2-17-0702 (Sharp Park Armoring)
16 authorization for work that led to the earthen berm and rock riprap as it currently exists, including all unpermitted armoring and earthen work previously conducted on site. Due to the nature of the significant changes to the berm, it is considered a replacement structure, and is evaluated herein as a new berm in the existing configuration for the purposes of this report.5 C. PROJECT DESCRIPTION
Therefore, SFRPD seeks after-the-fact CDP authorization of constructed shoreline armoring seaward of the Sharp Park Golf Course, consisting of an earthen berm approximately 3,200 feet in length, and two sections of rock riprap fronting the berm, approximately 1,425 lateral feet in total (or almost half of the length of the berm). Based on current as-built plans, the approximate footprint of the entire armoring structure, including the earthen berm and the riprap fronting the berm is 170,500 square feet. As-built surveys of the armoring indicate that the earthen berm has been substantially expanded over the years from a permitted top width of 8 feet to an average top width of approximately 26.2 feet (and a max of over 80 feet wide). Additionally, the berm currently exists above the original design height of 25 feet above mean sea level, fluctuating in elevation from 29 to 30 feet along nearly its entire length aside from the very northern portion of the berm. Essentially, the berm has become both significantly wider and taller over time, more than doubling in size relative to original permitted dimensions.6Thus the proposed project is for after-the-fact approval of the berm as constructed, and this report evaluates the impacts of the proposed development as if it is not already present, even though the armoring is currently physically in place.
See Exhibit 1 for location maps and Exhibit 2 for as-built project plans.
D. STANDARD OF REVIEW
The proposed project is located along the seaward boundary of a public golf course along the shoreline in the City of Pacifica, which has a certified Local Coastal Program (LCP). However, the proposed project involves development within an area of the Commission’s retained permitting jurisdiction because development is proposed in an area that is defined as former tidelands, submerged land or land subject to the public trust (i.e., Sharp Park is an area that was historically filled prior to the Coastal Act, but is still considered former tidelands for CDP permitting purposes). In addition, the violation and the proposed project to rectify it are specifically associated with Commission CDPs and amendments. Therefore, the standard of review for this CDP application is the Chapter 3 policies of the Coastal Act, with the City’s LCP providing non-binding guidance, and the appropriate permitting entity is the Coastal Commission.
5 Including because the Commission’s regulations consider replacement of more than 50% of the materials of such a structure to be a replacement structure requiring a new CDP analysis (CCR Section 13252(b)), and because the SFRPD activities not only replaced more than 50%, but actually enlarged the berm essentially by 100% to create a new augmented berm structure.
6 CDPs 3-83-172-A4 and 3-83-172-A5 authorized construction of a 3,200-foot long earthen berm with a back slope and fore slope of 2:1, with a flattened top 8 feet wide, at an approximate height of 25 feet above mean sea level.