comprise the biological component of the wetland ecosystem. This biodiversity is considered one of the most important functions of wetlands today. An understanding of wetland biodiversity in the project area is necessary to fully protect and manage wetland resources. However, changes in biodiversity cannot be fully determined at this time due to a lack of appropriate information. There are indications though that wetland biodiversity has declined due to human impacts.

A reduction in biodiversity is indicative of a wetland that has suffered adverse impacts. The establishment of exotic species, the number of special status species (rare, threatened, or endangered), and changes in the number and abundance of native species are indicators of changes in biodiversity. ReCAP's findings show 34 wetlands within the study area either contain special status species or habitat appropriate for such species. This presence of special status species or their habitat suggests that species biodiversity in the project area has been adversely impacted.

A review of the project area LCPs/LUPs indicates that although all provide indirect protection for biodiversity through the recognition and protection of selected habitats, particularly habitats that are identified as environmentally sensitive habitat areas, they do not address biodiversity directly. In order to more fully protect biodiversity, a more consistent, direct, and proactive approach is needed. In conjunction with a more direct approach, ReCAP's findings point to the critical need for standardized methodologies in assessing wetland biodiversity. The methods used should yield information necessary to answer project specific questions, as well as the appropriate information for assessing the cumulative impacts to biodiversity over time and space. Although there are indications that wetland biodiversity is decreasing in the project area, the lack of consistent long-term biological (species abundance and distribution) and ecological (habitat type and condition) information prevents predictions of future trends.

Information Needs in Wetland Management Decision-Making

Each stage of the decision-making process regarding development projects involving wetlands, from project conception and wetland identification to follow-up monitoring, could be improved with the addition of better information.

ReCAP found this problem evident in several aspects of the management program: in how specific wetlands get identified, in permit and monitoring information requirements, in understanding of wetland systems, in analysis and decision-making on permits, in interagency coordination and technical expertise, and in information systems.

Knowledge of a wetland's existence and extent is crucial to managing the resource. Yet, to date, there is no complete and generally accepted listing or map of all of the area's wetlands. Previous inventories begun by the U.S. Fish and Wildlife Service in the 1970's are incomplete. ReCAP preliminarily identified about 100 wetlands totaling some 6,200 acres. This compares to 59 wetlands identified by background work done for the local coastal programs in the late 1970's to early 1980's. Further, although delineation maps are available for some wetlands, there is no single, easily accessible repository. For coastal managers, improvements in access to information which identifies wetland resources could improve wetland protection.

ReCAP encountered a range of informational requirements for projects proposed in and adjacent to wetlands. The California Environmental Quality Act (CEQA) requires biological analysis, but its guidelines do not address specific wetland parameters. Furthermore, approximately one-third of coastal permit applications involving the region's wetlands are exempt from the CEQA provisions. Inconsistent information makes it more difficult for coastal managers to assess a single project's affect on a wetland system.

After development is authorized, ReCAP found that requirements for compiling mitigation and restoration information varied. Of the 20 development projects which required monitoring, all contained varying requirements: time periods were not standard (generally 5 years or less); the content of monitoring reports frequently did not contain specific goal statements, baseline conditions and descriptions of historic changes; and application and monitoring reports typically presented only project-specific information rather than information from the overall wetland system.

ReCAP also found that formalized coordination among agencies and formal structures for sharing of information and expertise was not evident. Varied accessibility to expertise as well as available information and data has resulted in an uneven approach to using relevant information. However, efforts to improve information sharing have begun in the pilot region. The Association of Monterey Bay Area Governments (AMBAG) is currently developing a water quality program called the Coastal, Aquatic and Marine Projects Information Transfer System (CAMPITS), which will improve access to information for the Monterey Sanctuary. The Commission has also initiated the Monterey Bay Initiative to help integrate programs and share information within the Monterey region.

To understand and address cumulative impacts and to recommend and evaluate mitigation, it is necessary to understand the complete wetland system, defined by the watershed. ReCAP found most project analysis focused almost entirely on the individual project and site. Few projects contained analysis of potential cumulative impacts beyond the individual site.

