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<metadata>
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		<mainTitle nfc="0"><title>ReCAP Pilot Project</title>:<titleExt>findings and recommendations : Monterey Bay Region</titleExt>/<respStmt>California Coastal Commission, Regional Cumulative Assessment Project.</respStmt></mainTitle>
		<titleVariant type="portion"><title>Findings and recommendations : Monterey Bay Region</title></titleVariant>
	</titleStmt>
	<authorStmt>
		<corpAuthor><name>California Coastal Commission.</name><subName>Regional Cumulative Assessment Project.</subName></corpAuthor>
		<corpAuthor><name>California Coastal Commission.</name></corpAuthor>
	</authorStmt>
	<imprint>[<pubPlace>San Francisco</pubPlace>] :<pubName>The Commission</pubName>,[<pubDate>1995</pubDate>]</imprint>
	<classStmt>
		<locClass>
			<subject cat="top">Coastal zone management</subject>
			<subject cat="geo">California</subject>
			<subject cat="geo">Monterey Bay.</subject>
		</locClass>
		<locClass>
			<subject cat="top">Cumulative effects assessment (Environmental assessment)</subject>
			<subject cat="geo">California</subject>
			<subject cat="geo">Monterey Bay.</subject>
		</locClass>
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<text xml:space="preserve">
<pb n="1" />

       HT
       393
       .C2
       R44
       1995
<pb n="2" />

                                                                                                          EXHIBIT I

                                                                      ReCAP Pilot Project
                  JON 16 log  I                                       Findings and
                                                                      Recommendations:
                                                                      Monterey Bay Region

               Pt. Amo
                Nuevo                        S   A   N   T A

                                Bonn
                                Doon
                       Davenport                                                        7      Study Area
                                                  an a Cruz     Socluel                         Location

                                                             opitola
                    13;w C-@                         Pt. Santa Cruz                 Watsonville
                                                                                               '@Aromas

                                                                        Moss
                                                                        Landing
                                                             Y                              Prunedale
                                   'Z@                                 Salinas      Costroville
                                    C"),                               River P

                                                                              arina          0  Salinas
                S   DEPARTMENT OF COMMERCE NOAA            pt. Pacific      Fort Ord
             COASTAL SERVICES CENTEIR                     Pinos Grove    Sand City     M 0 N      T E R E       Y
             2234 SOUTH HOBSON AVENUE                                   Seaside
             CHARCESTON , SIC 29405-2413 Cypress Pt.                 onterey                        IV
                                                        Carmel   Carmel
                                                         'Fasl
                                                     Pt. Lobos

                                                                                            Scale 1:500,000
          California Coastal Commission                                                  1 inch equals approximately 8 miles
                                                                                          0                   10
          Regional Cumulative Assessment Project                                                    Miles
          September, 1995                                                                         Sfudy Area
                                                                                                                  JVC. ACH, 9/95

                                                            Property of CSC Library
<pb n="3" />

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

                  With assistancefrom.-                                   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 Hilt, Cartographer

                          This report was prepared with fmancial assistance firom 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                        Rick Hyman
                          Manager, Land Use Unit                          Coastal Planner
                          California Coastal Commission                   Central Coast District
                          45 Fremont Street, Suite 2000                   725 Front Street, Suite 300
                          San Francisco, CA 94105                         Santa Cruz, CA 95060
                          (415) 904-5280                                  (408) 427-4863
<pb n="4" />

                                                                     TABLE OF CONTENTS

                              1. INTRODUCTION                  ..........................................................................................................1

                              THE COMMISSION'S STRATEGY                          ..............................................................................................I
                              THE RECAP PILOT PROJECT                      ......................................................................................................2
                              THE RECAP REPORT                 ....................................................................................................................3

                              2. RECAP AREA REGIONAL OVERVIEW                                        .................................................................5

                              REGIONAL SETTING                 ....................................................................................................................5
                              POPULATION            .................................................................................................................................6
                              LAND USE          ......................................................................................................................................7
                              SUMMARY           ................................................................................................................................... 10

                              3. COASTAL HAZARDS                       ................................................................................................ 13

                              SUMMARY           ................................................................................................................................... 13
                              BACKGROUND               ............................................................................................................................ 13
                              LACK OF REGIONAL CONSISTENCY FOR AREAS PRONE To SHORELINE EROSION                                            ....................... 24
                                 Analysis    ................i..................................................................................................................... 24
                                 Recommendations           ....................................................................................................................... 27
                              IMPACTS To ACCESS FROM ARMORING ARE OFTEN OVERLOOKED                                       ............................................. 28
                                 Analysis    ....................................................................................................................................... 28
                                 Recommendations           ....................................................................................................................... 29
                              LACK OF ANALYSIS ASSOCIATED WITH THE EMERGENCY SHORELINE ARmORING PROCESS                                                   ..... 30
                                 Analysis    ...................................................................................................................................... 30
                                 Recommendations           ....................................................................................................................... 32
                              INADEQUACY OF THE ExiSTING SETBACK METTIODOLOGY AND FRAMEWORK                                             ........................... 32
                                 Analysis    ...................................................................................................................................... 32
                                 Recommendations           ....................................................................................................................... 35
                              FUTURE PLANNING AND MANAGEMENT OF COASTAL HAZARDS                                     .................................................. 36
                                 Analysis    ...................................................................................................................................... 36
                                 Recommendations           ....................................................................................................................... 38

                              4. PUBLIC ACCESS                 ........................................................................................................ 41

                              SUMMARY           ................................................................................................................................... 41
                              BACKGROUND              ............................................................................................................................ 41
                              IMPROVEMENTS ARE NEEDED IN THE IMPLEMENTATION OF ACCESS MITIGATION                                            ...................... 46
                                 Analysis    ...................................................................................................................................... 49
                                 Recommendations           ....................................................................................................................... 52
                              IMPROVING MITIGATION OF SHORELINE PROTECTIVE DEVICES                                 ................................................... 53
                                 Analysis    ...................................................................................................................................... 53
                                 Recommendations           ....................................................................................................................... 55
                              CONFLICTS BETWEEN PUBLIC ACCESS AND THE PROTECTION OF SENSITIVE RESOURCES ARE
                              INCREASING        .................................................................................................................................... 55
                                 Analysis    ...................................................................................................................................... 55
                                 Recommendations           ....................................................................................................................... 58
                              CUMULATIVE IMPACTS To REACHING THE COAST                             ....................................................................... 58
                                 Analysis    ...................................................................................................................................... 58
                                 Recommendations           ....................................................................................................................... 61
<pb n="5" />

                            RESPONDING To CHANGING ACCESS DEMANDS AND DEMOGRAPHICS                                                               ........................................ 61
                                Analysis       .......................................................................................................................................    61
                                Recommendations                .......................................................................................................................    63
                            FUTURE MANAGEMENT OF CUMULATIVE IMPACTS To ACCESS                                                         ................................................... 63
                                Analysis       .......................................................................................................................................    63
                                Recommendations                .......................................................................................................................    67

                            5. WETLANDS                    .................................................................................................................              71

                            SUMMARY                ....................................................................................................................................   71
                            BACKGROUND                    ............................................................................................................................    73
                            DIRECT LOSS OF ACREAGE, FRAGMENTATION, AND HABITAT CHANGE                                                             ....................................... 80
                                Analysis       ......................................................................................................................................     80
                                Recommendations                .......................................................................................................................    87
                            INADEQUATE PROVISION OF BUFFER AREAS                                       .................................................................................  go
                                Analysis       ......................................................................................................................................     91
                                Recommendations                .......................................................................................................................    95
                            IMPACTS To WETLAND HYDROLOGY                                   .............................................................................................  96
                                Analysis       ......................................................................................................................................     96
                                Recommendkitions               .....................................................................................................................      105
                            IMPACTS To WETLAND WATERQuALiTY                                       ....................................................................................    106
                                Analysis       ....................................................................................................................................       106
                                Recommendations                ......................................................................................................................     109
                            IMPACTS To WETLAND 13IODIVERSITY                                 ........................................................................................     110
                                Analysis       ......................................................................................................................................     110
                                Recommendations                .................................................... I .................................................................   113
                            INFORMATION GAPS IN DECISION-MAKING PROCESS NEED To BE ADDRESSED                                                                   ........................   114
                                Analysis       ....................................................................................................................................       114
                                Recommendations                .....................................................................................................................      120
                            COMPREHENSIVE WETLAND PLANNING FRAmEwoRK Is ABSENT                                                          ..............................................    124
                                Analysis       ....................................................................................................................................       124
                                Recommendations                .....................................................................................................................      130

                            6. INFORMATION MANAGEMENT                                                .........................................................................            147

                            SUMMARY                .................................................................................................................................      147
                            BACKGROUND                    ..........................................................................................................................      148
                            EASIER ACCESS To INFORMATION Is NEEDED                                       ............................................................................     150
                                Analysis       ....................................................................................................................................       151
                                Recommendations                .....................................................................................................................      152
                            AN IMPROVED SYSTEM FOR TRACKING PERMIT CONDITIONS SHOULD BE IMPLEMENTED                                                                           .........   154
                                Analysis       ....................................................................................................................................       154
                                Recommendations                .....................................................................................................................      155
                            GREATER INFORMATION SHARING BETwEEN AGENCIES WOULD IMPROVE COASTAL RESOURCE
                            MANAGEMENT                ..............................................................................................................................      155
                                Analysis       .....................................................................................................................................      155
                                Recommendation                 .......................................................................................................................    156
                            ADDITIONAL STAFFING AND/OR TRAINING is NEEDED                                            ................................................................     156
                                Analysis       ....................................................................................................................................       156
                                Recommendation                 ......................................................................................................................     156
<pb n="6" />

                              7. ECONOMIC EFFECTS OF RECOMMENDATIONS                                                   ......................................... 159

                              SUMMARY            ................................................................................................................................. 159
                              BACKGROUND               .......................................................................................................................... 159
                              HAzARD REcommENDATioNs                    ..................................................................................................... 159
                              ACCESS REcoN*AENDATioNs                 ....................................................................................................... 160
                              WETLANDS RECOMMENDATIONS                     ................................................................................................. 161
                              INFORMATION MANAGEMENT RECOMNffiNDATIONS                               ................................................................... 162
                              CONCLUSION          ................................................................................................................................ 162

                              7. APPENDIX A: CHANGES IN ACCESS OPPORTUNITIES                                                     ............................ A-1

                              8. APPENDIX B: QUANTIFYING PHYSICAL ACCESSIBILITY                                                        ....................... B-1
<pb n="7" />

                                                                                                                                        M"
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                                        Because of growing concern over the ability of state coastal management programs to
                              address the impacts of cumulative growth and development, the U.S. Congress identified
                              cumulative impacts as a priority area for improving                    -CumulativeImpacts are the combined effects of a
                              coastal management programs nation-wide,                               series oIfdevelIopmcnt activities or natural effects.
                              Section 309 of the 1990 Amendments to the                              Although an individual    project @may not greatly
                              Coastal Zone Management Act (CZMA) provides                            affect the natural or human environment@ the
                              funding and oversight to guide this effort. In                         cumulative impacts created by many different
                              response to the 1990 Amendments, the Coastal                           projects over time may significantly,alter these
                              Commission completed an Assessment of the                              environments. For exa.mple@ the. conversion of.
                              California Coastal Management Program and in                           coastalibitbitatto developed land1from-arrindividual
                              March, 1992, adopted a multi-year strategy to                          project may not seem that significant: However@'.
                                                                                                     twenty years of development projects may
                              implement program improvements in several issue                        collectively: degrade: important habi   t* values.
                              areas: Cumulative and Secondary Impacts,
                              Wetlands, Coastal Hazards, and Public Access. The Coastal Commission's Regional Cumulative
                              Assessment Project (ReCAP), undertaken as a pilot project in the Monterey Bay region,
                              comprises the core of this strategy. Under ReCAP, the Commission staff assessed the
                              cumulative impacts of development on wetlands, coastal hazards, and public access in the pilot
                              region and developed program and policy recommendations to improve management of such
                              impacts. The ReCAP pilot region is defined as the coastal zone extending from the Santa
                              Cruz/San Mateo county line through Point Lobos State Park in Monterey County.

                                        Cumulative impacts are addressed and coastal resources managed primarily through
                              three major processes under the California Coastal Management Program (CCMP): coastal
                              development permitting and appeals, planning and implementation of local coastal plans (LCPs)
                              and federal consistency review. However, the existing management framework makes effective
                              management of cumulative impacts difficult. In the pilot region, seven local jurisdictions have
                              certified LCPs and therefore issue most coastal permits, with the Commission retaining only
                              limited permit and appeal authority. These jurisdictions are: Santa Cruz County, Santa Cruz
                              City, Capitola, Watsonville, Monterey County, the City of Marina, and Sand City. The
                              Commission approved amendments to these LCPs at least 58 times, many of which were project
                              related. Four jurisdictions have yet to be certified and the Commission retains jurisdiction in
                              these areas (the Cities of Pacific Grove, Seaside, Carmel-by-the-Sea, and Monterey). In addition
                              to the CCMP, other state and federal agencies have regulatory authority affecting coastal
                              resources under separate laws. Therefore, under the existing framework, multiple jurisdictions
                              have varying policies and standards in different geographic
                              areas.                                                                             Section 3 0519.5 of the GoastalAct
                                                                                                                 provides that at least once every five
                                        Recognizing these difficulties, the CCMP relies on                       year Is the Commission s    Ih.all review: every
                              the periodic review of LCPs, called for in Section 30519.5,                        certified LCP to determine whether the
                              to help reconcile multiple policies and to ensure that                             program is. being effectively: implemented.
                              policies remain effective in managing resources and                                in conformity with the policies of the
                              responsive to social and cultural changes over time.                               Coastal Act and: submit recommendations
                              However, this monitoring and program review has been                               of corrective actions, if any, to. the.local
                              accomplished in only a few cases. In the ReCAP region,                             government.
                              Santa Cruz County and Santa Cruz City completed
                              comprehensive revisions and updates to their LCPs. Monterey County is currently revising its

                                                                        CALIFORNIA COASTAL COMMISSION                                                   PAGE 1
<pb n="8" />

                 RECAP PILOT PROJECT

                 implementation ordinances. In only one case (the City of Sand City), has the Commission itself
                 looked at the combined, long term results of numerous individual permit decisions, and
                 suggested improvements to the LCPs in carrying out the goals of the Coastal Act.
                         As indicated in this report, the CCW has accomplished much in mitigating site specific
                 impacts through its review of specific development projects. However, addressing the
                 cumulative impacts of these combined projects is difficult without periodic reviews. The
                 cumulative effects of individual development proposals on the resources of the region beyond
                 the site, beyond a political jurisdiction and beyond the coastal zone are considered in only a few
                 permit reviews; such analysis is generally limited to major projects, where cumulative impacts
                 analysis is mandated by the California Environmental Quality Act (CEQA). The lack of a
                 structured information exchange among agencies further makes determining the effects of a
                 single development proposal on regional resources difficult. Regional reviews and the data
                 collection that results can provide the catalyst for better regional resource management by: 1)
                 helping coastal managers see beyond the routine review of individual sites; 2) linking individual
                 sites and development proposals to the larger regional resource trends; 3) recognizing sources
                 and impacts from both inside and outside the coastal zone; 4) developing policy and
                 intergovernmental. tools to address cumulative and secondary impacts; and 5) helping programs
                 realize their full potential to manage coastal resources.

                                                                          'NA        K         mp_
                                                                        ME`          21_@                2-0-M a
                         Through ReCAP, the Commission seeks to develop a new framework for conducting
                 regional periodic reviews throughout the coastal zone and to put in place information exchange
                 mechanisms to facilitate continued monitoring of regional- effectsof individual development -
                 proposals. As a pilot project, ReCAP identified broad coastal trends in the Monterey Bay area to
                 evaluate cumulative impacts over time that were not otherwise evident through "project by
                 project" review, analyzed the major factors contributing to the cumulative impacts, and
                 evaluated the effectiveness of coastal policies or procedures across multiple jurisdictions in
                 responding to cumulative impacts. The results of the ReCAP pilot project include
                 recommendations to improve coastal policies and procedures and -to improve implementation of
                 local coastal programs. Such improvements will enable both the C ommission and local
                 governments to better address cumulative impacts in their management of coastal resources.

                         The ReCAP team began the pilot project with a broad effort to identify regional aspects
                 of wetlands, hazards, and access most important to the region. Once these were identified, the
                 team created a framework for analyzing cumulative impacts. This framework was created by
                 developing a matrix for the three priority issue areas. The matrix identified relevant policy
                 questions, the methods and indicators by which the questions could be analyzed, the time frames
                 and pilot area locations where these questions could be analyzed, data which should be used to
                 analyze the questions, and the possible sources of data. In addition to the matrix development,
                 the team completed a regional outreach to seek suggestions for how to measure and analyze
                 these issues. Questionnaires were developed and sent to various regional parties, including
                 technical experts in the areas. The team interviewed technical experts and key local government
                 planning directors, officials and staff, and discussed issues with representatives of local
                 environmental groups. In March, 1994, the team issued its Preli in= Report on Resource
                 Status and Change, which described the current condition of the resource systems and changes
                 documented over the past 10 years. Staff circulated the document to the Commission, local
                 government and interested parties and conducted a'workshop with staff of local and regional
                 agencies and interested public. The Commission held a public hearing on April 12, 1994. In
                 addition, ReCAP staff convened a seminar of wetland specialists to provide early feedback on
                 the wetland impact analysis in May, 1994. This public input helped guide the ReCAP analysis of
                 important policy questions. In this report, the team builds upon this earlier work.

                 PAGE 2                           CALIFORNIA COASTAL COMMISSION
<pb n="9" />

                                                                                                CHAPTER 1 - INTRODUCTION

                               The data used in this project came from a variety of information sources, with the major
                       sources being Commission and local government permit actions. The ReCAP team developed a
                       database of Commission permit activities from 1983-1993 and a database of local permits from
                       1986 to 1994, supplemented with detailed information on the three issues areas. The pilot
                       project also benefited greatly from extensive and sophisticated mapping analysis developed by
                       Santa Cruz County as part of the County's Geographic Information System. In addition, the
                       ReCAP analysis provided some immediate assistance to Commission staff in ongoing review of
                       LCPs and individual permits. For example, ReCAP information was used by Commission staff
                       in working with Santa Cruz County staff on proposed revisions to the County's LCP.

                               The ReCAP pilot area has some of the most spectacular and important resources of
                       coastal California. These resources are also subject to increasing pressures from growth and
                       development. Overall, from 1970 to 1995, nearly one-quarter of a million persons were added to
                       Santa Cruz and Monterey Counties combined -- an increase of over 65%. In terms of land use in
                       Santa Cruz County and the northern portion of Monterey County, growth contributed to a 43%
                       increase in urban land uses over the past two decades. From 1983 to 1993, the Commission and
                       local government approved approximately 3,005 coastal development permits in the ReCAP
                       pilot region. Nearly one third of these (949), were issued by the Coastal Commission. These
                       Commission issued permits approved 765 residential units, 931 lodging units and over 300 new
                       lots. The implementation of the CCMP in this period saw major accomplishments. As noted
                       later in this report, the total acreage of wetland resources has not declined and major new access
                       areas and facilities were developed. However, during this time, over 2 miles of shoreline were
                       armored, impacts to wetlands were evident through changes in hydrology and the loss of buffers
                       and habitat, and the ability to use available public access sites became more constrained.

                               This document contains the results of the year-long pilot project to assess cumulative
                       impacts and to recommend improvements in coastal policy and procedures to address these
                       impacts. The document summarizes how resources have changed over time in the pilot region
                       and analyzes the factors contributing to these changes. It projects possible future trends given
                       current policies. Finally, the report outlines recommendations for program improvements in the
                       short-term and identifies longer term program opportunities in policies or procedures to better
                       manage cumulative impacts on a regional basis. The general economic effects of the
                       recommendations are considered. The recommendations are not presented in any priority, but
                       rather are organized as initial steps, some of which could be taken in the next year's work
                       program, as well as a wide range of longer term opportunities for program improvements. The
                       Commission staff recommends that the findings and recommendations of this pilot project guide
                       development and implementation of future specific program improvements and provide input to
                       review of permits and LCP amendments in the pilot area. This report can be the basis for'
                       working with local governments to develop modified policies, programs or procedures in
                       individual LCPs to better manage cumulative impacts.

                        California Coastal Commission, Developing a Regional Cumulative Assessment Processfor the California Coastal
                         Zone: Issues and Concerns, Regional Cumulative Assessment Project Working Paper No. 1, February, 1993, pg. 4.

                                                        CALIFORNIA COASTAL COMMISSION                              PAGE 3
<pb n="10" />

                                                                                                                                                                         . . . . ........... .....

                                                                                                                                                                                                                                                                     .... . . .. ...................... .

                                                                                      Evaluating the cumulative impacts of development on coastal resources requires
                                                               factoring in how the coastal zone is impacted by (and impacts) the surrounding area. While the
                                                               ReCAP area is bounded by the coastal zone in Santa Cruz and Monterey Counties, it is important
                                                               to place it within the context of the Monterey Bay region and to consider the particular
                                                               characteristics of the overall resource area of the two counties combined. In order to generate
                                                               this regional perspective, this chapter presents a brief overview of population and growth trends
                                                               in Monterey and Santa Cruz Counties. Clearly, these population and growth trends are prime
                                                               indicators of the overall increased pressure on coastal resources -- it is this cumulative pressure
                                                               over time that must be addressed within the California Coastal Management Program (CCMP).

                                                                                                                                                                                                                                                                                                                            eA

                                                                                      Monterey and Santa Cruz Counties are situated south of the San Francisco Bay area
                                                               along California's central coast. The diverse geography of the region encompasses mountains,
                                                               forests, rolling hills, agricultural lands, sand dunes and beaches. The range of natural resources
                                                               in tandem with a mild climate, world-renowned scenic vistas, and a multifaceted cultural identity
                                                               combine to make the Monterey Bay area a very desirable region in which to live and visit. The
                                                               influx of people attracted by the area's special character has also brought with it extensive
                                                               development and regional growth. Within the two-county region, the ReCAP area is defined by
                                                               the coastal zone extending from the Santa Cruz/San Mateo county line through Point Lobos State
                                                               Park in Monterey County (see Figure 2- 1). Within these borders, the ReCAP coastline stretches
                                                               83 miles and encompasses the largely undeveloped and agricultural north coast of Santa Cruz
                                                               County, the beaches in and around the cities of Santa Cruz and Capitola, a nearly unbroken 25-
                                                               mile stretch of dunes, and the rocky coastline of the Monterey Peninsula and Carmel.

                                                                                                                               Figure 2-1: ReCAP Study Area and Land Use Assessment Area

                                                                                                                                                                                                                                         WHOMIG Coaxtd COMMISSSon
                                                                                                                                                                                            ....                   Regional Cumulative Assessment Project
                                                                                                                                                                                                                          ReCAP Study Area
                                                                                                                           Nu"

                                                                                                                                                                                            . .......................................
                                                                                                                                                                               ...........         .......

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                                                                                                                                                                                                                                                                     Stua, Area
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                                                                                                                                                                                                                                    ............        ......

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                                                                                                                                                                                                                                                                                                                    J
                                                                                                                                                          CALIFORNIA COASTAL COMMISSION                                                                                                                                         PAGE 5
<pb n="11" />

               RECAP PILOT PROJECT

                      Partially isolated by the coastal ranges of the Santa Cruz and Santa Lucia Mountains, the
               Monterey Bay coastline is home to rare forests of redwoods, pines, and cypress, largely
               undeveloped dune systems, extensive slough and wetland complexes, large tracts of rare and
               endangered species habitat, as well as Monterey Bay itself. Providing opportunities for surfers,
               fishermen, divers, marine researchers, kayakers, and boaters, among others, Monterey Bay has
               long been a focal point for area residents and visitors alike. The Bay supports an extensive
               population of marine species and is site to the largest submarine canyon in North America. The
               unique grandeur of the region and its national significance was formally recognized in 1992
               when the Monterey Bay became part of the largest federally protected marine sanctuary in the
               nation (Monterey Bay National Marine Sanctuary).

                                2.                                W,015=1111W"SW@Z
                                             ZSIMIMMP!                                E
                      In analyzing the population changes impacting the project area, it would be useful to
               analyze both the population trends within the coastal zone and those of the region as a whole.
               Unfortunately, United States Census data is not kept in a manner which recognizes the coastal
               zone boundary. Because of this, and because population growth in a region will impact coastal
               resources regardless of which side of the coastal zone boundary the growth occurs, ReCAP chose
               to evaluate population growth in the overall two-county region. In fact, county-level population
               data is probably a more realistic gauge for measuring overall increased pressure on (and demand
               for) coastal resources in the ReCAP project area since these resources are used by more than just
               the coastal zone population.

                      Monterey and Santa Cruz Counties have both experienced significant growth in
               population since the early 1900s.IAs shown in Figure 2-2, nearly seven times as many persons
               lived in Monterey and Santa Cruz Counties in 1995 as did in 19301. Clearly, this transition from
               small coastal counties to growing population centers has had an overall effect on resource
               conditions in the region. More people leads to the need for more housing, more infrastructure,
               and more businesses, the development of which may result in.more resource impacts. As
               urbanization increases, the health of natural resource systems may cumulatively decline.

                                     Figure 2-2: Population of the ReCAP Counties, 1930-2010

                800,000

                700,000      E] Monterey County
                             N Santa Cruz County
                600,000

                600,000

                409000

                300,000

                200,000         . ... ...
                                                                                     259,905  283,396
                                                                             229,734
                100,000 -

                      0
                           1930    1940     1950    1960     1970    1980     1990    2000     2010

               Source: U.S. Census of Population and Housing (1930-1990); California Department of Finance January Estimates (1995); AMBAG
                    population projections (2000-2010)
                      These historical levels of population growth have been maintained since initiation of
               coastal management efforts in the early seventies.2Monterey and Santa Cruz Counties

               PAGE6                        CALIFORNIA COASTAL COMMISSION
<pb n="12" />

                                                                                           CHAPTER 2 - REGIONAL OVERVIEW

                      combined have increased by nearly a quarter of a million persons in the past twenty-five years --
                                                                      3
                      an average of nearly 10,000 persons per year.     While Santa Cruz County is much smaller than
                      Monterey County, both in terms of land area and overall population, both counties have grown in
                      population by roughly the same amount since 1970.     4 This growth represents a 65% increase in
                      persons for the two-county region; roughly equivalent to the 62% growth in California during the
                      same time period. This regional growth is impressive not. only because there are natural barriers
                      to growth (such as coastal mountain ranges), but also because there have been various growth
                      management measures put in place over the years. These restraints have ranged from legislative
                      efforts such as Santa Cruz County's Measure J in 1978 which set annual growth limits, to low-
                      growth community opposition groups, to efforts to limit the expansion of urban services and
                      infrastructure. The overall population in Santa Cruz and Monterey Counties declined for the first
                      time in 1994 due to the closure of Fort Ord. However, with Fort Ord converted to the new
                      California State University at Monterey Bay, this decline is likely to be a temporary
                      phenomenon. In fact, according to preliminary estimates, a positive population growth rate has
                                                                        a&lt; 5
                      been reestablished for the two county area in 1995.

                               Projections of future population growth show that the Monterey Bay region is expected
                      to maintain the long term growth patterns evident from the historical census figures in Figure 2-
                      2. The two counties should continue to maintain the     610,000 new persons a year pace with an
                      increase of nearly 150,000 persons by the year 2010. Should these population projections hold
                      true, Santa Cruz and Monterey Counties in 2010 would have more than double the number of
                      people as were living there when the Coastal Act was passed. Such ongoing population growth
                      will increase the regional need for housing, jobs, roads, urban services and infrastructure, water,
                      parks and recreational areas, and overall community services. For coastal counties such as
                      Monterey and Santa Cruz where the vast majority of residents live within a half-hour of the
                      coastal zone, coastal zone resources are seen as a critical element in helping to meet these needs.
                      Furthermore, -with coastal zone resources themselves attracting visitors into the region, an even
                      greater demand for services and resource pressure is likely to continue along the coast; as with
                      any finite resource, currently impacted coastal resources will likely be even more at risk in the
                      future.

                               Ongoing population growth in the ReCAP area has been mirrored by an increase in
                      urbanization for the Monterey Bay area. From historical surveys, it is clear that vegetated areas
                      and areas in agricultural production have been steadily declining in the past twenty years at the
                      hands of an ever-expanding urban and suburban landscape. Urban and suburban land use,
                      though still a relatively small proportion of the total land use area, has increased 43% in the
                      greater Monterey Bay area since 1976 (see Figure 2-3    ).7 This increase has been even more
                      pronounced in the southern portion of the greater Monterey Bay area with over three-fourths of
                      the urban and suburban acreage increase occurring in the Monterey County segment.       8 In
                      addition, though the offsetting decline in agricultural lands has been shared equally by the two
                      segments the decline in vegetated area was confined almost exclusively to the Monterey County
                      segment.4   These changes would appear to point to a more extensive urban and suburban
                      expansion in the southern portion of the Monterey Bay region. This expansion brings with it
                      increased impervious surfacing, increased human presence, and increased encroachment into
                      natural resource buffer areas (e.g., wetland and dune complexes).

                               Placing this overall urban expansion within the perspective of the CCMP and the project
                      region, ReCAP aerial photo analysis of development patterns in the coastal zone since the 1970s
                      confirms these overall urbanizing trends. 10 Within Santa Cruz County's coastal zone, most new
                      development has occurred within or adjacent to the urban services line (i.e., the boundary point
                      for such infrastructure as gas, water, and sewage hook-ups), especially in the unincorporated
                      areas of Live Oak (the area between the cities of Santa Cruz and Capitola) and the Aptos

                                                        CALIFORNIA COASTAL COMMISSION                                PAGE 7
<pb n="13" />

                 RECAP PILOT PROJECT

                 shoreline. While the Live Oak infilling occurred within an area already considerably "urban",
                 the expansion in 1984 of urban services into the Aptos area led to the conversion of large belts of
                 vegetated area into the urban landform (e.g., planned development in the Seascape area). The
                 general development pattern in Santa Cruz County's coastal zone has been a concentrated urban
                 band extending from the City of Santa Cruz southeast to La Selva Beach; very little new
                 development occurred in other areas of the County's coastal zone. This pattern appears to reflect
                 a strong adherence to Santa Cruz County's LCP goal of concentrating development in already
                 urbanized areas and protecting agricultural lands. While concentrating new development in
                 urban areas creates cumulative impacts on such coastal resources as urban wetlands that find
                 themselves slowly hemmed in by increased development, infrastructure, and population, it
                 minimizes the impacts to resources in less developed areas.

                                       Figure 2-3: Land Use Changes in the ReCAP Region, 1976-1989

                                          %    J..                                                  8.7%     10.8%

                           0 Urban
                           MAgriculture
                           0 Vegetated Area

                     82.4%    82.4%   81.9%
                                                                                           72,0%   71.4%     70.0%
                                                        64.5%    63.40%  61,3%

                     1976    1982     1989              1976    1982     1989              1976    1982      1989
                          Santa Cruz                          Monterey*                       Total Land Use
                                                                                            Assessment Area*
                 Source: DWR Quad County Summaries See Figure 2- 1)

                         In Monterey County, by contrast, ReCAP aerial photo analysis confirmed that while
                 there was significant growth in such areas as Marina and Del Monte Forest, a considerable
                 portion of new development within the coastal zone occurred in semi-rural areas of North
                 Monterey County -- especially in the areas north and east of Elkhorn Slough. This type of seini-
                 urban expansion into rural areas, largely outside the reach of urban services such as water and
                 sewer service, is clearly different from the expansion taking place in Santa Cruz County that is
                 primarily within areas that could be considered at least partially "urban". Although per acre
                 densities are low in North Monterey County, the amount of new development is sufficient to
                 warrant concern about short- and long-term cumulative affects on. nearby Elkhorn Slough. '
                 Sediments loosened during construction can end up as deposits in. the slough, and the increase in
                 impervious surfaces such as roads and rooftops will cause long-term cumulative changes in the
                 hydrology of the watershed. In addition, with most of this new development dependent on septic
                 systems for sewage disposal, there are water quality implications for nearby wetland systems.
                 The expansion of urban and suburban development into areas with high resource value
                 exemplifies the type of situation in which cumulative impacts cart easily be overlooked because
                 each individual project appears to have only minimal impacts.

                         The land use surveys and aerial photo analysis are further supplemented by CCMP
                 permitting information within the ReCAP study region for the past decade. The data show that
                 while new development pressures were widespread in the region, nearly 60% of the permit
                 activity occurred in unincorporated Santa Cruz County and the northern portion of Monterey
                 County (Figure 2-4).     With nearly 30% of all permitting activity in the region, the North
                                                      jo WII-70/o                       0 "-.01

                 PAGES                            CALIFORNIA COASTAL COMMISSION
<pb n="14" />

                                                                                       CHAPTER 2 - REGIONAL OVERVIEW

                       Monterey County LCP segment appears to have been the CCMP hotspot for development in the
                       ReCAP study area.

                               Figure 2-4: Coastal Commission and local government permitting in the ReCAP Area 1983-1993

                                     Seaside                                               _7

                                 Watsonville
                                      Marina    27                                To  I CCMP Permits    3005

                                                 '45
                                Carmel City

                               Pacific Grove      47
                                  Sand City       62
                               Monterey City       91
                                     Capitola

                            Santa Cruz C                     302
                                           ity
                         Santa Cruz County                                                905
                           Monterey County              North Monterey County (882)                    Carmel Area
                                                                                        ! 51 @_ @ (207@
                                             0        200      400       600       800      1000      1200      1400

                       Source: ReCAP Database
                               ReCAP's analysis of future development trends in the pilot region portends continuation
                       of these existing land use practices: primarily infill within Santa Cruz County's coastal zone and
                       further urban expansion into the semi-rural areas of Monterey County. 12 For Santa Cruz County,
                       a considerable amount of vacant lands zoned for urban uses (residential, commercial, industrial,
                       or government/institutional) still exist within primarily urban areas. With few urban uses
                       currently allowed for vacant parcels outside of the urban services line, growth pressures should
                       continue to be felf within the urban band extending from the City of Santa Cruz to La Selva
                       Beach. This scenario is supported by the County's own analysis showing that primary growth
                                                                                            13
                       areas should continue to be in the Live Oak and Aptos planning areas.

                               However, with a large amount of additional growth already approved in the Seascape
                       area along the southern boundary of the urban services line, there is also the potential for
                       development pressures to extend southward. In fact, ongoing pressures to develop outside the
                       rural/urban boundary line are already evident through a number of development proposals,
                       particularly in southern Santa Cruz County. While funneling development within the more
                       6urban" areas (in Live Oak and Aptos) is more protective of rural and agricultural lands,
                       development pressures outside the urban services line (southern Santa Cruz County) show that
                       these less urban areas are also at risk. Overall, this planned infilling leads to the need for
                       increased management of cumulative impacts. In urban areas, shrinking resource buffer areas,
                       increased parking demand, and overall increased shoreline use will lead to an intensification of
                       impacts to shoreline resources and public access. These potential impacts will require
                       comprehensive planning efforts focusing on defined 'systems' (e.g. public access plans, wetland
                       and watershed ecosystem planning, coastal hazard area management plans, etc.).

                               Within Monterey County's coastal zone, while limited infilling of urban areas is
                       expected, ReCAP's analysis of vacant lands in the region points to a number of areas with the
                       potential for conflicts between development and natural resources. For example, much of the
                       vacant land in the Elkhorn Slough area is zoned for residential use, albeit at low densities. With
                       good access to the job market in the Santa Clara Valley and San Jose via Highway 10 1, demand

                                                      CALIFORNIA COASTAL COMMISSION                              PAGE 9
<pb n="15" />

                     RECAP PILOT PROJECT

                     for residential development in this area is likely to continue. The Del Monte Forest LCP
                     segment also has large vacant areas planned for residential and golf course development. The
                     redevelopment of Fort Ord has the potential for creating resource conflicts on large remnants of
                     native habitats as well as on beaches and bluff areas that had heretofore been closed to public
                     access. The dune habitats of the county are also at risk, with the largest areas of undeveloped
                     shoreline in the ReCAP region zoned for urban uses located in the shoreline dunes of the Cities
                     of Marina and Sand City. Given the fragile nature of these resource systems, a high priority in
                     the southern portion of the ReCAP region should be placed on developing policies that manage
                     and/or avoid cumulative impacts within sensitive areas (e.g., refining performance criteria for
                     particular resource systems, developing management plans for particular resource areas,
                     directing development away from sensitive areas, etc.).

                                                                                                     "K,
                                                                                                                @p
                                                                                                                 , %,,
                     Is-                                                                             211 - M-1-11,
                              The population figures for the Monterey Bay region demonstrate that there has been
                     substantial historical growth in Santa Cruz and Monterey Counties with projections indicating
                     that this growth will continue in the future. The two counties' combined population increased
                     nearly seven-fold since the early 1900s, with an increase of nearly one-quarter of a million
                     persons since 1970 alone. Future population projections estimate that this rate of increase of
                     nearly 10,000 persons per year will be maintained, with nearly 150,000 new persons being added
                     to the two county region by the year 2010. This ongoing population growth highlights the
                     regional need for increased housing, jobs, roads, urban services and infrastructure, water, parks
                     and recreational areas, and other community services. With coastal zone resources seen as a
                     critical element in helping to meet these regional needs, individual LCPs must be able to address
                     these regional, 'greater than local' needs.

                              In terms of overall development trends, an increasing populace has contributed to a 43%
                     increase in the urban landforTn for the greater Monterey Bay area over the past twenty years.
                     Within the coastal zone of Santa Cruz County, this development appears to have been primarily
                     concentrated in existing urbanized areas within the urban services line. For Monterey County's
                     coastal zone, a considerable amount of development appears to be: due to urban expansion into
                     semi-rural areas in and around Elkhorn Slough; CCMP permitting history shows that nearly 30%
                     of all permits issued in the past decade in the ReCAP area were issued in the North Monterey
                     County LCP segment. In terms of future trends, Santa Cruz County's coastal zone can expect
                     development to be funneled to areas within the urban services lint. in the Live Oak and Aptos
                     planning areas. For the coastal zone in Monterey County, areas of potential growth appear to be
                     in and around areas of coastal resources such as wetlands, dunes, and forests. While there are
                     different policy implications for these differing development trends within the two counties,
                     incorporating management of both resource 'systems' and cumulative impacts into LCP policy is
                     crucial for ongoing resource protection in the Monterey Bay area.

                      These population figures are developed from: 1) for 1930-1970, U.S. Census of Population and Housing as found
                      in California Statistical Abstract. California State Senate, published 1958, 19,70, and 1971; 2) for 1980 and 1990,
                      U.S. Census of Population and Housing as found in Annual Planning Information Santa Cruz Metropolitan
                      Statistical Area 1993 and Annual Planning Information Salinas-Seaside-Monterey Statistical Area 1993. California
                      Health and Welfare Agency, Employment Development Departmen@ Labor Market Information Division, 1993; 3)
                      for 1995, population estimates from City and County Summary Report ofJanuary Population and Housing, Report
                      E-5, State of California, Department of Finance, Demographic Research Unit, 1995; 4) for 2000 and 2010,
                      population projections from 1994 Regional Population &amp; Employment Forecast. AMBAG, 1994.
                     2Proposition 20, the Coastal Initiative (1972) and the California Coastal Act (1976).
                     3Monterey and Santa Cruz Counties' combined population increased by 242,360 persons from 1970 to 1995 (an
                      average of 9,694 persons per year). These figures developed from: 1) for 1970, U.S. Census of Population and
                      Housing as found in California Statistical Abstract 1971. California State Senate, 1971; 2) for 1995, population

                     PAGE 10                               CALIFORNIA COASTAL COMMISSION
<pb n="16" />

                                                                                                      CHAPTER 2 - REGIONAL OVERVIEW

                            estimates from City and County Summary Report ofJanuary Population and Housing, Report E-5. State of
                            California, Department of Finance, Demographic Research Unit, 1995.
                           4Ibid. Santa Cruz County's population increased by 118,8 10 people while Monterey County's population increased
                            by 123,550 people from 1970 to 1995.
                           5Monterey and Santa Cruz Counties' combined population decreased by 2,693 persons from 1993 to 1994 and
                            increased by 3,759 persons from 1994 to 1995. Population estimates for 1993, 1994, and 1995 from City and
                            County Summary Report ofJanuary Population and Housing, Report E-5. State of California, Department of
                            Finance, Demographic Research Unit. Published 1993, 1994, 1995.
                           6Monterey and Santa Cruz Counties combined population is expected to increase by 148,419 persons from 1995 to
                            2010. These figures developed from: for 1995, population estimates from City and County Summary Report of
                            January Population and Housing, Report E-5 Ibid. For 2000 and 2010, population projections from 1994
                            Regional Population &amp; Employment Forecast. AMBAG, 1994.
                           7Based on California Department of Water Resources (DWR) land use surveys from 1976, 1982, 1989. While DWR
                            is primarily interested in water-management related land use categorizations that generally focus on agricultural
                            breakdowns, the figures also allow for a gross characterization of the urban landform. ReCAP has chosen to analyze
                            a land use area slightly larger than the coastal zone in Monterey and Santa Cruz Counties in order to place land use
                            issues within the regional context. The ReCAP land use area results in a total acreage breakdown that encompasses
                            all of Santa Cruz County and 18.5% of Monterey County (See Figure 2- 1).
                           8Ibid. Monterey County accounted for 16,704 (or 75-71/6) of the 22,075 acres converted to the urban landform from
                            1976 to 1989 in the ReCAP land use area.
                           9Ibid. Santa Cruz County accounted for only 1,337 (or 9.01/6) of the 14,788 acres of vegetated area lost from 1976 to
                            1989 in the ReCAP land use area.
                           10 ReCAP photo-analysis based on 1978 and 1993 aerial photographs of the coastal zone in Monterey and Santa Cruz
                            Counties.
                           I IReCAP Database, Administrative and Local Permit Sub-modules; for an in-depth discussion of the CCMP
                            permitting history in the ReCAP study region, see: Lester, Charles. Draft Coastal Development Permittingfor the
                            Monterey Bay Region Status and Trends Report 1973-1993. California Sea Grant Program, 1994.
                           12 Through the ReCAP aerial photo analysis, vacant lands were identified and compared with current zoning and
                            general plan/LCP policies on a parcel by parcel basis.
                           13 Over 6,600 additional housing units are possible at build-out within the urban services line, mostly in the Live Oak
                            and Aptos planning areas. As detailed in County ofSanta Cruz General Plan Update Background Report,
                            Preliminary Draft. Santa Cruz County Planning Department, Fall 1991.

                                                               CALIFORNIA COASTAL COMMISSION                                      PAGE 11
<pb n="17" />

                              This chapter summarizes ReCAP's investigation of shoreline hazard response
                      protection of upland development by armoring, the permitting associated with existing armoring,
                      the impacts from armoring, the policies which address shoreline protection, and the likely
                      changes which will happen to the shoreline in the future assuming existing trends and policies
                      continue. A major finding of this effort is that current coastal policies support the use of public
                      shoreline and public resources to protect private property and if the current situation continues,
                      more and more of the public shoreline will be lost as a public resource. While only an eighth of
                      the ReCAP coastline is now armored, over a third of the ReCAP coastline has the land use and
                      physical characteristics which could require armoring in the future. None of this includes the
                      shoreline already protected by groins, jetties and breakwaters. There are substantial portions of
                      coastline which can be affected by the land use and armoring policies which are in effect.

                              Most property owners consider shoreline armoring only after they perceive a threat to
                      their development and believe that without annoring, their home or business will be damaged or
                      destroyed. In many cases, the hazards posed by storms and coastal erosion can be serious.
                      Statewide, on average, shoreline hazards cost $100 million annually, either from damage due to
                      storms and erosion,Ior for shoreline armoring and modification designed to protect against
                      storms and erpsion. Breakdown for the ReCAP area is not available; however, a substantial
                      amount of public and private funds are being expended routinely to address coastal hazards.

                              The ReCAP Coastal Hazards team examined in detail the concerns that: (1) there is no
                      consistent regional approach to address areas prone to shoreline erosion, (2) impacts to shoreline
                      access from armoring are often overlooked, (3) armoring is often put in place during emergency
                      storm events which may have significant impacts to the coast but which has little overall
                      analysis, and 4) the building setbacks for much of the shoreline development in urban portions of
                      the ReCAP pilot area are often inadequate. Examination and analysis of these concerns led to
                      recommendations for improvements in the procedures for developing regular permit conditions,
                      issuing emergency permits, and establishing setbacks. Recommendations also include efforts to
                      introduce a more regionally based plan for shoreline protection. While the recommended
                      changes in procedures could provide some immediate improvement in the management of
                      coastal hazards, longer-term efforts could require changes to Coastal Act policies. The hazards
                      team identified a number of changes and revisions to the Coastal Act itself which could modify
                      or clarify the overall direction for safe development in areas of high coastal hazards.
                      Individually, or in combination, these recommended changes and modifications would provide
                      coastal planners with tools and resources to plan for future shoreline hazards and safe
                      development.

                      Methodology Used to Addres&amp; Coastal Hazards
                              Coastal erosion is a natural phenomenon which occurs along much of the Santa Cruz and
                      Monterey County shorelines. Coastal and upland erosion provides most of the current day beach
                      materia
                             1. Like other natural processes, such as flooding or earthquakes, erosion is considered a

                                                      CALIFORNIA COASTAL COMMISSION                            PAGE 13
<pb n="18" />

                  RECAP PILOT PROJECT

                                                      Figure 3-1: Hazardy System Diagram

                                SOURCES OF IMPACTS 'TO HAZARDS

                                                                                                Growth and Development
                         Natural Factors
                         Waves
                         Storms
                         Currents                               Changes to Coastal Systems
                         Winds                                  groundwater
                         Structure                              surfacewater
                         Rock type                              drainage
                         Sealevel                               sand supply
                                                                bluff vegetation
                                                                shoreline vegetation
                         Surface runoff                         bluff or beach surfaces
                         Groundwater                            change to wind or
                         Earthquakes                            wave response
                                                                shoreline processes
                                                                littoral process

                             Hazard Is                              Concern for Perceived or
                               corrected                            Real Hazards
                                                                    erosion          accreation
                                                                    bluff retreat    landslides
                                                                    flooding         other

                                   Hazard Is
                                   transferred

                                                    Hazard is          Responses to
                                                     aggravated        Hazards                     No
                                                                       Considered              No Action

                       bnplementation
                      of hazard                                            ulatory
                       response                                        Process       @d                       Development
                                                                             t                                Policies
                                                                      Cost and Benefit
                                                                      Analysis
                              @entatlon
                              rd I                                                                  YDoelve
                                                                                                              P ic

                  PAGE 14                            CALIFORNIA COASTAL COMMISSION
<pb n="19" />

                                                                                               CHAPTER 3 - COASTAL HAZARDS

                       hazard due to the interaction between development and the natural process. ReCAP identified
                       four variables to evaluate the cumulative impacts from policies designed to minimize hazards
                       from coastal erosion: identification of changes to the natural system, recognition of the hazard,
                       determination of responses to the hazard, and assessment of the costs and benefits of the
                       responses including determination of changes to the natural system resulting from the response.
                       Figure 3-1 is a conceptual model for coastal hazards which outlines many of the components of
                       coastal hazards and identifies their interactions.

                       Policies Governing Shoreline Armoring Activitle%
                                The California Coastal Act (Coastal Act) is a major, state-wide law establishing a
                       regulatory program that governs coastal hazard response, development along the shoreline, and
                       the use of shoreline armoring. The major Coastal Act policies which address coastal hazard
                       response are found in the following sections: Section 30253 which addresses the overall stability
                       of new development; Section 30235 which provides for protection of existing development along
                       the shoreline when it is threatened by shoreline erosion; and Section 30610 regarding the
                       rebuilding of existing development that has been destroyed by a natural disaster. These three
                       sections give somewhat conflicting direction regarding response to coastal hazards and reliance
                       on shoreline armoring. Section 30253 sets standards that require that new development:

                                (7) Minimize risks to life andproperty in areas of high geologic, flood, andfire
                                hazard.

                                (2) Assure stability and structural integrity, and neither create nor contribute
                                significantly to erosion, geologic instability, or destruction of the site or
                                surrounding area or in any way require the construction ofprotective devices
                                that would substantially alter natural landforms along bluffs and cliffs.
                                (Emphasis added)

                                This policy has been the basis for requiring technical reports (geologic reports, wave
                       run-up analysis, slope stability or site inundation studies, to name a few) for new development in
                       areas of high hazard to ensure that the proposed project, as designed, can be relatively safe over
                       its lifetime. The Coastal Commission and most of the Local Coastal Programs (LCPs) in the
                       pilot area address the safety of new development along coastal bluffs through setbacks which
                       require that the new structure be a sufficient distance from the edge of the coastal bluff that the
                       structure will not be threatened by bluff retreat or natural erosion during the life of the structure.
                       The Commission provides for use of setbacks through inclusion of suggested setbacks in the
                       Statewide Interpretive Guidelines. At the local level, setbacks are provided by detailed
                       discussion in the LCPs. Most LCPs in the ReCAP area require that setbacks be sufficient to
                       protect the structure for a 50 year economic life and require a minimum setback distance based
                       on either site-specific geology reports or use of the Area of Demonstration.    2

                                One requirement of Section 30253(2) is that new development should be stable without
                       the construction of protective devices to minimize hazards. However, once a new structure has
                       been built, it is an existing structure and Section 30235 of the Coastal Act permits existing
                       structures to use shoreline armoring to protect against shoreline erosion. Some permits for new
                       development have included conditions which make clear that the development was approved
                       only with the understanding that shoreline armoring would never be needed. Section 30235,
                       applied to most existing development, states in full:

                                Revetments, breakwaters, groins, harbor channels, seawalls, cliff retaining
                                walls, and other such construction that alters natural shoreline processes shall
                                be permitted when required to serve coastal-dependent uses or to protect
                                existing structures orpublic beaches in dangerfrom erosion, and when

                                                          CALIFORNIA COASTAL COMMISSION                                PAGE 15
<pb n="20" />

                  RECAP PILOT PROJECT

                          designed to eliminate or mitigate adverse impacts on local shoreline sand
                          supply.

                          Existing marine structures causing water stagnation contributing to pollution
                          problems andfish kills should be phased out or upgraded wherefeasible.
                          (Emphasis added)

                          All the LCPs for the pilot area, in conformance with the Coastal Act, allow shoreline
                  armoring where it is necessary to protect existing development, coastal dependent uses or public
                  beaches. While the pilot area LCPs all take a fairly similar regulatory approach to stability of
                  new development, the pilot area LCPs have several different approaches to the review and
                  regulation of protection for existing development. All LCPs require that an application for a
                  shoreline protective device be supported by technical or geologic reports; several jurisdictions
                  encourage the use of rip-rap whenever possible and allow vertical walls only when rip-rap cannot
                  provide adequate protection or when there are seawalls on adjacent properties. The City of Santa
                  Cruz allows seawalls at the toe of a seacliff only when all other alternatives are infeasible. The
                  City of Capitola allows shoreline protective devices only if non-structural alternatives are
                  infeasible. Other localities establish some performance standards for shoreline protection, such
                  as minimizing impacts on sand supply or to public access, but do not provide guidance as to the
                  preferred armoring type. The different approaches used in the LC.Ps reflect some of the
                  differences in shoreline hazards and responses to these hazards which exist throughout the
                  ReCAP pilot area.

                          Section 3 0610 of the Coastal Act indirectly addresses protection of shoreline
                  development through the reconstruction of structures that have been destroyed by natural
                  disaster. The policy provides that if the replacement structure is in the same location as the
                  destroyed structure and not more than 10% larger or higher than the destroyed structure, no
                  coastal development permit (CDP) is required for the replacement structure. If the replacement
                  structure will be further back from an eroding bluff or higher above the flood elevation than the
                  destroyed structure, the replacement will not be exempt and a CDP must be obtained. While an
                  intent of this policy is to prevent permit delays following a disaster event, its implementation
                  may have cumulative impacts by precluding the examination of risk reducing alternatives. In
                  cases where seawalls have been destroyed by natural events, this policy may perpetuate the
                  reliance on an inadequate seawall design; in cases where bluff top structures have been destroyed
                  by storms, this policy may perpetuate the use of inadequate setbacks. If the permit process is the
                  only mechanism for an analysis of the stability of the replacement structure, property owners can
                  rebuild without any analysis of the future risks of such activity.

                          The City of Santa Cruz, the County of Santa Cruz, and the Carmel area LCPs have
                  policies addressing reconstruction of structures destroyed by natural disaster. The other LCPs in
                  the ReCAP area do not give any guidance on how such projects will be handled. The City of
                  Santa Cruz and the Carmel Area LCPs follow Section 30610 completely and the County of Santa
                  Cruz LCP bases the requirements for reconstruction on the value of the losses. If the losses
                  exceed 50% of the value, the reconstruction is treated the same as new development, requiring a
                  technical report and deed restriction. (Such reconstruction does riot have to demonstrate long-
                  term stability without shoreline protection, as would be required were Coastal Act Section
                  30253(2) to apply).

                          In general, the guidance provided by the Coastal Act and LCP policies relating to
                  shoreline armoring is to try to site new development to avoid the need for any type of protective
                  device; however, if development is threatened by erosion, shoreline armoring will be allowed to
                  protect the development, with efforts made to minimize the impacts from the protection. In
                  terrns of reconstruction policy, except for those areas covered by the Santa Cruz County LCP, if
                  the hazard is sufficient to actually cause damage to the development, a similar structure can be
                  rebuilt in the same location without a CDP; however, relocation or redesign for greater safety

                  PAGE 16                          CALIFORNIA COASTAL COMMISSION
<pb n="21" />

                                                                                               CHAPTER 3 - COASTAL HAZARDS

                        would likely require complete review and a CDP. These policies together have established a
                        long-term reliance on shoreline armoring to protect private and public development.

                        Resource Conditions
                                 The pilot area, from the San Mateo/Santa Cruz county line south through Point Lobos in
                        Monterey, offers a variety of shoreline types and is an excellent area to examine the concerns of
                        cumulative impacts of shoreline erosion and responses to erosion. There are three separate
                        littoral cells within the pilot region, shown in Figure 3-2. The shore characteristics range
                        physically from beaches and dunes to lagoons and steep granite cliffs; the upland uses range
                        from low and high density residential and commercial to parks and agricultural lands.

                                 Figure 3-3 (page 21) shows the locations of shoreline armoring throughout the ReCAP
                        pilot area, based on a review of aerial photographs from 1978, 1986 and 1993. Due to the cost
                        of, and impacts from, armoring, it is rarely undertaken in areas where there is not now or has not
                        been a pressing need for protection. As can be seen from Figure 3-3, armoring has concentrated
                        mainly in those developed areas which combine highly erosive shoreline material with a high
                        instance of storm wave attack. The section of coast from Corcoran Lagoon to Soquel Point, for
                        example, is completely armored except for one small lot, approximately 60 feet wide.      3   Areas
                        where the shoreline material is very resistant to wave erosion and areas which have some natural
                        protection from storm waves have had very little armoring activity.

                                 There has been an historic demand for shoreline protection throughout the ReCAP pilot
                        area, beginning in Santa Cruz County. In 197 1, the U.S. Army Corps of Engineers (ACOE)
                        undertook an inventory of the California shoreline and found approximately three miles of
                        armored shoreline in the ReCAP area, all located in the City of Santa Cruz from Natural Bridges
                        to Soquel Point. Small areas south of this were armored, but the amounts were too little to
                        tabulate.4 The ACOE did not identify any protection in Monterey County. As part of the
                        ReCAP analysis, aerial photographs of the pilot area for 1978, 1986 and 1993 were examined for
                        armoring. This review differed from the work done by the ACOE and, without knowledge of the
                        techniques used by the ACOE, the results can not be compared quantitatively; nevertheless, a
                        qualitative comparison shows substantial increases in the amount of armoring throughout the
                        ReCAP pilot area between 1971 and 1978.

                                 As shown in Figure 3-4, by 1978, there were approximately 9.6 miles of armoring in the
                        ReCAP area      6 miles in Santa Cruz County and 3.6 miles in the ReCAP portion of Monterey

                                          Figure 3-4: Shoreline Armoring in the ReCAP Region, 1978, 1986 and 1993

                                 12

                                 10                                                 3.7
                                                                                            77
                                 8                                                                0 Monterey
                         MILES 6                                                                  E Santa Cruz

                                 4-

                                 2--

                                 0 4-
                                            1978                1986               1993
                                    @m

                        Source: Aerial Photo interpretation, Jon VanCoops, Cal ifornia Coastal Commission, 1994.

                                                          CALIFORNIA COASTAL COMMISSION                                PAGE17
<pb n="22" />

                                                                                                                                                                  Littoral C
    M                                                                                                                                         in the                     ReCAP
                                                 Pt. Ano
    W,                                             Nuevo                                                                                    N-

                                                                                                               S A N T A

                                                                                                                         C     R U       Z                                                         St

                                                                                  Bonn
                                                                                  Doon                                                                                                       IN,
                                                                       Davenport                                  Santa
                                                                                                                     Cru
                                                                                                                                Soqu
    0
    &gt;
    r-
    ,n
    0                                                                                                  Ile              Pt.
    ;a                                                                                                        C::@sonla
                             Net Longshore Movement                                           13@6                      Cruz                                                      Watsonville
    &gt;
    0                        or Offshore Movement
    0
                             Dune         Win                                                                                                                                                Aromas
                 EE*                  Ru'  spo@rt
                             Wind     Tran
                                                                                                 SANTA        CRUZ CELL
    0
    0                        River    Transport     Outlet                                                                                       jc"M River
                                                                &lt;1
    0                        Littoral Cell Boundary                                                   o n        e r e
    0
    z
                             Study Area Boundary                                                                                                              -?loss Landing                    Prune
                                                                                                                a
                                      ./V                                                                                                                                      Castroville

                                                                                                            SOUTHERN MONTEREY                                           ... ... . .. Unas River
                                                                                                            BAY CELL

                         Scale        1:400,000                                                                                                                   Marina                          0
                     1 inch equals  approximately 6 miles                                                                        Pt. Pinos P                     Fort Ord             M    0      N
                     0                                   10                                                                                G Gro' vi rel c
                                      Miles                                                                                                                 Sand City

                                                                                                                                                         Seaside
                The             e@                                                                                                                    - - - - - - - - - - -
                A
                 s.       S c                                                                                                                    Monterey
                   =ntou,nd       Atlas of Shoreline Erosion Along the                                               Cypress Pt.
                California Coast  CA Dept of Navigation and Ocean                         CARMEL
                Development, 1977.                                                                                                       ...... ........
                NOTE: Littoral Cell   boundaries are approximate.                         RIVER CELL                           Ca rm *I       Ca mel
                         Callfo /a Coasfal CommIssion                                                                     PL Lobos                  - - - - - - - - - - -
                         Technrlcnal ServIces DIvIslon                              L  - - - - - - - -
<pb n="23" />

                                                                                            CHAPTER 3 - COASTAL HAZARDS

                       County. By 1986, a total of 11.9 miles were armored, with 8.2 miles in Santa Cruz County and
                       3.7 miles in the ReCAP portion of Monterey County. By 1993, additional armoring in Santa
                       Cruz County increased the amounts of armored shoreline to 8.3 miles for Santa Cruz County and
                       12 miles for the entire ReCAP area. None of these estimates include lengths of beaches
                       protected by breakwaters, jetties or groins, nor do the figures for length reflect the maintenance
                       and additions of rock to existing walls. Much of the increase in armoring between 1978 and
                       1986 is thought to have been constructed in response to the storms in the late 1970s and early
                       1980s.

                               Almost all of the shoreline protection in the ReCAP area is provided by rip-rap or rock
                       rubble revetments, with only about 1. 1 miles of protection from concrete or timber seawalls
                       without rock. Rock is often less expensive than a vertical wall and is considered by many to be
                       more "natural" looking -- possible reasons for the preference given to rip-rap by some of the
                       LCPs in the ReCAP pilot region. However, rock takes up much more land or beach area than a
                       vertical wall and, when constructed on a public beach, can replace area used for access and
                       recreation. In some locations in the ReCAP area, access to shorefront property is so difficult that
                       the shoreline protection design is more dependent on the means of placing the structures than on
                       the coastal characteristics.5

                               ReCAP staff undertook a review of aerial photographs and land use plans to identify
                       potential areas of future growth and shoreline armoring in the pilot area. Much of the shoreline
                       land within the urban service areas has been developed and the only areas with a significant
                       amount of vacant urban shoreline are Sand City, Marina, and Del Monte Forest. In both
                       southern Santa Cruz County and northern Monterey County, there are large holdings of shoreline
                       property that are zoned agricultural. Some of the agricultural lands have levees for protection
                       from flooding but none now have any seawalls or revetments for protection from erosion. This
                       is likely to continue since erosion seems to be small in many of the areas of agricultural land and
                       armoring for a large agricultural parcel would be very expensive. Unless there is major rezoning
                       of agricultural shoreline lands, the key shoreline hazard concerns in the pilot area will come from
                       repair and maintenance of existing armoring and new armoring to protect either existing
                       development or new development on infill lots.

