CONSIDER APPROVAL OF A CEQA ADDENDUM FOR THE CARMEL RIVER BANK STABILIZATION PROJECT AT RANCHO SAN CARLOS ROAD (CEQA: Approve Addendum to the Carmel River Management Plan Environmental Impact Report Under CEQA Guideline Sections 15162 and 15164)


Meeting Date:

February 22, 2018





David J. Stoldt,




General Manager

Line Item:



Prepared By:

Larry Hampson and

Thomas Christensen

Cost Estimate:




General Counsel Review:  Yes

Committee Recommendation:  N/A

CEQA Compliance:  Addendum to EIR




















SUMMARY:  A series of high flows since 2011 have steadily destabilized a portion of the Carmel River channel downstream of the Rancho San Carlos Road Bridge.  In the winter of 2017, the area experienced significant erosion along about 300 feet of the south streambank and damaged Santa Barbara sedge, which is used by local Rumsen Ohlone Native Americans in the ancient art of basket weaving.  Further destabilization of the streambank would result in additional loss of Santa Barbara sedge and the instability could translate downstream into the reach of the river where Hacienda Carmel is protected from high flows by a ring levee. Staff proposes to carry out the Carmel River Bank Stabilization Project at Rancho San Carlos Road (RSC Project) as described in the attached project description and work plan (Exhibit 12-A).


Because physical modification within the river channel is considered a project under the California Environmental Quality Act (CEQA), the Board of Directors must review the proposed project for potential impacts to the environment.   On October 29, 1984, the Board of Directors certified a program Environmental Impact Report (PEIR) for the Carmel River Management Plan (CRMP) and adopted mitigation measures for river restoration projects within the channel of the Carmel River. The Board subsequently adopted an Addendum to the PEIR on August 18, 1997 to add mitigation measures for potential effects to California red-legged frogs.  The Board should review the RSC Project in light of this CEQA record, which was provided to the Board under separate cover, and determine whether to approve the RSC Project as an Addendum to the Carmel River Management Plan PEIR.  Attached as Exhibit 12-B is Resolution 2018-03, which contains findings of environmental review. 


RECOMMENDATION:  Staff recommends:

a)      the Board adopt Resolution No. 2018-03 approving the RSC Project and Addendum to the Carmel River Management Plan Program Environmental Impact Report; and

      c)   authorize staff to file a Notice of Determination with the Monterey County Clerk.


DISCUSSION:  In 1984, the District developed and adopted the Carmel River Management Plan and associated program Environmental Impact Report (PEIR).  These actions occurred after many citizens along the Carmel River requested such a plan in the wake of high flows between 1978 and 1983 that degraded the river.   The goals of this plan are to restore streambank stability and to enhance the natural resources of the river.  The proposed RSC Project is a continuation of the comprehensive restoration of the Carmel River. Specific goals of the project are:


1.         Prevent further erosion of the stream bank on both sides of the river in order to protect land, infrastructure, mature riparian habitat on the floodplain, and the Santa Barbara Sedge area.


2.         To restore riparian vegetation on the banks and active floodplains.


3.         To enhance habitat for California red-legged frogs and juvenile steelhead. 


The RSC Project area has had a long history of instability associated with groundwater pumping (loss of protective riparian trees) and down cutting of the channel bed over many years due to sediment being trapped behind Los Padres Dam and the former San Clemente Dam.  Recent small scale changes related to erosion on the right bank (facing downstream) were first observed in 2011. Temporary measures to stabilize the right bank included installation of jute netting and willow cuttings. However, on February 21, 2017 during a high flow event, when the Carmel River peaked at approximately 9,570 cubic feet per second at the U.S.G.S Near Carmel gage (about a mile downstream of the RSC Project), approximately 10 to 15 feet of bank eroded along 300 lineal feet of the southern river bank (left bank). With this new significant erosion of the left bank and the foreseeable loss of additional land, including a portion of the only remaining mature riparian forest along the lower 15 miles of the river, the District would like to restore and stabilize these two streambanks to prevent a large scale erosion event in future winters. Staff is currently collecting information on permit requirements and hopes to carry out the project in the summer and fall of 2018.


The current project description for the RSC Project entails stabilization of the left bank with a log cribwall (combination of logs, boulders, cobble, gravel, and native riparian trees) of approximately 160 linear feet and the stabilization of a small portion of the right bank (approximately 60 linear feet) with structural components of logs with rootwads, boulders, cobble, gravel, and native riparian plantings. Additional planting will occur at the upstream and downstream ends of the project.


Most construction activities would be confined to the active channel, which is approximately the area of the 10-year runoff event.  These projects are part of the District’s Riparian Corridor Management Program to provide erosion protection and restore natural resources along the river.  The projects are funded through the District’s Mitigation Program.


A draft set of plans was provided to owners of properties that would be directly affected by construction activities.  As a result, the District was made aware of the presence of Santa Barbara sedge on the terrace above the left streambank downstream of Ranch San Carlos Road Bridge.   The CRMP EIR has this to say about cultural resources:


“ Heritage Impacts


The flood plain and banks of the Carmel River have a high potential for archaeological sites. Despite extensive river and human activity, some sites may have escaped destruction through chance or sediment deposition.



An archival check of known sites should be carried out for all reaches of the preferred solution, and both banks of the river walked by an archaeologist prior to initiation of project activity. If any sites are discovered, project plans should be identified to incorporate appropriate mitigations. If unsuspected sites are unearthed during construction, all activities should halt until an archaeological inspection is carried out and mitigations devised.”


At their November 13, 2017 meeting, the Board of Directors authorized staff to retain a cultural resources consultant (LSA) to carry out a study of the site as described in Exhibit 12-C.  At that meeting the District received several letters from Native America stakeholders describing the importance of the sedge as a source of material for use in the ancient are of basket weaving.  See this link to the letters


In January 2018, staff met with the consultant (LSA), property representatives and stakeholders to discuss the RSC Project.  District staff agreed to revise the project plans to avoid damage to the Santa Barbara sedge on site.


CEQA Action Required


CEQA section 15162 “Subsequent EIRs and Negative Declarations” describes several possible conditions that could require a subsequent EIR.  Two parts of this section apply to the proposed project.  The key question in Section 15162 (a) (1) is whether substantial changes are proposed in the project.  The key question in Section 15162 (a) (3) (A) is whether the project will have one or more significant effects not discussed in the previous PEIR and any subsequent CEQA approvals. 


The proposed project techniques and potential impacts are within the scope of that program EIR and no substantial change to the PEIR is required to approve the RSC Project.  The locations and technique of using boulders, logs, and revegetation for bank stabilization are similar to those analyzed in the EIR. The proposed project and mitigation measures constitute a technical change that under CEQA Section 15164 “Addendum to an EIR or Negative Declaration,” requires the Board to adopt an addendum to the existing program EIR.  The addendum for RSC Project consists of the Project Description and Cultural Resources Study Agreement referred hence forth as the RSC Project Addendum.



12-A    RSC Project Description and Work Plan

12-B    Draft Resolution 2018-03

12-C    LSA Cultural Resources Study Agreement