Meeting Overview
The Commission met November 4–6 in San Francisco, where it addressed coastal adaptation in Santa Cruz, hosted a Local Government Working Group workshop on sea level rise, and approved “one of the largest encroachment impacts the Commission has ever considered in a single CDP” to protect an endangered beachfront rail segment in San Clemente.
After several hours of deliberation on Thursday, the Orange County Transportation Authority (OCTA) left with a 10-year permit to retain over 27,000 tons of emergency rock, add more to the existing footprint, and build an additional 1,200-foot seawall across a popular stretch of San Clemente State Beach. All told, a mile and a half of beach will become a pile of rocks, a wall of concrete, or both. As mitigation, OCTA committed to placing 690,000 cubic yards of sand on the beach in front of its armoring, but it’s uncertain whether, or for how long, that sand will stay.
In response to a unified front of coastal advocates, local residents, and tribal representatives calling for OCTA to maintain a walkable beach and minimize its armoring footprint, the Commission amended the permit to require a five-year check-in on how the sand replenishment performs. Depending on the results, the Commission will consider adding a requirement to maintain a passable beach in front of the armoring. That’s less than what ActCoastal and the community asked for, but it’s not nothing. Still, the mitigation package was too little, too late to earn a Pro-Coast vote without substantially stronger conditions. This was an Anti-Coast vote.
Lost in the wrangling over this permit were the larger questions: whether this rail segment can be maintained at all, and at what cost to taxpayers and San Clemente’s priceless public beaches. Coalition members Surfrider and California Coastal Protection Network urged the Commission to move up the timeline for the permit’s Long-Term Adaptation Study and to require a preferred alternative, but that ask fell short.
The day prior, the City of Santa Cruz received a CDP formalizing approximately 1,200 combined feet of emergency rock and seawalls along West Cliff Drive, most of it built after the 2023–24 and 2024–25 winter storms. In exchange for keeping the armoring, staff worked with the City on a mitigation package that includes a 600-foot landward realignment of West Cliff Drive along Lighthouse Field Park, the only segment of the corridor where this kind of proactive adaptation is immediately feasible. It’s only 600 feet, but it’s an exciting start, because the City’s recently certified LCP Update contemplates phased realignment of additional segments along the park.
Ambitious LCP policies like that lack teeth, though. If the City neglects, delays, or abandons those commitments outright, the Commission has little recourse. That’s why Surfrider and Save Our Shores asked the Commission to make these policies enforceable special conditions of the CDP, and a local beachgoer group, West Cliff Waves & Beaches, asked for similar accountability. City and Commission staff both disagreed, citing the City’s need for flexibility to secure funding and its good-faith progress toward proactive adaptation. The Commissioners ultimately deferred to staff.
ActCoastal understands wanting to reward the City for its good work, but this was a missed opportunity. Santa Cruz’s LCP requires armoring impacts to be commensurately mitigated, and that wasn’t demonstrated here. Conditioning those LCP commitments in the CDP would have given the Commission leverage to ensure the City follows through on realigning West Cliff Drive along Lighthouse Field, then removing the boulders from the beaches below. Without that, it’s unclear whether the mitigation for armoring is commensurate with impacts to beaches and sand supply that the Commission values at $18.3 million. Despite the City now taking West Cliff Drive adaptation seriously, this was also an Anti-Coast vote.
While the OCTA permit formalized far more armoring, both CDPs expose a back door in the Coastal Act, which Surfrider calls the “emergency-to-permanent permit pipeline” in its recent State of the Beach Report. The pattern is predictable. A storm hits, beaches erode, property or infrastructure is threatened, emergency permits are issued, and rock goes on the beach. “Temporary” armoring becomes permanent, as it did in both Santa Cruz and San Clemente. Full Coastal Act review doesn’t come until it’s too late, after the beach is already gone.
That segues into Friday’s Local Government Working Group (LGWG) workshop on sea level rise planning. With proactive plans in place, coastal communities could avoid answering foreseeable hazards with emergency armoring altogether. West Cliff Drive and the San Clemente rail corridor both should have had those plans years ago. The workshop centered on a draft Call-to-Action document, the majority of which aligns with ActCoastal’s priorities and provides useful common ground for coastal advocates and local governments to work toward.
