At its May 2025 meeting, the California Coastal Commission approved a highly controversial update to the City of Pacifica's Local Coastal Land Use Plan update (LCLUP), including policies that enable expanded neighborhood-scale seawall development through a framework called "Special Shoreline Resiliency Areas" (SSRAs). These provisions give the green light to continued armoring of Pacifica's shoreline for at least the next 20 years, even in areas that wouldn’t otherwise qualify for protection under the Coastal Act. This sets a dangerous precedent that may be the downfall of the California coast.

What Are SSRAs?

SSRAs are areas that Pacifica has designated for continued shoreline armoring despite their proximity to critical coastal resources. The theory is that this “temporary” armoring allowance will buy time for the city to develop a long-term adaptation plan. But here’s the catch: there’s no mandate to actually do adaptation planning in a way that protects the coast, no enforcement mechanism to make sure the seawalls eventually come out, and no requirement to identify where beaches and waves will be preserved or restored to offset the SSRAs. It’s all vague promises and deferred decisions.

Cities that invest millions into seawalls generally do not turn around and remove them just because a 20-year sunset clause runs out.

We’ve seen no evidence that shoreline armoring, once installed, even under “temporary,” or time-limited permits, is ever meaningfully removed. Instead, it becomes a de facto permanent fixture, locking in long-term impacts to beaches and public access. For example:

• At San Onofre State Beach, the Coastal Commission approved a 10-year permit in 2018 for riprap placed below the former SONGS site, despite Surfrider and others warning that it would likely never be removed. Today, the revetment remains, with no realistic plan for removal or restoration as the deadline approaches.
• Similarly, at Capistrano Beach in Dana Point, emergency and temporary armoring went in 2018 and 2020 but still remain. What was pitched as temporary protection is now part of a longer-term adaptation plan that still depends on riprap remaining indefinitely.
• In Solana Beach, new armoring approvals have included 20-year permit terms, but these permits rarely, if ever, result in actual removal. Instead, structures are typically reauthorized or expanded, as seen throughout Solana Beach where ~75% of the bluffs are now armored under legacy and updated CDPs.
• This same dynamic is unfolding in San Clemente, where OCTA installed over 1,000 feet of “emergency” riprap in 2022 and is expected to be issued a limited, 10-year duration permit later this year to retain the riprap. OCTA has publicly stated its intention to keep the riprap in place at least until 2050, despite significant impacts to beach use, surf quality, and natural sand transport.

While rare cases like Surfer’s Point in Ventura are often cited as success stories, that project was a proactive managed retreat effort, not the removal of emergency or “temporary” armoring after the fact. The takeaway is clear: once armoring goes in, it almost never comes out, even when the permit says it will.

The Coastal Commission’s own Sea Level Rise Guidance stands in direct conflict with the SSRAs:

"Avoid expansion and minimize the perpetuation of shoreline armoring." (Principle #12)

"Avoid new permanent shoreline protective devices unless found consistent with Section 30235... and only when they are clearly the least environmentally damaging alternative."

Even Pacifica staff has admitted that these policies are a political workaround, calling them a “temporary bridge.” But bridges become roads. Roads become status quo. And status quo is how we lose our beaches.

A Non-Technical, Politicized Debate

Several Commissioners echoed rhetorical patterns like, “we have to compromise to move forward” – commonly used to deflect conflict or sidestep legal shortcomings and signal pragmatism without actually defining what’s being compromised – or called the plan a “good balance”, but these statements weren’t grounded in the Coastal Act standards or the real-world outcomes the plan will produce.

Instead of weighing legal and policy compliance or the merits of proposed measures to offset the SSRA beach impacts, most of the Commission's discussion of the risk to the Coastal Act echoed the talking points of developer groups and organizations that prioritize private property over coastal access equity and beach preservation, such as, “there is no one-size-fits-all sea level rise plan”, as an excuse to carve out crucial Coastal Act protections. This shocked those attending the meeting in support of the rights enshrined in the Coastal Act. One attendee referred to it as "a surreal scene."

