Final Fire Management Plan 

Environmental Impact Statement 

Point Reyes National Seashore 

and 

North District of Golden Gate National 

Recreation Area 

National Park Service 

July 2004 
ii

Printed on Recycled Paper
Final Fire Management Plan and 

Environmental Impact Statement 

Point Reyes National Seashore 

North District of Golden Gate National Recreation Area 

Marin County, California 

Lead Agency: National Park Service 

Revisions to the current fire management plan for Point Reyes National Seashore (PRNS) and 

the North District of Golden Gate National Recreation Area (GGNRA) are needed to meet public 

and firefighter safety, natural and cultural resource management goals, and wildland urban 

interface objectives of the park. The action alternatives in this Environmental Impact Statement 

(EIS) vary in the emphasis they place on seven fire management goals developed by the park. 

The current program has been effective in fire suppression, but has not fully guided fuel 

reduction and/or resource management programs. 

This Fire Management Plan (FMP) and EIS describe and analyze a preferred alternative and two 

alternatives for future management of the fire program at PRNS and the GGNRA. The 

alternatives are: Alternative A (No Action) - Continued Fuel Reduction for Public Safety and 

Limited Resource Enhancement, Alternative B - Expanded Hazardous Fuel Reduction and 

Additional Natural Resource Enhancement and Alternative C - Increased Natural Resource 

Enhancement and Expanded Hazardous Fuel Reduction. The National Park Service prefers 

Alternative C. 

Impact topics assessed in the EIS include natural resources including air, water, soil, vegetation, 

wetlands and special status species; cultural resources including archeological sites, historic 

structures, and cultural landscapes; park operations; and the socioeconomic environment. 

The comment period on the FMP and EIS began February 20, 2004 with the publication of a 

Draft FMP and Draft EIS that lasted 60 days after the notice of availability. The comment period 

closed April 20, 2004. Comments and responses are presented in Chapter 5 of this Final FMP 

and EIS. 

The release of this Final FMP/EIS and published Notice of Availability in the Federal Register 

will be followed by a 30-day no action period after which time the alternative or actions 

constituting the approved plan will be documented in a Record of Decision. For further 

information, contact the Superintendent, Point Reyes National Seashore, Point Reyes Station, 

CA 94956, or by phone at 415-464-5100. 
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v 

Executive Summary 

Final Fire Management Plan 

Environmental Impact Statement 

Point Reyes National Seashore 

North District of Golden Gate National Recreation Area

Introduction 

National Park Service policy requires that each park with vegetation capable of burning prepare a 

plan to guide a fire management program that is responsive to natural and cultural resource 

objectives, reduces risks to developed facilities and adjacent communities, and provides for 

public and staff safety. Point Reyes National Seashore is currently operating under a Fire 

Management Plan that was written in 1993. The 1993 plan addresses various fire management 

techniques, including fire suppression, prescribed fire, and limited use of mechanical treatments 

to reduce forest fuels. The National Park Service proposes to revise Point Reyes National 

Seashore’s Fire Management Plan to expand the use of prescribed fire and mechanical treatment 

for all lands under its management. 

Purpose of and Need for the Fire Management Plan

The purpose of the Fire Management Plan (FMP) is to provide a framework for all fire 

management activities for the Seashore and the North District of Golden Gate National 

Recreation Area (GGNRA), including suppression of unplanned ignitions, prescribed fire, and 

mechanical fuels treatments. It is intended to guide the fire management program for 

approximately the next 10-15 years. The plan would include concise program objectives, details 

on staffing and equipment, and comprehensive information, guidelines, and protocols relating to 

the management of unplanned wildfire, prescribed burning, and mechanical fuels treatment. 

Fire management is an essential component of NPS operations in Point Reyes National Seashore 

(PRNS) and the Northern District lands of GGNRA. The need for a well-planned and effective 

fire management program is threefold. First, the project area’s ecosystems have evolved through 

time with the periodic occurrence of fires, both natural and human-ignited, and many 

components of these systems require the continuation of periodic fire. As is typical of many 

national parks and other federal lands, however, active and effective fire suppression efforts for 

the past 150 years have dramatically changed native ecosystems. Ecosystem changes from the 

lack of fire include forest and shrub encroachment on grasslands, decadence and death of fireadapted species, and extremely dense forests. 
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Second, fire suppression has also resulted in a dangerous accumulation of flammable or 

hazardous fuels - large quantities of dead and downed trees and branches that have accumulated 

in overly dense forests and shrublands. Because of these high fuel loads, residences and 

businesses adjacent to the PRNS and GGNRA are at risk from catastrophic wildfire or a smaller 

fire spreading from adjacent parklands. Also, a structural fire close to the park could spread into 

federal lands and develop into a wildland fire that damages park resources. 

Third, the park’s existing Fire Management Plan (NPS, 1993) needs to be updated. Since the 

current FMP was published in 1993, the national fire policies have been updated and new 

guidelines have been issued to park units. In addition, the NPS has conducted fire research and 

now has a better understanding of the role of fire in ecosystem preservation, resulting in a greater 

capability of the PRNS to conduct an effective fire program. Updating also allows PRNS to 

focus more heavily on effectively reducing fire risk along the wildland/urban interface, reducing 

hazardous fuels, and reestablishing fire in park ecosystems where it is safe to do so. 

The following goals have been developed for the updated Fire Management Plan for PRNS and 

the Northern District lands of GGNRA. These goals were generated from internal staff meetings 

and public external scoping meetings and presentations, from review of NPS Policies, Directors 

Orders, and other fire-related guidance documents listed below. 

 

Goal 1: Protect firefighters and the public. 

Goal 2: Protect private and public property. 

Goal 3: Maintain or improve conditions of natural resources and protect these resources 

from adverse impacts of wildland fire and fire management practices. 

Goal 4: Maximize efforts to protect cultural resources from adverse effects of wildland fire 

and fire management practices. 

Goal 5: Foster and maintain effective community and interagency fire management 

partnerships. 

Goal 6: Foster a high degree of understanding of fire and fuels management among park 

employees, neighbors, and visitors. 

Goal 7: Improve knowledge and understanding of fire through research and monitoring and 

continue to refine fire management practices. 

This final environmental impact statement (EIS) analyzes three alternative approaches to 

managing fire in the park. The alternative that is selected would be adopted as the new Fire 

Management Plan to guide the fire management program. Authority to develop a fire 

management program is derived from the National Park Service Organic Act (16 U.S.C. 1 et 

seq.), and in delegations of authority found in Part 245 of the Department of the Interior Manual. 

Director’s Order 18 also provides guidance to National Park Service wildland fire management 

and Director’s Order 12 guides National Park Service implementation of the National 

Environmental Policy Act (NEPA). 
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Decisions to be Made 

The park superintendent will use information provided in this document, along with input 

received during the 60-day public comment period, to recommend to the Regional Director of 

the National Park Service the alternative that should be selected. The selected alternative would 

update the Fire Management Plan and guide fire management in the park over the next 10-15 

years. 

Planning Issues Considered 

Planning issues are the concerns raised by park staff, other government agencies, and the public 

that were used to develop and evaluate the alternatives in this document. Concerns ranged from 

the impacts of wildland fire to the impacts associated with management actions taken to manage 

fire and reduce fuels. Planning issues discussed in this final document include impacts to the 

biological environment (vegetation, species of concern, wildlife), the physical environment 

(soils, water quality, and air quality), the cultural environment (cultural resources - historic and 

archeological), and the social environment (health and safety, regional economics, visitor 

experience, and visual resources). 

Alternatives 

Formulation of Alternatives

An interdisciplinary team of National Park Service staff developed the alternatives described in 

this document with input from the public and other agencies such as Marin County Fire 

Department and Inverness Fire Department. The interdisciplinary team was comprised of staff 

with expertise in fire management, wildlife, biology, botany, ecology, geology, safety, 

recreation, cultural resources, and public land policy and regulations. Public and interagency 

input was solicited and received through a scoping process. Three different approaches to 

managing fire at Point Reyes National Seashore were identified through this process. 

Alternative A (No Action) - Continued Fuel Reduction for Public Safety and Limited Resource 

Enhancement

The National Environmental Policy Act requires that environmental analysis documents include 

a No Action alternative. The No Action alternative for plan modifications, such as the proposed 

update of Point Reyes National Seashore’s Fire Management Plan, assumes that no new actions 

would be taken, but that current management would continue. The current fire management 

program outlined in the 1993 Fire Management Plan uses a limited range of fire management 

strategies - including prescribed fire, mechanical treatment, and suppression of all wildland fires 

(including natural ignitions). More specifically, existing practices include mechanical hazardous 

fuel(s) treatments on approximately 500 acres per year (primarily mowing in grasslands), and 

prescribed burning on approximately 500 acres per year (primarily for fuel reduction in 

grasslands and for Scotch and French broom control). The total treatments per year are 
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approximately 1000 acres. Research projects already in progress on reducing Scotch broom and 

velvet grass through prescribed burning would continue under this alternative. 

Alternative B - Expanded Hazardous Fuel Reduction and Additional Natural Resource 

Enhancement

Alternative B calls for a substantial increase over present levels in the reduction of hazardous 

fuels through prescribed burning and mechanical treatments (up to a total of 2,000 acres treated 

per year). Efforts would be concentrated in areas where unplanned ignitions are most likely to 

occur (e.g., road corridors) and where the creation of defensible space would be most effective at 

containing unplanned ignitions and protecting lives and property (e.g., around structures and in 

strategic areas along the park boundary). Natural resource enhancement would occur as a 

secondary benefit only. For example, in prescribed burns for fuel reduction along Highway 1, 

the non-native French broom would be eliminated as a secondary resource benefit. 

Alternative C (Preferred Alternative) - Increased Natural Resource Enhancement and Expanded 

Hazardous Fuel Reduction

Alternative C would result in a marked increase in efforts to enhance natural resources, including 

increasing the abundance and distribution of T&E species, reducing infestations of invasive, nonnative plants, and increasing native plant cover. Prescribed burning also would be used to 

protect or enhance cultural resources, such as reducing vegetation in areas identified as important 

historic viewscapes. 

Alternative C also would include increased reduction of hazardous fuels in high priority areas 

(e.g., along road corridors, around structures, and in strategic areas to create fuel breaks). Up to 

3,500 acres could be treated per year using prescribed fire and mechanical treatments. Under 

this alternative, research efforts would be expanded to determine the effects of fire on natural 

resources of concern (e.g., rare and non-native species) and to determine the effectiveness of 

various fuels treatments. Research results would be used adaptively to guide the fire 

management program in maximizing benefits to natural resources, while protecting lives and 

property. 

Actions Common to All Alternatives

Some actions, including the continuation of the Wildland Urban Interface Initiative Program, 

maintenance of fire roads and trails, vegetation clearing around buildings, suppression of 

unplanned ignitions, public information and education, and fire monitoring would be carried out 

under all three alternatives. Also, the park intends to build a fire cache to store equipment 

regardless of the alternative selected. Each of these activities is described below. 

Wildland Urban Interface Initiative Program 

In 2001, the NPS began implementing provisions of the federal Wildland Urban Interface (WUI) 

Initiative program. Over the past three years, the NPS has funded over $2.0 million in fuel 

reduction projects in PRNS, GGNRA’s North District, and adjacent lands. This program was 
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designed to facilitate cooperative ventures with park neighbors (including other federal agencies, 

states, counties, private landowners, and local fire agencies) to reduce the potential for wildland 

fire to burn from federal lands to neighboring properties. In the future, the PRNS would 

continue to request funding for defensible space and fuel reduction projects on private lands 

adjacent to the park. 

Maintenance of Fire Roads and Trails 

The Seashore routinely clears vegetation and debris from selected dirt and paved roads (See 

Table 4) that provide routes for emergency evacuation, access for fire suppression activities or 

conducting prescribed burns, or that serve as control lines for prescribed fire projects. The 

minimum requirement for defensible space along roadways is 10 feet on each side. This 

specification provides only the minimum degree of safety for firefighters and the public and is 

prescribed by California Public Resource Code (PL-4290 and 4291). An assessment of road 

conditions is performed in early summer, and then a work plan is developed and vegetation 

clearing needs are prioritized. 

Vegetation Clearing around Buildings 

Seashore staff routinely clears hazardous fuels (vegetation and flammable debris) adjacent to 

structures within the project area. These actions would continue under all alternatives. Structural 

clearing conforms to or exceeds the requirements of California Public Resource Code (PL-4290 

and 4291), which also dictates the parameters for structural safety in surrounding residential 

communities. This code requires a minimum 30-foot cleared buffer of defensible space around 

all structures. 

Suppression of Unplanned Ignitions 

The current policy at the Seashore is to suppress all unplanned ignitions using minimum impact 

suppression tactics (MIST) to the greatest extent possible. Since 1997, an average of three 

wildland fires per year have occurred at Point Reyes. All of these were kept less than ten acres 

in size; most were extinguished at less than one acre. To accomplish this, Point Reyes has had a 

10-person Hazard Fuels Crew, 1-2 Engine Technicians, and support from the GGNRA and the 

Marin County Fire Department. Most of the fires occurred in the Olema Valley, and all but one 

were human-caused. Under all alternatives, all unplanned ignitions would be suppressed. 

Public Information and Education 

A comprehensive public information and education program would be included as part of all 

alternatives. PRNS and GGNRA share a full-time Fire Education Specialist. The program 

emphasizes fire safety and prevention, fuels management, the role of fire in PRNS’s ecosystems, 

the Seashore’s fire history, the cultural use of fire on the landscape, and fire research programs 

and opportunities. 
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Fire Monitoring 

Monitoring of fire effects has been occurring in prescribed burn units at PRNS since 1991, and 

would continue under all alternatives. Monitoring of fuels, weather, air quality, and fire behavior 

for wildland and prescribed fires generally follows protocols outlined in the Fire Monitoring 

Handbook (NPS 2003a). Under these protocols, photo points and vegetation transect data are 

used to indicate attainment of objectives. Short and long-term objectives applicable to specific 

burn areas are stated in individual Prescribed Burn Plans. 

Fire Program Cache 

Currently, fire control vehicles and equipment are stored at the Hagmaier Complex, located 

approximately six miles from park headquarters. Storage of fire equipment and vehicles in a 

more central location of the park would decrease response time and facilitate communication 

between park staff responsible for fire management. Internal scoping discussions among 

specialists in different fields at the park indicated the cache should ideally be located near park 

headquarters for logistic and technical reasons. In addition, the environmental effects of siting 

the building near existing buildings would be minimal. At this time, the park staff has identified 

a location adjacent to the roads and trails facility at the Bear Valley administrative area (park 

headquarters) as its preferred choice for the cache. 

Environmental Impacts 

The environmental impact section of this EIS evaluates the degree of change a particular 

resource would experience if an alternative were implemented. The resources analyzed were 

identified by park staff, laws, regulations and policies, and the interested and affected public, 

including other agencies that were contacted during scoping. 

NPS director’s orders and management policies require analysis of whether an alternative might 

impair NPS values or resources, as this would be specifically prohibited by the Organic Act. As 

chapter 4 of this EIS indicates, none of the alternatives would impair park resources or values. 

Chapter 3 of this EIS describes the resources and their current state, and chapter 4 analyzes the 

extent, duration and intensity of impacts to the resources expected under each alternative. A 

summary of major conclusions in each of these chapters is presented below. 

Soils 

Impacts to soils from the actions anticipated in each alternative include changes in soil 

productivity and chemistry, as well as erosion following the removal of vegetation. The total 

acreage of all FMUs where some treatment in at least one alternative would take place totals 

about 22,000 acres. The potential for erosion of soils following a wildland fire is higher in some 

FMUs than others, and is particularly high in the Wilderness North FMU, where 64% of the 

acreage is covered with soils that have very high erosion potential. Overall, about 10,000 acres in 
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all FMUs have high erosion potential, 4,000 have very high erosion potential, and the remaining 

7,000 have low or moderate potential for erosion. 

The impacts of prescribed burning and average wildland fires (no more than about 30 acres per 

year) under Alternative A to soil from increased erosion would be negligible to minor. Impacts to 

soils from prescribed burning would be kept to no more than 10% of soils in watershed through 

the use of annual burn plans and NPS review under all alternatives. This mitigation measure 

would keep increases in soil erosion in this same range for Alternatives B and C as well, 

although as more acres are slated for prescribed burning, the impacts are progressively more 

likely to be minor rather than negligible. 

Moderate to major, short- to long-term, adverse cumulative impacts to the physical, chemical, 

and biological properties of soils from a very large or catastrophic wildland fire are possible 

under any of the three alternatives, although the risk of such a fire and its likely extent both 

decrease as treatment from prescribed fire and mechanical thinning increase. In addition to 

increased erosion, formation of hydrophobic soils, gullying, channel cutting, slope failure, and 

destruction of organic material and microorganisms in the soil are likely in the event of this type 

of fire. Suppression activities could have additional adverse, short to long-term moderate to 

major impacts from soil compaction, mixing, reduced infiltration, loss of vegetation, and changes 

in soils that prevent quick revegetation. Actively suppressing wildland fires before they reach 

sensitive resources could keep impacts from becoming major and adverse. 

Some of these same changes in soil productivity and chemistry would occur during prescribed 

burning or more average wildland fires, but to a much lesser extent. Because impacts would be 

monitored and kept to no more than 10% of a watershed, they would be negligible to minor for 

all three alternatives, although as described above for increases in erosion, they would be greater 

in Alternative C than B, and greater in Alternative B than A. Negligible to minor impacts to soils 

from compaction or other physical changes from mechanical treatments are also possible under 

any of the alternatives. 

Air Quality 

The predominant regional surface winds in the area are from the north-northwest during winter, 

spring and summer. In fall, warm easterly winds can break through to the coast while inland 

conditions remain hot and dry. These winds lower vegetation moisture levels and begin the 

season when the coastal region faces its most significant fire threat. 

The westerly winds help disperse air pollution from coastal communities, as does vertical 

mixing, which is most prevalent during hotter weather or the heat of the day. During winter or 

during temperature inversions, pollutants concentrate nearer the ground. 

Only PM2.5 (particulates less than 2.5 microns in size) is measured at PRNS, and the park is well 

below state and federal standards. Other air pollutants are not measured in the study area, so 

those from the closest rural locations (Santa Rosa and Vallejo) were used as an approximation. 

Santa Rosa meets the federal average standard for particulates smaller than 10 microns, but is 

higher than California’s more strict standards. It is well below both the maximum one-hour and 
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eight-hour average federal and state standards for carbon monoxide, and the state and federal 

one-hour (state) and annual average (federal) standards for nitrogen dioxide. Vallejo is also well 

below the federal and California maximum 24-hour and annual average standards for sulfur 

dioxide. Santa Rosa has exceeded the state’s maximum 24-hour ozone average of 50 μg/m3 twice 

over the three-year period measured, and the California one-hour ozone standard once. 

Particulate emissions generated annually under Alternative A from all FMP actions and wildfires 

would have a long-term, adverse but negligible effect on regional haze. Ranches and residences 

along Highway One and ranches east of Estero FMU could experience infrequent short-term, 

negligible to minor adverse nuisance smoke effects from prescribed burning. 

The annual acreage treatment under Alternative A would not appreciably reduce the potential 

size or severity of a catastrophic wildfire even after a decade of implementation. The cumulative 

effect on air quality would be short-term, adverse and major at both Year 1 of implementation 

and at Year 10. 

On an annual basis, Alternative B would generate higher levels of particulate emissions than the 

No Action Alternative (Alternative A), as twice as many acres would be subject to FMP actions 

each year. Alternative B would produce and average of 2.86 pounds of PM10 per acre managed, 

resulting in a long-term, adverse, minor effect on regional haze. This additional contribution 

would be offset by the long-term opportunity presented by Alternative B to achieve a major, 

beneficial reduction in the emissions that could result from a catastrophic fire as compared to the 

cumulative effect under Alternative A. Nuisance smoke would be an infrequent, short-term, 

adverse, negligible to moderate air quality impact for residents near prescribed burns during the 

duration of the burn. 

On an annual basis, Alternative C would generate the highest levels of particulate emissions 

compared to the No Action Alternative A and Alternative B. This is a result of the greater 

number of acres treated each year and the larger number of forested acres, which produce the 

highest emission levels. Alternative C would produce an average 5.3 pounds of PM10 per acre 

managed, resulting in a long-term, adverse, moderate effect on regional haze. Contributions of 

PM10 to regional haze would be a long-term, adverse, and moderate for 13 years rather than the 

indeterminate period under Alternative A. 

This additional contribution would be offset by the long-term opportunity presented by 

Alternative C to achieve a short-term, major, beneficial, cumulative effect on regional haze that 

could result from a catastrophic fire as compared to the emissions produced under the cumulative 

scenario in Alternative A. 

Nuisance smoke would be an infrequent, short-term, adverse, negligible to moderate air quality 

impact for residents near prescribed burns during the duration of the burn. 

Watersheds and Water Quality 

Total Suspended Solids (TSS) and nitrogen in park water resources could be exacerbated by fire 

management activities. The ash generated by fires is rich in nitrogen, a nutrient essential to biotic 
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reproduction. Excess nitrogen in a water body can increase production of algae and aquatic 

plants. When this excessive biomass decays, it can deplete a water body of oxygen and lead to 

fish kills. Sampling of several sites in the park showed that current nitrogen levels, measured as 

nitrate and nitrite, were below detectable limits (>0.2 mg/l) (Ketcham, 2001) except in one 

watershed supporting dairying operations. 

Mechanical thinning and prescribed burning activities would also result in soil compaction, 

removal of vegetation and other changes that could increase erosion and suspended solids in 

water resources. Fire changes vegetation, forest floor cover (e.g., ground vegetation, litter or 

duff) and structure, and soil properties, all of which can alter the movement of water over, or 

into, the soil. In the first years following a large fire, watershed storage capacity is reduced and 

net surface runoff is increased as a result of reduced soil cover, lack of soil cover, and/or 

increased soil hydrophobicity (water repellency). These changes can result in channel extension, 

upland erosion, and stream channel incision. These changes to hillslope process result in 

increased discharges, soil erosion, and higher sediment yield, affecting aquatic habitat conditions 

within the watershed. 

The heating of soils from prescribed or wildland fires can lead to development of a water 

repellent layer at or below the surface of the soil, a condition called hydrophobicity. This layer 

reduces the infiltration capacity of the soil and increases the potential for overland flow. The 

higher the fire intensity/severity, the deeper in the soil this layer will form. 

Extremely high levels of sediments can also injure fish by clogging their gills, obscuring the 

presence of food, or covering the gravel surface of spawning areas. All watersheds sampled for 

the Point Reyes National Seashore Water Quality Monitoring Report (Ketcham, 2001) had TSS 

that exceeds the recommended standard. Sampled watersheds were Lagunitas Creek, Olema 

Creek, Drakes Estero, Drakes Bay, and Pacific Drainages. Sediment data were not collected 

from the Bolinas Drainages, Pine Gulch Creek, or Tomales Bay watersheds. 

These types of impacts would occur on a small-scale from prescribed burning in Alternative A, 

and would be negligible to minor and short-term. Trampling and the removal of vegetation 

would also result in some negligible to minor, short-term localized increases in erosion. 

However, in any alternative, a large-scale unplanned fire could have adverse, potentially longterm, and major impacts to both water quality and features of watersheds, including riparian 

zones and watercourses. Fire management activities would reduce the risk of this much larger 

watershed level impact. In this regard, Alternative A could provide moderate, long-term benefits 

to watersheds and water quality through prescribed burning, and additional minor to moderate 

benefits from mechanical thinning. 

 

In the context of the 90,000 acre study area, the impacts to water quality and watershed 

characteristics of Alternative B or C would be nearly indistinguishable from Alternative A. In 

other words, over the entire study area, any alternative would provide a combined moderate to 

major benefit to watersheds through the use of prescribed burning and mechanical treatment in 

reestablishing natural hydrological processes and reducing fuel loads and potential for 

catastrophic wildfire. Each could also result in minor, adverse, short-term impacts to water 

quality from ash or increases in erosion and suspended solids. Because the treated acreage would 
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be larger in Alternative B than Alternatve A, and larger still in Alternative C, benefits and 

adverse impacts could be quite noticeable on a localized basis. 

Vegetation 

PRNS owes much of its distinctive character to the assemblage of plants that occur on the 

Peninsula. The Seashore is home to over 910 plant species, 55 of which are of management 

concern. Of the 910 plant species, roughly one third are not native to the area. Nine broad 

vegetation communities are addressed in the EIS. They are Bishop pine forest, Douglas-fir and 

coast redwood forest, hardwood forest, Monterey pine and Monterey cypress, riparian forests 

and shrublands, coastal scrub, California coastal prairie, pasture, and coastal dunes. 

Vegetation mapping in the park indicates approximately 3,570 acres of Bishop pine forest 

occurring within Seashore boundaries. In 1995, approximately 35% (1,250 acres) of this acreage 

was burned in the Vision Fire. Fire plays an important ecological role in maintaining Bishop 

pine forests, and regeneration in the burned area has been prolific. 

The Douglas-fir (Pseudotsuga menziesii) and Coast redwood (Sequoia sempervirens) forest is 

the most common forest type in the project area. Douglas-fir is shade intolerant and requires 

stand-destroying disturbance (e.g., wildfire, logging, extensive windthrow) to initiate a new 

cohort of seedlings. Coast Douglas-fir can survive moderately intense fires, particularly if they 

are more than about 100 years old. However, most cannot withstand a crown fire. This is a risk 

in the project area, where many stands have substantial ladder fuel accumulations. 

Hardwood forest, usually dominated by California bay, coast live oak, or eucalyptus, occupies 

about 1900 acres of the 21,000+ acres that may be treated through fire management activities in 

the study area. Eucalyptus is notable because it is an invasive non-native species, and would be 

treated in some alternatives by thinning and herbicide application to prevent stump resprouting. 

Monterey pine and Monterey cypress are both introduced species in the area. These forests occur 

over a small portion of the FMUs slated for treatment. Monterey pine cones are only opened 

when exposed to heat such as fire or high air temperature. 

Broad-leaved deciduous trees or shrubs such as red alder, mixed willows, and arroyo willows, 

dominate riparian forests and shrublands. Red alder quickly invades forest openings, such as 

those created from fires. Its seeds can travel several hundred yards in wind to recolonize these 

disturbed areas. Most willows resprout from the root crown or stem base following fire. They are 

also prolific seeders, and off-site plants are important as a seed source for revegetating burned 

areas. 

Coastal scrub is a highly variable vegetation type including all of the shrublands of the study area 

and a small amount of chaparral. Coastal scrub is one of the most widespread plant community 

types in the project area and is present to some degree in all FMUs. Coastal sage and coastal 

scrub community types are fire-dependent, with prominent shrubs establishing by seed and 

sprouting. They are flammable vegetation types that may burn again 1 to 2 years after fire if dry 

conditions exist. 
xv 

Pristine coastal prairie in the study area is dominated by perennial bunchgrasses, but non-native 

grasses dominate roughly 80% of the grasslands in the Seashore. 

Pasture is distinguished from grazed grasslands and other grazed naturally occurring vegetation 

types in the project area as it is used to graze cattle or horses, or managed to produce silage for 

cattle, or used for other agricultural purposes. Very little pasture is in the treatable area identified 

in this plan/EIS, although the Minimum Management FMU is predominately pasture. 