                               From this rough review of existing land use patterns and shoreline characteristics, the
                       ReCAP team estimated that up to a third of the entire ReCAP area shoreline, combining
                       developed or developable land, has a significant rate of erosion. If current armoring practices
                       continue, ultimately as much as 19.3 miles of the Santa Cruz County shoreline and 8.4 miles of
                       the ReCAP portion of Monterey County could be armored to protect either private development
                       or public works and infrastructure (including development immediately landward of public
                       beaches as has happened in the Live Oak area of Santa Cruz County for protection of East Cliff
                       Drive). This would more than double the length of armoring that exists in the ReCAP area
                       today.

                       Permit Activity from 1983 to 1993 Related to Shoreline Armoring.
                               Just as the examination of the shoreline conditions over time shows increases in
                       armoring in the pilot area, a review of the permit activity in the ReCAP area from 1983-1993
                       shows approval of numerous permits for shoreline protection. Many shoreline protection
                       projects were revised during the permit review process,- and many projects had conditions
                       attached to the approval to mitigate impacts; one project was initially denied but after several
                       appeals was approved with conditions. One hundred shoreline protection permits were approved
                       for the ReCAP region during this time period: 4 for beach nourishment projects and 96 for some
                       form of seawall, bulkhead, revetment, or cave filling. All four beach nourishment projects were
                       approved by the Commigsion and were associated with dredging projects.6 Of the 96 armoring
                       projects, 79 were approved by the Commission and the remaining 17 were approved by ReCAP
                       area local governments. 7

                                                        CALIFORNIA COASTAL COMMISSION                              PAGE 19
<pb n="24" />

                  RECAP PILOT PROJECT

                          Figure 3-5 shows the geographic location of the approved armoring projects. The
                  majority of approved seawall projects from 1983-1993 have taken place in the northern portion
                  of the ReCAP pilot region. The permit database indicates that 47 seawall projects were in the

                              Figure 3-5: Approved Seawall Locations by LCP Jurisdiction, ReCAP Region 1983-1993

                                                                         3,
                                                                         "A
                             Sand City           -J,
                                                       @-J      A"6
                           Carrnel City                             @q 2"@a
                                                    M,                                                    m s
                                                                                   (M Loml government per  it
                                                                  DA
                                                         "N
                                                           4
                               Capitola
                                                                           6,
                                                                              V's
                               Capitola
                                                                                    CCC
                                                                 w"                      permits
                                                                              '_0

                                                         "k
                                                        '0          -     ''_ @' '0@
                          Pacific Grove                            e)
                                                               K_" tp@     'A
                                                                                 "k,
                          Monterey City
                                                                                                        'o
                                                                A
                                                                                L
                                                                    M
                       Santa Cruz City
                      Monterey County
                    Santa Cruz County

                                       0       6      10     is      20       26    30      35     40      46         60
                   S urce: RoCAP Database, Hazards  :ub-module.       Number of Projects
                   N:te:  Monte my County by sogrne ts: North Monte my County (10), Doi Monte Forest (8)
                          City of Monterey by segments: He rbodDowntown (4), Doi Monte Beach (2), Cannery Row (2)

                  Santa Cruz County LCP jurisdiction alone. When the approved seawalls in the Capitola and
                  Santa Cruz City LCP jurisdictions are summed with those in Santa Cruz County (representing all
                  approved seawall activity along the Santa Cruz County shoreline), nearly 66% of all seawall
                  project activity in the-ReCAP pilot area was located in the northern portion of Monterey Bay.

                          The shoreline protection placed as a result of the 100 approved permits from 1983-1993
                  was primarily a response to private development interests: 59% of the approved projects were to
                  protect private residential, commercial, or industrial development, 15% to protect institutions or
                  harbors, 21% to protect public works or rublic recreation interests, and the remaining 5% to
                  protect some other type of development. While 30 of the 96 armoring permits were approved
                  for new seawalls or revetments, 63 were for some form of repair, maintenance, or expansion to
                  an existing shoreline structure and 3 projects were unclear as to their associated activity. One
                  reason for the high number of permits involved with modifications of existing structures is that
                  most of the armoring in the pilot region is made up of rip-rap revetment which requires regular
                  additions of rock for the structure to function effectively.

                          Table 3-1 (page 23) identifies some cumulative effects of the armoring that have been
                  permitted from 1983 to 1993 -- many of the activities that have contributed to the current 12
                  miles of armored shoreline. Table 3-1 also shows the lengths of the approved seawalls as well
                  as tons of rip-rap placed over the time period of 1983-1993. Unfortunately, complete records of
                  lengths and tonnage were not readily available. Of these 96 projects, 40 had some length
                  recorded and 38 had some tonnage of rip-rap recorded. Using the cases where these project
                  attributes were noted, totals and averages overall as well as for respective years are presented. It
                  is clear that the permit activity following the 1983 storms accounts for the majority of armoring
                  activity, making over 50% of the noted length and over 40% of the rip-rap tonnage. Overall,
                  more than 2 miles of approved seawall activity and over 65,000 tons of approved rip-rap were
                  identified in the ReCAP area from 1983 through 1993. (Since these values were developed from
                  only a portion of all the permits approved from 1983 to 1993, actual lengths and tons will be
                  higher). On average, where project attributes were noted, a typical approved ReCAP pilot area
                  armoring project involved 345 linear feet of coastline and 1,714 tons of rip-rap; further
                  breakdown shows that for private development in the form of residential, commercial, or
                  industrial uses, a typical average project was slightly smaller at 227 linear feet and 1205 tons of

                  PAGE 20                          CALIFORNIA COASTAL COMMISSION
<pb n="25" />

                   Sanla Cruz Coun                                          7YPE, APPROXIMATE Lrxom 0977,liq86'li                                                                                                                                                                                       California Coastal Commission
                   1. WGodell Bluffs                                        Rock rubble revetment, 6001210012100'
                   2. Davenport Londl@7g                                    Rock rubble revetment, 100/100/100'                                                                                                                                                                     Regional           Cumulative Assessment Project
                   -T De Anzo Mobile Home Pork                              Rock rubble revetment, 100/100/100'
                   4 West Cliff DrIve - Notural Bridges                     Rock rubble revetment, 2050124,5012,550'
                     State Pork to Point Santo Cruz                                                                                                                                                                                                                                   A             reline                        Armoring
                   5. Point Santo Cruz to Cowell Beach                      Rock rubble revetment, 27001270012700'
                                                                                                                                                     Pt. Aho
                   6. Dream Inn                                             Concrete seowall, 70017001700'                                             Nuevo
                   * Santo Cruz Boardwalk                                   Concrete seawall J0001J0001J000'
                   * Santo Cruz Harbor Entrance                             West jetty IJ501IJ5017J50'                                                                                                                         S      A     N        T   A
                                                                            East )L-tty 75017501750'
                   9. Twin Lakes Beach -                                    Rock rubble seawall, 10001IJ001IJ001                                                                                                                             C       R   U      Z
                     Schwanns Lagoon to          Block Point                                                                                                                                 Bonn                                                                                                                                Study Area
                   10. Block Pol@7 t                                        Rock rubble seawall -1175175'                                                                                    Doon                                                                                                                                    Location                CA
                   11. Sunny Cove to Corcoran Lagoon                        Rock rubble seawall 25018251825'                                                                           2
                   12. Corcoran Lagoon to Moran Lake                        Rock rubble seawall 16001170017700'*                                                               Davenport
                   IJ Moron Lake                                            Rock rubble seawall -12001200'                                                                                                                          Santo            Soquel
                   14. Moran Lake to Soquel Point                           Concrete, rock rubble seawalls, 70018001800'                                                                                                              Cruz 9                16 8
                   15. Opol Cliffs Drive - Soquel Point                     Concrete, rock rubble seawclls, 4900;14900'@14900"                                                                                                                       10
                     to Cqoito/0 Kharf
                   16. Capitold Beach                                       Crams, J001-3001.300'                                                                                                                                                             17 19                              1
                                                                            Concrete seawalls, 1000/1000/1000'                                                                                                                          Pt.Sonto         15
                                                                                                                                                                                                                                             Cruz
                   17 Caoitold 8luff to                                     Rock rubble seawall JJ001JJ001JJ00'                                                                                                                  34                  1                     20
                     New Brighton State Beach                                                                                                                                                                                                                                                                    Watsonville
                   18. Potbelly Beach                                       Rock rubble revetment, 85019501950'
                   19. Seacliff State Beach                                 Rock rubble revatment. 17001170011700'
                                                                            TImber concrete seawalls, 52001520015200'                                                                                                                                                                                                                     Aromas
                                                                            Groln, 70001850018,500'
                   20. Manreso State Beach                                  Rock rubble seawalls, 60019001900'                                                                                                                                                                       21
                   21. Palbro Dun es1Pqji7ro     River                      Rock rubble revetment, 8001140011400'                                                           17@                                                                                           jrkla@-o River
                                                                            Rock rubble seawall, -117500@17500'
                                                                            r1mber seawall 50015001500'
                                                                                                                                                                                                                          Af o n              e r e
                                                                                                                                                                                                                                                                               Moss Landirg
                   Yonlerey County                                          rYP&amp; APPROXIMATE LENGrH (19771@98611                                                                                                                                                                           22-
                   22. Moss Landing Harbor                                  North jetty, 15001150011500'                                                                                                                                                                                                                          Prunedole
                                                                            South )L-tty, 12501125011250'
                   2J. Fort Ord                                             Rock rubble revetments, 1100/1100'@/1100'
                   24. Foot of rloga Ave., Sand City                        Rock rubble revetment, seawall, 25001250012500'                                                                                                                                                            River                   Costroville
                   25. Holiday Inn                                          Concrete seawall 60016001600'
                   26. Foot of Surf Way, Del Monte Beach                    Rock rubble seawall -15401540'
                   2Z Monterey Harbor                                       Rock rubble revetment, JJ001JJ001JJ00'
                   28. Conner                                               Rock rubble breakwater 17501180011800'
                             y Row                                          Concrete, rock rubble seawalls, 40001400014000'                                                                                                                                                                                                             Sal in Gs
                   29. Point Cabrillo   to Point Pinos,                     Stone, concrete seawall, rock rubble revetment                                                                                                                                                                                                          0
                     Pacific Gro ve                                         265012650'*12650'                                                                                   Ar                                                                                           23                MIP  rina
                   30 Uonten@y Peninsula Country Club                       Concrete seawall, 100/100/100'                                                                                                                                                                          24         F rt Ord
                     SathIng Povillon                                                                                                                                                                                                                Pt. Pinos       Poc'f'c25                                        M      0     N      T     E     R      E     Y
                   X. Pebble Beach, C)press Point                           Rock rubble revetment, 75017501750'                                                                                                                                                      Grove
                   J2. Pebble Beach, Stillwater Cove                        Rock rubble revetment, 20001200012000'                                                                                                                                -TO         28            2            Sand       ity
                   JJ. City of Carmel                                       Rock, concrete seawalls, 160011600'@11600'                                                                                                                                                                 SeasidJC
                   J4. Point Lobos State Reserve                            Rock rubble revetment, 50015001500'                                                                                                                                                27                                   NOTE: The information depicted on this mop and included
                                                                                                                                                                                                                                             JT I                         Monterey                  in the list is preliminary and subject to revision. This mop
                                                                                   Rock added no length change                                                  Scale 1:325,000                                                         Cypress Pt.                                                 and list may not include all lands within the study area where
                   Thematic Sources:                                                                                                                                                                                                                                                                shoreline ormoring has occurred, or all types and actual
                   CA Dept. of Navigation and Ocean Development, 1977                                                                                     1 inch equols approximotely 5 miles                                                                                                       lengths of armoring which has occurred in the identified
                                                                                                                                                                                                                                                32                                                  areas. This map and listing do not establish any limitations
                   CA State Lands Commission, 1981        -                                                                                                0                                          10                                    Ca rM el J3               Carmel                        on Coastal Commission regulatory authority regarding past
                   NASA Aerial Photography, Scale 1.32,500, 1977                                                                                                                                                                                                                                                                                                  dy
                   CA Dept. of Water Resources Aerial Photography, Scale 1:12,000, 1978, 1986, and 1993                                                                       Miles                                                               -9'ZJ/                                            or present shoreline ormoring occurring in the stu                 area.
                                                                                                                                                                                                                                                  J4                                                                 Study Area Boundary
                                                                                                                                                                                                                                               Pt. Lobos
                            California Coastal Commission                                                                                                                                                                                                                                                                                                        Figure
                            Technical Services Division                                                                                                                                                                                                                                                                                                                     ACH 11/94
<pb n="26" />

                                                                                                                         CHAPTER 3 - COASTAL HAZARDS

                            rip-rap.   9 Since many of the residential applicants applied as groups, these figures do not reflect
                            averages for individual residential parcels.

                                                     Table 3-1: Shoreline Armoring Permitted in the ReCAP Region, 1983-1993

                                                 &amp;                  F

                                                                                                                                                   11R,
                                       Year Number of                     Number with             T         Totals              Averages,
                                                  projects           attributes noted
                                                                   Structure , Rip-raptons            Length -    Rip-rap     Length      Rip-rap
                                                  approved
                                                                 length noted:        noted            (fbet)   -  (tons)     (feet)       (tons)@,.
                                       1983            35                 17             21              7122      26321           4        1253
                                       1984            10                 3                6               498     18479           166      3080-111'.
                                       1985            3                  1                0                60           n/a       60           rVa
                                                                                                                         n/a                    n/qt
                                       1986            3                  1                0                20                     20
                                                                                                              5
                                       1987            9                  7                4            317        12050           454      3013
                                       1988            3                  2                1             1380        1200          690      1200          J
                                                                                                            n/a                    n/a
                                       1989            4                  0                1                         5000                   5000 "T
                                       1990            13                 4                3               882         948         221       31&amp;         A
                                                                                                               a,                  n1a          n/a
                                                                                                                        n/a
                                       1991    1       2         1        0      1         0
                                                                                                                       900         50         900
                                       1992            4                  1                1                501

                                                                                                                                                     M Xa-,
                                       1993            10        1        4      1         1               6051        250         151        250
                                Oz_
                                                                                                                                 AW
                                                                                                                J
                                                                            '00
                                          -93
                                       83              96        1        40     1       38                       65,1481          3451     1,714
                                                                                                      13,792F

                                                          R      "'P,
                                              R"*                                                                   "W,
                                                             Q1,0
                                        @W

                                       Future demands for shoreline protection will depend on trends in development along the
                            shoreline, erosion potential of the shoreline, and frequency of storm events. It is not possible to
                            graph historic demand and extrapolate since the conditions that establish the demand will
                            continue to change. ReCAP's predicted trend for future armoring was based on assumptions
                            regarding the amounts of development which may be threatened in the future by erosion. In
                            Santa Cruz County, 19.4 miles of upland shoreline are privately owned and 17.8 miles are
                            publicly owned; in the ReCAP portion of Monterey County, approximately 16.3 miles of upland
                            shoreline are privately owned and 24.5 are publicly owned. In the total ReCAP area, there are
                            3 5.7 miles of shoreline which have been or may be developed with private upland development,
                            and much of this has required, or eventually may require, shoreline armoring.

                                       A study by the ACOE provides a second identification that new portions of shoreline
                            may be armored in the future. As part of a. study on shoaling at Santa Cruz Harbor,                               10   the ACOE
                            studied the section of Santa Cruz coast from Seabright Beach to New Brighton State Beach for
                            shoreline geology, status of existing protection and current hazard level from erosion. Although
                            large stretches of this 4.8 miles of coast have been armored, the study identified several areas
                            where continued erosion can be expected to endanger development and structures in the future.
                            If the shoreline is unprotected or has inadequate protection and the historic erosion rate is
                            moderate or high, the study identified the area as liable to need future protection. Based on this
                            screening effort, 1.9 miles of coast were considered in need of future protection. Of these 1.9
                            miles, 0.7 miles would be required to prevent road closures or relocation of utilities and 0.4
                            miles would be required to protect homes or apartments from erosion; almost 0.8 miles would be
                            to protect vacant coastal land. Some of the proposed protection were efforts to restore the
                            functioning of the natural groins at Pleasure Point and Peeper's Beach, enhance the beach
                            building ability of these areas, enhance recreational opportunities and add 82,500 square feet of

                                                                          CALIFORNIA COASTAL COMMISSION                                                PAGE 23
<pb n="27" />

                    RECAP PILOT PROJECT

                    beach total;'1no estimates were made of the recreational losses which would result from the
                    encroachment of 1.9 miles of seawalls and revetments.

                           HAZARDS PROBLEM ONE

                            Many coastal areas contain a variety of shoreline protective devices. There is little
                    attempt, in most cases, to design shoreline armoring to address regional resources or constraints.
                    Adjoining properties, with similar wave climate and geology, have a variety of protective
                    Isolutions' all represented to be appropriate to the site. The only review for protective structures
                    provided by the Coastal Act is that the structures be "designed to eliminate or mitigate adverse
                    impacts on local sand supply" (Section 30235); no regional consistency is required.

                                                                   W
                                                                     Mr                                 N
                                                                       &amp;
                           In the ReCAP area, the geology of certain "regions" varies considerably.      Geologic
                    conditions for the coast of Santa Cruz County include a moderately resistant mudstone in the
                    northern cliffed areas and sedimentary formations of sandstone and siltstone in the southern
                    portion. Monterey Countys north coast consists of mostly beach and dune features -- relatively
                    young dunes such as the Marina Dune complex, as well as older.dunes such as the inland
                    portions of the former Fort Ord military reservation. The southern portion of Monterey County's
                    coastline consists of mostly resistant granite rock with interlying sandy pocket beaches.
                    Generally in the Monterey Bay pilot area, with the exception of few specific localities, the
                    coastline is eroding, losing large quantities of sand naturally to the offshore submarine canyons
                    and some to the inland dune systems.

                           While the ReCAP pilot area offers a variety of shoreline types, many smaller portions of
                    the shoreline have common features. Segments of the bay's shoreline may be broken down into
                    "regions" while considering such factors as geology, wave conditions, and natural sand budget,
                    to name a few. At a large scale, the shoreline can be divided into littoral cells which share
                    common characteristics of sediment sources and transport. On a smaller scale, there are
                    stretches of coast bounded by lagoons or headlands which have a similar geology and wave
                    climate. These common factors should affect the types of armoring which will be most effective
                    for a portion of shoreline; however, in many portions of the ReCAP area, the strategies used to
                    provide shoreline protection differ greatly from one property to the next, in spite of the apparent
                    physical similarities between the sites.

                           Shoreline protective measures in portions of the ReCAP pilot area generally lack any
                    regional scheme for dealing with erosion. For example, in many coastal permits for projects
                    within Santa Cruz County, geologic analyses often consider regional wave conditions and/or
                    tectonics, but rarely do these reports consider sand budgets or regional sand supplies. Santa Cruz
                    Harbor was constructed before the Coastal Act came into effect and thus it never received review
                    through the California Coastal Management Program (CCMP); however, this project illustrates
                    both the regional effects which can accompany a single project and the importance of a regional
                    overview of projects which may modify shoreline processes. Since the harbor has been
                    constructed, an expansive beach has developed upcoast of the jetties where there once had been
                    significant erosion; downcoast areas as far as Capitola have experienced profound decreases in

                    PAGE 24                         CALIFORNIA COASTAL COMMISSION
<pb n="28" />

                                                                                            CHAPTER 3 - COASTAL HAZARDS

                       sand supplies and increased shoreline retreat. Since construction of the harbor, there have been
                       at least six regional studies investigating ways to address these downcoast effects. 12

                                The Live Oak area of Santa Cruz County illustrates a second situation which can arise
                       when individual projects are undertaken without a regional overview to guide shoreline activity.
                       Much of the shoreline has been armored; numerous protective efforts exist in close proximity to
                       each other and review of permit activity shows repeated activity at some sites. Figure 3-6 shows
                       a mosaic of permit activity for one small section of coast within Live Oak along Opal Cliffs.
                       This plethora of armoring and permit activity makes comprehensive review difficult -- work has
                       been done through the emergency process, through regular Commission issued permits and
                       through local permits. Within this 3,000 foot long section of shoreline, properties have been
                       protected with gunite, vertical walls, rip-rap and concrete cylinders. Some properties were
                       issued two or three permits for different armoring activities, properties received permits for one
                       type of protection and different armoring was actually constructed, new properties have been
                       added to existing permits through the amendment process, and several properties received local
                       permits without any conditions for access.

                                A regional overview of this segment of coast could have identified the major factors
                       contributing to erosion and identified an effective strategy for the "region" to address natural
                       shoreline processes. Such an overview might identify recommended treatments for various
                       areas, such as where revetments may be most effective, areas where vertical walls may be most
                       effective, areas where surface treatment of the bluff (gunite, rock bolting, etc.) may be most
                       effective, and finally, areas where beach nourishment or sand management may be most
                       effective. Applicants could use this general direction to design a site-specific solution. As a
                       second type'of regional overview, some local governments have prepared "standard" designs for
                       shoreline protection which can be used in specified areas. 13 Applicants can use these designs in
                       the specified areas or identify different efforts for protection which better suit the site-specific
                       conditions.

                                The existing situation in Live Oak, however, presents a piecemeal confusion of
                       protective measures. From an engineering perspective, the weakest points in shoreline armoring
                       are normally the ends and the junctions between different styles of protection (rock adjacent to
                       concrete to gunite, for example). Such ends and junctions occur frequently in the Live Oak area,
                       and while no engineering evaluation has been prepared, the potential for weaknesses in the
                       protection would be greatly reduced by a regional approach to controlling erosion in the area. In
                       addition, the general look and aesthetic of the area would change if adjoining properties had
                       shoreline protection efforts with a similar visual effect.

                                A final support for a regional overview of shoreline activity comes from an earlier
                       analysis of coastal hazards by Gary Griggs, James Pepper and Martha Jordan, in which they find,

                                Since these decisions are usually made on a project-hy-project basis, they tend
                                to be evaluated independently, without any systematic consideration of the
                                aggregate or cumulative effects either within or amongjurisdictions. Within
                                such a decision-making context any given project can be viewed as small and
                                thus easy to rationalize in terms of approval. Cairns (1986) calls this endemic
                                failure to take into account the agregate effects of environmental management
                                "the tyranny ofsmall decisions ".

                       A regional overview for individual shoreline activity would provide coastal planners and
                       analysts a perspective on how an individual project would fit into the overall cumulative
                       approach to shoreline management.

                                                        CALIFORNIA COASTAL COMMISSION                               PAGE25
<pb n="29" />

                                                                                           0Z5
                                                                                   di    , '@ t
                                                                                          C
          SHORELINE ARMORING
                                                                                                                                                 M
 &gt;                                                                                                       Type of Armoring                        0
 G)                   1983-1993
 M                                                                                                                                               &gt;
                                                                                                         A Gunite                                "0
       Opal Cliffs, Santa Cruz County
                                                                                                                                                 0
                                                                                    M22                  El Vertical Wall

                                                                                                                                                 X
                                                                                                            Rip Rap                              0
                                                                                                                                                 M
                                                                                                                                                 0
                                                                                                         0 Cylinders
                                                                      @,5 0
                                                                       Zo
                                                                        q                    &lt;@&gt; 3-84-018 Approved with conditions 3/84
                                                                                                 6,000 tons of riprop (gunite already in place)

 0
 &gt;                                                                                               3-SCO-93-063 Approved 9/93
                                                                                                 Local permit for'seawall
 0                                                             4
 Z                                                        4  4
 &gt;                                                                                               3-SCO-93-029 Approved 4/93
                                                  4)
 0                                                                                               Local permit for seawall
                                               Cj 1'+
 0                                               0 9j
 &gt;                                               Oq
 &gt;                                                                                           (D  3-84-083 Approved with conditions 6/84
 r-                                                                                              "Modular stepped concrete seawall" (=cylinders?)
 0
 0

 U)                                                                                          &lt;@&gt; 3-83-176 Approved with conditions 9/83
 0                                                                                               Expand 3 shoreline protective devices by adding
 Z                                                                                               350 tons of riprap at each parcel (1,050 tons total)
                                                                                                 2 new riprop revetments (1.600 tons total)
                                                                                                 3-83-176-A Approved with conditions 9/84
                                             6  rzi                                              5 vertical cylinders with r1prap enrichment
                                         5                                                       15' high vertical wall; not part of original permit
                                                                                                 3-83-176-A2 Approved with conditions 9/85
                                          6                                                      20' high vertical wall
                                                                                                 17* high vertical wall

                         Qk                                                                      3-87-086 Approved with conditions 6/87
                                                                Location Map                     Seawall permit
                          qj
                         ON                    /V            "'@S A A                            3-84-075 Approved with conditions 5/84
                                                                    R U Z                        Proposed 14' high (5,500 tons) rock seawall;
                                                                        co                       was not constructed as proposed. rather gunite
                             MA                                Opa/ ClIffs                       was temporarily added to cliff face
                                                             Alva I* rev                         3-84-075-A Approved with' conditions 6/90
                                                                                                 Modified original permit resulting in 20' high,
                                                                         0 7 E R E               340 linear foot seawail for only 3 properties
                                         0            400                  co                    Assessor's map boundary
                                              VEE T                                                                                   L19,V1-61
<pb n="30" />

                                                                                          CHAPTER 3 - COASTAL HAZARDS

                                Without a regional overview, the piecemeal approach to shoreline protective devices will
                       continue to impact shoreline processes and resources. The attempt to minimize coastal hazards
                       with various devices (seawalls and numerous rip-rap structures), combined with naturally
                       occurring coastal processes, requires a closer examination of their cumulative impacts.
                       Piecemeal solutions to coastal erosion problems are not generally effective and have the
                       potential to create further problems. Often overlooked are the regional effects of such shoreline
                       protection. Where a regional coastal erosion problem exists, a regional solution should be
                       developed and implemented.

                                The ReCAP pilot area has had many years of experience with a variety of armoring
                       devices. It should be possible to study the on-site impacts, possible downcoast impacts and
                       maintenance records for these structures and determine which types are most effective in
                       different areas. From such information, local governments would be able to make sound
                       decisions about the types of armoring which would be allowed in the fiiture.

                                                 @7
                                                        - I MINOR, MM
                       17 @__b qM M _Eq        N_

                       Program Improvements-
                           *    Develop procedural guidance for defining and delineating all areas of high coastal
                                hazards in the pilot area coastline; these areas should then further be broken down into
                                smaller regions that share the same geologic and ocean processes. These "regional" or
                                "sub-regional" breakdowns of the pilot area coastline should consider, but not be limited
                                to, such factors as geology, wave conditions, and sand budget situation. Regions would
                                not necessarily be bounded by city or county jurisdictions, but would follow the bounds
                                established by the physical characteristics of the coast.

                           *    Prepare procedural guidance for the development of regional shoreline erosion and bluff
                                retreat management plans suitable for implementation by ReCAP area LCP jurisdictions
                                that are broken down by the defined geologic sub-regions taking into account the
                                specific geologic and geographic constraints of the subject area and incorporating
                                concerns and regulations governing protective devices along the shoreline as well as the
                                sand budget situation within the specified "region". The framework for this guidance
                                would include, but not be limited to:

                                0  Standard engineering plans defining the specific types of armoring which would be
                                   acceptable for specific areas, and where appropriate, identification of the types of
                                   armoring which should never be considered for certain areas.

                                0  Standard alternatives feasibility analysis worksheet that would be a required element
                                   of all hazard response projects and that would require applicants to go through a
                                   series of steps to assure that hard protective devices were only created as a last
                                   resort. The analysis may require, but not be limited to, the use of technical
                                   evaluations of the site (geotechnical reports, engineering geology reports, etc.), an
                                   examination of all other options (removal, relocation, "do nothing", sand
                                   replenishment, etc.), and a conclusion that a shoreline protective device would be the
                                   "best option" (most protective of the public trust, best long term solution, etc.) for
                                   the subject site.
                                0  Standard conditions and monitoring requirements that may include discussion of
                                   mechanisms to ensure shoreline protection effectiveness and public safety with

                                                       CALIFORNIA COASTAL COMMISSION                            PAGE 27
<pb n="31" />

                RECAP PILOT PROJECT

                            provisions for the removal of ineffective or hazardous protective structures as well
                            as programs to address beach replenishment and sand supply.

                                                erm.
                Obbortunitieis In the Loh;giRr,,T
                    *   Provide guidance for the development of regional programs for managing and expanding
                        shoreline sand resources through such mechanisms as aggressive beach nourishment,
                        especially for areas where beach sand loss exceeds supply.
                    *   Provide guidance for ReCAP area LCP jurisdictions to address major watershed projects
                        -- both in and outside the coastal zone -- for impacts to shoreline sand supply issues,
                        particularly in areas with sediment deficits.

                    *   Pursue expanding Section 30235 of the Coastal Act governing protective devices to
                        require that protective efforts be compatible with both regional conditions and with the
                        protective efforts used for properties in the same shoreline region.

                        HAZARDS PROBLEM TWO

                        Incremental impacts to beach areas, access and the general character of the shoreline
                have occurred from approval of permits for shoreline armoring. Over the ReCAP time period,
                there have been measurable losses in beach access through increases in the length and area extent
                of shoreline armoring, but many permits have been approved without any conditions directed at
                access impacts.

                                                                                  For
                                                                              M
                                                  01      1 1,
                        Public access concerns are not always addressed in permits for shoreline armoring.
                Review of approved shoreline armoring in the ReCAP region from 1983-1993 identified that
                many projects raised some access issues, such as blocking or encroaching on lateral or vertical
                access, but not all such permits contained access mitigation: 8 of the projects involved some
                type of improvement to access facilities, and no access mitigation was needed with the project;
                36 projects were required, through conditions, to improve access either through an easement,
                dedication, or improvements to access facilities; 45 projects had no permit conditions requiring
                mitigation of access impacts, but the information in the ReCAP database was not of sufficient
                detail to determine the types or extents of access concerns which were raised by these projects.
                It is likely that many of these permits with no access related condition were for repair and
                maintenance of existing structures. For such permits, the access concerns were likely to be the
                perpetuation of impacts resulting from the original structures; the major impacts to access would
                have resulted from the initial construction and would have been addressed in the original permit
                action, if the structure was built during the time of the Coastal Act. However, if any of these
                projects were for new structures or the physical expansion of existing structures, they would
                have added new constraints to access which should have been considered. Since access impacts
                from shoreline armoring can be significant and long-term, when access issues are raised by a
                project involving shoreline armoring, the individual and cumulative impacts to access should
                always be addressed.

                PAGE 28                         CALIFORNIA COASTAL COMMISSION
<pb n="32" />

                                                                                           CHAPTER 3 - COASTAL HAZARDS

                                 Much of the pilot area coastline has been developed and over 12 miles have been
                        armored, as of 1993. As noted earlier in Figure 3-3, portions of this armoring occurred prior to
                        the Coastal Act, LCP certification and the time frame for the ReCAP study. Assuming that a
                        vertical seawall extends 4 feet onto the beach and revetments or rubble walls extend 20 feet onto
                        the beach, the existing 12 miles of armoring occupies over I million square feet or 25 acres of
                        beach, not including other beach level development, such as homes, which occupy the protected
                        beach (for example, the development at Seascape). If, as projected, 35.7 miles of shoreline may
                        eventually rely on shoreline armoring for erosion protection, the loss of beach area could
                        increase to 65 acres. Even with the inclusion of mitigating lateral and vertical access dedications
                        where appropriate, clearly the loss of recreational access will be severe.

                                 Shoreline armoring alters the shoreline and shoreline processes in several ways. An
                        immediate and noticeable effect will be the physical encroachment or occupation of the shoreline
                        as mentioned above. If a section of beach is covered by revetment rock, the beach is no longer
                        available for beach access. A trail may be developed on top of the revetment, and while there
                        may be great benefit from such. a trail, the access opportunity would be different than that which
                        had been provided by the beach area.

                                 A more long-term impact from armoring will be its interference with long-term shoreline
                        retreat. A primary function of well designed shoreline protection is that it protect upland
                        development by halting or slowing future landward migration of the backshore. If the seaward
                        edge of the beach continues to erode, the available beach width will become more and more
                        narrow and will eventually disappear. Waves will run up on the revetment or to the toe of the
                        seawall and all beach access will be eliminated. Finally, if the back beach area is a source of
                        sand to the littoral system, efforts to armor the back beach will prevent this material from
                        reaching the littoral zone and nourishing beach areas downcoast. Thus, armoring can alter access
                        opportunities-in a number of ways.

                        Program Improvements
                                 Prepare procedural guidance for the development of standard access conditions to be
                                 implemented through the regional shoreline erosion and bluff retreat management plans
                                 (see Coastal Hazards Problem #1). These conditions may include, but not be limited to,
                                 discussion of the following mechanisms for ensuring public access:

                                 *  traditional easements such as lateral or vertical access, and non-traditional easements
                                    such as "rolling easements" which move landward as the beach area disappears and
                                    trail easements that may be landward, or on top of, shoreline armoring.
                                 *  in lieu fee programs to provide for regional access development and/or sand
                                    replenishment.

                        Opportunities In -the Longer Term
                            *    Pursue expanding Section 30235 of the Coastal Act governing protective devices to
                                 acknowledge the singular and cumulative negative effect that individual armoring
                                 projects can have on public coastal access and require all shoreline protective devices be
                                 designed to avoid or mitigate impacts to public coastal access.

                            *    Provide guidance for the development of regional programs for:

                                                        CALIFORNIA COASTAL COMMISSION                            PAGE 29
<pb n="33" />

              RECAP PILOT PROJECT

                      *    undertaking aggressive beach nourishment programs to replace armored beach areas
                           in order to maintain, and increase, public coastal access.

                      *    pursuing an acquisition strategy for privately-held coastal lands (especially areas that
                           are adjacent to public beaches), where any existing armoring could be removed and
                           public recreational areas could be expanded.

                    HAZARDS PROBLEM THREE
                                             Ord VINAU*'@'F

                      A large amount of shoreline armoring in the ReCAP pilot area has been put into place
              under "emergency" circumstances, either during or immediately following storm events. The
              emergency process allows for this annoring to take place with little regulatory review of the
              project, such as would be required through the standard permit process. Without this project
              review, shoreline protective devices are created and/or altered with:

              * minimal technical analysis/engineered design
              * minimal review of potential alternatives
              * minimal review of adverse impacts on coastal access.

                                                                                       NUIAARII_Ii:1900111 7- rn- P"' ff X1,11, "as
                      The ReCAP database showed that many of the issued armoring permits were emergency
              permits, many in response to the 1982/83 storms. Out of the 96 armoring permits, 24 (or 25%)
              were emergency permits; 5 new shoreline protective devices were permitted through the
              emergency process and 19 existing structures were maintained. Eighteen of the 24 emergency
              permits were issued during the severe 1983 storms, with many issued directly in the field.  is  All
              24 emergency permits were issued by the Commission, so nearly one-third of all Commission-
              issued armoring permits were issued as emergency permits. These same 24 emergency projects
              resulted in at least 24,000 tons of additional shoreline armoring. 16

                      Section 3 0611 of the Coastal Act states that the intent of emergency permits is to allow a
              rapid, non-permanent response "to protect life and public property from imminent danger."
              Section 30611 concludes with the limitation that it does not "authorize permanent erection of
              structures valued at more than twenty-five thousand dollars ($25,000)." Unfortunately, there are
              few inexpensive, temporary "stop-gap" measures for shoreline erosion and storm protection, and
              in most situations the emergency action ends up being a permanent structure.

                      Once the critical nature of an emergency situation has been recognized, emergency
              requests are generally granted due to concerns over public safety. While emergency permits
              usually require follow-up, regular permits to ensure detailed technical review andallow the
              incorporation of conditions for monitoring, maintenance or mitigation of impacts to public
              access, only a few of these emergency permits had associated regular permits.  17 It is the
              formalizing CDP process that would allow for the standard regulatory scrutiny of the project
              which, in turn, would provide technical analysis of the structure, analysis of non-structural
              alternatives, and mitigation of impacts to public shoreline resources. Many of the emergency
              permits were repair and maintenance waivers for existing shoreline protection permitted prior to

              PAGE 30                         CALIFORNIA COASTAL COMMISSION
<pb n="34" />

                                                                                                  CHAPTER 3 - COASTAL HAZARDS

                             the time period assessed by ReCAP; therefore, although those regular permits did not appear as
                             part of the ReCAP database, they would serve as the associated regular permit to the emergency
                             permit.

                                      Emergency armoring projects in the pilot area have typically occurred in high hazard
                             areas that have a high likelihood of storm driven events reoccurring in the future, leading to an
                             ongoing "emergency cycle". For example, in the Live Oak/Opal Cliffs area, an area of known
                             high hazard and extreme erosion over 40% of all recent armoring permits have been approved
                             through the emergency process.   I@ Live Oak/Opal Cliffs is discussed in Hazards Problem #I and
                             Figure 3-6 as an example of an area with little coherent approach to armoring; within
                             approximately 3,000 feet of beach, there are four distinct approaches to armoring and several
                             spots where two or three protective measures have been tried, one on top of or in front of the
                             other. In the absence of defined regional hazard management plans, the shoreline armoring put
                             in place with an emergency permit will typically result in haphazard placement of protective
                             materials in the specific geographic locations that are most in need of sound shoreline protective
                             devices.

                                      Some emergency permits were to add rock to existing revetments. Such actions, in non-
                             emergency situations, would be considered routine repair and maintenance. These projects
                             would require only baseline technical review and engineering rather than detailed technical
                             review and evaluation of alternatives. For a variety of reasons it seems that many property
                             owners postpone maintenance until a storm event. Emergencies are the worst time to undertake
                             proper and effective maintenance since the size and amount of rock may be dictated by
                             availability rather than engineering design and the locations which are protected will be those
                             which are easy to reach. Normally, these areas do not receive any more attention until the next
                             emergency. Regular permit follow-up for these "emergency" situations could plan for future
                             inspections and maintenance needs and break the cycle of crisis-based shoreline management.

                                      The areas of high hazards th at are currently susceptible to shoreline erosion and high
                             wave impact are expected to continue to be the hardest hit by both episodic storm events and
                             long term erosion. Without any regional shoreline planning prior to the emergency situation,
                             these same known hazardous areas will continue to see a collection of individual responses to
                             what is essentially a regional issue. The less "costly" emergency process (minimal filing
                             requirements, expediency of review, minimal project analysis, lack of required mitigation, etc.)
                             encourages an emergency response, so, absent program changes, large amounts of armoring will
                             continue to be put in place through the emergency process. The end result is short-term
                             protection of individual properties in a manner that may not have been analyzed for technical
                             adequacy or for impacts to coastal access.

                                      Concern about the use of the emergency process is not unique to the ReCAP area. One
                             of the key recommendations from the coastal hazards study by Griggs, Pepper and Jordan was to
                             strengthen the policies governing emergency protection projects. 19   Statewide, there is no
                             consistent follow-up of emergency actions nor assurance that emergency actions will either be
                             upgraded for permanent protection or removed following the emergency.

                                      The main issue for the processing of emergency shoreline protection permits is one of
                             ensuring that there is adequate review of the proposed project in terms of alternatives, technical
                             analysis, and public beach access, while accommodating the time constraints inherent in an
                             emergency situation. The emergency permit process needs to, as much as possible, agree with
                             and complement the review and analysis available through the regular permit process. The
                             emergency process must be improved to ensure standard review of the project after the
                             immediate crisis has ended. As part of a longer term effort, the mechanisms for an emergency
                             process should be included in comprehensive regional hazard plans that would define emergency
                             situations, outline acceptable designs and responses for emergency shoreline protection and
                             develop detailed review steps for foreseeable emergency actions.

                                                              CALIFORNIA COASTAL COMMISSION                               PAGE 31
<pb n="35" />

            RECAP PILOT PROJECT

            Pro        Im
                         provements:.
                    Prepare procedural guidance for the development of emergency shoreline erosion and
                    bluff retreat response plans suitable for implementation by ReCAP area LCP
                    jurisdictions through the regional shoreline erosion and bluff retreat management plans
                    (see Coastal Hazards Problem #1). These plans would pertain to the issuance of
                    emergency shoreline armoring permits; sub-components of procedural guidance should
                    include direction for the development of-
                         general engineering plans for different types of emergency armoring which would be
                         acceptable for specific areas and would accommodate the potential for redesign
                         and/or removal.

                    *    standard emergency permit cond   -itions and monitoring procedures to ensure that
                         emergency armoring complies with the same level of requirements as armoring
                         projects going through a standard permit review in a non-emergency setting;
                         mechanisms may include, but not be limited to, emergency fees, bond, and/or fines
                         as well as a formalized removal criteria and process.
                    *    program of public awareness altering coastal residents to the dangers that may be
                         posed by winter storms and how to respond in the event of an emergency.

                  HAZARDS PROBLEM FOUR

                    Setback distances incorporated into shoreline development approved in the ReCAP pilot
            area are not adequate in all cases to protect structures over the course of their lifetimes without
            the introduction of a hard protective device. Furthermore, the determination of "adequate"
            setback distances, relying greatly upon erosion rates that often overlook episodic erosion, does
            not always result in adequate long-term setbacks. This problem is particularly evident in high
            hazard areas that are already partially or substantially developed.

                    Throughout the ReCAP pilot area, the LCP policies use bluff top setbacks or shoreline
            setbacks in an attempt to ensure that new development will be at minimal risk from erosion,
            storm waves and bluff retreat. Typically these setback distances for ReCAP area LCP
            jurisdictions make use of a 50 year economic lifetime setback, often established as 40 or 50 feet
            from the bluff edge or beyond the point of maximum wave run-up, with provisions for allowing
            smaller setbacks if geologic conditions so warrant. 20 Structural setbacks are meant to minimize
            risk from these hazards by allowing natural processes to take place without threatening any
            structures on the subject property. The idea is that if the structures are far back from the
            shoreline, natural erosion and storm events will not adversely impact them and shoreline
            protective devices will not be necessary during the lifetime of the structure. Unfortunately,

            PAGE 32                          CALIFORNIA COASTAL COMMISSION
<pb n="36" />

                                                                                                                        CHAPTER 3 - COASTAL HAZARDS

                              setbacks do not address risk to all structures since setbacks can only minimize risk on a lot large
                              enough to accommodate both the necessary setback and the development. Also, setbacks do not
                              minimize risks to existing development, to new development on lots too small to accommodate
                              both a safe setback and development, or to any development which lasts longer than its
                              theoretical economic life.

                                        Setbacks are generally determined by an analysis of erosion rates along the coast;
                              unfortunately, erosion rates can be somewhat elusive. Among the numerous factors influencing
                              erosion rates (e.g., regional wave conditions, geologic conditions, sand budgets, and structural
                              development), one of the least understood and applied is episodic storm events. Coastal
                              engineers recognize the episodic nature of shoreline erosion; however, most setback regulations
                              are developed assuming steady, incremental erosion. While average annual seacliff erosion rates
                              in the ReCAP pilot region are commonly calculated at about one-half to one foot per year, these
                              rates must take into account episodic events that may or may not have been recorded for specific
                              areas or for specific time-frames. With these gaps in the historical record, as well as the
                              potential for an episodic event to be viewed as a rare occurrence with little probability of
                              repetition, average erosion rates may not represent the actual erosion process that is taking place.
                              As an example, during the winter storms of 1983, a top portion of a seacliff in Santa Cruz eroded
                              about 46 feet; this episode alone almost completely devoured the minimum adequate setback
                              required in the LCP.       21

                                        Table 3-2 shows some of the difficulties in attempting to quantify erosion rates and
                              setback distances. As shown, if analysts had theoretical data showing shoreline change back to
                              1954, they would likely estimate an erosion rate of 2 feet per year and would anticipate that a
                              100 foot setback would be the minimum necessary setback for 50 years of stability. If the
                              available theoretical data record only went back to 1970, the same site would be estimated to
                              have an erosion rate of only I foot per year and a minimum necessary setback of 50 feet would
                              be considered acceptable. If, in an effort to be conservative, the analysts were to add to the
                              minimum setback a distance equal to the maximum single event of retreat, an analyst using the
                              records from 1950 to 1990 would use the 30 foot retreat event from 1968, while an analyst using
                              the records from 1970 to 1990 would only add a 10 foot retreat event. Thus, an acceptable
                              setback for this theoretical site could range from 60 to 130 feet, depending on the extent of the
                              data record used to develop the retreat properties. And since both setbacks are based on historic
                              data, there is no certainty that either prediction will agree accurately with future events.

                                                                     Table 3-2: Difficulties in Calculating Setbacks

                                                                                                    Theoretical Retreat Rates
                                                                             :,:.:::::.:T in       T6W:                               5 Q-ij_ @ar
                                                                                                                                           Y
                                                                                                                . .... .             .... 1111- . . .. ....
                                                      ..........                                      .... . ..
                                                                                 P              M
                                                                                                                                  ::" 9 tb k:
                                                             t                   Perid             easure
                                                                                                                                        e, ac ...
                                                                                                    .. .... ......
                                                                                                                         ..... .....
                                                                                                     th at......
                                                        :4:954:             ........                 . . ....
                                                                              1950-1990             80'            2 ft./yr.             100,
                                                          ...............

                                          rie  t@tj..t.@]                     1960-1990             501           1.67 ft./yr.           83'
                                   110    f retreat:
                                        0
                                                                              1970-1990             20'             1 ft./yr.            50'

                                        The amount of pre-Coastal Act development along the shoreline in Santa Cruz and
                              Monterey Counties has substantially impacted setback effectiveness in the ReCAP region, as has
                              the high amount of development concentrated in urban service areas. In urban areas, most
                              development is an "infill" situation where the setback may be based not on the distance
                              necessary to protect the structure from threat during its life, but rather on the setback of the
                              adjacent structures, established as a "stringline" from these structures. "Stringlines" are setbacks

                                                                         CALIFORNIA COASTAL COMMISSION                                                PAGE 33
<pb n="37" />

                  RECAP PILOT PROJECT

                  determined by a line drawn between development on adjacent properties, rather than by a
                  standard setback distance. Ownership of a legal lot of record presumes a right to develop the
                  property regardless of the coastal hazards that are present. Unless setback policies change to
                  address the issue of infill development directly, areas of existing development will eventually be
                  built-out based upon a stringline approach that disregards hazards constraints and sites
                  development as near to the shoreline as possible, as is evident in the majority of the surrounding
                  parcels. Under this scenario, infill projects allowed in high hazard areas based upon historical
                  land use decisions will eventually require the same level of shoreline armoring as their
                  neighbors.

                          For reconstruction after a natural disaster, Section 3 06 10 of the Coastal Act allows
                  reconstruction in the same footprint as the original structure without a CDP, precluding any
                  analysis of potential alternatives -- regardless of the hazards involved. In fact, a conscientious
                  applicant who attempts to set back the building envelope of a reconstruction parcel from the
                  original footprint due to hazard constraints may be penalized by the imposition of CDP
                  requirements. In each case, hard protective devices may be necessary in order to protect the
                  structures prior to fulfillment of their economic lifetimes. The following examples illustrate the
                  actual implementation of these setback policies:

                      *   New development case: Two properties were being developed in an extremely
                          hazardous area, with project sites directly on sandy beach. Due to the fact that the
                          development was considered infill, not only were setbacks not considered (a string-line
                          approach was followed with respect to setback distance) but armoring was approved in
                          tandem with the new residences in seeming opposition to Section 30253(2) of the
                          Coastal Act. The Commission found that the "project area is nearly built out with beach
                          front residences so that it does not appear reasonable to prohibit the development of the
                          few remaining vacant lots despite the very real hazards from flooding and wave
                                  ,,22
                          action.     Both permits did contain conditions for lateral easements, as well as waivers
                          of Commission liability, among others.

                      *   Reconstruction case: A reconstruction project was approved that not only allowed re-
                          siting of the project in the same site as the original structure but also allowed for
                          additional structural expansion towards the bluff edge. This project, being sited in &amp;ti
                                                            23
                          area of known geologic hazards,      eventually required a new shoreline protective
                          device. 24

                          Finally, even when a full 50-year setback is used, the value of coastal land and the lack
                  of alternative coastal locations makes it unlikely that structures along the coast will be retired
                  after 50 years or the completion of their theoretical economic life. When structures are setback
                  using a 50 year economic life, they can be expected to "outlive" their setbacks and eventually
                  require armoring for long-term protection from erosion. ReCAP did not collect information on
                  building ages for development along the coast; however, from field investigations and informal
                  surveys it seems that a number of coastal buildings are 40 to 60 years old. If the generally
                  accepted estimate of economic life reflected actual structural life, most of these buildings would
                  have been removed. The 50 year economic life does not reflect the actual lifetime of a structure
                  or the length of time a coastal site will be occupied. (Note: Statewide, 46% of the coastal
                  jurisdictions using setbacks based upon economic lifetimes used either 75 or 100 years.)    25

                          If new development continues to be permitted in high hazard areas, setbacks should
                  function as they are intended to: allowing for natural processes to continue without the adverse
                  impacts that would be associated with the introduction of hard protective devices. By instituting
                  a setback based upon a 75 or 100 year economic lifetime and by using long-term average annual
                  erosion rates, a more realistic time span for retirement can be set for development. If setbacks
                  are based upon a practical economic lifetime for the structure, shoreline armoring will be

                  PAGE 34                           CALIFORNIA COASTAL COMMISSION
<pb n="38" />

                                                                                      CHAPTER 3 - COASTAL HAZARDS

                    unnecessary with the removal of these structures at the end of their economic lives. In tandem
                    with implementing this setback along the coastline, the regulatory program would require
                    procedural modifications to manage development in these high hazard areas setting forth specific
                    development criteria and requirements.

                            In order to better address reconstruction policy, the consideration of alternative strategies
                    and/or sites should be encouraged. A potential reconstruction project may need to analyze the
                    viability of the site due to the same hazard constraints to which new development would be
                    subjected. Options may run from an alternative building envelope on the subject property all the
                    way to acquisition of the subject parcel and transfer of development credit programs. One
                    response to the problem may be to modify the policy of permit exemptions to exempt
                    reconstruction provided that the structure is moved away from the hazardous constraints to the
                    greatest degree feasible, rather than sited in the same footprint or location. For example, the
                    policy language may say that reconstruction would not require a CDP if the structure is located
                    on a new footprint landward of the previous building site, at the site most protective of resources
                    (e.g., most landward, setback for a 100 year lifetime, not necessitating future shoreline
                    protection, etc.). In this way, landowners would continue to be allowed to reconstruct without a
                    CDP and hazard constraints would be better (although still not fully) addressed.

                            The Coastal Hazards study by Griggs, Pepper and Jordan recommends that "all
                    development proposals, including reconstruction or remodeling that increases the square footage
                    of the structure by more than 25 percent, must be evaluated on the basis of safety from all coastal
                    geologic hazards," and should be permitted "only when safety from wave impacts and inundation
                    throughout the projected I 00-year lifetime of the structure can be demonstrated without reliance
                                          9,26
                    on a protective device.

                              _M
                                                                 1110 WY

                    Program Improvements
                            Prepare procedural guidance on the benefits and uses of expanding development
                            setbacks for ReCAP area LCP jurisdictions from the current 50 year economic lifetime
                            to either 75 year or 100 year lifetime; sub-components of procedural guidance should
                            include direction for:

                                the development and delineation of mapped 75 year and 100 year setback lines
                                making use of long-term average annual erosion rates based on chronic and episodic
                                erosion.

                                mechanisms for updating mapped 75 year and 100 year setback lines every 5 to 7
                                years. The mechanisms would include guidance on compiling ongoing information
                                on long-term shoreline erosion, from such sources as project-specific geotechnical
                                reports, for incorporation into the setback delineation.

                                procedures for managing development within the mapped setback zones including,
                                but not limited to, urban/rural boundary distinctions, alternative setback distances
                                (including stringline setback criteria) and processes for regulating structural
                                development, shoreline protection, and subdivisions.

                    Opportunities In the Longer Term
                            Pursue modifications of Section 30610 of the Coastal Act regarding reconstruction of
                            property damaged or destroyed by ocean waves or erosion to allow for a new building

                                                    CALIFORNIA COASTAL COMMISSION                            PAGE35
<pb n="39" />

                    RECAP PILOT PROJECT

                             envelope relocated landward of the previous footprint; reconstruction without a coastal
                             development permit would be allowed provided that the new site is reviewed for
                             environmentally sensitive habitat and identified view corridors maintaining the same
                             size and use constraints as are now present in Section 30610.
                             Provide guidance for the development of strategies to address development constraints in
                             areas of high coastal hazards including, but not limited to:
                                 procedures on the use of waivers of public liability and other types of hold-harmless
                                 clauses as deed restrictions that require property owners to assume all responsibility
                                 for high hazard properties, and to waive access to disaster relief funds and other
                                 coastal hazard-related, subsidized economic assistance.

                                 identification and utilization of structural design criteria that allow for the
                                 construction of structures that can be easily moved and removed should coastal
                                 hazard conditions warrant relocation at some future date.

                             0   procedures for incorporating full permit review for all structures between the first
                                 public road and the sea that are damaged by wave action, bluff retreat, shoreline
                                 erosion, or any other coastal hazards (such as tsunamis, earthquakes, fires, flooding,
                                 etc.).

                             0   utilization of transfer of development credit programs to compensate for coastal
                                 development that is infeasible due to site-specific coastal hazards constraints.

                           HAZARDS PROBLEM FIVE

                             In the ReCAP pilot area, development has been located in high hazard areas immediately
                   adjacent to eroding shorelines. New development in the region is likely to continue this practice
                   and locate on the remaining coastal lots. Once located in these areas of high hazard, this
                   development can be expected to be threatened by shoreline erosion. The traditional response in
                   the ReCAP region to such a threat is to construct shoreline armoring to halt the erosion, thus
                   encroaching onto public beach areas in the process and shifting much of the cost of risk
                   reduction from the private development to the public.

                             When development is allowed in areas of high coastal erosion, it should come as no
                   surprise that those developments will eventually require protection if their shoreline locations are
                   to be maintained. This armoring of the coastline is typically put in place at substantial public
                   cost, both in terms of subsidies such as low-interest loans, disaster relief funds, and joint
                   public/private ventures as well as public loss of beach area, beach access, and coastal
                   aesthetics.  27 With ocean processes and geologic instability contributing to an actively eroding
                   California coastline, coastal parcels today are more at risk than ever before.   28 Since the current
                   'state of coastal hazards planning does not systematically restrict development in areas of high
                   hazards, inappropriate development may continue to be sited along the shoreline. Given the

                   PAGE36                             CALIFORNIA COASTAL COMMISSION
<pb n="40" />

                                                                                                CHAPTER 3 - COASTAL HAZARDS

                         current coastal hazards policy framework in California, costly shoreline armoring will be
                         required in order to maintain the development's perilous perch.

                                  On the state regulatory level there appears to be a dichotomy between Sections 30253
                         and 30235 of the Coastal Act regarding the level of safety expected for siting new versus existing
                         development. Since many LCPs repeat these sections, the CCMP provides confusing guidance
                         on coastal hazards and shoreline armoring. While Section 30253(2) requires the stability of new
                         development without future reliance on protective devices, Section 30235 provides that a
                         recently built beach level or bluff top structure will be allowed the exact protective devices that
                         30253 disallowed before the structure was built. If the structure was truly built to not necessitate
                         future shoreline protective devices (as per 30253), little or none of the development built since
                         the Coastal Act should require protective devices. Section 30235 allows seawalls to protect
                         existing structures where "existing" has been taken to mean the time at which the application for
                         armoring is made. While other states have used cutoff dates coinciding with enabling legislation
                         for their definition of "existing" structures (for example, existing as of January 1, 1977), or have
                         legislation that prohibits armoring or any construction seaward of a legislatively enacted setback
                         line, California has not taken these types of steps to limit armoring. 29 For Sections 30235 and
                         30253 to function symbiotically, there needs to be a cut-off date that treats pre-Coastal Act
                         development differently than post-Coastal Act development due to different regulatory policies
                         being in effect (i.e., pre-Coastal Act development was not subject to Section 30253 and thus may
                         require shoreline protection while post-Coastal Act development should have been constructed in
                         such a way as to meet Section 30253 requirements for stability and not require protective
                         devices).

                                  At a federal level, some programs contribute to the incremental increase in reliance on
                         shoreline armoring for coastal properties. A federal agency that has a large impact on coastal
                         hazard management in California is the Federal Emergency Management Agency (FEMA),
                         which provides insurance for coastal properties and low-interest loans for emergency armoring
                         and rebuilding fo 'llowing a disaster. FEMA assistance to private property owners who have built
                         in areas of high coastal hazards provides a.direct public subsidy to private development.
                         Throughout the entire state, shoreline protection and repair of damaged structures has averaged
                         over $100 million annually.  30 This is a significant expenditure of public and private funds for
                         shoreline development, with little, if any, overall direction on the ultimate intent of these efforts.

                                  While the construction of new armoring seems to have slowed since enactment of the
                         Coastal Act, additional armoring has occurred in the ReCAP area with both regular and
                         emergency permits approved by the Commission. Much of the ReCAP area coastline, with the
                         exception of approximately 14 miles of shoreline close to the Pajaro River and small isolated
                         locations totaling another 6 miles, has been identified as having either critical or non-critical
                         erosion. 31 Over 55 miles of coastline in the ReCAP area are considered erosional. Over time,
                         more and more "non-critical" erosion will become "critical" as protective setbacks become too
                         small to continue to afford protection. In time, it can be expected that most privately held
                         developed coastal property, and some publicly held coastal property, will be threatened by
                         erosion and property owners will apply for some form of shoreline armoring. This type of future
                         armoring will be increased by future development of coastal lands or the conversion of coastal
                         agricultural lands to more development-intense land uses.

                                  If current regulations for armoring continue, it can be expected that eventually much of
                         the coast will be armored, either with vertical walls or rip-rap revetments. Future demands for
                         armoring can be expected from existing and future development, both future development on
                         existing lots of record and on future subdivided lots. While some future demand for armoring
                         may be prevented by careful review of any new subdivisions to ensure adequate, long-term
                         setbacks for all coastal lots, such efforts will not be effective for many existing lots of record or
                         existing development. ReCAP review identified that 12 miles of existing shoreline is now

                                                           CALIFORNIA COASTAL COMMISSION                                 PAGE37
<pb n="41" />

                 RECAP PILOT PROJECT

                 armored and a rough review of land use patterns and shoreline characteristics has identified over
                 27 miles of shoreline which may ultimately be armored under existing policies.

                         Currently the ReCAP area encourages the use of rip-rap, which would occupy vast areas
                 of public beach. With a conservative estimate of 20 feet of encroachment onto public beach by a
                 rip-rap wall and 4 feet of encroachment by a vertical wall, the current armoring occupies
                 approximately 25 acres of public beach; should the future armoring estimates hold true, 27.5
                 miles of new revetment would eliminate over 65 acres of shoreline from public use (comparable
                 in scale to losing all of Moss Landing or Natural Bridges State Beach). In addition, as the
                 shoreline continues to erode, the beach in front of these walls will become smaller and ultimately
                 the walls will be in the surf zone with little or no usable beach. Access stairs will drop into the
                 surf and the only accessible beach will be along small sections of coast without erosion or at
                 public parks. 32 Ultimately too, this loss of beach will limit the ability of property owners to
                 repair and maintain their seawalls.

                         Land use planning with an emphasis on coastal hazards avoidance would identify those
                 areas of rapid coastal erosion and high ocean impacts where it is not appropriate to site public or
                 private development. These high hazard areas will eventually require some type of hazard
                 response at considerable public expense. It is clear that coastal land-use planners and regulators
                 need to develop new ways for looking at the issues of coastal hazards.

                                                                     -;F 0@7                  7,7 771T
                                     ................. ' 05 N"", PERU:      QN,wA
                                  IXTUJ'!@                                                        x KRY577,
                                                                                                        N
                                                                                                        RUM

                         ni iew    th'         `7     51
                  PP rtul"...    h  .: e oiWr -em
                        Pursue amendments to Section 30235 of the Coastal Act to:

                             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 were an issued
                             building permit as of the effective date of the amendment. No permanent shoreline
                             protective device would be permitted for development receiving a building permit
                             after the effective amendment date.

                    * 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.

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

                        *    prohibit any remodeling project adjacent to an eroding coastline from expanding
                             seaward regardless of the size of the remodeling.
                        *    require full permit review if the rebuilding of property damaged or destroyed by
                             ocean waves or erosion occurs in the same footprint; require only a review for
                             environmentally sensitive habitat and identified view corridors if the rebuilding
                             occurs either entirely outside the new development setback or at the most landward
                             portion of the property, if location landward of the new development setback line is
                             not possible, maintaining the same size and use constraints as now used.
                    * Pursue research that examines and analyzes the policy implications of the public subsidy
                        of private development along the California coastline due to coastal hazards and the

                 PAGE38                           CALIFORNIA COASTAL COMMISSION
<pb n="42" />

                                                                                                                 CHAPTER 3 - COASTAL HAZARDS

                                      implementation of the Federal Emergency Management Agency process and disaster
                                     relief funds.

