The California Coastal Commission (CCC) reviewed the National Park Service’s (NPS) amendment to the Point Reyes National Seashore’s General Management Plan (GMPA) on Earth Day on April 22nd. EAC participated along with public officials and agencies, nonprofit organizations, and individuals that expressed serious concerns or support of the GMPA.
The hearing kicked off with a CCC staff presentation of the GMPA submission for review and explanation of CCC staff recommendations. NPS followed with their perspective, goals, and objectives of the plan. Following the staff presentations, elected leadership spoke in support of the CCC Staff Report recommendations that included Congressman Jared Huffman, Marin County District 4 Supervisor Dennis Rodoni, California Assemblymember Mark Levine, and California Senator Mike McGuire.
Following elected representatives, more than twenty organizations provided public testimony that was followed by hours of individual public comments that were dominated by concerns with the plans impacts to public lands, water quality, and tule elk management. Public comments lasted through the afternoon and were followed by deliberations, discussion, and questions by the CCC to NPS about the GMPA. The CCC focused on water quality concerns and the tule elk management plan.
At the end of an almost 12 hour day, the CCC voted by a narrow margin (5 to 4) to approve the federal consistency plan after adding three new requirements for NPS.
Background: Consistency Determination
EAC has been engaged in the public process with the CCC since November 2020 leading up to the previously scheduled January 2021 consistency hearing. We submitted two comment letters and had several phone calls with CCC and NPS staff regarding our concerns with the GMPA and provisions and protections for water quality.
Learn more about the CCC Consistency Determination process and jurisdictional authority.
eac’s Coastal Commission Strategy
Our primary goal in this stage of the public process was focused on building additional agency oversight to protect water quality and increase public transparency.
We started this process back in November prior to the release of the December 2020 CCC staff report. In January, we advocated for the CCC and NPS to delay the hearing to April to allow additional time for CCC staff review of the plan. We were pleased the CCC hearing was moved to April 2021 and dug in on reviewing areas under the CCC jurisdiction to protect water quality and increase public transparency.
In the March 2021 CCC staff report, several of the new recommendations were items we advocated for, including: require the submission of a water quality plan to be approved by the CCC Executive Director prior to the issuance of leases; an annual report to the CCC that included details on installed and planned best management practices; and requirements to specify timelines and who is responsible for installation and maintenance of these items.
All of these items are important for the public to know whether the plan is being implemented at the level that NPS stats.
These were all excellent requirements; however, we knew more needs to be done and did not want to miss out on additional public input in the plan at the CCC level.
So we worked with our partners at the National Park Conservation Association to coordinate our oral testimony to present four key points. Our goal, get the attention of one or more of the Commissioners and provide them with the tools to do more with their limited review.
EAC’s Testimony Focus:
1) Delay new types of ranching (diversification) until NPS receives the funding and is able to implement best practices for beef and dairy operations.
Our Concern: During the GMPA process we have highlighted several lease violations to NPS for authorized beef and dairy ranches. Diversification will add other livestock to the ranchlands; rather than adding new uses that will compound problems, wait until the funding has been received so that NPS can manage it all.
2) Eliminate uniform 20-year leases to all ranchers; rather, implement a lease contingency checklist that would evaluate the history of tenancy and the future plans related to water quality protection to determine appropriate length of lease.
Our Concern: Length of lease should be matched to a rancher’s intentions and plans on public lands. If ranchers have implemented water quality protection through infrastructure, habitat restoration, and reduction of livestock, those actions could be rewarded with longer-term leases.
National Parks Conservation Association Testimony Focus:
3) Require the water quality proposal in the staff report return to the CCC for public review, input, and CCC approval.
Our Concern: This is the main strategy that NPS will use to manage water quality in the ranchlands zone. The public should be part of this process to provide input and feedback that the strategy is appropriately designed.
4) Limit the CCC Conditional Concurrence Determination to five years and return to the CCC for another hearing.
Our Concern: As proposed by staff, the CCC Conditional Concurrence would be good for 20 years; due to the complexity of the plan and changing environmental conditions, there is a need for a check in 2026 to ensure NPS is on track as they outlined in the GMPA. If something is not working, then this affords an opportunity to change and provides the public with an opportunity to discuss the plan.
Commission’s New Conditions in Addition to Staff Recommendations
Commissioner Hart picked up on our joint testimony and after hours of deliberation and discussion, the CCC was supportive of limiting its approval to less than 20 years, bringing the water quality plan back for CCC review, eliminating diversification, and revising the elk management plan. Not all of these items advanced, as NPS indicated that eliminating diversification and revising the elk management plan were something they would not agree to.
At the end of the day, the CCC ended up with three new conditions that NPS agreed to include:
1) Return to the CCC in five years to check in on the status of the plan.
CCC Legal advised that the Conditional Concurrence could not be limited to five years. Therefore, NPS and CCC agreed that returning for a status update and check in would be beneficial.
2) Return to the CCC with the Water Quality proposal for review.
This will allow the public to review the proposed plan to ensure that it is comprehensive and provide additional feedback.
3) Return to the CCC at the time of the Water Quality proposal to submit a climate change strategy proposal for review.
We are encouraged by this development; however, we remain concerned that we will see an increase in diversification of operations proposals due to the drought and economic conditions. We are opposed to diversification that could further impair the park’s natural resources.
Next Steps
EAC is pleased with the new inclusions by the CCC, specifically that an additional regulatory agency will be included in the implementation of the GMPA in the future. This ensures opportunity for additional public input and feedback over the course of the implementation of this plan.
The CCC picked up on 2 of the 4 items we publicly testified for and we were close on delaying implementation of diversification. Commissioner Hart asked for complete removal of diversification from the plans, ultimately, NPS would not agree to delaying diversification.
The GMPA continues to have issues and we have serious concerns about the plan for elk management, and the impacts to the land, water, and character of the Seashore in the future related to beef and dairy ranching.
At the CCC hearing, Seashore Superintendent Kenkle reported to the CCC that the Seashore had issued a notice to one rancher to remove his cattle and infrastructure from NPS pastures. We are hopeful that NPS is planning on using the GMPA as intended to enforce the rules and regulations of the leases now and into the future with established guidance for the preservation of natural and cultural resources and the management of infrastructure and visitor use in the planning area.
We expect NPS to file the Record of Decision in the coming months and will keep our EAC community updated and informed.
