STATE OF CALIFORNIA - NATURAL RESOURCES AGENCY CALIFORNIA COASTAL COMMISSION South Coast Area Office 301 E. Ocean Boulevard, Suite 300 Long Beach, CA 90802 (562) 590-5071 GAVIN NEWSOM, GOVERNOR CALIFORN W16b 5-23-0753 (City of Newport Beach) February 5, 2025 Correspondence O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Fri 1/31/2025 3:08 PM Sent: Friday, January 31, 2025 3:01 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Honorable members of the Coastal Commission, I am writing to express concerns about Newport Beach's Coastal Development Permit (CDP) 5-230753, which proposes sweeping changes to the mooring fields in Newport Harbor. Please, consider the following three points before approving this CDP: 1. Safety Concerns - Unsafe Access is No Access!
The proposed changes push moorings closer together ("densification"), reducing the space available for boaters to safely maneuver their vessels on and off their moorings. This increases the risk of collisions (and injuries), particularly during the frequent strong winds and currents in Newport Harbor. This will disproportionately affect older boaters and those with mobility issues.
This increase of risks directly conflicts with the California Coastal Act Section 30210, which calls for maximizing access and taking into consideration public safety needs.
hose with mobility issues.
This increase of risks directly conflicts with the California Coastal Act Section 30210, which calls for maximizing access and taking into consideration public safety needs.
The current system in Field C is perfectly functional and exists well within the mooring footprint mandated by the Army Corp of Engineers in the late 1940s. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan.
2. No process for reviewing and replacement of the current moorings The language in the CDP regarding the replacement is alarming and does not delineate a process where a mooring holder can: 1) Get notification that their mooring tackle is out of compliance and 2) Price out replacement tackle for their particular boat and mooring placement.
Specifically, the new requirements for anchor weights to be non-toxic Iron or steel “shall be replaced at the time the respective mooring is repositioned pursuant to the approved project plans. All removed tackle shall be disposed of at a legal disposal site or recycled at a recycling facility within 24 hours of removal." See 2. B below And if a mooring holder is not given time to identify a cost-effective replacement for their mooring weights, what happens? Does the City take over the permit at the time the mooring is repositioned?
2.
Anchor Replacement Plan.
A. By acceptance of this permit, the permittee agrees that it shall require all anchors/weights within mooring field C to be replaced with helical anchors or an anchor weight consistent with the following anchor weight requirements: i. Anchor weights shall consist of non-toxic iron and/or steel.
ii. The use of anchor weights that contain oil, grease, and/or creosote are strictly prohibited.
e following anchor weight requirements: i. Anchor weights shall consist of non-toxic iron and/or steel.
ii. The use of anchor weights that contain oil, grease, and/or creosote are strictly prohibited.
iii. The use of anchors that consist of or include engines, tires, forklifts, and treated railroad tie timber are strictly prohibited.
iv. Anchor weight replacements shall minimize fill of coastal waters. An increase of fill, or square footage, for a replacement weight is strictly prohibited.
6 5-23-0753 (City of Newport Beach) B. All existing anchors/weights that do not satisfy the requirements pursuant to Subsection A of this condition shall be replaced at the time the respective mooring is repositioned pursuant to the approved project plans. All removed tackle shall be disposed of at a legal disposal site or recycled at a recycling facility within 24 hours of removal.
3. Places a financial burden on mooring holders The City's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this Harbor user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining moorings as affordable public access to the harbor.
I urge you to DENY CDP 5-23-0753 as it currently written, and to require a thorough safety analysis and provisions that allow the current mooring holder community adequate time to remediate their long-held moorings, as well as develop a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Thank you for your consideration, Matthew Anderson O Outlook FW: IMPORTANT CONSIDERATIONS FOR CDP 5-23-0753
better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Thank you for your consideration, Matthew Anderson O Outlook FW: IMPORTANT CONSIDERATIONS FOR CDP 5-23-0753 Date Thu 1/30/2025 11:00 AM To Sent: Thursday, January 30, 2025 9:53 AM Subject: IMPORTANT CONSIDERATIONS FOR CDP 5-23-0753 Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce coastal access for ordinary boaters, older boaters, and those with mobility challenges. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, and the use of specialized hydraulic installation equipment, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and
on equipment, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.23), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional and time tested. The City has not performed a proper alternative Harbor Engineering analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already over crowded mooring fields, rather than first converting spacious "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough Harbor Engineering Safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, HEIN AUSTIN O Outlook FW: CDP 5-23-0753 concerns Date Wed 1/29/2025 8:17 AM To
and the City's commitment to affordable and safe access.
Sincerely, HEIN AUSTIN O Outlook FW: CDP 5-23-0753 concerns Date Wed 1/29/2025 8:17 AM To Sent: Tuesday, January 28, 2025 10:15 PM Subject: CDP 5-23-0753 concerns Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs.
Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore
an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Sue and Bill Baker Presentation to California Coastal Commission February 5, 2025 The following presentation contains content (with some updates) previously presented at various public stakeholder meetings and to Newport Beach City Council.
Prepared by Ira Beer CITY OF NEWPORT CALIFORNIA BEACH Mooring Field Open Water Initiative Improved Utilization Report
resented at various public stakeholder meetings and to Newport Beach City Council.
Prepared by Ira Beer CITY OF NEWPORT CALIFORNIA BEACH Mooring Field Open Water Initiative Improved Utilization Report Newport Beach Harbor Commission Objective For Harbor Viability Within Functional Area 2.3 Ira Beer Harbor Commissioner May 23, 2023 OF CITY NEWPORT CALIFORNIA BEACH Mooring Field Open Water Initiative Improved Utilization Report Harbor Commission Objective 2.3 as Approved by City Council Purpose: To evaluate the current mooring fields and provide a recommendation for new guidelines resulting in: • • • Better Define Rows and Fairways To Improve Navigation and Safety Improved Optimization Of Space Within The Mooring Fields Additional City Moorings Within The Current Mooring Fields CITY OF NEWPORT CALIFORNIA BEACH Public Outreach Mooring Fields Reconfiguration Changes to Muni Code 17.60.040 and 17.25.020 Harbor Commission Publicly Noticed Meetings 09/13/17 Proposed Revisions to Mooring Specifications 02/14/18 Mooring Lengths Review within Mooring Fields 08/08/18 Mooring Policy Discussion 10/10/18 HC Objective 3.2 Establish Policies for Modifications to Offshore Mooring Lengths 01/09/19 Proposed Language to Amend Title 17 to Allow for Offshore Mooring Extensions 06/12/19 Proposed Amendment to Title 17, the Harbor Code Regarding Offshore Mooring Extensions 04/13/22 Update on Mooring Row Alignments and the Mooring Extension Application Process 06/08/22 HC Objective 2.3 including Changes to Title 17 Summarizing the configuration Guidelines to Improve Navigation Safety and Allow for Additional Moorings Within the Fields
on Application Process 06/08/22 HC Objective 2.3 including Changes to Title 17 Summarizing the configuration Guidelines to Improve Navigation Safety and Allow for Additional Moorings Within the Fields 10/12/22 HC Objective 2.3 including Changes to Title 17 to Improve Navigation Safety, Allow for Additional Moorings Within the Fields and Mooring Size Exchange Requests 11/09/22 HC Objective 2.3 including Changes to Title 17 to Improve Navigation Safety, Allow for Additional Moorings Within the Fields and Mooring Size Exchange Requests 03/08/23 HC Objective 2.3 Approve Recommendation for changes to Title 17 and to Improve Navigation Safety, Allow for Additional Moorings Within the Fields and Mooring Size Exchanges Requests Stakeholder Meetings 02/03/22 NMA (in-person) Meeting Open Discussion Objective 2.3 10/20/22 NMA (in-person) Meeting Open Discussion Title 17 and Objective 2.3 11/29/22 Balboa Island Improvement Association (in-person) Meeting (Full presentation of the Mooring Reconfiguration Initiative and Changes to Title 17) 12/14/22 Public Stakeholder Meeting - City Hall (Full presentation of the Mooring Reconfiguration Initiative and Changes to Title 17) 01/12/23 Lido Island HOA (in-person) Meeting (Full presentation of the Mooring Reconfiguration Initiative and Changes to Title 17) 01/30/23 NMA Stakeholder Meeting - Marina Park (Full presentation of the Mooring Reconfiguration Initiative and Changes to Title 17) 02/02/23 Commercial Operator (virtual) Meeting (Full presentation of the Mooring Reconfiguration Initiative and Changes to Title 17) 02/24/23 Newport Harbor Yacht Club (in-person) Meeting (Full presentation of the Mooring Reconfiguration Initiative and Changes to Title 17) OF CITY NEWPORT CALIFORNIA BEACH Solution for Improved
17) 02/24/23 Newport Harbor Yacht Club (in-person) Meeting (Full presentation of the Mooring Reconfiguration Initiative and Changes to Title 17) OF CITY NEWPORT CALIFORNIA BEACH Solution for Improved Navigation, Safety and Creating New Open Water Space New Double Rows vs. Single Row Mooring Configuration Expected Result is: • Improved public access and utilization of water space over public tidelands • Increased size of navigational channels throughout the harbor • Wider and well-defined fairways inside the mooring fields .
Increased spacing between moorings in the same row .
• • More overall room when navigating to or departing from a mooring Safer navigation throughout the mooring fields for all mariners (motor, sail, Duffy boats and human powered craft) Allows for the addition of new long-term moorings in each mooring field.
OF CITY NEWPORT CALIFORNIA Lido Peninsula Resort BEACH Single Row Mooring Field Approximately 200 Moorings covering 1.3 million sq/ft (30 ACRES) Newport Harbor Mooring Fields J & H Via Lido Soud Via Lido Soud do Soud Via Lido Soud Via Lido Soud IMH Newport Bay Without policies defining row and fairway sizes, a mooring field can become a safety concern to navigate and become very inefficient use of limited waterways.
MaNice OF CITY NEWPORT CALIFORNIA BEACH Double Row Mooring Configuration America's Cup Harbor, San Diego Approximately 180 Moorings covering 650,000 sq/ft (15 ACRES) 90% of the moorings in 50% of the space • Double rows provide more efficient use of limited space Standardized boat sizes per row • .
Wider fairways improve public access and navigation 40 years of safe operations Similar wind and current speeds are recorded in both San Diego and Newport Harbors America's Cup Harbor may experience less current than the main channel
ess and navigation 40 years of safe operations Similar wind and current speeds are recorded in both San Diego and Newport Harbors America's Cup Harbor may experience less current than the main channel Americas Cup Harbor • OF CITY NEWPORT CALIFORNIA BEACH Problem: For Decades There Have Been No Guidelines for Mooring Lengths, Extension Requests, Spreader Lines or Fairway Navigation Guidelines in Newport Harbor.
Cluttered Fairway Fairway 12' Spreader Line Dangerously narrow and cluttered fairway poses a safety hazard to all mariners.
Propellers often become tangled.
Closer view of fairway shows approximately 12 feet space to navigate through. Spreader line is longer than the mooring creating a safety hazard.
CITY OF NEWPORT ✓ CALIFORNIA BEACH Current Spacing Between Boats and Fairway Widths Fairway less than 20' Present Challenges for Mariners Spacing less than 10' Maps Spacing less than 10' Narrow fairways under 20' in places Limited public access over public tidelands inside mooring fields Nov 8, 2022 at 11:17:01 AM Newport Beach CA Speed:1.7mph Often less than 20' distance between boats in the same row OF CITY NEWPORT CALIFORNIA BEACH Improved Double Row Design for Two Point Moorings PROPOSED LAYOUT FOR NEWPORT BEACH MOORINGS -20' TO 40' STILL WATER SEPARATION DISTANCE (LOA) BOAT LENGTH OVERALL 20' 101010101.5 x LOA FAIRWAY WIDTH (STERN TO STERN) -BOAT MOORING RANGE 15' 4' DISTANCE BETWEEN BOATS = 50' TO 60' ON-CENTER Substantial increase in overall spacing from current single row configuration.
60' 90' wide fairways (1.5X LOA) • 50'-60' between boats in the same row.
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20' minimum between boats in shared double rows Diagram: Noble Engineers Currently, many fairways allow less than 20' navigation Currently, vessels sharing the same row are
en boats in the same row.
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20' minimum between boats in shared double rows Diagram: Noble Engineers Currently, many fairways allow less than 20' navigation Currently, vessels sharing the same row are less than 20' apart Exhibit 5 - Mooring Field Configurations Amended from CCC Staff Report Single-Row Mooring Field AAAAAAA Double-Row Mooring Field Vessels sharing a double row are a minimum 20' apart 14 14 A Vessels sharing the same row are 50'-60' apart on center Fairways are narrower and accessible on both sides of the vessel.
Boats are often closer together in the same row.
Fairways are wider and accessible on both sides of the vessel.
Boats are farther apart in the same row.
Fairways are 60'90' wide or not less than 1.5x the vessel LOA Rows Fairways OF CITY NEWPORT CALIFORNIA BEACH Safety and Improved Navigation With Double Row - Two Point Moorings New Double Row Mooring Design - C Field 40 40 40 40 40 110' 20' 60' 40 , 100 55' 40 40 75' 50 50 50 50 110' 125 55' 50 50 50 • When approaching a 50' mooring, a boater will have a 75' wide fairway (1.5 x its LOA) and open space of approximately 100' x 125' to grab the mooring line and secure the vessel.
A boater can safely move left or right a distance up to 50' when abandoning an attempt to retrieve the mooring line. A boat tied to a mooring should not be able to encounter adjacent boats in the same row.
Even with all this extra room, boaters must know how to properly operate their vessel and are responsible to match their ability with present conditions in an open an active mooring field.
Height in feet (MLLW) Tidal Change During King Tides Newport Harbor and San Diego Harbor December 2024 Tidal swings are a strong driver of currents and current speeds, particularly in coastal and estuarine environments. The
idal Change During King Tides Newport Harbor and San Diego Harbor December 2024 Tidal swings are a strong driver of currents and current speeds, particularly in coastal and estuarine environments. The gravitational pull of the moon and sun causes tides to rise and fall, creating horizontal water movement known as tidal currents. How Tidal Swings Influence Currents: Larger Tidal Ranges = Stronger Currents. When tidal swings (differences between high and low tides) are large, more water moves in and out of bays, estuaries, and coastal areas, leading to faster currents.
Newport Harbor and San Diego Harbor both experience similar tidal patterns, with two high and two low tides each day. The tidal ranges are comparable, though San Diego exhibits slightly higher high tides and lower low tides for the date range shown below.
8.0 6.0 4.0 2.0 0.0 12:00 AM 12/1 NOAA/NOS/CO-OPS Tide Predictions at 9410580, NEWPORT BEACH, NEWPORT BAY ENTRANCE CA From 2024/12/01 12:00 AM LST/LDT to 2024/12/31 11:59 PM LST/LDT 12:00 AM 12:00 12/3 AM 12/5 12:00 AM 12/7 12:00 AM 12/9 12:00 AM 12/11 12:00 AM 12/13 NOAA/NOS/CO-OPS Tide Predictions at 9410170, San Diego CA From 2024/12/01 12:00 AM LST/LDT to 2024/12/31 11:59 PM LST/LDT 8.0 8.0 6.0 4.0 2.0 0.0 AM AM 12:00 12:00NOAA2NOS/Centerdor Opethal 200graph Bduc12300 Service 00 AM AM AM AM AM AM AM 12/15 12/17 12/19 12/21 12/23 12/25 12/27 12/29 12/31 Source for all above data: tidesandcurrents.NOAA.gov and Chat GTP Height in feet (MLLW) 6.0 4.0 2.0 0.0 12:00 12:00 12:00 AM AM AM 12/1 12/3 12/5 12:00 AM 12/7 12:00 AM 12/9 12:00 12:00 12:00 12:00NOAAZNOS/Centro Opal AM AM AM AM AM AM AM 12/11 12/13 12/15 12/17 12/19 12/21 12/23 AM 12/25 8.0 6.0 4.0 2.0 0.0 200graph: Boduc12300 Servi:00 AM AM AM 12/27 12/29 12/31 Wind Speeds
0 12:00 12:00 12:00NOAAZNOS/Centro Opal AM AM AM AM AM AM AM 12/11 12/13 12/15 12/17 12/19 12/21 12/23 AM 12/25 8.0 6.0 4.0 2.0 0.0 200graph: Boduc12300 Servi:00 AM AM AM 12/27 12/29 12/31 Wind Speeds Newport Harbor and San Diego Harbor Month San Diego (mph) Newport Beach (mph) January 7.7 7.4 February 7.8 7.4 March 7.7 7.2 April 7.8 7.2 May 7.4 6.7 June 6.6 6.0 July 6.1 5.5 August 5.9 5.3 September 5.9 59 5.4 October 6.2 79 5.8 November 70 7.0 6.7 December 7.9 7.6 Comparison in Newport & San Diego Harbors The figures indicate that San Diego generally experiences slightly higher average wind speeds compared to Newport Beach throughout the year. Both locations see a decrease in wind speeds during the summer months, while wind speeds tend to be higher during the winter months.
Newport Harbor: Due to its relatively small, enclosed nature, tidal forces are the dominant driver of currents, but strong Santa Ana winds or coastal storms can create noticeable localized currents.
San Diego Harbor: A larger, deeper bay with more open access to ocean currents, wind influence is present but typically less significant compared to its tides and densitydriven circulation.
Source: weatherspark.com OF CITY NEWPORT CALIFORNIA BEACH Double Row Moorings Provide Flexibility and Ample Space for Mooring in Varying Conditions When tailwinds, tidal currents or other conditions affect the approach to a mooring, the improved open water space between moorings (50'to 60' oncenter), should be ample room for approaching the mooring from the downwind or opposing fairway.
Mariners can safely approach moorings from either fairway or either side of a mooring with more space on average than exists currently.
NEWPORT CITY OF BEACH CALIFORNIA AGI Single Row Mooring Configuration Current Before
approach moorings from either fairway or either side of a mooring with more space on average than exists currently.
NEWPORT CITY OF BEACH CALIFORNIA AGI Single Row Mooring Configuration Current Before J & H Fields Proposed After * 49 Existing Mooring New Mooring 30' New 35' 40' 45' 50' Mooring Rows Row 55' Fairway 60' 65' 70' 75' 80' 90' 95' G New Open Water Space New Open Water bace H 50° 20° 40° 间内物 New Open Water Space 60 40 20 50 75 50° 20′ 50 78' 112.5 225 Marina Park (Docks) Veterans Memorial Park Marina Park Mooring Fields H & J BAY AVE W NBGIS NEWPORT BEACH City of Newport Beach GIS Division October 10, 2022 Mooring Row 2022 OctNBHC.aprx 112.5 225 Feet Marina Park (Docks) Marina Park Veterans Memorial Park Mooring Fields H & J BAY AVE W NBGIS NEWPORT BEACH City of Newport Beach GIS Division October 05, 2022 Mooring Row 2022 OctNBHC.aprx Improved navigation and utilization of space • • Poor utilization of space and limited public access Up to 15 boats in a row • • Up to 11 boats per row .
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• • Fairways average less than 40' wide Narrow navigation channel between Lido Island Non-compliance with Harbor Design Standards • • Fairways are all 60' - 90' wide Larger navigation channel between Lido Island Full compliance with Harbor Design Standards OF CITY NEWPORT CALIFORNIA BEACH Single Row Mooring Configuration C Field Pilot Test - Before (current) Existing Mooring Mooring Rows Row Fairway 30' 35' 40' 45' New Mooring 50' 55' New 60' 65' 70' 75' 80' 90' 95' 6 to 7 Boats per Row Boats are Outside Legal Boundaries Larger Boats are Obstructing Fairways 32 69' 55 40' 55' 45' 45' 40' 60' 60° 40° 40' 45 45' 50' 71' 35 40' 67' 58' +50° 40° 40' 69' 35' 45° 50' 78' 50' 40 70' EXC 40° 79' 58' 60' 40° 59' 50' 53' 45° 110' 40' 54' 75° 45° 52' 65' 75 40 45 35
' 45' 40' 60' 60° 40° 40' 45 45' 50' 71' 35 40' 67' 58' +50° 40° 40' 69' 35' 45° 50' 78' 50' 40 70' EXC 40° 79' 58' 60' 40° 59' 50' 53' 45° 110' 40' 54' 75° 45° 52' 65' 75 40 45 35 5.0' 94' 50' 40 40' 50' 75' 40° 40 45' 40' 50' 450 550 50' 65' C-09 C-08 C-07 C-06 C-05 C-04 C-03 C-02 C-01-> 3 Mooring Field C 8-90-5/ CYPRESS EDGEWATER PL • • .
Existing Conditions All rows provide less than adequate spacing that is not compliant with Harbor Design Standards. Fairways are only 41' to 65' wide with up to 75' boats protruding into fairways.
Many vessels are moored outside the designated mooring field boundaries.
Poor utilization of valuable water space along the main channel of Newport Harbor NBGIS NEWPORT BEACH City of Newport Beach GIS Division October 31, 2022 Mooring Row 2022 OctNBHC.aprx OF CITY NEWPORT CALIFORNIA 35 62.5 Feet BEACH Existing Mooring Mooring Rows 30' 35' Row Fairway 40' 45' New Mooring 50' 55' New 60' 65' 70' 75' 80' 90' 95' 40 125 40 40 40 40 New Double Row Mooring Configuration C Field Pilot Test - After (proposed) 11915 New Open Water Space 45 75 55 65 50 50 50 50 45 40 45 45 New Open Water Space 45 45 45 45 Mooring Field C 50 60 50 50 60 50 50 55 CYPRESS ST EDGEWATER PL 55 NBGIS NEWPORT BEACH City of Newport Beach GIS Division October 31, 2022 Mooring Row 2022 OctNBHC.aprx 75 75 New Configuration Provides Improved Utilization of Space Every Row is in Substantial Compliance with Harbor Design Standards. All boats are spaced 50' - 55' on center and fairways range from 60' to 100'.
Rows Reduced in Size from 6 to 7 Boats Down to 5 Boats 7 New Moorings Are Added 2 Acres of New Open Water Created Along The Main Channel (appx 1200' x 70' Greater Distance Between the Mooring Field and Residential Properties
m 6 to 7 Boats Down to 5 Boats 7 New Moorings Are Added 2 Acres of New Open Water Created Along The Main Channel (appx 1200' x 70' Greater Distance Between the Mooring Field and Residential Properties Complete one-double row then test and confirm engineering design before continuing with the balance of the field.
OF CITY .
NEWPORT CALIFORNIA BEACH Newport Harbor Open Water Initiative Mooring Field Reconfiguration Summary Hundreds of letters resulting from public outreach over several years have been considered • Big clean-up of the mooring fields with no cost to the existing mooring permittees • • • .
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• • Moorings will be relocated in the same mooring field to like-for-like locations, where practicable Accommodation for all (about 10) 5' mooring extension requests received before November 1, 2022 More overall room between boats in the same row for all mooring permittees Wider fairways will improve public access and provide safer navigation through the mooring fields Fewer expected incidents involving propellers caught in mooring lines - common occurrence today Improved aesthetics from the shoreline and while cruising the harbor Welcomed addition of new moorings made available to the public that require no initial investment Conservation environmental buoys installed at all relocated moorings and helical anchors installed for new and relocated City moorings *Source: visitnewportbeach.com OF CITY NEWPORT CALIFORNIA BEACH Open Water Initiative Mooring Fields Optimization For the Long-term Preservation and Enhancement of Newport Harbor, our Most Cherished Asset For the Benefit of All Stakeholders and Mariners, 9,000 boats in and adjacent to Newport
Fields Optimization For the Long-term Preservation and Enhancement of Newport Harbor, our Most Cherished Asset For the Benefit of All Stakeholders and Mariners, 9,000 boats in and adjacent to Newport Harbor, Waterfront and Local Residents, Mooring Users, Commercial Operators, Paddleboarders, Young Sailors, Aquatic Centers, and Millions of Annual Visitors Presented by Ira Beer Harbor Commissioner May 23, 2023 O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 (City of Newport Beach, Newport Beach) Date Fri 1/31/2025 11:32 AM To 1 attachment (3 MB) CCC Presentation 250131.pdf; Sent: Friday, January 31, 2025 11:00 AM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 (City of Newport Beach, Newport Beach) January 31, 2025 To: California Coastal Commission From: Ira Beer Meeting Agenda: February 2025 Re: Item 16b - Coastal Permit Application Application No. 5-23-0753 (City of Newport Beach, Newport Beach) Dear Chair Cummings and Honorable Commissioners, I am writing to you individually on my own behalf. I am the current Vice-chair of the Newport Beach Harbor Commission and served as a Harbor Commissioner for almost 8 years. I have also owned and operated various boats (from 21' Duffy to 58' Viking Sport Cruiser) all berthed in Newport Harbor for most of the last 25 years. I am very familiar with navigating in Newport Harbor and the coastal waters from Santa Barbara to Los Cabos, MX. Additionally, as part of the Harbor Commission's Open Water
most of the last 25 years. I am very familiar with navigating in Newport Harbor and the coastal waters from Santa Barbara to Los Cabos, MX. Additionally, as part of the Harbor Commission's Open Water Initiative, since 2018 I have been the Chair for City Council approved objective 2.3 – Optimization of the Current Mooring Fields in Newport Harbor.
I have reviewed the staff report and exhibits, including the NMA letter referenced therein. I believe there may be some items that deserve clarification. In lieu of writing a letter detailing all the concerns, I will summarize below and reference the attached PDF supporting why both the Harbor Commission and City Council unanimously approved this long-needed initiative. I have attached a compilation of data and images used in prior public and stakeholder meetings with some updates since approved by City Council in early 2023. I ask that you please take the time to carefully review the attachment.
Additionally, it is my intent to be present virtually for public comments and will limit my discussion and offer Commissioners the opportunity to ask me any questions during my allocated time, should it be appropriate at this forum to do so.
1. In the staff report Exhibit 5, the diagram does not depict an accurate before and after representation. This is perhaps due to the fact the diagram is not to scale and may imply that the new double row configuration will not allow for boats to access both adjacent fairways. This is not correct. Boats can access both adjacent fairways and there is more room on average than currently exists with today's single row configuration. You will see in the amended Exhibit 5 on page 10 of the attached PDF (although still not to scale) it
ays and there is more room on average than currently exists with today's single row configuration. You will see in the amended Exhibit 5 on page 10 of the attached PDF (although still not to scale) it more accurately reflects the proposed new configuration and for clarification shows the dimensions between rows, fairways, and boats in the same row. Page 11 shows a more detailed diagram of the increase in space and accessibility from all directions for navigation with the new configuration. More space overall between boats, greater visibility and large fairways for public access will almost always result in safer navigation for all mariners (i.e., mooring permittees, pleasure craft and human powered craft).
I would respectfully ask that the Commission consider referencing the Amended Exhibit 5 (page 10 and 11 of the attached PDF) during the hearing should staff have no objection.
2. Exhibit 6 - NMA letter please see comments below: a. Page 13 of the staff report – Exhibit 6 page 4 of 10. The statement and diagram referencing the proposed anchor system for the new mooring configuration are not correct. The diagram shows two boats sharing one new center anchor. The approved design for the new mooring configuration uses the two existing anchors for each mooring (see Noble Engineering diagram on page 9 of the attached PDF as approved by City Council on May 23, 2023); and the distance between the relocation of existing anchors will be 20' apart also as shown in the same diagram. An anchor rode will connect each anchor weight to a buoy that will have a 10'-15' bridal (line) from the buoy to the cleat on the boat. Therefore, when properly tied at the opposing anchor, the distance between the boats will generally be between 20' to 30' apart in the shared row.
bridal (line) from the buoy to the cleat on the boat. Therefore, when properly tied at the opposing anchor, the distance between the boats will generally be between 20' to 30' apart in the shared row.
As a reference, the design at America's Cup Harbor in San Diego uses a single shared anchor weight configuration resulting in vessels maintaining a safe distance of about 10' to 12' apart. America's Cup Harbor operations manager Greg Boeh reports few or no safety issues, incidents, or concerns with respect to the configuration over the past 40 years. As an overabundance of caution, Noble Engineers designed the proposed configuration in Newport Harbor with separate anchor weights for each vessel (same as exists today) and spaced 20' apart on the sea floor.
Page 9 of the attached PDF displays the approved engineering diagram from Noble Engineering. I would respectfully ask the commission to only reference this current and accurate diagram (page 9 of the attached PDF) when referencing the new mooring configuration, should staff have no objection.
b. Pages 14 and 15 of the staff report – Exhibit 6 pages 5 and 6 of 10. The statements and video links referencing comparisons to San Diego Harbor and Newport Harbor are not evidenced-based, as such have no merit.
The videos show a small piece of plastic or small tender floating in the harbor, in an ill attempt to purport it is challenging to moor a vessel if there is another vessel 20' away. In response to this, (i) a 5-to-25-ton boat with the hull partially submerged will require much more force to move than a small piece of plastic or light tender floating on the surface. While this is a simple matter of physics, Harbormaster Blank and I conducted a similar test using a small 25' harbor patrol vessel during the ebb flow of a
tic or light tender floating on the surface. While this is a simple matter of physics, Harbormaster Blank and I conducted a similar test using a small 25' harbor patrol vessel during the ebb flow of a king tide which typically produces the fastest current speeds with the highest tidal change. The result was the vessel took approximately 40 seconds to travel 20 feet from a stopped position as would be the case when tying to a mooring (video available upon request – large file). This is ample time for a reasonably experienced captain operating a vessel alone to walk the opposing end of the boat and grab the mooring line, and (ii) the current mooring configuration as exists today has boats CITY OF Best regards, closer than 20' apart in both rows and fairways – see attached PDF pages 7 and 8, and (iii) The proposed new configuration will have no less than 20' between boats sharing the same row and 50' to 100' of space in every other direction (more distance on average than exists currently) – see slides 10 and 11 of the attached deck, and (iv) The NMA purports San Diego's safety record of 40+ years using the double row system should not be used as a comparison because wind and current speeds in Newport Harbor are higher. There is no basis for this theory. The tidal currents and average wind speeds in Newport Harbor and San Diego Harbor are about the same.
In fact, average wind speeds and tidal changes (the primary driver of current speed) are higher in San Diego Harbor. Please reference slides 12 and 13 of the attached deck for data collected from NOAA and WeatherSpark.com for accurate average wind and tidal change comparisons. I would respectfully ask the Commission to not consider NMA general statements surrounding wind and tidal current
from NOAA and WeatherSpark.com for accurate average wind and tidal change comparisons. I would respectfully ask the Commission to not consider NMA general statements surrounding wind and tidal current differences as a safety consideration but rather rely on evidenced-based data such as recorded and documented wind and current speeds from NOAA and WeatherSpark.com as shown on slides 12 and 13 of the attached deck, and safety records from 40 years of operations using a similar mooring field layout with shorter distances between boats, rows and fairways than the proposed double row configuration presented by the City of Newport Beach.
Safety is always a primary concern and driver of any solution to a problem in Newport Harbor or any boating community. The ad-hoc committee, Harbor Commission and Harbor Department have all investigated and discussed the safety concerns voiced at public stakeholder meetings with city staff and third-party engineers. This pilot test will not only put to rest such concerns but will mark the first step of the Newport Harbor Open Water Initiative to pave the way for improved navigation, public access to new moorings for which there is great demand (currently 80+ person wait list) and environmental benefits to water quality including the promotion of eel grass replenishment resulting from environmental buoys and helical anchors.
Thank you for your valuable time and consideration.
NEWPORT CALIFORNIA Ira Beer Harbor Commissioner [email protected] (949) 702-6900 Outlook FW: Newport Beach Mooring Realignment Date Fri 1/31/2025 12:44 PM To Sent: Friday, January 31, 2025 12:38 PM
Date Fri 1/31/2025 12:44 PM To Sent: Friday, January 31, 2025 12:38 PM Subject: Newport Beach Mooring Realignment Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 523-0753 (City of Newport Beach, Newport Beach) Dear California Coastal Commission, The moorings in Newport harbor have been in use for 100 years. There have been no major safety issues reported. The existing mooring fields have been approved by the US Coast Guard, and the Army Corps of engineers.
The Newport Mooring Association and the overwhelming majority of mariners and mooring users in Newport harbor, including many US Coast Guard certified captains, strongly oppose the realignment of mooring field “C” due to safety concerns. This area of the harbor has significant hazardous currents which have not been adequately addressed in the realignment plan. The double-row system will make this mooring field extremely dangerous for boaters to use and will therefore restrict access. Several videos will be presented at the upcoming meeting to illustrate these facts.
The Newport Mooring Association has offered an alternative plan which address the City's concerns, most of which are aesthetic in nature ("The mooring fields look too messy and unorganized"), while providing a safe environment for boaters and mooring users. In addition, the City plans to spend $473,000 for this unwanted, unneeded, and dangerous project. The Newport Mooring Association has gotten a quote from the local mooring contractor (South Mooring Service) for $25,000-$30,000 to align all the moorings in “C” mooring field using
dangerous project. The Newport Mooring Association has gotten a quote from the local mooring contractor (South Mooring Service) for $25,000-$30,000 to align all the moorings in “C” mooring field using existing mooring equipment to create a safe, functional mooring field, in an area that is already safer and better functioning than what they are proposing.
Please do not approve this very dangerous and costly plan.
Thank you, Christopher Bliss Newport Mooring Association.
Please see the attached images.
This is how mooring field “C” looks today. It is a safe, functioning mooring field.
"C" Mooring field January, 2025 A This is How Mooring Field “C” could look after moving the existing moorings and straightening up the rows.
There is ample room between boats for safe navigation, and it addresses the City's concerns for "Aesthetics”. Cost: $25,000 - $30,000 Realignment of existing moorings Projected cost: $25 K - $30 K This is the proposed dangerous plan by the City. 2 boats to a mooring, with very limited room for safe navigation. None of the dangers of strong currents and wind conditions have been addressed.
Cost:$472,781 Existing Mooring Mooring Rows 30' 35' Row Fairway 40' 45' 50' New Mooring Lorem Ipsum 55' New 60' 65' April 2024 Eelgrass 70' 75' 80' 90' 95' 60° 40° 80 35 60 35 65 Feet Proposed Configuration and Eelgrass Cover Projected Cost: $472.781 1191' 60 40' 20' 40 60' 40' 20 40 60 45 20 45' 75 50° 20' 50° 82' 55' 20' 65° 100' 40 40 40 35 130 40 40 40 45 45 50 50 55 65 45 45 30 50 55 60 40 40 45 45 50 60 50 40 40 40 40 45 45 45 50 50 60 40 40 40 40 45 45 Mooring Field C 50 55 EDGEWAT 5-23-0753 City of Newport Beach Exhibit 3 Page 2 of 2 Ma O Outlook FW: Newport Moorings Date Mon 1/27/2025 12:40 PM To
ooring Field C 50 55 EDGEWAT 5-23-0753 City of Newport Beach Exhibit 3 Page 2 of 2 Ma O Outlook FW: Newport Moorings Date Mon 1/27/2025 12:40 PM To Sent: Monday, January 27, 2025 8:23 AM Subject: Newport Moorings Good Morning I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore
an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Charles Bloemen 949 220 4689 O Outlook FW: Newport Harbor Mooring Item Date Mon 1/27/2025 1:55 PM To Sent: Monday, January 27, 2025 1:51 PM
025 1:55 PM To Sent: Monday, January 27, 2025 1:51 PM Subject: Newport Harbor Mooring Item Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to
s as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Paul Bopp O Outlook FW: Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 523-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 12:37 PM To Sent: Monday, January 27, 2025 10:00 AM Subject: Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753
t> Sent: Monday, January 27, 2025 10:00 AM Subject: Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to
s as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Dale Bowman O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 12:41 PM Sent: Monday, January 27, 2025 6:30 AM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach)
Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to
s as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Christopher Bridge O Outlook FW: Newport Beach Moorings. Public Comment on February 2025 Application No. 5 23-0753 (City of Newport Beach Date Mon 1/27/2025 12:38 PM To Sent: Monday, January 27, 2025 9:44 AM Subject: Newport Beach Moorings. Public Comment on February 2025 Application No. 5 23-0753 (City of Newport Beach [email protected]
9:44 AM Subject: Newport Beach Moorings. Public Comment on February 2025 Application No. 5 23-0753 (City of Newport Beach [email protected] Subject: Public Comment on February 2025 Agenda Item Wednesday 16b Application No. 523-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-230753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Recent wind events and resultant damage to moored boats illustrates the danger of moving vessels closer together.
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3),
al mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, James M. Carmack O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 12:38 PM To
pplication No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 12:38 PM To Sent: Monday, January 27, 2025 9:32 AM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 523-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue
ders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, L. Ashton Chase 843-817-5575 Spelling courtesy of my iPhone O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753
affordable and safe access.
Sincerely, L. Ashton Chase 843-817-5575 Spelling courtesy of my iPhone O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Wed 1/29/2025 12:41 PM To Sent: Wednesday, January 29, 2025 12:35 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in
onsidering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Reagan Clemens O Outlook
rrently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Reagan Clemens O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Wed 1/29/2025 12:41 PM Sent: Wednesday, January 29, 2025 12:34 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders
rectly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Anne Clemens O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 12:41 PM To Sent: Monday, January 27, 2025 6:47 AM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders
rectly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENYCDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the
.
I respectfully urge the California Coastal Commission to DENYCDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Jonathan Cohen 401 Bay Front Get Outlook for iOS O Outlook FW: Public Comment on February 2025 Agenda Item Date Mon 1/27/2025 12:39 PM To Sent: Monday, January 27, 2025 9:28 AM Subject: Public Comment on February 2025 Agenda Item Subject: Wednesday 16b - Application No. 523-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders
rectly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Tal cohen SMD® Atlantic Wholesalers west Inc., 4701 Whittier Blvd, Los Angeles CA 90022 Tel: 562-912-1367 Email:[email protected] Website: www.smd.lighting Wechat Id: tccohen contact: TC cell: 562-777-7717 A B2B supplier O Outlook FW: City of Newport Beach Is Becoming Dictorial Date Mon 2/3/2025 8:51 AM To Sent: Friday, January 31, 2025 11:29 PM Subject: City of Newport Beach Is Becoming Dictorial Dear Coastal Commission, I have been boating for 60 years and have spent the last 25 years in Newport Harbor. What the Newport Harbor Commission and City Council have put myself and so many other average middle class boaters through over the past few years has definitely stressed out many of the long time boating community. They have gone far beyond their fiduciary responsibility to make boating safe and enjoyable and affordable. Imagine there was a point in time approximately one year ago, when the Harbor Commission came up with a pricing schedule to quadruple the Mooring Rates for permit holders.
Back to the subject of the double row idea of anchoring boats in the C field. It is unnecessary unwanted and unsafe. And unconventional. It's not necessary for this system be in a recreational mooring field.
the subject of the double row idea of anchoring boats in the C field. It is unnecessary unwanted and unsafe. And unconventional. It's not necessary for this system be in a recreational mooring field.
I know that the California Coastal Commission is doing an intensive study on the past performance of the City of Newport Beach as it relates to the operation and oversight of the Newport Harbor. Several years ago, after the city created its own Harbor Department and found that it was developed to a point where it was operating at a $2 million a year loss, they came up with the scheme to recover as much of those dollars spent, from the Mooring Permit holders in Newport Beach Harbor. I am retired and live on a fixed income and it took me many many years to be able to afford a boat and the mooring to enjoy sailing in Newport Harbor and Coastal California. Do the right thing and rein in this power grab that the elected and appointed politicians in Newport Beach have been trying to establish. Thank you.
Ronald Costabile Mooring Permittee. A - 285 I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce coastal access for ordinary boaters, older boaters, and those with mobility challenges.
ns like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce coastal access for ordinary boaters, older boaters, and those with mobility challenges.
Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, and the use of specialized hydraulic installation equipment, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional and time tested. The City has not performed a proper alternative Harbor Engineering analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already over crowded mooring fields, rather than first converting spacious "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential
" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough Harbor Engineering Safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Ronald Costabile O Outlook FW: Newport Beach Moorings Date Fri 1/31/2025 2:10 PM To Sent: Friday, January 31, 2025 1:45 PM Subject: Newport Beach Moorings Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-230753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the
inds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
nd consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Greg Crow O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 Date Fri 1/31/2025 7:58 AM To Sent: Friday, January 31, 2025 7:18 AM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 Dear Coastal Commissioners, A very short (under 3 minutes) educational video on the Helical Anchor System with conservation buoy.
eco-mooring SYSTEM The Eco-mooring System Demonstration Video youtu.be Sincerely, Scott Cunningham Chair Harbor Commission O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 Date Fri 1/31/2025 7:57 AM To Sent: Friday, January 31, 2025 5:53 AM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 Dear Coastal Commissioners,
anuary 31, 2025 5:53 AM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 Dear Coastal Commissioners, I am writing in support of staff's recommendation to approve the City of Newport Beach's application for Coastal Development Permit 5-23-0753.
This application is a pilot program that is intended to be replicated throughout the harbor. The goal is to create significantly more open water for the 2.6 million annual users while enhancing safety.
As an 8-year Harbor Commissioner, I often hear concerns about the dangerous mix of swimmers and human-powered crafts (SUPs, kayaks, rowers, sailors) with powerboats. This plan will substantially increase the water channels around Balboa Island and the Balboa Peninsula-critical areas that are used in our annual Christmas Boat Parade. The Open Water Initiative will dramatically improve safety and navigation in these narrow, tight shoreline channels.
Over the past few years, we've held many public meetings to gather input. Some strong opinions have emerged, particularly about whether areas within the mooring fields should be open to public use. It is true that navigating through these fields can be perilous, as they have been neglected for decades.
The current mooring fields are like a Walmart parking lot—there are no defined lanes or organized spaces. This program will create wide fairways and organized rows, opening up a tremendous amount of water space for all users of the harbor.
As you know, we can't move the Balboa Peninsula further out into the Pacific, nor can we shrink Balboa Island. But with this initiative, we can make better use of the water we have today, increasing available
now, we can't move the Balboa Peninsula further out into the Pacific, nor can we shrink Balboa Island. But with this initiative, we can make better use of the water we have today, increasing available space for recreational boating, adding over 50 lower-cost moorings, and creating a safer, more accessible environment for the public to enjoy.
Thank you for considering this important project. I strongly urge you to approve the application.
Sincerely, Scott Cunningham Chair Harbor Commission O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Tue 1/28/2025 9:25 AM To Sent: Monday, January 27, 2025 8:22 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will
ime and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve lowcost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency.
This approach gives the impression that the City may be granting preferential treatment to the
mooring fields into more space-efficient configurations, raises concerns about fairness and consistency.
This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Keith Doolittle O Outlook FW: Date Fri 1/31/2025 11:32 AM To Sent: Friday, January 31, 2025 11:19 AM Subject: Send to: [email protected] Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 523-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks
s like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve lowcost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency.
This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
nd consistency.
This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Stu Douglas O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 3:01 PM To Sent: Monday, January 27, 2025 2:54 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual
collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point
ds into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Anthony Fedoryk Sent from my iPhone O Outlook FW: Application No. 5-23-0753 Date Mon 1/27/2025 2:40 PM To Sent: Monday, January 27, 2025 1:47 PM Subject: Application No. 5-23-0753 Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 523-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual
collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point
ds into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Captain Joseph Feese President Paradiso Charters Inc.
[email protected] Get Outlook for iOS O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 12:39 PM To Sent: Monday, January 27, 2025 9:24 AM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like
pace available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve lowcost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency.
already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency.
This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, John Forester O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-,23-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 12:36 PM To Sent: Monday, January 27, 2025 11:24 AM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-,23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, We are writing to express our concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. We urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds
s to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs.
Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This
dy compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
We respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Keith and Cheryl Garrison Mooring Holder O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 12:36 PM Sent: Monday, January 27, 2025 12:01 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 (City of Newport Beach, Newport Beach) I thought this matter, was discussed and thought to not be a good system. This double sided deal will make it much harder to negotiate and navigate when bringing your boat in and out. I have an older slow moving SailboAt, with the current being a factor I think there'd be many more Insurance claims. I believe this would not be a benefit to me or those around me. If you need further discussion on my position. I am available to discuss it at any time. Thank you.
O Outlook
any more Insurance claims. I believe this would not be a benefit to me or those around me. If you need further discussion on my position. I am available to discuss it at any time. Thank you.
O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 6:50 PM To Sent: Monday, January 27, 2025 5:13 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in
onsidering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Tim Geiman O Outlook
t currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Tim Geiman O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 12:39 PM To Sent: Monday, January 27, 2025 8:48 AM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders
rectly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent.
This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings asaffordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or singlepointmooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal
per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Gary George Gary George | President GGC: www.georgegeneral.com GEORGE GENERAL CONTRACTING, INC [email protected] O Outlook FW: Moorings Coastal Development Permit (CDP) 5-23-0753 Date Mon 2/3/2025 8:52 AM To Sent: Monday, February 3, 2025 8:35 AM Subject: Moorings Coastal Development Permit (CDP) 5-23-0753 Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
ose with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands
ment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Janet Griebel Newport Beach Resident and Mooring Owner O Outlook FW: Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5Date Mon 1/27/2025 2:39 PM Sent: Monday, January 27, 2025 2:32 PM Subject: Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access
will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve lowcost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency.
This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently
l treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Regards, Steve Guzowski 114 Collins Ave Newport Beach, CA 92662 (949) 285-6950 [email protected] To: California Coastal Commission From: Capt. James L. Haley 79 Dapplegray Lane Palos Verdes Peninsula, Ca. 90274 Capt. Christian Hempstead 222 Dena Lane Chimacum, WA 98325 January 31, 2025 Subject: Comment on proposed changes to Mooring field "C" in Newport Harbor Capt. James L. Haley & Capt. Christian Hempstead Dear California Coastal Commission: We have been asked by the Newport Mooring Association to give our expert opinions on the proposals contained in the staff report for the pilot test of the proposed double mooring field layout. We have reviewed the report of oceanographer Dr. Bart Chadwick and the report of Noble Consultants.
It is our opinion that the current proposal to change mooring field "C" from its current configuration to the proposed double row configuration is ill conceived. This would reduce the existing safe maneuvering space available to each boat and would create a much greater risk of collision and injury.
In our opinion, the proposed layout would produce a less safe usage of the mooring arrangement for the following reasons: • Boaters often need to abort approaches to moorings due to wind and current • The proposal will eliminate the safest escape route to abort a mooring approach, which is by powering ahead, offering greater control over the vessel
t approaches to moorings due to wind and current • The proposal will eliminate the safest escape route to abort a mooring approach, which is by powering ahead, offering greater control over the vessel • Aborting an approach by backing away from moorings offers little control and increases collision risks We consider that the present proposal will increase the difficulty of approaching or departing any mooring with less than the existing safe distances in Newport Harbor. The present proposal is a grossly flawed plan in concept and will render any mooring field that is so configured less safe, less desirable and less valuable to the boating public.
The majority of sail vessels and many power boats have a single engine and thus have very limited steering or maneuverability when approaching or departing a mooring at slow speeds. Unpredictable wind changes and strong tidal currents often force mariners to abort approaches or correct for unanticipated effects of wind and/or current. The existing single row mooring configuration provides ample space ahead of each mooring to abort approaches or make course corrections.
The America's Cup Harbor arrangement -has been offered as an example. However, it is not comparable to Newport for two very important reasons, namely, wind and tidal current. First, America's Cup Harbor has almost no tidal current. In Newport, the tidal currents are significant, frequently exceeding 3 knots.
Secondly, America's Cup Harbor is shielded from wind by the topography of Point Loma and protected from tidal currents by virtue of being land locked on three sides. Newport, by contrast, is surrounded by low land masses that do little to protect the mooring fields from prevailing winds and tidal currents that
urrents by virtue of being land locked on three sides. Newport, by contrast, is surrounded by low land masses that do little to protect the mooring fields from prevailing winds and tidal currents that frequently create very challenging boat handling conditions.
The Noble Consultants report that we reviewed specifically states: “Disclaimer - The mooring layout and anchor spacing for this project was not conceived or endorsed by Noble Consultants, Inc. nor its staff Engineers” (page 2). Of even greater concern is that the report is completely silent on the dynamic forces of wind, current or their impact on maneuvering to and from moorings. Presumably seamanship and boat handling considerations are outside the scope of Noble's engineers' expertise, but they are the primary concern to mooring permittees and must not be glossed over or ignored.
The proposed ill-conceived five-year trial of a double row configuration in mooring field “C”, puts all the risks of property damage and/or injury unfairly on the current permittees, and should be rejected as an affront to public safety and an attack on the publics' access to a priceless feature of the California Coast.
Any changes to the existing mooring arrangement that have served the boating community quite well for decades should be given the most serious consideration to the input of the present permittees.
Their experience is the best source of knowledge about what works and what will create problems for them, their fellow boaters and future users of the moorings.
Please feel free to call me (J. Haley) with any questions at (928) 713-6277 Sincerely, 4 Capt. James Haley: I have held a US Coast Guard License as Master Mariner since 1982, including First Class Pilotage,
feel free to call me (J. Haley) with any questions at (928) 713-6277 Sincerely, 4 Capt. James Haley: I have held a US Coast Guard License as Master Mariner since 1982, including First Class Pilotage, Unlimited Tonnage in Los Angeles and Long Beach harbors and been employed as a pilot in the Port of Long Beach for 32 years. I have been admitted and given testimony as an expert in numerous State and Federal courts as an expert in ship handling and navigation. I have also been a recreational sail and power boat owner since childhood and a frequent user of moorings in Southern California.
