March 12, 2001Richard Parsons, Project manager City of San Buenaventura P.O Box 99 Ventura, CA 93002
RE: Surfers Point Managed Shoreline Retreat - Initial Study/Environmental Assessment
Dear Mr. Parsons,
Thank you for the opportunity to review and comment on the Surfers Point Initial Study. As you know, the Ventura County Chapter of the Surfrider Foundation has been a member of the "Surfers Point Working Group" since its inception. This beach is the most popular recreational area in the city, and deserves the best restoration effort possible. We are proud of the progress made to date, and we commend the working group for its successful consensus on this project.
We would like to express our enthusiastic support for the "Managed Retreat" concept. We look forward to this long-term solution to the problems at Surfers Point. Relocating the bike path and infrastructure landward will solve the principle cause of the erosion problem and allow the dynamic littoral zone to function unhindered. This high profile project reflects a precedent setting approach to shoreline erosion. If well designed, the restored Surfers Point will undoubtedly serve as an example for other beach communities worldwide.
However, the project proposal as currently presented lacks many details that could have a significant influence on the ultimate success of the project. In fact, it will be difficult to provide an accurate evaluation of the environmental impacts without a final design. Recognizing the role of the EIR in addressing all potential environmental impacts from this project, we encourage an iterative process whereby the design details are worked out in conjunction with the EIR to reach a final design.
While many of the potentially significant environmental impacts of this project have been identified in the Initial Study, we would like to point out some additional areas of concern that should be addressed in the EIR:
1. Remnant dunes near the rivermouth: The City of Ventura, the State Fairgrounds, the Coastal Conservancy, the State Department of Parks, and the Ventura Chapter of the Surfrider Foundation made an informal agreement that this area in the vicinity of the rivermouth was "Sensitive Habitat". A grant from the Coastal Conservancy was obtained to protect the dune area and to educate the public about the ecological significance and importance of this rare Southern California river-ocean-dune habitat. For more than 8 years, the signage indicating sensitive habitat and fences to minimize pedestrian impacts have been diligently maintained by Surfrider Foundation volunteers.
This dune area is a prominent feature of the Ventura rivermouth, and remains in existence despite several severe winter storms over the past decade. The proposed "cobble mattress" and regrading in this vicinity could have potentially significant impacts to these dunes, the beach, and the existing cobble substrate that makes up the delta near the rivermouth. This is not reflected in the Initial Study, and findings of potentially significant impacts should be considered as follows:
A. Aesthetics -1,3- This portion of the rivermouth area has significant aesthetic appeal to beach users, and the proposed imported cobble berm could adversely affect the naturally sandy beach and dunes.
D. Biological Resources - 4 - Although the Initial Study references the high use of this area, it has been designated "Sensitive Habitat". Although the project has the potential to enhance the habitat benefits of this area, the potential for significant impacts does exist as mentioned above.
G. Geophysical - 3 - Substantial grading or change in the natural features of this remnant dune area has potentially significant impacts to the geophysical processes in this area. Impacts from the proposed buried seawall and the potential for its exposure in the future should also be addressed. The effects of the levee extension, which essentially acts as a jetty with associated downdrift impacts, also needs to be considered in the overall design.
2. Surface Runoff: The Initial Study implies that the net increase in paved area is insignificant. Although a significant area of pavement will be removed with the project, the area to be paved within the Fairgrounds is larger and has very different geographical characteristics than the existing parking lot near the beach. The potential impacts to surface water are significant:
O. Water - 1, 2, 3, 5 - The parking lot to be removed is essentially the backshore of the beach, with runoff currently being directed toward storm drains on Shoreline Drive. The project will result in a more natural cobble and sand surface, so that future runoff will migrate through the soil toward the beach. In the past, large quantities of fill material were deposited in this area, much of it with possible contaminants. The EIR should address the presence of this material to ensure adequate mitigation measures.