                               1Griggs, Gary, James Pepper and Martha Jordan, California's Coastal Hazards: A Critical Assessment ofExisting
                               Land- Use Policies and Practices, California Policy Seminar Report, Berkeley, Page xix. 1992.
                               2The Area of Demonstration is taken from the California Coastal Commission, "Statewide Interpretive Guidelines",
                               as of December 16, 1981 (Supersedes May 5, 1981 edition). The "Area of Demonstration" is within the area of a 20
                               degree angle from the toe of a cliff or within 50 feet of the face of the bluff of cliff, whichever is greater.
                               3Approximately 4,000 linear feet of this shoreline is protected with rip-rap extending, conservatively, 20 feet from the
                               bluff face. This is a highly used recreational beach and yet this protection alone encroaches onto more than 1.8
                               acres of beach.
                               4US Army Engineer Division, South Pacific, Corps of Engineers, San Francisco, National Shoreline Study:
                               California Regional Inventory. August 197 1.
                               5Comments provided by Norbert Dail. December 12, 1994 at Santa Cruz workshop.
                               6ReCAP database, Hazards sub-module.
                               7In addition to the 79 Commission approved structures for the 1983-1993 time period, there were two other permits
                               approved by the Commission involving shoreline armoring: one involved the removal of rip-rap and the second
                               involved conditions stating that a hard protective structure would not be allowed in the future. As these projects did
                               not result in additional armoring being approved, they have been excluded from this analysis. [Note: only one
                               Commission reviewed permit involving shoreline protection was denied from 1983-1993; this project was
                               eventually approved.]
                               8ReCAP database, Hazards sub-module.
                               9 ReCAP database, Hazards sub-module.
                               to US Army Corps of Engineers, San Francisco District, Santa Cruz Harbor and Vicinity Shoaling: General
                               Investigation Study, Reconnaissance Report. January 1994.
                               11 Ibid.
                               12 Ibid.
                               13 Ventura County is one such area, with standard designs for vertical walls and maps that identify the coastal locations
                               where each design has been found to be appropriate.
                               14 Griggs, Pepper, and Jordan. Page 31. 1992.
                               15 ReCAP database, Hazards sub-module.
                               16 Only fifteen of the emergency permits recorded the number of tons of rip-rap placed, thus the 24,000 ton figure
                               likely underestimates the actual amount of rock placed through the emergency process,
                               17 ReCAP database, Hazards sub-module.
                               is Permitting figures from the ReCAP database, Hazards sub-module; Live Oak/Opal Cliffs characterization as
                               described in: Griggs, Gary and Lauret Savoy, eds. Living with the California Coast,. Duke University Press. Pages
                               186-187. 1985.
                               19 Griggs, Pepper and Jordan, Recommendation #6, Pages 191 and 192. 1992.
                               20 Of ReCAP area certified LCP jurisdictions, only Santa Cruz City does not define the 50-year economic lifetime
                               setback, instead using an undefined economic lifetime (See Coastal Commission document "Overview of Local
                               Coastal Programs Relating to Hazards and Shoreline Development").
                               21 The Santa Cruz County LCP generally requires a 50 foot setback for development along the coast.
                               22 From California Coastal Commission staff reports for coastal development permits 3-81-149, 3-81-149-A, 3-81-150,
                               and 3-81-150-A.
                               23 Live Oak area of Santa Cruz County.

                                                                    CALIFORNIA COASTAL COMMISSION                                            PAGE39
<pb n="43" />

                   RECAP PILOT PROJECT

                   24 From California Coastal Commission staff reports for coastal development permits 3-81-055 and 3-81-055-A, and
                      Santa Cruz County permit findings for permit 87-0556 (California Coastal Commission identification number 3-
                      SCO-87-094).
                   25 Griggs, Pepper, and Jordan. Page 130. 1992.
                   26 Griggs, Pepper and Jordan. Pages 187 and 188. 1992.
                   27 Griggs and Savoy. Pages 47-48. 1985.
                   28 It has been estimated that out of California's 1, 100 miles of coastline, 86% is "actively eroding". Griggs, Pepper
                      and Jordan. Page xix. 1992.
                   29 In Oregon, state law prohibits hard shoreline protective structures for property developed after January 1, 1977. In
                      Florida, buildings developed within "Coastal Construction Control Lines" must meet state standards for surviving a
                      100 year storm event; buildings approved by the state cannot apply for protection since they have been designed to
                      avoid the need for protection.
                   30 Griggs, Pepper, and Jordan. Page xix. 1992.
                      U.S. Army Engineer Division, South Pacific, Corps of Engineers, San Francisco, National Shoreline Study:
                      California Regional Inventory, August 1971. From this 1971 inventory by the ACOE, erosion was critical if
                      11 experienced judgment indicated that prospective damage prevented and benefits from tangible and intangible
                      values may justify action to halt erosion (Page 3). "Areas with roads or houses in danger from erosion are classified
                      as non-critical erosion if it is economical to abandon or move the facilities." (Page 23).
                   '2 Anecdotal evidence points to these types of scenarios as already occurring within the ReCAP pilot area (e.g.,
                      Pleasure Point/Opal Cliffs area of Live Oak in Santa Cruz County).

                   PAGE 40                               CALIFORNIA COASTAL COMMISSION
<pb n="44" />

                                                                                                       CHAPTER 4 - ACCESS

                                                  D

                                                                      .............

                                                           TEE, . . ... ...
                                                      IN
                             Cumulative impacts to coastal access result from the overall loss of coastal recreation
                     opportunities. Defined broadly, these opportunities include not only the physical availability of
                     beach sites, but also the ability to reach and utilize those sites. In the ReCAP area, most impacts
                     have occurred: (1) due to incomplete mitigation of development projects, (2) as a result of
                     physical beach loss due to the construction of shoreline protective devices, and (3) due to overall
                     increases in use of recreational sites. The increase in use of beach areas leads to overall
                     congestion, strains on the available facilities, and impacts to site quality, all of which affect use
                     of recreational sites. In addition, increasing use often leads to impacts on sensitive habitat.

                             One goal of the California Coastal Management Program is to ensure maximum coastal
                     access in balance with coastal resource protection. In the ReCAP region, the overall supply of
                     physical access to and along the coast improved significantly since 198 1, due to the addition of
                     several new accessways and improvements to existing access sites. Many of these
                     improvements result from conditions required by the Commission or local governments to
                     mitigate impacts on access from individual development projects. The availability of coastal
                     access for physically challenged users also increased. In addition, both the California
                     Department of Parks and Recreation and the Monterey Regional Park District purchased land for
                     public use, which has enhanced coastal access.

                             However, cumulative impacts to coastal access opportunities are evident throughout the
                     region. In part, this is because required mitigation of development projects impacting coastal
                     access is often incomplete. For example, a primary tool used to mitigate impacts is the use of an
                     offer to dedicate an access easement for public use; of the 92 offers required at this time, only
                     one has been currently opened and available for the public in the ReCAP region. Thus, one of
                     the major implementation tools for addressing impacts to public access is not fully mitigating
                     those impacts. Several of ReCAP's recommendations will result in improving the effectiveness
                     of current mitigation efforts.

                             In addition, as overall growth and demand for access continue, even if the maximum
                     supply of physical access is available for public use, impacts to other aspects of access will
                     become increasingly critical, particularly with regard to parking and transit accessibility, the
                     availability of support facilities, the overall quality of the recreational experience. The impacts
                     to these other variables often cannot be easily tied to a specific development project, and
                     therefore become difficult to fully mitigate through a project-by-project review of development
                     proposals. Improvements in how permit review analyzes public access and improved regional
                     planning for access will help address these cumulative impacts. A number of ReCAP's
                     recommendations, including the development of beach and regional management plans, are
                     designed to initiate these improvements.

                     Policy Framework
                             Due to the historic importance of coastal recreation in the ReCAP area, providing for and
                     managing public coastal access into the future is vital. A primary mandate of the Coastal Act, to
                   4

                                                       CALIFORNIA COASTAL COMMISSION                                PAGE 41
<pb n="45" />

                   RECAP PILOT PROJECT

                   provide maximum access to and along the shore, is required by the California Constitution under
                   Section 4, Article 10. After the Coastal Commission certifies a jurisdiction's Local Coastal Plan
                   (LCP), the local government assumes responsibility for implementing the Coastal Act's goals
                   and objectives on a local level, including providing maximum public access. Access is also
                   managed by some nongovernmental managers and the California Department of Parks and
                   Recreation (DPR). DPR is required to develop a comprehensive recreational policy for
                   California; this policy incorporates coastal areas, although the plans do not specifically discuss
                   coastal recreation. In the pilot region, DPR manages I I coastal units; a twelfth (Lighthouse
                   Field State Beach) is owned by DPR, but managed by Santa Cruz City.
                           To ensure maximum public access, the Coastal Commission and local governments must
                   both protect existing access and ensure the availability offuture access commensurate with a
                   growing demand. Several policies in the Coastal Act serve to meet this objective: the Coastal
                   Act requires that development will not interfere with the public's right to the sea (Section
                   30211); specifies the need to protect ocean front land suitable for recreational use (Section
                   3022 1); and requires the protection of upland areas to support coastal recreation, where feasible
                   (Section 30223). Most of the LCPs in the region specify various projects to enhance the physical
                   supply of coastal access and require access dedications as a mechanism to mitigate access
                   impacts from new development along the shore.

                           However, the objective of providing coastal access'must often be achieved consistent
                   with other Coastal Act objectives: ensuring public safety (Section 30212); protecting sensitive
                   habitat and species (Sections 30212, 30214); protecting agricultural use (Section 30212); and
                   protecting private property rights (Section 30214). As a result of these objectives, access may
                   not be appropriate at every street end or may need to be managed. As development and
                   population increase, the need to balance these objectives in determining how to "maximize"
                   access will also increase.

                          There are a variety of ways to define coastal access and to assess cumulative impacts to
                   access. Coastal access is generally viewed as an issue of physical supply. The supply of access
                   can be described as lateral access (access across a beach), vertical access (access from the upland
                   street or bluff to the beach), trails above the coast (for example along a blufftop), or upland trails
                   that lead to the coast. ReCAP focused primarily on an assessment of lateral and vertical access
                   immediately along the shoreline. It should be noted however that upland trails form a vital
                   component of an access network.

                          While the physical supply of access is a primary factor in assuring access opportunities,
                   an access program cannot view the issue of supply in isolation of a number of other factors, as
                   illustrated in Figure 4- 1. These variables include: availability of transit to beaches; parking
                   availability; providing other necessary support facilities, such as restrooms and picnic areas;
                   addressing user demands and conflicts; and maintenance of a diversity of coastal recreational
                   experiences. Impacts to any one of these variables may ultimately affect the availability and use
                   of the physical supply of access. For example, without adequate parking or alternative
                   transportation, users will have difficulty reaching an access site. Similarly, a lack of adequate
                   support facilities or a site that is perceived as over-crowded may make a site less desirable for
                   some users. In other cases, the development of extensive support facilities, which often draws a
                   larger number of users, may not be appropriate. Therefore, managing coastal access and
                   ensuring that growth and development does not cumulatively impact the resource, involves
                   managing not only the physical supply of access, but all the other variables that contribute to
                   ensuring maximum coastal access.

                          The Coastal Act and LCPs have policies directed at several of these other variables. The
                   Coastal Act identifies the need to enhance access to the coast by providing transit service and/or
                   adequate parking (Section 30252), the need for support facilities (Section 30223), and the need to

                   PAGE42                          CALIFORNIA COASTAL COMMISSION
<pb n="46" />

                                                                             Figure 4-1: Access System Diagram
                                                   SOURCES OF IMPACTS TO ACCESS

                                                                      Growth and Development                      Change in demographics grid
                                                                                                                  socio-economics

                                                                  closures      maintenance                                        Accessibility to Site
                                                                  restrictions fees                                                Local vs. regional
                                                                  acquisitions                                                     Transit options
                                                                  encroachment                                              -      Parking availability
        0                                                         mitigation                                                -      Travel time
        &gt;                                                                                                                          Congestion
        -n             Effects of Access
        0
        X              Impact to sensitive  'habitat
        &gt;              Carrying capacity/overuse
        0              Neighborhood impacts-parking
        0
        &gt;              Economic Impacts
                                                                      Su ply                                                           Distributionl Equity
                                                                        P
        &gt;                                                             vertical/lateral beach                                           Access points
        0                                                             parks                                                            Facilites
        0                                                             trails                                                           Types of use
        9
                                                                      marinas/harbors
        U)                                                            piers
        0                                                             day use facilities
        z                                                             dive areas
                                                                      surf areas
                                                                      developed/undeveloped sites
                                                                      scenic view areas                                                    Site Quality
                                                                                                                                            User satisfaction:
                                                                                                                                            water quality                            0
                                                                                                                                            capacities                               &gt;
                                                                                                                                            facilities
                                                                                                                                                                                     M
                                                                                                                                            types of access                          X
                                                                                                                                            scenic impacts
        T                                                                                                                                   conflicts                                &gt;
        &gt;                                                                  Demand                                                                                                    0
                                                                           U                                                                overall satisfaction                     0
        M                                                                    ser Needs:                                                                                              M
                                                                           types of access
                                                                           facilities
                                                                           capacities
                                                                           user conflicts
                                                                           access to sites
<pb n="47" />

                        RECAP PILOT PROJECT

                        distribute facilities throughout the coastline (Section 30212.5). Most of the LCPs also recognize
                        the need for beach parking and alternative transit options.

                        Resource Conditiolif
                                 Available data indicate that beach use has increased in the ReCAP area. Figure 4-2                   1and
                        Figure 4-3 show levels of use for the City of Santa Cruz and DPR beach areas in the region.
                        Using a linear regression, these figures indicate a 45% increase in use for Santa Cruz City beach

                                                        Figure 4-2: Santa Cruz City Beach Use, 1982-1993

                               3,600,000 -

                               3,000,000 -
                                                                              Zz
                           CL
                               2,500,000
                           0
                               2,000,000-    V,                                         0011-
                                                              ,00g'
                           0

                               1,600,009
                           E   1,000,000
                           Z
                                  500,000        OEM                                1111111111IN           I     I
                                       0 _L             I        I    I             MINIM.                A      I
                                             C4     cn            W      0                            0      V-      9      C*
                                             am     al                                                       C"             0)
                                             0)     IN     a,                                                0              W

                                           Source: City of Santa Cruz              Year
                                           Note: Data not available for 1983,1984,1988, and 1989

                                                      Figure 4-3: Use in Coastal State Park Units, 1981-1992

                               3,000,000      17-1 Free V hicles
                                              I1lllllllllllllll@Paid hicles
                                           _V1
                               2,500,000 -
                                                                                  -w
                           CIO                --0-- Free Walk-ins
                           0
                                                                       ME
                           IL  2,000,000
                           0
                                                                                         v

                                                        @4,
                               1,500,000 -

                                                    01,
                               1,000,000-
                                                                                                                                J1,
                                                                                                   ""Al
                           E
                                                                             A,                     4
                           Z    500,00: -
                                           1981   1982    1983   1984   1985   1986   1987    1988   1989    1990  1991     1992

                                           Source: California Department of Parks and Recreation Year
                                           Note: Excludes Big Basin Reftroods State Park
                       between 1982 and 1993. For State Parks, the increase in use is 83% in walk-in users, 18% in
                       vehicles which pay no fee, and 55% in paid vehicles during approximately the same time                     qeriod.
                       If numbers of vehicles are converted to numbers of people, using DPR conversion factors, the
                       overall increase in use for the region's State Parks is approximately 50%. Comparison of this
                       increase in use with the growth in population in the Santa Cruz and Monterey Counties indicates
                                                                                                                            3
                       that beach use grew twice as fast as population increase during the same time period                 . Since at

                       PAGE 44                                CALIFORNIA COASTAL COMMISSION
<pb n="48" />

                                                                                                                               CHAPTER 4 - ACCESS

                           least part of the growth in use is apparently from tourism, planning for adequate coastal access
                           must address use issues beyond the local area, particularly issues such as parking and transit
                           availability.

                                     Coinciding with this overall increase in use is a rise in specialized sports, particularly,
                           surfing, jet-skiing and other use of thrill craft, wind surfing, diving, hang-glidin§, mountain
                           biking on trails and on sandy beaches, equestrian riding, kayaking, and diving.                      4, ,6,7,8 Demand
                           for boating facilities has also increased. Both Santa Cruz and Monterey harbors have historically
                           been unable to meet demand for berths, and both have extensive waiting lists.                       9, 10 With an
                           increase in use and a diversification of activities in fairly confined areas, conflicts between users
                           also become more common."""" This trend of increasing use and diversifying activities leads
                           to many of the cumulative impacts evident in the region.

                                     Increasing use generally leads to demand for additional supply, although an increase in
                           supply may in itself generate more use by drawing more people to the area. Overall, the supply
                           of lateral and vertical access in the pilot region has increased since 198 1, both through the
                           opening of several new beach areas and new stairways, and through significant improvements to
                           existing areas of use by formalizing paths. (See Figure 4-4 on page 47 for location of access
                           sites identified by ReCAP.) Numerous other projects enhanced access by providing easier lateral
                           access along the coast; these include the Monterey-Pacific Grove Recreation Trail, the Spanish
                           Bay Recreation Trail, improved access to the Santa Cruz Harbor, bike paths in Santa Cruz, and
                           trails along several wetlands. (See Appendix A for detailed access improvements in the ReCAP
                           area.)

                                   Table 4-1: Shoreline Areas in ReCAP Region that do not Meet LCP Vertical Access Standards in 1994

                           Area            -                                                                                       Miles (approx.)
                           Southern end of Natural Bridges                                                                         .3
                           West Cliff Drive except area near Almar St. stairs                                                      1.5
                           Northern end of Cowell Beach                                                                            .15
                           Opal Cliffs Drive except at Key Beach (private, pay beach)                                              .6
                           Southern end of Capitola Beach to, and including, northern end of New                                   .5
                           Brighton State Beach
                           Potbelly Beach, Las Olas Drive area                                                                     .35
                           Rio Del Mar area: Beach Drive and Via Gaviotta                                                          .5
                           La Selva Beach area                                                                                     .25
                           South of Manresa State Beach to area around Monterey Bay Academy                                        .8
                           South of Palm Beach and northern part of Zmudowski State Beach                                          1.3
                           South of Zmudowski State Beach and north part of Moss Landing State Beach                               .45
                           Monterey Dunes Colony and near Salinas River Wildlife Refuge                                            1.9
                           Northern Marina Dunes area                                                                              .95
                           Fort Ord                                                                                                4
                           Naval Postgraduate School area                                                                          .2
                           Hopkins Marine Research area                                                                            .6
                           Segment at Carmel River State Beach                                                                     . I                   I
                           Note: For ease of reference, common names of beaches are used when possible. Beach names in this 5 le d not mean that vertical
                           access is completely unavailable at these beaches; vertical access is unavailable only along the sections of beaches noted above.

                                     In order to meet the demand for the region and minimize overburdening of sites, vertical
                           access sites should be distributed throughout the area. One measure of whether access is
                           distributed and maximized is to compare available access opportunities with established
                           standards. Both the Santa Cruz County and Monterey County LCPs have adopted standards for

                                                                    CALIFORNIA COASTAL COMMISSION                                             PAGE46
<pb n="49" />

                  RECAP PILOT PROJECT

                  vertical access for urban and rural areas. 14 Based on these standards, approximately 75% of the
                  ReCAP coastline that is physically suitable for public access currently provides such access; only
                  about 15 miles of the shoreline that could support access, do not 15 (see Table 4-1, previous page).
                  However, although vertical access is not provided at these areas, many have good lateral access.

                          A second key issue in assessing the adequacy of public access is determining if
                  improvements are keeping pace with population growth, use, and/or new development in the
                  area. As noted in the Regional Overview section of this report, the ReCAP area has experienced
                  significant development and population growth since 198 1. Much of this growth has probably
                  contributed to an overall increase in recreation use, even though much of the new development
                  may not be in the coastal zone. Most areas in the ReCAP region show a general correlation
                  between increased population and/or development and improved access. Physical access in
                  Santa Cruz County improved approximately 36%, while access in Monterey County improved
                  approximately 8%, leading to an overall increase for the region of approximately 2 1%. (For a
                  full discussion of this analysis and how access was quantified, see Appendix B.)

                          Overall growth and development in the Monterey Bay area is expected to continue,
                  although the amount of new development in the coastal zone may be minimal as the amount of
                  vacant land diminishes. The use of access areas will also likely continue to increase, due both
                  from increasing use within the region as population growth increases and from continued tourism
                  from other areas. However, the amount of additional physical access possible is limited. Many
                  beaches in the pilot region that currently do not support coastal access are unlikely to be able to
                  support it in the future, due to geographic constraints or conflicts with other uses. Santa Cruz
                  County currently provides access at approximately 88% of maximum possible; Monterey County
                  currently provides access at approximately 59% of maximum. Overall, the ReCAP region
                  provides access at 7 1 % of maximum possible. 16 (For a complete discussion of how maximum
                  access was calculated-, see Appendix B.) While these figures indicate the possibility of some
                  additional access, particularly with the future development of coastal access at Fort Ord,
                  ultimately the supply will become saturated. At that point, adding another stairway will have
                  minimal benefits for coastal access. As use continues to grow, factors such as accessibility to
                  sites and maintaining the quality of access sites will play an increasingly vital role in ensuring
                  that maximum access is available to the population.

                          Since the above analysis indicates that the physical supply of access has generally kept
                  pace with growth and development in the region, ReCAP focused additional analysis on some of
                  the other variables that affect access. Based on available data and discussions with local
                  recreation managers, ReCAP focused on: (1) the effectiveness of mitigation measures; (2)
                  impacts from seawalls; (3) possible resource/access conflicts; (4) impacts to parking and
                  accessibility to the coast; (5) access issues with regards to changing demands and demographics;
                  and (6) the need for a more regional approach to access planning.

                          ACCESS PROBLEM ONE

                          To be fully effective in mitigating impacts to access from development, offers-to-
                  dedicate must be recorded, accepted, and available for public use. Additional mechanisms may
                  also be needed in the future to supplement the offer-to-dedicate process.

                  PAGE46                          CALIFORNIA COASTAL COMMISSION
<pb n="50" />

                                                                                                                                                                                                                                                                                          California Coastal Commission
                 Sontc Cruz Coun                                                Monterey Coun
                   NORTH SAV7A CRUZ COUNTY COUPLEX                                NORTY MON7FREY cOuNry comPLEe
                                                                                                                                                                                                                                                                      Regiona            Cumulative Assessment Project
                 I. Big Basin State Pork.- Wcodell Creek Beach               52.  Zmudowski State Beach
                 2 6rephound Rock Beach                                      53.  Moss tonding State Beach
                 J. Scott Creek Beach                                        54.  KirbY Park
                 4. Davenport tondIng Beach                                  55   Elkhorn Slough WIdIffe Areas                                                                                                                                                 Public. Access Locatiolis
                 5. Davenport 6eoch                                          56.  Moss Landing Harbor
                                                                                                                                             Pt. AA,,
                 6. Pon th er Beach                                          57   Moss Lonaling Marine        L ab orc tory                   Nuevo
                 7 Bonny Doon Beach                                          58.  Salinas River State Beach
                 8 Yellowban* Beach                                          59   Monterey Boy Dune Colonl                                                                                                          S       A    N     T A
                 9. Loguno Creek Beach                                       60.  Salinas   River WIldlife Area                                             2
                 10. Red ;Mile, and Blue Beach                                    MARINA COMPLEX
                 11. 9111der Ranch State Park Beaches                        61.  Dunes Drive Access                                                                                                                             C     R     U      Z
                 12. Long Morine Laboratory*                                 62.  Morino State Beach                                                                               Bonn                                                                                                                           Study Area
                   Natural grioges State Beach                               6J.  Locke Poddon Pork                                                                    4           Doon                                                                                                                               Location               CA
                   9EST CLIFF DRIVE COMPLEX                                       SAND C17'Y1Y0N7FRf'Y COMPLEX                                                                5
                 14. West Cliff Overlooks                                    64.  f -ort Ord                                                                          Davenport
                                                                                                                                                                          6
                 15. Almar Avenue Stcirwcy                                   65.  Sand City Access Wo                                                                                                                    Son to        Soquel
                                                                                                              y
                 16. Lighthouse Field State Beach                            66.  Roberts take                                                                                                                              Cruz                38-39
                 17. Felton Avenue Stairway                                  67   Monterey State Beach                                                                                                                          0      7                    40                       1
                 18. Steamer I-one Stairway                                  68.  toguna Grande                                                                                              10              18 20
                 19. Monterey Street Stairway                                69.  Navol Postgraduate School beach area                                                                                                                          35-37 4
                 20 Cowell Beach                                             70.  Monterey State Beach (WIndows on the 8cy)                                                                                                        1
                 21. Neory's Lagoon Clty Pork                                                                                                                                                                               Pt. Santa         32 - 34 42
                                                                             71.  Mon tere                                                                                                                                       Cruz
                                                                                            .y Beach Park
                 22. Santo Cruz Municipol Hharf                              72.  Del Monte Beach                                                                                                                14 1                           1                4.345                                                 1\
                 2J. Santo Cruz Beach and Boardwalk                               M0A/7Z-RfY CITY COUPLEX                                                                                                                   6-17          29-30                             6                      Watsonville
                 24. Son Lorenzo River Bike Path                             73   Mon tere                                                                                                                                                                        48        7                            14
                                                                                            .y Municipal Wharf f2                                                                                                           - 4
                 25. Santo Cruz Harbor                                       74.  Monterey Manna                                                                                                                                       28                                   49                                         1,/
                 26. Twin takes State Beach                                  75   Mon ter&amp;                                                                                                                                       25-26                                                                                     Aromas
                                                                                            y f7sherman's Marf
                   EAsr qlFr DRIvE coypifx                                   76.  Monterey Coast Guard Pier
                 27 Sunny Co ve                                              77   Shoreline Pork - East                                                                                                                                                                  51
                 28. Corcoran Lagoon                                         78.  Breakwater Cove                                                                                                                                                             PqP&amp;r0 River
                 29. Moran Lake Beach                                        79   Son Carlos Beach
                 JO. Rockview Drive Overlook                                 80.  Aeneas Beach                                                                                                                                                                        52
                 34 Pleasure Point Beach and Overlook                        81.  Uaccbee Beach                                                                                                               JfonZer,-y                                                    53             55 ca
                 J2. East Cliff Drive Access Points                               PACIRC CROVE COVPLJ-X                                                                                                                                                          Moss Londing
                 JJ East Cliff DrIve Overlooks                               82.  Hopkins Marine Loboratorv                                                                                                                                                                      6
                 J4 Opal Cliffs Beach                                        83.  Berwick Park and Beaches                                                                                                                                                            57    58                                    Prunedale
                   -CAPITOLA COUPLEX                                         84.  Shoreline Pork - West
                 J5. Hooper Beach                                            85.  Lover@p Point Pork and Beaches                                                                                                                                                       59
                 J6 Copitold Wharf                                           86.  Perkins Park and Beaches                                                                                                                                                              Salinas                 Costroville
                 J7 Capitold City Beach                                      87   Monterey Peninsula Recreational Trail                                                                                                                                                   River
                 J8. New Brighton State Beach                                88.  Pt. Pinos Lighthouse Reservotion                                                                                                                                                          60
                   SOUTH SANrA CRUZ COUNTY COUPLE)(                          89.  Asilomar State Beach
                 J9. Potbelly Beach *                                             DEL MONTE FOREST COUPLEX
                 40. Seocliff State Beach                                    .90  5panlsh Boy Recreational Troll
                 41. Rio del Afar Area                                       91.  Spanish Boy Shoreline Pedestrian Trail                                                                                                                                                                                                Salinas
                 42. Hidden Beach                                            92.  Moss Beach - North                                                                                                                                                          61-                                                    0
                 4J. Seascape Accessway                                      93   Moss Beach - South                                                                  /V                                                                        88               64              Ma,ino
                 44. Lundborgh Beach*                                        94.  Point loe Overlook                                                                                                                                                                   65 Fort Ord
                 45. LoSelva Beach*                                          95.  gird Rock Beach                                                                                                                                                             @fl (
                                                                                                                                                                                                                                        Pt. Pinos              ic                                      M     0 N          T E R             E Y
                 46. Monreso State Beach                                     96.  Seol Beach                                                                                                                                             89            Grove
                 47 Place del Mar Area                                       97   fanshell Beach                                                                                                                            90-9-T                                          Sand Chy
                 48 Sand Dollar Accessway                                    98.  Modway Point Ovellook                                                                                                                               94                      69            66-
                 49. Sunset State Beach                                      99.  Pescodero Point Overlook                                                                                                                                   79-81                       Seaside
                 50. Pajaro River Bike Path                                  100. Stillwater Cove                                                                                                                           95-96           76-78                           72
                                                                                                                                                                                                                                 97                           Monterey
                 51. Pojbro Dunes Area                                            CARVEL COMPLEX                                                      Scale 1:325,000                                                       Cypress Pt..        190
                                                                             101. Cormet City Beach                                              1 inch equals approximately 5 miles
                 no Public varticol access     available                                                                                                                                                                         98                             75
                 Thematic Sources:                                           102. Carmel River State Beach                                       0                                          10                              99 Car-mel 10                Carmel                                       Study Area Boundary
                 CA Dept. of Parks and Recreation, 1991                      103. Carmel River Beaches
                 CA Coastal Commission Access Inventory. 1994                     POINT LOBOS COMPLEX                                                               Miles
                                                                             104. Point Lobos State Reserve                                                                                                                 104 Pt. Lobos

                        California Coastal Commission
                        Technical Services Division                                                                                                                                                                                                                                                                                          Figure d-,d
<pb n="51" />

                                                                                                  CHAPTER 4 - ACCESS

                   ANALYSIS@'
                        1----, 1 1--l-l-'. 11- "-"L . . ...... ...
                           Impacts to the physical supply of access from development may be evident through
                   encroachment onto beach areas, blockage of accessways, and overall increases in use. One of
                   the major tools that the Commission and local governments use to mitigate impacts on the
                   physical supply of public access from new development is a condition requiring an offer-to-
                   dedicate (OTD) a public access easement. OTI)s are generally required only for development
                   between the first public road and the sea. Although specific language varies, LCPS' generally
                   require an OTD as a mechanism to implement access mitigation. A lateral easement (along the
                   beach) is generally required to compensate for the impacts to public use when development
                   encroaches onto a public beach or impacts existing public access; a vertical easement is
                   generally required when development would block access to the beach from the upland road or
                   bluff. The easements themselves, however, do not ensure the availability of public access: once
                   recorded as an OTD, the offers must then be accepted for management, and opened and managed
                   by a public agency or acceptable nongovernmental association before the land becomes available
                   for public use. LCPs do not currently require local governments to accept offers. Review of the
                   OTD process in the ReCAP area indicates that: (1) the OTD recordation process and acceptance
                   needs improvement; (2) exemptions limit the use of OTDs; (3) a review of whether OTI)s are on
                   public or private land is often not done; and (4) additional mechanisms may be needed in the
                   future to supplement the OTD process. All these issues, discussed separately below, point to
                   improvements needed to increase the effectiveness of OTI)s in mitigating impacts on the
                   physical supply of access.

                   Recordation and Acceptance of=s
                           Under the Coastal Act, the Commission has required 42 lateral and 23 vertical OTDs in
                   the ReCAP region to mitigate the impacts of new development. Under the LCPs, local
                   governments required another 6 lateral and 8 vertical OTDs  17 (see Table 4-2, page 50). In
                   general, the Commission and local governments required OTDs for shoreline protective devices,
                   commercial development, subdivisions, and occasionally single family residences. Additional
                   permits granted by the Commission and local governments incorporate access to the beach into
                   the project and therefore are not conditioned with OTDs.

                           Generally, when the Commission or local government requires an OTD for mitigation of
                   a development project, the condition language requires that the OTD be recorded prior to
                   issuance of the coastal development permit. In some cases, the applicant will choose not to
                   pursue an approved project, and will not need to meet conditions of a permit or obtain the permit.
                   Since it is difficult to determine from Commission filing logs which permits ha"ve actually been
                   issued, ReCAP attempted to verify issuance of coastal development permits using local
                   government approvals. After a project is approved by the Commission, but prior to issuance of a
                   coastal development permit, applicants must receive local building or grading permits. For those
                   projects thatrequired an OTD, but did not have one recorded, ReCAP attempted to determine if
                   these local permits were issued. For those that did receive local permits, ReCAP assumed that
                   the coastal development permit was also issued, and the OTD requirement would be in effect.
                   For projects not receiving local permits, ReCAP assumed that the coastal development permit
                   was also not issued, and since the new development would not be pursued, compliance with the
                   OTD condition was not required.

                           Of the 79 projects requiring an OTD, eight had no building or grading permits issued;
                   local permits for five projects could not be verified. Excluding the eight projects that had no
                   local permit, 24 projects, approximately 30% of those projects requiring an OTD, did not have
                   one recorded (36 lateral, 23 vertical). 18 Of those recorded, some were done only after an
                   enforcement action to ensure compliance with permit conditions. The impacts from the
                   remaining projects have not yet been mitigated, resulting in a cumulative loss of beach access.
                   To improve recordation of OTDs, the Commission and local governments need to improve

                                                   CALIFORNIA COASTAL COMMISSION                             PAGE 49
<pb n="52" />

                     RECAP PILOT PROJECT

                     information tracking on projects with easement requirements. ReCAP has initiated steps to
                     improve previous Commission access inventories to better track OTD requirements.

                     Table 4-2: Lateral and Vertical OTDs Required by Coastal Commission and Local Governments

                          Davenport                                    1          2
                          Santa Cruz                                   17         6
                          Aptos                                        3          2
                          Capitola                                     9          1
                          Live Oak Area, Santa Cruz Co.                1          4
                          Rio del Mar                                  3
                          South Santa Cruz County                                 2
                          North Monterey County                        1          2
                          Moss Landing                                 3
                          Marina                                       I
                          Monterey                                     4          2-
                          Pacific Grove                                I
                          Pebble Beach                                 3          8
                          Carmel                                       I
                          TOTAIL                                       42         23
                        rqote: Numbers do not include amendments with 7 easement require;7ent -where the original
                        permit was also conditioned with an easement

                            Further, until the OTI)s are actually opened, the impacts from the development are not
                     fully mitigated as the land is still not available for public use. To date, only six of the recorded
                     OTI)s have been accepted by a managing agency and only one vertical accessway is actually
                     open for public use. 19 One barrier for local governments or private associations, including non-
                     profit organizations, in accepting OTI)s is a concern over potential liability; both Santa Cruz
                     County and the City of Pacific Grove have indicated that liability is a concern in managing
                     access areas. 20,21 Section 831.4 of the State Government. Code provides limited immunity for
                     public entities managing land for public recreation. Non-profit organizations are protected under
                     similar immunities for accepting coastal access easements if they enter into an agreement with
                     the State Coastal Conservancy. Despite these immunities, concern over the extent of protection
                     remains. Guidance via case law is limited; because of this uncertainty, liability will likely
                     remain a concern limiting the acceptance of OTDs.

                            It is unlikely, however, that resolving the issue of liability will completely address the
                     hesitancy of agencies to accept OTDs. Perhaps more of a constraint is the need to maintain an
                     accessway once it is accepted, and the associated costs involved. This issue was identified early
                     in the access program as a constraint to accepting OTDs, and remains an issue today.  22'23 Given
                     the current problem of funding maintenance programs, the reluctance to open new accessways
                     will probably continue until agencies or governments are assured of sufficient funding or
                     alternatives.

                                       OTDS:_:
                     EicernpUdn4roni
                            In reviewing development proposals for impacts on access, the Commission and local
                     governments may exempt development proposals from requiring OTI)s when access would
                     conflict with public safety, habitat, agriculture or military use, or where "adequate access" exists
                     nearby. Since 1983, the Commission and local governments exempted a total of 291 permits
                     from OTD requirements in the ReCAP region. For many of these developments, the

                     PAGE 50                         CALIFORNIA COASTAL COMMISSION
<pb n="53" />

                                                                                                        CHAPTER 4 - ACCESS

                    Commission and local governments did not require other access mitigation. Of the exemptions,
                    151 were exempt due to a finding of adequate access.     24  However, the Coastal Act provides no
                    guidance for what constitutes "adequate access". The Statewide Interpretive Guidelines suggest
                    that adequate access cannot be found laterally along any beach. For vertical access, analysis of
                    whether adequate access exists should consider: (1) the amount of public use; (2) availability of
                    support services; and (3) the location of pocket beaches.   25  Only two LCPs provide any guidance
                    as to the amount of vertical access that is appropriate: the Santa Cruz County LCP requires
                    vertical access every 1/4 mile in rural areas and every 650 feet in urban areas; the North Coast
                    segment of Monterey County LCP requires vertical access every 1/4 mile.

                            Review of adopted permit findings generally discuss only whether vertical access is
                    physically located nearby a proposed development, but do not take into account increasing use of
                    a site, availability of facilities, or the quality of a site, all of which cumulatively affect access.
                    Multiple development proposals will often cite the same accessway to indicate that an area has
                    "adequate existing access". For example, eight permits cited the 26      th Avenue accessway in the
                    Live Oak area as a reason for not requiring additional access mitigation to address impacts of
                    new development. None of the permit findings analyzed the cumulative impacts from multiple
                    development projects, the effect on the site from past increases in use due to adjacent
                    development, any growing need for facilities -- especially parking -- due to increased use, or
                    when new development begins to overburden the site. All of these factors affect whether an
                    existing accessway is truly "adequate".

                            Further, local governments exempted a number of permits from access mitigation due to
                    findings of development being too dense to accommodate access, lots being too small to
                    accommodate access, and sites not being designated as access sites in an LCP. However, in
                    areas of dense development, the demand for access is probably high. Continued development
                    will increase the demand for access and will overburden other access sites if additional access is
                    not provided. One method of addressing these impacts is to develop a program of in-lieu fees for
                    maintenance of existing accessways near the sit    'e location, the development of support facilities,
                    or the development and maintenance of other accessways. For example, a policy in Sand City's
                    LCP states that where a dedication of access is not feasible, payment of an in-lieu fee for
                    development and maintenance of other accessways should be done.

                    Public vs. Private Land
                            In order for an OTD to provide mitigation for development, the OTD should be on land
                    that is not already publicly owned. To determine whether OTDs were being recorded against
                    already public land, ReCAP reviewed permit files for a State Lands determination of the
                    boundary between public and private land. This determination would indicate if projects, and the
                    mitigating OTDs, were on public, state owned lands. Only 18 of the 40 projects conditioned
                    with a lateral easement also required a determination by State Lands. For six of those projects,
                    State Lands determined that the development was probably not on public land, but did not make
                    a final determination. For these projects, it is likely that the OTDs are also on private land,
                    thereby providing mitigation for the impacts from development. Of the remaining projects
                    requiring State Lands review, seven had no determination in the file, and five files were not
                    located in the Santa Cruz office. (Due to limited resources, staff was not able to check missing
                    files in archives.) Since State Lands review is not completed for most of the projects, ReCAP
                    could not determine the extent to which these OTDs are recorded on already public land.

                    Additional Planning Mechanisms. Needed
                            Even though conditioning a permit to require an OTD is one of the primary methods to
                    mitigate impacts on access, additional mechanisms may be needed in the future to supplement
                    the OTD process. Recent court cases have emphasized the need to fully document impacts from
                    development projects in order to mitigate those impacts. Due to the nature of cumulative

                                                       CALIFORNIA COASTAL COMMISSION                                 PAGE 51
<pb n="54" />

                     RECAP PILOT PROJECT

                     impacts, documenting the contribution of a single project to the overall impacts on access can be
                     difficult. As buildout of a region and use of an area continues, the cumulative impacts on access
                     continue; it is these impacts both to the physical supply of access and to other variables that
                     comprise an access system which cannot be solely mitigated through review of permits and
                     conditions requiring an OTD.

                             Further, the use of OTDs, even in cases where impacts can be fully documented, is likely
                     to decrease. Staff review of aerial photos and land use maps reveals few vacant lots or areas of
                     future subdivisions between the first public road and the sea. Further, since most of the pilot
                     region conforms to access standards set forth in the LCPs, new development would likely be
                     exempt from access requirements if adequate access nearby is determined under current
                     procedures. Therefore, the Commission and local governments will have fewer cases where
                     access impacts can be mitigated through project specific review and the use of access easements.
                     The lack of available shorefront parcels, however, does not necessarily mean a decline on
                     impacts to coastal recreation and access; inland subdivisions and development will continue to
                     draw additional people to the existing accessways, as will continued tourism.

                             Given the limitations in the ability of OTI)s to address the cumulative impacts to access,
                     additional mechanisms should be developed to supplement this program. Ultimately an increase
                     in vertical access easements or actual access points would have minimal benefit as the supply
                     reaches saturation. When the availability of physical access is maximized, the question becomes
                     one of managing an increasing and concentrated use, rather than increasing supply. The use of
                     OTI)s cannot address these issues. Development of a regional plan for public coastal access
                     could help ensure continued access and could ensure that a number of other variables are
                     addressed. The development of such plans is discussed under Access Problem #6. However,
                     OTI)s should continue to be used to mitigate site specific impacts to the physical supply of
                     access.

                        *    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.
                        *    Develop a regional strategy for improving mitigation of access impacts. This strategy
                             should include measures to accept and open all lateral Offers to Dedicate easements,
                             identify priorities for accepting and opening existing vertical Offers to Dedicate
                             easements, and require new access mitigation through OTDs. This strategy should be
                             one component of a regional management plan (discussed under Access Problem #6).
                        *    Provide guidance for developing in-lieu fee programs or other mechanisms for the
                             operation and maintenance of existing offers to dedicate access easements.
                        *    Improve permit review procedures to address measures for obtaining State Lands
                             Commission determination of the boundary of public and private lands as part of filing
                             requirements.
                        *    Improve permit review procedures to include guidance for considering cumulative
                             impacts in the determination of whether access mitigation is exempt due to sensitive
                             resources, public safety or adequate access nearby. Provide a guidance document and
                             revise LCPs to require in lieu fees or other mechanisms, where appropriate, for support

                     PAGE52                          CALIFORNIA COASTAL COMMISSION
<pb n="55" />

                                                                                                     CHAPTER 4 - ACCESS

                              facilities and maintenance of access sites when impacts to access result from factors
                              other than a lack of physical supply.

                              ACCESS PROBLEM TWO

                                                               -41
                                                                                                       0
                                                                                      0              U "'Y
                                                        t K1                   MRYF,
                                                  of 11                    tri

                              The use of shoreline protective devices negatively impacts shoreline access by
                      encroaching onto beaches, leading to a loss of recreational beach area. Current mitigation efforts
                      to minimize these impacts are not fully effective.

                              As noted in Section 3 of this report, shoreline protective measures cover an estimated 25
                      acres of beach 26 along 12 miles of coastline in the ReCAP region (8.3 miles in Santa Cruz
                      County and 3.7 miles in Monterey County). Permits granted since 1978 under California's
                      coastal management program represent approximately 20% of this total. Between 1983 and
                      1993, the Commission and local governments in the pilot region approved 96 permits for
                      armoring. Although shoreline protective devices are found throughout the pilot area, they are
                      concentrated from the City of Santa Cruz to Seacliff State Beach and in the Monterey City-
                      Pacific Grove area. These areas also tend to be areas of high recreational use. The shoreline
                      from Corcoran Lagoon Beach to Moran Lake Beach, along Pleasure Point, and along Opal Cliffs
                      Beach is significantly affected by armoring, and provides an example of the impacts on public
                      access. Approximately 1.4 acres of beach have been lost in this area, due to encroachment of
                      armoring. Near Pleasure Point, rip-rap extends to the edge of the beach, making lateral access
                      around the point impossible. Along Opal Cliffs, sections of armoring 'are strewn along the beach
                      itself, degrading the quality of the beach and leading to public safety concerns. At the same
                      time, use has probably increased in the area, due to general population increases in the region,
                      the extent of tourism, and new development in the region. Review of aerial photographs reveals
                      a significant amount of development in this region between 1979 and 1993.

                              In its review of development proposals, the Commission has found numerous times that
                      armoring negatively impacts public access. The direct impacts on access are evident through
                      encroachment onto the beach; the Commission has found that the development of shoreline
                      protective devices can:

                              impede access physically through construction adjacent to the mean high tide
                              line or through "walling off' beach areas from public view and usage,
                              eliminating or reducing the possibility of vertical accesswaysfor public use and
                              creating the appearance of a private beach.  27

                      Although all shoreline protective devices encroach onto the beach to some degree, the amount of
                      encroachment varies with the type of device constructed. Most of the protective measures
                      constructed in the region are revetments, which encroach onto beach areas more than seawalls.

                              The Commission has also identified more indirect, but equally severe, impacts to public
                      access, including effects on sand supply and erosion. Unless beach nourishment is undertaken,
                      placement of a shoreline protective device may ultimately lead to a complete loss of a beach.
                      With the placement of a shoreline protective device, a beach can no longer migrate landward; as
                      erosion continues, whether through natural means or increased erosion due to the seawall, the

                                                       CALIFORNIA COASTAL COMMISSION                             PAGE 53
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                  RECAP P1ILOT PROJECT

                  sand is not replaced, and 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. Although it may not be possible to determine the loss of beach when
                  reviewing individual projects, the cumulative loss of public land over time may be significant.

                          While Commission findings for shoreline protective devices in the ReCAP area
                  generally discuss the potential impacts on a beach, the Commission and local governments
                  required mitigation of those impacts in only approximately 38% of cases (36 of 96 permits). In
                  most cases where the Commission has determined that armoring will affect access, it has
                  required a lateral offer to dedicate a public access easement, dedicating the remainder of the
                  beach area for public use. 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 structures, as well as expansion and maintenance projects that push shoreline protective
                  devices further seaward, may have significant cumulative impacts. More consistently requiring
                  mitigation of impacts from these projects will reduce the cumulative loss to access.

                          A related issue that leads to access impacts is the lack of mitigation for seawalls
                  constructed through the emergency permit process. As outlined in Section 3 of this report,
                  emergency permits are temporary permits, requiring full review through the regular permit
                  process. However, in the ReCAP area, many emergency permits did not receive a subsequent
                  regular coastal development permit; at least some of these were repair and maintenance waivers
                  of earlier projects, but a few remain enforcement questions. It is through the regular permit
                  process that development projects can be fully reviewed for consistency with the Coastal Act or
                  LCPs and impacts can be mitigated. Since emergency permits have minimal regulatory review,
                  and by their nature are not conditioned to mitigate impacts, there is no compensation for beach
                  loss, leading to a cumulative loss of public access, unless mitigation occurs through the
                  subsequent regular permit process. For example, of the 24 emergency permits, 16 were granted
                  in the Live Oak area of Santa Cruz, primarily adjacent to Moran Beach. Without mitigation, the
                  loss of recreational opportunities to this beach alone may be significant.

                         In spite of the requirement to mitigate impacts from armoring, the mitigation may not be
                  entirely effective. As discussed previously, OTDs do not actually mitigate loss of beach area
                  until they are accepted and open for public use. Further, even with an OTD, the beach area will
                  continue to erode; with the armoring in place, sand is not replaced, leading to an ongoing loss of
                  beach area.

                         In general, LCPs seek to avoid impacts on public access from shoreline protective
                  structures by requiring that they not reduce lateral access or adversely affect shoreline processes,
                  including sand supply. However, the LCPs lack any specific criteria or standards to assess
                  impacts and to reduce them. Of the certified LCPs, Sand City, Santa Cruz County, and the
                  Carmel segment of the Monterey County LCP have policies specifying that shoreline protective
                  devices should not restrict or impede access; the LCP for Santa Cruz City states that any
                  development in the shoreline protection overlay area must protect or enhance free public access
                  to and along the beach. Only the Sand City LCP specifies that development proposals must
                  indicate how impacts to access will be prevented. The Del Monte Forest segment LCP lacks any
                  language requiring that impacts to access be avoided. Both the City and County of Santa Cruz
                  LCPs encourage revetments, which encroach further onto the beach than other forms of shoreline
                  protective devices; new information on shoreline processes since these plans were certified may
                  indicate more appropriate approaches to armoring. In addition, the North County and Del Monte
                  Forest segments of the Monterey County LCP and the Santa Cruz City LCP specify that
                  armoring can be used to protect public beaches. However, as discussed, the use of armoring will
                  not protect a beach in the long-run; as noted in adopted findings by the Commission in several
                                                                                                             ,,28
                  permits in the ReCAP area, shoreline protective devices "do not hold or protect the beach

                  PAGE54                           CALIFORNIA COASTAL COMMISSION
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                                                                                                  CHAPTER 4 - ACCESS

                             As discussed in Section 3 of this report, if current policy implementation continues, 27.5
                     additional miles of shoreline in the pilot region may be armored. With this additional armoring,
                     a total of approximately 65 acres of additional beach area, and possibly significantly more,
                     would be lost to public access through the encroachment of shoreline protective devices. At the
                     same time, as discussed previously, demand for coastal access is expected to continue. The
                     cumulative result of this loss will be additional pressure and congestion at other sites.
                     Minimizing the number of structures approved and the amount that shoreline protective devices
                     encroach onto a beach will reduce impacts to access and help protect available supply of
                     recreational access.

                         *   Through implementation of the Hazard Management Recommendations in Section 3,
                             revise procedures to reduce the amount and encroachment of shoreline armoring and to
                             address emergency authorizations for shoreline protective devices.

                         *   Within the pilot region:

                              *  Revise the Del Monte Forest segment LCP to require policies that shoreline
                                 protective devices minimize impacts to access.

                              *  Revise Santa Cruz City and County LCPs to modify standards for the type and
                                 design of shoreline protective devices to minimize encroachment.
                              *  Revise LCPs to develop criteria or standards to assess impacts from shoreline
                                 protective devices and require LCPs to identify how impacts to public access will be
                                 avoided.

                         * Provide guidance for alternative mitigation programs, including increasing the use of
                             beach replenishment as alternative mitigation to shoreline protective devices. Ensure
                             more consistent use of mitigation requirements on shoreline protective device projects.

                            ACCESS PROBLEM THREE

                             As the demand for coastal access continues to increase, and existing areas become more
                     congested, pressure to add additional access to areas not currently providing it will increase,
                     and/or informal use will expand to areas not already providing formal access. Since most of the
                     areas that can easily support access are already developed to do so, the remaining potential
                     access areas are in places with some sort of constraint -- particularly the presence of sensitive
                     habitat or species. This conflict between providing access and protecting species will become
                     more prevalent in the future.

                                                                                                   W,-      T!W-

                             Sensitive habitat and species are found along the shoreline and adjacent dunes
                     throughout the pilot region; many of these areas already support coastal access. By definition,

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                  RECAP PILOT PROJECT

                  sensitive habitat is susceptible to impacts from use: Section 30107.5 of the Coastal Act defines
                  an "environmentally sensitive area" in part as "any area in which plant or animal life or their
                  habitats ... could be easily disturbed or degraded by human activities and developments".
                  Sensitive habitats include dunes, wetlands, and riparian areas. Of the 106 access sites identified
                  by ReCAP, 21 are at or border wetlands, 25 occur nearby or at dunes, and 19 occur at or near
                  streams; many access areas support multiple sensitive habitat types. Wetlands in the ReCAP
                  area support'passive recreation, boating, nature observation, fishing, and hunting; several
                  wetlands have hiking trails and support facilities, including Waddell Creek Marsh, Antonelli
                  Pond, Neary Lagoon, Elkhorn Slough, and Laguna Grande.

                           The issue of impacts to species due to human presence is not a new issue, but is well
                  documented in general literature. Impacts can include trampling of vegetation, resulting in a
                  direct loss of those species and a loss of habitat for other species; erosion from informal trails;
                  accidental or intentional killing of animal species (i.e. crushing bird eggs); predation from
                  domestic animals; and/or the abandonment of a species from a site. While some of these impacts
                  may be fairly easy to mitigate -- for example defining trails to avoid species -- other uses are
                  more difficult to manage due to inherent conflicts of shared areas -- for example, human
                  presence near snowy plovers. Although currently the conflict.between the snowy plover, a
                  recently listed species, and human presence is receiving considerable attention, many other
                  species are prone to impacts as well.

                          While these impacts are well recognized, quantifying them is often difficult, as
                  information, when available, is often anecdotal. Impacts leading to species abandoning a site
                  due to disturbance is particularly difficult to quantify, as it requires an on-going monitoring
                  program, starting prior to any use of the site. Within the pilot area, there are numerous examples
                  of impacts to resources as a result of human presence. Erosion due to unmanaged access and
                  people creating informal paths to the beach is evident along most of the coastline in the Pacific
                  Grove area and in the Manresa/La Selva area.    29,30,31 Impacts to the dune system are evident at
                  various state beaches from vehicle intrusion, foot access and equestrian use (including Asilomar,
                  Zmudowski, Moss Landing, Salinas State Beaches).      32,33,N Human activity may also be a factor
                  in impacts to snowy plover nests.  35 The increase in the number of endangered species noted in
                                                                        36
                  some areas may also indicate increased disturbance.

                          Further, impacts to habitat may occur due to the management focus of agencies; agencies
                  responsible for resource management often may have to balance use of resources. In some cases,
                  as in Santa Cruz City and the San Lorenzo River mouth, the Recreation Department focus is
                  solely on recreation, and does not recognize the river mouth as wetland habitat. Therefore, the
                  River is managed for access and breached regularly to ensure access to the adjacent beach area,
                  without considering the habitat impacts of the action.
                          Review of certified LCPs in the pilot region show that all LCPs, except the City of
                  Watsonville's, recognize the potential conflict between access and resource protection and have
                  policies seeking to prevent, or reduce, those impacts. Management measures typically include
                  formalizing trails to reduce impacts; use of boardwalks; limiting uses in sensitive areas to low-
                  intensity uses, nature study, education, research, and/or hunting; and directing access to less
                  sensitive areas. Some of these actions taken in the pilot region have been at least partially
                  effective in mitigating impacts that have occurred. Dune restoration at several state parks,
                  particularly Asilomar, has been successful,  37 and the installation of boardwalks appears to have
                  minimized impacts to dune vegetation. Guard rails installed along the bluffs in Carmel have
                  somewhat reduced the number of random trails, but they remain a problem.       38

                          Once objectives and policies are in place to protect resources, monitoring of resources
                  becomes critical to ensure that policies are being effectively carried out. As overall use increases
                  and spreads to more areas with sensitive resources, the likelihood of impacts on sensitive
                  resources increases, as does the need for monitoring. Without monitoring, attention is not given

                  PAGE56                            CALIFORNIA COASTAL COMMISSION
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                                                                                                      CHAPTER 4 - ACCESS

                     to an area until the impacts have already occurred. While these impacts can sometimes be
                     mitigated through restoration programs, restoration is not always successfill, and in cases of
                     species abandonment, it is extremely difficult to mitigate after-the-fact, even if the problem is
                     known. Therefore, the goal should be to prevent the impacts from occurring. Neither the
                     Coastal Act nor the LCPs require monitoring of areas, and do not establish criteria or methods to
                     evaluate if impacts are occurring. Wetland management plans also do not require monitoring of
                     impacts. Of the 19 wetlands with management plans in place or under preparation, 14 discuss
                     public access (See Chapter 5, Wetlands, Table 5-15). However, none have criteria to measure
                     and monitor the impacts from access, and only three of these have any kind of species
                     monitoring. Seven wetlands currently show impacts from access, including erosion, vegetation
                     loss, and disturbance of wildlife. 39

                              A policy used in several LCPs is to tie the amount of access an area can support to its
                     carrying capacity. While in theory this rationale is perfectly appropriate, the carrying capacities
                     of sites have not been determined, and therefore cannot be used to determine appropriate levels
                     of access. Even if the carrying capacity is determined, monitoring will still be needed to ensure
                     protection of resources.

                              In addition to monitoring, adequate enforcement of policies and regulation on use is
                     necessary in order to protect resources. A lack of adequate enforcement of the beach closure at
                     Wilder Beach has been cited as a reason for continuing impacts to the snowy plover      40'41  and
                     inadequate enforcement of activities including off-road vehicle use has also led to impacts to
                     dunes.  42 A lack of adequate enforcement is also a factor in increasing impacts in inter-tidal
                     zones, particularly increased poaching. 43 Increased enforcement is especially important in areas
                     with increasing use and where resource protection is dependent on restricted use if the intent of
                     Coastal Act and LCP protection policies is to be carried out.

                              The LCPs for the cities of Marina and Sand City, and the Carmel segment of the
                     Monterey County LCP identify areas that should not encourage access due to the presence of
                     sensitive habitat. These areas include the southern end of San Jose Creek at Carmel State Beach,
                     north of Dunes Drive in Marina, and areas north of Tioga in Sand City. Except for the Sand City
                     LCP which specifies fencing or other measures necessary to protect the areas, the LCPs lack
                     mechanisms to ensure their protection.

                              One area of potential fliture impacts is the Marina area of Monterey County. Over the
                     last two decades, the City of Marina has grown significantly.  44 Review of aerial photographs
                     shows a large number of vacant lots remaining in the Marina area. The area near Dunes Drive is
                     zoned visitor service use, which includes overnight accommodations. However, this area also
                     has significant amounts of sensitive shoreline habitat. If development continues to occur in this
                     area, it is likely that dunes will be impacted, both through the development itself and through
                     unmanaged access across the dunes to the beach area, particularly absent monitoring and
                     enforcement of resource protection policies.

                              A third factor leading to cumulative impacts on sensitive habitat from access is a lack of
                     adequate budgets. Limited budgets and insufficient staff with expertise in resource protection
                     leads to a reduction or elimination of interpretive and resource management programs, and to the
                     priority of recreational use over resource protection. 45 At least one agency responsible for
                     providing both access and protecting resources has experienced a decline in staff over the years,
                     and has emphasized law enforcement over other activities, including interpretive programs and
                     resource protection. 46 Without a strong, on-going resource management program, growing
                     demand for additional access will make balancing access and resource management more
                     difficult.

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                    RECAP PILOT PROJECT

                                                                                                                       7'

                            Provide guidance to establish baseline and on-going monitoring in areas where access
                            and sensitive resources exist.

                            Access management plans should be developed for recreation areas with sensitive
                            habitat or species, including measures to ensure that management measures are put in
                            place prior to increase in public access within these areas.
                        *   Provide guidance for inclusion of access management components in wetland
                            management plans (See Chapter 5, Problem Wetlands Problem #7).
                        *   Encourage community groups to participate year-round in the Commission's adopt-a-
                            beach program, including wetlands and dunes.

                            ACCESS PROBLEM FOUR
                                                    Wi W-40- M "I"

                            Although the physical supply of coastal access has increased throughout the ReCAP
                   area, the ability to reach access sites is increasingly more difficult, due in part to increasing
                   numbers of users and-overall development.

                                                                                                 IR 'P, na@

                            Ensuring accessibility to the coast is a vital element of complying with the Coastal Act's
                   goal of providing maximum public access. Availability of parking for access areas and
                   alternative transit serving access sites are both necessary to ensure accessibility. While the focus
                   traditionally tends to be on providing parking, the availability of an effective transit alternative is
                   becoming increasingly more important.

                            As overall use and development in an area grows, competition for existing parking will
                   also increase, leading to increasing difficulty in reaching the coast. Both the Commission and
                   local governments try to mitigate this impact on access by requiring parking as part of new
                   development projects. By ensuring that parking is provided with new development, the
                   Commission and local governments minimize increased competition for existing parking and the
                   impacts on recreational use. Between 1983 and 1992, the Commission required approximately
                                          47
                   3,115 parking spaces.

                            However, ensuring accessibility to the coast through such a project-by-project review of
                   development and requiring additional parking as mitigation is only partially effective. While
                   new parking may reduce the competition for existing spaces between the new development and
                   recreational use, it does not address the direct increases in use at beach areas, and the resulting
                   increased demand for parking. This is particularly true in areas, such as Carmel, where
                   inadequate parking for recreational use has historically been a problem. As discussed earlier, use
                   of access sites has grown significantly. However, of the new 3,115 parking spaces required by
                   the Commission, only 456 are dedicated to beach use throughout.the pilot region. It is unlikely
                   that the additional parking is sufficient to meet a growing demand. Although few studies are
                   available to track the supply and demand of parking for recreational use, studies for Santa Cruz
                   City indicate that while parking in the beach area increased by approximately 2,400 spaces

                   PAGE58                            CALIFORNIA COASTAL COMMISSION
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                                                                                                  CHAPTER 4 - ACCESS

                    between 1980 and 1987, demand for parking still exceeds the supply, leading to competition
                                                  48,49
                    between residents and visitors.     By 1987, parking deficiencies in the beach area were noted
                    not only on summer weekends, but during the week as well. Requiring parking for new
                    development will help minimize additional competition, but will not resolve the larger issue of
                    accessibility to access sites. This concern of inadequate parking was an issue during LCP
                                                                                        50,51,52,53,54
                    planning and development in many jurisdictions in the ReCAP area.