Sincerely, Chist Hempsted Capt. Christian Hempstead Since the late 1960's, I have been on the water. By 1980 I had 2 year's sea time on tugs, ferries, crew boats and tour boats on the Great Lakes, bays, sounds, rivers, coastal, and oceans as wiper, deckhand and as 100t Operator. By 2000, I had sailed deep sea on large tankers of all types advancing to Master Mariner Unlimited. Since then, I have worked ashore as a USCG-certified trainer, the originator of STCW ECDIS training and as a full professor at the US Merchant Marine Academy, earning a USCG Commendation and serving on NAVSAC. In 2013, I began my simulator-based training and consulting business with clients in many states and countries. I have provided expert witness services on several prominent maritime cases. My courses include the development of maneuvering skills on small and midsized vessels in confined conditions.
O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 2:40 PM To
Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 2:40 PM To Sent: Monday, January 27, 2025 1:28 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport
olders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, lan Harvey.
O Outlook FW: Newport Beach Mooring changes Date Mon 1/27/2025 12:40 PM To
port Beach Mooring changes Date Mon 1/27/2025 12:40 PM To Sent: Monday, January 27, 2025 7:17 AM Subject: Newport Beach Mooring changes Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions
ort Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve lowcost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency.
This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Gary Humphreys O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Tue 1/28/2025 4:11 PM To Sent: Tuesday, January 28, 2025 4:09 PM
2025 4:11 PM To Sent: Tuesday, January 28, 2025 4:09 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. While I am supportive of improving boater access to the harbor, environmental condition of the bay, and the long term sustainability of the public moorings, I am concerned with a number of items in the application that are either at odds with the stated goals, not driven by data or supported as interventions, or likely to disproportionately impact harbor users that rely on affordable access. I urge you to carefully consider the following points before making a decision: 1. Navigation and Vessel Safety Concerns In the "C Field", the proposed changes would locate moorings close together and reduce the space available for safe navigation. This loss of space reduces reaction time and increases the risk of collisions and injuries. Of note are the tidal and estuarine currents that influence this location, often in complex juxtaposition with wind. It is currently a challenge for many boaters to safely use the mooring systems in Newport Harbor and the loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues.
Additionally, the helical anchors utilized in a dual anchor system, identified in the application, have not been evaluated in the context of their specific use (as dual-end anchors of multiple vessels) or
tionally, the helical anchors utilized in a dual anchor system, identified in the application, have not been evaluated in the context of their specific use (as dual-end anchors of multiple vessels) or assessed associated with the vectors produced by the two predictable, major extreme wind conditions. I have concern that the system will sufficiently maintain its capacity for a mooring field in close quarters holding a large number of boats in a small field with nearby dockage (with additional vessels) and significant financial loss given any mooring failure. Our extreme wind events occur following major frontal storms (producing southerly winds) and associated with so-called Santa Ana events (producing Northeasterly winds). The current anchor systems maintain functioning through these events and the rare events of property damage are mostly associated with tackle failure. But the new design raises concern. These wind directions are near perpendicular with the mooring alignment.
Engineering studies on these anchors provided during public discussion by the city appear to have been evaluated in the context of a single anchor holding a vessel with bow to the wind. Shear pressure on vessels with significant windage held with a new anchor system in a double-vessel setting presents the opportunity for catastrophic failure and the lack of specific analysis associated with this case gives me pause. At minimum an engineering analysis of the specific design in the context of these known stressors should be explicitly required.
The above two issues create risks that directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs.
2. Unnecessary Financial Burdens Placed on Mooring Holders
that directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs.
2. Unnecessary Financial Burdens Placed on Mooring Holders The project's reliance on costly helical anchors, along with requirements for what appears to be all mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes a significant financial burden on this user group. It also sets a worrisome precedent for other areas and user groups in the bay. The argument for this change of anchor systems appears to be that the current anchor systems are an environmental contaminant risk. This doesn't follow common knowledge or available data - the mooring consultant approved by the City to maintain and install mooring anchors has a standard practice of power washing potential contaminants from the anchors, and/or has not used the described potentially contaminant materials in years. But more importantly, there is no material data demonstrating any concern, especially with metal contaminants from these potential sources in the bay. Indeed, the California Regional Water Quality Control Board for the Santa Ana Region has published the results of decades of monitoring that demonstrates a continued decline in any contaminant in the harbor, except copper, which we know is associated with vessel bottom paint practices that can be mitigated in other ways (see Santa Ana Water Board Staff Report, October 25, 2022).
As such, this component of the application conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis, Alternative Solutions, and Additional Issues
Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis, Alternative Solutions, and Additional Issues I continually am concerned about how the City is tackling the shared goal of increasing the access of moorings to more boat owners. I understand that the realignment plan associated with Mooring Field C is in part to reduce the mooring footprint and increase the number of moorings that can be offered.
At the same time, I am concerned that there are more straightforward, easy, pragmatic, and effective ways to bring more boats to the moorings, that require neither significant financial burden to individuals or Coastal Development Permits. For example, casual observation of the mooring fields with aerial imagery repeatedly identified ~30% vacant moorings, lasting extended periods (months to years; Google Earth imagery). The City currently has the authority to reassign permits to individuals not using their mooring for extended periods. A simple, cost-effective mechanism to bring more affordable access to the harbor is to encourage/facilitate the transfer of those mooring permits to new individuals. Why this first level intervention has not been employed, but elaborate redesigns requiring Coastal Development Permits are proposed is concerning and not an effective means for moving forward on what is a shared goal.
I respectfully urge the California Coastal Commission to address the issues I raise above prior to moving forward with CDP 5-23-0753, especially in its current form.
Sincerely, Travis E. Huxman O Outlook FW: Newport Beach moorings Date Tue 1/28/2025 9:22 AM
Sincerely, Travis E. Huxman O Outlook FW: Newport Beach moorings Date Tue 1/28/2025 9:22 AM Sent: Tuesday, January 28, 2025 5:55 AM Subject: Newport Beach moorings Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
ets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Matthew Ippolito O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5Date Mon 1/27/2025 12:40 PM Sent: Monday, January 27, 2025 8:11 AM
Date Mon 1/27/2025 12:40 PM Sent: Monday, January 27, 2025 8:11 AM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions
ort Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve lowcost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency.
This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Richard Jacks Mooring B43 [email protected] 949.335.2324 O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 12:41 PM Sent: Monday, January 27, 2025 6:43 AM
Date Mon 1/27/2025 12:41 PM Sent: Monday, January 27, 2025 6:43 AM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following 4 points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
ets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve lowcost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency.
This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Michael Jarvis O Outlook FW: Agenda 16 b Date Mon 1/27/2025 4:00 PM To Sent: Monday, January 27, 2025 4:00 PM Subject: Agenda 16 b Beach) Dear Coastal Commission,
Sent: Monday, January 27, 2025 4:00 PM Subject: Agenda 16 b Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to
s as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely Desi Jones Andrea Bill Sudarka J 49 O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Tue 1/28/2025 1:11 PM To Sent: Tuesday, January 28, 2025 12:00 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of
> Sent: Tuesday, January 28, 2025 12:00 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
ets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan.
Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more spaceefficient configurations, raises concerns about fairness and consistency.
This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 523-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Jeff Jordan O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 12:40 PM To Sent: Monday, January 27, 2025 7:57 AM
Date Mon 1/27/2025 12:40 PM To Sent: Monday, January 27, 2025 7:57 AM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
ets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Hartman King O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Wed 1/29/2025 8:14 AM To Sent: Tuesday, January 28, 2025 11:28 PM
Date Wed 1/29/2025 8:14 AM To Sent: Tuesday, January 28, 2025 11:28 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
ets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Peter Kinney Peter Kinney (949)735-9582 - Cell [email protected] [email protected] O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 City of Newport Beach Date Thu 1/30/2025 1:29 PM
ity of Newport Beach Date Thu 1/30/2025 1:29 PM Sent: Thursday, January 30, 2025 12:02 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 City of Newport Beach Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent.
This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which
ring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent.
This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or singlepoint mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Robert Kinney Alcom Marine Electronics Alcom Marine Electronics 711 West 17th Street Unit C12 Costa Mesa, California 92627 949 515 1727 office 949 279 5048 mobile O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach)
sa, California 92627 949 515 1727 office 949 279 5048 mobile O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Wed 1/29/2025 8:14 AM To Sent: Wednesday, January 29, 2025 7:56 AM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. If the moorings had been closer together on January 7, 2025 our boat would have been severely damaged by the boat next to us that broke loose from its stern mooring. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders
rectly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Gratefully, Cathy Kinney O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 12:39 PM Sent: Monday, January 27, 2025 8:45 AM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-230753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders
rectly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better
significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Josh and Stephanie LaGatta 136 Topaz NB CA home owner Mooring N-050 Sent from AT&T Yahoo Mail for iPhone O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 12:41 PM To Sent: Monday, January 27, 2025 5:58 AM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California
occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
nd consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Chris LaMorte O Outlook FW: Coastal Development Permit (CDP) 5-23-0753 Date Mon 1/27/2025 12:41 PM To Sent: Monday, January 27, 2025 7:10 AM Subject: Coastal Development Permit (CDP) 5-23-0753 Coastal Commission, I have concerns about Coastal Development Permit (CDP) 5-23-0753, relating to the mooring fields in Newport Harbor.
The proposed changes would put moorings closer together, reducing the space available for boaters to safely maneuver their vessels, especially with strong currents or winds, which occur frequently in Newport Harbor.
The project requires costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent.
The current system in Field C is fine. It doesn't appear the City has performed a proper alternative analysis to its dangerous "double-row" plan.
Prioritizing the densification of already compact single-row mooring fields, rather than first converting
ppear the City has performed a proper alternative analysis to its dangerous "double-row" plan.
Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency.
Please DENY CDP 5-23-0753 and suggest a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Judith Lang O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 12:38 PM To Sent: Monday, January 27, 2025 9:40 AM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual
collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point
ds into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Kaj Lea California State Lands Commission 100 Howe Avenue, Suite 100 South Sacramento, CA. 95825 January 26, 2025 [email protected] [email protected] Re: California State Lands Commission (CSLC) Review of the City of Newport Beach's management of state public trust lands consistent with its statutory trust grant, the Public Trust Doctrine, and the California Constitution as it relates to setting rates for the Newport Harbor mooring fields, and CDP 5-23-0753.
Good day all, On Oct. 9, 2024, the California State Lands Commission Executive Officer, provided a briefing to the California Coastal Commission (CCC) on these matters.
During that agenda item, speaking about the CSLC, the Executive Director of the CCC stated: "❝ ...we were collectively pleased that the City opted to pause its consideration of
(CCC) on these matters.
During that agenda item, speaking about the CSLC, the Executive Director of the CCC stated: "❝ ...we were collectively pleased that the City opted to pause its consideration of mooring rate increases and rule changes while the State Lands Commission conducts a review of the City's management of its granted public trust lands."
The CCC Meeting calendar for Feb. 5, 2025, under Agenda Item 16 b. "Coastal Permit Applications", identifies the following: b. Application No. 5-23-0753 (City of Newport Beach, Newport Beach) Application by the City of Newport Beach to reconfigure one mooring field from single-row to double-row moorings, resulting in an increase from 55 moorings to 62 moorings, install conservation buoys, and replace existing anchor tackle with helical anchor tackle at mooring field C in the coastal waters of Newport Harbor, Orange County. (JP-LB) Submit Comment This CDP proposes various, substantial changes relating to both rates and rules, during a time that these things are under review, and hopefully the watchful eye of the CSLC, CCC, et al. As the City has been inclined to do, this CDP proposes burdening Mooring Permittees with added and/or unnecessary expense, and doing so absent of data. It proposes increasing by up to 7, the number of "shortterm", high-cost "City owned" Mooring Licenses, which are fee assessed at the problematic rates. Rates, that the CSLC Executive Officer described as having "discrepancies", and those being "really appalling". (16 Mooring Licenses already exist, as of 01/15/2025). The CDP process was not undergone for the creation of any of these City Owned “Licenses", a vastly different mooring option in regulatory aspects, in length of term, in rate and rate increase structure, etc., etc.
ss was not undergone for the creation of any of these City Owned “Licenses", a vastly different mooring option in regulatory aspects, in length of term, in rate and rate increase structure, etc., etc.
Given the very short amount of time before CPD 5-23-0753 is to be heard by the CCC, I ask for immediate determination from CSLC and CCC Commissioners and Management, if the City pushing this CPD forward during the "Review" process, is in good faith, and/or complies/upholds/comports with both the CSLS, and CCC's stated belief and desire, that the City had agreed to pause? ... This does not look like a pause to numerous stakeholders.
Sincerely, Adam Levens everand Adam Leverenz [email protected] To: California Coastal Commission 455 Market Street Suite 300 San Francisco, CA. 94105 January 31, 2025 Re: W16b - CDP Application No. 5-23-0753, for a project located in Newport Beach, California.
Good day Commissioners, Coastal's Staff Report for this agenda item of February 5, 2025, indicates reliance on statements made by the City of Newport Beach. One of these, is directly below: 66 .... the City has estimated that a replacement anchor weight would cost approximately $120 per ton and $700 to $800 for service per anchor."
Regrettably, I have found that statements made by the City, often seem to offer opinions favorable to City goals, rather than fact-based conclusions. This to be further addressed.
service per anchor."
Regrettably, I have found that statements made by the City, often seem to offer opinions favorable to City goals, rather than fact-based conclusions. This to be further addressed.
Inquiries about replacement anchor weight costs to the predominant mooring service provider in Newport, do not closely align with what the City has "estimated” these costs to be. Approximately a $1.00 per pound is the mooring servicer's estimated cost for replacement weights. This equates to $2,000 per ton, not the City indicated $120. The total cost to replace weights on a 50' mooring, was estimated by the servicer, to be in the vicinity of $5,000.
It was also relayed, that this servicer has not used engine blocks for 15 or 20 years, and when they were used, they were steam cleaned prior to placement. Train car wheels, were indicated as coming to the mooring servicer “clean”. This mooring servicer also said that replacement of anchor weights was not needed, but that he could get rich on it.
Given the variations in estimates, and given the loss of access that will occur with the City imposing their mooring weight substitution condition on people unable to pay, The City must be required to provide hard data on all associated costs with their proposal, and identify the vendors/contactors to be used.
This data to include, but not be limited to: A verifiable written estimate for mooring weight acquisition costs, to include any associated tackle/hardware, and transport and placement expenses.
A verifiable written estimate for mooring weight disposal costs, to include transport, and identifying approved location(s) to be disposed of.
Identification of who will be responsible for these costs.
If Permittees are to bear costs associated with the unwilling replacement of their
t, and identifying approved location(s) to be disposed of.
Identification of who will be responsible for these costs.
If Permittees are to bear costs associated with the unwilling replacement of their established, long-term, and functional mooring weights, a plan to assist Permittees who cannot immediately afford these expenses, and who would be at risk of losing access, due to an inability to pay.
The plan to be used for the relocation of vessels in the C Mooring Field, while their locations are being re-aligned, including any possible costs.
Identification of any additional/ancillary expenses which may be reasonably expected, based on verified consultations, and or data from qualified vendors/contractors/etc.
During the Newport Beach Harbor Commission Meeting of November 13, 2024, a City Staff Report, and the Harbormaster, presented a rather glowing over-view of City plans for the "Conversion to Helical Anchor Systems for Moorings". This report, and associated deliberation, mentioned sources, reports, studies, etc. As these were not included with the City's Staff Report, a Public Records Request was submitted to obtain said materials. The response to that Request produced very little, seeming to indicate a lack of factual data to support City contentions. An accurate and fair analysis on these matters, absent of data and references, and only based upon things the City has estimated, or said, would be a flawed analysis. Coastal should not acquiesce to this.
Thank you.
Adam Levenan everens Adam Leverenz [email protected] Enclosures: PRAR Request re: Harbor Commission 11/13/2024 Agenda Item 6.4 −2 pgs.
City Notice of Decision to PRAR - 12/16/2024 3 pgs.
Documents City included with Notice of Decision 3 pgs.
hotmail.com Enclosures: PRAR Request re: Harbor Commission 11/13/2024 Agenda Item 6.4 −2 pgs.
City Notice of Decision to PRAR - 12/16/2024 3 pgs.
Documents City included with Notice of Decision 3 pgs.
Harbor Commission 11/13/2024 Agenda Item 6.4 Staff Report 4 pgs.
CITY O NEWPORT CALIFORNIA TO: FROM: BEACH CITY OF NEWPORT BEACH Harbor Commission Staff Report HARBOR COMMISSION Paul Blank, Harbormaster - (949) 270-8158, [email protected] November 13, 2024 Agenda Item No. 6.4 TITLE: Report on Conversion to Helical Anchor System for Moorings "FUNDING REQUIREMENTS: There is no fiscal impact related to this item as converting three moorings to the helical anchor system is within the current budget for the required, semi-annual inspection and maintenance of moorings for which the City is responsible."
What costs will be incurred related to removal and disposal of the existing mooring weights/tackle?
How, and where will these things be disposed of?
"Traditional mooring tackle, such as chains and weights, has long been the industry standard."
Please define what the Harbor Commission/Harbormaster/City define as "Traditional mooring tackle" as stated above, and "non-traditional methods" as stated by Harbor Commissioner Gary Williams during the Harbor Commission meeting of 11/13/2024.
"According to several sources, helical anchors provide a more secure and reliable mooring solution."
Please identify these "several sources", and data relied upon for the above statement.
"Additionally, helical anchors are reportedly easier to install and require less maintenance than traditional weight and chain systems. This can lead to reduced operating and maintenance costs for the city of Newport Beach, making the overall mooring system more cost-effective in the long term."
n traditional weight and chain systems. This can lead to reduced operating and maintenance costs for the city of Newport Beach, making the overall mooring system more cost-effective in the long term."
Please provide the report(s) and data relied upon for the above statements, to include identification of their sources.
"Studies have shown that helical anchors can provide up to 40% more holding capacity compared to traditional anchor systems of the same size."
Please provide the "Studies" and sources referenced in the above statement, to include data used, "Reduced Maintenance Requirements Unlike traditional anchor systems that can be susceptible to corrosion, wear, and damage, helical anchors have a more durable construction that often requires less frequent inspection and maintenance. This can lead to reduced operational costs and downtime associated with mooring system maintenance."
Please identify the source(s) and data relied on for the above statements.
"A component of the proposed pilot project involves testing the implemented anchors for holding capacity with loads above those considered extreme."
Please provide details on the method, means, testing process(es), standards, etc., to be met, and vender(s) to be used for said "testing".
"Estimated Cost for Proposed Pilot Project The engineer's estimate of probable cost for the three mooring pilot program in the C field is $43,037.50 and includes: Mobilization for the contractor Equipment including the anchor, elastic system, and floats Installation Pull tests on 50% of the anchors Contingency Contractor overhead " Please provide the itemized engineer's estimate for any/all associated expenses.
"The estimated costs are higher than those for simply inspecting and replacing the
rs Contingency Contractor overhead " Please provide the itemized engineer's estimate for any/all associated expenses.
"The estimated costs are higher than those for simply inspecting and replacing the existing mooring tackle with like-for-like equipment."
Please reconcile the statement above, with the previous Staff Report statement: "There is no fiscal impact related to this item as converting three moorings to the helical anchor system is within the current budget for the required, semi-annual inspection and maintenance of moorings for which the City is responsible."
CITY NEWPORT CALIFORNIA BEACH December 16, 2024 CITY OF NEWPORT BEACH 100 Civic Center Drive Newport Beach, California 92660 949 644-3005 | 949 644-3139 FAX newportbeachca.gov/cityclerk Delivery Via Email for Ticket No. 602283 Adam Leverenz RE: CALIFORNIA PUBLIC RECORDS ACT REQUEST DATED DECEMBER 4, 2024 NOTICE OF DETERMINATION The City of Newport Beach ("City") has received and reviewed your California Public Records Act request dated December 4, 2024. This response will serve as the City's notice of determination as to whether the request in whole or part seeks the production of non-exempt, non-privileged, disclosable public records in the possession of the City, pursuant to the California Public Records Act ("Act") (Gov. Code §§ 7920.000 et seq.).
Based on your request for: "Estimated Cost for Proposed Pilot Project The engineer's estimate of probable cost for the three mooring pilot program in the C field is $43,037.50 and includes: -Mobilization for the contractor -Equipment including the anchor, elastic system, and floats -Installation -Pull tests on 50% of the anchors -Contingency -Contractor overhead Records Requested: Please provide the itemized engineer's estimate for any/all
the anchor, elastic system, and floats -Installation -Pull tests on 50% of the anchors -Contingency -Contractor overhead Records Requested: Please provide the itemized engineer's estimate for any/all associated expenses.
"Traditional mooring tackle, such as chains and weights, has long been the industry standard."
Records Requested: Please define what the Harbor Commission/Harbormaster/City define as "Traditional mooring tackle" as stated above, and "non-traditional methods" as stated by Harbor Commissioner Gary Williams during the Harbor Commission meeting of 11/13/2024.
All non-exempt, non-privileged, disclosable public records in possession of the City have been gathered and are attached to this notice hereto.
Please note that the City is not in possession of any records responsive to the below portion of your request: City Clerk's Office Adam Leverenz December 16, 2024 Page 2 Staff Report: Report on Conversion to Helical Anchor System for Moorings "FUNDING REQUIREMENTS: There is no fiscal impact related to this item as converting three moorings to the helical anchor system is within the current budget for the required, semi-annual inspection and maintenance of moorings for which the City is responsible."
Records Requested: What costs will be incurred related to removal and disposal of the existing mooring weights/tackle?
How, and where will these things be disposed of?
"According to several sources, helical anchors provide a more secure and reliable mooring solution."
Records Requested: Please identify these “several sources", and data relied upon for the above statement.
"Additionally, helical anchors are reportedly easier to install and require less maintenance than traditional weight and chain systems. This can lead to reduced
ta relied upon for the above statement.
"Additionally, helical anchors are reportedly easier to install and require less maintenance than traditional weight and chain systems. This can lead to reduced operating and maintenance costs for the city of Newport Beach, making the overall mooring system more cost-effective in the long term."
Records Requested: Please provide the report(s) and data relied upon for the above statements, to include identification of their sources.
"Studies have shown that helical anchors can provide up to 40% more holding capacity compared to traditional anchor systems of the same size."
Records Requested: Please provide the "Studies” and sources referenced in the above statement, to include data used.
"Reduced Maintenance Requirements Unlike traditional anchor systems that can be susceptible to corrosion, wear, and damage, helical anchors have a more durable construction that often requires less frequent inspection and maintenance. This can lead to reduced operational costs and downtime associated with mooring system maintenance."
Records Requested: Please identify the source(s) and data relied on for the above statements.
"A component of the proposed pilot project involves testing the implemented anchors for holding capacity with loads above those considered extreme."
Records Requested: Please provide details on the method, means, testing process(es), standards, etc., to be met, and vender(s) to be used for said "testing".
"The estimated costs are higher than those for simply inspecting and replacing the existing mooring tackle with like-for-like equipment."
Records Requested: Please reconcile the statement above, with the previous Staff Report statement: Adam Leverenz December 16, 2024 Page 3
ing the existing mooring tackle with like-for-like equipment."
Records Requested: Please reconcile the statement above, with the previous Staff Report statement: Adam Leverenz December 16, 2024 Page 3 "There is no fiscal impact related to this item as converting three moorings to the helical anchor system is within the current budget for the required, semi-annual inspection and maintenance of moorings for which the City is responsible."
Pursuant to the Public Records Act, the City shall make the records promptly available to any person, electronically and free of charge, or upon payment of fees covering direct costs of duplication, or a statutory fee if applicable. The reimbursable costs associated with your request are calculated as follows: $0.03 per page for photocopying records and/or $0.49 per CD/DVD.
If you have any further questions, please contact this office.
Sincerely, Cassandillam Cassandra Hawks Records Specialist CITY OF NEW CALIFORNIA BEACH Mooring Pennant (Attaches to boat and Mooring Shackle) Typical Mooring Design In Newport Harbor Sur-Moor™ T3C Mooring Buoy Light Chain Mushroom Anchor or block The diagram shows the typical configuration of an offshore mooring in Newport Harbor. A single two-point mooring will typically use two of the mooring configurations shown. One for the bow of the boat and one for the stern.
Galvanized Shackle Shackle & Swivel Heavy Chain Newport Beach Pilot Mooring Project Engineer's Estimate of Probable Construction Cost Item Quantity Unit Cost Units Extended Cost 1. Mobilization / Demob 1 1000 LS $ 1,000.00 2. Elastic Mooring System (Eqmt Only) 6 3000 Each $ 18,000.00 3. Helix Earth Screw Anchors (Eqmt only) 6 600 Each $ 3,600.00 4. Install Anchor and Mooring 6 1200 Each $ 7,200.00 5. Pull Test (50% of Anchors) 3 500 Each $
ystem (Eqmt Only) 6 3000 Each $ 18,000.00 3. Helix Earth Screw Anchors (Eqmt only) 6 600 Each $ 3,600.00 4. Install Anchor and Mooring 6 1200 Each $ 7,200.00 5. Pull Test (50% of Anchors) 3 500 Each $ 1,500.00 SUBTOTAL $ 31,300.00 10% Contingency $ 3,130.00 SUBTOTAL $ 34,430.00 Contractor Profit and Overhead 25% $ 8,607.50 TOTAL ESTIMATED COST $ 43,037.50 August 20, 2024 Page 1 of 1 Remarks NEWPORT CALIFORNIA CITY OF NEWPORT BEACH Harbor Commission Staff Report TO: FROM: HARBOR COMMISSION Paul Blank, Harbormaster - (949) 270-8158, [email protected] November 13, 2024 Agenda Item No. 6.4 TITLE: Report on Conversion to Helical Anchor System for Moorings ABSTRACT: The City currently has 16 moorings for which it is responsible for the semi-annual inspection and maintenance of the tackle. Interest has been expressed in potentially converting the ground tackle on these moorings from traditional weights and chains to more environmentally friendly helical anchor systems. This report will update the Commission on a pilot project to convert three City moorings in the C mooring field to the helical anchor system.
RECOMMENDATION: a) Determine this action is exempt from the California Environmental Quality Act (CEQA) pursuant to Sections 15060(c)(2) and 15060(c)(3) of the CEQA Guidelines because this action will not result in a physical change to the environment, directly or indirectly; AND b) Receive and file OR c) Recommend the Harbor Department move forward with the pilot project to convert three moorings in the C Mooring field to the helical anchor system.
FUNDING REQUIREMENTS: There is no fiscal impact related to this item as converting three moorings to the helical anchor system is within the current budget for the required, semi-annual inspection and maintenance of
MENTS: There is no fiscal impact related to this item as converting three moorings to the helical anchor system is within the current budget for the required, semi-annual inspection and maintenance of moorings for which the City is responsible.
DISCUSSION: Mooring systems play a crucial role in securing vessels and ensuring their stability and preventing drift or displacement. Traditional mooring tackle, such as chains and weights, has long been the industry standard. However, advancements in marine technology have led to the development of alternative mooring solutions, including the helical anchor system. The City is interested in exploring the potential benefits of converting from a traditional mooring tackle to a helical anchor system.
Helical anchors, also known as screw anchors or helical piles, offer several advantages over traditional weight and chain mooring systems. According to several sources, helical anchors Report on Conversion to Helical Anchor System for Moorings November 13, 2024 Page 2 provide a more secure and reliable mooring solution. Unlike weight and chain systems, which can be susceptible to dragging or shifting during severe weather conditions, helical anchors are designed to screw deeply into the seafloor, offering superior holding power and stability.
Furthermore, helical anchors have a significantly smaller footprint compared to weight and chain systems. That smaller footprint on the seafloor can be very beneficial in areas where environmental concerns, such as the presence of eelgrass need to be addressed. The installation process of helical anchors is also less disruptive to the seabed, reducing the potential impact on marine ecosystems. Helical anchor systems also reduce the risk of unsuitable materials leeching
ation process of helical anchors is also less disruptive to the seabed, reducing the potential impact on marine ecosystems. Helical anchor systems also reduce the risk of unsuitable materials leeching from the traditional weights into the water column.
Additionally, helical anchors are reportedly easier to install and require less maintenance than traditional weight and chain systems. This can lead to reduced operating and maintenance costs for the city of Newport Beach, making the overall mooring system more cost-effective in the long term.
Components of a Helical Anchor System A helical anchor system is made up of the components in the table below. Also in the table are the traditional anchor system component equivalents.
Helical Anchor System Components Traditional Anchor System Components Mooring buoy Mooring buoy Thimbles Thimbles Elastic Mooring System Light chain Submerged floats Rope or cable Heavy chain Weight Helical screw The helical anchor system components are depicted in Attachment A - Mooring Pilot Project Design. The traditional anchor system components are depicted in Attachment B - Traditional Anchor System Components.
Improved Holding Power Helical anchors are designed with a screw-like configuration that allows them to penetrate and grip the seafloor more effectively than traditional anchors. This increased holding power translates to greater stability and reduced risk of mooring failure, even in challenging seabed conditions such as soft or rocky substrates. Studies have shown that helical anchors can provide up to 40% more holding capacity compared to traditional anchor systems of the same size. The seabed in Newport Harbor has been sampled on several occasions and in several locations. Analysis of
rovide up to 40% more holding capacity compared to traditional anchor systems of the same size. The seabed in Newport Harbor has been sampled on several occasions and in several locations. Analysis of Report on Conversion to Helical Anchor System for Moorings November 13, 2024 Page 3 those samples indicates conditions well suited to the use of the helical anchor system throughout the harbor.
Reduced Footprint and Scaring on Seafloor The footprint on the seafloor of the helical anchor head, the only exposed portion of the system is significantly smaller than that of materials used as traditional anchors. The traditional anchors in use in Newport Harbor include steel wheels and gears, engine blocks, concrete blocks, concrete piles, and metal crankshafts.
The optimal hardware between the mooring float and the helical anchor in the proposed system is a cable including a group of elastic bands and submerged floats. The elasticity in the hardware means that no part of the connection between the mooring buoy and the helical anchor head will rest on the seafloor. The combination of light and heavy chains in use in the traditional anchor system means that some portion of the chain is resting on the seafloor most of the time providing the shock-absorbing capability required for shifts in tide, current, and forces acting on the mooring and moored vessel. The chain scars the seafloor as it is lifted and replaced as well as dragged laterally by the prevailing forces.
It is estimated that the ground tackle for an average mooring in the C field occupies 0.84 square meters of substrate. The proposed helical anchor tackle minimizes the substrate area occupied to an average of 0.01 square meters each. The total area of the substrate occupied by the three
.84 square meters of substrate. The proposed helical anchor tackle minimizes the substrate area occupied to an average of 0.01 square meters each. The total area of the substrate occupied by the three moorings would be reduced by 4.98 square meters through the implementation of the proposed pilot project.
Increased Versatility Helical anchors can be designed to accommodate a wide range of seabed conditions and mooring requirements. They can be customized with different helix configurations, shaft lengths, and materials to optimize performance for specific applications, making them a versatile solution compared to traditional anchor types.
Reduced Maintenance Requirements Unlike traditional anchor systems that can be susceptible to corrosion, wear, and damage, helical anchors have a more durable construction that often requires less frequent inspection and maintenance. This can lead to reduced operational costs and downtime associated with mooring system maintenance.
Traditional anchor systems are also prone to dragging in adverse conditions such as severe wind and waves. There have been a couple of notable examples of moorings dragging in recent severe weather conditions. These occurrences have resulted in significant damage to the vessel assigned to the mooring in Newport Harbor that dragged and nearby vessels. Even when damage does not result, repositioning of traditional mooring tackle can be costly, inconvenient, and dangerous. Helical anchor systems are not prone to drift or relocation in severe weather Report on Conversion to Helical Anchor System for Moorings November 13, 2024 Page 4 conditions. A component of the proposed pilot project involves testing the implemented anchors for holding capacity with loads above those considered extreme.
tem for Moorings November 13, 2024 Page 4 conditions. A component of the proposed pilot project involves testing the implemented anchors for holding capacity with loads above those considered extreme.
Estimated Cost for Proposed Pilot Project The engineer's estimate of probable cost for the three mooring pilot program in the C field is $43,037.50 and includes: Mobilization for the contractor Equipment including the anchor, elastic system, and floats Installation Pull tests on 50% of the anchors Contingency Contractor overhead The estimated costs are higher than those for simply inspecting and replacing the existing mooring tackle with like-for-like equipment. However, the long-term maintenance costs are expected to be less and the commensurate benefits to the health of the harbor including improvements to the water quality and proliferation of eelgrass should be significant.
The adoption of a helical anchor system by the city of Newport Beach could offer improved mooring security, reduced environmental impact, and lower maintenance requirements making it a compelling alternative to the traditional weight and chain mooring ground tackle.
No action is currently required from the Harbor Commission. However, the Commissioners may wish to take an affirmative position that the Harbor Department move forward with the pilot program to convert three moorings in the C mooring field to the helical anchor system as part of the regular, required semi-annual inspection and maintenance of mooring tackle.
ENVIRONMENTAL REVIEW: Staff recommends the Harbor Commission find this action is not subject to the California Environmental Quality Act (CEQA) pursuant to Sections 15060(c)(2) (the activity will not result in
NTAL REVIEW: Staff recommends the Harbor Commission find this action is not subject to the California Environmental Quality Act (CEQA) pursuant to Sections 15060(c)(2) (the activity will not result in a direct or reasonably foreseeable indirect physical change in the environment) and 15060(c)(3) (the activity is not a project as defined in Section 15378) of the CEQA Guidelines, California Code of Regulations, Title 14, Division 6, Chapter 3, because it has no potential for resulting in physical change to the environment, directly or indirectly.
NOTICING: The agenda item has been noticed according to the Brown Act (72 hours in advance of the meeting at which the Harbor Commission considers the item).
ATTACHMENTS: Attachment A - Mooring Pilot Project Design Attachment B - Traditional Anchor System Components To: California Coastal Commission 455 Market Street Suite 300 San Francisco, CA. 94105 January 21, 2025 Re: CDP Application No. 5-23-0753, for a project located in Newport Beach, California.
Good day Commissioners, Given the amount of materials I'm here (re) submitting, I'm getting them in as soon as I was able, in hopes that this will offer adequate time for their review by Commissioners, prior to the February 5th agenda item.
For a number of reasons, I feel it improper for CDP 5-23-0753 to be heard by the Coastal Commission at this time. As you know, a disparity in rates for users of the same State
ebruary 5th agenda item.
For a number of reasons, I feel it improper for CDP 5-23-0753 to be heard by the Coastal Commission at this time. As you know, a disparity in rates for users of the same State resource in Newport Beach has been noted, and the CSLC is in the process of reviewing the City's management of these granted sovereign Tide/Submerged lands. Both the State Lands and Coastal Commissions have requested the City to pause. At the meeting of the Coastal Commission on October 9, 2024, the CCC Executive Director, referencing the State Lands Commission (CSLC) stated “...we were collectively pleased that the City opted to pause its consideration of mooring rate increases and rule changes while the State Lands Commission conducts a review of the City's management of its granted public trust lands." CDP 5-23-0753 coming before the Coastal Commission now, is not a "pause", and I contend that by pushing it forward, the City is not acting in good faith.
To elaborate, the City developed it's “short-term", high-cost Mooring Licenses, 16 as of 01/15/2025, along with 7 more to be created under CDP 5-23-0753, without undergoing the CDP process for their creation. These are a vastly different mooring option, in regulatory aspects, in length of term, in rate and rate increase structure, etc. The City's apparent desire to incrementally sneak these in, absent a CDP for them, appears process out of order. Moreover, the intimate involvement of parties with pretty clear conflicts/ financial interests, is beyond problematic. The City substituting or transitioned Mooring Permits to Mooring Licenses, and/or creating new Licenses outside of Coastal's permitting process, and fee assessing them at rates the CSLC has under review, rates, which at the
r transitioned Mooring Permits to Mooring Licenses, and/or creating new Licenses outside of Coastal's permitting process, and fee assessing them at rates the CSLC has under review, rates, which at the CCC meeting of October 9, 2024, were identified by the CSLC Executive Officer as having "discrepancies", and these discrepancies being noted as "really appalling", come across as City efforts to seek Coastal's validation, prior to completion of the CSLC review.
At this point, I feel that more than adequate amounts of information and analysis have been submitted, to show the discriminatory nature of many of the City's past/present efforts, and the expense, risks, and detriments to safety and access to be borne by those selectively subjected to the outcomes. Improper things have, and continue to occur under the City of Newport Beach's management. The CSLC review of some of these matters is not even complete, yet the City presses forward with creating additional areas to be subject to the disparate rates, and the new City Mooring License rules.
The onslaught of changes the City has brought forth, are working towards a singular goal... The transitioning of coastal access in Newport, towards being even more limited to the exclusive and affluent. Multiple City efforts to drive up prices for a specific and limited group of users, and City efforts at creating expense to try and rationalize this, along with simultaneous efforts at phasing out the highly regulated liveaboard community, evidence a targeting. This onslaught has been exhausting, overwhelming, and disheartening for many.
The old saying “You can't fight City Hall” resonates.
If under these circumstances, CDP Application No. 5-23-0753 is still to be heard/acted
been exhausting, overwhelming, and disheartening for many.
The old saying “You can't fight City Hall” resonates.
If under these circumstances, CDP Application No. 5-23-0753 is still to be heard/acted upon by the Coastal Commission in February, I am attaching some items which have previously been provided Staff. I know that Staff is very busy. I am certain that Coastal Commissioners likewise, have more than enough on their plates. Given the loss of safe, affordable, and equitable access that many face though, along with the loss of housing that numerous others face, I hope that Commissioners can find an adequate amount of time to go through what's included along with this cover letter. I hope that each recognizes a systematic and wrongful pattern of local conduct/actions, which have led us to this point.
Regardless of whether or not my recently realized 15-year dream of being able to moor a boat in Newport Beach can exist in this City, you have my sincere thanks for your many efforts at protecting the Coast.
Adam Levens Adam Leverenz [email protected] Enclosures: Letter - Innovative Structural Engineering – 10/07/2024 Letter - Follow-up - Leverenz - 11/04/2024 Letter CCC Workload - Leverenz - 11/24/2024 Letter CDP Considerations – Leverenz 01/05/2025 Letter - Mooring Rent Increase - Leverenz 07/17/2024 (For that last item, please pay particular attention to the timing of City process, as related to interactions between City personnel; their favored Appraiser; and the Newport Aquatic Center.)
Innovative Structural and Specialty Engineering PLLC Mr. Jeffrey Palm California Coastal Commission Sacramento, CA 95814 [email protected] October 7, 2024 CC: Amrita Spencer (Coastal Program Manager): [email protected]
. Jeffrey Palm California Coastal Commission Sacramento, CA 95814 [email protected] October 7, 2024 CC: Amrita Spencer (Coastal Program Manager): [email protected] Karl Schwing (District Director SD and OC): [email protected] Shannan Vaughn (Coastal Program Manager): Shannon. [email protected] Mandy Revell (District Supervisor): Mandy. [email protected] Louise Warren (Chief Counsel): [email protected] Zack Rehm (District Supervisor): [email protected] Fernie Sy (Coastal Program Analyst): [email protected] Dr. Kate Hucklebridge (Executive Director): [email protected] Executivestaff: [email protected] Newport Mooring Association: [email protected] Radhi Majmudar [email protected] David Williams [email protected] Re: Newport Harbor Mooring Field C Realignment Proposal - CDP Application No 5-23-0753 Dear Mr. Palm, On behalf of the Newport Mooring Association, ISSE have reviewed the subject Application and supporting documentation and provide the following submission for your review.
Introduction Newport Harbor is a naturally protected waterway, ideally located to provide access to the California coast. For over a century, this valuable resource has supported a significant population of mariners and their watercraft. The harbor includes several mooring fields designed to offer safe, economical parking for boats with convenient access to coastal waters. For the 55 permittees of the Field C Pilot Program, coastal access fundamentally depends on having secure moorings and safe, accident-free mooring operations.
The primary function of mooring fields is not navigation, but rather to ensure safe and secure
oastal access fundamentally depends on having secure moorings and safe, accident-free mooring operations.
The primary function of mooring fields is not navigation, but rather to ensure safe and secure boat storage. Design priorities for mooring fields should focus on providing well-secured moorings that allow craft movement while withstanding adverse weather conditions and preventing collisions. Additionally, mooring fields should ensure that mariners can approach and depart their moorings safely in most weather conditions.
Innovative Structural and Specialty Engineering PLLC In fact, the Newport Harbor Mooring Fields are designated “special anchorage areas" in the Federal Register, Coast Guard Final Rule, effective May 16, 2012. Such areas "should be well removed from the fairways and located where general navigation will not endanger or be endangered by unlighted vessels”. Thus, even contemplating fairways within the mooring fields would seem to be in violation of the Coast Guard Rules.
Background The environmental conditions in “Mooring Field C” often make mooring operations challenging, with tidal currents frequently exceeding one knot and significant winds generating waves from multiple directions and additional wind-driven currents. As sea states deteriorate, the likelihood of accidents increases disproportionately. Mooring operations are particularly hazardous during severe weather conditions when the mariner's ability to control the boat is impaired by the wind, strong currents and wind-induced waves. Even under the prevailing regular West winds combined with tides, the dynamic conditions become challenging for mooring. These conditions
impaired by the wind, strong currents and wind-induced waves. Even under the prevailing regular West winds combined with tides, the dynamic conditions become challenging for mooring. These conditions directly impact the probability of accidents, especially when boats are in close proximity during mooring or departure.
The high profile of many power boats, and the windage of the rigging on many sailboats, create significant difficulties in brisk wind, even when wave action is less of an issue. Wind conditions often complicate mooring operations more than wave activity in Field C.
Comparisons between “Newport Harbor” and “America's Cup Harbor, San Diego" are not valid due to the vastly different tidal and wind conditions in each location. America's Cup Harbor is sheltered from wind, and tidal currents are negligible, making it easier to maneuver boats during mooring. Therefore, San Diego's ACH conditions are not applicable to the proposed reconfiguration of Field C, except to highlight the stark differences in sea-state challenges. In Field C, the risk of collisions increases significantly when nearby boats are closer, as reduced space for error leaves little room for drift or navigational mistakes during mooring operations.
Findings A factor contributing to the increased likelihood of accidents is the modification of established procedures that mariners have become accustomed to. When habitual mooring methods are changed, particularly under time pressure in storm conditions, human decision-making becomes more error-prone. The proposed reconfiguration for "Mooring Field C" would require permittees to adopt new mooring protocols, further increasing the potential for accidents. Any changes that
g becomes more error-prone. The proposed reconfiguration for "Mooring Field C" would require permittees to adopt new mooring protocols, further increasing the potential for accidents. Any changes that reduce the clear space between moored boats-such as increasing the density of moorings or shrinking the area of the mooring field—will amplify the probability of collisions.
One of the objectives of the reconfiguration is to create wider fairways within the mooring fields to improve navigation and optimize space utilization. However, this may have unintended consequences, such as encouraging vessels to take shortcuts through the mooring field, increasing the risk of accidents. Building a thoroughfare through a mooring field is akin to running a road through a public parking lot-it introduces unnecessary hazards by encouraging Innovative Structural and Specialty Engineering PLLC traffic in areas meant for stationary boats. This design compromises safety, particularly for mooring operations, which require space for maneuvering and securing boats in dynamic conditions.
Navigation channels outside the mooring fields should remain the primary route for vessels in transit to avoid unnecessary traffic within the mooring area. The mooring field should be protected from in-transit traffic, creating safer conditions for human-powered craft and swimmers.
The proposal to expand every other fairway at the expense of eliminating every alternate fairway further compounds the issue. Boat operators need an equal amount of fairway space in both directions to ensure various escape routes under different conditions. Reducing the
ng every alternate fairway further compounds the issue. Boat operators need an equal amount of fairway space in both directions to ensure various escape routes under different conditions. Reducing the number of fairways compromises their ability to safely maneuver, especially in dynamic sea-state conditions. (See attached 3-page visual/slide provided by NMA for reference.)
The reconfiguration, as described in Dudek's letter to the California Coastal Commission dated February 12, 2024, (Item 4, Alternative Reconfigurations) emphasizes safety for mariners in transit and the optimized use of space within the mooring field. However, the real safety concern arises during the critical offshore mooring operations when boats are most vulnerable. During transit, boats are under control with steerageway, whereas mooring operations, particularly in adverse weather conditions, pose far greater challenges, with potential loss of steerage. The Application appears to prioritize optimizing space for parked boats, similar to the layout of a car parking lot, without adequately considering the space requirements necessary for safe mooring operations.
Likewise, the City of Newport Beach Harbormaster's statement from December 7, 2023, Re Navigability, focuses on improving navigation and space optimization within the mooring fields, but fails to address the critical space needs for safe mooring. Navigation is relatively straightforward compared to the complex and hazardous process of securing a boat during offshore mooring during non-calm conditions. The reconfiguration's emphasis on fairways and aesthetics may create a visually regular arrangement, but it sacrifices the global space required for safe mooring operations, especially in adverse conditions. Aesthetics are subjective, and
ways and aesthetics may create a visually regular arrangement, but it sacrifices the global space required for safe mooring operations, especially in adverse conditions. Aesthetics are subjective, and while the proposed changes may enhance the visual appeal of the mooring field for some, they introduce additional risks by reducing the space between boats.
Additionally, any realignment that increases the density of moored boats, such as double-row mooring, further reduces the minimum space between vessels, increasing the likelihood of accidents during both mooring and routine transits to and from the field.
The Application explores different anchoring options, such as helical anchors and steel weights.
At present there is no evidence of eelgrass in Mooring Field C (2022 Eelgrass Map, Marine Taxonomic Services, Ltd). The nearest eel grass is greater than 5m distance from Field C. The submerged floating lines of “conservation moorings", though considered for environmental Innovative Structural and Specialty Engineering PLLC protection of eelgrass, pose additional hazards during mooring operations and thus should be discouraged. Although the helical anchors demonstrate considerably greater vertical pull capacity than the others, lateral cyclic prying action, from all directions, during strong wind and low tides (greatest line slackness) is likely to degrade the hold-down capacity, and could test the long-term lateral capacity. Significantly, any changing of mooring anchors is likely to disturb the sea-bed and is expected to invoke CEQA.
The maximum tidal range is +7.0' to -1.4' MLLW without storm surge. Therefore the slackness in
icantly, any changing of mooring anchors is likely to disturb the sea-bed and is expected to invoke CEQA.
The maximum tidal range is +7.0' to -1.4' MLLW without storm surge. Therefore the slackness in the mooring buoy anchor lines varies by over 8 ft, depending on tide, causing variable boat drift around the mooring site. The catenary action in the mooring tackle is crucial for absorbing dynamic loads caused by storm drift, and any reduction in scope distance during high tides will increase the hazard by amplifying impact loads on boats. This critical aspect of mooring design has not been adequately considered in the reconfiguration plan, raising concerns about the safety and practicality of the proposed changes.
Conclusion For the above reasons, fundamental to most mariners who moor in open water, we respectfully submit CDP Application No 5-23-0753 for Mooring Field C Pilot Program should be rejected in its entirety.
Sincerely, Radli Morada Innovative Structural and Specialty Engineering PLLC Radhi Majmudar PE David Williams PE Innovative Structural and Specialty Engineering PLLC Radhi Majmudar PE is a structural engineer with extensive experience in marine and coastal structural engineering, with a particular focus on design, analysis, and condition assessments of piers and underwater structures. She has led teams that performed underwater inspections to evaluate the condition of piles and other submerged components, addressing issues such as marine borer attacks and environmental wear. Based on these assessments, she provided recommendations for structural repairs
ondition of piles and other submerged components, addressing issues such as marine borer attacks and environmental wear. Based on these assessments, she provided recommendations for structural repairs and reinforcements to restore and maintain the operational safety and longevity of key coastal infrastructure.
In addition to inspections, she has experience overseeing and approving mooring engineering activities for marine projects. This includes supervising contractors on model testing, evaluating mooring strength, conducting fatigue analysis, and performing finite element analysis (FEA) to ensure the structural integrity of mooring systems. Her responsibilities also encompassed reviewing mooring and ensured that mooring systems and associated infrastructure met rigorous safety and performance standards in challenging marine environments.
She contributed to the analysis and evaluation of large offshore platforms, performing seismic assessments to understand the impact of natural forces such as earthquakes on these structures.
Utilizing advanced tools and modeling techniques, she, as part of a team, analyzed the safety, stability, and functionality of critical offshore installations, enhancing their resilience against environmental forces and extending their operational lifespan. Their work helped safeguard the long-term stability of offshore and coastal structures under dynamic and harsh marine conditions.
Furthermore, her experience includes playing a critical role in the development of major container terminals. She was involved in the design process, overseeing physical model tests and conducting computer simulations to assess the motion of moored ships, including factors like surge, sway, heave,
terminals. She was involved in the design process, overseeing physical model tests and conducting computer simulations to assess the motion of moored ships, including factors like surge, sway, heave, yaw, pitch, and roll. She also evaluated various structural design alternatives for quay walls, including gravity block walls, pile-supported platforms, and steel caissons. Their contributions helped optimize both the functionality and structural integrity of key port facilities, ensuring they were designed to handle the operational demands of international shipping routes while withstanding harsh marine conditions.
