The Point Reyes National Seashore received more than 7,600 public comments during the 45-day review public review of the proposed General Management Plan Amendment Draft Environmental Impact Statement in September 2019.
The National Park Service is currently preparing the Final Environmental Impact Statement which is expected to be released this spring with a 30-day waiting period prior to a record of decision.
Public Comments may be reviewed here.
In a statement released on February 27, 2020, the National Park Service (NPS) stated,
“Public comment is a critical component of the GMP Amendment process. The NPS is reviewing all submitted comments and preparing responses to substantive comments. Some responses to comments may be reflected as edits to the text of the final EIS if needed to clarify existing information or add new information. The final EIS will contain summaries of the substantive comments and responses to those comments in an appendix. Numerous comments that repeat the same basic message will be responded to collectively. “
EAC’s comments highlighted our concerns with the draft environmental impact statement:
The Preeminent Mission of a National Park is to Conserve Natural Resources
Inconsistencies with Direction to Enable Long Term Leases for Beef and Dairy Ranching, Consistent with Applicable Laws and Planning Processes:
Direction to Issue Long-Term Leases for the Purpose of Cattle and Dairy Ranching
Direction to Issue Leases for Purpose of Multi-Generational Ranching
Inconsistencies with NEPA Requirements
Failure to Analyze Connected and Cumulative Impacts of Diversification on Environmental Resources
Diversification – Individually Reviewed Ranch Operating Agreements
Impacts of Diversification – Conflicts with Wildlife
Diversification – Vehicles, Public Safety, and Traffic Congestion
Impacts of Diversification – Visitor Experiences
Failure to Analyze Connected and Cumulative Impacts to Wilderness Areas
Boat-In Camping, Drakes Estero Marine Wilderness
Wetlands/Watershed Protection for Wilderness
Arbitrary Selection of Reduced Ranching Areas
Failure to Provide Financial Planning Analysis Necessary to Evaluate Alternative Actions
Management of Tule Elk
EAC proposed the creation of modified version of Alternative B that included:
Removal all types of diversification from the Draft Environmental Impact Statement (DEIS) consideration and programmatic planning as the DEIS does not evaluate cumulative, direct or indirect impacts, connected actions, or reasonably foreseeable outcomes of diversification.
Removal the proposed boat-in camping on the shorelines of Drakes Estero Marine Wilderness, because the DEIS fails to analyze the impacts to the Estero.
Revised development of Ranchland Zoning so that it prioritizes holistic planning areas and resource protection buffers that are connected to sensitive resources, watersheds, and wilderness areas that are within and outside of the planning area. The Ranchland Zoning also needs to consider future impacts from climate change including rising sea levels. To protect park resources these protections should be prioritized over ranching activities. Additional maps for the public should be developed that identify current restoration projects and sensitive water resources that are outside the planning area but are impacted by development within the planning area.
Impacts of climate change should be addressed as a cumulative impact as it has been analyzed in past environmental impact statements issued by the Point Reyes National Seashore. The Point Reyes National Seashore was identified in the 2018 Sea Level Rise and Storm Surge Projections for the National Park Service, as a park with potential future inundation and storm surge under four greenhouse gas emissions scenarios. The DEIS fails to address the topic and foreseeable impacts of climate change.
Development of Ranch Operating Agreements (ROAs) to be evaluated as Resource Management Plans that consider all the foreseeable impacts on park resources before the issuance of the Final EIS. This may be accomplished with a supplemental update of the DEIS so that the current impacts of specific operations of beef and dairy ranching are analyzed and to the extent that current ranching operations impair park resources, those impairments should be cured.
Keeping within the delegated authority and be consistent with the park’s purpose, NPS must focus continuation of ranching on cultural and historical significance of multi-generational beef and dairy ranching in the Seashore and should not open ranching operations through competitive bidding process to the general public. Opening the Seashore to outside operators would have significant impacts on the park’s cultural and historic values. The DEIS fails to analyze these impacts, and even fails to provide enough detail about the RFP process to say what the impacts may entail, or when they may occur.
Updated maps to include locations of NPS and rancher restoration plans for water quality, special status species, and other important plant and animal communities. These maps need to be generated for the Seashore and should inform the development of the individual maps for Ranchland zones to inform placement of Resource Protection Zones and Pasture Zones.
Revised the reduce ranching alternative to be based on the best available science and applicable legal authority.
Provide the financial budget for implementation of the GMPA so that public can understand how the Seashore will implement the GMPA and ensure the plan is fully informed and well considered.
Eliminate culling of tule elk: Consistent with the park’s management goals and directives, NPS management of tule elk would occur only to support other resource protection needs and management goals. New herds would be allowed to continue, regardless of geographic location if they do not move outside Point Reyes. Authorized animal units for each ranch would be adjusted as needed to meet residual dry matter goals. Resource protection is the highest value for the Seashore as intended by Congress in requiring the Department of the Interior to administer its Point Reyes lands “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, based upon, and supportive of the maximum protection, restoration, and preservation of the natural environment within the area,…” 16 U.S.C. Sec. 459c (6)(a) (emphasis added).
Added a requirement for numeric water quality testing of surface waters (including the wilderness area and all recreational bodies of water). The best available science on water quality in, and hydrologically connected to, many parts of the planning area are outdated by as much as 20 years. While NEPA does not require the Seashore to collect data prior to issuing a DEIS, the Seashore cannot adequately monitor mitigation measures and enforce ROA terms with extremely outdated data. Consequently, the NPS must test water quality both now, and on an ongoing basis in the future. Otherwise, the DEIS mitigation terms regarding water quality are empty promises to protect public resources.
Read EAC’s Comment Letter
EAC will continue to keep our membership engaged and up to date on the General Management Plan Amendment for Point Reyes National Seashore as things continue to develop.
