Restore Sloat

In Ocean Beach, the coastline south of Sloat Boulevard is an erosion 'hotspot' where the beach is disappearing due to coastal squeeze — which is getting worse due to sea level rise and the fact that public infrastructure is setting a back to the beach.

South Ocean Beach has long been the focus of a pplanned climate adaptation project led by the San Francisco Public Utilities Commission, and Surfrider is advocating that the City work to preserve the public beach in this project.

The city's current project plans include removal of the Great Highway Extension from Sloat to Skyline Boulevard and replacing it with a multi-use bike trail; as well as construction of a mile long 'buried' seawall to protect the Lake Merced Tunnel.

Surfrider is concerned that this plan will result in the quick disappearance of the beach as sea levels rise — join our listserv to learn more and help us protect South Ocean Beach. 

The San Francisco Chapter's vision for beach restoration involves:

• Cleanup of the rubble and rock from the beach
• The landward relocation of the Great Highway 
• The minimization (inward location, limit on height and size) of the impacts of the planned seawall
• A realistic sand maintenance plan and nature-based design that keeps the seawall buried
• The minimization or elimination of the concrete features of the planned stairway and multi-use path
• Retention of 70 parking spots in the area

Current Updates:

The project has completed the EIR/local review phase and will head to the Coastal Commission for approval in 2024. Surfrider is interested in bringing community concerns/opinions/amendments regarding the project to the Coastal Commission meeting; where there is opportunity for significant adjustments to be made (the project may be approved or denied at this meeting.)

Surfrider had many concerns that we expressed to the City during the EIR phase, and our official comments are pasted below. Broadly,  the proposed 3,200 foot long seawall as well as the proposed concrete bike path are concerning concrete structures that will together erode the beach as seas rise — particularly if the City's proposed sand management plan does not actually keep the wall buried (an exposed wall causes erosion.) We seek a reduction in the use and location of concrete in this project. 

Our official comments on the City's Draft Environmental Impact Report are below.

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SURFRIDER COMMENTS ON THE EIR

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. Surfrider has long advocated for solutions in the area that maximize public access and recreational use of the beach.

In evaluating the Draft Program EIR (EIR) for the Ocean Beach Climate Change Adaptation Project, our comments are focused on the context of the beach in this area, which is being narrowed by sea level rise and erosion. Our primary concern is that the alternative studied in this project does not accurately analyze inconsistencies with other land use plans — in particular the Ocean Beach Master Plan — as required by CEQA. In particular, plans and policies explicitly intended to limit the use of hard armoring and preserve the public beach as sea levels rise are not accurately considered.

The San Francisco Public Utilities Commission (SFPUC) considers the EIR’s preferred project to be an updated version of a design concept that was originally considered and widely accepted in the OBMP in 2012 and then further analyzed by SFPUC in 2015. Surfrider disagrees with this assessment due to substantial differences amongst the two project designs. The proposed project will impact beach width, will decrease sediment accumulation and will result in a narrowed beach.  Due to the significant divergence from the OBMP and related goals to limit shoreline armoring, we find that the EIR has failed to identify an environmentally preferable alternative with large implications for many resources.

In general, the relatively low adaptive capacity of the selected EIR alternative also means that SFPUC has not properly analyzed or mitigated for resource impacts related to the existence of a walkable beach; including minerals, public access, and public recreation.

Land Use Impacts Have Not Been Properly Analyzed

The related problems of sea level rise and erosion in South Ocean Beach have been extensively considered by SFPUC and many other entities for decades. Considerable planning has been done to acknowledge an environmental setting that has been known to be evolving; where sea level rise will exacerbate the erosion issues that the beach south of Sloat already experiences. The EIR points to a number of planning processes that have addressed the challenge of protecting infrastructure and maintaining a beach in the last ten years, and makes the following finding that the project would not cause significant impacts:

“The project would not cause a significant physical environmental impact due to a conflict with any land use plan, policy, or regulation of an agency with jurisdiction over the project adopted for the purpose of avoiding or mitigating an environmental effect.” (EIR, S-28)

Surfrider strongly disagrees with this analysis. We maintain that the policy and planning context is very clear about the need to limit shoreline armoring in this area due to the negative impacts that armoring has on beach space and a wide variety of coastal resources.

A Long Planning History Seeks to Limit Armoring In This Area

In 2012, the Ocean Beach Master Plan sought to balance environmental protection needs with the need to protect infrastructure in South Ocean Beach:

“The Ocean Beach Master Plan is an effort to develop a sustainable long-term vision for Ocean Beach, addressing public access, environmental protection and infrastructure needs in the context of erosion and climate-related sea level rise.” (Ocean Beach Master Plan, I-10).

