March 25, 2022
California Coastal Commission
455 Market Street, Suite 300
San Francisco, CA 94105
RE: Request for Commission Action on the Point Reyes Coastal Consistency Determination (CD-0006- 20) at the April 2022 Meeting
Chair Brownsey, Vice Chair Hart and Members of the Commission:
The undersigned 122 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 put the Point Reyes Consistency Determination on the April 2022 Commission Agenda for action by the Commission, including the option to revoke the Conditional Concurrence it issued in April 2021.1The current wording of the April 2022 agenda notes the Commission will consider this matter, but it is not clear that the Commission will vote on if the NPS has produced an adequate Water Quality Strategy within 12 months as required by the Commission: “Coastal Commission consideration of Water Quality Strategy and Climate Action Plan developed by National Park Service (NPS) as specified in Conditions I and IV of the Coastal Commission’s conditional concurrence on Consistency Determination No. CD-0006-20 for the 2020 General Management Plan Amendment for Point Reyes National Seashore and the north district of Golden Gate National Recreation Area, Marin County.”
When the Commission narrowly approved Conditional Concurrence by a 5-4 vote last April, it specifically directed the National Park Service (NPS) to address serious concerns it had with topics ranging from water quality to Tule Elk to climate change. For example, the Commission added a condition that the NPS would bring a water quality strategy to the Commission within 12 months for public review and Commission review and approval.2“Condition: The National Park Service will bring its water quality strategy to the Commission within a period of twelve months for public review, as well as Commission review and approval.”
Importantly, the Commission retained oversight and jurisdiction over this condition, including independently reviewing the NPS’ water quality strategy to determine if it protects coastal resources to the maximum extent practicable, or if it should be rejected. Due to the very urgent concerns raised by the Commission and members of the public, the Conditional Concurrence required action on this matter within 12 months, which would be April 2022.
As Commission staff wrote to the NPS on May 10, 2021, “[t]he Commission determined that, only as conditioned, could the GMPA be found consistent to the maximum extent practicable with the enforceable policies of the California Coastal Management Program. The Commission notes that as provided in 15 CFR § 930.4(b), should the NPS not agree with the Commission’s condition of concurrence, then all parties shall treat this conditional concurrence as an objection.”
The NPS must be held accountable to bring forth adequate resource protection strategies within the timeframe the Commission directed, and NPS agreed to, a year ago. Development of these strategies within the one-year timeframe was fundamental to the Commission’s decision to conditionally approve the Consistency Determination and remains essential for ensuring the protection of one of the most biologically important areas in the state. Please ensure that this Point Reyes Consistency Determination is placed on the April 2022 agenda for action by the Commission, including the option to revoke the Conditional Concurrence.
Sincerely,
Chance Cutrano
Director of Programs
Resource Renewal Institute
Neal Desai
Senior Program Director, Pacific Region
National Parks Conservation Association
And the following undersigned signatories
| Bonnie Kellogg President 2 Wheel Safety Training Bonnie Robins Director Access Nature, Lewisboro Land Trust Theodora Simon Investigator ACLU of Northern California Eric Mills Coordinator ACTION FOR ANIMALS Julie Krachman Secretary/Treasurer Adiscovery Jeff Miller Executive Director Alameda Creek Alliance Theresa Harlan Director Alliance for Felix Cove Michael Garrity Executive Director Alliance for the Wild Rockies Cara Dana CEO CGDana Photography Michael Murray Chair Coalition to Protect America's National Parks Jia Li Founder Consciously be Denise Boggs Director Conservation Congress James McLachlan Director Conundrums2Solve Jason Doherty Founder/Director Daraja Education Fund Dave Rothwell Owner Dave Rothwell Photography Debbie Fier Owner Debbie Fier Photography Nancy Graalman Director Defense of Place Dene Miles Owner Dené Miles Photography Lindsay Donald Founder Donald Photography Jill Fortin Director Jay Witcher Orchestra Jennifer Hadley Owner Jennifer Hadley Photography Jim Zipp Owner Jim Zipp Photography John Comisky Owner John Comisky Photo Julie Picardi Owner Julie Picardi Photography Keith Flood Owner Keith C. Flood Photography Kimberly Baker Executive Director Klamath Forest Alliance Patricia Puterbaugh Principle Lassen Forest Preservation Group Barbara Salzman and Roger Harris Conservation Committee Co-Chairs