EAC Recommends the Water Quality Strategy NOT BE APPROVED unless changes are made.
The National Park Service (NPS) released their much anticipated Water Quality Strategy (Strategy) for public review and approval by the Coastal Commission (Commission) on September 8th regarding the Point Reyes National Seashore.
The Strategy is a required Condition of the Commission’s Federal Consistency Determination from April 2021 to ensure the General Management Plan Amendment (GMPA) is consistent with the enforceable policies of California’s Coastal Management Program–Chapter 3 of the Coastal Act–to protect, enhance, and restore marine resources, sensitive habitat, maintain healthy populations of species and biological productivity and quality of coastal waters, streams, wetlands, estuaries, and lakes.
The submitted Strategy focuses on monitoring, developing strategies to improve water quality, implementation timelines, updating lease conditions to include water quality protection best management practices, and annual reviews of operational practices.
EAC has reviewed the Commission Staff Report and the National Park Service (NPS) Strategy, spoken with staff from the Regional Water Quality Board, NPS staff, Commission Staff, and other environmental partners and submitted comments requesting the Commission to NOT APPROVE the Strategy unless changes are made.
As we reviewed the submitted Strategy, we are focused on whether the submitted Strategy satisfies the conditions of the Federal Consistency Determination; if there are any gaps or inconsistencies; and to ensure the Strategy will meet ongoing needs for water quality sampling and monitoring over the next 10-20 years to protect water quality.
Consistent with the Commission Staff’s recommendation, we have asked the Commissioners to take a hard look and make additional recommendations prior to approving the plan, as this is likely the last opportunity for the public and the Commission to weigh in on what’s included.
The Seashore has been experiencing deficiencies in infrastructure and operational capacity to manage manure and wastewater for decades. It’s critical the Commission emphasize the importance of conducting long-term monitoring based on the current conditions with fecal indicator bacteria and require adjustments to protect Coastal Resources in the short-term and long-term.
HOW YOU CAN HELP
Public Participation
The public is encouraged to comment on the submitted Strategy to offer feedback to the Commission on how the Strategy can be improved. The public may also comment at the meeting on September 8th remotely or in-person.
Sign up here to speak virtually at the Commission meeting.
See EAC’s Concerns below for suggested talking points to the Commission.
Volunteer
EAC is looking to train volunteers to assist with the off-season recreational water quality sampling at Drakes Beach and Drakes Estero from November 2022 through March 2023.
If you are interested in helping, submit an application today!
EAC’s Concerns AND SUGGESTED TALKING POINTS TO COASTAL COMMISSION:
The Coastal Commission should consider requesting the NPS to include the below items in order to satisfy Sections 30230 and 30231 of the Coastal Act and increase public transparency in the implementation of the GMPA:
Require all Conditions to be satisfied that were agreed to in the 2021 Consistency Determination and in 2022 Coastal Commission Meetings.
To improve public transparency and trust, require the NPS update its GMPA webpage to include: the annual report submitted to the Commission, links for water quality results, copies of leases, Ranch Operating Agreements, and other reports and information regarding ranching operations and agency actions. This is important so that the Commission and the public can understand in real-time what actions are being made to implement the Strategy.
Include copies of the Ranch Operating Agreements; maps of pending and completed projects; and regulatory limits for water quality results in all tables, graphics, and charts in the annual report to the Commission to improve public transparency and understanding of the actions being made in the implementation of the GMPA.
Expand the Strategy to define, improved water quality, and the milestones the Strategy seeks to achieve in 5 years, 10 years, and 20 year timelines. Essentially, what is the baseline (current conditions) and what water quality targets is the NPS trying to achieve with the GMPA, lease requirements, and Ranch Operating Agreements?
Commit to retaining long-term sampling metrics in the Strategy. Retaining metrics over time ensures comprehensive long-term monitoring and flag issues with any changed conditions (environmental and operational).
Require reductions in animals if existing operational infrastructure fails to meet regulatory water quality standards. For example, if a dairy is unable to support the current number of animals due to failing manure management systems, the number of animals should be reduced to the current system capacity until after remedial measures have been implemented and reviewed to protect coastal resources and water quality.
Request the NPS outline the process for the annual operational ranch inspections, who is present, which partner regulatory agencies will be participating, and when those inspections will occur each year.
Clarify what happens if an operator consistently fails to meet regulatory and GMPA standards as outlined in their lease agreement. As the Strategy notes, updated leases that are being signed include regulatory requirements for water quality, but it is unclear what actions the NPS will take if those standards are not met as those leases are not finalized and not available for public or commission review.