Representative Project Experience Port Salalah Container Terminal Development and Design Study, Oman, Arabian Sea Client: Sea Land Service Inc. and the Sultanate of Oman Design, Analysis, Inspection Services for Pier 35 Gowanus Bay in Brooklyn, New York Client: New York City Economic Development Corporation Design, Analysis, Inspection Services for East River Pier 13/14 Complex in Manhattan, NY Client: New York City Economic Development Corporation Design and Inspection Services for Administration and Maintenance Building -Howland Hook Marine Terminal Staten Island, NYClient: Port Authority New York and New Jersey Innovative Structural and Specialty Engineering PLLC Design, Analysis and Inspection Services for Bulkheads at Piers 1 through 5 Brooklyn, New York Client: Port Authority New York and New Jersey Design of Breakwaters and Wharf Structures Haifa Port, Israel Client: Government of Israel, Israel Port Authority Seismic Analysis of Steel Fixed Offshore Platforms Santa Ynez, California Client: Exxon Corporation
akwaters and Wharf Structures Haifa Port, Israel Client: Government of Israel, Israel Port Authority Seismic Analysis of Steel Fixed Offshore Platforms Santa Ynez, California Client: Exxon Corporation David Williams, PhD, PE, has been involved with marine infrastructure throughout his career (over five decades), primarily in the capacity of structural design, constructability, risk assessment, value engineering, safety and support of critical projects.
His experience ranges from analysis and design of large floating bridges and moored caissons, barges and ocean transport; design and assessment of flood-protection structures and retaining walls for the US Army Corps of Engineers following the Katrina hurricane (including navigation facilities through flood gates, incorporating pilot simulation results/reaction times for guide and fender arrangement); project management of a replacement floating launching pier and gangway (ADA-compliant) for a coastal inland lagoon, used for human powered craft (kayaking, rowing, canoeing, SUPs); design review of redesigned sheet-pile bulkheads and forensic engineering for a new container terminal following construction failure; to detailed design and seismic analysis of new locks for a major canal, dry dock facilities, and a shiplift; seismic retrofit of port facilities; analysis of major fixed and floating offshore structures designed for extreme storm and seismic effects in adverse environments; the first installation of large piles for over-water bridge foundations using offshore technology (from semi submersible barge cranes). He has designed and analyzed anchors and mooring systems for a variety of applications and undertaken peer review of pioneering marine engineering concepts.
ology (from semi submersible barge cranes). He has designed and analyzed anchors and mooring systems for a variety of applications and undertaken peer review of pioneering marine engineering concepts.
As such, he brings invaluable multidisciplinary experience, and familiarity with permitting coastal facilities, including stringent environmental concerns and regulations. He is familiar with extreme environments, remote sites, construction limitations due to environmental hazards and other permitting issues, bio-fouling and cold-climate engineering (obtained Alaska PE License in 2001).
His expertise and independent investigation of several hydrodynamic problems (analytical and experimental wave tank testing) has led him to provide specialist consulting on many pioneering marine and coastal projects including expert testimony before regulatory authorities regarding safety of critical infrastructure.
In addition he brings years of experience in aquatic recreation – open water, coastal and ocean sailing, open water and flatwater rowing, kayaking and white water rafting. This experience provides invaluable understanding of the variability of sea states and challenges involved in controlling and mooring boats in open water.
Proposed Double Row System with Prevailing Winds Innovative Structural and Specialty Engineering PLLC These tight quarters will not allow forward boats to take appropriate angled approach when accessing moorings, making access more difficult and less safe compared to existing configuration.
When single-handed boater unties bow line, they will immediately be blown into boat behind. This configuration does not allow for reasonable reaction time.
ess safe compared to existing configuration.
When single-handed boater unties bow line, they will immediately be blown into boat behind. This configuration does not allow for reasonable reaction time.
Innovative Structural and Specialty Engineering PLLC No room to rear-unsafe for current and winds in Newport Existing single row mooring alignment provides multiple access and departure routes depending on variable winds and currents. The proposed double row eliminates various access and departure angles.
Innovative Structural and Specialty Engineering PLLC To: California Coastal Commission 455 Market Street Suite 300 San Francisco, CA. 94105 November 4, 2024 [email protected]; Re: Meeting Follow-up, CDP #5-23-0753 for a project located at Mooring Field C, Newport Beach, California, and CSLC Granted Lands Management Review.
Dear Coastal Commission Staff, Thank you so much for the time you shared during our online meeting of October 29, 2024.
Time constraints precluded me from going into much detail on the images I'd sent as PDFs the preceding day, and this is the written follow-up I'd indicated I'd offer. For some of this, I am attempting to write in terms that may assist any unfamiliar with the intricacies of mooring boats. For those who are familiar, please take no offense at my efforts to simplify.
For some of this, I am attempting to write in terms that may assist any unfamiliar with the intricacies of mooring boats. For those who are familiar, please take no offense at my efforts to simplify.
I hope that my analogy of mooring of a boat, as being similar to parking a vehicle in an icy parking lot, made some sense. To rehash, in each case, other vehicles are often nearby.
A vehicle on ice, and a boat on water, offer very limited traction, and boats don't have brakes.
To slow down, you have to throw it in reverse, and/or use approach angles to take advantage of wind and current as braking mechanisms. Conditions can vary widely between departure and arrival. To complicate matters, boats powered by a single inboard motor, of which there are many in salt water, have very limited, or nearly no effective steering capability in reverse, or when going slow. A low volume and speed of water moving past the rudder, contributes to minimal steering control. And boats are heavy! I have personally seen larger boats, piloted by licensed captains, make 4 or 5 passes to get on their permitted moorings. I have jumped from one boat to another, to push vessels off by hand, or with a boat-hook to prevent impacts.
The City moving moored boats closer together, by removing an existing fairway/travel lane fore or aft, would severely reduce available approach angles. It would also reduce the time mariners have to react. Seconds often matter. Being restricted to the option of either a bow/front or stern/rear approach, offers the choice of whether you want the highest exposure to danger when you leave, or when you return. It is supposed that considerations such as these, are why the City failed to provide the Safety Analysis requested by Coastal
ou want the highest exposure to danger when you leave, or when you return. It is supposed that considerations such as these, are why the City failed to provide the Safety Analysis requested by Coastal Commission staff for the CDP. It has been observed, that dangerous access is reduced, or eliminated access. Boaters already give serious consideration to prevailing conditions when they depart from, or return to their permitted moorings. Increased levels of danger will logically decrease times when these permittees feel access is safe enough.
Please recall that single-point moorings have one mooring buoy/can/ball/float, which sits on the water surface, and sections of chain that extend to weights situated on the Harbor floor.
This equipment is commonly referred to as mooring "tackle", and resembles this: Boat Trader Guide to Mooring Mooring Buoy Pick-up Buoy Shackles Mooring Buoy Swivel Eye Mooring Line (Option 1) Mooring Line (Option 2) Mushroom Mooring Heavy Chain (length = 1.5x max depth) Light Chain (length = max depth) Mooring Chain Shackle and Swivel A boat on a single point mooring would most commonly be attached from the bow/front, and swing in 360-degree arcs with changes in winds/tides/currents, as in the following two images: Rough example of swing area on 4 single-point moorings: 1801 BAYSIDE DR 1801 BAYSIDE DR APN: 050 252 04 Address Status: Active Report Add to Results View Additional Details 2001 1 of 2 L Rough example of swing area on 4 single-point moorings: 720 BAY AVE W 720 BAY AVE W APN: 048 010 03 Address Status: Active Report Add to Results View Additional Details 1 of 2 Cas BUENAVISTABLVD 3 BAY AVE LINDO AVE Boats on Double-point moorings attach from both the bow and the stern, and thus have "tackle"
Status: Active Report Add to Results View Additional Details 1 of 2 Cas BUENAVISTABLVD 3 BAY AVE LINDO AVE Boats on Double-point moorings attach from both the bow and the stern, and thus have "tackle" to secure both ends. These boats do not swing in circles, but can drift a bit from side to side, and fore and aft, with changes in tides/winds/currents. They occupy much less space: BALBOA BI VDW With each type of mooring, the associated lengths of mooring chain/line have to accommodate these tidal/wind/current changes. They also act as a form of shock absorption during adverse weather conditions.
In instances when the Newport Harbor Department has sent out notices of impending severe weather (Tropical Storm Hillary, Santa Ana and other high wind events, etc.), I have gone aboard my boat on a double-point mooring, to be there in case anything breaks loose. The sudden stops each time the mooring chains and lines come taught, can knock one off their feet if not prepared. The creaking and groaning from stresses the mooring lines transfer to the holding cleats on the boat, are like something from a horror movie. Shorter lengths of chain and lines, reduce shock absorption, and increase stresses on lines and hardware. Stresses can result in the need to "Re-bed" hardware and attachments on boats. Closer proximity to other boats, is only going to increase the impacts that already occur in the H Mooring Field, where I moor. The boat on my permitted mooring, and those on either side of me, still make contact on occasion, even after the every-other-year required professional mooring service.
The City of Newport Beach has touted the "Open Water Initiative" as a selling point for realigning mooring fields:
t on occasion, even after the every-other-year required professional mooring service.
The City of Newport Beach has touted the "Open Water Initiative" as a selling point for realigning mooring fields: Sent: Monday, January 8, 2024 2:34 PM Subject: Fwd: City Mooring License Program Announcement fields to clean up the fairways and add in a few more moorings? It's one way that we can increase the "size" of our harbor by creating much more open water. Currently we have an application with Coastal for a CDP on the Pilot project. Happy to pass the presentation and City Please note in the image below, the amount of “open water” that currently exists to the north of Mooring Field C. There is indication of eight vessels transiting through, or using this open space simultaneously. Safe distances are evident between each. There are "fairways", or travel lanes between each mooring row within the C Field. Again, these provide multiple approach angles, and distance from other vessels, fostering safety while mooring in the varying conditions of Newport Harbor: Mooring Field C Newport Beach Harbor Note: Existing Open Water Space "Fairways" between each row of boats HDIC 26 HD2C 76 63 55 95 85 75 35 25 24 HD3C 84 13 23 33 43 63 53 22 12 42 62 52 31 21 11 41 61 51 AVER PUBLIC DOCK EDGEWATER PL The City's reconfiguration plan in the next image, indicates slight increases in "open water", but these come at the expense of eliminating fairways, approach angles, and distances between rows of boats. The plan will also result in boaters having to rely more on reverse, which
in "open water", but these come at the expense of eliminating fairways, approach angles, and distances between rows of boats. The plan will also result in boaters having to rely more on reverse, which as has been explained, is often problematic: • MOORING FIELD C RECONFIGURATION New Open Water Space New Open Water Space Council OKs mooring field reconfiguration pilot program, open water initiative And at the same time the Coastal Commission is reviewing the City's mooring realignment plan, another CDP, #5 - 24 - 0779, for the rebuilding of Beacon Bay HOA Docks is under review by Coastal Program Analyst Emily Greer. Three T-docks and a work-dock there, offer about 44 boat berthing spaces: CITY OF NEWPORT BEACH Harbor Commission Staff Report x TITLE: July 10, 2024 Agenda Item No. 2.1 Residential Dock Reconfigurations at 20 Beacon Bay (Beacon Bay Homeowner Association Dock Systems) Section: A.20 Zoom to Pan A. Piers and floats located in the areas of Newport Harbor set forth in this subsection shall not extend bayward beyond the specified limits without the approval of the Harbor Commission pursuant to subsection (GX1) 20. From U.S. Bulkhead Station No. 137 to the east property line of Beacon Bay subdivision: 16 feet bayward of the U.S. Pierhead Line.
5m 20 ft Dock 3 BUT THEOR Pierhead Line A 20 PROIBETLEH PERHEAD 16-Feet 16' Beyond Pierhead Line Project Line If approved, CDP #5 - 24 - 0779 would have the Coastal Commission endorse extensions into the Harbor beyond Federally designated limit lines, as well as increases in width and square footage of the docks: Proposed Dock is 17½ feet wider than Existing, and extends beyond designated Army Corps limits: 153-3 (N) 14" SQ. PILE GUIDE (E) FLOATING DOCK (N) 14" SQ. PILE GUIDE PROJECT LINE 20-6 20-6 20-6 (E) PIER, PLATFORM
k is 17½ feet wider than Existing, and extends beyond designated Army Corps limits: 153-3 (N) 14" SQ. PILE GUIDE (E) FLOATING DOCK (N) 14" SQ. PILE GUIDE PROJECT LINE 20-6 20-6 20-6 (E) PIER, PLATFORM & PILE (8 TOTAL) LJ LJ 18 20-6 20-6 ERHEAD LINE 8-94 20'-6" (E) 14" SQ. PILE GUIDE (2 TOTAL) GANGWAY BULKHEAD LINE TOTAL AREA 376 FP 1,571 LEGEND DOCK AREA EXISTING TOTAL AREA GANGWAY AREA 4X24 TOTAL PIER AREA TOTAL AREA PROPOSED DOCK AREA 1.099 FT TOTAL AREA 1.266 FT" GANGWAY AREA 96 FT 4X24 96 FF TOTAL 96 FT 96 F WALKWAY 132 PIER AREA TOTAL AREA TOTAL AREA 376 F 1,738 FT EXISTING/PROPOSED DOCK 03 SWIFT SLIP SWIFT SLIP DOCK & PIER BUILDERS, INC 6351 Industry Way, Westminster, CA 92683 Phone: (949) 631-3121 Fax: (714) 509-0618 CLIENT AMENDMENTS BEACON BAY H.O.A.
RO DRAWN CHECKED 2.0 REVISION 06/20/24 REV DESCRIPTION DATE SITE BEACON BAY, NEWPORT BEACH, CA 92660 BY DATE 52 33 U.S. Code § 424§ 424. Establishment of pierhead or bulkhead lines in Newport Harbor, California "The Secretary of the Army is authorized and directed to fix and establish pierhead and bulkhead lines, either or both, at Newport Harbor, California, in accordance with plan dated United States Engineer Office, Los Angeles, California, March 25, 1913, and entitled "Newport Bay, California", showing harbor lines, beyond which no piers, wharfs, bulkheads, or other works shall be extended..."
The City's Open Water Initiative looks to me, like a selectively applied solution, in search of a specific problem. That specific "problem" appearing to be the less affluent mooring permittees. If this is not the case, wouldn't the Open Water Initiative be more equitably and logically actualized by conditioning that new docks comply with Federal standards to safeguard navigation routes?
ees. If this is not the case, wouldn't the Open Water Initiative be more equitably and logically actualized by conditioning that new docks comply with Federal standards to safeguard navigation routes?
Moreover, wouldn't the City's "Open Water Initiative" be more equitably, logically, and impactfully actualized by converting the single-point mooring fields to double-point first?
As indicated in the following three images, fewer vessels on single-point moorings occupy more space, than do a greater number of vessels on double-point. And the single-points can randomly protrude further into navigation channels as they transit their 360-degree arcs: https://www.mapdevelopers.com/area finder.php Newport Beach Single-Point Mooring Field Approximately 79 Offshore Mooring Spaces encumbering 21.19 acres: Area calculator - Find the area of a shape you draw on a google map Address Area AAAA1B Border 000000 Only Show Border 1801 bayside drive corona del mar Zoom to Address Draw New Area Edit Active Area Area 85758 meters², 923087 feet? 21.19 acres 0.033 miles2 0.086 km² Remove Active Area Enlarge Map Perimeter 1024 meters, 3361 feet 0.636 miles 1.024 km SBay Front Map Satellite SBay Front SBay Front Balboa Yacht Club C9924 Google Newport-Avalon Google 24264 Newport Beach Harbor Patrol US Coast Guard Bayside Dr ea Terrace Galateau Bayadere Terra Cutter Narwhal Sophie's Beach https://www.mapdevelopers.com/area finder.php Newport Beach Single-Point Mooring Field Approximately 73 Offshore Mooring Spaces encumbering 19.91 acres: Area calculator - Find the area of a shape you draw on a google map Address Area AAAAAA Border 000000 Only Show Border Zoom to Address Draw New Area Edit Active Area Remove Active Area Enlarge Map Area 80567 meters2, 867215 feet2 19.91 acres 0.031 miles2 0.081 km²
map Address Area AAAAAA Border 000000 Only Show Border Zoom to Address Draw New Area Edit Active Area Remove Active Area Enlarge Map Area 80567 meters2, 867215 feet2 19.91 acres 0.031 miles2 0.081 km² Perimeter 1278 meters, 4193 feet 0.794 miles 1.278 km Map Satellite W Bay Ave Google Lido Soud MUZA Cosule + 2024 Google 10th St Beach Via Lido Soud 2024 Geoghe Newport Bay Bay Island Tennis Court Bay Island East Beach (Private Access) East Beach 1+ Keyboard shortcuts Map data @2024 Imagery 2024 Airbus, Maxar Technologies Terms Report a map error https://www.mapdevelopers.com/area finder.php Newport Beach Double-Point Mooring Field Approximate 128 Mooring spaces encumbering 14.6 acres Area calculator - Find the area of a shape you draw on a google map Address Area AAAA1B 1801 bayside drive corona del mar Zoom to Address Draw New Area Edit Active Area ☐ Only Border 000000 Remove Active Area Enlarge Map Area 59078 meters², 635914 feet² 14.60 acres 0.023 miles2 0.059 km² Perimeter 675 meters, 2216 feet 0.420 miles 0.675 km Мар Satellite el Rd Bay Beach H Field moorings Bay Ave Marina Park Playground 15th Street Public Dock American Legion Post 291 Lighthouse Cafe Google Marina Park Parking Via The "Open Water Initiative" being used by the City as a selling point to try and dangerously densify mooring fields permitted to less affluent members of the public, while at the same time no mention is made of the "Open Water Initiative" under the pending CDP for reconstruction of multi-dock platforms at a Harbor Commissioner's neighborhood, and with no apparent consideration of realigning the exclusive, larger and lower occupancy single-point yacht club mooring fields, epitomizes hypocrisy. This looks to me, like the same type of
orhood, and with no apparent consideration of realigning the exclusive, larger and lower occupancy single-point yacht club mooring fields, epitomizes hypocrisy. This looks to me, like the same type of discrimination versus favoritism I sense in the City's recent Rate, and Mooring License schemes. I believe that The Coastal Act precludes this sort of selective class discrimination and favoritism, and that it encourages that safe and affordable access be maintained for those who can only afford to boat in Newport through the use of moorings.
Consequently, I ask that The Coastal Commission inquire of the City, if they would be amenable to a CDP #5-23-0753 condition of approval, being the converting the single-point Yacht Club Moorings as the pilot test? This would clearly be of greater benefit to the Open Water Initiative. And if the City would not agree to that condition, since Mooring Field C is planned in stages, perhaps a condition that after the first two realigned rows in the C Field are found to be safe and successful, the City shall next transition to realigning the Yacht Club Moorings into double-point mooring fields. Fairness and sincerity as far as the Open Water Initiative, should require this, or similar conditions.
Sincerely, Adam Levens Adam Leverenz [email protected] To: California Coastal Commission 455 Market Street Suite 300 San Francisco, CA. 94105 Sent via e-mail: Karl. [email protected] November 24, 2024 [email protected] Re: Workload/CDP #5-23-0753 and CDP #5-24-0779, for projects located in Newport Beach, California District Director Schwing,
[email protected] Re: Workload/CDP #5-23-0753 and CDP #5-24-0779, for projects located in Newport Beach, California District Director Schwing, Thank you so very much for allowing me some time to propose an idea to perhaps reduce current, and impending work-load before Coastal, while at the same time, seek equity among various groups of users in Newport Harbor. I have attached some materials which I hope indicate to you, the strong City desire to protect Yacht Club and Community Association moorings from adverse consequence, intended for mooring permits held by members of the general public.
Were there sincerity on the part of those advocating the "Open Water Initiative", and their goals truly were more open water in the Harbor, one would expect little objection to converting single-point moorings to double-point, even though those single-points are Yacht Club moorings. There should likewise be little objection to having docks, when rebuilt, constructed so as not to extend into the Harbor beyond Federally designated lines, or increase in square footage. (My understanding is that docks near shore create shade, to the detriment of shallow water eel grass) Mooring Field "Optimization" and open water, would clearly occur sooner, and on higher levels, if the City first converted to double-point, the more exclusive and space consuming Yacht Club single-point moorings. And if the City wanted to create even more open water simultaneously, they could optimize even further, by implementing the double-row configuration the City proposes for Mooring Field C.
I suspect however, a lack of sincerity on the part of those pushing the Open Water Initiative. The single-
further, by implementing the double-row configuration the City proposes for Mooring Field C.
I suspect however, a lack of sincerity on the part of those pushing the Open Water Initiative. The singlepoint moorings permitted to local Yacht Clubs are a much superior mooring option, and sacrifice on the part of the exclusive and affluent in Newport Beach, would likely make mooring field optimization for them a non-starter. The clear desire to protect Yacht Club moorings from the extreme rate increases the City recently recommended for others, evidences favoritism for the chosen ones, and discrimination for the others. I anticipate that the City intent to insulate Yacht Clubs and neighborhood associations from fee increases, would also manifest itself in a strong desire to preserve the more exclusive single-point Yacht Club moorings as they are.
So, a CDP condition that the most expansive mooring fields, where far fewer boats moor, undergo "Optimization" first, may result in a flawed and controversial CPD being withdrawn, and cleared off of Coastal's table just in time for the Holiday season. Other CDPs that appear in the pipeline, based upon Newport's Harbor and Beaches Master Plan revealed at the 11/13/2024 Harbor Commission Meeting, might then also benefit from more thoughtful local refinement with stakeholders, before being advanced to State Commissions/Agencies. This I think, would offer cost and time savings to those same State Commissions/Agencies.
Sincerely, Adam Leverano Adam Leverenz [email protected] A selection of materials re: Inquiring of The City of Newport Beach, if Yacht Clubs, et al. would be exempted from substantial Mooring Fee Increases.
(12 pgs.)
Notes: After having heard that the Harbormaster had stated during a Yacht Club function,
ty of Newport Beach, if Yacht Clubs, et al. would be exempted from substantial Mooring Fee Increases.
(12 pgs.)
Notes: After having heard that the Harbormaster had stated during a Yacht Club function, that they would not be subject to the City's desired Mooring fee/rent increases ranging from about 300 to over 500%, numerous efforts were made by others, and then me, seeking documented clarification on the matter. Most inquiries went unanswered.
The Harbormaster is a former Harbor Commissioner; current Yacht Club Member; and current Yacht Club Mooring Permittee. He was heavily involved in formulation of the fee increase plan, even after having entered into agreement with the City in 2022, to not participate. Others involved in the plan, are members of, and/or associated with the Yacht Clubs.
Yacht Club Moorings (Single-point) serve far fewer boats, over a much larger area.
(Please refer to a letter to the California Coastal Commission, dated November 4, 2024, from Adam Leverenz) They benefit from being easier to get on/off, as users only have to grab/release one mooring line; They are more easily approached from multiple directions, making mooring safer; With fewer boats in a larger area, there can be more distance between boats/ neighbors, offering a bit more privacy; The boats moored there transit 360 degrees, offering ever changing Imax style views; They receive sun exposure on all sides, reducing algae growth and cleaning labor/costs; They have ½ the mooring tackle, and logically less maintenance cost; There is less shock to boat cleats/lines/guides, as the boats are always facing into, and never broadside to wind/weather. They are all around, a more spacious and desirable form of boating access than the double-point moorings permitted to
/guides, as the boats are always facing into, and never broadside to wind/weather. They are all around, a more spacious and desirable form of boating access than the double-point moorings permitted to members of the general public.
Sent: Tuesday, May 7, 2024 2:48 PM Subject: Adjusted Newport Beach Mooring Rents Good day Mr. Blank, I would like to know if the Harbor Commission's recent (04/10/2024) recommendation of adjustment to fees/rates for Mooring Permits, are fees/rates that will be applied to those Moorings held/managed under Yacht Club stewardship? As you've heard me say, this question has been posed a number of times, but a clear answer has seemed elusive.
Thank you, Adam Leverenz Sent: Tuesday, May 7, 2024 3:01 PM Subject: RE: Adjusted Newport Beach Mooring Rents Mr. Leverenz: As a mooring permittee, these discussions may affect me financially.
As you have likely observed, I am not participating in the proceedings and therefore do not have any information for you.
I am forwarding your question to Lauren Wooding-Whitlinger, the Real Property Administrator for the City.
You may also wish to address your question to the Harbor Commission Chair, Steve Scully, or the ad hoc committee Chair, Ira Beer.
CITY NEWPOR CALIFORNIA BEACH Paul Blank Harbormaster Harbor Department Office: 949-270-8158 1600 W Balboa Blvd Newport Beach, CA 92663
ion Chair, Steve Scully, or the ad hoc committee Chair, Ira Beer.
CITY NEWPOR CALIFORNIA BEACH Paul Blank Harbormaster Harbor Department Office: 949-270-8158 1600 W Balboa Blvd Newport Beach, CA 92663 Sent: Tuesday, May 7, 2024 3:14 PM Subject: Re: Adjusted Newport Beach Mooring Rents Mr. Blank, Thank you so much. I do appreciate your reply, and guidance.
Take care, Adam Sent: Sunday, May 12, 2024 11:17 AM Subject: Fw: Adjusted Newport Beach Mooring Rents Good day, Harbormaster Paul Blank has directed me to Newport Beach Harbor Commission Chair Steve Sculley; ViceChair Ira Beer, and Real Property and Asset Management Program manager Lauren Wooding Whitlinger, in relation to the following inquiry made to him: "I would like to know if the Harbor Commission's recent (04/10/2024) recommendation of adjustment to fees/rates for Mooring Permits, are fees/rates that will be applied to those Moorings held/managed under
uld like to know if the Harbor Commission's recent (04/10/2024) recommendation of adjustment to fees/rates for Mooring Permits, are fees/rates that will be applied to those Moorings held/managed under Yacht Club stewardship? As you've heard me say, this question has been posed a number of times, but a clear answer has seemed elusive.
Thank you, Adam Leverenz" Sent: Thursday, May 30, 2024 2:32 PM Subject: Inquiry Councilwoman Grant, I would very much appreciate if you could source, or provide a simple "yes" or "no" answer to the following: "I would like to know if the Harbor Commission's recent (04/10/2024) recommendation of adjustment to fees/rates for Mooring Permits, are fees/rates that will be applied to those Moorings held/managed under Yacht Club stewardship?"
As I have noted, a determination on this, has been elusive.
I hope that you have a wonderful trip to Japan. Just prior the last regular Council Meeting, I'd been enjoying the Sister City sculpture.
Thank you, Adam Leverenz Sent: Thursday, May 30, 2024 2:32 PM Subject: Inquiry Councilwoman Kleiman I would very much appreciate if you could source, or provide a simple "yes" or "no" answer to the following: "I would like to know if the Harbor Commission's recent (04/10/2024) recommendation of adjustment to fees/rates for Mooring Permits, are fees/rates that will be applied to those Moorings held/managed under Yacht Club stewardship?"
As I have noted, a determination on this, has been elusive.
Thank you, Adam Leverenz Sent: Thursday, May 30, 2024 2:28 PM
ld/managed under Yacht Club stewardship?"
As I have noted, a determination on this, has been elusive.
Thank you, Adam Leverenz Sent: Thursday, May 30, 2024 2:28 PM Subject: Inquiry Councilman Avery, I would very much appreciate if you could source, or provide a simple "yes" or "no" answer to the following: "I would like to know if the Harbor Commission's recent (04/10/2024) recommendation of adjustment to fees/rates for Mooring Permits, are fees/rates that will be applied to those Moorings held/managed under Yacht Club stewardship?"
As I have noted, a determination on this, has been elusive.
Thank you, Adam Leverenz Sent: Thursday, May 30, 2024 2:28 PM Subject: Inquiry Councilman Blom, I would very much appreciate if you could source, or provide a simple "yes" or "no" answer to the following: "I would like to know if the Harbor Commission's recent (04/10/2024) recommendation of adjustment to fees/rates for Mooring Permits, are fees/rates that will be applied to those Moorings held/managed under Yacht Club stewardship?"
As I have noted, a determination on this, has been elusive.
Thank you, Adam Leverenz Sent: Thursday, May 30, 2024 2:28 PM Subject: Inquiry Councilman Stapleton, I would very much appreciate if you could source, or provide a simple "yes" or "no" answer to the following: "I would like to know if the Harbor Commission's recent (04/10/2024) recommendation of adjustment to fees/rates for Mooring Permits, are fees/rates that will be applied to those
swer to the following: "I would like to know if the Harbor Commission's recent (04/10/2024) recommendation of adjustment to fees/rates for Mooring Permits, are fees/rates that will be applied to those Moorings held/managed under Yacht Club stewardship?"
As I have noted, a determination on this, has been elusive.
Thank you, Adam Leverenz Sent: Thursday, May 30, 2024 2:31 PM Subject: Inquiry Councilman Weigand, I would very much appreciate if you could source, or provide a simple "yes" or "no" answer to the following: "I would like to know if the Harbor Commission's recent (04/10/2024) recommendation of adjustment to fees/rates for Mooring Permits, are fees/rates that will be applied to those Moorings held/managed under Yacht Club stewardship?"
As I have noted, a determination on this, has been elusive.
I hope that you enjoy your upcoming trip to Japan. Just prior the 05/28/2024 Meeting, I'd been admiring the related sculpture.
Thank you, Adam Leverenz Sent: Thursday, May 30, 2024 2:32 PM Subject: Inquiry Mayor O'Neill, I would very much appreciate if you could source, or provide a simple "yes" or "no" answer to the following: "I would like to know if the Harbor Commission's recent (04/10/2024) recommendation of adjustment to fees/rates for Mooring Permits, are fees/rates that will be applied to those Moorings held/managed under Yacht Club stewardship?"
As I have noted, a determination on this, has been elusive.
Thank you, Adam Leverenz Sent: Thursday, June 13, 2024 11:55 AM Subject: Thank you
nation on this, has been elusive.
Thank you, Adam Leverenz Sent: Thursday, June 13, 2024 11:55 AM Subject: Thank you Chair Scully, I very much appreciate you approaching me after the Harbor Commission Meeting last evening, to answer my question about applicability of the fee/rent increases for Mooring Permits, under the Recommendation that has been forwarded to Council. Just to assure that I understood correctly, please confirm, that as with Mooring Permits held/administered under Yacht clubs, those under the Lido Island Community Association, are likewise, not subject to the Recommendation?
Again, thank you.
Adam Leverenz Sent: Thursday, June 13, 2024 12:25 PM Subject: Re: Thank you Correct Adam.
Steve Scully Newport Beach Harbor Commission [email protected] 909-322-2893 Harbormaster Update – April 2022 Activities May 11, 2022 Page 5 Initiatives were launched resulting in better data capture and statistics reporting.
Future improvements will include customer satisfaction survey data analysis and calls for service location analysis Participated in the Emergency Operations Response to the following: о Elly oil spill Tsunami warning Three severe weather occurrences Sewage spill into the harbor Out of control stolen boat in the harbor The Harbormaster has disclosed the arrangements made, at his own expense to alleviate any conflict of interest associated with his ongoing use of an offshore mooring permit.
While undergoing the recruitment process, any and all known possible conflicts of interest were disclosed. Prior to the City making an offer of employment, all such possible
n offshore mooring permit.
While undergoing the recruitment process, any and all known possible conflicts of interest were disclosed. Prior to the City making an offer of employment, all such possible conflicts were discussed with the City Attorney. Agreements and arrangements satisfactory to all relevant parties were made during that discussion. The Harbormaster was entrusted and empowered to make determinations going forward related to any conflict disclosures. In support of this arrangement, the Harbormaster: does not participate in discussions or the development of recommendations related to use or financial arrangements associated with offshore moorings reminds anyone with an interest that input on recommendations related to offshore mooring permits are made by Real Property Administration staff does not deliberate or vote on any policy related matters before the Harbor Commission is expected to answer questions related to policy implementation and impacts on Harbor Department operations hereby discloses that the offshore mooring permit he enjoys is held in an irrevocable trust the beneficiary of which is the Balboa Yacht Club. The Balboa Yacht Club holds all the offshore mooring permits adjacent to the subject mooring hoping to avoid other conflict of interest concerns also hereby discloses any significant financial interests related to the Balboa Yacht Club including a membership certificate are held in the same irrevocable trust further discloses that all remaining financial interests in either the subject offshore mooring permit or membership in the Balboa Yacht Club are de minimis ENVIRONMENTAL REVIEW: Staff recommends the Harbor Commission find this action is not subject to the California
the subject offshore mooring permit or membership in the Balboa Yacht Club are de minimis ENVIRONMENTAL REVIEW: Staff recommends the Harbor Commission find this action is not subject to the California Environmental Quality Act (CEQA) pursuant to Sections 15060(c)(2) (the activity will not result in a direct or reasonably foreseeable indirect physical change in the environment) and 15060(c)(3) (the activity is not a project as defined in Section 15378) of the CEQA Approximate "Impact Area" of a 40' double-point V.
a 40' single-point offshore mooring: The most common offshore mooring in Newport Harbor is said to be 40'.
Double-points are claimed to encumber about 1,200 sq. ft., presuming about 10' of space fore and aft.
A 40' single-point offshore mooring, presuming 10' of space fore, and given that vessels on these moorings swing 360 degrees, encumbers a circular area with a radius of about 50': https://www.gigacalculator.com/calculators/area-of-circle-calculator.php GI GIGA calculator GA Calculators Converters Randomizers Articles Calculators / Geometry / Area of a Circle Calculator Area of a Circle Calculator Use this calculator to easily calculate the area of a circle, given its radius in any metric: mm, cm, meters, km, inches, feet, yards, miles, etc.
[x] hide illustration radius Circle radius 50 ft Calculate area Calculation results Circle area 7,853.981634 ft² These calculations indicate that a 40' single-point mooring encumbers a 654% greater area than a 40' double-point.
Share calculator: f✔ in Share your result!
fin get direct link Embed this tool: (Numbers used for calculations are sourced from Appraisal Reports; City of Newport Beach materials; Etc.)
To: California Coastal Commission 455 Market Street Suite 300
nk Embed this tool: (Numbers used for calculations are sourced from Appraisal Reports; City of Newport Beach materials; Etc.)
To: California Coastal Commission 455 Market Street Suite 300 San Francisco, CA. 94105 January 5, 2025 Re: Staff quote - "we are limited to CDP applications that are currently before us”; CDPs #5-23-0753 and #5-24-0779, for projects located in Newport Beach, California.
Good day all, I hope that each of you has become aware of some of the extreme, and long-standing variations in the way the City of Newport Beach has managed different users of the same granted sovereign lands under its stewardship. Examples that have been brought to the attention of State Lands and Coastal Commissioners and Staff, have included vast disparities in rate/fee assessments; vast differences in the areas over which rates/fees are calculated; vast differences in levels of regulation vs. levels of non-regulation or indifference; vast differences in levels of utility/use/access; etc., etc., etc.
Personally, I've been quite surprised to find that the more research and study I do, the more documents | uncover, and the more City meetings I attend, I continue to learn of additional examples of unjust and improper City management styles, conflicts of interests, favoritism towards some, and disfavor towards others. I have hereto attached graphics which show a number of parties who have advocated City positions that benefit themselves, their peers, friends, fellow club members, etc. The
d disfavor towards others. I have hereto attached graphics which show a number of parties who have advocated City positions that benefit themselves, their peers, friends, fellow club members, etc. The graphic purports to outline connections to groups/organizations which historically have, and continue to benefit from the City's arbitrary and capricious Harbor management style. Something I find of great concern, is that the current Harbormaster appears to be a member of a benefitting yacht club, holds a mooring permit in that yacht club's mooring field, and due to the potential for conflicts of interest, and as a condition of City employment, entered into agreement that he: "does not participate in discussions or the development of recommendations related to use or financial arrangements associated with offshore moorings." (Excerpt page Attached) In spite of this agreement, the Harbormaster was intimately involved in the creation of the new, highcost, and more restrictive City Mooring License program; the proposed 300, to over 500% increase in Mooring Permit rents/fees; the Mooring Field C reconfiguration plan; the conversion to helical anchor plan; the lax regulation of Residential Piers/fees; etc., etc. The Harbormaster has continued to draft Staff Reports, continued to speak to, and advocate for things that clearly relate to the use or financial arrangements associated with offshore moorings. I feel that the Coastal Commission should not turn a blind eye to this, given the inequities that have, and continue to result.
As has been previously noted, a majority of Mooring Permittees are not residents of Newport Beach.
The existing Mooring Permit program, assures that boaters who cannot afford to live, rent, or own real
s has been previously noted, a majority of Mooring Permittees are not residents of Newport Beach.
The existing Mooring Permit program, assures that boaters who cannot afford to live, rent, or own real property in Newport Beach, still have Coastal access. The Local Coastal Program Land Use Plan specifically seeks to: 3.3.2-3.
Continue to provide shore moorings and offshore moorings as an important source of low-cost public access to the water and harbor.
The Newport Beach Harbor Commission in 2024, expressed that their desires towards Mooring Permittees were allowable, because as a group, Mooring Permittees are not a protected class. I believe that The Coastal Act protects all users, not just those who are members of what have come to be known as "protected classes". I have long been an advocate for equity and fairness, and a term I have heard from various State Commissioner's, and some Staff, which I believe advocates similarly, is "Environmental Justice".
I contend that for Coastal Staff to foster equity, fairness, and Environmental Justice, Staff cannot act with the mindset that "we are limited to CDP applications that are currently before us". The context of considering who benefits from the City placing before Coastal, CDP's which detrimentally affect those primarily of lower socio-economic standing and means, warrants your consideration. An inapplicability of full context to CDP 5-23-0753, risks having the Coastal Commission be party to ongoing City patterns of creating inconvenience, hardship, and expense for members of the public who hold Mooring Permits, while at the same time, insulating the more exclusive and affluent, who use yacht club moorings or private docks.
convenience, hardship, and expense for members of the public who hold Mooring Permits, while at the same time, insulating the more exclusive and affluent, who use yacht club moorings or private docks.
To not consider the logical benefits, increased public access, and larger amounts of open water that would come from realignment/optimization of the more expansive, and lower occupancy yacht club mooring fields, and instead endorse realigning/optimizing the mooring fields permitted to members of the public, which already locate more boats over smaller areas, would only add to the string of cumulative adverse impacts foisted upon the lower echelon of boaters in Newport. For Coastal to disregard the fact that the City's stated goals and intents would be far more realized, were the project applied to the exclusive yacht club mooring fields, should not be overlooked. And the fact that another pending CDP, #5-24-0779, proposes rebuilding exclusive docks that extend into the Harbor beyond Federally designated limit lines, and increase them in width, at the same time the City desires to dangerously densify the non-yacht club mooring fields, placed into context, evidences an ongoing pattern of discrimination and favoritism, thus continuing a trend of winners and losers in the realm of coastal access/use.
This is Environmental In-justice. Coastal Commission Staff should not enable/endorse/acquiesce to this, by refusing to look at the big picture.
Sincerely, Adam Levenamo Adam Leverenz [email protected] NEWPORT HARBOR FOUNDATION THE FIRST ANNUAL State OF THE Bay LUNCHEON Seymour Beek Paul Blank Scott Cunningham BOARD OF DIRECTORS cordially invites you to attend GUEST SPEAKERS Seymour Beek Ferry Electrification Status Paul Blank City of Newport Beach Harbormaster
CHEON Seymour Beek Paul Blank Scott Cunningham BOARD OF DIRECTORS cordially invites you to attend GUEST SPEAKERS Seymour Beek Ferry Electrification Status Paul Blank City of Newport Beach Harbormaster Harbor Department Report Bill Kenney NHF Board Member Mooring Fields-Reconfiguration and Rates Update Duffy Duffield NHF Board Member Trash Collector and Dredging Projects HOST COMMITTEE Dennis Durgan Devon Kelly Bill Kenney Lido Yacht Anchorage Val Lyon Phil Lyons Don Russell Featuring Newport Beach City Council Members Duffy Duffield Brad Avery Noah Blom Robyn Grant Lauren Kleiman Will O'Neill Joe Stapleton Erik Weigand NEWPORT HARBOR YACHT CLUB 720 West Bay Avenue Balboa, CA 92661 platinum sponsor $25,000 WEDNESDAY MAY 15 2024 gold sponsor $10,000 11:30AM VIP Sponsor Reception 12:00PM Lunch & Program silver sponsor $5,000 VIP RECEPTION & LUNCH TICKETS $1,000 per person $2,000 per couple INDIVIDUAL LUNCH TICKETS $500 per person $1,000 per couple CASUAL BUSINESS ATTIRE NEWPORT HARBOR FOUNDATION THE FIRST ANNUAL State Bay OF THE LUNCHEON Seymour Beek BOARD OF DIRECTORS cordially invites you to attend Paud Blank (1) Scott Cuningham (5) Duffy Duffield (3 GUEST SPEAKERS Seymour Beek Ferry Electrification Status Paul Blank (1) City of Newport Beach Harbormaster Bill Kenney (2) NHF Board Member Mooring Fields-Reconfiguration and Rates Update Duffy Duffield NHF Board Member Trash Collector and Dredging Projects (3) HOST COMMITTEE Dennis Durgan Devon Kelly Bill Kenno(2) Lido Yacha Anchorage Val Lyon Phil Lyons Don Russell Featuring Newport Beach City Council Members (6) Brad Avery Noah Blom Robyn Grant Lauren Kleiman Will O'Neill Joe Stapleton Erik Weigand NEWPORT HARBOR YACHT CLUB 720 West Bay Avenue Balboa, CA 92661 WEDNESDAY MAY 15 2024 gold sponsor $10,000 11:30AM
rad Avery Noah Blom Robyn Grant Lauren Kleiman Will O'Neill Joe Stapleton Erik Weigand NEWPORT HARBOR YACHT CLUB 720 West Bay Avenue Balboa, CA 92661 WEDNESDAY MAY 15 2024 gold sponsor $10,000 11:30AM VIP Sponsor Reception 12:00PM Lunch & Program platinum sponsor $25,000 TITI VIP RECEPTION & LUNCH TICKETS $1,000 per person $2,000 per couple silver sponsor $5,000 INDIVIDUAL LUNCH TICKETS $500 per person $1,000 per couple CASUAL BUSINESS ATTIRE RSVP contact Julie Ackman Follow the money...
ACKMAN CONSULTING GROUP We are proud to have provided services for NEWPORT HARBOR FOUNDATION (NGO) BRAD AVERY FOR NEWPORT BEACH CITY COUNCIL (4) NOAH BLOM FOR NEWPORT BEACH CITY COUNCIL (6) DUFFY DUFFIELD FOR NEWPORT BEACH CITY COUNCIL (3) LAUREN KLEIMAN FOR NEWPORT CITY COUNCIL (6) SCOTT PEOTTER FOR NEWPORT BEACH CITY COUNCIL JOE STAPLETON FOR NEWPORT BEACH CIT COUNCIL (3) Current/former City positions: (1) Harbor Commissioner, Harbormaster, Balboa Yacht Club Staff Commodore (2) Harbor Commissioner, CFO Balboa Yacht Club, NGO member (3) Harbor Commissioner, City Councilmember, NGO member (4) Harbor Commissioner, City Councilmember, Newport Harbor Staff Commodore (5) Harbor Commissioner (6) City Councilmember Harbormaster Update – April 2022 Activities May 11, 2022 Page 5 Initiatives were launched resulting in better data capture and statistics reporting.
Future improvements will include customer satisfaction survey data analysis and calls for service location analysis Participated in the Emergency Operations Response to the following: о Elly oil spill Tsunami warning Three severe weather occurrences Sewage spill into the harbor Out of control stolen boat in the harbor The Harbormaster has disclosed the arrangements made, at his own expense to alleviate
ami warning Three severe weather occurrences Sewage spill into the harbor Out of control stolen boat in the harbor The Harbormaster has disclosed the arrangements made, at his own expense to alleviate any conflict of interest associated with his ongoing use of an offshore mooring permit.
While undergoing the recruitment process, any and all known possible conflicts of interest were disclosed. Prior to the City making an offer of employment, all such possible conflicts were discussed with the City Attorney. Agreements and arrangements satisfactory to all relevant parties were made during that discussion. The Harbormaster was entrusted and empowered to make determinations going forward related to any conflict disclosures. In support of this arrangement, the Harbormaster: does not participate in discussions or the development of recommendations related to use or financial arrangements associated with offshore moorings reminds anyone with an interest that input on recommendations related to offshore mooring permits are made by Real Property Administration staff does not deliberate or vote on any policy related matters before the Harbor Commission is expected to answer questions related to policy implementation and impacts on Harbor Department operations hereby discloses that the offshore mooring permit he enjoys is held in an irrevocable trust the beneficiary of which is the Balboa Yacht Club. The Balboa Yacht Club holds all the offshore mooring permits adjacent to the subject mooring hoping to avoid other conflict of interest concerns also hereby discloses any significant financial interests related to the Balboa Yacht Club including a membership certificate are held in the same irrevocable trust
other conflict of interest concerns also hereby discloses any significant financial interests related to the Balboa Yacht Club including a membership certificate are held in the same irrevocable trust further discloses that all remaining financial interests in either the subject offshore mooring permit or membership in the Balboa Yacht Club are de minimis ENVIRONMENTAL REVIEW: Staff recommends the Harbor Commission find this action is not subject to the California Environmental Quality Act (CEQA) pursuant to Sections 15060(c)(2) (the activity will not result in a direct or reasonably foreseeable indirect physical change in the environment) and 15060(c)(3) (the activity is not a project as defined in Section 15378) of the CEQA California Coastal Commission South Coast District Office 301 E. Ocean Blvd, Suite 300 Long Beach, CA 90802-4235 July 17, 2024 Re: City of Newport Beach, Mooring Rent Increase Recommendation/Alternative Amrita, Thank you so much for the letter you'd sent to The City of Newport Beach, dated July 9, 2024. 1, and others, are quite distressed, that like a similar letter from The California State Lands Commission, dated April 9, 2024, the City chose to disregard each Commission's input. I will note, that during a Study Session at City Council on July 9, Mayor and Council voiced a high level of displeasure with State mandates and obligations, as related to an agenda item for "Implementation of the Housing Element and Charter Section 423". I heard from them, how damaging imposition of State Housing mandates would be here, and that generally speaking,
to an agenda item for "Implementation of the Housing Element and Charter Section 423". I heard from them, how damaging imposition of State Housing mandates would be here, and that generally speaking, putting the matter before the electorate, would involve a risk that voters might make the wrong choice. It appears to me, that the City does not wish to submit to State authority, and that public input may be troublesome. I'll opine that this apparent disinterest in what certain members of the public, and/or what State Commissions have to say, may be a primary reason there's currently such rate disparity and discrimination in use of the Tide/Submerged Lands here.
I apologize if any of what I write below is repetitive, but more recent data has come to light. And having the City morph what was anticipated to be a proposal to further increase the existing rate disparity between Moorings and Residential Piers/Docks, into something more far flung, has me feel that perhaps I have previously failed to well articulate some of my remarks. Although some of what follows may be viewed as outside of the purview of the Coastal Commission, the total here, is a sum of the parts. I pose that an awareness of those many parts, and the resultant cumulative adverse impacts on low-cost/affordable Harbor/ Coastal boating access, put into context a more complete picture of what has occurred, how it has occurred, and reflect what I believe, is a near single-minded City focus, to transition this Harbor to better suit the more exclusive and affluent.
This is discriminatory, and I think does fall within Coastal Commission purview.
The City's "Alternative Recommendation" for Moorings, which received 6-1 Mayoral/Council endorsement on July 9, raises a number of significant issues.
hink does fall within Coastal Commission purview.
The City's "Alternative Recommendation" for Moorings, which received 6-1 Mayoral/Council endorsement on July 9, raises a number of significant issues.
The "Alternative" was first publicly noticed on Friday July 5th, 2024, over a major holiday weekend, which set records for numbers of people travelling away from home. The plan itself, requires some level of analysis. To have had the extreme changes/proposals not come through the customary channel of the Newport Beach Harbor Commission, deprived interested parties and stakeholders, of the customary opportunity to study, and comment. It is quite disheartening, to have had such substantive proposals pop out of nowhere, on such short notice, over a holiday.
Please be aware too, that the City "Alternative" actualizes all of the apparent objectives/changes the City desires, but feigns stretching them out over a period of time. The "Alternative" will result, over time, in all Mooring Permits transitioning into City held "Mooring Licenses". This will result in the complete deprivation from members of the general public, an ability to obtain "Mooring Permits". The "Alternative" will also result, over time, in all moorings being subject to the excessive price increases the City favors (300 to over 500%). These high prices will then be compounded annually, by removal of the predictable CPI based rent/fee adjustments that Permit holders have become accustomed to, and which the City continues to use in adjustments for other types of rents/fees.
The "Alternative" will result, over time, in no more Live-aboard Permits (Liveaboards are not permissible under City Mooring Licenses). I do not feel that the City should take away the last affordable method I'm aware of, for persons of
me, in no more Live-aboard Permits (Liveaboards are not permissible under City Mooring Licenses). I do not feel that the City should take away the last affordable method I'm aware of, for persons of lesser means to live/work in Newport Beach. Nor should the City do anything to contribute to the homeless crisis. Newport Beach entering into agreement to ship its homeless out to Costa Mesa, does not mitigate. I feel that given how strictly the City manages/monitors Live-aboards now, the ending of a California boating tradition of over 100 years, is not necessary.
The "Alternative" will result, over time, in erasing the security recreational/ commercial-fishing/marine services/etc./etc. boat owners/operators have, by converting all Mooring Permits to Licenses. Permits run for years, Licenses run month to month. The eventuality of having to deal with where to locate a large boat on short notice, is a horrible thing to experience.
The City has long desired more control, over more permits. There have been discussions in the past, about the City setting aside funds to purchase permits.
