Today is the final day to submit public comments on the Point Reyes National Seashore's General Management Plan Amendment (GMPA) Draft Environmental Impact Statement (DEIS).
This is the last stage of public involvement, meaning it’s your last day to submit comments. TheDEIS and public comment will be used to inform the Final EIS. Your voice is needed to provide comments on the DEIS today. In order to do this, you need to let the Seashore and NPS know that they have not analyzed all foreseeable impacts in their plan.
What is the GMPA’s DEIS?
The DEIS outlines a framework in which the National Park Service (NPS) proposes to manage 28,000 acres leased to 24 families operating beef and dairy businesses in the “Ranchland Zone” within the Seashore and the adjacent Golden Gate National Recreational Area. The plan proposes these lands would be managed through four subzones categorized as Resource Protection, Range, Pasture, and Ranch Core subzones. The DEIS is required to describe the effects of the proposed activities on the natural and physical environment and the relationship of people with that environment.
The GMPA, developed through a public planning process, should protect, restore, and preserve park resources using ranch leases that ensure multi-generational, environmentally sustainable ranching that is complementary to the natural resources and visitor experiences in the park.
What Policy Guides the GMPA’s DEIS?
A critical portion of the National Environmental Policy Act (NEPA) is public review and commenting on proposed actions. Many additional laws also govern this process including, but not limited to, 54 U.S.C. § 100101 (a),
…to conserve the scenery, natural and historic objects, and wild life in the System units and to provide for the enjoyment of the scenery, natural and historic objects, and wild life in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.
The four statutory elements of 54 U.S.C. § 100502, 54 U.S.C. § 100101,
In order to save and preserve, for purposes of public recreation, benefit, and inspiration, a portion of the diminishing seashore of the United States that remains undeveloped…
and the Seashore’s Enabling Legislation (16 U.S. Code § 459c.),
Point Reyes National Seashore; purposes; authorization for establishment. “In order to save and preserve, for purposes of public recreation, benefit, and inspiration, a portion of the diminishing seashore of the United States that remains undeveloped…
In addition, the GMPA and the EIS must also align with the Seashore’s purpose statement that is the foundation for understanding what is most important about the park that states,
“Established for the public benefit and inspiration, the Point Reyes National Seashore protects a rugged and wild coastal peninsula and surrounding waters, connecting native ecosystems, enduring human history, and recreational, scientific, and educational opportunities.”
Problems with the DEIS?
Unfortunately, the DEIS prioritizes the effects on commercial lease holders of foreseeable financial market fluctuations ahead of foreseeable environmental impacts to park resources. This priority is inconsistent with Congressional direction for the Seashore.
Resource protection is the highest value for the Seashore as intended, where Congress elaborated on this statement by requiring the Department of the Interior to administer its Point Reyes lands “without impairment of its natural values, in a manner which provides for such recreational, educational, historic preservation, interpretation, and scientific research opportunities as are consistent with, based upon, and supportive of the maximum protection, restoration, and preservation of the natural environment within the area,… “16 USC Sec. 459c (6)(a) (emphasis added).
EAC finds the DEIS failed to consider the full scope of cumulative impacts to environmental resources (including direct and indirect effects) and connected actions and has discovered inconsistencies with the proposed purpose of action through the allowance of new agricultural uses and erosion of multi-generational ranching, inconsistencies with regulatory requirements and failure to consider impacts of diversification on park resources.
Specifically, EAC argues in our comments:
The preeminent mission of a National Park is to conserve natural resources.
The Seashore’s enabling legislation provided for a limited exception for beef and dairy ranching consistent with the maximum protection, restoration, and preservation of the natural environment.
The Secretary directed the NPS to work to enable longer-term leases for beef and dairy ranching, consistent with applicable laws and planning processes.
The effects of diversification on Park resources would be contrary to the Park’s mission; the DEIS exceeds its authority in proposing diversification.
The DEIS has not analyzed many connected and cumulative effects of diversification on environmental resources.
Submit Your Comments Today
We encourage you to submit comments if you have not already.
Comment deadline is 10:59 PM PST today!
To comment effectively, focus your comments on the purpose and need of the proposed action, the proposed alternatives, the assessment of environmental impacts, and proposed mitigations. Focus on what NPS overlooked, what was not considered, etc. Comments are not a form of voting for an alternative and template form letters are not useful tools at this stage.
EAC has analyzed the DEIS focused on key impacts that would impair the Seashore’s resources and provides some suggestions for comments below for EAC members to consider incorporating into their public comments.
IMPACTS of diversification:
Remove all types of diversification from DEIS consideration and programmatic planning as the DEIS does not evaluate cumulative, direct or indirect impacts, connected actions, or reasonably foreseeable outcomes of diversification.
