Chapter 1
Purpose of and Need for Action

1.1   Introduction
1.2   Projects
1.3   Purpose and Need
  1.3.1   Physical Integrity of the Bluffs
  1.3.2   Geologic Background
1.4   Project Area
1.5   Project History
1.6   Use of a Joint NEPA/CEQA Document
1.7   Public Involvement Process

1.1  Introduction

This environmental impact statement/environmental impact report (EIS/EIR) has been prepared in accordance with the National Environmental Policy Act of 1969 (NEPA), 42 United States Code (USC) §§ 4321-4347 (1994); the Council on Environmental Quality (CEQ ) regulations implementing NEPA, 40 Code of Federal Regulations (CFR) § 1500-1508; the US Army Corps of Engineers (Corps) NEPA Guidelines (33 CFR Part 230); the California Environmental Quality Act (CEQA) of 1970 as amended, California Public Resources Code (Cal. Pub. Res. Code) §§ 21000-21178.1, and implementing guidelines, California Code of Regulations, Title 14, §§ 15000-15387 (1999).

The County of Santa Cruz Redevelopment Agency is the sponsor of this project, and the Santa Cruz County Planning Department is the CEQA lead agency. In order for the project to be approved and funded, the Corps must affirm that the project is permitted under the Clean Water Act and the Rivers and Harbors Act; this requirement makes the Corps the NEPA lead agency for the project. This joint EIS/EIR evaluates the impacts on the environment that could result from the proposed East Cliff Drive Bluff Protection and Parkway Project. The proposed activity is located midway between the cities of Santa Cruz and Capitola in Santa Cruz County, California, which is approximately 75 miles (121 kilometers) south of San Francisco, on the north shore of Monterey Bay (Figure 1-1) .

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1.2  Projects

The proposed activity involves three separate projects that would be constructed individually of each other over approximately two to three years. Because the three projects are in close proximity to each other, the potential environmental impacts associated with each of the construction projects are addressed in this EIS/EIR.

The three construction projects analyzed in this EIS/EIR would be funded by the Santa Cruz County Redevelopment Agency and would include the following features:

Project 1 (Main Bluff Protection Structure)

Project 2 (Parkway Improvements)

Project 3 (The Hook Bluff Protection Structure)

Community residents near the proposed project area and Santa Cruz County have identified certain resources to be of particular importance; they include geological, water, biological, cultural (including paleontological sites), visual, and recreational resources. Transportation also has been identified as being particularly important. Chapter 2 provides a list of other federal, state, and local agencies that would be involved in the project approval and implementation process.

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1.3  Purpose and Need

The purpose of the proposed projects (projects 1, 2, and 3) are: to increase the longevity of the public right-of-way ; to protect the road and utilities from coastal bluff erosion; and to improve and enhance public access to the coast by constructing a parkway for pedestrians and cyclists. The public right-of-way includes the road (East Cliff Drive), parking areas, pedestrian/bicycle path, coastal access stairways, public utilities , and park areas. The potential loss of East Cliff Drive has been a concern for many years, and in the 1990s it became clear that continued failures would undermine the road and utilities and threaten public access to the coast. In 1994, the Corps completed a draft study, concluding that stabilizing and protecting the bluffs along East Cliff Drive was critically needed. A more recent threat analysis, conducted by Sanders & Associates Geostructural Engineering, Inc., in 2005, indicates that approximately 65 percent of East Cliff Drive between 33 rd and 36 th avenues is currently failing (13 percent) or may be unsafe to use within the next few years (52 percent).

The parkway project (project 2), which includes the park area, paths, restrooms, stairways, and beach and road improvements, helps to implement the California Coastal Act , Section 30001.5, which declares that one of the basic goals of the state for the coastal zone is to:

Maximize public access to and along the coast and maximize public recreational opportunities in the coastal zone consistent with sound resources conservation principles and constitutionally protected rights of private property owners” (California Coastal Commission 2001).

