City of Carlsbad
Attn: Carl Stiehl, Community and Economic Development Department Planning Division
1635 Faraday Ave.
Carlsbad, CA 92008
September 25, 2017
Dear Mr. Stiehl:
The Surfrider Foundation’s San Diego Chapter (Surfrider San Diego) appreciates this opportunity to
provide comments to the City of Carlsbad regarding the May 2017 Draft Final Sea Level Rise
Vulnerability Assessment. Surfrider San Diego appreciates the multiple opportunities for extensive
stakeholder and public engagement in the development and review of this update.
Surfrider Foundation (Surfrider) is a nonprofit environmental organization that engages a vast volunteer
network of ocean users to protect the ocean, waves and beaches through conservation, activism,
research, and education. Surfrider San Diego represents thousands of ocean recreation users from
surfing to seabird watching and beach going, as well as the coastal communities and economies that rely
on them throughout the region.
Surfrider San Diego is very happy to see the inclusion and consideration of potentially using a phased
approach to implement various adaptation strategies based on pre-determined sea level rise triggers.
This method is a great way to account for uncertainty in sea level rise prediction estimates, while still
ensuring that the coastal community remains prepared and resilient. We urge that if this method is
utilized, that the necessary time between triggers and the approval, construction, and complete
implementation of the adaptation method is sufficient. Pre-emptive permitting and detailed action plans
could help ensure that triggered adaptation methods are readily employable.
We support the additional consideration of potential sea level rise impacts to visual resources, cultural
resources, saltwater intrusion, and lifeguard services. The consideration of maladaptation, tradeoffs,
and negative impacts from the use of hard protective devices and sand nourishment are extremely
important. Surfrider San Diego applauds their consideration and the inclusion of secondary impacts in
the adaptation overview. We would like to encourage the shift towards using more effective, and
affordable (over the long term) soft adaptation measures like living shorelines and reconstructed sand
dunes, as well as accommodation and retreat. Additionally, pre-emptive planning can help avoid the use
of emergency approved hard protective devices such as seawalls.
Surfrider San Diego would like to bring attention to the following considerations identified in the
• The vulnerability assessment only reviews impacts from 2050 on, nothing beforehand. With
projections showing sea level rise of up to 1 foot by 2030, this failure to consider more immediate
sea level rise hazards puts the community at risk, doesn’t provide a thorough review of actual
vulnerabilities, and weakens the integrity of any future adaptation plan based on this assessment.
• Environmentally sensitive lands in Planning Zone 1 were reduced from moderate vulnerability to low
vulnerability in the 2017 assessment, due to a weir’s ability to restrict tidal exchange through 2050:
however, we’d like to remind the City that this is not a complete climate change impact assessment.
For instance, flooding of the lagoon and loss of environmentally sensitive lands could occur from
stronger and more frequent rain events and run off, not just rising sea levels. Surfrider would also
like to highlight that the weir is privately owned and operated, so to account for the protection of
the weir when lifted, the City must have an approved, official, and enforceable agreement with
operating landowners to ensure that the weir is employed to prevent tidal exchange through 2050.
• We support the use of hazard overlay zones, and the potential requirement of “site-specific coastal
hazard reports” to be included with each coastal development permit.
• We support the development of a coastal armoring database and action plan. Information regarding
the age, type, and condition of coastal structures is vital in ensuring that current seawalls are
maintained and usable, while seawalls no longer useful are removed in a timely manner.
• When ranking effectiveness of various adaptation strategies for the region’s range of shoreline
types, managed retreat was consistently and accurately identified as the most effective strategy,
followed by a form of soft adaptation methods including dune restoration, wetland restoration, or
construction with movable foundations.
• Although we are happy to see a preliminary review of adaptation options, we hope to see more
explicit adaptation plans in a separate and comprehensive citywide adaptation plan. We believe this
assessment fell short on the stated task to “[d]evelop adaptation strategies to minimize risks from
hazards and to protect coastal resources”.
• Regarding the methodology –
o It is unclear how “overall beach function” was measured, as this has big implications on the
beach vulnerability ranking.
o Were extreme storm events (1 in 100 years) modeled to occur more frequently between
now and 2100 during the analysis?
We submit these comments on behalf of Surfrider Foundation’s San Diego Chapter and our thousands of
members, supporters, and volunteers throughout the San Diego region. Thank you for your
consideration of our comments regarding the City of Carlsbad’s 2017 Draft Final Sea Level Rise
Surfrider Foundation San Diego