Developing mechanisms to make it easier for coastal managers to analyze a project within the context of the entire watershed, and to more easily use mapped wetland information and consistent data on regulatory actions, morphology, water quality, biodiversity, and other basic wetland attribute information will help address cumulative impacts. On a regional level, improvements in the flow of information can lead to its use in setting priorities for wetland and watershed improvement initiatives, as well as to identify gaps to be addressed by future research.

A Comprehensive Wetland Planning Framework will Improve Management of Cumulative Impacts

ReCAP found that a more comprehensive planning and management framework is needed to effectively address cumulative impacts to wetlands. This is particularly true for the impacts of activities occurring outside the coastal zone but affecting wetlands within the coastal zone.

A number of previous and ongoing planning efforts are available to serve as models for the type of comprehensive management that can better address cumulative impacts. These efforts have been occurring at several geographic scales, and each has its own unique advantages and disadvantages. Because ReCAP's focus has been on program improvements to the CCMP, these evolving models were not fully evaluated; however, they deserve mention because they appear to offer significant benefits for cumulative impact management not available in permit-by-permit review.

At the regional level, no framework currently exists to address cumulative impacts to wetlands. However, one regional effort -- Monterey Bay Marine Sanctuary's Integrated Coastal Management (ICM) process -- although currently focused on water quality issues, could be expanded and used to coordinate regional wetland planning and management. Through the ICM process, the various agencies with wetland management responsibilities could gather and disseminate information on the region's wetlands and watersheds, identify and prioritize problems from a regional perspective, and guide the implementation of regional solutions to address those problems.

At the watershed level, there is also no uniform structure to address cumulative impacts to wetlands. However, ad hoc structures are forming to address problems in individual watersheds. Watersheds may be the most appropriate scale to address activities, uses, and growth patterns that affect wetland hydrology and, to some extent, biodiversity.

To date, one watershed plan has been completed in the region. The San Lorenzo River Watershed Management Plan addresses water resources, erosion and sedimentation, flood hazard, water quality, fishery resources, vegetation and wildlife resources, recreation, and scenic and historic resources. Although it did not originally contain a specific wetland component, one was developed in a subsequent process. The North Monterey County Land Use Plan was partially based on a watershed analysis to limit sedimentation into Elkhorn Slough. Watershed planning programs are in the formative stages for Soquel Creek, Pajaro River, and Elkhorn Slough. Watershed issues are also receiving attention in the planning for a new dam on the Carmel River. Four wetland based management plans, including the one for Elkhorn Slough and two under preparation, contain some provisions which address activities beyond, but affecting, wetlands proper.

At the individual wetland level, wetland planning has been extensive but has occurred without the benefit of a uniform structure to address cumulative impacts. Instead, the content, structure and quality of wetland management plans vary widely. Wetland plans provide an opportunity to comprehensively and specifically address issues for each individual wetland including regulation, management, acquisition, restoration, enhancement, and monitoring.

To date, 19 wetland plans (some covering multiple wetlands) have been or are being prepared in the ReCAP region. However, ReCAP found these plans are far from comprehensive. On average, these plans cover only half of the topics important to wetlands planning. Better guidance regarding the contents of wetland management plans would greatly improve their quality. In addition, some mechanism is needed to incorporate these wetland plans into LCPs and the CCMP; currently, they have little binding authority and so are under-utilized as a management tool.

At the jurisdictional level, land use planning is universal, but its ability to address comprehensive wetland issues is limited. This is especially true where wetlands (or watersheds) straddle jurisdictional boundaries.

Local coastal programs in the ReCAP region were prepared in the early 1980's, prior to completion of most wetland management plans. While several LCPs called for wetland management plans, no explicit criteria were provided to guide the content or structure of such plans. Santa Cruz City is the only jurisdiction to have formally incorporated policies and excerpts from its completed wetland management plans into its LCP.

A fifth geographical scope relevant to wetlands is natural communities. While conservation plans for individual species have been around for a long time -- one was prepared for the Santa Cruz long-toed salamander, for example -- recent state legislation has created a process for enlarging the scope of such planning to encompass distinct natural areas that are home to a group of species.

