Sand and Recreation Mitigation Fees on Solana Beach Bluff Projects: A Briefing

Briefing summary

• Solana Beach’s certified Land Use Plan requires owners who build bluff retention devices to pay two separate fees: a Sand Mitigation Fee and a Public Recreation Fee.
• The two fees address different impacts. One covers sand the bluff would have supplied to the beach. The other covers beach area the public loses.
• Both are calculated per project, using the structure’s size, the bluff’s geometry and an assumed erosion rate over a 20-year period.
• Fees are collected before the coastal development permit is issued. Boards should plan for them as part of any shoreline project, separately from construction.

This briefing is for owners and HOA boards along the Solana Beach bluffs. It describes how the fees are structured in the City’s Local Coastal Program. It doesn’t calculate anything for a particular property, and it isn’t legal advice. Fee amounts and rate tables are published in the City’s documents and change over time; we deliberately leave them out.

Background: why a seawall triggers mitigation at all

A coastal bluff is also a source of beach sand. As it retreats, some of the eroding material reaches the beach. A bluff retention device, whether a seawall at the toe or an upper-bluff structure, holds the bluff in place. That has two side effects the City’s plan names directly: less sand delivered to the beach, and less beach area available as the shoreline would otherwise have shifted inland.

Policy 4.50 of the Land Use Plan requires the bluff property owner to pay for the structure and to pay both a Sand Mitigation Fee and a Public Recreation Fee. The same policy says these fees are not intended to duplicate fees assessed by other agencies. They’re meant to work alongside mitigation the Coastal Commission and the State Lands Commission typically assess.

1. The Sand Mitigation Fee: paying for sand that won’t arrive

Appendix A of the Land Use Plan sets the formula, based on a Coastal Commission method. In words, it multiplies two things:

1. Sand cost: the cost of one cubic yard of beach-quality sand, assuming a large purchase delivered to the beach.
2. The sand volume: the cubic yards of beach-quality sand that would have reached the beach from the protected bluff over the permit period but for the device.

The volume calculation draws on several site inputs: the fraction of beach-quality sand in the bluff material (from analysis the applicant provides), the width of the device, a 20-year permit duration, the height of the protected section, the height of the unprotected upper bluff above it, and retreat rates for the bluff with and without the device. Owners may submit site-specific geotechnical information to support different retreat values than the defaults.

Under Policy 4.50, Sand Mitigation Fees go into an interest-bearing account and are to be spent on sand replenishment and potentially retention projects first. Secondary uses for public access and recreation require a City analysis and written approval from the City Council and the Coastal Commission’s Executive Director.

2. The Public Recreation Fee: paying for beach the public loses

Appendix C describes the Public Recreation Impact Fee, also called the Public Recreation Fee. It’s separate from, and independent of, the sand fee. It’s calculated project by project to keep it proportional to the impact.

The appendix bases the fee on two areas:

1. The Initial Area: the beach footprint the device occupies, measured as its width times its length, plus the full area of any seacave or notch behind it. Notches previously filled with erodible concrete that can no longer erode as originally approved are counted too.
2. The Bluff Retreat Area: the beach the public would have gained over 20 years as the bluff retreated naturally, calculated per linear foot of device.

Each area has its own rate in a published table. Those rates trace back to a recreational value per square foot of beach, derived from beach attendance, beach area measured from LiDAR surveys, and a per-visitor day-use value. For the retreat portion, the appendix assumes an erosion rate of 0.4 feet per year through 2025 and 0.673 feet per year from 2026 through 2046. Those are planning assumptions for the fee, not a prediction for any one bluff.

3. What happens at the end of 20 years

Both fees are tied to a 20-year mitigation period. Appendix C says that at the end of each period, the device is either removed or new fees are assessed. If a geotechnical report finds the device can’t be removed, mitigation is required for the next period, and that later mitigation covers the full beach area that passive erosion would have made available had the armoring not been built.

Policy 4.53 adds that permits for bluff retention devices expire when the protected structure is redeveloped, is gone, or no longer needs protection. Before expiration, the owner applies for a new coastal development permit to remove, modify or retain the device, with a fresh assessment of need, condition and impacts. Our briefing on cumulative alterations explains how redevelopment is tracked.

4. Exemptions, offsets and alternatives

Appendix C contains several rules boards often ask about:

• Erodible concrete infills. Seacave and notch infills built entirely of erodible concrete are exempt from both fees, provided they erode with the natural bluff, are maintained to do so, and no retention device is built in front of them. If monitoring shows the back of the beach has become fixed, the permittee must apply for an amendment and mitigation becomes due.
• In-kind projects. Applicants may propose a public coastal recreation or beach access project instead of paying the recreation fee. The City may accept it if it provides a comparable or greater public benefit.
• No private-property offsets. Reductions or offsets to recreation fees for devices whose main purpose is protecting private property are prohibited. Retroactive adjustments based on later observed erosion are also prohibited, apart from interim fee deposits.

5. When the money is due

Appendix C says the decision-making agency calculates the recreation fee during the permit process, and the entire fee is submitted to the City before the coastal development permit is issued. Appendix A describes the sand fee and an interim recreation fee deposit as conditions of approval payable when the discretionary permit is issued. Read the current conditions for your own permit; the City’s shoreline management page is the starting point.

For boards, the practical point is cash timing. Mitigation fees arrive before construction starts, and they sit outside a typical construction bid. Our briefing on reserve studies covers how boards separate long-range funding from one-time project costs.

6. Where structural work fits

Fees are a permitting matter. Structural work on the house itself, such as foundation repair set back from the bluff edge, follows its own path. Our pages on Coastal Commission permits for foundation repair, seawall and upper-bluff repair and bluff-top foundation repair explain how those projects relate. We coordinate with licensed engineers as needed on any project that touches a bluff device. We don’t predict permit outcomes, fee totals or timing.

Inputs that shape both the structural scope and the fee picture include the device’s dimensions, any seacaves or notches behind it, bluff material composition, the condition of the existing structure, and the permit history of the parcel.

Numbered takeaways

1. Two fees, two purposes: lost sand and lost beach area.
2. Both use project-specific inputs and a 20-year period.
3. Seacaves and previously infilled notches can count toward the recreation fee.
4. Erodible concrete infills that erode naturally are exempt, with monitoring.
5. Fees are due before the permit issues; budget for them separately.

For a documented structural look at a bluff-top home or building, request a Free Quote. We serve all of Solana Beach, from the bluffs to the inland neighborhoods.