Working Towards a Sustainable Future for Broad Beach E NVIRONMENTAL NGO R ECOMMENDATIONS FOR THE P ROJECT

A beach and dune restoration in some form will help reduce erosion issues at Broad Beach, but the project must be carefully planned, implemented, and monitored to reduce impacts to water quality, sensitive environmental habitats and public access. Overall we support the staff recommendations and special conditions with additional modifications, but we do not support the applicant’s proposed project in the form they have submitted. O UR P OSITION

Background Concerns regarding: Septic Systems Coastal Armoring & Revetment Public Access Marine Life Protection & Monitoring Sand Nourishment Caps Permit Length & Feasibility Studies Sediment sourcing Long-term planning for sea level rise

H ISTORY Post World War II PCH, with Trancas and Broad Beach in the foreground, and Zuma and Point Dume in the Background. Broad Beach is a misnomer. CCC Venture office-- historical records of a thinner beach in Widest in 70’s before fully developed. Rapid erosion post development

Broad Beach Note how thin the west end is without development.

40 years ago No beach after 40 yrs of erosion post development

Three Issues Plaguing Broad Beach. Septic Systems/leach fields Public Access Revetment

S EPTIC S YSTEMS Problems Antiquated technology Sand bags and revetment largely protecting leach fields/septic system. Potential failure of project could put septics at more risk. A handful of leach fields are very close to the MHTL Recommendations Transition to a centralized wastewater treatment plant. Moving systems lessen need for revetment. Support Special Condition 16, with modifications (5 years, not 10): “Removal of the existing septic systems and connection to a new or upgraded package sewage treatment plant based on the findings of feasibility study.”

R EVETMENT A RMORING Problems Accelerated Erosion– revetment blocking the natural migration of sand; wave action is undercutting the ocean floor perpetuating erosion. Recommendations Remove, or improve and relocate, the rock revetment to lessen erosion Support Special Condition 1.A.1 and 3: “Landward re-location and re-construction of the approximately 2,000 linear ft. downcoast end.

P UBLIC A CCESS Provide unambiguous lateral and vertical public access that allows the public to access the shoreline for passive recreation. Checkerboard patterns—illegal actions Public land used for Private use “As such, the majority of the proposed as-built revetment (2 acres of the approximately 3 acre revetment footprint) directly impacts public access and recreational use of public. trust lands and existing lateral public access easement/restriction areas, and is expected to continue impacting public access over time.” CCC Staff report.

P UBLIC A CCESS Support Special Condition 13: execute deed restriction-- grants the public right of lateral access and passive recreational use along the shoreline. 51 current easements 32 are under/landward of revetment. Condition mirrors Sections and of the Malibu LCP Support Special Condition 14: requires 10 ft. wide public access path immediately landward of the revetment if beach erodes with in 10ft seaward. Improve vertical access. LCP requires 5 points. Support Special Condition 3: to remove all unpermitted private stairways. Support Special Condition 15: requires Public Access Management Program. Limit excessive private pathways. 5 homes one path.

M ARINE L IFE P ROTECTION Project proposes to bury sensitive and protected essential habitats important for marine communities and ecosystem health and function in the region. MPA: Point Dume State Marine Conservation Area Area of Special Biological Significance (ASBS) Federal Essential Fish Habitat

M ARINE L IFE P ROTECTION The Coastal Commission has already done a commendable job of upholding MPAs by voting to modify or deny projects that would harm life in those areas. We appreciate those decisions and believe Coastal Commission staff is on the right track in its handling of projects that affect MPAs. It is paramount that the Commission continue this trend and protect MPAs to the fullest extent possible.

M ARINE L IFE P ROTECTION Protect sensitive habitats and wildlife within the MPA and ASBS by not allowing sand nourishment to bury sensitive marine protected area habitat.  Support Special Condition 1, with modifications  Support Special Condition 6, with modifications  Support Special Condition 9

M ARINE L IFE P ROTECTION Support Special Condition 1, with modifications: Staff Report: “No beach nourishment shall occur upcoast of the property at Broad Beach Road … No backpassing may extend upcoast of Broad Beach Road, as limited by Special Condition 1.” Revise Special Condition 1.A.2. to Broad Beach Road

M ARINE L IFE M ONITORING Support Special Condition 6, with modifications Special Conditions 6.D.6 should be revised to require annual evaluation and reporting of disturbance to marine life and beach ecology, rather the than five-year analysis and reporting requirements currently proposed in the staff report.

S ENSITIVE B EACH S PECIES Support Special Condition 9. Avoid adverse effects to sensitive beach species. Backpassing and re-nourishment events should adhere to “Construction and Operational Timing Constraints” to avoid sensitive species.

S AND N OURISHMENT Reduce the beach nourishment footprint to match average historical beach width Support Special Condition 1.A:“The total amount of beach/dune nourishment material for the initial nourishment event, and each separate renourishment event shall not exceed 300,000 cu. yds. of sand for each event.”

S AND N OURISHMENT Modify Special Condition 4: Include a 600, ,000 cy cap for the total volume of sand for all nourishment events under the CDP Include a cap for total number of renourishment events allowed under permit, to: one initial major nourishment one major re-nourishment two minor re-nourishments

P ERMIT L ENGTH Modify Special Condition 2 to five year permit length. Require that the sewage treatment feasibility study and revetment alternative studies are completed within five years. After 5-year feasibility studies are complete, scope projects identified in the studies to advance improved sewage treatment and revetment removal, conduct environmental review, and and secure permits, etc.

D UNE H ABITAT C REATION Support Special Condition 5 which “requires that the applicant submit a final revised dune habitat restoration and enhancement program that would provide for the restoration and enhancement of coastal strand and southern foredune habitat on-site.” Require applicant to change one private path for every two homes to one private path for every five homes.

S EDIMENT S OURCING Support Special Condition 8 with modifications: include toxicity testing require smaller grain size of sand to more closely match the native sand on Broad Beach; capping size at.40 to also create congruity with the adjacent Zuma beach which has a mean grain size 0.40 mm

F UTURE S USTAINABILITY Sea Level Rise Managed Retreat & Caisons Landward Relocation

F UTURE O PTIONS : M ANAGED R ETREAT ? CCC staff report states that some homes could benefit from managed retreat. “Existing structures could also potentially be raised to safer elevations on deep-seated caissons, as is required under the City’s LCP when homes along Broad Beach are redeveloped (and some have been), but this alternative is extremely expensive and the Commission would need to require that many endangered structures essentially be entirely reconstructed on new elevated caisson foundations.” While there might be cost associated with this type of coastal adaptation planning, managed retreat might be the only option for some homes in light of future sea-level rise.

S EA L EVEL R ISE A DAPTATION Surfer’s Point in Ventura: scaling development back from the coast to provide a larger habitat buffer against sea level rise and erosion, also known as “managed retreat.” A solution like this for Broad Beach would be preferred, as intact dune habitat provides a strong buffer against storms and sea level rise.

P RECEDENT Your decision today on the proposed project will be precedent-setting and set the stage for how California addresses: Coastal development in the face of a changing climate Inundation and erosion associated with sea level rise and increased storm surges Changing precipitation patterns Projects in Marine Protected Areas