While the OBMP was generally a visioning process, clear priorities for the beach South of Sloat were put forth to limit armoring and protect the natural capacity of the beach to rebuild itself under conditions of extreme erosion and wave runup. This was memorialized best in two plans that intentionally built off the OBMP — the 2015 Coastal Protection Measures and Strategies for South Ocean Beach framework and the Western Shoreline Area Plan LCP Amendment in 2017.

The 2015 framework was an SFPUC-commissioned effort to more technically evaluate the Lake Merced Tunnel protection device recommended in the OBMP for the area South of Sloat Boulevard. The preferred concept that emerged from that effort was intended to incorporate new information related to sea level rise and was ultimately designed to “emphasize the use of low impact technologies inland of the current shoreline that provide multiple benefits and opportunities for integrated management (e.g. protect critical infrastructure and provide for the protection and enhancement of natural resources).” (Alternatives Analysis, page 1))

The Western Shoreline Area Plan Update in 2017 also explicitly sought to limit hard armoring strategies for the area:

“Western Shoreline Area Plan Objective 6: Maintain and enhance the recreational use of San Francisco’s Ocean Beach Shoreline” (Western Shoreline Area Plan, Chapter 1)

“Shoreline protection devices such as rock revetments and seawalls can negatively impact coastal resources… Because of these impacts, shoreline protection devices shall be avoided and only implemented where less environmentally damaging alternatives are not feasible. Shoreline protection devices such as rock revetments and seawalls shall be permitted only where necessary to protect existing critical infrastructure and existing development from a substantial risk of loss or major damage due to erosion and only where less environmentally damaging alternatives such as beach nourishment, dune restoration and managed retreat are determined to be infeasible.” (Western Shoreline Area Plan, Chapter 12)

The broad impacts of hard armoring to environmental resources such as coastal access, coastal recreation, and habitats are summarized in the Coastal Commission’s 2018 Sea Level Rise Policy Guidance:

“Hard armoring refers to engineered structures that…can result in serious negative impacts to coastal resources, particularly as sea level rises. Most significantly, hard structures form barriers that impede the ability of natural beaches and habitats to migrate inland over time. If they are unable to move inland, public recreational beaches, wetlands, and other habitats will be lost as sea level continues to rise.. Other detrimental impacts may include interference with other ecosystem services. (Sea Level Rise Guidance, page 123)

The Coastal Commission has made exceedingly clear that hard armoring harms beaches. Most recently, the Commission’s 2021 “Sea Level Rise Guidance for Critical Infrastructure” emphasizes the need to protect coastal resources when hard armoring is used:

“Prioritize siting infrastructure to avoid hazards, and where hazard avoidance is not feasible, prioritize nature-based adaptation strategies over hard shoreline armoring. When hard shoreline armoring is used, require mitigation for adverse coastal resource impacts and long-term planning to identify a long-term solution that is most protective of coastal resources.” (Critical Infrastructure Guidance, 136)

Finally, intentions to limit hard armoring in this project have explicitly been memorialized in the Coastal Commission Staff Report for Phase 1 of this project:

“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, 2018 Coastal Commission Staff Report)

In summary, there is a long history — in both the statewide regulatory context and local planning documents — which anticipates sea level rise and intends to limit hard armoring in South Ocean Beach.

The Described Project Departs from Regulatory Recommendations

The project described in the draft EIR includes a 3,200 seawall covered by a 3:1 sloped sand layer that is stabilized by a four foot layer of “cementitious” material. The seawall is massive in scale, the back of the beach has been set by a series of concrete designs (the coastal trail and access road; in addition to the sloped sand layer and buried sea wall), and the enforced slope is steep and requires steady maintenance. All of these characteristics together mean that the project has very low ability to replenish itself and relies on high impact and costly artificial sand replenishment. Without steady maintenance, the cementious layer and the seawall will both contribute to further erosion of the beach which does not have the ability to migrate or build itself back. A cement shoreline, when unearthed, also puts recreation and access at high risk.

Surfrider fundamentally cannot characterize this design as an attempt to limit shoreline armoring or as a necessary use of shoreline armoring that is most protective of coastal resources. 

Surfrider therefore believes that the EIR project conflicts with the land use policies described in the Ocean Beach Master Plan and the Western Shoreline Area Plan and with important Sea Level Rise Guidance approved by the Coastal Commission. Our conviction is formed by practical questions surrounding the need for such a large seawall and the feasibility of a sediment management program that will mitigate all armoring-caused erosion, which is discussed in a later section. 