Coastal dunes are dominated by non-native species, in particular European beachgrass and nonnative iceplant. Remnant patches of native plants covering about 25% of this vegetation 

community exist. 

Under the continuation of existing management described in Alternative A, prescribed burning 

would be used to manage hazardous fuels along primary roads and reduce the aerial extent and 

density of non-native invasive plant species, including Scotch broom, French broom, and 

Monterey pine. In Alternative B, burning would be conducted in the same FMUs for the same 

reasons as in Alternative A, although significantly more burning in shrublands and grasslands in 

Limantour Road and Bolinas Ridge FMUs would occur, primarily to reduce fuels. In addition to 

more treatment to reduce fuels and increase the ability to fight wildfires, under Alternative C the 

Seashore would use fire to enhance the condition of natural and cultural resources. Some 

treatment of natural resources would involve the widespread attempt to eliminate non-native 

species, but treatment to improve species richness and wildlife habitat also would occur. 

The focus of mechanical treatment in Alternative A would be mowing grasslands to reduce 

hazardous fuels and control Scotch and French broom, as well as cutting Monterey pine to help 

eliminate this non-native species. This would remain true of Alternatives B and C as well, 

although progressively more acreage would be treated in each. 

In the FMUs treated with prescribed fire, minor, short-term adverse impacts associated with loss 

of vegetation, as well as the possibility of introduction or spread of non-native plants, could be 

greater than under other alternatives. However, the burns also would result in minor to moderate 

beneficial impacts as burning would stimulate growth of many native plant species, and would 

kill non-native vegetation. Although they would remain moderate, the potential for beneficial 

effects from Alternative B are greater than Alternative A, and from Alternative C are greater than 

either of the other alternatives because of the increasing number of acres treated. 

Mechanical fuel reduction would have minor short-term adverse impacts on native vegetation 

through crushing or other physical impacts, but clearing of dense vegetation also would have 

possibly long-term, minor to moderate benefits on most plant communities as well. The effects 

would be greater in Alternative C than under Alternative B, and greater under Alternative B than 

Alternative A because more acres would be treated. 

Treatment of non-native Scotch broom with prescribed fire has been successful, and would 

provide minor to moderate benefits to coastal scrub and grassland habitat in any alternative. 

Mechanical treatment of Scotch and French broom in coastal scrub, grasslands, and pasture 
xvi 

would provide additional moderate to major benefits to these vegetation communities. Additional 

minor benefits to coastal scrub from prescribed burning to increase native species richness in 

Alternatives B and C would occur in Palomarin and Bolinas Ridge FMUs. Prescribed burns and 

mechanical treatments in grasslands could have beneficial or adverse impacts, as results are 

highly variable. Monitoring and adaptive management would keep these impacts from becoming 

more than minor if they are adverse. 

Limited prescribed burning in Alternative A may have negligible benefits to hardwood, Douglas 

fir, or Bishop pine forests from decreasing fuel loads. This would increase to minor or moderate 

benefits in the other two Alternatives as fuel reduction would take place over a larger area. 

Additionally, possible major benefits to Douglas-fir forests from the return of natural fire 

intervals following treatment with prescribed burning are possible in Alternative C. In all 

alternatives, mechanical fuel reduction could have negligible to minor short-term adverse 

impacts to hardwood and other forests (including Bishop pine and Douglas-fir forests) from 

trampling, or from the inadvertent introduction and spread of non-native species. 

All alternatives would result in minor to moderate localized benefits to native vegetation from 

the removal of Monterey pine and cypress trees. For these beneficial impacts to persist, however, 

follow-up activities must be conducted to remove new recruits that come into the site in years 

following prescribed burning or mechanical treatments. 

Alternatives B and C would offer minor benefits to coastal dune vegetation from the burning of 

non-native beachgrass. 

The risk of a catastrophic wildfire would progressively decrease as more acres are subject to 

prescribed burning or mechanical treatment. In some native vegetation communities, such as 

Bishop pine or hardwood forest, large-scale fire could be beneficial by eliminating non-native 

species or otherwise creating conditions favoring the spread of native plants. In others, such as 

Douglas-fir/coast redwood forests, hot crown fires can destroy the seed source for a large area, 

making re-establishment difficult. Riparian areas may also experience major adverse impacts 

from hot fires from the destruction of seed source or root crown. The effect of a wildland fire in 

coastal scrub or grassland is more complex and less well understood, as some native and nonnative species are benefited and some are adversely affected. Overall, the cumulative effects of a 

large-scale fire and all other activities such as development, historic logging, disease, and the 

introduction of exotics have and would continue to have major, long-term, adverse impacts on 

native vegetation communities in the park. Alternative B and C would reduce the risk of such a 

fire, but should it occur, the impacts on most vegetation communities at the Seashore would be 

major, long-term and adverse. 

Wetlands 

Wetlands, including salt and fresh-water wetlands, make up about 300 acres of the study area. 

Impacts to wetlands associated with fire management activities are similar in many respects to 

impacts described in the preceding sections on soils and vegetation. Impacts on wetland sites, 

however, can differ from impacts on upland sites because wetlands usually have a higher level of 

soil moisture and denser vegetation cover than non-wetlands, which can result in variable 
xvii 

impacts. These conditions can result in wetlands being more vulnerable to impact from certain 

activities. Wetlands are also considered unique habitats that support a diversity of vegetation 

and wildlife species, and so are protected by the Clean Water Act and other laws and policies. 

No burning or mechanical treatment in wetlands is prescribed in any of the alternatives; 

however, wetlands do occur in treated areas, and vegetation in some small wetlands may 

unintentionally be burned. Thinning may be required to reduce the risk of prescribed burns 

encroaching on wetland vegetation. 

In all three alternatives, short-term, minor adverse impacts from unintentional burning of 

vegetation are possible, especially in dry years. However, some research and observations at the 

Seashore indicate wetland vegetation can be thinned and stimulated to reproduce by low or 

moderate intensity fires. These same fires can destroy non-native plants in wetlands. Minor to 

moderate short to long-term benefits on wetland vegetation from prescribed burning or even 

small wildfires in an average year are therefore possible in all three alternatives. In both adverse 

effects and beneficial effects, the degree of impact is greater the more acreage treated; therefore 

beneficial impacts are more likely to be moderate in Alternative C than A, for example. 

Minor short-term adverse impacts on wetlands from unplanned wildfires and their suppression 

could occur in any alternative. Minor beneficial effects also could occur due to reduction of nonnative plant species or stimulation of germination and resprouting in native species. 

Mechanical treatments would avoid wetland areas to the greatest extent possible. If such 

treatments in wetlands were deemed necessary to ensure fire safety around structures or along 

roads, these treatments would have negligible to minor short-term adverse impacts on vegetation 

in Alternative A, and minor adverse impacts in Alternatives B or C. Clearing vegetation also 

could have minor short-term benefits to wetland species if native species establishment is 

enhanced in all three alternatives. 

Cumulative impacts from development in the park may have a minor adverse impact on 

wetlands. However, a large-scale wildfire could have major, long-term adverse impacts on 

wetlands from destruction of vegetation and reproductive ability, and invasion by non-native 

species. 

Wildlife 

The project area supports a wide diversity of wildlife species, including 28 species of reptiles and 

amphibians, 65 species of mammals, and breeding habitat for 130 species of birds. Nearly 490 

bird species (representing 45% of the avian fauna documented in the United States) have been 

sighted on land and over near shore waters at Point Reyes. PRNS is also home to innumerable 

invertebrates. The waters of the Pacific Ocean and Tomales Bay support rich and diverse 

fisheries. 

Generally, the effects of fire on wildlife depend on the characteristics of the fire itself (e.g., 

intensity, duration, frequency, size, shape, season, and time), the characteristics of the vegetation 

or habitat burned, and on species characteristics (e.g., size, mobility, habitat preferences). The 
xviii 

types of impacts to wildlife can be direct or indirect. Direct impacts include incineration, 

asphyxiation, injury, or avoidance of an area, and are most often experienced by less mobile 

species or life stages. Wildlife may also experience indirect effects. For example, fish or aquatic 

invertebrates can be harmed by sedimentation in a creek due to post-fire soil erosion, or 

carnivores can suffer from reductions in the prey base as a result of either direct mortality of the 

prey, or a reduction in the food and cover resources used by the prey species. 

Habitat loss itself is a possible adverse indirect impact from fire, and can be short- or long-term. 

Changes in vegetation structure and composition, down and dead woody material, and snags that 

occur after the fire can all affect wildlife. In particular, the loss of down and dead woody 

material and snags during a prescribed burn remove essential structural habitat components for a 

variety of wildlife and reduce species diversity (McMahon and deCalesta, 1990). Depending on 

the season, a fire can also have adverse effects on a species’ nesting or reproductive success. The 

nature of the fire, e.g., its severity, patchiness, whether it is a crown or understory fire, etc., will 

also determine if ground-dwelling or canopy-dwelling species are affected. If wildland fires 

burn extensive areas, and/or the fire is of high intensity, entire populations or subpopulations of 

wildlife can be affected. 

Wildlife can also benefit from fire. For instance, populations of species dependent on early seral 

stage vegetation increase following a burn. Vegetation that grows in the first 2-10 years after a 

burn often contains higher levels of nitrogen, which can cause increases in some herbivore 

populations. Decreased cover can improve the growth of forage and can improve predator 

hunting success. Decreased parasite loads and increased dispersion in some species can diminish 

disease levels. 

Hot, stand replacing fires, which become more likely with increased fuel loads, can type change 

the vegetation (e.g., a forest that changes to brush/grassland after a severe fire), and can have a 

long-term adverse impacts on fauna that thrived on the pre-fire habitat type. Patchy low intensity 

fires do not dramatically alter landscapes, remaining unburned vegetation provides habitat for 

existing species, and impacts are relatively minor and short-term. Evidence suggests that 

maintenance of a variety of successional stages with patchy fire patterns ensures the highest 

levels of wildlife biodiversity (Nichols and Menke, 1984). In other words, patchy, low intensity 

fires can provide long-term benefits to a variety of wildlife. 

Under Alternative A, prescribed fire and mechanical treatment would have a beneficial, short or 

long-term minor impact on wildlife by creating more open habitat and reducing the risk of 

catastrophic fire. Short-term minor adverse impacts on species using existing down wood or 

dense forest habitat are also likely. 

Some wildfire suppression activities or actions to control prescribed burns, such as spike camps, 

access or creating fire lines, would have short-term adverse and, therefore, minor impacts on 

wildlife. Others, such as creating helispots or the use of helicopter buckets of water or retardants, 

may have longer lasting impacts. Overall, these activities are not expected to have more than 

minor impacts to wildlife. This is true of Alternatives B and C as well. Impacts would remain 

minor, but be greater in Alternative B than A, and greater in Alternative C than B. Actions to 
xix 

suppress large fires would likely be more intense, with short-term major or long-term moderate 

adverse impacts to wildlife. 

The machinery used for chipping and shredding would be loud, which would have negligible, 

short-term impacts to some species, such as nesting birds, through disturbance. 

In the context of the 90,000 acre study area, the impacts to wildlife of Alternative B would be 

nearly indistinguishable from Alternative A. Treatment with prescribed fire and through 

mechanical means would result in short- to long-term, negligible to minor benefits to wildlife 

from the reestablishment of the natural fire cycle, reduction of fuel loads, and reduction of the 

potential for catastrophic wildfire. However, compared to No Action, Alternative B could offer 

moderate short- to long-term benefits to wildlife because twice as many acres would be treated 

(up to 2000 pre-year total; 2% of total acres managed) and effects would be noticeable on a local 

scale. Forest dwelling species would suffer negligible to minor short-term adverse impacts from 

reductions in habitat overall, and minor to moderate impacts relative to those from the No Action 

alternative. 

In the context of the entire study area, Alternative B would result in negligible to minor short- to 

long-term benefits to wildlife from creating open habitat using mechanical thinning. Compared 

to Alternative A, these benefits could be moderate. 

Treatment with prescribed fire and through mechanical means in Alternative C would result in 

short- to long-term, minor to moderate benefits to wildlife from the reestablishment of the 

natural fire cycle, reduction of fuel loads, and reduction of the potential for catastrophic wildfire. 

However, compared to No Action, Alternative C could offer moderate to major short- to longterm benefits to wildlife because up to four times as many acres would be treated (3500 total; 

3.5% of total acres managed) and be noticeable on a local scale. Forest dwelling species would 

suffer minor to moderate short-term adverse impacts from reductions in habitat overall, and 

moderate or even major localized impacts relative to those from the No Action Alternative A. 

In the context of the entire study area, Alternative C would result in minor short to long-term 

benefits to wildlife from creating open habitat using mechanical thinning. Compared to 

Alternative A, these benefits could be moderate. 

Special Status Species 

The study area supports 47 federally listed animal species - 14 are listed endangered, 8 are 

threatened, and 24 are “species of concern.” Among these are the endangered Brown Pelican 

(Pelecanus occidentalis) and Myrtle’s silverspot butterfly (Speyeria zerene myrtleae). Federally 

threatened species include Northern spotted owl (Strix occidentalis), Western snowy plover 

(Charadrius alexandrinus), and California red-legged frog (Rana aurora draytoni). Nineteen 

federally listed plant species (seven of which also are state listed) and an additional 25 species 

listed or proposed for listing by the California Native Plant Society (CNPS) have been 

documented in the study area. 
xx 

Federally listed plants in the study area that may be affected by fire management activities 

include Sonoma alopecurus (Alopecurus aequalis var. sonomensis), Sonoma spineflower 

(Chorizanthe valida), robust spineflower (Chorizanthe robusta), Tiburon paintbrush (Castilleja 

affinis ssp. neglecta), Marin dwarf flax (Hesperolinon congestum), beach layia (Layia carnosa), 

and Tidestrom’s lupine (Lupinus tidestromii [var. layneae]). Others are listed as federal “species 

of concern.” Species of concern are species for which USFWS is collecting additional 

information to determine if they warrant consideration for future listing. In addition, two species 

(Point Reyes blennosperma and Mason’s ceanothus) are considered rare by the state of 

California and one species is state endangered (Point Reyes meadowfoam). In Alternative A, 

although no federal or state listed species have been found in FMUs that would be treated with 

prescribed fire, one state rare species (Mason’s ceanothus) is present in the Bolinas Ridge FMU. 

Mason’s ceanothus does not occur in any FMUs slated for mechanical treatment in this 

alternative. Several federal species of concern are present in Estero and Limantour Road FMUs, 

which would be treated with both prescribed fire and mechanical thinning. 

The following threatened or endangered animal species are listed under the federal Endangered 

Species Act and may experience impacts from fire management activities: Northern spotted owl 

(Strix occidentalis caurina), California red-legged frog (Rana aurora draytonii), Central 

California coho salmon (Oncorhynchus kisutch), Central California Coast steelhead 

(Oncorhynchus mykiss), California freshwater shrimp (Syncaris pacifica), Myrtle’s silverspot 

butterfly (Speyeria zerene myrtleae), and Western snowy plover (Charadrius alexandrinus 

nivosus). The Seashore is also home to many animal federal species of concern and those listed 

by the state of California. One species in particular from this list, the Point Reyes mountain 

beaver is discussed in more detail because it may be more likely than other species to experience 

effects from fire or fire management activities. 

Fire management activities have potential to affect these species in the ways identified above in 

the sections on vegetation, wetlands, and wildlife. For example, several of these species occupy 

stream or riparian habitat, which could be adversely affected by increased sedimentation in 

creeks and/or persistent turbidity following wildland or prescribed fire. Fire management 

activities such as cutting fire line or removing vegetation to reduce fuel accumulations could 

destroy or harm individuals or damage their habitat. Conversely, as is the case for common 

plants and wildlife, many special-status species in the project area are adapted to periodic fire, 

and application of fire to the ecosystems could benefit these species by providing a wider 

diversity of habitats, by stimulating seed germination, or by improving habitat for prey species. 

All known individuals of the seven federally threatened and endangered plant species in the 

study area occur only in the Minimum Management FMU, so would not be subject to either 

prescribed burning or mechanical fuels treatments. The populations could be subject to impacts 

associated with an unplanned wildfire or by fire suppression activities, but this is unlikely 

because the populations occur in wet sites, within pastures routinely grazed by cattle, or in 

beaches or rocky outcroppings where fire is unlikely to carry. 

Plant species that are not federally listed, but are of concern are more likely to benefit from 

prescribed burning, as the Point Reyes ecosystem evolved in a regime that included frequent 

low-intensity fires. As progressively more of the study area is treated, natural fire cycles and 
xxi 

intensities would be more likely over a wider area. Therefore, benefits from Alternative C would 

be greater than Alternative B, and Alternative B greater than Alternative A, although all would 

be minor on a landscape scale. Some patches or individuals of these species may experience 

minor, adverse effects from destruction through fire or suppression, or from the inadvertent 

stimulation of invasive exotic species by burning in any of the alternatives. 

In Alternative A, prescribed fire and mechanical treatments would offer negligible to minor, 

long-term benefits on a limited scale to Northern spotted owls, red-legged frogs, and California 

freshwater shrimp (from fire only) by reducing the threat of catastrophic fire and the resultant 

habitat destruction. This benefit would increase as the number of acres treated increases, to 

minor benefits in Alternative B and moderate benefits in Alternative C. Mechanical treatments 

such as hand thinning and pile burning (actions taken to manage prescribed fire) could have a 

minor, short-term adverse effect on owls through human disturbance, reduction of prey species, 

and habitat alteration in unknown roosting and nesting sites; and on frogs from inadvertently 

killing individuals in all three alternatives. Large-scale wildfires could have more serious adverse 

effects on owls by eliminating habitat, and on frogs by burning riparian vegetation and 

increasing sedimentation in any of the alternatives. Both these species experience a positive 

cumulative impact from the large blocks of conservation land adjacent to the study area. 

Under any alternative, adverse impacts to coho salmon and steelhead trout from prescribed 

burning would be negligible to minor, as riparian vegetation would be retained. Negligible 

positive benefits from reducing the risk and extent of a catastrophic burn would result from both 

prescribed burning and mechanical thinning. A large-scale wildfire would have more serious 

adverse effects by increasing siltation of streams and burning riparian vegetation, which in turn 

would increase water temperature. 

Both Myrtle’s silverspot butterfly and snowy plovers occur only in the Minimum Management 

FMU, and would not be subject to either prescribed burning or mechanical fuel treatments in any 

alternative. The populations could be subject to impacts associated with an unplanned wildfire or 

by fire suppression activities, but this is unlikely because the populations occur within pastures 

routinely grazed by cattle (silverspot) or beach areas (plover) where fire is unlikely to carry. 

The impacts of fire management activities, including those of average size and intensity wildfires 

in the study area on Point Reyes mountain beaver would be kept to no more than minor and 

short-term through the use of mitigation measures in any alternative. Large-scale wildfires could 

have moderate adverse impacts that may be long-term. 

There would be some indirect long-term benefits by conducting research and fire education. 

There are no adverse impacts to special status species by the construction of the fire cache in any 

alternative. 

Cultural Resources 

The Seashore has recorded 124 prehistoric, terrestrial sites, and estimates an additional 41 to 123 

occur within current park boundaries. These sites are either habitation or use sites that reflect 

Coast Miwok occupation or resource processing sites. Another 92 historic terrestrial 
xxii 

archeological sites have been recorded, and it is estimated that another 5 to 37 sites are likely to 

exist within the boundaries of PRNS. These sites typically reflect historic occupations and use of 

the peninsula; first by homesteaders and dairy ranch communities, and later by government 

lighthouse and lifesaving personnel and private radio telecommunications companies. Park 

cultural resource staff has also documented nine known and recorded terrestrial archeological 

sites that contain both prehistoric and historic components (not necessarily related to each other). 

They estimate another 5 to 14 such sites exist within park boundaries, but have not yet been 

identified. PRNS also manages 39 cultural landscapes; 23 are within the boundaries of Point 

Reyes National Seashore and 16 are within the North District of GGNRA. The landscapes 

primarily reflect the maritime, ranching, communications, and military history of the park. 

The intensity of a fire and susceptibility of resources to heat ultimately determines the degree of 

damage from the direct effect of fire. In general, the longer a cultural resource is exposed to 

heat, the greater the likelihood of damage. Fire can result in the complete elimination of an 

artifact or feature (e.g., through consumption) or can alter attributes of an artifact or feature such 

that important research (e.g., obsidian hydration rinds, residues on pottery, bone burning) is 

hindered, or traditional (e.g., Native American spiritual sites) or other values are impacted. 

The behavior of a fire (ground, surface, or crown) and proximity to a cultural resource are also 

important. While running surface fires and crown fires reach extreme temperatures (500 to 1500° 

C) and have high energy release rates, relatively little of that heat is directed towards the surface 

of the ground. Conversely, ground fires can result in long duration heating (400 to 700° C) 

within the upper 15 cm. of the soil profile. Ground or creeping active surface fires are usually 

associated with prescribed burns, whereas running surface and crown fires occur primarily 

during wildfires. Very generally, cultural resources located above the ground surface (e.g., rock 

imagery panels, historical structures) are most vulnerable to direct fire effects during crown and 

active surface fires, while ground and creeping surface fires threaten those found at or just below 

the ground surface (e.g., archeological sites). Because of this, the chances of adversely affecting 

a high percentage of cultural resources found exclusively on or near the ground surface are often 

greater. This is significant because cultural resources generally considered to have high data 

potential, such as Native American villages with subsurface components, may actually have a far 

lower percentage of artifact classes or attributes exposed to direct fire effects than a lithic scatter, 

often considered to have low data potential that is restricted to the ground surface. 

Direct effects of fire management actions on cultural resources can also be beneficial, as 

mechanical thinning or reduction of fuels around important cultural resources can result in their 

preservation should a wildfire occur in the same area. 

Impacts can also result from fire management operations, including mechanical thinning and fire 

suppression. These effects would generally be restricted to the displacement, breakage, and/or 

destruction and looting of cultural resources. Except in rare situations, operational effects are 

likely to be most pronounced on cultural resources found on and near the ground surface. 

Operational effects would be most likely to occur, and at the greatest intensity, during wildfires. 

This is due primarily to the fact that such actions are often carried out with little or no preplanning and without consultation or supervision by a cultural resource specialist. 
xxiii 

All alternatives would result in moderate short-term benefits to historic buildings by reducing 

fuels around these structures, both through prescribed burns and mechanical treatment. Benefits 

would remain moderate but be greater in Alternative C than Alternative B, and in Alternative B 

than Alternative A. 

Mitigation measures would keep adverse impacts to archeological resources from pre-treatment 

prescribed burns, or mechanical thinning activities from becoming more than short-term and 

minor in Alternatives A and B. The potential for these impacts to archeological resources is 

moderate in Alternative C because more acres and FMUs are being treated. 

Moderate long-term benefits to cultural landscapes such as grasslands from their restoration or 

maintenance of them through prescribed fire or mechanical treatments are also likely in all 

alternatives, although benefits would be greater in Alternative C than Alternative B, and greater 

in Alternative B than in Alternative A. 

All alternatives could have negligible impacts to permanent major adverse effects on cultural 

resources, including historic structures and archeological resources from suppression activities 

associated with even average sized wildfires. Impacts to cultural landscapes, however, would be 

minor to moderate, as only a small portion of the landscape would be burned. Larger wildfires 

would be much more likely to result in major permanent impacts from the burning of historic 

structures, damage to buried resources, and the loss of a significant portion of cultural 

landscapes. 

No adverse or beneficial effects are anticipated with the construction of the new fire cache or 

implementing research activities on historic structures, archeological sites, or cultural 

landscapes. 

Visitor Use and Visitor Experience 

The project area is unique not only in its assemblage of natural and cultural features, but also in 

its proximity to a major urban population. This juxtaposition makes PRNS’s resources and 

recreational opportunities readily accessible to a large number of people, and enhances the 

importance of the special qualities for which it was set aside. Over 2.25 million people visit 

PRNS annually. Visitation estimates for 2002 found that the North District of the park (north of 

Bear Valley) receives roughly 60% of the overall visitation. Over 700,000 visitors went to the 3 

park visitor centers and over 70,000 visitors have extended contacts with park interpretive staff 

through ranger-led programs. 

The area supports 147 miles of hiking trails, backcountry campgrounds, and numerous beaches. 

Activities include hiking, water sports, horseback riding, fishing, camping, wildlife viewing, and 

other interpretive opportunities. 

Hiking is primarily a day-use activity. Approximately 50 trails are designated throughout PRNS, 

and they encompass a range of habitat types from wooded mountains to sandy beaches. 

Overnight stays are available through four backcountry campgrounds: the Stewart Horse Camp, 

the Point Reyes Hostel, a private campground, and local hotels and inns. Dozens of visitors 
xxiv 

bring horses to ride on designated horse trails, and hundreds rent horses every week from 

commercial stables. 

Water sports include kayaking, canoeing, boating, and swimming. The majority of paddle crafts 

use Tomales Bay as it provides protection from ocean waves and surf, while power boaters more 

freely use the ocean. Though Stinson Beach and Bolinas attract more surfers, North Beach is 

known as a challenging surfing area. Nature study and wildlife viewing are important activities 

at Point Reyes. Visitors make special trips to PRNS to see migrating whales, shorebirds, 

breeding elephant seals, tule elk, and spring wildflowers. Information received from visitor 

surveys conducted by Sonoma State University (NPS, 1997 and NPS, 1998) found that most park 

visitors spend 2-6 hours at PRNS in a variety of activities dependent upon the season, ranging 

from whale watching and kayaking to hiking and bird watching. 

The NPS gathers standardized annual surveys for each park unit to determine the percent of 

visitor satisfaction based on park facilities, visitor services, and recreational opportunities. 

During Fiscal Year 2002, based on a random visitor survey conducted by the University of 

Idaho, the park received a 98% visitor satisfaction ranking (NPS, 2002a). 

Prescribed burning would have minor positive effects by opening and restoring scenic vistas in 

all alternatives, but varying adverse effects on some visitor activities from blackening of 

vegetation from prescribed fires. In Alternatives A and B, this adverse effect would be minor, but 

because more acreage would be treated with prescribed fire in Alternative C, the impact may be 

more moderate. Smoke and closures would also have temporary minor adverse impacts on 

visitors in Alternatives A and B, but may extend to up to 50 days out of the year to complete 

burning in Alternative C, a moderate adverse impact. 

Mechanical treatment may adversely affect nearby visitors through noise and closures. In 

Alternatives A and B, these impacts would be minor. However, because closures would be more 

extensive in Alternative C, impacts would be moderate. Changes in the treated area resulting 

from mowing or hand cutting would be adverse for some visitors, but beneficial for others. Pile 

burning may also cause localized changes that some visitors find to be negative and others 

positive. Overall, impacts from mechanical treatment would be short-term and minor in 

Alternatives A and B, and moderate in Alternative C, regardless of whether they are adverse or 

beneficial. 

 

Actions to suppress wildfire have the potential to have short-term effects on visual resources, in 

the form of evidence of helispots and spike camps. These effects would be local in scale and 

probably not be encountered by most visitors. Effects would be adverse, short-term, and minor in 

all three alternatives. 

