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Goal 18: Pre-1977 Development Focus Group

Purpose of the Focus Group

In 2019, the Department of Land Conservation & Development (DLCD) convened a focus group of relevant interest groups, local government staff, and state agencies to review the equity and consistency of the application of Statewide Planning Goal 18: Beaches and Dunes, Implementation Requirement #5. This provision of the Goal relates specifically to shoreline armoring requirements. This focus group considered information related to the practical, political, technical and scientific aspects of Goal 18 shoreline armoring requirements.

Oregon Statewide Planning Goal 18, Beaches and Dunes (OAR 660-015-0010) limits the issuance of permits for beachfront protective structures (BPS)* to areas where development existed on January 1, 1977. Development is defined as:

  • Houses, commercial and industrial buildings;
  • Vacant subdivision lots which are physically improved through construction of streets and provision of utilities to the lot; or
  • Areas where an exception to Goal 18 Implementation Requirement #2 has been approved.

*Note: Shoreline armoring = beachfront protective structures (these terms are used interchangeably, but neither are defined in statute or rule).

The focus of this group was limited to addressing only these specific implementation provisions of Goal 18 identified by the department. The group did not address other provisions of Goal 18, nor was it the purpose of this group to debate the fundamental, date-based limitation on shoreline armoring established in Goal 18.

Focus Group Overview Document

Scope of the Focus Group

With the adoption of the coastal goals in 1977, LCDC established one of the foundational policies for the management of Oregon's ocean shore recreation area, namely that beach armoring for the protection of new shoreline development would be prohibited. A provision was provided in the policy to allow armoring to protect existing development. This was based on the rationale that prior siting and development decisions made without knowledge of this policy should be effectively "grandfathered" for purposes of shoreline armoring.

The allowance in Goal 18 for the protection of pre-1977 development is narrow and somewhat technical in its construction. Over the course of the years since the adoption of Goal 18, several issues have arisen related to the implementation of this allowance that DLCD believes warrant evaluation. This focus group was convened for the purpose of assisting DLCD in evaluating issues related to the application of the Goal 18 allowance for protection of pre-1977 development.

Focus Group Deliverables

A final report by the focus group was finalized and submitted to DLCD for consideration related to the concepts discussed by the focus group members. This input has helped to guide the department's next steps related to shoreline armoring and coastal erosion policy. Several of the recommendations outlined in the Final Report are now underway, and are described in the next section.

Final Report from the Goal 18: Pre-1977 Development Focus Group

Appendix: Public Comments submitted to the focus group

Ongoing Projects

Based on the recommendations of the focus group, several projects are underway to address identified issues or opportunities related to Goal 18.

  1. A Sea Grant Natural Resources Policy Fellow developed a guidebook to address the various types of erosion control practices on the Oregon coast, their regulatory framework, and whether or not they are considered a structure by practitioners (and therefore allowed only on Goal 18 eligible properties).
    Guidebook on Erosion Control Practices of the Oregon Coast (2021)
  2. DLCD completed a rulemaking process to add a reasons exception to include Highway 101 and other public, ocean-fronting roads built as of January 1, 1977, as eligible for shoreline armoring, through the local government exception process. More information about this rulemaking effort and the final rules can be found here.
  3. The Oregon Department of Transportation received a grant to complete a hazard risk assessment for Highway 101. This assessment is prioritizing the most vulnerable sites on Highway 101 to erosion, flooding, landslide, and sea level rise and potential adaptation strategies, including where shoreline armoring is the best solution. This work will complement the rulemaking process described above and should be completed by the spring of 2023.

DLCD will continue to work on moving forward with other recommendations from the focus group as time and resources allow.

Focus Group Meetings

Meetings of the Goal 18: Pre-1977 Development Focus Group were held every 5-8 weeks from January through August 2019 for a total of six meetings. Meeting dates and materials can be found in the table below.

Focus Group Members

Focus group members represent the various interests and expertise related to this topic, such as state agencies, non-profit groups, local planners, private property interests, coastal erosion specialists, and others as identified. They are listed below in alphabetical order by first name.


Meg Reed
Coastal Policy Specialist
Phone: 541-514-0091