Our concern also stems from the technical analysis that SFPUC worked on in 2015, entitled “Coastal Protection Measures & Management Strategy For South Ocean Beach - Ocean Beach Master Plan: Coastal Management Framework” (referred to hereafter as the ‘2015 Design Concept’).” While we are aware that SFPUC now considers certain features of the 2015 Design Concept to be technically infeasible, the concept would have drastically different implications for the beach and demonstrates the need for an environmentally preferable alternative that still achieves OBMP goals. 

The EIR Has Failed to Analyze an Environmentally Preferable Alternative

While SFPUC seems to treat the 2015 Design Concept as a jumping off point for the project in the draft EIR, the 2015 Design Concept features an armoring proposal with drastically limited impacts to the beach and beach resources. The wall in the 2015 concept was much shorter in both length and height, in addition to being more landward.  The concept featured a shotcrete cap covered by 6 feet of artificial fill and sand and colma formation instead of a fixed cementious layer. In combination with the more seaward siting of other infrastructure discussed in the plan, these features allowed for a back beach and more traditional dune system which was generally more recreatable and held more capacity to retain sand naturally.

As stated above, Surfrider acknowledges that SFPUC has done further analysis of this design concept and found aspects of the design to be infeasible and/or unaffordable. We reference the concept in order to illustrate the point that, although the EIR concept may ‘look’ similar to the 2015 Design Concept in certain features (the presence of a low profile wall, and some managed retreat of the beach), many of the environmental benefits of the 2015 design are missing and should be restored in a reimagined design alternative. 

The planning context surrounding South Ocean Beach must facilitate a project with increased natural capacity to resist and respond to erosion without constant artificial replenishment. This has widespread impacts for environmental resources; including access, habitat, and recreation. 

The EIR fully acknowledges that erosion in combination with high tides could become so significant under sea level rise conditions that the wall in its proposal may become exposed, which would signify the complete loss of portions of the beach and would trigger further erosion-inducing effects caused by the seawall. This is made clear on page 2-14:

“Under normal conditions, the wall and slope stabilization would remain buried. However, the wall and slope stabilization could be exposed after severe storms and high wave conditions when the beach and bluff can erode away rapidly.” (EIR, 2-14)

Surfrider strongly encourages the City to explore opportunities for reinstating aspects of the dune system and back beach; which may include an adjustment to the location of the coastal trail and/or aspects of the seawall that will reduce the slope fronting the wall and allow the wall to be situated more landward.

Further, Surfrider would like to point out that the wall; which is larger, higher, and more seaward than was expected based on previous design concepts and a history of intentions to limit armoring in the area, is not the only form of armoring proposed in the EIR project concept. The pedestrian path is attached to the cementious sand slayer slope, and a service road now exists along the path. All of this is not easily removable and sets a back to the beach as sea levels rise.

The enforced slope in particular will serve as a front line of ‘de facto’ armoring that can contribute to beach erosion in the near future. Surfrider is aware that the SFPUC project team researched concepts that had made use of this material in order to justify its stabilizing features and make conclusions about its ability to retain sand. However, none of those projects were situated on marine coastlines and would therefore not experience the same impacts from coastal dynamics. There has been insufficient analysis to show that dunes would actually form on top of this material and the steep 3:1 slope that is planned.

Sand Management Details Are Insufficient 

Surfrider agrees with statements made in the draft EIR which equate beach loss with impacts to mineral resources, public access, and public recreation. However, Surfrider does not feel at all confident that the draft EIR mitigates for these potential impacts through its descriptions of an artificial sand replenishment program.

Our primary concern is that the EIR does not properly address or characterize a known area of controversy. It does identify the following statement as an area of known controversy related to erosion on the Southern Reach of the beach:

“Estimating rates of sediment transport and erosion of beaches and bluffs are inherently uncertain because of the highly variable nature of the forcing mechanisms that include ocean swells, storm surges, El Nino events, and other unpredictable natural processes.”

We would like to point out that there is a net average loss of sand over time in parts of the project area and that sea level rise guarantees further net losses of available beach space. The controversy in question is more about the project’s ability to retain sand in light of these established processes. To that end, Surfrider believes the sand management strategy has not properly considered relevant environmental conditions and we are highly skeptical that the sand retention strategy can effectively mitigate for widespread impacts associated with a project that is unable to retain sand effectively.

