As it stands, the proposed project to hard armor approximately seven miles of coastal rail segment from the San Diego/Orange County border north to Dana Point has many drawbacks —accelerated coastal erosion, bluff failure, ongoing risk from storm surge and sea level rise (SLR), and landslides on the landward side of the tracks.
For decades, Surfrider has urged the Orange County Transportation Authority (OCTA) to relocate this segment to protect against ongoing loss of sandy beach habitat and public recreation opportunity, yet OCTA has failed to take necessary steps for long-term planning and permitting for the relocation of this vulnerable segment. Instead, OCTA has chosen a reactive approach of incessant rail armoring in response to these ongoing threats.
Most egregiously, beginning in Fall 2021 in the southern end of San Clemente, OCTA applied for the first of several “emergency” permits to dump massive amounts of riprap on the public beach. These boulders have effectively eliminated the beach at Cyprus Shore and severely impacted Cottons, the northernmost of famed surf breaks of Trestles, degrading the wave and creating dangerous conditions with boulders in the surf zone. The riprap also blocks the public from walking to and from the surf breaks of Trestles and San Onofre State Beach to the south. Finally, the riprap impedes the natural ebb and flow sand supply while accelerating coastal erosion.
Image: Cyprus Shores seawall at Cottons Point and Trestles Surf Break
OCTA is now planning to further armor south San Clemente, extending the rock revetment north from Cyprus Shore for 2/3 of a mile, along San Clemente State Beach up to Calafia Beach Park. If allowed, this 50-foot wide revetment would eliminate the coastal dunes and sandy beach and block access to popular surf spots. For these reasons, Surfrider opposes any additional riprap in south San Clemente and supports full restoration of Cyprus Shore beach and Cottons surf break, allowing coastal processes to be restored to a more natural state.
Image: San Clemente State Beach, site of proposed shoreline armoring extension
Unfortunately, rather than planning for removal of the vulnerable coastal rail segment and restoring our beaches' natural processes, OCTA has not acted upon the need for relocation and continues building revetments upward and outward, further exacerbating coastal erosion and loss of sediment supply. In 2021, OCTA determined in their sea level rise study that their preferred coastal resiliency strategy is to maintain the existing rail and infrastructure in place and continue to build and expand rock revetments and seawalls at the expense of the beach. OCTA repeated this flawed approach in its February 2024 Coastal Rail Resiliency Study Initial Assessment.
Protecting Public Trust Lands and Waters
The preservation of California’s beaches and tidelands for natural habitat and recreation is protected under the common law Public Trust Doctrine, the Coastal Act, and the California Constitution. The public has a right to access and enjoy these special places and this right cannot be infringed upon by non-Public Trust uses such as the railroad.
As the United States Supreme Court announced in the lodestar case Illinois Central, the State may not abdicate control of these lands and waters and must preserve them for the use of the public. The Court specifically determined that the State cannot place control of these lands and waters in the hands of a railroad, for the limited purpose of “transportation of passengers and freight.”1 OCTA falsely claimed that its 2021-2023 beach armoring would not impact public access and would only have minimal and temporary impacts on recreational opportunities and coastal ecosystems. In reality, OCTA has permanently blocked public lateral access to the extremely popular San Onofre state park and is responsible for highly significant impacts to coastal recreational opportunities and ecosystems.2
This infringement on public beaches and tidelands constitutes trespass and a taking of public lands and waters. Instead of reversing these harms, OCTA is now planning to further impede the public’s ability to access and enjoy yet another very popular State Park and again permanently damage the recreational, habitat, and scenic value of immensely important public trust resources.
Surfrider strongly supports robust public transit that reduces greenhouse gas emissions in the region. However, an analysis of alternative means of achieving this goal that do not destroy our beaches and have other benefits is necessary under the California Environmental Quality Act (“CEQA”) and the Coastal Act. The Coastal Act is clear that coastal-dependent uses must be protected and prioritized over non coastal-dependent uses.3 The rail line is not a coastal-dependent use and OCTA has an affirmative duty to ensure that the line does not infringe on the public’s right to access and enjoy our public lands and waters.
A recent study from UC Irvine researchers notes4 that in the absence of coastal armoring, beaches along the Camp Pendleton and San Clemente coast will have a tendency to widen in the presence of a sand supply, pointing to the potential for effective beach nourishment and living shoreline projects once the riprap is removed.
The most cost-effective and sustainable sand supply comes from natural sources. However, the railroad tracks and associated hard armoring act as a barrier to the natural sediment supply from eroding coastal sandstone bluffs and seasonal streams, including the hoodoos and coastal canyons at State Beach. For example, at State Beach, heavy accumulations of sediments have been collected and restrained from reaching the adjacent beach with K-rail and stacked concrete interblock units placed at the mouth of finger canyons. Surfrider also supports the restoration of our coastal canyons and watersheds to enhance the amount of sediment that is delivered to the beach from fluvial sources such as the San Juan Creek.
The taking of our public trust lands cannot be remedied by in-lieu fees or inconsistent and insufficient sand replacement. In the early 2010s, sand placements in San Clemente of 251,000 cubic yards was quickly washed away within a few storm cycles, wasting millions of tax-payer dollars.5 OCTA cannot create a new San Clemente State Beach once it is destroyed. The complexity and diversity of natural systems that have evolved over millennia, both living and geological, cannot be recreated. An in-lieu fee is completely inadequate mitigation for the loss of a priceless beach. One-time or intermittent sand replacement is unlikely to restore Cyprus Shore and Cottons while the riprap remains in place. The northern sand transport that occurred during late-summer and early-fall south swells that previously naturally rebuilt the beach at Cottons and Cyprus Shore is now blocked, starving these beaches and adjacent beaches of naturally occurring sand.
Surfrider recognizes the need to mitigate for the ongoing loss of public trust resources, including beach loss, local shoreline sand supply, restrictions in beach access and recreation, impacts to tourism industry and regional economy, and impacts to the coastal trail system. Surfrider supports a requirement to restore lateral access to Trestles from San Clemente beaches by removing the riprap in south San Clemente and restoring natural coastal dynamics and Cottons surf break.
Surfrider supports short-term adaptation strategies that do not require armoring and allow for ecological function, including dune restoration and a living shoreline that promotes the restoration of coastal habitats and helps maintain ecological function and balance. We have determined that dynamic living shorelines in some areas would require greater beach width than currently possible with the railroad tracks and associated hard armoring in place.
Ultimately, given the reality of SLR, it is clear that we must create or maintain open space inland from the beach, so that it can slowly migrate inland rather than eroding away entirely. This practice of managed retreat, while challenging, is preferable to hard armoring because it preserves the natural beach. It is incumbent upon the state and local governments to identify short and long-term adaptation strategies that protect California's beaches and public trust resources.
Citations
- Illinois Central Railroad v. Illinois, 146 U.S. 454, 460 (1892).
- HDR. (2022, February 25). Resubmittal: Coastal Development Permit Application for Railroad Emergency Stabilization Project – San Clemente Orange Sub MP 206.85. Letter to Ms. Shannon Vaughn, Coastal Program Manager, California Coastal Commission, South Coast District Office, Long Beach, California. (Page 7). https://tinyurl.com/bd6drv4b
- Cal. Pub. Res. Code § 30255
- https://www.sciencedirect.com/science/article/pii/S0378383924000218
- California Coastal Commission. Staff Report for Consistency Determination CD-029-11. https://documents.coastal.ca.gov/reports/2011/11/W6b-11-2011.pdf