‘Erodible’ infill on Solana Beach’s bluff rebuffed by Coastal Commission
The California Coastal Commission last month rejected a proposal to install concrete infills that would bolster a 90-foot gash in Solana Beach’s bluffs — a reversal in policy that commissioners justified by saying the time has come to make “hard decisions” that back California away from armoring its shoreline.
The case concerns two homes on Pacific Avenue, immediately north of Fletcher Cove Community Center — that of Robert Monroe and his neighbors to the south, Norm and Gretchen Sloan. State engineers do not consider the homes to be in imminent danger, but say that filling the 90-foot notch with the concrete mix will stave off the bluff’s collapse.
Such infills — hailed by proponents as “erodible concrete” but as a de facto seawall by environmentalists — have been used to preemptively combat bluff erosion for more than 20 years, a stopgap measure to larger, more intrusive seawalls that most experts believe hasten narrower beaches.
The infill question is unique to Solana Beach’s geology. Its bluffs have a layer of loose, sandy material — known as “clean sand lens” — between its sheets of sandstone. When that layer is exposed, the sandstone could collapse, setting off a geologic cascade that would require, by law, a seawall to protect the endangered homes above.
After a pair of highly technical hearings in November and December, the Coastal Commissioners voted 7-3 (with one abstention) to reject the infill. Last week, Monroe and the Sloans asked the Coastal Commission to reconsider its ruling. The new hearing could come as early as March.
The saga dates back to 1998, when Monroe and a half-dozen of his neighbors on Pacific Avenue applied for a permit to fill a sea cave below their homes. The Coastal Commission rejected that permit in favor of a less extensive infill set back into the bluff — work that had to be redone in 2005 after the concrete mixture eroded too quickly.
Two years later, a wide sandstone ledge collapsed below Monroe’s northerly neighbors, exposing the sand lens. Flummoxed to see the Coastal Commission sign off on a 35-foot-tall seawall for his neighbors but not his less-intrusive infill, Monroe withdrew his application in 2010 and waited for Solana Beach to craft its Land Use Plan (LUP). The LUP, which the Coastal Commission approved in 2014, embraces preemptive infills. At least two infills have been approved in Solana Beach since, prompting Monroe and the Sloans to query the Coastal Commission once again.
Framing the project as a preemptive alternative to a seawall, D. Wayne Brechtel, their lawyer, argued at the Coastal Commission’s Dec. 13 hearing that infills have far less impact while giving local and regional officials more time to develop non-armoring methods such as sand replenishment and sand retention.
“Our project is specifically designed … to avoid the need for permanent shoreline protection,” Brechtel said. “Erodible concrete is not a seawall. It’s far weaker than concrete. It’s 90 percent sand. There’s no rebar. It’s designed to retreat.”
But infills have been met with stiff pushback from the Surfrider Foundation, which cites a lack of data on infills’ erodibility and a history of homeowners refusing to report on their progress. They need point no further than the 1996 infill below the Solana Beach & Tennis Club, which eroded too slowly and now juts out several feet from the natural bluff.
“I keep hearing that hypothetically this is better than a seawall. The reason that we’re here and we keep fighting this is that from our standpoint, this essentially is a seawall. It fixes the back of the beach where it is today,” said Julia Chunn-Heer, policy manager for Surfrider’s San Diego chapter. “Erodible concrete doesn’t work —and if it does, it’s just a seawall.”
The technology should be proven to work before it is installed, she said as she showed photos of the previous infill below Monroe’s home jutting out as much as a foot from the natural bluff.
“We believe this is a pathway to circumvent the law and a way to get a seawall where you would otherwise not be entitled,” she said.
Coastal Commission staff had recommended approving the Monroe/Sloan application with several conditions, mostly relating to requirements to report back on the concrete’s erosion and to repair any sections that jut out by six inches or more. Four recent infill projects “appear to be functioning as designed,” said a Coastal Commission analyst, citing “strong evidence infills can and do work as proposed.”
John Ainsworth, the Coastal Commission’s executive director, described erodible concrete as an interim step in the agency’s broader discussion of sea-level rise, which the Coastal Commission is trying to address as cities update their Local Coastal Program over the next several years. That process in Del Mar, one of the first jurisdictions in San Diego county to undertake the effort, has erupted in controversy.
“This is just a little interim plug that we’re putting in in this particular case,” Ainsworth said. “[The bluff] is going to erode and we’re going to be at the place where the sand lens is going to fall in and we’re going to have to ask the hard questions then.”
The hearings in November and December left commissioners feeling anguished and conflicted.
“We’re between a rock and a hard place on this particular project,” said Commissioner Donne Brownsey, prompting Commissioner Aaron Peskin to chime in: “an erodible rock.” And Commissioner Steve Padilla — perhaps the panel’s most ardent defender of private property rights — conceded Surfrider’s concerns “in a general and conceptual way.”
“However, when you look at implementation and you look at the facts and circumstances on the ground, it seems to me that the record tilts in favor of the fact that this course of action is a superior if not perfect course of action than simply stepping back and allowing failure to occur,” he said. “I get it: in a perfect world you could say, ‘Let everything collapse and we’ll gain some more beach’ and then we’ll just deal with it at the time. But it really isn’t that simple. And I think staff—particularly legal staff—knows that it’s not that simple.”
But Commissioner Mark Vargas harkened back to the agency’s recently drafted guidance on sea-level rise, which accepts that California’s armoring mentality has to come to an end. Infills, he said, open the door to “larger, more obtrusive shoreline armoring,” and the solution ought to come from a legislative fix, not by continuing to approve infills in a piecemeal fashion.
“I’m nervous that by creating this novel solution the unfortunate side effect is that we’re going to continue this dialogue about shoreline armoring and, in effect, kick the can down the road when we need to be making these tough decisions now,” Vargas said. “I just can’t in good conscience continue to further these ideas that shoreline armoring provides any real solution to the larger problem that we’re facing.”
Brechtel re-submitted the Monroe/Sloan case last week, basing the motion for reconsideration comes on the basis that the Commission committed three mistakes of law: the evidence in the record indicates that project is fully consistent with stated policy, the ruling disregards Solana Beach’s certified LUP, and, lastly, commissioners mistakenly applied sea-level rise guidance as a basis for denial.
“Their decision was bad from an environmental and policy point of view,” he said in an interview. “Denial of this project leaves the only alternative to be a seawall, and it hurts the Coastal Commission’s reliability with local agencies.”
He said he hopes the Coastal Commission will re-hear the application as early as March.
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