From: Elizabeth Bettenhausen, Ph.D
To: the Board of Directors of the Cambria Community Services District
Re: Resolution 01-2010 on the Agenda of the Special Meeting, January 5, 2010
Download for printing here.
The Resolution before you today claims that you will have considered, “all evidence, including public testimony,” before finding “that it is in the best interests of the community to proceed with” the geotechnical and hydrogeologic study at Santa Rosa Creek Beach. I submit my comments to you in writing, request their inclusion in the public record, and hope you will now take the time to listen to them before you make your decision.
The claim is made that this “information gathering” study will not “result in a serious or major disturbance to an environmental resource.” (CEQA, Title 14, 15306. Information Collection). I raise several questions in this regard.
Question 1. How long will this study take? The CCSD District Engineer in the Agenda Discussion today writes, “A maximum of three monitoring wells (6-8 inches in diameter each) will be installed for periodic groundwater sampling and monitoring over a two-year maximum time period.”
However, the “Coastal Consistency Determination” by the Army Corps of Engineers states, “Each monitoring well may need to remain for up to one year after installation” (3.1.7).
Which claim is accurate?
If a well of 100 ft. is left in the beach and activated over two years, instead of one year, will this be more likely to result in a serious or major disturbance to an environmental resource? By what studies and criteria is this judgment made?
Indeed, if at the end of the one or two years it is discovered that removal of the whole test well is not possible, what will be the effects of this permanent disturbance of the beach and its environs? “If the complete removal of test wells is impracticable, the monitoring wells will be removed by drilling out to the maximum depth practicable. Well bores will be filled with bentonite-cement slurry from the bottom of the well bore to 5 feet below the lowest beach scour elevation, and native sand used to fill the remainder of the well. The surface will be sealed….”(3.1.) With what studies and criteria has this judgment about effects on San Simeon State Park Beach been made?
Question 2 If initially 7-11 coring sample wells are drilled, and then three test wells are installed, along with six monitoring wells, along with pumps and generators, and this testing equipment stays in the beach for one to two years, how is the conclusion reached that no development is being placed on and in the beach? Invisible on site (unless storms or earthquakes change the conditions) does not mean unreal.
Question 3 The Coastal Consistency Determination states, “The objective of this initial investigation is to help define the paleochannel extension offshore from the Santa Rosa Creek beach to characterize the subsurface materials and hydrology.” (3.0.)
However, 3.1 states, “The site investigation will occur onshore along the beach, entirely above (landward of) the mean higher high water line.”
If “[t]he objective of this initial investigation is to help define the paleochannel extension offshore from the Santa Rosa Creek beach,” how does drilling only above “the mean higher high water line” accomplish this? (emphasis added). What criteria will be used to judge the information gathered in this respect?
Question 4 The Coastal Consistency Determination states, “The proposed exploration locations may be subject to minor relocation (i.e., within a 50-foot radius) during the course of the field investigation based on geologic conditions or site conditions. These conditions include the depth to bedrock or nature of the sediments, tide, storm events, wave run-up, then-current beach topography, or presence of any other impediment.”
How and why was the decision made to construe “the depth to bedrock or nature of the sediments, tide, storm events, wave run-up, then-current beach topography” as “impediments” to the planned research rather than as constitutive elements of the environment? How are these so-called impediments factored into the computer modeling mentioned in the objectives? The bedrock, sediments, tides, storm events, wave run-up, beach topography and much more constitute the beach environment. To determine whether a study poses “a serious or major disturbance to an environmental resource” by first defining these elements as impediments violates scientific methodology.
Question 5 Neither the CCSD agenda discussion nor the ACE Coastal Consistency Determination consider the possibility that the beach itself under its surface merits any environmental concern. Out of sight, out of mind characterizes this analysis. (Of course, some core sampling and test wells will be minded.)
They apparently do not consider the beach as a whole an environmental resource. In this they are fearfully behind the times. I cite only two studies here. Sylvia Earle, oceanographer, has served as Chief Scientist of the National Oceanographic and Atmospheric Administration, been named a Living Legend by the Library of Congress, and is the 2009 recipient of the TED prize, and recipient of more than 100 national and international honors for her work over the past half century.
In The World Is Blue: How Our Fate and the Ocean’s Are One, Dr. Earle writes, “The bottom line answer to the question about why biodiversity matters is fairly simple: The rest of the living world can get along without us, but we can’t get along without them” (National Geographic, 2009; p.129).