Based upon the Mooring Permit Transfer Log for calendar year 2024, through "3.25.24", they could have obtained 7 Mooring Permits in desirable lengths, for less than the cost of the new electric Harbor Department Patrol boat on order. The fact that the City hopes to Codify an ability to revoke/impound/confiscate Permits at no cost instead, does not make doing so "right" or "just".
The City could have been reducing issues related to "Permit Transferability" for years, by purchasing Permits as they became available. Permits are regularly available. The City did substantially increase the cut it receives through Transfer Fees. That specific income should have been applied to increasing the City's
became available. Permits are regularly available. The City did substantially increase the cut it receives through Transfer Fees. That specific income should have been applied to increasing the City's inventory of Permits. The fact that Permits have come to have an associated value, does not make members of the public holding Permits guilty of something. I had to save and plan for years to be able to acquire a Mooring Permit. The fact that doing so can pose difficulty, does not mean that the process is fatally flawed.
Everyone who wants a Bentley, can't afford one. Everyone who wants a government Permit to operate a Radio or T.V. station can't afford one. Everyone who wants to harvest/extract natural resources from public lands (Oil and gas/Timber/Mineral/Etc.), cannot afford a Permit to do so. The fact that everyone who wants a Mooring Permit, cannot immediately afford one, is consistent, and logical.
It seems that some City actors look at asking prices for Mooring Permits, and errantly conclude that any amount identified, is 100% profit. This could not be further from the truth. I have been keeping a close eye on, and studying Mooring Permits in Newport for over 15 years. I have found, that when the maintenance costs, rent, and other expenses and difficulties are factored in, there is typically little financial gain in Transferring Permits. Historical policy making decisions are a primary contributing factor to Permits having come to have some associated value (Discussed in more detail below). Policy created this, and policy to remedy it, should not subject innocent parties to extreme loss through potential Eminent domain/Inverse condemnation/Municipal theft/Constitutional due process taking violations/Etc.
is, and policy to remedy it, should not subject innocent parties to extreme loss through potential Eminent domain/Inverse condemnation/Municipal theft/Constitutional due process taking violations/Etc.
What the City has referred to as "Grandfathering” rates for Mooring Permit Holders as of a date certain, is not actually provided for under the plan. Mayor and Council stated during their July 9 Meeting, that future Mayors and Councils could change pricing. Moreover, this Mayor, Council, and Harbormaster, have done 180-degree reversals on previous assurances they've made to stakeholders.
Past City actions, have shown beyond any doubt, that the City's word, is not its bond. Permit holders, at present, have no security as far as future rates/fees.
Important to acknowledge too, is that a discriminatory and unfair rate (Moorings vs. Residential Piers/Docks), paid over the unsubstantiated promise of a Permittee's life-time, or until Mayor and Council change their minds, remains a discriminatory and unfair rate!
The California State Lands Commission (Hereafter “SLC"), calculates annual rental rates for the lease of State tide and submerged lands approximately every 5 years, the last time being about two years ago, in June of 2022. Their current Category 1 Benchmark rate for Southern California, is .451 cents per square foot per year. Newport Beach data was used in determining that rate. Associated SLC Staff Report 39, for purposes of comparing commercial marinas to buoys/mooring poles states: “These facilities offer many of the same amenities as a commercial marina, such as a place for the docking and mooring of boats and the loading and unloading of passengers and equipment".
SLC Staff Report 39 uses the words "fair"; "equitable"; "reasonable"; "consistent";
na, such as a place for the docking and mooring of boats and the loading and unloading of passengers and equipment".
SLC Staff Report 39 uses the words "fair"; "equitable"; "reasonable"; "consistent"; and "appropriate", to describe their current Benchmark rate. This means that the current rate of .451 cents per square foot per year, is what the State, with vast levels of knowledge and experience in such things, has determined to be “fair” here. The formula The State used to set that rate, has been clearly outlined. It's not rocket science.
Moorings in Newport Harbor, are clearly lacking in the amenities of docking, and the loading and unloading of passengers and equipment. A lack of onshore parking, access to utilities and services, and dinghy/tender storage have also been cited as impediments Mooring Permitees face here. Over all, Residential Pier Permits have a much greater level of utility and value, yet pay less in fees.
And while Mooring Permittees are prohibited by Code from subletting their Mooring Permits, Residential Pier Permittees are allowed to sublet their dock space, often at substantial financial gain. Little of this goes into the Tidelands Fund, other than the fee calculated over the actual physical footprint of the pier/dock. Fees are not assessed by the City, over the space the many vessels there occupy. And interestingly, the City Codified that it may sublet permitted moorings, with the City keeping all of the proceeds. Mooring Permitees are also required to add The City as insureds to their vessel policies, providing the City millions of dollars of free coverage. Apparently, Residential Pier Permittees are exempted from this standard. The City's Mooring vs. Pier/Dock discrimination,
heir vessel policies, providing the City millions of dollars of free coverage. Apparently, Residential Pier Permittees are exempted from this standard. The City's Mooring vs. Pier/Dock discrimination, extends far beyond just pricing. And still, with the various challenges faced by Mooring Permitees, and a much higher level of imposed City restriction, this group currently pays much more in rent/fee amounts.
The City of Newport Beach's Fee Schedule, dictates that Residential Piers, aka docks over State owned, City managed tide/submerged lands adjacent to residential properties, incur annual rental fees of .57 cents per square foot per year. Various City Resolutions setting past and present fees for these Residential Pier Permits in Newport, for use of the same lands as Mooring Permitees, describe those rates as “fair market value rent”. That being the case, The City's current Residential Pier Permit rate, must be considered to be fair.
Information is also readily available, indicating that Offshore Mooring rents/fees in Newport Beach, are presently higher, sometimes significantly so, than those in other areas of the State. (Attachment A) As I mentioned during Coastal Commission Public Comment on July 12, 2024, coincidentally, or ironically, Residential Pier Permit fees were also on the City Council Agenda for July 9 (Attachment B). In spite of The SLC noting in April, that it's an "opportune" time to address "significant" rate disparity, and in spite of the Coastal Commission in July, recommending that the City "develop a proposal to simultaneously implement the updated rates for both moorings and private slips to resolve this discrepancy", the City increased the Residential Pier Permit rate/fee by an insignificant 1 to 2 cents per square foot per year, while at
ated rates for both moorings and private slips to resolve this discrepancy", the City increased the Residential Pier Permit rate/fee by an insignificant 1 to 2 cents per square foot per year, while at the very same meeting, voted to increase the already higher mooring fees, by hundreds of percentages. These actions, in tandem, assured that Harbor Commissioners; Electeds; and others, for the space their piers/docks/boats encumber over granted sovereign lands, will continue to be assessed much lower fees on their docks, and no fees at all on their boats. How can the City think that fee free boat storage at these spaces, is not an unconstitutional gift? This just baffles me.
As I think you know, a 2024 Appraisal Report from highly regarded firm CBRE, determined fair annual rent amounts for offshore moorings in Newport, closely in line with what they are presently. The City commissioned Netzer and Associates Appraisal Report of 12/26/2023 on the other hand (Again, Holiday proximate timing), concluded that Offshore Mooring rents should increase exponentially.
Netzer's conclusions appear based on inappropriate/flawed methodology; comparisons to dry-land real properties; for-profit Marina slips; etc.; etc. These do not so closely compare to moorings over generally undevelopable land/water, as is implied. Netzer materials also evidence some discrepancy about how many offshore mooring fields, and how many public docks exist in Newport Harbor, and contradict a 2016 determination made by the very same firm: Mr. Netzer's January 6, 2016 Appraisal, stated: "The Ratio analysis attempts to estimate the market rent for moorings as compared to the rent for similar slip spaces in the same marina or harbor. As shown in the analysis, the ratio can vary dramatically (25% to 92%) and,
empts to estimate the market rent for moorings as compared to the rent for similar slip spaces in the same marina or harbor. As shown in the analysis, the ratio can vary dramatically (25% to 92%) and, while a potential renter could take this into consideration (cost of a slip v.
cost of a mooring), it is not judged to be a reliable measure of Fair Market Rent."
Timelines related to various Netzer Appraisal Reports, and other interactions with The City, have also raised serious concern among many. Addressing materials sourced from various Public Records Requests, some of which I've seen presented at local City, and Yacht Club meetings: The timing of Newport Beach Harbor Commissioner Scott Cunningham's e-mail of July 22, 2020, as related to the subsequent Mooring Appraisal RFP, is quite concerning. The RFP for the Appraisal wasn't even "Posted" by the City, until April of the following year, and "Awarded on August 3, 2021", after four firms had submitted bids. (Attachment C) Harbor Commissioner Cunningham, seemingly knowing nearly a year in advance, that James B. "Jim" Netzer would be the Appraiser selected, and knowing from "two long conversations with Jim" prior to his selection, that the resulting appraisal would deviate substantially from Mr. Netzer's January 6, 2016 Appraisal, tends towards indication of a rigged selection process, and a curated appraisal. Commissioner Cunningham, also took it upon himself to e-mail the chosen Appraiser online listings of Mooring Permits purportedly for sale. This looks to me, like further effort to influence the Appraisal.
Serious concerns also arise from the fact that in April/May 2022, to alleviate any conflict of interest, The Harbormaster had entered into an agreement with the City,
ffort to influence the Appraisal.
Serious concerns also arise from the fact that in April/May 2022, to alleviate any conflict of interest, The Harbormaster had entered into an agreement with the City, to not participate in discussions related to offshore moorings (Attachment D).
Public Records requests however, have shown multiple instances of participation in 2023 and 2024. Are we to conclude that the City Attorney; select City staff/ personnel; The Harbormaster, et al., all simply forgot about this agreement? Or, that the parties knowingly disregarded it? Is either scenario acceptable?
Although boats on shore moorings are restricted to no more than 8' wide, and 18' long, communications indicate that Mr. Netzer tells the Harbormaster that he uses a length of 36' long for his calculations. The Harbormaster, subsequent to having entered into the agreement that he ""does not participate in discussions or the development of recommendations related to use or financial arrangements associated with offshore moorings", responds in kind, with likewise inflated numbers, writing that a boat on a 40' Mooring would typically be 14' wide, and 40' long (Note: Boats with rectangular footprints are very uncommon). The Harbormaster then opines, that the actual square footage of Tide/Submerged lands a mooring would encumber, could be 20' x 60', or 20' x 80'.
Other e-mails show the Harbormaster telling the Appraiser to price a 25' Mooring at the 30' rate. Similarly, the Phase-in documents the City provided the State, apply the rate for 20', well-appointed marina slips at the City's Balboa Yacht Basin Marina ($32.23 per If), to 18', challenging to use, Permitted shore moorings.
An apparent pattern of basing conclusions on calculations using more space than
ina slips at the City's Balboa Yacht Basin Marina ($32.23 per If), to 18', challenging to use, Permitted shore moorings.
An apparent pattern of basing conclusions on calculations using more space than is actually encumbered by moored vessels, in conjunction with applying higher fee rates to lower tier permits, unrealistically inflates the resultant prices.
Important to understand too, is that boats on moorings do not continually occupy any such amount of space, and that other Tide/Submerged land users regularly transition through, and use much of that supposed mooring space for their activities. The City, and parties holding Residential Pier/Dock Permits on the other hand, occupy a generally fixed space, and often proclaim that the spaces they use over public lands, are not to be used by anyone else. (Attachment E) And in early October of 2023, Jim Netzer, acting on behalf of The Newport Aquatic Center (Hereafter NAC), was involved in negotiating from the City, a 3 to 5 decade long, "Amended and Restarted" zero fee ground lease, for acres of prime, waterfront sovereign land. The City generously waived its policy F-7 requirement, that full fair market value be obtained under said lease. Mr. Netzer, along with the Harbormaster's brother, are/were Board Members of the NAC. Mr.
Netzer's family members, also have close ties with the NAC (Please refer to "Presentation BYC Meeting 04-08-2024” previously provided).
Just a couple of weeks subsequent to this no fee lease, a Microsoft Teams meeting, captioned "Appraisal Kick-Off Call Off-shore Moorings" was arranged.
City personnel, including the Harbormaster and Commissioner Cunningham, as well as the Appraiser, were to participate. The timing of the no-cost lease, so
ck-Off Call Off-shore Moorings" was arranged.
City personnel, including the Harbormaster and Commissioner Cunningham, as well as the Appraiser, were to participate. The timing of the no-cost lease, so closely coinciding with the kick-off for an Appraisal Report that Harbor Commissioner Cunningham said would quote - unquote “look much different", along with Mr. Netzer's reversal of his 2016 position that a slip to mooring ratio is not judged a reliable measure of Fair Market Rent, and the involvement of multiple parties with financial interests, who thus, should not have even been involved, raises numerous, serious concerns, quid pro quo being one. And if events in the timeline do not rise to a level of impropriety, I think they certainly rise to the level of the appearance of impropriety.
The City has also tried to use the new, and relatively untested City Mooring License Program, to rationalize extreme fee increases for these water only permits. Under the Program though, the City maintains the mooring tackle. In contrast, individual Mooring Permitees incur that not insignificant expense themselves. The City has also touted the number of Mooring License applicants, as justification to raise fees exponentially. Subsequent determination though, indicated that some applicants were using multiple e-mail addresses to apply.
Consequently, the high numbers of applicants the City cites, are not accurate.
40' moorings are said to be the most common. Even if the near 20 License applications for the single 40' Mooring License the City offered, were truly separate individuals applying, auction style pricing would be the result. The sole 30' Mooring License, suffers from the same deficiencies. Moreover, at the Harbor
License the City offered, were truly separate individuals applying, auction style pricing would be the result. The sole 30' Mooring License, suffers from the same deficiencies. Moreover, at the Harbor Commission meeting of July 10, 2024, I believe the Harbormaster stated that three 50' Licenses remain unclaimed. If there is such high demand, why are these vacant? The City's Mooring License data, cannot rationally be used to determine "fair market rent”.
Consider too, that near 100 moorings sit unoccupied in Newport Harbor on any given day. This is due in large part, to the fact that the overnight sublet price set by the City, pencils out to be near the cost of a fully appointed marina slip! The over-pricing of the many empty moorings, deprives the Tideland's Fund of potential revenue, and creates a false scarcity. This in turn, serves to drive up the price which might be obtained for the very limited number of City held Mooring Licenses (16). It's simple supply and demand economics. Pricing is being artificially manipulated through policy.
Conclusion: The City willfully and knowingly choosing to ignore multiple sources of reliable and consistent data, in favor of manipulated and flawed data, is beyond problematic. As is the City choosing to rely on their preferred, outlier Appraisal Report.
An ongoing refusal by the City to accept that the current SLC Benchmark rate; Their own Residential Pier Permit fee; The CBRE Offshore Mooring Appraisal Report values; and the lower fees for moorings in other areas of the State establish "fair market rent" for moorings, should not be encouraged through the granting of autonomy from the State.
Until this most recent misguided and deceptive Harbor Commission rate increase
tate establish "fair market rent" for moorings, should not be encouraged through the granting of autonomy from the State.
Until this most recent misguided and deceptive Harbor Commission rate increase Recommendation was begun, Mooring Permitees, for use of the same State resource, were willingly paying multiple times more in rates than Residential Pier Permitees. Oftentimes, the moorings and piers are not even very distant from one another. It is difficult to extract fairness from this disparity, but it was being tolerated. As more and more information has come to light during the progression of the Recommendation and Alternative though, the level of unfairness has become increasing pronounced, concerning, and to many, unacceptable.
How could Harbor Commissioner Vice Chair Ira Beer, in good conscience, have repeatedly implied that Mooring Permittees, while paying higher fees, may be beneficiaries of unconstitutional gifts of the use of State lands, while at the same time, others are paying no fees for the actual space their associated vessels occupy? How could have each Harbor Commissioner, in good conscience, have ethically endorsed increasing the rate disparity and discrimination even further?
And in the same vein, how can The Harbor Commission, some of whom are equity members in Newport Yacht Clubs, think that it's "fair" to not subject themselves or their peer's Clubs, and The Lido Isle Community Association, to the same excessive fee increases, in the same timelines they propose for Mooring Permittees unaffiliated with these exclusive entities? And how could Mayor, and five of six Councilmembers have bought into this?
I contend, that in addition to what has occurred being morally offensive to many,
unaffiliated with these exclusive entities? And how could Mayor, and five of six Councilmembers have bought into this?
I contend, that in addition to what has occurred being morally offensive to many, the City's proposals to implement such significant changes in use and pricing, along with their removal of individual's ability to hold Permits for longer than a month at a time, are changes so drastic, that at the very least, the City must be required to obtain CDP(s)..... Regardless of whether or not the City suggests that it will spread the significant changes out, over some unsecured, indeterminant, and unpredictable period of time.
Sincerely, Adam Levenges Adam Leverenz [email protected] Attachment A: Statewide Mooring Rent/Fee Comparison: 1 pg.
Mooring fees in California 2024 Yearly fees for 40' boat Avalon Yearly fee to city 24/7 dinghy docks provided.
Morro Bay Yearly fee to city 24/7 dinghy dock provided.
San Diego Shelter Island Yearly fee to city 24/7 dinghy dock provided.
Monterey Bay Yearly fee to city 24/7 dingy dock $600 yr $523.20.
$1320.
$1538.04. (Maintenance included) $1000.
Santa Barbara Yearly fee to city is $350.00.
24/7 dingy dock $125 yr Conclusion: Average yearly fees in California $1091.25 24/7 dinghy docks provided: Newport Harbor $1603.00 Mooring permitee must pay approx. $750 yearly for mooring maintenance and upkeep.
No dinghy docks provided After new fee schedule phase-in: $5760.00* This rate hike is designed to deny access to all but the wealthiest people, and force middle class boaters out of the harbor. It will put an end to affordable family boating in Newport Harbor.
*This number will increase in proportion to increases in marina fee increases and inflation.
Attachment B: Public Comment Slide Coastal Commission July 12, 2024: 1 pg.
amily boating in Newport Harbor.
*This number will increase in proportion to increases in marina fee increases and inflation.
Attachment B: Public Comment Slide Coastal Commission July 12, 2024: 1 pg.
California State Lands Act, CHAPTER 74, SECTION 1 (a)(3)(d) (d) In the management, conduct, operation, and control of the lands or any improvements, betterments, or structures thereon, the city or its successors shall make no discrimination in rates, tolls, or charges for any use or service in connection therewith.
3.3.2-3.
City of Newport Beach Local Coastal Program - Coastal Land Use Plan Continue to provide shore moorings and offshore moorings as an important source of low-cost public access to the water and harbor.
CALIFORNIA STATE LANDS COMMISSION 100 Howe Avenue, Suite 100-South Sacramento, CA 95825-8202 Lauren Wooding Whitlinger Real Property Administrator City of Newport Beach April 9, 2024 Page 3 impact of increased rates. Staff also observes a significant disparity between the City's residential pier rates and mooring rates. In addition to reassessing mooring rates, staff believes it is an opportune time for the City to also reassess its residential pier rates to ensure these rates reflect fair market value consistent with the City's granting statutes and fiduciary duties.
CITY OF NEWPORT BEACH NEWPORT BEACH City Council Staff Report Agenda Item No. 3 July 9, 2024 RECOMMENDATIONS: b) Adopt Resolution No. 2024-44, A Resolution of the City of Newport Beach, California, Revising Certain Rents Within the Schedule of Rents, Fine and Fees.
PUBLIC WORKS - HARBOR RESOURCES 1 Piers a) Residential $0.56 $0.55 $0.57 per sq ft Attachment C: Harbor Commissioner e-mails/ RFP Invitation #21-53 Info: 5 pgs.
On Jul 22, 2020, at 1:48 PM, Cunningham, Scott
WORKS - HARBOR RESOURCES 1 Piers a) Residential $0.56 $0.55 $0.57 per sq ft Attachment C: Harbor Commissioner e-mails/ RFP Invitation #21-53 Info: 5 pgs.
On Jul 22, 2020, at 1:48 PM, Cunningham, Scott Removing Jim.
Hi All, I've had two long conversations with Jim regarding the 2016 Mooring Appraisal.
The net net is when we are ready (and funded) the appraisal results will look much different than the 2016 numbers.
Note the dates: Scotts email - 7/22/2020 TENTATIVE PROJECT SCHEDULE RFP Published: April 8, 2021 RFP 21-53 Published - 4/8/2021 73 City of Newport Beach Bid Opportunities Keyword Department Bid Type Due Date From Categories Due Date To Stage Clear Search NEWS LOG IN Found 862 bids Posted Project Title 04/08/2021 Tidelands On-Shore & Off-Shore Appraisal Services 04/27/2021 Landfill Gas (LFG) Control System Operation & Mainte... 21-57 Invitation # 21-53 Due Date Remaining Stage Format 05/20/2021 01:00pm Awarded Electronic 05/18/2021 01:00pm Awarded Electronic 04/20/2021 Business License and Permit Processing Software 04/28/2021 (4) 2021 Ford F-150 2WD SuperCab Trucks 21-55 05/18/2021 01:00pm Awarded Electronic 21-58 05/12/2021 01:00pm Closed Electronic 04/19/2021 On-Call Traffic/Transportation Engineering 21-09 05/10/2021 03:00pm Awarded Electronic 04/15/2021 FY2020-21 Traffic Signal Rehabilitation C-7791-1 05/10/2021 10:00am Closed Electronic 04/13/2021 Establishment of Eligibility List for Referral of Real Est... 21-54 04/28/2021 01:00pm Closed Electronic 04/01/2021 Armored Transport Services 21-52 04/28/2021 01:00pm Awarded Electronic 03/19/2021 UNDERGROUND STORAGE TANKS - TESTING, DESIG... 7223-1 03/22/2021 Parking Code Consulting Services 04/20/2021 02:00pm Award Pending Electronic 21-43 04/13/2021 01:00pm Awarded
rded Electronic 03/19/2021 UNDERGROUND STORAGE TANKS - TESTING, DESIG... 7223-1 03/22/2021 Parking Code Consulting Services 04/20/2021 02:00pm Award Pending Electronic 21-43 04/13/2021 01:00pm Awarded Electronic 03/19/2021 AS-NEEDED SPORT & RECREATIONAL FIELD LANDS...
03/24/2021 As-Needed Athletic and Recreational Field Services 03/25/2021 Dover Shores Traffic Calming Improvements 03/24/2021 (3) 2021 Toyota Tacoma 4x4 Double Cab Vehicles 02/18/2021 7997-1 04/08/2021 02:00pm Awarded Electronic 21-45 04/08/2021 01:00pm Awarded Electronic 7998-1 04/08/2021 10:00am Closed Electronic 21-46 04/07/2021 01:00pm Closed Electronic UNDERGROUND UTILITY ASSESSMENT DISTRICT N... 7979-1 04/07/2021 10:00am Awarded Electronic 03/10/2021 Generator Maintenance & Repair Services 21-41 04/06/2021 01:00pm Awarded Electronic PLANET BİDS Copyright © 2024 PlanetBids, LLC City of Newport Beach < Back to Bid Search Tidelands On-Shore & Off-Shore Appraisal Services 21-53 Bid Information Documents Addenda/Emails Q&A Prospective Bidders Bid Results Awards Showing 4 Bid Results Vendor Lea Associates, Inc.
1631 Pontius Avenue Los Angeles, California 90025 Contact: Robert M. Lea, MAI Phone: 310-477-6595 Netzer & Associates 170 E. Seventeenth Street, Suite 206 Costa Mesa, California 92627 Contact: James Netzer, MAI Phone: 9496316799 R. P. Laurain & Associates, Inc.
3353 Linden Avenue Suite 200 Long Beach, California 90807 Contact: John P Laurain Phone: 5624260477 The Dore Group Inc 1010 University Avenue Suite C207 San Diego, California 92103 Contact: Lance W. Dore Phone: 619-933-5040 ext. 101 PLANET BIDS Copyright ©2024 PlanetBids, LLC Type Bid Amount NEWS LOG IN Ranking $0.0000 0 Responsive Yes $0.0000 0 Yes $0.0000 0 Yes
alifornia 92103 Contact: Lance W. Dore Phone: 619-933-5040 ext. 101 PLANET BIDS Copyright ©2024 PlanetBids, LLC Type Bid Amount NEWS LOG IN Ranking $0.0000 0 Responsive Yes $0.0000 0 Yes $0.0000 0 Yes $0.0000 0 Yes DGS Awarded City of Newport Beach < Back to Bid Search Tidelands On-Shore & Off-Shore Appraisal Services 21-53 NEWS LOG IN Awarded Bid Information Documents Addenda/Emails Q&A Prospective Bidders Bid Results Awards Awarded on August 3, 2021 Please see the attached Notice of Intent to Award (also uploaded under the "Addenda & Emails" tab of this RFP page) for additional details regarding the evaluation and award process for RFP 21-53.
The project has been awarded to Netzer & Associates View Item # ✓ Complete Project 1 PLANET BIDS Copyright ©2024 PlanetBids, LLC Item Code Description UOM Tidelands On-Shore & Off-Shore Appraisal Services Complete Project Qty 1 From: To: Cc: Subject: Date: Attachments: Scott Cunningham Jim Netzer Wooding, Lauren 45" Newport Offshore Mooring in D Field - boats - by owner - marine sale - craigslist September 20, 2023 1:03:50 PM 45" Newport Offshore Mooring in D Field - boats - by owner - marine sale - craigslist.png [EXTERNAL EMAIL] DO NOT CLICK links or attachments unless you recognize the sender and know the content is safe Nice tidy profit...
From: To: CC: Subject: Date: Hi Jim, Cunningham, Scott Jim Netzer Wooding, Lauren Fwd: alert: Newport Mooring June 09, 2022 10:17:32 AM Scott Cunningham Begin forwarded message: Date: June 9, 2022 at 9:36:41 AM PDT To: [email protected] Subject: alert: Newport Mooring
2022 10:17:32 AM Scott Cunningham Begin forwarded message: Date: June 9, 2022 at 9:36:41 AM PDT To: [email protected] Subject: alert: Newport Mooring 1 new result for search terms: Newport Mooring, sort: relevant, as of 2022-06-09 09:36:37 AM PDT Probably going to move forward with offshore appraisal towards end of Summer but wanted you to keep this for your records. Check out last sentence.
⚫ Newport Mooring - $48,000 (Newport Beach) View all the results.
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Thanks, Scott Commissioner Cunningham is seen here sending emails of craigslist ads, which shows the purported listings of craigslist ads for offshore moorings for sale 99 66 Attachment D: Harbormaster/ City Attorney/ City Agreement & Some related e-mails: 5 pgs.
Harbormaster Update – April 2022 Activities May 11, 2022 Page 5 Initiatives were launched resulting in better data capture and statistics reporting.
Future improvements will include customer satisfaction survey data analysis and calls for service location analysis Participated in the Emergency Operations Response to the following: о Elly oil spill Tsunami warning Three severe weather occurrences Sewage spill into the harbor Out of control stolen boat in the harbor The Harbormaster has disclosed the arrangements made, at his own expense to alleviate any conflict of interest associated with his ongoing use of an offshore mooring permit.
While undergoing the recruitment process, any and all known possible conflicts of interest were disclosed. Prior to the City making an offer of employment, all such possible conflicts were discussed with the City Attorney. Agreements and arrangements satisfactory to all relevant parties were made during that discussion. The Harbormaster
er of employment, all such possible conflicts were discussed with the City Attorney. Agreements and arrangements satisfactory to all relevant parties were made during that discussion. The Harbormaster was entrusted and empowered to make determinations going forward related to any conflict disclosures. In support of this arrangement, the Harbormaster: does not participate in discussions or the development of recommendations related to use or financial arrangements associated with offshore moorings reminds anyone with an interest that input on recommendations related to offshore mooring permits are made by Real Property Administration staff does not deliberate or vote on any policy related matters before the Harbor Commission is expected to answer questions related to policy implementation and impacts on Harbor Department operations hereby discloses that the offshore mooring permit he enjoys is held in an irrevocable trust the beneficiary of which is the Balboa Yacht Club. The Balboa Yacht Club holds all the offshore mooring permits adjacent to the subject mooring hoping to avoid other conflict of interest concerns also hereby discloses any significant financial interests related to the Balboa Yacht Club including a membership certificate are held in the same irrevocable trust further discloses that all remaining financial interests in either the subject offshore mooring permit or membership in the Balboa Yacht Club are de minimis ENVIRONMENTAL REVIEW: Staff recommends the Harbor Commission find this action is not subject to the California Environmental Quality Act (CEQA) pursuant to Sections 15060(c)(2) (the activity will not result in a direct or reasonably foreseeable indirect physical change in the environment)
ect to the California Environmental Quality Act (CEQA) pursuant to Sections 15060(c)(2) (the activity will not result in a direct or reasonably foreseeable indirect physical change in the environment) and 15060(c)(3) (the activity is not a project as defined in Section 15378) of the CEQA From: To: Subject: Date: [email protected] Wooding, Lauren; Blank, Paul Offshore Mooring Appraisal Question December 05, 2023 4:08:15 PM [EXTERNAL EMAIL] DO NOT CLICK links or attachments unless you recognize the sender and know the content is safe.
Lauren & Paul, I am trying to get the draft appraisal completed but I have a question about the size of a "typical" mooring and the square feet of tidelands that it encumbers. On methodology I apply the "land value" to the square footage and convert it to a rental rate. In the onshore mooring appraisal I based the value on an onshore mooring encumbering an area of 288 square feet (36' x 8') based on the "typical" area from the point of attachment (seawall) to the mooring buoy/ball and an 8' beam. What dimensions and square footage should I use for the offshore mooring?
Thanks for your assistance!
Regards, Jim Netzer 67 20 From: To: Subject: Date: Attachments: Blank, Paul [email protected] RE: DRAFT - Offshore Mooring Appraisal w/ Tiered rates December 27, 2023 10:23:00 AM image001.png From: To: Subject: Date: Attachments: Wooding, Lauren "[email protected]" RE: DRAFT APPRAISAL - Offshore Moorings - Fair Market Rent December 20, 2023 5:18:00 PM image001.png Great work!!
Thank you.
Have a great New Year.
CITY NEWPORT From: To: Cc: Subject: Date: Attachments: Blank, Paul Paul Blank Harbormaster jamesbnetzer Wooding, Lauren Re: Offshore Mooring Appraisal Question December 05, 2023 4:48:06 PM PastedGraphic-2.png
PORT From: To: Cc: Subject: Date: Attachments: Blank, Paul Paul Blank Harbormaster jamesbnetzer Wooding, Lauren Re: Offshore Mooring Appraisal Question December 05, 2023 4:48:06 PM PastedGraphic-2.png The cool thing about onshore moorings is they are essentially all the same size.
Offshore moorings are of a variety of sizes (25', 30', 35', 40'...90').
Any dimensions I give you will be subject to critique as "not representative of the variety of sizes, configurations and conditions” actually out there.
That disclaimer out of the way, the biggest population of moorings out there are 40' moorings.
A typical 40' boat on one of those moorings would be 40' long x 14' wide but the mooring takes up much more space than that.
The distance from the boat to each mooring float is approximately 10' - so the space taken up on the surface is approximately 60'. Then there is the placement of the weights on the sea floor. The distance from the float to the weight adds at least 7' and up to as many as 15' to each end of the mooring depending on the depth where the mooring is placed.
If you want to go with just the surface dimensions consumed by the typical mooring on Newport Harbor, go with 60' x 20'.
If you want to go with the dimensions of the entire mooring including what's below the surface, go with 80' x 20'.
Best, Hi Jim, Thanks very much for getting this draft in to me before the end of the year. I will be sharing internally and will be in touch after the new year with any comments or changes before we have you finalize the report and take it out of draft mode.
I hope you have a very Merry Christmas and Happy New Year and get to spend time with your family in the next few weeks!
And I look forward to catching up with you in the new year.
Thank you, Lauren OF NEWPORT ORT BE
a very Merry Christmas and Happy New Year and get to spend time with your family in the next few weeks!
And I look forward to catching up with you in the new year.
Thank you, Lauren OF NEWPORT ORT BE Lauren Wooding Whitlinger Real Property Administrator Community Development Department wrote: Hi Jim, I'm going through the report and have some additional comments and questions that I'd like to address before we publish this, since I know it will be reviewed very closely.
Do you have time tomorrow morning to review with me?
Thank you, Lauren NEWPORT Lauren Wooding Whitlinger Real Property Administrator NEWPORT Paul Blank Harbormaster 70 70 --Original Message----Sent: Mon, Jan 31, 2022 10:35 am Subject: FW: Shore Mooring Rental Rate Increase Hi Jim, Thanks for answering all of the questions I submitted to you. I am reviewing them with Paul and will let you know if we have any further questions.
In the meantime, can you review the email below and let me know when you have some time to chat. I think this should be considered in our valuation, but I think it is mostly a matter of administrative capacity. I want to get your take on it before I discuss further with Paul.
Thank you, Lauren OF NEWPORT BE LAUREN WOODING WHITLINGER Community Development Department 71 Howdy Jim: Thanks for taking the meeting this morning.
Upon further inspection of that one 25' mooring in the BYC field, I noticed that an individual holds it and therefore needs a rate set by the City.
I don't think you need to perform some extensive analysis just for that one mooring.
one 25' mooring in the BYC field, I noticed that an individual holds it and therefore needs a rate set by the City.
I don't think you need to perform some extensive analysis just for that one mooring.
Please just apply the 30' rate you determine to that mooring but definitely add an entry in the report that includes the 25' category.
Sorry for my previous inaccurate or incomplete statement.
EWPOR Paul Blank Harbormaster 72 Attachment E: A partial selection of images, showing various members of the public transitioning through; recreating in; and using the supposed space Mooring Permittees are claimed by the City, to have Private Exclusive Use of, as compared to the level of Private Exclusive Use exercised by the City itself, and select Residential Pier Permitees: 21 pgs.
الكرز 119-H 136 BARK The following images, show City and Residential piers/docks, which occupy granted sovereign land, but which are posted as if Private Property: Authorized Guests Only No Trespassing For harbor information and services plea Department contact the City of Newport Beach Herber Office: 949-270-8159 Dockmaster 949 514-7040 VHF Chander 1 MyNS App AUTHORIZED GUESTS ONLY NO TRESPASSING 20 AUTHORIZED GUESTS ONLY NO TRESPASSING of part eh Dict (949) 270-8159 VHF Channel 19A MYNB app +9 ER 20 PRIVATE DOCK AND PROPERTY TRESPASSING PRIVA 20 B E+: PIER WATER EDGE 19AY DOCK PRIVATE EED OFF EP LEASE PRIVATE WASSALL'S VIVATE DOCK EDGEWATER PRIVATE BEACHANDDOCK FUSTED PRIVATE PROPERTY HUNTING, FISHING, TRAPPING OR TRESPASSING FOR ANY PURPOSE IS STRICTLY FORBIDOEN POLATOES WILL PROSECUTED PRIVATE BEACH む PRIVATE DOCK Costal commission application 5-23-0753 As a long-time mooring user, my experience tells me this application is filled with smoke and mirrors.
What's wrong with this application?
BEACH む PRIVATE DOCK Costal commission application 5-23-0753 As a long-time mooring user, my experience tells me this application is filled with smoke and mirrors.
What's wrong with this application?
1. While it suggests environmental improvement, it isn't, when you look at allowing the single can moorings that "will not be part of any changes" to do 400% more damage to the sea floor. Those moorings are operated for the exclusive use of two yacht Clubs. Those clubs pocket the profit from subletting these moorings. No other moorings allow subletting. You have to think the City of Newport Beach is starting in the wrong place for environmental and physical management.
2. Screwing in helical anchors is fine, however, to have any value to the environment the entire system must be employed. This requires unique mid depth floats and the use of lines from the anchors to them. Replacing the all chain use that has been the standard and works well.
3. The cost of renovating the mooring fields was promised to be at the expense of the City. We think that is an empty promise as the costs are likely to be underestimated. The permit users will be priced out of using these areas by the City's POSH designs.
4. The mooring maintenance is currently done by barge at the permit holders expense. The proposed changes could cause the inspection period to change. Because those inspections would have to be done by divers, the cost could be many times the current expense. The application doesn't address this issue.
5. Over the years, the lack of good management has allowed some problems to develop. Most of these are by accuracy of the mooring's locations and the mixing of boat sizes. Both of these are easily
ue.
5. Over the years, the lack of good management has allowed some problems to develop. Most of these are by accuracy of the mooring's locations and the mixing of boat sizes. Both of these are easily corrected and almost the entire cost could be covered at the biannual maintenance inspection by the permitted.
6. This project is a hidden attempt to take control of the tide lands for the cities benefit.
I would like you to send this application back to Newport Beach with this message: We understand that the use of state tide lands by average income users might not make Billion dollar water front real estate owners happy, however, it is the intention of this State Commission to allow sharing of these State resources. Your City while blatantly ignoring more pressing issues, is proposing unproven and unsafe design changes that will change value, interrupt the use of and out price the use of these tide lands by the current users. This project will become an economic disaster for the current users. Your City seems to want to be in the mooring business and the location of those Marinas is Public Tide lands. Owning and operating Marinas is not the same as Managing tide lands.
We would like to better understand what your overall intentions and the true impacts are before you start his project. We would also like you to detail how you will remediate the area if this "test" project fails to work as intended.
Thank you for what you do Tim Lewis O Outlook FW: Newport Beach - Public Comment on February 2025 Agenda Item Wednesday 16b Application No. 5-23-0753 Date Tue 1/28/2025 9:23 AM To Sent: Tuesday, January 28, 2025 9:13 AM
Date Tue 1/28/2025 9:23 AM To Sent: Tuesday, January 28, 2025 9:13 AM Subject: Newport Beach - Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-230753 Coastal Commission, As an insurance broker for over 40 years, I am writing to express my life safety concerns about changes to the mooring fields in Newport Harbor.
1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels.
Not only is the navigation of the boats more difficult but the access to the beach for swimmers' kayakers, fishing floats and paddle borders is drastically reduced. Currently swimming in from the open channel areas to the beach is difficult due to all of the congestion with boats moored side by side along the sand. Adding moorings will make access that much more complicated and difficult whether side by side or double stacked.
Swimmer access between sand and channel is very important especially during peak season when a huge number of locals and tourists are swimming, paddle boarding, fishing and kayaking. This includes people of all ages and all physical conditions.
The inability for a swimmer to get to the beach quickly in the event of a fall or other emergency is critical. Swimming between boats that are moored shoulder to shoulder is not only very difficult but as the boats move, they can hit swimmers causing injury or loss consciousness.
This loss of space between boats reduces reaction time for swimmers and increases the
lder is not only very difficult but as the boats move, they can hit swimmers causing injury or loss consciousness.
This loss of space between boats reduces reaction time for swimmers and increases the risk of collisions and injuries at all times and not just with high winds and chop conditions.
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group and may be discriminatory for lower income boaters.
3. Alternatives Analysis and Alternative Solutions It is not imperative to add moorings to harbor. Additional moorings bring more revenue to the Commission which is an understandable goal however the additional life safety issues as described above are real.
In addition, the is no need for additional watercraft in the harbor. During the peak season the volume of boat traffic is significant which is at times dangerous. More boats exacerbates the traffic issue and increases the likelihood of injury to all boaters and swimmers.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency.
This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel. This again may be discriminatory because these are the larger more expensive boats using single point moorings and wealthier boat owners.
, which occupy and impact significantly more space per vessel. This again may be discriminatory because these are the larger more expensive boats using single point moorings and wealthier boat owners.
I respectfully ask the California Coastal Commission to deny CDP 5-23-0753. Newport Harbor is one of the finest boat harbors on the world, let's keep it that way!
Thank you, Blake Blake Longo, CIC 253 N. Lake Avenue Pasadena, CA 91101 Direct # 626-657-2274 Cell # 626-975-3131 Blake's License #: 0740399 Agency License #: 0M07762 AJLongo INSURANCE BROKERS O Outlook FW: safety concerns with NB city Harbor department plans Date Mon 1/27/2025 12:39 PM To Sent: Monday, January 27, 2025 9:11 AM Subject: safety concerns with NB city Harbor department plans Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks
s like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve lowcost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency.
This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
nd consistency.
This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Buzz Lowry Newport Beach mooring holder O Outlook FW: newport beach moorings Date Mon 1/27/2025 12:40 PM To Sent: Monday, January 27, 2025 8:26 AM Subject: newport beach moorings Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 523-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California
occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
nd consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, paul O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Tue 1/28/2025 9:23 AM To Sent: Tuesday, January 28, 2025 8:51 AM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual
collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point
ds into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Karen Luttrell NEWPORT HARBOR FOUNDATION EST 2019 CALIFORNIA COASTAL COMMISSION South Coast District Office 301 E. Ocean Blvd, Suite 300 Long Beach, CA 90802 RE: Coastal Development Permit 5-23-0753 Dear California Coastal Commission: January 31, 2025 The Newport Harbor Foundation (NHF) established in 2019 was created for the purpose of preserving, protecting and enhancing Newport Harbor for the benefit of the City of Newport Beach, the homeowners on or near the bay, the commercial operators in the bay, and the recreational user of the bay. The Foundation's founders, contributors, and members are made up of individuals and business who have a long history of using and enjoying the harbor and a vested interest in its enhancement and preservation for use by current and future generations.
A recent meeting of the NHF Board of Directors reviewed the Coastal Development Permit 5-23-0753 (CDP) and by a unanimous vote by the board, it moved to support approval of this permit in its entirety by the California Coastal Commission.
The Board reviewed four points of concern pointed out by the Newport Mooring Association (NMA) that was sent to all mooring users and many NHF members and disagrees with all four points of view regarding the CDP.
viewed four points of concern pointed out by the Newport Mooring Association (NMA) that was sent to all mooring users and many NHF members and disagrees with all four points of view regarding the CDP.
1. Safety Concerns Irrespective of NMA's arguments, the proposed changes will actually move the moorings further apart and allow boaters to maneuver their vessels in a safer manner.
2. Financial Burden on Mooring Holders The City of Newport Beach will bear the cost to test the helical anchors on City owned moorings in this test of Field "C". The test must be successful before any recommendations are made to replace all of the anchors presently used in the mooring fields today.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is not functional, nor are any of the other 9 mooring fields around the harbor. There are many dangerous circumstances that occur on a daily basis in the harbor under various weather conditions. The proposed "Test" of the double-row mooring plan will be able to evaluate and adjust to perfect a better solution of mooring vessels and opening up more water space for safe and enjoyable boating.
4. Inequitable Treatment of This Mooring User Group The distance between the moorings, and more importantly the access lanes ("fairways"), will actually be widened and the distance between the moorings and the shoreline will be increased. This configuration will better protect swimmers, kayakers and paddleboarders from vessel traffic in the harbor. Unlike the two-point mooring fields, the single point mooring fields referred to by the NMA are unsheltered and NEWPORT HARBOR FOUNDATION EST 2019
ds, the single point mooring fields referred to by the NMA are unsheltered and NEWPORT HARBOR FOUNDATION EST 2019 are exposed to climactic events such as storms and high wind events. For this reason, the boats in the single point mooring fields must be able to rotate so the bow of the moored vessel faces the climactic event. A vessel secured by a two-point mooring taking a Santa Ana wind to its side could break loose or swamp.
Please contact me if you have any questions.
Sincerely, Dennis Durgan Dennis Durgan Chairman Newport Harbor Foundation O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Mon 2/3/2025 8:52 AM To Sent: Saturday, February 1, 2025 1:49 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the
The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields
r.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Todd Lyon O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 (City of Newport Beach, Newport Beach) Date Fri 1/31/2025 2:10 PM Sent: Friday, January 31, 2025 1:14 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 (City of Newport Beach, Newport Beach) Coastal Commission Staff, As a resident of Newport Beach and frequent user of the harbor, I strongly support the approval of the city's application (5-23-0753) for the reconfiguration of mooring field C. The improved accessibility for mooring users, and the improved width of runways will greatly benefit all users of the harbor. In addition, safety will be enhanced for swimmers, kayakers, and paddleboarders who utilize this section of the bay.
Thank you.
Edward Lyon 427 San Bernardino Avenue
y benefit all users of the harbor. In addition, safety will be enhanced for swimmers, kayakers, and paddleboarders who utilize this section of the bay.
Thank you.
Edward Lyon 427 San Bernardino Avenue Newport Beach, CA 92663 [email protected] 949.351.4300 (m) O Outlook FW: Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 523-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 12:40 PM To Sent: Monday, January 27, 2025 8:05 AM Subject: Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders
rectly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Bradley W. MacMillan A261 Sent from my iPhone Outlook FW: Public comment on Feb 2025 Date Fri 1/31/2025 7:57 AM To Sent: Friday, January 31, 2025 5:54 AM Subject: Public comment on Feb 2025 Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 523-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: GROUND ZERO: Mooring permit holders cannot safely access their moorings. Live aboard permit holders are forced to share very very limited public dock space with fishermen. The fishermen consistently are overhead casting on the dock, endangering everyone within twenty yards of their hook. My dingy was hooked by fisherman yesterday as I tried to go home to my vessel, missing impailing me with a fishing hook by inches. The general public are being blocked from accessing thee dock as well. Sheriffs have not enforced the law. They have zero infractions reported for YEARS against illegal dangerous fishing practices. We need your help IMMEDIATELY in this regard. We are in danger (photo shows fishing line and hook imbedded in the blue rope)!
nfractions reported for YEARS against illegal dangerous fishing practices. We need your help IMMEDIATELY in this regard. We are in danger (photo shows fishing line and hook imbedded in the blue rope)!
occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holde The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable reatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach
t single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Sandy Manich Newport Beach mooring live aboard resident, full time public school teacher and mooring permit owner O Outlook FW: Public comment -City of Newport Beach Date Fri 1/31/2025 7:57 AM To Sent: Friday, January 31, 2025 6:02 AM Subject: Public comment -City of Newport Beach Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 523-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: GROUND ZERO: Our currrent system of moorings just withstood the winds of one of the worst natural disasters in modern history. Why would the city of Newport Beach even consider changing something that worked impeccably well in the worst conditions? Imprudent city management -
of the worst natural disasters in modern history. Why would the city of Newport Beach even consider changing something that worked impeccably well in the worst conditions? Imprudent city management City of Newport Beach is threatening our homes by trying to force moorings out with their continuous ever increasing regulations on moorings, while they completely ignore issues with private dock permit holders and fisherman breaking the law on public docks.
1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to
s as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sandy Manich Mooring A193 Live aboard permit holders cannot Ca Licensed full time public school teacher, OUSD.
California Coastal Commission South Coast District Office 301 E. Ocean Blvd. Suite 300 Long Beach, CA 90802 January 31, 2025 Subject: Application 5-23-0753 Dear Members of the Commission: I am a Harbor Commissioner for the City of Newport Beach and I highly support and recommend the pilot program for Mooring Field C realignment. This realignment will serve the Harbor users by
mmission: I am a Harbor Commissioner for the City of Newport Beach and I highly support and recommend the pilot program for Mooring Field C realignment. This realignment will serve the Harbor users by reducing the overall footprint of the mooring field yet providing additional moorings to serve the public. The proposal intends to revise the single-row mooring layout to double-rows which will more efficiently utilize the space. The existing and seven new City-owned moorings will utilize helical anchors which will reduce seafloor disruptions.
The existing layout has boats which protrude into fairways and all existing rows provide less than adequate spacing which is not compliant with the harbor design standards. Many vessels are moored outside of the designated mooring field boundary. The existing layout is a poor utilization of valuable water space along the main channel in Newport Harbor. Overall, the realignment will result in better defined rows and fairways that are intended to improve navigation and safety, improve the optimization of space within the field, while adding additional City-moorings. It will result in a greater average distance in rows between boats to allow for safer mooring. The fairways will be substantially wider than the current condition which will improve public access and provide for safer navigation through the mooring fields for both human-powered and motor-powered craft.
The proposed layout will be in substantial compliance with the harbor design standards which currently the layout is not in compliance with. Additionally due to the realignment, approximately two acres of open water would be "created" along the main channel.
There will be no cost to the existing mooring permittees. The new moorings created will be more
due to the realignment, approximately two acres of open water would be "created" along the main channel.
There will be no cost to the existing mooring permittees. The new moorings created will be more affordable than existing moorings given there will be no initial investment to use as there is for existing moorings. Relocations of permittees will be in the same field with consideration for like-forlike positioning where practicable.
I hope you will consider the approval of this pilot program. The City and the Harbor Commission will use the results of this pilot program to incorporate changes to the layout or helical anchors based on the results of the program and then hopefully implement the realignment on a permanent basis.
Sincerely, Marie Mat Marie Marston, P.E.
Harbor Commissioner O Outlook FW: Deny CDP 5-23-0753 Date Tue 1/28/2025 11:47 AM Sent: Tuesday, January 28, 2025 11:34 AM Subject: Deny CDP 5-23-0753 Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds
s to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This
dy compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Craig McCullum (N-25 Mooring Holder) O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b- Application No. 5-23-0753 (City of Newport Beach, Newport Beach) Date Fri 1/31/2025 3:47 PM To Sent: Friday, January 31, 2025 3:47 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b- Application No. 5-23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the
The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce coastal access for ordinary boaters, older boaters, and those with mobility challenges. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, and the use of specialized hydraulic installation equipment, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.23), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional and time tested. The City has not performed a proper alternative Harbor Engineering analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already over
effective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already over crowded mooring fields, rather than first converting spacious "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough Harbor Engineering Safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Jerry and Kathy McGraw Mooring owners and liveaboards O Outlook FW: Comment on Application No. 5-23-0753 City of Newport Beach Date Mon 1/27/2025 12:40 PM Sent: Monday, January 27, 2025 7:54 AM Subject: Comment on Application No. 5-23-0753 City of Newport Beach Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 523-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission members, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to mooring field C in Newport Harbor. I urge you to carefully consider the following points before making your decision: 1. Safety Concerns
t Permit (CDP) 5-23-0753, which proposes significant changes to mooring field C in Newport Harbor. I urge you to carefully consider the following points before making your decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues like myself. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. The public dock at Fernando Street is also not handicap accessible, the stairs are very difficult for me to negotiate and are not ADA compliant, Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, I just serviced my morning, this imposes an undue financial burden on this user group, and sets a worrisome precedent.
