Center for Biological Diversity * Coalition to Protect America’s National Parks * Sierra Club * Environmental Action Committee of West Marin (EAC) * Marin Audubon Society * Resource Renewal Institute * National Parks Conservation Association * Save Our Seashore * Action for Animals * Alameda Creek Alliance * All-Creatures.org * Animal Legal Defense Fund *
Animals Are Sentient Beings, Inc. * Biodiversity First! * Californians for Western Wilderness * Center for Farmworker Families * Climate Action Now! * Coalition on the Environment and Jewish Life * Committee for the Preservation of the Tule Elk * Conservation Congress * Conservation Council for Hawaii * Conserve Southwest Utah * Dorothy King Young Chapter of the California Native Plant Society *
Earth Island Institute * EarthAction * Eastern Coyote/Coywolf Research * Ecologistics, Inc. * Ecology Party of Florida * Endangered Habitats League * Endangered Species Coalition * Environmental Protection Information Center * Eyak Preservation Council * ForELK * Friends of the Black-tail Prairie Dog * Friends of the Earth U.S. * Fund for Wild Nature * Gallinas Watershed Council * Global Movement Network * Golden Gate Audubon Society * Golden West Women Flyfishers * Granite Chief Wilderness Protection League * Harvard Law School Animal Law and Policy Clinic * Hilton Pond Center for Piedmont Natural History *
Howling For Wolves * In Defense of Animals * Interfaith Council for the Protection of Animals and Nature * International Marine Mammal Project of Earth Island Institute * Kickapoo Peace Circle * Klamath Forest Alliance * Madrone Audubon Society * Marin Chapter, California Native Plant Society * MLK Coalition of Greater Los Angeles * Movement Rights * National Wolfwatcher Coalition * Northcoast Environmental Center * Northeast Oregon Ecosystems * Northwest Animal Rights Network * NY4WHALES * Ocean Voyages Institute * Oceanic Preservation Society * Old Growth Forest Network * OVEC-Ohio Valley Environmental Coalition * Patagonia * Paula Lane Action Network (PLAN) * Pelican Media * Petaluma Wetlands Alliance * Point Reyes Safaris * Predator Defense * Project Coyote
Public Interest Coalition * Public Lands Conservancy * Public Trust Alliance * Rainforest Action Network* Regional Parks Association * RESTORE: The North Woods * Sandra Lee Photography * Santa Cruz Climate Action Network * Save Our Sky Blue Waters * SAVE THE FROGS! * Shark Stewards * Social Compassion in Legislation * Spottswoode Winery, Inc. * Supporters for Del Norte Roosevelt Elk *
Tending the Ancient Shoreline Hill * The Fire Restoration Group * The Rewilding Institute * The Wildlife Trust * Topanga Peace Alliance * Turtle Island Restoration Network * Watershed Alliance of Marin * Wellkind * Western Watersheds Project *
Wholly H2O * Wild Zone Conservation League * WildCare * Wilderness Watch * WildernessPress Photography * Yellowbilled Tours
January 7, 2021
RE: Coastal Consistency Determination by the California Coastal Commission for the Proposed Point Reyes National Seashore General Management Plan Amendment CD-0006-20
Dear California Coastal Commissioners,
The NationalPark Service (NPS) is asking the Coastal Commission to fast-track concurrence with a Consistency Determination for the Proposed Point Reyes National Seashore General Management Plan Amendment (GMPA), despite inadequate information regarding coastal zone impacts and the fact that
the proposed plan and expanded agricultural activities are not consistent to the maximum extent practicable with the California Coast Management Program (CCMP).
The undersigned 98 conservation groups, environmental justice organizations, and local businesses hold diverse positions on the future role of agriculture in the Seashore, ranging from supporting to opposing the continuation of agriculture leases in the Seashore. Yet we are united in our request that the Coastal Commission Object to the Point Reyes plan at its January 14, 2021 Commission meeting. It is substantively and politically prudent for the Commission to allow time for the Commission staff and the Biden administration’s NPS to work together – free of the current political pressure – to finalize this plan.
