Carstens v. California Coastal Com

In Carstens v. California Coastal Com. (1986) 182 Cal. App. 3d 277, a utility company sought approval from the Commission to build nuclear power plants on San Onofre State Beach. To mitigate the loss of beach access occasioned by the project, approval was granted on condition that the company pay $ 3 million for construction of campsites on an adjacent beach and convey two parcels of beachfront property in the City of Carlsbad. (Id. at pp. 284, 291.) A citizen's challenge to the mitigation conditions on various grounds (not including the contention here that off-site mitigation is per se improper) was rejected in the trial court. On appeal, the Carstens court concluded that the administrative record showed that the Commission had adequately evaluated the relevant considerations under the Coastal Act. (Carstens v. California Coastal Com., supra, 182 Cal. App. 3d at pp. 290-294.)