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May 5, 2022

Tomales Point Area Plan
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes Station, CA 94956

To Whom It May Concern:

We appreciate the opportunity to comment on the Tomales Point Area Plan (TPAP). Tomales Point is an area that has remarkable wilderness qualities. The area is also highly used by the public for solitude and access to the western shore of Tomales Bay. We appreciate being able to comment on this pre-scoping of the proposed area plan.

The Point Reyes National Seashore (PRNS) legislation and National Park Service (NPS) Policies provide guidance for development of the TPAP and for our comments regarding the proposed plan.

§ 459c-6. Administration of property
(a) Protection, restoration, and preservation of natural environment

Except as otherwise provided in sections 459c to 459c-7, . . . the property . . . shall be administered by the Secretary 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 … the maximum protection, restoration, and preservation of the natural environment within the area, subject to the provisions of sections 1, 2, 3, and 4 of this title … and in accordance with other laws of general application relating to the national park system as defined by sections 1b and 1d of this title….5

NPS Management Policies (2006; Wilderness Management Planning)

These policies state: “The superintendent of each park containing wilderness resources will develop and maintain a wilderness management plan or equivalent planning document to guide the preservation, management, and use of these resources. The wilderness management plan will identify desired future conditions, as well as establish indicators, standards, conditions, and thresholds beyond which management actions will be taken to reduce human impacts on wilderness resources.

In evaluating environmental impacts, the National Park Service will take into account (1) wilderness characteristics and values, including the primeval character and influence of the wilderness; (2) the preservation of natural conditions (including the lack of man-made noise); and (3) assurances that there will be outstanding opportunities for solitude, that the public will be provided with a primitive and unconfined type of recreational experience, and that wilderness will be preserved and used in an unimpaired condition. Managers will be expected to appropriately address cultural resources management considerations in the development and review of environmental compliance documents impacting wilderness resources.”

54 U.S.C. § 100502

“General management plans for the preservation and use of each System unit, including areas within the national capital area, shall be prepared and revised in a timely manner by the Director. On January 1 of each year, the Secretary shall submit to Congress a list indicating the current status of completion or revision of general management plans for each System unit. General management plans for each System unit shall include—

(1) measures for the preservation of the area’s resources;(2)indications of types and general intensities of development (including visitor circulation and transportation patterns, systems, and modes) associated with public enjoyment and use of the area, including general locations, timing of implementation, and anticipated costs;(3)identification of and implementation commitments for visitor carrying capacities for all areas of the System unit; and(4)indications of potential modifications to the external boundaries of the System unit, and the reasons for the modifications.”

Director’s Order #41: Wilderness Stewardship

6.2 Wilderness Character

The Wilderness Act (16 U.S.C. 1133(b)) directs that “each agency administering any area designated as wilderness shall be responsible for preserving [its] wilderness character.” Wilderness character is the combination of biophysical, experiential, and symbolic ideals that distinguishes wilderness from other lands. The five qualities of wilderness character are (1) untrammeled, (2) undeveloped, (3) natural, (4) offers outstanding opportunities for solitude or primitive and unconfined recreation, and (5) other features of scientific, educational, scenic, or historical value. Accordingly, each wilderness park will integrate the concept of wilderness character into park planning, management, and monitoring in order to preserve the enduring benefits and values of wilderness for future generations. Whenever a park planning process that has the potential to affect wilderness character occurs, the park should determine how wilderness character can be both integrated into the planning effort and presented in the planning document. As a foundation, wilderness parks should develop a wilderness character narrative which describes what is unique and special about a specific wilderness, organized by each of the qualities of wilderness character.