As we outline below, this process and plan have been co-opted by the Trump administration in its waning days. There is no reason why the Coastal Commission should fast-track approval of a plan and forgo the careful consideration that Californians and Point Reyes National Seashore deserve.
- Your staff requested that the NPS extend the review deadline through the March 2021 Commission meeting, calling the extension “warranted and necessary.” In response to this request, the NPS set a deadline of January 20, 2021, signaling that the Trump administration is intent on fast-tracking the controversial and complex plan before the new administration assumes office, even if it comes at the expense of not allowing California (through its Coastal Commission) to protect its coastal resources.
- In a multi-party Settlement Agreement in 2017, the NPS, environmental groups, Seashore ranchers, and Marin County agreed that the NPS could have until July 2021 to complete the GMPA. Your staff’s request to have until March 2021 in order to fully review the plan falls squarely within this agreed upon timeframe, yet the Trump administration now wishes to prevent the Commission from conducting a careful review process.
- Your staff has reported a high level of public interest in the GMPA (e.g. Commission staff recently stating it has received more than 20,000 public comments during its review of the GMPA opposing the NPS plan for ranching at Point Reyes National Seashore and Golden Gate National Recreation Area and its spillover impacts to wildlife and other public resources in the coastal zone).
- Your staff has determined that there are significant spillover effects from proposed ranching activities in the plan related to water quality and the protection of marine resources. Your staff believes that the current GMPA is inconsistent with Coastal Act policies related to marine resources (Section 30230) and water quality (Section 30231), particularly for the Point Reyes portion of the GMPA planning area. Your staff also raised concerns that there are limited, insufficient water quality data available for Point Reyes National Seashore, where water quality standards have historically not been met in creeks and wetlands that drain into Drakes Estero, Abbotts Lagoon, and the Pacific Ocean. The efficacy of proposed best management practices and water quality protection measures for coastal resources in the GMPA are, at best, uncertain. Any water quality assessment plan including a timeline for compliance targets and enforcement measures for Point Reyes should be finalized before any decision on concurrence.
- Your staff’s concern that more time was needed to adequately review this GMPA is confirmed in the NPS Consistency Determination and the Commission staff report – both which are missing credible analyses of additional impacts to the environment and public access that will result from the GMPA, many of them with spillover effects on the coastal zone, including impacts to water quality, water quantity, and migratory birds. For example, the Staff Report states the NPS informed Commission staff that “we expect adjustments to the timing of harvest mowing to be limited.” This refers to harvest of silage, which overlaps with bird nesting season, and the NPS is stating that it won’t end the unnecessary killing of birds due to this practice. Related, the NPS highlights its lack of commitment to ensure protection of coastal resources, stating (emphasis ours) that “Approaches to minimize harvest impacts on wildlife should be considered when using this Practice Standard (e.g., harvest timing, cutting procedures, and cover patterns).” (GMPA Appendix F pg 25), yet “considerations” does not equal protection.This is just one of the many examples of the fine details within the GMPA that require additional time for careful analysis and point to why the Commission should object and let the Staff have more time to address by working with a NPS that isn’t being politically pressured.
- GMPA also lacks specificity on proposed mitigation measures; the NPS refers to this missing information as “programmatic details” which will be described at some future date and “may be subject to future review by the Commission, after site-specific actions are developed.”
The National Seashore is a keystone for California’s interconnected coastal resources. This Federal administration’s refusal to accept the Commission’s proposed timeline is an attempt to usurp the state’s ability to request additional information. It denies the Commission the time necessary to adequately analyze and evaluate how the maintenance of ranching operations and further agricultural development in these national parks will affect coastal resources for decades to come.
The Commission needs more time and information to confidently decide whether the NPS’ plan is adequate and consistent with protecting the California coast. Please object to the Point Reyes plan at the January 14 Commission meeting.
