STATE OF CALIFORNIA-NATURAL RESOURCES AGENCY

EDMUND G. BROWN JR., GOVERNOR

CALIFORNIA COASTAL COMMISSION

CENTRAL COAST DISTRICT OFFICE
725 FRONT STREET, SUITE 300
SANTA CRUZ, CA 95060
PHONE: (83 I) 427-4863
FAX: (83 I) 427-4877
WEB: WWW.COASTAL.CA.GOV

June 29, 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:

We understand that the City Council will be holding a public hearing on the proposed Beach Fire
Management Pilot Program (Program) on June 30, 2016. As we have previously indicated, we
are very interested in ensuring that the Program appropriately addresses issues discussed when
the Coastal Commission reviewed the City's proposal in December 2015, and we have
previously provided you our recommendations in that respect (see our correspondence dated
December 30, 2015, May 9, 2016, and June 6, 2016). We have reviewed the currently proposed
Program, and are supportive of many of its elements. At the same time, we believe that
additional Program elements, including more clearly defining some of the proposed elements, are
critical to ensuring that the Program can be found both LCP and Coastal Act consistent. We
strongly recommend that the Program be modified as recommended in this letter. If it is, we
believe that it can be found LCP and Coastal Act consistent and that, barring unforeseen changes
or additional information/understanding, we would recommend that the Coastal Commission not
take jurisdiction over such a Program should the City's approval be appealed to the Coastal
Commission. Towards this end, please accept these comments for consideration at the City's
June 30, 2016 Council meeting.
As stated in our previous letters dated May 9, 2016 and June 6, 2016, we strongly recommend
that the Program include provisions for some wood-based fires, as have historically been the
norm in Cannel. We agree that propane-fueled fires can appropriately be added to that mix and
their uses tested and evaluated as a means to expand potential options, but they should not be the
only option. Our recommendation is that there be a minimum of 12 wood fire rings installed on
the beach between 8111 Avenue and Mmiin Way during periods when the beach and shoreline
conditions allow for it. More units may be considered during the pilot phase (see also below)
should the nun1ber of fire rings fall short ofthe demand for said units, and the Progrmn's
maintenm1ce a11d monitoring elements cm1 reasonably address any potential impacts of such
units.

Mayor Steve Dallas and City Council

Carmel Beach Fire Management Program
Jnne 29, 2016
Page2

As noted above, we support the City's consideration of expanding the Program. Previous reasons
for limiting the Program area to south of 1oth Avenue will be addressed via installation of fire
rings and associated maintenance, and the additional space afforded by an expanded Program
area will serve to increase separation between fire rings to help aid in the dispersal of smoke and
other potential fire-related impacts (e.g., noise, etc.). As noted in our June 6, 2016letter,
expanding the Program area to gth Avenue and allowing 12 fire rings would provide almost 200
feet of linear beach area between each fire ring device.
We also recommend that the City adopt an LCP-consistent minimum 25-foot setback from the
bluff. As we understand it, the purpose of the Program is to allow the City flexibility in
implementing the Program, including adapting to changing shoreline conditions that may require
that the fire devices be relocated closer to the bluff during winter months. During the winter
when the beach is narrower, the fire rings will need to be removed from the beach and/or
relocated closer to the bluff to prevent potential inundation during high tides and wave-driven
up-rush and to allow for continued active use of the beach. The current LCP policy requires only
a minimum 25-foot setback, which gives the City the flexibility to site the fire rings in locations
that protect health and safety while allowing for this important recreational use. When the beach
is at its widest, the fire rings can be placed farther away from the bluff while still allowing plenty
of area for more active use of the beach.
With regard to hours of use, the LCP requires that beach fires be allowed for cooking and
warmth between the hours of7am and 10pm daily. However, we understand that the City is
considering pursuing a reduction in the hours of use (from 4pm to lOpm) in order to address
potential impacts from beach fires and to allow beach users an opportunity to enjoy the beach
and shoreline path during a larger portion of the day when fires are not present. We are sensitive
to the City's concern, and, though not LCP consistent, we agree that it makes sense to try a
variety of options to address identified concerns. Following the pilot phase, we would expect that
Program parameters would gel, and we would expect that an LCP amendment to codify
established Program elements could then follow (see also below). However, we believe that the
reduction from the LCP-identified 15 hours of potential fires down to six hours is too limiting.
We recommend that a more appropriate balance is to allow beach fires to start at 2pm as part of
the pilot phase (thus reducing the LCP-identified timeframe by about half).
On the issue of propane devices, and as indicated above, we support the City's intent to introduce
propane-fueled devices on the beach for cooking and warmth. This option provides a different
means of providing for public recreational activity, and we are interested in seeing how this
option functions on Carmel Beach. We understand that the City is no longer pursuing providing
such devices for free (i.e., funded by the City and provided to users for free, as was indicated to
our Commission), and are interested in seeing how the public adapts to this option. As with the
timing, the LCP will need to be appropriately amended to allow propane-fueled devices once the
Program parameters are better set after the pilot phase. In the same vein, we encourage the City
to seek opportunities to retain charcoal-fueled barbeques, or similar, for cooking. These are
specifically authorized under the LCP and have historically been a popular component of the
City's Beach Fire Management Program.