This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor. How long will we have to come up with the money to pay for all of these changes that are being forced upon us?
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to
these changes that are being forced upon us?
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor. The Harbor commission meetings that I attended were a waste of my breath. They had their plan and were hellbent on forcing it down our throats.
4. Inequitable Treatment of Mooring field C: Prioritizing the densification of an already compact single-row mooring field C, rather than first considering converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
A. I also feel that a two week trial for test moorings is grossly insufficient. 6 months would give a more representative sample of how these things will work. 2 weeks would allow the City to cherry pick a sweetheart time where all conditions are optimal.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access. Most mooring holders are financially strapped and cannot afford such extravagant grandiose plans, foisted upon us by unelected bureaucrats.
Sincerely,
City's commitment to affordable and safe access. Most mooring holders are financially strapped and cannot afford such extravagant grandiose plans, foisted upon us by unelected bureaucrats.
Sincerely, Edward McLaughlin, Owner of mooring C-85 O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 2:40 PM Sent: Monday, January 27, 2025 1:10 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders
rectly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, John McTasney Sent from my iPhone O Outlook Re: Approved Anchor Weight Criteria Date Wed 1/29/2025 2:56 PM Hi Jeff, Thank you for the update. Am I to understand that these criteria for weighted anchors are new, have never been used by the CACC, and are being promulgated by the City of Newport Beach?
The helical anchor "creep" from no mention of them in the CDP and a statement from Harbormaster Blank that helical anchors would not be mandated, to modifying the CDP to install helical anchors at city-owned moorings, to now requiring all moorings in C-field to either meet newly promulgated (with no public input) criteria for weighted anchors, or replace existing anchors with city-owned helical anchors raises several important questions.
1. Has the City clarified who will bear the burden (cost) of determining if current anchor weights meet the criteria and how the determination will be made?
2. If existing anchor weights are determined to not meet the criteria, who pays for their removal, disposal, and replacement? This mandate potential puts an unfair financial burden on C-field mooring permittees.
3. Why is C-field being signaled out and not the rest of the harbor? This last minute change substantially alters the CDP from a pilot test to a mandate with implications for the whole harbor without due process.
I would urge you to return to the original CDP and remove the anchor replacement clauses, or remove
s the CDP from a pilot test to a mandate with implications for the whole harbor without due process.
I would urge you to return to the original CDP and remove the anchor replacement clauses, or remove the CDP from the February 5th agenda and require that the City submit two separate CDP's - one for the mooring realignment "pilot" and a second CDP for the anchor replacement plan.
Thank you for your consideration.
Best regards, Richard O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Fri 1/31/2025 7:57 AM Sent: Thursday, January 30, 2025 11:41 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California
occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
nd consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Dominica Navarro O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 (City of Newport Beach, Newport Beach) Date Fri 1/31/2025 12:29 PM To ---Original Message----Sent: Friday, January 31, 2025 12:25 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 (City of Newport Beach, Newport Beach) TO: California Coastal Commission FROM: Richard Navarro SUBJECT: CDP 5-23-0753 DATE: 31 January 2025 I have read the staff report, which favors the City's position that the realignment of the C mooring field and alteration from single point to double point moorings will enhance public access and increase open fairways. My sailboat is on C-72 mooring.
The staff report acknowledges the concerns of the mooring permittees that the double row moorings will increase the risk of accidents and compromise safety. Therefore, the staff recommends annual safety reports for the first five-years and establishes a threshold of 10% of accidents in the mooring field. While
the risk of accidents and compromise safety. Therefore, the staff recommends annual safety reports for the first five-years and establishes a threshold of 10% of accidents in the mooring field. While the dangers are real, the logic for the remedy is flawed for the following reasons.
1.
Under the current single row configuration there have been NO accidents caused by mooring permittees getting on or off their mooring, so why introduce a different configuration that staff acknowledge poses risks to the mooring permittees and the public?
2.
Given the risks to safety contained in the staff report, the standard for approval of the CDP should be much higher than increasing the number of City-owned moorings by 7 new moorings. The City already has the sole authority to rent any vacant moorings, including the moorings of private permittees. There is no shortage of moorings to accommodate public demand. In fact, the City has depressed demand for moorings by raising the nightly mooring rate by as much as 1000%, pricing out many mariners from visiting Newport Harbor.
3.
The staff report requires an annual report of verified contact incidents by the Newport Beach Harbor Department for five years. The purpose of the report is to determine the safety of the doublerow mooring reconfiguration. If 10% or more of the vessels in the C field (a minimum of 6 vessels) are involved in a verified contact incident within a one-year period following completion of the reconfiguration, and for a total period of five years the City will be required to submit a new reconfiguration to reduce the number of contact incidents.
The logic of the staff report is backwards – changing the current configuration with NO contact incidents
will be required to submit a new reconfiguration to reduce the number of contact incidents.
The logic of the staff report is backwards – changing the current configuration with NO contact incidents to a configuration that the staff acknowledge poses greater risks makes no sense. This CDP takes a small problem of realignment of moorings to fit in the designated footprint, and makes a much larger problem, introducing greater safety risks to mooring permittees and the public, especially paddleboarders and kayakers who transgress the mooring fields.
4.
Given the risks to safety acknowledged in the staff report, contact incidents are not the only concerns of mooring permittees. The increased dangers the reconfiguration poses will deter mariners like me from leaving the mooring and risking an accident particularly in the summer months when the harbor is more crowded, and the winds and currents are at their peak in the late afternoons. My wife and I are both 70 years-old and have over 40 years of boating experience and yet, we have had several failed attempts at securing the mooring in summer wind and strong current conditions. Putting boats closer together only increases the dangers and reduces access. We will not be able to afford to leave our mooring and risk damaging our boat if the untested double-row reconfiguration is implemented.
In conclusion, I am requesting that you reject CDP 5-23-0723 and maintain safe access to Newport Harbor.
Richard A. Navarro, Ph.D.
O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 (City of Newport Beach, Newport Beach)
O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 (City of Newport Beach, Newport Beach) Date Fri 1/31/2025 3:35 PM To ---Original Message----Sent: Friday, January 31, 2025 3:34 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 (City of Newport Beach, Newport Beach) Dear Commissioners: This email is to address Special Condition #2, Anchor Replacement which, if approved, would allow the City of Newport Beach to replace existing weighted anchors and tackle with helical anchors and tackle, taking ownership of the achor and tackle away from the mooring permit holder and transferring ownership to the City. As a mooring permit holder I own my anchor and tackle, which I maintain as required by the City, I object to what appears to be the City's attempt to take away from me my private property without compensation and replace it with a much more costly alternative at my expense. In my view, this movida by the City of Newport Beach represents the latest attempt after failing at an exorbitant permit hike, to price mooring permit holders of modest means out of the harbor.
The original CDP submitted by the City in 2022 for a "pilot project" made no mention of helical anchors.
In December 2023, Harbormaster Blank stated in writing that helical anchors would not be mandated for use in the harbor. However, in May 2024, the City reneged on its promise and the CDP was modified to
December 2023, Harbormaster Blank stated in writing that helical anchors would not be mandated for use in the harbor. However, in May 2024, the City reneged on its promise and the CDP was modified to authorize installation of helical anchors at city-owned moorings. Next, just 10-days ago, the City changed course again amending the CDP to require all moorings in C-field to either meet newly promulgated criteria for weighted anchors, or replace existing anchors with city-owned helical anchors.
All of the City's actions have been conducted with a lack of transparency, meaningful engagement, and no participation of the principal stakeholders - the mooring permit holders - in the process. These actions raise several important questions.
1. Why was the City of Newport Beach allowed to make substantive changes to the CDP without public input, or at the very least, consultation with stakeholders all the way up to last week?
2.
Has the City clarified who will bear the burden (cost) of determining if current anchor weights meet the criteria and how the determination will be made?
3. If existing anchor weights are determined to not meet the criteria, who pays for their removal, disposal, and replacement? This mandate potentially puts an unfair financial burden on C-field mooring permittees.
4.
Why is C-field being signaled out and not the rest of the harbor? This last minute change substantially alters the CDP from a pilot test to a mandate with implications for the whole harbor without any due process.
Therefore, I urge you to return to the original CDP and remove the anchor replacement clauses or deny the CDP in its current form and require the City to submit two separate CDP's - one for the mooring realignment "pilot" and a second CDP for the anchor replacement plan.
or replacement clauses or deny the CDP in its current form and require the City to submit two separate CDP's - one for the mooring realignment "pilot" and a second CDP for the anchor replacement plan.
Respectfully, Richard A. Navarro, Ph.D.
O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 (City of Newport Beach) Date Mon 1/27/2025 12:37 PM To Sent: Monday, January 27, 2025 10:44 AM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 (City of Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California
occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields, the exclusive privilege yacht clubs, into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the yacht clubs with single-point mooring fields, which occupy and
s concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the yacht clubs with single-point mooring fields, which occupy and impact significantly more space per vessel. The yacht clubs are also exempted from the conversion to helical anchors, further underlining the discriminatory practices of the City of Newport Beach.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Richard A. Navarro, Ph.D.
+1 909 263-3881 (Mobile) [email protected] Innovative Structural and Specialty Engineering PLLC Mr. Jeffrey Palm California Coastal Commission Sacramento, CA 95814 [email protected] September 19, 2024 Re: Newport Harbor Mooring Field C Realignment Proposal - CDP Application No 5-23-0753 Dear Mr. Palm, On behalf of the Newport Mooring Association, ISSE have reviewed the subject Application and supporting documentation and provide the following submission for your review.
Introduction Newport Harbor is a naturally protected waterway, ideally located to provide access to the California coast. For over a century, this valuable resource has supported a significant population of mariners and their watercraft. The harbor includes several mooring fields designed to offer safe, economical parking for
ver a century, this valuable resource has supported a significant population of mariners and their watercraft. The harbor includes several mooring fields designed to offer safe, economical parking for boats with convenient access to coastal waters. For the 55 permittees of the Field C Pilot Program, coastal access fundamentally depends on having secure moorings and safe, accident-free mooring operations.
The primary function of mooring fields is not navigation, but rather to ensure safe and secure boat storage. Design priorities for mooring fields should focus on providing well-secured moorings that allow craft movement while withstanding adverse weather conditions and preventing collisions. Additionally, mooring fields should ensure that mariners can approach and depart their moorings safely in most weather conditions.
In fact, the Newport Harbor Mooring Fields are designated “special anchorage areas" in the Federal Register, Coast Guard Final Rule, effective May 16, 2012. Such areas “should be well removed from the fairways and located where general navigation will not endanger or be endangered by unlighted vessels".
Thus, even contemplating fairways within the mooring fields would seem to be in violation of the Coast Guard Rules.
Background The environmental conditions in "Mooring Field C" often make mooring operations challenging, with tidal currents frequently exceeding one knot and significant winds generating waves from multiple directions and additional wind-driven currents. As sea states deteriorate, the likelihood of accidents increases disproportionately. Mooring operations are particularly hazardous during severe weather conditions when the mariner's ability to control the boat is impaired by the wind, strong currents and wind-induced waves.
ionately. Mooring operations are particularly hazardous during severe weather conditions when the mariner's ability to control the boat is impaired by the wind, strong currents and wind-induced waves.
Even under the prevailing regular West winds combined with tides, the dynamic conditions become challenging for mooring. These conditions directly impact the probability of accidents, especially when boats are in close proximity during mooring or departure.
Innovative Structural and Specialty Engineering PLLC The high profile of many power boats, and the windage of the rigging on many sailboats, create significant difficulties in brisk wind, even when wave action is less of an issue. Wind conditions often complicate mooring operations more than wave activity in Field C.
Comparisons between "Newport Harbor” and “America's Cup Harbor, San Diego" are not valid due to the vastly different tidal and wind conditions in each location. America's Cup Harbor is sheltered from wind, and tidal currents are negligible, making it easier to maneuver boats during mooring. Therefore, San Diego's ACH conditions are not applicable to the proposed reconfiguration of Field C, except to highlight the stark differences in sea-state challenges. In Field C, the risk of collisions increases significantly when nearby boats are closer, as reduced space for error leaves little room for drift or navigational mistakes during mooring operations.
Findings A factor contributing to the increased likelihood of accidents is the modification of established procedures that mariners have become accustomed to. When habitual mooring methods are changed, particularly
tor contributing to the increased likelihood of accidents is the modification of established procedures that mariners have become accustomed to. When habitual mooring methods are changed, particularly under time pressure in storm conditions, human decision-making becomes more error-prone. The proposed reconfiguration for "Mooring Field C" would require permittees to adopt new mooring protocols, further increasing the potential for accidents. Any changes that reduce the clear space between moored boats such as increasing the density of moorings or shrinking the area of the mooring field-will amplify the probability of collisions.
One of the objectives of the reconfiguration is to create wider fairways within the mooring fields to improve navigation and optimize space utilization. However, this may have unintended consequences, such as encouraging vessels to take shortcuts through the mooring field, increasing the risk of accidents. Building a thoroughfare through a mooring field is akin to running a road through a public parking lot—it introduces unnecessary hazards by encouraging traffic in areas meant for stationary boats. This design compromises safety, particularly for mooring operations, which require space for maneuvering and securing boats in dynamic conditions.
Navigation channels outside the mooring fields should remain the primary route for vessels in transit to avoid unnecessary traffic within the mooring area. The mooring field should be protected from in-transit traffic, creating safer conditions for human-powered craft and swimmers.
The proposal to expand every other fairway at the expense of eliminating every alternate fairway further compounds the issue. Boat operators need an equal amount of fairway space in both directions to ensure
posal to expand every other fairway at the expense of eliminating every alternate fairway further compounds the issue. Boat operators need an equal amount of fairway space in both directions to ensure various escape routes under different conditions. Reducing the number of fairways compromises their ability to safely maneuver, especially in dynamic sea-state conditions. (See attached 3-page visual/slide provided by NMA for reference.)
The reconfiguration, as described in Dudek's letter to the California Coastal Commission dated February 12, 2024, (Item 4, Alternative Reconfigurations) emphasizes safety for mariners in transit and the optimized use of space within the mooring field. However, the real safety concern arises during the critical offshore mooring operations when boats are most vulnerable. During transit, boats are under control with steerageway, whereas mooring operations, particularly in adverse weather conditions, pose far greater challenges, with potential loss of steerage. The Application appears to prioritize optimizing space for parked boats, similar to the layout of a car parking lot, without adequately considering the space requirements necessary for safe mooring operations.
Innovative Structural and Specialty Engineering PLLC Likewise, the City of Newport Beach Harbormaster's statement from December 7, 2023, Re Navigability, focuses on improving navigation and space optimization within the mooring fields, but fails to address the critical space needs for safe mooring. Navigation is relatively straightforward compared to the complex and hazardous process of securing a boat during offshore mooring during non-calm conditions. The
critical space needs for safe mooring. Navigation is relatively straightforward compared to the complex and hazardous process of securing a boat during offshore mooring during non-calm conditions. The reconfiguration's emphasis on fairways and aesthetics may create a visually regular arrangement, but it sacrifices the global space required for safe mooring operations, especially in adverse conditions.
Aesthetics are subjective, and while the proposed changes may enhance the visual appeal of the mooring field for some, they introduce additional risks by reducing the space between boats.
Additionally, any realignment that increases the density of moored boats, such as double-row mooring, further reduces the minimum space between vessels, increasing the likelihood of accidents during both mooring and routine transits to and from the field.
The Application explores different anchoring options, such as helical anchors and steel weights. At present there is no evidence of eelgrass in Mooring Field C (2022 Eelgrass Map, Marine Taxonomic Services, Ltd). The nearest eel grass is greater than 5m distance from Field C. The submerged floating lines of "conservation moorings", though considered for environmental protection of eelgrass, pose additional hazards during mooring operations and thus should be discouraged. Although the helical anchors demonstrate considerably greater vertical pull capacity than the others, lateral cyclic prying action, from all directions, during strong wind and low tides (greatest line slackness) is likely to degrade the hold-down capacity, and could test the long-term lateral capacity. Significantly, any changing of mooring anchors is likely to disturb the sea-bed and is expected to invoke CEQA.
likely to degrade the hold-down capacity, and could test the long-term lateral capacity. Significantly, any changing of mooring anchors is likely to disturb the sea-bed and is expected to invoke CEQA.
The maximum tidal range is +7.0' to -1.4' MLLW without storm surge. Therefore the slackness in the mooring buoy anchor lines varies by over 8 ft, depending on tide, causing variable boat drift around the mooring site. The catenary action in the mooring tackle is crucial for absorbing dynamic loads caused by storm drift, and any reduction in scope distance during high tides will increase the hazard by amplifying impact loads on boats. This critical aspect of mooring design has not been adequately considered in the reconfiguration plan, raising concerns about the safety and practicality of the proposed changes.
Conclusion For the above reasons, fundamental to most mariners who moor in open water, we respectfully submit CDP Application No 5-23-0753 for Mooring Field C Pilot Program should be rejected in its entirety.
Sincerely, Radli Жужде Innovative Structural and Specialty Engineering PLLC Radhi Majmudar PE David Williams PE Innovative Structural and Specialty Engineering PLLC Radhi Majmudar PE is a structural engineer with extensive experience in marine and coastal structural engineering, with a particular focus on design, analysis, and condition assessments of piers and underwater structures. She has led teams that performed underwater inspections to evaluate the condition of piles and other submerged components, addressing issues such as marine borer attacks and environmental wear. Based on these assessments, she provided recommendations for structural repairs
ondition of piles and other submerged components, addressing issues such as marine borer attacks and environmental wear. Based on these assessments, she provided recommendations for structural repairs and reinforcements to restore and maintain the operational safety and longevity of key coastal infrastructure.
In addition to inspections, she has experience overseeing and approving mooring engineering activities for marine projects. This includes supervising contractors on model testing, evaluating mooring strength, conducting fatigue analysis, and performing finite element analysis (FEA) to ensure the structural integrity of mooring systems. Her responsibilities also encompassed reviewing mooring and ensured that mooring systems and associated infrastructure met rigorous safety and performance standards in challenging marine environments.
She contributed to the analysis and evaluation of large offshore platforms, performing seismic assessments to understand the impact of natural forces such as earthquakes on these structures.
Utilizing advanced tools and modeling techniques, she, as part of a team, analyzed the safety, stability, and functionality of critical offshore installations, enhancing their resilience against environmental forces and extending their operational lifespan. Their work helped safeguard the long-term stability of offshore and coastal structures under dynamic and harsh marine conditions.
Furthermore, her experience includes playing a critical role in the development of major container terminals. She was involved in the design process, overseeing physical model tests and conducting computer simulations to assess the motion of moored ships, including factors like surge, sway, heave,
terminals. She was involved in the design process, overseeing physical model tests and conducting computer simulations to assess the motion of moored ships, including factors like surge, sway, heave, yaw, pitch, and roll. She also evaluated various structural design alternatives for quay walls, including gravity block walls, pile-supported platforms, and steel caissons. Their contributions helped optimize both the functionality and structural integrity of key port facilities, ensuring they were designed to handle the operational demands of international shipping routes while withstanding harsh marine conditions.
Representative Project Experience Port Salalah Container Terminal Development and Design Study, Oman, Arabian Sea Client: Sea Land Service Inc. and the Sultanate of Oman Design, Analysis, Inspection Services for Pier 35 Gowanus Bay in Brooklyn, New York Client: New York City Economic Development Corporation Design, Analysis, Inspection Services for East River Pier 13/14 Complex in Manhattan, NY Client: New York City Economic Development Corporation Design and Inspection Services for Administration and Maintenance Building -Howland Hook Marine Terminal Staten Island, NYClient: Port Authority New York and New Jersey Innovative Structural and Specialty Engineering PLLC Design, Analysis and Inspection Services for Bulkheads at Piers 1 through 5 Brooklyn, New York Client: Port Authority New York and New Jersey Design of Breakwaters and Wharf Structures Haifa Port, Israel Client: Government of Israel, Israel Port Authority Seismic Analysis of Steel Fixed Offshore Platforms Santa Ynez, California Client: Exxon Corporation
akwaters and Wharf Structures Haifa Port, Israel Client: Government of Israel, Israel Port Authority Seismic Analysis of Steel Fixed Offshore Platforms Santa Ynez, California Client: Exxon Corporation David Williams, PhD, PE, has been involved with marine infrastructure throughout his career (over five decades), primarily in the capacity of structural design, constructability, risk assessment, value engineering, safety and support of critical projects.
His experience ranges from analysis and design of large floating bridges and moored caissons, barges and ocean transport; design and assessment of flood-protection structures and retaining walls for the US Army Corps of Engineers following the Katrina hurricane (including navigation facilities through flood gates, incorporating pilot simulation results/reaction times for guide and fender arrangement); project management of a replacement floating launching pier and gangway (ADA-compliant) for a coastal inland lagoon, used for human powered craft (kayaking, rowing, canoeing, SUPs); design review of redesigned sheet-pile bulkheads and forensic engineering for a new container terminal following construction failure; to detailed design and seismic analysis of new locks for a major canal, dry dock facilities, and a shiplift; seismic retrofit of port facilities; analysis of major fixed and floating offshore structures designed for extreme storm and seismic effects in adverse environments; the first installation of large piles for over-water bridge foundations using offshore technology (from semi submersible barge cranes). He has designed and analyzed anchors and mooring systems for a variety of applications and undertaken peer review of pioneering marine engineering concepts.
ology (from semi submersible barge cranes). He has designed and analyzed anchors and mooring systems for a variety of applications and undertaken peer review of pioneering marine engineering concepts.
As such, he brings invaluable multidisciplinary experience, and familiarity with permitting coastal facilities, including stringent environmental concerns and regulations. He is familiar with extreme environments, remote sites, construction limitations due to environmental hazards and other permitting issues, bio-fouling and cold-climate engineering (obtained Alaska PE License in 2001).
His expertise and independent investigation of several hydrodynamic problems (analytical and experimental wave tank testing) has led him to provide specialist consulting on many pioneering marine and coastal projects including expert testimony before regulatory authorities regarding safety of critical infrastructure.
In addition he brings years of experience in aquatic recreation – open water, coastal and ocean sailing, open water and flatwater rowing, kayaking and white water rafting. This experience provides invaluable understanding of the variability of sea states and challenges involved in controlling and mooring boats in open water.
Proposed Double Row System with Prevailing Winds Innovative Structural and Specialty Engineering PLLC These tight quarters will not allow forward boats to take appropriate angled approach when accessing moorings, making access more difficult and less safe compared to existing configuration.
When single-handed boater unties bow line, they will immediately be blown into boat behind. This configuration does not allow for reasonable reaction time.
ess safe compared to existing configuration.
When single-handed boater unties bow line, they will immediately be blown into boat behind. This configuration does not allow for reasonable reaction time.
Innovative Structural and Specialty Engineering PLLC No room to rear-unsafe for current and winds in Newport Existing single row mooring alignment provides multiple access and departure routes depending on variable winds and currents. The proposed double row eliminates various access and departure angles.
Innovative Structural and Specialty Engineering PLLC Main Office Phone: 310 798-2400 Direct Dial: 310-798-2400 Ext. 1 CBM Carstens, Black & Minteer LLP 700 North Pacific Coast Highway, Suite 200 Redondo Beach, CA 90277 www.cbcearthlaw.com Douglas P. Carstens Email Address: [email protected] California Coastal Commission South Coast District Office 301 E. Ocean Blvd., Suite 300 Long Beach CA 90802 January 31, 2025 [email protected] Re: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 (City of Newport Beach, Newport Beach); Request to Deny or Continue Application For a Coastal Development Permit For Mooring Field Design Changes/ Major Public Works Project Dear Honorable Commissioners, On behalf of the Newport Mooring Association we object to the approval of the City of Newport Beach's application for a mooring so-called “reconfiguration” program. The CDP is in fact an application for an extensive public works program¹ of mooring field physical configuration and policy revisions. These mooring field revisions would render coastal access more
m. The CDP is in fact an application for an extensive public works program¹ of mooring field physical configuration and policy revisions. These mooring field revisions would render coastal access more dangerous, and would have extensive environmental impacts that have not been analyzed and mitigated as required by the Coastal Act and the California Environmental Quality Act (CEQA).
The City of Newport Beach Harbor Department (City) submitted the Coastal Development Permit (CDP) application for mooring field reconfiguration with significant defects in the application. Thus, we encourage the Commission to deny the application or at the very least to continue the hearing to require the submission of more complete analysis of serious safety issues and environmental impacts that could occur, and ways to mitigate those impacts including alternatives.
1 The City should apply for a public works plan pursuant to Public Resources Code section 30605.
Coastal Commission January 31, 2025 Page 2 A. The City's Proposed Mooring Relocation Program Would Impede Coastal Access and Render it More Dangerous.
The City's proposal to relocate existing mooring tackle and/or the construction of new moorings constitutes development under the Coastal Act.
We previously wrote to you on November 2, 2023 around the time of the City's application for the CDP. (Enclosure 1.) The serious concerns raised in that letter have been made worse by the most recent version of the proposal.
Safety Concerns Require Denial Or, At the Very Least, A More Detailed Analysis.
1.
The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels.
This loss of space reduces reaction time and increases the risk of collisions
es would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels.
This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. "Public Resources Code section 30210 ... emphasizes the need to consider public safety and private property interests. (See also Pub.
Resources Code, §§ 30212, 30214.)" (Carstens v. California Coastal Com.
(1986) 182 Cal.App.3d 277, 290.) The bottom-line is: unsafe access is no access at all.
The application does not include naval/marine engineering to prove the new densified mooring configuration will be safe and operable, without contributing to the increased risk of collisions. In contrast, as stated in the January 28, 2025 email to you, the Newport Mooring Association (NMA), NMA has obtained the expert evaluation of Innovative Structural and Specialty Engineering PLLC (ISSE). (Enclosure 2.) In summary, ISSE concludes "contemplating fairways within the mooring fields would seem to be in violation of the Coast Guard Rules" designed to prevent boat collisions.
(Enclosure 2, ISSE Letter, p. 1.) We are also providing a copy of the applicable Coast Guard Rules - Title 33 Code of Federal Regulations section 109.10 (Enclosure 3) and special anchorage designation (Enclosure 4).
Coastal Commission January 31, 2025 Page 3 The proposed mitigation for increased risks of collision presented in the
tions section 109.10 (Enclosure 3) and special anchorage designation (Enclosure 4).
Coastal Commission January 31, 2025 Page 3 The proposed mitigation for increased risks of collision presented in the staff report is literally to let increased collisions happen, but under Special Condition 1 to require annual status reports and, if collisions (referred to in the staff report at page 24 as “boat contact incidents") 2 increase by more than 10%, require the City to return with an amendment request. This is no way to plan mooring revisions in Newport Harbor. Instead, adequate and expert safety analysis must be conducted prior to changes being made, not evaluated afterward.
Additionally, the Coast Guard should have been consulted. Among other issues, the Coast Guard must approve any boundary changes to the mooring fields (Federally Designated Special Anchorages) as consistent with item #12 on the NOIA issued by Coastal Staff on 11/8/23. We do not believe the City has obtained this approval.
The application is woefully scant on engineering details. The only technical information provided in this CDP application is the illustration of underwater tackle Exhibit 4 “Mooring Tackle Diagram” document. This illustration is an inaccurate depiction of the proper catenary (slack and scope) required in the existing two-point/catenary “spreader” mooring systems.
The mooring fields as currently configured provide protection from larger vessels. We are concerned that the proposed mooring reconfiguration, which provides for wide, up to 100-foot-wide fairways, would encourage navigation of large vessels in the mooring fields. This would both obstruct coastal access and create a safety concern for permittees operating small
ide, up to 100-foot-wide fairways, would encourage navigation of large vessels in the mooring fields. This would both obstruct coastal access and create a safety concern for permittees operating small vessels, as well as for paddleboarders, kayakers, and others operating small human-powered vessels in the safe haven of the mooring fields. This goes against the Chapter 3 policies of the Coastal Act, which protect such activities. (Pub. Resources Code §§30211, 30220, 30224.) Marine life that 2 "[T]he word 'collision' is usually used to describe () the situation where a moving ship hits a stationary ship or a fixed object such as a bridge.”
FOOTNOTEHealySweeney 1991359-1) citing Healy, Nicholas J.; Sweeney, Joseph C. (July-October 1991). "Basic Principles of the Law of Collision".
Journal of Maritime Law and Commerce. 22 (3), page 359.
Coastal Commission January 31, 2025 Page 4 frequent the harbor, such as dolphins and sea lions, may also be impacted by the introduction of larger vessels. (See Pub. Resources Code §30230.)
The mooring areas in Newport Harbor are designated “Special Anchorages" by the Coast Guard. (Title 33 C.F.R. §110.95; see 77 Fed. Reg.
22489, available at: https://www.govinfo.gov/content/pkg/FR-2012-0416/pdf/2012-9006.pdf.) Special anchorage areas "should be well removed from the fairways and located where general navigation will not endanger or be endangered by unlighted vessels." (Title 33 C.F.R. §109.10, emphasis added.)
Thus, fairways that accommodate large vessels should not be located within the mooring fields.
2.
Coastal Water Access Would be Impeded Because Access Will be Made More Dangerous For Some.
The proposed revisions include new restrictions regarding designated
be located within the mooring fields.
2.
Coastal Water Access Would be Impeded Because Access Will be Made More Dangerous For Some.
The proposed revisions include new restrictions regarding designated mooring row lengths, which are undefined and will require certain permittees to relocate, making it more difficult for those permittees to access moorings, and thereby impeding coastal access.
The current mooring field design works well. The City has not proven a need for a new system. Decreasing access by making mooring use more difficult and more dangerous for all including folks with less mobility will be detrimental to coastal access overall.
There are serious safety concerns for users of the moorings when mooring rows are pushed together. The application lacks a safety analysis regarding safe operation of moorings that have been pushed close together in any environment comparable to Newport Beach's.
We are not aware of any professional coastal engineer who has signed off on the impact to safe mooring operations after pushing mooring rows closer together in terms of preserving safe access to the moorings and the application provides none, even though Coastal Staff requested this as item 9, in their Notice of Incomplete Application (NOIA) of Nov. 8, 2023, and again as item three in Coastal's NOIA of Jan. 19, 2024. This two minute video gives a good explanation of the safety issues involved created by wind and tide conditions specific to Newport Harbor: Newport Harbor Mooring Configuration - YouTube Coastal Commission January 31, 2025 Page 5 nuanced and complicated as getting on and off a mooring is challenging given tidal currents and wind.
ion January 31, 2025 Page 5 nuanced and complicated as getting on and off a mooring is challenging given tidal currents and wind.
There should be an examination and comparison to analogous mooring fields throughout the state (i.e., Avalon, Two Harbors, and Morro Bay). In them, there is generally equal space in the fairways (to the bow and to stern) for boats to get on and off moorings safely in changing wind and tidal currents. The onus must be on the applicant- the City of Newport Beach- to provide sufficient analysis as part of the application to ensure what it is proposing will not create unsafe conditions.
3. Coastal Dock Access Would Be Impeded.
Currently, there is not enough dinghy dock space to accommodate access to the existing moorings. Adding seven additional moorings will further impact access to the moorings in terms of inadequate dinghy dock space at the public piers, such as the Fernando Street pier adjacent to the C field. The application must include a dock space access analysis.
4. Coastal Parking Access Would Be Impeded.
Vehicle parking is a problem in the area. There is not enough parking. Seven new mooring users will impact parking. The application must include a vehicle parking access analysis.
5. Coastal Visual Access Would be Impeded.
The proposal to push mooring rows together will alter view corridors from the public boardwalk around Balboa Peninsula and Island (and possibly other boardwalks in Newport Harbor). (See Pub. Resources Code § 30251 ["The scenic and visual qualities of coastal areas shall be considered and protected as a resource of public importance."]) The plan will also alter views of the harbor. While under the proposed reconfiguration, views may be
qualities of coastal areas shall be considered and protected as a resource of public importance."]) The plan will also alter views of the harbor. While under the proposed reconfiguration, views may be improved for some—those whose properties are fronted by a fairway-views may also be greatly worsened for others, including where views are confronted by the proposed double-wide tandem rows of boats. We question Coastal Commission January 31, 2025 Page 6 whether these property owners have been properly notified by the City of these proposed changes that would affect them.
B.
Environmental Review as the Lead Agency Must Be Done by the Commission, not the City of Newport Beach.
Newport Harbor falls under the direct permitting jurisdiction of the Coastal Commission so the Coastal Commission must evaluate any potential Coastal Development Permit de novo. The Staff report for CDP 5-23-0753 erroneously states that the Commission is a "responsible agency" for the CDP. (Report, p. 26.) Contrary to this statement, the Commission is the lead agency because the Commission has the primary responsibility for review and approval of the City's application for the CDP. The City is the CDP applicant, not the lead agency.
Furthermore, the project is not exempt from CEQA under section 15302 of the CEQA Guidelines³ as the City claims and the staff report repeats without questioning. (Staff Report, p. 26.) Instead, this exemption is intended only for projects which replace existing facilities, not projects that expand capacity, as this one does, or projects that make revisions to existing facilities, as this one does in that it adds mooring locations (increasing capacity) and changes the types and configurations of those mooring
his one does, or projects that make revisions to existing facilities, as this one does in that it adds mooring locations (increasing capacity) and changes the types and configurations of those mooring facilities- creating safety and public access issues. The CDP is not exempt from CEQA nor should it be treated as such.
Even if the project were exempt under section 15302, and it is not, it would be subject to the exceptions to the exemption provided under Guidelines section 15300.2 subdivisions (a), (b), and (c) because it impacts a 3 Section 15302 states: “Class 2 consists of replacement or reconstruction of existing structures and facilities where the new structure will be located on the same site as the structure replaced and will have substantially the same purpose and capacity as the structure replaced, including but not limited to: ... (c) Replacement or reconstruction of existing utility systems and/or facilities involving negligible or no expansion of capacity." (CEQA Guidelines section 15302, emphasis added.)
Coastal Commission January 31, 2025 Page 7 resource designated and precisely mapped (eelgrass), it has significant effects due to unusual circumstances (safety impacts, public access and visual impacts), and continues a series of City actions which cumulatively adversely impact public safety, public access, environmental, and visual resources.
The project should not be considered exempt from CEQA because it will have environmental impacts related to public access to water, aesthetics, and construction of new moorings or relocation of existing mooring tackle in the submerged mooring field as detailed here and in our attached letter.
The City claimed the project would be exempt from CEQA pursuant to
of new moorings or relocation of existing mooring tackle in the submerged mooring field as detailed here and in our attached letter.
The City claimed the project would be exempt from CEQA pursuant to CEQA Guidelines 15302 for replacement or reconfiguration of existing facilities. However, this exemption is not applicable because the mooring program will intensify usage of the moorings, create visual and public safety impacts that do not exist with the current configuration, and add to adverse cumulative impacts. Moreover, this CDP expands the number of moorings under the City's recently created short-term Mooring License program. These are a vastly different mooring option, and were created outside of the CDP process. And the much higher fee costs associated with Mooring Licenses, are currently under review by the California State Lands Commission.
The City apparently relied on a "memo" from Dudek for waiving CEQA and other environmental reporting in regards to studying the impact on eelgrass from moving anchor systems for 55 moorings and adding 7 additional moorings (and related boats that will shade the eelgrass).
Exhibit 3, page 2 of 2, shows at least one patch of eelgrass that would be newly impacted by a 40-foot mooring. Implementation of conservation moorings will not offset negative impact on eelgrass. Conservation moorings are designed for "single-point" moorings whereby a boat (and associated mooring chain) freely weather vanes (swings) around the mooring in a circle (360 degrees). In the case of a single-point mooring, a conservation buoy can help reduce the chain scraping the seafloor as the vessel rotates 360 degrees around the single point mooring. However, the moorings in the C field are
a single-point mooring, a conservation buoy can help reduce the chain scraping the seafloor as the vessel rotates 360 degrees around the single point mooring. However, the moorings in the C field are double-point (spreader) moorings. The chain does not move much at all because the boat is tethered from bow and stern and holds in one position. There is not a real eelgrass "scraping" problem with double point moorings. Therefore, the conservation mooring is not applicable and offers Coastal Commission January 31, 2025 Page 8 little if any eelgrass mitigation given the two-point configuration in the C field.
Eelgrass mitigation is planned in the Commission's Staff Report, with a re-plant ratio of 1.2:1, but it is not possible to mitigate into an exemption from CEQA. Rather, the CDP application must be subject to proper CEQA review, both by the City and by the Commission, and the mitigation measure's effectiveness evaluated as part of that review process, with proper public review and comment procedures. A project that requires mitigation measures in order to avoid significant impacts to the environment is by definition not properly subject to an exemption from CEQA.
C. Significant Visual Impacts Could Occur to Coastal Resources.
Visual impacts from mooring reconfiguration can be significant, especially to those from vantage points around the harbor and in nearby harbor-adjacent homes. It appears there will be 3 new rows of moorings including a new row of 70-foot boats (east end of mooring field C as depicted in green) blocking the view from the area of 421-425 E. Edgewater Avenue and Edgewater Place- a public road. (Compare Exhibit 3, page 1 of 2 with page 2 of 2.) Please note this row will be established in an area where no
he view from the area of 421-425 E. Edgewater Avenue and Edgewater Place- a public road. (Compare Exhibit 3, page 1 of 2 with page 2 of 2.) Please note this row will be established in an area where no moorings exist today. (Ibid.) The installation of three new mooring rows (and seven new moorings with boats) will certainly have adverse visual impacts.
While a mooring field reconfiguration may open up views from certain vantages, it will lead to blocking and obscuring views from other vantage points. Thus, overall, the negative aesthetic impacts of the reconfiguration must be analyzed prior to approval.
The application understates and minimizes the impact to coastal views regarding pushing mooring rows closer together. A coastal view impact analysis should have been done, especially with regard to the completely new row of 70-foot boat moorings.
D. The City Should Be Required to Disclose Necessary LIP and LUP Changes at the Same Time it Seeks CDP Approval.
The City's CDP application contains an incomplete disclosure of the actions that the City contemplates, or has already taken, to implement its Coastal Commission January 31, 2025 Page 9 proposed mooring modifications. The City should be required to disclose, and seek certification of, its changes to the Harbor Code and Municipal Code which are components of the City's LCP. The City contemplates, or has already undertaken, changes to its Local Implementation Program (LIP) to implement its mooring modifications program without disclosing those to the Commission or including them as part of its CDP application. (Enclosure 1 to Enclosure 1, objecting to amendments to the City of Newport Beach Harbor Code, Municipal Code, Title 17, sections 17.25.020 and 17.60.040 without a
them as part of its CDP application. (Enclosure 1 to Enclosure 1, objecting to amendments to the City of Newport Beach Harbor Code, Municipal Code, Title 17, sections 17.25.020 and 17.60.040 without a CDP or LIP modification to modify mooring procedures.) These changes must be the subject of an LIP amendment certification application that should accompany the CDP application because the City's planned changes should not be piecemealed over the course of different approval applications or associated City actions outside of the permitting process.
E. The Project Would Reduce Low Cost Access To the Coast and is Inequitable.
We strongly object to Special Condition 2 "Anchor Replacement Plan" as currently drafted. (Staff Report, p. 6.) The CDP's reliance on costly helical anchors, along with requirements for some mooring holders to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This directly conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.23), which emphasizes maintaining shore and offshore moorings as "an important source of low-cost public access to the water and harbor.”4 Additionally, the Due Process rights of these mooring holders has been violated because the requirement imposing expensive mandates on them has been proposed without adequate notice to them and involvement by them in evaluating the proposal. The imposition of this unnecessary and expensive requirement on current mooring holders could constitute an unconstitutional regulatory taking.
4 Local Coastal Program Coastal Land Use Plan page 3-36 states: "3.3.2-3.
Continue to provide shore moorings and offshore moorings as an important
uld constitute an unconstitutional regulatory taking.
4 Local Coastal Program Coastal Land Use Plan page 3-36 states: "3.3.2-3.
Continue to provide shore moorings and offshore moorings as an important source of low-cost public access to the water and harbor." (See https://www.newport beachca.gov/PLN/LCP/Internet%20PDFs/CLUP_Part%2 03_Public%20Access%20and%20Recreation.pdf.)
Coastal Commission January 31, 2025 Page 10 In December 2023, a City official- Paul Blank the City of Newport Beach Harbormaster- confirmed that the City no longer proposed the use of helical anchors. (Enclosure 6 [“...following input from public and stakeholder consultations [u]ltimately, the use of helical, screw-in anchor and shared anchors or weights for moorings were discarded."]) For the CDP to now include helical anchors as a requirement in the Anchor Replacement Plan (Special Condition 2, Staff Report p. 6) feels to the public involved in City review processes like a bait-and-switch and a betrayal of earlier City official reassurances.
Prioritizing the densification of already compact single-row mooring fields permitted to members of the public, rather than first converting "swing" or single-point mooring fields, which are the exclusive privilege of the members-only yacht clubs, into more space-efficient configurations, raises concerns about fairness and consistency.
This approach gives the impression that the City is granting preferential treatment to the yacht clubs with single-point mooring fields, which occupy and impact significantly more space per vessel. The yacht clubs are also exempted from the conversion to helical anchors, and insulated from the much higher City Mooring License rates intended for other Permittees, further underlining the discriminatory practices of the City of
ted from the conversion to helical anchors, and insulated from the much higher City Mooring License rates intended for other Permittees, further underlining the discriminatory practices of the City of Newport Beach.
We ask that, if you do not deny the CDP entirely, you amend Special Condition #2 to indicate: The city [permittee] is only authorized to install helical anchors at the 3 existing city mooring locations and up to 7 new city mooring locations. The city [permittee] may not install helical anchors at any of the 52 private mooring locations without the specific consent of the permit holder. All existing mooring anchor tackle made of steel or iron can be utilized in the relocation regardless of the object description.
There is no environmental analysis of what the wholesale mooring tackle replacement of 52 moorings will entail and over what period of time it will be implemented. Existing mooring tackle includes engine blocks and other materials acting as artificial reefs, that can have considerable habitat associated with them. (Enclosure 5.) Helical anchors substantially reduce Coastal Commission January 31, 2025 Page 11 these little safe-havens for crabs, crustaceans, small fish, octopi, etc.
Removal/Disposal of the existing mooring tackle will create environmental impacts. Screwing in the helical moorings could have environmental impacts.
The City's previous proposal for a mooring rate increase manifests itself in City Mooring Licenses. This mooring field revision application is a rate increase proposal in disguise. The City recently recommended a manifold increase in mooring rates that must be viewed as “development” within the meaning of the Coastal Act. An analogous situation was clarified by Peter
n disguise. The City recently recommended a manifold increase in mooring rates that must be viewed as “development” within the meaning of the Coastal Act. An analogous situation was clarified by Peter Douglas in his 1993 Memo which explained substantial increases in beach parking rates would require a CDP. As a memo of Peter Douglas makes clear, a "substantial increase” “means any fee increase of 25% or more in any given year or 50% or more on a cumulative basis over any three consecutive year period." The mooring rate increase proposed in by Newport Beach far exceeds the amounts triggering substantial fee increase analysis. It does not matter for purposes of the requirement of a CDP whether the rates are charged as a private use or as a public use. The fact is that substantial fee increases for mooring in the waters of Newport Harbor create public access issues that must be addressed through a CDP process. The current CDP process for the mooring field revisions is the best place to do that because the overall project cannot be segmented or piecemealed into various smaller projects that appear to have no impact on their own.
F. Alternatives Analysis and Alternative Solutions Are Feasible, Less Environmental Damaging, and Safer.
The current mooring system is functional, safer than the proposed revisions, and provides low-cost public access to the coastal zone.
The City has not performed a proper alternatives analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
Coastal Commission January 31, 2025 Page 12 Conclusion.
lly have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
Coastal Commission January 31, 2025 Page 12 Conclusion.
We ask that you deny the City's application until full disclosures regarding the scope of the proposed project are made and the proper safety analysis and environmental review is conducted, including the preparation of an initial study and circulation of a negative declaration or environmental impact report for public comment at the City level.
The proposed CDP presents significant changes that would alter access to water-both visual and physical access, would construct new moorings in the submerged mooring fields, and thus intensifying use. Accordingly, the proposed changes are subject to the California Environmental Quality Act, not exempt from it, and further information is required before the application may be accepted as complete.
Sincerely, Dough P. Conta Douglas P. Carstens Enclosures: Cc: 1. November 2, 2023 Letter to the Coastal Commission 2. Innovative Structural and Specialty Engineering PLLC Evaluation of Newport Harbor Mooring Field C Realignment Proposal- CDP Application No. 5-23-0753 3. Title 33 Code of Federal Regulations section 109.10 4. Federal Register, Vol. 77, No. 73/ Monday, April 16, 2021/ Rules and Regulations, p. 22489-22492.
5. List of Mooring Tackle materials 6. Letter of Paul Blank, Newport Beach Harbormaster, dated December 7, 2023, confirming City's abandonment of helical anchor proposal [email protected].
ENCLOSURE 1 Main Office Phone: 310-798-2400 Direct Dial: 310-798-2400 x 1 CBM
ise. [email protected]; [email protected].
ENCLOSURE 1 Main Office Phone: 310-798-2400 Direct Dial: 310-798-2400 x 1 CBM Carstens, Black & Minteer LLP 2200 Pacific Coast Highway, Suite 318 Hermosa Beach, CA 90254 www.cbcearthlaw.com Douglas P. Carstens Email Address: [email protected] November 2, 2023 California Coastal Commission South Coast District Office 301 E. Ocean Blvd., Suite 300 Long Beach CA 90802 By Email: [email protected]; [email protected] Re: Objection to City of Newport Beach Application For Coastal Development Permit for Mooring “Optimization" Dear Honorable Commissioners, On behalf of the Newport Mooring Association - a Non Profit Corporation we object to the acceptance as complete of the City of Newport Beach's application for a mooring so-called "optimization" program.
The City of Newport Beach Harbor Department (City) submitted the Coastal Development Permit (CDP) application for mooring field "optimization"¹ on October 8, 2023. There are significant defects with the application. Thus, we encourage the Commission to issue a notice of incomplete application.
A. Significant Objections to Defects Identified During the City's Review of the Program Were Not Adequately Addressed.
The application indicates the City has not heard of objection to pushing mooring rows closer together. This is not accurate given we believe 1 The application is dated October 4, 2023 and stamped as received on October 8, 2023. Coastal staff has 30 days to deem it complete (or issue a Notice of Incomplete Application.
Coastal Commission November 2, 2023 Page 2 approximately 100 people have written to the City to express concern and
staff has 30 days to deem it complete (or issue a Notice of Incomplete Application.
Coastal Commission November 2, 2023 Page 2 approximately 100 people have written to the City to express concern and object at City Harbor Commission meetings and City Council.
On behalf of the Newport Mooring Association, we wrote to the City's Harbor Commission on November 8, 2022 to inform them that a Coastal Development Permit application is required in order for the City of Newport Beach ("City") to proceed with its proposal to amend the City of Newport Beach Harbor Code (Municipal Code, Title 17, sections 17.25.020 and 17.60.040) in order to modify mooring procedures. A copy of that letter was attached to our follow up letter of March 7, 2023. In our follow up letter of March 7, 2023, we also informed the City's Harbor Commission that review pursuant to the California Environmental Quality Act (CEQA) is required prior to approval of the ordinance changes or pilot test program. We attach these letters for your information. (Enclosure 1.) We also informed the City Council of our concerns. (Enclosure 2.) Our concerns, and those of other members of the public, have still not been addressed sufficiently, despite the City's approval of the mooring relocation.
B. The Application Fails to Include Proof That Public Notice Has Been Adequate.
The application indicates they have not made notifications of this CDP. We object to the lack of notice to the the mooring holders and the nearby homeowners as views and coastal access will be impacted by doublerow moorings and the addition of more moorings.
The applicant has certified the "posting" document (appendix D of application) without dating this document. We are concerned that proper
ted by doublerow moorings and the addition of more moorings.
The applicant has certified the "posting" document (appendix D of application) without dating this document. We are concerned that proper posting may not have occurred. The main access point to the "C" mooring field is the public dock at Fernando St. This would be a logical place to post the document. To date, our client's members have not seen a posting there.
C. The City's Proposed Mooring Relocation Program Would Impede Coastal Access.
The City's proposal to conduct a pilot test involving the relocation of existing mooring tackle and/or construction of new moorings constitutes development under the Coastal Act.
Coastal Commission November 2, 2023 Page 3 1. Coastal Water Access Would be Impeded.
The proposed revisions include new restrictions regarding designated mooring row lengths, which are undefined and will require certain permittees to relocate, making it more difficult for those permittees to access moorings, and thereby impeding coastal access.
The current mooring field configuration has been in existence for over 50 years and functions very well. The city has not proven a need to push moorings closer together. Decreasing access by making mooring use more difficult for all including folks with less mobility will be detrimental to coastal access overall.
There are serious safety concerns for users of the mooring when mooring rows are pushed together. The application lacks a safety analysis regarding safe operation of moorings that have been pushed close together.
