STATE OF CALIFORNIANATURAL RESOURCES AGENCY

EDMUND G. BROWN JR., G OVERNOR

CALIFORNIA COASTAL COMMISSION

CENTRAL COAST DISTRICT OFFICE
725 FRONT STREET, SUITE 300
SANTA CRUZ, CA 95060
PHONE: (831) 427-4863
FAX: (831) 427-4877
WEB: WWW.COASTAL.CA.GOV

June 6, 2016
Mayor Steve Dallas and City Council Members
City of Carmel-by-the-Sea
P.O. Drawer G
Carmel by the Sea, CA 93921
Subject: Carmel Beach Fire Management Program
Dear Mayor Dallas and Council Members:
Please accept these brief comments in advance of this evenings Council meeting regarding the
Citys proposed Beach Fire Management Pilot Program (Program). Unfortunately, we did not
receive a copy of the Program or the Citys staff report until just this morning, which has not
given us adequate time to work with your staff to refine Program details prior to the Councils
consideration of a coastal development permit (CDP) for it. In its current form, the Program is
not clearly defined, and we believe it raises LCP and Coastal Act consistency questions. Given
the late arriving materials and the heightened interest in this Program, we strongly
recommend that the Council hold a public hearing to allow public comment and to provide
for Council direction to its staff regarding the proposed Program, but ask that the Council
not take an action on a CDP tonight. Although we appreciate the sense of urgency given we
are in June now, we believe that it is more important to get it right than to get it done, and that it
would be much more appropriate for City staff to more clearly define a Program that can be put
out for review and public comment for more than one day. It is our sincere hope that we would
work together to develop Program elements that address potential issues while still providing for
traditional beach fire opportunities at Carmel Beach.
Should the Council decide to move forward and take a CDP action at this time, we offer the
following comments. First, we take exception to the program allowing for only propane-fueled
fires for the first year. As stated in our letter dated May 9, 2016, a pilot program must necessarily
contain a mix of options, including wood-based fires as have historically been the norm in
Carmel. Yes, we agree that propane-fueled fires might appropriately be tested as a potential
option, but they should not be the only option. Please see the May 9, 2016 letter.
Second, we support the Citys consideration of expanding the Program area as a way to provide
increased separation between fire devices and to aid in the dispersal of smoke and other potential
fire-related impacts (e.g., noise, etc.). If fires are contained, then that allows for the Program
boundaries to be expanded, given the reason for the limited area currently was due to fires not
being contained historically. For example, expanding the Program area to Eighth Avenue and
allowing 12 - 15 fire rings would provide almost 200 feet between each fire ring device, which
should be adequate to address the coastal resource impacts cited above.

Mayor Steve Dallas and City Council

Carmel Beach Fire Management Program
June 6, 2016
Page 2

Third, the 100-foot setback from the bluffs appears to inappropriately push fire rings into the
middle of the more active use areas of the beach and closer to potential inundation zones during
high tides and wave driven up-rush. Further there is no data to suggest that the additional setback
from the bluff will reduce impacts from fire-related activities. Indeed, the current LCP policy
requires only a minimum 25-foot setback, which gives the City the flexibility to site the fire
devices where it best makes sense to protect health and safety, as well as recreational use. In
addition, if the area within which fires are allowed is expanded (e.g., to the Del Mar parking lot
area), potential smoke related issues can be better dispersed. Again see the May 9, 2016 letter.
Fourth, we also believe the pilot program should include provisions for the allowance of
charcoal-fueled barbeques, or similar, for cooking. These are specifically authorized under the
LCP and are a necessary component of the Citys beach fire management program.
Once again, we very much welcome the opportunity to work with your staff to resolve the issues
identified above, and would appreciate your direction to them to this effect as soon as possible.
The busy summer recreational season is upon us, and we would very much like to make some
progress quickly in this respect, including so that we can stand together in agreement when the
City takes the requisite CDP action. For now, though, this matter is not ripe. We strongly
recommend that you not take action tonight, and you allow adequate time for consideration and
thoughtful discussion regarding a clearly defined program. If you do take action, we would hope
that you would consider these comments as well as the recommendations in our May 9, 2016
letter.
Please do not hesitate to contact me at our Santa Cruz office if I or my staff can help in any way
to move such a beach fire management program to fruition. Thank you for your consideration.
Sincerely,

Dan Carl
Central Coast District Director
California Coastal Commission

cc: Chip Rerig, City of Carmel-by-the-Sea City Manager

Marc Weiner, City of Carmel-by-the-Sea Acting Planning Director
Rob Mullane, City of Carmel-by-the-Sea Public Works Director