27 April 2013
Dear Mayor Barth, Deputy Mayor Shaffer, and Councilmembers Gaspar, Kranz, and Muir:
On 8 May, you will be considering one of the most far-reaching decisions that you will make during your tenure on the city council – that is, whether or not to support the 50-year shoreline protection program proposed for the Cities of Encinitas and Solana Beach by the U.S. Army Corps of Engineers.
The USACE has been developing this program for about 11 years but is proposing only methods that have been in use for many decades. These approaches have not resolved the issues of concern locally, despite repeated application, over the past 15 years. To the best of our knowledge, it has engaged the cities through staff members that have no real expertise in these issues. It did not engage the public until late January 2013, when it released its draft EIS/EIR for public review and comments. Unfortunately, it is our understanding that the USACE has chosen to address the comments made by state and federal agencies and the public primarily as a glorified technical editing effort; it will not adopt any of the suggestions or recommendations into the revised EIS/EIR. The alternatives proposed in the draft document are the only ones you will be allowed to vote on; it will be an up-or-down vote.
We believe this program is badly flawed and, unless greatly modified, should be not be approved or funded. Some of our concerns with the proposed plan are listed below:
- Does not solve any of the long-term, ongoing problems posed by bluff erosion, sand loss, or rising sea level;
- Omits consideration and discussion of currently widely employed shoreline protection strategies that are being employed nation-wide, e.g., managed retreat, rolling easements, and beach dewatering;
- Does not protect the beaches of Encinitas from north of a point ≈1,000 feet south of Beacon’s Beach;
- Does not protect Restaurant Row, Pacific Coast Highway, or the beaches adjacent to San Elijo Lagoon;
- Declares “No Impact” to the productive ecosystems living in sandy habitats in the borrow sites, thereby assigning as having no value, requiring no mitigation, and thus allowing the Cost: Benefit analyses to become positive
- Uses flawed impact analyses for the borrow sites; these are based on the ephemeral component of the ecosystem (the “weeds”) rather than the perennial or long-lived species that characterize that ecosystem (the “trees”);
- Did not compare ecological value among the various borrow sites to ensure that dredging will cause the least injury;
- Did not include local input from early in the process;
- Refuses to consider valid suggestions and objections by federal and state agencies and private citizens.
One problem with this program is that the USACE plan options do not propose to protect any shoreline north of about 1,000 feet south of Beacon’s Beach. This decision supposedly was based on differences in rates at which the bluffs are eroding. Apparently, the USACE believes the bluffs south of the northern end of the Receiver Beaches are eroding at a rate that will require sand replenishment up to 10 times over the proposed 50-year life of the program. In contrast, it believes the bluffs to the north, upstream in the normal sand littoral drift, will not require any sand replenishment at all during that period. This seems like an unrealistic assumption that should be reviewed at intervals throughout the proposed program, i.e., a step towards adaptive management.
Neither do any of the USACE plan alternatives propose to protect the shoreline of the San Elijo Lagoon Estuary and Restaurant Row, a bluffless sand spit shore also subject to periodic erosion and property threatening sand loss, with a wide range of unexplored options for protection.
The range of alternatives proposed is both limited in scope and would result in substantial environmental damage. Moreover, the USACE chose to exclude managed retreat and other “soft” coastal engineering solutions from the alternatives under consideration. It is our impression that the term “managed retreat” is very poorly understood but it and other “soft” solutions are gaining great traction and showing success nationally, especially on the East coast (e.g., New York, New Jersey, North and South Carolina). They also have recently been adopted as preferred alternatives in Monterey Bay, California. Several New York towns in the path of Hurricane Sandi benefited greatly from their expenditures on various “soft” coastal engineering solutions. In contrast, neighboring communities that did not employ these strategies suffered substantial storm damage.
In the long view, especially with rising sea levels resulting from global warming, we will not defeat Mother Nature. She will win, in the end, no matter how much treasure and energy we pour into our efforts. The process of erosion has been proceeding for millennia. It will not be stopped by our irrational impulse to “tame Mother Nature” because we have built structures and “own” property on those bluffs. At the end of this proposed program, we will still be faced by the same problems that we are faced with now, except we will have spent a great deal of treasure that could have been spent on long-term solutions.
A variety of other “soft” approaches is available for dealing rationally with this inevitable loss. “Managed Retreat”, often used as a blanket term for these “soft” strategies, does not imply simply “doing nothing”. There are many tools in the “soft” coastal engineering solutions tool kit - it is not a one-size-fits-all strategy. Just one of the tools is prudent targeted sand replenishment with respect to “borrow” and “receiver” sites, again, a step toward adaptive management.
We have a major concern about how the USACE is dealing with its proposed 50-year plan. It has excluded discussion of these valuable and appropriate strategies and it has not offered to educate the cities or the citizens on these alternatives. Again, the USACE is requiring the respective decision-makers to vote on an expensive, defective, long-term, environmentally damaging program from a point of ignorance with regard to the wide range of alternatives that is available for addressing the issues of bluff retreat and loss of sand as exacerbated by rising sea level and more intense storm activity resulting from global warming.
We believe that it is imperative that the City Council takes the time to become better educated on the many aspects and implications of this program. We realize that the USACE is trying to force a rapid but relatively uninformed decision based on funding cycles. However, the council needs to understand clearly the ramifications of its decision. What are managed retreat and other “soft” coastal engineering solutions. What types of alternatives are relevant for our various types of shoreline and activities? What are the costs associated with those various alternatives? What are the most rational approaches for dealing with various areas of the bluffs, Restaurant Row, public recreational access, the surf breaks, some world famous, Pacific Coast Highway, Swamis Marine Protected Area, and the wetlands reserve inshore of the highway.
Experts that could provide answers to these questions include Dr. David Revell and his associates at ESA | PWA, in San Francisco (drevell@esassoc.com). Is the city, as many assume, obligated to purchase bluff properties if it adopts a “soft” approach? That implies that the city tacitly assumed responsibility for “defending” these private property owners against loss due to Mother Nature when the owners purchased their properties. Are the values used in the Cost: Benefit analyses valid or have they been manipulated to produce positive results? We refer specifically to the finding of “No Impact” in the ecosystems in the borrow sites and no requirement for mitigation for dredging in these habitats. In addition, what are the annualized costs of the project, as currently proposed, to the city, and are the projected “escalation” factors reasonable for the 50-year duration of the program? These factors can be easily manipulated, especially on a 50-year project. These questions and answers, and many others, should be addressed publicly before any action is taken on the USACE plan.
Finally, it is clear that this 50-year program is not a “fix’ to any of our problems. The proposed approach is merely a Band-Aid that “kicks the can down the road” for 50 years. Nevertheless, it will spend hundreds of millions of taxpayer dollars. Moreover, it will result in major environmental damage to hundreds of acres of habitat that provides valuable ecological support to local and statewide fisheries. This habitat is a key component of the carefully spaced network of marine reserves established in 2012. This system of Marine Protected Areas is heavily dependent on the Swamis MPA link because it is the only MPA between La Jolla and Laguna Beach. Damage to this habitat, in all probability, will persist much longer than the 50-year life of the program.
Respectfully,
Dennis Lees
Littoral Ecological & Environmental Services
Leucadia
Garth Murphy
Integrated Ecosystems Management
Encinitas