However, the main sticking point is “neighborhood-scale adaptation,” which the LGWG now refers to as “Strategic Coastal Adaptation and Local Enhancement Districts” or “SCALED” adaptation planning. ActCoastal supports it where it preserves beaches and coastal access through nature-based solutions. The concern is that it will also be used to justify neighborhood-scale seawalls that further destroy beaches, including in front of structures that otherwise wouldn’t qualify for armoring under the Coastal Act. The Commission’s approval of Pacifica’s LCP Update did exactly that, and ActCoastal counted it as the worst vote of 2025.
Check out our full November report for a deeper dive into West Cliff Drive, the ongoing debate over the San Clemente rail segment, and the Local Government Working Group workshop.
Issues voted on at this meeting:
he Commission approved a permit for the City of Santa Cruz formalizing about 1,200 feet of emergency rock and seawalls along West Cliff Drive, most of which went in after the 2023–24 and 2024–25 winter storms. Commission staff valued the armoring’s impacts on public beaches and sand supply at $18.3 million. Unfortunately, the mitigation package fell short of being commensurate with the impacts as Santa Cruz's LCP requires. The Commission missed an opportunity to hold the City to its ambitious LCP planning commitments.
On November 5, after several hours of deliberation, the Coastal Commission gave the Orange County Transportation Authority (OCTA) a 10-year permit to protect its railroad along San Clemente’s beaches. OCTA gets to retain over 46,000 tons of emergency rock placed since 2021, add significantly more rock within the existing footprint, and build a 1,200-foot seawall across a popular stretch of San Clemente State Beach. As mitigation, OCTA committed to placing 690,000 cubic yards of sand in front of its armoring. It’s uncertain whether, or for how long, that sand will stay.
Other Discussions
Local Government Working Group, A Call to Action, & SCALED Adaptation Planning
On Friday morning, the Commission hosted a Local Government Working Group (LGWG) Workshop to discuss sea level rise adaptation and LGWG priorities. The LGWG brings together Commission staff with local elected officials from coastal cities and counties to work through challenges related to local sea level rise adaptation. For over a decade, they’ve held a public workshop every 2-3 years to discuss progress.
This year’s workshop centered on a draft Call-to-Action document, much of which aligns with ActCoastal’s priorities and provides useful common ground for coastal advocates and local governments to build on.
For several years now, discussion at these workshops has revolved around a stated need from the LGWG, backed by Commission staff, to move beyond parcel-by-parcel planning toward neighborhood-scale adaptation. The LGWG has since rebranded the concept as “Strategic Coastal Adaptation and Local Enhancement Districts,” or “SCALED” adaptation planning. It remains a major point of contention between the LGWG and the ActCoastal coalition.
ActCoastal supports neighborhood-scale adaptation where it preserves beaches and coastal access through nature-based solutions. The concern is that it will also be used to justify neighborhood-scale seawalls that further destroy beaches, including in front of structures that otherwise wouldn’t qualify for armoring under the Coastal Act. The Commission’s approval of Pacifica’s LCP Update did exactly that by creating Special Shoreline Resilience Areas, which relied on a questionable application of the Coastal Act’s conflict resolution provision. Other coastal communities may now follow Pacifica’s lead. That creates a legal pathway for neighborhood-scale seawalls that will likely lead to beach loss, and it closes the door on proactive, nature-based adaptation that requires making hard decisions before time runs out. For these reasons, ActCoastal counted the Pacifica LCP Update as the worst vote of 2025.
Commission staff is now developing two guidance documents as a result of the LGWG Workshops: one on SCALED adaptation approaches in LCP amendments, and a companion technical guidance document for assessing beaches persistence with sea level rise. Both should be available for public review in December. ActCoastal looks forward to reviewing them and will be watching closely to make sure SCALED planning doesn’t become a fast track for armoring.
November Report Now Live
The Commission met November 4–6 in San Francisco, where it addressed coastal adaptation in Santa Cruz, hosted a Local Government Working Group workshop on sea level rise, and approved “one of the largest encroachment impacts the Commission has ever considered in a single CDP” to protect an endangered beachfront rail segment in San Clemente.