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California Coastal Commission Cd-0006-20 STATE OF CALIFORNIA - NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR CALIFORNIA COASTAL COMMISSION 455 MARKET STREET, SUITE 300 SAN FRANCISCO, CA 94105-2219 FAX (415) 904-5200 TDD (415) 904-5400 Th3a CD-0006-20 (National Park Service) April 22, 2021 CORRESPONDENCE (received as of March 26, 2021) Individual Members of the Public Part II CD-0006-20 (NPS) CORRESPONDENCE - INDIVIDUALS PART II - pg 2 December 7, 2020 To: California Coastal Commission RE: The Consistency Determination for the National Park Service Point Reyes National Seashore 2020 General Management Plan Amendments The National Park Service (NPS) at the Pt. Reyes National Seashore (PRNS) has submitted for your review a Federal Consistency Determination for the adoption of amendments to the Seashore’s General Management Plan (GMP) and the accompanying Final EIS, which will be discussed during your meetings in January. We strongly urge the Commissioners to reject the NPS submittal because it misrepresents consistency of the GMP with the California Coastal Act with respect to Section 30251 Scenic and visual qualities: The scenic and visual qualities of coastal areas shall be considered and protected as a resource of public importance. Permitted development shall be sited and designed to protect views to and along the ocean and scenic coastal areas, to minimize the alteration of natural land forms, to be visually compatible with the character of surrounding areas, and, where feasible, to restore and enhance visual quality in visually degraded areas. New development in highly scenic areas such as those designated in the California Coastline Preservation and Recreation Plan prepared by the Department of Parks and Recreation and by local government shall be subordinate to the character of its setting. After living abroad for 15 years, we were excited to return to the Bay area and all that it has to offer. One of our favorite activities is to spend a day at Point Reyes National Seashore to enjoy the beautiful natural habitat and wildlife. We have made numerous visits to the park over the past two years, and find portions of the visit to be disappointing and disturbing. We visit a national park to be immersed in nature, but often find ourselves driving through what appears to be a barren wasteland. This is the case for most of the drive along Pierce Point Road on the way to the Tomales Point Elk Reserve. The view consists of Confined Animal Feeding Operations, trodden and barren dirt and/or weeds, areas filled with manure, miles of barbed wire fencing, and farm related buildings in various states of repair. This is not the view we expect to see in a National Park. In fact, we find the experience to be depressing and an example of extremely poor stewardship of the land. Although we haven’t visited the entire park, we wonder if it is even possible to enjoy any of the coastal areas without being confronted with the stark views caused by the dairy and beef operations located within the park. By law, the NPS is mandated to manage all national parks in a manner which provides maximum protection, restoration and preservation of the natural environment for generations to come. This is certainly not taking place on the land that one must view on the drive to Tomales Bay. Please see photos below: CD-0006-20 (NPS) CORRESPONDENCE - INDIVIDUALS PART II - pg 3 Stark Views Along Pierce Point Road - Sep, 2020 Stark Views Along Pierce Point Road - And Strong Manure Odor - Sep, 2020 CD-0006-20 (NPS) CORRESPONDENCE - INDIVIDUALS PART II - pg 4 Stark Views Along Pierce Point Road - Sep, 2020 Stark Views Along Pierce Point Road - Sep, 2020 CD-0006-20 (NPS) CORRESPONDENCE - INDIVIDUALS PART II - pg 5 Stark Views Along Pierce Point Road - Nov, 2020 In January of this year, we had the good fortune to attend a PRNS field trip led by Laura Cunningham, California Director of Western Watersheds Project. We learned that the barren and degraded landscapes that we view within PRNS are due to the grazing of cows. The barren and/or weed covered land that we view within the park should be covered in native coastal prairie, valley grassland, and coastal scrub. Ms. Cunningham also discussed the rare and biodiverse coastal prairie ecosystem. This native habitat contributes to the wellbeing of native animals and protects the soil from erosion. We also learned that the cattle areas are not only absent of native grasses, but the vast amounts of manure produced by the cows pollutes the streams, beaches and ocean. We should be protecting natural habitat within a National Park for the enjoyment of visitors and also preserve the natural environment. Below are photos taken during the field trip: CD-0006-20 (NPS) CORRESPONDENCE - INDIVIDUALS PART II - pg 6 Non-Native Weeds In The Areas