Impacts and conflicts with wildlife predation and interference with wildlife habitat by the introduction of sheep, goats, chickens, and pigs were not analyzed.
Impacts on roads and park infrastructure with increases in commercial traffic for farm-stays, processing centers, and retail sales, were not analyzed.
Impacts to visitor experiences and development of new trails and visitor uses by the introduction of immediate allowances for diversification were not analyzed.
Impacts to the scenic and historic values of the Seashore, as the ranch cores and historic pastures will be changed to support new uses, were not analyzed.
IMPACTS TO NATURAL RESOURCES:
Revise development of Ranchland Zoning so that it prioritizes holistic planning areas and resource protection buffers that are connected to sensitive resources, watersheds, and wilderness areas that are within and outside of the Planning Area.
The Ranchland Zoning also needs to consider future impacts from climate change including rising sea levels. To protect park resources these protections should be prioritized over ranching activities. Additional maps for the public should be developed that identify current restoration projects and sensitive water resources that are outside the Planning Area but are impacted by development within the Planning Area. Previous Seashore planning documents have analyzed climate change as a cumulative impact, this DEIS does not consider climate change impacts at all.
Require development of Ranch Operating Agreements (ROAs) to be evaluated as Resource Management Plans that consider all the foreseeable impacts on park resources before the issuance of the Final EIS. This may be accomplished with a supplemental update of the DEIS so that the current impacts of specific operations of beef and dairy ranching are analyzed and to the extent that current ranching operations impair park resources, those impairments should be cured.
Add a requirement for water quality testing for wilderness and all recreational bodies of water. The best available science on water quality in many areas of the DEIS are outdated by as much as 20 years. While NEPA does not require the Seashore to collect data prior to issuing a DEIS, the Seashore cannot adequately monitor mitigation measures and enforce ROA terms with seriously outdated data. Consequently, the NPS must test water quality both now, and on an ongoing basis in the future. Otherwise, the DEIS mitigation terms regarding water quality are empty promises to protect public resources.
Update maps to include locations of NPS and rancher restoration plans for water quality, special status species, and other important plant and animal communities. These maps need to be generated for the Seashore and should inform the development of the individual maps for Ranchland Zones to inform placement of Resource Protection Zones and Pasture Zones.
To keep within the delegated authority and be consistent with the park’s purpose, the Seashore must focus continuation of ranching on cultural and historical significance of multi-generational beef and dairy ranching and should not open ranching operations through competitive bidding process to the general public.
Opening the Seashore to outside operators would have significant impacts on the park’s cultural and historic values. The DEIS fails to analyze these impacts, and even fails to provide enough detail about the RFP process to say what the impacts may entail, or when they may occur.
IMACTS TO WILDERNESS
The DEIS excludes analysis of federally listed wildlife that utilize the unique habitat of Drakes Estero stating,
“Listed marine mammals (e.g. whales, seals, sea lions, sea turtles, and abalones) may use beaches adjacent to the planning area but are not included in this analysis because ranch activities would not affect these species in the planning area…elephant seals are found immediately adjacent to ranch lands…however, ranch operations do not affect them.” (emphasis added)
This analysis fails to consider the cumulative and connected impacts of ranching activities that includes trampling, erosion, and nutrient deposits from storage and distribution of manure that flows into the creeks that drain to beaches, wetlands, and wilderness areas that are not in the planning area but are adjacent and connected by ecological functions or species movement to new areas.
The shoreline of Drakes Estero should have a 100-foot buffer from development and grazing activities, to protect sensitive resources and preserve wilderness values. The impacts of boat-in camping sites along the shores of Drakes Estero are not analyzed in the DEIS. Based on the 2012 Wilderness Designation of the estero marine system, camping site designations should be removed.
Provide the financial budget for implementation of the GMPA so that public can understand how the Seashore will implement the GMPA and ensure the plan is fully informed and well considered.
Eliminate culling of tule elk: Consistent with the Park’s management goals and directives, NPS management of tule elk would occur only to support other resource protection needs and management goals. New herds would be allowed to continue, regardless of geographic location if they do not move outside Point Reyes. Authorized animal units for each ranch would be adjusted as needed to meet residual dry matter goals. Resource protection is the highest value for the Seashore as intended by Congress in requiring the Department of the Interior to administer its Point Reyes lands “without impairment of its natural values, in a manner which provides for such recreational, educational, historic preservation, interpretation, and scientific research opportunities as are consistent with, based upon, and supportive of the maximum protection, restoration, and preservation of the natural environment within the area,…” 16 USC Sec. 459c (6)(a) (emphasis added).
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