Regardless of which scale is used, in order to effectively address cumulative and secondary impacts in wetland management, ReCAP found that program improvements to guide wetland planning should include measures to identify management responsibilities and authorities. This raises issues regarding the role of private ownership in protective stewardship, the role of public works departments which manage wetlands, and actions by upstream authorities outside the coastal zone. Appropriate and capable management authorities should be part of management planning to improve wetland management.

INFORMATION MANAGEMENT

In order to manage cumulative impacts more effectively, the Commission needs to be able to manage information more effectively. By definition, analyzing cumulative impacts requires the ability to synthesize information from previous, on-going and foreseeable future projects, and then to apply that information to understand how an individual project contributes to overall resource trends. To do this, Commission analysts need to be able to access and synthesize more information than may be available in any single permit application. Efficient access to such information is currently lacking.

Better information management would also enable the Commission to implement strategies beyond permit review for managing cumulative impacts, including helping local governments keep their LCPs up-to-date, and playing a bigger role in guiding the development of regional plans. Instead of relying 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 proactive programs to prevent and reverse resource degradation.

Easier Access to Information is Needed

Currently, information about coastal resources and past development projects is not readily available for permit analysts to use in assessing development proposals and impacts on resources from those proposals. As a result, cumulative impact assessment and management is difficult to incorporate into the Commission's or local government's day-to-day permit reviews.

Information about resources that is available generally does not provide a complete picture of the resources over time. Historic data can sometimes be obtained from LCPs; current information about resources is often limited to information available in recent permit applications. Thus, knowledge about the resources tends to be patchy, both geographically and across time. In some cases, when new information is available older information is discarded. Yet this older information is critical for tracking long-term trends. When information is available over time, it is often difficult to use for trend analysis because it has been collected using a variety of inconsistent methods. Even basic information about impacts on resources, such as acres of wetlands filled or miles of beach armored, is not kept in any organized fashion by the Commission or local governments.

Fortunately, the Commission is making progress in improving its information management, particularly through the upgrading of computers and through ReCAP's efforts to create easily accessible databases and information tracking systems. The latter have built upon previous work done as part of the development of the Commission's Coastal Resource Information Center. The databases developed by ReCAP should be finalized and transferred to all the District offices and made available to local governments. Developing procedures for entering resource information from technical reports will further improve the accessibility of information. Through the ReCAP project, this compilation of information has been achieved for the pilot region. Ultimately, a Geographic Information System (GIS) system should be developed for the Commission; such a system would further improve analysts' abilities to assess cumulative impacts by integrating a spatial component that must currently be added manually.

A Computerized Tracking System Would Improve Permit Condition Compliance

Permit conditions are a primary impact management tool used in California's Coastal Management Program. For certain types of projects -- e.g., those affecting wetlands -- permitees are often required to submit reports substantiating the effectiveness of their mitigation efforts. In its analysis, ReCAP found that no agency-wide system is in place to track compliance with such conditions. As a result, in the ReCAP region, one third of the wetland mitigation monitoring reports required under permit conditions could not be found. When this occurs, not only is the mitigation potentially compromised, but an important source of basic information about the affected wetland is lost.

A computerized tracking system currently being developed by ReCAP staff should help address this problem by alerting analysts when post-permit condition compliance items -- such as mitigation monitoring reports -- are due. Data collected from such monitoring reports can then be entered into resource databases (also developed by ReCAP) to help the Commission keep track of resource trends.

Information Sharing Between Agencies Will Improve Coastal Management

Because the Commission shares responsibility for managing coastal resources with numerous other agencies, including local governments, information exchange between agencies is crucial. Currently, few formal mechanisms exist in the region to exchange information about coastal resources or management activities. As a result, resource agencies are not always aware of information that is available from other agencies, and data collection efforts are sometimes duplicated.

