Drakes Estero, State Marine Conservation Area that borders pasture and range sub-zones.
December 8, 2020. Photograph by Morgan Patton.
The Point Reyes National Seashore's General Management Amendment (GMPA) Final Environmental Impact Statement (Final EIS) is set for review by the California Coastal Commission (Commission) for a federal consistency determination on January 14, 2021.
The Commission makes a consistency determination when a federal agency activity affects the coastal zone. The federal agency submits a project description and analysis of the activity's coastal zone effects based on the policies of Chapter 3 of the California Coastal Act (Coastal Act) that is reviewed by Commission staff and Commissioners.
At the November 2020 Commission meeting, Jack Ainsworth, Commission Executive Director, provided a GMPA Final EIS consistency determination update to the Commissioners including:
The National Park Service (NPS) submitted consistency paperwork on October 16, 2020 that would have required a deadline of December 31, 2020 to meet its statutory requirements.
The Commission sent a letter on October 23, 2020 requesting an extension to March 23, 2021, as four-weeks was not enough time to review and plan a special meeting in light of the enormous public interest in this matter.
NPS replied at the end of October that they would agree to extend the deadline to January 20, 2020.
Ainsworth noted, “you can all guess why they have [selected] that date, why that is important to the administration.”
Some of eac’s initial concerns:
Leading up to the Commission consistency determination, EAC is currently fully engaging in this process including the submittal of a letter and public testimony last week at the Commission meeting.
The GMPA Final EIS raises several environmental concerns and fails to adequately protect coastal resources. Sections 30230 and 30231 of the Coastal Act require the Commission to find that the proposed actions provide special protection of areas of special biological significance, like Drakes Estero Marine Wilderness, Abbotts Lagoon, and Drakes Bay.
The Final EIS not only fails to meet that heightened standard, but fails also to meet the basic requirement that the biological productivity of these waters be maintained, and, where feasible, restored.
In order to be consistent to the maximum extent possible with the relevant coastal management policies, the Final EIS must minimize adverse effects through enforceable mitigation measures, implemented in a timely manner, accompanied by ongoing scientific monitoring and data collection to assess their effectiveness. The Final EIS fails to apply this standard.
We are deeply concerned that NPS is setting up an unattainable goal for proposed operational mitigations that assume to reduce adverse impacts of ranching without any realistic ability to enforce those standards once this process is finalized. Plans are just plans if there is no way to implement them.
Finally, this process is rushed. Based on the amount of public interest in this plan, it is unfortunate, to say the least, that the consistency determination must be made before the new federal administration takes office on January 20th. The decision to rush this review is political and not based on science, policy, or in the public interest.
consistency determination timeline
We expect the Commission’s staff report to be released Friday, December 18, 2020.
The Public meeting will take place on January 14, 2021.
Public comments on the staff report will be due the Friday before, on January 8, 2021.
HOW TO GET INVOLVED
We will be sending out an action alert to our members with suggestions and applicable Chapter 3 Coastal Act policies that NPS failed to address in future emails.
We encourage anyone concerned about the GMPA Final EIS to submit their personal comments (not form letters) to the Commission during this process to ensure the protection of the irreplaceable coastal resources we treasure.
LEARN MORE ABOUT THE COASTAL COMMISSION’S ROLE
In the meantime, below are important links on this process provided by the Commission to bring you up to speed on the process, what to expect, and how to best craft your comments in order to make the most impact based on the applicable policies of the Coastal Act.
Cows in Abbotts Lagoon. November 29, 2019. Photograph by Sarah Killingsworth.
Tule Elk, Point Reyes National Seashore. November 17, 2020. Photograph by Morgan Patton
