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HomeMy WebLinkAboutPA2021-308_20211222_Coastal Hazards_7-15-21Geotechnical C Geologic C Coastal C Environmental 5741 Palmer Way C Carlsbad, California 92010 C (760) 438-3155 C FAX (760) 931-0915 C www.geosoilsinc.com July 15, 2021 Mr. Jack Langson c/o PMR Construction 2026 West Balboa Blvd. Suite D Newport Beach, CA 92663 SUBJECT: Coastal Hazard and Sea Level Rise Discussion for New Residence, 2676 Bayshore Drive, Newport Beach, Orange County, California. Dear Mr. Langson: In accordance with the request and authorization, GeoSoils, Inc. (GSI) is pleased to provide this discussion regarding the potential coastal hazards, including the impact of future sea level rise (SLR), on the proposed new residence at 2676 Bayshore Drive in Newport Beach, California. The purpose of this report is to provide the hazard information for your permit application typically requested by the City of Newport Beach and the California Coastal Commission (CCC). Our scope of work includes a review of the State of California Sea-Level Rise (SLR) Policy Guidance document (March 2018), CCC SLR Guidance (November 2018), a review of City of Newport Beach Municipal Code (NBMC) 21.30.15.E.2 and 21.30.15.E.3, a review of the proposed plans, and preparation of this letter report. INTRODUCTION The proposed project is new single-family residence and associated improvements, in the City of Newport Beach. The site is fronted by a concrete bulkhead, a boat dock, and a large navigation channel within Newport Bay. The project will include either reinforcing the existing bulkhead and raising the top of the bulkhead to elevation +10.9 feet NAVD88, or replacement with a new bulkhead to a minimum height of 10.9 feet NAVD88. The proposed finished first floor (FF) of the residence is ~+12.4 feet NAVD88. The surface drainage flow line on Bayshore Drive is at about elevation +11.0 feet NAVD88. Figure 1, downloaded from Google Maps (Bird’s Eye View), shows the site in relation to the adjacent properties and the navigation channel. The site is currently mapped by FEMA (FIRM Panel 06059C0381K) to be in the Shaded X Zone with no base flood elevation (BFE). The bulkhead and adjacent navigation channel are in the FEMA AE Zone with a BFE of +8 feet NAVD88. PA2021-308 2 Figure 1. Subject site, 2676 Bayshore Drive, adjacent properties, and navigation channel within Newport Bay. DATA & DATUM The datum used in this report is NAVD88, which is about 2.62 feet below the mean tide level (MTL). The units of measurement in this report are feet (ft), pounds force (lbs), and seconds (sec). Site elevations were taken from a topographic map prepared by CivilScapes Engineering. Preliminary development plans were discussed with Scott Shaffer and PMR Construction. A site reconnaissance was performed on March 23, 2021. There is no beach or shoreline fronting the site. HAZARD ANALYSIS There are three different potential shoreline hazards for ocean and waterfront development: shoreline movement/erosion, waves and wave runup, and flooding. For ease of review, each of these hazards will be analyzed and discussed separately, followed by a summary of the analysis including conclusions and recommendations, as necessary. Shoreline Erosion Hazard There is no actual beach or shoreline at the site proper. The elevation of the mudline at the bulkhead is below the lowest bay water elevation. PA2021-308 3 Waves and Wave Runup The potential surface gravity waves (ocean swell) to arrive at this site is nil. Boat wakes are the only possible waves that can reach the bulkhead fronting the site. However, boat wakes are typically small due to speed restriction within the channel. Anticipated wave runup and overtopping of the bulkhead at the site was calculated using the USACOE Automated Coastal Engineering System, ACES. ACES is an interactive computer-based design and analysis system in the field of coastal engineering. The methods to calculate wave runup and overtopping implemented within this ACES application are discussed in greater detail in the 2004 Coastal Engineering Manual. A 0.75-foot high wave was used in the ACES wave runup and overtopping analysis with a current maximum historical water level of +7.7 feet NAVD88 (no future SLR). This combination of wave and water level represents an approximate 100-year recurrence interval oceanographic condition under current sea level. Table I below is the computed output from the ACES program for the wave runup analysis. TABLE I The calculated maximum wave runup under the current 100-year recurrence interval water level conditions is about 0.84 feet above the 100-year