Three initiatives have recently been developed to address the need for regional information sharing. One is the Commission's "Monterey Bay Initiative", in which regional resource managers meet periodically to exchange information about ongoing projects and explore opportunities for collaboration and data sharing. A second is the Integrated Coastal Management process discussed earlier in the wetlands section, which includes efforts to collect, synthesize, and distribute relevant information.

The third initiative is the Coastal Aquatic and Marine Projects Information Transfer System (CAMPITS) administered by AMBAG. 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 resource agencies, finding out what GIS information they have, how it is formatted, and what data "layers" they think should be in a regional GIS. CAMPITS is also coordinating the establishment of GIS data standards to ensure that data from throughout the region can be shared.

In order to further enhance information sharing among agencies, data sharing protocols and agreements need to be developed that resolve technological compatibility problems and address data ownership issues. With improved technologies and better information sharing, the Commission will be better able to incorporate regional and cumulative perspectives in its permitting work, in its assistance to local governments, and in its coordination with other agencies.

ECONOMIC EFFECTS OF RECAP RECOMMENDATIONS

Many of the recommended improvements in the ReCAP report can be implemented with minimal costs through minor changes in ongoing activities of coastal analysts. Other recommendations, such as modifying policies or procedures, developing management plans and undertaking technical studies, will have more significant costs associated with them. However, implementing these recommendations will generate information and strategies that will clarify and make the coastal permitting process more efficient for applicants. These improvements can also lead to increased government coordination and more efficient use of limited resources.

RECOMMENDATIONS FOR PROGRAM IMPROVEMENTS

Note: The following recommendations are not weighted as to priority or importance. Rather, ReCAP identified initial and longer-term recommendations.

HAZARDS MANAGEMENT

Initial Program Improvements

1.0 Regional shoreline erosion and bluff retreat management plans should be developed to help guide state and local planning and permitting efforts along the shoreline. To advance this goal, guidelines should be prepared containing the following elements:

  1. methods for defining, identifying and mapping of high coastal hazard areas along the coastline, including delineating and mapping "regional" and "sub-regional" areas considering, but not limited to, factors such as geology, wave conditions, and sand budget situation.
  2. a standard alternatives feasibility analysis worksheet that would be an element of all hazard response projects to help assure that hard protective devices are allowed only in situations where less permanent or intrusive efforts will not be effective.
  3. standard permit conditions and monitoring requirements to mitigate adverse resource impacts.
  4. analysis of the utility of general engineering plans for armoring options which would be acceptable for specific areas.

2.0 Regional shoreline erosion and bluff retreat management plans should contain a component for guiding issuance of emergency armoring permits. To address this, procedural guidance for the development of these emergency response plans should be developed. Guidelines should contain the following elements:

  1. analysis of the utility of general engineering plans for different types of armoring which would be acceptable for specific areas and would accommodate the potential for redesign and/or removal.
  2. standard conditions and monitoring procedures including formal removal process for structures placed under emergency conditions.

3.0 Guidance for expanding development setbacks for ReCAP area LCP jurisdictions from the current 50-year economic lifetime to either 75-year or 100-year lifetimes should be developed, including:

  1. the development of mapped 75-year and 100-year setback lines making use of long-term average annual erosion rates.
  2. mechanisms for updating mapped 75-year and 100-year setback lines.
  3. procedures for managing development within the mapped setback zones.

Longer Term Opportunities

4.0 Regional shoreline erosion management plans should eventually be supplemented with regional programs and guidelines for managing and expanding shoreline sand resources, including such mechanisms as aggressive beach nourishment. Guidance to help develop these programs should be provided.

5.0 Guidance for including other coastal hazards constraints (such as tsunamis, earthquakes, fires, flooding, etc.) into the regional shoreline erosion and bluff retreat management plans should be developed as information on these hazards becomes available.

6.0 Guidance for the development of strategies to address development constraints in areas of high coastal hazards should be developed, including, but not limited to:

  1. procedures on the use of waivers of public liability.
  2. structural design criteria that allows for easily movable structures.
  3. procedures for full permit review of structures damaged by erosion and bluff retreat.
  4. acquisition strategies for privately-held coastal lands.
  5. guidance for transfer of development credit programs or other alternative measures in high hazard areas.