The parkway component of the project would also help implement the Monterey Bay Sanctuary Scenic Trail System, which is envisioned to provide a multiuse recreational and alternate transportation trail system along Monterey Bay. The parkway project would contribute to the trail by constructing a bicycle and pedestrian path and other public access amenities along East Cliff Drive, between 32 nd and 41st avenues. The vision is that, over time, such trail segments can be connected into a continuous regional trail system.

Additional benefits that have been identified through public input include the following:

The coastal bluffs around Santa Cruz have been and continue to be susceptible to continuous and periodically severe erosion; the bluffs along East Cliff Drive are no exception. There is also a threat of a sudden failure from large seismic events. While the probability of large earthquakes causing severe bluff failure in the project area is low, such events have occurred at numerous locations within the region (Plant and Griggs 1990a, 1990b, 1991; Sydnor et al. 1990). The most recent event, the 1989 Loma Prieta earthquake, caused bluff failures in areas near the project and resulted in one observed failure within the project area, near 41 st Avenue.

The susceptibility of the area's bluffs to erosion was confirmed in a Federal Emergency Management Agency (FEMA ) erosion hazard mapping study (FEMA 2001). A study of aerial photographs spanning 41 years in Santa Cruz County was used to estimate shoreline erosion rates along the Santa Cruz coast. Areas of wide sandy beaches have advanced and retreated as a function of storm frequency and nourishment. While there are some small areas where no erosion was documented over this 41-year interval, most of the erosion rate values fall into the 8 to 12 inches (20 to 30 centimeters) per year range. This erosion rate depends on the rock type and its inherent weaknesses, wave exposure, and human impacts. The bluffs along the proposed project area are very erodable, heavily urbanized, and armored with riprap and a variety of seawalls.

Figure 1-2 shows a 60-year erosion hazard line based on erosion rates determined for each individual section of coastline for the period from 1953 to 1994, projected 60 years into the future to the year 2054. A Corps report in 2003 estimated that utilities and roadway structures would begin to fail by 2011 under the current erosion rate, and provides estimates of the economic cost of such failures (Corps 2003).

More recent studies indicate that the Corps report may have been optimistic. In 2005, the County commissioned a threat assessment from Sanders and Associates Geostructural Engineering, Inc. (SAGE), to evaluate the bluff between 33 rd and 36 th avenues (SAGE 2005a). Sanders identified three categories of threat zones in the project area: (1) Active Impact , where the shoulder of East Cliff Drive has already been lost; (2) In Danger , where existing structures may be unsafe within the next few years; and (3) Potentially In Danger , where sections of East Cliff Drive are not likely to be rendered unsafe within the next few years but are still subject to erosion. SAGE's evaluation indicated that 133 linear feet (41 linear meters) of the study area fall within Threat Zone 1, 518 linear feet (158 linear meters) fall within Threat Zone 2, and 350 linear feet (107 linear meters) fall within Threat Zone 3. The areas within Threat Zone 1 are places where sections of East Cliff Drive have already collapsed (but not the three areas protected by the new soil nail walls). Based on the SAGE report, Threat Zone 1 makes up 13 percent of the project 1 area (between 33 rd and 36 th avenues); Threat Zone 2 makes up 52 percent, in danger of failure within the next two to three storm cycles; and Threat Zone 3 makes up 35 percent. Of Threat Zone 3, over half of that area consists of the three new sections of bluff stabilization.

The SAGE report emphasized that bluff failure tends to occur episodically rather than incrementally, so that average erosion rates may be unreliable in predicting short-term impacts on the bluff face. The SAGE report goes on to support earlier findings that, given the seismic instability of the general area, it is possible that potential bluff failure during an earthquake could exceed approximately 10 feet (3 meters) inland from the edge of the cliff, and that the Purisima Formation, which is undercut as far as 18 feet (5.5 meters) inland from the face of the bench, could also collapse under stress, along with the terrace deposits above it.

