The Park Service is submitting this Coastal Consistency Certification in compliance with

Consistency Regulations (Title 15 Code of Federal Regulations Part 930).

As required by 15 CFR § 930.57(b), we have concluded that the proposed Management

Plan complies with the enforceable policies of California’s approved management program

and will be conducted in a manner consistent with such program. The environmental impact

statement included with the management plan provides the basis for the finding and is

incorporated by reference.

The implementing regulations of the CZMA and the policies of the California Coastal

Commission apply to lands within coastal zone boundaries and to activities conducted

outside the coastal zone that may affect lands within the coastal zone. The GMP includes

actions and programs in both categories.

The GMP contains a mixture of general and specific actions and proposals. This

consistency determination evaluates all these in as much detail as is presently available.

Some actions, programs, and proposals will need additional federal consistency

determinations in the future when site-specific information is available.

Under Section 307 (c) (3)(A) of the Coastal Zone Management Act (CZMA), 16 USC

Section 1456 (c) (3)(A), federally permitted activities that effect any land or water use or

natural resource of the coastal zone are required to be consistent with the affected state's

coastal management program.

The standard of review for federal consistency determinations consists primarily of the

principal component of the California Coastal Management Program (CCMP), namely the

policies of Chapter 3 of the Coastal Act. Section A(6) of the Introduction to the CCMP also

states, that, once incorporated into the CCMP, certified Local Coastal Programs (LCPs) "will

certified and incorporated into the CCMP provides development standards that are

applicable to the project site, the LCP can provide guidance in applying Chapter 3 policies in

light of local circumstances. If the Commission has not incorporated the LCP into the

CCMP, it cannot guide the Commission's decision, but it can provide background

information.

The Commission has certified LCPs for areas in both Humboldt and Del Norte counties that

are relevant to management of RNSP.

The General Management Plan is intended to provide comprehensive guidance for

managing the resources and visitor use of RNSP. The purpose of the plan is to provide an

overall direction for resource preservation and visitor use in RNSP and a basic foundation

for decision making for the next 15 to 20 years. More detailed implementation plans will be

prepared for actions and programs to be tiered off the GMP/EIS. Some actions and

programs might affect the coastal zone and will require additional federal consistency

determinations and Commission review.

General actions typically undertaken in national parks that will occur throughout RNSP and

within the coastal zone are protection, preservation, and interpretation of natural and

cultural resources, and providing access to the full spectrum of resources to enhance visitor

enjoyment and understanding of RNSP.

This part of the consistency determination summarizes Park Service actions and programs

that may occur in or affect the coastal zone, followed by more detailed descriptions of each

actions or program in relation to specific coastal policies.

The major programs outlined in the GMP that are subject to consistency determination

because they occur in or affect lands in the coastal zone include:

I . Management Zoning, including Marine Management Zone

2. Watershed Restoration, including Management and Restoration of the Redwood Creek

Estuary

3. Vegetation Management

4. Cultural Resource Management

5. Public Use, Recreation, and Visitor Safety

6. Facility Development

RNSP is divided into nine management zones that describe the desired resource conditions

and visitor experience, and the type of facilities allowed (pp. 22-32; Alternative I maps a, b,

c). The coastal zone boundary overlaps all the management zones, except the Bald Hills

zone, at some location in RNSP. The management zones provide guidance for managing

areas in which the GMP makes no specific proposals or for resolving issues for resource

management and visitor use that arise in the future. Different degrees of development and

allowable uses distinguish the zones.

The developed and high-standard transportation zones are intended to have concentrated

development and heavy use. Developed zones have been restricted to as small an area as

necessary to provide essential services. Park Service facilities in the coastal zone that are

identified as developed zones are the Crescent Beach Education Center, the Redwood,

Hostel at Wilson Creek, the Requa maintenance facility, and the Redwood Information

Center. U. S. Highway 10 1 along the coast is in the high standard transportation zone. The

highway is owned and managed by the California Department of Transportation (Caltrans)

and is not subject to proposals in the GMP. The Park Service will continue to work closely

with Caltrans to ensure protection of the redwood forests in the highway corridor and that

travelers on the highway would have a world-class scenic travel experience.

The GMP describes a marine management zone, all of which lies within the coastal zone

boundaries. The marine management zone includes 3,627 acres in Del Norte County and

2,312 acres in Humboldt County of coastline and ocean waters lying between the mean

high water line and extending westward one-quarter mile to the Congressionally established

national park boundary. This zone is dominated by marine forces and processes, which will

be allowed to continue unhindered by management action. The desired visitor experience

within the marine management zone varies widely, depending on the proximity to other

management zones. Visitors to the coastline in RNSP may experience a range of conditions

varying from areas that have never been altered by human beings (steep cliffs in the

primitive zone and offshore rocks in the marine management zone) to areas developed

specifically for visitor use (Redwood Information Center in the developed zone).

The majority of park lands in the coastal zone that lie inland of the marine management

zone are included in the primitive or backcountry zones. The primitive zone is intended to

include lands that are in essentially natural condition and where low use is desirable to

protect resources. No facilities or development other than existing trails will be allowed in

this zone.

Backcountry zones are intended to preserve resources in a pristine state while allowing for

primitive developments to serve visitors. There are two subcategories of backcountry zone,

mechanized and non-mechanized. The two backcountry zones are distinguished primarily

by whether mechanized forms of visitor transportation such as mountain bikes are allowed

on trails (backcountry mechanized). Unpaved trails, primitive campgrounds and camping

areas, and walk-in picnic areas are allowed in the backcountry zones. The Coastal Trail

south of Enderts Beach, and the Nickel Creek, DeMartin, and Flint Ridge primitive

campgrounds are zoned as backcountry mechanized. In frontcountry zones, resource

protection takes precedence over development. A full range of facilities to serve visitors is

allowed in frontcountry zones but resources must be the dominant feature. Crescent Beach

and Enderts Beach are frontcountry zones, as are the Lagoon Creek picnic area, the High

Bluff overlook along the Coastal Drive south of the Klamath River, and Freshwater Spit.

The cultural zone is applied to areas whose primary resources are archeological, historical,

or ethnographic properties, or cultural landscapes, or where the intended use is associated

with American Indian traditions. The area south of the Klamath River mouth and the mouth

of Redwood Creek and its estuary are major cultural zones within the coastal zone.