Providing information to the public to increase understanding of the objectives of the fire 

program would be indirectly beneficial, minor, and long-term in any alternative. 

The relocation of the fire cache would have short-term adverse impacts to visitors from noise and 

dust associated with construction. 
xxv 

While construction projects or past fire management activities would have no more than minor 

short-term cumulative impacts to visitors, a large-scale wildfire could result in major adverse 

impacts to recreational activities or scenic quality for several years in any of the alternatives. 

Park Operations 

The park currently has about 90 permanent staff, 23 term employees, and 47 temporary staff 

working on a variety of projects and programs. This represents about 115 FTE (full time 

equivalents or one person for a full year). During the peak summer months, the park staff 

increases to about 160 staff members, including Youth Conservation Corps enrollees who 

provide assistance in a number of ways to Point Reyes National Seashore. This work force is 

supplemented by 20,000 hours of Volunteers-in-Parks service, three Student Conservation 

Assistants, and AmeriCorps. 

The Fire Management Office is staffed by a Fire Management Officer, a program analyst, a 

hazardous fuels specialist, an eight-person hazard fuels crew, one engine foreman, and a fourperson engine crew. Three fire staff members are also trained as emergency medical technicians 

at the basic life support level. Providing technical assistance to both the fire management offices 

at PRNS and GGNRA are technical staff including a GIS technical specialist, an education 

specialist, and an environmental planner. PRNS, GGNRA, and Pinnacles National Monument 

share a fire ecologist and a team of five fire effects monitors. PRNS has mutual aid agreements 

with Marin County Fire Department, Bolinas Fire Protection District, Inverness Public Utility 

District, and Nicasio Volunteer Fire Department. While PRNS has direct protection authority for 

federal lands, Marin County has been given “delegated initial attack responsibility” for these 

same lands. This allows Marin County to assume authority of initial suppression actions until 

Seashore firefighters arrive. 

Financial resources available to achieve the park’s annual goals include a base operating budget 

of approximately $4,900,000. In addition, the park receives supplemental support for fire 

operations, cyclic maintenance, special natural resource projects, and repair and rehabilitation of 

structures. Fire funding for operations is approximately $770,000 annually for wildfire 

suppression, mechanical treatments, and prescribed fire. For the last three years, Point Reyes 

and GGNRA have received an additional $700,000 annually for Wildland Urban Interface 

(WUI) projects. Staffing for all aspects for fire management is approximately 13 FTE’s. 

Because funding and staffing levels would remain the same for all aspects of the fire 

management program, no positive or adverse impacts to either are expected from No Action. 

Small increases in budget in Alternative B to conduct additional prescribed burning and thinning 

would have minor adverse impacts to park operations and management compared to Alternative 

A. This alternative would require $211,000 in annual operating funds, a 3.8% increase to overall 

park funding. An overall 5.9% increase in budget and additional 5 FTEs in staffing in Alternative 

C to conduct additional prescribed burning and thinning would have minor adverse impacts to 

park operations and management compared to Alternative A. 
xxvi 

The one time funding of a new fire cache would have a short-term negligible adverse impact to 

the park’s budget, but would have long-term minor benefits in terms of fire management 

operations by creating new efficiencies. 

Ongoing past, present, and future development and resource management projects in the park 

would have a negligible adverse effect on park operations and management. However, 

suppression of a large-scale wildfire would result in a short-term adverse major effect on park 

operations, management, and budget. This is true for any of the alternatives. 

The cumulative impacts of all the projects listed with this proposed action (except large-scale 

wildfire) would have a negligible adverse effect on park operations and management. 

Suppression of a large-scale wildfire would a short-term adverse major effect on park operations, 

management, and budget. 

Public Health and Safety 

The protection of public and firefighter safety is the most important goal of the PRNS fire 

management plan, and many of the actions in each alternative are geared to provide the most safe 

and defensible environment possible. In addition, several of the communities in the vicinity, 

including Inverness, Bolinas, and Olema, were recently published in the Federal Register as key 

communities at risk from wildfire because of their proximity to forested federal lands managed 

by the Departments of Agriculture and Interior. In recognition of potential risk, the National 

Park Service, through the Wildland Urban Interface (WUI) Program, has been funding fire 

education, fuel reduction, and roadway improvement projects in these communities; 2002 is the 

third year of local National Fire Plan funding. 

Prioritization of projects needed in the wildland urban interface has been informed by a study of 

strategies for rehabilitating the resources in the Vision Fire burn area and preventing future 

similar occurrences. Prepared for the Environmental Action Committee of West Marin, “After 

the Vision Fire,” prepared by the Phoenix Team, documented many of the projects that have 

subsequently been funded and implemented on private and federal lands with Wildland Urban 

Interface funding. 

The EAC Phoenix Report (1996) recognizes that the most fundamental line of defense to 

increase public safety is to promote conformance with code requirements for defensible space 

and reduced fuels around homes and along streets providing emergency ingress and egress. 

The WUI program money has been used by the park and other agencies to clear fuel or thin 

brush from subdivision roads, as well as to complete fire hazard assessments. The next round 

will focus on creating fuel breaks between open space lands and residential areas. Actions in this 

FMP in the Inverness Ridge, Limantour, Palomarin, and Olema FMUs would improve safety to 

responding firefighters, reduce fuels along existing fire roads, and create zones of reduced fuels 

to impede fire spread. 

The principal effect of FMP activities on public health is generation of smoke, especially 

particulate matter, from prescribed fires and unintended wildland fire. Particulate matter, found 
xxvii 

in the air-liquid droplets and small solid particles of minerals and soot, can penetrate deep into 

the lungs. In smoke, roughly 80% of the particulate matter is smaller than 2.5 micrometers in 

diameter. 

Healthy adults are not usually at risk from particulate matter; they may experience runny noses 

and coughing but these symptoms usually subside as the smoke disperses. People with heart or 

lung diseases, such as congestive heart disease, chronic obstructive pulmonary disease, 

emphysema, or asthma, can be at risk. People with these conditions may find it difficult to 

breathe, may cough or feel short of breath. Children and the elderly are generally more 

susceptible to the harmful effects of smoke (CARB, 2003). 

The actions in all alternatives would have direct adverse, short-term and minor impacts upon the 

health and safety of both the public and firefighters, except during large, high severity fire 

events, when the proximity of people to smoke and flame would result in major, short-term, and 

unavoidable adverse impacts. 

Alternative A minimizes smoke impacts in the short-term, but offers no more than negligible 

benefits in addressing the continued accumulation of fuels that is a wildfire risk to adjacent 

communities. These benefits would increase to moderate and long-term in Alternatives B and C 

from the reduction of fuels through both prescribed fire and mechanical thinning and reduction in 

the risk of catastrophic fire would occur. 

Public education, fire research, and fire cache construction would provide minor benefits by 

informing the public of prescribed burns and by reducing response time and increasing response 

effectiveness. 

Socioeconomics 

Point Reyes National Seashore received 2.35 million visitors in 2000 accounting for 930 travel 

party days/nights in the area. An average visitor party spends $94 per party per night in the local 

area ($109 if locals excluded). Total visitor spending was $87 million in 2000, $80 million 

excluding local visitors. This spending of visitors from outside the local region generates $69 

million in sales by local tourism businesses, yielding $25.6 million in direct income and 

supporting 1,100 jobs. Each dollar of tourism spending yields another $.63 in sales through the 

circulation of spending within the local economy. Including these secondary effects, the total 

economic impact of the park on the local economy is $113 million in sales, $42 million in wages 

and salaries, and 1,800 jobs (Michigan State University, 2001). 

The park has not received complaints from visitors during past prescribed fires in the park (pers. 

comm. Neubacher, 2003). Park visitation dropped dramatically for the first few months after the 

1995 Vision Fire, but returned to normal within six months. 

Under all alternatives, direct fire funding and staffing would have long-term, beneficial impacts 

compared to dollars and staff positions generated from tourism in the local economy. These 

benefits would be minor in Alternatives A and B, and moderate in Alternative C. 
xxviii 

In any alternative, the prescribed burn program is not expected to result in more than very shortterm closures of small areas, with no or negligible adverse impacts on tourism and the local 

economy. Areas may be closed during mechanical treatment, which because it lasts longer, may 

result in negligible to minor short-term impacts to tourism and the local economy. 

In past years, average sized unplanned ignitions have not impacted the regional economy or the 

visitor population of the park. However, there have been short-term, negligible impacts to the 

local economy due to minor closures of areas during suppression for short periods (less than one 

day). This would continue under any of the alternatives. 

Additional building and other projects in the Seashore would have a minor beneficial cumulative 

effect on the local economy. Cumulative effects from a larger wildfire, should it occur, could be 

major and both adverse and beneficial. Adverse impacts would result from the loss of property 

and money spent to suppress the fire, but benefits would also result from rebuilding and the 

influx of federal money. 
xxix 

Table of Contents 

Executive Summary........................................................................................................................ v 

Introduction ................................................................................................................................. v 

Planning Issues Considered....................................................................................................... vii 

Alternatives ............................................................................................................................... vii 

Environmental Impacts ............................................................................................................... x 

Soils ......................................................................................................................................... x 

Air Quality.............................................................................................................................. xi 

Watersheds and Water Quality.............................................................................................. xii 

Vegetation............................................................................................................................. xiv 

Wetlands ............................................................................................................................... xvi 

Wildlife................................................................................................................................ xvii 

Special Status Species .......................................................................................................... xix 

Cultural Resources................................................................................................................ xxi 

Visitor Use and Visitor Experience....................................................................................xxiii 

Park Operations ................................................................................................................... xxv 

Public Health and Safety .................................................................................................... xxvi 

 Socioeconomics ................................................................................................................. xxvii

CHAPTER 1: Purpose and Need for Action...............................................................1 

Introduction ................................................................................................................................. 1 

Purpose of the Fire Management Plan..................................................................................... 4 

Need for the Fire Management Plan........................................................................................ 4 

Fire Management Plan Goals .................................................................................................. 4 

Legislative and Policy Constraints and other Considerations used in Developing the Fire 

Management Plan .................................................................................................................... 5 

Issues and Concerns Raised During Scoping ........................................................................ 10 

Issues Dismissed from Further Consideration....................................................................... 13 

Selection of Impact Topics.................................................................................................... 13 

CHAPTER 2: Alternatives -Including the Preferred Alternative ................................................. 16 

Overview of Alternatives .......................................................................................................... 17 

Discussion of Fire Management Units .................................................................................. 19 

Actions Common to All Alternatives .................................................................................... 29 

General Description of Prescribed Fire and Mechanical Fuels Treatments .......................... 35 

Alternative A (No Action) - Continued Fuel Reduction for Public Safety and Limited 

Resource Enhancement.......................................................................................................... 37 

Alternative B - Expanded Hazardous Fuel Reduction and Additional Natural Resource 

Enhancement ......................................................................................................................... 40 

Alternative C - Increased Natural Resource Enhancement and Expanded Hazardous Fuel 

Reduction............................................................................................................................... 47 

Mitigation Measures.............................................................................................................. 53 
xxx 

Alternatives Considered But Not Analyzed Further in This FEIS ........................................ 63 

The Environmentally Preferred Alternative .......................................................................... 64 

The Preferred Alternative ...................................................................................................... 65 

CHAPTER 3: Affected Environment ........................................................................................... 74 

Introduction ............................................................................................................................... 75 

Project Setting ........................................................................................................................... 75 

Overview ............................................................................................................................... 75 

Regional Context and Surrounding Communities................................................................. 77 

Park Management Zoning ..................................................................................................... 77 

Natural Resource Zones......................................................................................................... 80 

Historic Resource Zones........................................................................................................ 81 

Geology and Topography ...................................................................................................... 81 

Fire Regime ........................................................................................................................... 83 

Fire History............................................................................................................................ 86 

Affected Environment............................................................................................................... 88 

Soils ....................................................................................................................................... 88 

Air Quality............................................................................................................................. 93 

Water Resources.................................................................................................................. 100 

Vegetation............................................................................................................................ 104 

Wetlands .............................................................................................................................. 115 

Wildlife................................................................................................................................ 116 

Special Status Species ......................................................................................................... 118 

Habitats of Management Concern ....................................................................................... 152 

Cultural Resources............................................................................................................... 152 

Visitor Use and Visitor Experience..................................................................................... 157 

Park Operations ................................................................................................................... 159 

Public Health and Safety ..................................................................................................... 163 

Socio-Economics................................................................................................................. 165 

CHAPTER 4: Environmental Consequences.............................................................................. 168 

Introduction ............................................................................................................................. 169 

Definition of Terms................................................................................................................. 169 

Regulations and Methodology by Impact Topic..................................................................... 171 

Soils ..................................................................................................................................... 171 

Air Quality........................................................................................................................... 174 

Water Resources and Water Quality ................................................................................... 184 

Vegetation............................................................................................................................ 185 

Wetlands .............................................................................................................................. 187 

Wildlife................................................................................................................................ 189 

Special-Status Species ......................................................................................................... 191 

Cultural Resources............................................................................................................... 195 

Visitor Use and Visitor Experience..................................................................................... 199 

Park Operations ................................................................................................................... 202 

Public Health and Safety ..................................................................................................... 204 

Socioeconomics................................................................................................................... 205 

Impact Analysis....................................................................................................................... 206 

Impacts to Soils ....................................................................................................................... 206 
xxxi 

Alternative B........................................................................................................................ 219 

Alternative C........................................................................................................................ 224 

Impacts to Air Quality............................................................................................................. 228 

Alternative A ....................................................................................................................... 229 

Alternative B........................................................................................................................ 235 

Alternative C........................................................................................................................ 239 

Impacts to Water Resources and Water Quality ..................................................................... 243 

Alternative A ....................................................................................................................... 243 

Alternative B........................................................................................................................ 249 

Alternative C........................................................................................................................ 252 

Impacts to Vegetation.............................................................................................................. 254 

Types of Impacts ................................................................................................................. 254 

Types of Effects From Prescribed Burning ......................................................................... 255 

Types of Effects from Wildland Fires and Suppression...................................................... 255 

Types of Effects From Mechanical Treatment.................................................................... 256 

Alternative A ....................................................................................................................... 267 

Alternative B........................................................................................................................ 281 

Alternative C........................................................................................................................ 290 

Impacts to Wetlands................................................................................................................ 295 

Alternative A ....................................................................................................................... 295 

Alternative B........................................................................................................................ 299 

Alternative C........................................................................................................................ 301 

Impacts to Wildlife.................................................................................................................. 302 

Types of Impacts ................................................................................................................. 302 

Invertebrates, Amphibians, and Reptiles............................................................................. 304 

Fisheries and Aquatic Species ............................................................................................. 304 

Birds..................................................................................................................................... 305 

Mammals ............................................................................................................................. 305 

Alternative A ....................................................................................................................... 306 

Alternative B........................................................................................................................ 312 

Alternative C........................................................................................................................ 315 

Impacts on Special-Status Species .......................................................................................... 318 

Alternative A ....................................................................................................................... 318 

Alternative B........................................................................................................................ 347 

Alternative C........................................................................................................................ 359 

Impacts to Cultural Resources................................................................................................. 369 

Alternative A ....................................................................................................................... 369 

Alternative B........................................................................................................................ 377 

Alternative C........................................................................................................................ 379 

Impacts to Visitor Use and the Visitor Experience................................................................. 381 

Alternative A ....................................................................................................................... 381 

Alternative B........................................................................................................................ 386 

Alternative C........................................................................................................................ 388 

Impact to Park Operations....................................................................................................... 390 

Alternative A ....................................................................................................................... 390 

Alternative B........................................................................................................................ 392 
xxxii 

Alternative C........................................................................................................................ 394 

Impacts to Human Health and Safety...................................................................................... 396 

Alternative A ....................................................................................................................... 396 

Alternative B........................................................................................................................ 399 

Alternative C........................................................................................................................ 401 

Socioeconomic Impacts........................................................................................................... 402 

Alternative A ....................................................................................................................... 402 

Alternative B........................................................................................................................ 405 

Alternative C........................................................................................................................ 408 

Mandatory Sections................................................................................................................. 410 

Alternative A ....................................................................................................................... 410 

Alternative B........................................................................................................................ 410 

Alternative C........................................................................................................................ 411 

CHAPTER 5: Consultation and Coordination............................................................................ 412 

Public Involvement and Scoping............................................................................................. 413 

Compliance Status................................................................................................................... 413 

List of Preparers ...................................................................................................................... 416 

List of Consultants .................................................................................................................. 416 

Participating Governmental Agencies..................................................................................... 416 

Federal Agencies ................................................................................................................. 416 

Federal Advisory Groups..................................................................................................... 417

Elected Officials .................................................................................................................. 417 

State Agencies ..................................................................................................................... 417 

Regional, County, and Municipal Agencies........................................................................ 417 

Non-Governmental Organizations, Non-Profit Organizations, etc. .................................... 418 

Libraries............................................................................................................................... 419 

Comments Received and NPS Responses to Comments ........................................................ 420 

I. Introduction ...................................................................................................................... 420 

II. Comment Received and Response to Comments ........................................................... 421 

Appendix A: Glossary of Terms and Acronyms......................................................................... 451 

NEPA Terminology................................................................................................................. 452 

Acronyms ................................................................................................................................ 455 

Fire Terms and Definitions ..................................................................................................... 456 

Appendix B: List of Classified Structures .................................................................................. 461 

Appendix C: Other Projects Considered in Cumulative Impacts Analysis ................................ 475 

Appendix D: Biological Opinion United States Fish and Wildlife Service................................ 479 

Literature Cited ........................................................................................................................... 503 

Index........................................................................................................................................ 533 
xxxiii 

List of Tables 

Table 1. Maximum Number of Acres that would be Treated with Prescribed Fire and 

Mechanical Treatment in Any One Year Under the Three Alternatives. ..................................... 18 

Table 2. Fire Management Units That Would Be Subject To Treatment Beyond Clearing 

Around Buildings Of Fire Roads And Trails (Prescribed Fire, Mechanical Treatment Or Both) 

Under Each Alternative................................................................................................................. 24 

Table 3. Federal, State, and California Native Plant Society (CNPS) Listed Plant Species in each 

Fire Management Unit. ................................................................................................................. 25 

Table 4. Fire Roads and Trails in Pt. Reyes Receiving Annual or Periodic Maintenance .......... 31 

Table 5. Range of FMP Alternatives Compared by Fire Management Goals............................. 65 

Table 6. Summary of Preferred Alternative and Alternatives ..................................................... 66 

Table 7. Summary of Impacts of Alternatives............................................................................ 68 

Table 7A. Erosion Hazard Potential Per FMU ............................................................................ 92 

Table 8. Temperature and Precipitation Data for Bear Valley- Point Reyes National Seashore, 

California ...................................................................................................................................... 96 

Table 9. Ambient Air Quality Standards & Bay Area Attainment Status ................................... 97 

Table 10. Ambient Ozone Standards and Levels at Santa Rosa: 1999-2001............................... 99 

Table 11. Percent of Project Area in Project Watersheds.......................................................... 101 

Table 12. Acres Within Each General Vegetation Class Within Each Fire Management Unit. 105 

Table 13. Marsh and Other Wetland Acreage in each FMU Where Management Would Take 

Place............................................................................................................................................ 116 

Table 14. Sonoma alopecurus Occurrences and Numbers of Plants from 2000-2003 .............. 119 

Table 15. Federal Threatened, Endangered, Candidate, and Proposed Plant Species that may 

occur in Areas Affected by PRNS's Fire Management Plan (per USFWS Letter, May 24, 2001).

..................................................................................................................................................... 119 

Table 16. Population Estimates for Sonoma Spineflower on G Ranch 1980-2002 (intermittent)

..................................................................................................................................................... 121 

Table 17. Monitoring for Tiburon paintbrush (Nicasio Ridge) ................................................. 122 

Table 18. Occurrences and Estimated Numbers of Marin Dwarf Flax on Nicasio Ridge......... 123 

Table 20. Tidestrom's lupine Occurrences and Estimated Numbers, 2000-2002...................... 124 

Table 21. Plant Species of Concern and California-listed Species that may Occur in Areas 

Affected by PRNS’s Fire Management Plan (per USFWS Letter, May 24, 2001). ................... 126 

Table 22. Additional Plant Species of NPS Management Concern that Occur in Areas Affected 

by PORE's Fire Management Plan.............................................................................................. 127

Table 23. Site History of Northern Spotted Owl Activity Centers within PRNS and the Northern 

District of GGNRA..................................................................................................................... 129 

Table 24. Federal Threatened, Endangered, Candidate, and Proposed Animal Species that May 

Occur in Areas Affected by PRNS's Fire Management Plan (per Attachment A in USFWS Letter, 

May 24, 2001)............................................................................................................................. 132 

Table 25. Potential Impacts on Red-legged Frog Aquatic Habitats........................................... 134 

Table 26. Coho Salmon Spawning Survey Data for Overall Lagunitas Creek Watershed........ 139 

Table 27. Total Coho Redds in Lagunitas Creek Watershed, 1995-2003 (MMWD & PRNS). 140 

Table 28. Coho Salmon Spawning Survey Data for Lagunitas Creek Mainstem...................... 141 

Table 29. Coho Salmon Spawning Survey Data for Devil’s Gulch .......................................... 142 

Table 30. Coho Salmon Spawning Survey Data for Olema Creek Mainstem........................... 143 
xxxiv 

Table 31. Coho Salmon Spawning Survey Data for the John West Fork.................................. 144 

Table 32. Snowy plover Nesting at PRNS................................................................................. 149 

Table 33. Animal Species of Concern and California-listed Species That May Occur in Areas 

Affected by PORE's Fire Management Plan (per USFWS Letter, May 24, 2001)..................... 150 

Table 34. Cultural Landscapes................................................................................................... 155 

Table 35. National Register Status............................................................................................. 157 

Table 36. Federal Wilderness in the Fire Management Units ................................................... 163 

Table 37. Ambient Air Quality Standards & Bay Area Attainment Status ............................... 175 

Table 38. Vegetation Cover Types Used in Air Quality Emissions Analysis ........................... 179 

Table 39. Smoke Emission Factors by Fire Type...................................................................... 180 

Table 40. Emission Factors for Equipment Use in Fire Management Activities ...................... 181 

Table 41. Alternative A, Potential Watershed Level Effects..................................................... 211 

Table 42. Alternative B: Potential Watershed Level Effects..................................................... 220 

Table 43. Alternative C: Potential Watershed Level Effects..................................................... 225 

Table 44. Projected Annual Fire Management Emissions Under Alternative A....................... 231 

Table 45. Determination of Cumulative Effect on Air Quality Alternative A .......................... 234 

Table 46. Projected Annual Fire Management Emissions under Alternative B........................ 235 

Table 47. Determination of Cumulative Effect on Air Quality Alternative B........................... 238 

Table 48. Projected Annual Fire Management Emissions under Alternative C........................ 239 

Table 49. Determination of Cumulative Effect on Air Quality Alternative C........................... 242 

Table 50. Broom Acreage within Fire Management Units......................................................... 268 

Table 51. Eucalyptus Acreage occurring within Fire Management Units................................. 288 

Table 52. Number of Occurrences and Estimated Population Trends for Listed Plant Species in 

the Project Area........................................................................................................................... 319 

Table 53. Potential Impacts on Red-legged Frog Aquatic Habitats from Fire Management 

Activities..................................................................................................................................... 327 
xxxv 

List of Figures 

Figure 1. Project Area- Point Reyes National Seashore and North District of Golden Gate 

National Recreation Area......................................................................................2

Figure 2. Regional Context Map..............................................................................3 

Figure 3. Fuel Ranking Map Measuring Risk of Wildland Fire................................................... 20 

Figure 4. Potential Living Unit Loss Measuring the Risk of Wildland Fire................................. 21 

Figure 5. Resistance of Control Measuring the Risk of Wildland Fire ........................................ 22 

Figure 6. Map of Project Area Showing All Fire Management Units.......................................... 23 

Figure 7. Map of Project Area Showing Alternative A FMUs..................................................... 38 

Figure 8. Map of Project Area Showing Alternative B FMUs ..................................................... 41 

Figure 9. Map of Project Area Showing Alternative C FMUs ..................................................... 49 

Figure 10. Population Density for San Francisco Bay Area in 1990........................................... 76 

Figure 11. Local Communities .................................................................................................... 78 

Figure 14. Point Reyes National Seashore Soil Map Unites ........................................................ 90 

Figure 17. Vegetation in Tomales Point FMU........................................................................... 257 

Figure 18. Vegetation in the Headlands FMU........................................................................... 258 

Figure 19. Vegetation in the Estero FMU.................................................................................. 259 

Figure 20. Vegetation in Inverness Ridge FMU........................................................................ 260 

Figure 21. Vegetation in the Limantour Road FMU.................................................................. 261 

Figure 22. Vegetation in Wilderness North FMU ..................................................................... 262 

Figure 23. Vegetation in Wilderness South FMU ..................................................................... 263 

Figure 24. Vegetation in Highway One FMU ............................................................................ 264 

Figure 25. Vegetation in Bolinas Ridge FMU ....................................................... 265 

Figure 26. Vegetation in Palomarin FMU...... ....................................................... 266 

 
xxxvi 
CHAPTER 1: PURPOSE OF 

AND NEED FOR ACTION 
1 

INTRODUCTION 

This Final Environmental Impact Statement (FEIS) has been prepared to assist the public and the 

National Park Service (NPS) in the development of a Fire Management Plan (FMP) for Point 

Reyes National Seashore (PRNS). The FEIS has been prepared in accordance with the 1969 

National Environmental Policy Act (NEPA), which requires federal agencies to evaluate the 

potential impacts of their actions on the environment. As required by NEPA, the FEIS analyzes 

several alternatives that could meet the park’s objectives for fire management and presents a 

comparison of the probable impacts of implementing the alternatives. 

The planning area for the Fire Management Plan (FMP) includes NPS lands located 

approximately 40 miles northwest of San Francisco in Marin County, California (Figures 1 and 

2). These lands include the 70,046-acre Point Reyes National Seashore (PRNS or the Seashore), 

which is comprised primarily of beaches, coastal headlands, extensive freshwater and estuarine 

wetlands, marine terraces, and forests; as well as 18,000 acres of the Northern District of Golden 

Gate National Recreation Area (GGNRA), which primarily support annual grassland, coastal 

scrub, and Douglas-fir and coast redwood forests. Under a joint working agreement with 

GGNRA, the Seashore performs day-to-day management of these nearby GGNRA lands, as well 

as participating in some planning. 

Point Reyes National Seashore was created on September 13, 1962 to “save and preserve for 

purposes of public recreation, benefit, and inspiration, a portion of the diminishing seashore of 

the United States that remains undeveloped (Public Law 87-657).” The park is a coastal 

sanctuary with an exceptionally diverse variety of habitat types - roughly 20% of California’s 

plant species and 45% of North America’s bird species have been recorded within its boundaries. 

The Seashore contains numerous sites indicating Native American occupancy, as well as cultural 

resources from early periods of European settlement. To preserve the historic ranching legacy of 

the area, approximately 30 ranches and dairies within Seashore boundaries are under permit 

agreements with the federal government. 

