Dear Coastal Property Owners Association of Santa Cruz County Member:

Your comments are needed by April 5, 2018.

The California Coastal Commission is drafting a Residential Adaptation Policy Guidance which:

1.Targets coastal homes to be sacrificed to compensate for sea level rise
2.Makes it more difficult to protect our homes from coastal erosion
3.Defines homes built after 1976 as “not existing”, limiting the right to obtain shoreline protection (another step towards removing coastal protection rights for all coastal homes)
4.Provides no just compensation for homes lost as a result of the Policy Guidance
5.Only addresses sacrificing residential properties for the sake of sea level rise while excluding commercial and public properties.

The following e-mail received from Charlie Caspary offers another opinion which you may find helpful in addressing your comments.

From: Charles Caspary
Sent: Tuesday, March 20, 2018 6:00 PM

Subject: Comments must be received by April 5th on Coastal Commission’s Residential Sea Level Rise Adaptation Policies

The Dear Neighbors

Draft #2 of this Coastal Commission policy (they are calling it “guidance”) is available for your review and comment. Rather than dealing with Sea Level Rise (SLR) on a community wide basis, the Commission has singled out residential property adjacent to the shoreline. If adopted, local governments will not only have substantially reduced options to deal with SLR, but also will not have the option of protecting you and your family – historical protections that are contained in the California Constitution and the Coastal Act

Last year, the Commission received 160 pages of comments on Draft #1 and dismissed most them in responses contained in a Frequently Asked Question format and left all of the bad stuff unchanged in the text of the current (Mar 2018) version.
Partial Comment sent last year
The basis of policies being proposed appears to be as stated in the Guidance document: “maintaining residential development adjacent to the shoreline will cause the narrowing and eventual loss of beaches, dunes and other shoreline and offshore recreational areas.
First it should be recognized that this statement is applicable to certain kinds of measures in certain locations but not to all coastal areas. Second, this statement is also overly broad and oversimplified in making a simple causal link between maintaining residential development and very extensive loss. The threat of climate change induced sea level rise (SLR) and shoreline loss should be taken very seriously but we must be clear that this threat is an underlying and much larger cause to be addressed–rather than “maintaining residential development”.
You can review the current (March 2018) draft of the “guidance document” by going to the Coastal Commissions web page at: https://www.coastal.ca.gov/cli mate/slr/vulnerability-adaptat ion/residential/

There are numerous tabs to select for your review.
1.View Public Comments (These will give you heartburn)
2.View Responses to FAQ’s (These staff responses will get you fired up to write your own comments to CCC)
3.Revised March 2018 Draft

Your written comments are vitally important (see below) – portions of the Coastal Act that guarantee your property rights are being ignored and / or subverted in this document. Please cc your comments to your local City Council Members / County Supervisors / County Planning directors / California Congressional Representative and be sure to cc the Coastal Rights Coalition at coastalrightscoalition@gmail.org

Please share this with all of your neighbors and HOA Board. Ask them to comment also. A sample comment letter is attached.

Written comments on the March 2018 revised draft are requested by April 5, 2018. Comments may be submitted by email to ResidentialAdaptation@coastal. ca.gov or by US Mail to the address below:

California Coastal Commission
c/o Sea Level Rise Working Group
45 Fremont Street, Suite 2000
San Francisco, CA 94105

Charlie Caspary
cell 818-384-4074

Sample comment letter:

California Coastal Commission
c/o Sea Level Rise Working Group
45 Fremont Street, Suite 2000 San Francisco, CA 94105

Delivered to ResidentialAdaptation@coastal.ca.gov


RE: Draft Residential Adaptation Policy Guidance (RAPG) March 2018 Document

The following represent several of the important issues and positions taken by the CCC we see in the draft RAPG that cause great concern amongst us and our neighbors along the California coast. We ask the Working Group and the Commission itself to take our concerns seriously as they reflect the same concerns of many others in our community along with those who have made similar statements in your public comment section to date.

In regard to the RAPG in whole, it is important to state clearly that it is only policy guidance document and has no regulatory power or requirement that any of the documents contents be included or adopted by a city/county LCP’s.

The RAPG attempts to redefine or alter the meaning of “Existing Structures” as being only those in place prior to 1976. This is a nefarious attempt by the CCC to circumvent the property rights of California coastal property owner’s contrary to the California State Constitution. This position in its entirety should be stricken from the document as it is direct opposition to the Coastal Act’s promise to allow coastal properties to be protected from the erosive forces of the ocean. This attempt at redefinition is illogical and frankly insulting for those of us who have built and have permits for our structures and protective shoreline devices approved by the CCC at great cost to us over the past 40 years.

Requirements or even recommendations for Sea-Level rise modifications to LCP’s should be reasonable, area specific, flexible and be based on practicality/feasibility. The amount and effect of Sea-Level rise is speculative at best and will affect the California coastline differently depending on location and a variety of other factors. Policy guidance suggests that managed retreat, raising home elevations while removing protective shoreline structures in place for decades or just letting homes be destroyed are the best way to deal with the Sea-Level rise issue. All these proposed options are either too expensive, unproven, not possible to implement (as in many cases there is no available land to retreat to) and appear to represent another effort by the CCC to take away private property ownership along the coast.

We are also very concerned that there are growing dramatic differences in how the CCC and other State agencies view the need, building, maintenance and repair of protective shoreline devices. In our area of Southern California there are more than 20 continuous miles of armor rock protecting mostly public and some private property along the coast. When damaged by storms or due to age, replacement or repair of the public protective devices is required, these projects are quickly done by Cal Trans, State Parks, the City/County or other governmental agencies in charge of these areas. No public hearings, permits, fees, or multi agency approval for these projects is apparently required by the CCC. This is the exact opposite for private property owners connected to these same protective structures. All we ask is there be consistent application of a standard processes that applies both to public and private property with regards to building, repairing, maintaining or altering the same protective structures in a specific area. This should also apply to all areas along the California coastline and should also apply to all related sections of the RAPG.

The original intent of the Coastal Act, which we continue to support, did not have the intention of taking of private property or make it relatively impossible and costly to adequately protect our homes and property. This proposed RAPG and the Commission as a whole seem to want to ignore private property owner’s rights and force an adversarial relationship between them and those of us that live along the coast of California. We are all for working out solutions that jointly protect both public and private property ownership along the coast as long as they are equitable, reasonable, and consistent for both public and private property. Single family private property residences along the coastline in total represent less than 5% of the coastline available in California. We are gravely concerned, given this current RAPG, and their increased power/influence over local governments LCP’s that the CCC wants to make us disappear by any means possible and this we cannot support!



The public comment periods April 5, 2018.


Please contact the Coastal Commission Sea Level Rise Team at ResidentialAdaptation@coastal.ca.gov

Please submit written comments by April 5 2018, by email to:
ResidentialAdaptation@coastal.ca.gov or by US Mail to the address:

California Coastal Commission
c/o Sea Level Rise Working Group
45 Fremont Street, Suite 2000
San Francisco, CA 94105


Keith Adams
Coastal Property Owners Association of Santa Cruz County