This program involves removal of, and projects to control erosion on, abandoned roads to

prevent excessive sedimentation of park streams and degradation of aquatic resources

caused by road erosion and failure (pp. 33-37, 48, 58). The majority of actions under this

program will take place outside the coastal zone in the Redwood Creek basin, but lands and

resources that lie downstream in the coastal zone would be affected. The Redwood Creek

estuary in the coastal zone is affected by the watershed restoration program upstream, as

well as being directly affected through restoration proposals described in the GMP. The

watershed restoration program will have a beneficial effect on the Redwood Creek estuary

and other lands in the coastal zone through reduction of excess sediment that would

otherwise move downstream and be deposited into the estuary to the detriment of the

wildlife and anadromous fish habitat and the estuarine wetlands.

Restoration of the Redwood Creek estuary will require coordination among many agencies

and property owners (pp. 58). The GMP describes a range of proposals that would restore

the estuary to varying degrees (pp. 299-304). Flood control levees along Redwood Creek

have altered the physical and biological functioning of the estuary. This has resulted in

decreased water circulation, fewer deepwater pools, decreased extent of wetlands and

riparian habitat, deteriorated water quality, degraded juvenile rearing and adult holding

habitat for fish, and reduced wildlife and invertebrate abundance and diversity. The estuary

is critical to the survival of coho salmon, chinook salmon, and steelhead, all federally listed,

proposed, or candidates for listing under the Endangered Species Act. The estuary and its

tributaries are also important habitat for coastal cutthroat trout, a federal candidate for listing

as threatened. When there is insufficient flow in Redwood Creek to break through the sand

berm at the mouth, the water levels rise in the estuary and cause flooding on adjacent

private agricultural land. Repeated breaching of the sand berm to protect private property

during the summer months when fish use the estuary for holding and rearing adversely

affects the biological and physical functioning of the estuary.

The Park Service proposes to lead the effort to restore the functions of the estuary, which

will require coordination and cooperation among private landowners and numerous public

agencies. Strategies to be considered for restoration include combinations of land

acquisition from willing sellers, conservation easements, partial levee removal, and

restructuring affected roads and drainage structures. Water level management (e.g.

controlled breaching of the sand berm and channel manipulation) to conserve salmonid

habitat by preventing the negative effects of an uncontrolled natural breach and to protect

the Redwood Information Center would continue.

The major vegetation management programs are management of second growth forests,

prairie and oak woodland restoration, fire management, and exotic plant control. Actions

that would occur in the coastal zone include control of exotic plant species and restoration

of native dune communities at Freshwater Spit, and restoration of other naturally occurring

plant communities. The majority of vegetation management actions occur outside the

coastal zone but could indirectly affect the coastal zone through restoration of large-scale

ecosystem processes.

The fire management program includes both suppression of wildland fires and use of

prescribed fire to meet resource management objectives. Most fire management actions

occur outside coastal zone boundaries in the drier interior areas of RNSP. Prescribed fire is

being used as a tool primarily to restore native plant communities in which fire was an

important ecological process.

Archeological sites, historic structures, cultural landscapes, and ethnographic properties will

be preserved, protected, and managed under Applicable Park Service laws, regulations,

policies, and guidelines (pp. 268-271). For any actions that might affect cultural resources,

the Park Service will consult with the California State Historic Preservation Office in

compliance with the 1995 Programmatic Agreement among the National Conference of

State Historic Preservation Officers, the Advisory Council on Historic Preservation, and the

Park Service, or with the Yurok Tribal Historic Preservation Office for properties within

aboriginal Yurok lands.

Several cultural resource properties listed on the National Register of Historic Places are

located within the coastal zone, including the World War II Radar Site B-71 along the

Coastal Drive south of the Klamath River, and portions of the Coastal Drive itself (the former

Redwood Highway) north of the Klamath River. Areas within the coastal zone of

ethnographic significance to local American Indians include Crescent Beach, Enderts

Beach, the mouth of the Klamath River, the mouth of Redwood Creek, and several coastal

prairies.

Facilities to serve visitors or RNSP administrative needs are allowed in all management

zones, with the most intensive development allowed in developed zones and no new

development or new uses allowed in primitive zones other than existing trails.

Visitor facilities include visitor centers, trailheads, trails, camping areas and campgrounds,

picnic areas, scenic overlooks, roads and parking areas, and comfort stations. Visitor

facilities within the Coastal Zone are located at the Redwood

Information Center, Freshwater Spit, High Bluff Overlook, primitive campgrounds at Flint

Ridge, DeMartin Prairie, and Nickel Creek, the Crescent Beach picnic area, the Klamath

River overlook at Requa, the Lagoon Creek picnic area and trailhead, and several overlooks

and parking areas along the Coastal Drive. The Yurok Brush Dance site on the south bank

of the Klamath River estuary is also within the coastal zone.

Park Service administrative facilities located within the coastal zone include the Requa

maintenance area and park headquarters in Crescent City.

The Park Service proposes to expand the park trail system and to engage in coordinated

planning with other agencies for a regional trail system with links between park trails and

trail systems outside the park (p. 67). A major goal of the trail program is to develop trail

links between the California Coastal Trail and inland trails. Trail and backcountry

management plans currently being prepared might require future federal consistency

determinations for trail construction and backcountry use management proposals that are

located in or affect use of lands in the coastal zone.

Two visitor centers located in the coastal zone provide information, orientation, and

interpretive services to park visitors-the Redwood Information Center at the southern end of

RNSP near Orick and the Crescent City information center in the Park Service headquarters

building in Crescent City near the northern end of RNSP.

The Redwood Information Center is located on the beach south of the mouth of Redwood

Creek and north of Freshwater Spit. New scientific information developed since the center

was constructed in the mid-80s suggests that the earthquake and tsunami hazard from the

Cascadia subduction zone located several miles offshore is much greater than was

anticipated based on knowledge of earthquake faults at the time of construction (pp. 63-64).

Thus, the center is located in a coastal high hazard zone and is subject to a greater

potential hazard than the center was designed to withstand. The center is also subject to

damage from changes in the course of Redwood Creek that were not anticipated at the time

of construction because the sand berm at the mouth of the creek had been regularly

breached to prevent flooding of private agricultural land.

