Proposed Railroad Armoring Threatens San Clemente Beaches

San Clemente, California beachgoers used to be able to walk along their sandy beaches for miles—for instance, folks could stroll from the San Clemente Pier south to “Trestles,” one of Southern California’s internationally renowned surf breaks. Sadly, this is no longer possible, as huge rock revetments now cover the beach in front of the Cyprus Shores neighborhood and down to Cotton’s Point, the northernmost surf break at Trestles. Shockingly, there are proposals to not only keep those rocks in place, but to add significantly more armoring along San Clemente’s 7 miles of coast, significantly exacerbating coastal erosion.

The Orange County Transportation Authority (“OCTA”) claims that its proposed beach armoring is necessary to protect its railroad—and aims to do so without completing the necessary environmental review. To ensure that San Clemente’s public tideland resources are protected, the Surfrider Foundation is calling for a thorough review of environmental impacts and potential alternatives to the proposed armoring on behalf of its South Orange County Chapter, and for No. More. Rocks. On. The. Beach.

This stretch of coastal rail, within the Los Angeles-San Diego-San Luis Obispo (“LOSSAN”) Corridor, has been repeatedly hardened over the decades, to the detriment of our sandy beaches. The latest proposal includes extending existing riprap revetments and replacing vegetated coastal dunes with a 50-foot-wide engineered revetment as far as two-thirds of a mile north through San Clemente State Beach and Calafia Beach Park; the armoring would completely occupy the remaining sandy beach area, leaving these beloved beach parks without a beach. This would result in permanent damage to an extremely popular state park that provides refuge from the harsh Southern California inland heat, critical habitats for threatened and endangered species, priceless open space, invaluable coastal recreational opportunities, and direct benefits to the regional economy.

The LOSSAN Rail Corridor as seen in South San Clemente, on August 18, 2023.

To accelerate its project, OCTA has indicated plans to evade environmental review processes by applying for emergency permits through the California Coastal Commission. Surfrider has submitted a letter to the Commission that strongly urges the agency to require that OCTA complete a full Environmental Impact Report (“EIR”) or its equivalent with ample opportunity for public comment, and calls for no more rocks on the beach.

Two of California’s foundational environmental laws, the California Environmental Quality Act (“CEQA”) and the Coastal Act of 1976, mandate these procedural safeguards to allow the public and regulators to make informed decisions before a project is approved. Under these laws, the project must disclose any of its potential significant effects, explore less-environmentally-damaging project alternatives, and mitigation measures, as well as provide public notice and opportunity for review and comment.

The claim that this coastal erosion is a sudden “emergency” requiring immediate action, as OCTA alleges, only demonstrates that the agency plays loose with the facts. Not only has OCTA known about the increasing threat to this coastal stretch of rail line for decades, but it has also attempted to resolve the issue through faulty emergency permits on multiple occasions. In 2003, the Southern California Regional Rail Authority (“SCRRA”) received emergency authorization to augment revetments on this same stretch of coastline due to erosion concerns. Even then, the Coastal Commission doubted that this was a true emergency.

In 2021 and 2022, OCTA and SCRRA again evaded environmental review by falsely claiming that its plans for the placement of over 27,000 tons of rock riprap in south San Clemente’s beaches would only have minimal and temporary impacts on recreational opportunities, coastal systems, and public access. The truth, however, is that this armoring has already caused irreversible damage to public trust resources at Cyprus Shores Beach and around Cotton’s Point—the northernmost surf break at internationally renowned Trestles. Those rocks now permanently block public lateral access to the rest of Trestles and San Onofre, an extremely popular state park, significantly impact coastal recreational opportunities and ecosystems, and have degraded multiple sensitive species’ habitats.

These impacts were not considered by the regulatory agencies during OCTA’s emergency permitting application. Likewise, these impacts and misrepresentations were never exposed because OCTA and SCRRA never conducted proper review with the opportunity for the public to weigh in. OCTA and SCRRA even failed to comply with the scope and reporting requirements that the Commission set out in their temporary emergency permits at the time, which led to increased erosion and further infringed on public beach access.

OCTA’s existing rock riprap at Cotton’s Point, which has increased erosion and blocked lateral access to Trestles.

The currently proposed project plans to expand this armoring north to a stretch of beach that OCTA has admitted is mostly stable. By covering and effectively eliminating the remaining sandy beach area at Calafia Beach Park and San Clemente State Beach, Surfrider’s letter writes that the project will not just eliminate beach access, “but the public trust resource itself.” This directly violates the right to enjoy public tidelands and coastal access enshrined in existing Supreme Court case law, the Public Trust Doctrine, and the California Constitution, Section X, Article IV. 

Surfrider’s letter calls for the Coastal Commission to uphold its duty to protect our public trust resources. The only adequate remedy to OCTA’s existing armoring at Cyprus Shores and Cotton’s Point is the full restoration of dynamic shorelines—providing essential coastal access, recreational opportunities, and sandy beach habitat. As such, OCTA must comply with California coastal law and remove the riprap. 

As sea levels rise and coastal erosion worsens, adapting our coasts to a changing climate is more important than ever. This, however, does not give our public agencies the green light to go full steam ahead with projects that will only do more damage than good. How we accomplish this adaptation is just as crucial. 

Thus, OCTA’s proposed armoring and revetments, as it currently stands—or any project that will irreversibly occupy our public beaches—is not a true, long-term resiliency solution. In accordance with CEQA, the California Constitution, and the California Coastal Act, OCTA must complete a thorough EIR with proper opportunity for public comment to evaluate the significant harms and alternatives to this devastating armoring plan.

“Alternative modes of transporting passengers and freight exist,” Surfrider’s letter writes. “Alternative beaches do not.”

Families and visitors on June 28, 2024 spending time in San Clemente at Calafia Beach Park, just in front of the LOSSAN Rail Corridor, where OCTA plans to place a 50-foot wide engineered revetment.