                            Although Section 30223 of the Coastal Act attempts to address the need for upland
                    support for access areas, review of the ReCAP region indicates that implementation of this
                    policy has not been entirely effective in providing a mechanism to ensure future access to the
                    coast. Section 30223 states:

                            Upland areas necessary to support coastal recreational uses shall be reserved
                            for such uses, wherefeasible.

                    Parking remains a significant issue in some parts of the pilot rpSion, and few areas of the coast
                    remain undeveloped and able to be used for support facilities.5@'_ In addition, few LCPs identify
                    specific areas for upland support facilities. Although areas are zoned for visitor serving or
                    commercial uses, specific areas for upland parking support are not identified. Thus, neither the
                    Coastal Act nor LCPs assure that as use and development increase, support facilities for
                    recreation, particularly parking, will also increase.

                            Ensuring access to the beach becomes much more difficult if adequate support facilities
                    are not reserved before areas become built out. For example, in Carmel, many of the impacts to
                    public access are the result of development patterns prior to the implementation of the Coastal
                    Act and the LCP, which makes adding new access to the beach and providing additional parking
                    difficult.56

                            Improving the implementation of Section 30223 to ensure upland parking support can
                    help increase accessibility to the coast; however, its success may be limited. Improvements can
                    consist of specifically designating land for recreational parking and encouraging joint-use
                    programs for new developments, whereby businesses that are closed on weekends and holidays
                    make their lots available for visitor parking. Other areas in the coastal zone have required joint-
                    use parking programs in approving new commercial or retail development along and nearby the
                    coast. Even with these improvements, long-term expansion of parking will be limited, due in
                    part to limited vacant land, especially near access sites, and competing demands for it. Even
                    with an expansion in parking at some sites, the supply of parking is unlikely to keep pace with
                    growing recreational use and demand.

                            Other factors also indicate that cumulative impacts are occurring to access through
                    restricted parking availability, particularly through the increase in preferential parking programs
                    and red curbing/no parking signs. These actions result from increased competition for limited
                    street parking among users, particularly residential and recreational users, and further reduce the
                    supply of on-street parking for recreational users. In the ReCAP region, the City of Capitola, the
                    City of Santa Cruz in the Beach Hill and Beach Flats areas, and the Live Oak area in Santa Cruz
                    County have all implemented preferential parking programs. The Beach Hill and Beach Flats
                    program prohibit any visitor parking; the other programs do not completely prohibit public
                    parking, but they greatly restrict it, making beach access more difficult. Commission staff has
                    also observed an increase in No Parking signs and red-curbing in the region, particularly in the
                    Live Oak area and South Santa Cruz County. Better controlling where these actions occur, and
                    ensuring adequate mitigation for parking losses can help ensure access to the coast for
                    recreational opportunities.

                            An increase in parking fees also affects the perceived availability of parking. In
                    downtown Santa Cruz, parking is available, but the increasing cost makes access to the coast

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                    RECAP PfLOT PROJECT

                    m
                            iff
                      ore d  1CUlt.57 Some State Park units also require a fee forRarking. Although available data
                    provides no clear evidence of the effect of fees on beach use, the imposition of a fee probably
                    contributes to increased competition for available free on-street parking. 59 This competition
                    again lead to conflicts between visitors and residents, and will likely lead to a desire by local
                    residents for some form of restricted parking.
                            While improvements can be made to increase the availability of parking, the limitations
                    on expanding parking for an increasing demand necessitates additional mechanisms to ensure
                    adequate access to the coast. Effective transit systems are becoming increasingly more
                    important to ensure this access.

                            Most LCPs in the region have policies that support expansion of transit services. Section
                    30252 of the Coastal Act encourages expanded transit to ensure that new development does not
                    negatively impact access to the coast. Section 30252 of the Coastal Act states, in part:
                            ... new development should maintain and enhance public access to the coast by 1)
                            facilitating the provision or extension of transit service ... 4) providing adequate parking
                            facilities or providing substitute means of serving the development with public
                            transportation, 5) assuring the potentialfor public transitfor high intensity uses... .

                            Improvements to access through transit opportunities have been made in the ReCAP
                    region. Beach shuttles run in the cities of Capitola and Monterey; although suspended for 1995-
                    1997, a shuttle has also provided additional access in Santa Cruz City. However, even with
                    policies that support transit, implementing the policies is often difficult under a project-by-
                    project review of development proposals. In the past, transit has been required only to mitigate
                    large development projects generating traffic. 60 In general, the Commission's role focuses on
                    reviewing projects, with or without conditions to mitigate impacts, and is limited in its ability to
                    encourage new transit programs, particularly those that extend beyond the coastal zone.
                    However, much of the need for transit is from outside the immediate ReCAP area. Even in areas
                    which have local transit to beaches and park-and-ride lots for out of town visitors, like Capitola,
                    the need for transit directly from inland communities remains.  61,62

                            While the need for public transit will probably increase, the Commission and local
                    governments' ability to require transit measures as mitigation for development under the Coastal
                    Act or LCPs will remain limited. To the extent possible, the Commission- should encourage
                    additional transit options for recreational uses by working with local governments and ensuring
                    that recreational needs are addressed in regional transportation plans and congestion
                    management plans. The regional management plans discussed under Access Problem #6 also
                    provide an opportunity to help develop an effective transit system for recreational use. Because
                    needs for recreational users differ from commute users, simply adding buses to commute routes
                    on weekends without some adjustments does not always provide adequate service for
                    recreational users. To be effective, transit for recreational purposes need to ensure frequent
                    service, transit stops in convenient locations for recreational uses, and the ability to bring
                    recreational equipment on buses.

                            One recent proposal could begin to address the need for effective transit: The Santa
                    Cruz County Regional Transportation Commission is working on improving transportation
                    between Watsonville and Santa Cruz. While much of the focus of this effort is to ensure transit
                    for commuters during the week, the Commission should work with the Transportation
                    Commission to ensure that recreational needs are included in transit planning. The need for
                    alternate funding and implementation of recreational transit service is crucial for this and other
                    transit programs. Options to fund recreational transit programs, such as using fees from parking,
                    should be considered.

                    PAGE 60                         CALIFORNIA COASTAL COMMISSION
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                                                                                               CHAPTER 4 - ACCESS

                                                                                       . . ..... ....
                    RECOMMENDATIONS
                                   . . . .......

                       * Provision of additional support facilities should be encouraged by:

                               Designating additional sites for upland parking and support facilities in LCPs.
                            *  Developing in-lieu fee programs for parking, transit, and shuttle programs to the
                               extent possible.

                            *  Developing joint-use parking programs of commercial and other private parking for
                               beach use in appropriate situations.

                            *  Developing guidelines for approval of preferential parking proposals, including the
                               conditions under which such proposals could be implemented, such as: 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.
                            *  Improving interdepartmental coordination on issues of installing red curing and no
                               parking signs to ensure impacts to access are minimized.

                       *    Amend LCPs to specify that the implementation of preferential parking programs
                            constitutes development under the Coastal Act, for which a coastal development permit
                            is required.

                       *    Develop framework for increased intergovernmental coordination in developing transit
                            plans- Develop a memorandum of understanding to work with local governments on
                            Regional Transportation Plans to ensure recreational transit needs are met.

                       *    Develop guidelines to address the need for alternative funding for recreational transit.
                            Guidance could include developing a system of user frees to pay for shuttles,
                            encouraging shoreline businesses to help subsidize shuttles, and using parking fees to
                            partially fund transit programs.

                            ACCESS PROBLEM FIVE

                            The Coastal Management Program needs to stay responsive to the region's changing
                   demands for access opportunities and changing demographics.

                    AN YMS114
                            To maximize public access, an access program needs to match opportunities with
                   demand for them. This demand will vary among different users groups, leading to the need for a
                   diversity of recreational opportunities, and may change over time. While many changes in
                   demand may result from the emergence of new types of recreational activities, changing
                   demographics may also lead to new demands and may raises issues that were not previously

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                      RECAP PILOT PROJECT

                      considered. While much is known about the demographics of the region, little information is
                      available on the implication for coastal access management.
                                As shown in Figure 4-5, significant shifts are occurring in the region's demographics.
                      Generally, the census data shows a rapid rise in the Hispanic community. By 2020, projections
                      show a Hispanic majority in the state and the pilot region. Other demographics, such as the age
                      of the population, may also be changing and may have implications for ensuring adequate public
                      access.

                                         Figure 4-5: Ethnicity ofPopulation, ReCAP Counties Combined, 1970-2020
                           100%

                              %
                                         17.8%
                           90                                21.5%
                                                                                28.4%
                                                                                                   34.3%
                           8056                                                                                        40.3%

                           70%
                                                                                                                          11  Hispanic
                           60%                                                                                            N   White
                                                                         &amp;!
                                                                                                                          E   Black
                           50%
                                                                       OR,
                                                                                                                          El  Other
                           40%

                           3 0 0

                           20%

                           10%

                             0%
                                         1970               1980               1990               2000                 2010

                                  Source: U.S. Census of Population and Housing (1970-1990); Department of Finance projections (2000 and 2010)
                                           Figures may not round to total due to independent

                              A major constraint regarding this issue is a lack of available research and data. DPR's
                      1993 Recreation Plan states that recreational needs change with increasing ethnic diversity, in
                      part due to different cultural values and uses.    63 Studies also indicate that additional steps, other
                      than simply providing the physical access, need to be taken to ensure access for all groups of
                      people; these steps include providing transit services from inland areas to the coast, addressing
                      the potential lack of familiarity of coastal recreation opportunities, and ensuring that
                      opportunities are relevant to the users and that facilities can accommodate different ways of use
                      (for example, ensuring clusters of picnic tables for large groups).       64,65,66,67 However, due to a
                      lack of information and long-range planning, information on whether ethnic groups have
                      differing needs, and if so, what those needs are, is not available. Therefore, it is difficult to
                      assess if the current recreation and access system is responsive to the needs of the population.

                              Meeting the needs of all potential users is dependent on determining who those users are,
                      what types of facilities are wanted, and what barriers which prevent or hinder access. As a first
                      step to addressing this issue, ReCAP sought to do a comprehensive survey to determine what
                      types of access and facilities were wanted, and what, if anything, hinders access to the coast. In
                      order to obtain the necessary information, the survey needs to reach those groups of people who
                      do not currently use coastal access sites. A general population survey would reach not only
                      existing users of coastal access to determine what is not meeting their needs, but also those
                      groups who do not use access sites. However, this objective quickly became infeasible, due to
                      the time and cost involved. To obtain additional information on barriers to use of coastal access
                      sites, ReCAP contacted representatives of community organizations. ReCAP sent surveys to 18
                      representatives and received seven responses. All seven respondents indicated that access to
                      coastal recreation opportunities was "very important". The main barriers to use of sites were:
                      inadequate parking/lack of access to sites, fees, and a lack of information about sites. The

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                      majority of respondents indicated a need for better transit to the coast, additional parking, and
                      additional facilities. The facilities cited as being necessary included improved access for
                      handicapped users, facilities for groups, picnic facilities, and better diving access. The need for
                      better maintenance of sites was also noted.

                                           7-[S -,7777@7_                         77@,
                          *    The Commission should encourage research on recreation demands and changing
                               demographics by sponsoring a workshop, focus groups or other discussions with
                               community groups and recreation providers.
                          *    The Commission should encourage survey research specifically addressing the issue of
                               demographics and barriers to public access and use. The surveys should target non-users
                               of access sites, and not only people at sites. One method of achieving this is to
                               undertake a general population survey. These surveys should be updated and done
                               periodically to continue to monitor changing needs.

                               ACCESS PROBLEM SIX

                               In spite of limited quantitative data, some qualitative evidence suggests that cumulative
                      impacts are occurring to public access due to impacts on a number of variables other than
                      physical supply. These variables include impacts to site quality, parking, and restrictions on use.
                      In a number of cases, the existing framework of coastal access management through individual
                      permits and LCPs does not adequately address these issues. Developing beach management
                      plans and regional access plans may offer a more effective framework for addressing cumulative
                      impacts to some factors of public coastal access.

                           J,  . .. .. .... 150
                                                   N E

                               As discussed previously, the Coastal Act requires protection of public coastal access
                      opportunities. Regulatory review of new development proposals seeks to ensure that where
                      development proposals will lead to negative impacts on access, those impacts are mitigated to
                      protect access opportunities. While this review is generally effective in mitigating the loss of
                      physical supply at specific sites, evidence indicates that cumulative impacts are occurring to
                      overall site quality and accessibility to sites. Many aspects of ensuring public access are difficult
                      to deal with through regulation of individual projects, as much of access planning requires
                      coordination among agencies and departments. Further, since many of the impacts to these
                      factors come from an overall increase in use of, and demand for, the resource, impacts may not
                      be attributable to specific development projects; therefore, addressing impacts to these factors of
                      access through mitigation measures on new development is difficult.

                               The LCPs generally focus on ensuring the physical supply of access by identifying
                      access sites available at the time of certification within that jurisdiction. Many LCPs also
                      identify where access dedications should be required for new development in order to protect
                      access opportunities. However, as discussed under Access Problem #1, it is becoming more
                      difficult to require such mitigation. In addition, many of the access sections of LCPs have not
                      been updated since their preparation in the late 1970s and early 1980s. Although the LCPs are

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                  effective planning tools for guiding the protection and provision of access and recreation areas in
                  general, in order to address many of the cumulative impacts to access, they need to expand to
                  provide guidance to daily management of access sites. The policies of an LCP generally are
                  implemented through review of a development proposal, and are therefore not generally aimed at
                  day-to-day management of beaches. Few access components have policies or mechanisms to
                  address issues rising from increasing use, and do not respond to changing situations, such as
                  changing priorities for access locations or emerging demands for new or different facilities.

                          Because LCPs are developed for individual political jurisdictions, the pilot area LCPs do
                  not address regional issues, particularly the distribution of access, the prioritization of facility
                  development throughout a region, the availability of a diversity of recreational experiences, and
                  regional transportation for access. Ensuring that access is provided throughout a region and that
                  access improvements are placed where the demand is greatest is difficult under a program
                  implemented through a project-by-project review and mitigation of site impacts.  6  Further, since
                  use of the resource is not limited to users from a single jurisdiction, and the resource itself
                  crosses jurisdictions, many of the issues involved with providing for and managing access also
                  span jurisdictions. For example, in a number of cases in the pilot region, a stretch of beach is
                  governed by different management entities where a beach is divided by political jurisdictions. In
                  the City of Santa Cruz, the beach in front of the Santa Cruz Harbor is managed by the Port
                  District, while immediately adjacent, DPR manages Twin Lakes State Beach. Although the
                  beach between New Brighton State Beach in Santa Cruz County and Moss Landing State Beach
                  in Monterey County is essentially an unbroken stretch of beach, it is managed by several
                  different entities, including DPR, private owners, and the two counties.
                          In order to address the cumulative impacts to public access that are not being fully
                  addressed through the current regulatory framework, different planning mechanisms may be
                  more effective; developing management plans will provide guidance for recreational
                  departments and ensure that daily management carries out the broader objectives of the Coastal
                  Act and LCPs. Regional and site specific management plans can help address the cumulative
                  impacts to those management issues that single LCPs and project-by-project review of
                  development in the region cannot. Management plans could also incorporate some of ReCAP's
                  other access recommendations and can provide a tool to address the conflicts between access and
                  sensitive resources, including wetlands.
                          Many of the cumulative impacts to access result from an overall increase in use of beach
                  areas. Other impacts result because of increasing trends that LCPs in the pilot region do not
                  currently address, such as beach curfews and fees, and other impacts result from competing
                  objectives within departments of a local government or between local governments.
                          One of the basic objectives an access management plan can address is mediating among
                  a wide range of use conflicts. As use of sites continues to grow, and congestion at sites
                  continues, the problems with competing uses at a site also increase. Without addressing these
                  conflicts, the perceived availability of access and the quality of the recreational experience is
                  affected. One example of a conflict in use affecting site quality centers around alcohol use at
                  beaches. When Santa Cruz City imposed a ban on alcohol in the mid 1980s at Cowell Beach and
                  Main Beach, law enforcement problems declined, improving the overall quality of the
                  recreational experience. 69 As a result, family use of these beaches increased. However,
                  undesirable activities and resulting impacts on site quality may have moved to unregulated
                  beaches. A similar situation was seen when dogs were banned from some beaches. In order to
                  avoid impacts from simply being transferred from beach to beach, regional management plans
                  can establish which beaches are appropriate for what uses and ensure that site quality, overall
                  recreation quality, and a diversity of experiences is maintained for the maximum users.
                          Also evident in the pilot region are other examples of impacts to site quality. For
                  example, clean dredge spoils from Santa Cruz Harbor are often placed directly on Twin Lakes

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              State Beach. Dredging operations, while helping to maximize boating opportunities and safety
              in the harbor, also can have significant impacts on beach access opportunities: stretches of beach
              are closed while the dredging occurs, and spoils emit unpleasant odors and attract large number
              of seagulls; thus the area is generally unattractive to beach users. However, it is important to
              ensure that the dredged sand remains in the shoreline system to maintain area beaches. The
              mitigation measures required for the Santa Cruz Harbor dredging provide examples of how to
              mitigate impacts and ensure maximum access: conditions require that spoils be placed during
              times of low recreational use and must be graded onto the beach.    70
                       Another example of impacts to site quality occur from polluted runoff draining onto
              beaches, as occurs from Schwan Lagoon to Twin Lakes State Beach and from Neary Lagoon to
              Cowell Beach. Concern over, and reports of, degraded water quality at some sites in the pilot
              region are increasing; however, it is unclear if these reports are due to increased pollution, better
              monitoring, increased awareness and publicity, or a combination of these factors.    71,72
              Regardless, beach closures throughout the region impact the availability of public access. A
              degraded access site, or one that is perceived to be unsuitable for use, may reduce the desire of
              people to use the site, reducing the, actual opportunities available to the public. The loss of
              opportunities at these sites may in turn lead to increasing use and congestion at other sites. A
              site management plan can be instrumental in assuring these types of issues are addressed in ways
              that protect beach access.

                       A number of cumulative impacts also result from a trend of increasing restrictions on
              access opportunities, including growing use of beach curfews and new and/or increased fees. In
              the ReCAP area, approximately 30% of the access sites ReCAP identified restrict hours.       73
              Although ReCAP does not have historic data detailing when restrictions on hours were imposed,
              or when they changed, the trend of limited hours seems to be more prevalent in recent years: for
              example, after DPR imposed a curfew at Twin Lakes State Beach in the Live Oak area of Santa
              Cruz, the County supervisors imposed a curfew at their adjoining beaches. Data in 1981
              indicates that at that time few beach areas restricted hours of use. 74 As the imposition of curfews
              spreads, access opportunities are lost not only at the specific beaches, but at a wider, regional
              area. One example of the loss of access opportunities is the inability of surfers, fishermen and
              other users to reach sites early in the morning. 75

                       The imposition of fees is another trend that can cause significant changes in use of sites
              and adjoining uplands. Review of use data for DPR units in the pilot region cannot specifically
              correlate a change in use with the imposition of fees, particularly as many other factors may
                                      76
              affect the use of a site.  However, staff observation indicates significant changes in use at
                                                                77
              several State Beaches since fees were imposed    .   Moss Landing State Beach has provided
              historic access for sport fishing; after DPR imposed a day use fee, staff observed a significant
              decline in use of the Park by fishermen. At the same time, the number of sport fishermen using
              the South Harbor at Moss Landing and the Moss Landing Wildlife Area increased. This
              displacement in use has led to secondary impacts at these other sites: the South Harbor area has
              no facilities to support the increase in use by fishermen, leading to conflicts with parking and
              operation of the commercial harbor. Use at the Moss Landing Wildlife Area has led to resource
              impacts.
                       A second example of impacts from fees is observed at Palm Beach State Park.       78 Since
              DPR imposed fees at Palm Beach, staff observed increased parking along the side of the road.
              This trend raises not only safety concerns, but, since the roads border wetlands, result in resource
              impacts to these wetlands. Further, the fees may restrict lower-income users, particularly for
              fishing.

                       Intra- and inter-jurisdictional conflicts can also lead to cumulative impacts to access.
              Occasionally, an action taken by one department within a government contradicts the coastal
              access and recreation goals of another department. For example, staff observation in the ReCAP

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                           area indicates that in a number of areas, when residents perceive congestion due to beach use,
                           they call the local public works departments and ask for "No Parking" signs to be installed or for
                           curbs to be painted red; staff has observed this in the Live Oak and south County areas of Santa
                           C
                               79
                           ruz. However, it appears that the public works departments do not always coordinate with the
                           other departments responsible for maintaining public access to ensure that public access will not
                           be compromised. In many areas, street parking is vital to ensure public access to the coast.
                                 Different departments within a local government may also have competing objectives.
                           When planning is undertaken in different departments, those competing objectives are difficult
                           to correlate and require coordination. At Neary Lagoon and the San Lorenzo River Mouth, the
                           City of Santa Cruz must manage both recreation/habitat values and ensure neighboring property
                           against flooding. However, actions taken for either objective can affect the other.80 A
                           management plan can help resolve potential conflicts between such objectives.
                                 Another example of such inter-jurisdictional conflicts occurs when interpreting some of
                           the general policies in LCPs. For example, the Commission and City of Santa Cruz interpret
                           policies regulating what development can occur on the beach differently. 81 A management plan
                           can help ensure consistent application of policies and ensure that development on and adjacent to
                           beach areas does not negatively affect access.
                                 Since different issues relate to different geographic scales, different management plans
                           should be developed for both individual access sites that are experiencing cumulative impacts
                           and for a region. Management plans designed for the site level should address use numbers, user
                           conflicts, upland support at the sites, habitat concerns at the site, and operation and maintenance.
                           A beach management plan should also include procedures for coordinating intra-jurisdictional
                           actions to ensure that actions from one department do not counter another department's access
                           objectives.

                                 Regional management plans should address overall parking availability and transit;
                           habitat issues; priorities and distribution for access and support facilities, with an objective of
                           providing a diversity of recreational experiences (i.e. urban, developed beaches versus rural,
                           solitary beaches); and assuring that access priorities meet demand. Such regional plans should
                           also establish priorities for opening and accepting offers to dedicate new access. Since many
                           times adjacent beaches are managed by different entities, a regional management plan should
                           also address intedurisdictional actions and include measures to minimize the effects of one
                           action on another area.

                                 Due to limited existing data, management plans should also develop mechanisms to
                           track and monitor the data necessary to improve the provision of public access. This data
                           include: use figures; the amount, type, and location of support facilities; change in facilities;
                           ongoing maintenance; water quality; fees and limited hours; user needs; and sensitive species.
                           This information is necessary to evaluate the extent to which cumulative impacts are occurring
                           and the extent that those impacts are affecting use of sites. Currently, even basic information
                           such as the number of users to a site was obtainable only for State Park units and for the main
                           beach in Santa Cruz City. Use data provides the foundation for understanding access use and
                           demand, determining whether increases in facilities match demand for them, and determining
                           cumulative impacts to the resource. More accurate data will help develop more responsive
                           policies.

                                 In a number of cases, a management plan can be developed by supplementing an existing
                           plan or process to incorporate the issues discussed above. For example, DPR has developed
                           General Plans for each of the State Parks in the region; these plans can be updated to include
                           management measures to address cumulative impacts. Current regional planning efforts may
                           also be able to address some of the issues in a regional management plan. As discussed in
                           Access Problem #4, Santa Cruz County is currently undertaking a regional transportation

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                    planning effort. By working with the County on this and other regional transportation efforts,
                    such as congestion management plans, the issue of a regional transportation network for beach
                    access can be incorporated. The development of the Monterey Bay National Sanctuary also
                    provides opportunities to address access management through the coordination of coastal
                    planning and management authorities in the region.

                           While development of a beach management plan or a regional management plan will
                    provide the most comprehensive mechanisms for dealing with multiple sources of cumulative
                    impacts, other mechanisms may be sufficient in cases where cumulative impacts are limited to a
                    specific issue. In these cases, tools such as Memorandums of Agreement between the
                    Commission and local government or between departments within a local government may be
                    able to address the problem.

                    LR:k7C_fAJt
                        '.qV.WN0
                       *   Develop guidance documents and implement methods to collect and retrieve data
                           necessary for cumulative impact analysis.

                       *   Develop guidance documents for developing beach management plans and regional
                           management plans which suggest new mechanisms to address cumulative impacts.

                       *   Prepare a Beach Management Plan for City of Santa Cruz Main Beach as a pilot project
                           to guide preparation of guidance documents.

                       *   Work with other local governments in the pilot region to prepare management plans.

                       *   Work with DPR to update their General Plans to include management of cumulative
                           impacts.

                       *   Where appropriate, develop MOAs or other agreements with local governments to
                           resolve issues leading to cumulative impacts on access.

                    IDepartment of State Parks and Recreation day use data is calculated by paid walk-ins, paid group walk-ins, free walk-
                     ins, and free and paid vehicle. ReCAP has not included data for paid walk-ins and paid groups, as these groupings
                     were seldom reported on.
                    2DPR most frequently uses a conversion rate of 3.2 people per vehicle., The 50% increase shown in this analysis holds
                     within +/- 3% for conversion factors ranging from 2.0-3.0 people per vehicle.
                    3Population growth based on Department of Finance Estimates, 1976-1993.
                    4Mitchell, Dave and Gretchen Iliff. Santa Cruz County: Parks, Open Space and Cultural Services. Personal
                     Communication. September 9, 1993.
                    5 Culbertson, Bob. California Department of Parks and Recreation. Santa Cruz County District. Personal
                     Communication. November 4, 1993, and November 30, 1993.
                    6Jones, Paula; Dave Dixon; Glen McGowan; Rick Surmon; and Mark Ikenberry. State Department of Parks and
                     Recreation. Monterey County. Personal Communication. December 15, 1993.
                    7Smith, Sally and Frojon Banwell. Surfrider Foundation. Personal Communication. November 30, 1993.
                    8Lobay, Anthony; Bob Davis; and Vern Yadon. City of Pacific Grove. Personal Communication. September 10,
                     1993.
                    9Scheiblauer, Steve. Harbor Master, Santa Cruz Harbor. Personal Communication. August 31, 1993

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                        10 Bowhay, Brooks. Harbor Master, Monterey Harbor. Personal Communication. September 3, 1993.
                        1 'Smith, Sally and Frojon Banwell. Ibid.
                        12 Culbertson, Bob. Ibid. November 4, 1993, and November 30, 1993.
                        13 Scurich, Catol and Rick Gould. City of Santa Cruz. Personal Communication. September 10, 1993
                        14 Santa Cruz County adopted standards requiring access every 114 mile in rural areas and every 650 feet in urban
                        areas. Monterey County adopted standards only for the North County segment requiring access every 1/4 mile;
                        ReCAP generalized these standards to the entire county.
                        15 Two areas of the pilot region--Northem Santa Cruz County and the Del Monte Forest--were not included in this
                        assessment due to the physical infeasibility of increasing vertical access beyond what currently exists. These two
                        regions correspond to approximately 50 miles of the coast.
                        16 Although these figures represent a comparison between the two counties and offer a general assessment of physical
                        access improvements and the ability to further increase vertical access opportunities, the percentages may include
                        some beaches that are not suitable for maximum recreational development for reasons other than geography: for
                        example, the presence of sensitive habitat. Therefore, the actual amount of future access possible may be less than
                        indicated.
                        17 These figures do not include permits conditioned by the local government requiring an easement for lateral or
                        vertical access; easements differ from OTI)s in that easements are generally dedicated to a local government and are
                        available for public use after recordation occurs. Further, these figures do not include Commission or local
                        governments conditioned to require an OTD for a trail, which provide additional access.
                        is If the five permits where local grading or building permits cannot be verified are excluded, the percent of projects
                        complying with the OTD recordation requirement is approximately 23%.
                        19 As noted previously, the-additional access easements required by local governments do provide access for public
                        use.
                        20 Mitchell, Dave and Gretchen lliff. Ibid.
                        21 Lobay, Anthony, et al. Ibid
                        22 California Coastal Commission. Coastal News: Standards and Recommendationsfor Coastal Access. 1980.
                        21 Mitchell'Dave and Gretchen lliff. Ibid.
                        24 An additional 49 Commission permits and 16 local government permits did not require OTI)s because access
                        improvements were incorporated into the development proposals. These improvements however are not always
                        lateral or vertical access.
                        25 California Coastal Commission. Statewide Interpretive Guidelines. 198 1.
                        26 As discussed in Section 3, this figure is calculated by estimating that seawalls extend 4 feet onto a beach and
                        revetments/rubble walls extend 20 feet onto a beach.
                        27 Commission adopted findings, including for permits 3-87-86; 3-88-51; 3-83-176-Al; 3-83-176-A2; 3-84-75-A; 3-
                        84-83.
                        28 Department of Boating and Waterways. Shore Protection in California. 1976. Adopted by Commission findings,
                        including permit 3-87-86.
                        29 Lobay, et. al. Ibid. 1993.
                        30 Roseth, Brian. Planning Director, City of Carmel. Personal Communication. December 10, 1993.
                        31 Everly, John D. Ill. No Trespassing: Incremental Loss of Coastal Public Access in California. 1993.
                        32 Monterey Bay Dunes Coalition. Monterey Bay Dunes. 1989; revised 1991.
                        33 Coastal Development Permit Files #3-87-258 and #3-86-011.
                        34 Jones, et. al. Ibid. 1993.

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                      35 Page, Gary. Point Reyes Bird Observatory. Personal Communication. May 13, 1994.
                      36 Jones, et. al. Ibid. 1993.
                      37 Coastal Development Permit File #3-87-258.
                      38 Roseth, Brian. Planning Director, City of Carmel. Personal Communication. December 10, 1993
                      39 California Coastal Commission. ReCAP Wetlands Database. 1994.
                      40 Page, Gary. Ibid. May 13, 1994.
                      41 Gray, Ken. Department of State Parks and Recreation. Personal Communication. February 11, 1994.
                      42 Monterey Bay Dunes Coalition. Ibid. 1989; revised 199 1.
                      43 Jones, et. al. Ibid. 1993.
                      44 Analysis based on review of 1979 and 1993 aerial photographs,
                      45 Department of State Parks and Recreation. California Outdoor Recreation Plan: 1993. Sacramento, CA. 1994.
                      46 Culbertson, Bob. Ibid. November 30, 1993.
                      47 This figure is probably an underestimation, as some files did not have specific numbers of parking spaces.
                      48City ofSanta Cruz Beach Area Plan. 1980.
                      49 DKS Associates. Beach Area Transportation Studyfor Santa Cruz City, 1987.
                      50 Arthur D. Little, Inc. Draft Working Paper 2; Cannery Row Local Coastal Plan. 1978.
                         Monterey County Planning Department. Carmel Coast 400 Series Draft Background Data Reports. 1980.
                      52 City of Capitola. Local Coastal Plan. 198 1.
                      53 City of Carmel. Local Coastal Plan. 198 1.
                      54 City of Santa Cruz. Local Coastal Plan. 1985.
                      55 Based on review of 1978 and 1993 aerial photos.
                      56 City of Carmel. Local Coastal Program: Land Use Plan. 198 1.
                      57 Scurich, Carol and Rick Gould. Ibid.
                      58 Department of State Parks and Recreation. Use data. 1981-1992.
                      59 While ReCAP has no concrete data on the extent of this problem, informal observations suggests the problem exists
                         at Seacliff, Manresa, and Moss Landing State Beaches.
                      60 The Commission has required a shuttle as mitigation for the development of the Monterey Bay Aquarium; however,
                         in most cases the necessary connection between the development and transit issues probably cannot be made, since
                         much of the problem stems from increased use and congestion overall. Individual development projects may add to
                         the problem, but cannot be required by themselves to fund a shuttle, nor would it probably be effective on a project
                         by project case.
                      61 Fry, Linda. Santa Cruz Metro Transit. Personal Communication. September 30, 1993.
                      62 Scurich, Carol and Rick Gould. Ibid.
                      63 Department of State Parks and Recreation. Ibid. 1994.
                      64 Department of State Parks and Recreation. California Outdoor Recreation Resources Plan. Sacramento, CA. 1973.
                      65 Department of State Parks and Recreation. Ibid. 1994.
                      66 Allison, Maria T. "Problems of Access and Ethnic Boundary Maintenance." In Proceedings ofthe Symposium on
                         Social Aspects and Recreation Research. United States Department of Agriculture. 1992.
                      67 Healy, Doug. Department of State Parks and Recreation. Sacramento. Personal Communication. October 6, 1993.

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                      68 Dickert, Thomas. "Limits to the Ad Hoc Approach", in Fawcett, James A, Andrew T. Manus, and Jens C. Sorensen,
                        eds. Proceedings ofa Forum on Recreational Access to the Coastal Zone. 1979.
                      69 Stmad, Les. California Coastal Commission. Personal Communication. July 27, 1995.
                      70 California Coastal Commission. Coastal development Permit #3-86-175.
                      71 Scurich, Carol and Rick Gould. Ibid.
                      72 Ricker, John. Santa Cruz County Environmental Health Services. Personal Communication. August 24, 1993.
                      73 California Coastal Commission. ReCAP Database.
                      74 California Coastal Commission. California Coastal Access Guide. 198 1.
                      75 Smith, Sally and Frojon Banwell. Ibid.
                      76 Department of State Parks and Recreation. Use Data. 1981-1993.
                      77 Stimad, Les. Ibid.
                      78 Stmad, Les. Ibid
                      79 Locklin, Linda. California Coastal Commission. Personal Communication. July 24, 1995.
                      80 California Coastal Commission. Coastal Development Permits #3-92-15 and #3-90-3 1.

                        Stmad, Les. Ibid.

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                                                         EIMER=

                             This chapter examines both wetland resources and the institutional framework used to
                     determine how these resources are protected and managed. The historic, current and projected
                     status of wetland morphology (acreage, fragmentation, and habitat), physicochemical processes
                     (hydrology and water quality), and biodiversity are presented. Institutional analysis focuses
                     primarily on the California Coastal Management Program (CCMP), as implemented by the
                     Coastal Commission and local governments, and secondarily on other federal and State statutes
                     governing wetlands.

                             Wetland resources within the ReCAP region have suffered significant adverse impacts
                     over time. Results from this project generally indicate that:

                         *   The most dramatic adverse impacts occurred in the century predating the Coastal Act
                             (i.e., pre 1970's), although adverse impacts have also occurred more recently.

                         *   Most-adverse impacts are human-induced, both diredtly from activities occurring in and
                             around wetlands and indirectly from other activities occurring in the associated
                             watersheds.

                         *   Many adverse impacts have resulted in smaller, scattered wetlands, altered hydrology,
                             deteriorated water quality, and reduced biodiversity.

                         *   The cumulative impacts to wetland resources and the current status of these resources
                             are best illustrated through qualitative information and specific examples rather than
                             quantitative information, due to a lack of appropriate data and/or analyses that are
                             beyond the scope of ReCAP.

                         *   Conditions currently exist that adversely affect wetlands within the region. In some
                             cases (e.g., the building of roads or dams), the adverse conditions have persisted over
                             long periods.                              I

                         *   Continued development pressures and regulatory gaps may lead to additional adverse
                             effects.

                         *   Various efforts, although sometimes uncoordinated, are being made to prevent and
                             correct some adverse conditions, especially through the development of wetland
                             management plans.
                             A framework for regulating adverse affects to natural resources, consisting of the
                     California Coastal Act, the Clean Water Act, and the California Environmental Quality Act,
                     among others, was institutionalized in the early 1970's. By and large, the resulting regulations
                     have prevented significant additional adverse wetland impacts from new development.
                     However, these laws contain several exemptions that limit their universal application, especially
                     for pre-existing land use activities. Various implementation deficiencies also limit the
                     5

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                   effectiveness of these laws. Limitations on wetland fill are most stringent, while limitations on
                   other types of activities in wetlands (e.g., vegetation removal or draining), and limitations on
                   detrimental development adjacent to wetlands (such as those causing abnormal erosion) are less
                   stringent. A lack of readily available information ftirther limits the ability of regulatory
                   programs to address cumulative adverse impacts to wetlands.

                            A variety of approaches are possible to address the existing procedural deficiencies. For
                   instance, changes in the way some regulations are implemented to improve consistency would
                   benefit both the regulatory agencies and the regulated community. Additionally, numerous
                   wetland management plans have been and are being prepared to address current wetland issues.
                   Recent and pending federal legislation to control nonpoint source pollution promises new
                   mechanisms at the watershed level to further reduce wetland degradation.' Notably, this new
                   generation of comprehensive wetland- and watershed-based planning and regulation, and the
                   resultant information generated, has occurred since the project area's local coastal programs
                   were originally adopted. The challenge faced by the Commission and local governments is to
                   incorporate these new approaches into the CCMP, while continuing to support currently
                   successful protective efforts.

                                                                                                      N,
                                                                                                              Q'
                                                                                       W - MMM 180
                            ReCAP's analyses show that in order-to more fully address cumulative impacts, wetland
                   issues should be addressed in a comprehensive, watershed-based framework, which is contrary to
                   the typically fragmented practices of the past. The primary recommendation is to establish a
                   regional framework to set priorities, coordinate, provide technical assistance, and otherwise
                   guide preparation and implementation of wetland and watershed management plans (see
                   Wetlands Problem #7). The apparent best course of action is to capitalize on the recently-
                   initiated Monterey Bay National Marine Sanctuary's Integrated Coastal Management (ICM)
                   process, which is currently working to complete a water quality protection program. It is within
                   the ICM framework that specific watershed and wetland management planning should continue,
                   so as to address local concerns from a regional perspective. This chapter recommends some
                   guidelines for preparing wetland management plans and processes for integrating these plans
                   into the CCMP.

                            In conjunction with this overall recommendation, ReCAP recommends specific
                   improvements in the following categories:

                       *    short-term, procedural improvements to the CCMP (i.e., to the appropriate local coastal
                            programs and Coastal Commission operations) to better achieve policy objectives and
                            prevent cumulative impacts.
                       *    longer-term strategies to ftirther comprehensive wetland and watershed management.
                       *    opportunities for further research, data analyses, and integration of the resulting
                            information.

                            These opportunities for further research are based on an evaluation of what information
                   is currently available. They are presented so as to be available to universities and others
                   interested in pursing wetland issues, rather than as recommended work items for the Commission
                   to undertake.

                            ReCAP's analyses represent only a first level of recommended improvements. As
                   additional information and recommendations are generated, they are expected to lead to further
                   refinements of the existing local coastal programs and other elements of the CCMP. At the same
                   time, implementation of wetland and watershed management plans should lead to enhancement

                   PAGE 72                           CALIFORNIA COASTAL COMMISSION
<pb n="75" />

                                                                                              CHAPTER 5 - WETLANDS

                    of the region's degraded wetlands. With respect to wetlands, the CCMP must be improved in a
                    manner that leads to more comprehensive management, of which regulation of new development
                    is only one component.

                            The next section of this chapter presents as background information the policy
                    framework under which wetlands are regulated, summarizes the status and trends of wetland
                    resources in the region, and describes the analytical approach used to assess cumulative impacts
                    to wetlands. Finally, this chapter describes seven problems identified through the cumulative
                    assessment, including a discussion of the apparent causes of the problems, projections for their
                    continuance and resolution, and specific recommendations for correction or improvement. The
                    problems are:

                            direct loss of wetland acreage, fragmentation, and habitat change.

                            inadequate provisions of buffer areas.

                            hydrologic impacts.

                            water quality impacts.

                            biodiversity impacts.

                            information gaps in the decision-making process.
                            lack of regional, watershed, and jurisdictional planning and management frameworks for
                            achieving comprehensive wetland protection.

                            Wetlands are a significant, but severely impacted, natural resource within California.
                    Only since the late 1960's have wetlands engaged the attention of individuals from a range of
                    disciplines who endeavor to understand their variety and complexity.2 Recent but intense
                    interest in wetlands is due largely to their role in aquatic and terrestrial ecosystems, and our
                    changing perceptions of them. Humans have come to understand how important wetlands are to
                    the existence of numerous plants and animals, as well as the many functions they perform (e.g.,
                    flood control, ground water recharge, and maintenance of water quality) that are important to our
                    quality of life.

                            This section provides a description of three elements that play an important role in
                    assessing the cumulative impacts to wetlands within the ReCAP region: (1) the existing policy
                    framework; (2) the current status of wetland resources; and (3) the analytical framework used for
                    this assessment. Each of these elements is described separately, but together form the foundation
                    for ReCAP's identification and analysis of cumulative impacts to wetlands.

                                                                           0@ ,
                                                                             T,7
                              f ''MEW                          4"D
                    POL[C                                                 . .... . ..... . .....
                                FM
                                                                                                Rk
                                                   Olt, UYS, 1,                            1 IT,     M
                            Currently, numerous federal, State, and local agencies administer and enforce a myriad.
                    of regulations that limit and control the development and alteration of wetlands in California.3
                    (For an example of the regulatory framework for wetlands in the ReCAP pilot area, see Figure 5-
                    1, next page.) Although a few statutes and directives are specific to wetlands, most of the
                    regulatory influence over wetlands occurs indirectly through management or regulation of water
                    quality and quantity, fish and wildlife, endangered species habitat, water navigation, floodplain

                                                   CALIFORNIA COASTAL COMMISSION                             PAGE73
<pb n="76" />

                                  RECAP PILOT PROJECT

                                                                                                                                                                                       4
                                  control, public trust, environmental land use regulations, and coastal resource conservation                                                        .
                                  However, even with the complex array of existing regulations, California's wetlands do not
                                  receive equal protection. Although the federal regulations stipulated in the Clean Water Act
                                  (Section 404) and the River and Harbors Act (Section 10) apply to most of the wetlands within
                                  the State, only wetlands within San Francisco Bay and the coastal zone are afforded additional
                                  protection through specific State coastal program provisions.

                                  Figure 5-1: Relationships Between Various Permits that May be Requiredfor Development in a Wetland Occurring in
                                                                                                     the Coastal Zone      S

                                                                                                  1. Local Government

                                    Project will result       Applicant must get a                                                    Applicant must get           Project will impact
                                    in significant            CCC permit if wetland                                                   a COE permit if              threatened or
                                    environmental             is in uncertified or original                                           project impacts              endangered species
                                    impacts                   CCC pemitjurisdiction                                                   &gt; I acre of wetland

                                                                                     Local government review          5. Regional Water
                                                                                     project for conformance          Quality Control Brd.                    6. Fish and Wildlife Serv.
                                                                                     with LCP wetland policies          Review project for                    or Dept of Fish &amp; Game
                                      CEQA                                           and approves or denies             conforinance with                     Takings Permit required,
                                                                                     permit, which can be               Section 401 of the                    review project for
                                                                                     appe aled to the C                 Clean Water Act                       conformance with the
                                                                                                                                                       *      Endangered Species Act
                                                                                                                                      4. Army Corps of Engineers

                                         2. Coastal Commission                 37 Dept of Fish &amp; Game
                                       CCC reviews project for                       Project affecting a                                                           project proposed
                                       conformance with Section                      stream, river, or lake                                d*                      in navigable waters
                                       30233 of the Coastal Act and                  must get a Strearnbed
                                       approves or denies permit                     Alteration Agreernent_
                                                                                                                      Review project for                        Review project for
                                     -- -           V                                                                 conformance with Section                  conformance with
                                  Flf acZtivity is below mean high tide line, then the p-ject requires                404 of the Clean Water Act                Section 10 of the
                                    certification from the Monterey Bay National Marine Sanctuary                                                               Rivers and Harbors Act

                                             The Coastal Commission is the lead State agency charged with the regulation of
                                  development in California's coastal zone.                         6   The California Coastal Act is the document the
                                  Coastal Commission relies on for overall guidance and direction in fulfilling its charge. Sections
                                  3 023 0, 3 023 1, 3 023 3, 3 023 6, and 3 0240 of the Coastal Act relate directly to the preservation and
                                  protection of wetlands and other environmentally sensitive areas. The development and
                                  alteration of wetlands in the coastal zone, however, are primarily regulated by Section 30233(a)
                                  of the Coastal Act. Among other things, Section 30233(a) lists the types of development for
                                  which diking, filling, or dredging may be permitted in open coastal waters, estuaries, lakes, and
                                  wetlands.     7  This section also stipulates the criteria under which development is permitted (i.e.,
                                  least environmentally damaging feasible alternative and provision of adequate and feasible
                                  mitigation). In addition to the specific provisions of the Coastal Act, the Coastal Commission
                                  has adopted the Statewide Interpretive Guidelinesfor Wetlands and Other Wet Environmentally
                                  Sensitive Habitat Areas (1981). These guidelines contain technical definitions for wetlands and
                                  riparian areas, discuss conditions for pennitting development in these areas, and provide
                                  information pertaining to the maintenance and restoration of wetlands. The guidelines were

                                  PAGE 74                                            CALIFORNIA COASTAL COMMISSION
<pb n="77" />

                  Scntc Cruz County                                    Monterey Counly                                                                                                                                                            California Coastal Commission
                  I. WCO'dell Creek Marsh and Estuary                55  McClusky Slough
                  2. Last Chance Road Marsh                          56  2mudowski Slough 5                                                                                                                                     Regio      al Cumulative Assessment Project
                  J. Scott Creek Marsh                               57  Gibson Landing Morshl
                  4. Molina Creek Marsh                                  Lower Bennett Slough                                                                                                                                             IT
                  5 Davenport Landing Marsh                          58. Uoper Bennett Slough
                  6. Silverking Ponds                                                                                                                                                                                                Wetland Locations
                  7 Son r1cente Creek                                    (Struve Pond)                                  Pt. Ano
                                                                     59. Elkhorn Slough                                   Nuevo
                  8. L iddell Creek                                  60. Moss Landing N. Harbor
                  9. Laguna Creek                                    61. Moro Cojo Sioughl
                  10. Sand H171 Bluff Marsh and Pond                     Shadow Oak                                                   2                                              S A N T A
                  I/. Molars Creek                                   62  Old Salinas R Channel
                  12. roble Rock Wetland                             65. Coastal Alkali Grassland                                                                                               C R U          Z
                  IJ Baldwin Creek Marsh                             64. 7embladero Slough
                  14. f-our-Mile Beach                               65  Salinas River Mouth                                                            Bonn                                                                                                       Study Area
                  15 Lombardi Gulch                                      and Lagoons                                                          Al        Doon                                                                                                           Location           CA
                  16 Old Dairy Gulch Marsh                           66. Porsons Slough
                  17 Wilder Creek                                    67  Tarpey Lake                                                         Davenport
                  18. Younger Lagoon                                 68  San Miguel Canyon                              C-1                         8  7                                 Santa
                  1.9 7erroce Point Lower Ponds                          Rood Marsh                                                                       9                                Cruz       Soquel
                  20. Terrace Point Upper Pond                       69. Tucker Road Pond                                                                  10   11          12         0      0                         40
                  21. De Anza Pond                                   70. Long Ccn.@vn Rood Marsh                                                     13-14                                                   38          4
                  22. Natural Bridges Lagoon                         71. Paradise Rood Pond                                                                        15 16
                  2J. Antonelli Pond                                 72. Rolling Hills // Marsh                                                                      17                        Pt"         3739
                  24 Monarch Pond                                    73. Martin  Dunes Marsh                                                                13-20                             Santa    35-36
                  25. UCSC Inclusion Area A                          74. Morino  Vernal Pond fl                                                                         21-24                 Cruz              43-44
                    Seasonal Wetlands                                75  Morino  vernol Pond f2                                                                                             26       30-J4                45                           Watsonville
                  26. Neory's Lagoon                                                                                                                                                                                                                      1 141
                  27 Son Lorenzo RIver                               76  Morino  Vernal Pond OU                                                                                              27-29                   46-4             48--4
                                                                     77  Morino  Vernal Pond OF4
                  28 Jessie St Marsh                                 78. Morino  Vernal Pond                                                                                                                                 51                                           Aromas
                  29. Seabright Cove Draincge Outlet                 79. Morino  Vern al Pond                                                                                                                             52  50
                  jo. Aranc Gulch Marsh                              80. Marina  Vernal Pond f7                                                                                                                                 51T       1                         067
                  it. Schwonn:r Lagoon                               81. Morina  Vernal Pond f8                                                                                                                        Pqldro Rz      r
                  12. Block's Pond                                   82. Morin a Vernal Pond f9                                                                                                                                           1  58
                  JJ. Bonita Lagoon                                  8J  Morino  Vernal Pond RO                                                                                                                             55-      6          5_9       .69
                  .34. Sunny Cove Drainage Outlet                    84. Marino  Vemol Pond P1                                                                                      o n                                               60
                  J5. Corcoran L ogoon                               85. Fort Oro' Pond                                                                                                                                   Moss Landin                      0
                  J6. Moran L oke                                    86  Indian Head Ponds                                                                                                                                                                    I
                  J7 Soquel Creek                                    87  Roberts Lake                                                                                                                                                              61
                  J8. Borregas Creek                                 88. Laguna Grande                                                                                                                                                                             Prunedole
                  39. Aptos Creek                                    89. Cresoi Pond                                                                                                                                                                 72
                  40. Valencia Lagoon                                90. Pacifi-c Grove Muni    Pond                                                                                                                             R2'?Vle  @4
                  41. Bonita Drive creek                             91. Frog Pon d                                                                                                                                             65                    ostroville
                  42. Seascape Pond                                  92. Majello Slough
                  43. Los Borroncos Drainage Outlet                  9J  Spanish Boy Marsh
                  44. "Onreso Drainoge Outlet                        94. Sawmill Gulch Marsh                                                                                                                                73
                  45. Ellicott Station Pond                          95  Seal Rock Creek                                                                                                                               74-84
                  46 00111gl7on Slough
                  47 Harkins Slough                                  96. Fanshell Beach Welland                                                                                                                                                                         Salinas
                  ,48. Hanson Slough                                 97  Pescoolero Creek                                                                                                                                                                            0
                  49. W Branch Struve Slough                         98. Carmel River Lagoon                                                 2V                                                             89                         M rina
                  50. Sunset Beach FW Marsh                          99. Son lose Creek                                                                                                                        Pacific 85-86          Fof t Ord
                  51. Upper Wctsonville Slough                                                                                                                                                       Pt. Pinos Grove87-                                   M     0 N       T E       R    E    Y
                  52 Shorebirds Pond                                                                                                                                                                 90
                  53 Lower Wotsonville Slough                                                                                                                                               91-92                                 Sand City
                  54. Po/&amp;O River                                                                                                                                                      93-94                                   Seaside
                  Thematic Sources:                                                                                                                                                             95
                  NASA Aerial Photography. 1977, Scale 1:32,500                                                                 Scale 1:325,000                                           Cypress Pt.      96         Monterey
                  CA Dept. of Water Resources Aerial Photography, 1978, 1979, 1986, and 1993                                1 inch equals approximately 5 miles
                  Atlas of Marine Resources. CA Dept. of Fish and Game, 1980
                  National Wetlands inventory. US Fish and Wildlife Service, 1986                                           0                                   10                          Ca,7- m el.11'         Carmel
                                                                                                                                             ----i           . I                                i9ay
                                                                                                                                            Miles                                               99     .98                                7-             Sfudy Area Boundary
                                                                                                                                                                                                Pt. Lobos

                      cclifornia Coastal Commission
                      Technical Services Division                                                                                                                                                                                                                                         FIgure 5-2
                                                                                                                                                                                                                                                                                                     A(-H 11 94
<pb n="78" />

                                                                                                       CHAPTER 5 - WETLANDS

                       developed to assist the Coastal Commission, local governments, and the public in the application
                       and interpretation of the Coastal Act and in the development of local coastal programs. Most
                       recently, the Coastal Commission has produced a document entitled Procedural Guidance For
                       The Review Of Wetland Projects In California's Coastal Zone (1994). This document describes
                       a review process the Coastal Commission uses to evaluate proposed wetland development
                       projects.

                               The California Coastal Act is designed to delegate to local governments much of the
                       Coastal Commission's authority to regulate coastal development through the implementation of
                       local coastal programs (LCPs). To become certified for use, the LCPs must, compared to the
                       Coastal Act, provide equal or greater protection of coastal resources. With a certified LCP, a
                       local government assumes authority for permitting certain types of development in specified
                       areas of the coastal zone, including many of the wetlands in the ReCAP region.

                               Local governments with jurisdictions in the ReCAP pilot area ensure that their LCPs
                       provide for the regulation of wetland development by identifying wetlands as "environmentally
                       sensitive habitat areas" and, pursuant to Coastal Act Section 30240, limiting development to
                       resource-dependent uses. The LCPs also contain specific language relating to the protection of
                       wetlands within the jurisdiction. For example, the LCPs specify the width of buffer areas around
                       wetlands (see discussion of buffer areas under Wetland Problem #2), specify erosion control
                       measures to prevent excessive amounts of sediment from entering wetlands, and specify
                       management strategies for particular wetlands.   8  Because of the shared responsibility for
                       management of wetlands, program improvements need to be implemented in a coordinated
                       fashion by the Commission and local governments.

                                                                                                                       0"711,  1
                                                                                                          .21
                                                             D
                                                             5, U Pt cll.@ rus
                               The ReCAP project area contains a diverse array of wetlands.       Coastal lagoons, large
                       slough complexes, salt and freshwater marshes, lakes, and rivers all occur within the project
                       area. Analysis completed as part of this project revealed 99 wetlands9l within the project area
                       (Figure 5-2, page 75), totaling approximately 6,200 acres. A review of aerial photographs from
                       1977, 1986, and 1993 suggests there has not been an appreciable change in total wetland acreage
                       over the last 16 years. 10 Of the 99 wetlands identified in the project area, at least 16 have been
                       placed under more protective status in the last 20 years. Comprehensive management plans have
                       been prepared or are being prepared for at least 24 of the area's wetlands. Restoration projects
                       have been undertaken for at least 32 of the area's wetlands.

                               It is important to realize, however, that wetland acreage is not the sole determinant of the
                       condition of wetland resources. The quality of a wetland is more accurately determined by
                       acreage and functional capacity. California's coastal wetlands serve a number of important
                       functions such as the provision of habitat for native wildlife, water purification, and flood
                       control. The value of these functions will vary depending on the wetland size, its location in the
                       watershed, and the surrounding land use.

                               Both natural and anthropogenic processes have historically affected the quality of
                       wetlands in the ReCAP project area. Natural changes involve processes still occurring today:
                       seasonal berm formation at the mouths of coastal lagoons, changes in freshwater inputs due to
                       droughts and floods, and earthquakes. Human-induced changes have involved activities related
                       to agricultural and urban development. Over the previous century, development projects such as
                       the damming of rivers, construction of transportation corridors, and major urban and agricultural
                       development have all diminished the quantity and quality of wetland habitat through the
                       degradation of wetland hydrology, water quality, and direct habitat loss. More recently,
                       however, wetland habitat has been most affected by the lingering effects of earlier development
                       (e.g., point and nonpoint source pollution, chronic reductions in the amount of water reaching

                                                         CALIFORNIA COASTAL COMMISSION                                PAGE 77
<pb n="79" />

                                   RECAP PILOT PROJECT

                                   wetlands, and the loss of adjacent buffer areas). Although still apparent, the rate at which
                                   wetland habitat, hydrology, water quality, sedimentation rates, and biodiversity are adversely
                                   impacted appears to have declined since inception of the Coastal Act. On the other hand, there
                                   are few examples of positive change from an ecological perspective. Thus, the challenge is not
                                   simply to halt, but to reverse the historic adverse impacts, as enhancement and restoration are
                                   also Coastal Act objectives (Section 30001.5).

                                         A-M."', P'L
                                                        @_ffl, A P, P
                                                                  @@R@00
                                                                                                           1, @Nl
                                                 Conceptually, a number of factors have the potential of affecting a wetland through
                                   changes to one or more of the physical, chemical, or biological attributes (Figure 5-3). The
                                   conceptual diagram below illustrates the key attributes of a wetland, the various factors that
                                   could impact those attributes, and the principal processes that exert influence over the factors.
                                   The connecting arrows depict the pathways by which the processes can influence the various
                                   attributes. For example, urban development (an anthropogenic process) may enhance the
                                   establishment of introduced species, which can adversely impact wetland biodiversity. In
                                   addition, many of the pathways are interconnected. For example, a drought will lead to reduced
                                   freshwater inputs, which will affect wetland hydrology (physicochemical), which can ultimately
                                   affect both the size (morphology) and species abundance (biodiversity).

                                     Figure 5-3: Original Conceptual Model Showing the Relationships Between Processes, Factors and Attributes in
                                                                                                                       Wetlandy

                                                                                                   Natural Pro                                         Anthropogenic Processes
                                    PROCESSES                                                      - Weather p=                                        - Zculture
                                                                                                                                                       - Urbanifindustrial Dev.
                                                                                                                es
                                                                                                    - Earthquak El                                     - Pollution

                                                                Introduced        Erosion and          Changes in       twater                                  Draining or          Vegetation Re        al
                                      FACTORS                     Species         Sedimentation I lorFreshwatear'lisputs                or G ading                 Flooding               - Shading mov
                                                                                                                                                                                          - Burnin.

                                                                                                                           Physicochemicol Attributes                                     Morphology
                                                                                                                                 -Hydrology                                               - Total Size
                                                                                                                                 -Water Quality                                           - Patchin
                                                                                                                                 - Sediment Dynamics                                      - Habitat Size
                                                                                                                                 - Soil Salinity                                          - Elevations
                                                                                                                                 - Nutrient Cycling/Flux

                                   ATTRMUTES

                                                                                            Biodiversity                                                                            es
                                                                                            -Species Abundance                                                                      IFlux
                                                                                            -Species Richness

                                                 Because of their complexity, the cumulative impacts to wetland resources in the ReCAP
                                   project area were investigated through separate study of three key attributes: (1) morphology;
                                   (2) physicochernical processes; and (3) biodiversity. Although trophic dynamics was also
                                   considered a key attribute, it was not included in this analysis due to a lack of valid
                                   information.          11    Based on analyses of the various wetland attributes, this chapter describes, as
                                   problem statements, the various sources of impacts, and recommends procedural or policy
                                                                                                                                                       _U

                                                                                                                            ply"    @Ieinicsl Attributes
                                                                                                                                 'Iss,

                                                                                                                                                                   Trophic Dynami
                                                                                                                                                                   - Energy Sourca
                                                                                                                                                                   - Productivity

                                   changes to resolve or reduce the identified problem. This chapter also examines wetland
                                   regulatory concerns and comprehensive management issues in an attempt to determine strategies

                                   PAGE78                                                      CALIFORNIA COASTAL COMMISSION
<pb n="80" />

                                                                                                                                                                                   CHAPTER 5 - WETLANDS

                                         for long-term effective management of cumulative impacts. In all cases, the analyses attempt to
                                         answer three basic questions: (1) what has happened; (2) why has it happened; and (3) what will
                                         happen if past trends continue. The analyses generally consider two time frames: (1) the Coastal
                                         Act period (1973 -1993, emphasizing the second decade, 1983-93, when many of the region's
                                         local coastal programs were certified); and (2) to a lesser extent, the pre-Coastal Act period
                                         (1972 and earlier).

                                                       Although separate analyses were completed for the various attributes, wetlands are not
                                         isolated systems. Interactions among wetlands and the surrounding landscape occur continually
                                         by way of water, air, and the organisms that rely on them. Thus, impacts to one aspect of a
                                         wetland will affect other attributes as well as other wetlands. With this in mind, results of the
                                         analyses were also used to revise the conceptual model of wetland impacts (Figure 5-4). These
                                         revisions included refinement of the connections between sources of impacts (processes and
                                         factors) and the affected attributes. In addition, the connecting arrows were qualitatively
                                         weighted (e.g., high, medium, and low). This weighting provides an indication of the
                                         contribution various processes and factors made to documented changes in wetland attributes.
                                         The results show that anthropogenic processes had the largest cumulative effect on wetlands in
                                         the ReCAP project area, which manifest as changes in physicochemical and morphological
                                         attributes. Natural processes were also found to affect the wetlands over the last ten years, albeit
                                         to a lesser extent, through changes in saltwater or freshwater inputs. There were several
                                         indications that wetland biodiversity has been adversely affected, but the available information
                                         was limited and did not provide evidence for the magnitude or sources of the impacts.