If the Redwood Information Center is significantly damaged by future events, its functions

would be relocated to a new visitor center to be situated somewhere in the vicinity of Orick

out of the tsunami zone. The present site of the visitor center would be converted to a

day-use area with interpretive opportunities including exhibits, beach access, and

boardwalks to improve access to the beach and the estuary for persons of all physical

abilities.

The information and orientation services at the Crescent City information center would

continue until incorporated into a multi-agency visitor center if one is developed in the

Crescent City area (p. 64).

Freshwater Spit is the southern gateway to RNSP (pp. 67-68). The spit was stabilized and

widened with fill when U. S. Highway 10 1 was rerouted onto the spit in the 1950s. Caltrans

once planned to add two additional lanes to make a 4-lane highway but currently has no

plans for a 4-lane road at this location. The fill area of the spit is a highway right-of-way

owned by Caltrans and has been used for many years for overnight camping, primarily by

recreational vehicles.

In the early 1980s after the expansion of the national park, the Park Service agreed to

manage the overnight camping to protect park resources and values. The Park Service

leased the area from Caltrans. Overnight use is allowed along a 1.5-mile-long strip of fill

parallel to the west side of U.S. Highway 101. There is a 15-consecutive-day camping limit,

with a 30-day annual limit. No fee is charged although a $7 donation is requested. Park

Service policies require that a certain level of facilities, including drinking water, must be

provided if a camping fee is charged. The overnight use results in sanitation and public

safety problems which the Park Service manages by providing portable toilets, garbage

dumpsters, and law enforcement patrols.

During the summer months, the entire length of the spit is occupied by overnight users.

Overnight use degrades resources and detracts significantly from the outstanding visual

qualities of the area by blocking the view of the beach and ocean. Merchants in the local

community of Orick believe that the campers at Freshwater Spit contribute significantly to

the economy of Orick through purchases of gas, food, and supplies. Private RV park owners

in the area believe that allowing free camping constitutes unfair competition with their

businesses.

The Park Service proposes to change the use of Freshwater Spit from overnight to day use

to provide all visitors with the opportunity to enjoy the outstanding scenic values and to

improve public health and safety. Site-specific planning and design will be required to

implement the proposal, which will require additional consistency review. The new facility

would be developed to include structured parking, safe access to the highway, pedestrian

access to the beach, and appropriate interpretive exhibits and support facilities. Overnight

use would be phased out over a 3-year period to allow the private sector the opportunity to

develop replacement camping facilities nearby. A fee would be charged for overnight use

during the phase-out period.

Vehicles are operated on federally administered beaches at Freshwater Spit and north, of

the mouth of Redwood Creek at Hidden Beach (Humboldt County), and in Del Norte County

at the mouth of the Klamath River and Crescent Beach (pp.. 68-69). This off-road vehicle

use occurs in violation of Park Service regulations that apply service-wide. Vehicle use at

Crescent Beach is subject to a Del Norte County permit system but the other beaches are

presently open to all properly registered vehicles capable of driving on soft sand. Vehicles

are required to stay on the wave slope of the beach to avoid damaging native dune

vegetation. Vehicles can cross Redwood Creek during those times when the sand berm

prevents the creek from reaching the ocean or when the creek is low enough to allow safe

crossing.

Some of the vehicle use is by commercial fishermen fishing for surf fish and smelt in

accordance with the provisions of the legislative history of the 1968 legislation that

established Redwood National Park. Other vehicles travel on the beaches for recreational

activities such as sportfishing, beachcombing, and wood gathering, or for access for

traditional American Indian uses. Removal of wood from the beaches is facilitated by

off-road vehicle access. While limited wood gathering for the purpose of campfire wood

collection is allowed under Park Service regulations, off-road vehicle access facilitates

removal of large pieces of woody debris for commercial purposes. Large woody debris on

beaches in the Northwest provides shelter, nutrients, hiding places, perches, and nesting

habitat for numerous species of wildlife. Wood also plays a key role in energy dissipation

during storms and promotes the entrapment and retention of sand and the formation of

dunes. These natural functions and processes are disturbed when large woody debris is

regularly removed from the beaches after storms.

The Park Service proposes to enforce its service-wide regulations (3 6 CFR 4. 10)

prohibiting off-road vehicle use in national parks, resulting in elimination of all off-road

vehicle use other than that which is essential to provide access for commercial surf fishing

activities (p. 69). These regulations are based on the requirements of Executive Orders

11644 and 11989 which established policies and constraints to protect the resources found

on federal public lands from the adverse effects of off-road vehicle use.

Because of the provision in Redwood National Park's legislative history, off-road vehicle use

associated with commercial fishing will be phased out over the long term, rather than

eliminated immediately. Off-road vehicle use associated with commercial surf fishing at

Freshwater Spit and Crescent Beach would continue by renewable, nontransferable annual

permit only. Only permits issued between March 1996 and September 1, 1999 would be

renewed. No new permits will be issued. Any permit not renewed in a given year will be

terminated. Off-road vehicle use of beaches in connection with traditional American Indian

cultural/religious activities consistent with the purposes of the parks will continue only at

Gold Bluffs Beach in Prairie Creek Redwoods State Park.

The purpose of eliminating off-road vehicle use on federally owned or administered beaches

is to maintain consistency in managing Park Service units, to protect a nationally significant

natural setting and resources, and to reduce public safety and public use conflicts that result

from vehicles and pedestrians using the same beach.

The GMP proposes minor changes to several public roads located in the coastal zone.

Changes to road design that might affect resources or use of lands in the coastal zone will

require additional federal consistency review.

Enderts Beach Road provides 24-hour public access to the Crescent Beach picnic area, the

Crescent Beach scenic overlook, a trailhead for the Coastal Trail, and the Nickel Creek

primitive campground (pp. 66, 71).

At Crescent Beach, there is paved road access, a small parking area, restrooms, and a

handicapped-accessible boardwalk and picnic area. The parking area, portions of the road,

and the restrooms are located in a former wetland, and are occasionally flooded during

intense rainy periods.

Enderts Beach Road would continue to provide public access to the Crescent Beach

overlook and the trailhead for the Coastal Trail leading to Nickel Creek. campground. The

overlook and nearby facilities have been subject to vandalism, generally after dark. Both the

Park Service and local agencies have offered rewards for information, but with little effect on

the frequency or severity of the vandalism. Gating the road and/or conversion to day use

has been suggested but would occur only as a last resort if efforts to resolve public use

issues were unsuccessful.