6.3 Wilderness Planning

For every designated wilderness, a Wilderness Stewardship Plan will guide management actions to preserve wilderness character. Parks should notify the WASO Wilderness Stewardship Division Chief and work with their Regional Wilderness Coordinator during the Wilderness Stewardship Planning process. Parks with lands determined to be eligible, proposed, or recommended should also develop plans to preserve wilderness character. Wilderness Stewardship Plans should be completed within two years of designation, subject to funding. Preservation of wilderness character will be incorporated into appropriate sections of park planning and management documents. Also see Management Policies 2006, Section

Our specific comments follow:

  1. As stated in 54 U.S.C. § 100502, general management plans for the preservation and use of each System unit shall be prepared and revised in a timely manner by the Director. With this statute in mind, we believe the TPAP has segmented the requirement to develop a timely, updated, and comprehensive GMP. Segmentation occurs when an action is broken down into small parts to avoid the appearance of the significance of the total action. An action can be too narrowly defined, minimizing potential impacts to avoid a higher level of impacts. Because the 1980 Point Reyes General Management Plan (GMP) is almost 40 years old (and required by law to be updated), amending this outdated document by focusing primarily on Tomales Point will mislead the public and not meet requirements of the National Environment Policy Act. For example, visitation, facilities such as parking, historic features, special status species numbers, and abundance, and water quality standards have all dramatically changed since 1980. In turn, the 1980 GMP did not consider NPS Management Policies that were significantly updated in 2006. And, the NPS Director’s Order regarding wilderness stewardship was updated in 2013. Because of these issues, the public cannot fully understand what changes are being made to the 1980 GMP because a complete document with changes has not been produced. A full GMP process would be required to fully understand management direction, based on updated policies, previous park actions such as new facilities, and the impacts of these new actions and their cumulative actions.
  2. The PRNS does not have a wilderness plan as required by policy and law. However, overall 85% of the TPAP proposed planning area is designated wilderness and will have direct, indirect, and cumulative impacts on wilderness values throughout the park’s 30,000 plus acres of wilderness. We believe additional data and baseline information need to be collected to ensure the overall Philip Burton Wilderness Area is managed to maintain its wilderness character, as required by law. At present, the lack of a comprehensive wilderness plan and baseline information (desired future conditions, measurable and monitored indicators, monitoring plan, wilderness character description, and standards) makes the characterization of cumulative indirect and direct impacts on wilderness values impossible.
  3. We are concerned about how cumulative impacts will be addressed. Without baseline data regarding the rest of the park and adjacent areas, it seems impossible to quantify these impacts from all the changes. The existing GMP data is limited and outdated; thus, the TPAP will have to update baseline data such as economic, air quality, and climate change impacts to fully address cumulative impacts. The CEQ regulations (40 CFR §§ 1500 -1508) define the cumulative impacts and effects that must be addressed and considered by Federal agencies in satisfying the requirements of the NEPA process. This includes direct, indirect, and cumulative impacts: Cumulative impact is the impact on the environment, which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions. Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time. (40 CFR § 1508.7)
  4. All long-term strategies to manage the elk populations should be in the context of NPS policy and law as are other natural resources within PRNS. It has to be a comprehensive plan covering the entire park, including other wilderness areas outside of Tomales Point. Tule elk at Point Reyes should be managed in the context of the overall population level and not just the Tomales Point area. We strongly believe the continuation of a managed tule elk herd is important ecologically (restores natural processes as directed in NPS policies and park legislation) and provides for enjoyment for park visitors. In addition, we do not believe the park has sufficient data to set a carrying capacity number at this time. The park’s legislation directs protection and restoration of the natural environment as the highest priority for park management. Overall carrying capacity for tule elk should be established in the park for the entire park, including areas that do not have elk populations, and scientifically based.
  5. As stated NPS policy and law require superintendents to “identify visitor carrying capacities for managing public use. Superintendents will also identify ways to monitor for and address unacceptable impacts on park resources and visitor experiences.” We recommend the TPAP address carrying capacity for this area and the entire park. Park visitation increased dramatically from 2020 to 2021, 2.0 to 2.8 million visitors respectively.
  6. Recreational use along the shoreline and within the waters of Tomales Bay should be evaluated in the TPAP to see if it’s meeting the requirements of the Wilderness Act.

We appreciate the opportunity to comment. Thank you for your public service in maintaining and preserving our precious parks.


Tom Baty
President, Public Lands Conservancy
Box 696
Point Reyes Station, CA 94956

Michael Murray
Chair, Coalition to Protect America’s National Parks
2 Massachusetts Ave NE, Unit 77436
Washington, DC 20013