Mill Creek General Plan Amendment

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