Critical Infrastructure Guidance


November 1, 2021

The Coastal Commission adopted Critical Infrastructure at Risk: Sea Level Rise Planning Guidance for California’s Coastal Zone – new state guidance to help local jurisdictions plan and adapt critical water and transportation infrastructure to climate change hazards and sea level rise. ActCoastal partners, along with a larger coalition of other nonprofit organizations, overall supported the guidance document. The guidance clearly suggests phased adaptation approaches, evaluation of extreme sea level rise scenarios, and prioritization of nature-based adaptation solutions. It also guides users in addressing the disproportionate burden that sea level rise inflicts on environmental justice communities and acknowledges that decisions we make today will impact coastal species, migratory birds and marine wildlife in the future as they adapt to future climate change scenarios.

A coalition of partners including ActCoastal members also focused comments on the need to address seawater desalination structures more thoroughly as part of the guidance on water infrastructure, especially given pending desalination projects in Huntington Beach and statewide that are imminent before the Commission. Coastal Commission staff resisted this recommendation citing capacity and the need to evaluate desalination facilities on a case-by-case basis, but did incorporate some specific criteria that could be used to evaluate whether a proposed desalination plant would be considered critical infrastructure.

Why You Should Care

This guidance will be critical for making water and transportation systems more resilient over the coming decades.


Pro-Coast Vote

Anti-Coast Vote

Surfrider Foundation and others urged the Commission to more definitively reiterate in the document that armoring is not an acceptable approach to phased adaptation where other alternatives are an option. This recommendation was not addressed by Commissioners or incorporated into the final document. Commissioners discussed concerns raised over a comment letter submitted by Poseidon Water LLC, which stated their interpretation and support for the guidance as specifically excluding desalination from any critical infrastructure designation. Exclusion of desalination would allow facilities to be built to a lower standard of design, saving costs for shareholders but potentially leaving the public with the tab if the structure or public supporting utilities are damaged by sea level rise or other environmental hazards like an earthquake or tsunami.

Commissioner Mark Gold clearly opposed the desire to address seawater desalination in the guidance because other structures (i.e. power plants) were not specifically addressed. Other Commissioners disagreed, since this guidance intends to address water infrastructure. Commissioner Dayna Bochco and Carly Hart advocated for addressing desalination in the guidance more clearly. Commissioner Donne Brownsey sought a compromise that was ultimately incorporated into the document and staff recommendation – a footnote that more guidance regarding desalination may be the subject of a future update to the guidance.

Organizations Opposed

Poseidon Water, LLC

Decision Type

Guidance Adoption

Staff Recommendation


Coastal Act Policy