water level or about elevation +8.5 feet NAVD88. This is currently below the proposed minimum elevation of the reconditioned or replaced bulkhead. With the proposed minimum bulkhead elevation +10.9 feet NAVD88 and SLR of 2.3 feet (+8.5 NAVD88 + 2.3 feet SLR = 10.8 NAVD88), waves/wakes will not overtop the bulkhead. Any wake/wave runup waters that reach near this elevation will have a low velocity, no energy, and no erosion capacity. It should be noted that under higher future SLR conditions the height of the bulkhead can be increased to prevent overtopping. ACES I Mode: Single Case I Functional Area: Wave -Structure Interaction App I icat ion: Wave Runup and Overtopping on Impermeable Structures Item Unit Ualue Smooth Slope Runup and Incident Wave Height Hi: ft 0 .750 Overtopping Wave Period T: sec 3 .500 COTAN of Nearshore Slope COTC!II): 20.000 2676 Bayshore Water Depth at Structure Toe ds: ft 7.200 Drive COTAN of Structure Slope COTC8): 0.000 Structure Height Above Toe hs: ft 8.500 No SLR Bulkhead Wave Runup R: ft 0 .838 Overtopping Onshore Wind Velocity u: ft/sec 8.439 Deepwater Wave Height H0: ft 0 .813 Relative Height ds/H0: 8 .860 Wave Steepness H0/CgT"2): 0.002062 Overtopping Coefficient 0:: 0.070000 Overtopping Coefficient Qstar0: 0.070000 Overtopping Rate Q: ftA3/s-ft 0 .000 PA2021-308 4 Current Flooding Hazard The National Oceanographic and Atmospheric (NOAA) National Ocean Survey tidal data station closest to the site with a long tidal record (Everest International Consultants Inc. (EICI), 2011) is located at Los Angeles Harbor (Station 94106600). The tidal datum elevations are as follows: Mean High Water 4.55 feet Mean Tide Level (MSL) 2.62 feet Mean Low Water 0.74 feet NAVD88 0.0 feet Mean Lower Low Water -0.2 feet The historical highest ocean water elevation at the Los Angeles Harbor Tide station is +7.72 feet NAVD88 on January 10, 2005. In addition, EICI reported that the elevation of 7.71 feet NAVD88 is the 1% water elevation. For this analysis the historical highest water elevation will be +7.7 feet NAVD88. Future Tide Levels Due to Sea Level Rise The California Coastal Commission (CCC) SLR Guidance document recommends that a project designer determine the range of SLR using the “best available science.” The California Ocean Protection Council (COPC) adopted an update to the State’s Sea-Level Rise Guidance in March 2018. These new estimates are based upon a 2014 report entitled “Probabilistic 21st and 22nd century sea-level projections at a global network of tide-gauge sites” (Kopp et al., 2014). This update included SLR estimates and probabilities for Los Angeles Harbor the closest SLR estimates to Newport Bay. These SLR likelihood estimates are provided below in Figure 2 taken from the Kopp et al., 2014 report. The report provides SLR estimates based upon various carbon emission scenarios known as a “representative concentration pathway” or RCP. Figure 2 provides the March 2018 COPC data (from the Kopp et al., 2014 report) with the latest SLR adopted estimates (in feet) and the probabilities of those estimate to meet or exceed the 1991-2009 mean, based upon the best available science. PA2021-308 5 Figure 2. Table from Kopp et al., (2014) and COPC 2018, providing current SLR estimates and probabilities for the Los Angeles Harbor tide station. This table illustrates that SLR in the year 2100 for the likely range, and considering the most onerous RCP (8.5), is 1.3 feet to 3.2 feet above the 1991-2009 mean. The City of Newport Beach currently requires the use of a lower probability SLR estimate. The design historical water elevation at the for Newport Bay is elevation +7.7 feet NAVD88 (1% water elevation). Interpolating the above table, the very low probability SLR (0.5%) for the year 2096, low emissions, SLR is ~5.0 feet, and the high emissions, SLR is 6 feet. Based upon this table there is a much lower probability (0.5%) of SLR of about 6.0 feet. This SLR would account for future extreme bay water level of 13.7 feet NAVD88 (7.7 feet NAVD88 + 6 feet SLR). As stated before, the present maximum (1%) historical water elevation at the site, including El Niño effects, is +7.7 feet NAVD88. Based upon the elevation of the modified or replaced bulkhead (10.9 feet NAVD88), the extreme Newport Bay water level will exceed the height of the bulkhead when SLR is 3.2 feet or greater. For the likely COPC SLR estimate range (high emissions) the site is safe from flooding until beyond the year 2090. For the 0.5% SLR case, this may occur after the year 2070. It should be noted that, if SLR is higher, flooding at the site will not occur constantly but rather only a few times a