The picnic area and beach access at Crescent Beach would be retained (p. 66). To protect

the coastal wetlands, the access road, restroom, and parking area would be relocated out of

the wet areas to a non-wetland site within walking distance. Options for retaining access to

the beach for visitors, including those with disabilities, and for interpreting the coastal

wetlands and ponds would be considered during site planning.

Changing the vehicle access to Enderts Beach Road or redesigning the Crescent Beach

picnic area will require site-specific planning and will be subject to additional consistency

review.

This road would be improved to provide access to trails, a picnic area, and Alder Camp

Conservation Center (p. 71). Commission review for federal consistency would depend on

the degree of improvement and associated development that is proposed.

Portions of this road lie within the coastal zone in Prairie Creek Redwoods State Park.

These portions of the road will remain unpaved, as well as portions outside the coastal zone

that are presently unpaved (p.71). Minor improvements will be made to facilitate access by

two-wheel drive passenger vehicles.

Drainage and surface improvements will continue to be made on the Coastal Drive (p. 72).

The road will remain unpaved. Major road failure would lead to conversion to a trail.

The Park Service primary maintenance facility is located in the former Air Force Radar

Station at Requa. This facility lies about 800 feet above sea level in a geologically unstable

area within the coastal zone. This facility and associated utilities would continue to be

upgraded and improved to meet current codes. If the structural integrity of the buildings or

the safety of the occupants is significantly threatened by geological instability, the

maintenance functions would be relocated and the site restored (p. 74).

Park Service housing at Crescent Beach will be removed when no longer needed as

housing and the site restored with native vegetation.

This section summarizes the policies in the Humboldt and Del Norte County LCPs that are

relevant to management of RNSP.

The Del Norte County LCP was certified in 1983. This plan will be revised as part of the

county General Plan revision process currently underway. Policies in the 1983 LCP that are

relevant to the GMP are access, protection of sensitive coastal habitats, recreation, hazard

areas, and visual quality. Management of Park Service lands as guided by the GMP is

maximally consistent with these policies.

for protection of sensitive coastal habitats described on pages 60-70 of the Del Norte

County LCP. Sensitive habitats listed on page 49 in the LCP that are within RNSP

boundaries are the offshore rocks and islands, tidepools throughout the rocky coastline, the

Klamath River estuary, wetlands and ponds in the coastal dune region at Crescent Beach,

riparian systems associated with the coastal streams and creeks, and sea cliffs and bluffs.

These sensitive habitats are protected by laws, regulations, policies and guidelines

governing Park Service areas.

The LCP directs heavy recreational use of beaches to sandy beaches rather than to

tidepool areas which are susceptible to disturbance (LCP p. 62). Tidepools in RNSP are

protected by Park Service regulations prohibiting collecting, except for one gallon per

person per day of unoccupied seashells. Offshore rocks are protected under existing Park

Service regulations prohibiting collection as well as under the state regulations protecting

rocks lying within the Area of Special Biological Significance (pp. 176-177). The GMP does

not propose any development or visitor use of the offshore rocks, although recreational use

is not prohibited. The difficulty of access combined with the danger of approaching the rocks

due to wind, waves, and currents provide general protection from recreational use of the

rocks. Page 80 of the LCP identifies boating as a popular recreational activity on the Smith

and Klamath Rivers but not on the ocean. The GMP is consistent with the LCP for protection

of tidepools and offshore rocks.

The LCP notes on page 61 that a 1977 study found that vehicular traffic on tidal flats at

Crescent Beach resulted in significant mortality to sand beach organisms. Thus, the Park

Service proposal to prohibit off-road vehicle use of Crescent Beach except by permit for

commercial fishing is consistent with the LCP.

The LCP identifies the Sandmine Road ponds as important wetlands (LCP p. 64) and calls

for a 100-foot buffer around adjacent development (LCP p. 66). The ponds near the

Crescent Beach picnic area are part of the same system. The GMP calls for removal of

some facilities out of the area adjacent to the pond and wetlands while retaining access to

the sandy beach. Redesign of the existing development at Crescent Beach proposed in the

GMP will require site-specific planning and design and will be subject to additional federal

consistency review. This proposal is consistent with the LCP.

The LCP notes on page 68 that sea cliffs and bluffs are inherently unstable and potentially

hazardous when associated with development. Park Service development along the cliffs is

limited to the Coastal Trail south of Enderts Beach and to the Coastal Drive south of the

mouth of the Klamath River. The Coastal Drive will be converted to a trail if it fails (p.72). No

direct access to the coast from unstable sea cliffs or bluffs is proposed in the GMP. The

Park Service Requa maintenance site is a former military site constructed in the 1950s and

is known to be located on unstable ground (GMP p. 74, LCP p. 225). The GMP proposes

that the maintenance functions be relocated if and when land movement threatens the

integrity of the structures or safety of the occupants (p. 74). LCP policies listed on page 68

for construction on unstable areas apply to new construction. No new construction on sea

cliffs or bluffs is proposed. The GMP is maximally consistent with the LCP with respect to

policies for sea cliffs and bluffs.

recreational opportunities.' County goals for recreational development listed on page 7 7 are

well-distributed facilities, maintenance of areas for future recreation, low-cost facilities, and

protection of fragile coastal resources. The GMP proposals are maximally consistent with

these goals and with the recreation policies listed on pages 83 and 84 of the LCP.

Page 79 of the LCP identifies off-road vehicle and pedestrian use of beaches as a notable

recreational use conflict, which the county manages through closure of South Beach during

the summer months. The Park Service proposal to reduce potential pedestrian/vehicle

conflicts on Crescent Beach through enforcing its regulations prohibiting general

recreational off-road vehicle use on park beaches and to manage off-road vehicle access

for commercial fishing by permit during a long term phase-out period is consistent with this

policy and the county recommendation on pages 86 and 87 of the LCP.

It is county policy to encourage improved and increased access in the national park (LCP p.

