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. The meeting resulted in two Anti-Coast votes, the most of any meeting in 2026. Both votes expose a major Commission vulnerability, its failure to properly mitigate emergency armoring when it comes back for a required followup CDP.

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.

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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.

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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.

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