7.0 Research which examines the public subsidy of private development along the coastline due to coastal hazards and the implementation of the Federal Emergency Management Agency process and disaster relief funds should be encouraged.

Opportunities for Long-Term Regulatory Improvements

8.0 Pursue amendments to Section 30235 of the Coastal Act to:

  1. require all shoreline protection be reviewed for compatibility with existing regional conditions.
  2. limit the permitting of permanent shoreline protective devices to include only the main development on the property (excluding minor buildings, ancillary structures, etc.) and to development which had occurred and for which there was an issued building permit as of the effective date for the amendment. No permanent shoreline protective device would be permitted for development receiving a building permit after the effective amendment date.

9.0 Pursue modifications of Section 30253 of the Coastal Act to add a requirement that specifies that all new development be sited and designed to avoid, over the full life of the development, the construction of any type of shoreline armoring that would prevent or hinder natural shoreline erosion and bluff retreat.

10.0 Pursue modifications of Section 30610 of the Coastal Act to:

  1. prohibit any remodeling project adjacent to an eroding coastline regardless of size, from expanding seaward of the new development setback line.
  2. encourage relocation of structures damaged by ocean waves or erosion to a less hazardous portion of the site, preferably landward of the long-term setback.

PUBLIC ACCESS

Initial Program Improvements

1.0 Revise Commission and local government procedures to improve the efficacy of existing mitigation measures, including measures to ensure recordation of all offers to dedicate prior to issuance of permits.

2.0 Monitoring procedures should be improved, including:

  1. procedures to develop, maintain and share access databases among recreation providers, including information on offers to dedicate access easements.
  2. procedures to track visitor and beach use.
  3. guidance to establish baseline and on-going monitoring in areas where access and sensitive resources exist.

3.0 Guidance to improve permit review procedures should be developed. This should address:

  1. measures for obtaining State Lands Commission determination of the boundary of public and private lands as part of filing requirements.
  2. guidance for considering cumulative impacts in the determination of whether access mitigation is exempt due to sensitive resources, public safety or adequate access nearby.

4.0 Through implementation of the Hazard Management Recommendations, revise procedures to reduce the amount and encroachment of shoreline armoring and to address emergency authorizations for shoreline protective devices.

5.0 Within the Pilot region:

  1. Revise Santa Cruz City and County LCPs to modify standards for the type and design of shoreline protective devices to minimize encroachment.
  2. Modify the Del Monte Forest segment LCP to require policies that shoreline protective devices minimize impacts to access.

6.0 Provision of additional support facilities should be encouraged by:

  1. Revising Commission procedures and LCPs to increase joint-use of commercial and other private parking for beach use.
  2. Developing guidelines for review of preferential parking proposals, including requiring baseline parking and user inventories prior to implementation, avoiding additional preferential parking programs absent accompanying public parking or transit expansion, and requiring monitoring of parking resources.
  3. Designating additional sites for upland parking and support facilities in LCPs.
  4. Revising Commission procedures and LCPs to incorporate in-lieu fee programs for parking, transit, and shuttle programs.

Longer Term Opportunities

7.0 Develop a regional strategy for improving mitigation of access impacts, including accepting and opening all lateral Offers to Dedicate easements, identifying priorities for accepting and opening existing vertical Offers to Dedicate easements, and for requiring new access mitigation through OTDs.

8.0 Guidance for alternative mitigation programs should be developed including:

  1. guidance for developing in-lieu fee programs or other mechanisms for the operation and maintenance of existing easements.
  2. guidance for increasing use of beach replenishment as alternative mitigation to shoreline protective devices.

9.0 Access management plans should be developed for recreation areas with sensitive habitat or species. Guidance for plans should include measures that ensure that management measures are put in place prior to increase in public access within these areas.

10.0 Provide guidance for inclusion of access management components in wetland management plans should be developed.

11.0 Encourage additional research on recreation demands and changing demographics by:

  1. sponsoring a workshop, focus groups or other discussions with community groups and recreation providers.
  2. encouraging survey research specifically addressing the issue of demographics and barriers to public access and use.