The parking lot planned for the Fairgrounds area also has potentially significant impacts. Because of its low-lying location in historical wetlands, this area is prone to chronic flooding. The change in absorption rate upon paving this site will increase the flood hazard and affect coastal water quality with discharges of this water into the coastal zone unless mitigated.
3. Recreational resources: The initial study does not mention the recreational resources of Surfers Point. This regional park provides the most popular and utilized recreational resources within the City of Ventura. In addition to the bike path, which also serves walkers and runners, the beach itself provides the most popular surfing and windsurfing resource in Ventura County:
L. Public Services - 5 -Potential impacts to the quality of the surfing wave and access to the waters edge may occur with the creation of an artificial cobble berm. Similarly, the proposed buried seawall would have a significant impact should it become exposed in the future. This recreational resource should be considered in the EIR.
G. Geophysical - 3 - Substantial grading or change in the natural features of the shoreline has potentially significant impacts to the recreational resource. The surfing wave, a recreational resource for which Surfers Point is named, could potentially suffer if the dynamics that create the bottom contours are affected by regrading/removing the existing sand and cobble beach and dunes. Impacts from the potential exposure of the buried seawall should also be addressed.
In addition, the following details should also be considered in the final project design:
1. Future Renourishment: The project description includes a "sacrificial dune field" and "a commitment to periodic renourishment". This implies the potential for future erosion, possibly back to the "buried seawall". This brings up several issues that the coastal studies and final design should address:
a) Design lifespan - The projected lifespan and justification of design parameters for the cobble and dune features should be defined.
b) Existing fill - The existing parking lot is constructed upon approximately 4 feet of artificial fill. This material consists of a variety of soils and debris that is not suitable for beach replenishment (i.e. glass, steel, soils from oil fields, etc). The artificial beach near the bathrooms serves as a clear example of shoreline recession exposing inappropriate fill. It would be prudent to excavate the entire area beneath the parking lot. Filling this void with cobble and sand will ensure that any future erosion will feed beach quality material into the littoral zone.
c) Sources of sand and cobble - The recent cobble project in this area illustrates the potential for this type of renourishment using native materials from the Ventura River watershed. Similar native sources of sand and cobble should be used for this project. One potential could be the sediments trapped behind Matilija Dam.
Another consideration when selecting source material should be grain size. For instance, cobble is technically defined as less than 8" in diameter, but the recent cobble project included boulders up to 2 feet in diameter. At what point does a "cobble berm" become a "revetment"?
d) Buried seawall - We understand the concept of the buried seawall as a "silent sentinal", but why a wall and not an alternative such as a boulder-cobble core or a geotube core that provides greater permeability? What are the design parameters for this structure? And if this structure becomes exposed in the future, what is the fiscal and jurisdictional mechanism to ensure a "commitment to future replenishment"?
2) Other Design Details:
a) Backshore Design - The ultimate functional and aesthetic appeal of the entire project will rely upon the landscape design for the area between the bike path and the high water line. The drawings presented provide no indication of what will occur in this area other than the small dune field. Neither the horizontal area 25.5' wide, nor the vertical cross section beneath the parking lot has yet been defined.
The opportunity to create a functional and aesthetically appealing landscape should not be neglected. The dunes should be vegetated with native dune plants, walkways should be established to funnel pedestrian traffic, and this should all be integrated with the natural contours of the beach and the constructed contours of the bike path.
b) Removal of submerged infrastructure - To the extent possible, all nonfunctioning infrastructure should be removed from the nearshore area. This should include all outfall pipes that present a current and future hazard to recreation in shallow waters.
The Surfrider Foundation is proud to be a part of this project. Careful consideration of the issues outlined above will ensure that residents and visitors to Ventura will have a beautiful, safe recreational beach for generations to come.
Thank you for this opportunity, and we hope these comments are helpful during the scoping phase of the EIR.
A. Paul Jenkin M.S. Ocean Engineering Chair, Surfrider Foundation, Ventura County Chapter
Cc: Joe Power (Rincon Consultants Inc.)