82) while preserving and enhancing scenic and environmental values. Management of

federal lands and waters under the Park Service statutory mission to preserve resources

while providing for visitor enjoyment of those resources and under goals specific to RNSP

(GMP p. 22) is maximally consistent with these policies. A more specific county recreational

policy found on page 83 is establishment of a regional trail and path system to link Crescent

City to the national park. The GMP proposal that the RNSP trail system be expanded

through links to trails in gateway communities and other jurisdictions to create a regional

trail system (p. 67) is maximally consistent with the county policy.

Hazard Areas--GMP proposals are consistent with LCP policies listed on pages 230-233.

Park Service policies and guidelines for managing risk in floodplains, coastal high hazard

zones, and geologically unstable areas are essentially equivalent to the county policies.

Tsunami information for visitors and park staff who visit or occupy hazardous areas is being

developed, and RNSP staff are working closely with county emergency services agencies to

plan for evacuation in case of earthquakes and tsunamis. The US Army Corps of Engineers

identified a critical erosion hazard area in RNSP along a mile of coastal cliffs south of False

Klamath Cove (LCP p. 218). The GMP proposes no new development in this area but does

propose retention of the existing section of the Coastal Trail.

the GMP is maximally consistent with LCP policies listed on pages 257-260 relating to

protection and enhancement of visual qualities and scenic values.

The portions of the North Coast Area Plan (NCAP) of the Humboldt County LCP that are

relevant to management of RNSP have been certified.

The NCAP discusses policies applicable to the entire county, with occasional references to

park lands, followed by more specific recommendations and policies. Specific county

policies relevant to GMP proposals are trail access to the Tall Trees Grove (NCAP 4-9);

Freshwater Spit use (NCAP 4-11); commercial recreation sites at Freshwater Spit and

Stone Lagoon (NCAP 4-11); and access in general (NCAP 4-14 through 4-18).

Recommendations in the NCAP on planning issues related to the national park (NCAP 4-

are covered in the access component The Park Service proposals for Freshwater Spit use

and commercial fishing access to beaches are discussed briefly under the NCAP access

recommendations and in more detail under the relevant sections of the Coastal Act.

Federal lands, waters, and resources within RNSP associated with county policies for

environmentally sensitive habitats (NCAP 3-22) are:

I . the offshore waters from the Humboldt/Del Norte County line included in the Redwood

National Park Area of Special Biological Significance

2. Redwood Creek (rivers, streams and riparian habitats)

3. Freshwater Lagoon and the mouth of Redwood Creek (wetlands, lagoons, and

estuaries)

4. Critical habitats for rare and endangered species (proposed critical habitat for coho and

chinook salmon in Redwood Creek).

The NCAP encourages restoration of wetland habitat of the Redwood Creek oxbow in the

estuary (NCAP 3-24) under certain conditions. Several policies described under public lands

resource buffers on NCAP 3-36 apply to the Park Service proposals for Redwood Creek

estuary restoration. The GMP proposals for restoration of the estuary in cooperation with the

county, other agencies, and private landowners are consistent with these policies.

The NCAP identifies Freshwater Spit as a coastal scenic area and coastal view area (page

3-37) and the wetlands associated with Redwood Creek estuary as significant visual

resources (page 4-4). GMP proposals for management of scenic and visual qualities at

these areas, as well as any views of the Pacific Ocean, are maximally consistent with

county policies.

to the Tall Trees Grove in the Redwood Creek basin outside the coastal zone is identified as

a high priority in the GMP (p. 67). The GMP is maximally consistent with this policy of the

NCAP.

Freshwater Spit was being used as an overnight campground without authorization or

adequate support facilities (NCAP 4-11). Subsequently, the Park Service leased the area

from Caltrans, developed management alternatives for the spit in 1990 that were reviewed

for consistency by the Coastal. Commission (CD-022-90), and provided minimal services to

improve sanitation and safety. The GMP calls for development of a day-use area, with

overnight use phased out over 3 years, and a fee charged for overnight use during the

phase-out period. The NCAP states that the county policy is to prefer the private sector as

the provider of visitor-serving facilities (page 3-5). The GMP proposal to phase out overnight

use at Freshwater Spit over a three-year period to allow the private sector the opportunity to

develop replacement camping facilities elsewhere is maximally consistent with this policy.

Based on Park Service policies for charging camping fees proportionate to services

provided, the temporary fee will be well within the "low cost" policy required under Section

30213. Full pedestrian access will be allowed at Freshwater Spit under the proposal, no

day-use fee will be charged, and parking and restroom facilities will be provided in addition

to the existing restrooms, parking, boardwalks, and picnic area at the Redwood Creek picnic

area at the north end of the spit.

Commercial recreation-The NCAP recommends that the private landowner at the Redwood

Trails development near Stone Lagoon investigate opportunities for establishing trail access

to the national park. The landowner has initiated discussions with the Park Service for trail

access from the development as part of the trail planning process described in the GMP (p.

67).

section.

Access-The NCAP notes that there are almost no property limits to access along the

coastline. Pedestrian access to federal lands in the coastal zone in RNSP is free and

unconstrained except by geological, physical, and coastal processes (cliffs, rivers and

streams, tides, waves, etc.). The NCAP recommends that Davison Road be improved for

access by conventional two-wheel drive sedans (NCAP 4-15). The GMP is consistent with

this recommendation and proposes that minor road improvements be made to facilitate

access. The GMP proposes that shuttle access be evaluated as an alternative to major road

improvements that might create adverse effects on sensitive park resources. The road is

presently accessible by two-wheel drive sedans, but trailers and large RVs are not

recommended due to narrow width and tight curves. The GMP is partially consistent with

NCAP recommendations for use of the mouth of Redwood Creek and for Redwood Creek

County Park/Freshwater Lagoon, as follows.

The NCAP recommends parking, restroom, and separate pedestrian and off-road vehicle

access to the beach at the mouth of Redwood Creek. This beach is continuous with the

beach at Freshwater Spit except at high tides. Humboldt County granted the Redwood

Creek County Park to the Park Service in 1982 on the condition that it be used for park

purposes in perpetuity. In 1997, the Park Service upgraded the existing restroom and

parking area, provided covered picnic area and boardwalks, provided separate vehicle and

pedestrian access between Freshwater Spit and the picnic area, and landscaped the area

with local driftwood and native plants. These improvements are consistent with the NCAP

recommendations on page 4-4, and with the grant deed conditions that require that the

former county park "be used and maintained in perpetuity as a public park, and only as a

public park, and shall at all reasonable times be open to the public."