month, at the full moon and new moon, for a period of about 1 hour. With the proposed FF at elevation ~12.4 feet NAVD88, the structure will be safe from flooding from offsite sources until about the year 2085 for the 0.5% SLR. For the 5% COPC SLR estimate range (high emissions) the structure is safe from flooding until beyond the year 2110. LOW Medium -High Extreme Risk Aversion Risk Aversion Risk Aversion High emissions 2030 0 .3 0.2 0.5 0.6 0.7 1.0 2040 0.5 0.4 0.7 0.9 1.2 1.7 2050 0.7 0.5 1.0 1.2 1.8 2.6 Low emissions 2060 0 .8 0.5 1.1 1.4 22 High emissions 2060 1.0 0.7 1.3 1.7 2.5 3.7 Low emissions 2070 0.9 0.6 1.3 1.8 2.9 High emissions 2070 1.2 0.8 1.7 2.2 3.3 5.0 Low emissions 2080 1.0 0.6 1.6 2.1 3.6 High emissions 2080 1.5 1.0 2.2 2.8 4.3 6.4 Low emissions 2090 1.2 0.7 1.8 2.5 4.5 High emissions 2090 1.8 1.2 2.7 3.4 5.3 8.0 Low emissions 2100 1.3 0.7 2.1 3.0 5.4 High emissions 2100 22 1.3 3.2 4.1 6.7 9.9 Low emissions 2110· 1.4 0.9 2.2 3.1 6.0 High emissions 2110· 2.3 1.6 3.3 4.3 7.1 11.S PA2021-308 6 The Kopp et al. paper used 2009 to 2012 SLR modeling for the probability analysis, which means the “best available science” as determined by the CCC is almost 10 years old. The CCC SLR Guidance requires the use of the “best available science.” Dr. Reinhard Flick from the Scripps Institution of Oceanography has provided information that global sea level from 1992 to 2018 has resulted in 8.32 centimeters of relatively uniform SLR in the past 26 years. This information is shown on Figure 3 taken from the CCC SLR Guidance (2015). This current measurement shows that SLR is tracking more on the intermediate SLR prediction curves, which is more like a 50% (median) probability SLR in the year 2100, as shown in Figure 3. Figure 3. Current global SLR plotted on SLR prediction curves (graphic taken from TerraCosta Consulting). The recent global SLR measurement provided in Figure 3 shows that the current SLR trend, is not following the higher SLR estimate curves. It is GSI’s professional opinion that the methodology and SLR estimates suggested by the CCC SLR Guidance, based upon current SLR trends, are an overestimate of SLR over the project design life of 75 years. The City of Newport Beach has recognized that in the future there will be a need to raise the elevation of the boardwalks and bulkheads around the Newport Bay. The City of Newport Beach Building Department (CNBBD) has a standard drawing, and a regional plan for rehabilitating and raising the bulkheads. Flooding from the bay and from the beach will result in flooding of the public roads in the area. Recent action by the City Council has raised the minimum bulkhead elevation for new development to be 10.9 feet NAVD88. i ~ t 0 i e ~ s ii 'W • . .., .. rZ C i ii ..Q .2 0 ~---------------------------~2.13m (7.011.) 200 Observed 160 12() 80 4() 0 1 .. 3.2 mm/year J -40 1900 1950 2000 Ye■r S<:enanos 8.32 cm I C0 2050 a "' Higheot • 2.0 m 1.37 m (4.511.) Jntormadlato-H,gh • 1.2 m tntermediat•Low • 0.5 m Lowest -0.2 m 2100 Modified from Figure 5 of the California Coastal Commission Sea Level Rise Policy Guidance document adopted August 12, 2015. PA2021-308 7 Tsunami Tsunami are waves generated by submarine earthquakes, landslides, or volcanic action. Lander, et al. (1993) discusses the frequency and magnitude of recorded or observed tsunami in the southern California area. James Houston (1980) predicts a tsunami of less than 5 feet for a 500-year recurrence interval for this area. Legg, et al. (2002) examined the potential tsunami wave runup in southern California. While this study is not specific to the site, it provides a first order analysis for the area. The Legg, et al. (2002) report determined a maximum open ocean tsunami height of less than 2 meters. The maximum tsunami runup in the Newport Beach open coast area is less than 1 meters in height. Any wave, including a tsunami, that approaches the site in will be refracted, modified, and reduced in height by the Newport jetties, and as it travels into the bay. Due to the infrequent nature and the relatively low 500-year recurrence interval tsunami wave height, and the elevation of the proposed improvements, the site is reasonably safe from tsunami hazards. It should be noted that the site is mapped within the limits of the California Office of Emergency Services tsunami innundation map, Newport Beach Quadrangle (State of California, 2009). The tsunami inundation maps are very specific as to their use. Their use is for evacuation planning only. The limitation on the use of the maps is clearly stated in the PURPOSE OF THIS MAP on every quadrangle of California coastline. In