Commissioner Mike Wilson floated concepts like future GHADs and climate resiliency districts, urging the city to explore those options without meaningfully pushing for those concepts to be embedded into the plan update. While climate resiliency districts may have merit as a concept, we know from experience in Malibu that GHADs are unlikely to be helpful to facilitate nature-based solutions. As a member of the Local Government Working Group working to resolve the state’s sea level rise planning difficulties, Wilson praised the SSRA framework as a start, "an iterative first step," but that’s not how legal frameworks work: You don’t open the floodgates and just hope someone builds a living shoreline instead of a dam.

Commissioner Meagan Harmon claimed that not approving this LCP would be a step backward for local governments, saying:

"With my vote in support, I hope jurisdictions watching will work together pragmatically in service to protect and serve our coast."

But the takeaway for local jurisdictions is that they now have carte blanche to refuse to follow the law. Harmon claimed SSRAs are a path forward, but they’re a path forward only if we’re walking away from beach preservation.

Commissioner Caryl Hart said the SSRAs were limited in scope and would still require CDPs, and hoped for long-term benefits like beach restoration. But she also noted:

"We don’t have an exact set of options yet."

Precisely. You don’t build the seawall now and then figure out how to save the beach later. We’ve heard this time and time again in past “compromises” where Commissioners lament approving seawalls, but do so anyway.

Commissioner Paloma Aguirre struck a slightly cautious note but was also unfazed about the Coastal Act roll back:

"I think this is a good balance... but I want us to be vigilant that this isn’t used advantageously by anybody."

Unfortunately, that vigilance was not embedded in the policy. There are no triggers for enforcement. No requirements to remove seawalls. No requirement that the city designate restoration zones.

Commissioner Matt O’Malley was a lone hold out with enough concerns about the SSRA policies, asserting that better policy alternatives surely existed.

This Plan Violates the Coastal Act

The Coastal Act prohibits new development from relying on shoreline protection. The SSRAs allow precisely that. They are structured to enable seawalls to be repaired, expanded, or built to protect infrastructure, housing, and development that is not eligible for protection under the Act. That’s illegal.

The conflict resolution provision used to justify the SSRA policy was designed for cases where two Coastal Act policies, say, habitat protection and public access, come into true conflict. It’s not meant to authorize speculative benefits decades down the line while locking in resource-harming development today. Yet that’s exactly what happened here.

The Commission could have taken a different path. It could have:

• Tied new seawall permits to the remaining life of structures
• Required upfront identification of beach restoration or relocation zones
• Established enforceable triggers for wall removal

Instead, it opted for murky promises and delayed planning. Meanwhile, local surfers, beachgoers, and environmental advocates flooded the hearing with opposition. Hundreds of voices asked the Commission to reject SSRAs at the hearing and in written pleas in the correspondence, which totaled over 800 pages. Surfrider Foundation's team, along with the UCLA Frank G. Wells Environmental Law Clinic, attended the meeting and spoke in strong opposition to the SSRAs. Other than gratitude expressed for “participation,” all were ignored.

The “Coastal Access Program” is Smoke and Mirrors

Staff described Pacifica’s proposed Coastal Access Program and Shoreline Resiliency Program as mitigation measures to the SSRAs, but they’re nothing more than fuzzy notions with loose requirements. They stated during the hearing presentation that these programs would require the City to pursue nature-based adaptation and acquisition of properties, phased adaptation, sand nourishment, living shorelines and shoreline armoring removal. Painting this rosy picture, but one nowhere to be found in the actual policy language.

To illustrate the discrepancy between the staff presentation at the hearing and the actual policy language:

CR-I-44 states,

“The priority for [...] access benefits and mitigation shall be efforts/projects designed to maintain and enhance sandy beaches and public access to and along the City’s shoreline in a manner that is most protective of coastal resources and general public access utility.”