WETLANDS

Initial Program Improvements

1.0 Revise Commission permit procedures and implement LCP amendments where necessary to improve identification and protection of wetland resources by incorporating:

  1. standard wetland delineation techniques and habitat classifications including riparian areas based on the Cowardin method in permit application filing requirements.
  2. standard requirements for biological information required as part of filing for wetland projects.
  3. standard procedures for measuring and monitoring wetland biodiversity.
  4. common identification of specific and aggregated wetlands and watersheds.

2.0 Revise Commission permit procedures and implement LCP amendments where necessary to improve mitigation and monitoring procedures by developing:

  1. revised monitoring and evaluation procedures for condition compliance for permits in and adjacent to wetlands, including criteria for determining success of mitigation and restoration.
  2. interim mitigation and monitoring measures based on the U.S. Army Corps of Engineers' "Habitat Mitigation and Monitoring Proposal Guidelines".
  3. standardized monitoring procedures as a condition of development activities affecting water quality.
  4. review forthcoming Project of Special Merit Wetlands Performance Standards for potential measures to implement mitigation guidance.
  5. a guidance document for restoration projects, including guidance for goals and objectives, allowable uses and standards for implementation.
  6. measures for assuring recordation of wetland and buffer easements and for identification of appropriate management authorities.

3.0 Improve information sharing and access to expertise by:

  1. finalizing and distributing the ReCAP wetland and permit databases.
  2. implementing procedures to improve tracking mitigation projects, including conditions, easements, and deed restrictions.
  3. developing a Wetland Inventory.
  4. developing interagency agreements with the Department of Fish and Game and the U.S. Army Corps of Engineers to review and monitor wetland projects, to share technical staff to review EIRs and biotic reports with wetlands issues, and to try to achieve consistency in criteria for evaluating development in wetlands.
  5. developing a training program for Commission and local staff on wetland and watershed management.

4.0 Revise and formalize Commission enforcement procedures to improve enforcement of unauthorized development in wetlands and to increase condition compliance on wetland projects requiring monitoring.

5.0 Develop standard conditions, guidelines or agreements with other regional agencies for a consistent approach to, and alternatives to, breaching river and creek lagoon mouths.

6.0 Revise Commission permit procedures and develop LCP amendments where necessary to ensure that local native plant species are required in all restoration projects.

7.0 Revise Commission permit procedures and LCPs to:

  1. require evidence of U.S. Army Corps of Engineers and Department of Fish and Game permits before issuance of coastal permits.
  2. encourage participation in U.S. Army Corps of Engineers' interagency meetings.
  3. provide guidance for cumulative impact findings with regards to wetland impacts.

8.0 Develop suggested LCP amendments to:

  1. inventory and revise policies to protect wetlands which may be newly identified in cities of Pacific Grove, Marina, Seaside, Monterey and Carmel-by-the-Sea.
  2. incorporate interim 100 foot wetland buffer requirements and standards for measuring buffer areas from the outer delineated edge of the wetland or riparian area.
  3. incorporate priorities for restoration of impaired hydrology as identified by the Monterey Bay National Marine Sanctuary's watershed analysis and planning work.

Longer Term Opportunities

9.0 Within the pilot region, develop a common set of regional wetland maps based on standard delineation requirements and distribute among agencies for use in permitting.

10.0 Develop policy guidance for consolidating and enhancing small, scattered wetlands as part of mitigation for large scale development projects.

11.0 Develop guidelines and criteria for preparing Regional Watershed Management Plans and Wetland Management Plans, including criteria for land use, permitted uses, parcel size and other information. Develop measures, including incentive programs, to identify and restrict adverse grazing and agricultural activities from wetlands and buffer areas. Implement specific provisions governing urban and agricultural lands to protect hydrology within wetlands and the associated watershed, with emphasis on improving the control of erosion, sedimentation rates, and other polluted runoff. Include a strategy for restoration of historic wetlands.