                                             Figure 5-4:. Revised Conceptual Model Showing the Relationships Between Processes, Factors and Attributes in
                                                                                                                            Wetlands

                                                                               INEW    INUM    SEEN     INNO    NONE    SEEN    SEEN     INEW    1000    " Anthropogenic Processes
                                                                                                            Natural Processes
                                           PROCESSES                                                          Weather pantemm                                     Agriculture
                                                                                                              Earthquakes                                         Urban/Industrial Day.
                                                                                                                                                                  Pollution

                                                                                                                                                                                                       A
                                                                                         Erosion and           Changes in Saltwat r              edging@'                                     Vegetation Removal
                                              FACTORS                                    Sedimentation         or Freshwater inpu                      Icilling'                                       Shading
                                                                                                                                                                                                       Burning

                                                                                                                                   Physicochemical Attributes                                     Morphology
                                                                                  Riodiversity                                        - Hydrology                                                      Total Size
                                                               Is                                                                     - Water Quality                                                  Patchiness
                                          ATTRYBUTE                               -Species Abundance 1      .4-
                                                                                  -Species Richness                                   - Sediment Dynamics                                              Habitat Size
                                                                                                                                        Soil Salinity                                                  Elevations
                                                                                                                                        Nutrient Cycling/Flux                                              I

                                                                                            asoo     anus    onos    suat     song    aoos    sans     uous       nous sooo     aoos    sooo      aoss   ab

                                                                                                                                           INFORMATION                       LIMITED OR NO
                                                                                                                                                EXISTS                        INFORMATION
                                                                                                                                                                                    EXISTS
                                                                                             HIGH IMPORTANCE                                                                   SOME 0000

                                                                                             MEDIUM IMPORTANCE                                                                 - - - - -

                                                                                             LOW IMPORTANCE                                                                    ----------

                                                        Because wetlands are not isolated systems, assessments that evaluate wetland impacts as
                                         isolated occurrences provide an incomplete picture. There is clearly a need to take a landscape
                                         approach to protecting and managing wetlands. Resource and regulatory agencies must think
                                         about wetlands as part of a bigger system, as integral components of the watershed. Finally,

                                                                                                     CALIFORNIA COASTAL COMMISSION                                                                             PAGE79
<pb n="81" />

                 RECAP PILOT PROJECT

                 these agencies need to include humans within that bigger system, not only as a source of   12
                 impacts, but also as the potential solution to the cumulative impacts humans have created.

                       WETLANDS PROBLEM ONE

                         The amount of wetland acreage in the Monterey Bay pilot region has greatly decreased
                 over the last century and wetlands have become more fragmented, due primarily to human
                 impacts. Neither the CCMP nor any other program comprehensively addresses historic loss.
                 Recent and potential permitted and unpermitted development have resulted in and may continue,
                 absent some regulatory improvement, to result in some additional wetland acreage loss.

                 E-A @N-

                               Pro- blems,
                 Vo 'h 10     1C:;
                           9:
                         The disappearance of our nation's wetlands     an estimated 90% loss in California    is a
                 major environmental concern.  13 So is the resulting fragmentation: historic wetland connections
                 have been severed and distances between wetlands have increased. In the project area, wetland
                 loss and fragmentation are historic problems that persist with no comprehensive, accepted
                 remedy. In addition, alterations to existing wetlands have resulted in habitat changes, some of
                 which have been adverse.  14

                                     Table 5-1: Historical Areal Changes in Salinas River Lagoon Habitat

                                                                            ... ........
                                                                                    .. .. . ... .......
                               1910                             Open Water                            341.38
                                                             Islands/Wetlands                            0.00
                                                                   Total                              341.38
                               1933                             Open Water                            235.18
                                                             Islands/Wetlands                           16.04
                                                                   Total                              251.22
                               1937                             Open Water                            184.01
                                                             Islands[Wetlands                           41.61
                                                                   Total                              225.62
                               1990                             Open Water                            132.11
                                                             Islands/Wgtlands                           94.97
                                                    L              Total                              227.08

                 Historic Wetland Loss
                         Large portions of the pilot area's historic wetlands disappeared in the ce4ury prior to
                 environmentally-based regulation (pre-1970's). Although the total loss has not been quantified,
                 some examples illustrate the magnitude. Is Table 5-1 shows over 114 acres (3 3%) lost at Salinas

                 PAGE 80                         CALIFORNIA COASTAL COMMISSION
<pb n="82" />

                                                                                                                            CHAPTER 5 - WETLANDS

                            River Lagoon.     16  Neary Lagoon's size diminished 60% from 75 to 30 acres.                    17  Wilder Lagoon
                            shrunk by almost 70% from 49 to 15 acres as Figure 5-5 shows.                    18  In all cases, human activities,
                            especially diking, draining and filling for agriculture, were largely responsible.                   19

                               Figure 5-5: Wetland delineation of Wilder Pilot Area based on present vegetation, soil, and standing water; and
                                                                           likely historical wettand area

                                             WUL4ND
                                             PKESWT
                                             WISTIAND

                                                                   vim
                                           L                     TERRACUE
                                          P-P.Tmv"
                                          0 -so too                                                                           EAST
                                              mcrm                                           PACIFIC OCEM                  TEMACE

                            Fxggmentation
                                      This historic loss of wetland acreage also resulted in the fragmentation of wetlands.                      20
                            Fragmentation refers to the severing of physical and ecological linkages between wetlands.
                            Fragmentation affects wetlands adversely by reducing water circulation and limiting the
                            migration of individuals among previously continuous populations of plants and animals. Small,
                            isolated populations are much more susceptible to natural and human-induced stresses and have
                            more difficulty recovering from such stresses than large, contiguous populations. Fragmentation
                            may, therefore, be closely linked with declines in biodiversity. Within the ReCAP region, this is
                            seen most prominently in southern Santa Cruz and northern Monterey Counties. For example,
                            within the coastal zone north of the Salinas River and south of Moss Landing, some wetland
                            areas disappeared altogether,        21 while the two remaining wetlands (Old Salinas River Channel
                            and Tembladero Slough) were reduced to drainage channels.                    22  The historic connection between
                            the Salinas River and the Pajaro River north of Moss Landing was lost. The alteration of Upper
                            Watsonville Slough (which connected to the Pajaro River mouth via lower Watsonville Slough)
                            resulted in the severing of historic connections with Harkins, Hanson, Gallighan, and West
                            Branch Struve Sloughs.        23

                                      Just outside the coastal zone of Monterey Bay a significant example of wetland
                            fragmentation occurred over time along the northern corridor of the Salinas River. A chain of
                            nine lakes spaced over a distance of approximately ten miles has mostly disappeared, due to
                            agricultural activities; only one lake remains.          24

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                 Habitat Changg
                         The physical character of some of the remaining wetlands has also changed over time.
                 For example, Schwann Lagoon was transformed from a coastal lagoon into a freshwater lake
                 when its connection with the sea was obstructed by road construction. Open water habitat areas
                 in Bonita Lagoon, Carmel River Lagoon, and Salinas River Lagoon have gradually filled in and
                 become vegetated (see Table 5-1 for one example). Conversely, harbor construction has turned
                 portions of the vegetated marsh habitats in Arana Gulch (Woods Lagoon) and the Old Salinas
                 River Channel into open deepwater habitats. The construction of Moss Landing Harbor has been
                 linked to excessive channel erosion, resulting in the loss of intertidal marsh habitat in Elkhorn
                         25
                 Slough  .

                         Not all habitat changes are bad. Sometimes such changes are done intentionally as part
                 of wetland restoration efforts. However, most of the unplanned habitat changes (i.e., those that
                 occurred as unintentional consequences of other activities) are likely to result in negative
                 impacts. (For additional details and examples, see endnote #14.)

                 R6guNtor.
                                'S
                         Continued development pressures coupled with gaps in the regulatory process suggest
                 that further wetland losses, fragmentation, and adverse habitat changes are possible.

                         The vast changes to wetlands occurred in an era when environmental regulation was
                 absent and economic development of wetlands was more highly valued than their natural state.
                 This changed in the early 1970's with the advent of the California Coastal Act, the California
                 Environment Qualit:y Act (CEQA) and its federal counterpart the National Environmental Policy
                 Act (NEPN, and with the consideration of environmental factors in implementing the Clean
                 Water Act. Coastal-Act Section 30233c, for example, prohibits most development in wetlands,
                 except those of a resource-dependent nature that lack less environmentally damaging feasible
                 alternatives, and for which adequate mitigation exists. 27

                         As a result of protective legislation, few permits issued in the study area since 1973 have
                 allowed wetland fill; those that have by-and-large required at least equivalent compensation (i.e.,
                 required an equal or greater acreage of wetland to be restored or created from dry land
                 elsewhere). 28 The Coastal Act's authority has allowed Commission staff to participate in
                 discussions about potential projects before permit applications are submitted and thereby
                 encourage alternatives to wetland fills. In the few instances where applicants persisted with
                 insupportable fill projects, the Commission has denied the request. Such instances include urban
                 development in Jessie Street marsh, wastewater plant expansion into Neary Lagoon, and road fill
                 in Elkhorn Slough. 29

                         In spite of existing regulations, some direct loss of wetland area has occurred over the
                 last twenty years at Moro Cojo Slough, Elkhorn Slough, McCluskey Slough, and Watsonville
                                                                                                  .30
                 Slough, due to agriculture activities, and at Spanish Bay due to urban activities.   At least
                 temporary losses have occurred at Neary Lagoon, Majors Creek, and Lower Watsonville Slough,
                 where after-the-fact enforcement actions have been initiated to remediate unpermitted fills.  31

                         That these instances have occurred, along with other factors, suggest that additional
                 activitiesresulting in wetland loss will be attempted in the future. These other factors include
                                          32                              33
                 known pending projects, some unauthorized activities, potentially allowable wetland uses,
                 disputes about what is really a wetland, no guarantees of mitigation success, and private and
                 public ownership of wetlands not in preserve status. In addition, gaps in the CCMP regulatory
                 process can allow incursions into wetlands to occur. 34 These gaps include agricultural
                 exemptions, inconsistent enforcement and condition compliance, inconsistent wetland
                 delineation methods, and permitted uses without guaranteed compensatory mechanisms.

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                  Agricultural Exemi2tions
                         The list of allowable wetland uses in Coastal Act Section 30233a does not include
                  agriculture. Most LCPs place wetlands under a resource protection category and do not
                  explicitly show agriculture as a permitted use. However, not all agricultural activities qualify as
                  new "development," and therefore do not require a coastal permit. According to the
                  Commission's Statewide Interpretive Guidelines (1981),

                         When wetlands are seasonallyfarmed, the continued use of agriculture is
                         allowed ExpandingJarming operations into non-farmed wetlands by diking or
                         otherwise altering thefunctional capacity q
                                                             f the wetland is notpermitted Farm-
                         related structures (including barns, sheds, andfarm-owner occupied housing)
                         necessaryfor the continuance of the existing operation of thefarmed wetlands
                         may be located on an existingfarmed wetlandparcel, only if no alternative
                         upland location is available for such purpose and the structures are sited and
                         designed to minimize the adverse environmental effects on thefarmed wetland
                         Clustering will be required 35

                         The Coastal Commission has considered that expanding cultivation or grazing into a
                  wetland that has not been recently farmed, even if no diking or grading is involved, is
                  "development". However, others might not share that interpretation based on Section 30106 of
                  the Coastal ACt,36 which states in part:

                         Development means, on land, in or under water, the placement or erection of
                         any solid material or structure; discharge or disposal of any dredged material
                         or any gaseous, liquid, solid, or thermal waste; grading, removing, dredging,
                         mining, or extraction of any materials; change in the density or intensity of use
                         of land, and the removal or harvesting of major vegetation other than for
                         agriculturalpurposes..

                         The North Monterey County Land Use Plan is the only plan in the ReCAP region that
                  has a broadened definition of development that includes some agricultural removal or harvesting
                  of ma.or vegetation, but not specifically wetland vegetation. 37
                      J

                         The result of these regulatory limitations has been the continued cultivation of historic
                  wetlands (especially in the Watsonville Slough complex), a few new (or reactivated) cultivated
                  wetland areas, and expanded grazing in wetlands. 38 The vegetation removal exception may also
                  have been interpreted by agricultural land owners to mean that diking, draining, and filling are
                  allowed without a permit if the purpose of such activities is to allow the continuation of on-going
                  agricultural activities (for example, diking to prevent a wetland from reclaiming part of a
                  cultivated field at the end of a drought).

                  Condition Non-Com-pliance and Impediments to F4forcemen
                         Chapter 9 of the Coastal Act provides for judicial review, enforcement, and penalties for
                  violations. Most local coastal programs echo such provisions, and contain procedures for
                  addressing violations on a local level. 39 Staffing limitations have required reliance on discovery
                  by others and have resulted in highly variable follow-up. Lack of consistent reporting and
                  computerized record keeping has further hindered compliance monitoring efforts. Even when
                  enforcement commences, guaranteeing successful mitigation is problematic (see section on
                  mitigation problems below).

                         The resulting unrectified incursions, discovered through ReCAP's aerial photography
                  interpretation, include, for example, several acres of Moro Cojo Slough that have been diked and
                  cultivated since 1977, and small areas at the margins of McCluskey Slough and Elkhorn
                  Slough. 40 In cases where discovery has already led to enforcement actions being initiated,

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                restoration has not always been achieved. For example, out of 14 required restoration plans, only
                eight have been formulated and six completed. 41 Unpermitted activities in wetlands represent
                net wetland acreage losses until restoration is completed.

                        In cases where wetland alterations are conditionally permitted, similar staffing and
                tracking limitations constrain the Commission's ability to assure condition compliance (e.g.
                successful mitigation). Without adequate staffing to conduct field inspections, it is often not
                known whether permitted losses are successfidly mitigated. Unfortunately, limitations in the
                Commission's tracking and post-construction inspection system mean that there is a lack of
                sufficient evidence available to evaluate this concern. 42

                Inconsistent Delineation Methods
                        Coastal Act Section 30121 simply defines "wetlands" as "lands ... which may be covered
                periodically or permanently with shallow water and include saltwater marshes, freshwater   -
                marshes, open or closed brackish water marshes, swamps, mudflats and fens." According to the
                Coastal Commission's Interpretive Guidelines, the U.S. Fish and Wildlife Service's
                                                                                       43
                classification system (1979), commonly known as the Cowardin method    ,  is to serve as the
                guide for identifying wetlands. Local coastal programs contain the Coastal Act definition.
                However, only two out of ten LCPs in the ReCAP region reference the Cowardin method (or for
                that matter any particular delineation method). 44 Various other less encompassing methods have
                been and are performed for local and state agencies (typically through the CEQA process). 45
                Recent wetland delineations are based on the U.S. Army Corps of Engineers' methodology for
                implementing the Clean Water Act, which itself has undergone changes in the past ten years. 46
                Earlier EIRs and other documents often termed what would be "wetlands" under the Cowardin
                (and possibly the Corps) method as "drainage channels" or "riparian areas." Even the Coastal
                Commission's guidelines distftiish riparian areas as distinct from wetlands, a distinction not
                made by the Cowardin method. Furthermore, Coastal Commission Interpretive Guidelines @
                remain advisory. In fact; the Commission has substantial latitude to determine whether an area
                falls under the Coastal Act definition of "wetland".

                       The result of wetland delineation uncertainties has allowed some fills to escape Coastal
                Act Section 30233's requirements. For example, prior to development at Spanish Bay, which
                had previously been mined, drainage channels and ponds existed that would likely be classified
                as wetlands under the Cowardin method. However, EIRs and Coastal Commission findings
                described these features variously, and the Commission ultimately did not classify them as
                         48
                wetlands.   Commission staff explained that this was because they Were unnatural, the results of
                water ponding in mined areas.   It appears that there was a net (permitted, but unstated) loss of
                                                                           50
                approximately eight of these variously labeled wetland acres.

                       Two other examples involved eight acres of "seasonally flooded grassland" at Neary
                Lagoon and about one-half acre of "man made degraded riparian channel" at Schwann Lagoon.
                Both were ultimately determined not to be "wetlands" by the Commission.  51 In these cases,
                project proponents (both public agencies: a city and a school district) offered biological opinions
                against the areas being "wetlands," while concerned citizens countered with pro-wetland
                biological determinations. Projects filling these areas were approved, without compensating
                mitigation in the case of Neary Lagoon.

                Permitted Uses Without Guaranteed CoMpensatoCE Mitigation
                       Despite requiring compensatory mitigation for identified wetlands, the Coastal Act does
                not guarantee no net loss, especially of habitat value, because compensatory mitigation success is
                problematic at best. 52 Examples of the few restoration projects in the pilot area with monitoring
                tend to support this conclusion. Of two projects funded by and retrospectively analyzed by the
                Coastal Conservancy, one was a failure.53 Also, the submitted reports for the Spanish Bay

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                      mitigation site, which has been monitored for five years, indicate general success of restoration.
                      However, planted willows have not all survived, sediment has filled an area that now must be
                                                                       54
                      redredged, and unauthorized work has occurred.      At a mitigation site on the Old Salinas River
                      channel, monitoring reports indicate that the plant communities are developing in a manner     55
                      similar to that anticipated, with some non-native colonization and various revegetation rates.
                      Independent evaluation offers a more neptive perspective, calling the project a mistake for
                      removing an historic pickleweed marsh.

                              A review of these and other monitoring reports shows continued oversight is necessary
                      to discover problems and recommend corrections. Where staff training or availability is limited,
                      mitigation success will be less assured. This review also suggests that although net wetland
                      acreage may remain constant or increase if compensatory mitigation is successful, habitat
                      differences may result and habitat value may be consequently reduced (see Endnote # 14).

                              Thus, the more development permitted in wetlands, the greater the probability of some
                      continued loss. Consequently, the more leeway in allowing development, the greater the
                      probability of its occurrence. Out of 28 permitted projects involving wetland fill, four were for
                      explicitly permitted uses under Section 30233a (boating and resource restoration) and seven -
                      were associated with urban development (which is not listed as a permitted use). The remainder
                      were for public projects (flood control, roads, wastewater facilities) which in some cases may be
                      considered incidental public services under 30233a.  57 Thus, there is a fair amount of discretion
                      built into implementing this section. Local coastal programs have narrowed this discretion,
                      generally limiting allowed development to resource-dependent uses.    58 Seven of these projects
                      were permitted by local governments.

                              To the extent that riparian areas are not defined as "wetlands" for regulatory purposes
                      (see delineation discussion), there is a higher risk of loss of this type of wetland. Although
                      Section 30240 of the Coastal Act treating riparian areas as "environmentally sensitive habitats"
                      could apply to such areas, the wetland mitigation standards in Section 30607.1 do not.59    Thus
                      riparian wetland areas may be especially at risk of being developed without adequate mitigation.

                      Emerging and Potential Responses:
                              Initiatives to standardize delineation methods, achieve "no net loss" and guide
                      restoration could help reduce future wetland loss. Tightening exemptions that allow wetland fill
                      and increasing enforcement and education would provide additional help. Programs extending
                      beyond regulation are also needed to restore and enhance historic wetlands.

                      Delineation
                              The Coastal Commission's recently published "Procedural Guidance for the Review of
                      Wetland Projects in California's Coastal Zone" reiterates the Coastal Act's broad wetland
                      definition, suggests the importance of riparian area protection, and emphasizes early
                      involvement in the CEQA process.    60 Comments on CEQA documents could request that
                      appropriate wetland delineations are made early on in the project review process. Incorporating
                      these concepts into the local governments' local coastal program implementation would be a
                      logical follow up.

                              Federal agencies have standardized wetland delineation methods for regulato purposes,
                      and California's Resources Agency is attempting to develop a single state definition.  67 Such
                      standardization, followed up with a manual and training course, has the potential to ensure more
                      consistent and complete delineations. However, if the standardized methodology does not
                      account for all wetlands protected under the Coastal Act, as previous attempts did not, then the
                      CCMP will not benefit from this course of action.

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                No Net Loss
                        Both Governor Wilson and President Clinton have issued wetland policies that include
                the goal of "No Net Loss" of wetland quantity or quality. 62, The California Department of Fish
                and Game also operates under "No Net Loss" directives, applying to habitat values as well as
                acreage. 63 Codifying the no-net loss principle at all levels of government and establishing
                guidelines for implementation is a logical next step.

                Aft=ion Guidance
                        The Coastal Commission's Procedural Guidancefor the Review of Wetland Projects       64
                offers criteria aimed at increasing the success rate of compensatory wetland mitigation efforts.
                Its forthcoming Procedural Guidancefor Evaluation of Wetland Mitigation Projects is expected
                to provide more detailed information. Incorporating the results of these in both the
                Commission's and local government's practices may improve wetland management.

                RegulatojX &amp;form
                        Possible changes to the Coastal Act and local coastal programs to further restrict allowed
                wetland uses would reduce the number of potential projects that could cause wetland loss. Such
                changes could include tightening agricultural exemptions, more explicitly defining and
                interpreting the categories of permitted uses (e.g., "incidental public services" and "restoration
                activities"), possibly eliminating some categories of permitted uses, strengthening the criteria for
                restricting permitted uses, and/or limiting the kinds of wetlands where the uses are allowed.
                Such initiatives wou.1d have to be undertaken in a manner consistent with Coastal Act
                requirements concerning constitutionally protected rights of property owners. 65 Recent-court
                cases suggest the advisability of examining non-regulatory as well as regulatory innovations to
                protect remaining weilands and/or strengthen compensating mitigation requirements.  66 Further
                impetus comes from the delineation of more areas now as wetlands (usually during the
                development review process) that do not "look like" wetlands, but have the requisite
                characteristics. 67

                Wetland Restoration and Creation Pro=ams
                        Certainly additional regulation will not result in the reappearance of lost wetlands. The
                Coastal Act supports restoration where feasible. Similarly, the LCPs all mention objectives to
                restore and increase wetland acreage. In 1983, the Legislature called for an increase by 50% of
                                                         68
                wetland habitat acreage by the year 2000.   Moreover, Governor Wilson's new wetland policy
                calls for a long-term net gain in the quantity and quality of wetland acreage, as does President
                Clinton's. 69

                        One "new" wetland was created just prior to the establishment of the Coastal Act. As
                part of a major condominium project, the 3.8 acre Shorebirds Lagoon was constructed north of
                Pajaro River in an area that earlier was salt marsh. 70 Since establishment of the Coastal Act,
                major restoration projects have occurred only at Elkhorn Slough and adjacent Parsons Slough.
                One hundred seventy-five acres of grazing land has been converted back to wetlands .71 These
                projects occurred on property owned by the Department of Fish and Game and were publicly
                funded. 72

                        At the beginning of 1994, there were commitments to undertake the following projects:

                                                                                                           73
                    * Wilder Creek marsh, convert 19 acres of agricultural land back to freshwater marsh  ,
                    * Blohm-Porter marsh portion of Elkhorn Slough, convert approximately 27 acres of
                        upland and pasture back to freshwater marsh with islandsY_

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                              Hansons Slough, convert approximately 20 acres of agricultural and grazing land back to
                              vegetated wetland. 75
                              This latter project is being undertaken by a non-profit group affiliated with Moss
                     Landing Marine Laboratories (Watershed Ecology Outreach Program). VVEOP's strategy is to
                     first obtain landowner permission and then to remove agricultural uses and plant with wetland
                     vegetation on as much historic wetland area as possible in southern Santa Cruz and northern
                     Monterey Counties.

                     Wetland @ Management Planning
                              Continuing to follow and improve the implementation of existing regulations should
                     help ensure that additional wetland loss does not occur. Even more assurance can be gained by
                     undertaking a more specific planning process focusing on individual wetlands and their
                     watersheds. A plan for a single or group of wetlands can include an actual wetland delineation,
                     identify specific permitted (from among the eight Coastal Act categories) and non-permitted
                     uses, and recommend changes in any existing detrimental uses or trends (e.g., mechanisms to
                     remove adverse grazing from wetlands). If a plan includes clear objectives, then it will be easier
                     to determine what the least environmentally damaging project alternative would be. A plan can
                     compare ownerships and management authorities to the proposed uses and management
                     strategies and recommend necessary changes (e.g., public acquisitions of privately owned
                     parcels in wetlands).

                              Wetland management plans could also improve the chances for successful restoration,
                     both for mitigation and redressing historic loss. Such plans could establish objectives for
                     restoration (e.g., optimal mix of habitat types) and identify locations in need of restoration.

                              Complementary broader-based watershed, natural communities, or regional plans could
                     further guide wetland restoration efforts. Using a landscape-based approach, these plans can
                     identify areas that were historically wetlands and are most appropriate to restore as wetlands;
                     such plans can also identify opportunities to reduce fragmentation. The last section of this
                     chapter discusses the status of and opportunities for these types of broader based planning
                     initiatives.

                     Program Improvements:
                         *    Develop wetland mitigation performance guidance document that includes procedures
                              and measures to assure policy objectives are met (i.e., adequate mitigation ratio,
                              appropriate mitigation plans, criteria for evaluating success) and incorporate into CCMP.

                         *    Revise definition of "development" in Coastal Act Section 30106 (or revised Interpretive
                              Guideline or Attorney General opinion) and LCPs to include removal of natural
                              vegetation in a wetland or wetland buffer for agricultural purposes, where the area has
                              not been recently farmed.

                         *    Revise local coastal programs to:

                                  incorporate the Cowardin wetland identification method in their application
                                  submittal requirements and initial studies under CEQA.

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                             require identification of possible wetland areas in addition to those previously
                             inventoried, where such procedures are currently lacking (i.e. Pacific Grove, Marina,
                             Seaside, Monterey City, Cannel-by-the-Sea).

                 I'filbatind': Midrrange 0: pp6JtU'rflfies*.:.:::

                 With rg@pect to -preventing-further wetland losses:
                      *  Review how riparian corridors are classified in various documents (e.g., Coastal Act,
                         Interpretive Guidelines, guidance document, LCPs) and recommend revisions to achieve
                         consistency in the CCMP program.

                      *  Utilize the CEQA/NEPA review processes to ensure that wetland delineations using the
                         Cowardin method are completed.

                      *  Participate in and encourage discussions on standardizing wetland definitions and
                         delineation methods.

                      *  In conjunction with enforcement staff of other state, federal, and local agencies involved
                         in wetland regulations, identify opportunities for better coordination and implementation
                         of regulatory programs.

                      *  Evaluate options for using the existing regulatory and non-regulatory incentive programs
                         to prevent additional agricultural and grazing incursions into the wetlands, including
                         revisions to ihe Coastal Act definition of development.
                      *  Evaluate staffing, support, and other options for improving implementation of CCMP's.
                         enforcement program with regard to adverse wetland impacts and recommend
                         improvements.

                      *  Continue involvement in early discussions and review of projects potentially affecting
                         wetlands.

                      *  Review recent aerial photographs to identify additional wetland losses and make
                         recommendations for on-going monitoring of wetland acreage change.
                      *  Evaluate options for protecting lands newly identified as wetlands in site planning (using
                         Terrace Point and former Rolling Hills sites as possible case studies) and recommend an
                         appropriate strategy.
                      *  In reviewing any mitigation or restoration projects, require a clear statement of goals,
                         objectives, and performance standards, including appropriate time frames.
                      *  Work with Moss Landing Harbor District and other interested entities in deriving an
                         alternative mitigation and monitoring strategy for its problematic mitigation project;
                         advocate preparation of a wetland management plan delineating optimal habitat types for
                         the Old Salinas River channel.

                      *  Allocate staff time for more consistent review of wetland monitoring plans.
                      *  Inventory parcels where habitat constraints may raise significant land use issues; work
                         with landowners to develop appropriate responses.
                      *  Continue to explore mitigation banking, as detailed in the final recommendations of the
                         wetlands task force, and other strategies for ensuring successful wetland mitigation.

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                     With respect to reversing historic wetland losses:
                         0   Foster the public's and agencies' awareness to appreciate the importance of increasing
                             wetland acreage above current levels.

                         0   Initiate and participate in a comprehensive study to determine the feasibility of restoring
                             historic wetlands in a study area (e.g., Watsonville Slough complex watershed) in
                             cooperation with academics, AMBAG, and other agencies.

                         0   Continue to participate in the Moro Cojo Slough Wetland Management Plan process and
                             use that plan as a vehicle to develop methods for reversing the adverse impacts from
                             agriculture and grazing.

                         0   In reviewing major development proposals or LCP amendments covering large areas
                             adjacent to wetlands, identify areas of historic wetland loss and describe the potential
                             preclusion for future restoration.

                     Wetland and Watershed Management Plans should:
                             Include provisions for wetland restoration where feasible;

                             Provide context and guidance for ftiture wetland restoration projects, including clear
                             goals and objectives;

                             Delineate and describe different habitat types;

                             List allowed uses in wetlands and criteria for allowing them, using the Coastal Act as a
                             basis,"

                             Address methods to discontinue agricultural, grazing, and other non-resource dependent
                             uses in wetlands.

                     Longer-range Opportunities:

                     With respect to preventing further wedand losses:
                             Evaluate any future federal unified delineation manual for application to California's
                             coastal wetlands and strive to achieve consistency among agencies' practices.

                             Develop objective, useable measures to ensure no net loss of wetland quality.

                             Designate an agency to assume responsibility for monitoring for no net loss through
                             annual review of aerial photography and selected field investigations.

                             Study options for possibly revising wetland policies to allow consolidation and
                             enhancement of scattered, small wetland areas as part of development projects.

                         *   To the extent riparian areas are considered to be in a separate, non-wetland
                             classification, evaluate options for revising riparian protection policies to ensure
                             commensurate protection.

                         *   Acquire wetlands (or development and use rights) in agricultural use as public lands
                             using federal or state programs, pursuant to the priorities established in the
                             comprehensive wetland planning program recommended in the final section of this
                             chapter.

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          With r"12ect to reversing historic wetland loss:
             * Undertake wetland restoration pursuant to watershed and wetland management plans and
               according to regionally-established priorities.

             * Develop a comprehensive strategy for redressing historic wetland loss through the
               recommended comprehensive regional wetland planning framework.

                             Y:.
                     I hor   d
          ,.pport rflUes4or
             * Use aerial photography, historic maps, and other sources to determine the extent of
               wetland change over the last century.

             * Identify land and/or water corridor requirements of target species that use wetlands and
               study reestablishing such natural connections.

             * Study habitat use and species abundance in areas with pocket wetland remnants
               compared to single larger wetlands to determine the advisability of consolidations.
             * Evaluate current uses and land values of historic wetlands and project costs of increasing
               wetland acreage.

             * Use field inspection and interviews to determine success of area's wetland restoration
               projects that have not yet been evaluated (e.g., at Elkhorn Slough's North and South
               restoration areas).

             * Review costs of mitigation projects relative to their resulting improvements to determine
               most cost-effective strategies.
             * Evaluate permit condition compliance in and adjacent to wetlands, both in the short and
               long term (i.e., determine if the conditions, even when initially complied with, remained
               effective over time).
             * Perform field delineations and physically describe the following possible wetlands:
               Indian Head, Fort Ord Pond, Pacific Grove Municipal Pond, DeAnza Pond.
             * Perform and compare delineations of some wetlands using the 1987 U.S. Army Corps of
               Engineers manual, the Cowardin method, and possibly other methods to determine any
               differences in coverage.
             * Perform field delineations on exemplary riparian corridors to identify "wetland"
               portions.

             WETLANDS PROBLEM TWO

               Undeveloped upland areas adjacent to wetlands, which buffer the wetland from human
         development and activities, have diminished over time and will continue to do so, absent
         improvements in the regulatory process. This has led to the chronic loss of transitional habitat
         immediately adjacent to wetlands and a hardening of wetland edges.

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                                                                             ---- - ----- - -               .. .... .
                                                                                           7%,
                                                                                                                         . . . ...... .....
                       ANALY9i6,:,-`     . . ...... . ..
                                The upland area adjacent to wetlands is an important habitat for many wetland species.
                       These areas function as transition zones between wetlands and uplands and often exhibit
                       characteristics of both habitats. In situations where development occurs on parcels with land
                       adjacent to wetlands, some portion of the transition zone (usually closest to the wetland) may be
                       left undeveloped and designated a buffer area. As a complement or alternative, restrictions on
                       various activities or uses (e.g., lighting, pets, non-native landscaping) may also be placed on
                       lands bordering wetlands. These areas act to protect the wetland from the direct effects of nearby
                       disturbance (both acute and chronic), and provide necessary habitat for organisms that spend
                       only a portion of their life in the wetland, such as amphibians, reptiles, birds, and mammals.

                                Buffer areas are incorporated into a significant number of coastal development permits;
                       however, the conditions requiring the establishment and use restrictions of buffer areas are not
                       consistent, and in some cases the resulting buffer area is ineffective due to the small size or non-
                       permanent protection (e.g., no easement or deed restriction). A review of the ReCAP database
                       shows 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. Of
                       course, buffers are not required for activities, such as on-going agriculture, that are exempt from
                       or predate the permit process. Although it is known that buffers can reduce the adverse affects
                       adjacent develo
                                       7Rment has on a wetland, scientific studies to determine the appropriate size of a
                       buffer are rare.   In addition, no investigations have been completed to determine how variations
                       in buffer width have affected wetland resources. Nevertheless, there is a definite need to require
                       buffers, and current standards should be refined as the requisite studies are completed.

                                Development projects that occur near wetlands often affect the wetland edge as well.
                       Site visits by Coastal Commission staff offered the most revealing information regarding the
                       condition of wetland edges and adjacent transition zones. Staff inspected 20 (20%) of the 99
                       wetlands identifiod in the project area. Adverse impacts to the wetland edge and/or transition
                       zone were noted at fourteen of the wetlands inspected (Table 5-2, page 94). A time series view
                       of Neary Lagoon (Figure 5-6, page 92)77     provides a clear example of how urban development
                       has obliterated the transitional zone and hardened the edges of this wetland, a scenario common
                       to many wetlands surrounded by urban development. Although many of the documented
                       changes pre-date the Coastal Act, the impacts from these changes continue to the present. For
                       example, agricultural development adjacent to wetlands often includes a cultivation area
                       extending up to the wetland edge. During drought years, the wetland will recede as water inputs
                       are reduced. The cultivation area is then extended into the "now dry" wetland area. 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. Ultimately, the
                       loss of transition zone habitat results in the severing of important 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 the quality of wetlands in the project area.

                                The requirement for buffer zones around wetlands is a contentious issue. The Coastal
                       Act does not contain specific requirements for buffer zones, just general policy language for
                       compatible, non-impacting adjacent development (Section 30240b), so landowners may consider
                       all adjacent upland areas available for development. Although the Coastal Commission's
                       Statewide Interpretive Guidelines (198 1) suggest a minimum 100 foot buffer zone around
                       wetlands, in practice wetland buffer widths are determined on a case-by-case basis with widely
                       disparate results. 78 A review of the certified local coastal programs (LCPs) and land use plans

                                                          CALIFORNIA COASTAL COMMISSION                                 PAGE 91
<pb n="93" />

                                                              Time Series of Developmental Changes
                                                     NEARY LAGOON, City of Santa Cruz (1853-1994)
                                                                                         Panels 1-4 of 8

                                                                                  1,653

                                                                               Pristine   lagoon.
                                                                                                                                                                    r
                                                                                                                                                                    f
                                                                                                                                                                    t

                                                                                                                                                                    t

                                                                                                                    V-
 I&gt;

                                 7
 Z                                                                                                                                                      ..............
 &gt;
                                                                                                                                                           ...........
 0

 A

 Z                                                                                 1909-1928

                                                                               Construction of
 0                                                                             city's sewer pumping
 Z                                                                             station (1909).                                                                      t

                                                      Y@
                                                                               Construction of

                                                                                                                        .................
                                                                                                                           ...........
                                                                               new sewage
                                                                                                                        ............
                                                                                                                         .. ........
                                                                               treatment plant                           .. .......
                                                                               (1928).
                                                                                                                     ;m

                                                                               Large scale
                                                                               urbanization of
                                                                               agricultural   lands.

                                   F1          FIKI                                                                El     FIFIED

                            Cultivation                  Marsh                       Riparian                  Open Water                    Development

                 colito nia Coosta/ Commission
                 fechnrical Services Division                               Sources; See andnote #77. For illustrative purposes only.
<pb n="94" />

                                                                       Time Series of Developmental Changes
                                                            NEARY LAGOON, City of Santa Cruz (1853-1994)
                                                                                                    Panels 5-8 of 8
                                  ej 0                                                      1975-1978                             ej
                            _j                                                           Construction of
                                                                                         park with tennis
                                                                                         courts, lawns,
                                     .................                                   boardwalks, and
                                                                                         paths.      Lagoon                                                                               r
                                                                                                                                          ..........
                                                                                         dredged; islands
                                                                                                                                                 j
                                                                                              ated
                                                                                         cre
                                                                                         (1975-1978).

                                                                                         Expansion of
                                                                                         wastewater
 0
 &gt;                                                                                       treatment        plant
                                                                            .... ........
                                                                                                                                                                                .........
                                                                               ....                                                                                        .. .........
 ,n                                                                                           76).
                                                                                         (19
 0
                                                                                                                                                                               ..........
                                  F r] F-I F-I F-I                                                                                FIFIFIFIEDE-Y-1                        . ........
 Z

 0
 0

 Cn
                                  ej  0                                                                                           ej e;
 r-                                 &amp;L                                                                                                                                                r1a
 0
 0
                                                                                         Construction of                                                                                  E
                                                                                         senior commons                                                                                   V
                                                                                         housing and                                                                                      t
 0
 Z                                                                                       affordable                                                                                       d
                                                                                         housing units.
                                                                                                                                      @v::

                                                                                                                                                                             .... .......

                                                                             ..........
                                                                                                                                      00FIFIF-I

 M

                                                Marsh                            Riparian                      Open Water                       Development

                   Callfornia Coastal Commission
                   Technical Services Division                        Sources:     See endnote #77.       For illustrative purposes only.
<pb n="95" />

                        RECAP PILOT PROJECT

                                                   Table 5-2: Adverse Impacts to Wetland Edges and Transition Zones

                                                                                       W               gea                        Ttahsition@@Zone.

                                                                                                          ...........
                                                                     . ..........                .......
                        Neary Lagoon                                 Construction of recreational               Construction of recreational
                                                                     facilities, housing, roads, and            facilities, housing, roads, and
                                                                     sewage treatment facilities                sewage treatment facilities;
                                                                                                                unauthorized camping
                        Schwann Lagoon                               Rip-rap in main channel,       roads       Housing development, urban
                                                                                                                landscaping
                        Hanson Slough                                                                           Agricultural cultivation
                        Upper Watsonville Slough                     Agricultural cultivation,                  Agricultural cultivation
                                                                     industrial development
                        W. Branch Struve Slough                      Agricultural cultivation                   Agricultural cultivation
                        McCluskey Slough                             Agricultural cultivation                   Agricultural cultivation
                        Elkhorn Slough                               ----                                       Agricultural cultivation
                        Moro Cojo, Slough                            Agricultural cultivation                   Agricultural cultivation, housing
                                                                                                                development
                        Castroville Slough (portion of               Agricultural cultivation, housing          Agricultural cultivation, housing
                        Moro Cojo Slough)                            development                                development
                        Tembladero Slough                            Agricultural culti@a_tion                  Agricultural cultivation
                        Salinas River Lagoon                         Building rubble deposited along            Agricultural cultivation
                                                                 A   the north edge of lagoon                  f
                        Marina Vernal Ponds 1,3,&amp;4                   ---                                        Housing development, road
                                                                                                               Iconstruction

                        (LUPs) covering areas with wetlands shows buffer area provisions vary among local jurisdictions
                        (Table 5-3). The point from which the buffer is measured also varies." These inconsistencies in
                        LCP/LUP buffer area provisions no doubt compound the problem of inconsistent application.
                        Furthermore, most LCPs allow exceptions to the stated criteria, if accompanied by some
                        biological evaluation that a lesser buffer will suffice.

                                 The scientific information necessary to determine the proper size of a buffer area in
                        California is lacking, so it is not known if any of the LCPALUP buffer provisions are truly
                        adequate. This problem also carries over to questions regarding the structure a buffer area

                                                   Table 5-3: LCPIL UP Provisions Relating to Wetland Buffer Areas

                                      ..........
                                    ............... ...  ......
                                       ..........
                                                                                    r
                        Santa Cruz County                   100 Feet                                   High water mark
                        Santa Cruz City                     100 Feet                                   Wetland
                        Capitola                            25-35 Feet                                 Lagoon shoreline/outer edge of riparian
                                                                                                       vegetation or bank
                        Watsonville                         50 or 100 Feet                             not stated
                        Monterey County
                         North County                       100 Feet                                   Edge of wetland vegetation
                         Del Monte Forest                   100 Feet                                   Edge of wetland
                         Carmel Area                        100 Feet                                   Edge of wetland per USFWS definition
                        Marina                              100 Feet                                   Edge of wetland
                        Seaside                             20 or 50 feet                              Edge of wetland vegetation
                        Pacific Grove                       None                                       Not applicable

                        PAGE94                                    CALIFORNIA COASTAL COMMISSION
<pb n="96" />

                                                                                                    CHAPTER 5 - WETLANDS

                      should provide. Leaving buffer areas in a natural state has obvious advantages, but may not
                      provide proper protection to the wetland from adjacent development. For example, one common
                      objective of buffer areas is to prevent domesticated animals from entering a wetland. Often the
                      most straightforward solution is to erect a fence in the buffer area; however, this would restrict
                      wildlife movement between the wetland and adjacent uplands. Clearly, our lack of information
                      regarding the functions of buffers compounds the policy and procedural problems associated
                      with securing buffer areas as a condition of development.

                               Regulated (e.g., urban) and unregulated (e.g., agricultural) development are both
                      continuing sources of impacts to transitional zones and wetland edges. Although land use
                      analyses suggest full buildout has nearly been reached in several portions of the project area,
                      population levels are projected to increase. Thus, development pressure will continue. Likely
                      areas for urban development include south Santa Cruz County and North Monterey County.
                      Both areas contain substantial wetland resources including three large slough complexes:
                      Watsonville Slough, Elkhorn Slough, and Moro Cojo Slough. Strong agricultural interests will
                      remain in the project area well into the future. Cultivation practices may begin to change in the
                      near term as a result of concerns over nonpoint source pollution; however, practices affecting
                      buffer areas and wetland edges will probably not change substantially unless specific regulations
                      are implemented.  80

                               Based on these analyses, there is little doubt that transition zones and wetland edges will
                      continue to be adversely affected in the future unless changes in management strategies are
                      made. The chronic loss of these areas will adversely affect the quality of wetland habitat
                      eventually leading to a loss in biodiversity and overall degradation of the resource. This is the
                      situation in inuch of Southern California where the majority of wetlands exist in a degraded state
                      and increasing wetland biodiversity is a primary objective of wetland conservation and
                      restoration projects.

                               Continuing to follow and improve wetland setback regulations will help ensure that
                      development near wetlands does not adversely impact the resource. Even greater assurance of
                      protection is possible by undertaking a more specific planning process focusing on individual
                      wetlands and their watersheds. A plan for an individual wetland can include an actual wetland
                      delineation, allowing setback requirements relative to an accepted reference point. An inventory
                      of, analysis of, and resultant plan for a wetland can result in a recommended buffer zone tailored
                      to the attributes of that wetland (i.e., its species' needs and its habitat types). A plan can
                      establish one or more optimal buffer zones along the wetland's entire perimeter depending on the
                      type of adjacent development. It can include recommendations to manage the buffer zone and
                      enhance it where degraded or where incompatible uses have encroached. The final problem
                      section of this report details the status of and opportunities for this type of wetland planning.

                                       PA IMP 44

                      Program Improvements:
                          0    Explore the possibility of legislation to incorporate buffer area requirements as a specific
                               provision of the Coastal Act.

                           0   Work with local governments to amend LCPs to ensure that buffer area provisions are
                               strictly and consistently applied.

                           0   Study options for using the regulatory process and/or incentive programs to prevent
                               agricultural and grazing activities from further intruding into wetland buffer areas.

                                                        CALIFORNIA COASTAL COMMISSION                               PAGE95
<pb n="97" />

                RECAP PILOT PROJECT

                Long.er'Range Opportunities::
                     * Until the necessary scientific studies dictate otherwise, ensure that all LCPs have a
                       provision requiring at least a 100 foot buffer area adjacent to any wetland, measured
                       from the wetland edge as determined by the Cowardin method. These provisions should
                       also include limitations on permitted uses and activities within the buffer appropriate to
                       the wetlands in question.

                     * Ensure that all LCPs measure buffer areas from the same point, preferably the outer
                       delineated edge of the wetland or riparian area; make available clear and accurate maps
                       of the established buffer zones.

                wi6th h
                                         a a              -6 ould:,
                     a, a.hdwiatershed m n gementplans h'
                       Specifically identify the location and appropriate uses and functions of wetland buffer
                       areas (and discourage or preclude inappropriate, high-impact uses); require their
                       preservation in perpetuity and, if appropriate, restoration to native vegetation; include a
                       monitoring program to ensure maintenance of their structure and function.

                         ft...` I fb                                   . ..... .
                 .pp
                     ,9.,unmes, r.,U11therstu V:i:
                       Complete the necessary scientific studies to determine the appropriate size and structure
                       of buffer areas.

                     * Apply such studies to individual wetlands; determine if studies conducted elsewhere in
                       the country are applicable to ReCAP area wetlands.
                     * Review effectiveness of Commission-imposed wetland buffer requirements over time.
                     * Prepare time-series maps of wetland-edge changes for other wetlands as was done for
                       Neary Lagoon.

                     WETLANDS PROBLEM THREE
                                                                 MIMESIS

                       The hydrology of most wetlands within the project area has been adversely affected by
                development

                       The hydrology of coastal wetlands is made complex by their location at the interface
                between upland and aquatic environments. 81 Tides, waves, currents, freshwater discharge, and
                ground-water seepage are all important@ but variable, elements of coastal wetland hydrology. 82
                In California, wetland hydrology will also vary markedly with season, with many wetlands
                                                                                    8384
                becoming dominated by freshwater during the winter/spring rainy period. , In addition, the
                hydrology of wetlands in the project area is directly affected by the multi-year drought/flooding
                events that pervade California's climate.
                       A number of factors, both anthropogenic and natural, can affect the hydrology of
                wetlands. When human development alters a wetland's hydrology, the changes can adversely

                PAGE96                        CALIFORNIA COASTAL COMMISSION
<pb n="98" />

                                                                                                                   CHAPTER 5 - WETLANDS

                          affect wetland size, water quality, and habitat quality. For example, past development in the
                          coastal zone, particularly roads and railways, have muted (e.g., at Bennett Slough and Corcoran
                          Lagoon) or in some cases completely severed (e.g., Upper Watsonville Slough and Schwann
                          Lagoon) the connections these coastal wetlands had with the ocean. In most cases a road or
                          other structure was built through the wetland reducing the size of one or more channels and
                          resulting in the placement of culverts, weirs, or tide gates that restrict or exclude tidal flow. As a
                          result, the amount of water that these wetlands receive and the movement of water through the
                          wetland have been diminished. In addition, earthquakes have influenced the hydrology of some
                          coastal wetlands in the project area. For example, the 1989 Loma Prieta earthquake increased
                          the -amount of saltwater reaching some wetlands          Ae.g., Struve and Bennett Sloughs) by rupturing
                          the roads and culverts that restricted tidal flows, and by lowering bottom elevations.

                                   Information reviewed and compiled by ReCAP suggests the hydrology of virtually all
                          wetlands within the project area has been altered to some degree by human activities, such as
                          dam buildinA, road construction, and urban and agricultural development in the surrounding
                          watersheds.      A sequence of activities on the Salinas River illustrate the timing and type of
                          activities which have adversely affected numerous wetlands within the region (Table 5-4).
                          Cumulatively, these activities, which mainly occurred prior to the Coastal Act, have resulted in a
                          reduction of the amount of salt- and/or freshwater reaching the wetlands, and changes in the
                          timing and velocity of water flowing into the wetlands. However, natural events within the
                          ReCAP project area have also affected hydrological processes. For example, the drought of
                          1987 to 1992 resulted in reductions in the amount of freshwater reaching all wetlands. In
                          contrast, the Loma Prieta earthquake in 1989 increased the amount of saltwater reaching some
                          wetlands. The anthropogenic alterations to wetland hydrology have tended to compound the
                          effects of these natural processes leading to synergistic cumulative impacts, including reductions
                          in water quality, changes in habitat composition, and reductions in habitat size and biodiversity.

                                                                                                                            7
                                           Table 5-4: Sequence ofHuman Activities Affecting the Salinas River Watershed

                                                                                                                                 ..........
                                                          .............                                                   .....................
                                                  ..........  ...............                        .......... ......                    ......
                                                                                                                                          ............ ..
                       A fiwt                                                        @@Jmlo.
                                                                             ...........
                       Railroad and highway bridge crossings           1850-1950      Altered channel morphology; potential degradation
                       built                                                          of water quality from highway runoff
                       Salinas valley sewage treatment plants          1930 and       Increased regulation of water flows; chronic
                       goes on line                                    1942           degradation of water quality
                       Santa Margarita dam built                       1942           Altered timing and amount of freshwater outflow;
                                                                                      loss of habitat for anadromous fish
                       Salinas River channel reconfigured and          1946           Altered estuarine habitat; change in saltwater
                       mouth relocated                                                hydrology
                       Nacimiento dam built                            1957           Altered timing and amount of freshwater outflow;
                                                                                      loss of habitat for anadromous fish
                       San Antonio dam built                           1965           Altered timing and amount of freshwater outflow;
                                                                                      loss of habitat for anadromous fish
                       Approximately 87% of watershed in               by 1976        Increased withdrawal of surface and ground water;
                       agriculture"                                                   increased levels of agriculturally related nonpoint
                                                                                      source pollution; altered watershed drainage.
                       Salinas River Lagoon placed under               1972-          Preserved lagoon habitat
                       protective status by Fish and Wildlife          Present
                       Service and State Parks &amp; Recreation

                                   Thirty-five of the wetlands identified in the pilot area are true coastal wetlands, having
                          one or more connections with the ocean (Table 5-5). Of these, 15 have a perennial source of
                          freshwater. Thus, although marine processes dominate the hydrology of these wetlands,
                          freshwater inputs are an important part of the overall hydrology. These coastal wetlands occur at

                                                                CALIFORNIA COASTAL COMMISSION                                        PAGE 97
<pb n="99" />

             RECAP PILOT PROJECT

             the mouths of rivers as small estuaries or lagoons, or as large systems such as Waddell Creek
             Marsh and Elkhorn Slough. Sixteen wetlands have a perennial source of freshwater but no
             connection with the ocean. The hydrology of these wetlands is a function of the freshwater
             supply, which although always present, will vary with season and weather patterns (e.g.,
             droughts and floods). Coastal and freshwater wetlands with an intermittent supply of freshwater
             account for 69% of the wetlands in the project area (Table 5-5). These include Arana Gulch, the
             Marina vernal ponds, and Spanish Bay wetland. The hydrology of coastal wetlands with
             intermittent freshwater inputs is dominated by marine processes. The freshwater supply to these
             wetlands will vary with surface runoff, which is highly seasonal.

                           Table 5-5: Gross hydrologic categories of wetlands in the ReCAP Pilot area

                                 .... ..............
                           ro
                                                              fW
                        'H
                              0glogae or              :umber: o
                                        q                       ...   ..... ....... .......
                        Coastal wetland, perennial   15
                        source of freshwater
                        Coastal wetland, intermittent 20
                        source of freshwater
                        Freshwater wetland, perennial 16
                        water source
                        Freshwater wetland, intermittent 48
                        water source

                   Natural hydrological changes in freshwater supply to a wetland can be inferred through
             an examination of river outflow data. For example, river outflow data for the Salinas River
             (Figure 5-7), show artnual freshwater inputs between 1983 and 1993 were largely related to
             regional weather patterns. Freshwater flows were highest in 1983, an extremely wet year, and
             lowest during the drought years, 1987 through 1992. For those 15 coastal wetlands having a

                                 Figure 5- 7.- Salinas River Ouylow at Spreldes, California

                       CV)
                 LL

                 .2
                 3:

                 U-

                 Z     CD
                                                                a/-

                       C-4
                           83   84    @85  86   87   88    89   90   91   92    93

                                                     Year

                 Source: USGS stream gauge data

             PAGE98                    CALIFORNIA COASTAL COMMISSION
<pb n="100" />

                                                                                                     CHAPTER 5 - WETLANDS

                      perennial freshwater source, these outflow data suggest hydrological conditions within the
                      wetlands were dominated by marine processes over much of the last ten years. Typically, such a
                      change in hydrology would result in increased salinity throughout the year, and could affect
                      species' distribution and abundance. For example, several species of fish use coastal wetlands as
                      nurseries in the spring when brackish (moderate salinity) waters prevail. During a drought there
                      may not be enough freshwater to maintain brackish conditions throughout the wetland, forcing
                      the fish to reproduce (often less successfully) further upstream or in a different wetland. In this
                      way, substantial droughts, such as occurred between 1987 and 1992, could adversely affect
                      reproductive output of some wetland dependent organisms. For those 64 wetlands relying solely
                      on freshwater as a water source, the impacts could be more direct. The drought related loss of
                      water to these wetlands would result in a reduction in the size of the wetland and loss of wetland
                      habitat.

                               Hydrologic processes within some coastal lagoons occurring in the project area illustrate
                      the interaction between natural and anthropogenic processes and the results that these
                      interactions can have. Several of the major wetlands in the project area are coastal lagoons (e.g.,
                      Waddell Creek Marsh, Soquel Creek, Salinas River Lagoon, and Carmel River Lagoon), and thus
                      subject to closure through the formation of berms at the mouth. The opening and closing of a
                      lagoon mouth is fundamentally a natural process; however, anthropogenic alterations such as the
                      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 have numerous adverse affects including
                      increasing the potential for flooding, causing extreme changes in water quality, and blocking fish
                      migration. Three examples in the project area with coastal development permits illustrate some
                      of the processes used to prevent the adverse impact of lagoon mouth closure:

                               (1) Santa Cruz harbor (Arana Gulch) was historically a coastal lagoon that was altered
                      for use as a marina. Hydrologic conditions within the marina coupled with nearshore ocean
                      currents require nearly constant dredging to maintain the harbor mouth. The harbor district has
                      permits to operate a suction dredge at the mouth for much of the year at considerable cost. Even
                      so, the mouth has closed several times over the last ten years inhibiting navigation in and out of
                      the harbor, and resulting in the production of foul odors and fish kills.

                               (2) The lower San Lorenzo River is another coastal lagoon whose mouth has often closed
                      during the summer, due to low flows and beach buildup. These closures have increased the
                      potential for flooding, and could adversely impact salmon and steelhead fish migration. A coastal
                      development permit" was approved for placement of an outflow control device at the mouth, as
                      an alternative to artificial breaching. However, the water elevation control device was never
                      installed and the City later abandoned its permit due to liability concerns, so breaching is still
                      proposed.90 Currently, the Army Corps of Engineers has plans to dredge the' lower river channel
                      to improve flood storage capacity; this project would also increase the tidal prism and could
                      reduce the incidence of mouth closures.

                               (3) Soquel Creek is in a situation similar to the San Lorenzo River. However, unlike the
                      San Lorenzo River, a coastal development permit?l was obtained to operate a water level control
                      and fish bypass system and to allow breaching of the mouth as necessary. These examples,              92
                      although of a common problem, illustrate three different approaches taken to achieve a remedy.
                      Overall, these three wetlands have been maintained as lagoon ecosystems, although at substantial
                      costs to the public and natural resources.

                               Excess erosion or sedimentation is the most obvious result of changes to wetland
                      hydrology. In terms of assessing the magnitude of this problem Elkhorn Slough is the most well
                      studied wetland within the ReCAP project area. A recent study     @3 found that the construction of
                      Moss Landing Harbor in 1946 dramatically altered the Slough's hydrology and initiated ongoing

                                                        CALIFORNIA COASTAL COMMISSION                                PAGE99
<pb n="101" />

                 RECAP PILOT PROJECT

                 erosion. Between 1988 and 1993, approximately 420,000 cubic meters (approximately 70,000
                 cubic meters per year) of material was eroded from the subtidal portions of Elkhorn Slough. In
                 addition, intertidal saltmarsh habitat has been retreating from the center of Elkhorn Slough at an
                 average rate of 18 centimeters per year (cm./yr.) since 1946. Present day rates of saltmarsh edge
                 retreat average 39 cm/yr. Thus, excessive development-induced erosion has been a chronic
                 problem in Elkhorn Slough over the last 47 years, and the rate of erosion is increasing.
                         Meanwhile, excessive sedimentation is an ongoing problem in upper Elkhorn Slough. A
                                               94
                 recent report by Belden et. al. found that two-thirds of the total sediment (approximately
                 178,070 tons/years) entering Elkhorn Slough is due to erosion from strawberry farms, although
                 strawberry farms comprised only eight percent of the land use within the watershed. These
                 unnaturally generated sources of excessive sediment will accelerate the conversion of wetland
                 habitat to upland habitat. As wetland habitat is lost, fewer wetland dependent species can be
                 supported. Existing policies governing land use in the coastal zone emphasize the protection of
                 agricultural lands, limitin
                 excessive sedimentation. 9§ the regulatory alternatives for controlling agriculturally generated

                         Although human-induced acceleration of erosion and sedimentation are considered
                 adverse impacts, these processes do occur naturally and play an important role in wetland
                 ecology. A review of aerial photographs taken in 1977, 1986, and 1993 shows the location and
                 size of some coastal wetland outlets have changed over time. For example, the outlet of Waddell
                 Creek Estuary migrated north about 1000 feet between 1986 and 1993. At Scott Creek, the main
                 channel was approximately 75 feet wide in 1986 (an extremely wet year), but only about 20 feet
                 wide in 1993. The San Lorenzo River mouth was approximately 350 feet wide in 1986, but only
                 about 50 feet wide in 1993, when substantially different shoaling and beach conditions existed.
                 In 1986, the Salinas River flowed through the north lagoon before entering the ocean; however,
                 in 1977 and 1993 the river entered the ocean well south of this lagoon. These examples illustrate
                 how wetland hydrology contributes to the dynamic nature of wetlands, an aspect critical to the
                 long-term maintenance and health of this resource.

                         Changes in wetland hydrology will also affect the plants and animals within a wetland.
                 Reducing the amount of water available to the wetland will alter the types of organisms that
                 occur in the wetland and the density of organisms the wetland can support. For example,
                 Valencia Lagoon is a freshwater wetland that supports the Santa Cruz long-toed salamander, an
                 endangered species. The hydrologic function of this lagoon is critical to the existence of this
                 species. Reductions in salamander density have been linked to a loss of habitat due to adverse
                                                                                      96
                 impacts to the wetland hydrology stemming from road construction.       Similarly, changes in
                 wetland hydrology can result in water quality changes, which in turn can affect the resident
                 biota. The discussion on the closure and maintenance of coastal lagoon openings above is a
                 good example of the relationship among hydrology, water quality, and wetland biota.
                         Many of the factors affecting wetland hydrology do not occur directly in the wetland, but
                 rather within the wetland's watershed. The project area includes portions of nine major
                 watersheds (Figure 5-8, page 10 1). Much of the drainage area of these watersheds occurs
                 outside the coastal zone; however, many of the wetlands within the pilot area occur at the ends of
                 streams, rivers, and other drainage. areas within the coastal zone, and are directly affected by
                 activities occurring throughout the watershed. Urban development increases the amount of
                 impervious surface within the watershed, leading to increased runoff rates and channelization.
                 Timber harvesting and agriculture have resulted in increased rates of erosion and nonpoint
                 source pollution.
                         Urban and agricultural development also increase local needs for freshwater, reducing
                 the amount of water flowing through the watershed and altering the timing of those flows. For
                 example, aerial photograph analysis shows the existence of a substantial number of small
                 detention ponds within the project area (Figure 5-9, page 102). These ponds are primarily used

                 PAGE `100                        CALIFORNIA COASTAL COMMISSION
<pb n="102" />

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                                                                                                                                                                                                 -
<pb n="104" />

                                                                                                 CHAPTER 5 - WETLANDS

                     by agriculture and industry, but some may serve other functions as well. The ponds are generally
                     small, but together cover a substantial area (Table 5-6). Some ponds are created through     97
                     impoundment of small streams, but most are created in dry areas and filled with well water.
                     Between 1977 and 1993, the number of ponds increased by 5 1 %. No doubt the presence of these
                     detention ponds has affected the way water moves through the watershed. Although the
                     ecological affects of these ponds are not well studied, it should be mentioned that these ponds are
                     not without benefit. Perennial ponds can provide suitable habitat for freshwater marsh plants,
                     and have increased the distribution of small freshwater wetlands over a broader area. 98 These
                     ponds can provide resting and foraging habitat for migrating birds and wetland dependent
                     animals. Yet it is unknown whether the benefits of these detention ponds outweigh the costs.