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1.3.1  Physical Integrity of the Bluffs

The bluffs in the project area are expected to continue retreating at average annual rates of approximately eight inches to one foot per year. In some areas, retreat of the bluff tops has already caused segments of the road to fail, requiring road or lane closures and emergency repairs. The roadway has already been reconfigured from a two-lane road to a one-way road because of past bluff failures. Based on the history of bluff erosion in this area, long-term and short-term erosion patterns, and slope stability, complete failures along certain parts of East Cliff Drive are expected to occur within the next few years (SAGE 2005a), with most of East Cliff Drive being lost in the next 50 years. The loss of East Cliff Drive would severely restrict access to the bluffs, thereby greatly reducing recreational access in the area. Such a loss would also disrupt major utility sources in the area as well as lead to the loss of the existing public right-of-way.

While the County has performed some emergency stabilization work, other portions of the bluff are not supported at all, or are supported by retaining walls that are in poor condition and beginning to fail. The Purisima Formation is expected to continue to be undercut by wave action, resulting in incremental collapse and failure of the overlying terrace deposits. However, bluff retreat occurs episodically because of sudden failure related to undercutting of the Purisima or from erosion during major storm events, rather than continuously at the same rate, and it also varies by location. Bluff failure from undercutting of the Purisima can result in a sudden collapse of blocks as much as five to 10 feet wide (3 meters), and extending as far as seven to 10 feet (2 to 3 meters) inland from the face of the bluff. Utilities, such as water mains, storm and sanitary sewer lines, and aboveground electrical lines, would eventually be undermined and would need to be relocated. Public access to the bluff top and parking in the area would also be affected by the continued bluff erosion.

Please see individual resources chapters (chapters 3 through 14) for a complete discussion of existing conditions in the project area and potential impacts related to the implementation of the various alternatives outlined in Chapter 2.

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1.3.2  Geologic Background

Until the mid-1990s, East Cliff Drive was a two-way road, but during winter storms in the 1980s and 1990s, the bluffs were eroded far enough inland to threaten the road, and they continue to recede today. In 1995, a section of East Cliff Drive near Larch Lane collapsed after a severe winter storm, closing the road to through traffic for approximately nine months. Continued erosion has caused the partial collapse of East Cliff Drive, which is in jeopardy of being lost completely. The bluffs are believed to lack sufficient bearing capacity to handle the weight of vehicles in the eastbound lane. As a result, in 1995, the Santa Cruz County Board of Supervisors designated portions of East Cliff Drive as a one-lane, one-way (eastbound) road, traffic was reduced to one direction, weight limits were imposed, and a pedestrian/bicycle path was created in the former eastbound lane. Since 1995, the bluff erosion has caused the deterioration and partial collapse of the curb and guardrail , requiring certain areas of the pedestrian/bicycle path to be fenced off for public safety (see Appendix A for photographs of the site).

Retreat of the bluffs along East Cliff Drive is due to several factors:

The combination of these processes has resulted in the current condition of the bluffs along the project area, with the annual erosion of the bluffs varying from year to year, depending on the frequency of severe storms. Thus, the bluffs recede at slightly different rates along their face, and at any one time portions of the bluffs are in different stages of failure. In addition, large storms , waves, and seismic activity can precipitate failure that otherwise might take many years to occur. Finally, human activities can either contribute to increased erosion rates or reduce the rate of erosion (such as where bluff protection structures are installed to protect a home or segment of road); these activities also can affect adjacent areas. For example, a large amount of concrete rubble and rock riprap was placed on the beach some years ago as an emergency protection measure. The rock riprap is large enough to remain in place. However, because the concrete rubble is small, it actually may increase bluff erosion. Waves easily move flat relatively lightweight slabs of concrete, which act to grind down the bluff face during times of high tides and large waves (Corps 1998; SAGE 2005a).

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1.4  Project Area

The project area includes and is adjacent to: East Cliff Drive, the Pleasure Point Park site (located on the southeast corner of the intersection of East Cliff Drive and 32 nd Avenue/Pleasure Point Drive; 32 nd Avenue becomes Pleasure Point Drive on the south side of East Cliff Drive), The Hook park site on the south side of East Cliff Drive at the south end of 41 st Avenue, and the adjacent beach areas (Figure 1-3). The project area is a coastal residential neighborhood within the Live Oak planning area of Santa Cruz County. Pleasure Point and the remainder of the Live Oak planning area are primarily urban. Most of Pleasure Point contains residential uses, but the coastal bluff and beach is a popular recreation area. The County General Plan designates the bluff and beach as “Park and Recreation” land use. It also designates East Cliff Drive from 33 rd Avenue to 41 st Avenue as a scenic roadway and the adjacent area as an important coastal scenic resource.