addition, the following paragraph is taken from the CalOES Local Planning Guidance on Tsunami Response concerning the use of the tsunami inundation maps. Inundation projections and resulting planning maps are to be used for emergency planning purposes only. They are not based on a specific earthquake and tsunami. Areas actually inundated by a specific tsunami can vary from those predicted. The inundation maps are not a prediction of the performance, in an earthquake or tsunami, of any structure within or outside of the projected inundation area. The City of Newport Beach and County of Orange have clearly marked tsunami evacuation routes for the entire Newport Beach/Bay area. CITY OF NEWPORT BEACH INFORMATION Coastal Hazards Report (NBMC 21.30.15.E.2): i. A statement of the preparer’s qualifications; Mr. Skelly is Vice President and Principal Engineer for GeoSoils, Inc. (GSI). He has worked with GSI for several decades on numerous land development projects throughout California. Mr. Skelly has over 40 years experience in coastal engineering. Prior to joining the GSI team, he worked as a research engineer at the Center for Coastal Studies at Scripps Institution of Oceanography for 17 years. During his tenure at Scripps, Mr. Skelly worked on coastal erosion problems throughout the world. He has written numerous technical reports and published PA2021-308 8 papers on these projects. He was a co-author of a major Coast of California Storm and Tidal Wave Study report. He has extensive experience with coastal processes in southern California. Mr. Skelly also performs wave shoring and uprush analysis for coastal development, and analyzes coastal processes, wave forces, water elevation, longshore transport of sand, and coastal erosion. ii. Identification of costal hazards affecting the site; As stated in this hazard analysis, the typical coastal hazards to consider are shoreline erosion, flooding, and wave/wake impacts. There is no beach at, or near, the site. Boat wakes and wind waves are too small, even with sea level rise (SLR), to potentially flood the proposed residence provided the bulkheads in the area are maintained to mitigate SLR impacts. The City of Newport Beach has recognized that in the future there will be a need to raise the elevation of the boardwalks and bulkheads on Balboa Island (and other areas), and as such the City of Newport Beach has a standard drawing(s), and a regional plan for rehabilitating and raising the bulkheads. There is no potential coastal hazard of flooding of the development provided adaptation strategies such as waterproofing the structure to above the potential flood elevation, and increasing the height of the bulkhead are implemented, if required, in the future. iii. An analysis of the following conditions: 1. A seasonally eroded beach combined with long-term (75 year) erosion factoring in sea level rise; There is no beach at, or near, the site. 2. High tide conditions, combined with long-term (75 year) projections for sea level rise; Using the likely CCC SLR estimate over the project 75-year design life, the SLR in the year ~2096 is 2.9 feet. There is a 0.5% probability that SLR could be 6 feet in the next 75 years. This is the design sea level rise range (2.9 feet to 6 feet) for the proposed project. This SLR would account for future extreme bay water level of 10.6 feet NAVD88 to 13.7 feet NAVD88. 3. Storm waves from a one hundred year event or storm that compares to the 1982/83 El Nino event; No ocean waves can reach the site. 4. An analysis of bluff stability; a quantitative slope stability analysis that shows either that the bluff currently possesses a factor of safety against sliding of all least 1.5 under static conditions, and 1.1 under seismic (pseudostatic conditions); or the distance from the bluff edge needed to achieve these factors of safety; and PA2021-308 9 There is no bluff fronting the site. This condition does not occur at the site. 5. Demonstration that development will be sited such that it maintains a factor of safety against sliding of at least 1.5 under static conditions and 1.1 under seismic (pseudostatic) conditions for its economic life (generally 75 years). This generally means that the setback necessary to achieve a factor of safety of 1.5 (static) and 1.1 (pseudostatic) today must be added to the expected amount of bluff erosion over the economic life of the development (generally 75 years); There is no bluff fronting the site. There is no potential for sliding. This condition does not occur at the site. iv. On sites with an existing bulkhead, a determination as to whether the existing bulkhead can be removed and/or