Mayor Steve Dallas and City Council

Carmel Beach Fire Management Program
June 29, 2016
Page3

The Program must also contain a robust maintenance and monitoring component, including one
that allows for adaptation over time. The issue of smoke from beach fires and charcoal debris in
the sand are central to the development of the City's Program in.the first place, and itwill be
critical to have both bona fide data to support Program elements going forward, as well as robust
maintenance to keep the beach clean. With regard to air quality monitoring, we envision the
Program containing a requirement to monitor air quality and the effects of smoke on beachgoers,
pathway users, and nearby residents. The monitoring should provide broad coverage of the
overall beach area, including providing monitoring associated with non-fire ring areas (as a
control) as well as the fire-ring areas to allow comparisons to be accurately made between data
collected from both areas. Monitoring should also include data on PM2.5 as well as
corresponding meteorological data (including wind speeds and directions) associated with each
monitoring station, and provide as clear a representation as possible of the amount ofPM2.5
correlated to beach fires as opposed to other sources. We recommend that the City use all of the
components that we recommended in our December 2015 staff report on this topic to form the
basis for such a Pro gram.
In addition, we view the pilot Program as an adaptive management tool that can provide the City
the flexibility to shape the beach fire Program as needed to address coastal resource issues and
public access needs over time. It will be critical that adaptation measures are clearly built into the
Program, and again we recommend that you start with the adaptive management components that
we recommended in our December 2015 staff report on this topic to form the basis for such a
program. We believe that an appropriate pilot phase would run three years, with adaptation
possible over the course of all three years as needed, and with a regular annual reporting and
modification element that includes City and Commission staff consultation and agreement on
potential changes. Following the three-year pilot period, we would expect that Program
parameters would be better settled, and a longer term CDP, as well as an LCP amendment to
codify changes, could be pursued at that time.
Finally, we note again that the City's current weekend beach fire prohibition is not pem1itted and
cannot be enforced under the LCP. We recommend that you take steps to eliminate this
prohibition, including in light of the pilot Progran1 to be installed, as part of any action on the
City's Beach Fire Management Program.
Once again, thank you very much for the opportunity to work with your staff to resolve issues
associated with the City's Beach Fire Management Program. As indicated above, we strongly
recommend that the Program be modified as recommended in tllis letter. If it is, we believe that it
can be fmmd LCP and Coastal Act consistent and that, barring unforeseen changes or additional
information/understanding, we would recommend that the Coastal Commission not take
jurisdiction over such a Program should the City's approval of the Program be appealed to the
Coastal Commission.
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.

Mayor Steve Dallas and City Council

Carmel Beach Fire Management Program
June 29, 2016
Page4

Sincerely,

/h~Wd~

DanCarl
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