This language is sufficiently unclear that when left to the City’s interpretation it will surely rely on the lowest cost, lowest difficulty types of projects. Indeed, the suggested projects listed do not preserve or restore beach space, they merely “enhance” access along the shoreline, the policy goes on to state:

“Potential projects include but are not limited to:

• Enhanced public pathway system seaward of private development in the Rockaway Beach area.
• Coordinated vertical accessways, landscaping, benches, picnic tables, bicycle racks, garbage and recycling receptacles, doggie mitt stations, and enhanced signage in the Sharp Park area.
• The following projects listed in the program: Rockaway to Pacifica State Beach Trail Rehabilitation, Rockaway Beach Parking Structure, Rockaway Parking Area, Beach Boulevard Promenade Park Improvements, Sharp Park Priority Development Area (PDA) Access Pedestrian Improvement project”

We shudder to think Commissioners find "Doggie Mitt Stations" an adequate replacement for the loss of California's coast. The fact that this is listed speaks volumes to what we can expect from the City and what the Commission is willing to accept. We note that not one of these examples align with the types of nature-based, beach-protecting projects described in the staff presentation at the hearing. The staff presentations are key for helping Commissioners make informed decisions and thus their accuracy is vital.

This policy does not require the city to preserve beaches or waves. It does not require them to seek planning and funding for nature-based projects. They do not even require the city to identify which areas might be prioritized for restoration.

When Pacifica first introduced the SSRA concept, the Commission asked them to include specific plans to offset the damage. They didn’t. The City has not even built consensus around the SSRA approach, so why would we think they can build consensus around the far more politically fraught issue of where to make space for the coast?

What’s most likely is that the City will install stairways and trails to beaches that are already eroding or gone. That’s what we’re trading our public trust for: the right to walk down to a beach that no longer exists.

Giving Into Political Pressure

The question facing California is bigger than Pacifica. Do we give into state and federal political pressure to deregulate coastal protections and greenlight armoring for any city that asks? Or do we enforce the Coastal Act as intended, to protect our beaches, our access, and our public resources, just as past Commission leaders have been obligated to do for decades?

The Coastal Commission is not just another stakeholder. It was created because local governments don’t have the same incentives to protect the public good. Cities respond to local budgets, tax bases, and infrastructure concerns. The Commission is supposed to take the long view for future generations, to see the coast as a living system.

And yet, this vote signals a turn away from that vision. Under pressure from jurisdictions including Santa Barbara County, Del Mar, and Marin, places that have objected to basic planning tools like setbacks, hazard disclosures, the Commission blinked (see this presentation by Santa Barbara County starting at 1:12). This, despite recent court rulings such as Casa Mira v Coastal Commission which settled the debate on which structures are entitled to shoreline armoring: those built before the Coastal Act in 1977.

To date, nine strong LCP updates have been certified. Seven more are in the pipeline as “pending”. That’s over 40% of local governments who have received local assistance grants for sea level rise planning. Another 26 are in the works and moving steadily. The problem isn’t the standards in the Coastal Act, it’s that the handful of communities resisting them are exerting an outsized influence on decision makers. And in this case, they won.

The Bottom Line

This was a political solution to a physical problem: We are already on track to lose up to 70% of Southern California beaches if current trends continue. This moment required bold, clear leadership. Instead, the Commission chose appeasement, setting a precedent that could undermine beach preservation statewide.

The truth is that this planning process takes time, energy and money. We can’t cave to bad plans now with hopes they will do better in twenty years. We have the money and energy in the process now - let’s get it right.  Delaying crucial planning will preclude some options in the future, and it is important to make tough decisions now, so they can be implemented within the next several decades as seas rise and before it's too late.

If we want a California coast that future generations can enjoy, not just look at from behind seawalls, we must do better. This decision was not it.

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