the existing or a replacement bulkhead is required to protect existing principal structures and adjacent development or public facilities on the site or in the surrounding areas; and There is a bulkhead on the site. It is our understanding that the project includes the raising of the bulkhead up to elevation 10.9 feet NAVD88 or replacement of the bulkhead to a minimum elevation of 10.9 feet NAVD88. Another engineering consultant, PMA Consulting Inc., has been retained for this phase of the project. v. Identification of necessary mitigation measures to address current hazardous conditions such as siting development away from hazardous areas and elevating the finished floor of structures to be at or above the base floor elevation including measures that may be required in the future to address increased erosion and flooding due to sea level rise such as waterproofing, flood shields, watertight doors, moveable floodwalls, partitions, water- resistive sealant devices, sandbagging and other similar flood-proofing techniques. The project is safe from the coastal hazard of flooding by the proposed addition to the bulkhead height (or bulkhead replacement), the finished floor elevation, and the ability to waterproof the building, if necessary. It is important to point out that SLR will not impact this area alone. It will impact all of the Newport Bay low lying areas. The public streets throughout the Newport Beach coastal area, including the Lido Island, Balboa Peninsula and Balboa Island, will flood with lower SLR well before the residence floods. It is very likely that the entire community will soon adopt some of the SLR adaptation strategies that are currently being considered by the City of Newport Beach. The City recently raised the minimum bulkhead elevation to 10.9 feet NAVD88. These strategies involve raising, or adding/replacing the bulkheads, beaches and walkways that surround the bay, and waterproofing of residences. These are a site specific adaptation strategies. PA2021-308 10 The project includes the raising of the height of the bulkhead or replacement of the bulkhead without any new bayward encroachment. The engineer of record for this phase of the project, PMA Consulting inc., will provide additional assessment of the bulkhead, as warranted. The following is provided as GSI’s preliminary assessment of the existing bulkhead. Bulkhead condition report shall include (NBMC 21.30.15.E.3): i. A statement of the preparer’s qualifications; Mr. Skelly is Vice President and Principal Engineer for GeoSoils, Inc. (GSI). He has worked with GSI for several decades on numerous land development projects throughout California. Mr. Skelly has over 40 years experience in coastal engineering. Prior to joining the GSI team, he worked as a research engineer at the Center for Coastal Studies at Scripps Institution of Oceanography for 17 years. Mr. Skelly has extensive experience in shoreline erosion, bluff erosion, soils engineering, and the design, permitting, and construction of shore protection devices. Projects include levee engineering and design in San Francisco Bay, seawall and marina engineering in Baja California Sur, coastal boardwalk design and protection in Pacifica, and seawall projects throughout southern California. ii. An analysis of the condition of any existing bulkhead including whether the top elevation meets current City standards, the conditions of the sheetpiles or panels, the condition of existing tiebacks and/or deadmen or similar, and any other relevant conditions; The bulkhead was visually inspected and is in reasonably good condition. There is some spalling of the concrete cap that does not impact the performance of the bulkhead at this time. The bulkhead, with the top at elevation ~+8 feet NAVD88, does not meet the current City’s top of bulkhead elevation requirement of +10.9 feet NAVD88. It should be noted that very few bulkheads in the Newport Bay area meet this newer elevation requirement. Based upon our visual observations and general knowledge of bulkhead design, it is GSI’s opinion that the bulkhead height can be increased without any bayward encroachment. However, the condition of the tieback rods that restrain the wall is unknown and should be investigated before any increase in height. Additional inspection and opinion will be provided by the bulkhead engineer, PMA Consulting Inc. (PMACI). iii. Recommendations regarding the need for repair, augmentation or replacement of the bulkhead or any parts thereof; Augmentation or replacement of the bulkhead will be necessary to meet the current City height requirement, and to protect site and general area