The GMP is not consistent with the 1982 NCAP recommendation for maintaining overnight

use of Freshwater Spit, allowing vehicle access to the Freshwater Spit and Redwood Creek

beaches, and allowing burl gathering. The Park Service proposes to change Freshwater

Spit use from overnight use to day use to improve the visual appearance of area, to protect

resources, to improve public health and safety, and to provide consistency in I management

of this beach with other national park beaches off-road vehicle access is prohibited in

national parks, and that regulation will be enforced, although off-road vehicle access for

commercial fishing at Freshwater Spit will be retained during a phase out period because of

the provisions in the legislative history of the legislation that established the national park.

The county encourages continued access for commercial wood (burl) gathering but both the

off-road vehicle access and commercial removal of resources are prohibited by Park

Service regulations.

The NCAP recommended that parking at the boat ramp at Freshwater Lagoon be increased

and the turnout improved. There were no requests for this action during the scoping and

public comment periods for the recent revision of the GMP, thus it appears that this is no

longer an issue. There appears to be adequate boat trailer parking along the east shoulder

of Highway 101 along Freshwater Lagoon. However, the planning process for implementing

the Freshwater Spit proposals will provide an opportunity for the public to reiterate this

request, which the Park Service would consider.

This portion of the federal consistency determination analyzes consistency between policy

sections of the California Coastal Act (Division 20, California Public Resources Code) and

Park Service proposals and actions on federal lands in Redwood National and State Park

Service included within the California Coastal Zone boundary. The relevant policies are

listed first, followed by comment and analysis. Page numbers in parentheses refer to pages

in the final General Management Plan/Environmental Impact Statement (GMP).

Policies under the California Coastal Act that are not applicable to Park Service proposals in

the GMP are:

use and development;

subsections (a) (1-4); section 30236 Water supply and flood control; section 30237

Habitat conservation plan; Bolsa Chica;

conversions;

section 30254 Public works facilities; and

and warnings about coastal hazards will be provided to visitors in a variety of ways and at a

number of locations (p. 63). Vehicle access to parklands in the coastal zone is available

along the length of Freshwater Spit adjacent to U.S - Highway 10 1, at Freshwater Lagoon,

at the Redwood Creek Picnic Area south of the Redwood Information Center (former

Redwood Creek County Park), at the Redwood Information Center, via Davison Road

leading to Gold Bluffs Beach, along the Coastal Drive north of Prairie Creek Redwoods

State Park, along the Klamath Beach Road leading to the Coastal Drive, along Requa Road

leading to the Klamath River Overlook, at Lagoon Creek picnic area, at the Redwood Hostel

at Wilson Creek, at the Crescent Beach picnic area, and along Enderts Beach Road as far

as the Crescent Beach Overlook.

Pedestrian access to the coastal zone is available from all the vehicle access points listed

above and additionally along the length of the Coastal Trail, at the Yurok Loop Trail

originating at the Lagoon Creek picnic area (Lagoon Creek fishing access), and at Crescent

Beach extending south along Enderts Beach road to the Coastal Trail trailhead. Pedestrian

access is allowed along the length of the coastline within RNSP, although safe access along

the coastal bluffs and cliffs is dependent on tides.

General off-road vehicle use on federally owned beaches in RNSP will be prohibited under

Park Service general regulations found in 36 CFR 4. 10 pursuant to the requirements of

Executive Orders 11644 and 11989. These regulations limit off-road vehicle use to

designated routes and areas in certain units of the national park system but prohibit off-road

vehicle use in national parks. Consistency for actions related to off-road vehicle access for

commercial fishing is discussed under Sections 30234 and 30234.5.

resource conditions and visitor experiences that are acceptable in each zone. Facilities and

use levels allowed in each zone must not exceed the conditions set for protecting resources

or for the desired visitor experience. Developed and frontcountry zones in which roads and

parking are allowed are well-distributed in areas that are able to withstand impacts along the

35 miles of park coastline. The GMP identifies several areas of RNSP as susceptible to

crowding and calls for carrying capacity studies prior to redesign of the areas (pp. 43, 65).

None of these areas is subject to federal consistency review. The present use of Freshwater

Spit for overnight camping is considered by some publics to be in excess of the social

carrying capacity because the spit is crowded by vehicles that block the view of the ocean.

GMP proposals for Freshwater Spit address the resource impacts from this overnight use.

in RNSP. A fee will be charged for overnight use at Freshwater Spit during the 3-year period

during which overnight use will be phased out. At present, a $7 donation is requested.

Under Park Service policies, any fees charged must reflect the level of services provided,

e.g. potable water, portable toilets versus flush toilets in restrooms, RV hookups, etc' There

is no charge for primitive camping at Nickel Creek, DeMartin Prairie, or Flint Ridge. The

Redwood Hostel at Wilson Creek provides low cost overnight accommodations.

reduce the potential earthquake and tsunami hazard to visitors. The Park Service

anticipates that parking will be managed so as to maintain open vistas of the ocean

uninterrupted by vehicles parked along the length of the spit. Aesthetic values will be

enhanced further by removing portable toilets and garbage dumpsters from the spit, with

restrooms and trash containers provided at the new day-use parking area and the existing

Redwood Creek picnic area. Park Service maintenance staff will continue to provide regular

trash pickup at this site and at other parking areas and trailheads in the coastal zone.

in RNSP are scenic viewing, beachcombing, wildlife-watching, and sport fishing. General

Park Service regulations prohibit removal of park resources except unoccupied sea shells

as specified in the park regulations. Regulations specific to Redwood National Park allow

collection of one gallon-bucket of unoccupied seashells per person per day (36 CFR 2.1

(c)(1)). The national park boundary runs north-south through the center of Freshwater

Lagoon. Recreational use of waters of that portion of Freshwater Lagoon within the national

park boundary is subject to general Park Service regulations found in 36 CFR Part 3 that

apply to boating, water skiing, fishing, hunting, and other water-based activities. The Park

Service has proposed general regulations under 36 CFR Parts 1 and 3 that would prohibit

use of personal watercraft jet skis) on federally administered waters in RNSP, although this

use would be allowed on the east side of the lagoon outside the national park boundary. Jet

skiing and water skiing are uncommon uses of Freshwater Lagoon because of its relatively

small size.