The surrounding neighborhood is primarily residential, with most of the homes located on the land side of East Cliff Drive, approximately 50 feet (15 meters) from the top of the coastal bluffs. Three homes on the ocean side of the East Cliff Drive are constructed directly on the coastal bluffs.

This portion of East Cliff Drive is designated as a bike path in the County's Master Bikeway Plan , and the General Plan gives priority to the coastal recreational use of this area. East Cliff Drive is a highly valued recreational resource enjoyed by pedestrians, bicyclists, and drivers. Also, both The Hook and the Pleasure Point Park are designated as coastal priority sites for their recreational use, in accordance with their General Plan designations as “Parks, Recreation and Open Space” and corresponding zoning of PR (Parks and Recreation). The properties to the south of East Cliff Drive also are zoned PR; the beach below the cliff is also a highly valued recreational resource. In addition, this stretch of East Cliff Drive is designated for signs, trail markers, and interpretive elements as part of the MBNMS Scenic Trail.

Wave conditions near the project area are excellent for surfing , and the area is one of the most intensively used surfing locations in the Monterey Bay area. Waves typically break approximately 400 to 600 feet (122 to 183 meters) offshore. The proposed project area is affected by both Northern Hemisphere and Southern Hemisphere swells. (A swell is a long wave that moves continuously without breaking.)

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1.5  Project History

The East Cliff Drive Bluff Protection Project was initially designed as a project co-funded by Santa Cruz County and the Corps, with the County and the Corps holding discrete authority over separate elements of the project. Under this structure, the project was announced to the public and a draft EIS/EIR was released to the public on March 21, 2003. A public meeting was held on April 30, 2003, public comments were received, and the County and the Corps revised the EIS/EIR and distributed the final EIS/EIR in October 2003.

Project construction depends upon the approval of the California Coastal Commission (Commission), which has authority granted under the Coastal Zone Management Act (CZMA) to manage development within the coastal corridor. Before a project can move forward, the Commission must find it consistent with the California Coastal Management Program (CCMP). Commission staff participated in regulatory review of the draft EIS/EIR and provided extensive comments, which were replied to in the final EIS/EIR. However the Commission was not satisfied with the changes made to the project and, at its hearing on November 7, 2003, found the project inconsistent with the CCMP.

At this stage, the County Redevelopment Agency is the sole project sponsor; however, the Corps remains involved as a regulatory agency with jurisdiction over the project, similar to the US Fish and Wildlife Service (USFWS) and Monterey Bay National Marine Sanctuary (MBNMS). It is this federal regulatory involvement that requires NEPA documentation for the project.

In the period since January 2004, the bluff along East Cliff Drive has continued to fail. As a result, the County undertook emergency stabilization efforts in order to protect the right-of-way, public utilities, and public access to the water. These stabilization efforts consisted of three sections of soil nail wall, totaling 290 linear feet (88 linear meters), between 32 nd and 35 th avenues. The work was conducted over a period of three months during July, August and September of 2004, using the same techniques and best management practices (BMPs) described in the project description in Section 2. The soil nail walls built as part of the emergency stabilization effort differ from the proposed projects in that only the top section of the wall was constructed, protecting only the terrace deposits above the Purisima Formation, and not the Purisima itself.

This Revised Draft EIS/EIR is designed to take into account the changes in the project area since the final EIS/EIR was distributed, and address and resolve the concerns of the public and the Commission about the original project.