                                                Table 5-6: Summary Informationfor Detention Ponds

                                  .::.Varia.ble            . .... .     1.977       :4 986:::.:.:
                                   V                                                              993.
                                   Total Number of Ponds                i02-140'     145-199     154-212
                                   Mean square acreage per pond         0.6-0.8      0.5-0.6     0.6-0.8
                                   Total acreage                        72-98        88-120      105-145

                             Overall, substantial portions of many watersheds associated with the project area have
                     undergone significant development. Unfortunately, due to jurisdictional boundaries, regulations,
                     for the most part, are not developed or enforced on a watershed basis. For example, between
                     1988 and 1992, the Department of Fish and Game processed I I stream bed alteration agreements
                     for projects located in Struve Slough. Although none of these projects occurred in the coastal
                     zone, they all have affects on other locations in the watershed through alterations in the amount
                     and timing of-freshwater flows. This is a prime example of how adverse cumulative impacts
                     could continue to occur within the ReCAP project area regardless of any procedural or policy
                     changes made within the coastal zone, and why new watershed-based approaches for addressing
                     these issues must be developed.

                             A review of the region's LCPs/LUPs shows that with the exception of Santa Cruz
                     County, development projects affecting wetlands are not limited based on their potential to alter
                     wetland hydrology (Table 5-7). Santa Cruz County's LCP contains policies prohibiting
                     construction that alters saltwater inflows to coastal lagoons and limits some dam development
                     based on instream flow requirements. In addition, none of the LCPs/LUPs contain explicit
                     requirements for mitigating adverse impacts to wetland hydrology. Regulation of new
                     development cannot solve hydrologic problems caused by on-going activities. Half of the
                     LCPs/LUPs do suggest programs to restore hydrologic functions in wetlands, but funding and
                     other program implementation is not specified.

                             The process for regulating adverse impacts to wetland hydrology is complicated by the
                     fact that wetlands comprise only a portion of larger watersheds that span multiple jurisdictions.
                     Yet a wetland's hydrology is inextricably linked to hydrologic processes within the associated
                     watershed. Hydrologic manipulations at wetland outlets would most likely remain in the Coastal
                     Commission's original permit jurisdiction. However, alteration of freshwater flows could occur
                     anywhere in a watershed. As mentioned previously, the coastal zone includes only a small
                     portion of the watersheds in the Monterey Bay area, and other jurisdictional boundaries often
                     bisect one or more watersheds. Activities permitted in one jurisdiction can have a direct affect
                     on the hydrology of a wetland in another jurisdiction if these jurisdictions share the same
                     watershed.

                      Numbers reported as a range which incorporate empirically derived margins of error.

                                                      CALIFORNIA COASTAL COMMISSION                            PAGE 103
<pb n="105" />

                       RECAP PILOT PROJECT

                                  In terms of future trends, adverse imp              acts to wetland hydrology will continue unless
                       changes are made to current regulatory and management practices. Although major development
                       activities resulting in the largest changes to local hydrology have long since been completed,
                       population projections suggest substantial increases in regional population over the next decade.
                       Higher population levels would increase the demand for natural resources such as water and
                       require additional development. Undoubtedly this would result in further degradation of wetland
                       hydrology absent comprehensive mitigation measures. In addition, development in other parts of
                       the coastal watersheds will continue. This development could also contribute to the cumulative
                       degradation of coastal zone wetland hydrology. Meanwhile, numerous opportunities exist to
                       restore and enhance the hydrologic functions of wetlands within the region. These projects could
                       provide positive benefits both to the individual wetlands and in a cumulative sense to the natural
                       resources within the region. Efforts to pursue all possible restoration opportunities must
                       continue at all levels of government and within the community.                        99  A new publication by the
                       California State Coastal Conservancy entitled Optionsfor Wetland Conservation, A Guide For
                       California Landowners (1994) provides valuable information relevant to this issue.

                                      Table 5-7.-   Results ofLCPILUP Reviewfor provisions relating to Hydrologic Alternations

                                                        t ktiqnspd:@::@.T..: equire                                     C
                           Mr. L.
                                                   Ws h                     R          S.,.elp)           di lii4i4oi    Hk
                                                                                                      ...........
                                 ........... .... .. ...                                        ..... ......
                                                                                                           ast Joe m:            @@i@po-    0179 aW:.-
                                                                                   11     Ion....
                                                                                    t
                                                           ...........

                           ..... .....................
                                                                                                              ........                         o reswre.....
                              ........... . .                               ...... - -...                                              b d
                       Santa Cruz                Does not permit            No                        70-95% of stream           Yes
                       County                    projects that alter                                  flow
                                                 saltwater
                                                 hydrology; some
                                                 limits on dams
                       Santa Cruz City           No language                Through CEQA              No                         Yes
                       Capitola                  No language                Permit review             No                         No
                       Watsonville               No language                No                        No                         No
                       Monterey County           No language                No                        No                         Yes
                       Marina                    No language                Through CEQA              No                         No
                       Seaside                   No language                No                        No                         Yes
                       Pacific Grove             No language                No                        No                         No

                                 Continuing to follow and improve existing regulations will help ensure that                            'hydrologic
                       impacts from new development do not occur or are adequately mitigated. Even more assurance
                       can be gained by undertaking a more specific planning process focusing on individual wetlands
                       and their watersheds. Such a plan can describe current and optimal hydrologic conditions to
                       serve as a basis for analyzing new projects.              100 Such a plan can also anticipate likely hydrologic
                       manipulations (e.g., river lagoon breaches) and provide criteria for (or recommend alternatives
                       to) them. Finally, a wetland management plan can also review existing hydrologically-impacting
                       structures (e.g., a broken tide gate) or activities (e.g., pumping) and recommend remedial
                       actions.

                                 There is a definite trend by many government agencies to use a watershed approach as
                       the basis for comprehensive natural resource planning. This approach offers additional
                       opportunities for the management and conservation of wetland hydrology based on processes and
                       activities occurring throughout the watershed. In addition, this approach could help to reduce
                       duplication, foster cooperation and consistency, and result in more efficient use of limited
                       government funds. Such a plan can recommend regulatory improvements to uniformly apply to

                       PAGE 104                                   CALIFORNIA COASTAL COMMISSION
<pb n="106" />

                                                                                              CHAPTER 5 - WETLANDS

                    new development in the watershed as well as necessary programs to address existing
                    contributory activities and uses. The final problem section of this chapter outlines the status of
                    and opportunities for such planning initiatives.

                    Program Improvement:
                        *   Develop proposed legislation aimed at revising management and regulatory processes to
                            incorporate a watershed approach into comprehensive planning and regulatory
                            procedures.

                        *   Develop a consistent approach for breaching lagoon mouths in consultation with the
                            Army Corps of Engineers, the Department of Fish and Game, the Regional Water
                            Quality Control Board, local flood control districts, local governments, and other
                            relevant agencies. This could include the development of guidelines and/or
                            memorandums of agreement foruse in the regular permitting process.

                    Revise local. coastal programs to:.
                        *   Include specific provisions to maintain and manage hydrologic processes both within the
                            wetlands and the associated watersheds. These provisions should be cost effective and
                            should apply equally to urban and agricultural lands. The regulation of erosion and
                            sedimentation is the most direct way to accomplish this recommendation and should be
                            an explicit part of any provision. These provisions must be consistent among LCPs to
                            ensure equal treatment, since current jurisdictional boundaries bisect watershed
                            boundaries.

                        *   Incorporate appropriate information developed from the Monterey Bay National Marine
                            Sanctuary's watershed analysis and planning work, including the identification of
                            opportunities for the restoration of impaired hydrology and associated processes.

                    Wetland and watershed management plans should:
                            Include wetland hydrology as a specific component of the overall plan including an
                            inventory of problems, established baseline conditions, and recommended remedial
                            actions.

                    Opportunities for further study:
                            Investigate the hydrologic implications of detention ponds.
                            Evaluate the effectiveness of policies to control runoff in the Elkhorn Slough watershed.

                            Evaluate the success of wetland restoration projects that included hydrologic
                            components; evaluate success of restoration projects where hydrology was not given
                            consideration.

                                                   CALIFORNIA COASTAL COMMISSION                           PAGE 105
<pb n="107" />

                   RECAP PILOT PROJECT

                        WETLANDS PROBLEM FOUR

                   Impacts To Wetland Water Quality

                            The water quality status of most wetlands within the project area is unknown, although
                   some wetlands are known to have suffered adverse impacts due to human development.

                   ANALYSIS

                            Water quality is defined here as the physical, chemical, and biological integrity of a
                   water body. Proper wetland water quality is necessary to provide an environment that not only
                   supports the existence of wetland plants and animals but allows for their reproduction and
                   growth. Thus, water quality is a direct measure of the health of a wetland. However, interest in
                   wetlands has intensified recently, because of the ability of wetlands to enhance water quality.
                   Through a variety of processes, wetlands are able to remove sediments and both organic and
                   inorganic pollutants from the overlying water.    101,102

                            Unfortunately, much of the water quality information available in the project area is
                   inappropriate or unsuitable for determining the long-term cumulative impacts to wetland water
                   quality. Although a large amount of water quality data has been collected from wetlands within
                   the pilot area, most of the information was collected to answer project specific questions. In
                   addition, sampling methods and testing criteria vary considerably. Thus, much of the available
                   data cannot be readily used to establish general water quality conditions or long-term trends for
                   specific constituents. -A 1976 assessment of water quality conditions in Santa Cruz County
                   found that "in-depth examination of the surface and ground water historical water quality records
                   indicates that there is insufficient information to adequately define the long-term, short-term, and
                   areal variations for most of the County".  103 A recent assessment of water quality information by
                   the Monterey Bay National Marine Sanctuary shows relatively little is still known about the
                   quality of water in the project area (Table 5-8).

                        Table 5-8: Summary of Information Need for Wetlands/Water Bodies Within the ReCAP Project Area*

                   Number of 		Number and (percent)		Number and (Percent)		Number and (Percent)
                   Wetlands and	for which Designated		for which Designated		for which Water Quality
                   Water Bodies	Human Use is			Habitat Use is Unknown		Classification is
                   Reviewed		Unknown									Unknown

                		31		     23(74%)			 	  13(42%)				19(61%)

                *Source: National Oceanic and Atmospheric Administration. 1994. Monterey Bay National Marine Sanctuary Water
                  Quality Protection Program. Workbook Regional Characteristics. Draft.

                 Designated use only includes existing or designated uses.

                 Water Quality Classifications: Good - Waters that support and enhance the designated beneficial uses.  Intermediate
                  - Waters that support designated beneficial uses while there is occasional degradation of water quality.  Impaired-
                  Water bodies that cannot reasonably be expected to attain or maintain applicable water quality standards.  Unknown
                  - Water bodies with unknown water quality where limited or no direct observations are available.

                   PAGE 106                          CALIFORNIA COASTAL COMMISSION
<pb n="108" />

                                                                                                     CHAPTER 5 - WETLANDS

                              There is information that shows nonpoint source pollution is adversely affecting some
                      wetlands in the project area at various times. For example, there are numerous reports of
                      elevated coliform bacteria counts.  104,105,106 Elevated bacterial concentrations typically occur
                      after winter storms, suggesting nonpoint source runoff is responsible. Although coliform
                      bacteria problems mainly occur in wetlands surrounded by pasture lands and agriculture, there
                      have been reports of problems in urban areas. Neary Lagoon provides a recent example. It is
                      estimated that Neary Lagoon receives nearly two-thirds of Santa Cruz city's urban storm water
                      runoff. 107 Fecal coliform levels in excess of 500 percent of the State and Federal water quality
                      standards have been documented in the lagoon.' 03 This situation has persisted for a number of
                      years, and only recently has the Regional Water Quality Control Board required Santa Cruz City
                      to apply for a federal discharge permit in an attempt to regulate this problem.

                              The introduction of pesticides, heavy metals, and other pollutants into wetlands in the
                      project area is of ongoing concern. Unfortunately, long term monitoring data are generally not
                      available. Additionally, the in-depth studies necessary to identify, track, and quantify these
                      pollutants are generally cost prohibitive. The few studies completed show pesticides do exist in
                      some wetlands within the project area. Specifically, studies of Moro Cojo Slough, Elkhorn
                      Slough, Moss Landing Harbor, and the Salinas River Lagoon all concluded that pesticides do
                      occur in these wetlands.  109,110 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
                      are 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.       11r,  Also,
                      Marina Vernal Pond # I (approximately 10 acres) receives runoff from approximately 13 acres
                      of an adjacent stretch of Highway One,   112 Thus, while it cannot be determined if water pollution
                      in the project area is widespread, there clearly are areas of concern.

                              As with hydrology and morphology, many of the factors affecting wetland water quality
                      do not occur directly in the wetland, but rather occur within the wetland's watershed. Along
                      with urbanization come new sources of pollution (e.g., household pesticides, fertilizers, motor
                      oil, and cleansers) that can enter the watershed with stormwater runoff. Timber harvesting and
                      agriculture can result in increased rates of erosion and nonpoint source pollution. These sources
                      of pollution have had adverse impacts on wetlands located in both urban (e.g., Neary Lagoon and
                      Schwann Lagoon) and agricultural (e.g., Elkhorn Slough, Upper Watsonville Slough, and
                      Tembladero Slough) areas.

                              Point source discharges also exist within the project area. A review of current waste
                      discharge permits shows there- are 13 active discharges into local streams and 5 active discharges
                      into local wetlands.' 13 These discharges include treated sewage, overflow from settling ponds,
                      cooling water, and effluent from vegetable and meat processing plants. The exact effects of
                      these discharges are not fully known.

                              A review of the LCPs/LUPs covering areas with wetlands, revealed all but one included
                      some pollution control requirements (Table 5-9). (The City of Pacific Grove's policy is simply
                      to investigate potential pollution problems.) 114 Requirements include provision (if erosion
                      controls, as well as sediment and grease traps, which are implemented on a case-by-case basis.
                      Maintenance of such devices is generally stipulated, but there are no requirements to monitor
                      specific pollutants or potential project related sources. With the exception of Pacific Grove, all
                      LCPs/LUPs require wetlands to have buffers (which can help protect wetland water quality). In
                      no case has an analysis been performed leading to information on maximum acceptable pollutant
                      loading into a wetland. All but two LCPs (Capitola's and Watsonville's) suggest programs
                      aimed at reducing existing pollution problems; however, Capitola has recently adopted a
                      management plan to do so for Soquel Creek, its only wetland.

                                                       CALIFORNIA COASTAL COMMISSION                               PAGE 107
<pb n="109" />

                        RECAP PILOT PROJECT

                                             Table 5-9: Results ofLCPILUP Reviewfor Provisions Relating to Water Pollution

                                                                                                 R          esZ.       r    -g
                                         P L .          @@7611uti
                                  ... LC I    't   .....                                                                        Suggestsi
                                                               ........ ....                                  . . . .....
                                                                                                               ... ..........    .. .......
                                                                                                                                      il .....t
                                                                                                                            ... -ine-ia,ion:..
                                                                ".ed
                                     .........                 uir            j,ptentill               o efiti   f

                                                                                                    .......  .......

                                  Santa Cruz            Yes               No                     Yes                        Yes
                                  County
                                  Santa Cruz            Yes               No                     Yes                        Yes
                                  city
                                  Capitola              Yes               Possibly               Yes                        No
                                  Watsonville           Yes               No                     Yes                        No
                                  Monterey              Yes               No                     Yes                        Yes
                                  County
                                  Marina                Yes               No                     Yes                        Yes
                                  Seaside               Yes               No                     Yes                        Yes
                                  Pacific               Investigate       No                     No                         Yes
                                I Grove

                                  It is hard to predict future trends for water quality in the absence of appropriate
                       information. Land use analyses suggest full buildout has nearly been reached in several portions
                       of the pilot area. If more recent activities such as infill development and changes in zoning
                       decline as full buildout is reached, then the adverse impacts to water quality from development
                       activities should stabilize. In contrast, population projections suggest substantial increases in
                       regional population over the next decade. Higher population levels would increase the potential
                       for pollution, particularly nonpoint sources. However, government agencies, such as the Coastal
                       Commission, Monterey Bay National Marine Sanctuary, and Regional Water Quality Control
                       Board, continue to refine and enhance education programs and regulatory measures aimed at
                       reducing and/or preventing impacts to water quality. One such effort is the Coastal
                       Commission's project of special merit to address polluted runoff.' 15 These agencies must remain
                       proactive in their work to safeguard water quality. Although the constraints and costs to the
                       individual may at times seem excessive, the cost of remedying chronic and cumulative adverse
                       impacts to water quality is many times greater. Left uncorrected, the cumulative degradation of
                       water quality will ultimately have adverse affects on many other economic resources (e.g.,
                       tourism, agriculture, and fishing) within the region.

                                  Continuing to follow and to improve existing regulations will help ensure that adverse
                       water quality impacts from new development do not occur or are adequately mitigated.
                       However, as discussed in the preceding Hydrology section, real progress in addressing water
                       quality is best achieved through watershed planning and management. Such a planning process
                       can comprehensively address all sources polluting a wetland and coordinate responsibilities for
                       controls and remediations. The final problem section of this chapter outlines the status of and
                       opportunities for such planning initiatives.

                       PAGE 108                                    CALIFORNIA COASTAL COMMISSION
<pb n="110" />

                                                                                             CHAPTER 5 - WETLANDS

                    RECOMMENDATION&amp;@,_

                    Program Improvements::
                        0   Continue to participate in the Monterey Bay National Marine Sanctuary's water quality
                            program to complete. a comprehensive Water Quality Protection Program, including a
                            determination of baseline water quality where the condition is unknown.
                        0   Develop mechanisms and strategies for incorporating new information and procedures
                            for protecting water quality into the Coastal Commission's planning and regulatory
                            programs.

                        0   Utilize and train local government staff to use the Procedural Guidance Manual:
                            Addressing Polluted Runoff in the California Coastal Zone; incorporate relevant control
                            measures into local coastal programs.

                        0   Continue to participate in the Moro Cojo Slough wetland management planning process
                            and use that plan as a vehicle for developing methods to apply best management
                            practices (BMPs) to control nonpoint source pollution.

                    @onger Range Opportunities:
                        *   Incorporate the appropriate policies developed by the Monterey Bay National Marine
                            Sanctuary's Water Quality Protection Program.

                        *   Provide guidance to require standardized monitoring procedures as a condition of all
                            development activities having the potential to impact water quality. 116 Local
                            governments, the Regional Water Quality Control Board, the Coastal Commission, and
                            the Monterey Bay National Marine Sanctuary should work together to formulate such
                            guidance.

                        *   A region-wide monitoring program should be developed to obtain basic water quality
                            information. This information should be used to determine long-term trends in water
                            quality, help eliminate or reduce pollution sources, and identify wetlands most in need of
                            attention.

                    Wetiand and Watershed Management Plans Should:
                        * Incorporate wetland/watershed water quality as a specific element of management plans,
                            including an inventory of problems.

                        * Include a standardized water quality monitoring program.

                        *   Consider strategies to restore water quality where degraded conditions exist.

                    Opportunities for Further Study
                        * Compile water quality information from all available studies into a ReCAP wetland
                            database; use results to recommend priorities for future data collection (e.g., by category
                            and wetland).

                        0   Study cumulative or synergistic effects of various pollutants entering a wetland system.

                                                   CALIFORNIA COASTAL COMMISSION                          PAGE 109
<pb n="111" />

                 RECAP PILOT PROJECT

                       WETLANDS PROBLEM FIVE

                        An understanding of wetland biodiversity in the project area is necessary to fully protect
                 and manage wetland resources. However, such an understanding cannot be determined at this
                 time due to a lack of appropriate information. Nonetheless, there are indications that wetland
                 biodiversity has declined due to human impacts.

                        The plants and animals that exist in or rely on wetlands comprise the biological
                 component of the wetland ecosystem. Providing the function of wetland biodiversity, that is,
                 providing the resources that result in the existence and reproduction of a diverse array of species,
                 is considered one of the most important functions of wetlands today. Measurements of species'
                 number and their abundance is one way to quantify the value of this function. The establishment
                 of exotic species, the number of special status species, and changes in the number and abundance
                 of native species are indicators of changes in biodiversity. A reduction in biodiversity is
                 indicative of a wetland that has suffered adverse impacts.

                        There are several cases where actual changes in biodiversity have been noted; the
                 majority of cases conclude that a reduction in native species has occurred.' 17 In terms of
                 animals, fewer steelhead have been found in Carmel River Lagoon, clams have virtually
                 disappeared from M6ss Landing North Harbor (once part of the Old Salinas River Channel),
                 fewer fish occur in the Pajaro River Marsh, and fewer invertebrates populate the Salinas River
                 Lagoon. In terms of plants, non-native species have supplanted cattails in Gallighan Slough after
                 it was deepened by peat harvesting, lupines in the UC Santa Cruz Inclusion Area A Seasonal
                 Wetlands disappeared after heavy grazing, vegetation changed at Majella Slough as a result of
                 mining activities, and willows died in the Blohm-Porter Marsh (a portion of Elkhorn Slough)
                 after harbor construction opened it to tidal influence. Grazing and agriculture in McCluskey
                 Slough are thought to have resulted in a loss of native species and a concurrent increase in
                 introduced species. These changes may be responsible for a decline in the abundance of Santa
                 Cruz long-toed Salamanders, which inhabited McCluskey Slough.

                        Although 9 large amount of biodiversity data has been collected for wetlands within the
                 project area, much of this information is inappropriate or unsuitable for determining the long-
                 term cumulative impacts to wetland biodiversity. For example, numerous studies contain
                 information related to plant biodiversity. However, a review of several reports shows the study
                 results are highly dependent on the amount of time spent completing the survey and the area
                 covered. Various biological surveys of wetlands in the pilot area found between 2 species of
                 plants in Moro Cojo Slough and 249 species of plants in Elkhorn Slough (Table 5-10). On
                 average, 36 species of plants were found.118 Surprisingly, few surveys identified the number of
                 special status (rare, threatened, or endangered) species. Slightly more information was available
                 for exotic species.

                        Fewer studies included information relating to animal biodiversity (Table 5-11). Much
                 of the data was categorized among animal groups such as mammals, birds, amphibians, and fish
                 (Table 5-12, page 112). However, making comparisons among wetlands using these data would
                 be erroneous without first standardizing the data based on a common level of survey effort. As
                 with plants, the data was quite variable. For example, two different surveys of Elkhorn Slough
                 identified 7 and 404 animal species respectively (Table 5-11). Few surveys identified special

                 PAGE 110                       CALIFORNIA COASTAL COMMISSION
<pb n="112" />

                                                                                                                                               CHAPTER 5 - WETLANDS

                                                               Table 5-10: Examples ofPlant Species Biodiversity Survey Results                119

                                                          ..........                                                            .4:,:N mberof               .:Numberof:
                                                                                                                                           u
                                                          .. ... . .. .....
                                                                    . . . . .. ......
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                                                                                                                .............
                                                                                                                                                                   Pt
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                                          .. ........                                                                                                          . . ......
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                                ...... ....... ........- ......... ........... ......... .... .........                 ......                                         ecjes:::@xx::@:
                                                                                                                                           ... .... .. ..... .. .. . .......
                                                                                                       .. ........ .    ........
                                Carmel River Lagoon                                    1991                             6
                                Elkhorn Slough                                         1989                             279                  2
                                Elkhorn Slough                                         1990                             9                                              1
                                Gallighan Slough                                       1982                             5
                                Hansons Slough                                         1982                             48                                             21
                                Harkins Slough                                         1982                             46                                             16
                                Laguna Grande                                          1993                             8                                              4
                                Lower Bennett Slough                                   1990                             4
                                Majella Slough                                         1984                             16                                             3
                                Marina Vernal Pond # 1                                 1973                             5
                                Marina Vernal Pond # 1                                 1978                             15
                                Marina Vernal Pond # 1                                 1992                             19
                                McCluskey Slough                                       1973                             3
                                McCluskey Slough                                       1977                             12
                                Moro Cojo Slough                                       1990                             2
                                Moro Cojo Slough                                       1993                             184

                                status species or non-native species.                  All of the survey reports containing animal species
                                abundance or distribution data reported data for various groups of animals (e.g., birds, mammals,
                                reptiles, etc.). Birds were most commonly identified, followed by mammals. Methods for
                                completing such surveys were rarely stated, although the results suggest a high degree of
                                variability. In particular, many reports included listings of "species that may potentially occur in
                                the wetland based on the presence of appropriate habitat". Identification of appropriate habitat
                                was based on gross observations.

                                                               Table5-11: Examples ofAnimal Species Biodiversity Survey Results'20

                                                                  ........ .......                   ........           . ...... ....- ...... ...
                                                                                             ...........
                                                                                                                . . ............. ....
                                                                                                                                               ... . .... .. .... hi er::6
                                                                                                                                                        ........ ..
                                                                                                      ............ ........
                                                                                                . . ................. .. ....                                          ... . .. .... ... .
                                                                                               ........ ......  ........b...
                                                                                   a 6:
                                                         ........ .                        U            N               f      S,          I St  tus- EX0115           A
                                                                                           6 ... S um er o                           ecia   ...... a
                                                                                                                                 @p
                                                                                                      .... ......... ............. -....
                                                                                                                                                                            ...........
                                                                 . ... ... ..M                t             A,          I               pecies,
                                                                          @: easuremen                          11
                                                  d N          :.    ...
                                         Rt an           ame                                                                                            @:@!
                                .....                                                                                                                                  ecies:
                                                                                                                .. ... ........       ....... . ........
                                                                                           . .. . ........ .....- .....                     .. .... .
                                         ....... ...     ...... ...  .. ......
                                             ........... ......     .... ...
                                              .......... . .... ..  .. .. ... . . ...
                                                                    .... ... .... . .......                                           ........                         ......
                                                                          . ......... .. .. .....                          .... ........ ........... .. ... .    .. .... ..... .. ..... ...
                              ...     ...........        ............ ........                                                        .......
                                Elkhorn Slough                                     1989                         404                        6
                                Elkhorn Slough                                     1990                         7                          2
                                Marina Vernal Pond # 1                             1978                         46
                                Marina Vernal Pond # 1                             1992                         42
                                Moss Landing North                                 1990                         23                                                     5
                                Harbor
                                Soquel Creek Lagoon                                1992                         18                         1
                                Valencia Lagoon                                    1978                         17                         1

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                RECAP PILOT PROJECT

                       In general, little can be concluded from the review of this data. Much of the variability
                among surveys is attributed to methodological differences, rather than actual differences in
                biodiversity. Although repeat surveys were completed in several wetlands, generally the time
                span between surveys was relatively short. One exception was two surveys completed for
                Marina Vernal Pond #1. These surveys conducted in 1978 and 1992 found similar numbers of
                plants and animals in the wetland (Table 5- 10 and Table 5-11), although species numbers among
                animal categories varied somewhat (Table 5-12). Given the available data, however, it is not
                possible to directly determine the cumulative impacts to wetland biodiversity. These findings
                point to the critical need for standardized methodologies in assessing wetland biodiversity. The
                methods used should yield the information necessary to answer project specific questions, as
                well as the appropriate information for assessing the cumulative impacts to biodiversity over
                time and space.

                                  Table 5-12: Animal Species (By Group) Biodiversity Survey Results 121

                 Wetland      Date of      Total     Number Number Number Number of Number
                   Name      Measure-    Number          of      of Bird      of     Amphibian     of Fish
                               ment     of Animal    Mammal     Species    Reptile     Species     Species
                                          Species     Species              Species
                Elkhorn        1989         404          59       307         18          11          9
                Slough
                Elkhorn        1990           7          5          2
                Slough
                Marina         1978         46           5          35        4           2
                Ver. Pd. # 1        -
                Marina         1992         42           1          38        1           2
                Ver. Pd. # 1
                Moss Land.     1992         23           3          20
                N. Harbor
                Soquel Crk.    1992         18                      11                                7
                Lagoon                 I           I                     I         I             I         I
                Valencia       1978         17           8          --        7           3
                Lagoon

                       Other types of data were also examined in an attempt to characterize regional changes in
                biodiversity. The presence of special status species or their habitat may provide an indication of
                a change biodiversity. An inverse relationship presumably exists between biodiversity and the
                number of special status species. That is, as overall biodiversity is negatively impacted, more
                species are placed in jeopardy of extinction, some of which receive special status listing (34%).
                As the number of special status species increases so does the number of habitat types critical to
                their existence. So the presence of special status species or their habitat may be indicative of a
                decline in a wetlands' ability to maintain biodiversity. A review of the ReCAP database shows
                34 wetlands within the pilot area either contain special status species or appropriate habitat. This
                suggests that species biodiversity in the project area has been adversely impacted.

                       A review of the LCPs/LUPs within the region showed they all provide indirect
                protection for biodiversity through the recognition and enhanced protection of select habitats.
                Typically, the LCPs/LUPs specifically identify select habitats (e.g., habitat for the Santa Cruz
                long-toed salamander) or specific areas (e.g., Laguna Grande) that are rare or have received
                recognition because of their uniqueness in the local area. These habitats are identified as
                environmentally sensitive habitat areas, which severely limits development under the provisions

                PAGE 1112                     CALIFORNIA COASTAL COMMISSION
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                                                                                                         CHAPTER 5 - WETLANDS

                       of Coastal Act Section 30240. However, is it not known if the indirect approach incorporated
                       into LCPs/LUPs to protect biodiversity is preventing the loss of wetland species or appropriate
                       habitat. 122 This suggests a more consistent, direct, and proactive approach is needed to ensure
                       the preservation of wetland biodiversity.

                                Although there are indications that wetland biodiversity is decreasing in the project area,
                       the lack of consistent long-term biological (e.g., species abundance and distribution) and
                       ecological (e.g., habitat type and condition) information prevents predictions of future trends. In
                       addition, changes in the regional biodiversity of wide ranging species such as birds are affected
                       by processes occurring outside the project area and outside the region, further confounding
                       predictions of future trends. The analyses above suggest that the future condition of wetland
                       biodiversity is to some extent related to land use changes within the region. On a basic level,
                       additional development that directly or indirectly affects wetlands will affect biodiversity.

                                Continuing to follow and improve the regulatory process can help ensure that new
                       development does not further affect biodiversity. Even greater assurance can be gained by
                       undertaking a more specific planning process focusing on individual wetlands and their
                       watersheds. A plan for an individual wetland can more specifically identify permitted uses,
                       mitigation measures, and buffers to protect its specific plants and animals. Furthermore, in
                       identifying existing habitat types, hydrologic systems, and water quality, such a plan can
                       recommend improvements that would conserve or enhance biodiversity as well. Complementary
                       broader-based natural community, watershed, and regional planning can further advance
                       biodiversity protection and restoration at the level necessary to address entire habitats of species
                       that frequent wetlands and the activities and land uses that affect them. The final problem
                       section of this chapter outlines the status of and opportunities for such planning initiatives.

                       Program Improvements:. .
                                Explore the potential for local governments, the Department of Fish and Game, the
                                Monterey Bay National Marine Sanctuary and other appropriate agencies to work
                                together to formulate standardized procedures for determining regional wetland
                                biodiversity. These procedures should include select indicator species or other
                                appropriate measures which can be used to identify changes in the biodiversity
                                throughout the region.

                       Longer Range Opportunities:
                                Incorporate standardized procedures for determining wetland biodiversity into the
                                CCMP (e.g., local coastal programs). These procedures should also be used in studies
                                required for environmental impact reports, management plans, and other environmental
                                documentation required as part of the regulatory process.

                                Explicitly require the use of local native plant species in all revegetation projects.

                                Explore the potential for developing comprehensive habitat conservation plans for
                                unique habitats within the region.

                       Wetland/Watershed Management Plans Should:
                                Incorporate standardized procedures for determining wetland biodiversity for the region.

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                        Use relevant biodiversity information to assist in determining specific habitat restoration
                        goals and procedures.

                 ,pppitunitiewforfurther Study
                        Compile biodiversity information from all available studies into the ReCAP wetland
                        database; use results to recommend priorities for future data collection (e.g., by category
                        and wetland).

                        Evaluate effectiveness of Santa Cruz long-toed salamander protection policies in the
                        Valencia Lagoon watershed over time.

                      LYAMWII@ILFS PROBLEM SIX

                        Each stage of the decision-making process regarding wetland projects -- from project
                conception and wetland identification to follow-up monitoring and management -- could be
                improved with the generation of better information and by improving access to that information.

                                                             -W UR,                                    P'n   11@50
                                    71t , @ @q

                Infomiation'PrObleins,
                        ReCAP has found that analysis of cumulative impacts to the project area's wetlands is
                hampered by the lack of readily available and useable data. Direct access to reliable and
                accurate data is important in all stages of the CCMP in order to improve identification of
                wetlands, to assess impacts, to develop appropriate alternatives and mitigation measures, and to
                evaluate condition compliance and restoration success.

                        In reviewing Commission and local government permit files, ReCAP found the problem
                of information gaps evident in several aspects of the CCMP:

                    *   specific wetland identification;

                    *   information requirements for permit applications;

                    *   systematic understanding of wetlands;
                    *   agency information sharing and coordination;

                    *   access to expertise in, and training in, hydrology and biology;

                    *   information storage and retrieval.

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                                                                                                    CHAPTER 5 - WETLANDS

                      Wetland Identification
                              Knowledge of a wetland's existence and boundaries is crucial to managing the resource.
                      Coastal managers need direct access to an inventory of wetlands to guide wetland site
                      identification and delineation. Without such information, a site visit may not be performed or a
                      wetland may be missed. Access to reliable, updated site delineations would further increase
                      assurance of wetland identification and appropriate regulatory action. Access to maps and
                      descriptions *of individual habitat types would also assist coastal managers in identifying adverse
                      impacts and in devising appropriate mitigation requirements.

                              ReCAP discovered cases where identified wetlands were not acknowledged in previous
                      regulatory actions. These cases arose where previously approved projects were never built and
                      new site information become available upon project resurrection. For example, at Terrace Point,
                      environmental studies in 1981 and 1987 failed to note any wetlands (the area was under            123
                      cultivation), whereas a 1994 field investigation revealed four wetland areas totaling 12 acres.
                      At a site formerly called Villa Nueva or Rolling Hills 1, a small ponded area and a swale not
                      identified in 1982 and 1986 are now delineated as "wetlands" under standard criteria applied by
                      the U.S. Army Corps of Engineers.    124  .

                              Previous efforts to inventory, locate, and delineate all of the area's wetlands have been
                      incomplete. To date, the wetland location map provided in this report is the most comprehensive
                      listing of all of the area's wetlands (see Figure 5-2, page 75). Yet, there is no single repository
                      for wetland delineation maps. The U.S. Fish and Wildlife Service began a national wetland
                      inventory program, the National Wetland Inventory, in the 1970's@ Although all of the ReCAP
                      area in Monterey County was inventoried, only about 50% of Santa Cruz County has been
                      inventoried. 125 ReCAP identified 99 wetlands totaling about 6200 acres based only on staff
                      review of the -literature and aerial photography interpretation. However, some of the wetlands
                      identified by ReCAP staff are not shown on the National Inventory maps. Further, only 59
                      wetlands (6 1 %) were identified in the aggregate by background work done in the late 1970's to
                      the early 1980's for the Local Coastal Programs (Table 5-13).

                              It should be noted, however, that the wetlands not identified in the LCP documents are
                      comparatively small, representing only about 3% of the total wetland acreage. The categories of
                      wetlands identified by ReCAP, but not in the LCPs, include:

                              small stream mouths blocked by summer beach sands (e.g., Seabright, Borregas, Los
                              Barancas, Pescadero).

                              small ponds (e.g. Marina Vernal Ponds 8-11).

                              seasonally wet areas (e.g. Terrace Point Lower and Upper ponds).
                      The existence of some of these wetlands became evident through the regulatory process.
                      Generally, they were noted in environmental impact reports or in biological investigations that
                      were based on actual field work.

                              The wetland regulatory process would be improved if coastal managers had direct access
                      to a complete inventory of wetland resources. Development of such an inventory will necessitate
                      detailed field work. In turn, successful field work would require manuals and training to identify
                      appropriate indicators, as well as the necessary time, maps, and other tools to perform a complete
                      delineation. Ultimately, wetland management would benefit if all the region's wetlands and their
                      component habitats were named and accurately mapped on a computerized Geographic
                      Information System (GIS) directly accessible to all.

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                                              Table 5-13: LCP Weiland Identification

                  ..J insd di  .. ....... .. .
                                      .... .. .. ......
                         ...                  Wied:,b  @:::*Jd- entiflo: d
                                              It
                                         en i                                            t;
                                                                             Ve .... am.,.s:ilgq @:
                    .......                            ...... .......                             glires:
                    .... ........
                                                             ocumen s          ell 1@ te :sin
                         ......               CAP
                                       ........ .............
                @@:XXX:::::: :::X                                 ....... .... ....
                   .............                                                  L
                                                                  -XXI ....... _XX         Im H
                    ..........
                                                                  ............
                                         ..........                           d
                                    . . . . ......
                Santa Cruz                    42                  27               15             yes
                County
                Santa Cruz City               11                  6                5              yes
                Capit(@ia-                    I                   I                               yes
                Monterey County
                 Carmel Area                  2                   1                1              yes
                 North County                 23                  10               13             yes
                 Del Monte Forest             6                   5                1              yes
                Marina                        7                   6                1              no
                Seaside                       2                   2                               no
                Pacific Grove                 3                   1                2              no
                      k.LS                    97                  59               38
                Notes: Two wetlands in Fort Ord are not within any LCP jurisdiction, thus bringiRg the total to 99. since 71 of the @!ity of
                Watsonville's coastal zone wetlands extend into Santa Cruz County as well, they are included under the County entry; wetlands in
                more than onejurisdiction were counted only once. Watsonville also requires subsequent delineations.
                &amp;fimiational Requirements
                       In order to increase ease of access to available information, improvements could be
                made in how information is collected in the regulatory process. Also, ensuring timely and
                complete information from all permit applicants will assist coastal decision makers in providing
                a prompt, fair and thorough review. To foster a scientific basis to regulatory actions, it is also
                important that the information is prepared by qualified persons.

                       ReCAP encountered a range of informational requirements for projects involving
                wetlands and varying responses. For example, 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 from 1983-
                1993 'involving the region's wetlands have been found exempt from CEQA provisions. The
                Coastal Commission staff recently completed a Wetlands Procedural Guidance Documentfor
                the Review of Wetland Projects, which lists items that should be included in permit
                applications" 26 Santa Cruz County has a tiered system. Initially staff performs a biotic
                evaluation and based on the results, may then require a more thorough biotic report prepared by
                                   127
                a technical specialist. Monterey County's Local Coastal Program appendices spell out
                required contents of biotic reports. Such reports are required for sites containing or adjacent to a
                wetlarad. A cursory review of biological reports submitted with local and Coastal Commission
                permit applications showed a wide range in content.
                       In reviewing authorized developments, ReCAP found that monitoring requirements for
                restoration and mitigation projects varied greatly. Out of 39 projects, 20 required monitoring
                and 6 apparently did not (the record was unclear for the remaining 13 projects). The most
                common monitoring period was 5 years. Although thorough evaluation of the scope and
                effectiveness of local monitoring programs was not attempted, a common finding of a
                preliminary review was the lack of appropriate information includin
                                                                              12§ goal statements, baseline
                condition presentations, and as-built descriptions and assessments.ICurrently, the U.S. Army
                Corps of Engineers has thorough monitoring report guidelines. 129 These guidelines could be
                used by other agencies who currently lack them. The Coastal Commission is currently

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                                                                                          CHAPTER 5 - WETLANDS

                    developing a procedural guidance document that provides information useful to developing
                    wetland monitoring plans.

                           Reports submitted with permit applications and monitoring reports typically present only
                    project-specific information (see Water Quality and Biodiversity sections of this chapter and the
                    Coastal Commission's Elkhorn Slough Watershed monitoring report 130 ). As a result, cumulative
                    impacts on wetland systems are difficult to quantify. Overall biodiversity or water quality may
                    be declining in a wetland system, while the specific plant species that a project was required to
                    protect or enhance may be flourishing, or the specific discharge that a project was required to
                    control may be lower in concentration than the ambient condition. Ultimately, agreement should
                    be reached on specific standardized indicators and protocols for all required project and
                    monitoring reports.

                    Systematic Presentation Allowing Cumulative Impact Fin-dLng
                           The background section to this chapter illustrates a systems diagram for wetlands (see
                    Figure 5-4, page 79). Depending on the complexity of a project, analysis should assess how the
                    project impacts each component of the system. A systematic understanding is also necessary to
                    recommend and to evaluate appropriate alternatives or mitigation measures. Watersheds would
                    typically define the outer system boundaries. As is the case for wetlands, common identification
                    and descriptions of watersheds is lacking in the region.  131

                           A review of 20 coastal permits involving development in and adjacent to wetlands in the
                    Live Oak area of Santa Cruz County revealed that analysis focused almost exclusively on the
                    subject project and site. As illustrated in Table 5-14, there was little discussion of the project
                    areas in the context of the wetland system and hence potential cumulative impacts to wetlands
                    were rarely addressed.

                          Table5-14: Cumulative Impacts Analysis Characterization in the Regulatory Process(Live Oak Area)

                                                        ......... ... .     ...... .... ..
                                                  ........ ......  id ..... .... @@Ti
                                                   t::An  -018:                           h: Pem
                                ..Cumu 9. Jive: I                                             ... ... if--@@
                                                PAP:4,
                                             -d'-.,.,-'-..- @ -, -.- :::::: ....... .... .... ..
                                            . .. .. ... .. ........ .. .... .....
                                                          ... ...... .... .. . .... ..
                                  .. ... .. ..  ...... .... .. .... .. ......  ....
                                            .. .... ... ... ..
                                                                                        -.71 ftj
                                     ...... . ... . .... . .....          ......
                              Generally characterized entire wetland      3             0
                              Discussed other projects in wetland         2             0
                              Related the project to entire wetland system2             1
                              Analyzed watershed/cumulative impacts       3             1
                             *This column reters to other inlo"rmation contained in tiles, such as Environmental Impact and biotic reports.
                             Complete local files (N=13) were not available for review. Projects with Negative Declarations stating that there were
                             no cumulative environmental impacts without any elaboration are not included in the tallies.
                           In other cases, more extensive analyses of cumulative impacts have been attempted.  132
                    One notable example is at Neary Lagoon where a massive wastewater treatment plant was
                    proposed adjacent to the wetland. As indicated in Figure 5-6 (page 92), this proposal followed a
                    series of other adjacent developments. The project's EIR qualitatively attempted to discuss the
                    cumulative effect of these structures which "walled" in the lagoon bird habitat. 133 In other cases,
                    cumulative impacts have been addressed (in a limited sense) but the mitigation deferred. For
                    example, permits allowed immediate culvert repairs coupled with the longer-term development
                    of monitoring and/or management plans.

                           Cumulative impact analysis has also been employed in the regulatory process for two
                    wetland watersheds. At Valencia Lagoon, a breeding pond for the endangered Santa Cruz long-
                    toed salamander, the total amount of potential development was analyzed. As a result, each
                    individual project had to conform to measures intended to mitigate cumulative effects. At
                    Elkhorn Slough, development was supposed to stay within targets designed to prevent

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                 cumulative erosion problems. Until these targets were developed (as part of the local coastal
                 program process), new subdivisions were denied, pursuant to the cumulative impact provision in
                 Coastal Act Section 30250(a).

                         While comprehensive wetland and watershed planning can best address cumulative
                 impacts (see last section of this chapter), regulators meanwhile. develop and use limited
                 cumulative impact information in reviewing individual projects, as these examples illustrate.

                 Aggenj@ , Information Sharing and Coordination
                         Coastal managers can use existing resources more efficiently by sharing information and
                 expertise. Efforts have begun in the pilot region to do this, through ReCAP, the Monterey Bay
                 Initiative and the Coastal Aquatic and Marine Projects Information Transfer System (CAMPITS)
                 program. Development of further mechanisms to share information about other agencies'
                 actions and to increase coordination prior to decisions can improve wetland management.

                         There are some examples of intergovenirriental coordination mechanisms that are useful
                 in resolving potential wetland management problems before much project design and investment
                 has occurred. For example, the U.S. Army Corps of Engineers holds voluntary, monthly
                 interagency meetings (before applications are filed) for projects requiring Corps' Section 404
                 permit,,,. The Department of Fish and Game, Environmental Protection Agency and other
                 appropriate agencies are invited and usually attend; the Coastal Commission is invited for
                 projects in the coastal zone. Roughly 25% of the applicants to the Corps take advantage of these
                                                                                       3
                 pre-filing meetings, with a higher attendance rate for larger projects.' " Although exact figures
                 were not gathered, a: number of coastal permits involving wetlands have been the subject of these
                 interagency meetings. In other cases, coastal planners often make informal contact with other
                 agency personnel, but no tabulated accounting of such contacts is available.

                         After the Coastal Commission approves a permit involving a wetland, it typically
                 conditions permit issuance to receipt of other agency permits, such as those of the Department of
                 Fish and Game and the U.S. Army Corps of Engineers. In contrast, very few locally-issued
                 coastal perTnits are conditioned for receiving other agency approvals.

                         In the absence of consolidated wetland project review, coastal managers can continue to
                 improve their information base by increasing and formalizing interagency contacts.   135

                 Acce to &amp;_dwlogical and Biologkal &amp;,pertise and Tra
                         Some level of scientific training is desirable for staff involved with the planning,
                 regulating, or managing of wetlands. For example, in order to identify wetlands, a certain level
                 of biological expertise is necessary. In order to understand the wetland Ustem components
                 discussed in this report, knowledge of hydrology and biology is helpful."" A basic knowledge
                 of these factors and relationships is helpful in suggesting the contents of environmental reports,
                 in developing alternatives and in making informed decisions. A review of coastal permit
                 applic.itions involving wetlands shows that many technical issues are posed. Out of 64 projects
                 in wetlands, 26 posed hydrologic issues. The majority of these involved culverts and/or
                 associated water control devices or sand bar breaching. A review of restoration projects,
                 discussed above, also showed technical issues present in determining success and suggesting
                 corrective measures.

                         Coastal managers could improve the ability to evaluate these technical issues by
                 increasing access to, and sharing, available scientific expertise and training. Currently, state and
                 local coastal managers seem to gain information and assistance in wetland science through
                 information in EIRs and the consultants preparing these documents, from the staff of state and
                 federal resource agencies and, in some cases, from Commission technical staff. In cases where

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                      biologic information is required, the providers have usually had biological training. A small
                      number of consulting firms with specific wetland expertise and experience now provide the bulk
                      of the technical information required by permitting agencies in the project area. For example, a
                      review of five projects with EIR's in the Live Oak area showed that the preparers of at least the
                      three most recent ones included biologists. 137 LCP requirements for wetland reports typically
                      specify preparation by a "qualified7 biologist. Technical consultation and information is
                      sometimes provided to coastal managers by staff of the Department of Fish and Game and the
                      federal resource agencies. Although the Department of Fish and Game (DFG) is a central source
                      of expertise for the Coastal Commission, DFG personnel availability has limited the number of
                      consultations in the region.

                              Given limited staff and resources, mechanisms need to be developed to make more
                      efficient use of existing expertise in wetland systems. Mechanisms to share staff and to develop
                      staff training programs and technical assistance programs can help increase access to, and
                      knowledge of, wetland management.    138

                      M&amp;rmation Storagg and Retriev
                              The greater the availability of useful information, the more informed staff and decision-
                      makers can become. Varied accessibility has resulted in an uneven approach to using relevant
                      information. Initial steps to improve access to available records were taken in the establishment
                      of the Coastal Resource Information Center in the Commission. Cataloguing and access to
                      available documents is ongoing, albeit slowly. Efforts are underway to make access to library
                      catalogues available from Commission computers. ReCAP examined over 350 documents from
                      Commission records concerning the area's wetlands, but less than 10% are catalogued in the
                      Coastal Commission's library to date. Setting priorities for cataloguing the reminder of these
                      documents would help accelerate access to this information. In the process of ReCAP, many
                      wetland-related reports prepared by other agencies or academicians were discovered that were
                      not known to or ava 'ilable to staff or decision-makers. The same wetlands may be identified by
                      different names and in different ways, thus making comparison among reports difficult. Maps of
                      individual wetland are scattered among these different sources and are of varying scale and
                      quality. It is apparent that there is a fair amount of technical information existing which would
                      help coastal managers and decision makers if it were more directly available.

                      Emerging: informational Improvements
                              The above analysis suggests several areas where information or its use can be improved.
                      Fortunately, some improvements are emerging as discussed in the following examples.

                              One agency, the Department of Fish and Gwne, is comprehensively reevaluating its
                      programs. The Coastal Commission has recommended increasing information exchange and
                      increasing input on coastal permit decisions from that Department as a way to improve
                      implementation of the CCMP.    139 The Clean Water Act allows for state assumption of some
                      Corps permitting functions in wetlands. While this progarn has generated controversy and is not
                      necessarily recommended for California, pursuit of the concept may lead to protocols for better
                      utilization of expertise and information among state and federal agencies. 140

                              With regard to mapping wetlands and watersheds, the Coastal Commission has available
                      computer hardware and software that should eventually enable the storage and retrieval of such
                      information. Some local governments have such capability, but none has a complete file of
                      computerized wetland identification maps. The State Department of Forestry and Fire Protection
                      is digitizing watershed boundaries for the whole state. Santa Cruz County plans to name its
                      delineated watersheds and perform further, more individualized watershed mapping. The
                      Commission could play an important role in coordinating these efforts.

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                         ReCAP developed a computerized wetland database to summarize information on
                 permits, morphological, physical, chemical, biological, bibliographical, and basic attribute
                 inforination that it has reviewed. After the database modules are completed and an operational
                 guide -written, the database will offer an opportunity for agencies and the public to use and
                 exchange the available information.

                 li;&amp;Mikion  .al@Relationshi   T 6"W 6flaindPlannifigan  d M  nage rhient:
                                            ps                              a
                         Not only will improvements in the flow of information directly assist wetland
                 management and regulatory decision-making, its use in the planning process may lead to
                 improved decision-making. The wetland and watershed management planning processes
                 described in the following section of this chapter can base recommendations on compiled and
                 analyzed information. The resultant plans thus provide the context on which to base future
                 decisions. For example, a plan may describe an optimal wetland system, including restoration
                 areas and standards. A subsequent applicant could then incorporate such provisions as project
                 mitigation. 141 Planning also offers an avenue through which to address cumulative impacts.
                 Planscan set maximum densities or coverages or requirements that assure cumulative impact
                 thresholds are not exceeded. Individually permitted projects then have to simply comply with
                 these requirements without the need to generate extensive original cumulative impact
                 information. In the above-mentioned cases for Valencia Lagoon and Elkhorn Slough, such
                 provisions were incorporated into the local coastal programs. While regulatory evaluation may
                 still be necessary afterplanning is complete, it could be performed within a pre-defined context
                 relying on directly available information. Acceptance of such plans by all agencies with
                 regulatory authorities might lead to future efficiencies in the decision-making process itself.

                         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 logical next step would be to identify an appropriate regional
                 framework for wetland information compilation and dissemination.

                                               4_1 pwl                                  NOME
                 NREM-4

                 Pro  a
                    91 M-1171movdMents
                         Revise local coastal programs to:
                         *   require evidence of obtaining necessary U.S. Army Corps of Engineers and
                             Department of Fish and Game permits for wetland projects before final issuance of
                             local coastal permits;
                         *   develop ways to encourage applicants with wetland projects to participate in U.S.
                             Army Corps interagency meetings;
                         *   require identification of possible wetland areas in addition to those inventoried,
                             where such procedures are currently lacking (i.e., Pacific Grove, Marina, Seaside,
                             Monterey City, Carmel-by-the-Sea); and
                         *   specifically require cumulative impact findings for any project proposing to
                             adversely impact a wetland.
                         Revise local coastal program procedures (for the region's cities) to detail required
                         biological information for wetland projects.

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                                                                                              CHAPTER 5 - WETLANDS

                     Initial and Mid-Range Opportunities:

                     With regyrd to wetland and watershed identification:
                        *   Distribute summaries of the currently used 1987 Corps wetland delineation manual to
                            Commission and local government staff to understand how delineations they review
                            have been derived.

                        *   Make available other information on various delineation methods and attempts at
                            standardization to local government staff.

                        *   Utilize the CEQA/NEPA comment opportunities to ensure that wetlands delineations
                            using the Cowardin system are made.

                        *   Promote common identification of wetlands currently unnamed or with multiple names
                            to local governments and U.S. Board of Geographic Names.

                        *   Transfer identified wetland map information to a local government within the project
                            area using a Geographic Information System. Evaluate options for public display
                            (accounting for possible inaccuracies), and develop a protocol for future transfers to the
                            other local jurisdictions. -

                        *   Obtain a Geographic Information System program for the Santa Cruz district office; train
                            a district staff person to use it; and transfer available wetland delineations to it.

                        *   Promote common identification of specific and aggregated watersheds to local
                            govemments and regional authorities.

                        *   Assess the usefulness of the Div ision of Forestry and Fire Protection's digitized
                            watershed mapping project, offer the agency any appropriate information or comments,
                            and transfer to the Commission's computer.

                     With regard to information requirements:
                        *   Using the ReCAP wetland database, identify, request, and if necessary, use the
                            Commission's enforcement powers to obtain outstanding monitoring reports.

                        *   Revise the Commission's permit application form to incorporate the information needs
                            specified in its wetlands procedural guidance document.

                        *   Complete the Wetland Mitigation Guidance Document under the Project of Special
                            Merit using the U.S. Army Corps of Engineers "Habitat Mitigation and Monitoring
                            Proposal Guidelines" in the interim to secure necessary information.

                     With re,"r to cumulative impact information:
                        *   Apply ReCAP methods from this pilot project to ensure evaluation of cumulative
                            impacts in the permit process (i.e., the elements of permit analysis such as those listed in
                            Table 5-14 that address cumulative impacts); include directions for using the ReCAP
                            database in reviewing permits to determine past impacts and place current proposals in
                            context.

                        * In reviewing and commenting on any wetland management plans and in developing any
                            guidelines for wetland and watershed plan preparation, ensure that the plans include land

                                                    CALIFORNIA COASTAL COMMISSION                          PAGE 121
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              RECAP PILOT PROJECT

                      use, permitted use, parcel status, and other information to provide background for
                      cumulative impact analysis for future projects.

              With -,-Zqr_,d to intergg=-y Ln_formation shari=
                      Update, expand with local entities and academicians, and distribute the contact list of
                      wetland experts and regulatory staffs involved in wetlands.
                      Make the ReCAP wetland database available and provide manuals and training in its use.

                      Invite other agencies to meet to develop a common guidance document concerning what
                      it takes to develop in wetlands, integrating all requirements.

                      Conduct ajoint study review with the U.S. Army Corps of Engineers for a permit
                      involving a wetlands (i.e., accept applications simultaneously, coordinate on analysis,
                      issue simultaneous recommendations consistent to the greatest degree possible).

                  *   In completing preparation of the Project of Special Merit wetland performance guidance
                      document, strive to achieve consistency with similar information requirements of the
                      U.S. Army Corps or Department of Fish and Game.
                  *   In reviewing and commenting on any wetland management plans and in developing any
                      guidelines for preparation of wetland and watershed plans, strive to have clear
                      descriptions of the review procedures for proposed future projects.

                  *   Continue to participate in the Department of Fish and Game's strategic planning process
                      in order to obtain more expertise devoted to wetland issues.

              With  ggaz:d to tra
                  *   Establish a training program on wetland issues with local government staff in the area
                      and make technical resource issues, especially polluted runoff, a priority for training.
                  *   Develop ways to expand use of the Commission's computerized mapping program
                      (ARCVIEW) to be able to map wetlands and watersheds and retrieve such maps for
                      future planning and regulatory use.
                  *   Revive and maintain the Wetlands Task Force and designate at least one person in each
                      office to be its wetland coordinator as a means of maximizing access to wetland
                      knowledge.
                  *   Derive a low-cost, on-going training program for Commission staff, especially the
                      wetlands coordinators.

                  *   Establish a procedure to use technical staff (either in house or from another agency) to
                      review EIRs and biological reports with wetland issues and expand to encompass at least
                      one study local government.

              ffitlu-egard to information stora= and retrieval.,
                      Maintain ReCAP's wetland and permit databases to improve tracking of mitigation
                      projects.

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                                                                                               CHAPTER 5 - WETLANDS

                         *   Establish a framework for a computerized Wetland Inventory to complement the
                             Commission's Access Inventory, with regard to required easements, deed restrictions,
                             etc.

                         *   Continue to organize, catalog, and disseminate watershed management information
                             under the Polluted Runoff Project of Special Merit.
                         *   Update the Commission's library circulation list of wetland journals and articles and
                             evaluate options for extending circulation to local government staffs.

                         *   Accelerate the cataloging of wetland documents in the Commission library and add and
                             catalog other related wetland documents gathered or identified by ReCAP to be
                             retrievable for future planning and regulatory uses.

                     Wetland and Watershed: Management Plans should:.
                             Include maps delineating wetland habitats.

                             Discuss the authorities of, functions of and interrelationships among agencies with
                             identified regulatory responsibilities.

                             Include cumulative impact analysis.
                             Identify the most threatened components of a wetland and determine a threshold to
                             ensure that either future development will not result in the threshold being exceeded or
                             measures will be implemented to reduce impacts to the threshold (if already exceeded).

                     Longer-Range Opportunities:
                         *   The Coastal Commission and other agencies regulating wetland development should
                             have access to an independent wetland biologist and hydrologist with sufficient time
                             budgeted for reviewing and monitoring wetland projects.

                         *   All agencies regulating wetlands should have a common set of delineation maps.
                         *   Options for coordinated wetland project review among all regulatory agencies should be
                             explored.
                         *   On-going training should occur to improve existing staff s expertise (e.g., how to better
                             review restoration plans) and to reach new,staff.

                     Opportunities for future. research:.
                         *   Review a sampling of biological reports submitted to the Coastal Commission and local
                             governments for completeness and accuracy and recommend criteria for more adequate
                             reports.
                         *   Use field inspection and interviews to determine success of area's wetland restoration
                             projects that have not yet been evaluated and suggest remedial actions.
                         *   Compare actions on allowed uses, buffers, mitigation ratios, etc. for a sampling of
                             projects that received Coastal, Army Corps and Fish and Game permits and recommend
                             coordinated, standardized requirements.
                     See also, the Information Management section of this report.

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<pb n="125" />

                  RaCAP PILOT PROJECT

                                        PROBLEM SEVEN

                                                                               .0                           N@
                                                                                                           n
                                                      fana-rumn
                        MAM

                           The lack of a comprehensive wetland and watershed management framework has led to
                  piecemeal decisions that do not fully protect the region's wetlands. In particular, individual
                  decisions made on projects in wetlands without comprehensive management plans cannot readily
                  account for cumulative impacts.

                                                                   F
                                                                   FT
                           The California Coastal Management Program's primary implementation mechanism
                  regulation under local coastal programs -- does not fully address the cumulative impacts to
                  wetlands identified earlier in this chapter. LCPs primarily address new development, whereas
                  ReC@&amp; found that in the pilot area, existing uses and activities are the more significant
                  contributors to cumulative effects. LCPs cover only the coastal zone, but activities throughout a
                  wetland's watershed may have substantial cumulative effects on wetlands in the coastal zone.
                  Many watersheds are bisected by the coastal zone; for some watersheds, only a small portion
                  resides within the coastal zone. LCPs are divided by political jurisdiction, whereas some
                  cumulative effects on wetlands are regional. LCPs primarily regulate the jurisdiction's land use
                  actions, and not typically the regulatory or management actions of other agencies with authority
                  over -wetlands (e.g., a@Department of Fish and Games decision to allow hunting in a wetland).
                  On die other hand, LCPs can set fairly specific land use standards, but are often not of the detail
                  needed to address many wetland cumulative impact concerns. Initiation of proposed LCP
                  amendments are at the discretion of the local governments, so new or more detailed wetland
                  initiatives are not automatically incorporated into an LCP.

                           Another complicating factor is that some wetlands or parts of wetlands remain under
                  Coastal Commission permit jurisdiction, even after local coastal program certification.   142 The
                  same regulatory limitations noted here that local governments operate under also apP4V to    the
                  Commission's permitting authority and to some extent, its federal review authority.       In some
                  cases, a project in or affecting a wetland may require two separate coastal permits -- one from
                  the Commission and one from the local government -- further fragmenting the decision-making
                  process. The preceding sections of this chapter conclude that new planning and management
                  initiatives at various geographic and jurisdictional levels are necessary to more completely
                  address the identified problems.

                  C'dh..;iderations..:fi6t-Wetia'nd.:.PI!Finitig::.4y.:'G:e:o' hiA
                                                                   grap.. 1c. rea::
                           Within the complex regulatory, ownership, and management milieu that affects
                  wetl.mds, a strategy to address both the broad and specific aspects of cumulative impact concerns
                  is already emerging in the pilot area. Four levels of planning and resultant management are
                  operating: by region, watershed, jurisdiction, and wetland. Another level, encompassing natural
                  communities, may become a factor. Building on this framework in the short-term and possibly
                  refining it in the longer-term offers a means to fiirther protect wedand resources.

