The San Luis Obispo County Chapter of the Surfrider Foundation has responded to the seawall proposals made by the Army Corp of Engineers. In the short time we had posted information on our website, over 20 people responded to our beach survey in time for submission. You can review our formal response Here: Pismo Beach Seawall and Here: Pismo Beach Seawall Pics. Our Chair, Jeff Pienak, made some additional comments which where submitted with the surveys:
Vista Del Mar (188.8.131.52)
Given that the largest winter swells tend to come from the west,14 it is reasonably foreseeable that the proposed project at this location would result in flank erosion to exposed unarmored bluffs located southeast of the proposed project. The sculpted concrete wall alternative (which is the preferred alternative for this location in the EA/MND15) could have impacts on the existing stairwell adjacent to the project area due to scour caused by wave energy reflection from the revetment. Unlike rock revetments which tend to dissipate energy due to gaps in the revetment and the angular surface of the revetment, smoothsurfaced concrete revetments tend to reflect wave energy. This can result in scour of sediments that lie in the zone of reflection, such as the sediment underneath and around the existing stairwell. Loss of this stairwell via cumulative impacts of the project would be a significant impact to access, which should have been analyzed in Section 5.7. The rock revetment alternative, if implemented, would place a rock revetment beneath and immediately adjacent to an existing stairwell. By locating a rock revetment here, the eastern portion of the beach currently accessible via the stairwell would not be easily accessible (i.e. without climbing on the rock revetment) during high tides, restricting accessible beach area from this stairway at high tides to a very small area between the stairwell and westerly adjacent seawall. Rock revetments are generally undesirable because of the relatively large footprint on the beach.
Ocean Park (184.108.40.206)
A rock revetment at this location would cover 51 percent of the total beach area at this site,16 which would be a significant loss of usable beach area. Although this beach is not heavily used,17 data from our beach access survey indicates that is used regularly by beach goers and tidepoolers.
Price Street – North (220.127.116.11)
Beach access is available via a path from the hotel.18 The loss of beach to the rock revetment footprint would be 0.39 acre, which is 23 percent of the beach at this site.19 Given that this pocket beach is the only accessible swath of beach area from the trail, this would result in a significant loss of currently-accessible beach.
14 EA/MND p. 53, Section 18.104.22.168
15 p. 30
16 EA/MND p. 120
17 Appendix A. Beach Access Survey, Surfrider Foundation San Luis Obispo Chapter. Dec. 13 – Dec. 16 2010.
18 EA/MND p. 157
19 EA/MND p. 161
Cypress Street (22.214.171.124)
The proposed rock revetment alternative would result in a loss of 0.69 acres of sandy beach.20 The beach near the Cypress Street Lift Station is heavily used by beachgoers.21 Although this beach is a broad, sandy beach, the proposed project footprint would displace a significant amount of recreationally-used beach area, including existing beach volleyball courts. Traffic, Section 4.11: Broadly, the EA/MND uses an inappropriate baseline figure for traffic. Although the most significant traffic impacts will occur along neighborhood streets adjacent to the project areas where streets are narrow and designed to accommodate a low level of traffic flow, the EA/MND uses the Average Annual Daily Traffic volumetric figures for traffic on Highway 101 as the baseline against which the number of truck trips through the neighborhood are compared. Therefore, these baseline traffic figures for the neighborhood areas are grossly inaccurate. During construction periods, there are potentially significant impacts to traffic which have not been appropriately characterized or analyzed. Aesthetics, Section 4.14: If rock revetments were put in place in any of the project areas, there would be significant impacts to aesthetics, particularly regarding views from the beach. Large rockpiles would change the landscape significantly and would be incompatible with the surrounding natural bluffs and/or adjacent armoring (as armored areas are predominantly concrete revetments).
V. Additional Issues
Inappropriate Use of Public Funds to Protect Private Property The proposed project at the Cypress Street site would partially protect private residences where the bluff has continued to retreat underneath hardened armoring of the bluff top. It is inappropriate for the U.S. Army Corps of Engineers or the City of Pismo Beach to extend its project scope to include protection of privately owned property and would constitute to a gift of public funds.
20 EA/MND p. 136
21 EA/MND p. 137
In conclusion, to comply with relevant law promulgated by CEQA and NEPA, Surfrider urges the Corps and City of Pismo Beach to fully analyze the potentially significant environmental impacts associated with this project, as identified in this comment letter, and prepare an Environmental Impact Statement/Environmental Impact Report (“EIS/EIR”).
Jeff Pienack, Chair
San Luis Obispo Chapter