Santa Cruz Rock Revetment Restacks - Improved Monitoring Conditions

The Commission approved three separate, but similar, permits for beachfront homeowners in Santa Cruz to restack riprap boulders that had fallen from their permitted revetments onto the public beach.

• Application No. 3-24-1004 (Walsh Revetment, Pleasure Point)
• Application No. 3-24-1005 (Sherman Revetment, Live Oak) 
• Permit Amendment 3-07-058-A1 (Kessinger Revetment, Pleasure Point) 

While shoreline armoring negatively impacts beaches and public access, this is considered a pro-coast vote for two reasons. First, the homeowners will be removing boulders from public beaches where they do not belong and are not permitted. More importantly, Commission staff added special conditions that inch us in the right direction towards fuller mitigation for the negative impacts of these rock revetments. 

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Coastal armoring negatively impacts beaches and our access to them. Because these three homes are pre-Coastal Act structures, they are entitled to shoreline protection… but with conditions. 

‍Rocks Off the Beach

The permit conditions include a requirement to maintain their revetments within a specified footprint, and to remove boulders from the beach when they become dislodged. However, it remains unclear at what point the Commission should step in and enforce this condition - is it when one boulder falls on the beach, two boulders, or several? Additionally, staff enforcement capacity is limited so districts must prioritize where to focus. Usually and in this case, it is the applicants themselves who initiate the process, presumably to fortify their revetments before larger winter swells arrive. 

‍Revetment Redevelopment Status

Commission staff added special conditions to the restacking CDPs requiring agreement on where each revetment stands relative to the 50% redevelopment threshold (5%, 15%, and 16% respectively).

Including Redevelopment Status in CDP conditions ensures the Commission, applicants, and public have clear information about shoreline structures that harm coastal access and resources.

This is especially important given accelerated sea level rise and climate change. We'll see more CDP applications to modify shoreline armoring, and tracking these modifications is essential since each further harms coastal resources and public access.

Publicly monitoring redevelopment status, with binding owner agreement, helps mitigate impacts. A pre-Coastal Act structure reaching 50% redevelopment becomes new development, losing its armoring rights under Section 30235.

While the Commission's response to revetments exceeding 50% redevelopment is unknown, this shifts power back to the Commission to require additional mitigation, relocation, or removal.

Mean High Tide Survey for Revetments near Public Trust Lands

For the Walsh revetment, which appears to have encroached on public trust lands, Surfrider suggested requiring an updated Mean High Tide Line (MHTL) survey in the five-year Monitoring & Reporting requirements. Commission staff agreed, adding this condition with stronger language clarifying the permit doesn't allow encroachment on public trust lands.

An updated MHTL survey showing the revetment is on public tidelands would allow the State Lands Commission to require a lease from the applicant. This would help compensate the state for negative impacts from private structures on public tidelands, and might allow the Commission to assess additional mitigation for lost public access. It also provides a better understanding of shifting public-private boundaries.

Surfrider recommended that redevelopment status be standard in all shoreline armoring permits, and MHTL surveys be required for any armoring near the public trust border. Tracking both redevelopment status and tideland encroachment enables increased mitigation for armoring's negative impacts, further disincentivizing its use.

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