Plaintiff, a surfer, alleged viable claims against the city for violating the California Coastal Act by (a) allowing the Bay Boys (a group of local residents who threatened or engaged in violence to keep others from using the prime surfing site, Lunada Bay) to erect and keep in place a “Rock Fort” on the beach, from which they sallied forth to intimidate non-locals, and (b) knowingly allowing and approving the Bay Boys intimidation of non-locals. The Coastal Act requires a permit for any “development” in the Coastal Zone. The Rock Fort was a development, a structure within the Coastal Zone. Though the City did not build the structure, it allowed the fort to remain on the beach for 30 years when it had the ability to remove it. As the party controlling the beach, the city could be held liable to allowing the unpermitted development to remain on the beach. Also, following Surfrider Foundation v. Martin’s Beach 1, LLC (2017) 14 Cal.App.5th 238, the decision holds that activities designed to discourage or bar public access to the beach are a “development” requiring a permit, and the city could be held liable for conspiring with the Bay Boys to engage in those activities.