Has a professional coastal engineer signed off on the impact to safe mooring operations after pushing mooring rows closer together in terms of preserving safe access to the moorings? This two minute video gives a good explanation
gineer signed off on the impact to safe mooring operations after pushing mooring rows closer together in terms of preserving safe access to the moorings? This two minute video gives a good explanation of the safety issues involved created by wind and tide conditions specific to Newport Harbor: Newport Harbor Mooring Configuration - YouTube nuanced and complicated as getting on and off a mooring is challenging given tidal currents and wind. There should be an examination and comparison to analogous mooring fields throughout the state (i.e., Avalon, Two Harbors, and Morro Bay). In them, there is generally equal space in the fairways (to the bow and to stern) for boats to get on and off moorings safely in changing wind and tidal currents.
Additionally, the current mooring fields are well-used by humanpowered vessels such as kayaks, stand up paddleboards, and intertube fishers as they seek safe haven from boat traffic by hiding in the mooring fields. Widening fairways within the mooring fields and inviting large boats to cruise through the mooring fields will make it less safe for the human powered vessels and will essentially kick them out of the mooring fields, thus decreasing safe access.
If necessary, our clients can explain these issues further in more detail.
However, the onus must be on the applicant to provide sufficient analysis as Coastal Commission November 2, 2023 Page 4 part of the application to ensure what it is proposing will not create unsafe conditions.
2. Coastal Dock Access Would Be Impeded.
Currently, there is not enough dinghy dock space to accommodate access to the existing moorings. Adding seven additional moorings will
reate unsafe conditions.
2. Coastal Dock Access Would Be Impeded.
Currently, there is not enough dinghy dock space to accommodate access to the existing moorings. Adding seven additional moorings will further impact access to the moorings in terms of inadequate dinghy dock space at the public piers, such as the Fernando Street pier adjacent to the C field. The application must include a dock space access analysis.
3. Coastal Parking Access Would Be Impeded.
Vehicle parking is a problem in the area. There is not enough parking. Seven new mooring users will impact parking. The application must include a vehicle parking access analysis.
D. The City Failed to Conduct Proper Environmental Review.
The application is incomplete due to the City's failure to conduct proper environmental review. The project should not be considered exempt from the California Environmental Quality Act (CEQA) because it will have environmental impacts related to public access to water, aesthetics, and construction of new moorings or relocation of existing mooring tackle in the submerged mooring field as detailed here and in our attached letters.
The City claimed the project would be exempt from CEQA pursuant to CEQA Guidelines 15302 for replacement or reconfiguration of existing facilities. However, this exemption is not applicable because the mooring program will intensify usage of the moorings, create visual and public safety impacts that do not exist with the current configuration, and add to adverse cumulative impacts.
With regard to intensity of usage, we note that the budget for the mooring program includes significant new funding that could be used for the installation of new moorings. The City Staff Report states that reconfiguration "allows for the addition of several new moorings." (Staff
am includes significant new funding that could be used for the installation of new moorings. The City Staff Report states that reconfiguration "allows for the addition of several new moorings." (Staff Report for City Council hearing, p. 5.) The purpose of the new allocations Coastal Commission November 2, 2023 Page 5 must be clarified if it is not to expand use of the mooring field by adding new moorings.
The City is relying on a "memo" from Dudek for waiving CEQA and other environmental reporting in regards to studying the impact on eelgrass from moving anchor systems for 55 moorings and adding 7 additional moorings (and related boats that will shade the eelgrass). The City is relying on an April 2023 Marine Taxonomic Services Ltd. (MTS) eelgrass report which did not even analyze the eelgrass in mooring field "C". A careful review of page 24-(region 3) and page 8 (Figure 2) of the MTS report reveals that the MTS report only looked at shoreline shallow water eelgrass near the shoreline as part of RGP 54 (local dredging permit) in the area near mooring field "C". Therefore, there is no adequate study of the impact to eelgrass with this CDP application.
The Dudek memo suggests the implementation of conservation moorings will offset any negative impact on eelgrass. However, conservation moorings are designed for "single-point" moorings whereby a boat (and associated mooring chain) freely weather vanes (swings) around the mooring in a circle (360 degrees). In the case of a single-point mooring, a conservation buoy can help reduce the chain scraping the seafloor as the vessel rotates 360 degrees around the single point mooring. However, the moorings in the C field are double-point (spreader) moorings. The chain does not move much
e chain scraping the seafloor as the vessel rotates 360 degrees around the single point mooring. However, the moorings in the C field are double-point (spreader) moorings. The chain does not move much at all because the boat is tethered from bow and stern and holds in one position. There is not a real eelgrass "scraping" problem with double point moorings. Therefore, the conservation mooring is not applicable and offers little if any eelgrass mitigation given the two-point configuration in the C field.
E. The Application Does Not Include Naval/Marine Engineering To Prove The New Densified Mooring Configuration Will Be Safe And Operable.
The application is woefully scant on engineering details. The only technical information provided in this CDP application is the illustration of underwater tackle on page 3 of the "Plans" document. This illustration is an inaccurate depiction of the proper catenary (slack and scope) required in the existing two-point/catenary "spreader” mooring systems.
Coastal Commission November 2, 2023 Page 6 F. Significant Visual Impacts Could Occur to Coastal Resources.
Visual impacts from mooring reconfiguration can be significant, especially to those from vantage points around the harbor and in nearby harbor-adjacent homes. In reviewing page 2 of the "Plans" document, it appears there will be 4 new rows of moorings including a new row of 70 foot boats (east end of mooring field C as depicted in green) blocking the view from the area of 421-425 E. Edgewater Ave. Please note this row will be established in an area where no moorings exist today. The installation of four new mooring rows (and seven new moorings with boats) will certainly have adverse visual impacts. While a mooring field reconfiguration may open up
ere no moorings exist today. The installation of four new mooring rows (and seven new moorings with boats) will certainly have adverse visual impacts. While a mooring field reconfiguration may open up views from certain vantages, it will lead to blocking and obscuring views from other vantage points. Thus, overall, the negative aesthetic impacts of the reconfiguration must be analyzed prior to approval.
The application understates and minimizes the impact to coastal views regarding pushing mooring rows closer together. A coastal view impact analysis should be part of the application.
G. The Scope of the City's Mooring Modification Program is IllDefined or Misleading.
The CDP application is purportedly for a "pilot test" yet no testing criteria has been established. There are no performance or other type of criteria to determine if the test is successful. The City seeks a blanket approval to push forward an ill-defined program while presenting it as no more than a pilot test.
On one hand, the application indicates the application is for a pilot test. On the other hand, the submittal letter indicates the City will push forward with implementing the densified double row system in mooring fields B, D, J and H as part of this application (submittal letter, page 3), which has not been approved by the City Council. The City should not be allowed to piecemeal or segment the approvals it ultimately seeks.
Coastal Commission November 2, 2023 Page 7 H. The City Should Disclose Necessary LIP Changes at the Same Time it Seeks CDP Approval.
The City's CDP application contains an incomplete disclosure of the actions that the City contemplates, or has already taken, to implement its proposed mooring modifications. The City should be required to disclose, and
ication contains an incomplete disclosure of the actions that the City contemplates, or has already taken, to implement its proposed mooring modifications. The City should be required to disclose, and seek certification of, its changes to the Harbor Code and Municipal Code which are components of the City's LIP. The City contemplates, or has already undertaken, changes to its LIP to implement its mooring modifications program without disclosing those to the Commission or including them as part of its CDP application. (Enclosure 1, objecting to amendments to the City of Newport Beach Harbor Code, Municipal Code, Title 17, sections 17.25.020 and 17.60.040 without a CDP or LIP modification to modify mooring procedures.) These changes must be the subject of an LIP amendment certification application that should accompany the CDP application because the City's planned changes should not be piecemealed over the course of different approval applications.
Conclusion.
We ask that you determine that the City's application is incomplete until full disclosures regarding the scope of the proposed project are made and the proper environmental review is conducted, including the preparation of an initial study and circulation of a negative declaration or environmental impact report for public comment at the City level.
The proposed CDP and revisions to the Harbor Code present significant changes that would alter access to water- both visual and physical access, would construct new moorings in the submerged mooring fields, and thus intensifying use. Accordingly, the proposed changes are subject to the California Environmental Quality Act, not exempt from it, and further information is required before the application may be accepted as complete.
Sincerely, Dough P. Cart
ed changes are subject to the California Environmental Quality Act, not exempt from it, and further information is required before the application may be accepted as complete.
Sincerely, Dough P. Cart Douglas P. Carstens Coastal Commission November 2, 2023 Page 8 Enclosures: Cc: 1. March 7, 2023 Letter to Harbor Commission with November 8, 2022 attached.
2. May 23, 2023 Letter to City Council ENCLOSURE 1 Main Office Phone: 310 798-2400 Direct Dial: 310-798-2400 Ext. 3 CBM Carstens, Black & Minteer LLP 2200 Pacific Coast Highway, Suite 318 Hermosa Beach, CA 90254 www.cbcearthlaw.com March 7, 2023 VIA E-MAIL (HarborCommission@newport beachca.gov) City of Newport Beach Harbor Commission c/o Office of the City Clerk P.O. Box 1768 Newport Beach, CA 92658 Re: Douglas P. Carstens Email Address: [email protected] Wed. March 8, 2023 Agenda Item 6-2; Objection to Harbor Code Amendments to Mooring Procedures that Require Coastal Development Permit and Environmental Review Dear Honorable Commissioners, On behalf of the Newport Mooring Association - a Non Profit Corporation, we wrote to you on November 8, 2022 to inform you that a Coastal Development Permit application is required in order for the City of Newport Beach ("City") and the Harbor Commission to proceed with its proposal to amend the City of Newport Beach Harbor Code (Municipal Code, Title 17, sections 17.25.020 and 17.60.040) in order to modify mooring procedures. A copy of that letter is attached.
with its proposal to amend the City of Newport Beach Harbor Code (Municipal Code, Title 17, sections 17.25.020 and 17.60.040) in order to modify mooring procedures. A copy of that letter is attached.
The City's proposal to conduct a pilot test involving the relocation of existing mooring tackle and/or construction of new moorings constitutes development under the Coastal Act, for which a Coastal Development Permit is required. Additionally, the proposed revisions include new restrictions regarding designated mooring row lengths, which are undefined and will require certain permittees to relocate, making it more difficult for those permittees to access moorings, and thereby impeding coastal access. Thus, the City and Harbor Commission may not proceed without obtaining a Coastal Development Permit from the California Coastal Commission.
Furthermore, the project is not exempt from the California Environmental Quality Act because it will have environmental impacts related to public access to water, aesthetics, and construction of new moorings or relocation of existing mooring tackle in the submerged mooring field as detailed here and in our November 8, 2022 letter.
City of Newport Beach Harbor Commission March 7, 2023 Page 2 We ask that you withhold your approval of this proposed project until proper environmental review is conducted, including the preparation of an initial study and circulation of a negative declaration or environmental impact report for public comment.
The proposed revisions to the Harbor Code present significant changes that would alter access to water and construct new moorings in the submerged mooring fields. Accordingly, they constitute development under the Coastal Act and as such, must be reviewed for approval by the Coastal Commission.
Sincerely,
construct new moorings in the submerged mooring fields. Accordingly, they constitute development under the Coastal Act and as such, must be reviewed for approval by the Coastal Commission.
Sincerely, Dough P. Cant Douglas P. Carstens Sunjana Supekar Enclosure Enclosure 3 Hermosa Beach Office Phone: (310) 798-2400 San Diego Office Phone: (858) 999-0070 Phone: (619) 940-4522 CBCM Douglas P. Carstens Email Address: Chatten-Brown, Carstens & Minteer LLP [email protected] 2200 Pacific Coast Highway, Suite 318 Hermosa Beach, CA 90254 www.cbcearthlaw.com November 8, 2022 VIA E-MAIL (Harbor [email protected], harborfeedback@newport beachca.gov) City of Newport Beach Harbor Commission c/o Office of the City Clerk P.O. Box 1768 Newport Beach, CA 92658 Re: Harbor Code Amendments to Mooring Procedures Require Coastal Development Permit; November 9, 2022 Harbor Commission Meeting Agenda Item 3 Dear Honorable Commissioners, On behalf of the Newport Mooring Association - a Non Profit Corporation, we are writing to inform the Harbor Commission that a Coastal Development Permit application is required in order for the City of Newport Beach ("City") to proceed with its proposal to amend the City of Newport Beach Harbor Code (Municipal Code, Title 17, sections 17.25.020 and 17.60.040) in order to modify mooring procedures. The City's proposal to eliminate mooring extensions and conduct a pilot test constructing new moorings constitutes development under the Coastal Act, for which a Coastal Development Permit is required. Further, the proposal would encourage unsafe navigation by large vessels in the mooring fields, and would impede coastal views. Thus, we urge the Harbor Commission to advise the City that
is required. Further, the proposal would encourage unsafe navigation by large vessels in the mooring fields, and would impede coastal views. Thus, we urge the Harbor Commission to advise the City that it may not proceed without obtaining a Coastal Development Permit from the California Coastal Commission.
I. The Coastal Commission Has Original Jurisdiction Over the Mooring Fields.
The Coastal Act recognizes the importance of protecting recreational and commercial boating and fishing activities. (See Pub. Resources Code §§30224, 30234, 30234.5.) The City of Newport Beach's Local Coastal Program Land Use Plan ("LUP") also emphasizes the importance of maintaining access to moorings, with Policy 3.3.2-3 which states "Continue to City of Newport Beach Harbor Commission November 8, 2022 Page 2 provide shore moorings and offshore moorings as an important source of lowcost public access to the water and harbor."
Though the City has adopted a Local Coastal Program, the Coastal Commission retains original jurisdiction for developments in the tidelands, public trust, and submerged lands. (Pub. Resources Code §30519, subd. (b); see City of Newport Beach's Post LCP Certification and Appeal Jurisdiction Map, available at: https://www.newport beachca.gov/PLN/LCP/LCP Zoning/Maps/21 80 045 Pe rmit and Appeal Jurs Maps/Offcial_CNB PostCert Map.pdf.) Thus, any development in the mooring fields at Newport Harbor, which are submerged lands, require review and approval by the Coastal Commission in the first instance.
II.
The Proposed Revisions to the Harbor Code Eliminating Mooring Extensions Constitute Development and Require a Coastal Development Permit.
The proposed revisions to the Harbor Code (Newport Beach Municipal
Proposed Revisions to the Harbor Code Eliminating Mooring Extensions Constitute Development and Require a Coastal Development Permit.
The proposed revisions to the Harbor Code (Newport Beach Municipal Code, Title 17) constitute development under the Coastal Act. Under the Coastal Act, development includes, inter alia, "change in the intensity of use of water, or of access thereto." (Pub. Resources Code §30106; Surfrider Foundation v. Martins Beach 1, LLC (2017) 14 Cal.App.5th 238, 250.) Under the existing Harbor Code, permittees may request mooring extensions for vessels longer than the assigned vessels, and extensions five feet or under may be granted by the Harbormaster without seeking approval from the Harbor Commission. (Newport Beach Municipal Code §17.60.040, subd. (M).)
The proposed revisions to the Harbor Code drastically change this process by eliminating mooring extensions. (October 12, 2022 Harbor Commission Agenda Packet, pp. 59-60; November 9, 2022 Harbor Commission Staff Report, Attachment C, pp. 8-9.) These revisions will alter and impede the access of permitholders to moorings, thereby constituting development under the Coastal Act.
The proposed revisions state: Requests for mooring extensions shall no longer be considered.
Instead, requests for a longer or extended mooring will require relocating to a larger mooring. The mooring permittee making the request shall pay a fee for the relocation request and shall 5 City of Newport Beach Harbor Commission November 8, 2022 Page 3 bear all costs of relocating their vessel and the displaced vessel.
Relocations will require payment of a fee and be contingent upon availability of a vacant mooring or another permittee in the same mooring field (or also an adjacent field in the case of moorings in
.
Relocations will require payment of a fee and be contingent upon availability of a vacant mooring or another permittee in the same mooring field (or also an adjacent field in the case of moorings in the H and J fields) having a vessel in a mooring row that is designated for a length of at least 5-feet greater. In no event will relocations be considered for mooring lengths in excess of 5' of the current mooring length for the permittee making such request.
Authority to approve relocation requests shall lie with the Harbormaster.
(November 9, 2022 Harbor Commission Staff Report, Attachment A.)
These revisions alter access to water because they will result in requests even for small, de minimus extensions to be considered as a request for relocation of a permittee's mooring. The location of a permittee's mooring is an important access consideration, because if a mooring is relocated far away from a permittee's dinghy location, it will be difficult for the permittee to access their mooring. Additionally, flipping any moorings where boaters have to now access the mooring in a downwind fashion will change access to and from moorings and make accessing a mooring more difficult as the operator will have less control. Finally, these revisions impose the cost of unnecessary relocations onto permittees and requires them to pay a relocation fee, which further impedes access to moorings and is contrary to LUP Policy 3.3.2-3 which requires provision of moorings as a source of "lowcost" access. These modifications to the public's access to moorings require review and approval by the Coastal Commission.
III. The Proposed Phase I Pilot Test Constitutes Development and Requires a Coastal Development Permit.
As part of the City's plan to reconfigure the Harbor, the City plans to
the Coastal Commission.
III. The Proposed Phase I Pilot Test Constitutes Development and Requires a Coastal Development Permit.
As part of the City's plan to reconfigure the Harbor, the City plans to conduct an initial reconfiguration of C Field (Phase I), with a pilot test constructing 3 to 6 double mooring systems in one row to verify engineering and functionality. (October 12, 2022 Harbor Commission Agenda Packet, p.
86.) Under the Coastal Act, development includes "in or under water, the placement or erection of any solid material or structure; [or] construction . . .
of any structure...." (Pub. Resources Code §30601.) The construction of new moorings thus falls squarely within the definition of development, for 6 City of Newport Beach Harbor Commission November 8, 2022 Page 4 which a Coastal Development Permit is required. Construction of new moorings during the pilot test will require installation and placement of new shared anchors, shackles, chains, and buoys within the mooring fields.
(October 12, 2022 Harbor Commission Agenda Packet, pp. 48, 78.) As described above, development within the mooring fields is subject to the Coastal Commission's original jurisdiction and thus requires a Coastal Development Permit. Accordingly, the City cannot proceed with the Phase I pilot test without a Coastal Development Permit.
IV. The Proposed Mooring Reconfiguration Would Encourage Unsafe Navigation of Large Vessels in the Mooring Fields.
The mooring fields as currently configured provides protection from larger vessels. We are concerned that the proposed mooring reconfiguration, which provides for wide, up to 100-foot fairways, would encourage navigation of large vessels in the mooring fields. This would both obstruct coastal access
that the proposed mooring reconfiguration, which provides for wide, up to 100-foot fairways, would encourage navigation of large vessels in the mooring fields. This would both obstruct coastal access and create a safety concern for permittees operating small vessels, as well as for paddleboarders, kayakers, and others operating small human-powered vessels in the safe haven of the mooring fields. This goes against the Chapter 3 policies of the Coastal Act, which protect such activities. (Pub. Resources Code §§30211, 30220, 30224.) Marine life that frequent the harbor, such as dolphins, may also be impacted by the introduction of larger vessels. (See Pub. Resources Code §30230.)
The mooring areas in Newport Harbor are designated "Special Anchorages" by the Coast Guard. (33 C.F.R. §110.95; see 77 Fed. Reg. 22489, available at: https://www.govinfo.gov/content/pkg/FR-2012-04-16/pdf/20129006.pdf.) Special anchorage areas "should be well removed from the fairways and located where general navigation will not endanger or be endangered by unlighted vessels." (33 C.F.R. §109.10.) Thus, fairways that accommodate large vessels should not be located within the mooring fields.
V. The Proposed Mooring Reconfiguration Would Impact Harbor Views.
We are also concerned with City staff's questionable assertion that the mooring reconfigurations would greatly improve harbor views. (October 12, 2022 Harbor Commission Agenda Packet, p. 82.) The proposal to push mooring rows together will alter view corridors from the public boardwalk around Balboa Island (and other boardwalks in Newport Harbor). (See Pub.
7 City of Newport Beach Harbor Commission November 8, 2022 Page 5 Resources Code § 30251 ["The scenic and visual qualities of coastal areas
a Island (and other boardwalks in Newport Harbor). (See Pub.
7 City of Newport Beach Harbor Commission November 8, 2022 Page 5 Resources Code § 30251 ["The scenic and visual qualities of coastal areas shall be considered and protected as a resource of public importance."]) The plan will also alter homeowner views of the harbor. While under the proposed reconfiguration, views may be improved for some-those whose properties are fronted by a fairway-views may also be greatly worsened for others, including those whose properties are fronted by the proposed doublewide tandem rows of boats.
VI.
Conclusion.
The proposed revisions to the Harbor Code present significant changes that would alter access to water and construct new moorings in the submerged mooring fields. The proposed mooring reconfiguration would encourage unsafe navigation of large vessels that impede coastal access for small-scale recreational boaters and others, and would obstruct coastal views.
Accordingly, the proposed mooring plan constitutes development under the Coastal Act and appears to be in conflict with the Coastal Act. As such, it must be reviewed for approval by the Coastal Commission. We request that the Harbor Commission, in fulfilling its charge, advise the City of these issues prior to making any recommendation.
8 Sincerely, Junjana Jupbrar рироват Douglas P. Carstens Sunjana Supekar ENCLOSURE 2 Main Office Phone: 310 798-2400 Direct Dial: 310-798-2400 Ext. 3 CBM Carstens, Black & Minteer LLP 2200 Pacific Coast Highway, Suite 318 Hermosa Beach, CA 90254 www.cbcearthlaw.com May 23, 2023 VIA E-MAIL ([email protected]) City of Newport Beach City Council c/o Office of the City Clerk P.O. Box 1768 Newport Beach, CA 92658 Douglas P. Carstens Email Address: [email protected]
VIA E-MAIL ([email protected]) City of Newport Beach City Council c/o Office of the City Clerk P.O. Box 1768 Newport Beach, CA 92658 Douglas P. Carstens Email Address: [email protected] Re: Tuesday May 23, 2023, Item 15; Objection to Harbor Code Amendments to Mooring Procedures and Pilot Program that Require Coastal Development Permit and Environmental Review Dear Honorable Mayor and Councilmembers, On behalf of the Newport Mooring Association - a Non Profit Corporation we object to approval of the mooring pilot program and associated Municipal Code changes without first conducting required environmental review and obtaining a Coastal Development Permit.
On behalf of the Newport Mooring Association, we wrote to your Harbor Commission on November 8, 2022 to inform you that a Coastal Development Permit application is required in order for the City of Newport Beach ("City") to proceed with its proposal to amend the City of Newport Beach Harbor Code (Municipal Code, Title 17, sections 17.25.020 and 17.60.040) in order to modify mooring procedures. A copy of that letter was attached to our follow up letter of March 7, 2023. In our follow up letter of March 7, 2023, we also informed your Harbor Commission that review pursuant to the California Environmental Quality Act (CEQA) is required prior to approval of the ordinance changes or pilot test program. We write to underscore these points, which have still not been addressed sufficiently.
The City's proposal to conduct a pilot test involving the relocation of existing mooring tackle and/or construction of new moorings constitutes development under the Coastal Act, for which a Coastal Development Permit and environmental review is required. Additionally, the proposed revisions City of Newport May 23, 2023 Page 2
ngs constitutes development under the Coastal Act, for which a Coastal Development Permit and environmental review is required. Additionally, the proposed revisions City of Newport May 23, 2023 Page 2 include new restrictions regarding designated mooring row lengths, which are undefined and will require certain permittees to relocate, making it more difficult for those permittees to access moorings, and thereby impeding coastal access. Thus, the City may not proceed without obtaining a Coastal Development Permit from the California Coastal Commission. We appreciate assurances in the Staff Report (page 5) that the City will apply for a Coastal Development Permit prior to implementing the test program.
Furthermore, the project is not exempt from the California Environmental Quality Act (CEQA) because it will have environmental impacts related to public access to water, aesthetics, and construction of new moorings or relocation of existing mooring tackle in the submerged mooring field as detailed here and in our prior letters.
The Staff Report claims the project would be exempt from CEQA pursuant to CEQA Guidelines 15302 for replacement or reconfiguration of existing facilities. However, this exemption is not applicable because the mooring program will intensify usage of the moorings, create visual and public safety impacts that do not exist with the current configuration, and potentially adversely cumulative impacts exist.
With regard to intensity of usage, we note that the budget for the mooring program includes significant new funding that could be used for the installation of new moorings. The Staff Report states that reconfiguration "allows for the addition of several new moorings." (Staff Report, p. 5.) The
gnificant new funding that could be used for the installation of new moorings. The Staff Report states that reconfiguration "allows for the addition of several new moorings." (Staff Report, p. 5.) The purpose of the new allocations must be clarified if it is not to expand use of the mooring field by adding new moorings.
Visual impacts from mooring reconfiguration can be significant, especially to those from vantage points around the harbor and in nearby harbor-adjacent homes. While mooring field reconfiguration may open up views from certain vantages, it will lead to blocking and obscuring views from other vantage points. Thus, overall, the negative aesthetic impacts of the reconfiguration must be analyzed prior to approval.
We ask that you withhold your approval of this proposed project until proper environmental review is conducted, including the preparation of an initial study and circulation of a negative declaration or environmental impact report for public comment.
City of Newport May 23, 2023 Page 3 The proposed revisions to the Harbor Code present significant changes that would alter access to water- both visual and physical access, would construct new moorings in the submerged mooring fields, and thus intensifying use. Accordingly, the proposed changes are subject to the California Environmental Quality Act, not exempt from it, and the changes require a Coastal Development Permit from the Coastal Commission.
Sincerely, Dough Pa Douglas P. Carstens ENCLOSURE 2 Innovative Structural and Specialty Engineering PLLC Re: Newport Harbor Mooring Field C Realignment Proposal - CDP Application No 5-23-0753 Dear Mr. Palm, On behalf of the Newport Mooring Association, ISSE have reviewed the subject Application and
PLLC Re: Newport Harbor Mooring Field C Realignment Proposal - CDP Application No 5-23-0753 Dear Mr. Palm, On behalf of the Newport Mooring Association, ISSE have reviewed the subject Application and supporting documentation and provide the following submission for your review.
Introduction Newport Harbor is a naturally protected waterway, ideally located to provide access to the California coast. For over a century, this valuable resource has supported a significant population of mariners and their watercraft. The harbor includes several mooring fields designed to offer safe, economical parking for boats with convenient access to coastal waters. For the 55 permittees of the Field C Pilot Program, coastal access fundamentally depends on having secure moorings and safe, accident-free mooring operations.
The primary function of mooring fields is not navigation, but rather to ensure safe and secure boat storage. Design priorities for mooring fields should focus on providing well-secured moorings that allow craft movement while withstanding adverse weather conditions and preventing collisions. Additionally, mooring fields should ensure that mariners can approach and depart their moorings safely in most weather conditions.
In fact, the Newport Harbor Mooring Fields are designated "special anchorage areas" in the Federal Register, Coast Guard Final Rule, effective May 16, 2012. Such areas "should be well removed from the fairways and located where general navigation will not endanger or be endangered by unlighted vessels".
Thus, even contemplating fairways within the mooring fields would seem to be in violation of the Coast Guard Rules.
Background The environmental conditions in "Mooring Field C" often make mooring operations challenging, with tidal
ays within the mooring fields would seem to be in violation of the Coast Guard Rules.
Background The environmental conditions in "Mooring Field C" often make mooring operations challenging, with tidal currents frequently exceeding one knot and significant winds generating waves from multiple directions and additional wind-driven currents. As sea states deteriorate, the likelihood of accidents increases disproportionately. Mooring operations are particularly hazardous during severe weather conditions when the mariner's ability to control the boat is impaired by the wind, strong currents and wind-induced waves.
Even under the prevailing regular West winds combined with tides, the dynamic conditions become challenging for mooring. These conditions directly impact the probability of accidents, especially when boats are in close proximity during mooring or departure.
Innovative Structural and Specialty Engineering PLLC The high profile of many power boats, and the windage of the rigging on many sailboats, create significant difficulties in brisk wind, even when wave action is less of an issue. Wind conditions often complicate mooring operations more than wave activity in Field C.
Comparisons between "Newport Harbor" and "America's Cup Harbor, San Diego" are not valid due to the vastly different tidal and wind conditions in each location. America's Cup Harbor is sheltered from wind, and tidal currents are negligible, making it easier to maneuver boats during mooring. Therefore, San Diego's ACH conditions are not applicable to the proposed reconfiguration of Field C, except to highlight
dal currents are negligible, making it easier to maneuver boats during mooring. Therefore, San Diego's ACH conditions are not applicable to the proposed reconfiguration of Field C, except to highlight the stark differences in sea-state challenges. In Field C, the risk of collisions increases significantly when nearby boats are closer, as reduced space for error leaves little room for drift or navigational mistakes during mooring operations.
Findings A factor contributing to the increased likelihood of accidents is the modification of established procedures that mariners have become accustomed to. When habitual mooring methods are changed, particularly under time pressure in storm conditions, human decision-making becomes more error-prone. The proposed reconfiguration for "Mooring Field C" would require permittees to adopt new mooring protocols, further increasing the potential for accidents. Any changes that reduce the clear space between moored boats-such as increasing the density of moorings or shrinking the area of the mooring field-will amplify the probability of collisions.
One of the objectives of the reconfiguration is to create wider fairways within the mooring fields to improve navigation and optimize space utilization. However, this may have unintended consequences, such as encouraging vessels to take shortcuts through the mooring field, increasing the risk of accidents. Building a thoroughfare through a mooring field is akin to running a road through a public parking lot-it introduces unnecessary hazards by encouraging traffic in areas meant for stationary boats. This design compromises safety, particularly for mooring operations, which require space for maneuvering and securing boats in dynamic conditions.
ouraging traffic in areas meant for stationary boats. This design compromises safety, particularly for mooring operations, which require space for maneuvering and securing boats in dynamic conditions.
Navigation channels outside the mooring fields should remain the primary route for vessels in transit to avoid unnecessary traffic within the mooring area. The mooring field should be protected from in-transit traffic, creating safer conditions for human-powered craft and swimmers.
The proposal to expand every other fairway at the expense of eliminating every alternate fairway further compounds the issue. Boat operators need an equal amount of fairway space in both directions to ensure various escape routes under different conditions. Reducing the number of fairways compromises their ability to safely maneuver, especially in dynamic sea-state conditions. (See attached 3-page visual/slide provided by NMA for reference.)
The reconfiguration, as described in Dudek's letter to the California Coastal Commission dated February 12, 2024, (Item 4, Alternative Reconfigurations) emphasizes safety for mariners in transit and the optimized use of space within the mooring field. However, the real safety concern arises during the critical offshore mooring operations when boats are most vulnerable. During transit, boats are under control with steerageway, whereas mooring operations, particularly in adverse weather conditions, pose far greater challenges, with potential loss of steerage. The Application appears to prioritize optimizing space for parked boats, similar to the layout of a car parking lot, without adequately considering the space requirements necessary for safe mooring operations.
•
tion appears to prioritize optimizing space for parked boats, similar to the layout of a car parking lot, without adequately considering the space requirements necessary for safe mooring operations.
• Innovative Structural and Specialty Engineering 140 Broadway 46th Floor ⚫ New York NY 10005 (646) 974-1390 Innovative Structural and Specialty Engineering PLLC Likewise, the City of Newport Beach Harbormaster's statement from December 7, 2023, Re Navigability, focuses on improving navigation and space optimization within the mooring fields, but fails to address the critical space needs for safe mooring. Navigation is relatively straightforward compared to the complex and hazardous process of securing a boat during offshore mooring during non-calm conditions. The reconfiguration's emphasis on fairways and aesthetics may create a visually regular arrangement, but it sacrifices the global space required for safe mooring operations, especially in adverse conditions.
Aesthetics are subjective, and while the proposed changes may enhance the visual appeal of the mooring field for some, they introduce additional risks by reducing the space between boats.
Additionally, any realignment that increases the density of moored boats, such as double-row mooring, further reduces the minimum space between vessels, increasing the likelihood of accidents during both mooring and routine transits to and from the field.
The Application explores different anchoring options, such as helical anchors and steel weights. At present there is no evidence of eelgrass in Mooring Field C (2022 Eelgrass Map, Marine Taxonomic Services, Ltd). The nearest eel grass is greater than 5m distance from Field C. The submerged floating
present there is no evidence of eelgrass in Mooring Field C (2022 Eelgrass Map, Marine Taxonomic Services, Ltd). The nearest eel grass is greater than 5m distance from Field C. The submerged floating lines of "conservation moorings", though considered for environmental protection of eelgrass, pose additional hazards during mooring operations and thus should be discouraged. Although the helical anchors demonstrate considerably greater vertical pull capacity than the others, lateral cyclic prying action, from all directions, during strong wind and low tides (greatest line slackness) is likely to degrade the hold-down capacity, and could test the long-term lateral capacity. Significantly, any changing of mooring anchors is likely to disturb the sea-bed and is expected to invoke CEQA.
The maximum tidal range is +7.0' to -1.4' MLLW without storm surge. Therefore the slackness in the mooring buoy anchor lines varies by over 8 ft, depending on tide, causing variable boat drift around the mooring site. The catenary action in the mooring tackle is crucial for absorbing dynamic loads caused by storm drift, and any reduction in scope distance during high tides will increase the hazard by amplifying impact loads on boats. This critical aspect of mooring design has not been adequately considered in the reconfiguration plan, raising concerns about the safety and practicality of the proposed changes.
Conclusion For the above reasons, fundamental to most mariners who moor in open water, we respectfully submit CDP Application No 5-23-0753 for Mooring Field C Pilot Program should be rejected in its entirety.
Sincerely, Radli Manda Innovative Structural and Specialty Engineering PLLC Radhi Majmudar PE David Williams PE •
ion No 5-23-0753 for Mooring Field C Pilot Program should be rejected in its entirety.
Sincerely, Radli Manda Innovative Structural and Specialty Engineering PLLC Radhi Majmudar PE David Williams PE • Innovative Structural and Specialty Engineering • 140 Broadway 46th Floor New York NY 10005 (646) 974-1390 Innovative Structural and Specialty Engineering PLLC Radhi Majmudar PE is a structural engineer with extensive experience in marine and coastal structural engineering, with a particular focus on design, analysis, and condition assessments of piers and underwater structures. She has led teams that performed underwater inspections to evaluate the condition of piles and other submerged components, addressing issues such as marine borer attacks and environmental wear. Based on these assessments, she provided recommendations for structural repairs and reinforcements to restore and maintain the operational safety and longevity of key coastal infrastructure.
In addition to inspections, she has experience overseeing and approving mooring engineering activities for marine projects. This includes supervising contractors on model testing, evaluating mooring strength, conducting fatigue analysis, and performing finite element analysis (FEA) to ensure the structural integrity of mooring systems. Her responsibilities also encompassed reviewing mooring and ensured that mooring systems and associated infrastructure met rigorous safety and performance standards in challenging marine environments.
She contributed to the analysis and evaluation of large offshore platforms, performing seismic assessments to understand the impact of natural forces such as earthquakes on these structures.
ronments.
She contributed to the analysis and evaluation of large offshore platforms, performing seismic assessments to understand the impact of natural forces such as earthquakes on these structures.
Utilizing advanced tools and modeling techniques, she, as part of a team, analyzed the safety, stability, and functionality of critical offshore installations, enhancing their resilience against environmental forces and extending their operational lifespan. Their work helped safeguard the long-term stability of offshore and coastal structures under dynamic and harsh marine conditions.
Furthermore, her experience includes playing a critical role in the development of major container terminals. She was involved in the design process, overseeing physical model tests and conducting computer simulations to assess the motion of moored ships, including factors like surge, sway, heave, yaw, pitch, and roll. She also evaluated various structural design alternatives for quay walls, including gravity block walls, pile-supported platforms, and steel caissons. Their contributions helped optimize both the functionality and structural integrity of key port facilities, ensuring they were designed to handle the operational demands of international shipping routes while withstanding harsh marine conditions.
Representative Project Experience Port Salalah Container Terminal Development and Design Study, Oman, Arabian Sea Client: Sea Land Service Inc. and the Sultanate of Oman Design, Analysis, Inspection Services for Pier 35 Gowanus Bay in Brooklyn, New York Client: New York City Economic Development Corporation Design, Analysis, Inspection Services for East River Pier 13/14 Complex in Manhattan, NY Client: New York City Economic Development Corporation
k Client: New York City Economic Development Corporation Design, Analysis, Inspection Services for East River Pier 13/14 Complex in Manhattan, NY Client: New York City Economic Development Corporation Design and Inspection Services for Administration and Maintenance Building -Howland Hook Marine Terminal Staten Island, NYClient: Port Authority New York and New Jersey Innovative Structural and Specialty Engineering PLLC Design, Analysis and Inspection Services for Bulkheads at Piers 1 through 5 Brooklyn, New York Client: Port Authority New York and New Jersey Design of Breakwaters and Wharf Structures Haifa Port, Israel Client: Government of Israel, Israel Port Authority Seismic Analysis of Steel Fixed Offshore Platforms Santa Ynez, California Client: Exxon Corporation David Williams, PhD, PE, has been involved with marine infrastructure throughout his career (over five decades), primarily in the capacity of structural design, constructability, risk assessment, value engineering, safety and support of critical projects.
His experience ranges from analysis and design of large floating bridges and moored caissons, barges and ocean transport; design and assessment of flood-protection structures and retaining walls for the US Army Corps of Engineers following the Katrina hurricane (including navigation facilities through flood gates, incorporating pilot simulation results/reaction times for guide and fender arrangement); project management of a replacement floating launching pier and gangway (ADA-compliant) for a coastal inland lagoon, used for human powered craft (kayaking, rowing, canoeing, SUPs); design review of redesigned
anagement of a replacement floating launching pier and gangway (ADA-compliant) for a coastal inland lagoon, used for human powered craft (kayaking, rowing, canoeing, SUPs); design review of redesigned sheet-pile bulkheads and forensic engineering for a new container terminal following construction failure; to detailed design and seismic analysis of new locks for a major canal, dry dock facilities, and a shiplift; seismic retrofit of port facilities; analysis of major fixed and floating offshore structures designed for extreme storm and seismic effects in adverse environments; the first installation of large piles for over-water bridge foundations using offshore technology (from semi submersible barge cranes). He has designed and analyzed anchors and mooring systems for a variety of applications and undertaken peer review of pioneering marine engineering concepts.
As such, he brings invaluable multidisciplinary experience, and familiarity with permitting coastal facilities, including stringent environmental concerns and regulations. He is familiar with extreme environments, remote sites, construction limitations due to environmental hazards and other permitting issues, bio-fouling and cold-climate engineering (obtained Alaska PE License in 2001).
His expertise and independent investigation of several hydrodynamic problems (analytical and experimental wave tank testing) has led him to provide specialist consulting on many pioneering marine and coastal projects including expert testimony before regulatory authorities regarding safety of critical infrastructure.
In addition he brings years of experience in aquatic recreation - open water, coastal and ocean sailing, open water and flatwater rowing, kayaking and white water rafting. This experience provides invaluable
tion he brings years of experience in aquatic recreation - open water, coastal and ocean sailing, open water and flatwater rowing, kayaking and white water rafting. This experience provides invaluable understanding of the variability of sea states and challenges involved in controlling and mooring boats in open water.
Innovative Structural and Specialty Engineering 140 Broadway 46th Floor New York NY 10005 (646) 974-1390 ) Proposed Double Row System with Prevailing Winds Innovative Structural and Specialty Engineering PLLC These tight quarters will not allow forward boats to take appropriate angled approach when accessing moorings, making access more difficult and less safe compared to existing configuration.
When single-handed boater unties bow line, they will immediately be blown into boat behind. This configuration does not allow for reasonable reaction time.
Innovative Structural and Specialty Engineering PLLC No room to rear-unsafe for current and winds in Newport • Innovative Structural and Specialty Engineering 140 Broadway 46th Floor New York NY 10005 (646) 974-1390 Existing single row mooring alignment provides multiple access and departure routes depending on variable winds and currents. The proposed double row eliminates various access and departure angles.
Innovative Structural and Specialty Engineering PLLC ENCLOSURE 3 LII > Electronic Code of Federal Regulations (e-CFR) > Title 33 - Navigation and Navigable Waters > CHAPTER I - COAST GUARD, DEPARTMENT OF HOMELAND SECURITY > $ 109.10 Special anchorage areas.
33 CFR § 109.10 - Special anchorage areas.
CFR Table of Popular Names § 109.10 Special anchorage areas.
An Act of Congress of April 22, 1940, provides for the designation of special anchorage
e areas.
33 CFR § 109.10 - Special anchorage areas.
CFR Table of Popular Names § 109.10 Special anchorage areas.
An Act of Congress of April 22, 1940, provides for the designation of special anchorage areas wherein vessels not more than sixty-five feet in length, when at anchor, will not be required to carry or exhibit anchorage lights. Such designation is to be made after investigation, by rule, regulation, or order, the procedure for which will be similar to that followed for anchorage grounds under section 7 of the Rivers and Harbors Act of March 4, 1915, as referred to in § 109.05. The areas so designated should be well removed from the fairways and located where general navigation will not endanger or be endangered by unlighted vessels. The authority to designate special anchorage areas was transferred to and vested in the Secretary of Homeland Security by section 902(j) of the Coast Guard and Maritime Transportation Act of 2006 (Pub. L. 109-241, 120 Stat 516), and delegated to the Commandant of the U.S. Coast Guard in Department of Homeland Security Delegation No. 0170.1. The Commandant redelegated the authority to establish anchorage grounds to each Coast Guard District Commander as provided in 33 CFR 1.05-1(e)(1)(i).
[USCG-2007-27887, 72 FR 45902, Aug. 16, 2007] CFR Toolbox Law about... Articles from Wex Table of Popular Names Parallel Table of Authorities Accessibility About LII Contact us Advertise here Help Terms of use Privacy 2 ENCLOSURE 4 AUTHENTICATED US. GOVERNMENT INFORMATION GPO Federal Register/Vol. 77, No. 73/Monday, April 16, 2012/Rules and Regulations penalties for failure to timely provide certain notices or other material information. Under the rule, such assessments will be subject to reconsideration in accordance with the
/Rules and Regulations penalties for failure to timely provide certain notices or other material information. Under the rule, such assessments will be subject to reconsideration in accordance with the provisions of the regulation.
DATES: Effective May 16, 2012 and Among the proposed actions was amendment of the administrative review regulation to make determinations with respect to penalties under section 4071 subject to that regulation, in the class of matters reviewable by reconsideration.³ No comments were received on the applicable to determinations made on or proposal.4 after that date.
FOR FURTHER INFORMATION CONTACT: Catherine B. Klion (klion.catherine@ pbgc.gov), Manager, or Deborah C.
Murphy ([email protected]), Attorney, Regulatory and Policy Division, Legislative and Regulatory Department, Pension Benefit Guaranty Corporation, 1200 K Street NW., Washington, DC 20005-4026; 202-3264024. (TTY/TDD users may call the Federal relay service toll free at 1-800877-8339 and ask to be connected to 202-326-4024.)
SUPPLEMENTARY INFORMATION: The Pension Benefit Guaranty Corporation (PBGC) administers the pension plan termination insurance program under title IV of the Employee Retirement Income Security Act of 1974 (ERISA).
PBGC's regulation on Rules for Administrative Review of Agency Decisions (29 CFR Part 4003) provides rules governing the issuance of initial determinations by PBGC involving the matters set forth in the regulation and procedures for requesting and obtaining PBGC review of those determinations, either by appeal (a more formal proceeding) or by request for reconsideration (a less formal process), depending on the type of matter. A person that fails to exhaust administrative remedies under the regulation with respect to a
al proceeding) or by request for reconsideration (a less formal process), depending on the type of matter. A person that fails to exhaust administrative remedies under the regulation with respect to a determination may not be able to raise in court some legal defenses against enforcement of the determination that might otherwise have been available.
Section 4071 of ERISA authorizes PBGC to assess a penalty for failure to timely provide any notice or other material information required under ERISA sections 4001-4071 or 303(k)(4) or regulations thereunder. PBGC published policy guidance on its assessment and review of section 4071 penalties on March 3, 1992 (at 57 FR 7605), and July 18, 1995 (at 60 FR 36837). On January 12, 2001 (at 66 FR 2857), PBGC published a proposed rule on Assessment of and Relief from Penalties under both ERISA section 4007 (dealing with payment of premiums) and ERISA section 4071.2 1 The 1995 policy statement generally replaced the 1992 statement.
2 Although it was published as a proposal with an invitation for public comment, the 2001 penalty policy proposed rule was (as its preamble stated) This final rule amends the administrative review regulation consistent with the 2001 proposal. This change will promote uniformity in PBGC's procedures for making and reviewing determinations. The provisions of the administrative review regulation will supersede any inconsistent provisions of the 1992 and 1995 penalty policy statements; in other respects, those policy statements will be unaffected.
Applicability The amendment made by this rule applies to determinations under section 4071 made on or after May 16, 2012.
Compliance With Rulemaking Guidelines PBGC has determined that this action is not a "significant regulatory action"
his rule applies to determinations under section 4071 made on or after May 16, 2012.
Compliance With Rulemaking Guidelines PBGC has determined that this action is not a "significant regulatory action" under the criteria set forth in Executive Order 12866.
This rule is not subject to notice and comment rulemaking requirements under section 553 of the Administrative Procedure Act because it deals only with PBGC procedural rules. Because no general notice of proposed rulemaking is required, the Regulatory Flexibility Act does not apply. See 5 U.S.C. 601(2), 603, 604.
This action is associated with retrospective review and analysis in PBGC's Plan for Regulatory Review 5 issued in accordance with Executive Order 13563 on "Improving Regulation and Regulatory Review."
not subject to notice and comment rulemaking requirements under section 553 of the Administrative Procedure Act because it dealt only with general statements of PBGC policy and with PBGC procedural rules. On November 17, 2006 (at 71 FR 66867), PBGC published a final rule adding a penalty policy appendix, drawn from the 2001 proposed rule, to its regulation on Payment of Premiums.
3 Premium penalties under ERISA section 4007 are already covered by the administrative review regulation. Premium penalty determinations are in the class of matters for which reconsideration is provided.
4 On May 7, 2004 (at 69 FR 25797), PBGC proposed a new penalty policy for failures to issue Participant Notices as required under ERISA section 4011 and PBGC's regulation on Disclosure to Participants (29 CFR part 4011), the provisions of which are inapplicable to plan years starting after 2006. Comments received on that proposal were relevant to some aspects of the 2001 proposal, but not to the administrative review provisions.
ons of which are inapplicable to plan years starting after 2006. Comments received on that proposal were relevant to some aspects of the 2001 proposal, but not to the administrative review provisions.
5 See www.pbgc.gov/documents/plan-forregulatory-review.pdf.
22489 List of Subjects in 29 CFR Part 4003 Administrative practice and procedure, Organization and functions (Government agencies), Pension insurance, Pensions.
For the reasons given above, PBGC is amending 29 CFR part 4003 as follows.
PART 4003-RULES FOR ADMINISTRATIVE REVIEW OF AGENCY DECISIONS ■1. The authority citation for part 4003 continues to read as follows: Authority: 29 U.S.C. 1302(b)(3).
2. In § 4003.1, paragraph (a) is amended by removing the words "(b)(1) through (b)(4)" and adding in their place the words "(b)(1) through (b)(5)" and by removing the words "(b)(5) through (b)(10)" and adding in their place the words "(b)(6) through (b)(11)"; paragraphs (b)(5) through (b)(10) are redesignated as paragraphs (b)(6) through (b)(11); and a new paragraph (b)(5) is added to read as follows: §4003.1 Purpose and scope.
* * * * * (5) Determinations with respect to penalties under section 4071 of ERISA; * * * * Issued in Washington, DC, this 6th day of April 2012.
Joshua Gotbaum, Director, Pension Benefit Guaranty Corporation.
[FR Doc. 2012-9095 Filed 4-13-12; 8:45 am] BILLING CODE 7709-01-P DEPARTMENT OF HOMELAND SECURITY Coast Guard 33 CFR Part 110 [Docket No. USCG-2010-0929] RIN 1625-AA01 Special Anchorage Regulations, Newport Bay Harbor, CA AGENCY: Coast Guard, DHS.
ACTION: Final rule.
SUMMARY: The Coast Guard is expanding the boundaries of the special anchorage areas in Newport Bay Harbor, California, to encompass and replace temporary anchorage grounds C-1 and C-2, and
Final rule.
SUMMARY: The Coast Guard is expanding the boundaries of the special anchorage areas in Newport Bay Harbor, California, to encompass and replace temporary anchorage grounds C-1 and C-2, and anchorage ground C-3. This rule realigns anchorage boundaries to reflect the way the harbor currently is used.
DATES: This rule is effective May 16, 2012.
22490 Federal Register/Vol. 77, No. 73/Monday, April 16, 2012/Rules and Regulations ADDRESSES: Comments and material received from the public, as well as documents mentioned in this preamble as being available in the docket, are part of docket USCG-2010-0929 and are available online by going to http:// www.regulations.gov, inserting USCG2010-0929 in the "Keyword" box, and then clicking "Search." This material is also available for inspection or copying at the Docket Management Facility (M-30), U.S. Department of Transportation, West Building Ground Floor, Room W12-140, 1200 New Jersey Avenue SE., Washington, DC 20590, between 9 a.m. and 5 p.m., Monday through Friday, except Federal holidays.
FOR FURTHER INFORMATION CONTACT: If you have questions on this rule, call or email Lieutenant Lucas Mancini, Coast Guard District Eleven, telephone 510437-3801, email [email protected]. If you have questions on viewing or submitting material to the docket, call Renee V.
Wright, Program Manager, Docket Operations, telephone 202-366-9826.