available for recreational use consistent with Park Service regulations and policies, and

management zoning as described in the GMP. Management zoning allows recreational

uses consistent with the desired resource condition and visitor experience. The GMP

proposal for converting Freshwater Spit to day-use only is consistent with the proposing that

the phase-out occur over a 3-year period to allow private facilities to replace this use

nearby. Overnight camping is also available at the state park campgrounds, including

ocean-side camping at Gold Bluffs Beach campground in Prairie Creek Redwoods State

Park and at Clam Beach County Park in Humboldt County 25 miles south of Freshwater

Spit. Numerous private campgrounds are available at Trinidad, Klamath, and Crescent City.

commercial visitor-serving facilities outside parks. The management strategies described in

the GMP reinforce this policy through Park Service support of sustainable economic

development and availability of visitor services in local communities that serve as gateways

to RNSP (pp. 65, 69, 72).

allowed consistent with site-specific planning, Park Service regulations and policies, and

management zoning as described in the GMP. Management zoning allows recreational

uses consistent with the desired resource condition and visitor experience.

RNSP because there are not suitable natural harbors or other safe locations within the

parks for recreational boating of the type that requires launching, berthing, and storage

facilities. However, the management strategies described in the GMP reinforce this policy

through Park Service support of sustainable economic development and availability of such

facilities in Crescent City harbor.

under the laws, regulations, and policies applicable to national parks, and under park goals

expressed in the GMP (p. 22). The legislation establishing Redwood National Park set aside

the park in part to preserve seashores associated with the primeval redwood forests, for

purposes of public inspiration, enjoyment, and scientific study (p. 8). The Pacific coastal,

nearshore, and littoral environments and waters are considered significant attributes of the

parks (p. 9).

The restoration of the Redwood Creek estuary has been a long-term goal of the Park

Service. The Park Service recognizes that estuary restoration will require coordination and

cooperation among many agencies and individuals, and proposes to take a leadership role

to accomplish the restoration while seeking to maintain current land uses (p. 58).

The marine management zone specifies allowable uses of the area between mean high

water and the national park boundary one-quarter mile offshore. The Park Service

recognizes that the marine environment in RNSP is dominated by intense physical forces

and any allowable uses must account for these forces (p. 32).

Approximately 31 miles of the offshore waters in RNSP between Cushing Creek and the

southern end of Freshwater Spit were designated as the Redwood National Park area of

special biological significance in 1974 (p. 38). The Park Service will continue to work with

the California Department of Fish and Game to ensure that these waters are protected to

the greatest extent practicable, and to seek additional protection through modification of

existing CDFG regulations if needed. The Park Service will continue to inventory marine

organisms and monitor their condition under general Park Service laws and policies. With

the exception of those species that can be taken under commercial and sport-fishing

regulations as allowed under state law, Park Service laws, policies, and regulations dictate

complete protection of marine organisms.

planning committee to ensure continued protection of marine resources (p. 38).

Restoration of watersheds impacted by previous timber harvest is mandated by the, 1978

legislation expanding the national park (p. 8). The restoration program is designed to reduce

erosion that degrades water quality and to restore natural topography of hillslopes and

stream channels (pp. 9, 17, 48, 58). Most of the restoration occurs outside the coastal zone

but indirectly affects coastal resources downstream. The restoration of the Redwood Creek

estuary directly affects the Coastal Zone (p. 58).

Water quality and human health in the coastal zone at visitor use areas at Freshwater Spit,

the Redwood Creek picnic area, the Redwood Information Center, Lagoon Creek and

Crescent Beach picnic areas are protected through adequate waste water treatment

methods in compliance with applicable federal and state regulations.

participate on the planning committee to ensure continued protection of marine resources

(p. 38).

Management of RNSP does not entail activities that develop, generate, or require large

is in full compliance with federal, state and Department of the Interior regulations for use

and storage of these materials, including a hazardous materials management plan.

requiring burial of utilities in wetlands or estuaries will be submitted for additional federal

consistency determination. Likely locations for such development are Freshwater Spit,

Redwood Information Center, Lagoon Creek, and Crescent Beach areas.

most cases, prohibit beach nourishment. Park Service policies for developing in-park borrow

sites (including sand) for construction require that the site be the only economic source of

such materials, and that such use be identified in the GMP. The GMP did not identify any

in-park borrow sources are anticipated for management.

conserve salmon habitat and protect the Redwood Information Center requires periodic

dredging to control the breaching of the sand berm separating the estuary from the ocean

(p. 58). Additional dredging might be necessary as part of the program to restore the

organizing a multidisciplinary, multi-jurisdictional approach to restoration of the estuary (p.

58). The Commission found that previous actions by the Park Service for estuary

management were consistent with this section (CD-31-83).

or estuaries. Examples include core samples in and adjacent to coastal lagoons for study of

sediments deposited by tsunamis, or for studies related to sediment deposition in the

Redwood Creek estuary.

inmost cases, prohibit beach nourishment. Park Service policies for developing borrow sites

(including sand) for construction require that the site be the only economic source of such

materials, and that such use be identified in the GMP. No such proposals are anticipated for

management of RNSP. The Commission found no evidence of beach regression in the

vicinity of Freshwater Spit and found that previous management actions by the Park Service

associated with estuary restoration were consistent with the beach sand supply policies of

this section (CD-31-83).

conserve salmon habitat and protect the Redwood Information Center requires periodic

dredging to control the breaching of the sand berm separating the estuary from the ocean

(p. 58). Additional dredging of excess sediment might be necessary as part of the program

to restore the functions and values of the estuary and associated sloughs (p. 275).

circulation and functions of the Redwood Creek estuary (pp. 179-182). The flood control

levees altered circulation patterns in the estuary. Management of the water levels in the

Redwood Creek estuary to conserve salmon habitat and protect the Redwood Information

Center requires periodic dredging to control the breaching of the sand berm separating the

estuary from the ocean (p. 58). Additional dredging might be necessary as part of the

program to restore the functions and values of the estuary (p. 275). Park Service staff will

prepare the Redwood Creek Estuary Aquatic Resource Management Plan to outline issues,

resource conditions, and threats to aquatic habitats in the estuary, summarize past

research, and describe alternatives for restoring natural processes and physical conditions

(p. 44). This plan will be submitted for additional federal consistency determination. The new

Commission concurred with earlier consistency determinations submitted by the Park

Service for management projects for the estuary beginning in 1983 and in subsequent years

(CD-31-83, CD- 18-84, CD-20-85).

