Coastal Commission to Hear City’s LCP Implementation Plan

Written by Neil Farrell

Neil has been a journalist covering the Estero Bay Area for over 27 years. He’s won numerous journalism awards in several different categories over his career.

March 14, 2024

Morro Bay’s updated Local Coastal Program (LCP) is slated to go for a possible final action to the Coastal Commission at its March meetings, set for a hearing sometime on Friday, March 15. The LCP action is to approve the new Implementation Plan and “make minor amendments to the Land Use Map,” reads a notice of the hearing, which is being held in Sacramento.

This might not be the final action by the Commission, as it’s possible they could extend it. “If the Commission does not take a final action, possible action to extend the deadline for final Commission action on the amendment by up to a year.

According to the Commission report, the LCP’s so-called “Implementation Plan” or IP, “is the second part of a complete LCP update following the Commission’s certification of the updated LUP in August 2021. The existing IP was certified along with the prior LUP in 1984 with several amendments since then.”

The LCP and General Plan underwent a lengthy updating that took the better part of 10 years for the City to complete. Such plans are supposed to be updated every 5 years. Morro Bay’s tardy update work is not unusual as most California cities have been behind schedule on plan updates. However, whenever a project comes forward that doesn’t fit the plan it can be amended as part of its Coastal Development Permit process. And such amendments are limited to only a couple of times a year.

“The IP is well overdue for a refresh,” the Commission’s report said, “both to ensure consistency with the 2021 certified LUP and to reflect more modern standards associated with contemporary coastal land use planning issues. Commission staff and City staff have been working cooperatively throughout the LCP update process, which was partially funded via three grants from the Coastal Commission’s LCP Local Government Assistance Grant Program and has been the subject of an extensive and inclusive community planning process, which commenced in earnest in 2015.”

The City may have “commenced in earnest” to update the plans in 2015, but it started talking about doing the work back in the late 1990s, when former City Manager Dave Howell first brought up the prospect of updating the City’s main planning documents.

Back then, Howell had tossed about the figure of $1 million, as the likely cost to do the update, and in the end his predictions were pretty accurate.

The LCP is the guiding document for any development within the Coastal Zone, which in Morro Bay includes the majority of the town. 

“Almost the entire roughly 6-square-mile City is located within the Coastal Zone, with only about 14 acres in the northern hill portion of the City outside of the Coastal Zone,” the report said.

Perhaps the term “update” isn’t strong enough, as the Commission report said, “the proposed IP is a complete overhaul of the existing IP to carry out the provisions of the updated LUP.” (The Land Use Plan or LUP is part of the General Plan, and applies to the entire town, and the LCP deals specifically with the Coastal Zone and includes requirements and policies of the Coastal Act. The LUP includes the Zoning Ordinance and accompanying maps of the various zoning areas in town. In the end all these documents should mesh with each other.)

Conservation is the key word with Morro Bay’s LUP. “The LUP’s overarching intent is to form a greenbelt surrounding the urban core by protecting the City’s undeveloped hillsides and mostly unarmored beaches and bluffs, while also correspondingly providing for mixed use infill development and multi-modal transportation options within the already urbanized City core, including in downtown and along the Embarcadero.”

The new LUP tries to address some of the sticky issues local residents have faced over the years — namely people trying to develop in areas the community wants to protect. 

“The LUP includes a quite specific and directive set of policies aimed at protecting sensitive coastal resources, including in terms of public coastal access, coastal hazards, sensitive habitats, and public views.” 

And, “These policies,” the report added, “provide the ultimate performance standard [e.g., ensure new development does not include any form of armoring, prohibit residential development within wetlands and ESHA (environmentally sensitive habitat areas), protect public blue water coastal views, etc.], and the proposed IP carries these provisions out through required studies, technical reports, and other implementation techniques.”

As an example of the LCP/IP in action, the Commission report notes that the plan protects wetlands and other sensitive habitats, “by limiting the types of development in such areas and through requisite buffers. The IP maintains these overarching requirements and carries them out by specifying the procedural protocols to do so, including through the preparation of biological reports from qualified professionals that, among other things, identify specific siting and design techniques, specific buffer widths, and any restoration/mitigation components.”

Indeed, the list of studies required for development in Morro Bay’s LCP territory include things like archaeological studies and surveys (potentially including Native American monitoring); having sea otter watchers during marine construction projects; eel grass surveys; soil samplings; and environmental reviews — from simple checklists to full blown EIR reports.

Among the plans’ issues that have been most costly are coastal hazards, the avoidance of which moved Morro Bay’s new sewer treatment plant from the Atascadero Road site to the eventual location above South Bay Boulevard at a cost of an additional $120 million.

“With respect to coastal hazards,” the Commission report said, “the LUP requires development to be safe from coastal hazards risk, only allows for armoring to protect existing structures in danger from erosion, requires a series of coastal resource mitigation requirements for permissible armoring, and requires armoring to be removed should a structure be redeveloped.”

By “armoring,” the Commission is referring to seawalls, rock revetments and similar techniques, used to hold back the sea and prevent erosion.

“The proposed IP maintains and carries forward all such LUP provisions and provides the necessary details to implement the LUP policies by requiring certain technical studies that evaluate alternatives and mitigation measures, including identifying the potential impacts of erosion, flooding, tidal scour, and the sea level rise over the life of the development.”

The implementation plan is the key to unlocking the mysteries of Morro Bay’s planning documents and is a road map through the red tape inherent in any Coastal Zone town.

“In sum, the proposed IP contains a plethora of standards to guide development while ensuring the highest protection of coastal resources.”

If readers want to follow the Coastal Commission’s discussions on Morro Bay’s LCP/IP they can tune in the Commission’s meeting via its website, see: The City’s Implementation Plan runs for 223 pages and the Commission staff’s recommendation is to approve it.

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