Surfrider Additional Comments
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June 21, 2021 To: Lincoln County Department of Planning and Development Second Street Annex 210 SW Second Street Newport, OR 97365 Submitted via email to [email protected] Re: Additional Comments on Proposed Goal 18 Exception at Gleneden-Lincoln Beach - case files #01-LUPC-21, 02-LUPC-21, 03-LUPC-21 Dear Mr. Husing, Thank you for the opportunity to comment on the proposed Goal 18 Exception at Gleneden-Lincoln Beach for WorldMark, the SeaRidge Condominium Association, and the owners of four adjacent single-family homes (case files #01-LUPC-21, 02-LUPC-21, 03-LUPC- 21). Please enter these comments into the record for the applications. The Surfrider Foundation is an environmental nonprofit organization dedicated to the protection and enjoyment of the world's ocean, waves and beaches for all people, through a powerful activist network. We have chapters in Portland, the North Coast, South Tillamook County (Three Capes Chapter), Newport, Florence (Siuslaw Chapter), and Coos Bay. Our members live, work, visit, and recreate on Oregon’s coastal beaches and value these special places for exploration, research and enjoyment. Our activist network, who have a heartfelt interest in the outcome of your decision, urge you to consider the long-term effects of your decision on our coast, on the public’s ability to enjoy the beaches, and the health and wellness of our coastal systems for generations to come. Oregon is among a select group of states who hold our beaches open to the public as of customary right. This is our legacy to preserve for our children. With that we urge you to consider the weight of your decision and to help continue Oregon’s tradition of accessible open spaces and natural beauty for everyone. A. Shoreline armoring has no place in coastal management. Sufrider’s primary interest is to protect the public’s customary right of access and recreation across Oregon’s dry, sandy beaches. This includes what is left, if anything, of Gleneden-Lincoln Beach. This means protecting, and advocating for the preservation of the beach itself. We strive to protect the processes that promote sand accretion (build-up) along the coast. These natural shoreline processes include sediment deposit from upland rivers, cliff PO Box 719, South Beach, OR 97366 | [email protected] | oregon.surfrider.org erosion, and sand migration. But, these processes are being threatened by shoreline armoring structures like the rock revetments proposed here. Shoreline hardening structures are a major contributing factor to the loss of sand accretion. The structures deplete the existing sand profile and block it from its natural migration up and down the coast. Shoreline armoring directly destroys our beaches by inhibiting the natural processes that make up the sand. This stretch of shoreline--its development, its abundant armoring, and loss of public beaches--is a prime example of the outcomes that drive our opposition to shoreline armoring. This is what happens when static revetment structures are permitted in these highly dynamic environments. Shoreline armoring should rarely, if ever, be the solution to conflicts arising from coastal erosion or beach hazards, especially as they become more and more common with sea level rise. That said, if one does find that these circumstances warrant rip rap, then we urge you to consider narrowly defining the exception in order to keep shoreline armoring to locations that absolutely necessitate their use. B. The Commission should narrowly define the exception. If the Commission finds that the applicant's reasons justify an exception to the Statewide Land Use Planning Goal 18, the exception should only be based on the unique physical features-- both man-induced and naturally occurring--of Gleneden Beach. The justification should be narrowly defined to limit its use elsewhere. The exception should not be based on the “economic impact” argument that is found on page 18 of the Combined Narrative. Establishing this distinction aligns with the spirit of Goal 18 and with the exception criteria of Goal 2. Goal 18's purpose is to preserve beaches and dunes along the Oregon coast as well as mitigate the negative consequences that arise when naturally dynamic ocean processes meet human development. By the very presence of Goal 18--and the restrictions to beachfront protective structure--it’s clear legislators anticipated conflicts between competing public and private interests. They expressly provided specific criteria that warns private entities about developing near the beach. The Goal prohibits shoreline armoring that would otherwise protect their property when the date is not met. The warning specifies that their economic interests will not have the State’s protection if a conflict were to arise between the beach and their development, if development started after January 1, 1977. It follows then that the intent of legislators was to require more than considering private economic impact when