Golden Gate National Recreation Area was created in 1972 “to preserve for public use and 

enjoyment certain areas...possessing outstanding natural, historic, scenic, and recreational 

values, and ... to provide for the maintenance of needed recreational open space necessary to 

urban environment and planning.” In the management of the recreation area, the NPS shall 

“preserve the recreation area, as far as possible, in its natural setting, and protect it from 

development and uses which would destroy the scenic beauty and natural character of the 

area”(16 USC §460bb). 
2 

Figure 1. Project Area- Point Reyes National Seashore and North District of Golden Gate 

National Recreation Area 
3 

Figure 2. Regional Context Map 
4 

Purpose of the Fire Management Plan 

The purpose of the Fire Management Plan is to provide a framework for all fire management 

activities for the Seashore and the North District of GGNRA, including suppression of unplanned 

ignitions, prescribed fire, and mechanical fuels treatments. It is intended to guide the fire 

management program for approximately the next 10-15 years. The plan would include concise 

program objectives, details on staffing and equipment, and comprehensive information, 

guidelines, and protocols relating to the management of unplanned wildfire, prescribed burning, 

and mechanical fuels treatment. 

Need for the Fire Management Plan 

Fire management is an essential component of NPS operations in PRNS and the Northern 

District lands of GGNRA. The need for a well-planned and effective fire management program 

is threefold. First, the project area’s ecosystems have evolved through time with periodic fire, 

both natural and human-ignited, and many components of these systems require the continuation 

of periodic fire. As is typical of many national parks and other federal lands, however, active 

and effective fire suppression efforts for the past 150 years have dramatically changed native 

ecosystems. Ecosystem changes from the lack of fire include forest and shrub encroachment on 

grasslands, decadence and death of fire-adapted species, and extremely dense forests. 

Second, fire suppression has also resulted in a dangerous accumulation of flammable or 

hazardous fuels - large quantities of dead and downed trees and branches that have accumulated 

in overly dense forests and shrublands. Because of these high fuel loads, residences and 

businesses adjacent to the Seashore and GGNRA are at risk from catastrophic wildfire or a 

smaller fire spreading from adjacent parklands. Also, a structural fire close to the park could 

spread into federal lands and develop into a wildland fire that damages park resources. 

Third, the park’s existing Fire Management Plan (NPS, 1993) needs to be updated. Since the 

current FMP 1993 was published, the national fire policies have been updated and new 

guidelines have been issued to park units. In addition, the NPS has conducted fire research and 

now has a better understanding of the role of fire in ecosystem preservation, resulting in a greater 

capability of the PRNS to effectively conduct an effective fire program. 

This updated Plan recognizes that a more concerted effort is needed to effectively reduce fire risk 

along the wildland/urban interface, to reduce hazardous fuels, and to reestablish fire in park 

ecosystems where it is safe to do so. 

Fire Management Plan Goals 

The following goals have been developed for the updated Fire Management Plan for PRNS and 

the Northern District lands of GGNRA. These goals were generated from internal staff meetings 

and public external scoping meetings and presentations, from review of NPS Policies, Directors 

Orders, and other fire-related guidance documents listed below. 

 

Goal 1: Protect firefighters and the public. 
5 

Goal 2: Protect private and public property. 

Goal 3: Maintain or improve conditions of natural resources and protect these resources 

from adverse impacts of wildland fire and fire management practices. 

Goal 4: Maximize efforts to protect cultural resources from adverse effects of wildland fire 

and fire management practices. 

Goal 5: Foster and maintain effective community and interagency fire management 

partnerships. 

Goal 6: Foster a high degree of understanding of fire and fuels management among park 

employees, neighbors, and visitors. 

Goal 7: Improve knowledge and understanding of fire through research and monitoring and 

continue to refine fire management practices. 

Legislative and Policy Constraints and other Considerations used in 

Developing the Fire Management Plan 

The NPS is constrained from taking any actions that might go against relevant laws, regulations, 

or policies. These include enabling legislation for the NPS, the PRNS, and the GGNRA, NPS 

Management Policies (revised in 2000), Director’s Orders 12 (regulations for implementing the 

National Environmental Policy Act), Director’s Order 18 (regulations for Fire Management 

Programs), and the PRNS and GGNRA General Management Plan, Resource Management Plan, 

and other guidance from PRNS planning and policy documents. Other constraints also exist, 

such as funding limits, staff time, permit availability, resource impacts, burn window, etc. These 

are briefly explained below. 

National Park Service Legislation 

Act of August 25, 1916 (National Park Service Organic Act, PL 64-235, 16 USC §1 et seq. As 

amended). On August 15, 1916, Congress created the National Park Service with the National 

Park Service Organic Act. This act, as reaffirmed and amended in 1970 and 1978, establishes a 

broad framework of policy for the administration of national parks: 

“The Service thus established shall promote and regulate the use of the Federal areas known as 

National Parks, Monuments, and Reservations... by such means and measures as to conform to 

the fundamental purpose of the said Parks, Monuments, and Reservations, which purpose is to 

conserve the scenery and the natural and historic objects and the wild life therein and to provide 

for the enjoyment of the same in such manner and by such means as will leave them unimpaired 

for the enjoyment of future generations.” 

Specific Park Legislation 

Congress established Point Reyes National Seashore on September 13, 1962 “to save and 

preserve, for purposes of public recreation, benefit and inspiration, a portion of the diminishing 

seashore of the United States that remains undeveloped (Public Law 87-657).” An amendment 

to Public Law 94-544 (passed in 1976) states that the Seashore is to be administered without 

impairment of its natural values. 

Congress established Golden Gate National Recreation Area by Public Law 92-589 “in order to 

preserve for public use and enjoyment certain areas of Marin and San Francisco Counties, 
6 

California (San Mateo County added by P.L. #96-607).” In addition to providing for recreation 

and educational opportunities consistent with sound principles of land use planning and 

management, the NPS was also instructed to “preserve the recreation area, as far as possible, in 

its natural setting, and protect it from development and uses which would destroy the scenic 

beauty and natural character of the area.” 

Wilderness Act (16 USC 1133) 

All actions undertaken in the wilderness, including suppression of wildfires and other aspects of 

fire management, must conform to the “minimum requirement” concept, and be conducted in 

such a way as to protect natural and cultural resources (NPS, 2000, 6.3.9). The minimum 

requirement concept is a two-step documented process that determines: 

1. whether the action is appropriate or necessary to administer the area as wilderness and 

does not pose a significant impact to wilderness resources and character, and 2. which 

techniques or types of equipment are needed to ensure minimum impact to wilderness 

resources and character (NPS, 2000, Sec. 6.3.5). 

Endangered Species Act of 1973, as amended (PL 93-205, 87 Stat. 884, 16 USC §1531 et 

seq.) 

The Endangered Species Act protects threatened and endangered species, as listed by the U.S. 

Fish and Wildlife Service, from unauthorized take, and directs federal agencies to ensure that 

their actions do not jeopardize the continued existence of such species. Section 7 of the act 

defines federal agency responsibilities for consultation with the U.S. Fish and Wildlife Service 

and requires preparation of a Biological Assessment to identify any threatened or endangered 

species that is likely to be affected by the proposed action. The National Park Service initiated 

and maintains informal consultation with the U.S. Fish and Wildlife Service regarding this FEIS. 

Wildland Fire Management Policy 

The NPS has made fire and fuels management a very high priority national issue. In 2001 the 

Interagency Federal Wildland Fire Policy Review Working Group revised the Federal Wildland 

Fire Management Policy, which applies to all federal land management agencies. The key 

element of the policy is that firefighter and public safety is the first priority. In addition, the 

policy states that fire, as a critical natural process, will be integrated into land and resource 

management plans and activities on a landscape scale, and across agency boundaries. The policy 

also directs that fire management plans and programs will be based on a foundation of sound 

science. Research will support ongoing efforts to increase our scientific knowledge of 

biological, physical, and sociological factors. 

The National Park Service Management Policies 

NPS Management Policies (NPS, 2000) is the basic Service-wide policy document of the NPS. 

These policies provide guidance in the development of an updated Fire Management Plan. The 

following elements related to fire management are important considerations. 

Each park with vegetation capable of burning will prepare a fire management plan and will 

address the need for adequate funding and staffing to support its fire management program. The 

plan will be designed to guide a program that responds to the park’s natural and cultural resource 
7 

objectives; provides for safety considerations for park visitors, employees, neighbors, and 

developed facilities; and addresses potential impacts to public and private property adjacent to 

the park. 

Parks will use methods of wildland fire suppression that not only minimize impacts of both the 

suppression action and of the fire; but also are commensurate with the goals of maintaining 

effective control, working to ensure firefighter and public safety, and protecting valuable 

resources. 

Technical or Logistic Constraints 

The approximate weather window for prescribed burns at Point Reyes is from June to November. 

Burning can begin in the Olema Valley after annual grasses have cured, which does not normally 

occur until mid-June to early July. While the burn window in the Olema Valley is generally the 

most flexible in the Seashore, burns must be timed to fall between the dissipation of the coastal 

fog and the onset of afternoon sea breezes. 

During the summer months coastal fog normally keeps fuels moist on Inverness Ridge and to the 

west. Burning on Inverness Ridge and in coastal areas can be extremely difficult. This is 

because there is a narrow burning window from late September to early October when fuels dry 

out. East wind events during this same time frame can result in Red-Flag Days on which no 

burning is allowed. 

Smoke can have local impacts on residents of West Marin and can impair road visibility. All 

burns meeting resource management objectives must be submitted to the Bay Area Air Quality 

Management District (BAAQMD) for a permit. Often, “burn days” do not coincide with weather 

conditions appropriate for burning in PRNS. 

Constraints Imposed by Risk 

PRNS is one of three NPS units in this region that has been identified as having a wildland/urban 

interface at risk from a potential fire on NPS land. There are four communities bordering the 

Seashore that meet the criteria for communities at risk from wildfire. The NPS Management 

Policies (NPS, 2000, Sec. 4.5) indicate park units must comprehensively consider firefighter and 

public safety and costs as well as resource values in deciding appropriate strategic and technical 

options for managing wildland fires. Because of the existing neighboring urban areas and the 

potential for wide-spread risk to public safety or property, and because, as noted above, 

vegetation in the project area tends to grow quickly and burn hot and fast, wildland fire has been 

excluded as a tool. In other words, all natural or accidental ignitions would be suppressed. 

Any time a prescribed burn is executed on Seashore administered lands, there is always a risk to 

the residents and property of adjacent communities. The high financial and emotional cost of the 

loss of residential structures is a major concern. PRNS is committed to managing prescribed 

burns to minimize any risk to private land. The risk of such an escape is always a major factor 

when making the final decision as to whether to conduct a controlled burn or use mechanical 
8 

methods to reduce fuels. If controlled burning in the interface and along roads is conducted, it 

must proceed at a slower pace than in other areas to minimize smoke production. 

Because of high values at risk in the interface and smoke concerns, PRNS has adopted a general 

policy of not allowing fires to burn freely within a perimeter through the night. This requires that 

all burn perimeters be secure by the end of each day. Burn units must therefore be kept small 

and larger units must be subdivided into segments that can be burned in one day. This precludes 

any strategy of large-scale landscape fire restoration at PRNS. Smaller units generally take more 

time for fewer acres and drive up the cost per acre. 

Constraints Imposed by Park Resources or Values 

Point Reyes has significant populations of threatened and endangered plant and animal species, 

and other unique wildlife. These biota can and do affect the time, location and layout of fire 

management activities. For example, a buffer zone around spotted owl nests is required for a 

burn to take place and burning is restricted in habitat occupied by mountain beaver. Riparian 

areas are also avoided and not burned because they provide needed bank vegetation for Coho 

salmon and steelhead trout, which are federally listed as threatened 

Avoiding these sensitive resources can result in burn units that are not optimally laid out for 

operational defensibility. This means more firefighters are required and that slower, more precise 

fires result in fewer acres burned. 

Staffing Constraints 

The NPS has instituted new guidelines for prescribed burning (NPS Reference Manual 18, 

Chapter 10), which, among other changes, require that all NPS prescribed burns have 

“contingency resources” (such as fire trucks on stand-by) committed and assigned to every burn. 

These contingency resources must be available based on the prediction of a worst-case scenario. 

This is further complicated by the fact that the fire season peaks around the nation in the summer 

months, and resources that are normally used for conducting prescribed burns may be needed in 

another location for emergency fire suppression 

Relationship to Other Plans 

General Management Plan 

The General Management Plan/Environmental Analysis, Golden Gate National Recreation Area 

and Point Reyes National Seashore (NPS, 1980) recognized the need to incorporate prescribed 

burning into research programs designed to enhance ecosystem management in the park. The 

Plan states: “Although the majority of the seashore is generally viewed as a wild area where 

natural processes are allowed to predominate, manipulation of those processes through methods 

such as selective thinning, burning and mowing will be cautiously pursued when necessary to 

protect its scenic, ecological and recreational values (NPS, 1980).” 
9 

Point Reyes National Seashore Strategic Plan 

The PRNS Strategic Plan states that by 2003, the application of fire as a natural environmental 

variable will be incorporated to the fullest extent practicable in resource management and that 

fire management personnel will attempt to reduce fuels by 25% in strategic areas adjacent to the 

Seashore’s wildland urban interface boundary and within fire management units. 

Resources Management Plan 

The Resources Management Plan for PRNS (NPS, 1999b) describes goals, objectives and 

implementation strategies for documentation and long-term protection of cultural and natural 

resources. Research objectives within the plan regarding fire call for determining the following: 

• Fire history of the Seashore 

• Effects of fire on abiotic and biotic resources 

• Methods for controlling non-native plants using prescribed fire 

• Methods for restoring native grasslands using prescribed fire 

• Relationship to Plans, Projects, and Activities of Other Agencies 

Mount Tamalpais Area Vegetation Management Plan - Marin Municipal Water District 

(MMWD) 

This plan, prepared in 1995, presents strategies for managing vegetation on over 19,000 acres 

owned by MMWD and an adjacent 1,150 acres owned by Marin County Open Space District 

(MCOSD). The plan provides specific recommendations for reducing fire hazards and enhancing 

biodiversity. The plan did not provide specific recommendations regarding the interface between 

MMWD and GGNRA North District on Bolinas Ridge. However, at this interface, the plan 

recommends the NPS continue its fuel reduction operations along the top of Bolinas Ridge. This 

information would be used to guide the development of the updated Fire Management Plan. 

Marin County’s Fire Plan 

The Marin County’s Fire Plan: A Wildland Fire Risk Assessment Model (2000) provides a 

prescription for reducing costs and losses from wildland fire. The plan uses a four-factor 

assessment that defines Marin County’s wildland fire risk and hazards. The plan also addresses 

generalized wildland fire risk for federal parklands. This information has been be used to guide 

PRNS in developing strategic fire management units and fire treatments in this Fire Management 

Plan. 

California Fire Plan 

In 1996 the California State Board of Forestry and the California Department of Forestry (CDF) 

and Fire Protection prepared the California Fire Plan (CDF, 1996). The overall goal of the plan is 

to reduce total costs and losses from wildland fire in California by protecting assets at risk 

through focused pre-fire management prescriptions and increased initial attack success. Key 

elements of the plan are the development of wildfire safety zones and cooperation with 

stakeholders, including federal agencies. General strategies from the plan will be used as the 

updated Fire Management Plan is developed and implemented. 
10 

Marin Countywide Plan 

The Environmental Hazards Element of the Marin Countywide Plan (Marin Community 

Development Agency, 1994) discusses fire hazards and wildfires. Adopted polices encourage 

fuel breaks, brush clearance, and reduction of hazardous fuels. The Fire Management Plan 

would incorporate these and other strategies for reduction of fire hazard. In addition, PRNS and 

the GGNRA North District are part of the Marin County Coastal Recreation Corridor. The 

Countywide Plan recommends that PRNS and GGNRA be retained in their natural state to the 

greatest extent possible, and that recreation uses be low intensity. This recommendation is in 

accordance with the basic principals that guide all NPS planning efforts. 

Issues and Concerns Raised During Scoping 

During a series of scoping meetings, the NPS requested input from the public, from federal, 

state, and local agencies, and from park resource specialists on fire management concerns, the 

types of issues that should be addressed in the FEIS, and the range of fire management 

alternative strategies that should be considered. 

On January 27, 2000, a “Notice of Scoping for Fire Management Plan at Point Reyes National 

Seashore” was published in the Federal Register. On January 29, 2000, at a public meeting of 

the Point Reyes National Seashore Citizen Advisory Commission, a presentation was given 

announcing the scoping period for the plan. Scoping comments were solicited from January 27, 

2000 to March 28, 2000. 

In addition to the Federal Register Notice, the scoping period was publicized through a mass 

mailing to the public that included background information on the FMP and a notice of a scoping 

workshop held March 9, 2000. The workshop was also advertised through notices posted in the 

communities surrounding the park and a notice in the local weekly newspaper, the Point Reyes 

Light. The two-hour March 9 public scoping workshop was attended by five citizens. 

On February 14, 2000 and on February 22, 2000, internal scoping sessions were conducted to 

identify staff issues and concerns. These meetings were attended by an interdisciplinary group 

of resource and fire specialists from the PRNS and GGNRA staff. 

On March 28, 2000, a two-hour scoping session was held for local fire agencies. In addition to 

representatives of the NPS Fire Management Office, members of the Marin County Fire 

Department, Inverness Volunteer Fire Department, California State Parks, and Marin Municipal 

Water District were in attendance. Also invited, but not attending, were the Marin County Open 

Space District, Bolinas Fire Protection District, Nicasio Volunteer Fire Department, and Stinson 

Beach Fire Department. 

The issues and concerns identified during scoping and from earlier public comments fell into 14 

main areas, ranging from air and water quality to biological and cultural resources, visitor 

experience, and human health and safety. These issues and concerns provided the basis for the 

selection of the “impact topics” that will be addressed in the environmental consequences section 

of this FEIS. They are discussed briefly below. 
11 

Soils 

Wildland fire suppression activities, prescribed burns, and fuel reduction by mechanical means 

could remove vegetation from the soil surface, resulting in loss of topsoil to erosion. In areas 

that burn with high intensity, soils can become hydrophobic (i.e., water repellant), and suffer a 

decrease in soil productivity by destroying soil microorganisms or by volatilizing stored nitrogen 

and other essential nutrients. 

Air Resources 

PRNS is a Class I air quality area under the federal Clean Air Act. Class I areas carry the most 

stringent standards for pollution concentrations. Wildland fire releases pollutants that contribute 

to a degradation of local air quality and could contribute to a long-term decline of air basin air 

quality. Extremely small particles, less than 10 microns in size, can be generated by burning and 

ground-disturbing activities. These particles have been associated with health problems. 

Hydrology, Water Resources, and Water Quality 

Fuel reduction actions such as prescribed burning or brush clearing remove vegetation and 

disturb soils. This disturbance can result in soil erosion, increased sedimentation in nearby water 

bodies, and increased water turbidity. The use of off-road vehicles during wildland fire 

suppression can alter surface drainage patterns. Deposits of sediments can also increase the 

occurrence or severity of localized flooding and cause changes in surface hydrology. 

Vegetation 

Vegetation within the project area could be subject either to adverse or beneficial effects as a 

result of fire management activities. For example, pile burning of downed vegetation, poorly 

executed prescribed burns, and catastrophic wildland fires can create very hot, severe conditions 

that kill above ground biomass, as well as seeds in the soil, which can alter revegetation and 

successional patterns. During wildland fire suppression, the construction of control lines and 

firebreaks, the creation of access roads, and other activities such as “mopping up” can destroy or 

damage native vegetation. Fuel reduction methods such as scraping, mowing, or brush cutting, 

which are designed to eliminate non-native vegetation or to thin dense vegetation, can also 

destroy or damage native plant species. Both fires and mechanical treatments can increase the 

potential for invasion or spread of non-native plant species, many of which successfully outcompete native vegetation as the cleared area is revegetated. Alternatively, wildland or 

prescribed fire can benefit some plants and plant communities by creating a mosaic of 

successional states that will support greater species richness. Some species in the project area 

may be highly dependent on fire for their long-term reproductive success (e.g., Bishop pine, 

Marin manzanita). 

Wetlands 

Wetlands are lands that are transitional between terrestrial and aquatic systems, where the water 

table is usually at or near the surface or the land is covered by shallow water. Perennial and 

seasonal wetlands burn only occasionally in late summer and fall under dry conditions. 

Wetlands could be affected by fire suppression activities such as fire line creation, mowing, or 

the use of heavy vehicles in soft soils. High fire intensity could alter wetland soils, vegetation, or 

hydrology. Extremely hot fires, for example, can kill large areas of vegetation and allow nonnative species to vegetate the area. 
12 

Wildlife 

The project area supports an exceptional diversity of wildlife species, which could either benefit 

from or be harmed by fire management activities. Wildlife could be killed or harmed by 

wildland fire, prescribed burns, or mechanical treatments such as mowing. Species could be 

affected by changes in vegetation structure or composition resulting from fire or mechanical 

treatments. For example, some species are dependent on moist habitats and would be displaced 

if the canopy layer were removed. Fire and mechanical removal of fuels, however, usually 

results in greater habitat heterogeneity (i.e., a mosaic of different habitat types) that can increase 

or maintain wildlife species richness. 

Special-Status Species 

The project area is home to numerous plant and wildlife species that are globally, nationally, 

regionally, or locally rare. Examples of federally listed species in the project area are the 

northern spotted owl, coho salmon, steelhead trout, Myrtle’s silverspot butterfly, Point Reyes 

mountain beaver, California red-legged frog, and Sonoma spineflower. 

Fire management activities have the potential to affect many of these species. For example, coho 

salmon and steelhead trout could be affected by increased sedimentation in creeks and/or 

persistent turbidity following wildland or prescribed fire. Conversely, as is the case for common 

plants and wildlife, many special-status species in the project area are adapted to periodic fire, 

and application of fire to the ecosystems could benefit these species by providing a wider 

diversity of habitats, by stimulating seed germination, or by improving habitat for prey species. 

Cultural Resources 

Fire management activities, including fire suppression or fuels treatments, could result in impacts 

to prehistoric and historic cultural resources in the park. A hot wildfire could damage historic or 

prehistoric surface material. Conversely, a prescribed burn could enhance a culturally significant 

landscape by perpetuating an important historic scene. The project area contains important 

archeological and historically significant sites, as well as cultural landscapes that could 

experience impacts from these actions. 

Visitor Experience 

Fire management activities may affect visitor experience by requiring trail closures, or by 

causing changes to the physical environment and aesthetics of the park setting. PRNS includes 

the 33,373 acre Phillip Burton Wilderness Area that was Congressionally authorized n 1976. 

This designated wilderness area preserves a critical remnant of undeveloped California coast. 

Fire suppression actions and fire management projects may temporarily affect the wilderness 

qualities protected in this area, such as isolation, opportunities for solitude, and natural quiet. In 

the long-term, fuel reduction actions and prescribed burns have the potential to change both the 

visual appearance and the viewsheds of the park. 

NPS Management and Operations 

Each of the proposed alternatives may affect park staff and budgets differently, and budgetary 

constraints could reduce the ability of the park to implement each objective. The FEIS addresses 

the impacts of each fire management alternative on park operations in terms of staffing, 
13 

implementation costs and equipment, and requirements for maintaining effective fuel reduction 

zones. 

Human Health and Safety 

Fire management and fire suppression actions can affect the health and safety of firefighters, 

local residents, and visitors. Weather conditions during prescribed fires could change 

unexpectedly, resulting in an unanticipated shift in the smoke plume or in an uncontrolled 

wildfire that could put people or property at risk. Alternatively, reduction of hazardous 

accumulations of fuels around developed areas through mechanical treatments or prescribed 

burning will reduce the risk of catastrophic fire, thus having beneficial effects on human health 

and safety. 

Regional Economy (Socioeconomic Issues) 

Fire management projects involving prescribed burning or mechanical treatments that impede the 

use of the park by visitors through short-term road and trail closures could result in a loss of 

revenue to local businesses which rely on tourism. 

Issues Dismissed from Further Consideration 

Floodplains 

All federal agencies are required to consider the effects of federal actions on floodplains 

(Executive Order 11988 – Floodplain Management). This Executive Order, however, pertains to 

the occupancy or modification of floodplains, and to development within floodplains, neither of 

which would result from implementation of the proposed Fire Management Plan. 

Prime and Unique Farmlands 

To ensure compliance with the Farmland Protection Policy Act (FPPA; PL 97-98; 7 U.S.C. 4201 

et seq.), the Council on Environmental Quality (CEQ) requires consideration of impacts to prime 

and unique farmland as a result of federal actions. Prime and unique farmlands are defined by the 

U.S. Department of Agriculture (USDA) and are determined by the USDA Natural Resources 

Conservation Service (NRCS). Within the project area, Giacomini Ranch is classified as prime 

or unique. However, because of high year-round moisture levels and low intensity burning fuels 

in this area, none of the proposed alternatives includes management actions for Giacomini 

Ranch. Therefore, this issue is not included as an impact topic discussed in the FEIS. 

Sacred Sites and Indian Trust Resources

As stated in NPS Management Policies (NPS, 2000), the NPS acknowledges that American 

Indian tribes treat specific places containing certain natural and cultural resources as sacred 

places having established religious meaning, and as locales of private ceremonial activities. Fire 

management activities in the proposed Fire Management Plan would not have any impacts on 

sacred sites. In addition, there are no Indian Trust resources in PRNS. 

Selection of Impact Topics 

Selection of topics to be addressed in the FEIS was based on concerns raised during internal and 

public scoping, and on regulatory and NPS policy requirements. These issues involve significant 
14 

resources that could be beneficially or adversely affected by project implementation. Impact 

topics include the following: 

• Air Quality 

• Water Resources and Water Quality 

• Soils 

• Vegetation 

• Wetlands 

• Wildlife 

• Special Status Species (e.g., Threatened, Endangered, Rare and Sensitive Species) 

• Cultural Resources 

• Human Health and Safety 

• Visitor Experience and Visual Quality 

• NPS Management and Operations 

• Regional Economy (Socioeconomic Issues) 
15 
16 

CHAPTER 2: 

ALTERNATIVES -

INCLUDING THE 

PREFERRED 

ALTERNATIVE 
17 

OVERVIEW OF ALTERNATIVES 

The following three alternatives have been developed for the Seashore’s Fire Management Plan 

FEIS: 

• Alternative A (No Action) - Continued Fuel Reduction for Public Safety and Limited 

Resource Enhancement 

• Alternative B - Expanded Hazardous Fuel Reduction and Additional Natural Resource 

Enhancement 

• Alternative C (Preferred Alternative) - Increased Natural Resource Enhancement and 

Expanded Hazardous Fuel Reduction 

NEPA requires project proponents to identify a range of reasonable alternatives within an EIS. 

Reasonable alternatives must be economically and technically feasible and demonstrate common 

sense. Alternatives must meet stated goals and objectives for taking action to a large degree, and 

must be within identified constraints. The No Action alternative must be analyzed under NEPA 

requirements. For this FEIS, the No Action alternative represents no change in fire management 

actions as they have been implemented over the past five years (1997-2001). 

Initially, six alternatives were considered during development of this FEIS. Of these, three are 

fully analyzed in this document. The other three were considered carefully, but rejected because 

they would not adequately meet the fire program’s objectives. These alternatives are briefly 

discussed in the section Alternatives Considered But Not Analyzed Further in this FEIS at the 

end of this chapter. 

