CARLSBAD — The California Coastal Commission has found a “substantial issue” in an appeal challenging a property owner’s plans to repair the crumbling public beach access staircase at Terramar, setting the stage for a full de novo review at a future meeting.
During its March 13 meeting, the commission heard a staff presentation outlining concerns over the city-approved plan, which includes building two tied-back shotcrete seawalls, infilling sea caves with erodible concrete, drainage improvements and handrail and step replacements.
The project aims to stabilize the deteriorating staircase, a privately owned structure connecting the Terramar neighborhood to South Carlsbad State Beach.
The commission’s San Diego District staff recommended a “substantial issue” finding, citing concerns over jurisdiction, shoreline protection policies, public access and the project’s reliance on an unpermitted seawall.
According to commission staff, portions of the project extend seaward of the mean high tide line, meaning they fall under the Coastal Commission’s jurisdiction. The city has disputed this finding, arguing that multiple surveys confirmed the project lies within its authority.
“The city submitted a letter in response to the staff report disputing this determination,” a commission staff member said. “And while the commission’s mapping unit does not believe the site is bisected based on their initial review, the city’s continued dispute of this determination supports a finding of substantial issue and further review on de novo.”
The commission also raised concerns about whether the new seawalls comply with Carlsbad’s Local Coastal Program (LCP), which restricts shoreline protective devices to cases necessary to protect existing structures, coastal-dependent uses or public beaches in danger of erosion.
According to the appeal, filed by Commissioner Caryl Hart and Commissioner Justin Cummings, the project does not meet these criteria and lacks a sufficient alternatives analysis required under the LCP.
“The alternatives considered did not include repairs or stabilization measures on the staircase itself, or redesigning the staircase without constructing new shoreline protection or other lesser measures,” the staff member said. “So staff believes there’s still insufficient evidence that the approved project is the least environmentally damaging alternative.”
The appeal also challenges the mandatory mitigation measures, arguing it fails to address the long-term impact on shoreline sand supply and public access. The city’s approval required placing 85.1 cubic yards of sand on a nearby beach or paying a sand mitigation fee of approximately $5,106.
However, commission staff noted the mitigation plan only accounts for 20 years of impact, despite the project’s estimated 75-year lifespan.
Another central point of contention is the existing seawall north of the staircase, which was built under an emergency permit in 2009 but remains unpermitted. The appeal argues the new seawalls would effectively reinforce and expand this structure, raising additional questions about compliance with coastal policies.
“The new sea walls would tie into, and be dependent on, an unpermitted sea wall that’s located immediately up close to the staircase,” a staff member said.
The project has drawn support and opposition from community members and advocacy groups.
In a letter to the commission, Surfrider Foundation argued that the project relies too heavily on coastal armoring which could exacerbate erosion and limit public beach access. The group also criticized the lack of consideration for alternative designs, citing other coastal staircases in Carlsbad and Encinitas that do not rely on seawalls.
“Such an alternative analysis did not occur,” wrote Mitch Silverstein, Surfrider’s policy coordinator for San Diego County. “This oversight, along with an incorrect interpretation of when coastal armoring is allowable per Carlsbad’s LCP, has led to a locally-approved project that relies excessively on armoring and artificial bluff infill.”
Residents, including frequent Terramar beachgoers and surfers, submitted written comments raising concerns about the impact on wave conditions and long-term sand loss.
Others, however, have expressed support for immediate repairs, pointing to safety risks posed by the deteriorating structure. The Carlsbad Planning Commission unanimously approved the project in December, with project engineer Walt Crampton warning that the stairway could collapse without repairs.
The Coastal Commission’s determination that the appeal raises a substantial issue means that the project will now undergo a full de novo hearing, during which commissioners will decide whether to approve, modify or reject the proposed repairs.
“It’s just a matter of time before the stairway collapses,” Crampton said at the December hearing. “These treads are dangerous … and it’s just a matter of time before many people get hurt.”
