The Coastal Recreation Expansion Plan Is Missing Its Most Important Chapter

The California Coastal Commission released a draft plan this summer for expanded recreational access along a 40-mile stretch of the central coast between Morro Bay and Cambria. The plan proposes new parking facilities, trail connections, and kayak launch points. It is described as a response to increased demand for coastal access following the pandemic. It does not mention sea otters.

I want to be precise: the plan does not mention sea otters, pupping season, haul-out sites, or wildlife viewing distance guidelines. It does not mention the California Department of Fish and Wildlife's existing recommendations for minimum approach distances to marine mammals. It does not mention carrying capacity — the concept that a given stretch of coastline has a limit to the number of visitors it can absorb before the disturbance to wildlife exceeds the tolerance of the species present.

This is not an oversight. The plan was reviewed by multiple agencies. The omission reflects a consistent pattern in coastal recreation planning: wildlife considerations are treated as constraints to be noted in an environmental review, not as design parameters to be integrated from the beginning.

The stretch of coast covered by the plan includes several of the most important pupping sites for southern sea otters in California. Female otters give birth in the water and nurse pups for six to eight months. During this period, they are highly sensitive to disturbance. A kayak that approaches too closely, a dog that enters the water near a resting raft, a drone operated over a haul-out — these are not hypothetical disturbances. They are documented causes of pup abandonment and maternal stress.

The plan's proposed kayak launch points are located, in two cases, within a quarter mile of documented pupping areas. The plan does not acknowledge this. It does not propose seasonal closures, approach distance markers, or docent programs. It proposes parking.

I am not opposed to coastal access. I am opposed to coastal access planning that treats the coast as an amenity for humans and ignores the fact that it is habitat for species that have no other option. The otters using these pupping sites cannot move to a less disturbed location. The habitat is where it is.

The plan is in public comment. The comment period closes in October. The Coastal Commission has the authority to require wildlife protection measures as a condition of approval. Whether it will use that authority depends, in part, on whether the public comment record makes clear that the omission is not acceptable. This piece is part of that record.