The three alternatives analyzed - Alternatives A, B, and C - meet Seashore goals and objectives 

to an acceptably large degree, and are within constraints imposed by regulations and policies, by 

risks associated with the wildland urban interface, and by technical and funding limitations. 

Although EIS alternatives must meet objectives and resolve planning issues to a large degree, 

they can vary in their methods, or in the degree to which each objective is met. This is the case 

in this plan, as some objectives or issues were emphasized in one alternative, and others in 

another. 

All three alternatives involve different combinations of prescribed burning and mechanical 

treatments. The upper limits for both these management activities in all alternatives are a 

function of the risk, weather, staff, and funding limitations described in the Constraints Section 

of Chapter 1. As noted in that section, the use of fire on a landscape scale is not possible in the 

study area because of these constraints. In each alternative, an upper limit has been set on the 

number of acres that would be burned or mechanically treated in any one year (Table 1, based on 

internal scoping with park specialists in several fields. Alternative A (No Action) is based on the 

average number of acres treated over the past few years at the Seashore. 
18 

Table 1. Maximum Number of Acres that would be Treated with Prescribed Fire and Mechanical Treatment in Any 

One Year Under the Three Alternatives. 

Alternative Maximum Number of Acres 

 

Prescribed Burning Mechanical Treatment Total 

A 500 500 1,000 

B 1,000 1,000 2,000 

C 2,000 1,500 3,500 

Alternative A (No Action - Continued Fuel Reduction for Public Safety and Limited Resource 

Enhancement) involves the continuation of existing practices as prescribed in the 1993 Fire 

Management Plan. Existing practices include mechanical hazardous fuels treatments, primarily 

mowing in grasslands, and limited prescribed burning, primarily for fuel reduction in grasslands 

and for the control of Scotch and French broom. Current research projects regarding the 

reduction of Scotch broom and velvet grass through prescribed burning would continue under 

this alternative. 

Alternative B (Expanded Hazardous Fuel Reduction and Additional Natural Resource 

Enhancement) calls for a substantial increase over present levels in the reduction of hazardous 

fuels through prescribed burning and mechanical treatments. Efforts would be concentrated in 

areas where unplanned ignitions are most likely to occur (e.g., road corridors) and where the 

creation of defensible space would be most effective at containing unplanned ignitions and 

protecting lives and property (e.g., around structures). Natural resource enhancement would 

occur as a secondary benefit only. For example, in prescribed burns for fuel reduction along 

Highway 1, the non-native French broom would be eliminated. 

Alternative C (Increased Natural Resource Enhancement and Expanded Hazardous Fuel 

Reduction) would result in a marked increase in efforts to enhance natural resources. Increasing 

the abundance and distribution of threatened and endangered species, reducing infestations of 

invasive, non-native plants, and increasing native plant cover would be particularly emphasized 

under this alternative. Burning would also be used to protect or enhance cultural resources, such 

as to reduce vegetation in areas identified as important historic viewscapes. 

Alternative C also would include continued reduction of hazardous fuels in high priority areas 

(e.g., along road corridors and around structures). Under this alternative, research efforts would 

be expanded to determine the effects of fire on natural resources of concern (e.g., rare and nonnative species) and to determine the effectiveness of various fuel treatments. Research results 

would be used adaptively to guide the fire management program in maximizing benefits to 

natural resources, while protecting lives and property. 
19 

Discussion of Fire Management Units 

For planning purposes, the park landscape has been divided into 11 fire management units 

(FMUs) based on geography, fuels management and habitat enhancement needs, and on values at 

risk (Figure 6). Ten of these FMUs are units that may be subject to fire management actions 

(prescribed burning or mechanical fuel reduction treatments). The eleventh FMU - the Minimum 

Management Unit - includes large areas of the park that would only be subject to vegetation 

clearing around buildings and along roads, and full suppression of all fires. 

These FMUs were developed using Marin County’s Fire Plan: A Wildland Fire Risk Assessment 

Model (MCF, 2000) and fire professional expertise. Many FMUs such as Inverness Ridge, 

Wilderness North, Wilderness South, Bolinas Ridge, Highway 1, Limantour, and Palomarin are 

strategically located to primarily treat the highest ranking fuels (secondarily, there are resource 

enhancement benefits). In the event of a wildland fire, these treated areas would provide a 

tactical advantage to firefighters. Their treatment with defensible space, fire road clearing for 

emergency evacuation, and wildland urban interface programs provide a systematic effort to 

protect life and property. Other FMUs such as Tomales Point, Estero, and Headlands have been 

established primarily for resource management reasons. Three graphics – Fuel Ranking Map, 

Potential Living Unit Loss, and Resistance to Control (Figures 3, 4, and 5, respectively) - 

illustrate one aspect of the background behind establishment of the proposed FMU locations. 

These fire assessments, along with feasibility of access, potential for beneficial and adverse 

resource impacts, and the advice of fire professionals were used to develop the FMUs. 
20 

Figure 3. Fuel Ranking Map Measuring Risk of Wildland Fire 
21 

Figure 4. Potential Living Unit Loss Measuring the Risk of Wildland Fire 
22 

Figure 5. Resistance of Control Measuring the Risk of Wildland Fire 
23 

Figure 6. Map of Project Area Showing All Fire Management Units 
24 

Each FMU is addressed in the discussions of the three alternatives in this FEIS, but not all 

alternatives include management actions within each unit. Table 2 illustrates which FMUs could 

be subject to prescribed burning or mechanical fuels treatments under each alternative. Brief 

descriptions of the FMUs follow Table 2. 

Table 2. Fire Management Units That Would Be Subject To Treatment Beyond Clearing Around Buildings Of Fire 

Roads And Trails (Prescribed Fire, Mechanical Treatment Or Both) Under Each Alternative. 

Fire Management Unit Alternative A Alternative B Alternative C 

 PF1 MT2 PF MT PF MT 

Tomales Point 

 

X X X 

Headlands X 

Estero X X X X X X 

Inverness Ridge X X X X 

Limantour Road X X X X X X 

Wilderness North X X X X 

Wilderness South X X X X 

Highway One X X X X X X 

Bolinas Ridge X X X 

Palomarin X X X X 

Minimum Management3 1

Prescribed Fire 

2

Mechanical Treatment 

3

 No treatments to occur except clearing of fire roads and removal of vegetation around buildings. 

TOMALES POINT (2,781 acres) - This unit encompasses all of the land on Tomales Point north 

of a fence from Tomales Bay to the Pacific Ocean (in place to create a tule elk reserve.) It 

supports grassland, mixed coyote brush scrub, and dense bush lupine stands at the northern tip of 

the peninsula. In 1978, tule elk were reintroduced to Tomales Point, and the present herd size is 

approximately 450 animals. Populations of ten plant species of management concern occur in 

this FMU; six of these are federal Species of Concern and one, Point Reyes blennosperma 

(Blennosperma nanum), is listed as rare by the state (Table 3). The historic Pierce Ranch 

Complex, which has grounds that support a variety of associated invasive non-native plants (e.g., 

eucalyptus, cape-ivy) is within this FMU. 

HEADLANDS (881 acres) - The Point Reyes Lighthouse bluffs and Chimney Rock area at the 

westernmost tip of Point Reyes comprise this FMU. It contains some areas of designated 

wilderness along the outer bluffs. Vegetation on the unit is dominated by grassland and patches 

of mixed coyote brush and coastal scrub. This FMU has been subject to intense grazing pressure 

from cattle in the past, and currently some areas continue to be grazed, while others have been 

excluded from grazing. Twelve plant species of management concern occur in this FMU (Table 

3); five of these are federal Species of Concern, one is state-listed as rare (Point Reyes 

blennosperma), and one is state-listed as endangered (Point Reyes meadowfoam - Limnanthes 

douglasii var. sulphurea). The Headlands harbor sensitive animal species such as brown pelican 

and Steller sea lions. Other sensitive animal species include nesting seabirds such as ashy stormpetrel. Marine mammals such as harbor seals are sensitive to human activities including low 

flying helicopters. Lands within this FMU receive very high levels of visitor use, and are 

popular for wildflower viewing in the spring. 
25 

ESTERO (1,638 acres) - The Estero FMU is located at the northern end of Drakes Estero, along 

the edges of Schooner and Home bays. This area supports primarily grassland and mixed coyote 

brush and poison-oak scrub habitats, with patches of wax-myrtle (Myrica californica) in seasonal 

drainages. A stand of Monterey pine occurs in the southeast corner of the FMU. The Seashore 

has been using prescribed fire and mowing treatments to control the non-native plant Scotch 

broom (Cytisus scoparius) in this FMU since 1993, and plans to continue with these treatments. 

Populations of Point Reyes mountain beaver occur in shrubby drainages within this unit. This 

species, although not federally listed, is of concern to Seashore managers as it is a rare species 

whose populations were significantly reduced by the Vision Fire in 1995. This FMU also 

supports nine plant species of management concern, five of these are federal Species of Concern 

(Table 3). 

Table 3. Federal, State, and California Native Plant Society (CNPS) Listed Plant Species in each Fire Management 

Unit. 

SPECIES REGULATORY STATUS 

Common Name Scientific Name FEDERAL STATE CNPS LIST1 

Tomales Point FMU 

 

pink sand-verbena Abronia umbellata ssp. 

breviflora 

Species of 

Concern 

none 1B 

coast rock cress Arabis blepharophylla none none 4 

Point Reyes blennosperma Blennosperma nanum var. 

robustum 

Species of 

Concern 

Rare 1B 

coastal bluff morning glory Calystegia purpurata ssp. 

saxicola 

none none 1B 

Franciscan thistle Cirsium andrewsii none none 1B 

Point Reyes bird’s beak Cordylanthus maritimus 

ssp. palustris 

Species of 

Concern 

none 1B 

Marin checker lily Fritillaria affinis var. 

tristulis 

none none 1B 

San Francisco gumplant Grindelia hirsutula var. 

maritima 

Species of 

Concern 

none 1B 

rosy linanthus Linanthus rosaceus none none 1B 

Marin knotweed Polygonum marinense Species of 

Concern 

none 3 

San Francisco owl’s clover Triphysaria floribunda Species of 

Concern 

none 1B 

Headlands FMU 

 

Blasdale’s bent grass Agrostis blasdalei Species of 

Concern 

none 1B 

coast rock cress Arabis blepharophylla none none 4 

Point Reyes blennosperma Blennosperma nanum var. 

robustum 

Species of 

Concern 

Rare 1B 

Franciscan thistle Cirsium andrewsii none none 1B 
26 

Marin checker lily Fritillaria affinis var. 

tristulis 

none none 1B 

short-leaved evax Hesperevax sparsiflora var. 

brevifolia 

none none 2 

perennial goldfields Lasthenia marcrantha none none 1B 

Point Reyes meadowfoam Limnanthes douglasii var. 

sulphurea 

Species of 

Concern 

Endangered 1B 

North Coast phacelia Phacelia insularis var. 

continentis 

Species of 

Concern 

none 1B 

Point Reyes rein orchid Piperia elegans ssp 

decurtata 

none none 1B 

beach starwort Stellaria littoralis none none 4 

San Francisco owl's clover Triphysaria floribunda Species of 

Concern 

none 1B 

Estero FMU 

 

Blasdale's bent grass Agrostis blasdalei Species of 

Concern 

none 1B 

coast rock cress Arabis blepharophylla none none 4 

coastal marsh milk-vetch Astragalus pycnostachyus 

var. 

pycnostachyus 

none none 1B 

Point Reyes bird’s beak Cordylanthus maritimus 

ssp. palustris 

Species of 

Concern 

none 1B 

Marin checker lily Fritillaria affinis var. 

tristulis 

none none 1B 

marsh microseris Microseris paludosa none none 1B 

Gairdner’s yampah Perideridia gairdneri var. 

gairdneri 

Species of 

Concern 

none 4 

Marin knotweed Polygonum marinense Species of 

Concern 

none 3 

San Francisco owl’s clover Triphysaria floribunda Species of 

Concern 

none 1B 

Limantour Road FMU 

 

Marin manzanita Arctostaphylos virgata none none 1B 

Point Reyes bird’s beak Cordylanthus maritimus 

ssp. palustris 

Species of 

Concern 

none 1B 

California bottlebrush grass Elymus californicus none none 4 

Marin checker lily Fritillaria affinis var. 

tristulis 

none none 1B 

fragrant fritillary Fritillaria liliaceae Species of 

Concern 

none 1B 

Marin knotweed Polygonum marinense Species of 

Concern 

none 3 

Wilderness North FMU 

 

California bottlebrush grass Elymus californicus none none 4 

Wilderness South FMU 

 

Marin manzanita Arctostaphylos virgata none none 1B 

California bottlebrush grass Elymus californicus none none 4 
27 

Highway One FMU 

 

Marin checker lily Fritillaria affinis var. 

tristulis 

none none 1B 

Lobb’s aquatic buttercup Ranunculus lobbii none none 4 

Bolinas Ridge FMU 

 

Marin manzanita Arctostaphylos virgata none none 1B 

glory brush Ceanothus gloriosus var. 

exaltatus 

none none 4 

Bolinas ceanothus Ceanothus masonii Species of 

Concern 

Rare 1B 

California bottlebrush grass Elymus californicus none none 4 

Inverness Ridge FMU 

 

Marin manzanita Arctostaphylos virgata none none 1B 

swamp harebell Campanula californica none none 1B 

Mount Vision ceanothus Ceanothus gloriosus var. 

porrectus 

none none 1B 

California bottlebrush grass Elymus californicus none none 4 

Palomarin FMU 

 

Sonoma Alopecurus Alopecurus aequalis var. 

sonomensis 

Endangered none 1B 

Marin manzanita Arctostaphylos virgata None none 1B 

nodding semaphore grass Pleuropogon refractus None none 4 

NOTES: 

1 CNPS List 1B: Rare or Endangered in California and Elsewhere 

 CNPS List 3: Need More Information 

 CNPS List 4: Plants of Limited Distribution 

INVERNESS RIDGE (1,250 acres) - This linear FMU runs from the western edge of Tomales 

Bay State Park south along Inverness Ridge to the Bayview Trail parking area. This ridge is 

dominated by dense stands of Bishop pine (Pinus muricata) in the north, which grade into 

Douglas-fir (Pseudotsuga menziesii) forests further south. The understory vegetation is dense 

beneath the Bishop pine, and consists of highly flammable species such as manzanita 

(Arctostaphylos ssp.) and ceanothus (Ceanothus ssp.). The understory of the Douglas-fir forests 

can be sparse, consisting primarily of grasses and herbs, or more dense, with salal and 

huckleberry. This FMU supports four federal plant species of management concern (Table 3), 

including two federal Species of Concern - Marin manzanita (Arctostaphylos virgata) and Mount 

Vision ceanothus (Ceanothus gloriosus var. porrectus). Northern spotted owls, federally listed 

as a threatened species, nest within this FMU. 

The Inverness Ridge FMU is immediately adjacent to numerous residences and several business 

facilities (e.g., grocery stores, restaurants, delicatessens, galleries, and shops) in the communities 

of Inverness and Inverness Park. The proximity of dense, flammable vegetation to these 

communities results in an area where the risk of loss associated with fire is very high. The 

Vision Fire destroyed 44 homes in this area in 1995. 
28 

LIMANTOUR ROAD (4,142 acres) - This FMU consists of a corridor along the entire length of 

Limantour Road from the Limantour Beach parking area, up over Inverness Ridge, and down to 

the intersection of Limantour Road and Bear Valley Road. Much of the unit is within the Philip 

Burton Wilderness Area. For management purposes, it also includes the area encompassing the 

Point Reyes National Seashore headquarters buildings, the Bear Valley Visitor Center, and the 

Coast Miwok cultural exhibit at Kule Loklo. 

The southwestern portion of this FMU, from Limantour Beach to Inverness Ridge, spreads out 

east and west of the road to include portions of the Phillip Burton Wilderness Area. Vegetation 

in this area is dominated by grassland and mixed coastal scrub in the southwest, which grades 

into Bishop pine stands and Douglas-fir forests on Inverness Ridge. An extensive salt water and 

brackish marsh system occurs at the Estero de Limantour, and high quality riparian corridors are 

located along several northeast to southwest trending creeks (e.g., Muddy Hollow, Laguna, 

Coast). This section of the FMU supports six plant species of management concern, three of 

these are federal Species of Concern (Table 3). A free-ranging herd of 28 tule elk (which are 

identified in special legislation as a resource the Seashore is to protect and manage) were 

introduced in this area in 1999. Federally-listed threatened coho salmon (Oncorhynchus 

kisutsch) and steelhead trout (Oncorhynchus mykiss) occupy streams in this FMU. 

The section of this FMU that stretches from Inverness Ridge west to the Bear Valley area 

supports Douglas-fir forest, mixed conifer/hardwood forest with coast live oak, California bay, 

coyote brush scrub, and grasslands. There are large stands of eucalyptus near the Kule Loklo 

site, which are highly flammable. Northern spotted owls are known to nest in both sections of 

this FMU. 

WILDERNESS NORTH (1,591 acres) - Douglas-fir forests interspersed with small open 

meadows characterize this FMU, which follows Inverness Ridge southeast from the Bayview 

Trail parking area to the Bear Valley Trail. The terrain is characterized by steep slopes that 

climb up from the east and west toward the central ridge. This FMU contains Mt. Wittenberg, the 

highest point in the planning area at 1,407 feet. Much of the unit is within the Philip Burton 

Wilderness Area. This unit also contains Sky Camp, a backcountry campground. Spotted owls 

are known to nest in this unit. This FMU supports one plant species of management concern 

(Table 3) – the California bottlebrush grass (Elymus californicus). 

WILDERNESS SOUTH (2,297 acres) - This unit is largely comprised of designated wilderness 

land south of the Vedanta Society property (see Figure 6). It follows Inverness Ridge south to 

just south of Mud Lake, and includes Firtop (1,324 ft). The unit also encompasses land 

southwest of Firtop, reaching to the coast at Wildcat Camp. Vegetation is dominated by dense 

stands of Douglas-fir with significant amounts of dead and downed material present. The 

southwest corner of the FMU also supports high quality stands of coastal scrub, including 

coffeeberry, California sagebrush, coyote brush, bush monkeyflower, and lizardtail. This FMU 

supports two plant species of management concern, Marin manzanita (Arctostaphylos virgata), 

and California bottlebrush grass (Elymus californicus; Table 3). Marin manzanita is fire 

dependent, and in the absence of fire, this stand has become unhealthy and cannot reproduce. 

Encroachment of Douglas-fir has also served to reduce direct sunlight and further the “decadent” 
29 

status of the Marin manzanita population in this part of the park. Shrubs in these stands are old 

and not reproducing, or dead. 

HIGHWAY ONE (2,874 acres) - This unit begins immediately south of Five Brooks and runs 

along both sides of Highway One south to the Bolinas-Fairfax road. This unit includes the 

Olema Valley, which is characterized by the riparian corridors along Olema and Pine Gulch 

creeks and their tributaries. These waterways support coho salmon and steelhead trout. Above 

the riparian areas, the vegetation is dominated by annual grassland, mixed scrub, and hardwood 

communities. In many areas, the grasslands are grazed by cattle. This FMU supports dense 

stands of French broom and eucalyptus. Most of the unplanned ignitions that occur in the entire 

planning area result from car travel in this FMU. 

BOLINAS RIDGE (2,381 acres) - This long, linear unit stretches from Olema, east along Sir 

Francis Drake Blvd, then turns south and follows Bolinas ridge to the Bolinas-Fairfax Road. 

The northern half of the unit contains grasslands grazed by cattle. Drainages within this area 

support mixed scrub, hardwood woodlands, and some Douglas-fir. The southern half of the unit 

supports primarily Douglas-fir and redwood forests, hardwood forests, and mixed scrub plant 

communities. At the southern end, the FMU supports a dense stand of maritime chaparral that 

supports two rare species (Table 3) - Marin manzanita and Mason's ceanothus (Ceanothus 

masonii). The latter species is a federal Species of Concern and is state-listed as rare. 

PALOMARIN (2,021 acres) - Beginning in the Philip Burton Wilderness Area near Double 

Point, this unit follows the coastline to the southeast to the U.S. Coast Guard property, then runs 

inland on the northeast side of Mesa Road. This unit supports primarily mixed coastal scrub and 

grasslands. 

The area flanking the Palomarin trailhead is characterized by an exceptional diversity of nonnative plants, including eucalyptus, French broom, cape-ivy (Delairea odorata), pittosporum 

(Pittosporum oblongata), periwinkle (Vinca major), Harding grass (Phalaris aquaticus), kikuyu 

grass (Pennisetum clandestinum), oblong spurge (Euphorbia oblongata), and others. Three plant 

species of management concern (Table 3) are located in the Palomarin FMU. 

MINIMUM MANAGEMENT UNIT (approximately 70,000 acres) - This unit contains all areas 

within the Seashore and the Northern District of GGNRA that are not included in the other ten 

units. This includes the majority of the pastoral zone (roughly 19,000 acres), which is dominated 

by grasslands grazed by cattle and large tracts of the Wilderness Area that support mosaics of 

forest, scrub and grassland. The Unit also includes large bodies of water such as Drakes Estero, 

Limantour Estero, Abbotts Lagoon, and Tomales Bay. The actions in this FMU include 

vegetation clearing around buildings and along roads, and full suppression of all fires. 

Actions Common to All Alternatives 

Some actions, including the continuation of the Wildland Urban Interface Initiative Program, 

maintenance of fire roads and trails, vegetation clearing around buildings, suppression of 

unplanned ignitions, public information and education, and fire monitoring would be carried out 
30 

under all three alternatives. Also, the park intends to build a fire cache to store equipment 

regardless of the alternative selected. Each of these activities is described below. 

Wildland Urban Interface Initiative Program 

In 2001, the NPS began implementing provisions of the federal Wildland Urban Interface (WUI) 

Initiative program. This program was designed to facilitate cooperative ventures with park 

neighbors (including other federal agencies, states, counties, private landowners, and local fire 

agencies) to reduce the potential for wildland fire to burn from federal lands to neighboring 

properties. 

The emphasis of this program at the Seashore is to reduce the density of hazardous fuels that 

create a risk to lives or property, both on and off Seashore lands. Working cooperatively with 

FireSafe Marin Inc., a California 501(c)(3) public benefit corporation, PRNS has provided 

funding for numerous projects to reduce fuel hazards and increase fire prevention and public 

safety. This program would continue under all alternatives. 

Maintenance of Fire Roads and Trails 

The Seashore routinely clears vegetation and debris from selected dirt and paved roads that 

provide routes for emergency evacuation and access for fire suppression activities or conducting 

prescribed burns, or that serve as control lines for prescribed fire projects. The minimum 

requirement for defensible space along roadways is 10 feet on each side. This specification 

provides only the minimum degree of safety for firefighters and the public and is prescribed by 

California Public Resource Code (PL - 4290 and 4291). An assessment of road conditions is 

performed in early summer, then a work plan is developed and vegetation clearing needs are 

prioritized. 

For road clearing, trees along the sides of the roadways are limbed up to 10 feet in height as 

needed. Native tree species that would be limbed include Douglas-fir and Bishop pine. Trees 

less than four inches in diameter (dbh) are removed from 10-15 ft wide corridors on each side of 

the road (measured from the edge of the roadway). This width can increase to 20 feet wide 

where roads cross topographic saddles. Downed trees in or near the roads are cleared. Grass 

growing up within roads is cut or mowed. Marin County mows grasses along county-maintained 

roads. 

Tools used for these tasks include weed-whackers, chain saws, pole saws, and a chipper towed to 

the site by a truck. Vegetation debris can be cut up and broadcast in the immediate area, or piled 

and burned. Debris that is not broadcast on site is chipped and hauled to Beebe Ranch and 

stockpiled. In accordance with BAAQMD Regulation 5, debris piles could only be burned at 

Beebe Ranch with the approval of the Air Pollution Control Officer. Chipped material is not 

burned. 

Routine maintenance is performed on all fire roads and trails listed in Table 4 below, with the 

exception of Bolinas Ridge Fire Road, where it is less frequent. 
31 

Assessment and maintenance activities conducted on fire roads would include regrading where 

rills and gullies have formed. Where necessary, road regrading should follow standard local 

practices established in the Road Maintenance MOU and the Trail Assessment document. Marin 

County Open Space has used this method to recontour and enhance Fire roads on Marin County 

Open Space District Land. This includes outsloping of roads to prevent rill and gully erosion. 

This is acceptable as vehicle access on fire roads is only necessary in the dry period of the year. 

Table 4. Fire Roads and Trails in Pt. Reyes Receiving Annual or Periodic Maintenance 

Road Name Location 

Gunn Road Inverness Ridge 

Bayview Road Inverness Ridge 

Upper Vision Road Inverness Ridge 

Bolinas Ridge Fire Road Bolinas Ridge 

Limantour Road between Sky Camp and 

Kule Loklo 

Inverness Ridge 

Stewart Trail Inverness Ridge 

Randall Trail Bolinas Ridge 

Coast Trail Limantour Area 

Inverness Ridge Trail Inverness Ridge 

Sky Trail Inverness Ridge 

Mount Vision Road Inverness Ridge 

McCurdy Trail Bolinas Ridge 

Vegetation Clearing around Buildings 

Seashore staff routinely clear hazardous fuels (vegetation and flammable debris) adjacent to 

structures within the project area. These actions would be continued under all alternatives. 

Structural clearing conforms to or exceeds the requirements of California Public Resource Code 

(PL-4290 and 4291), which also dictates the parameters for structural safety in surrounding 

residential communities. This code requires a minimum 30-foot cleared buffer of defensible 

space around all structures. 

Structural clearing projects are prioritized annually and performed in early summer. The 

defensible space required at each structure is based on individual site topography, and usually 

ranges from 30-50 feet around structures. In some cases, a larger cleared area may be required to 

protect the structure from potential fire hazard due to prevailing winds or the presence of 

drainages or swales close to the structure. Large trees are pruned or removed if the tree poses a 

threat, grasses are cut to stubble, and smaller trees are pruned or removed based on individual 

site topography. The health of all trees within the defensible space is assessed and any dead or 

dying trees are removed. 
32 

NPS maintenance, fire, and engineering staff conduct fire inspections of each building during the 

winter to assure that all structures meet fire code requirements. 

Suppression of Unplanned Ignitions 

The current policy at the Seashore is to suppress all unplanned ignitions using Minimum Impact 

Suppression Tactics (MIST). MIST guidelines apply to all facets of suppression actions and 

direct personnel to implementation techniques that minimize long-term adverse effects on 

wildlands. These tactics will be outlined and defined in the park’s operational guidelines. Since 

1997, an average of three wildland fires per year have occurred at Point Reyes. All of these were 

kept less than ten acres in size; most were extinguished at less than one acre. To accomplish this, 

Point Reyes has had a 10-person Hazard Fuels Crew, 1-2 Engine Technicians, and support from 

the GGNRA and the Marin County Fire Department. Most of the fires occurred in the Olema 

Valley, and all but one were human-caused. 