In his book, Sand: The Never-Ending Story, the geologist, Michael Welland, writes about biodiversity and the beach, “Inevitably, the community of organisms growing on or living in sand has its own name: psammon.” The members of the community are “wondrous. Most of us don’t know they exist, but we should be grateful for them. Without meiofauna, the sands of our beaches and lakeshores would be stinking, toxic places, with organic debris rotting unconsumed and dangerous bacteria rampant. The microscopic creatures of the meiofauna feed off this debris: they keep our beaches clean.” (University of California Press, 2009; p. 63).
While J. Oakden’s work is quoted in 4.3 on marine environment, the only comment made about the impact of 10 wells on visible and microscopic life on and in the sand is this sentence: “Impacts to native wildlife and vegetation would be less than significant.” No supporting evidence is given, no relevant studies cited, no argument made. The assertion sits there bare as can be. Those designing the study did not take into account the immense complexity of life within the sand and human dependence on it.
Neither do they consider the possibility that the drilling of 7 to 11 wells across the beach might disrupt the natural behavior of the beach as a whole, i.e., in relation to what surrounds and engages it on all sides.
Question 6
The Coastal Consistency Determination presupposes the autonomous separation of the study area from each and every element around it. Santa Rose Creek and the beach apparently have nothing to do with each other. “The proposed study would have no effect on the creek and, therefore, would have no effect on these species” (4.3). However, no information is given to show what is meant by “Preliminary hydraulic modeling” that will be used to “confirm that the lagoon will be outside the cone of influence of the test well.” Is this hydraulic modeling based on actual data or only on mathematical models?
The assumption seems to be that the beach and creek can be mathematically and therefore actually separated from each other. This is epistemologically and environmentally dangerous.
The same kind of assumption is made about the Pacific Ocean and San Simeon State Beach. I quote only two of their examples. “Federal threatened southern sea otters may occur in the ocean offshore of the study site but would not be present on the study site itself. Noise and activities on the upper beach would not disturb sea otters offshore. Impacts of the proposed study to sea otters would be insignificant” (4.3). How do they know this? In addition, they write, “Study activities would occur above the mean high tide line and would not impact Essential Fish Habitat” (4.4). Making such assertions without giving any data to support them makes their claim for a Categorical Exclusion cursory.
Conclusion
Science and engineering seem to have little to do with each other in this proposed study. I cannot summarize the argument here, but I point you to The Corps and the Shore by Orrin H. Pilkey and Katherine L. Dixon, geologist and research associate at Duke University when they wrote the book. In Chapter 3, “Beaches by the Numbers,” they show the inadequacy of the mathematical models used by the Army Corps of Engineers to control beaches around the United States. The entire book documents this. In this chapter they name and discuss “[s]ome of the specific and fatal weaknesses of mathematical models used by coastal engineers”: isolation of natural processes, representation of complex nature with artificial simplicity, failure to consider inherent uncertainties of natural processes, failure to consider chaos theory, and failure to recognize variety in nature. Reading this book, I frequently said to myself, “Yes! This is exactly what’s happening here in Cambria.”
After reading the ACE’s Coastal Consistency Determination, I now walk through Shamel Park to Moonstone Beach and think, What will be the effect on the park of a Morooka/PS-600 track mounted sonic drill rig, weighing 37,700 pounds and 41 feet long, taking a 90 degree turn downhill from Windsor Boulevard, driving over the sandy, potted parking lot lined by old cypress and fence and small groundcover garden toward the ocean, making another 90 degree turn on to the service road between the younger cypress and another fence, driving past the only playground for children in town (apart from the schools), and making another 90 degree turn on to the cement ramp to the beach? What exactly will the effects of multiple trips be? And what will happen to the beach?
At the end of her book, Sylvia Earle writes, “I wish you would use all means at your disposal—Films! Expeditions! The Web! New submarines!—to create a campaign to ignite public support for a global network of Marine Protected Area, hope spots enough to save and restore the ocean, the blue heart of the planet” (p.263). The list of Protected Marine Sites that then follows includes the Cambria State Marine Conservation Area.
The “Coastal Consistency Determination/ Geotechnical and Hydrogeologic Investigation/ Cambria, CA” provided by the Army Corps of Engineers never even mentions The Cambria State Marine Conservation Area.
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