Letter originally submitted via email to CPC.OceanBeachEIR@sfgov.org
The Surfrider Foundation represents more than 250,000 surfers and beachgoers worldwide and is dedicated to the protection and enjoyment of oceans, waves and beaches. Our San Francisco Chapter has reviewed and commented on shoreline management projects in the City of San Francisco for more than 20 years and has actively participated in robust stakeholder-based sea level rise planning efforts at South Ocean Beach. These include: Ocean Beach Master Planning Process (OBMP), an LCP update to the Western Shoreline Plan, and Coastal Commission permit decisions in 2015, 2017 and 2021. All these efforts were geared to promote the work of the Ocean Beach Master Plan (OBMP) in this area.
After decades of participating in collaborative vision-setting for South Ocean Beach, Surfrider is very concerned that the project put forth in the draft EIR falls short of key goals outlined by the Ocean Beach Master Plan.
The Ocean Beach Master Plan has been held up as an exemplary model for how to address sea level rise and coastal erosion. President Obama’s policy advisor even commended the plan for its innovative approach to coastal erosion in 2017. The Ocean Beach Master Plan is held in such high regard it presents a solution to coastal hazards that was truly innovative, a bold departure from current practice. Instead of using seawalls and/or artificial sand replenishment (tools of the status quo approach) the OBMP called for the minimization of those two approaches and instead emphasizes a mix of new strategies to address coastal hazards. These include maximizing the managed retreat of infrastructure and the generous restoration of sand dunes and expansion of daylighted beach area so that natural processes can aid in maintaining a sandy shoreline and its protective dunes. Sand replenishment, which is energy intensive and ecologically harmful, was thus to be minimized.
SFPUC’s current design plans, unfortunately, promote the status quo approach. A large seawall and promenade structure made of concrete is to take the place of the beach. Sand replenishment will be needed on a much more regular basis to protect the beach.
Other Issues in the Draft EIR
Do note that in the EIR, SFPUC argues that their design is a major improvement of what is currently found at the site. However, what is now found out at the site is poor beach access and a blighted bluff top. This is due to minimal action on the Phase 1 recommendations of the Ocean Beach Master Plan. Phase 1 called for much more than sandbags and sand replenishment to temporarily improve conditions at South Ocean Beach. Phase 1 also called for a temporary bike/pedestrian path and temporary coastal access parking to be constructed using the abandoned asphalt from the reconfigured roadway. This work was never done, adding to the years of harm to beach visitors. All the coastal permitting work we participated in was based on the understanding that a long-term solution for the area would leave the beach and public access in a restored state, with infrastructure relocated and/or protected in a more beach friendly manner.
Surfrider’s specific concerns with the draft EIR are further described below.
In the 2015 permit for sand bags and nourishment strategies for the area, the Coastal Commission Staff Report summarizes this expectation with the following:
“During the initial up to 6-year term of this permit, existing rock revetments and sandbags along much of the project area south of Sloat Boulevard would be allowed to remain in place, as they are required to help assure short-term structural stability and protection of existing significant public infrastructure in danger from erosion. The long-term project, due to be implemented beginning in 2021, would likely include removal of these revetments and sandbags and a series of managed retreat measures designed to avoid hard armoring as much as possible in favor of instead managing the shoreline more naturally (with sand dunes, for example) and facilitating enhanced public recreational access in the area.” (page 2, 2015 Coastal Commission Staff Report
The draft EIR includes plans for an approximately 30-40 foot high wall running the length of the Lake Merced Tunnel. Surfrider finds it difficult to understand how a half a mile seawall on the beach represents a reduction of hard armoring strategies for the area.
Surfrider endorsed the Ocean Beach Master Plan which called for a much lower profile wall - half the height and more than half the width of the current proposal. It would have been much more beach friendly as wave and sand transport were to take place on top of and behind the structure, aiding in maintaining both the beach and a protective dune system. The new wall proposed by SFPUC impedes natural processes on top of the structure and provides for no back beach / dune system. We’d like to also point out that the current wall design is located closer to the surf zone than the OBMP wall. This is a major step in the wrong direction as this is a high energy shoreline. Wave attack and erosion threats to infrastructure have been an issue south of Sloat since the Great Highway Extension to Skyline was built here in the early 1960’s.
Beach Nourishment and Trigger-Based Shoreline Monitoring
The draft EIR attempts to address the erosion through a trigger-based shoreline monitoring and nourishment program, but Surfrider finds these triggers to be currently insufficient (see sand placement section.) Sand replenishment would be triggered when more than 500 linear feet of beach is narrowed to only 50 feet, or when more than 500 feet of the buried wall is observed. This represents enormous and extreme amounts of erosion where large parts of the wall may pose a danger to recreationalists in the area. Even with these relatively weak triggers, the plan estimates that sand replenishment will only be needed every four years. Surfrider objects to this estimation as it was calculated on an average over ten year periods. In reality, Ocean Beach may suffer extreme shorter-term periods of erosion, at which point the financing and planning for beach nourishment will become significantly more difficult.