Fire suppression actions typically include fire line construction and laying hose. A fire line 

(approximately 18 to 24 inches wide) is cut and cleared to bare mineral soil using chainsaws, 

shovels, and other hand tools such as Pulaskis (a shovel/hoe firefighting tool) and McLeods (a 

scraper firefighting tool). Fire line construction can include cutting brush, limbing trees, and 

cutting snags. 

It is also possible that, during an emergency situation where an unplanned ignition has grown to 

a large and dangerous fire (such as during the Vision Fire), the superintendent would authorize 

the use of heavy motorized equipment such as bulldozers to construct larger and longer fire lines. 

Other fire suppression activities require limited off-road vehicle use by trucks, fire engines, and 

lowboys for hauling heavy equipment. 

Air drops of retardant foam and water may occur during suppression of unplanned ignitions. 

Retardant foam (e.g., Phoschek) contains phosphorus. Water drops could also be made, using 

water from ponds in the Seashore. Helicopters will need areas to land (helispots) within the 

Seashore. The Seashore Aviation Management Plan addresses safe locations for landing in areas 

administered by the park. Temporary road and trail closures may occur during fire suppression 

events. 

Public Information and Education 

A comprehensive public information and education program would be included as part of all of 

the alternatives. PRNS and GGNRA share a full-time fire education specialist. The program’s 

emphases include fire safety and prevention, fuels management, the role of fire in PRNS’s 

ecosystems, the Seashore’s fire history and the cultural use of fire on the landscape, and fire 

research programs and opportunities. The following list illustrates several key components of 

the program. 

Notification of fire management activities would be done prior to project commencement using 

road and trail signs, and postings at visitor centers, entrance stations, post offices, and other areas 
33 

of high visitor use. Flyers would be distributed to residences and businesses, and posted 

throughout western Marin County in strategic locations (e.g., post offices) to notify the public of 

upcoming prescribed burns. Homeowner Associations and specific individuals would be 

contacted by phone or email prior to prescribed burning. 

Communication with adjacent land management agencies (e.g., State Parks, Marin County, 

Marin Municipal Water District) would always be conducted when projects occur at or near their 

boundaries. They also would be notified if a project on Seashore lands has potential to affect 

lands under their jurisdiction. 

When prescribed fires or unplanned ignitions are visible from scenic overlooks or popular visitor 

use areas, park interpreters or the Seashore’s fire education specialist would be present to 

alleviate public concern and to educate visitors on the objectives and benefits of prescribed 

burning. 

The Public or Fire Information Officer (P/FIO, respectively) would notify adjacent communities 

by press release, as requested, before implementing prescribed fires. 

PRNS staff would follow the standard operating procedures for implementing a Fire Step-up 

Plan during fire season. For example, when red flag warnings are issued by the National 

Weather Service (Sacramento Office), fire managers would post high fire danger signs within the 

park. 

In the event of wildland fire, the P/FIO would work closely with visiting FIOs who may be part 

of Incident Management Teams to assure the park message is delivered accurately and 

effectively. Wildland fires will also be reported to BAAQMD as soon as possible. Media and 

public queries would receive prompt replies and would contain information about the fire, the 

fire management plan, and ecosystem restoration as appropriate. 

Fire Monitoring 

Monitoring of fire effects has been occurring in prescribed burn units at PRNS since 1991. 

Monitoring of fuels, weather, air quality, and fire behavior for wildland and prescribed fires 

would generally follow the protocols outlined in the NPS Fire Monitoring Handbook 

(FMH)(NPS, 2003a). Under these protocols, photo points and vegetation transect data are used 

to assess attainment of objectives. Short and long-term objectives applicable to a specific burn 

area would be stated in individual Prescribed Burn Plans. 

Monitoring data are archived and reviewed to refine target conditions and burn prescriptions, and 

to determine program effectiveness. Most of the existing FMH plots are located in Divide 

Meadow, the Olema Valley, Estero Trail, and southern Bolinas Ridge. Under all alternatives, 

these plots would continue to be monitored and additional plots would be established in any new 

habitat types subject to prescribed burning. 

Mitigation measures to ensure the protection of cultural resources are enumerated in detail in the 

impact analysis in Chapter 4. Some of the larger actions the Seashore would take include 
34 

monitoring to document pre- and post-burn conditions that are readily observable, such as the 

condition of flammable historic fabric (e.g., elements that contribute to the structure’s integrity, 

such as original siding, shingles, etc.), preservation of milling slicks on archeological sites, 

visually identifiable changes in surface artifacts and surface conditions, and changes in landscape 

conditions in historic district and cultural landscape areas. Surveys of cultural resources would 

be conducted prior to all prescribed burns. As needed, fuel loads that might threaten a cultural 

resource during a prescribed burn or unplanned ignition would be lightened. 

Prior to prescribed burns, known cultural resources would be evaluated to the extent possible and 

current conditions would be assessed, using standard operating procedures. This would include 

documentation of current fuel loads, threats to features and artifacts, and potential for subsurface 

impacts through root and/or stump burn. 

For wildland fires, a cultural resource specialist or resource advisor would be present during all 

fire management actions where recorded and unrecorded resources of interest are considered at 

risk. The specialist or advisor would provide documentation of fire behavior and immediately 

observable effects of fire in and adjacent to cultural resources. If suppression or holding actions 

must be taken, the specialist or advisor would help in deciding site-specific actions. Following a 

fire, an archeologist would revisit known cultural resources in burn areas to document fire effects 

and/or changes in condition and assess post-burn protection needs. Fire effects would be 

documented and added to the database on cultural resource fire effects. 

Fire effects monitoring data will be analyzed and reviewed every five years using standard 

scientific analysis techniques and outside reviewers. New management questions may arise from 

these analyses that may require alternative strategies that are applied following the principals of 

adaptive management. For example, burning in areas with highly invasive non-native plants 

may result in enhancing the spread of the non-native species. An adaptive strategy might be to 

swamp the non-native seeds in the burn area with native seeds. 

Fire Program Cache 

Currently, fire control vehicles and equipment are stored at the Hagmaier Complex, located on 

Highway One approximately six miles south of park headquarters at Bear Valley. The current 

building is a former barn and has inadequate equipment storage space, no insulation or heating, 

poor lighting, insufficient windows, and limited office space. In addition, the majority of fire 

fighting staff members are currently stationed at Bear Valley (Park Headquarters). This creates a 

delay in accessing vehicles and equipment, which increases response time to unplanned ignitions 

at major park assets. Storage of fire equipment and vehicles in a central location would decrease 

response time to major park assets and facilitate communication between park staff members 

responsible for fire management. Internal scoping among specialists in different fields in the park 

indicated the cache should ideally be located near park headquarters for logistic and technical 

reasons. In addition, the environmental effects of siting the building near existing buildings 

would be minimal. Park staff members have identified a location adjacent to the roads and trails 

facility at the Bear Valley administrative area as its preferred choice for the cache. The site was 

formerly used for a trailer pad. 
35 

General Description of Prescribed Fire and Mechanical Fuels Treatments 

Under all alternatives, prescribed burning and mechanical fuel treatments would be carried out to 

meet program goals and objectives as described in Chapter 1 (Purpose of and Need for Action). 

Site-specific objectives, as well as locations, size, and timing of burns and treatments would 

vary, however, among the alternatives. The following sections provide detailed information on 

the steps that occur when a prescribed fire is implemented, and a discussion of the various types 

of mechanical fuel treatments that may be used under the three alternatives. 

Prescribed Fire 

Every year fire management and resource management personnel identify priority areas for 

prescribed burning. Projects then are scheduled for implementation. After a project area is 

selected, fire personnel visit the site to define its boundaries by placing flags at the perimeter. 

The site may also be mapped using a Global Positioning System (GPS). After surveying for 

cultural resources and completing internal environmental screening for other affected physical or 

natural resources, a burn plan is prepared for each unit. 

The burn plan is submitted to an outside expert, and both the expert and the park’s Fire 

Management Officer provide a recommendation to the superintendent. After the burn plan is 

approved by the superintendent, an application for permission to conduct a prescribed burn is 

made to BAAQMD. 

The burn plan estimates the percentage of the unit covered by different fuel types and of the tons 

of material to be burned. This information is fed into an air quality model for the burn, which is 

submitted as part of the application submitted to BAAQMD. BAAQMD approval requires that 

the NPS submit a Smoke Management Plan (SMP) and completed application materials for all 

prescribed burns at least 30 days prior to the proposed burn date. 

With the approval of the smoke management plan, the NPS begins final planning for the 

prescribed burn and the project site is prepped for the burn. To prepare for a burn in grassland 

habitat, a line is mowed around the perimeter of the burn by cutting grasses with either a weed 

whacker, mower, or tractor. In shrub or forested habitats a fire line (approximately 18 to 24 

inches wide) is cut and cleared and vegetation density reduced as described above under the 

heading “Suppression of Unplanned Ignitions.” Whenever possible, roads and trails are used as 

fire lines to reduce the amount of line that must be created. A hose lay is set up along the burn 

perimeter no more than one week prior to the burn. If the burn in being conducted in non-native 

tree or shrub stands (e.g., Monterey pine or Scotch broom), the non-natives may be cut down or 

mowed and left in the burn unit to dry before burning. This increases mortality of the targeted 

non-native species. 

As the proposed burn day approaches, NPS staff contact BAAQMD’s Meteorology and Data 

Analysis section, which provides forecasting services to assist with tentative scheduling of 

prescribed burns. The MDA section will provide 96-hour, 72-hour, 48-hour, and 24-hour 

forecasts and a 24-hour confidence level of receiving the final approval on the day of the burn 

itself. The NPS telephones BAAQMD between 8:30 a.m. and 1:30 p.m. on the burn day to 
36 

receive final approval and an acreage burning allocation for that day. BAAQMD requires 

verification that the meteorological conditions fall within the range described in the SMP. The 

BAAQMD makes a final decision based on wind and weather as to whether it would permit the 

burn. The burn is lit using a drip torch with a mixture of diesel and gasoline (3:1). This fuel is 

stored in a hazardous materials locker in the park and transported within the park in accordance 

with state and federal regulations. 

During the burn, park fire staff patrol the fire line and keep it secure by watching for and 

suppressing any spot fires and turning any logs that could potentially roll out of the burn and 

spread the fire. Vehicles (pick up trucks or fire trucks) may be used to drive the perimeter to 

patrol the fire. Additional fire line may be cut if required to control spot fires using hand tools or 

chain saws. The spot fire is extinguished using water, hand tools, and if necessary, power tools. 

Fire weather is carefully monitored during the burn to ensure that the conditions stay within the 

burn prescription. 

Following the burn, the burn crew determines whether or not “mop up” is necessary to ensure 

that all fire is completely extinguished. Mop up activities include digging, cutting, trenching (to 

prevent debris from rolling), chinking (taking a pulaski and clearing burning material off a log), 

chunking (putting smoldering material into one pile and letting it burn up), and mixing dirt with 

water from backpack pumps or from hoses. Any smoldering that is causing nuisance smoke is 

extinguished. 

Prescribed fire personnel monitor the fire until dark or until the perimeter is secured. Personnel 

would stay on site overnight for burns in forested habitats. The burn area is patrolled the day 

after burning by walking the perimeter and doing any additional mop up activities required. As 

required by BAAQMD, the total acreage of burned vegetation is reported by telephone to them 

by noon the day following the prescribed burn. 

Mechanical Fuels Reduction 

Mechanical treatment includes the following: 

• Fuel breaks - clearing corridors completely of vegetation. 

• Shaded fuel breaks – density of underbrush reduced; tree limbs removed. 

• Mosaics of cleared areas, areas with reduced vegetation density, and uncleared area. 

• Using animals to reduce fuels (cows or goats). 

• Removing non-native trees and treating cut stumps with herbicide. 

Every year fire management and resource management personnel identify priority areas for 

mechanical treatments such as mowing or hand fuels removal. Projects then are scheduled for 

implementation. After a project area is selected, fire personnel visit the site to define its 

boundaries by placing flags at the perimeter. The site may also be mapped using a Global 

Positioning System (GPS). Treatments are documented to ensure that a park has a historical 

record of the types of landscape treatments each area has been subjected to. 
37 

After the site and project environmental review process is completed, the project is approved by 

the superintendent with mitigations if appropriate. For example, specific appropriate mitigation 

measures could include leaving buffers along riparian zones and wetlands and/or creating a 

larger buffer around an archeological site. 

If herbicides are used, they are applied according to strict specifications using detailed Material 

Safety Data Sheets. Any application requires the approval of the park’s Integrated Pest Manager 

and the Washington Office coordinator for herbicide application. No applications occur in 

riparian or wetland areas. 

If goats or other animals are used as a type of mechanical treatment, they are closely monitored 

and contained by electric fences to eliminate the potential for feral animals or contamination of 

adjacent water resources. Grazing treatments would be limited to the number of days needed to 

conduct the fuel treatment in order to minimize any potential impacts to soil or water quality. 

Following the mechanical treatment, the site would be reviewed by park staff for any newly 

uncovered and previously unknown archeological material that may need preservation treatment. 

Sites would be monitored by park staff over the course of several years to review the success of 

the treatments. If invasive exotics are found, other treatments would be planned and 

implemented on the project area. 

Alternative A (No Action) - Continued Fuel Reduction for Public Safety and 

Limited Resource Enhancement 

Under Alternative A the Seashore would continue to apply existing fire management practices by 

implementing elements of the 1993 Fire Management Plan. Under this alternative, the Seashore 

would comply with the requirement of NPS Director’s Order 18 to develop a new Fire 

Management Plan based on guidelines outlined in NPS Reference Manual 18, but the fire and 

fuels management actions in the new plan would not differ from current practices. The emphasis 

of the existing program is to use both prescribed burning and mechanical treatment to: 

• Reduce hazardous fuels along primary roads (e.g., Highway One); and 

• Reduce the aerial extent and density of several non-native invasive plant species 

including Scotch and French broom, Monterey pine, and eucalyptus trees. 

Continuation of the existing fire management program and practices under Alternative A would 

allow the Seashore to minimally meet program goals as listed in the Fire Management Plan 

Goals section of the Purpose and Need chapter. Alternative A would not be as effective as 

Alternative C in meeting the goal to improve conditions for and protect natural resources, but 

would be comparable to Alternative B in the degree to which it meets this goal. The No Action 

alternative may also be less effective than the action alternatives (e.g., alternatives B and C) in 

meeting goals 6 and 7, which address public education and understanding of fire and an 

understanding by park staff of the specifics of fire behavior and effect inside the Seashore. 
38 

Under this alternative, a maximum of 500 acres would be subject to prescribed burning and a 

maximum of 500 acres would be subject to mechanical fuel treatments. Every five years, fire 

management and resource management personnel would develop specific plans for prescribed 

burning and mechanical treatments that would be subject to an NPS internal project review 

process. These five-year burn plans would in turn be reviewed annually and updated as needed. 

Fire management staff would draw from these plans to do all of the detailed work that goes into a 

site specific burn plan described above. 

Under the No Action alternative, six FMUs (Tomales Point, Headlands, Inverness Ridge, 

Wilderness North, Wilderness South, and Palomarin) would not be subject to prescribed burning 

or mechanical treatments except those actions prescribed for the Minimum Management Unit 

(e.g., suppression of unplanned ignitions, mechanical vegetation clearing along roads and around 

Figure 7. Map of Project Area Showing Alternative A FMUs 
39 

structures). This is because, as noted above, the focus of the existing fire management program 

(which would continue under No Action) is the management of hazardous fuels along primary 

roads and the reduction of non-native invasive plant species through prescribed burns and 

mechanical treatment. The four remaining FMUs to be treated - Estero, Highway One, Bolinas 

Ridge, and Limantour Road - contain primary roads and the majority of non-native broom 

species, as well as Monterey pine and eucalyptus (See Figure 7). The focus of treatment in each 

is described below: 

Prescribed Fire 

Prescribed burning would continue to occur on a maximum of 500 acres per year within the 

Estero, Limantour Road, Highway One, and Bolinas Ridge FMUs. The burns could occur in any 

of these FMUs, but the total acres burned within the Seashore would never exceed 500 acres in 

any given year. The focus and intent of prescribed burns in each FMU is outlined below. Three 

of these units (Limantour Road, Highway One, and Bolinas Ridge) are along primary park roads 

where the majority of unplanned ignitions occur and the potential for a major wildfire exists. 

Estero FMU is included because it contains large tracts of invasive Scotch broom, the control of 

which is a focus of the Seashore’s use of prescribed fire under the No Action alternative. 

Estero - The Seashore would continue to conduct prescribed burns to contain and reduce the 

extent and density of the non-native plants Scotch broom and Monterey pine. Research would be 

conducted on the Scotch broom burn sites to determine the effects of prescribed burning on 

Scotch broom aerial extent and density. 

Limantour Road - Prescribed burns would continue to be conducted near the Limantour Road 

parking area if required to eradicate Monterey pine. 

Highway One - Prescribed burns would continue in the central and southern portions of the unit 

to reduce hazardous fuels and to control the non-native French broom. 

Bolinas Ridge - Training burns would be conducted in the northern section of this FMU. 

Research burns to determine the effects of prescribed burning on the non-native plant velvet 

grass, and on two rare plant species (Marin manzanita [Arctostaphylos virgata] and Mason’s 

ceanothus [Ceanothus masonii]) that require fire to flourish, would occur in the southern section 

of this FMU. 

Mechanical Fuel Treatments 

In addition to routine clearing of hazardous fuel around structures and along fire roads, the 

Seashore would continue to conduct more extensive mechanical fuel treatments in the Estero, 

Limantour Road, and Highway One FMUs. Mechanical treatments would occur on a maximum 

of 500 acres per year. The treatments could occur in any of these FMUs, but the total acres 

treated within the Seashore would never exceed 500 acres in any given year. Some of the acres 

that are mechanically treated may also be burned (e.g., Scotch broom may be mowed prior to 

burning). The focus and intent of mechanical treatments in each FMU are outlined below. 

Estero - Mowing and cutting of non-native Scotch broom and Monterey pine would continue. 
40 

Limantour Road - Monterey pine near the Limantour Road parking area would be cut. 

Highway One - Grasslands would be mowed along both sides of the highway to reduce 

hazardous fuels and to control French broom. 

Fire Effects and Fuel Management Research 

Fire effects research on targeted species was initiated in 1999. Studies include the effects of 

prescribed burning on controlling Scotch broom in the Estero FMU and velvet grass on Bolinas 

Ridge, and on stimulating Marin manzanita and Mason’s ceanothus on Bolinas Ridge. None of 

the research plots were burned in 2000 due to the NPS burn moratorium. In 2001 the park 

burned approximately five acres of research plots as part of a study to determine the effects of 

prescribed fire on Scotch broom in the Estero FMU. Fire history studies using tree ring and 

sediment core analysis also have been ongoing in the Seashore. 

Under Alternative A, research burns on velvet grass and Scotch broom would continue in order 

to allow Seashore ecologists to refine burning prescription parameters to control these species. 

Planned research burns on Marin manzanita and Mason’s ceanothus would be conducted as 

planned to determine how best to use fire in managing these species. Research on fire history of 

the Seashore would continue under contract with Rocky Mountain Tree Ring Research and 

Northern Arizona University. Additionally, non-NPS researchers have been studying the effects 

of fire on plant communities and wildlife (NPS, 2003b; G. Geupel, Point Reyes Bird 

Observatory, pers. com.; G. Fellers, USGS-BRD. pers. com.). Northern spotted owls, duskyfooted woodrats, and land birds have specifically been targeted for study of fire effects in order 

to meet compliance requirements under Endangered Species Act. 

Alternative B - Expanded Hazardous Fuel Reduction and Additional Natural 

Resource Enhancement 

 

Under Alternative B, the Seashore’s fire and fuel management program would focus on reducing 

hazardous accumulations of vegetation (fuels). Mechanical thinning and prescribed burning 

would each be used to treat a maximum of 1,000 acres, or double that of the No Action 

alternative. All treatments would be applied in areas where fuel reduction activities would have 

the highest likelihood of reducing the risk of wildland fire to lives and property. Prescribed fire 

and mechanical treatment would also be used to treat non-native invasive plants as it is in 

Alternative A, but the acreages and species treated would expand. In addition to the treatment 

described above for FMUs under the No Action alternative, Alternative B would focus additional 

treatment on the following areas: 

• Sites where fuel accumulations have created situations where an unplanned fire in these 

fuels would directly threaten human lives or property, and 

• Sites where reduced levels of fuels could help firefighters slow or stop the spread of fire 

in the event of an unplanned ignition, such as along Highway One. 
41 

While this alternative would meet the goals of the Seashore’s fire program, it would not be as 

effective as Alternative C in improving conditions for natural resources. As in Alternative A, 

Figure 8. Map of Project Area Showing Alternative B FMUs 
42 

natural resource enhancement under Alternative B would occur only as a secondary benefit in 

areas that were treated for fuel reduction. For example, natural resource enhancement benefits 

associated with prescribed burning under this alternative would include reduction of the nonnative French broom in the Highway One FMU. It would, however, differ from Alternative A in 

that more acreage would be treated to control invasive non-native species, a natural resource 

objective of the Seashore. 

This alternative would also not be as effective as Alternative C in achieving the goal of 

improving the staff’s knowledge and understanding of fire inside the park. However, it would 

include the provision for test burns in vegetation communities where no research is currently 

conducted or would be conducted under Alternative A. These include Douglas-fir stands, Bishop 

pine forests, coastal scrub, and some grassland habitats. The results of these test burns would 

help Seashore staff to determine with more accuracy the prescription needed to effectively 

manage these vegetation types. 

As in all alternatives, every five years fire management and resource management personnel 

would develop specific plans for prescribed burning and mechanical treatments that would be 

subject to PRNS’s internal project review process. These five year burn plans would in turn be 

reviewed annually and would be updated as needed. 

Under Alternative B, all FMUs except the Headlands FMU would be subject to prescribed 

burning or mechanical treatments as described in the following sections (See Figure 8). The 

Headlands FMU would be subject only to those actions that are prescribed for the Minimum 

Management Unit (e.g., suppression of unplanned ignitions, mechanical vegetation clearing 

along roads and around structures). This is because the Headlands FMU is neither a high priority 

area for enhancement of natural resources nor an area of major concern with regards to invasive 

exotic plant species. 

Prescribed Fire 

Implementation of Alternative B would result in a substantial increase in the acres that could be 

subject to prescribed burning (e.g., the maximum number of acres that could be burned in any 

given year would double - from 500 to 1,000) when compared to Alternative A. 

In many of the Seashore’s habitat types, including Douglas-fir stands, Bishop pine forests, 

coastal scrub, and some grassland habitats, detailed site-specific information on the ecological 

effects of prescribed burning is not available. For example, in some areas, there is potential for 

the introduction of invasive non-native plants following burning. To ensure that prescribed 

burns are not resulting in adverse impacts, the Seashore plans to conduct small pilot project 

burns in these habitats, as described below, to assess actual impacts on a small-scale before 

proposing larger scale burns. In addition to the four FMUs where prescribed burns would take 

place in Alternative A, an additional four would be treated in this alternative. The eight FMUs 

where prescribed burns could be conducted are: 

• Estero 

• Inverness Ridge 
43 

• Limantour 

• Wilderness North 

• Wilderness South 

• Highway One 

• Bolinas Ridge 

• Palomarin 

The prescribed burns could occur in any of these FMUs, but the total acres burned within the 

Seashore would never exceed 1,000 acres in any given year. Most areas that would be subject to 

prescribed burning would be located within 0.5 miles of roads or major trails. The focus and 

intent of prescribed burns in each FMU is outlined below. 

Estero – As in Alternative A, prescribed burns would be conducted to contain and reduce the 

extent and density of the non-native plants Scotch broom and Monterey pine. Current research 

on the Scotch broom burn sites would continue to determine the effects of prescribed burning on 

Scotch broom aerial extent and density. 

Inverness Ridge - To date, prescribed burns have not been conducted in this FMU. Under this 

alternative, burns within this FMU would include small pilot projects (less than 30 acres) in 

Bishop pine forest to determine if such burns effectively reduce understory biomass and dead 

and downed fuels, and whether burning results in invasion by non-native plant species. 

Limantour Road - In the past, prescribed burns have occurred within this FMU near the 

Limantour Beach parking area to reduce the density of Monterey pine trees. Burning in this area 

would continue. Additional burning would occur in grasslands and shrublands along the 

Limantour Road corridor to reduce hazardous fuel accumulations. This FMU also contains the 

area around the Bear Valley NPS Headquarters, the Bear Valley Visitor Center, and the Kule 

Loklo visitor use site. Small prescribed burns would be conducted in grasslands or shrublands in 

these areas to reduce fuel accumulations. 

Wilderness North - To date, prescribed burns have not been conducted in this FMU. Initial burns 

would consist of pilot projects (less than 100 acres) in Douglas-fir forest and grassland near Mt. 

Wittenberg to determine the effectiveness of burning in these areas. The objectives of these 

burns would be to reduce understory biomass and stem density, to break up the continuity of 

ladder fuels, and to establish potential future staging areas to be used in the event of a wildfire. 

Wilderness South - To date, prescribed burns have not been conducted in this FMU. Initial burns 

would be pilot projects (less than 100 acres) in Douglas-fir forest and grassland near Firtop to 

determine the effectiveness of burning in these areas. The objectives of these burns would be to 

reduce understory biomass and stem density, to break up the continuity of ladder fuels, and to 

establish potential future staging areas to be used in the event of a wildfire. 

Highway One - Prescribed burns in the past in this FMU have been concentrated on grasslands 

that support the non-native plant French broom. Prescribed burning would continue in these 

areas, and would be expanded to further reduce grasses and other herbaceous fuels along both 

sides of the highway corridor. 
44 

Bolinas Ridge - In the past, prescribed burns have occurred only in the northern end of this FMU 

on the site of a former Christmas tree farm. Burns would continue at this site, and would also be 

conducted in the Beebe Ranch area, and in grasslands and shrublands along Bolinas Ridge. 

Grasslands along the western portion of Sir Francis Drake Boulevard would be subject to 

prescribed burning to create a corridor of defensible space along the road. A large portion of the 

northern half of this FMU is subject to grazing by cattle, which serves to reduce fuels. The area 

of emphasis for prescribed burning, therefore, would be on the southern half of the FMU along 

the Bolinas Ridge Fire Road. These burns would be conducted in cooperation with the Marin 

Municipal Water District. Prescribed burns in the southernmost portion of the ridge in coastal 

chaparral and mixed scrub habitats would also help achieve a natural resource benefit by 

stimulating reproduction in the rare, fire adapted species Marin manzanita and Mason’s 

ceanothus. 

Palomarin - To date, prescribed burns have not been conducted in this FMU. Burns would be 

conducted to reduce hazardous fuel accumulations and French broom populations near the 

Commonweal garden site and near the Palomarin Trailhead. Small-scale pilot burns also would 

be conducted to reduce fuels, and to discourage Douglas-fir encroachment on coastal scrub 

habitats around the Point Reyes Bird Observatory (PRBO) field station to create a mosaic of 

vegetation in the area and improve habitat for birds. Burns in coastal scrub would generally be 

less than 100 acres and used in part to determine effects. 