                  R='on
                           The Monterey Bay National Marine Sanctuary's Integrated Coastal Management (ICM)
                  process is a particularly promising prospect for coordinating regional wetland planning and
                  a elm,

                  management in the project area. Through the ICM process, the various agencies with wetland

                  PAGE 124                         CALIFORNIA COASTAL COMMISSION
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                                                                                                   CHAPTER 5 - WETLANDS

                      management responsibilities could gather and disseminate information on all the area's wetlands
                      and respective watersheds; continue to analyze the identified problems, especially their
                      interrelationships in a regional context; prioritize problem areas needing attention; and guide and
                      coordinate solutions. Several states and regions are undertaking such an approach, including the
                      San Francisco Bay area, which may serve as useftil models.   144

                              To date, efforts to plan for wetlands on a regional basis in the Monterey Bay area have
                      been limited: U.S. Fish and Wildlife Service's National Wetland Inventory simply mapped
                      wetlands by habitat type for part of the area in the mid 1970's; Santa Cruz County's Parks,
                      Recreation, and Open Space Plan of 1972 identified many of the County's wetlands and
                      recommended that they be the subject of specific plans; the Coastal Conservancy reviewed the
                      status of wetlands in the area and listed 21 potential enhancement projects in 1979; the California
                      Assembly Resources Committee listed 24 project area wetlands and causes of acreage loss; and
                      Santa Cruz County's local coastal plan called for a (not yet established) task force to identify and
                      prioritize key restoration projects and available funding.-, 45 Currently, as part of state and federal
                      efforts to protect sensitive sites from oil spills, an inventory and protection strategy for the area's
                      tidally influenced wetlands is being developed. 146 Concurrently, the State prepared an Ocean  147
                      Resources Management Plan which includes a mapped inventory of sensitive managed areas.

                              The current ICM process is an interagency effort to protect Monterey Bay's water
                      quality, under the auspices of the Strategic Environmental Assessments (SEA) division of the
                      National Ocean Service's Office of Ocean Resources Conservation and Assessment.       148 As part
                      of the establishment of the Monterey Bay National Marine Sanctuary, a number of agencies,
                      including the Coastal Commission, signed a Memorandum of Understanding to prepare a water
                      quality protection program for the Bay. Using a computerized database, the ICM team has
                      gathered some available water quality and related information, including wetland characteristics
                      for 34 of the major wetlands in the area, and combined the data by aggregate watersheds.   149
                      Prioritization of problem areas and a resultant regional water quality plan are the expected
                      results. Altering its focus and possibly its structure (e.g. membership, time frame) to include
                      wetland issues besides water quality and to present its findings by individual watershed would be
                      necessary to accomplish the strategy envisioned here.

                              A logical next step would be to approach SEA and the ICM participants to discuss
                      whether they are interested in assuming this role. If not, other entities could assume the lead
                      effort, such as the Association of Monterey Bay Area Governments (AMBAG, the regional
                      planning agency), the U.S. Environmental Protection Agency, Watershed Ecology Outreach
                      Program, the Coastal Commission, or an interagency task force (which would require some
                      entity to take the lead in organizing it).150 Major players would also include academic
                      researchers, as much scholarly work on area wetlands could be shared with decision-makers;
                      private consultants, who have collectively amassed the most information on the area's wetlands;
                      and the public, including various user groups. If in the future regional governance emerges,
                      coordination of wetland protection efforts as described here could be one of its functions.

                      Watershe
                              At the watershed level, there is no uniform structure nor single entity with
                      comprehensive responsibilities to address cumulative impacts on wetlands; rather, ad hoc
                      advisory groups are forming for individual watersheds. Watershed planning and management
                      are critical to address activities, uses, and growth patterns that affect wetland hydrology and to
                      some extent biodiversity, as discussed in this chapter. 151 Watershed planning is becoming quite
                      popular as a means to address polluted runoff. 152 Wetland protection would be an integral, but
                      not exclusive component or objective of watershed plans, which could also address other issues,
                      such as flood protection and resource utilization.

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                  RECAP PILOT PROJECT

                          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, and recreation, scenic
                  and historic resources. 153 It originalll had no specific wetland component, but one was
                  developed in a subsequent process.  15  Two draft Carmel River Watershed Management Plans
                  were prepared covering many of the same topics as the San Lorenzo plan. 155 Watershed issues
                  continue to receive attention in the planning for a new dam on the Carmel River.   156 The North
                  Monterey County Land Use Plan was partially based on a watershed analysis to limit
                  sedimentation into Elkhorn Slough.'  57 Watershed planning programs are in the formative stages
                  for Soquel Creek, Pajaro River, and Elkhorn Slough. Four wetland based management plans,
                  including the one for Elkhorn Slough, and two which are under preparation, contain some
                  provisions that address activities beyond, but affecting, wetlands proper (but are not
                  comprehensive watershed plans).

                          The forthcoming watershed initiatives in the pilot area may occur under the auspices of
                  CRMP (Coordinated Resource Management and Planning). Sponsored by a range of state and
                  federal agencies, this planning approach

                          addresses the dilemma of managing areas with multiple-use ownership,
                          conflicting management objectives and requirements, conflicting land-use
                          demands, and offsite impacts  ... CR14P integrates and coordinates resource uses
                          to accomplish specific goals ... The process is designed to achieve compatibility
                          between the land and resource uses.. All resources are effectively managedfor
                          short-term and long@-term use andperpetuatedforfiture generations in a
                          condition of high quality. 1-58

                  In the future, more standardized and formalized watershed-based governance entities may
                  emerge which could assume the noted functions. In anticipation of increased watershed planning
                  activities, a logical next step would be continuing to review and enunciate appropriate procedural
                  and content options. As a start, each section of this chapter contains recommendations for topics
                  to include.

                  Wethod
                          At the individual wetland level, there is no set structure to address cumulative impacts;
                  rather, a variety of wetland management plans have been and are being prepared under varying
                  circumstances and auspices.  159 Wetland plans provide an opportunity to comprehensively
                  address and relate all wetland issues. Wetland management plans are broadly construed in this
                  analysis to comprehensively address regulation, management, acquisition, restoration,
                  enhancement, monitoring and the like for entire wetland systems. Table 5-15 lists some
                  elements common to wetland plans.

                          To date, wetland planning has been extensive. Nineteen wetland plans (some covering
                  multiple wetlands) have been or are being prepared (and another two are just underway).
                  Eighteen out of the 25 largest wetlands are covered. F60 However, as Table 5-15 indicates, these
                  plans are far from comprehensive. Out of the 11 noted topics which ReCAP found to be
                  important in managing cumulative impacts, the average number covered per plan is half (5.5);
                  with a range from 2 to 11. 161 Having standard guidelines for wetland plan contents could
                  improve the ability to manage wetlands.

                          To achieve solutions to all wetland problems, the planning process requires the
                  participation of affected owners and managers, as well as the public. 162 No one structure appears
                  best for management plan preparation; evaluation of the approaches used to date would be
                  instructive. 163 As noted, wetland plans can result in recommendations for action within
                  watersheds. Conversely, a watershed analysis can lead to wetland recommendations that more

                  PAGE_ 126                        CALIFORNIA COASTAL COMMISSION
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                                                                                                                                   CHAPTER 5 - WETLANDS

                              comprehensively address cumulative impacts. While logically it would appear that watershed
                              planning should precede (and provide the information base and parameters to) wetland planning,
                              the latter process is currently more advanced and easier to undertake because the geographic
                              scope is typically smaller. At this point, proceeding on both geographic tracks is worthwhile, as
                              long as there is openness to future amendments to ensure consistencies.                         164  If a regional
                              framework becomes operational, it could schedule and coordinate future wetland and watershed
                              planning efforts more efficiently.

                                                       Table 5-15: Frequency of Topics Included in Wetland Management Plans

                             . ...........
                                                                                         ]a: Hqw:ManVCWfi
                                                                                                                                 .. . .. ..........
                                                                                                                                       ..............  ... . .. . . ....
                                                                                                                            ..... ........ . . .. .. ..... .......
                                                                                                    ..... ..............   ........                    ......

                                                             ...... .... ........ .................
                                           .......       ..................                          ansf
                                                         ..... . ... .. .... ............... ......
                                                                                                                                .......  ......
                                                                                                               ..........
                               ..........   ...... ......                    .......
                               ..........
                             ................
                             --....-.......... ... ;.;, - ::                  1.1 1.1.1'..'..................... _1 I.. .... . ... . . .. ......... . . ..... ... . . .....
                                                                                 .. ... .... ....        . -  __ . , .               , ::_ - - - .... ....
                              Clear Objectives                                                           8                                      4
                              Permitted Uses Of/In Wetlands                                              2                                      0
                              Habitat Types Delineated                                                   7                                      5
                              Buffers/Adjacent Development                                               4                                      2
                              Policies
                              Public Access Provisions                                                   10                                     4
                              Public Education Provisions                                                5                                      4
                              Watershed-based Policies                                                   4                                      2
                              Hydrology/Water Quality Provisions                                         7                                      6
                              Habitat Improvement Provisions                                             10                                     6
                              _@pecific Implementation Schedule                                          5                                      2
                              Interagency Coordination Provisions                                        5                                      2

                              Jurisdiction
                                         At the City and County level, land use planning is universal; but, as noted, its ability to
                              address wetland issues is limited. In the pilot area local coastal program land use plans were
                              predominantly prepared in the early 1980's, prior to preparation of most wetland management
                              plans. As noted, LCPs are not at the level of detail of subsequent management plans. Local
                              coastal programs for Marina, North Monterey County and Santa Cruz City, for example, simply
                              call for preparation of wetland management plans, although lack explicit criteria for doing so.
                              Santa Cruz City recently amended its local coastal program to incorporate policies and excerpts
                              from its completed management plans; Monterey County, on the other hand, did not. 165                                  Because
                              many management plans were prepared pursuant to its enforcement and permit issuance
                              authority, the Coastal Commission formally reviewed them. Since most were not explicit
                              components of the LCPs, they have not been amended into the California Coastal Management
                              Program.     166  Future plans may not receive Coastal Commission review (or formal review) or
                              local jurisdictional review unless required as a condition of a locally-issued coastal permit or to
                              resolve an enforcement action.

                                         The CCMP requires local coastal plans to have land uses, intensities, and locations as
                              well as development criteria that result in wetland resource protection, consistent with Coastal
                              Act Sections 30231, 30233, and 30240. ReCAP found that the region's LCPs generally conform;
                              a few improvements can be made as recommended in this chapter. Subsequent wetland and
                              watershed planning can apply these LCP policy and use parameters, as well as other factors, and
                              arrive at a greater level of detail necessary to address wetland resource issues (as Table 5-15
                              indicates, many wetland plans to date lack a land/water use component). If a wetland planning
                              process results in recommended land use changes (e.g., decreasing maximum bare ground

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                 RECAP, PILOT PROJECT

                 exposure to prevent sedimentation into a wetland or maximum densities in areas served by septic
                 systenis to reduce nutrient loading), then commensurate, follow-up LCP amendments will be
                 required (as well as general plan revisions to cover beyond the coastal zone). Broader structural
                 changes in the CCMP, involving integrating watershed and wetland management planning and
                 implernentation within the local coastal program or another process, are worthy of evaluation.
                 This should be undertaken in the context of ReCAP's overall investigation of how the CCMP can
                 address all cumulative resource impacts.

                 IM I       tationAuthodw
                    p . em.e.n
                         A comprehensive wetland management plan will likely contain a series of
                 recommendations to address adverse cumulative impacts. Some of these may address
                 minirnizing impacts from new development (e.g., setbacks, erosion controls) that can be
                 incoiTiorated into the existing regulatory process. However, other recommendations may address
                 how to manage existing natural processes and existing development; for example,
                 recommendations to remove invasive vegetation, adjust existing tide gates, or sweep streets to
                 prevent polluted runoff. It will thus be necessary for wetland plans to identify appropriate
                 authorities and provisions. Since various authorities may be involved in implementation, they
                 should also be part of the planning process. As Table 5-15 notes, only 7 out 19 plans have
                 significant implementation components and interagency coordination provisions.

                         ReCAP identified the following complexities that affect implementation of wetland
                 management recommendations in the pilot area: private ownership, multiple ownership, public
                 authorities with competing mandates, extra area authorities, and inadequately constituted
                 authorities.

                 Priva e Ownersh('=':
                         Many wetlands appear to be at least partially in private ownership. 167 In some cases the
                 owner, is knowingly committed to wetland protection (e.g., the Nature Conservancy and the
                 Santa Cruz County Land Trust). In some cases owners have given easements to other entities for
                 management purposes. The extent of other private ownerships engaged in, willing to engage in,
                 or willing to let others engage in protective stewardship is unknown. A logical next step would
                 be to assemble an accurate picture of ownership status (including easement status) and intentions
                 for all of the region's wetlands including their buffer areas. Also, dissemination of general
                 information on private protective stewardship options for wetland owners need not wait for a
                 formal planning process.

                 MmJQ@le Ownershim and Rg@ponsibilities
                         A second management complexity involves multiple ownerships and responsibilities. At
                 least 1. 1 wetlands are under multiple ownership -- some of these involve a mix of public and
                 private holdings. An example of the management dilemmas encountered with multiple owners
                 involved Lower Bennett Slough. The Slough is separated from Moss Landing Harbor North by a
                 roadwith culverts, which failed in the 1989 Loma Prieta earthquake. Moss Landing Harbor is
                 under public trust authority by the harbor district. The road is owned by the County; the lower
                 Slough, by the Department of Parks and Recreation and private parties; and the crossing to the
                 upper Slough, by CALTRANS. Since the proposed repair prpiect affected the wetland
                 hydrology, all of these ownerships were potentially affected.'" After much discussion
                 agreement was reached on a project that could be adjusted in the future if a comprehensive
                 wetland management plan is ever developed.

                         Beyond ownership, many agencies have management responsibilities which affect
                 Monterey Bay's wetlands. These are not necessarily the same agencies with regulatory
                 responsibilities. Even in the case of a single owner undertaking its own project, other agencies

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                                                                                                  CHAPTER 5 - WETLANDS

                      may be involved in regulation, funding, and the like. For example, at Laguna Grande, the three
                      primary owners, the cities of Seaside and Monterey and the Monterey Peninsula Regional Park
                      District, united under ajoint powers agreement to undertake a restoration project. Five other
                      agencies also played significant roles. T69

                      Public Authorities with ColUpeting Mandates
                              While some wetlands are owned by public agencies and managed for resource purposes
                      (e.g., at least 16 wetlands are owned by the Department of Parks and Recreation and many have
                      been placed in Natural Preserve status), a few portions of wetlands are owned by CALTRANS,
                      Port Districts, or local governments who have placed management under public works
                      departments. These agencies' stated missions (e.g., flood control, transportation) often conflict
                      with resource management objectives. And, in the cases of breaching coastal lagoon mouths
                      mentioned above, the responsible public agencies are other than the actual owners.

                      Extra-area Authorities
                              This chapter has documented instances of development occurring outside of, but
                      affecting, wetlands. In the cases of dams on the Carmel, Salinas, and San Lorenzo Rivers, for
                      example, the managing authorities do not own the downstream wetlands.

                      Inadequately Constituted Authorj&amp;
                              As solutions to cumulative impacts are developed, the logical implementing entities may
                      not exist, may lack authority to fully carry out the recommendations, or may not be adequately
                      constituted to perform the required tasks (e.g., may lack staffing, budget, equipment, training,
                      motivation, etc.). In North Monterey County, for example, a preventative program is in place to
                      clean up soils eroded onto roadways so they will not wash into Elkhorn Slough and then bill
                      property owners for costs. However, program evaluation discovered that soil is sometimes left
                      on the road and that property owners are not always billed. The responsible agency operates the
                      program for traffic safety, not environmental, purposes and lacks staff time and funding. 170 In
                      Santa Cruz City, the Neary Lagoon Management Plan presented a series of recreational, water
                      quality, and habitat management improvements and identified various city departments with
                      authorities to undertake them. 171 However, what was missing was an entity with authority to
                      oversee and coordinate implementation. To remedy this long-standing problem, the plan
                      recommended creating a coordinator position, which was subsequently authorized, funded, and
                      filled. In turn that coordinator has engaged students and volunteers to perform identified tasks
                      that city departments were constrained in performing.

                              As each wetland is likely to have different management needs, it will be incumbent upon
                      the development and subsequent monitoring of each plan to identify detailed implementation
                      strategies. In some cases, identifying new or restructured authorities or positions, with proper
                      funding, training, and the like may be necessary.

                      Conclusion
                              In conclusion, planning for wetland resources requires an understanding of the
                      relationship of all the system components and the effects on them as illustrated in Figure 5-4
                      (page 79). It then requires responses that address all of the topical issues at the appropriate
                      geographical levels -- wetland, watershed, region, and jurisdiction. Likewise, knowledge of all
                      the responsible and needed authorities, and a commensurate implementation strategy is
                      necessary to carry out planned long-term management and restoration.

                              Addressing the information gaps in the decision-making process at the project level
                      would also assist comprehensive plan preparation and implementation. Maintenance and use of

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                 a computerized, regional database to enable easy access to ownership, management, project
                 status., watershed locations and similar information for each wetland, such as developed by
                 ReCAP staff, would support and further the identified wetland planning -initiatives.

                 Prog!:ram Im
                             prbVem.ents:%...::
                         Prepare a guidance document as to contents of wetland and watershed management
                         plans, based on recommendations in each section of this chapter.

                     0   Prepare the following plans for the following wetlands of particular concern:

                             Carmel River Lagoon Enhancement Plan.

                         *   Coastal/Vernal Ponds Comprehensive Management Plan (all marina Vernal Ponds).

                         *   Moro Cojo Slough Management and Enhancement Plan.

                         *   Pajaro River Lagoon Management Plan.

                         *   Salinas River Lagoon Management and Enhancement Plan.
                         *   Wilder Ranch Wetland Restoration Plan. 172

                     0 Develop a schedule to prepare additional wetland and watershed management plans.

                     0 Revise local coastal programs to:
                         *   require the preparation of wetland management plans, where such provisions are
                             lacking.
                         *   incorporate standards for preparing and reviewing the adequacy of wetland
                             management plans.
                         *   incorporate policy provisions and other excerpts of completed wetland management
                             plans.
                         *   require harbor districts to update environmental management components of their
                             harbor plans.
                     a   Coordinate and link existing authorities, via a memorandum of agreement, to oversee a
                         regional wetland watershed protection and enhancement strategy to, at a minimum:
                             identify wetland and watershed systems and their relationships.
                             schedule future wetland and watershed planning and restoration programs.

                             seek and coordinate funding for implementing the strategy.
                             address regulatory options within and beyond the coastal zone.
                             provide technical assistance to those entities involved in implementing the strategy
                             and acting as a liaison with the academic community studying wetlands.
                             identify entities responsible for wetland protection and encourage and coordinate
                             efforts where multiple authorities are involved.

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                                                                                              CHAPTER 5 - WETLANDS

                                monitor success.

                    Initial and Mid-Range Opportunities:
                            Complete, maintain, and improve ReCAP's wetland and permit computerized databases
                            and prepare an operational manual to allow their use in future planning programs;
                            elements to emphasize include ownership and management authorities and geocoded
                            locations of wetland projects.

                     With reggrd to a regional-framework.
                        *   Coordinate with National Oceanic and Atmospheric Administration's Strategic
                            Environmental Assessments (SEA) division to share relevant information among its
                            databases and the Commission's and local governments' databases.
                        *   Continue participation in the strategic planning process and water quality protection
                            program and discuss with the participants the recommendations in this report related to
                            wetland and watershed planning.
                        *   Convene (or entice the ICM program or another entity to convene) a workshop or series
                            of workshops on the status of the area's wetlands and solicit ideas for comprehensive
                            planning, including using the ICM to guide implementation of this report's
                            comprehensive planning and management recommendations. Initiate necessary follow-
                            up (e.g., memorandum of agreement, further workshops, funding requests), based on the
                            results of such workshops.
                        * Participate in efforts to prioritize future wetland and watershed planning based on
                            identified issues and pending projects.

                     With re,gffd to watershed managgment planaj=
                        *   Work with other agencies to promote watershed planning and participate in working
                            groups and conferences to further this objective.
                        *   Be involved with legislative initiatives for watershed planning.
                        *   Evaluate options for implementing recommendations involving coastal wetland
                            watershed issues beyond the coastal zone.            I
                        *   Work with Monterey County in preparing a watershed management plan for Elkhorn
                            Slough under the Polluted Runoff Project of Special Merit and CRMP.

                        *   Actively participate in the Soquel Creek and Pajaro River watershed planning programs
                            now underway.

                        *   Continue to review dam proposals in the context of, and advocate for, comprehensive
                            planning for the Carmel River watershed.
                        *   Seek funding to prepare a guidance document on the preparation of watershed
                            management plans and the relation Of such plans to individual wetland plans.
                        *   In participating in the development of or in reviewing any wetland management plans,
                            seek to have the whole watershed addressed.

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                 R21hie "ar to wetland mana,ggment.planning@
                      *  Evaluate procedural and participatory options for preparation of wetland management
                         plans (i.e. the process for and participants to preparing the plans).
                      *  Evaluate options for requiring easements over wetlands and buffers as a condition of
                         new development on parcels containing wetlands.
                      *  Outline procedural and topical requirements for future wetland management plan
                         preparation (see other sections of this chapter for topical recommendations).
                      *  Evaluate options to determine when permitted work in or affecting wetlands will trigger
                         a management plan preparation requirement.
                      *  Participate in the on-going wetland management planning programs.
                      *  Evaluate options for requiring wetland management plans to be incorporated into the
                         CCMP (e.g., through the LCP amendment approval process or some other process).
                      *  Perform more in-depth analysis of effectiveness and adequacy of existing wetland
                         management plans.

                 M&amp;xemd- to managment authorities:
                      *  Gather information on wetland stewardship and disseminate to private wetland owners.

                      *  Inventory all required easements (e.g., scenic, conservation) over wetlands and buffers
                         (as identifiedin the ReCAP wetland database), strive to have recorded any not yet
                         recorded, identify possible receiving agencies and incorporate into the computerized
                         Wetland Inventory.
                      *  Identify and pursue with the relevant entities the possibility of assuming management
                         responsibilities for wetland areas under easement offers.

                      *  Complete entering ownership information in the ReCAP wetland database.

                Wkiiind 91 hd.Vatemhed manag,emen .:p ans,should,
                      *  List appropriate management authorities and a schedule for implementing any
                         recommendations.

                      *  Address interagency coordination where multiple responsible authorities are ident ified.

                ,0ver.th6166 qileftn.
                         Management plans should be completed and implemented for all watersheds, according
                         to a regionally established schedule. Thereafter, plans should be evaluated and updated
                         on a regular basis.
                         Management plans should be completed and implemented for all wetlands; plans may be
                         for single wetlands or groupings (in some cases for small wetlands with sufficient
                         watershed plans, the latter could include a detailed wetland component). Plans should be
                         evaluated and updated on a regular basis.
                         Wetland management plans should be revised to be consistent with their associated
                         watershed plans.

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                                                                                                                          CHAPTER 5 - WETLANDS

                                 0    Local coastal programs should be revised to incorporate the results of any regional
                                      watershed and wetland planning program.
                                 0    If regional governance entities are created (e.g., a joint powers authority), they could
                                      assume responsibility for implementing the proposed regional wetland strategy.
                                 0    Watershed governance entities that may be created could assume responsibility for
                                      preparing and implementing watershed management plans.

                                 0    Wetland and watershed management planning procedural guidelines should be refined
                                      and incorporated into the CCMP.

                                 0    Natural communities should be geographically defined and the recommended wetland
                                      planning framework be adjusted accordingly.

                             Opportunities for further study:
                                 * Identif@ the region's natural communities.

                                 *    Evaluate success of pioneering watershed planning exercises and offer recommendations
                                      for future efforts.

                             1 See, for example discussion in Chapter I of California Coastal Commission, Procedural Guidance For the Control of
                              Polluted Runoff. 1995.
                             2Williams M. Understanding wetlands. Pages 1041 in M. Williams [ed]. Wetlands: A Threatened Landscape.
                              Alden Press Ltd., Oxford, England. 1991.
                             3For more detailed discussions of individual regulations see Environmental Law Institute. Wetlands Deskbook.
                              Washington D.C. 1993
                             4Dennis, N.B. and M.L. Marcus. Status and Trends ofCalifornia Wetlands. Final report prepared for the California
                              Assembly, Resources Subcommittee. 1984.
                             5Note that diagram does not necessarily reflect the sequence of project review.
                             6Note that the "coastal zone" as defined in the Coastal Act does not include San Francisco Bay, which is the
                              jurisdiction of the Bay Conservation and Development Commission.
                             7Allowed uses within wetlands include: port-related and coastal-dependent industrial facilities; maintenance dredging;
                              mineral extraction (except in environmentally sensitive areas); restoration projects; nature study, aquaculture, or
                              similar resource-dependent activities; and incidental public service purposes such as utilities.
                             8 Since local coastal programs were certified, predominately in the early 1980's, they have been amended, in regard to
                              wetland issues, at least forty times in the aggregate, In many cases, the amendments facilitated development
                              adjacent to wetlands, both private and public (e.g., a park, wastewater treatment plant). On balance, the overall
                              result is slightly more intense development around wetlands; but in some cases, lower adjacent intensities have
                              resulted. In only two cases, did the amendments result in development in wetlands; one for a landfill, one for a
                              school. In these cases, "riparian" rather than wetlarid loss was acknowledged and compensating mitigation was
                              incorporated (see Problem One section of this Chapter). In general, local coastal program wetland provisions have
                              remained largely in tact since original certifications. California Coastal Commission. ReCAP database. Wetlands
                              and Local Coastal Program modules.
                             9The number and nomenclature of the project area wetlands is somewhat arbitrary. For example, the Independent
                              Report on Environmental Considerationsfor the Marina Freeway (Caltrans, 1973) and subsequent Environmental
                              Analysisfor the Coastal Zone of the City ofMarina (Biosystems Analysis, San Francisco, 1980) identified a wetland
                              impacted by the new Highway I as Marina Vernal Pond #6. Three nearby ponds were identified as Marina Vernal
                              Ponds #9, 10, and 11. Years later, a Coastal/Vernal Pond Comprehensive Management Plan (Habitat Restoration
                              Group, Felton, 1993) fails to identify Pond #6 (which still exists) and instead calls Ponds #9-11 "Pond #6."

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                          Some connected water bodies have been given different names (e.g., Laguna Grande and Roberts Lake) and hence,
                          in scme cases, are listed as separate wetlands in the California Coastal Commission ReCAP wetland database. On
                          the other hand, there are some connected water bodies or discernible components that are listed as a single wetland
                          (e.g., Elkhorn Slough which includes such components as South marsh, North marsh, and Blohm Porter marsh).
                          Separate water bodies are usually listed separately (e.g., Marina Vernal Pond #I and #2, etc.), but occasionally are
                          grouped under one name, especially when they were likely once connected (e.g., Pajaro River mouth includes the
                          small seasonally wet pond to the south). Riparian areas were generally not listed unless they were specifically
                          described as wetlands in the literature, a trend that has been increasing in recent years. Detention ponds, golf course
                          ponds, and other artificiaRy created water bodies are not listed.

                          This exercise identified as wetlands four sites that would require on-site biological evaluation to arrive at a final
                          deteirmination: Indian Head and Fort Ord Pond in the Fort Ord dunes, Pacific Grove Municipal Golf Course swale,
                          and DeAnza Mobile Estates pond.
                          As R eCAP progressed and new field delineations were made, additional small, non-tidal areas were determined to
                          be wetlands. Although within the already listed wetland systems, they are disjunct and could merit separate
                          nomenclature and database entries. In addition to those noted by Moro Cojo Slough (see Endnote #130), these
                          include: an acre wetland behind an old concrete spillway on Wilder Creek about one mile above the lagoon
                          (acCDrding to Short, Rob and Brown, Kathy, Wilder Creek Watershed: Facts, Photos and Fish Barriers, UCSC
                          papcr for ENVS 167, Santa Cruz, Spring 1994); a freshwater seep adjacent to Old Dairy Gulch (and three others on
                          its tributaries) about one mile above the lagoon (according to Jones &amp; Stokes Associates, Wilder Sand Quarry Draft
                          EIR., Sacramento, August 1994); and a half-acrc native marshy slope on a bend of Moore Creek about one mile
                          above Natural Bridges Lagoon. (according to Strelow, Stephanie, Sphere ofInfluence Amendment, Local Coastal
                          Progyrant Amendment, General Plan Amendment, and Prezoning of Meder Street Properties, Revised Draft EIR,
                          Sawa Cruz, December 1990, p. 28.)
                          '0 California Coastal Commission, Cartographic Unit. ReCAP Photo Interpretation Notes, 1994. These results are
                          based on an analysis of wetland acreage in the ReCAP project area using the following methodology: the
                          identification and subsequent acreage determinations of wetlands in the project area were completed via manual
                          interpretation of the Coastal Commission's existing vertical color aerial photographs obtained in 1977-78, 1986, and
                          1993. The nominal scale of the source photography is 1:32,500 (1 inch equals approximately 2,700 feet) for 1977,
                          and 1: 12,000 (1 inch equals 1,000 feet) for 1978, 1986, and 1993. Aerial photographs covering each wetland area
                          were examined stereoscopically, and detailed notations were made. Remarks were predominately qualitative,
                          however, in certain cases approximate measurements of length and area were made for purposes of comparison.
                          Although the resolution of the aerial photographs will readily allow detection of linear changes of less than 50 feet,
                          and area changes on the order of less than an acre, the images are not rectified (i.e., free from geometric distortion),
                          nor are they orthogonal (i.e., planimetrically correct). Therefore, the results are considered approximations,
                          appropriate for rough assessments of change only. In addition, other factors such as vegetation composition,
                          se&amp;,;onal changes, time of day, tidal stage, sun angle, film type, and aircraft position all affect the ultimate content of
                          the image and its utility for wetland analysis. A limited number of wetlands in the pilot area were visually inspected
                          in 6e field as a means of corroborating photographic analysis; however, these site visits were generally of a
                          reconnaissance nature, and involved no actual surveying.
                          11 Tro phic dynamics relates to the sources, sinks, and flux of energy within a wetland and the translation of that energy
                          into new individuals. This process is most straightforward for plants using measures of primary productivity.
                          12 Johnston, C.A. "Cumulative Impacts to Wetlands". Wetlands. 14(1)49-55. 1994.
                          13 Tiner, Ralph W. Jr., Wetlands ofthe United States: Current Status and Recent Trends, for U.S. Fish and Wildlife
                          Service, Washington, D.C., 1984 notes the net loss of approximately nine million acres of wetlands nationally, since
                          the 1950's, mostly due to agricultural development. Estimates for California's historic loss, (see for example,
                          Gosselink and Baumann, "Wetland Inventories: Wetland Loss Along the United States Coast," Z Geomorphology.,
                          N.F. Suppl.-Bd., 34: 173-187) do not include an estimate for the Central Coast area. Nearby San Francisco Bay is
                          estimated to have lost nearly 95% of its historic wetlands according to Josselyn, Michael, The Ecology of San
                          Francisco Bay Tidal Marshes. Washington, D.C., 1983.
                          14 Whether a habitat change is environmentally adverse or not depends on the entire wetland system and any
                          management goals. In the Elkhorn Slough system, for example, increased open water habitat at the expense of
                          vegetated salt marsh habitat and increased salt water at the expense of inland freshwater habitat have resulted in a
                          management plan strategy aimed at reverting the affected area to more historic conditions. See, ABA Consultants,

                          PAGE 134                              CALIFORNIA COASTAL COMMISSION
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                                                                                                                             CHAPTER 5 - WETLANDS

                               Elkhorn Slough Wetland Management Plan, Capitola, California 1989. In the Old Salinas River channel mitigation
                               occurred absent a management plan and more open water area resulted. According to project critics, "this mistake
                               could have been avoided if a resource management plan were available for Old Salinas River." ABA Consultants,
                               Moss Landing Marine Laboratories, Earthquake Reconstruction Planning Document A Wetland Enhancement
                               Plan, Capitola, November 1992, p. 12. Such a plan would have considered the entire wetland, resulting in better
                               judgments about optimal types of wetland habitats to restore. In contrast, the change to open water could be
                               beneficial in cases where dense vegetation growth has impaired water circulation and limited plant diversity.
                            15 ABA Consultants, Elkhorn Slough Wetland Management Plan, Capitola, California 1989, p. 14 shows an estimate
                               that at. least 90% of Monterey Bay's coastal wetlands were ditched and drained from the mid -1 800's to the 1940's,
                               but the method for determining this estimate is unstated.
                            16 Habitat Restoration Group. et. al., Draft Salinas River Lagoon Management and Enhancement Plan, 1992, Table 5,
                               p. 39.
                            17 Jones &amp; Stokes Associates, Inc., Final Neary Lagoon Management Plan, Sacramento, 1992, pp. 5 -8.
                            Is Moss Landing Marine Laboratories, Wilder Ranch Wetland Restoration Plan, Moss Landing, 1993, p. 84. This is the
                               only clear example of mapping historic wetland extent in the ReCAP project area.
                            19 California Coastal Commission, ReCAP Wetland Database. This database includes any mentioned or inferred causes
                               of historic wetland loss, based on the literature. Some development/activities occurring in wetlands (number of
                               wetlands affected in parentheses) prior to 1973 include agriculture (14 wetlands), road construction (12), flood
                               control (6), grazing (6), boating (5), urban development (4), resource extraction (3), and landfills (3). Quantified
                               losses from such activities are not generally offered.
                            20 This fragmentation may have been offset to some degree by the construction of numerous small detention ponds
                               which have developed wetland functions over time, according to Gordon, Burton L., Monterey Bay Area: Natural
                               History and Cultural Imprint, Boxwood Press, Pacific Grove, 1977, p. 224.
                            21 United States Geological Survey Map, Monterey Quadrangle, 1911-1912.
                            22 Gordon, Burton L., Monterey Bay Area: Natural History and Cultural Imprint, Boxwood Press, Pacific Grove,
                               1977, p. 234
                            23 Hornbeck, David, Landscape Change in the Pajaro Valley, 1840-1880: A Study in Change Processes, masters thesis,
                               Fresno State College, Fresno, 1969, pp, 11, 17.
                            24 Gordon, Burton L., Monterey Bay Area: Natural History and Cultural Imprint, Boxwood Press, Pacific Grove,
                               1977, pp. 85-87.
                            25 Crampton, T.A. Long Term Effects OfMoss Landing Harbor On The Wetlands OfElkhorn Slough. University of
                               California, Santa Cruz. Master of Science Thesis. 1994. 8 1 pp.
                            26 Holland, Cindy and Kentula, Mary, "Impacts of Section 404 Permits Requiring Compensatory Mitigation on
                               Wetlands in California (USA)", Wetlands Ecology and Management, 2(3), pp. 158-159.
                            27 Section 30607.1 provides a mitigation standard for no net loss or in lieu fees:
                                  Where any dike and fill development is permitted in wetlands in conformity with Section 30233 or other
                                  applicable policies set forth in this division, mitigation measures shall include, at a minimum, either acquisition
                                  of equivalent areas of equal or greater biological productivity or opening up equivalent areas to tidal action;
                                  provided, however, that if no appropriate restoration site is available, an in-lieu fee sufficient to provide an area
                                  of equivalent productive value or surface areas shall be dedicated to an appropriate public agency, or the
                                  replacement site shall be purchased before the dike or fill development may proceed. The mitigation measures
                                  shall not be required for temporary or short-term fill or diking if a bond or other evidence of financial
                                  responsibility is provided to assure that restoration will be accomplished in the shortest feasible time.
                               Few LCPs require mitigation of wetland fill, most are silent, probably because they do not explicitly permit wetland
                               fill. Only the North Monterey County Land Use Plan has a specific mitigation ratio, which is 1: 1.

                               California Coastal Commission, ReCAP Wetland Database. ReCAP has so far identified 64 projects as being
                               permitted in wetlands since 1973; 27 fills, mostly in minor amounts.

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                         29 California Coastal Commission, Coastal permit appeal A-3-STC-85-257; findings for Santa Cruz City Local Coastal
                         Program submittal, July 8, 198 1; Coastal permit P-670.
                         30 Changes in wetland area are primarily based on a review of aerial photographs from 1977, 1986, and 1993,
                         supplemented by permit files and the literature. California Coastal Commission, Cartographic Unit. ReCAP Photo
                         Interpretation Notes, 1994. In some cases, 1978 or 1979 aerial photos were used because they were clearer. Habitat
                         changes were difficult to cumulatively describe as they could not be discerned as well from the photos and are often
                         not described in the literature.
                         31 California Coastal Commission, ReCAP Wetland Database and Draft Summary of Wetland Enforcement Activity in
                         Santa Cruz and Monterey Counties, November 1994.
                         32 California Coastal Commission ReCAP Wetland Database, developed in 1994, identifies eight pending wetland fill
                         proj ects.                                                                    -
                         33 Almost the same number of wetlands (14) were subject to after-the-fact enforcement actions regarding wetland fills
                         as viere subject to before-the-fact permit applications for wetland fills (17 wetlands). California Coastal
                         Commission, ReCAP Wetland Database and Draft Summary of Wetland Enforcement Activity in Santa Cruz and
                         Monterey Counties, November 1994.
                         34 Other regulatory programs have similar gaps. For example, CEQA, where mitigation measures may be offered to
                         protect wetlands, does not apply to all projects which could affect wetlands, such as emergency repairs to public
                         facilities, waler withdrawals fforn a reservoir, housing in an urbanized area, and pipeline reconstruction. See Remy,
                         Michael et. al., Guide to the California Environmental Quality Act. Point Arena: Solono Press Books, 1993. Under
                         the Clean Water Act, no permit is required to fill less than one acre of wetland.
                         35 Cgifornia, Coastal Commission, "Interpretive Guidelines for Wetlands and Other Wet Environmentally Sensitive
                         Habitat Areas," San Francisco, 198 1, p. 40
                         36 California Coastal Commission, Jurisdiction to Require Coastal Permits for Removal of Major Vegetation Other
                         Thim for Agricultural Purposes, Section 30106, memorandum by Roy Gorman and Linda Breeden to Coastal
                         Commission, San Francisco, November 1980. The California Attorney General does not share the Commission's
                         intorpretation.
                         37 The: County Code explicitly states that coastal development permits shall be required for new or expanded
                         agricultural operations on parcels with predominantly 10% or greater slopes and on soils with high or very high
                         erosion potential. This allows the implementation of policies which basically prohibit the conversion of steep slopes
                         in the Elkhorn Slough watershed to agriculture (however, no permits have been issued before such conversions have
                         occurred; this was in response to a series of conversions that occurred in the late 1970's and early 1980's, before the
                         County assumed permit authority in 1988). This clarification would not be helpful in stopping most agricultural
                         intrusion into wetlands, since they are not typically over 10% slope or highly erodible.
                         38 Harris, Raymond, Jr., Application ofNOAA's Coastwatch Change Analysis Projectfor Wetland and Upland Change
                         Defection in the Elkhorn Slough Watershed, San Jose State University, May 1994; Habitat Restoration Group, Moro
                         Cojo Slough Management and Enhancement Plan Vol I Existing Conditions Report, Felton, March 1994; California
                         Coastal Commission, Cartographic Unit. ReCAP Photo Interpretation Notes, 1994.
                         39 Coastal Commission enforcement procedures are outlined in memoranda that have yet to be consolidated into a
                         guidance manual, although this is currently underway.
                         40 It is difficult to discern from aerial photos whether a complete loss of wetland has occurred; or whether the wetland
                         technically remains, but in an altered (degraded) state. Discovery through ReCAP has resulted in initiating
                         en-forcement follow-up. Use of aerial photo interpretation on a regular basis would be a valuable enforcement tool.
                         41 California Coastal Commission, Draft Summary of Wetland Enforcement Activity in Santa Cruz and Monterey
                         Counties, November 1994.
                         42 Based on ReCAP's review of aerial photos, there did not appear to be any cases of wetland loss in the pilot area due
                         to non-compliance. (California Coastal Commission, Cartographic Unit. ReCAP Photo Interpretation Notes, 1994).
                         However, a more thorough investigation than was possible for ReCAP might have found problems. In an example
                         where an actual field evaluation was performed in Oregon, 46 of 72 compensatory wetland mitigation projects had
                         one or more compliance violations. (Oregon, Division of State Lands, A Report Monitoring and Evaluating

                         PAGE 136                              CALIFORNIA COASTAL COMMISSION
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                                                                                                                            CHAPTER 5 - WETLANDS

                                Weiland Compensatory Mitigation Projects In Portland, Oregon by Joel Shaich and Ken Franklin, draft
                                memorandum, Salem, February 1994.)

                                With regard to paper conditions, half of the area's coastal land use plans require protective easements to be placed
                                over privately owned wetlands, as a condition of permitting development on the property. At least 21 coastal
                                permits required protective easements to be placed over wetland areas. A sampling of five required easement offers
                                at Moro Cojo Slough in the Elkhorn target area, revealed only two had been recorded. A review of the files of 13
                                restoration projects requiring monitoring reports, revealed that only three had the requisite reports. In one case,
                                Moss Landing Harbor District staff explained that sufficient money was not budgeted to cover a consultant's
                                estimated monitoring costs, and questioned the efficacy of spending substantial sums on monitoring, according to
                                personal communication with Larry Stefan, Harbormaster, June 22, 1994. Review of monitoring costs and ensuring
                                funding are issues worthy of further investigation, See for example, King, Dennis and Bohlen, Curtis, "Estimating
                                the Costs of Restoration,'@ National Wetlands Newsletter, Vol 16, No 3, May/June 1994, pp. 3-8. Whether the lack
                                of documentary condition compliance translates into incomplete wetland mitigation is unknown. Unlike the Coastal
                                Commission's computerized Access Inventory, no comparable database or tracking of easement or monitoring
                                requirements has been established. The ReCAP database can be used for such purposes. There is no record of
                                subsequent monitoring of easement use.
                            43  U.S. Fish and Wildlife Service, Classification of Wetlands and Deepwater Habitats ofthe United States, by Lewis
                                Cowardin, et. al. Washington, D.C. 1979.
                            44  Monterey County, Carmel Area Land Use Plan, and City ofSanta Cruz General Plan and Local Coastal Program
                                1990-2005.
                            45,, Wetlands" is a generic term without a universally accepted definition. Enlightening discussions of this topic are
                                found in California Coastal Commission, Procedural Guidancefor the Review of Weiland Projects in California's
                                Coastal Zone, San Francisco, 1994, pp. 41-48; San Francisco Estuary Project, Status and Trends Report On
                                Wetlands and Related Habitats in the San Francisco Estuary, Oakland, 199 1, pp. 21-27; Kusler, J.A., "Wetlands
                                Delineation," Environment, Vol 35, March 1992, pp. 6-11+. For purposes of analysis, the most important
                                consideration appears to be the presence of wetland indicators. Variations in definitions and hence delineation
                                methods hinge on the number of the three common wetland indicators - hydrology, hydric soils, hydrophytic
                                vegetation - requires before a positive wetland identification is made. According to personal communication with
                                Wayne Ferrin Jr., UCSB Department of Biological Sciences, June 14, 1994, there are potentially significant areas
                                that may not appear to be "wetlands" to the casual observer (because they are not always wet) that qualify under at
                                least the more expansive wetland definitions.

                                Interestingly, in some cases significant standing water bodies have been termed "ponds," "lakes," 'bays," etc. and
                                not considered wetlands, However, under Section 30233 of the Coastal Act, open waters and lakes receive almost
                                the same protection as wetlands.
                            46  See, for example, "What Is a Jurisdictional Wetland?" National Wetlands Newsletter, Vol 13, #5,
                                September/October 1991.
                            47  California Coastal Commission, Interpretive Guidelinesfor Wetlands and Other Wet Environmentally Sensitive
                                Habitat Areas, San Francisco, 1981. Also see California Coastal Commission, Procedural Guidancefor the Review
                                of Weiland Projects in California's Coastal Zone, San Francisco, 1994, p.25 for a discussion of this topic.
                            48  County of Monterey, Department of Planning, Environmental Impact Reportfor Spanish Bay Development, Salinas,
                                1976, p. 28. noted drainage channels into the area and ponds formed in the mined out areas. Environmental
                                Management Consultants, Spanish Bay Resort Environmental Impact Report, Monterey 1984, Appendix H, p. 3
                                briefly notes the presence of a wetland (riparian corridor). California Coastal Commission, 3-84-226 permit staff
                                report, March 1985, did not mention "wetlands." LSA, Spanish Bay Resources Management Plan, July 1987, p. II-
                                I, VII- I noted small seasonal wet areas and drainage ways.
                            49  California Coastal Commission ReCAP, personal communication with Lee Otter, Coastal Planner, May 3, 1994.
                            50  Derived from aerial photographic display maps accompanying Pebble Beach Company, Spanish Bay Resource
                                Management Plan, Fifth Annual Monitoring Report, Pebble Beach, March 1994 compared to California Coastal
                                Commission, Cartographic Unit. ReCAP Photo Interpretation Notes, 1994. Lacking a pre-development field
                                investigation, it will never be known how much wetland acreage there truly was.

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                      51 CalifDrnia Coastal Commission Coastal permit appeals A-3-SNC-89-10, -11, &amp; -12; findings on Santa Cruz County
                      Local Coastal Program Amendment # 1-93.
                      52 Ray, Daniel and Woodruff, Wayne, Mitigating Impacts to Wetlands and Estuaries In California's Coastal Zone,
                      paper presented at Association of State Wetland Manager's conference, New Orleans, October 11, 1986; San
                      Francisco Bay Conservation and Development Commission, Mitigation: An Analysis of Tideland Restoration
                      Projects In San Francisco Bay, San Francisco, March 1988; California Coastal Commission, Humboldt Bay
                      Wetlands Inventory Project: Data Interpretation and Summary, January 1989.
                      53 This project was not mitigation. Josselyn, M., S. Chamberlain, K. Goodnight H. Hopkins, and A. Fiorello.
                      Evaluation ofCoastal Conservancy Enhancement Projects 1978-1992, a report prepared for Reed Holderman, State
                      Coastal Conservancy. Oakland, California. 1993.
                      54 Pebble Beach Company, Spanish Bay Resource Management Plan, Fifth Annual Monitoring Report, Pebble Beach,
                      March 1994; Monterey County Coastal Permit PC-7523 (3-MCO-90-077).
                      55 Habitat Restoration Group, Moss Landing South Harbor Wetland Restoration Project Monitoring, SecondAnnual
                      Mani!toring Report, Scotts Valley, October 1992.
                      56 ABA Consultants, Moss Landing Marine Laboratories Earthquake Reconstruction Planning Document A Wettand
                      Enhancement Plan, Capitola, November 1992, pp. 12 -14.
                      57 See California Coastal Commission, Procedural Guidancefor the Review of Wetland Projects in California's
                      Coastal Zone, San Francisco, 1994, for a more expansive discussion of this issue of interpreting permitted uses
                      under Section 30233.
                      59 For example, only one LCP in the study area explicitly allows boating and only one explicitly allows limited resource
                      extraction (of peat). None, explicitly allow port, energy, or coastal-dependent industrial facilities. For a further
                      discussion of this topic on a statewide basis see California Coastal Commission, "Wetland Task Force Final
                      Recommendations," memorandum from Les Stmad, Santa Cruz, November 1988, pp. 6 -9.
                      59 Field work and aerial photo interpretation would be necessary to attempt an after-the-fact study of whether removal
                      of any (non-wetland-considered) "riparian vegetation" would have constituted wetland vegetation under the
                      Cowardin method.
                      60 California Coastal Commission, Procedural Guidancefor the Review of Wetland Projects in California's Coastal
                      Zone-, San Francisco, 1994.
                      61 California Coastal Commission, Procedural Guidancefor the Review of Wetland Projects in California's Coastal
                      Zone!, San Francisco, 1994, p. 48. The Coastal Commission has provided input to this effort.
                      62 California Coastal Commission, "Briefing on Recently Issued State and Federal Wetland Policy Statements,"
                      memorandum, San Francisco, September 1993.
                      63 Califbmia Department of Fish and Game, Wetland Resources Policy, Sacramento, 1987.
                      64 California Coastal Commission, Procedural Guidance for the Review of Wetland Projects in California's Coastal
                      Zone!, San Francisco, 1994.
                      65 There may be a few cases where either privately owned parcels are totally wetland or a wetland would have to be
                      filled to accommodate a single family home; further analysis would be necessary to identify these. Given recent
                      court cases, the Commission may face more issues related to proposed wetland fill for a non-priority (i.e.,
                      residential) use; see, for example, Berry, James, "The Dolan Case: Grabbing Tigard by the Tail?" Environment &amp;
                      Development, August 1994, p. 3.
                      66 Although it was beyond the scope of ReCAP to study the relationship of other agencies' mitigation requirements to
                      the Coastal Commission's and local governments', inconsistency among agencies, which threatens mitigation
                      success, was found on a statewide basis. California Coastal Commission, "Wetland Task Force Final
                      Recommendations," memorandum from Les Stmad, Santa Cruz, November 1988, Recommendations #3 &amp; 4 and pp.
                      12 -16. See Problem Six Information Gaps section of this chapter for further agency coordination
                      recomme nclations.
                      67 Two pending cases portend this trend. Recently delineated wetland remnants on former agricultural and grazing land
                      at both Terrace Point and what was once known as Rolling Hills respectively are proposed to be filled. Whether fill

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                               of small isolated, seasonal, and/or degraded areas With compensating mitigation may result in an overall net habitat
                               improvement is an issue worthy of further study.
                            68 California Department of Fish and Game, Wetlands Resources Policy, Sacramento, 1987.
                            69 California Coastal Commission, "Briefing on Recently Issued State and Federal Wetland Policy Statements,"
                               memorandum, San Francisco, September 1993.
                            70 California Coastal Commission Central Coast Region, Vested Rights file # E-3-73-5; Mitchell Swanson Associates
                               and Habitat Restoration Group, Final Pajaro River Lagoon Management Plan, Santa Cruz, May 1993, p. 12.
                            71 Coastal permit files-3-83-185 and P-81-162 and California Coastal Commission, Cartographic Unit. ReCAP Photo
                               Interpretation Notes, 1994.
                            72 At least two recent enhancement projects involved recreating historic habitat conditions, within existing Nv@etland
                               areas. Restoration of Laguna Grande and Roberts Lake included clearing 4.6 acres of tule vegetation, resulting in
                               open water habitat. Similarly, tule cutting has been permitted at Neary Lagoon on two occasions to result in more
                               open water habitat. Both of these projects were undertaken in concert with wetland management plans based on
                               biologists' beliefs that these smaller wetlands were being choked with too much vegetation. In some cases natural
                               restoration has been documented. At Carmel River Lagoon and Natural Bridges Lagoon, native vegetation had
                               reestablished itself after cessation of farming or grazing activities which had eliminated it.
                            73 Moss Landing Marine Laboratories, Wilder Ranch Wetland Restoration Plan, Moss Landing, 1993.
                            74 ABA Consultants, Elkhorn Slough Wetland Management Plan, Capitola, California 1989 and ABA Consultants,
                               Biological Assessment, Development and Restoration Planfor the Elkhorn Heights Parcel, Capitola, California,
                               1991.
                            75 Moss Landing Marine Laboratories, Benthic Lab, Watershed Ecology Outreach Program First Progress Report,
                               Moss Landing, September 1994. and personal communication with John Oliver, November 8, 1994.
                            76 See Dyste, Rosie, Methods ofDelineating and Determining the Effectiveness of Wetland Buffer Zones, student paper
                               for San Jose State University Environmental Studies 200, Spring 1994.
                            77 Data sources for Figure 5-6 are as follows: Panels 1-3: U.S. Coast Survey Register No. T-444, Santa Cruz Harbor
                               and Vicinity, 1853, Scale 1: 10,000; U.S. Coast and Geodetic Survey Register No. T-444a, Santa Cruz Harbor and
                               Vicinity, 19 10, scale 1: 10,000; Sanborn Fire Insurance Maps, Sanborn Map Co., 1909 and 1950; California Joint
                               Highway District No. 9, Aerial photograph No. 1, 1928. Panels 4-8: Santa Cruz County parcel base map, scale
                               1:7,200; California Dept., of Navigation and Ocean Development Aerial photograph No. 76-5-104, April 2, 1970;
                               and Aerial photograph No. 4-12-13 5, May 6, 1978; California Dept. of Boating and Waterways, Aerial photograph
                               No. 4-123-229, March 26, 1986 Aerial photograph No. 4-123-6, April 19, 1993; Brown and Caldwell, Pro'ject
                               Report, Santa Cruz Wastewater Facilities Planning Study, Walnut Creek, 1978; Jones and Stokes Associates, Inc.,
                               Final Neary Lagoon Management Plan. Sacramento, 1990.
                            78 California Coastal Commission. Statewide Interpretive Guidelinesfor Wetlands and Other Wet Environmentally
                               Sensitive Habitat Areas. San Francisco, 198 1. These guidelines were developed using extensive scientific input as
                               summarized in Castelle, Andrew, et. Al., Wetland Buffers: Use and Effectiveness, Olympia, Wa: February 1992, p.
                               20.
                            79 Since the point will relate to the wetland, how the wetland itself is delineated is a crucial factor; see previous section
                               on "Inconsistent Delineation Methods." Imposing different buffer widths may be appropriate for different situations;
                               however, the discrepancies identified are largely the result of policy decisions, not scientific evidence.
                            so . One new initiative regarding vegetated treatment systems is found in United States Environmental Protection
                               Agency, Guidance Specijying Management Measuresfor Sources ofNonpoint Pollution in Coastal Water,
                               Washington, DC., January 1993, Chapter 7,11C.
                            "Onne, A.R. "Wetland Morphology, Hydrodynamics, and Sedimentation," in Williams, Michael [Ed.]. Wetlands: A
                               Threatened Landscape. Oxford, England: Alden Press Ltd., 199 1, pp. 43-94.
                            82 Orme, A.R. Ibid.
                            83 Josselyn, M. The Ecology ofSan Francisco Bay Tidal Marshes: A Community Profile. U.S. Fish and Wildlife
                               Service, Division of Biological Services, Washington D.C. FWS/OBS-83/23. 102pp. 1983.

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                       "Zedler,J.B. 1982. The Ecology ofSoutherh California Coastal Salt Marshes: A Community Profile. U.S.Fishand
                       Wildlife Service, Division ofBiological Services, Washington D.C. FWS/OBS-81/54. 110pp. 1982.
                       "California Coastal Commission Permit File; Permit # 3-90-104.
                       86 California Coastal Commission ReCAP Database - Wetlands Module, 1983-1993.
                       87 California Coastal Commission ReCAP Database - Wetlands Module, 1983 - 1993.
                       "The Planning Collaborative and John Sanger, Regional Land Use Study, for AMBAG. San Francisco, 1978.
                       89
                       California Coastal Commission Permit File; Permit # 3-92-15,
                       90 As a recent alternative to breaching, Coastal Commission staff organized a human rescue effort to transport trapped
                       fish 1.5rom the lagoon to the Bay.
                       91California Coastal Commission Permit File; Permit # 3-90-41.
                       92 These approaches should not be construed to imply that breaching is always the appropriate solution. For example,
                       11 recent research of water quality and biological productivity, conducted at other lagoons along the central California
                       coasi; demonstrates that sand bar breaching is harmful to lagoon habitats for fish and other aquatic organisms.
                       Breaching in the spring or summer months delays or arrests a lagoon's seasonal conversion to freshwater from the
                       mixed fresh-salt water regime that occurs with an open river mouth in the winter months. The water column in the
                       lagoon becomes stratified, with a hot, saline, anoxic bottom water layer underlying a cooler, freshwater layer above.
                       Under stratified conditions, fish and other aquatic organisms, especially benthic organisms, cannot survive. Without
                       the basis for a healthy food chain, the biological productivity of the lagoon is diminished for fish, birds and other
                       wildlife," from Mitchell Swanson Associates and Habitat Restoration Group, Final Pajaro River Lagoon
                       Management Plan, Santa Cruz, May 1993, p. 3.
                       93 Crampton, T.A. Long Term Effects OfMoss Landing Harbor On The Wetlands OfElkhorn Stough. University of
                       Calffiornia, Santa Cruz. Master of Science Thesis. 81 pp. 1994.
                       94Belden, T., R. Gramlich, D. Leland, T. Panella, and H. To. Policy Strategy to Reduce Erosion in the Elkhorn Slough
                       Watershed A report to the California Coastal Commission, Central Coast District. 52pp. plus Appendices. 1994.
                       95 Belden, et al., ibid. The Coastal Commission did attempt to address the cumulative effects of erosion and
                       sedimentation on Elkhorn Slough from potential additional development. The Coastal Commission proceeded to
                       den), new subdivisions, in the late 1970's while permitting singly-family residences on vacant lots of record. A
                       fairly standard finding was applied to each subdivision permit, creating a de facto moratorium on new lots.
                       Exceptions were made for dividing property that already contained multiple units and a few other situations, on a
                       case-by-case basis. The findings made it clear that such denials were being given until a new plan for the area
                       addressing cumulative impacts could be developed. As background for that plan, a UC Berkeley Sea Grant study
                       identified "bare ground exposure" thresholds for the subwatersheds of Elkhorn Slough (Dickert, Thomas and Tuttle,
                       Andrea, Elkhorn Slough Watershed Linking the Cumulative Impacts of Watershed Development to Coastal
                       Wetiands, Berkeley, October 1980). These were incorporated into the local coastal program along with a tracking
                       system to ensure that they were not exceeded and a subwatershed planning process to address those that were
                       already exceeded. The local plan resulted in a downzoning, but does allow new subdivision based on the new
                       densities. (Hyman, Rick. Unpublished remarks at Methodologies and Mechanisms for Management of Cumulative
                       Coaaal Environmental Impacts Workshop, University of Rhode Island School of Oceanography, Narragansett@
                       Rhode Island, May 6, 1993.) Some would argue that this bias against new subdivision (and the commensurate
                       priority given to agriculture) is responsible for more erosion and sedimentation. For further details of this effort, see
                       Stmad, Les and Hyman, Rick, "A Watershed Approach to Coastal Zone Management for the Elkhorn Slough
                       Estuarine Complex," Coastal Zone 1993 Vol 2, Proceedings ofthe Eighth Symposium on Coastal and Ocean
                       Management, edited by Orville Magoon, et. al. New York: American Society of Civil Engineers, 1993, pp. 1569 -
                       158:3. For an evaluation of efforts to control sedimentation in the watershed see the Coastal Commission's
                       forthcoming project of special merit report on Cumulative Impacts of Nonpoint Source Pollution.
                       96 Reed, Rhonda. Population Study ofthe Santa Cruz Long-Toed Salamander at Valencia Lagoon. for California
                       Department of Fish and Game, Aptos, CA, 1978.
                       97 Gordon, B.L. Monterey Bay Area: Natural History and Cultural Imprints. Second edition. The Boxwood Press,
                       Pacific Grove, California. 1994.

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                          98 Gordon. Ibid.
                          99 As suggested earlier in this chapter, pursuit of restoration does not guarantee success and may require substantial
                             effort. Although it was beyond the scope of ReCAP to systematically evaluate success of wetland restoration
                             projects, many projects appear to emphasize acreage and habitat over hydrology. The problematic restoration
                             project at the Old Salinas River channel, as well as restoration projects at Elkhorn Slough, are not functioning as
                             planned. Hydrologic evaluation of potential tidal erosion and related factors were not incorporated in project design
                             or monitoring. Personal communication with Les Stmad, November 14, 1994 regarding coastal development
                             permits #3-83-125;P-81-162; 3-88-96.
                          100 For example, at Elkhorn Slough, bisected by Elkhorn Road, Monterey County proposed to replace flap gates and
                             earthquake-damaged culverts. The area above the tidegates known as Blohm-Porter marsh was thought to originally
                             be freshwater, but is now tidally influenced. (California Coastal Commission Permit file #3-94-11). At Upper
                             Bennett Slough, bisected by Highway One, CALTRANS proposed to replace a broken culvert for flood control
                             purposes. The area above the culvert, known as Struve Slough, was recently freshwater, but is now saline.
                             (California Coastal Commission pending permit file). In order to evaluate these projects from a wetland hydrology
                             perspective, a baseline objective needs to be agreed upon. In both of these cases, the objective discussed by the
                             various resource agency officials was for a freshwater system. But, neither area has a fully adopted management
                             plan stating this. When such a objective is agreed upon, it may result in a project which, while not the least
                             intrusive development, could be considered the least environmentally damaging in a systems context.
                          '0' Chan, E., T.A. Brusztynsky, N. Hantzsche, and Y.S. Litwin. The Use Of Wetlands For Water Pollution Control.
                             for Association of Bay Area Governments. Berkeley, California. 198 1.
                             Sather, J.H. and R.D. Smith. An Overview OfMajor Wetland Functions And Values. U.S. Fish and Wildlife Service,
                             Office of Biological Services. FWS/OBS-84/18. 68pp. 1984.
                          103 Aston, R.P. An Assessment of Water Quality in Santa Cruz County: Problems, Needs and Programs. A report
                             prepared for the Santa Cruz County Board of Supervisors, Health Services Agency, Division of Environmental
                             Health, Watershed Program, May 1976.
                          104 ABA Consultants. Elkhorn Slough Wetland Management Plan. Capitola, 1989.
                          105 Dames and Moore, Route I Improvement Study Background Report. Surface Water Quality ofMoss Landing
                             Vicinity, Goleta, (1990?).
                          106 Harvey and Stanley Associates, Neary Lagoon Enhancement Plan Part I Environmental Inventory; Part 11 Interim
                             Enhancement Plan. Alviso, August 1987.
                          '07 Sugar, K. "State Lowers the Boom on Neary Lagoon," Save Our Shores (SOS) Sanctuary Watch, June 1994, p. 7.
                          108 Sugar, K. Ibid.
                          109 California Central Coast Regional Water Quality Control Board. Proposed Amendments of the Central Coast Water
                             Quality Control Plan. 1993.
                          110 Dames &amp; Moore. Natural Environmental Studyfor the Widening ofHighway I from Castroville, Ca to the Santa
                             Cruz Co. Line Monterey Co. Goleta, CA. 1990.