Containing Cows CD-0006-20 (NPS) CORRESPONDENCE - INDIVIDUALS PART II - pg 7 An Unsightly Confined Animal Feeding Area View Across to Large Cattle Operation Showing Non-Native Plants CD-0006-20 (NPS) CORRESPONDENCE - INDIVIDUALS PART II - pg 8 A Small Area Of Undisturbed Native Plants CD-0006-20 (NPS) CORRESPONDENCE - INDIVIDUALS PART II - pg 9 Native Grasses and Shrubs Point Reyes National Seashore is the only national Seashore on the West Coast of the United States. It is a natural treasure that should be maintained as a haven for wildlife and wild habitat. The public should be able to visit this National Park to be immersed in nature without having to be confronted by scenes of destruction caused by agricultural operations. CD-0006-20 (NPS) CORRESPONDENCE - INDIVIDUALS PART II - pg 10 What We Expect To See in PRNS What We Expect To See in PRNS CD-0006-20 (NPS) CORRESPONDENCE - INDIVIDUALS PART II - pg 11 We strongly urge the Commissioners to reject the NPS submittal because it misrepresents consistency of the GMP with the California Coastal Act with respect to Section 30251 Scenic and visual qualities. Thank you for your consideration. Susan & Dennis Fischer 2735 Cherry Lane Walnut Creek, CA 94597 CD-0006-20 (NPS) CORRESPONDENCE - INDIVIDUALS PART II - pg 12 James Coda 2009 Falcon Ridge Drive Petaluma, CA 94954 December 7, 2020 VIA EMAIL California Coastal Commission 455 Market Street, Suite 300, San Francisco, CA 94105 Re: Agenda Item CD-0006-20 (NPS, Point Reyes GMPA); Coastal Consistency Determination for the Point Reyes National Seashore and North District Golden Gate National Recreation Area General Management Plan Amendment and Environmental Impact Statement Dear Commission Members: I. INTRODUCTION. I am very concerned about the water quality problems that exist in Point Reyes National Seashore (PORE) and Gate National Recreation Area (GOGA) with respect to Agenda Item CD-0006-20. These problems existed when the National Park Service (NPS) acquired the lands for these two national park units and there has never been any significant improvement. Conditions today are completely unacceptable for coastal watersheds, especially for coastal watersheds in units of the national park system. The Commission should object to what the Park Service plans to do to these parks.1 I am a retired attorney and starting in 2010 I have spent about two days each month photographing wildlife in the ranching area of PORE. Before my retirement I was an Assistant U.S. Attorney in the Northern District of California (San Francisco) where I handled environmental and natural resources cases for the United States. The most common case I would handle would involve NEPA. I started my career as an attorney in the Department of the Interior in Washington, D.C. and later transferred to its legal office in San Francisco. In San Francisco I handled mostly Park Service matters. One of the first matters I recall handling was a suit filed by a PORE rancher in 1978 to stop the reintroduction of the tule elk into PORE. The suit was dismissed. II. DISCUSSION. CD-0006-20 will violate the following sections of the Coastal Management Program: 1 Seashores and recreation areas are to be managed to the same standards as national parks. NPS Organic Act, 54 U.S.C. § 100101. Bicycle Trails Council of Marin v. Babbitt, 82 F.3d 1445, 1451- 1454, (9th Cir. 1996). CD-0006-20 (NPS) CORRESPONDENCE - INDIVIDUALS PART II - pg 13 Section 30230 Marine resources; maintenance Marine resources shall be maintained, enhanced, and where feasible, restored. Special protection shall be given to areas and species of special biological or economic significance. Uses of the marine environment shall be carried out in a manner that will sustain the biological productivity of coastal waters and that will maintain healthy populations of all species of marine organisms adequate for long-term commercial, recreational, scientific, and educational purposes. (Emphasis added.) Section 30231 Biological productivity; water quality The biological productivity and the quality of coastal waters, streams, wetlands, estuaries, and lakes appropriate to maintain optimum populations of marine organisms and for the protection of human health shall be maintained and, where feasible, restored through, among other means, minimizing adverse effects of waste water discharges and entrainment, controlling runoff, preventing depletion of ground water supplies and substantial interference with surface waterflow, encouraging waste water reclamation, maintaining natural vegetation buffer areas that protect riparian habitats, and minimizing alteration of natural streams. (Emphasis added.) The Legislature also made certain findings regarding the coastal management program. In section 30001 it found that the coastal zone is a valuable
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