Sincerely,
| Center for Biological Diversity Randi Spivak, Public Lands Program Director Washington, DC Resource Renewal Institute Chance Cutrano, Director of Programs Mill Valley, CA National Parks Conservation Association Neal Desai, Senior Director, Pacific Region Sacramento, CA Save Our Seashore Gordon Bennett, President Inverness, CA Action for Animals Eric Mills, Coordinator Seattle, WA Alameda Creek Alliance Jeff Miller, Director Fremont, CA All-Creatures.org Veda Stram Athens, NY Animal Legal Defense Fund Cristina Stella, Managing Attorney Cotati, CA Animals Are Sentient Beings, Inc. Sarah B. Stewart, President Watertown, MA Biodiversity First! Linda Seeley, Secretary Shandon, CA Californians for Western Wilderness Michael Painter, Coordinator San Francisco, CA California Native Plant Society, Marin Chapter Carolyn K Longstreth, Board Member Mill Valley, CA Earth Island Institute David Phillips, Executive Director Berkeley, CA Eastern Coyote/Coywolf Research Jonathan Way, Founder Barnstable, MA Ecologistics, Inc. Stacey Hunt, CEO San Luis Obispo, CA Ecology Party of Florida Cara L. Campbell, Chair Ft. Lauderdale, FL Endangered Habitats League Dan Silver, Executive Director Los Angeles, CA Endangered Species Coalition Tara Thornton, Deputy Director Washington, DC Environmental Protection Information Center Thomas Wheeler, Executive Director Arcata, CA Eyak Preservation Council Carol Hoover, Executive Director Cordova, AK The Fire Restoration Group Craig Thomas, Director Garden Valley, CA ForELK Diana Oppenhiem, Founder San Francisco, CA Howling For Wolves Maureen Hackett, Founder and President Hopkins, MN In Defense of Animals Lisa Levinson, Wild Animals Campaign Director San Rafael, CA Interfaith Council for the Protection of Animals and Nature Lewis Regenstein, President Atlanta GA International Marine Mammal Project Mark J. Palmer, Associate Director Berkeley, CA Kickapoo Peace Circle Marcia Halligan Viroqua, WI Klamath Forest Alliance Kimberly Baker, Executive Director Arcata, CA Madrone Audubon Society Susan Kirks, President Sonoma, CA MLK Coalition of Greater Los Angeles Julie Levine Los Angeles, CA Movement Rights Pennie Opal Plant, Co-founder San Francisco, CA National Wolfwatcher Coalition Nancy Warren Executive Director Duluth, MN Pelican Media Judy Irving, Executive Director San Francisco, CA Petaluma Wetlands Alliance John Schribbs, President Petaluma, CA Point Reyes Safaris Daniel Dietrich, Owner Inverness, CA Predator Defense Brooks Fahy, Executive Director Eugene, OR Project Coyote Camila Fox, Executive Director Mill Valley, CA Public Interest Coalition Marilyn Jasper, Chair Loomis, CA Public Lands Conservancy Don Neubacher, Board Member Point Reyes, CA Public Trust Alliance Michael Warburton, Executive Director Mill Valley, CA Rainforest Action Network Ginger Cassady, Executive Director San Francisco, CA Regional Parks Association Amelia Wilson, President Berkeley, CA Supporters for Del Norte Roosevelt Elk Phoebe Lenhart Crescent City, CA Tending the Ancient Shoreline Hill Margot Cunningham, Head Richmond, CA Topanga Peace Alliance Julie Levine Topanga, CA Turtle Island Restoration Network Todd Steiner, Executive Director Forest Knolls, CA Watershed Alliance of Marin Laura Chariton, President Mill Valley, CA Wellkind Catriona Glazebrook, Executive Director Burlingame, CA Western Watersheds Project Erik Molvar, Executive Director Laramie, WY Wholly H2O Elizabeth Dougherty, Executive Director Oakland, CA WildCare Alison Hermance, Director of Communications San Rafael, CA