The Problem

The GMPA will guide the management of the ranchland areas for the next two decades. It is essential that any permitted ranching activities protect water quality. The California Coastal Commission has limited authority in this review (they do not have jurisdiction on actions on federal lands), as they may only address impacts that affect the coastal zone. This includes protecting water quality for a marine wilderness areas, recreational beaches, and surface waters including creeks.

The Coastal Commission staff reviewed the GMPA Final Environmental Impact Statement (Final EIS) and has made important recommendations that would install accountability, improve transparency, and establish important timelines that will aide in protecting water quality if ranching activities continue in the park.

We want the Coastal Commission to Support the Conditional Concurrence and include additional conditions to protect water quality.

COASTAL COMMISSION CONDITIONS

The staff report recommends the Commission approve the proposed action (the GMPA) with new conditions that incorporate relevant, enforceable policies of the California Coastal Management Program that consists of primarily Chapter 3 policies of the Coastal Act.

The Commission staff proposed several new conditions to protect water quality including the requirement of assessment plans and protections for creeks and discharges that would require approval of the Commission's Executive Director prior to the issuance of new leases to ranchers that are summarized below:

Develop a strategy and timeline for assessing and improving water quality through installation of ranching-related infrastructure and management practices in areas of the GMPA that includes the Tomales Bay Watershed, Abbotts Lagoon, Drakes Estero, and other watersheds that drain to the Pacific Ocean;

Develop a sampling methodology to collect water quality data and strategies comparable to existing water quality standards by the Regional Water Board and Environmental Protection Agency;

Submit an annual report to the Coastal Commission that reports on the water quality monitoring results, and the measures taken and planned to address water quality issues in the leased ranchlands and environmentally sensitive areas that includes responsible parties, funding, timelines, and schedules for implementation; include the mitigations and practices implemented from the same year that would provide a measurement of actual implementation strategies over time; and include the results of the continuing or proposed mitigation and best management practices of water quality monitoring of ranchlands.

ADDITIONAL CONDITIONS NEEDED

We appreciate the time and effort of the Commission staff to thoughtfully develop conditions for concurrence seeking to improve mitigations and practices to protect water quality.

We support the staff recommendations and request additional conditions to be included if ranching is going to continue in the Seashore that will mitigate adverse environmental impacts, uphold lease accountability, protect public health, and increase transparency so that the public can ensure management decisions are based on science and performance indicators.

1. LEASE ELIGIBILITY must be DETERMINED history of actions AND FUTURE INTENTIONS

Missing from the recommendations is a transparent process to determine eligibility and length of the leases. Lease terms should only be extended based on a history of lease compliance and future intentions that improve water quality and restore environmentally sensitive habitat areas. Existing leasing authorizations allow for 10 year extensions. Ranchers with a history of lease violations and non-compliance that impair water quality should not receive 20-year leases, and should only earn longterm leases through demonstrated lease compliance.

2. Protect Public Health and Notice Impaired Water Bodies

The Final EIS outlines high fecal coliform counts in Drakes Bay and Abbotts Lagoon. These areas of biological significance are impaired by excessive nutrient loading and fecal coliform from beef and dairy ranching activities within watersheds. Based on the presence of pathogens in recreational water bodies, NPS should notice impaired recreational water bodies following the first annual rainfall of 1-inch or more to protect public health. Current and past water quality sampling supports this predictive noticing and is in the interest of the public.

3. Phased Implementation of Diversified Activities

EAC remains strongly opposed to any diversification activities in the Seashore; however, the Coastal Commission does not have jurisdictional authority to review these activities unless the activities affect the coastal zone. We are concerned some diversified activities may impair water quality and the Seashore lacks sufficient resources to implement the plan. Therefore, we request NPS to delay diversification of operations until they have additional funding and trained staff to implement the GMPA. NPS should not introduce new uses until they have sufficient staffing to protect coastal resources from beef and dairy ranching first.

4. LIMIT CONDITIONAL CONCURRENCE approval TO TEN YEARS

Due to the complicated nature of implementing the GMPA and the 20 year lease timeline, we recommend that the Coastal Commission authorize the conditional approval for 10 years. This will help to protect water quality, as NPS must return to the Commission to address any deficiencies within implementation of the plan and allow for necessary adjustments based on current climate change prediction models.

Action Alert: What You Can Do

Submit comments to the Coastal Commission
by 5pm on April 16th.

Updated May 4, 2021: Submit Comment button removed as comments closed April 16, 2021 5pm.

Point Reyes National Seashore, Drakes Estero Marine Wilderness

PROCESS NOTES

The Commissioners are not bound to the recommendations in the Staff Report.
After public comments are received by the Commission, an addendum to the report may be released before the hearing on April 22nd.
If the Commission agrees with the Staff Report and NPS does not agree to the conditional concurrence, it will be treated as an objection. An objection does not preclude NPS from moving forward with the plan.
Learn more about the Federal Consistency Process here.