12.0 Develop an interagency strategy to implement Regional Wetland and Watershed Plans. The strategy should:

  1. identify wetland and watershed systems and relationships.
  2. prioritize planning and restoration programs.
  3. seek and coordinate funding to implement strategy.
  4. develop regulatory options inside and outside the coastal zone.
  5. provide technical assistance.
  6. identify responsible entities and coordinate efforts of multiple authorities.
  7. develop procedures for periodically evaluating the effectiveness of such plans and revising them as needed.

13.0 Revise Commission procedures and implement LCP amendments to incorporate appropriate hydrologic modification criteria based on EPA's best management practices for controlling nonpoint source pollution.

Opportunities for Long-Term Regulatory Improvements

14.0 Amend the Coastal Act to:

  1. further clarify that natural vegetation removed for agricultural purposes in a wetland or wetland buffer, where the area has not been recently farmed, is development as defined by the Act.
  2. incorporate buffer area requirements.

15.0 Develop interagency mechanisms and possible legislation to incorporate a watershed approach in planning and regulation and to implement Watershed and Wetland Plans as part of the CCMP. Within the pilot region, incorporate existing and forthcoming wetlands plans into the LCPs and CCMP.

16.0 Revise Commission permit procedures to:

  1. require preparation of wetland management plans.
  2. incorporate standards for preparing and reviewing adequacy of wetland management plans developed under recommendation No. 11.0.
  3. implement provisions of existing wetland management plans.
  4. require harbor districts to complete environmental management components of harbor plans.
  5. prepare standards for assuring restoration of historic wetlands.

17.0 Develop proposed legislation or procedures to implement a coordinated, interagency wetland project review.

18.0 In addition to improvements in the planning and regulatory programs, the Commission should pursue longer term efforts designed to maximize protection of wetland resources including:

  1. developing public information programs to create public support for increased wetland acreage and to inform wetland owners of various stewardship options available to protect wetlands.
  2. implementing programs to acquire wetlands currently in agricultural use.
  3. encouraging research priorities which:
    1. assess the feasibility of restoring historic wetlands.
    2. evaluate the proposed federal unified delineation manual for application to California coastal wetlands and methods to achieve consistency among agencies.
    3. map historic wetlands.
    4. evaluate wetland restoration projects for habitat improvements and increases in number and/or abundance of species.
    5. evaluate disturbed wetland areas and land and/or water corridor requirements for target species.
    6. evaluate habitat and species abundance in scattered wetlands to assess feasibility of consolidation.
    7. compare historic wetland acreage with current land values and assess the costs of increasing wetland acreage.
    8. evaluate the success of current wetland restoration projects, in relationship to wetland systems and other existing or projected restoration projects in the system.
    9. evaluate the economic costs/benefits of mitigation projects.

INFORMATION MANAGEMENT

Initial Program Improvements

1.0 Expand the ReCAP database into an agency-wide computerized permit tracking system and complementary resource databases.

2.0 Develop guidance manuals on how to use the databases to enter and retrieve information and a set of standardized reports that speed administrative procedures and assist monitoring.

3.0 Develop procedures for tracking and making accessible environmental impact reports, technical reports, management plans and other resource-related documents that are submitted as part of the permit process.

4.0 Develop improved procedures for tracking permit conditions which require post-issuance monitoring.

5.0 Support the development of, and where necessary initiate, data sharing protocols with other regional agencies in the ReCAP area.

Longer Term Opportunities

6.0 Help local government expand their databases to include coastal permit impact information developed as part of the ReCAP database.

7.0 Develop a Geographic Information System.

8.0 Develop a coastal resource monitoring program as part of conducting other regional reviews.

9.0 Expand staffing in information management and Geographic Information System.

ENDNOTES

  1. A Local Coastal Program (LCP) consists in part of the local government's land use plans, zoning ordinances, and other implementing actions. A land use plan (LUP) is one component of the LCP, and, in part, indicates the kinds, location, and intensity of land uses, and applicable resource protection and development policies. See Coastal Act Sections 30108.5 and 30108.6 for complete definitions.

Go to the California Coastal Commission Publications list.

Go to the California Coastal Commission Home Page.