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1.6  Use of a Joint NEPA/CEQA Document

This joint EIS/EIR fulfills the requirements of NEPA and CEQA to assess the potential environmental impacts of the proposed project. Both NEPA and CEQA encourage the use of a joint EIS/EIR. NEPA requires federal agencies to cooperate with state and local agencies to the fullest extent possible to reduce duplication among NEPA, state, and local requirements, including joint environmental impact statements (40 CFR § 1506.2). CEQA guidelines allow state and local agencies to work with a federal agency to prepare a joint document to meet the requirements of both CEQA and NEPA (CEQA Guidelines, § 15170).

Requirements of an EIS and EIR are similar and generally parallel each other, but they do differ. For example, NEPA requires a substantially similar level of detail in the analysis for each project alternative, while CEQA allows alternatives to the proposed project to be analyzed in less detail. CEQA requires identifying an environmentally superior alternative , and NEPA requires identifying an environmentally preferable alternative . NEPA also requires a discussion of the relationship between short-term uses of the human environment and the maintenance and enhancement of long-term productivity. All NEPA and CEQA requirements are addressed in this joint document. Where these requirements differ, the more stringent requirement is followed.

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1.7  Public Involvement Process

Public involvement is a key part of the EIS/EIR process. Since 1995, the County of Santa Cruz has met with the public on many occasions to discuss the issues relating to the cliff erosion and failure of portions of East Cliff Drive. In addition to the community meetings, the County has issued “East Cliff Drive Update” newsletters (Santa Cruz County 1995a, 1995b, 1995c, 1996, 1997) to keep the public informed, to announce community meetings, and to receive input from the public on the long-range planning for this area.

As part of this EIS/EIR process, methods to involve the public have included or will include the following:

Public Review

The draft EIS/EIR was released on March 21, 2003, and the public review period ended on May 12, 2003. Comments received during the public review period were addressed in the final EIS/EIR, distributed in October 2003.

Draft EIS/EIR

As required under NEPA, the Corps' notice of availability for the draft EIS/EIR was published in the Federal Register by EPA on March 28, 2003. The NOA was also published in the local press and public notices were mailed to those on the mailing list, and the County of Santa Cruz filed a Notice of Completion (NOC) (required under CEQA) with the State Office of Planning and Research and the County Clerk. The public was invited to review and comment on the draft EIS/EIR during the public comment period from March 21 to May 12, 2003. The draft EIS/EIR was available for review on the County Planning Department website, as well as in the County Planning Department office and local library branches. During the public review period, written comment letters were received from five agencies, eight environmental organizations, and fifty-seven individuals. The County held a public forum to discuss the project on April 7, 2003, and the Corps held a public meeting to discuss the project on April 30, 2003. Twenty-two individuals presented comments at the public meeting.

Copies of the Corps and the County's notices of availability for the draft EIS/EIR are reproduced in Appendix B, Public Involvement, along with the transcript of the public meeting hosted by the Corps on April 30, 2003.

Final EIS/EIR

The 2003 final EIS/EIR incorporated and responded to comments on the draft EIS/EIR and was published and made available for review. An NOA of the final EIS/EIR was published in the Federal Register and in the local press, and a public notice was mailed to all individuals, agencies, and organizations who commented on the draft EIS/EIR or who had requested to be notified.

Ordinarily, there would a 30-day no action period under NEPA following distribution of the final EIS/EIR, during which the public could comment. At the end of this period, the federal agency would sign a record of decision (ROD), detailing its decisions about the project, and the County would present the final EIS/EIR to first the County Planning Commission and then the County Board of Supervisors for certification. However, because the CCC failed to find the project consistent with the LCP, no ROD was signed and the final EIS/EIR was not certified.

Revised Draft EIS/EIR

This Draft EIS/EIR will be noticed and distributed in compliance with CEQA requirements. Because the County Redevelopment Agency is now the sole project sponsor, the Corps' authorization for the bluff protection structure is limited to approving it under Nationwide Permit #13. NEPA requirements have already been satisfied through the Corps' approval of the Nationwide Permit. Additionally, the County will hold a public open house and receive public and agency comments on the project and the revised draft EIS/EIR. Written comments on the revised draft will be responded to in the Revised Final EIS/EIR.

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