SUPPLEMENTARY INFORMATION: Regulatory Information On December 16, 2011 we published a notice of proposed rulemaking (NPRM) entitled "Anchorage Regulations: Subpart A-Special Anchorage Regulations, Newport Bay Harbor, CA" in the Federal Register (76 FR 78185). We received no comments on the proposed rule. No request for public meeting was made.
Basis and Purpose
A-Special Anchorage Regulations, Newport Bay Harbor, CA" in the Federal Register (76 FR 78185). We received no comments on the proposed rule. No request for public meeting was made.
Basis and Purpose The legal basis for this rule is: 33 U.S.C. 471, 1221 through 1236, 2030, 2035, 2071; 33 CFR 1.05-1; and Department of Homeland Security Delegation No. 0170.1, which collectively authorize the Coast Guard to define anchorage grounds.
This rule expands the designated special anchorage areas in Newport Bay Harbor, and removes other anchorage grounds, to align with the actual placement of existing mooring areas and reflect the way the harbor is currently used.
Background Due to enhanced anchorage population over the years, the mooring areas being used in Newport Bay Harbor are nominally larger than the special anchorage areas originally charted in 33 CFR 110.95. As moorings were added or overhauled, the new moorings would fall outside the existing boundaries, resulting in moorings lying outside the charted areas. Similarly, the anchorage grounds designated in 33 CFR 110.212 were originally used as temporary overflow anchorages, but are now used regularly. Harbor users have been accustomed to this placement for the last 10 years.
The Mooring Master Plan Subcommittee of the City of Newport Harbor Commission led an outreach campaign involving a series of public meetings about aligning the anchorage regulations with actual harbor use patterns, and we understand that it did not receive any opposition from the waterway users. After these public meetings, the City of Newport asked the Coast Guard to amend its anchorage regulations. The Coast Guard therefore solicited public comment on proposed changes in the NPRM mentioned above.
We received no comment on the proposal.
rt asked the Coast Guard to amend its anchorage regulations. The Coast Guard therefore solicited public comment on proposed changes in the NPRM mentioned above.
We received no comment on the proposal.
Discussion of Changes The Coast Guard is finalizing the proposal without changes and realigning the anchorage boundaries in order to reflect the way the harbor currently is used. This rule removes § 110.212 and the three anchorage grounds found therein (anchorages C-1, C-2, C-3). The area covered by those anchorages is incorporated into the special anchorage area regulations at § 110.95. Anchorage C-1 is incorporated into area B-1 under revised § 110.95(m), and anchorages C-2 and C-3 is incorporated into area A-11 under revised $110.95(k). An image of the anchorage areas is available in the docket.
The enlargement of the special anchorage areas does not pose any waterway or navigational hazard, or restrict harbor use in any way. The Army Corps of Engineers has been consulted and did not have any opposition. We anticipate that this rule would have no impact on fishing or boating because the amendment adjusts the lines to fit the current layout of moorings in Newport Harbor. Small craft are not restricted in the harbor.
Berthing and anchoring in Newport Harbor also is regulated by Orange County ordinance and the City of Newport's municipal code. The enlargement of the special anchorages does not impact these laws; for the convenience of the reader we have included references pertaining to local municipal codes in the rule.
Regulatory Analyses We developed this rule after considering numerous statutes and executive orders related to rulemaking.
Below we summarize our analyses based on 13 of these statutes or executive orders.
Regulatory Planning and Review
s rule after considering numerous statutes and executive orders related to rulemaking.
Below we summarize our analyses based on 13 of these statutes or executive orders.
Regulatory Planning and Review This rule is not a significant regulatory action under section 3(f) of Executive Order 12866, Regulatory Planning and Review, as supplemented by Executive Order 13563, and does not require an assessment of potential costs and benefits under section 6(a)(3) of that Order. The Office of Management and Budget has not reviewed it under that Order. The Coast Guard is realigning anchorage boundaries in order to reflect the way the harbor currently is used.
The enlargement of the anchorages does not restrict harbor use in any way.
Small Entities Under the Regulatory Flexibility Act (5 U.S.C. 601-612), we have considered whether this rule will have a significant economic impact on a substantial number of small entities. The term "small entities" comprises small businesses, not-for-profit organizations that are independently owned and operated and are not dominant in their fields, and governmental jurisdictions with populations of less than 50,000.
The Coast Guard certifies under 5 U.S.C. 605(b) that this rule will not have a significant economic impact on a substantial number of small entities.
(1) This rule may affect the following entities, some of which might be small entities: The owners or operators of commercial and recreational vessels intending to transit or anchor in the affected area.
(2) The impact to these entities will not, however, be significant since this area will encompass only a small portion of the waterway and vessels can safely navigate around the anchored vessels.
Assistance for Small Entities Under section 213(a) of the Small Business Regulatory Enforcement
ompass only a small portion of the waterway and vessels can safely navigate around the anchored vessels.
Assistance for Small Entities Under section 213(a) of the Small Business Regulatory Enforcement Fairness Act of 1996 (Pub. L. 104-121), in the NPRM we offered to assist small entities in understanding the rule so that they could better evaluate its effects on them and participate in the rulemaking process.
Small businesses may send comments on the actions of Federal employees who enforce, or otherwise determine compliance with, Federal regulations to the Small Business and Agriculture Regulatory Enforcement Ombudsman and the Regional Small Business Regulatory Fairness Boards. The Ombudsman evaluates these actions annually and rates each agency's responsiveness to small business. If you wish to comment on actions by employees of the Coast Guard, call 1-888-REG-FAIR (1-888-734-3247).
Federal Register/Vol. 77, No. 73/Monday, April 16, 2012/Rules and Regulations The Coast Guard will not retaliate against small entities that question or complain about this rule or any policy or action of the Coast Guard.
Collection of Information This rule calls for no new collection of information under the Paperwork Reduction Act of 1995 (44 U.S.C. 35013520).
Federalism A rule has implications for federalism under Executive Order 13132, Federalism, if it has a substantial direct effect on State or local governments and would either preempt State law or impose a substantial direct cost of compliance on them. We have analyzed this rule under that Order and have determined that it does not have implications for federalism.
Unfunded Mandates Reform Act The Unfunded Mandates Reform Act of 1995 (2 U.S.C. 1531-1538) requires Federal agencies to assess the effects of
ermined that it does not have implications for federalism.
Unfunded Mandates Reform Act The Unfunded Mandates Reform Act of 1995 (2 U.S.C. 1531-1538) requires Federal agencies to assess the effects of their discretionary regulatory actions. In particular, the Act addresses actions that may result in the expenditure by a State, local, or tribal government, in the aggregate, or by the private sector of $100,000,000 (adjusted for inflation) or more in any one year. Though this rule would not result in such expenditure, we do discuss the effects of this rule elsewhere in this preamble.
Taking of Private Property This rule does not cause a taking of private property or otherwise have taking implications under Executive Order 12630, Governmental Actions and Interference with Constitutionally Protected Property Rights.
Civil Justice Reform This rule meets applicable standards in sections 3(a) and 3(b)(2) of Executive Order 12988, Civil Justice Reform, to minimize litigation, eliminate ambiguity, and reduce burden.
Protection of Children We have analyzed this rule under Executive Order 13045, Protection of Children from Environmental Health Risks and Safety Risks. This rule is not an economically significant rule and would not create an environmental risk to health or risk to safety that might disproportionately affect children.
Indian Tribal Governments This rule does not have tribal implications under Executive Order 13175, Consultation and Coordination with Indian Tribal Governments, because it will not have a substantial direct effect on one or more Indian tribes, on the relationship between the Federal Government and Indian tribes, or on the distribution of power and responsibilities between the Federal Government and Indian tribes.
Energy Effects
dian tribes, on the relationship between the Federal Government and Indian tribes, or on the distribution of power and responsibilities between the Federal Government and Indian tribes.
Energy Effects We have analyzed this rule under Executive Order 13211, Actions Concerning Regulations That Significantly Affect Energy Supply, Distribution, or Use. We have determined that it is not a "significant energy action" under that order because it is not a "significant regulatory action" under Executive Order 12866 and is not likely to have a significant adverse effect on the supply, distribution, or use of energy. The Administrator of the Office of Information and Regulatory Affairs has not designated it as a significant energy action. Therefore, it does not require a Statement of Energy Effects under Executive Order 13211.
Technical Standards The National Technology Transfer and Advancement Act (NTTAA) (15 U.S.C. 272 note) directs agencies to use voluntary consensus standards in their regulatory activities unless the agency provides Congress, through the Office of Management and Budget, with an explanation of why using these standards would be inconsistent with applicable law or otherwise impractical.
Voluntary consensus standards are technical standards (e.g., specifications of materials, performance, design, or operation; test methods; sampling procedures; and related management systems practices) that are developed or adopted by voluntary consensus standards bodies.
This rule does not use technical standards. Therefore, we did not consider the use of voluntary consensus standards.
Environment We have analyzed this rule under Department of Homeland Security Management Directive 023-01 and Commandant Instruction M16475.ID, which guide the Coast Guard in
ntary consensus standards.
Environment We have analyzed this rule under Department of Homeland Security Management Directive 023-01 and Commandant Instruction M16475.ID, which guide the Coast Guard in complying with the National Environmental Policy Act of 1969 (NEPA) (42 U.S.C. 4321-4370f), and have concluded that this action is one of a category of actions that do not individually or cumulatively have a significant effect on the human environment. An "Environmental Analysis Check List" and a categorical exclusion determination supporting this determination are available in the docket where indicated under 22491 ADDRESSES. This rule involves changing the size of special anchorage areas.
List of Subjects in 33 CFR Part 110 Anchorage grounds.
For the reasons discussed in the preamble, the Coast Guard amends 33 CFR part 110 as follows: PART 110-ANCHORAGE REGULATIONS 1. The authority citation for part 110 continues to read as follows: Authority: 33 U.S.C. 471, 1221 through 1236, 2030, 2035, 2071; 33 CFR 1.05-1(g); Department of Homeland Security Delegation No. 0170.1.
■2. Revise § 110.95 to read as follows: $110.95 Newport Bay Harbor, Calif.
(a) Area A-1. The entire water area within beginning at latitude 33°36'09.3" N., longitude 117°53'52.6" W.; thence to latitude 33°36'11.4" N., longitude 117°53'51.2" W.; thence to latitude 33°36'04.0" N., longitude 117°53′33.4" W.; thence to latitude 33°36'03.9" N., longitude 117°53'20.4" W.; thence to 33°36'01.1" N., longitude 117°53'09.9" W.; thence to 33°36'01.1" N., longitude 117°53'32.7" W.; thence to 33°36'03.9 N., longitude 117°53'41.9" W.; returning to latitude 33°36'09.3" N., longitude 117°53'52.6" W.
(b) Area A-2. The entire water area within beginning at latitude 33°36′12.9" N., longitude 117°53'44.2" W; thence to
de 117°53'41.9" W.; returning to latitude 33°36'09.3" N., longitude 117°53'52.6" W.
(b) Area A-2. The entire water area within beginning at latitude 33°36′12.9" N., longitude 117°53'44.2" W; thence to latitude 33°36'14.2" N., longitude 117°53'44.3" W.; thence to latitude 33°36'14.2" N., longitude 117°53'20.6" W.; thence to latitude 33°36'10.8" N., longitude 117°53'20.5" W.; thence to latitude 33°36'12.7" N., longitude 117°53'29.9" W.; thence to latitude 33°36'12.7" N., longitude 117°53'35.4" W.; thence to latitude 33°36'12.9" N., longitude 117°53'37.0" W.; returning to latitude 33°36'12.9" N., longitude 117°53'44.2" W.
(c) Area A-3. The entire water area within beginning at latitude 33°36'22.7" N., longitude 117 54'12.6" W.; thence to latitude 33°36'24.9" N., longitude 117°54'12.6" W.; thence to latitude 33°36'26.2" N., longitude 117°54'11.3" W.; thence to latitude 33°36'18.7" N., longitude 117°54'00.5" W.; thence to latitude 33°36'16.2" N., longitude 117°54'02.9" W.; returning to latitude 33°36'22.7" N., longitude 117°54'12.6" W.
(d) Area A-4. The entire water area within beginning at latitude 33°36' 32.7" N., longitude 117°53'56.6" W.; thence to latitude 33°36'33.6" N., longitude 117°53'56.6" W.; thence to latitude 33°36'33.5" N., longitude 117°53'26.2" W.; thence to latitude 33°36'32.9" N., 22492 Federal Register/Vol. 77, No. 73/Monday, April 16, 2012/Rules and Regulations longitude 117°53'26.2" W.; thence to latitude 33°36'32.6" N., longitude 117°53'33.8" W.; thence to latitude 33°36'32.4" N., longitude 117°53'36.7" W.; thence to latitude 33°36'31.7" N., longitude 117°53'40.9" W.; thence to 33°36'31.7" N., longitude 117°53'46.3" W.; thence to latitude 33°36'32.6" N., longitude 117°53'50.9" W.; returning to latitude 33°36' 32.7" N., longitude 117°53'56.6" W.
ude 117°53'40.9" W.; thence to 33°36'31.7" N., longitude 117°53'46.3" W.; thence to latitude 33°36'32.6" N., longitude 117°53'50.9" W.; returning to latitude 33°36' 32.7" N., longitude 117°53'56.6" W.
(e) Area A-5. The entire water area within beginning at latitude 33°36'29.1" N., longitude 117°54'55.3" W.; thence to latitude 33°36'27.8" N., longitude 117°54'55.8" W.; thence to latitude 33°36'24.1" N., longitude 117°54'41.8" W.; thence to latitude 33°36'26.7" N., longitude 117°54'40.8" W.; thence to latitude 33°36'26.7" N., longitude 117°54'46.3" W.; returning to latitude 33°36'29.1" N., longitude 117°54'55.3" W.
(f) Area A-6. The entire water area within beginning at latitude 33°36'43.3" N., longitude 117°54'26.4" W.; thence to latitude 33°36'51.7" N., longitude 117°54'22.8" W.; thence to latitude 33°36'51.4" N., longitude 117°54'21.5" W.; thence to latitude 33°36'42.9" N., longitude 117°54'25.2" W.; returning to latitude 33°36'43.3" N., longitude 117°54'26.4" W.
(g) Area A-7. The entire water area within beginning at latitude 33°36'32.1" N., longitude 117°55'12.5" W.; thence to latitude 33°36'37.7" N., longitude 117°55'11.0" W.; thence to latitude 33°36'35.1" N., longitude 117°55'01.3" W.; thence to latitude 33°36'30.4" N., longitude 117°55'02.6" W.; thence to latitude 33°36'31.2" N., longitude 117°55'06.7" W.; returning to latitude 33°36'32.1" N., longitude 117°55'12.5" W.
(h) Area A-8. The entire water area within beginning at latitude 33°36'34.2" N., longitude 117°55'27.3" W.; thence to latitude 33°36'36.2" N., longitude 117°55'26.7" W.; thence to latitude 33°36'39.5" N., longitude 117°55'20.9" W.; thence to latitude 33°36'38.9" N., longitude 117°55'15.4" W.; thence to latitude 33°36'37.9" N., longitude 117°55'11.7" W.; thence to latitude
ce to latitude 33°36'39.5" N., longitude 117°55'20.9" W.; thence to latitude 33°36'38.9" N., longitude 117°55'15.4" W.; thence to latitude 33°36'37.9" N., longitude 117°55'11.7" W.; thence to latitude 33°36'32.1" N., longitude 117°55'13.3" W.; returning to latitude 33°36'34.2" N., longitude 117°55'27.3" W.
(i) Area A-9. The entire water area within beginning at latitude 33°36'53.5" N., longitude 117°55'28.2" W.; thence to latitude 33°36'54.0" N., longitude 117°55'27.0" W.; thence to latitude 33°36'43.4" N., longitude 117°55'20.4" W.; thence to latitude 33°36′42.9" N., longitude 117°55'21.6" W.; returning to latitude 33°36'53.5" N., longitude 117°55'28.2" W.
(j) Area A-10. The entire water area within beginning at latitude 33°36'07.4" N., longitude 117°53'19.2" W.; thence to latitude 33°36'14.2" N., longitude 117°53'19.4" W.; thence to latitude 33°36'14.2" N., longitude 117°53'06.9" W.; thence to latitude 33°36'08.1" N., longitude 117°53'04.9" W.; thence to latitude 33°36'06.5" N., longitude 117°53'08.9" W.; thence to latitude 33°36'06.5" N., longitude 117°53'16.3" W.; returning to latitude 33°36'07.4" N., longitude 117°53'19.2" W.
(k) Area A-11. The entire water area within beginning at latitude 33°36′04.7" N., longitude 117°53'01.9" W.; thence to latitude 33°36'06.1" N., longitude 117°53'00.5" W.; thence to latitude 33°36'06.2" N., longitude 117°52'59.0" W.; thence to latitude 33°35'59.4" N., longitude 117°52'51.1" W.; thence to latitude 33°35'57.5" N., longitude 117°52'50.9" W.; thence to latitude 33°36'01.9" N., longitude 117°52'57.3" W.; thence to latitude 33°36'03.0" N., longitude 117°53'00.4" W.; returning to latitude 33°36'04.7" N., longitude 117°53'01.9" W.
(1) Area A-12. The entire water area within beginning at latitude 33°36'27.9"
nce to latitude 33°36'03.0" N., longitude 117°53'00.4" W.; returning to latitude 33°36'04.7" N., longitude 117°53'01.9" W.
(1) Area A-12. The entire water area within beginning at latitude 33°36'27.9" N., longitude 117°54'40.4" W.; thence to latitude 33°36'23.9" N., longitude 117°54'41.8" W.; thence to latitude 33°36'20.8" N., longitude 117°54'29.9" W.; thence to latitude 33°36'28.5" N., longitude 117°54'20.2" W.; returning to latitude 33°36'27.9" N., longitude 117°54'40.4" W.
(m) Area B-1. The entire water area within beginning at latitude 33°36'35.1" N., longitude 117°54'28.8" W.; thence to latitude 33°36'32.1" N., longitude 117°54'22.1" W.; thence to latitude 33°36'30.6" N., longitude 117°54'22.8" W; thence to latitude 33°36'30.5" N., longitude 117°54′30.9" W.; returning to latitude 33°36'35.1" N., longitude 117°54'28.8" W.
Note to $110.95: These anchorage areas are reserved for recreational and other small craft. Local law, including the City of Newport Beach Municipal Code 17.25.020, may provide for fore and aft moorings for recreational and small craft of such size and alignment as permitted by the harbor master.
Dated: April 1, 2012.
J.R. Castillo, Rear Admiral, U.S. Coast Guard, District Eleven Commander.
[FR Doc. 2012-9006 Filed 4-13-12; 8:45 am] BILLING CODE 9110-04-P DEPARTMENT OF HOMELAND SECURITY Coast Guard 33 CFR Part 117 [Docket No. USCG-2012-0144] RIN 1625-AA09 Drawbridge Operation Regulations; Long Island, New York Inland Waterway from East Rockaway Inlet to Shinnecock Canal, NY AGENCY: Coast Guard, DHS.
ACTION: Interim rule with request for comments.
SUMMARY: The Coast Guard is temporarily changing the drawbridge operating regulations governing the operation of the Atlantic Beach Bridge, mile 0.4, across Reynolds Channel at
h request for comments.
SUMMARY: The Coast Guard is temporarily changing the drawbridge operating regulations governing the operation of the Atlantic Beach Bridge, mile 0.4, across Reynolds Channel at Lawrence, New York. The owner of the bridge has requested a temporary change to the regulations to facilitate major rehabilitation at the bridge. It is expected that this temporary change to the regulations will help facilitate the bridge rehabilitation. This interim rule is intended to better meet the present needs of navigation by allowing the bridge rehabilitation repairs to continue on schedule while providing the public the opportunity to submit comments.
DATES: This interim rule is effective from April 23, 2012 through May 15, 2013. Comments and related material must reach the Coast Guard on or before May 15, 2012.
ADDRESSES: You may submit comments identified by docket number USCG2012-0144 using any one of the following methods: (1) Federal eRulemaking Portal: http://www.regulations.gov.
(2) Fax: 202-493-2251.
(3) Mail: Docket Management Facility (M-30), U.S. Department of Transportation, West Building Ground Floor, Room W12-140, 1200 New Jersey Avenue SE., Washington, DC 205900001.
(4) Hand delivery: Same as mail address above, between 9 a.m. and 5 p.m., Monday through Friday, except Federal holidays. The telephone number is 202-366-9329.
To avoid duplication, please use only one of these four methods. See the "Public Participation and Request for Comments" portion of the SUPPLEMENTARY INFORMATION section below for instructions on submitting comments.
FOR FURTHER INFORMATION CONTACT: If you have questions on this interim rule, ENCLOSURE 5 East West Asset East Weight West Chain No.
Chain Weight East Chain Length Chain Type Length Weight C-011 3600 20'1";15'5/8"
INFORMATION CONTACT: If you have questions on this interim rule, ENCLOSURE 5 East West Asset East Weight West Chain No.
Chain Weight East Chain Length Chain Type Length Weight C-011 3600 20'1";15'5/8" CASTINGS 3500 20'1";15'5/8" West Weight Туре CASTINGS CAR Proposed Munis Size Coverag Dimensions Dimension Proposed Proposed Dimension Coverage (Sq M) Wing 65.00 36 1.67 C-012 3600 20'1";15'3/4" CAR WHEEL 3600 20'1";15'3/4" WHEEL 75.00 36 1.31 Savings Post (Sq M) 1.67 1.31 4 TRAIN 4 TRAIN C-013 4300 20'1";15'3/4" WHEELS 4000 20'1";15'3/4" WHEELS CAR 75.00 48 2.34 2.34 C-021 2000 20'3/4";15'1/2" CAR WHEEL CAR 2000 20'3/4";15'1/2" WHEEL CAR 50.00 24 0.58 0.58 C-022 2400 20'3/4";15'1/2" WHEELS & AXEL 2700 20'3/4";15'1/2" WHEELS & AXEL 50.00 24 0.58 0.58 C-023 C-024 1700 20'3/4";20'1/2" CAST IRON 3500 20'3/4";15'1/2" CASTINGS 2400 20'3/4";20'1/2" 3300 20'3/4";15'1/2" CAST IRON 45.00 CONCRETE 60.00 235 24 0.74 0.74 36 1.67 1.67 OLD IRON STEEL C-025 2500 20'3/4";15'1/2" WHEELS 2 R&R 2500 20'3/4";15'1/2" GEARS 40.00 24 0.58 0.58 C-026 3000 20'3/4";15'1/2" WHEEL W/AXLE 2 R&R WHEEL 2800 20'3/4";15'1/2" W/AXLE 60.00 36 1.31 1.31 3 LARGE 3 LARGE C-031 3000 20'1";15'5/8" C-032 C-033 2200 20'3/4";15'1/2" 3800 20'1";15'3/4" CAR WHEELS IRON FORK LIFT CAR 3000 20'1";15'5/8" 2200 20'3/4";15'1/2" 3800 20'1";15'3/4" WHEELS 2 IRON WEIGHTS 55.00 46 36 1.31 1.31 50.00 24 0.74 18 3 0.01 0.73 75.00 36 1.67 1.67 C-034 2200 20'3/4";15'1/2" IRON FORK LIFT 2 IRON C-035 C-036 1800 20'5/8";15'1/2" 3500 20'3/4";15'1/2" CASTINGS TRUCK 2200 20'3/4";15'1/2" 1900 20'5/8";15'1/2" 3300 20'3/4";15'1/2" WEIGHTS 50.00 24 0.74 18 3 0.01 0.73 40.00 24 0.74 0.74 CONCRETE 60.00 36 1.67 24 3 0.02 1.65 TRUCK C-041 2000 20'3/4";15'1/2" WHEELS C-042 C-043 1650 20'5/8";15'1/2" 2050 20'3/4";15'1/2" IRON CASTINGS
EIGHTS 50.00 24 0.74 18 3 0.01 0.73 40.00 24 0.74 0.74 CONCRETE 60.00 36 1.67 24 3 0.02 1.65 TRUCK C-041 2000 20'3/4";15'1/2" WHEELS C-042 C-043 1650 20'5/8";15'1/2" 2050 20'3/4";15'1/2" IRON CASTINGS 2000 20'3/4";15'1/2" 1600 20'5/8";15'1/2" IRON 2050 20'3/4";15'1/2" WHEELS 30.00 24 0.58 0.58 40.00 24 0.74 0.74 CASTINGS 45.00 24 0.74 0.74 RR C-044 2200 20'3/4";15'1/2" WHEELS/1 GEAR 2100 20'3/4";15'1/2" 2 GEAR WHEELS 45.00 24 0.58 0.58 East West Asset No.
Chain East Chain Length Weight East Weight West Chain Chain Type Length Weight West Weight Type Munis Size Coverag Dimensions Proposed Dimension Proposed Proposed (Sq M) Wing Dimension Post Coverage Savings (Sq M) C-045 1500 20'5/8"; 15'1/2" 2 ENGINES C-046 2000 20'5/8";15'1/2" 3 ENGINES STEEL 1200 20'5/8"; 15'1/2" 2000 20'5/8";15'1/2" 2 ENGINES 35.00 C-051 2500 20'3/4";15'1/2" C-052 2000 20'5/8";15'1/2" PUMP IRON C-053 1200 20'5/8";15'1/2" C-054 1500 20'5/8";15'1/2" C-055 2000 20'3/4";15'1/2" WHEELS CASTINGS MAN HOLE CASTINGS 2300 20'3/4";15'1/2" 1700 20'5/8";15'1/2" 1300 20'5/8";15'1/2" 2200 20'5/8";15'1/2" 3 ENGINES 40.00 STEEL ENGINE IRON 22 24 0.74 0.74 24 0.74 0.74 45.00 40.00 C-056 2200 20'3/4";15'1/2" 2200 20'3/4";15'1/2" 2000 20'3/4";15'1/2" WHEELS CASTINGS 40.00 TRACTOR WHEELS 35.00 2222 24 0.74 0.74 24 0.74 0.74 24 0.58 0.58 24 0.74 0.74 50.00 45.00 22 24 0.58 0.58 24 0.74 0.74 CAR CAR C-061 2000 20'3/4";20'1/2" WHEELS 2600 20'3/4";20'1/2" WHEELS 40.00 24 0.58 0.58 C-062 1400 20'5/8";15'1/2" CASTING C-063 2000 20'5/8";15'1/2" 2 WHEELS 1400 20'5/8";15'1/2" CASTING 2000 20'5/8";15'1/2" 45.00 24 0.74 0.74 CONCRETE 40.00 24 0.58 0.58 C-064 1500 20'5/8";15'1/2" CASTING TRUCK 1600 20'5/8";15'1/2" CASTING STEEL 40.00 24 0.74 0.74 C-065 2000 20'3/4";15'1/2" WHEELS 2000 20'3/4";15'1/2" WHEELS 50.00 24 0.58 0.58
CRETE 40.00 24 0.58 0.58 C-064 1500 20'5/8";15'1/2" CASTING TRUCK 1600 20'5/8";15'1/2" CASTING STEEL 40.00 24 0.74 0.74 C-065 2000 20'3/4";15'1/2" WHEELS 2000 20'3/4";15'1/2" WHEELS 50.00 24 0.58 0.58 C-066 2300 20'3/4";15'1/2" METAL 2200 20'3/4";15'1/2" 2 TRAIN WHEELS 45.00 24 0.74 0.74 C-071 C-072 C-073 2200 20'3/4";15'1/2" 2000 20'3/4";15'1/2" 2000 20'3/4";15'1/2" CASTING 2200 20'3/4";15'1/2" CASTING 2200 20'3/4";15'1/2" 50.00 45.00 22 24 0.74 0.74 24 0.74 0.74 SHAFTING 2300 20'3/4";15'1/2" C-074 2000 20'3/4";15'1/2" CASTINGS/ IRON 2100 20'3/4";15'1/2" SHAFTING CASTINGS/ IRON 1 LG.
45.00 24 0.74 0.74 50.00 24 0.74 0.74 C-075 2000 20'3/4";15'1/2" C-076 2500 20'3/4";15'1/2" C-081 2000 20'5/8";15'1/2" CASTINGS ENGINE CASTINGS 2000 20'3/4";15'1/2" 2500 20'3/4";15'1/2" 2800 20'5/8";15'1/2" C-082 2100 20'3/4";15'1/2" C-083 1600 20'5/8";15'1/2" GEAR BOXES OIL WELL CASTINGS TRAIN WHEEL CASTINGS CASTINGS 40.00 GEAR 45.00 24 24 0.74 0.74 55.00 24 0.74 0.74 24 0.74 0.74 2000 20'3/4";15'1/2" 1600 20'5/8";15'1/2" BOXES OIL WELL CASTINGS 50.00 24 0.74 0.74 40.00 24 24 0.74 0.74 East West Asset Chain East Chain Length No.
East Weight Type West Chain Chain Length Weight Weight West Weight Туре Munis Size Coverag Dimensions Proposed Dimension Proposed Proposed Dimension Coverage Savings (Sq M) Wing Post (Sq M) C-084 2000 20'3/4";15'1/2" 2500 20'3/4";15'1/2" 50.00 24 0.74 0.74 C-085 1600 20'5/8";15'1/2" 1300 20'5/8";15'1/2" 35.00 24 0.74 0.74 C-086 2000 20'3/4";15'1/2" 3 RAILS 2000 20'3/4";15'1/2" 3 RAILS 45.00 24 0.74 0.74 CAR C-087 C-091 1250 20'5/8";15'1/2" 2600 20'5/8;151/2" CAR WHEEL IRON 1500 20'5/8";15'1/2" WHEEL 1500 20'5/8;15""1/2" IRON 40.00 24 0.58 0.58 40.00 24 0.74 0.74 CAR C-092 1600 20'5/8";15'1/2" CAR WHEEL 1600 20'5/8";15'1/2" WHEEL 40.00 24 0.58 0.58 C-093
" CAR WHEEL IRON 1500 20'5/8";15'1/2" WHEEL 1500 20'5/8;15""1/2" IRON 40.00 24 0.58 0.58 40.00 24 0.74 0.74 CAR C-092 1600 20'5/8";15'1/2" CAR WHEEL 1600 20'5/8";15'1/2" WHEEL 40.00 24 0.58 0.58 C-093 1600 20'5/8";15'1/2" 2 ENGINE BLOCKS CAR 2 ENGINE 1600 20'5/8";15'1/2" BLOCKS 40.00 24 0.74 0.74 CAR C-094 1600 20'5/8";15'1/2" C-095 2500 20'3/4";15'1/2" WHEELS STEEL 1600 20'5/8";15'1/2" 2600 20'3/4";15'1/2" STEEL WHEELS 40.00 24 0.58 0.58 55.00 24 0.74 0.74 New 1 0.01 New 2 0.01 New 3 New 4 New 5 New 6 New 7 0.01 0.01 0.01 0.01 0.01 Proposed Total Coverage Existing Total Coverage (sq m)| 42.85 (sq m) 39.81 3.04 Existing Average| 0.84 Proposed Average 0.69 ENCLOSURE 6 CITY OF NEWPORT CALIFORNIA BEACH December 7, 2023 RE: Alternative Configurations To Whom It May Concern, CITY OF NEWPORT BEACH Harbor Department 1600 W. Balboa Blvd.
Newport Beach, California 92663 949-270-8159 Newportharbor.org I am writing to provide an overview of the extensive and detailed process that led to the current application for the Coastal Development Permit. This process, spanning over three years, included numerous meetings where the project plans and specifications underwent significant revisions and refinements, largely influenced by public feedback.
Initially, the equipment or tackle proposed for use, as detailed in the attached Noble Consultants, Inc.
report dated September 20, 2022, involved a shared common anchor for two moorings and the use of an auger or helical soil screw-in anchor. However, this concept evolved following input from public and stakeholder consultations. Ultimately, the use of the helical, screw-in anchor and shared anchors or weights for moorings were discarded.
However, this concept evolved following input from public and stakeholder consultations. Ultimately, the use of the helical, screw-in anchor and shared anchors or weights for moorings were discarded.
Subsequently, a modified design is presented in the attached illustration 221102, highlighting the utilization of adjacent existing anchor weights. This approach aimed at cost-saving and provided flexibility in spacing, confirmed by testing outcomes.
Further refinements are evident in the latest mooring illustration 230308, resulting from continued public and stakeholder feedback. This current recommendation involves a central anchor weight spacing of 20 feet, with each anchor having 24 feet of rode and a 10-foot bridle from buoy to cleat. This configuration ensures an average separation of 20 to 30 feet between boats at the shared anchor point, varying with tide and wind conditions.
While conservation buoys were part of the original concept and remain in the current proposal, they are not mandatory for the project. Their effectiveness and safety will continue to be assessed during the project's progression.
The reorganization of moorings within the C field was meticulously planned in collaboration with the City of Newport Beach GIS team, focusing on engineering precision and optimal space use. This planning involved multiple revisions to ensure the most efficient distribution of moorings across different sizes permitted in the C field. The size distribution is summarized in this table: Harbor Department Mooring Size Count 30 1 35 3 40 16 45 11 50 10 55 3 60 3 65 1 70 0 75 3 80 0 85 0 90 Total 0 51 This layout accounts for the varied lengths of the moorings and proposes a new arrangement, as
epartment Mooring Size Count 30 1 35 3 40 16 45 11 50 10 55 3 60 3 65 1 70 0 75 3 80 0 85 0 90 Total 0 51 This layout accounts for the varied lengths of the moorings and proposes a new arrangement, as depicted in the "Proposed C Field Mooring Arrangement." Indicated in the arrangement are the lengths of different moorings, improved row spacing, and areas of new open water.
Sincerely, Paul Blank Paul Blank City of Newport Beach Harbormaster Harbor Department City of Newport Beach [email protected] 949-270-8159 ATTACHMENTS Mooring Anchor Calculations and Report 9-20-2022 Mooring Illustration 221102 Mooring illustration 230308 Proposed C Field Mooring Arrangement O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 (City of Newport Beach, Newport Beach) Date Tue 1/28/2025 9:22 AM To Sent: Tuesday, January 28, 2025 7:25 AM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 (City of Newport Beach, Newport Beach) Dear Honorable Chair Cummings and Coastal Commissioners, The Newport Mooring Association (NMA) is in the process of reviewing and analyzing the staff report for CDP #5-23-0753, which was posted two days ago. Please find our initial concerns below. We plan to send a more detailed letter of concern by Friday, January 31.
Thank you, The Newport Mooring Association NMA Opposition to Newport Beach's Dangerous Proposal to Realign and Densify Boat Moorings Dangerous Access is No Access -
r of concern by Friday, January 31.
Thank you, The Newport Mooring Association NMA Opposition to Newport Beach's Dangerous Proposal to Realign and Densify Boat Moorings Dangerous Access is No Access The NMA has conducted its own safety tests and found that mooring boats closer together is extremely dangerous and will significantly reduce access to the tidelands for boaters.
1. Extremely Dangerous - The NMA can present evidence that if boat moorings are put closer together, (proposed to be 20 feet to 30 feet) regardless of the intensity of normal daily tidal currents and winds, there simply will not be enough time for boaters who are either leaving or returning to a mooring, to release or attach their mooring lines and steer their boat out of harm's way before their boat drifts into an adjacent moored boat. Boaters will then have to wait hours or days for access to the tidelands and to the ocean. And during that period, what location will the City provide for them to safely dock until conditions allow them to return to their moorings?
2. Significant Reduction in Access. The proposed new mooring configuration will result in a significant reduction in access to the harbor and ocean because of (a) the increased difficulty/danger of accessing and departing moorings, (b) the reasonable fear of crashing into adjacent boats, and (c) having to wait hours or days until the tidal currents and winds change strength or direction.
3. Significant Reduction of Access for Older Boaters, Individual Boaters, and Boaters with Disabilities. The major reduction in access is even more critical for people with disabilities and for older boaters because of the increase in time needed to return to the
l Boaters, and Boaters with Disabilities. The major reduction in access is even more critical for people with disabilities and for older boaters because of the increase in time needed to return to the steering station after releasing the mooring lines when departing a mooring and the effort and time required to acquire and connect the spreader line when returning to a mooring.
The NMA asks the following: A. The Agenda Item Should Be Continued. A continuance will allow the NMA time to fully present its findings to both Staff and to the Commission.
B. A Comprehensive, Independent, Safety Study Should Be Obtained. Alternatively, the dangerous conditions identified in the proposal should be reviewed and studied by truly independent experts, including safety and human factors experts. The study should focus on the potential risks and increased dangers for boaters when getting on and off moorings in different common wind and tidal current conditions for people of different abilities, including older boaters and boaters with disabilities.
The study should be truly independent and commissioned by the Coastal Commission. Both the City and the NMA should be allowed to present evidence and information as the study and the method of testing are implemented.
In the view of the NMA (whose members are the ones who will be dealing with the increased risk and the significant reduced window of times when moorings can be used if boats are closer together), the key to these studies is the amount of time and effort required for the boater to release and/or attach mooring lines, and return to the steering station as the boat is being moved away from the mooring by the currents and winds. The NMA has done studies and found
for the boater to release and/or attach mooring lines, and return to the steering station as the boat is being moved away from the mooring by the currents and winds. The NMA has done studies and found a significant risk of damage to boats and injury to boaters when time to acquire a mooring is limited.
It should also be noted that when returning a boat to a mooring it is not always possible to predict the exact state of tidal currents and winds upon returning from outside the harbor.
While the NMA has conducted its own studies, formal studies of these dangers have never been done, despite the repeated requests by the NMA for more than a year. Such formal studies need to be conducted in order to test not only the holding power of anchor systems, but to also study the increased danger of getting on and off moorings for persons of different abilities under common tidal current and sea conditions that are unique to Newport Harbor.
It is the view of the NMA that such studies should be done before, and not after, disaster occurs.
Respectfully, The Newport Mooring Association O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Tue 1/28/2025 1:11 PM Sent: Tuesday, January 28, 2025 11:59 AM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which
m Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single
rnative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve lowcost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency.
This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Edward W. O'Connell Jr.
Mooring # C31 Edward W. O'Connell Jr.
Attorney at Law California Bar # 313780 Cell 951-464-9619 The content of this email is confidential and intended for the recipient specified in message only.
It is strictly forbidden to share any part of this message with any third party, without a written consent of the sender. If you received this message by mistake, please reply to this message and follow with its deletion, so that we can ensure such a mistake does not occur in the future.
O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753
ge and follow with its deletion, so that we can ensure such a mistake does not occur in the future.
O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Thu 1/30/2025 11:33 AM Sent: Thursday, January 30, 2025 11:27 AM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs.
Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in
onsidering public safety needs.
Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Brian H. Ouzounian January 31, 2025
nds and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Brian H. Ouzounian January 31, 2025 W16b Agenda Item Mooring Field C Newport Beach CDP Application No: 5-23-0753 Purpose: To express my opposition to this application From: Jim Palmer, mooring permit holder, Newport Beach, CA Re: Opposition to Mooring Field Reconfiguration [CDP #5-23-0753] I disagree with Staff's recommendation for CDP 5-23-0753 Mooring Reconfiguration and respectfully request that you vote no and deny the CDP. The reconfiguration is unsafe for mooring permit holders and also unsafe for other mooring field stakeholders.
1) Why does Staff support the views of a few dozen curated opinions over the hundreds of mariners that oppose the reconfiguration?
Despite the 100-year history of the mooring fields, the City provides no relevant data to support safety issues, offering only a few dozen curated opinions. In contrast, the Newport Mooring Association (NMA) has provided extensive data and represents hundreds of members and others who collectively possess tens of thousands of years of boating experience, who oppose the reconfiguration because it will reduce the safety of the mooring fields. Why does Staff support the views of a few dozen curated opinions over the hundreds of mariners that oppose the reconfiguration?
reconfiguration because it will reduce the safety of the mooring fields. Why does Staff support the views of a few dozen curated opinions over the hundreds of mariners that oppose the reconfiguration?
2) Why does Staff support the reconfiguration despite it making the mooring field stakeholders beyond mooring permit holders?
The reduction in safety is not limited to mooring permit holders. It also makes the fields less safe for other stakeholders, including swimmers, kayakers, paddlers, individuals fishing from small boats, and the many visitors who rent the popular electric boats by the hour to enjoy time on the bay. The Staff Report makes no mention of the multiple new safety hazards, both on the surface and submerged, introduced by the reconfiguration that impacts these additional stakeholders.
Please vote no and deny the CDP application Sincerely, Jim Palmer Mooring Permit Holder, City of Newport Beach January 31, 2025 Sent via e-mail: W16b Agenda Item Mooring Field C Newport Beach CDP Application No: 5-23-0753 Purpose: To express my opposition to this application From: Jim Palmer, mooring permit holder, Newport Beach, CA Re: Opposition to Mooring Field Reconfiguration [CDP #5-23-0753] I would like to correct inaccuracies in the Staff Report, state that I disagree with Staff's recommendation and respectfully request that you vote no and deny the CDP. If the Commission decides to vote yes and approve the CDP, I ask they do so with an additional condition.
sagree with Staff's recommendation and respectfully request that you vote no and deny the CDP. If the Commission decides to vote yes and approve the CDP, I ask they do so with an additional condition.
1) Inaccuracies in the Staff Report: a) The Staff Report incorrectly states there are approximately 800 offshore moorings in fields A-J. It is accurate to state are about 527 offshore moorings for public permit holders in mooring fields A-J and about 152 offshore moorings in two mooring fields exclusively for the members of two private yacht clubs b) The Staff Report states reconfiguration will create about two acres of open water space and a 36% reduction in the mooring field C footprint. The Staff Report fails to note the same mooring field reconfiguration and tackle specifications for the two private yacht club mooring fields would create over 18 acres of open water space and a 54% reduction in the private yacht club moorings footprint c) The Staff Report fails to note the private yacht club moorings are categorically excluded from any reconfiguration proposal 2) I respectfully request the Commission to vote no and deny the mooring field reconfiguration and tackle specifications due to the unequal, unfair and unjust treatment of public mooring field permittees compared to the preferential treatment of the private offshore moorings designated exclusively for yacht clubs.
3) Alternatively, if the Commission votes to approve the CDP, in order to ensure equal, fair and just treatment of both public and private offshore mooring users, I respectively ask the Commission to add a condition that the 152 moorings in two private yacht club mooring fields be subject to the same/similar reconfiguration and
d private offshore mooring users, I respectively ask the Commission to add a condition that the 152 moorings in two private yacht club mooring fields be subject to the same/similar reconfiguration and tackle specifications within three (3) years following the reconfiguration of public mooring field C.
Thank you for your consideration, Jim Palmer Mooring Permit Holder, City of Newport Beach O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 2:39 PM To Sent: Monday, January 27, 2025 2:34 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California
occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
nd consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, William R. and Lisa F. Pickett J77 O Outlook FW: Newport Beach Moorings Date Mon 1/27/2025 12:38 PM To Sent: Monday, January 27, 2025 9:46 AM Subject: Newport Beach Moorings Dear Coastal Commission, I want to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor.
Please consider the following points: 1. Safety The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders
rectly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal
per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Bret Pool Newport Harbor Mooring A-271 714.292.6484 Dear Coastal Commission Staff, For safety sake, please listen to those that regularly use these Mooring Fields and dismiss the Commissions/City's request.
My father and I have held a mooring permit in C Field in excess of 40 years. We have been navigating these waters for over 40 years. We have both held US Coast Guard Captains licenses and are excellent at operating vessels. Due to concerns over this unsafe plan and the extremely excessive Permit Fees I have been forced to sell my boat and mooring, so I no longer have a dog in this fight. I just don't want to see anyone hurt or killed.
The biggest problem with this double mooring system is a LACK of SAFETY. With the currents and winds in Newport Harbor docking and departing a mooring with this configuration is DANGEROUS.
When approaching a mooring the most common error, which is almost always caused by current, wind or both, is overshooting the forward buoy. With another boat within 20 feet or less of the buoy, again depending on the elements, and the inability to stop a boat immediately accidents WILL occur. This will not only cause property damage but personnel injury and Legal Liability.
I believe one of the Harbor Commissions goals is to make it navigable for their and their friends Duffy's.
The mooring fields are non-navigable to protect vessels entering and leaving moorings. If you make it appear to be more navigable boaters, who lack the knowledge that the fields are non-navigable, will
he mooring fields are non-navigable to protect vessels entering and leaving moorings. If you make it appear to be more navigable boaters, who lack the knowledge that the fields are non-navigable, will present a hazard to vessels using the moorings. If I depart my mooring and now need to clear the buoy and another boat off my bow a boat entering the fields at either end and traveling 5 MPH will create a collision scenario. The double mooring configuration will block the safe vision of the channel increasing the likelihood of a collision.
Reduction in Safe Access: The existing safely spaced mooring field arrangement has worked well for approximately 100 years. Pushing mooring rows closer together will make the moorings more difficult to use and even the most able bodied and experienced boaters will have difficulty accessing the moorings given the tidal currents and wind influences in Newport Harbor.
Reduction in Safe Access: The existing mooring field arrangement allows for an equal amount of safety space (Fore and Aft), of a mooring location to allow for safe access and safe departure in any direction.
Pushing mooring rows together will eliminate access and exit routes, making mooring access much more difficult and much less safe.
Reduction in Safe Access: The existing mooring fields are federally "Designated Special Anchorages" where general navigation is discouraged for the safety of mooring users. The proposal to widen fairways to encourage increased large boat traffic through anchorages will increase the risk of collision.
Reduction in Safe Access: The existing mooring fields provide a safe area of tidelands historically used by kayakers, swimmers and paddle boarders. Widening fairways to encourage more boat traffic in
Reduction in Safe Access: The existing mooring fields provide a safe area of tidelands historically used by kayakers, swimmers and paddle boarders. Widening fairways to encourage more boat traffic in mooring fields will be unsafe and negatively impact the existing safe enjoyment of human powered craft in the mooring fields as there will be an increased risk of collision.
Reduction in Safe Access: The existing single row mooring configuration allows for safety personnel to access a boat (or fight a boat fire) from any direction. Pushing mooring rows together will reduce access for safety personnel.
Lack of details: The application does not include any evidence that pushing mooring rows together will be safe for existing mooring holders to access the moorings.
Lack of details: The application does not include appropriate pilot test safety procedures or testing criteria. Which boats will be volunteered for the safety test? Who will pay for damages when boats collide and boaters get hurt and the inevitable LAW SUITS?
Please reject this Coastal Development Permit application as it fails to include details regarding impaired and restricted access, safety, and testing.
Sincerely Don Potenza MARINE ACCIDENT INVESTIGATIONS AND CONSULTING Doug Powell, Consultant 2102 Canyon Creek Dr, Stockton, CA 95207 Phone: 209-603-0836 Email: [email protected] RE: City of Newport Harbor Mooring Improvement Plan On January 17, I was contacted by Newport Beach Harbormaster Paul Blank for “independent review" in the matter above. I was asked to provide my opinions of the existing moorage field and review the new "double row configuration" The area of the current field and proposed moorage field are in Inland Waters
tter above. I was asked to provide my opinions of the existing moorage field and review the new "double row configuration" The area of the current field and proposed moorage field are in Inland Waters of the State. Navigational Laws including Inland Navigation Rules of the Road, Harbors and Navigations Code, and local ordinances apply.
I will express my opinions regarding improved safety, existing dangers and recommendations.
I will share my views on safety improvements, current risks, and suggestions.
This report is based on my physical inspection of the current mooring field, documents that I received including Noble Consultants, existing and proposed moorage fields, water conditions including mean low water depths, title range and ocean surge considered as well as my education, training and experience in vessel operations, accident investigation and reconstruction for the past 24 years.
I reserve my opportunity to refer to it and any future information and materials supplied to me in arriving at my opinions.
PRELIMINARY OPINIONS AND CONCLUSIONS After a detailed review of the proposed project objectives and layout, versus the existing mooring field will greatly allow vessel operators transiting the mooring field successfully by improving "lookout" for both operators navigating the area and operators mooring their vessels. The current mooring field specifically mixing of several sizing and types of vessels is cumbersome to operators visibility.
Look-out Rule 5 Every vessel shall at all times maintain a proper look-out by sight and hearing as well as by all available means appropriate in the prevailing circumstances and conditions so as to make a full appraisal of the situation and of the risk of collision.
look-out by sight and hearing as well as by all available means appropriate in the prevailing circumstances and conditions so as to make a full appraisal of the situation and of the risk of collision.
Grouping vessels by size will enable operators to observe and respond more consistently to various conditions, such as wind, current, and visibility.
Grouping vessels by size enables operators to respond more consistently to various conditions such as wind, current, and especially visibility.
Operators by law have certain duties as vessel operators to adhere to good seamanship. The Newport Harbor paid particular attention to the improvement plan and recommendations will enhance navigational safety. Particularly the distance between vessels in each row (centerline to centerline) Clearly defined 1 rows of mooring, clearly defined fairways between rows improving "lookout” and navigational operation for all vessels transiting through or using the mooring field.
After a detailed review of the proposed project, application and concerns addressed, I believe the new moorage plan will greatly improve the safety of all vessels, additionally providing more space. Based on the current information provided I concur with the proposed mooring field plan. Upon favorable consideration of this project, I would be willing to work with the City of Newport Beach on a program to assess the safety of navigation of the current conditions and how those conditions will change with the implementation of the proposed arrangement.
This opinion may be modified with the receipt of additional relevant information regarding this review.
Respectfully Submitted, DOUGLAS K. POWELL MARINE SERVICES CONSULTING Qualifications
arrangement.
This opinion may be modified with the receipt of additional relevant information regarding this review.