Mechanical Treatments 

Implementation of Alternative B would result in a substantial increase, when compared to 

Alternative A, in acres subject to mechanical treatments to reduce hazardous fuel accumulations, 

and to create and maintain defensible space and fuel breaks (i.e., the maximum number of acres 

that could be treated in any given year would increase from 500 acres to 1,000 acres). In 

addition to the three FMUs where mechanical treatment would be used under Alternative A 

(Estero, Limantour, and Highway One), the Seashore would treat fuels more extensively in five 

additional FMUs. These treatments would be more extensive than the routine clearing of 

hazardous fuels around structures and along fire roads identified above in Actions Common to 

All Alternatives. The eight that would receive this additional mechanical treatment are: 

• Tomales Point 

• Estero 

• Inverness Ridge 

• Limantour Road 

• Wilderness North 

• Wilderness South 

• Highway One 

• Palomarin 

The treatments could occur in any of the FMUs listed, but the total acres treated within the 

Seashore would never exceed 1,000 acres in any given year. Some of the acres to be 

mechanically treated would be the same acres that are subject to prescribed burning (e.g., Scotch 
45 

broom may be mowed prior to burning). The focus and intent of mechanical treatment in each 

FMU are outlined below. 

Tomales Point - Eucalyptus and Monterey cypress trees around Pierce Point Ranch would be 

subject to cutting and stump treatment with herbicides. 

Estero – In addition to mowing and cutting non-native Scotch broom and Monterey pine, actions 

described in Alternative A, Alternative B may add cutting and stump treatment with herbicides 

of non-natives eucalyptus and Monterey cypress. 

Inverness Ridge - A shaded fuel break may be constructed and maintained along a 3-mile long 

portion of Inverness Ridge. This fuel break would be constructed to reduce the risk of fire 

burning from Seashore lands onto adjacent private lands. Initially, a 0.25-mile section of fuel 

break would be constructed as a pilot project to evaluate the effectiveness of such a fuel break, 

and to determine and evaluate the significance of environmental effects of constructing and 

maintaining the fuel break. The fuel break would extend from the Bay View Trail Parking Area 

to the Point Reyes Hill and would be approximately 50-60 feet wide. Within the fuel break, dead 

and downed woody debris would be reduced by 60%, trees would be limbed up to 10 feet in 

height, trees up to 4 inches in diameter would be thinned, and brush would be cut in a mosaic 

pattern to break up fuel continuity. 

Limantour Road – As in Alternative A, non-native Monterey pine near the Limantour Road 

parking area would be cut. In addition, areas along Limantour Road would be subject to 

vegetation clearing. Trees along the sides of the road, primarily Douglas-fir, would be limbed up 

to a height of 10 feet. Trees less than four inches in diameter (dbh) would be removed from a 

corridor 10 - 15 feet wide on each side of the road (measured from the edge of the roadway). 

This dimension could increase to 20 feet wide where the roadway crosses a saddle. Downed 

trees in or near the roadways would be cleared. Grasslands along the road would be mowed. 

Wilderness North - Under this alternative, prescribed burns up to 100 acres in size would be 

conducted in this FMU. Douglas-fir forests would be subject to mechanical thinning prior to 

prescribed burning if such action is deemed necessary to enhance the ecological value of the 

burn and to ensure the burn can be conducted safely. 

Wilderness South - Under this alternative, prescribed burns up to 100 acres in size would be 

conducted in this FMU. Douglas-fir forests would be subject to mechanical thinning prior to 

prescribed burning if such action is deemed necessary to enhance the ecological value of the 

burn and to ensure the burn can be conducted safely. 

Highway One – As in Alternative A, grasslands along the highway would be mowed to reduce 

hazardous fuels, to create a corridor of defensible space along the highway, and to control French 

broom. In addition, Alternative B would include thinning or removal of non-native eucalyptus 

stands near McCurdy Trail, Dogtown, Hagmaier, and possibly at other locations in this FMU. 

Palomarin - Areas along the road would be subject to vegetation clearing. Trees along the sides 

of the roadways would be limbed up to a height of 10 feet. Trees less than four inches in 
46 

diameter (dbh) would be removed from a corridor 10 - 15 feet wide on each side of the road 

(measured from the edge of the roadway). This dimension could increase to 20 feet wide where 

the roadway crosses a saddle. Downed trees in or near the roadways would be cleared. 

Grasslands along the road would be subject to mowing. Douglas-fir encroaching into coastal 

scrub near the PRBO Palomarin field station would be cut before this site is burned. 

Fire Effects and Fuel Management Research 

All of the same research described under Alternative A, such as effects of prescribed burning on 

Scotch broom, velvet grass, Marin manzanita, and Mason’s ceanothus would take place in this 

alternative as well. 

As in Alternative A, research on fire history of the Seashore would continue under contract with 

Rocky Mountain Tree Ring Research and Northern Arizona University. However, new research 

would be initiated under this alternative to determine the effectiveness of mechanical treatments 

(e.g., shaded fuel breaks) at reducing hazardous fuel loads and the effects of such treatments on 

ecosystem elements. In addition, Alternative B includes the use of small test burns in vegetation 

communities such as Douglas-fir forest and coastal scrub to determine its effects. Specific 

research topics that could be included under this alternative include the following: 

Inverness Ridge - the effects of prescribed burning on Bishop pine populations and associated 

plant species within the Bishop pine community would be evaluated. 

 

Wilderness North – the effects of prescribed burning on Douglas-fir forest communities would 

be evaluated. 

Wilderness South - the effects of prescribed burning on Douglas-fir forest communities would be 

evaluated. 

Bolinas Ridge - the effects of prescribed burning on coastal grassland and chaparral plant 

communities would be evaluated to determine if fire can be used to increase native species 

richness and/or density. 

Palomarin – the effectiveness of prescribed burning at reducing density or diversity of non-native 

plants would be assessed; the effects of prescribed burning and mechanical treatments on birds 

would be assessed in conjunction with the Point Reyes Bird Observatory. 

General Research - researchers would continue to study the effects of fire on plant communities 

and wildlife (G. Geupel, Point Reyes Bird Observatory, pers. com.; G. Fellers, USGS-BRD, pers. 

com.). Northern spotted owls, dusky-footed woodrats, and land birds would continue to be 

specifically targeted for study of fire effects in order to meet compliance requirements under 

Endangered Species Act. 
47 

Alternative C - Increased Natural Resource Enhancement and Expanded 

Hazardous Fuel Reduction 

Alternative C is designed to provide the fire and fuel management program with maximum 

flexibility in the application of management treatments. This alternative would include all 

activities described in Alternative B, plus additional activities designed to protect and enhance 

natural and cultural resources in the Seashore. Research activities would increase over the other 

alternatives. Prescribed burns and mechanical treatments would emphasize the following: 

• Reduction of hazardous accumulations of vegetation (fuels) in areas where these 

activities would have the highest likelihood of reducing the potential risk of wildland fire 

to lives and property; 

• Enhancement of the conditions of natural resources (e.g., increasing abundance or 

distribution of T&E species; reducing infestations of invasive, non-native plants; 

increasing native plant cover); and 

• Protection or enhancement of cultural resource elements and values (e.g., burning would 

be used to reduce vegetation in areas that are identified as important historic viewscapes). 

As with other alternatives, Alternative C would meet the goals of the Seashore’s fire program as 

stated in the Purpose and Need chapter. Of all alternatives, Alternative C would most fully meet 

the goals of maintaining or improving the condition of natural resources (goal 3) and improving 

both the knowledge of fire and refinement of fire management practices through research and 

monitoring (goal 7). In addition, because it includes treatment over many more acres than the 

other alternatives, Alternative C would meet the goals of protecting public safety (goal 1) and 

property (goal 2) to a greater degree. 

Under this alternative, a maximum of 2,000 acres would be subject to prescribed burning and a 

maximum of 1,500 acres would be subject to mechanical treatments. As in other alternatives, 

every five years fire management and resource management personnel would develop specific 

plans for prescribed burning and mechanical treatments that would be subject to NPS internal 

project review process. These five-year burn plans would in turn be reviewed annually and 

updated as needed. Under Alternative C, all FMUs would be subject to prescribed burning (See 

Figure 9). 

Prescribed Fire 

Implementation of Alternative C would result in a substantial increase in the acres that could be 

subject to prescribed burning. As noted above, the maximum number of acres that could be 

burned in any given year would quadruple compared with Alternative A and double compared 

with Alternative B. 

Limited information currently exists on the natural frequency (e.g., without any human 

influence) of lightning fires in the Seashore. In addition, accumulations of fuel in many areas far 

exceed what would have been present if the ecosystems had been burning at regular intervals. 

Therefore, prescribed burns intended for resource enhancement initially would be small and 
48 

would be subject to intensive monitoring and research. If research results indicated that 

ecological conditions were improving after prescribed burns in certain habitat types, the size of 

prescribed burns in these habitat types could increase. 

Similar to Alternative B, this alternative includes small pilot project burns in habitats where the 

ecological effects of burning are not fully understood. These include Douglas-fir stands, Bishop 

pine forests, coastal scrub, and some grassland habitats. The focus for prescribed burns under 

this alternative would be on areas where Seashore ecologists feel ecosystem health would be 

enhanced by burning and on areas where fuel accumulations create fire hazards. To the extent it 

is possible, prescribed burns would be conducted to approximate historic natural fire intensity 

and fire intervals. The intent is to allow the process of fire to act on the landscape as it has for 

thousands of years to the greatest extent possible, while ensuring human safety and protecting 

property. As with the other alternatives, Alternative C would also use prescribed fire to reduce 

infestations of highly invasive non-native plant species. Seashore personnel may time burns at 

unusual times of the year (spring, for example) to increase its effectiveness by killing young 

plants before they reproduce. 

Prescribed burns could occur in any of the FMUs, with the exception of the Minimum 

Management Unit. The total acres burned within the Seashore, however, would never exceed 

2,000 acres in any given year. The FMUs that would be subject to prescribed burning in 

Alternative C that are not burned in any other alternative include Tomales Point and Headlands. 

Most areas that would be subject to prescribed burning would be located within one mile of 

roads or major trails. The focus and intent of prescribed burns in each FMU are outlined below. 

Tomales Point - The Tomales Point FMU supports a population of approximately 450 tule elk 

(N. Gates, personal communication) and a suite of 11 plant species of special concern (Table 3). 

No fire history data have been collected from the immediate vicinity of Tomales Point, but it can 

be inferred from fire history data collected elsewhere in the Seashore that this FMU has been 

subject to periodic fire through time. The plant species composition of the grasslands in this 

FMU includes a mixture of native and non-native grasses and herbs, with scattered patches of 

coastal scrub dominated by coyote brush (Baccharis pilularis) and lupine (Lupinus arboreus). 

Based on results of research conducted in other California grasslands, application of prescribed 

fire may encourage establishment of a larger proportion of native species than presently occur 

there. Small prescribed burns would be conducted in the Tomales Point FMU and would be 

carefully monitored to determine the response of the plant communities, including the plants of 

special concern, to fire. Additional benefits of fire in creating habitat and forage for tule elk and 

host plants for Myrtle’s silverspot butterfly are also possible. 

Studies would also be conducted on these burn units to determine the response of the invasive 

non-native velvet grass to prescribed burning at different times of the year. Velvet grass is a 

highly invasive, non-native, perennial, rhizomatous grass that has been increasing in aerial extent 

and density in many areas of the Seashore, and has been identified by the park’s Exotic Plant 

Management Plan (NPS, 1989) as a priority for management. 

Headlands - Prescribed burns have not been conducted in this FMU in the past. Although fire 

history data have not been collected in this area, it is unlikely that this area has historically 
49 

Figure 9. Map of Project Area Showing Alternative C FMUs 
50 

burned frequently due to the prevailing fog and moist conditions occurring most of the year. 

Small, prescribed burns would be applied in this FMU on a trial basis to determine if fire can be 

used to reduce the aerial extent and density of invasive non-native plants such as velvet grass, 

and to increase the percentage of native plant species in the headlands communities. 

Estero – As in alternative B, prescribed burns would be conducted to contain and reduce the 

extent and density of the non-native plants Scotch broom, Monterey pine, Monterey cypress, and 

eucalyptus. Research would be conducted on the Scotch broom burn sites to determine the 

effects of prescribed burning on Scotch broom aerial extent and density. 

Inverness Ridge - The same focus of treatment as described in Alternative B would apply to the 

use of prescribed burns in Inverness Ridge in this alternative. Initial burns would include small 

pilot projects in Bishop pine forest to determine if such burns effectively reduce understory 

biomass and dead and downed fuels, promote regeneration of rare species reliant on fire, and do 

not result in invasion by non-native plant species. 

Limantour Road – Prescribed burning would be used to accomplish the same objectives in this 

FMU as described in Alternative B. These include reducing the density of Monterey pines, 

reducing hazardous fuel accumulations along the road corridor, and maintaining defensible space 

around buildings and visitor use areas. 

Wilderness North - The initial burns in this FMU would be small pilot projects in Douglas-fir 

forest and grassland near Mt. Wittenberg. The primary objectives of these burns would be similar 

to, but more expanded than in Alternative B, and include: 

• Reduce or break up the continuity of the very dense fuel loads occurring in many areas of 

the forest; thereby reducing the chance for adverse effects associated with an unplanned 

ignition (e.g., potential stand-replacing crown fire, loss of homes or other structures); 

• Establish areas of reduced fuel loads where fire suppression crews could be staged in the 

event of a wildfire; and 

• Reintroduce fire into forests that have historically burned on a regular basis (estimated 

fire return interval: 7-14 years), but which have not burned for 50-100 years. 

If small burns effectively reduce understory biomass, larger burns may be conducted in this 

FMU in the future. 

Wilderness South - The initial burns in this FMU would be small pilot projects in Douglas-fir 

forest and grassland near Firtop, and in Douglas-fir forest near Mud Lake. The primary 

objectives of these burns are identical to those described above for Wilderness North, and are 

similar to, but more expanded than those in Alternative B for this FMU. If small burns 

effectively reduce understory biomass, larger burns may be conducted in this FMU in the future. 
51 

Highway One – Prescribed burning would be used to achieve the same objectives in this FMU as 

under Alternative B. These include reducing grasses and other fuels along the highway corridor 

and the control of non-native French broom. 

Bolinas Ridge – Prescribed burning would be used to achieve the same objectives in this FMU as 

under Alternative B. These include creating defensible space along the Sir Francis Drake 

Boulevard road corridor, reducing fuels, and managing Marin manzanita and Mason’s ceanothus. 

Palomarin – Prescribed burning would be used to achieve the same objectives in this FMU as 

under Alternative B. These include reductions of fuel and French broom, as well as control of 

Douglas-fir encroachment into coastal scrub habitats. 

Mechanical Treatments 

Implementation of Alternative C would result in an increase, when compared to either 

Alternative A or B, in acres subject to mechanical treatments to reduce hazardous fuel 

accumulations and to create and maintain defensible space and fuel breaks (i.e., the maximum 

number of acres that could be treated in any given year would increase from 500 acres to 1,500 

acres). The Seashore would use mechanical treatments in the same FMUs as in Alternative B 

with the same objectives or focus for treatment, but mechanical cutting and thinning would take 

place on more acres. The FMUs that would receive mechanical treatment beyond clearing for 

fire roads and trails and around buildings to create defensible space are: 

• Tomales Point 

• Estero 

• Inverness Ridge 

• Limantour Road 

• Wilderness North 

• Wilderness South 

• Highway One 

• Palomarin 

The treatments could occur in any of these FMUs, but the total acres treated within the Seashore 

would never exceed 1,500 acres in any given year. Some of the acres to be mechanically treated 

would be the same acres that are subject to prescribed burning (e.g., Scotch broom may be 

mowed prior to burning). The focus and intent of mechanical treatment in each FMU are 

outlined below. 

Tomales Point – As in Alternative B, eucalyptus and Monterey cypress trees around Pierce Point 

Ranch would be subject to cutting and stump treatment with herbicides. 

Estero – As in Alternative B, eucalyptus, Monterey pine, and Monterey cypress would be subject 

to cutting and stump treatment with herbicides. Scotch broom populations would be cut or 

mowed. 
52 

Inverness Ridge – The same actions as described in Alternative B for this FMU would take place 

in this alternative as well. These include the creation and maintenance of a 3-mile shaded fuel 

break along the ridge. 

Limantour Road – The same actions as described in Alternative B, including trimming or 

removing trees along the road and cutting Monterey pine, would take place in this alternative. 

Wilderness North – As in Alternative B, mechanical treatment would be used to thin forests prior 

to prescribed burning if test burns indicate burning can be conducted safely and enhances 

Douglas-fir in this FMU. 

Wilderness South - As in Alternative B, mechanical treatment would be used to thin forests prior 

to prescribed burning if test burns indicate burning can be conducted safely and enhances 

Douglas-fir in this FMU. 

Highway One – The actions described in Alternative B for this FMU would also be conducted in 

Alternative C. These include mowing grasslands along the highway and thinning or removal of 

eucalyptus. 

Palomarin – As in Alternative B, Alternative C would include clearing of trees along roadways, 

mowing grasslands along the road, and cutting Douglas-fir encroaching into coastal scrub before 

these areas are burned. 

Fire Effects and Fuels Management Research 

Under Alternative C, the fire management program would be guided continually by the results of 

research on the ecological effects of fire and mechanical treatments. Ongoing research on 

Scotch broom, velvet grass, and rare chaparral plants would continue, and research on the effects 

of prescribed burning would expand into additional habitat types, including coastal grassland, 

Douglas-fir forest, riparian woodland, and Bishop pine forest. If the results of these studies are 

ecologically favorable (e.g., lead to increased native species richness, create areas supporting a 

variety of age classes within habitat types, and/or result in increases in rare species abundance or 

distribution), additional prescribed burning would occur in subsequent years in those habitat 

types. 

Under this alternative, the research program also would be expanded to include studies on the 

effects of mechanical fuel treatments on ecological parameters. Vegetation would be selectively 

removed from within Douglas-fir forests and in shrub-dominated habitats such as coastal scrub 

and chaparral to determine the effects of such removal on physical and biological elements (e.g., 

soils, selected plant species). Specific research topics that could be included under this 

alternative include, but are not limited to, the following: 

Tomales Point - the effects of prescribed burning on coastal grassland plant communities and 

wildlife species would be evaluated to determine if fire can be used to increase native species 

richness and density, to reduce density of velvet grass, and to increase the aerial extent and/or 

density of rare plants. 
53 

Headlands - the effects of prescribed burning on coastal grassland plant communities would be 

evaluated to determine if fire can be used to increase native species - both animal and plant -

richness and density, and/or to reduce density and aerial extent of non-native species. 

Inverness Ridge - the effects of prescribed burning on Bishop pine populations and associated 

plant and animal species within the Bishop pine community (including Marin manzanita and 

Mount Vision ceanothus) would be evaluated as in Alternative B; the effects of prescribed 

burning and mechanical treatments on dusky-footed woodrats, northern spotted owls, and Point 

Reyes mountain beavers would be assessed. 

Limantour Road - the effects of prescribed burning on the highly invasive non-native Harding 

grass would be evaluated; the effects of prescribed burning on the rare plant fragrant fritillary 

(Frittilaria liliaceae) would be studied. 

Wilderness North – the effects of prescribed burning on Douglas-fir forest communities, 

including spotted owl habitat elements would be evaluated; the effects of prescribed burning and 

mechanical treatments on dusky-footed woodrats would be assessed. 

Wilderness South - the effects of prescribed burning on Douglas-fir forest communities, 

including spotted owl habitat elements would be evaluated; the effects of prescribed burning and 

mechanical treatments on dusky-footed woodrats would be assessed; the effects of prescribed 

burning and mechanical treatments on the rare plant Marin manzanita would be assessed. 

Highway One – the effects of prescribed burning and mechanical treatments on creeks, riparian 

habitat, coho salmon and steelhead, and California freshwater shrimp would be assessed. 

Bolinas Ridge - the effects of prescribed burning on coastal grassland and chaparral plant 

communities would be evaluated to determine if fire can be used to increase native species 

richness and/or density as in Alternative B. 

Palomarin – the effectiveness of prescribed burning at reducing density or diversity of non-native 

plants would be assessed; the effects of prescribed burning and mechanical treatments on birds 

would be assessed in conjunction with the Point Reyes Bird Observatory as in Alternative B. 

General Research - researchers would expand their studies of the effects of fire on plant 

communities and wildlife (G. Geupel, Point Reyes Bird Observatory, pers. com.; G. Fellers, 

USGS-BRD, pers. com.). Northern spotted owls, dusky-footed woodrats and land birds would 

continue to be specifically targeted for study of fire effects in order to meet compliance 

requirements under Endangered Species Act. Other topics that would be researched include: 

presence of sudden oak death, prescribed fire influence on the distribution of common ravens, 

and the spreading of native seeds after a prescribed fire. 

Mitigation Measures 

The following mitigation measures would be applied regardless of the alternative selected: 
54 

General 

G-1. To ensure that implementation of fire management plan actions conforms to 

findings of this impact assessment, subsequent fire year plans and individual projects will 

be subject to NPS project review. Prior to approval, all projects will be submitted 

through an NPS internal review process wherein an interdisciplinary team will evaluate if 

the potential effects of the proposed projects are adequately addressed through the FMP 

NEPA process. Conformance to the conclusions in the FMP EIS will be documented for 

the NEPA record. If the team finds that the project has major new environmental effects 

not addressed in this EIS or effects greater than those described in this EIS, a separate 

environmental process will be conducted. 

Soils 

 General 

S-1. Individual burn plans will be written with enough detail to determine the extent of 

impacts to soil from erosion. Subject matter experts will determine if the erosion control 

plan submitted is sufficient to prevent long-term moderate or major impacts on the rate of 

soil erosion. In other words, the expert will determine if the proposed erosion control 

strategy will be sufficient to ensure no greater than minor impacts to soils from erosion. If 

the assessment finds that standard erosion control strategies will be insufficient to avoid 

long-term moderate or major effects on the rate of erosion, a separate NEPA process will 

be initiated for that burn plan. Strategies used to minimize impacts to soils can include 

avoiding steep slopes, timing burns to minimize erosion potential, or using erosion 

control devices during or after burns. 

S-2. Watershed level planning will be used to assure that erosion rates within any one 

watershed will conform to the conclusions of environmental effect reached in this FEIS, 

(e.g., impacts will be no more than moderate in intensity). Watershed level planning will 

be triggered when proposed actions have potential to exceed 10% of the total area of one 

or more FMP watersheds in one year. This mitigation measure assures that planning 

considers the watershed scale, and if a potential effect is identified, that a specific 

assessment be conducted for the burn plan to assure the conformance of watershed level 

effects with this FEIS. 

For Prescribed Burns 

S-3. Some coarse, woody debris, if available, will be left on the site for nutrient cycling 

and mycorrhizal function. 

S-4. All constructed fire lines will be rehabilitated to prevent compaction if needed. 

For Mechanical Treatments 

S-5. Mechanical regrading of roads will be conducted to specifications identified in the 

PRNS Trails Inventory and Condition Assessment and Road Memorandum of 
55 

Understanding with adjacent land management agencies. Use of these specifications will 

minimize erosion from fire roads. 

S- 6. For FMP tree removal actions in areas with highly erosive soils or slopes over 15%, 

tree stumps will be left in place and cut as close to ground surface as feasible. 

For Wildland Fire Control Activities 

S-7. Following wildland fires, soil rehabilitation efforts will be focused on rehabilitating 

ground disturbance from heavy equipment. 

S-8. Unless no feasible alternative is available, heavy equipment will not be used in areas 

where soils are wet or extensive compaction could occur. If staging of equipment or 

supplies occurs on soils, a clearly marked and visible limit of disturbance line will be 

installed using either stakes, flagging, or fencing. Surface soils in areas subjected to 

compaction will be scarified at the end of the period of use to retard runoff and promote 

revegetation. 

S-9. Erosion control measures will be implemented where project actions could leave 

soils exposed to runoff prior to revegetation. Erosion control measures include covering 

exposed soils with weed-free chipped material, native duff, erosion control blankets, or 

certified sterile rice straw. 

S-10. Where surface soils must be disturbed and soils support native vegetation, existing 

vegetation and topsoil will be retained and reinstalled whenever feasible. 

Air Quality 

A-1. If recommended by BAAQMD, prescribed burn plans submitted for review could 

be modified to reduce production of pollutants. Options include modifying burns to 

reduce the area burned, reducing fuel loading (e.g., mowing and understory thinning), or 

managing fuel consumption. Treatments to reduce overall air emissions from prescribed 

burns can include: 

• Mowing grass and reducing density of vegetation in brushlands. 

• Mechanical treatment of forested areas by removing standing or downed trees, 

understory thinning, thinning of forests, and creation of shaded firebreaks. 

• More frequent, less intense burns to prevent unwanted vegetation from becoming 

established in clearings or in forest understory. 

A-2. Increasing combustion efficiency or shifting the majority of combustion away from 

the smoldering phase and into the more efficient flaming phase will reduce emissions 

(except NOx, which is produced in greater quantities at higher temperatures). Methods to 

accomplish this will include pile or windrow burning, rapid mop-up, and shortened fire 
56 

duration. Pile or windrow burning will generate more heat and burn more efficiently and 

be most effective in reducing forest fuel rather than brush type fuels. 

A-3. The park will develop a Smoke Communication Strategy to guide management of 

smoke events during prescribed fires, managed wildland fires, suppression actions, and 

fires occurring outside the park. Notification of proposed burns will be disseminated 

through local media and postings to provide adequate advance notice to persons with 

sensitivities to smoke when burning is planned. Information will be provided to visitors, 

employees, and residents in smoke affected areas regarding health issues and concerns. 

The park will monitor particulate levels in the park during large smoke events to provide 

data for future assessments. 

A-4. PM2.5 monitoring data will be collected at Bear Valley in the Point Reyes National 

Seashore. Data collected will be shared with local, regional, and national air quality 

agencies and databases. 

A-5. To reduce smoke and pollutant generation during late summer and early fall, efforts 

will be made to burn fuel concentrations, piles, landings, and jackpots outside of the 

prescribed burning season to increase the number of units that can be burned without 

overloading the airshed on days with good dispersal conditions. 

A-6. To avoid impacts to visibility in the Class I PRNS portion of the project areas, 

burning will be avoided on holidays or other periods when recreational visitation is 

typically high. 

A-7. To avoid public health and nuisance impacts to neighboring communities, 

prescribed burns will be conducted under meteorological conditions that will avoid 

smoke drift into sensitive residential areas and that will transport smoke away from 

populated areas. Planning for prescribed burning also will consider the smoldering 

period to avoid fires where downslope winds during the night could carry smoke into 

residential areas at the base of ridges. 

Water Quality and Water Resources 

W-1. Individual burn plans will be written with enough detail to determine the extent of 

erosion within the burn area due to a) the prescribed burn and/or, b) mechanical 

treatments. Subject matter experts will determine if the erosion control plan submitted is 

sufficient to prevent long-term moderate or major impacts to the water resources and 

water quality, and will assure project compliance with TDML implementation plans for 

Tomales Bay, Lagunitas Creek, and Walker Creek, according to availability through 

adoption by the EPA. Strategies to minimize erosion and sediment transport to water 

resources associated with prescribed burning include avoiding oversteep slopes, timing 

burns to minimize erosion potential, or using erosion control devices after burns. 