regardless of the proposed development at the site. The increase in height or replacement of the bulkhead is an SLR adaptation strategy. Recommendations for the augmentation will be provided by the bulkhead engineer, PMACI. PA2021-308 11 iv. If augmentation or replacement in the existing alignment is necessary, recommendations that will avoid seaward encroachment of the bulkhead; The augmented or replacement bulkhead can be located within the current bulkhead footprint. v. If replacement is necessary and the existing bulkhead is not in alignment with adjacent bulkheads, recommended alternatives that will relocate the bulkhead in as much in alignment with adjacent bulkheads and as far landward, as possible. The site bulkhead, even with the augmentation in height or replacement, can remain aligned with the adjacent bulkheads. CONCLUSIONS • The proposed residential structure, with a FF of +12.4 feet NAVD88, is reasonably safe from the unlikely 0.5% SLR hazards until about the year 2085. The design is such that implementation of additional SLR adaptation strategies (design for future water proofing to above elevation +13.7 feet NAVD88 and the future protection of area by adoption of a resiliency plan by the community) will not be adversely impacted by potential coastal hazards including a 6 feet sea level rise or more over the next minimum 75 years. The site will be part of a community wide response to mitigate SLR hazards. • An augmented bulkhead (or replacement bulkhead) is proposed at this time to meet the current City standard height of +10.9 feet NAVD88. This height increase can be accomplished without further bayward encroachment of the bulkhead. Plans for the increase in height have been prepared by PMACI and are provided as part of the project application package. • For the most part, in the entire Newport Beach coastal and bay areas, including the Balboa Peninsula, and other developed islands within the bay, flooding with a lower SLR is likely to occur. Such flooding will occur well before any part of the proposed residence will flood. • Provided the recommendations of this report are implemented during the project construction, no additional site specific protective devices will be necessary to protect the proposed development from any existing or anticipated future coastal hazards for the next 75 years or more. PA2021-308 12 RECOMMENDATIONS Based upon the analysis and discussion herein, the proposed development is reasonably safe from coastal hazards for the next 75 years including shoreline movement, waves and wave runup, and flooding with future SLR for the next 75 years. It should be noted that future flooding hazards due to SLR are shared by all development around Newport Bay. The public roads for access to the area will be impassable due to ocean flooding long before the flood water level approaches the FF elevation of the development. SLR impacts will be a regional problem and only solved by a regional management plan. The proposed City of Newport Beach bulkhead modification/replacement plan will likely mitigate any SLR impacts on the project. The proposed development will neither create nor contribute significantly to erosion, geologic instability, or destruction of the site or adjacent area. The opportunity to be of service is sincerely appreciated. If you should have any questions, please do not hesitate to contact me. Respectfully submitted, GeoSoils, Inc. David W. Skelly MS, PE RCE#47857 PA2021-308 13 REFERENCES Everest International Consultants, Inc., 2011, Assessment of seawall structure integrity and potential for seawall over-topping for Balboa Island and Little Balboa Island, main report, No Project No., dated April 21. Kopp, Robert E., Radley M. Horton Christopher M. Little Jerry X. Mitrovica Michael Oppenheimer D. J. Rasmussen Benjamin H. Strauss Claudia Tebaldi Radley M. Horton Christopher M. Little Jerry X. Mitrovica Michael Oppenheimer D. J. Rasmussen Benjamin H. Strauss Claudia Tebaldi “Probabilistic 21st and 22nd century sea-level projections at a global network of tide-gauge sites” First published: 13 June 2014 Newport Beach, “Waterfront Project Guidelines and Standards, Harbor Design Criteria Commercial & Residential Facilities,” March 23, 2021. NOAA, 2020, Web Site, Maps http://anchor.ncd.noaa.gov/states/ca.htm Tidal Datums http://www.opsd.nos.noaa.gov/cgi-bin/websql/ftp/query_new.pl State of California, County of Orange, 2009, “Tsunami Inundation Map for Emergency Planning, Newport Beach Quadrangle,” 1:24,000 scale, dated June 1. State of California Sea Level Rise Guidance 2018 Update, by Ocean Protection Council, dated in March 2018. PA2021-308