Respectfully Submitted, DOUGLAS K. POWELL MARINE SERVICES CONSULTING Qualifications I Doug Powell am a retired lieutenant with the Contra Costa County Sheriff's Office, Martinez, CA. I served as a deputy, sergeant, and Lieutenant in the Marine Patrol Unit for over 20 years. I logged more than 8,000 hours of time on the water patrolling and enforcing boating laws of California and investigated, reviewed and or approved over 500 boating and PWC accidents.
I am under contract with The California Division of Boating and Waterways to proctor and issue Captain Licenses under the "For Hire Boating License Program" in all inland lakes of California.
I am an instructor for the CA Department of Boating & Waterways. I Instruct Basic Boat Accident Investigation, Boating under the Influence and Inland Boating Skills and Operations. I have observed staged boating and PWC collisions between the speeds of 5 MPH to 55 MPH. I hold a "Public Safety" PADI certification, in evidence recovery and currently a public safety diver for Contra Costa County.
I am the Co-chair for the California State Sheriffs Association Boating and Watercraft Safety Committee and The Legislative Chair for The California Boating Safety Officer Association. I have testified in court on boating cases and in the California State Assembly / Senate regarding new boating laws for the State of California.
I hold a U.S.C.G. Master license not more than 100 tons on near coastal waters with a towing assistance endorsement issued by the United States Coast Guard for the last 15 years.
PUBLICATIONS: I have authored and co-authored CA State Sheriff's magazine boating articles and "a legal Point of View"
stance endorsement issued by the United States Coast Guard for the last 15 years.
PUBLICATIONS: I have authored and co-authored CA State Sheriff's magazine boating articles and "a legal Point of View" for the Beacon Magazine, training manuals used in the instruction of law enforcement in California to include Boating Skills and Operations Manual- State of CA Department of Boating & Waterways 2010 California State Sheriff's Association State Marine Training Manual.2010 Boating Education and Training Courses 1999 1999 2000 2000 2000 Waterways 16 hrs. Boating Intoxication and Enforcement Course 08 hrs. Boat Accident Injuries and Boating Under the Influence Course 24 hrs. CBSOA Training Seminar Underwater Investigations 24 hrs. CBSOA Training Seminar Crime Scene Investigations 08 hrs. Basic Boating Safety Course California Department of Boating and 2 2000 2000 2000 2001 2001 2001 2001 2002 2002 2002 Course 2003 2004 2004 2004 2009 2009 2011 2013 2015 2016 2017 2017 2018 2014 - Present 40 hrs. Boating Safety and Enforcement Course 40 hrs. Coastal Piloting and Navigation for Boating Course 40 hrs. Accident Reconstruction for Boating Course 24 hrs. CBSOA Training Seminar Waterborne Mass Casualties/ PWC Rescue 40 hrs. Rescue Boat Handling Course 40 hrs. Boating Skills and Operations Course 40 hrs. Underwater Investigations Course 24 hrs. CBSOA Training Seminar Surf Operations 24 hrs. International Assoc. of Marine Investigators Training Seminar 40 hrs. Advanced Boating Accident Investigations and Analysis (NASBLA) 40 hrs. Marine Fires Course 84 hrs. Maritime Institute Master Near Costal 100 gross Tons Course 24 hrs. Marine Investigations Training Seminar 24 hrs. CBSOA Training Seminar Evidence Recovery, Accident Reporting 40 hrs. Personal Watercraft for Law Enforcement Course
Costal 100 gross Tons Course 24 hrs. Marine Investigations Training Seminar 24 hrs. CBSOA Training Seminar Evidence Recovery, Accident Reporting 40 hrs. Personal Watercraft for Law Enforcement Course 32 hrs. Professional Development in Boating Safety and Development Course 40 hrs. Marine Enforcement Officer Course 24 hrs. Accident Investigation and Stand up Paddle 24 hrs. Rescue Team and Dive Operations 08 hrs. Boating Under the Influence (NASBLA) Course 40 hrs. Instructor Certification Course 48 hrs. Vessel Boarding, BUI, Cold Water Emersion 40 hrs. NASBLA Basic Accident Investigation class audit Marine Accident Investigation, Stockton, CA Consultant / Expert Witness- Self Employed Boat and PWC accident investigation and reconstruction Vessel collision analysis Evaluation of vessel, human and environmental factors Court preparation and expert witness testimony Consult with attorneys on marine accidents and safety matters Assessment of culpability and liability 2014 - Present CA Department of Boating & Waterways, Sacramento, CA Instructor / Consultant/ Per-Diem Deputy Sheriff Contra Costa Sheriff/ Department of Boating and Waterways Contractor Instruct three 40 hour P.O.S.T. certified classes annually on Boating Accident Investigation Instruct three 40 hour P.O.S.T. certified class annually on Basic Boating for Patrol Officers 1999 - 2014 Contra Costa County Sheriff's Office, Martinez, CA Deputy Sheriff, Sergeant and Lieutenant of the Marine Services Unit Duties included patrolling over two hundred miles of waterway Enforced local, State and Federal laws and regulations Primary duty was marine investigation and reconstruction of boating accidents Court testimony Duties included scheduling, budgeting and grant writing.
1991 - 1999
tate and Federal laws and regulations Primary duty was marine investigation and reconstruction of boating accidents Court testimony Duties included scheduling, budgeting and grant writing.
1991 - 1999 Contra Costa County Sheriff's Office, Martinez, CA Deputy Sheriff Assigned to Detention Division, Town of Danville, Patrol Division, Administration Division three years and Marine Patrol for nine years Professional AffiliationsCalifornia Boating Safety Officers Association 1999 – Present Legislative Chair-California Boating Officer Association.
Co-Chair California State Sheriff's Boating and Watercraft Safety Committee.
Committees Assisted in updating a forty-hour course on Basic Boating Enforcement for the California Department of Boating and Waterways in 1999. I taught this class from 2005 to Current.
Assisted revising the California Division of Boating and Waterways Vessel Accident Report Manual in 2000 Assisted in developing a curriculum for a forty-hour Advanced Boating Accident Reconstruction class, Inland Boat Officers Class These P.O.S.T. certified courses are offered by the California Division of Boating and Waterways.
Technical Advisory Committee (TAG) for California's New Boater education requirement for The State of California.
2017 Assisted in the development and curriculum for the new “seated battery" field sobriety tests and Boating Under the Influence Class for The Division of Boating and Waterways.
Awards and Certificattes 2004 2004 2005 2005 Masters Training Program. Department of Boating and Waterways.
Certificate Boating Safety Education.
Life Saving Award for efforts to reduce boating fatalities. Mothers against D.D.
U.S. Merchant Marine Officer License 2009 Boating Officer of the Year. California Boating Safety Officers Assoc.
2017 2017
e Saving Award for efforts to reduce boating fatalities. Mothers against D.D.
U.S. Merchant Marine Officer License 2009 Boating Officer of the Year. California Boating Safety Officers Assoc.
2017 2017 Wes Dodd Boating Safety Officer of the Year. (CBSOA) Boating Education Certificate 2018 (NASBLA) Butch Potts Officer of the Year for California for DBW.
Case Work Jan 21, 2017 RE: Palla v. LM Sports, INC dba Action Watersports United States District Court, Eastern District Case # 2:16-CV-02865-JAM-EFB Dena S. Aghabeg COGSWELL NAKAZAWA & CHANG, LLP 444 W. Ocean Blvd. Suite 1410 Long Beach, Ca 90802 Case # 16-6580 March 6, 2017 - Provided Deposition, settled RE: Iwamoto v BNSF Case NO. 39-2014-00315313-CU-PP-STK Stockton CA Bass Boat Fatal deposition Flesher Schaff & Schroeder 2202 Plaza Drive Rocklin, CA 95765 June 26, 2016 RE: Mejia v Union Pacific United States District Court Eastern District Court of California Case #2:17-CV-01037-KJM-AC Van Blois & Associates 7677 Oakport Street, Suite 565 Oakland Ca, 94621 May 19, 2016 RE: Flores Vessel Accident Alan Ridenour Arnold and Arnold, Inc.
2329 India Street San Diego, CA 92101 619-233-1096 Investigation Only RE: Muir Trail Ranch Vessel Inspection June 15, 2016 Eilert Insurance Group 16450 Monterey Rd Morgan Hill CA 95037 Vessel Inspection only RE: People vs Conner Ramero Riverside District Attorney Riverside County Superior Court Expert Consultation/ Vessel Inspection March 2018 -Pending LQ RE: Rockey v Cantor Enterprises Inc.
Paddle Incident Pending in the U.S. District Court for the Southern District of California, Case No. 3:17-CV-01281-CABBLM Vessel Inspection/ Provided report Gibson Robb & Lindh LLP 201 Mission Street, Suite 2700 San Francisco CA 94105 (415)348-6000 RE: Lind Marine v King
ict of California, Case No. 3:17-CV-01281-CABBLM Vessel Inspection/ Provided report Gibson Robb & Lindh LLP 201 Mission Street, Suite 2700 San Francisco CA 94105 (415)348-6000 RE: Lind Marine v King COMPANY, LLC, as owner, and LIND MARINE, INC., as bareboat charterer of Vessel Sinking Case #3:16-CV-01223VG Report, case settled RE: Re: MALORY v BAHLER September 6th, 2017 Propeller Accident Investigation and Deposition question provided BERSCHLER ASSOCIATES Arnold I. Berschler 22 Battery Street, Suite 888 San Francisco, CA 94111 Telephone (415) 398 1414 RE: William Osegueda v. Mandy Lorraine Doumit PWC fatal Inspection and Report Case Settled June 13th, 2018 Dena S. Aghabeg COGSWELL NAKAZAWA & CHANG, LLP 444 W. Ocean Blvd. Suite 1410 Long Beach, CA 90802 O Outlook FW: Trump was right. Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 12:39 PM Sent: Monday, January 27, 2025 9:12 AM Subject: Trump was right. Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 523-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space
Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve lowcost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already
ost-effective and realistic solutions that prioritize safety and preserve lowcost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency.
This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Randall Sent from AOL on Android O Outlook FW: Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before mak Date Mon 1/27/2025 12:37 PM Sent: Monday, January 27, 2025 10:52 AM Subject: Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before maki...
Carol Rinderknecht [email protected] O Outlook
, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before maki...
Carol Rinderknecht [email protected] O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 12:36 PM To Sent: Monday, January 27, 2025 12:08 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in
onsidering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Philip Rodas 714-801-7445 California Coastal Commission
thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Philip Rodas 714-801-7445 California Coastal Commission Long Beach Civic Center City Council Chambers 411 West Ocean Blvd Long Beach, CA. 90802 Subject: Support for Agenda Item 16b - Mooring Field Reconfiguration at Newport Harbor Dear Members of the California Coastal Commission, My name is Steve Scully, and I am currently a member of the Newport Beach Harbor Commission, and I served on the subcommittee to study the Mooring Field Reconfiguration. I have been a resident of Newport Beach for 32 years and an active boater for over 60 years. As a current boat owner who has navigated Newport Harbor for the past 30 years, I am writing to express my strong support for Agenda Item 16b regarding the reconfiguration of the offshore mooring fields in Newport Harbor.
Need for Mooring Field Reconfiguration The current state of the offshore mooring fields in Newport Harbor is disorganized, reducing navigability and creating a hazardous environment for boaters. Historically, mooring placements were managed by the Orange County Sheriff's Department (OCSD), which approved mooring extensions on an ad-hoc basis without any formal policy or guidelines. This resulted in inefficient water space utilization and dangerously narrow fairways. Since 2019, the Newport Beach Harbor Commission has ceased approving mooring extension requests and has focused on developing a structured and optimized layout for mooring fields that ensures safer navigation, better public access, and improved environmental protections.
Benefits of the Proposed Reconfiguration The proposed Mooring Field Optimization Plan aims to correct these issues by implementing a
tion, better public access, and improved environmental protections.
Benefits of the Proposed Reconfiguration The proposed Mooring Field Optimization Plan aims to correct these issues by implementing a structured layout that organizes moorings by vessel length, plans the efficient use of the designated water space, improves safety, and enhances harbor aesthetics. Specifically, the plan will: Increase Open Water Space: The reconfiguration will create additional navigable areas for all harbor users, including recreational boaters, rental operators, and human-powered watercraft.
Improve Safety & Navigation: The current fairways are too narrow, with some waterways providing only 12 to 20 feet of clearance. The new configuration will significantly widen fairways to align with best practices, ensuring that all vessels have adequate space to maneuver and for permitees to safely approach and secure moorings.
Introduce a More Efficient Mooring Layout: As an example, under the current system, the J & H mooring fields in Newport Harbor accommodate approximately 200 moorings covering over 1.3 million sq. ft. (30 acres). The proposed double row mooring configuration, inspired by America's Cup Harbor in San Diego, would allow 90% of moorings to fit within 50% of the original space. This efficiency allows for safer navigation and enhanced harbor usability.
Enhance Mooring Security & Flexibility: The new spacing will enable permittees to safely secure their vessels from multiple directions, eliminating the need for tight and potentially unsafe maneuvering.
Improve Environmental Sustainability: The plan introduces conservation moorings that reduce damage to the harbor's eelgrass beds and marine ecosystem. By replacing outdated single-point
e maneuvering.
Improve Environmental Sustainability: The plan introduces conservation moorings that reduce damage to the harbor's eelgrass beds and marine ecosystem. By replacing outdated single-point anchor systems with environmentally friendly helix moorings, we can prevent habitat destruction while maintaining a world-class harbor.
Expand Public Access: The reconfiguration adds new long-term moorings within the existing mooring fields, making boating more accessible and safer.
A Responsible and Necessary Plan for Newport Harbor The Harbor Commission and City Council unanimously support this reconfiguration because it represents a common-sense approach to improving harbor safety, navigability, and environmental stewardship. The plan aligns with the City's Harbor Design Standards, Coastal Act requirements, and best practices for sustainable harbor management.
I urge the California Coastal Commission to approve Agenda Item 16b and support the implementation of this much-needed optimization plan. Thank you for your time and consideration.
Please feel free to contact me should you have any questions or require additional information.
Sincerely, Steve Scully Newport Beach Harbor Commission [email protected] 909-322-2893 SIERRA CLUB CALIFORNIA January 31, 2025 To: California Coastal Commissioners and Staff From: Sierra Club California, Coastal Sub-committee Re: Public Comment on CCC February 2025 Meeting, Wednesday, Agenda Item 16b, Application No. 5-23-0753, Applicant: City of Newport Beach Harbor Department Dear Commissioners and Staff, Due to concerns over public safety, public access, and environmental justice, we recommend that this CDP not be approved but postponed until the project's lack of compliance with the Coastal Act regarding public
erns over public safety, public access, and environmental justice, we recommend that this CDP not be approved but postponed until the project's lack of compliance with the Coastal Act regarding public safety, public access, public recreation, and Coastal Act Environmental Justice policies, can be resolved.
We appreciate that staff has addressed the need to preserve and expand lower cost mooring sites, increase open waters, and install more environmentally sustainable mooring hardware. However, we find that this "pilot program," applied solely to lower cost moorings while ignoring opportunities to reconfigure higher cost moorings, appears to be a continuation of efforts by the Newport Beach Harbor Department to deny equitable public access to coastal waters, recreation, and affordable housing. We support the position of the Newport Mooring Association, an organization dedicated to preserving affordable harbor access, fair mooring rates, and equitable terms, as stated below, 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in
onsidering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
Additionally, we would point out the need to specifically address how the proposed project/pilot plan will comply with Coastal Environmental Justice Policy with respect to the following mandates: Providing public access and lower-cost recreation opportunities for everyone.
proposed project/pilot plan will comply with Coastal Environmental Justice Policy with respect to the following mandates: Providing public access and lower-cost recreation opportunities for everyone.
Coastal development should be inclusive for all who work, live, and recreate on California's coast and provide equitable benefits for communities that have historically been excluded, marginalized, or harmed by coastal development.
The Commission recognizes that all aspects of our mission are best advanced with the participation and leadership of people from diverse backgrounds, cultures, races, color, religions, national origin, ethnic groups, ages, income levels, disability status, sexual orientation, and gender identity.
"Equity" refers to the fairness of achieving outcomes for all groups Understanding that even nominal costs can be barriers to access preserving and providing for lowercost recreational facilities is also an environmental justice imperative.
The Commission recognizes that the elimination of affordable residential neighborhoods has pushed low-income Californians and communities of color further from the coast, The Commission will increase these efforts with project applicants, appellants and local governments, by analyzing the cumulative impacts of incremental housing stock loss, and by working with local governments to adopt local coastal program policies that protect affordable housing.
The Commission will also support measures that protect existing affordable housing. If the Commission staff determines that existing, affordable housing would be eliminated as part of a proposed project in violation of another state or federal law, the Commission staff will use its discretion to contact the appropriate agency to attempt to resolve the issue.
e eliminated as part of a proposed project in violation of another state or federal law, the Commission staff will use its discretion to contact the appropriate agency to attempt to resolve the issue.
Partner with environmental justice leaders and groups to educate their communities about coastal issues that intersect with environmental justice.
Include an analysis of environmental justice issues in applicable staff reports, and, when appropriate, propose mitigation measures to avoid or fully mitigate identified impacts, in a manner that is fully consistent with Chapter 3 or local coastal program policies.
Recommendations CCC Staff states that, CCC does not consider costs of tackle used to minimize impacts to habitat as follows, "It is important to note that these fee structure issues are not addressed in this CDP application, as the subject project does not propose any changes to the rates or fee structure but is rather solely for the physical realignment of the mooring field." This rationale that the financial impacts of the project on lower income boaters do not have to be addressed is flawed as the project does not simply realign moorings, but also requires that the mooring hardware be replaced at the boat owners' expense. Staff acknowledges this as a financial burden: “requiring all permittees to replace existing weights with helical anchors could impose financial hardship resulting in a barrier to maintaining access to the mooring permits." Special Condition 2, while allowing for some cost savings, still requires boaters to assume the considerable cost of improvement to mooring hardware which cannot rationally be considered to be their personal property but will remain
ing for some cost savings, still requires boaters to assume the considerable cost of improvement to mooring hardware which cannot rationally be considered to be their personal property but will remain onsite should they no longer be able to afford the mooring fees. We recommend that the City of Newport Beach be responsible for the cost of installing new anchor weights and associated hardware and disposing of old hardware with respect to lower cost mooring sites.
The Coastal Commission is mandated to protect existing affordable housing and lower cost recreational facilities in the Coastal Zone. Multiple lower cost mooring sites in Newport Bay serve as full time residences for boaters. These qualify as affordable housing units. Additionally, some mooring fields, including Mooring Field C, must also be considered to be affordable residential neighborhoods. We see the Harbor Commission "pilot” program's focus on Mooring Field C as part of a continued effort to place undue burdens on lower income boaters as residents in violation of Coastal Act housing policies. If the City seeks to increase open water areas in the harbor, a pilot program focused on higher value single-point mooring fields should be implemented instead. We recommend that an analysis of the impacts of reducing or eliminating affordable moorings be done with respect to the lack of affordable local coastal housing. This analysis should include outreach to and input from those who currently reside on their boats as well as those who have been displaced due to rising fees or related expenses.
With respect to the inclusion "of all who work, live, and recreate on California's coast," it does not appear that the City has adequately consulted nor obtained the support of those most immediately impacted in
t to the inclusion "of all who work, live, and recreate on California's coast," it does not appear that the City has adequately consulted nor obtained the support of those most immediately impacted in this "pilot program." Coastal Commission staff simply ignores and overrides legitimate safety concerns raised by those who are most qualified to judge the proposed changes to the mooring configuration. Too little, too late, Special Condition 1, states that accidents due to the new configuration must be reported annually and changes may be considered after 5 years if enough accidents have been reported. Were those holding moorings in Field C consulted in the design process? Were alternative designs and locations considered with respect to public safety, public access, and environmental justice? It appears not. We recommend that this CDP be revised to include outreach to and input from all those holding moorings in Newport Bay, with a mandate that those most familiar with navigating these waters and those most at risk of losing access to mooring sites participate in the decision making process.
We recommend that further safety studies be conducted and alternatives be considered before any new configuration is approved.
O Outlook FW: Date Tue 1/28/2025 9:25 AM To Sent: Monday, January 27, 2025 7:01 PM Subject: Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-230753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision:
Coastal Development Permit (CDP) 5-230753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Erin Smale O Outlook FW: Moorings Date Mon 1/27/2025 12:40 PM To Sent: Monday, January 27, 2025 8:36 AM Subject: Moorings Please take into consideration, that the tidal changes and speed at which the ebb and flood of these tides are much greater than many of the other Harbors in Southern California. In addition to our negligence of acknowledging the reality of climate change. Just last week, the area was hit with winds that have been increasing, exponentially, caused several incidents, resulting in additional weight requirements to our existing moorings.
of climate change. Just last week, the area was hit with winds that have been increasing, exponentially, caused several incidents, resulting in additional weight requirements to our existing moorings.
Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Ruben RS Builders Ruben Smulovitz (714) 308-0844 O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Thu 1/30/2025 9:02 AM To Sent: Thursday, January 30, 2025 6:47 AM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns
t Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve lowcost access to the harbor.
City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve lowcost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or singlepoint mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Liz Stenton January 30, 2025 Dear Chair Cummings, Coastal Commissioners, and Coastal Staff, Thank you for taking the time to read my comments regarding CDP 5-23-0753. My name is Anne Stenton, and I am the president of the Newport Mooring Association. My husband and I are public school teachers, and we have kept our boat on a mooring for the past 15 years. My connection to Newport Harbor runs deep-some of my earliest childhood memories are of watching my dad inflate a dinghy on the public dock so he could row our family out to our boat.
He was a public school teacher too, and with a strong knowledge of fiberglass repair, engine maintenance, and sheer determination, he was able to keep a boat through Newport's mooring system. Today, my husband and I are proud to carry on that tradition with our own modest
glass repair, engine maintenance, and sheer determination, he was able to keep a boat through Newport's mooring system. Today, my husband and I are proud to carry on that tradition with our own modest 50-year-old sailboat, sailing on weekends and spending summers at the Channel Islands. The mooring community I know is made up of hardworking, adventurous, and passionate individuals who deeply care about the ocean, the harbor, our moorings, and each other.
A year ago, in January 2024, I learned that the Newport Beach Harbor Commission had proposed a mooring rate increase of around 400%. That would have made it impossible for us to continue our family's sailing tradition, so I got involved with the Newport Mooring Association.
I quickly realized that the rate increases were just the beginning. Over the past year, I have been trying to understand the City's proposed development plans for the mooring system, which has successfully provided affordable boat storage for nearly 100 years to approximately 1,000 permittees. First, there were discussions about rate increases despite mooring permittees already paying significantly more than dock permittees. Then, in July 2024, just days before the Fourth of July holiday, the City suddenly announced that mooring permits would no longer be transferable, even though other tidelands permits in the harbor remain transferable. City officials had previously assured us in 2023 that mooring permits would be transferable "in perpetuity."
Now, in addition to a CDP that proposes shifting moorings into an unsafe configuration, the City has amended CDP 5-23-0753 to require mooring holders to replace privately owned mooring tackle at great expense. This rapid, inconsistent policymaking is deeply concerning. Below is a
ration, the City has amended CDP 5-23-0753 to require mooring holders to replace privately owned mooring tackle at great expense. This rapid, inconsistent policymaking is deeply concerning. Below is a timeline of key changes to CDP 5-23-0753: • ● October 8, 2023: CDP submitted without helical anchors December 7, 2023: Helical anchors, which were discussed but not officially added to the CDP, were "discarded" from the public discussion (see Attachment A).
• May 20, 2024: CDP modified to include helical anchors for City-owned moorings.
January 16, 2025: CDP amended to require helical anchors for all moorings, including those with privately owned tackle.
The City is now seeking approval to change what was originally presented as a small-scale pilot program into a broad policy that forces mooring permittees to adopt expensive new mooring tackle, and potentially, helical anchors. Although the City has indicated that adopting helical anchors would be at the discretion of the mooring permittees, the unclear language of Special Condition #2 coupled with frequent reversals in mooring policy without regard for precedent make it difficult for the mooring community to trust that this will be the case. This financial imposition is being placed on mooring holders with no analysis or data to show it's necessary.
This is despite the fact that, on December 7, 2023, Harbormaster Blank wrote that "the use of the helical, screw-in anchor and shared anchors or weights for moorings were discarded." What was supposed to be a test program has now become a sweeping policy change.
I have spoken at many Harbor Commission and City Council meetings, reached out to City leaders individually, and advocated for fair and collaborative policymaking. According to the
ping policy change.
I have spoken at many Harbor Commission and City Council meetings, reached out to City leaders individually, and advocated for fair and collaborative policymaking. According to the Coastal Commission's Environmental Justice Policy, "equity is at the heart of the Coastal Act, a law designed to empower the public's full participation in the land-use decision-making process that protects California's coast and ocean commons for the benefit of all people." This should apply to the decision making process regarding submerged lands as well. Despite my efforts, I have not received any response from City officials regarding this application or its modifications.
When the CDP was first submitted, it was meant to test a double-row, tandem mooring configuration. Then, in May 2024, the City amended it to include helical anchors for 10 City-owned moorings. Around January 16, 2025, the CDP was amended again—this time requiring permittees to replace their own, privately owned mooring tackle. This places an unfair financial burden on some mooring holders while exempting others. City officials have already stated that single-point mooring fields—which occupy significantly more space and could have greater environmental impacts—will be unaffected by this CDP or "any extension of it." (Please see Attachment B). If the City is serious about conserving space in the harbor, why are they focusing on denser, stationary, double-point moorings used by budget-conscious boaters rather than the single-point moorings that mostly serve private yacht clubs?
We are not opposed to needed improvements. In fact, we have alternative proposals that would enhance the use of existing mooring infrastructure at a fraction of the cost to taxpayers. But we
ht clubs?
We are not opposed to needed improvements. In fact, we have alternative proposals that would enhance the use of existing mooring infrastructure at a fraction of the cost to taxpayers. But we have not been given a real seat at the table. While the City solicited feedback previousy, they have disregarded community input and moved forward unilaterally, leaving us without a genuine voice in the decision-making process.
Today, I ask that you vote against CDP 5-23-0753 in its current form. It does not serve the public interest in ensuring equitable and safe coastal access. This plan was developed without meaningful community input, while the City's management of tidelands is still under review by the State Lands Commission.
All we are asking for is a fair process that includes the voices of those most affected. Thank you for your time and consideration.
Sincerely, Anne Stenton President, Newport Mooring Association CITY NEWPORT CALIFORNIA BEACH December 7, 2023 RE: Alternative Configurations To Whom It May Concern, Attachment A CITY OF NEWPORT BEACH Harbor Department 1600 W. Balboa Blvd.
Newport Beach, California 92663 949-270-8159 Newportharbor.org I am writing to provide an overview of the extensive and detailed process that led to the current application for the Coastal Development Permit. This process, spanning over three years, included numerous meetings where the project plans and specifications underwent significant revisions and refinements, largely influenced by public feedback.
Initially, the equipment or tackle proposed for use, as detailed in the attached Noble Consultants, Inc.
report dated September 20, 2022, involved a shared common anchor for two moorings and the use of an
ially, the equipment or tackle proposed for use, as detailed in the attached Noble Consultants, Inc.
report dated September 20, 2022, involved a shared common anchor for two moorings and the use of an auger or helical soil screw-in anchor. However, this concept evolved following input from public and stakeholder consultations. Ultimately, the use of the helical, screw-in anchor and shared anchors or weights for moorings were discarded.
Subsequently, a modified design is presented in the attached illustration 221102, highlighting the utilization of adjacent existing anchor weights. This approach aimed at cost-saving and provided flexibility in spacing, confirmed by testing outcomes.
Further refinements are evident in the latest mooring illustration 230308, resulting from continued public and stakeholder feedback. This current recommendation involves a central anchor weight spacing of 20 feet, with each anchor having 24 feet of rode and a 10-foot bridle from buoy to cleat. This configuration ensures an average separation of 20 to 30 feet between boats at the shared anchor point, varying with tide and wind conditions.
While conservation buoys were part of the original concept and remain in the current proposal, they are not mandatory for the project. Their effectiveness and safety will continue to be assessed during the project's progression.
The reorganization of moorings within the C field was meticulously planned in collaboration with the City of Newport Beach GIS team, focusing on engineering precision and optimal space use. This planning involved multiple revisions to ensure the most efficient distribution of moorings across different sizes permitted in the C field. The size distribution is summarized in this table: Harbor Department Mooring Size Count 30 1 35 3 40 16
ure the most efficient distribution of moorings across different sizes permitted in the C field. The size distribution is summarized in this table: Harbor Department Mooring Size Count 30 1 35 3 40 16 45 11 50 10 55 3 60 3 65 1 70 0 75 3 80 0 85 0 90 Total 0 51 This layout accounts for the varied lengths of the moorings and proposes a new arrangement, as depicted in the "Proposed C Field Mooring Arrangement." Indicated in the arrangement are the lengths of different moorings, improved row spacing, and areas of new open water.
Sincerely, Paul Blank Paul Blank City of Newport Beach Harbormaster Harbor Department City of Newport Beach [email protected] 949-270-8159 ATTACHMENTS Mooring Anchor Calculations and Report 9-20-2022 Mooring Illustration 221102 Mooring illustration 230308 Proposed C Field Mooring Arrangement Mayor Pro Tem O'Neill thanked the community for participating in the discussion. In response to his questions, Harbormaster Blank indicated that the language regarding transferability in the ordinance pertains to all existing mooring permits and will remain transferrable until revoked or rescinded; however, new mooring permits will not be transferable and remain in the City's name for leasing out with no rights to the lessee upon completion. He also clarified that Mr. Colome has a mooring in perpetuity and is transferrable in perpetuity, and the two mooring fields designated for the Newport Harbor Yacht Club and Balboa Yacht Club are not affected by the pilot program or any extension of it in the future. He stated that the population of existing moorings and their lengths have been assessed in several surveys and provided to the engineers who will guide the City on the
y extension of it in the future. He stated that the population of existing moorings and their lengths have been assessed in several surveys and provided to the engineers who will guide the City on the best arrangement. He pointed out that Mooring Field C is not a 360-degree field, indicated that mooring permittees do not want clear fairways because they do not want more transient traffic through the mooring fields, there is no required vessel orientation language included in the plan, permittees should retrieve their mooring in the way that is most suitable and safe, and the pilot program is for the entire field. City Attorney Harp relayed confidence in the CEQA review and will look at the exceptions.
Harbormaster Blank indicated that the established length of mooring rows will be based on a recommendation by the engineer, vessel lengths are included on each permit, and vessel lengths will be used to create the rows. City Attorney Harp stated that the process would rely on the Harbormaster to relocate the moorings into the rows based on length or it could be delegated to the City of Newport Beach Volume 65 - Page 559 City of Newport Beach City Council Meeting May 23, 2023 Attachment B O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Tue 1/28/2025 9:24 AM To Sent: Monday, January 27, 2025 9:47 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission,
Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan.
or.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan.
Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more spaceefficient configurations, raises concerns about fairness and consistency.
This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 523-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Matt Stenton O Outlook FW: Reconfiguration of mooring field C located within Newport Harbor. Coastal Development Permit 5-23-0753 Date Fri 1/31/2025 3:16 PM To Sent: Friday, January 31, 2025 3:11 PM Subject: Reconfiguration of mooring field C located within Newport Harbor. Coastal Development Permit 5-230753 Dear Members of the California Coastal Commission,
Subject: Reconfiguration of mooring field C located within Newport Harbor. Coastal Development Permit 5-230753 Dear Members of the California Coastal Commission, I am a resident of Newport Beach and strongly support the proposed mooring plan. This plan will improve access for public users and enhance safety in the harbor.
There has been discussion regarding the spacing between mooring cans and boats. The proposed plan ensures: • 20 feet between mooring cans fore and aft (resulting in 30 feet between boats due to the 10-foot line from the mooring ball to the cleat).
50 feet between boats in the same row (port to starboard).
To compare current conditions to the proposed plan, I conducted a survey of Fields A, C, D, F, and K. While navigating these areas, I found 63 vessels on double-point moorings that are already in tighter, less safe conditions than the proposed plan allows.
Additionally, I surveyed Fields B, H, and J to assess fairway widths. The proposed plan provides: • 60-foot fairways for 40-foot boats • 90-foot fairways for 60-foot boats However, my survey found 10 existing fairways in Field B as narrow as 15-35 feet and 12 fairways in Fields H & J as narrow as 10-40 feet.
These current conditions are more restrictive and less safe than the proposed plan.
The new plan will evenly distribute space, improve safety and maneuverability, and create clear, navigable paths for the 2-3 million annual harbor users. As a pilot program, it presents little downside and the potential for significant benefits to Newport Harbor stakeholders.
Thank you for your time and consideration.
Best regards, Rudy Svrcek O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753
o Newport Harbor stakeholders.
Thank you for your time and consideration.
Best regards, Rudy Svrcek O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 6:50 PM To Sent: Monday, January 27, 2025 6:48 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional
Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan.
Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more spaceefficient configurations, raises concerns about fairness and consistency.
This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 523-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Meridee Thompson 50 year veteran of harbor mooring use, sail and power O Outlook FW: CDP 5-23-0753
etter aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Meridee Thompson 50 year veteran of harbor mooring use, sail and power O Outlook FW: CDP 5-23-0753 Date Thu 1/30/2025 1:29 PM Sent: Thursday, January 30, 2025 1:08 PM Subject: CDP 5-23-0753 Dear Coastal Commission Members.
My name is Pedro Tibau, and I have proudly been a mooring permit holder in Newport Harbor for over 30 years. My journey with the sea began long before that, growing up in Rio de Janeiro, Brazil, where I spent my days surfing, diving, lifeguarding, and most of all-sailing, my greatest passion.
For my wife and me, our boat, Aurora, was NOT just a vessel—it was a DREAM. When we found a "project boat", we poured everything we had into building her from a bare hull. Thanks to the remarkable community of local boat builders and boat owners we were guided, supported, and inspired to never give up. Against all odds, we finished Aurora and launched her in 1995. But a boat is only half the story—she also needed a home.
That home came one lucky day when I found a 60-foot mooring permit listed in "The Log", the local paper. I acquired that permit, not just securing a place for my boat, but becoming part of a historic, tight-knit harbor community-people from all walks of life, bonded by our love for the water and the shared stewardship of this harbor.
But now, after decades of contributing to this community, I and many others like me-longtime, dedicated mooring holders-are facing the threat of being priced out of what has been our
p of this harbor.
But now, after decades of contributing to this community, I and many others like me-longtime, dedicated mooring holders-are facing the threat of being priced out of what has been our sanctuary, our second home, and in many cases, our only home. We are not asking for favors. We have invested years of hard work, financial sacrifice, and deep commitment to this harbor. Yet, we are being systematically pushed out, our stake in Newport Harbor disregarded in favor of those with deeper pockets.
This is not just about me, or Aurora, or any one individual. This is about fairness. It's about protecting the integrity of a harbor that has been shaped by generations of sailors, craftsmen, and everyday people who have built their lives around it. We refuse to stand by as our community is dismantled and auctioned off to the highest bidder.
I urge the Coastal Commission to recognize the significance of this issue, and deny CDP 5-23-0753, which will endanger access, and price many out of Newport. Please stand with those of us who have given our hearts to this harbor.
Thank you, Pedro and Anita Tibau O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 (City of Newport Beach, Newport Beach) Date Wed 1/29/2025 4:12 PM Sent: Wednesday, January 29, 2025 3:50 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which
em Wednesday 16b - Application No. 5-23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
The existing safely spaced mooring field arrangement has worked well for approximately 100 years.
Pushing mooring rows closer together will make the moorings more difficult to use and only the most able bodied and experienced boaters will have access to the moorings given the tidal currents and wind influences in Newport Harbor.
The existing mooring field arrangement allows for an equal amount of safety space (in front and behind) a mooring location to allow for safe access and safe departure in any direction. Pushing mooring rows together will eliminate access and exit routes, making mooring access more difficult and less safe. The plan will diminish navigation safety, especially when conditions are not ideal (e.g., higher winds and/or
will eliminate access and exit routes, making mooring access more difficult and less safe. The plan will diminish navigation safety, especially when conditions are not ideal (e.g., higher winds and/or tides). This will raise the risk of collision during both operations as well as for moored vessels.
The existing mooring fields are federally "Designated Special Anchorages" where general navigation is discouraged for the safety of mooring users. The proposal to widen fairways to encourage increased large boat traffic through anchorages will increase risk of collision.
The existing mooring fields provide a safe area of tidelands historically and currently used by kayakers, swimmers and paddleboarders. Widening fairways to encourage more boat traffic in mooring fields will be unsafe and negatively impact the existing safe enjoyment of human powered craft in the mooring fields as there will be an increased risk of collision. The current configuration of the mooring fields provides a safety buffer for the operation of human powered vessels like paddleboards, kayaks as well as swimmers.
The existing single row mooring configuration allows for safety personnel to access a boat (or fight a boat fire) from any direction. Pushing mooring rows together will reduce access for safety personnel.
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
ets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve low-cost access to the harbor. Space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Best regards, Craig Tillman O Outlook FW: Newport Beach Moorings Date Tue 1/28/2025 11:48 AM --Original Message--Sent: Tuesday, January 28, 2025 11:44 AM Subject: Newport Beach Moorings O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 3:58 PM
c Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Date Mon 1/27/2025 3:58 PM Sent: Monday, January 27, 2025 3:54 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5- 23-0753 (City of Newport Beach, Newport Beach) Dear Coastal Commission, I am writing to express my concerns about Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I urge you to carefully consider the following points before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce access for individual boaters, older boaters, and those with mobility issues. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport
olders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.2-3), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional. The City has not performed a proper alternative analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore costeffective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already compact single-row mooring fields, rather than first converting "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
I respectfully urge the California Coastal Commission to DENYCDP 5-23-0753 as it currently stands and to require a thorough safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
Sincerely, Marlene Webster 714 315-7990 Sent from my iPhone Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 (City of Newport Beach, Newport Beach) Date Mon 2/3/2025 8:50 AM To
Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 (City of Newport Beach, Newport Beach) Date Mon 2/3/2025 8:50 AM To Sent: Friday, January 31, 2025 4:59 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 16b - Application No. 5-23-0753 (City of Newport Beach, Newport Beach) Dear Honorable Chair Cummins and Coastal Commissioners, While I appreciate the work of Staff and the City, I respectfully ask you to deny this CDP primarily because it is not wise to reduce the width of every other fairway, in an effort to invite more boating traffic to traverse through the mooring fields. The current arrangement has worked well for years. Please take a look at the city image below and you will see that the boats all fit within the red mooring field boundary as codified by the Coast Guard. I believe the staff report may be inaccurate when it indicates the are 5 or 6 boats outside the boundary. You will also find the mooring field is out of the way of the main navigable channel. There is no problem here.
This appears to be a very expensive solution looking for a problem. The proposal to reshuffle the deck of mooring locations combined with the special condition to dispose of existing repurposed steel anchors (and fill local dumps) contradicts Coastal Policy of using recycled materials and sustainable building. The fact is the existing weighted anchors provide good habitat for sea life on the harbor floor which is otherwise devoid of eel grass due to lack of sunlight in the deeper waters and the composition of the harbor muck.
sting weighted anchors provide good habitat for sea life on the harbor floor which is otherwise devoid of eel grass due to lack of sunlight in the deeper waters and the composition of the harbor muck.
The existing repurposed anchors are artificial reefs that allow sea life to grab onto. I do not believe there has been an analysis on the impact to sea life regarding the comparison to the new helix which offers no habitat. While I am intrigued by the helix concept, it is untested and it does not seem wise to replace existing until the new is tested.
I feel this major disruption will leave the mooring users in Field C further disenfranchised after their moorings are all moved around and their anchors to taken to the dump for no substantial benefit.
Thank you for your consideration.
Sincerely, Wade Womack Map Viewer Newport Beach - GIS > I want to...
+ 29 328 327 24 32 DINA WA EDGEWATER AVE E 1329 324 ALVARADO F ARADO PL 322 320 321 318 319 316 317 AB 3141 14 315 312 313 310 311 309 308 309 CORONADO NADO STS 318 314-1/2 3391 314 312 310-3/21 310 311 308 3097 307 306 307 306 307 FERNANDO ST 10 308 306 30 305 304 305 30s "BALBOA BI 100 2020 Aer... 0 200ft 211AB 209A-C 205AB 04(1-7) 121 413 122 24 1/2 82* EDGEWATER PL 430 % ADAMS ST 501 (A-B) BAY AVE 125 410 34 421 4171 419 416 423 418423 420 427 HARDING m PALM S $1061/2mm 106 019 171 140 1/2 114 200 2012 EMERALD AVE 202-1/2 200.11 118 12310 108.1/2 GARNET AVE 106.3 78m 200.112 21012 209 730812.
208 206 203 VE PEARL AVE 123 C 121 B 20.112 CC Carroll Beek Comunity enter 112 1.10 106406-1/2 523 O Outlook FW: EJ contact at CCC Date Wed 1/29/2025 1:32 PM To
contact at CCC Date Wed 1/29/2025 1:32 PM To Sent: Tuesday, January 28, 2025 4:47 PM Subject: RE: EJ contact at CCC Hi All, Charming, thank you for this introduction. I appreciate your quick response.
Mr. Padilla, I am pleased to be introduced to you by Charming. I am a member of the Newport Mooring Association, which has been standing up to the City of Newport Beach management practices of Newport Harbor on behalf of California residents. Most of our members are not residents of Newport Beach and are very diverse ethnically, racially, and economically. We include veterans, first-responders, educators, and a growing number of retirees, some of whom live aboard their boats as their only affordable access to live on the coast.
You may have heard of the City's proposed rate hikes of 300% to 500% for private mooring permittees in July, which was put in abeyance after the California Coastal Commission and the State Lands Commission stepped in to request a pause in the City's actions. The CACC and SLC involvement came after the Newport Mooring Association and several other stakeholders exposed the discrepancy in the rates charged to homeowners with docks compared to mooring permit holders for the same tideland uses. Although the matter is not yet resolved, we believe the California Coastal Commission's Environmental Justice policy prevailed in pausing the City's proposal.
Unfortunately, the City's rate hike proposal is only one of the many discriminatory practices of
California Coastal Commission's Environmental Justice policy prevailed in pausing the City's proposal.
Unfortunately, the City's rate hike proposal is only one of the many discriminatory practices of the City against mooring permit holders to the benefit of others. For this reason, the Newport Mooring Association has formally requested that the California Coastal Commission require the City to pause all actions impacting private mooring permittees until the Commission has been able to conduct a cumulative impact analysis. Frankly, without a comprehensive review and analysis of the City's past, current and future plans to remake Newport Harbor, the Newport Mooring Association and other stakeholders representing the interests of the public as articulated in the EJ policy, are being whipsawed into having to react to each individual threat.
The City is trying to wear us down. The latest example of this is agenda item 16B, Application No. 5-23-0753 scheduled for next Wednesday, February 5th in Long Beach.
The first response we received to our request for a cumulative impact analysis from Jeff Palm, Southcoast Program Analyst, was that the Commission does not have the staff to conduct such an analysis. If this is the case, then we are appealing to you to assist the Newport Mooring Association and other EJ policy champions to balance the scales of justice. We are all on the same team.
Would you be willing to meet with me and a couple of Newport Mooring Association board members prior to the CACC February 5th meeting to hear our EJ concerns with the CDP in its current form? After addressing our immediate concern, we look forward to working with you to ensure that the Commission's Environmental Justice policy is prominently enacted in Newport Harbor.
in its current form? After addressing our immediate concern, we look forward to working with you to ensure that the Commission's Environmental Justice policy is prominently enacted in Newport Harbor.
Thank you for your consideration. I look forward to receiving a timely response.
Sincerely, Wade Womack 949-292-1165 O Outlook FW: CDP 5-23-0753 Date Thu 1/30/2025 5:21 PM Sent: Thursday, January 30, 2025 5:10 PM Subject: RE: CDP 5-23-0753 Dear Coastal Commission, I am writing to join the chorus of mooring holders who are expressing the same concerns that I have relative to Coastal Development Permit (CDP) 5-23-0753, which proposes significant changes to the mooring fields in Newport Harbor. I am reiterating the points made in a letter written by another member of the community, as I agree with every point made in that letter - as it lays out the issues more eloquently than I could put them.
I have been boating for over 60 years, with experience in boats of all sizes and types (including having earned a USCG Masters Certificate along the way) - visiting numerous ports, all over the world. In addition, I have been a mooring holder with over 15 years of residence in the Newport Harbor "J" field, and have experienced firsthand, the safety issues discussed below - and have long wondered how long the City would be allowed to continue the inequitable treatment of the distinct mooring populations, as described below. So please take all of this experience into account, when I urge you to carefully consider the points laid out below, before making a decision: 1. Safety Concerns
oring populations, as described below. So please take all of this experience into account, when I urge you to carefully consider the points laid out below, before making a decision: 1. Safety Concerns The proposed changes would push moorings closer together, thereby reducing the space available for boaters to safely maneuver their vessels. This loss of space reduces reaction time and increases the risk of collisions and injuries, particularly during challenging conditions like strong currents or winds which occur frequently in Newport Harbor. The loss of reaction time will reduce coastal access for ordinary boaters, older boaters, and those with mobility challenges. Such risks directly conflict with the California Coastal Act Section 30210, which calls for maximizing access and considering public safety needs. Unsafe Access is No Access!
2. Financial Burden on Mooring Holders The project's reliance on costly helical anchors, and the use of specialized hydraulic installation equipment, along with requirements for some mooring holders in Field C to replace existing functional mooring weights at their own expense, imposes an undue financial burden on this user group, and sets a worrisome precedent. This conflicts with Newport Beach's Coastal Land Use Plan (CLUP 3.3.23), which emphasizes maintaining shore and offshore moorings as affordable public access to the harbor.
3. Alternatives Analysis and Alternative Solutions The current system in Field C is functional and time tested. The City has not performed a proper alternative Harbor Engineering analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually
er alternative Harbor Engineering analysis to its dangerous "double-row" mooring plan. Instead of targeting existing single row moorings, the City should collaborate with mooring holders, who actually have boats on moorings, to explore cost-effective and realistic solutions that prioritize safety and preserve low-cost access to the harbor.
4. Inequitable Treatment of This Mooring User Group: Prioritizing the densification of already over crowded mooring fields, rather than first converting spacious "swing" or single-point mooring fields into more space-efficient configurations, raises concerns about fairness and consistency. This approach gives the impression that the City may be granting preferential treatment to the single-point mooring fields, which occupy and impact significantly more space per vessel.
This proposal has all the earmarks of “a solution, looking for a problem that does not exist”. And an unnecessarily expensive and dangerous solution at that. So, I respectfully urge the California Coastal Commission to DENY CDP 5-23-0753 as it currently stands and to require a thorough Harbor Engineering Safety analysis and a plan that better aligns with the Coastal Act and the City's commitment to affordable and safe access.
That said. I am not much of a public speaker but would be happy to discuss the points mentioned above in more detail - with any of the members of the Coastal Commission - in person or on the phone, if desired.
Respectfully, Mark Womble +1-949-500-3440 Newport Harbor Mooring #J1101 O Outlook FW: Date Tue 1/28/2025 9:09 AM -Original Message--Sent: Monday, January 27, 2025 8:08 PM
l.ca.gov> Date Tue 1/28/2025 9:09 AM -Original Message--Sent: Monday, January 27, 2025 8:08 PM Subject: My name is James Woodworth. I am a mooring permittee in Newport Harbor. Please do Not pass #16B for mooring reconfiguration in the harbor. It will be Unsafe and will have Multiple Obstacles for boat owners and operators. There are Other Solutions that will work and be Safe, including leaving the mooring fields alone as they are.
Thank You for your consideration.
O Outlook FW: City of Newport Beach Harbor Dept. Project - Reconfiguration of Existing 5.5-Acre Mooring Field C Date Mon 2/3/2025 8:51 AM Sent: Friday, January 31, 2025 5:02 PM Subject: City of Newport Beach Harbor Dept. Project - Reconfiguration of Existing 5.5-Acre Mooring Field C Hi, My name is Donald Yahn and I am a citizen of Newport Beach. I am in favor of proceeding with the aforementioned project. I assert that the project will improve the safety and overall navigability within the field by increasing the width of fairways. Also, it will increase recreational boating opportunities.
Thank you.
Regards, Donald Yahn Donald Yahn Executive Director theyahngroup.com Direct: +1 949 930 9235 Mobile: +1 714 580 3295 [email protected] CUSHMAN & WAKEFIELD 18111 Von Karman Ave, Suite 1000 Irvine, CA 92612 | USA cushmanwakefield.com
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For information on how your personal information is processed, including information on how to exercise state or country specific Privacy Rights please view our privacy notice here: https://www.cushmanwakefield.com/en/privacy-and-cookies O Outlook FW: Public Comment on February 2025 Agenda Item Wednesday 6b - Commission Correspondence Date Mon 2/3/2025 10:27 AM ----Original Message-----
y 6b - Commission Correspondence Date Mon 2/3/2025 10:27 AM ----Original Message----Sent: Friday, January 31, 2025 1:28 PM Subject: Public Comment on February 2025 Agenda Item Wednesday 6b - Commission Correspondence Dear California Coastal Commissioners: I am writing to ask you to support along with Staff Coastal Development Permit 5-23-0753 as presented.
As a 65 year resident of Newport Beach I enjoy our harbor on a daily basis. I am thrilled to see the City of Newport Beach is taking steps to improve access and safety for all to enjoy the harbor.
Thank you in advance for your time to review this CDP and encourage a positive vote in favor...
Best Sailing, D. Durgan