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Planning commission keeps draft geological hazards report under review after debate over 2055 railroad assumption
Summary
Planning staff presented a draft geological hazards report prepared under a Coastal Commission grant; commissioners and a resident expert urged keeping the report an administrative draft and sharpening language on erosion formulas, railroad assumptions and site-specific analysis before any policy adoption.
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Planning staff on Wednesday walked the San Clemente Planning Commission through a draft Geological Hazards Report written as part of the city's Local Coastal Program (LCP) update, and commissioners signaled support for keeping the document an administrative draft while staff continues negotiations with the California Coastal Commission.
Christopher Wright, the staff presenter, said the 79-page draft is a grant deliverable meant to guide homeowners, developers and geotechnical consultants preparing site-specific studies for coastal bluff or canyon development. "This is not meant to be a static document," Wright said, adding that the draft relies on "the best available science" and will be revisited if new data appear.
The draft includes a new formula-based approach to establish baseline erosion rates for review of coastal bluff projects and cites a planning horizon tied to 2055 for the railroad referenced in an OCTA strategic plan. Wright described the approach as an effort to reach a compromise with the Coastal Commission and to reduce repeated, project-by-project disagreements about erosion assumptions: "What we're trying to go for is making it easier for someone by being able to assume some baseline rate of erosion," he said.
Resident consultant Mark Maguire urged caution. He praised staff for the draft and recommended it remain an "administrative draft" rather than a final report that would be routinely cited in permit findings. Maguire argued the draft's formula and the use of a 2055 railroad-relocation assumption risk turning tentative negotiating positions into fixed policy: "I would ask that it stay a draft, administrative draft report for as long as it needs to until the city's comfortable saying, 'Look, we're ready to finalize this,'" he said.
Maguire and several commissioners questioned whether the draft overstates the likelihood of wave attack at the bluff toe by 2055, noting that site failures in San Clemente are more commonly driven by landward factors such as irrigation, drainage and soil slippage than by immediate shoreline wave attack. Maguire also pointed to recent approvals and case examples — including a house approved in April 2025 sited 34 feet from the bluff edge — to show that one-size-fits-all minimum erosion assumptions could push required setbacks significantly farther inland on some sites.
Commissioners pressed staff on several technical and policy points: how consultant NGIO coordinated with the Coastal Commission, which parts of the draft are negotiated to date, how the draft treats different geomorphic conditions (vertical cliff faces versus gentle slopes), and whether the setback language on page 27 would operate as a minimum floor or allow site-specific geotechnical evidence to justify smaller setbacks.
Wright said the city and consultant have met several times with Coastal Commission staff and that progress has been made on some issues, including a negotiated method for addressing the railroad question by tying assumptions to a 2055 horizon with a commitment to revisit the policy in 15 years. He emphasized that the draft does not itself change policy and that site-specific geotechnical reports would still be required for any project.
Commissioners and Mr. Maguire recommended clearer draft wording so the document cannot be read as a fixed codified policy and suggested adding more explicit guidance on when the formula is a minimum, when site-specific studies may establish different rates, and how renovations or repairs to existing structures would be treated. Several commissioners also requested that staff provide more granular guidance on differences among bluff types and on examples of projects that have performed well under past reviews.
No formal action was taken. Commissioners asked staff for periodic check-ins with the commission as the LCP negotiations continue and for clearer implementation language in later drafts. Wright said the grant-funded schedule anticipates a public-review draft later this year and a goal of completing the LCP process by the end of 2027, subject to Coastal Commission certification and further revisions.
What happens next: staff will continue meetings with the Coastal Commission, refine the draft (including clarifying setback and formula language), and provide interim updates to the planning commission. Commissioners stressed that if the city cannot reach an acceptable set of terms with Coastal staff, the city can decline to adopt a certified LCP and continue with existing processes for project review.
Authorities referenced in the discussion included the California Coastal Act and the Local Coastal Program framework, OCTA's strategic plan (cited for the 2055 horizon), and the city's municipal code provisions governing bluff setbacks and Mills Act contracts (as part of parallel historic-property conversation).