Surfrider is concerned that this project would engender a need for sand replenishment that is ecologically destructive, costly and based upon a plan not properly accounted for. The draft EIR states numerous small and large sand placement options that are not fully explored and has underestimated the need for available sand in periods of time under four years. It is not clear that strategies for large placements of sand from the offshore environment would lead to retention onshore, with the report only referencing retention of sand from an offshore placement in 2021 (the San Francisco Bay Main Ship Channel), which has not had the time to be vetted for retention.
Finally, this draft EIR refers to plans to create a and covered ‘slope,’ rather than a dune, as the feature in the rendering below and described further in the plan is by no means a dune. It is sea wall crown - based on a mixture including concrete, covered with sand.
The long-term vision in the Ocean Beach Master Plan has called for a real, natural shoreline and dune system. The intention of such features would be to harness natural adaptive capacity while providing other recreational benefits and benefits to habitat. While the slope above provides aesthetic benefits, it is missing many of the co-benefits that make a dune worthwhile.
As a hill with no backslope, this false dune is not a system that flexibly allows sand to move and erode. It is a steep, 3:1 layer of cementitious material, covered at times by a 4 foot veil of sand. Therefore its adaptive capacity is relatively low, and it requires ongoing maintenance by SFPUC in the form of beach nourishment.
One of the key goals of the Ocean Beach Master Plan was to relocate as much infrastructure as possible away from the water and harm’s way. The SFPUC proposal attaches the multi-use trail to the seawall slope, thus locating it close to the coastal hazard zone. The Ocean Beach Master Plan had called for the back beach / dune system to buffer the area between the seawall and the coastal trail, a much smarter and ecologically beneficial approach as coastal processes would be able to aid in maintaining the beach while keeping the trail at a safe distance from the water.
Most of the coastal access parking has been lost due to erosion since the late 1990s. At the time of the completion of the new wastewater infrastructure at south Ocean Beach, coastal parking south of Sloat consisted of two parking lots totalling approximately 200 spaces. At this point in time, only one parking lot at the Sloat intersection remains with only 35 spaces. The 2012 Ocean Beach Master Plan earmarked two parking lots for restoration. One at the end of Zoo Road, slated to replace the primary access parking lot at Sloat and another near the Skyline intersection. With the Zoo road site being the primary access - and including a restroom, shower, bike rack and trash/recycling facilities - it could have been an excellent plan.
However, in the draft EIR, only the Skyline parking lot appears confirmed; and this location only provides for 65 spaces. This is woefully inadequate and; once again, shows how far the Ocean Beach Master Plan recommendations have been watered down. Gaining only 30 more parking spaces is particularly disappointing when one takes into account the enormous increase in visitation to Ocean Beach that we have seen in recent years.
SFPUC Service Road
This feature was not located in the coastal restoration area outlined in the Ocean Beach Master Plan. Now, SFPUC has placed it directly alongside the multi-use path, thus adding new infrastructure and covering more habitat in area that was supposed to be mostly dune. Currently, SFPUC accesses the Wastewater Pumpstation from the Zoo Parking lot, located behind the coastal berm. Surfrider recommends that any service road keep to this more inland route.
Interpretive Center / Warming Hut
The Ocean Beach Master Plan had recommended that the old, but elegant Fleishhaker pool house be converted into an interpretive center and warming hut, similar to the new National Park Service center we see presently at Point Lobos. Unfortunately, a fire swept thru the old building. Instead of working to restore the building for the Ocean Beach Master Plan interpretive / warming hut, the city just demolished the structure. This was done without outreach to the Ocean Beach Master Plan stakeholder group, historical preservationists or comments from the public. What’s worse, in the ensuing years, SF Zoo has built their own “education center” on the site, without a coastal development permit. That sight now rusts and rots away, an eyesore to all beach visitors.
Concrete Stairwells to the Beach
The Ocean Beach Master Plan had envisioned wooden sand ladder pathways to the beach, similar to the ones found at other National Park Service beach access points in the GGNRA. Surfrider applauded that method as it was low impact and easy to fix if damaged by wave attack. Unfortunately, SFPUC’s new seawall is such a large structure that the agency is proposing a staircase access system to safely traverse over it. The staircase is to have a concrete base. Again, this is yet another deviation from the OBMP goal of minimizing infrastructure that is subjected to coastal hazards.