                             Environmental Management Consultants. Spanish Bay Resort Environmental Impact Report. Appendix D.
                             Monterey, CA. 1984.
                          112 Bestor Engineers. Initial Study ofEnvironmental Impact Marina Beach Tract No. 2. Monterey, CA. 1978. p. 15.
                          113 California Coastal Commission. Cotter, P. Unpublished data.
                          114 Coastal Act Section 30231 provides the policy basis for protecting water quality in the coastal zone. Although the
                             Coastal Commission and local governments can apply this section to new development, primary responsibility for
                             coastal water quality is vested in the State Water Resources Control Board and its Regional Water Quality Control
                             Boards. It was beyond the scope of ReCAP to analyze effectiveness of coastal permits in addressing pollution of
                             wetlands. Such is a focus of the Commission's forthcoming project of special merit, "Cumulative Impacts of
                             Nonpoint Source Pollution."
                          115 California Coastal Commission, Procedural Guidance Manual: Addressing Polluted Runoffin the California
                             Coastal Zone, San Francisco: May 1995.

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                    116 Form example of such procedures see Cotter, P.J., L. Mortello, and L. Stmad. Data Evaluation Report and
                       Monitoring Frameworkfor the Elkhorn Slough Watershed. Draft report. California Coastal Commission, Monterey
                       Bay Initiative. EPA Region IX Near Coastal Waters Grant No. X-009999-01-0. 1994.
                    117 Cali fornia Coastal Commission ReCAP Database - Wetlands Module.
                    '"California Coastal Commission ReCAP Database - Wetlands Module
                    119 California Coastal Commission ReCAP Database - Wetlands Module.
                    120 Cahfornia Coastal Commission ReCAP Database - Wetlands Module
                    121 Calilfornia Coastal Commission ReCAP Database - Wetlands Module
                    122 For example, in the Valencia Lagoon watershed continued development threatened the habitat of the Santa Cruz
                       long-toed salamander. The Coastal Commission devised a two-part protection strategy. Some lots immediately
                       adjacent to the Lagoon were designated "critical habitat." Permits for single-family homes were denied and the lots
                       were eventually purchased by the State Department of Fish and Game. The remainder of the lots could be built on
                       to a maximum of 15% site disturbance. This standard was incorporated into a special "SD" overlay zoning district
                       in the Santa Cruz County local coastal program. No evaluation of the effectiveness of these measures has occurred.
                       (Hyman, Rick. Unpublished remarks at Methodologies and Mechanisms for Management of Cumulative Coastal
                       Environmental Impacts Workshop, University of Rhode Island School of Oceanography, Narragansett, Rhode
                       Island, May 6, 1993.)
                    123 City of Santa Cruz, Final EIR on the Westside Lands Final Plan, 1987 and Strelow, Stephanie, Draft
                       Environmental Impact Report, Terrace Point Specific Plan, Santa Cruz, 1994.
                    114 Earth Metrics, Final EIRfor the Villa Nueva Subdivision, Burlingame, 1982; Earth Metrics, Final EIRfor the Villa
                       Ferde and Villa Nuev@ Subdivision, Burlingame, 1986; Jones and Stokes, Moro Cojo Inclusionary Housing
                       Development Project Final EIR, Sacramento, 1994.
                    125 U.S. Department of Commerce, National Oceanic and Atmospheric Administration, Coastal Wetlands of the United
                       States: An Accounting ofA Valuable National Resource, Washington, D.C., February 199 1, p. 55.
                    126 California Coastal Commission, Procedural Guidancefor the Review of Wetland Projects in California's Coastal
                       Zone, San Francisco, 1994.
                    127 Santa Cruz County. Code. Sections 16.32.070 &amp;.080.
                    128 See, for example: 1) Ray, Daniel and Woodruff, Wayne, Mitigating Impacts to Wetlands and Estuaries In
                       California's Coastal Zone, paper presented at Association of State Wetland Manager's conference, New Orleans,
                       October 11, 1986; 2) San Francisco Bay Conservation and Development Commission, Mitigation: An Analysis of
                       Tide-land Restoration Projects In San Francisco Bay, San Francisco, March 1988; 3) California Coastal
                       Commission, Humboldt Bay Wetlands Inventory Project: Data Interpretation and Summary, January 1989; and 4)
                       California Coastal Commission, Wettand Task Force Final Recommendations, memorandum by Les Stmad, Santa
                       Crur, November 1988, p. 10.
                    129 U.S. Department of the Army, San Francisco District Corps of Engineers, Habitat Mitigation and Monitoring
                       Proposal Guidelines, effective October 1991.
                    130 California Coastal Commission, Data Evaluation Report and Monitoring Frameworkfor the Elkhorn Slough
                       Watershed, draft, by Patrick Cotter, Linda Mortello, and Les Stmad. Santa Cruz, November 1994.
                    131 Watersheds are theoretically easier to delineate, since they can be drawn from topographic maps. A complication
                       does occur with artificial, uninapped drainages to other watersheds. As suggested in the final section of this chapter,
                       themain issue with watershed delineations is how fine they are drawn; the referenced ICM and the State Water
                       Resources Control Board currently aggregate individual stream drainages into larger hydrologic units. Standardized
                       norr ienclature is also lacking.
                    132 Timber Harvest permits, reviewed by the Department of Forestry and Fire Protection, and not subject to the CCMP,
                       contain cumulative impact assessments, analyzing the effects of harvests on downstream wetlands.
                    133 Jones and Stokes, City ofSanta Cruz Wastewater Treatment Plan Modification Addition ofSecondary Treatment,
                       Draft EIR Supplement, Sacramento, November 1990.

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                          134 Personal communication with Craig Vassell, U.S. Army Corps of Engineers, October 6, 1994.
                          135 Both President Clinton and Governor Wilson have suggested common wetland regulations as differing
                             requirements are a source of frustration to applicants. California Coastal Commission, "Briefing on Recently Issued
                             State and Federal Wetland Policy Statements," memorandum, San Francisco, September 1993. While this is not a
                             CCMP nor cumulative impact problem, the California Coastal Commission can participate in efforts towards
                             coordination, consolidation, and standardization. For example, it would also be valuable to provide applicants
                             information as to the various wetland regulatory requirements. This can occur at the Corps' interagency meetings.
                             Using Figure I as a start, preparation of a guide compiling wetland permit requirements is a worthy interagency
                             task.                                                                            1
                          136 See Kusler, Jon. Hydrology: An Introductionfor Wetland Managers, Berne, New York (n.d.).
                          137 the two other EIRs did not list preparers' expertise, but at least in one case biologists were consulted. Those were
                             earlier EIRs from the mid 1970's, and one was for a project never built.
                          138 See California Coastal Commission, "Wetland Task Force Final Recommendations," memorandum from Les
                             Stmad, Santa Cruz, November 1988, Recommendation #I C.
                          139 California Coastal Commission, Memorandum by Thomas Crandall on the Department of Fish and Game, San
                             Francisco, September 1994.
                          '40 See, for example, National Wetlands Newsletter, Vol. 16 #4, July/August 1994 for some discussion of this topic.
                          141 To date there are no such known examples in the pilot area, as management plans are either too new or re flect
                             permit conditions (i.e., permit issuance preceded the development of the plan). However, some wetland
                             enhancement projects have been proposed, at Neary Lagoon and Elkhorn Slough, pursuant to previously completed
                             management- plans.
                          142 See California Coastal Commission, "Post LCP Certification Permit and Appeal Jurisdiction" maps, various dates,
                             which distinguish areas that remain under the Commission's permit jurisdiction (tida'lly-influences or potential
                             public "st) from those that revert to local jurisdiction after local coastal program certification.
                          14' Federal projects are reviewed under consistency revie;v, rather than under coastal development permits. Federal
                             consistency review is the one authority that the Coastal Commission now possesses to review federal projects and
                             federally licensed projects affecting coastal zone resources.
                          '44 For example, see: (1) San Francisco Estuary Project Status and Trends Report On Wetlands and Related Habitats
                             in the San Francisco Estuary, Oakland, 199 1; and (2) Oregon Division of State Lands, Oregon's Wetland
                             Conservation Strategy, Draft, April 1993. Plans which attempt to rate wetland significance and provide lesser
                             degrees of protection for some classes of wetlands would not be appropriate models, given the Coastal Act's
                             protective policy framework and the significant historic wetland loss in California.
                          145 Duncan &amp; Jones and Ribera &amp; Sue, Parks, Recreation and Open Space Plan, Santa Cruz County, California,
                             Berkeley and Oakland, 1972; California State Coastal Conservancy, Update ofCalifornia Coastal Wetlands
                             Enhancement Needs, Oakland, March 1984; Dennis, Nona and Marcus, Mary. Status and Trends ofCalifornia
                             Wetlands, Sacramento, 1984, pp. 87-95; Santa Cruz County, Coastal Land Use Plan, Policies 1. 14.3 and 1. 14.4.
                          146 This task is being undertaken by the California Department of Fish and Game, Office of Oil Spill Prevention and
                             Response. Jeanne Lau, California Coastal Commission. Personal communication, November 1, 1994.
                          147 California Resources Agency. California Ocean Resources: An Agendafor the Future (Draft), Sacramento, 1994..
                             Map 3 of 4, Central Coast, Appendix F.
                          148 U.S. Department of Commerce, National Oceanic And Atmospheric Administration, National Ocean Service,
                             Monterey Bay National Marine Sanctuary Water Quality Protection Program Workshop Summary Report Issue
                             Identification and Strategy Development, Draft, June 1994.
                          149 It would be beneficial at some point to link or merge SEA's database with the Coastal Commission's ReCAP
                             wetland database.
                          150 Other emerging efforts include (1) AMBAG's CAMPITS program, described in Work Planfor Water Quality
                             Management Planning Program on Coastal and Marine Water Quality Information Coordination, Integration and
                             Outreach, A Pilot Programfor the Monterey Bay Region, July 1992; (2) Moss Landing Marine Laboratories' lead in

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                        foste.ring a Monterey Bay and Salinas Valley Regional Watershed Plan with a main goal of holding fresh water in
                        the watershed by restoring as much of the natural wetland system as possible. The initial report attempts to catalog
                        various restoration projects underway in the Pajaro River valley, Elkhorn Slough, and Salinas River valley
                        watersheds and suggest some future projects, Moss Landing Marine Laboratory's Outreach Program: Moss Landing
                        Marine Laboratories, Benthic Lab, Watershed Ecology Outreach Program First Progress Report, Moss Landing,
                        September 1994.
                     151 An emerging geographical framework for performing resource planning is the natural community, which may
                        consist of single or multiple habitats, and would likely not be coterminous with watershed boundaries. However,
                        such boundaries are variable and are not yet d'efined. For a discussion of this topic, see, National Wetlands
                        News,letter, Vol 16,#5, September/October 1994.
                     152 U.S. Environmental Protection Agency. The Watershed Protection Approach Annual Report 1992. Washington
                        D.C.:: 1993. Watershed-Protection Approach: A Project Focus. Washington D.C.: 1994. The 1976 Coastal Plan
                        recommended watershed based planning. However, watersheds extended beyond the area determined to be
                        appropriately state-regulated, which was the resultant coastal zone. Additional federal watershed legislation is also
                        being considered by Congress, such as H.R. 3873 Urban Watershed Restoration, H.R. 3894 Conservation Reserve
                        Progwn, H.R_ 42113 River and Watershed Protection and Restoration Act. Congress, see National Wetlands
                        Newsletter, Vol 16, No. 3, May/June 1994, p. 20. "Major legislation is expected to be introduced in the California
                        Legislatum in January [1995] on watershed management planning," according to APA Northern News, p. 5.
                        Santa Cruz County Planning Department &amp; California Resources Agency, The San Lorenzo River Watershed
                        Management Plan, Santa Cruz, December 1979.
                     154 Philip Williams &amp; Associates and Harvey and Stanley Associates, The San Lorenzo River Enhancement Plan,
                        February 1989.
                     155 Monterey Peninsula Water Management District Draft Carmel River Watershed Management Plan by John
                        Willi ams, March 1984 and Monterey Peninsula Water Management District, Draft Carmel River Watershed
                        Man2gement Plan by Ken Greenwood, Monterey, April 1988.
                     116 EIP Associates, Supplemental EnvironmentalJmpact ReportlStatement 11 Monterey Peninsula Water Supply
                        Project, 1993 lists over 300 documents associated with this project.
                     157 Dickert, Thomas and Tuttle, Andrea, Elkhorn Slough Watershed Linking the Cumulative Impacts of Watershed
                        Development to Coastal Wetlands, Berkeley, October 1980. See Stmad, Les and Hyman, Rick, "A Watershed
                        Approach to Coastal Zone Management for the Elkhorn Slough Estuarine Complex," Coastal Zone 1993 Vol 2,
                        Proceedings ofthe Eighth Symposium on Coastal and Ocean Management, edited by Orville Magoon, et. al. New
                        York: American Society of Civil Engineers, 1993, pp. 1569 -1583 for a history of attempts to plan for the Elkhorn
                        watershed.

                        CRPAP Cooperating Agencies, A Conservation Ditemma.4 Cooperative Solution, undated brochure.
                     159 The following management plans have been completed: Antonelli Pond 198 1; Marina Vernal Pond #2 1986;
                        Laguna Grande &amp; Roberts Lake 1986; Younger Lagoon 1987; Marina Vernal Pond #3 1987; Elkhorn Slough
                        (including Parsons Slough) 1989; San Lorenzo River mouth (including Jessie Street marsh) 1989; Soquel Creek
                        Lagoon 1990; Gibson Landing Marsh/Lower Bennett Slough 1990; Neary Lagoon 1992; Ellicott Slough 1993;
                        McCluskey Slough 1993.
                        The following seven wetland management plans were well underway in 1994 with review drafts avaflable and
                        included in the analysis: Carmel River Lagoon Enhancement Plan, Coastal/Vernal Ponds Comprehensive
                        Management Plan (for all of Marina Vernal Ponds), Moro Cojo Slough Management and Enhancement Plan, Pajaro
                        River Lagoon Management Plan (includes Lower Watsonville Slough), Salinas River Lagoon Management and
                        Enhwicernent Plan, Restoration/ Management Options for Schwan Lake, and Wilder Wetland Restoration Plan.
                        Two other plans just commencing were for Waddell Creek Lagoon and for the six wetlands of the Watsonville
                        Slough complex, the latter effort the result of many years of prodding by a local citizens group, Watsonville
                        Wetlands Watch.

                        For complete bibliographic information see California Coastal Commission ReCAP Database Wetlands module,
                        Wetlands Documents section.

                     PAGE 144                               CALIFORNIA COASTAL COMMISSION
<pb n="146" />

                                                                                                                                  CHAPTER 5 - WETLANDS

                             160 Wetlands lacking plans are Old Salinas River Channel, Upper Bennett Slough/Struve Pond, Scott Creek Marsh,
                                 Laguna Creek, and Corcoran Lagoon. The three next largest wetlands lacking management plans are all within
                                 Wilder Ranch State Park. Park officials hope to prepare restoration plans for each of them, as soon as the Wilder
                                 Lagoon plan is completed, according to personal communication with Ian Calderwood, November 1, 1994. Two
                                 large weland areas (originally Woods Lagoon and part of the old Salinas River Channel) were transformed into
                                 harbors and are governed by Master Plans, excerpted into the Santa Cruz City and North Monterey County LCPs
                                 respectively. These plans do not contain and could benefit from environmental management components akin to
                                 wetland management plans.
                             161 The lack of a plan or of a topic does not necessarily mean that management or some aspect of management is not
                                 occurring. Rather, it is an indicator of a potential deficiency in attempting to achieve resource protection. A further
                                 evaluation of the adequacy of these management measures that are in place is beyond the scope of ReCAP, as is an
                                 analysis of the actual implementation of these measures. It can be said, however, that many of these plans have yet
                                 to be fully implemented.
                             162 Most of the management plans have been prepared by consultants. The lead agency is usually a local government.
                                 In some cases technical advisory groups have helped guide plan preparation. Some plans have gone through a
                                 public hearing process, others have not. Individuals and groups, such as Friends of Neary Lagoon, occasionally
                                 provided public input.
                             163 For some of the more recent management plans (e.g., for Moro Cojo Slough), detailed work programs were
                                 prepared and revised based on input from Coastal Commission staff and others. For general procedural guidance,
                                 see Local Councils of Governments, "Hints on Preparing A Comprehensive Wetland Management Plan," Eugene,
                                 February 1992.

                                 Funding to date has come from a variety of sources, such as the State Coastal Conservancy, State Water Resources
                                 Control Boaid, local governments, and applicants. Some management plans have been required as permit conditions
                                 (to address adverse impacts of the permitted developments), while others have been submitted along with
                                 applications (e.g., for Lower Bennett Slough and Ellicott pond). Based on recent court cases, there may be a need to
                                 more closely scrutinize permit conditions requiring applicants to pay for management plans; however, to date
                                 funding for wetland planning has not generated significant controversy and has been readily available.
                             164 See Kusler, Jon, Advanced Planning of Wetlands: Wetlands and Watershed (Water Resources) Management A
                                 Background Paper, Berne, New York, February 1993, pp. 8-18 for a discussion of the relationships between
                                 watershed management plan components and wetland protection issues.
                             165 The Elkhorn Slough Management Plan was called for in the local coastal program, then prepared. While Coastal
                                 Commission staff did work extensively with the local government (Monterey County) in preparing the plan, it was
                                 not formally submitted to the Coastal Commission as a local coastal program amendment (a          fter originally noticing it
                                 as one).
                                 The issue of incorporation of management plans into local coastal programs would benefit from further review.
                                 Depending on the wetland's size and issues raised, a good management plan will likely run some 50 to 150 pages
                                 and include a fair amount of background information. Since LCPs themselves are already quite bulky documents
                                 and any revision to them requires Coastal Commission review, the advisability and popularity of adding entire
                                 management plans to them may be low. Alternatives, such as incorporating into the LCPs just policy excerpts from
                                 management plans (see next endnote) or separately incorporating plans directly into the CCMP, thus deserve review.
                             166 All but one of the completed management plans have been reviewed and either approved by, or formed the basis of
                                 a project approved by, the Coastal Commission or local government issuing coastal permits. In two cases the plans
                                 provided the background for regulatory review (one permit, one federal consistency) but were not formally
                                 approved by the Coastal Commission. In some cases, the essence of the plans (but not the entire documents) have
                                 been incorporated into local coastal programs certified by the Coastal Commission. The Coastal Commission retains
                                 jurisdiction (e.g., through original permit jurisdiction, appeals, enforcement remediation, previous condition
                                 compliance, federal consistency, or State Parks public works plan approvals) over all of the management plans
                                 currently under preparation, except for the one on Marina!s Vernal Ponds. A plan just released, Habitat Restoration
                                 Group and Mitchell Swanson &amp; Associates, Coastah Vernal Pond Comprehensive Management Plan, Felton, 1994
                                 does not incorporate many of the Coastal Commission staffs comments.
                             167 Some wetland (and former wetland) areas, although shown as privately-owned on assessor's rolls, may be subject to
                                 the public trust.

                                                                        CALIFORNIA COASTAL COMMISSION                                              PAGE 145
<pb n="147" />

                    RECAP, PILOT PROJECT

                    168 California Coastal Commission permit file 3-90-104.
                    169 Harvey &amp; Stanley Associates and William Farrel Associates, Wetlands ManagementlEnhancement and Restoration
                       Programfor the Laguna GrandelRoberts Lake Local Coastal Program, Alviso and Santa Cruz, December 1983.
                    170 Belden, Timothy, et. al., Policy Strategy to Reduce Erosion in the Elkhorn Slough Watershed, Berkeley: University
                       of California School of Public Policy, May 1994, pp. 15-17.
                    171 Jonus &amp; Stokes Associates, Inc., Final Neary Lagoon A4anagement Plan, Sacramento, 1992.
                    172 These plans can likely be completed in the next two years; other mentioned plans in preparation, such as for
                       Watsonville Slough, Schwann Lake, and Soquel Creek and Pajaro, River watersheds can also be incorporated, if
                       completed within a similar time frame.

                    PAGE 146                             CALIFORNIA COASTAL COMMISSION
<pb n="148" />

                                                             A                 4",      A\       A
                                                 1) M r

                                                  .. . ............ .................... . ... . . . ...............

                              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 reading 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 necess     ary, initiate efforts
                     6

                     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.

                                                      CALIFORNIA COASTAL COMMISSION                           PAGE 147
<pb n="149" />

			RECAP PILOT PROJECT

			Background

			HOW INFORMATION IS CURRENTLY MANAGED IN THE REGION

            	      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                             Database vs. GIS
                  information about the permits they review.
                  The County Assessors in both ReCAP              Databses are a vast improvement over hard-copy                                                                                                                                                                                                                          .........          ......... .
                  counties keep tax code information in        sources in terms of accessing information quickly and doing
                  databases. Santa Cruz County and a few       such analytical tasks as sorting data into categories, summing
                  other agencies in the region have            impact assesment.
                  operational GISs and a number of others,        The next step from a database is a Georgraphic
                  including the Commission, are at various     Information System (GIS). A GIS is a database which allows
                  stages of developing GIS capability.         information to be displayed in a mapped form. (databases
                                                               display information in tables or lists).
                                                                  For many aspects of a cumulative analysis, tabular data
                        With the right equipment,this          is sufficient. But for analyzing spatial relationships, such as
       		electronic information is much easier to	   the distribution of permits within a region, a GIS is better
			access and analyze than information kept in  than a database.
			hard-copy sources. However, because each        With a database, locational information can be entered
			agency has a different type of computer      as text into a table, but the analyst must transiate that into a
			system and a unique structure to its         "mental map" before the locational information means
			database or GIS, sharing electronic          anything. A GIS does that as part of its function, and unlike
			information across agencies requires         a "mental map", the GIS can handle millions of separate data
			working out date transfer protocols which    points and make complex calculations that quantify the
			can sometimes be quite complicated. There    spatial relationships between those data points.
			are technological obstacles to overcome-         A GIS also serves as a communication tool because it
			for example, translating date from one       can display the results of analysis in a mapped form that is
			format to another and rectifying geographic  easier for most people to understand.
			reference points.  In addition, there are    The down side to GIS is that they are more complex and therefore more expensive
			often data ownership issues that need to be  to develop and operate than database. In spite of the greater cost, most resource agencies that
			addressed through some kind of formal or     can afford to are investing in GIS technology; however, none of them are throwing out their databases. The best option
			informal agreement. In ReCAP's               seems to be to have both, starting with a database and later
			experience, most agencies are willing to     building a GIS tha can link to the database. This is the
			provide data, but they look much more        course ReCAp recommends for the Commission.
			favorably on two-way data exchanges in
			which they get something they need in exchange for whate 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
			exhanged on an informal "request-reply" basis, formal information exchanges are generally

                  PAGE 148                     CALIFORNIA COASTAL COMMISSION
<pb n="150" />

                                                                               CHAPTER 6 - INFORMATION MANAGEMENT

                     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, utiUing a GIS to integrate diverse
                     informationfrom. the region's resource agencies. Because it is ftinded largely through grants
                     under the Federal Clean Water Act, CAMPITS has focused on water quality data so far.
                     However, CA-WITS 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.

                                                                                            q,
                                                                                                                 k
                     I,- IRS ANNE,                                                                       K111=
                             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

                                                     CALIFORNIA COASTAL COMMISSION                           PAGE 149
<pb n="151" />

                  RECAP PILOT PROJECT

                  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 totrack 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 e;?xly 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.

                        INFO MGMT PROBLEM ONE

                    _44            W

                          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,

                  PAGE 150                         CALIFORNIA COASTAL COMMISSION
<pb n="152" />

                                                                                    CHAPTER 6 - INFORMATION MANAGEMENT

                       cumulative impact management strategies are very difficult to include in the Commission's day-
                       to-day permit review activities.

                       FANAW-6-1@M1,
                               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.

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<pb n="153" />

                 RECAP PILOT PROJECT

                         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
                 occuning 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.

                 Rx                      i

                                        C.
                                         ommissiow:
                     QVI  o. ...ormAh                 Should
                 6th' S1fi rt@T'
                         Expand the ReCAP database into an agency-wide computerized permit tracking system
                         with complementary resource databases. The Commission should evaluate the
                         usefulness of information collected during the ReCAP pilot assessment and, based on
                         that evaluation, develop useful and user-friendly databases for entering, storing and
                         retrieving baseline data about resources, about Commission and locally issued permits,
                         LCP amendments, and about the impacts that development projects are expected to have
                         on coastal resources. As new procedures are developed in response to ReCAP's
                         recommendations (e.g., monitoring guidelines for wetland mitigation projects), the
                         Commission should incorporate the appropriate data fields in the databases to make data
                         entry efficient and cumulative assessments easy enough to include as a routine part of
                         permit review.
                         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 help the
                         Commission monitor its own activities better (e.g., standardized quarterly activity
                         reports, Commission meeting agenda items, automated public notices, shared mailing
                         lists, etc.).
                         Build upon existing CRIC procedures to improve the ability for Commission analysts to
                         locate and retrieve EIRs, technical reports, management plans, and other documents with
                         resource-related information. Extra copies of such documents should be requested from
                         permit applicants, cataloged and placed in the Commission's District library.

                 PAGE: 152                      CALIFORNIA COASTAL COMMISSION
<pb n="154" />

                                                                                   CHAPTER 6 - INFORMATION MANAGEMENT

                               Develop procedures to enter basic data about resources from environmental documents
                               into a database so that the information is easily accessible to permit analysts reviewing
                               other projects. Even if the Commission develops its own resource monitoring program
                               or data exchange protocols with other agencies, project-related documents will continue
                               to be an important source of information that helps the agency track what is happening to
                               the resources over time. Data from these reports should be easily available, with an
                               effective system in place for tracking down the original document for any additional
                               details not in the database.

                               Review and improve the District's record storage, archiving, and retrieval system for
                               important permit-related documents. Develop a more effective system for keeping
                               storage areas organized (i.e. schedule periodic file room clean-up days).

                      In the Short Term, Local Governments Should
                          0    Expand their databases and GISs (where available) to include impact information
                               derived from review of development permits (e.g., acres of wetland disturbed, length of
                               shoreline protective devices erected, etc.). The revisions should incorporate those data
                               fields found to be useful in ReCAP's analysis. The fields should be added in such a way
                               that local governments and the Commission have information that corresponds and can
                               be combined to get a picture of what is happening in the region's entire coastal zone.
                               ReCAP can assist local governments in the pilot region by transferring the information
                               collected on local permits as part of the ReCAP effort in addition to the records of
                               Commission permits that pre-date local certification.

                      In the Long: Tenn, tho'Commission Should,:
                          *    Develop a Geographic Information System (GIS).      The GIS should be able to show
                               permit analysts where past, present, and known future development projects are located,
                               identify the resources potentially impacted by a project, and perform analysis on the
                               cumulative impacts of that and other nearby projects.
                          *    Develop a resource monitoring program of its own to fill in needed information that
                               cannot be obtained from other agencies. This would provide two important benefits: (1)
                               the Commission would have a more complete picture of the resources it is charged with
                               managing, thus enabling better management decisions; and (2) it would provide data that
                               the Commission could trade for data that other agencies are collecting. Without having
                               something useful to trade, it is unlikely that other agencies would continue to provide the
                               Commission with information that they had to spend money to collect.

                          *    Encourage local governments without GISs to develop such systems by providing
                               technical assistance and identifying potential funding sources. Local governments
                               should be encouraged to develop systems that are compatible with others in the region,
                               including the Commission's.

                                                       CALIFORNIA COASTAL COMMISSION                             PAGE 153
<pb n="155" />

                  RECAP PILOT PROJECT

                        NMI* MGMT PROBLEMTWO

                          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.

                                                                 T="'
                                        FFN 1-W      R-IR
                  007-AM041 9ESKM ONE                                Off,
                                                     Z
                  h::Mmaz                         WE @
                          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 mitigatiom. 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
                  m
                       ation projects that required moni      .2                         -up on these permit
                    itig,                               toring The inconsistent follow
                  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.

                  PAGE! 154                       CALIFORNIA COASTAL COMMISSION
<pb n="156" />

                                                                                  CHAPTER 6 - INFORMATION MANAGEMENT

                      Kit M!&amp;N5AfIdNt,-
                                                                                                                   .......... .. ......

                      In the Short Term,. the Commission Should:
                              Continue developing improved procedures for tracking permit conditions which require
                              post-permit review, such as monitoring. The permit tracking database currently being
                              developed by ReCAP should be designed to include a standard report that lists all
                              permits with outstanding permit conditions, the nature of the conditions, the due dates of
                              any materials required under the condition (e.g., monitoring reports), and the name of the
                              analyst responsible for each item.

                           INFO MGMT PROBLEM THREE

                              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 ig available from other agencies and are not able to access information that is
                      available because of technical and political obstacles.

                                                                                                   TMU'm F-01 T          py,
                                                                                                                         ,, q
                                                                                      go                    I     V      ,
                              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 Reaeation 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

                                                       CALIFORNIA COASTAL COMMISSION                              PAGE 165
<pb n="157" />

                  RECAP PILOT PROJECT

                  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.

                          .@MEN NOT-1

                   -Thii: Shdrt,Term; Thw   orn i        Sh ld:
                  n                             misionr ....owd:
                          -Support the development of, and where necessary initiate, data sharing protocols with
                          other agencies in the ReCAP region. Where possible, the protocols should be formalized
                          in Memoranda of Agreement, including agreements to share the costs of collecting
                          information. To the extent possible, the Commission should continue to coordinate with
                          CAMPITS and through the Monterey Bay Initiative in order to develop such protocols
                          and agreements.

                       IN&amp; MGMT PROBLEM FOUR

                          Additional staffing and/or training is needed to support the modem information
                  management tools currently being developed by the Commission. In addition, adequate staff
                       n              -
                  time needs to be set aside for training analysts and support staff in how to use these tools
                  efficiently and effectively.

                  [AM,
                          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.

                  IMVAM@R,A@M@W,N@

                  nAh0::ShdK@,Tdnn   the Qmmisslow Should.
                          Expand its staffing in information management and/or increase training to existing staff
                          to provide for a hardware technician and a software technician that are familiar with the
                          new generation of desktop computers, networks, and software. Providing adequate
                          technical support for analysts as they learn the new system will be crucial to successful
                          implementation of better information management.

                  PAGE 156                        CALIFORNIA COASTAL COMMISSION
<pb n="158" />

                                                                                     CHAPTER 6 - INFORMATION MANAGEMENT

                               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.

                       IFor example: COASTAL DEVELOPMENT PERMIT FOR SINGLE FAMILY DWELLING, ACCESSORY
                         STRUCTURES AND GRADING; USE PERMIT FOR SEIVIOR CITIZEN UNIT, etc..
                       2ReCAP database, Hazards and Wetlands Sub-Modules.
                       3The exception was the Army Corps of Engineers' permit database which did not have the capability of identifying
                         which permits were located in the ReCAP area. ReCAP had the choice of getting all the data (an unmanageable
                         quantity) or none at all.

                                                         CALIFORNIA COASTAL COMMISSION                              PAGE 167
<pb n="159" />

                                                        . ..... .. . ........ . ... .. ........ . .. .... ..................

                              The recommendations of this report are not presented in any priority and do not
                      constitute a mandate on local jurisdictions. Many factors will undoubtedly enter into a decision
                      by the Commission or local government as to which of these recommendations to pursue first.
                      Included in these factors will be the economic effects of implementing the recommendation and
                      identification of a suitable funding source, if needed. Many of the recommendations are not very
                      costly and could be implemented through minor changes in the ongoing activities of coastal
                      planners. Project resources preclude the Commission staff from conducting detailed costfbenefit
                      analysis on each of these recommendations. However, it is important to consider the general
                      economic effects -- positive and negative -- that may occur as a result of these suggested
                      program improvements. ReCAP will be looking for opportunities to implement
                      recommendations in conjunction with ongoing, funded initiatives.

                      Run=                                                   I=
                              Economic activity along the coast is influenced by a number of factors, some of which
                      are beyond the scope of coastal management (e.g. population growth). Recent studies have
                      documented the positive economic benefits of sound coastal management! A recent report by
                      The Resources Agency concluded that seven ocean-dependent industries contributed $17.3
                      billion dollars to the state's economy in 1992 and supported 3 70,000 jobs in the state. Ocean and
                      coastal tourism and recreation alone contributed $9.9 billion in 1992, the largest spending
                      component of the industries examined in the study.  2 In addition, the shoreline area supports a
                      significant amount of residential development which contributes to the economies of local
                      communities. As the following sections illustrate, it appears that implementing these
                      recommended program improvements will contribute to the overall economic benefits of coastal
                      management.

                              The recommendations of the ReCAP report for improving hazards management suggest
                      improvements designed to minimize additional armoring of the shoreline and attendant loss of
                      sandy beach area, and measures to protect sources of sand for maintaining natural shoreline
                      processes needed to maintain the beaches. The recommendations also include minimizing
                      development in geologically unstable areas, thereby avoiding hazards. These objectives would
                      be achieved in part by implementing regional management plans for hazardous areas and by
                      improving policies for new development.

                              Implementing these recommendations could result in significant benefits. Public costs
                      associated with disaster relief, construction of protective armoring, government assistance
                      insurance, and environmental costs from arnioring on public trust lands are minimized or
                                                                          3
                    7

                      avoided when development avoids hazardous sites. Public beaches which are critical to the

                                                       CALIFORNIA COASTAL COMMISSION                             PAGE 159
<pb n="160" />

                  RECAP PILOT PROJECT

                  local tourism economy would be protected from encroachment of shoreline protective devices,
                  and the need for beach replenishment would be also reduced. Beach replenishment, while
                  resulting in public benefits from protecting property and recreation areas, is costly. Nationwide,
                  the Army Corps of Engineers has nourished an estimated 118 miles of beaches at a cost of $3 06
                  million. The use of public funds for subsidized loans to rebuild houses destroyed by waves
                  would also be lessened. For property owners, implementation may result in less costs for
                  construction of protective devices. (The cost of armoring varies by type of structure, but typical
                  costs for installation of riprap ranges from $500 to $1000 per linear foot.5) Frequent repair,
                  rebuilding or maintenance costs for the structures would be lessened. After management plans
                  are implemented, they will provide better information for property owners regarding identified
                  and mapped hazard areas, erosion rates and alternative options; use of this improved information
                  can reduce costs by speeding the siting and permit processing.

                          While development may be sited for greater long term stability, it may have less
                  dramatic edge-of-the-bluff private views. Property owners may incur costs from removal of
                  temporary emergency structures but will incur savings from not having to continually place
                  emergency armoring each year. Such program improvements will, however, require funds for
                  developing or revising specific land use and engineering plans, implementing ordinances and
                  codes, and more specific monitoring and follow-up measures. The largest public costs would be
                  associated with any recommendations that lead to the condemnation and purchase of unbuildable
                  lots on hazardous sites. Such recommendations were specifically identified only as a last resort
                  if other measures were ineffective and if public benefit was considered greater than the costs.

                          Pursuing modification to the Coastal Act would require Commission and local
                  government staff time to develop a workable legislative response; the resulting improvements to
                  coastal management may serve to protect the beach and shoreline resources which many local
                  economies rely upon for recreational and tourism revenues.

                          04-
                          The recommendations of the ReCAP report for improving access management suggest
                  improvements to maximize access by improving the mitigation of impacts from development,
                  addressing issues beyond the provision of physical access, and ensuring the long-term quality of
                  the recreational opportunities in the region. Coastal tourism plays a vital element in the
                  economies of a number of communities in the ReCAP area; implementing the ReCAP
                  reconamendations, particularly the management plans, will help to protect the long-term value of
                  the shoreline for recreation and tourism.

                          Suggested program improvements to revise procedures to record public easements and
                  delineate state public trust lands could create more opportunities for public use of the shoreline
                  and would protect existing public areas from encroachment of development. Revising
                  procedures could also result in some savings for property owners by streamlining the time
                  required to process development permits. In addition, information management improvements
                  would contribute to reduced time and costs associated with these procedures. Revising plans and
                  procedures will, however, require commitment of state and local staff time.

                          As noted above, implementation of the hazard recommendations also helps to maximize
                  pubfic access and recreation use. While planning costs and local staff time will be incurred in
                  developing LCP amendments, implementation of revised LCP polices on hazards will contribute
                  to the long term protection of sandy beach and improved aesthetic quality of recreation areas
                  which is critical for continued growth of tourism and for growth of related commercial
                  recreation.

                          Since few agencies currently track and monitor access and recreation on a consistent
                  basis, implementing the recommendation to develop baseline information and improved tracking

                      PAGE 160                     CALIFORNIA COAS  TAL COMMISSION
<pb n="161" />

                                                                    CHAPTER 7 - ECONOMIC EFFECTS OF RECOMMENDATIONS

                       of visitor use and demand could help management agencies improve the allocation of limited
                       resources to best respond to user needs; this will contribute to better access to recreation
                       resources in the long term. Increased demands on local park and recreation agencies for
                       developing baseline information and monitoring could be minimized by incorporating efforts as
                       much as possible into the current operational routines of the local agencies and by developing
                       partnerships with community organizations that benefit directly from well-managed beach access
                       (e.g. dive groups, swim clubs, visitor associations, etc.)

                               Implementing changes in plans and procedures designed to maximize parking and
                       upland support facilities could result in more areas designated for upland commercial recreation
                       development thus contributing to the local economy and maximizing access to the shoreline.
                       Carrying out these changes will have costs associated with revising LCPs and ordinances.
                       Additional construction costs may be incurred by developers to incorporate parking changes into
                       project designs.

                               As part of the longer term recommendations, development of a regional access strategy
                       could result in increased governmental efficiencies through joint management and operation of
                       areas and sharing of limited resources among jurisdictions. The provision of upland support
                       facilities could improve as a result of a more coordinated access strategy among jurisdictions.
                       Developing interjurisdictional access strategies will require time and resources from all relevant
                       agencies. Implementing a strategy may result- in additional costs to accept and open high priority
                       access easements.

                               Long term protection and management of significant shoreline resource areas for a
                       variety of users will result in contributions to the tourism segment of the economy by helping to
                       assure a wide range of diverse recreational experiences.. Preservation of resource areas will
                       contribute to maintaining the quality of the access experience and thus a higher tourism value.
                       Research on user demands and the changing demographics of users would also help recreation
                       planning more directly serve the public and help increase the use of the facilities and resources.
                       However, additional costs may be required to complete resource management plans for sensitive
                       areas where access is provided. Planning and survey costs to assess and respond to user demand
                       would be significant, estimated to be at least $50,000.

                               The ReCAP recommendations generally focus on measures to improve wetland and
                       watershed management to further protect these sensitive areas. Many of the recommendations
                       do not suggest major new initiatives but rather improvements on existing efforts by
                       incorporating revised procedures or policies. Some of the recommendations could result in
                       improved management of these sensitive resources upon which tourism and fishing segments of
                       the economy depend, but may change the activities allowed adjacent to sensitive wetlands, such
                       as restricting some activities within larger buffers. Generally, however, the recommendations do
                       not contemplate changes in the currently permitted uses of wetland areas.

                               Several of the wetland recommendations involve commitment of local and state agency
                       time and resources to conduct technical planning studies and to develop and implement LCP
                       amendments that would improve management of wetlands and the watersheds critical for their
                       long term health. While this may require project applicants to conduct different studies and
                       submit additional information, the effort recommended to compile inventories and to standardize
                       procedures could result in substantial savings to applicants and reviewing agencies by
                       streamlining regulatory review and increasing clarity in the application process.

                               Longer term improvements to develop regional wetland and watershed plans and
                       interagency management strategies could yield greater savings through more efficient uses of
                       limited resources and more effective management of resources. A shift to greater interagency

                                                        CALIFORNIA COASTAL COMMISSION                             PAGE 161
<pb n="162" />

                     RECAP PILOT PROJECT

                     coordination may require a commitment of agency staff time. An overall watershed planning
                     effort will also help ensure that property owners and planners have better information in advance
                     of project planning, leading to improved resource protection and streamlined permitting
                     procedures. Also, such long range planning and management could contribute to improved
                     water quality in the Monterey Bay Sanctuary. Much federal funding is currently directed to
                     water quality planning and it is anticipated some of these efforts could be undertaken in
                     conjwiction with these programs.

                     IMIRK         "T                                   'C" 'M
                             The recommendations of ReCAP are directed to using electronic technology to make
                     day-to-day regulatory activities more efficient. Implementing new electronic information
                     management measures can result in great savings in staff time required to analyze information
                     and can provide quicker service to the public who need access to Commission information.
                     Implementation of the recommendations to improve information management and sharing will
                     require a larger investment in obtaining needed equipment, developing programs and procedures,
                     and training staff in the use of new technologies and equipment. Some local agencies have
                     already taken this step and future costs would generally be needed for expanding existing
                     capabilities. However, much greater costs will be incurred by remaining with slower,
                     predominately manual information retrieval. Improving information sharing among agencies
                     could also lead to increased benefits to property owners by making the regulatory review process
                     quicker and easier.

                             While there afe costs and benefits associated with each individual recommendation,
                     overall, the picture that emerges from the pilot project is a positive one. Major efficiencies can
                     be gained, resource management savings achieved, and recreation and tourism segments of the
                     economy enhanced for the price of the initial investment in planning and policy improvements in
                     the LC Ps.

                             It is a continuing objective of ReCAP implementation to find ways to assist local
                     agencies in helping to implement these recommendations, including finding alternative funding
                     sourculs.

                     ICoast Alliance, State of the Coasts, June 1995.
                     2State of California, The Resources Agency, California's Ocean Resources: An Agendafor the Future, July 1995
                      (Draft), pg. ES-3, and 5G-1.
                     3Griggs, G. et. a]. California's Coastal Hazards: A Critical Assessment ofExisting Land Use Policies and Practices,
                      Cali fornia Policy Seminar Research Report, University of California, 1992, p.60.
                     4Griggs, p. 58.
                     5 Griggs, p. 56.

                        PAGE 162                         CALIFORNIA COASTAL COMMISSION
<pb n="163" />

                             This Appendix summarizes the changes that ReCAP identified with respect to public
                     access opportunities in the pilot region for the period between 1981 and 1993. To facilitate its
                     assessment, ReCAP divided the pilot study area into geographic sub-regions, or complexes.
                     These complexes are broadly divided based on location, environment, and types of use received.
                     The name and location of each complex is shown on Figure 4-4, page 47.

                             Although several formal vertical access sites exist in the complex (e.g., Greyhound
                     Rock), much of the access in this section of the coast has historically been achieved through
                     informal trails down cliffs and sometimes across private property. While these informal trails
                     continue to provide much of the access available today, several new beaches were opened for
                     public use since 198 1: the County developed Scott Creek Beach and the California Department
                     of Parks and Recreation opened Wilder Ranch State Park. Prior to 198 1, Four Mile Beach (part
                     of Wilder Ranch State Park) had been available for public use; however, the opening of the rest
                     of the park provides the opportunity for public use at several additional beaches. Several private
                     beaches in the complex also became available for use: Davenport Landing Beach, Davenport
                     Beach, Panther Beach, Yellowbank Beach, and Laguna Creek Beach.' These additional beaches
                     represent approximately 3.7 miles of shoreline. However, it should be noted that especially in
                     this region ofthe coast, many of these beaches may have been well used prior to their "official"
                     opening.

                             Although a significant loss of trails to the beach and along the bluffs had been identified
                     between 1948 and 1980, 2Commission staff review of aerial photographs between 1986 and 1993
                     show minimal changes in access paths in the region. However, field visits indicate severe 3
                     erosion along many of the bluffs, which may affect the ability to use some of the existing trails.

                                                                                              @ 71111
                             Since 1981, the City of Santa Cruz has installed several stairways along this stretch of
                     coast; only one vertical accessway was available previously.4In addition, the former Lighthouse
                     City Park expanded and became part of the State Park System, although it is managed by the
                     City of Santa Cruz. The city also developed the park with facilities and a walkway along the top
                     of the bluff overlooking the beach.

                                                                               WWW'@
                                                     501F X,
                     UNW, AU'r-', 0"',
                             Significant improvements to the Santa Cruz Harbor have occurred since 1981, including
                     several stairs/walkways to and around the harbor, picnic tables, parking, and summer moors for
                     boats. Several improvements at Twin Lakes State Park are evident: an accessway to the beach
                     was added, San Lorenzo Point overlook was opened, and a blufftop pathway was completed. In
                     addition, Antonelli Pond was improved for public access.

                             Physical access to this part of the coast was significantly improved between 1981 and
                     1993 with the addition of access to the beach at Corcoran Lagoon Beach, 26 th Avenue, and an

                                                   CALIFORNIA COASTAL COMMISSION                         PAGE A-1
<pb n="164" />

                  RECAP PILOT PROJECT

                  overlook at Rockview Drive. Two stairs that were closed in 1981 (Pleasure Point and Opal
                  Cliffs) were reopened, although Opal Cliffs access requires payment of a fee to receive a key to a
                  locked gate. Additional stairs have also been added to the Pleasure Point Beach area.   The
                  opening of these beaches represents approximately one mile of beach access.

                                                         F -I -   - -                          I -,
                        I " "                                                 '1@.         - @,,, - M
                         11TO
                          The primary change in physical supply of access noted is the addition of a stairway from
                  the Capitola Wharf to the beach. Capitola, however, has had a significant amount of access
                  points to the beach existing prior to 198 1. The California Coastal Conservancy acquired Hooper
                  Beach, a private beach which has historically allowed public access, and installed a stairway
                  down the bluff to improve access.

                          I F '- --
                  17SO-0    fS, " NaMMIC
                          The County provided new access at Hidden Beach, representing increased access to
                  approximately one-tenth of a mile of beach for public use. A significant amount of the coastline
                  in this complex that is not under the jurisdiction of the California Department of Parks and
                  Recreation has been, and remains, inaccessible to the public due primarily to a lack of vertical
                  access in the La Selva area. The new development at Seascape, however, provided access north
                  of Lundborgh Beach. The Manresa State Beach uplands campground was also opened.

                          A primary change in access in this complex is evident through the installation of
                  boardwalks at Zmudowski, Salinas, and Moss Landing State Beaches. While the boardwalks do
                  not add new access points, they significantly improve the accessibility of existing sites. In
                  addition, the repair of Sandholdt Road restored access to Moss Landing State Beach after the
                  1989 earthquake. Further improvements around Moss Landing include expanded boat facilities
                  and public parking at Moss Landing Harbor.

                          Access was also improved significantly with the development of trails in the Elkhorn
                  Slough Reserve and through the construction of the Kirby Park boat launch. Access easements
                  will also provide access along Moro Cojo Slough when they are accepted and opened for public
                  use.

                          The Monterey Peninsula Regional Park District acquired approximately seven acres of
                  coastal dunes for public use. Access at Marina State Beach was improved through the extension
                  of boardwalks, and a hang-gliding concession and platform were installed. Two new parks were
                  also developed at Locke Paddon and KIDD pond.

                  "M M N V 1 _@Tyzl S_
                                  ,@4
                                     @'S@Qg@,V
                                                   @TTE R
                          Much of the coastal access in this complex is informal trails to the beach. A new vertical
                  access point to the beach was developed from Roberts Lake since 198 1. Access across the Post-
                  Graduate Naval School was improved and formalized with a boardwalk through the dunes; this
                  area had previously been posted with No Trespassing signs, although public use of the beach was
                  evident through informal paths across the dunes. Boardwalks were also installed at Del Monte
                  Beach, and a pedestrian path was developed around Laguna Grande for public access.

                  PAGE A-2                        CALIFORNIA COASTAL COMMISSION
<pb n="165" />

                                                                                     APPENDIX A - ACCESS IMPROVEMENTS 1981-1993

                                          'CITY,                     -
                                                                    -7-
                         MONTEREY
                                                                                    ..... .......            . ........ . .
                                  A primary improvement to access in this area was the development of the Monterey
                         Peninsula Recreation Trail. Vertical and lateral access was also improved with the development
                         of several new beach parks and access points at San Carlos Beach, Aeneas Beach, and Macabee
                         Beach, as well as several public plazas near the shoreline. Many of the access improvements
                         resulted from conditions of coastal development permits.

                                                                                                                   7%
                         @7A
                                                                                                                          M -7
                                  As with the Monterey City area, the development of the Monterey Peninsula Recreation
                         Trail significantly improved access along the shoreline throughout Pacific Grove. Perkins Park,
                         a bluff top park, was also developed, although access to the shore already existed from this area.
                         Access at Asilornar was improved by formalizing access points and providing a boardwalk
                         through the dunes to the shore in conjunction with dune restoration.

                         L_1LE_CM:Q_'_
                                       @,7@7 , @Rl
                                  Access at Del Monte Forest was significantly improved during this time period, in large
                         part due to the conditions on two permits granted for development. The public gained use of
                         Stillwater Cove, a private beach, although the hours and total number of people allowed at a
                         given time are limited. Access was improved to several other beaches in the northern section of
                         the forest through the development of two pedestrian trails, one of which connects to the
                         Asilomar State Park boardwalk. However, approximately 136 acres of vacant land that had
                         historically been used for recreation was converted to the Spanish Bay Resort. Though access
                         through the Del Monte Forest has historically been allowed, a fee is required to enter by car.

                                  Historically the Carmel complex had a significant number of vertical access points to the
                         beach area. Two additional stairs were added since 1981. Access to Carmel River State Beach
                         was improved by formalizing an access trail, and two        5access points from Carmel Meadows
                         (south of Carmel River State Beach) were developed          .  The city also created a pedestrian
                         walkway and replaced stairs along Scenic Drive that had been damaged by storms in 1983.

                         7F
                                  No significant changes in access were noted in this complex since 1981.

                         I Although the California Access Guides do not identify these beaches as available for public use in 198 1, the Santa
                           Cruz County Local Coastal Plan does identify trails to the beaches in 1980. California Coastal Commission. 1991.
                           California Coastal Access Guide.
                         2 Santa Cruz County. 1980. Working Paper: Public Accessfor Santa Cruz County Local Coastal Program.
                         3 California Coastal Commission staff. January I-February 2, 1994. Field observations.
                         4 California Coastal Commission. 1981. California Coastal Access Guide.
                         5 California Coastal Commission staff. June29-30,1993. Field observations.

                                                             CALIFORNIA COASTAL COMMISSION                                    PAGE A-3
<pb n="166" />

                                                                                   R

                                                    . .. . .. .. ............ .. ..................... . . . . . . .. ....................

                                  One of the key issues in assessing public access is determining if improvements are
                         keeping pace with population growth, use, and/or development in the area. In order to undertake
                         this analysis, ReCAP needed to quantify the improvements in access and compare them with
                         growth in the region. To do so, ReCAP identified all vertical access points in the region existing
                         in 1993 and areas of the coast that could support access but currently do not; areas with steep
                         bluffs dropping directly into the sea were not included since access to the shore would be
                         infeasible. I ReCAP then rated these areas according to the availability of access, based on the
                         scale below, for a base year of 1981 and for 1993.        2

                         Access Ratin=
                            0.0   no access
                            0.2,  unknown, but historic use probable due to location/geography of site
                            0.3   private beach with informal trails to beach
                            0.5   public beach with informal trails to beach
                            0.7   private beach with developed access to beach (i.e. stairs or boardwalks)
                            0.9   public beach with developed access (i.e. stairs or boardwalks)
                            1.0   site meets access standards in local coastal program and has developed accessway

                                  TablG B- 1 shows the results of the analysis. A weighted rating was calculated for each
                         site by multiplying the site's rating by the miles of beach at that site. A total was obtained for
                         each complex by summing the weighted ratings of all the sites in that complex. Except for Point
                         Lobos, which already provided excellent public access in 1981, every complex in the region
                         improved the supply of vertical access.

                                     TableB-l: Comparative Improvement in Physical Access to the Coast in the ReCAP Region

                                    Complex              TotalMiles Sumof.1981                 Sum,of.1993         Improvement
                                                           of Beach. Weighted ratings       Weighted:rAtings ftom][981to'1993
                         North Santa Cruz County              6.35             3.9                  5.9                 50.6%
                         West Cliff Drive                     0.80             0.5                  0.8                 66.7%
                         Santa Cruz City                      3.55             2.3                  3.4                 49.4%
                         East Cliff Drive                     1.90             0.9                  1.8                 97.8%
                         Capitola Area                        1.08             1.0                  1.1                 5.7%
                         South Santa Cruz County              11.45            7.6                  9.1                 20.1%
                         Santa Cruz County Subtotal           25.13            16.2                 22.0                36.4%
                         North Monterey County/               10.50            3.7                  4.3                 16.1%
                         Elkhorn Slough
                         Marina Area                          1.65             1.2                  1.3                 9.4%
                         Sand City/Seaside/Monterey           7.25             1.4                  1.5                 11.9%
                         Monterey City Area                   1.15             1.0                  1.2                 17.9%
                         Pacific Grove Area                   4.30             3.5                  3.6                 2.5%
                         Del Monte Forest Area                2.40             1.5                  1.7                 13.1%
                         Carmel Area                          3.00             2.4                  2.6                 10.9%
                         B

                         Point Lobos                          4.20             4.2                  4.2                 0.0%
                         Monterey County Subtotal             34.45            18.8                 20.4                8.4%
                         TOTAL                                59.58            35.0        @-42.5                       21.4%

                                                              CALIFORNIA COASTAL COMMISSION                                   PAGE B-1
<pb n="167" />

                  RECAP PILOT PROJECT

                           To relate these improvements to the increase in demand for access, ReCAP needed to
                  compare the areas having increased use with improvements to access in those areas. Since the
                  data fm actual use of sites is limited, ReCAP used both population increases and the amount of
                  new development for the various areas in the ReCAP region as indicators of increasing use.
                  While: these figures do not indicate actual use of coastal access sites, they do indicate areas of
                  growth; it is likely that an increase in population and development corresponds to an overall
                  increase in use of the area, especially in areas known for high coastal recreation like the pilot
                  region. In fact, since an increase in tourism is not considered, the actual increase in use will
                  likely be greater than that estimated from population growth in the region and development
                  increases.

                           Table B-2 shows the population growth for the coastal zone cities in the ReCAP region,
                  and for each county as a whole. While Table 13- 1 and Table B-2    3 show a general correlation
                  between areas with population increase and improved access, a few exceptions are evident.
                  While Watsonville grew significantly since 1980, the city does not physically border the coast,
                  and therefore cannot improve its coastal access. However, the increased population probably
                  places additional demands on coastal access sites near Watsonville. Although many areas within
                  Monterey County significantly improved coastal access, the overall improvement falls well
                  below the population growth for the County, particularly due to growth in the Marina area. The
                  City of Marina did however develop two parks: Locke Paddon and KIDD pond. Although they
                  do not provide coastal access, the parks do provide recreational opportunities. In addition,
                  although th@e City of Capitola grew in population at a fairly high rate, its improvements to access
                  supply are minimal. However, Capitola has historically provided significant amounts of beach
                  access; the improvements undertaken between 1981 and 1993 appear to have maximized
                  physical access in the City to the greatest extent possible.

                                           Table B-2: Population Growth in ReCAP Cities, 1980-1990

                                                                        uns q iow   ....         '..X'th t d'.
                                                                                                    S Mae :@Gftwth--*@@
                  Santa Cruz County                                   Monterey County
                  Capitola                     11.8%                  Carmel                       10.5%
                  Santa Cruz                   18.2%                  Marina                       28.0%
                  Watsonville                  31.4%                  Monterey                     15.8%
                                                                      Pacific Grove                2.3%
                                                                      Sand City                    5.5%
                                                                      Seaside                      6.4%
                  Santa Cruz County:           21.90/6                Monterey County:             23.9%
                  incorporated area                                   incorporated area
                  Santa Cruz County:           22.2%                  Monterey County:             18.9%
                  unincorporated area                                 unincorporated area
                  County Total                 22.1%                  County Total                 22.5%
                 - =dopted from Department 'ofnnancc'

                           The ReCAP region has experienced significant development since 1981. Much of this
                  development has probably contributed to the overall increase in recreation use. Review of aerial
                  photos (1978 and 1993) shows major areas of development in Santa Cruz County south of
                  Capitola through the La Selva area, along with infilling in the Live Oak area. In Monterey
                  County, significant development was seen in the Marina area. While not all of this development
                  may be in the coastal zone, and most is not directly adjacent to the beach, it likely leads to
                  increased demand for access. Improvements to access in these areas include several stairways in
                  the Live Oak area, significant improvements at Santa Cruz harbor, two new access points in
                  southern Santa Cruz County, and the development of two parks in Marina.

                  PAGE B-2                          CALIFORNIA COASTAL COMMISSION
<pb n="168" />

                                                                                   APPENDIX B - QUANTIFYING ACCESSIBILITY

                               Many of the areas that currently do not meet the access standards identified in LCPs
                        have had significant amounts of development nearby. However, many of these areas cannot
                        support additional vertical access, due to the geography of the site. These areas include West
                        Cliff Drive, Opal Cliffs Drive, and the southern end of Capitola Beach to New Brighton Beach.
                        In addition, areas near the Hopkins and Long Marine labs and north of Marina dunes area
                        probably could not support access due to research needs and conflicts with habitat protection.

                                To assess the amount of future vertical access feasible, ReCAP compared the ratings
                        calculated in Table B-1 to a theoretically possible rating of I for each access site for 1981 and
                        1993. Totals for each complex were then determined (see Table B-3). These calculations show
                        the extent that access could still improve in each complex. The percent of maximum does not
                        indicate the percent of coastline in the complex with available access, but represents how much
                        additional access can physically be provided. For example, West Cliff Drive shows maximum
                        physical access is now available. While there are stretches of the coast in this complex without
                        vertical access, those areas cannot physically support access due to physical constraints. Where
                        access can be provided, it exists and meets the standards of the local coastal plan; therefore the
                        complex provides access at 100% of the maximum possible. This analysis suggests that much of
                        Santa Cruz County is at, or near, its capacity to provide physical access to the shore.

                                         Table B-3: Percent ofMaximum Physical Accessibility, 1981 and 1993

                                                                                                        'of'r
                                                                                         -of,
                                                                                            Max;,
                                                       Comp ex,'                         A,               99
                                                                                         vt 'k          "
                                     North Santa Cruz County                             61.8%          93.1%
                                     West Cliff Drive                                    60.0%          100.0%
                                     Santa Cruz City                                     63.5%          94.9%
                                     East Cliff Drive                                    47.6%          94.2%
                                     Capitola Area                                       94.7%          100.0%
                                     South Santa Cruz County                             66.2%          79.5%
                                     Santa Cruz County Subtotal                          64.3%          87.7%

                                     North Monterey County/Elkhorn Slough                35.0%          40.6%
                                     Marina Area                                         74.2%          81.2%
                                     Monterey/Seaside Area                               18.6%          20.8%
                                     Monterey City Area                                  84.8%          100.0%
                                     Pacific Grove Area                                  82.3%          84.4%
                                     Del Monte Forest Area                               61.9%          70.0%
                                     Carmel Area                                         79.7%          88.3%
                                     Point Lobos                                         100.0%         100.0%
                                     Monterey County Subtotal                            54.6%          59.2%
                                     TOTAL                                               58.7%          71.3%

                        1 It should be noted that bluff top lateral access could often be achieved in these areas.
                        2ReCAP based the ratings on the development of vertical access, but did not include improvements to facilities such as
                          parking or picnic areas at a site. Although the availability of such facilities is important to the use of a site, they do
                          not affect whether the actual physical supply exists. For this particular analysis, ReCAP sought to quantify only the
                          increase in physical supply.
                        3The City of Santa Cruz encompasses the complexes of West Cliff Drive, Santa Cruz City, and East Cliff Drive.
                        4Department of Finance. 1992. Population and Housing Estimatesfor California Cities and Counties. Report E-
                          8090CITY.

                                                         CALIFORNIA COASTAL COMMISSION                              PAGE B-3
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                                                 3 6668 00001 8210
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