Freshwater Spit, Klamath, and Crescent Beach will be managed under a permit system

similar to that used at Gold Bluffs Beach in Prairie Creek Redwoods State Park and at those

portions of Crescent Beach owned by Del Norte County. Recreational boating is not a

common use of park marine waters because of the lack of safe harbors or anchorages in

RNSP, and rough conditions typical in marine waters of northwestern California.

uses will be allowed to the extent such uses are consistent with regulations and statutes

applicable to the Park Service and RNSP. Commercial and recreational fishing will continue

in park waters and be governed under state laws, as provided in the legislative history for

the legislation that established Redwood National Park. Limiting off-road vehicle use to

vehicles used for commercial fishing only and eventually phasing out off-road vehicle use

altogether will be done to meet Park Service statutory obligations to protect park resources

and enhance public enjoyment of park resources and values, and to provide consistent

management of vehicles on beaches owned by the Park Service and the California

Department of Park Service and Recreation within RNSP. Commercial fishing at Freshwater

Spit, Klamath, and Crescent Beach will be managed under a permit system similar to that

used at Gold Bluffs Beach in Prairie Creek Redwoods State Park and at those portions of

Crescent Beach owned by Del Norte County 6. 68-69).

no need for extensive alteration of natural topography. No future developments that would

require protection from coastal processes are planned for any of the locations in the, coastal

zone identified in the GMP as development zones. Breaching of the sand berm, at the

mouth of the Redwood Creek estuary will continue if needed to protect the Redwood

-Information Center (p. 58).

under existing Park Service laws, policies, and guidelines.

section under existing laws, policies, and guidelines. Management zones (pp. 22-32)

prescribe desired resource conditions and visitor experiences, and set allowable types of

uses and facilities that will not detract from desired conditions.

lands in RNSP but might apply some proposals for restoration of the Redwood Creek

estuary. Under some restoration scenarios (pp. 300-302), estuary restoration would remove

land from agricultural production for wetland restoration and protection of endangered

species. The Park Service is seeking to restore functions and values of the estuary while

retaining current land uses (p. 58).

purchase of private agricultural land or conservation easements that are among the

proposed management options for restoration of the Redwood Creek estuary (p. 3 0 1).

the natural functions and values of the Redwood Creek estuary while retaining current land

uses, including agricultural uses, in the lower Redwood Creek valley (p. 58). Land adjacent

to the estuary purchased by the Park Service from willing sellers would be used for park

purposes which would include preservation of environmentally sensitive habitat such as

wetlands, fish and wildlife habitat, and endangered species habitat. Land that becomes part

of RNSP would be available for public access. If conservation easements are purchased,

agricultural uses would be retained on the private lands.

the national park system require that the Park Service actively protect and preserve natural

and cultural resources, including archeological and paleontological resources. Laws and

regulations specific to the management of cultural resources are summarized on pp. 268-

The GMP is maximally consistent with this section.

developments to serve park visitors. No new major visitor-serving developments are

proposed in the coastal zone or outside of any currently developed area. GMP proposals

are maximally consistent with this section.

with this section under Park Service laws, policies and guidelines that require that scenic

and visual qualities of a park be protected and that all development be compatible with the

visual quality of an area.

(p. 70) are maximally consistent with this section. The Park Service is cooperating with Del

Norte County to develop new or enhance existing public transit to serve park visitors, e.g.

public transportation serving the Coastal Trail trailhead at Damnation Creek and the

Redwood Hostel at Wilson Creek. The existing access and circulation system within RNSP

is intended to enhance both vehicle access and pedestrian access to coastal areas. US

Highway 10 1 through RNSP provides the primary access to park developments and visitor

facilities, including coastal areas at Freshwater Spit, Lagoon Creek, and Enderts Beach.

Major coastal access areas have adequate parking (Freshwater Spit, Redwood Creek picnic

area, Redwood Information Center, Lagoon Creek and Crescent Beach picnic areas.)

with this section. Existing Park Service laws, regulations, policies, and guidelines require

that RNSP be managed in a manner that is maximally consistent with this section.

The Park Service acknowledges that RNSP are located in an area subject to geological

hazards (Cascadia subduction zone, local and distant source tsunamis, river and stream

flooding, landslides). Where there is no feasible location for facilities outside the hazard

zones, the hazards are mitigated by developing emergency action plans and procedures,

and posting warnings. Park Service staff participate in tsunami disaster planning with

Humboldt and Del Norte county emergency services offices, as well as participating in the

National Tsunami Hazard Mitigation Program.

Based on public comments on the draft plan, the Park Service changed its original proposal

to move the existing Redwood Information Center out of the tsunami zone. The final

proposal is to relocate the center only if it should be destroyed or severely damaged by

future events (pp. 63-64). The center was approved for construction in its present site based

on scientific knowledge current in the early 1980s. New evidence indicates that the chance

of a tsunami or damaging earthquake is substantially greater than known at that time.

However, the cost of relocating the relatively new structure was determined to be excessive,

based on estimates of potentially available funding. To protect visitors and employees who

might occupy the center at the time of a tsunami, Park Service staff have prepared a

tsunami evacuation plan and are participating in the National Tsunami Hazard Mitigation

Program.

The Park Service proposal to convert Freshwater Spit from overnight use to day use is

consistent with the Park Service guidelines for implementing Executive Order 11988,

"Floodplain Management." These guidelines require that overnight occupation areas such

as campgrounds be located out of coastal high hazard zones, because of the difficulty of

providing timely warning and adequate evacuation time. Presently, there are tsunami

warning signs and evacuation procedures posted on the information kiosks along

Freshwater Spit.

Visitor facilities located in coastal high-hazard zones throughout RNSP have tsunami

warnings and evacuation procedures posted.

maximally consistent with this policy. Management strategies for public use (p. 65)

described in the GMP indicate that proposals for development and use of coastal and

marine areas must support and facilitate appropriate use and enjoyment and participation in

activities related to the resources at that area; that facilities are provided in appropriate

locations; that access is provided to the full range of park resources, including coastal and

marine resources; and that such use is managed to protect the resources.

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http://www.coastal.ca.gov/fedcd/CC-Detailed.pdf

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