Marin Audubon Society David Long Co-President Marin Chapter of the California Native Plant Society Douglas Punzel Operations PunzPics Tony Sehgal Media Producer Pygmy Mammoth Productions Miyoko Schinner Founder Rancho Compasion Lisa Owens Viana Director Raptors Are The Solution Rhett Taber Owner Rhett’s Wildlife Excursions Roy Dunn Owner Roy Dunn Photography Drew Feldmann Conservation Chair San Bernardino Valley Audubon Society Sandra Zelasko Owner Sandra Lee Photography Shani Kleinhaus Advocate Santa Clara Valley Audubon Society Gordon Bennett President Save Our Seashore | Dr. Ana Noles Owner Ana E Noles, PsyD Anna Cramer Owner Ann Kramer Photography Craig Elson Founder Arbor Lane Investments Christine Kittinger Vice President Assets Unlimited, Inc. Jules Evans Principal Avocet Research Associates Sally Harati Director Ban Toxic MHF Derick Carss Photographer Before it Gets Dark Birgit Winning Executive Director Bluecology Tara Thornton Deputy Director Endangered Species Coalition Thomas Wheeler Executive Director Environmental Protection Information Center-EPIC Morgan Patton Executive Director Environmental Action Committee of West Marin Robert Raven Founder everythingismc2.org Sheila Newenham President Exploring Nature Joe Sweeney Organizer ForElk Robin Chiang Executive Director Friends of Islais Creek Matt Maguire President of the Board Friends of Lafferty Park Larry Campbell Conservation Director Friends of the Bitterroot Judy Schriebman Secretary Gallinas Watershed Council Joseph III Scalia President Gallatin Yellowstone Wilderness Alliance Jennifer Valentine CEO married in the forest Michelle Waters Owner Michelle Waters Art Deb Castellana Director of Strategic Alliances Mission Blue Matthew Polvorosa Kline Founder Mission Rewild Victoria Canby Executive Director Museum of the American Indian Melissa Samet Senior Water Resources Counsel National Wildlife Federation Gerald Meral California Water Program Director Natural Heritage Institute Rene Voss Director Natural Resources Law Gary Theisen Owner Northwoods Photo William Rossiter Vice President NY4WHALES Pradip Thachile Managing Member OH Investors A Diane Gentile Founder Save Point Reyes National Seashore Kathy Kayner Secretary Save The American River Association Kerry Kriger Executive Director SAVE THE FROGS! Ara Marderosian Executive Director Sequoia ForestKeeper® Alan Carlton Chair, SF Bay Chapter Federal Lands Committee Sierra Club Nickolaus Sackett Director of Legislative Affairs Social Compassion in Legislation Shanti Zinzi Owner The Nature of the Beast Jack Gescheidt Founder The TreeSpirit Project William Given President The Wild Source Chris Brinkman President TNL Holdings inc | Mike Young Political and Organizing Director California Environmental Voters (formerly CLCV) Daniel Glusenkamp Executive Director California Institute for Biodiversity Isabella Langone Conservation Program Manager California Native Plant Society Michael Painter Coordinator Californians for Western Wilderness Jeff Miller Senior Conservation Advocate Center for Biological Diversity Lia Schnipper Co-Chair Center Reach Farm, LLC Daniel Heagerty Senior Director Generation Our Climate Laura Cremin Vice President of the Board Golden Gate Audubon Society Daniel Heagerty Executive Director Granite Chief Wilderness Protection League Bradley Angel Executive Director Greenaction for Health and Environmental Justice Shanna Edberg Director of Conservation Hispanic Access Foundation David McGuire Director Shark Stewards, Earth Island Institute Jonathan Huyer President Huyer Perspectives Photography Lisa Levinson Campaigns Director In Defense of Animals Rudi Dundas Director Innerlight Photo Mark J Palmer Associate Director International Marine Mammal Project Earth Island Institute Joan Maloof Executive Director Old-Growth Forest Network Patricia Mitchell Owner Patricia Mitchell Photography Tracy Reiman Executive Vice President PETA (People for the Ethical Treatment of Animals) Jonas Minton Senior Water Policy Advisor Planning and Conservation League Daniel Dietrich Owner Point Reyes Safaris Brian Elliot Conservation Director Pomona Valley Audubon Society Camilla Fox Executive Director Project Coyote Jeff Ruch Pacific Director Public Employees for Environmental Responsibility (PEER) Marilyn Jasper Chair Public Interest Coalition Tom Baty Board Chair Public Lands Conservancy Christine Price Founder Tribal ground Scott Webb Advocacy Manager Turtle Island Restoration Network Scott Artis Executive Director Urban Bird Foundation Nancy Valente Principal Valente Archaeological Consulting Laura Chariton President Watershed Alliance of Marin Eric Molvar Executive Director Western Watersheds Project Alison Hermance Director of Communications WildCare George Nickas Executive Director Wilderness Watch Will Tabor Owner Will Taber ornithology Max Venturi Photographer Max Venturi Photography Lisa Robertson President & Co-Founder Wyoming Untrapped |