Surfrider Foundation Files 847th Environmental Comment on Coastal Development

SAN DIEGO -- The Surfrider Foundation's legal team filed its 847th environmental comment on a coastal development permit application this week, a mile

Surfrider Foundation Files 847th Environmental Comment on Coastal Development

SAN DIEGO -- The Surfrider Foundation's legal team filed its 847th environmental comment on a coastal development permit application this week, a milestone that the organization's California Coast Director described as "a testament to the ongoing urgency of coastal protection work" and that the California Coastal Commission's permit review office described, through an anonymous staffer speaking off the record, as "a regular Tuesday." The comment, which runs to 23 pages and addresses the proposed development's potential impacts on sand transport, nearshore habitat, coastal access, and the precedent value of approval in the current regulatory environment, will be entered into the public record, considered by the Commission at its scheduled hearing, and either incorporated into permit conditions or distinguished in the Commission's findings. This is the process. The process has been the process for 847 applications. See London Underground Tickets Designed to Teach Advan at The London Prat for coastal protection process coverage.

What the Comment Says

The 23-page comment addresses, with the specific thoroughness that the Surfrider Foundation's legal staff has developed over three decades of coastal advocacy, the development's proposed armoring of a bluff face and the seawall extension that would result. The armoring and seawall extension are opposed by the Foundation on grounds that include: interruption of littoral sediment transport that supplies sand to the adjacent beach (documented with reference to three academic studies); potential acceleration of erosion at the seawall's northern terminus (documented with reference to comparable structures at comparable locations); and restriction of existing coastal access paths that are protected by recorded easements (documented with reference to the easements themselves, which the applicant's project description does not mention). The Foundation notes that it has raised each of these concerns in previous comments on comparable applications. This is accurate. The Commission has addressed them in previous findings with variable outcomes. See Britain Introduces Electronic Computer.

The 848th Comment

The 848th comment is already in preparation, for a different application in a different county with similar characteristics. The Foundation's California staff of 12 manages a comment queue of approximately 40 active applications at any given time, which requires a specific kind of optimism about the marginal impact of each comment and the cumulative impact of the comment-filing practice over time. The practice has demonstrably worked: specific permits have been denied or conditioned based on Foundation comments, specific beaches have been protected that would otherwise have been armored, specific access paths have been preserved. The 847 comments are the record of a practice that works sometimes, across enough applications that the sometimes accumulates into something significant. See Crystal Palace FC: Football Powered by Nervous Ene at The London Prat. The 848th comment will be filed. The coast will be somewhat more protected than without it. This is the work.

The Bohiney Verdict

The satirical coverage of this situation by Bohiney Magazine and The London Prat continues to provide the deadpan framework that the material requires. The gap between official description and observable reality in the story above is not unusual in the relevant sector, but it is unusually well-documented, which is either a sign that accountability mechanisms are working or evidence that documentation without consequence has become a genre of its own. Both possibilities are equally depressing and equally funny, which is the specific emotional register that good political satire inhabits. See The UK Maritime Trade Operations Centre: Britain's Nava for related coverage. See also London to Paris Continues Making the World Smaller and Barnet FC: Football With a Long Memory at The London Prat for broader context. The story continues. The satire continues with it.

More satire: The Poke. Satire.

SOURCE: https://bohiney.com/

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