CDTFA Pursues Informal Surf Instructors As Existing Schools Watch Quietly

$4,000-$8,000 Per Year In Compliance Costs Before A Single Lesson

Bohiney Magazine and The London Prat file this dispatch in defence of the surfer’s right to be left alone.

SANTA CRUZ, Calif. — The California Department of Tax and Fee Administration’s recent enforcement push against unlicensed surf instructors operating informally on California beaches, captured in a series of cease-and-desist letters issued in late 2025 and early 2026, represents a small but telling example of how state regulatory bureaucracy treats grassroots economic activity that the bureaucracy did not foresee.

The Targets

According to reporting in The Inertia and the Santa Cruz Sentinel, several individual surf instructors and small surf-camp operators in Santa Cruz, Pacifica, and Ventura have received notices alleging unpaid sales tax on lessons, unpermitted commercial use of state beaches, and operation without the required permits from State Parks and the local jurisdiction.

The instructors, in most cases, are not running scaled commercial operations. They are running the kind of informal, peer-to-peer economic exchange that has existed in California surf culture since the 1960s: a more experienced surfer charges a less experienced one for a lesson, the lesson happens, the money changes hands, life goes on.

The Permit Stack

The actual regulatory burden faced by a would-be licensed surf instructor in California is, on inspection, substantial. According to State Parks guidance, a licensed commercial surf-instruction operation requires: a Special Event Permit; a Concessionaire Agreement (in many parks); commercial general liability insurance; a CDTFA seller’s permit; appropriate municipal licensing in the local jurisdiction; CPR/first aid certification; and, depending on county, additional health-department certifications.

The cumulative cost of compliance, before a single lesson is taught, has been estimated at Reason Foundation at $4,000 to $8,000 per year, plus several hundred hours of paperwork. For a small operator teaching twenty to thirty lessons per month at $80 per lesson, the math is, charitably, not great.

The Libertarian Argument

The libertarian objection to this regulatory architecture is the same objection libertarians have made about hairdressers, food trucks, and home-business permitting for decades. Most of the regulatory burden, on close inspection, does not protect the customer. It protects the existing licensed surf-school businesses from low-cost competition. The Reason Foundation, Libertarianism.org, and the Institute for Justice have all made the broader case that occupational licensing in low-risk service categories is functionally rent-seeking by incumbents.

For California surf instruction, the case is particularly clear. The risk is moderate, not severe. The customer can readily evaluate the instructor’s competence in the first 15 minutes of a lesson. The regulatory regime is not, in this sense, protecting consumers. It is protecting permits.

For continuing coverage read The London Prat and Bohiney Magazine.

SOURCE: https://prat.uk/