Wild Horse Education Laura Leigh, President Reno, NV | Environmental Action Committee of West Marin (EAC) Morgan Patton, Executive Director Point Reyes Station, CA Marin Audubon Society Barbara Salzman, President Mill Valley, CA Center for Farmworker Families Dr. Ann López, Executive Director Felton, CA Climate Action Now! Markos Major, Director San Francisco, CA Coalition on the Environment and Jewish Life Rabbi Daniel Swartz, Executive Director Scranton, PA Coalition to Protect America’s National Parks Philip A. Francis, Jr., Chair Washington, DC Committee for the Preservation of the Tule Elk Bruce E. Keegan San Francisco, CA Conservation Congress Denise Boggs, Director Rohnert Park, CA Conservation Council for Hawaii Moana Bjur, Executive Director Honolulu, HI Conserve Southwest Utah Tom Butine, Board President St. George, UT Dorothy King Young Chapter of the California Native Plant Society Renee Pasquinelli, Conservation Co-chair Gualala, CA EarthAction Lois Barber, Executive Director Amherst, MA Friends of the Black-tail Prairie Dog David Orr, Founder and President Austin, TX Friends of the Earth U.S. Ariel Moger, Legislative and Political Coordinator Washington, DC Fund for Wild Nature Marnie Gaede, President Sebastopol, CA Gallinas Watershed Council Judy Schriebman, Secretary San Rafael, CA Global Movement Network Diana Oppenheim, Founder San Francisco, CA Golden Gate Audubon Society Laura Cremin, Vice President Berkeley, CA Golden West Women Flyfishers Cindy Charles, Conservation Chair San Francisco, CA Granite Chief Wilderness Protection League Daniel Heagerty, Director Mill Valley, CA Harvard Law School Animal Law and Policy Clinic Katherine A. Meyer, Director Cambridge, MA Hilton Pond Center for Piedmont Natural History Dr. Bill Hilton Jr., Executive Director York, SC Northcoast Environmental Center Larry Glass, Executive Director Arcata, CA Northeast Oregon Ecosystems Wally Sykes Joseph, OR Northwest Animal Rights Network Rachel Bjork, Board President Seattle, WA NY4WHALES William Rossiter, Vice President New York, NY Oceanic Preservation Society Courtney Vail, Director of Strategic Campaigns Greenbrae, CA Ocean Voyages Institute Mary T Crowley, President and Founder Sausalito, CA Ohio Valley Environmental Coalition (OVEC) Vivan Stockman, Executive Director Huntington, WV Old Growth Forest Network Joan Maloof, Executive Director Easton, MD Patagonia Hilary Dessouky, General Counsel Ventura, CA Paula Lane Action Network (PLAN) Susan Kirks, Chair, Board of Directors Petaluma, CA RESTORE: The North Woods Michael Kellett, Executive Director Concord, MA The Rewilding Institute John Davis, Executive Director Albuquerque, NM Sandra Lee Photography Sandy Zelasko, Owner Valley Center, CA Santa Cruz Climate Action Network Pauline Seales, Organizer Santa Cruz, CA Save Our Sky Blue Waters Lori Andresen, President Duluth, MN SAVE THE FROGS! Kerry Kriger, Ph.D. Laguna Beach, CA Shark Stewards David McGuire, Director Sausalito, CA Sierra Club Olga Bolotina, SF Bay Chapter Chair Berkeley, CA Social Compassion in Legislation Nickolaus Sackett, Director of Legislative Affairs Laguna Beach, California Spottswoode Winery, Inc. Beth Novak Milliken & Lindy Novak St. Helena, CA WildernessPress Photography Andrw Carothers-Liske, Owner Emeryville, CA Wilderness Watch George Nickas, Executive Director Missoula, MT The Wildlife Trust Edward S. Loosli, President Walnut Creek, CA Wild Zone Conservation League Patrick Lee Hord, Director El Cajon, CA Yellowbilled Tours Richard Cimino, Owner Larkspur, CA |