counties and municipalities grant goal exceptions. This is because the Goal was designed around the understanding that these two competing interests were bound to clash. The property owners were on notice that the impact of developing too close to the beach could be an economic hardship on them. It should be noted that Statewide Land Use Planning Goals 7,8,9, and 10 should not hold weight in the decision. Rather, Surfrider finds that many of these above referenced Goals and applicant arguments provide for more reasons not to provide a Goal 18 exception. The county should not apply these in the bearing of their decision. PO Box 719, South Beach, OR 97366 | [email protected] | oregon.surfrider.org C. The beach provides recreational opportunity for purposes of Goal 8 (Recreation) The applicants make a number of arguments asserting that protecting the subject properties will promote Statewide Land Use Planning Goal 8 (Recreation). However, these assertions are misguided. They are based on the rip rap protecting private dwellings and not recreational resources like the ocean. Goal 8’s purpose is to “To satisfy the recreational needs of the citizens of the state and visitors and, where appropriate [emphasis added], to provide for the siting of necessary recreational facilities including destination resorts.” The beaches provide a recreational outlet for the citizens and visitors, the houses do not. In that respect, utilizing Goal 8 as justification for creating a goals exception misses the purpose of the Goal and should not be considered when analyzing the application. Protecting the homes is not the purpose of Goal 8; providing access to recreational opportunities is. Beach and ocean based activities drive in billions of dollars for the local economies on the Oregon coast. “In 2010, Oregon residents took an estimated 27 million trips to the coast, 88 percent of which the primary purpose was recreation. The average respondent spent $87.72 per trip, translating to an estimated 2.4 billion dollars in total direct expenditures.”1 Economic impact should be considered when weighing the decision. It’s important to recognize that this stretch of coastline presents unique recreational opportunities in the Ocean. These activities are often related to but separate and unique from those recreational activities of the beach. These activities include, but are not limited to, swimming, bodysurfing, surfing, kiteboarding, stand-up paddle boarding, and kayaking. The Lincoln-Gleneden Beach shoreline is highly unique in providing for many of these opportunities for recreational activities that are important to Lincoln County residents, visitors and the local economy. These activities have been well mapped in this area and economic contributions have been clearly identified as important to the state of Oregon. This is true both in planning for Oregon’s Territorial Sea Plan, but also in the management of the coastal shore. D. Impact on adjacent state park Surfrider is highly concerned with how this rip rap will further affect the erosion of Gleneden Beach State Park and the beaches surrounding the area. The armoring will accelerate erosion at a well-established access point for recreational ocean users. These activities, as described and planned for in Oregon’s Territorial Sea Plan Part III (documented within Surfrider Foundation’s Non-Consumptive Ocean Recreation Study), should be considered and planned for. Negative impacts are likely to occur to the access point and these recreational opportunities will be affected. As previously described, these are important resources for the state and county to identify and plan for in any land use decision-making. Further, diminishing beaches as a result of the rip rap will detrimentally affect beach access at the Park. Rip rap, while protecting the property they are designed to protect, focuses water to the neighboring park of the subject properties. The county, with support from the State 1 A study shows the amount of money the beach drives in from people visiting for recreational purposes. http://oregon.surfrider.org/wp-content/uploads/2014/09/Surfrider_OR-Report_ExecSumm.pdf PO Box 719, South Beach, OR 97366 | [email protected] | oregon.surfrider.org of Oregon, should provide (or require of the applicant) a detailed, comprehensive report on the effects of this structure on the Park and the littoral cell as a whole. This is because of the impacts to these important recreational and economic resources of the state. E. The unique nature of Lincoln-Gleneden Beach area. The Lincoln-Gleneden Beach area is extraordinarily unique for several reasons. First, proliferation of existing armoring has led to a steep beach profile. Second, Gleneden-Lincoln was the location of sand mining from 1965-1971. The project removed an immense amount of sand from the area. Third, Siletz Bay to the north contributes to some of the deprivation of sand on this beach because it acts as a deposit. Finally, 90-Percent of the adjacent beach is already armored with existing rip rap.