Now Comes the Hard Part
In April, the California Coastal Commission unanimously rejected the National Park Service’s (NPS) Water Quality Strategy and Climate Action Plan for Point Reyes National Seashore as inadequate and sent the NPS back to the drawing board.
This Thursday, September 8, Commissioners will revisit the NPS’s newly submitted plan.
The Resource Renewal Institute will be traveling to Pismo Beach (Central Coast) to speak in person at the CCC meeting. We’re counting on you to have our back. Please call in to the meeting via Zoom to ask the Coastal Commissioners to reject the NPS plan as written.
The deadline to sign up to speak is TODAY, Wednesday, September 7 at 5pm.
Public testimony on Thursday is limited to two minutes per person.
Delivering a Water Quality Plan is not in itself the assignment the Commissioners imposed on the NPS when they gave conditional approval of National Park Service’s GMPA last year. The assignment is—or should be—to comply with the California Coastal Act. As written, the NPS Water Quality Plan falls short.
Now comes the hard part.
Since April, the National Park Service has faced a daunting to-do list from numerous state agencies that have launched investigations into operations at Point Reyes National Seashore. The Mercury News reported yesterday that independent water testing had again revealed that fecal bacteria from cattle manure at levels hazardous to public health was found in five waterways at the Seashore. Today, the Marin Independent journal reported that Marin County Environmental Health Services has, after investigating sewage dumping and leaks at a number of dairy ranchers in April, identified a growing list of environmental health and safety violations at seven ranching complexes across the National Seashore. And, curious, on the Coastal Commission agenda now states: “The Commission’s enforcement division has opened an investigation into potential Coastal Act violations associated with this site.”
Despite these outstanding environmental and regulatory concerns—and their funding and staffing constraints—the latest NPS Water Quality plan continues to prioritize the survival of 17 Seashore ranches over public health, wildlife and protection the California coast.
The plan lacks clear goals and timelines for meeting them, leaving government officials, ranch lessees, and the public in the dark about what “success” looks like.. It’s unclear whether the NPS proposal will be funded, or by whom; when, or if, it will be implemented; or when—if ever—water quality compliance will be attained.
Here’s what’s needed to strengthen the Water Quality Plan:
- The NPS plan is required to comply with Section 30231 of the California Coastal Act, which states “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, prevent depletion of groundwater supplies and substantial interference with surface water flow.” There is no discussion of restoration efforts in the NPS water quality strategy for the planning area. The Biden and Newsom administrations have called for implementation of nature-based solutions across our public lands to restore biodiversity and combat climate change. The NPS is silent on how these efforts apply to Point Reyes National Seashore. The public and the environmental community are calling for stronger commitments to Restore Point Reyes.
- The NPS strategy lacks public transparency. The NPS does not make public the ranch leases, which would help park advocates and Coastal Commissioners assess whether or leases include clear and enforceable stipulations for resource protection. In addition, the NPS plan does not explicitly require the disclosure of water quality testing results to allow for oversight of NPS progress on their proposed strategy. The public and the environmental community are calling for the CCC and the NPS to publish the NPS’s annual report and for staff to provide an oral report to the CCC at the Coastal Commission meeting immediately following the submission of the annual report.
- Is the Commission or the public willing to accept on faith that the NPS will have the funding needed to implement the plan? The NPS has yet to provide the Commission or the public a funding plan to ensure the growing list of compliance issues will satisfactorily be resolved in a reasonable timeline to protect coastal resources and public health.
- The Commissioners required the NPS to provide a “Climate Action Plan” to address the climate-related impacts of ranching operations at Point Reyes National Seashore. That plan was not discussed at the April 2022 Commission meeting due, in part, to a lack of a staff report to help Commissioners analyze the efficacy of the NPS’s plan. To date, there has been no analysis of the NPS Climate Action Plan, and the CCC staff has quietly accepted the plan. This plan, like the water quality plan, has no goals or timelines for meeting them. The Climate Action Plan still deserves public scrutiny and a review by Commissioners and Commission staff.
At this point, only the State of California can hold the NPS accountable. Commissioners are pledged to represent the public interest in protecting the coast. Commissioners must consider the NPS’s past performance and ensure that the NPS’s proposal is specific, effective, and will be implemented. If this isn’t possible, the Resource Renewal Institute asks that the Coastal Commission reject the NPS Water Quality Strategy.
Today is the deadline to sign up to speak at the Commission’s hearing on the NPS plan. We anticipate the Commission will vote on the plan following public comment, on Thursday, September 8, at around 11:00 AM PT.
Your voice is needed. With thanks, always, for your support for Point Reyes Seashore.