A few years ago, I saw a fairly extensive report prepared by the TDC for the County on access points and right of way locations along the entire beach. You might request to see this if anyone can locate. Very informative, pictures, locations, etc. It is also amazing to see the number of public beach access points and right of ways that were blocked with anything from a fence, pool or even a building. Perhaps the right of ways might transfer to public access points or clarify right of public use. That might get you up to that bigger number. This could really open up a bag of worms, so some may be in no hurry to find or clarify. For example, could a condo be asked to remove a fence it has built between its building and the next that blocks a public beach access or right of way?
I am also familiar with the report you are talking about which is one reason why the TDC now has about 50 beach accesses from the mid-20's in 2004. Unfortunately, a lot of the perceived beach accesses were for utilities and other uses instead of County easements for pubic use and access. Additionally, some were abandoned a long time ago in County Commission minutes, or were perceived as publically-owned areas but in reality were privately-owned and have been converted into existing parcels like the ones that we have discussed in Blue Mountain.
That being said, new ones are adequately documented and added to the TDC list every year. For example, this year one was added on Scenic Gulf Drive at the south end of Geronimo Street.