It is astounding what passes for environmental planning in Southern California these days. Clinging to the coast like lemmings on perpetual holiday, local municipalities purposely ignore ecological issues, when planning for public infrastructure. Few cities, if any, have clearly defined policies regarding biological stewardship. In the face of unending human population pressure, failure to account for ecological reality, can only be seen as reckless endangerment.

One could say the history of California has always been study of miscalculated indifference. In the past, ignorance, uncertainty, and utilitarianism could explain the trashing of the native habitat in the name of progress. That is no longer the case.

Californians of the 21st century will be forced to confront the limits of human ingenuity and anthropocentrism. Duplicitous denial is no longer in the best interest of anyone, yet this is the only thing elected officials and civic employees seem comfortable with.

The City of Encinitas is the current poster child for sweeping ecological considerations under the procedural rug. The vacuum planning associated the ill conceived plan to build a sea wall at Beacon's Beach is just the most recent example.

Looking back to hold back the ocean and coastal geology, lack of consideration regarding ecological alternatives on the part of City of Encinitas Parks and Recreation staff, when preparing a draft Environmental Impact Report (EIR) for the proposed Beacon's Beach Access project, is insulting to the residents of Encinitas. Not addressed in the EIR is the continued maintenance of a seawall in this location, nor does it address the long term viability of the project in the face of changing climatic conditions. This EIR is remarkably incomplete.

Staff acknowledges bluff failures occur yearly in the vicinity, what the report doesn't address is ongoing anthropogenic impacts on the coastal environment and the role they play in bluff failure. Nor does the EIR address if the viability of a seawall if ecological concerns aren't addressed and mitigated.

Questions not addressed by the Beacon's EIR include, has residential plantings, irrigation, and run-off been addressed in relation to past bluff failures in the immediate area?

If ground water impacts have not been factored into project evaluation, are recommendations resulting from incomplete assessments by Parks and Recreation staff accurate or even valid?

Missing from the EIR is the estimated longevity of the proposed seawall, and any assurances that is maintainable regular sand replenishment programs. No sand replenishment programs were identified. Does Encinitas have access to those funds? Has staff factored in the likelihood of not receiving sand replenishment funds on a regular basis for sand replenishment at Beacon's Beach?

It was also made clear ecological mitigation alternatives were not, and have not been, pursued by city staff while seeking grant funding for the seawall project.

Was the potential for damage such as end scour, scour trough formation, deflated profiles, beach cusps, passive erosion, loss of beach width, beach encroachment, and wave reflection, given adequate consideration?

What about the impacts of kelp harvesting off Beacon's beach? What role does kelp harvesting play in beach and bluff retention? Has Parks and Recreation staff and explored the potential bluff retention benefits of restoring the degraded California Kelp forests of our coast, while avoiding expensive and invasive public work projects?

Have native landscaping alternatives been considered? Will native species, indigenous to the area, be required as mitigation in the final plan designs?

Has the presence of California Ground Squirrels otospermophilus beecheyi been factored into the assessment of long term viability of the proposed seawall?

Why was biological resources and cultural resources not included in the EIR. Which qualifications were used to determine that coastal bluffs are not sensitive biological resources? Who determined that ecology was not important in the planning process?

Alternative A would not only achieve what the Parks and recreation department is seeking, beach access and parking improvement at Beacon's Beach, it is also recognized as the environmentally superior project. I suggest the Alternative A be given higher priority in subsequent review of the Beacon's access project.

A second EIR should be conducted as the first one was done in the absence of critical thought. This second "ecological" Environmental Impact Report, should focus on the biological and cultural resources, discounted and overlooked when the parameters for studying the environmental conditions of Beacon's Beach were decided.

Sea walls are so 20th century.