The project estimates that sand nourishment will be needed approximately every 2-3 years. This finding stands in contrast to the trend of replenishments needed every 1-3 years. The project assumes that a partnership with the US Army Corps (USACEOE) will bring ‘large’ sand placements to the beach, and these are estimated to be almost 200,000 cubic yards larger than the largest ever placement in this area (see Table 1-1 in Draft EIR.) Not only are details on the potential partnership very vague, but the additional cost of pumping so much additional sand from offshore has not been calculated. Additionally, the retention of this type of sand has not been properly analyzed, with the only similar offshore placement occurring in 2021 (thus there has not been enough time to analyze this offshore sand for multi-year retention success.) 

Surfrider also questions whether the triggers that are meant to enact sand placement will be effective in this context. The first trigger, which would be reached if beach width were less than 50 feet over 500 or more total linear feet of beach, may happen multiple times in a given season when swells are strong. The report states that sand replenishment will likely occur “approximately once every 2-3 years,” “depending on sand availability,” which means the beach could be virtually lost for up to 3 years after a strong storm season. 

The second trigger, which states that sand placements would occur if 500 feet or more total length of the buried wall were observed or exposed, doesn’t account for a scenario where less than 500 feet is exposed, and the beach has become pinched such that no lateral access is possible. The impacts on public recreation seem clear. With such little information about the cost, the Army Corps partnership, the quality of offshore sand for this beach and the effectiveness of triggers in ensuring that the beach is walkable; Surfrider finds it difficult to assume that artificial sand replenishment will indeed keep the beach covered 98% of the time, as the report concludes.

The associated disappearance of the beach equates to the loss of many resources that are unable to be fully analyzed in the report. A narrow beach means less space for public recreation, including walking, fishing, and swimming. It also increases the likelihood of a ‘pinched’ section of beach, which could destroy lateral access in this area altogether. Any amount of degradation of the vegetated hill would be lost habitats to dune species including the bank swallow. Finally, sand itself is a mineral resource that is becoming increasingly valuable as sea levels rise. The lack of analysis of a project which is better able to maintain sand naturally is a serious oversight.

Even if artificial sand replacement were affordable, successful and guaranteed on a schedule which could properly maintain resources in this area, the report acknowledges that a ‘small’ sand placement for the area includes 2,830 truckloads of sand and weeks of the beach being closed to recreationalists. Again we point out that a project alternative with more adaptive capacity that relies on less artificial sand placement would be far more environmentally preferable and would expose the current plans as using “large amounts of fuel in a wasteful manner,” in conflict with the finding related to Impact EN-1, which states that “The project would not result in the use of large amounts of fuel, water, or energy, or use these in a wasteful manner” is less than significant.

 

Other Considerations in the EIR

 

Parking Conclusions Are Woefully Inadequate

 

Most of the coastal access parking in this area has been lost due to erosion since the late 1990s. When new wastewater infrastructure at south Ocean Beach was originally installed, more than 200 spaces existed in two parking lots south of Sloat. Now, only a single 35-space parking lot at the Sloat intersection remains. The 2015 Design Concept 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. The Zoo road site would have constituted the primary coastal access lot and would have included a restroom, shower, bike rack and trash/recycling facilities. The current project appears to only confirm the Skyline parking lot, which would provide for 65 spaces. This is a serious diminution of parking. The lack of a better plan for parking is particularly disappointing when one takes into account the enormous increase in visitation to Ocean Beach that has been evident to locals in recent years.

 

The Service Road is a New Feature of the Plan that Takes Away Beach Space

 

This feature was not located in the coastal restoration area outlined in the OBMP. The EIR Project features a road that has been placed directly alongside the multi-use path, thus adding new infrastructure and covering more habitat in an area that was intended 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.

 

The Proposed Accessway is Concrete Subject to Coastal Hazards

 

The 2015 Design had envisioned wooden sand ladder pathways to the beach similar to the ones found at other National Park Service beach access points in the Golden Gate National Recreation Area.  Surfrider applauded that method as it was low impact and easy to fix if damaged by wave attack.  Unfortunately, the new seawall is such a large structure that a concrete staircase access system is proposed to safely traverse over it.  This again deviates from the goal of minimizing infrastructure that is subjected to coastal hazards.

 

Conclusion

 

Thank you for the opportunity to comment on this draft EIR. We hope to work with SFPUC and all interested to pursue changes to this plan that honor the OBMP vision for a more sustainable beach and public access friendly project for the area.

 

Thank you,

 

Holden Hardcastle

Chair

Surfrider Foundation San Francisco Chapter

 

Laura Walsh

California Policy Manager

Surfrider Foundation