Strategies to minimize erosion and sediment transport to water resources associated with 

mechanical treatment include avoiding oversteep slopes, avoiding scraping or clearing to 
57 

bare mineral soil (leave duff layer), or installing erosion control devices as part of 

mechanical treatment (if necessary). 

W-2. Watershed level planning will be used to assure that prescribed burning and/or 

mechanical treatment within any one watershed will conform to the conclusions of the 

environmental effect reached in this EIS (e.g., the impacts will be no more than moderate 

in intensity). Watershed level planning will be triggered when proposed actions have the 

potential to exceed 10% of the total area of one or more FMU watersheds in one year. 

This mitigation measure assures that planning considers the watershed scale and, if a 

potential effect is identified that a specific assessment be conducted for the burn plan to 

assure the conformance of the watershed level effects within this EIS. 

W-3. Helispots, staging areas, and spike camps will be located at least 100 feet away 

from streams, creeks, and other water bodies. 

W-4. All fireline (both handline and dozer line) will be rehabilitated as quickly as 

possible, which will include application of Burned Area Emergency Rehabilitation 

(BAER) techniques such as recontouring, soil stabilization as needed, and monitoring for 

erosion and treatment as necessary in the first winter following disturbance. 

W-5. When developing prescribed burn boundaries, non-treatment buffer areas will be 

established around perennial, intermittent, and ephemeral channels associated with 

Lagunitas Creek, Olema Creek, Pine Gulch Creek, and other coastal drainages originating 

from Inverness Ridge. Some treatment within buffer areas, including hand removal of 

non-native species and “cool” burns of non-native grasses, may occur within these areas. 

Fire lines around these areas will be mowed - not graded or scraped - in order to leave a 

100-foot vegetated buffer strip from burn areas. 

Vegetation

The following mitigation measures will be applied to reduce impacts from prescribed fire and 

mechanical treatment within all vegetation types: 

V-1. “Pre”-Treatment Measures 

• Individual prescribed burns will be conducted within the framework of a 

multidisciplinary planning effort. Personnel from fire management and from resource 

management will work together to identify areas that are expected to benefit from 

prescribed burning. Existing data on the response of plant communities in the 

Seashore to fire will be consolidated and analyzed to determine optimal areas, 

configurations, and times for burns. Clear objectives will be developed for prescribed 

burns that will include measurable parameters to determine the effects of the burns on 

vegetation. Following burns, vegetation will be analyzed to determine the effects of 

the burn, which will aid in future burn planning. 
58 

• Prescribed burns will be conducted at a time of year when introduction or spread of 

non-native plants will be minimized, and mortality of non-native plant species will be 

maximized. 

• Whenever possible, existing roads or trails will be used as firebreaks for prescribed 

burns and for wildland fire suppression. 

• Vegetation managers will work with fire management staff to develop maps of areas 

that support plant communities of special management concern (e.g., uncommon 

communities, wetlands, riparian areas, dunes, areas with no non-native plants that 

need to be kept intact, areas with highly invasive non-native plants that should not be 

spread) so fire personnel can attempt to avoid such areas when making decisions 

about fire management tactics. 

V-2. “During” Treatment Measures 

• Soil disturbance will be minimized to the greatest extent possible to reduce potential 

for introduction or spread of invasive non-native plant species. 

• The aerial extent of disturbance associated with mechanical treatments will be kept to 

the minimum necessary to reduce fire risk. 

• For helispots or spike camps, previously disturbed sites and open areas will be used 

whenever possible to minimize additional disturbance. 

• Burn piles will be kept small to minimize the area disturbed and to allow for the 

recolonization of sterilized patches by mycorrhizal fungi and other soil organisms in 

adjacent areas. 

V-3. “Post”-Treatment Measures 

• Areas subject to fire management treatments will be monitored periodically for the 

presence of invasive non-native plant species, and if such species have established or 

spread as a result of such activities, the non-natives will be removed. 

• All fireline (both handline and dozer line) will be rehabilitated as quickly as possible, 

which will include application of Burned Area Emergency Rehabilitation (BAER) 

techniques such as recontouring, soil stabilization as needed, and monitoring for and 

removal of invasive non-native plant species for a minimum of three years following 

a fire. 

V-4. In grasslands 

• Follow-up non-native plant monitoring and removal will be conducted to remove new 

recruits that come into the site in years following prescribed burning or mechanical 

treatments. 
59 

• All grassland burns will be carefully monitored to ensure burn objectives (= 

recruitment and long-term maintenance of native species without introduction of 

invasive non-native plant species) are being met. 

• To enhance grassland plant species composition, and reduce the chance of invasion or 

spread of non-native species, native seeding trials will be conducted following fire 

management treatments in some areas. 

• In Alternative C, small pilot burns (less than 100 acres) will be conducted in the 

Tomales Point FMU grassland to determine plant community response. These burns 

will be carefully monitored to ensure burn objectives (= recruitment and long-term 

maintenance of native species without introduction of invasive non-native plant 

species) are being met. If pilot projects determine objectives can be met using 

prescribed fire, individual burn size will increase to a maximum of 150 acres. 

V-5. In Bishop pine 

• Follow-up non-native plant monitoring and removal will be conducted to remove new 

recruits that come into the site in years following prescribed burning or mechanical 

treatments. 

• Prescribed burning in Bishop pine stands will occur only if the burns can be 

conducted under conditions that will result in germination and recruitment of new 

stands of Bishop pine. Relatively cool fires under moist conditions may not meet this 

objective. 

• Initially, prescribed burns in Bishop pine forest habitat will be small and will be 

carefully monitored to ensure burn objectives (= recruitment and long-term 

maintenance of Bishop pine and associated native species without introduction of 

invasive non-native plant species) are being met. 

V-6. In Douglas-fir/coast redwood forests 

• If pre-burn thinning of trees is required in forested stands, the trees to be thinned will 

be no larger than 10” in diameter. 

• Prior to conducting prescribed burning in Douglas-fir or coast redwood forests, 

Seashore fire and vegetation managers, and wildlife and plant ecologists will 

collaborate to fully develop rationale, objectives, prescriptions, and plans for 

conducting burns in the redwood forests within the project area. 

V-7. In hardwood forests 

• Site-specific objectives will be developed for prescribed burns in hardwood forest 

habitat. The intent of such burns may be to reduce density or abundance of this 
60 

vegetation type to encourage coastal scrub development, or may be to enhance the 

ecological health of the hardwood plant communities. Unique, site-specific burn 

prescriptions and timing will be required to meet these differing objectives. 

V-8. In coastal scrub 

• In coastal scrub small pilot burns (> 50 acres) will be conducted. These burns will be 

carefully monitored to ensure burn objectives (= recruitment and long-term 

maintenance of native species without introduction of invasive non-native plant 

species) are being met. If pilot projects determine objectives can be met using 

prescribed fire, individual burn size will increase to a maximum of 200 acres. 

Wetlands 

W-1. Burns will be allowed to back into and burn around wetlands and meadows or 

through them if the vegetation is dry enough to carry fire. Wetlands will be avoided to 

the greatest extent possible during fire confinement and containment. 

W-2. Fire suppression activities will not occur in wetlands unless there are no 

alternatives available to control the spread of a wildland fire. 

W-3. Fires near wetlands will be ignited when wetlands are too moist to sustain fire 

spread, thereby minimizing impacts to wetlands. 

W-4. To the greatest extent possible, mechanical treatments will not occur in wetlands. 

W-5. Wetlands may be used as natural boundary for prescribed fires. When a wetland 

area is being used as a boundary, the control line will occur in adjacent uplands, not in 

wetlands. 

W-6. Prescribed fires will not occur more frequently than the time required for native 

plant species to set seed. 

W-7. Foams or other fire retardants will not be used in or near wetlands. 

W-8. Firebreaks or firelines will be constructed in previously disturbed areas whenever 

possible. 

W-9. Chipped material will not be spread in wetlands. 

Special Status Species 

SS-1. Known populations of special-status plant and animal species will be monitored to 

ensure long-term impacts are avoided. Known populations of special status species will 

be avoided when locating helispots or spike camps. 
61 

SS-2. In Spotted Owl Habitat 

• annually identify and map areas where spotted owls are nesting, 

• protect occupied and previously used nest sites from unplanned ignitions, 

• do not conduct prescribed burns within 400 meters of an occupied or previously 

used nest site, 

• do not conduct mechanical treatments with mechanized equipment within 400 

meters of an occupied or previously used nest site between February 1 and July 31 

(breeding season), 

• conduct post-treatment monitoring to ascertain any impacts. 

SS-3. In Point Reyes Mountain Beaver Habitat 

• identify and map areas known to support Point Reyes mountain beaver and areas 

that have habitat suitable for supporting Point Reyes mountain beaver, 

• protect known and potential habitat from unplanned ignitions, 

• establish buffer areas 30 feet wide around known habitat areas, 

• conduct small burns (less than 100 acres) of mountain beaver habitat each year. 

SS-4. Avoid conducting treatments during nesting season, March 15 through July 31, 

unless biologists can ascertain that birds are not nesting in the planned burn area. 

SS-5. During the tule elk calving seasons, burns will be conducted in habitat away from 

areas where birthing and loafing of females and calves occur. 

SS-6. To protect California red-legged frogs, areas to be treated by mechanical means or 

prescribed fire will have a buffer area of 30 feet established around known 

breeding habitat. 

SS-7. The annual work plan for FMP implementation will be provided to NOAA 

Fisheries each year to allow that agency to monitor the types of projects proposed. 

Cultural Resources 

CR-1. Pre-Action 

• Cultural resources will be considered during all fire management planning efforts. 
62 

• Fire management personnel and other staff will receive annual training on cultural 

resources and fire management actions. 

• All cultural resources will be evaluated with respect to hazardous fuel loads. As 

needed, fuel loads will be reduced using methods commensurate with avoiding or 

minimizing adverse effects. Maintaining light fuel loads on and in close proximity to 

cultural resources will be emphasized. All areas slated for ground disturbing 

activities will be subjected to pre-action field surveys. This includes areas likely to 

be disturbed during future wildfires. 

• Pre-burn survey will be conducted prior to all prescribed burns as dictated by 

resource distribution and vulnerability, vegetation and topography, and expected fire 

behavior. 

• Consultation with local Native American communities will continue to occur in the 

context of fire management actions. Spiritual sites and important plant communities 

will be identified and appropriately managed for preservation, maintenance, and/or 

enhancement. 

• Computer and other databases containing cultural resources data will be created and 

maintained, and made available to fire management personnel in the event of 

emergencies. 

• Cultural resources specialists from adjacent land management agencies will be 

consulted in order to coordinate mitigation efforts prior to planned and unplanned fire 

management actions. 

• Appropriate cultural resources monitoring protocols will be established and 

implemented. 

• Potential research opportunities to study the effects of fire management actions on 

cultural resources will be identified. 

CR-2. During-Action 

• A cultural resource specialist or resource advisor will be present during all fire 

management actions where recorded and unrecorded resources of interest are 

considered at risk. Additional survey will be conducted on an as-needed basis. 

• Observations of fire behavior and other variables will be made with respect to 

recorded cultural resources and/or areas with high probability of containing 

unrecorded cultural resources. 

• Cultural resources data will be shared with fire management personnel as needed to 

avoid or minimize adverse effects. 
63 

• A cultural resource specialist or resource advisor will educate fire management 

personnel about cultural resources and the potential impacts of fire management 

actions. 

CR-3. Post-Action 

• The post-action condition of all recorded cultural resources will be assessed. 

Resources requiring stabilization or other treatment will be mitigated. 

• As appropriate, post-action survey will be conducted in previously surveyed and 

unsurveyed areas. Previously unrecorded cultural resources will be assessed for 

condition, and stabilization and other protection needs. 

• Monitoring and research data will be compiled, evaluated, and used to help refine 

cultural resource compliance for fire management actions. 

Human Health and Safety

HH-1. Firefighters will be frequently rotated and allowed to rest or sleep when needed, 

and firelines and safety zones will be used to minimize exposure. 

Alternatives Considered But Not Analyzed Further in This FEIS 

Allow Wildland Fires to Burn without Human Intervention 

This alternative was considered initially to determine the associated extent of impacts and 

resource benefits. Although wildland fire would result in substantial ecological benefits in many 

areas of the Seashore, the risk of significant adverse impacts to lives, property and resources 

would increase to an unacceptable level. In other words, meeting the FMP goal of protecting 

private and public property could not be guaranteed. Allowing uncontrolled burning also could 

violate a number of state and federal resource laws (e.g., Clean Air Act). For these reasons, this 

alternative was not analyzed further. 

Apply Mechanical Treatments Only 

The park uses mechanical treatments, including mowing, grazing and selective thinning, to 

remove hazardous fuels around buildings and along travel corridors. Use of these methods 

throughout the entire park is not possible due to federal laws (e.g., Wilderness Act) and 

unacceptable adverse impacts to natural resources. Much of the park that is not currently in the 

Pastoral Zone is rugged and without access. To mechanically treat these areas would require 

extensive labor and use of equipment incompatible with land use. Additionally, many of the 

species and ecosystems in the Seashore depend on periodic fire for their survival, and 

mechanical treatments cannot substitute for burning. For these reasons, this alternative was not 

analyzed further. 

Create Wildland Fire Use Zone for Philip Burton Wilderness Area 

This alternative was considered initially to meet objectives of the 1999 Resources Management 

Plan - to protect and perpetuate the diversity of natural ecosystems and to manage as wilderness 
64 

those lands so designated. Upon further consideration, however, it was recognized that 

defensible boundaries to contain fires within the wilderness do not exist, and the risk of adverse 

impacts to lives, property and resources would be unacceptable. For these reasons, this 

alternative was not analyzed further. 

The Environmentally Preferred Alternative 

National Park Service policy regarding implementation of the National Environmental Policy 

Act (NEPA) requires that an environmentally preferred alternative be identified in all NEPA 

analysis documents. Determination of this alternative takes place after the environmental 

analysis is complete. The environmentally preferred alternative is the alternative that best 

promotes the national environmental policy expressed in Section 101 of NEPA. This includes 

alternatives that would: 

• Fulfill the responsibilities of each generation as trustee of the environment for succeeding 

generations; 

• Assure for all visitors a safe, healthful, productive, and aesthetically and culturally 

pleasing surroundings; 

• Attain the widest range of beneficial uses of the environment without degradation, risk of 

health or safety, or other undesirable and unintended consequences; 

• Preserve important historic, cultural and natural aspects of our national heritage and 

maintain, wherever possible, an environment which supports diversity and variety of 

individual choice; 

• Achieve a balance of population and resource use which would permit high standards of 

living and a wide sharing of life’s amenities; and 

• Enhance the quality of renewable resources and approach the maximum attainable 

recycling of depletable resources. 

Essentially, this means the environmentally preferred alternative is the one that causes the least 

damage to the biological and physical environment or most naturally perpetuates biological or 

physical process; it also means the alternative which is best suited to protect, preserve, and 

enhance historic, cultural and natural resources and process. After analyzing the alternatives 

described in this FEIS, the National Park Service has determined that Alternative C is 

environmentally preferred. Alternative C includes fire management treatments that would 

provide a high level of protection of human health, life and property, while maximizing efforts 

toward restoring and maintaining ecological integrity, and protecting and enhancing cultural 

resources (e.g., preserving important historic, cultural and natural aspects of our national 

heritage). Although Alternative B also would provide a high level of protection of life and 

property, it would not provide the same benefits to natural and cultural resources. Of the three 

alternatives, Alternative A (No Action) would provide the lowest degree of protection of lives 

and property, and minimal benefits to natural and cultural resources. 

National Park Service policy also directs that all environmental analysis documents address 

compliance with Section 102(1) of NEPA. This section states that the policies, regulations, and 

public laws of the United States shall be interpreted and administered in accordance with the 

policies set forward in NEPA. This document was written in support of National Park Service 
65 

Fire Policy and other policies and legislation governing management of National Park sites in 

accordance with NEPA. 

The Preferred Alternative 

Alternative C has been selected as the alternative preferred by the National Park Service. The 

Superintendent has reviewed the FEIS and has evaluated the three alternatives with respect to 

how well they meet the fire program objectives, and their beneficial and adverse impacts on all 

resource topics (Table 5). Alternative C offers the best combination of benefits, with a high level 

of protection of life and property, and greater long and short-term natural and cultural resource 

benefits than either Alternatives A or B. 

Table 5. Range of FMP Alternatives Compared by Fire Management Goals 

Goals Alt. A Alt. B Alt. C 

Protect firefighters and the public 2 2 3 

Protect private and public property 1 2 3 

Maintain or improve conditions of natural resources and 

protect these resources from adverse impacts of wildland 

fire and fire management practices 

2 2 3 

Maximize efforts to protect cultural resources from 

adverse effects of wildland fire and fire management 

practices 

2 3 3 

Foster and maintain effective community and interagency 

fire management partnerships 

3 3 3 

Foster a high degree of understanding of fire and fuels 

management among park employees, neighbors, and 

visitors 

2 3 3 

Improve knowledge and understanding of fire through 

research and monitoring and continue to refine fire 

management practices 

2 2 3 

1 - Partially Meets Goal 

2 –Meets Basic Level of Goal 

3 –Provides Highest Levels of Goal Achievement 

 
66 

Table 6. Summary of Preferred Alternative and Alternatives 

 Alternative A: 

No Action 

Continued Fuel 

Reduction for Public 

Safety and Limited 

Resource Enhancement

Alternative B: 

Expanded Hazardous 

Fuel Reduction and 

Additional Natural 

Resource Enhancement

Alternative C: 

(Preferred) 

Increased Natural 

Resource Enhancement 

and Expanded 

Hazardous Fuel 

Reduction 

Prescribed Fire 500 acres would be treated 

annually with prescribed fire 

to reduce fuel loads. 

1000 acres would be treated 

with prescribed fire to 

reduce fuel loads and 

conduct natural and cultural 

resource enhancement. 

2,000 acres would be treated 

with prescribed fire to 

reduce fuel loads and 

conduct natural and cultural 

resource enhancement. 

Mechanical Treatments 500 acres would be treated 

annually with mechanical 

means to reduce fuel loads. 

1000 acres would be treated 

annually with mechanical 

means to reduce fuel loads 

and conduct resource 

management enhancement. 

1,500 acres would be treated 

annually with mechanical 

means to reduce fuel loads 

and conduct resource 

management enhancement. 

Fire Management Units 

Treated by Alternative 

A total of four (4) FMUs 

would be treated. 

Prescribed Fire FMUs (4): 

Estero, Limantour Road, 

Highway One, and Bolinas 

Ridge. 

Mechanical treatment FMUs 

(3): Estero, Limantour Road, 

and Highway One. 

A total of nine FMUs would 

be treated. 

Prescribed Fire FMUs (8): 

Estero, Inverness Ridge, 

Limantour Road, Wilderness

North, Wilderness South, 

Highway One, Bolinas 

Ridge, and Palomarin. 

Mechanical treatment FMUs 

(8): Tomales Point, Estero, 

Inverness Ridge, Limantour 

Road, Wilderness North, 

Wilderness South, Highway 

One, and Palomarin. 

A total of ten (10) FMUs 

would be treated. 

Prescribed Fire FMUs (10): 

Tomales Point, Headlands, 

Estero, Inverness Ridge, 

Limantour Road, Wilderness

North, Wilderness South, 

Highway One, Bolinas 

Ridge, and Palomarin. 

Mechanical treatment FMUs 

(8): Tomales Point, Estero, 

Inverness Ridge, Limantour 

Road, Wilderness North, 

Wilderness South, Highway 

One, and Palomarin. 

Total Acres in the FMUs 

to be Treated During 

Life of Plan (some 

acres may be treated 

more than once to 

ensure fuel reduction) 

10,865 20,620 21,419 

Wildfire Suppression Current policy is to suppress 

all unplanned ignitions using 

minimum impact 

suppression tacks to the 

greatest extent possible. 

Same as Alternative A Same as Alternative A 

Fire Education A comprehensive program 

of information and education 

would be conducted to 

ensure public knowledge 

Same as Alternative A. Same as Alternative A. 
67 

and understanding of 

prescribed burns and other 

treatments. NPS would 

work with local fire districts 

to encourage defensible 

space. 

Fire Cache Construction A fire cache would be 

constructed at Bear Valley 

(park headquarters) to 

facilitate fire management 

program. 

Same as Alternative A. Same as Alternative A. 

Fire Effects and Fuel 

Management Research 

Fire effects program would 

continue and research on 

velvet grass and Scotch 

broom would continue. 

Same as Alternative A. Same as Alternative A, but 

expanded research on a 

variety of topics to guide 

expansion of resource 

enhancements projects. 
68 

Table 7. Summary of Impacts of Alternatives 

Alternative A: 

No Action 

Continued Fuel Reduction for 

Public Safety and Limited Resource 

Enhancement 

Alternative B: 

Expanded 

Hazardous Fuel 

Reduction and 

Additional Natural 

Resource 

Enhancement 

Alternative C: 

Preferred 

Increased Natural 

Resource 

Enhancement and 

Expanded 

Hazardous Fuel 

Reduction 

Prescribed burning would result in 

negligible to minor increases in erosion 

and changes soil productivity and 

chemistry 

Burn plans would be 

used to ensure 

increased erosion 

would affect no more 

than 10% of soils in a 

watershed; impacts 

would be no more than 

minor 

Same as Alternative B 

Moderate to major short to long-term 

impacts to soils from a catastrophic 

wildland fire from erosion, hydrophobic 

soils, slope failure, suppression 

Same as Alternative A Same as Alternative A 

Soils 

Negligible impacts to soils from their 

removal to build the fire cache would 

occur 

Same as Alternative A Same as Alternative A 

Particulate emissions from all fire 

management activities would have a 

negligible long, term, adverse effect on 

regional haze. 

Fire management 

activities would 

produce 2.86 pounds of 

particulates per acre—

about twice that of 

Alternative A and a 

minor long-term, 

adverse impact to 

regional haze. 

Fire management 

activities would 

produce 5.3 pounds of 

particulates per acre 

and a moderate, longterm adverse impact on 

regional haze 

The ongoing risk of a large wildfire and 

associated major adverse impacts to air 

quality would remain high. 

Treatment would 

reduce the risk of a 

catastrophic wildfire 

and offer possible 

short-term major 

benefits to air quality as 

a result. 

Same as Alternative B, 

although the risk of 

wildfire would be even 

lower. 

Air Quality 

Negligible short-term impacts to air 

quality from the use of construction 

equipment to build the fire cache would 

occur. 

Same as Alternative A Same as Alternative A 

Increases in erosion from hydrophobic 

soils, loss of vegetation and ash from 

prescribed burning would increase 

suspended solids, with negligible to minor 

impacts to water quality. 

Same as Alternative A, 

although impacts would 

be more likely to be 

minor than negligible. 

Same as Alternatives A 

and B, although 

impacts would be the 

most adverse of any 

alternative. 

Water 

Resources 

and Water 

Quality 

Trampling and removal of vegetation from 

mechanical thinning or suppression of 

small wildfires could increase erosion and 

have negligible, localized short-term 

adverse impacts to water quality 

Impacts would be 

minor. 

Impacts would be 

minor and greater than 

Alternatives A or B. 
69 

Large wildfires could have major adverse 

impacts on water quality and watershed 

from increased erosion and destruction of 

vegetation, including riparian vegetation. 

Same as Alternative A Same as Alternative A 

Treatment with mechanical thinning and 

prescribed burning would reduce the risk 

of catastrophic fire and have potential 

moderate benefits to watersheds and water 

quality. 

Potential moderate to 

major benefits to 

watershed and water 

quality from a 

reduction in fuel 

loading and resulting 

decreased risk of 

catastrophic wildfire. 

Same as Alternative B, 

although the benefits 

would be more likely to 

be major. 

No impacts to any water quality or 

watershed resource from building the fire 

cache would occur. 

Same as Alternative A Same as Alternative A 

Minor, short-term impacts from the spread 

of non-native plants following prescribed 

fire are possible 

Same as Alternative A Same as Alternative A 

Minor to moderate beneficial impacts to 

native fire dependent vegetation from 

stimulating growth and killing non-native 

plants 

Moderate benefits Moderate benefits, but 

greater than Alternative 

B 

Crushing or shearing from mechanical 

equipment or trampling could have shortterm minor adverse impacts 

Same as Alternative A Same as Alternative A 

Minor to moderate benefits from clearing 

dense vegetation through mechanical 

treatment 

Moderate benefits Moderate benefits, but 

greater than Alternative 

B 

Minor to moderate benefits would occur to 

native scrub and forest vegetation from 

removing Monterey pine and Monterey 

cypress trees 

Same as Alternative A Same as Alternative A 

Minor to moderate benefits to coastal 

scrub from the removal of scotch broom 

with prescribed fire and additional 

moderate to major benefits from removing 

scotch and french broom with mechanical 

treatment. 

Moderate benefits from 

prescribed fire and 

major benefits from 

mechanical treatment. 

Moderate benefits from 

prescribed fire, but 

greater than Alternative 

B; major benefits from 

mowing, but larger than 

Alternative B. 

No plans to burn in these FMUs to 

increase species richness 

Minor benefits to 

coastal scrub from 

prescribed burning in 

Bolinas and Palomarin 

to increase species 

richness 

Same as Alternative B 

Prescribed burning in grasslands may have 

minor adverse impacts or benefits, 

depending on reaction of native and nonnative species 

Same as Alternative A, 

although benefits or 

adverse impacts may be 

greater (they would 

remain minor) 

Same as Alternative B, 

although benefits or 

adverse impacts may be 

greater (they would 

remain minor) 

Vegetation 

Negligible benefits to hardwood, Douglas 

fir or Bishop pine forests from decreased 

fuel loads 

Minor to moderate 

benefits 

Moderate benefits 
70 

No plans to aggressively treat in Douglas 

fir forest 

Same as Alternative A Possible major benefits 

to Douglas fir forests 

from returning natural 

fire intervals following 

treatment 

Cumulative impacts of catastrophic fire, 

historic logging, development and disease 

have been major, long-term and adverse. 

This would continue. 

Same as Alternative A, 

although the risk of a 

catastrophic fire would 

decrease. 

Same as Alternative B, 

although the risk of a 

catastrophic fire would 

decrease further. 

Negligible impacts to scrub, forest or 

grassland vegetation may occur from 

removing them to build the fire cache, 

although the cache is to be located in an 

area that is already disturbed. 

Same as Alternative A Same as Alternative A 

Short-term minor adverse impacts from 

inadvertent burning to non-adapted 

wetland vegetation during prescribed 

burns. 

Same as Alternative A Same as Alternative A 

Minor to moderate short to long-term 

benefits from inadvertent burning of 

adapted wetland vegetation or of exotics in 

wetlands from prescribed fire possible 

Same as Alternative A Same as alternative A, 

although more likely to 

be moderate than minor 

Minor short-term adverse impacts from 

suppression of average sized wildfires, and 

minor positive or negative impacts to 

vegetation from fires. 

Same as Alternative A Same as Alternative A 

Mechanical treatment in wetlands usually 

avoided; however if needed it may have 

negligible to minor short-term adverse 

impacts from trampling, or minor benefits 

from clearing exotics 

Same as Alternative A, 

although adverse 

impacts more likely to 

be minor. 

Same as Alternative B, 

although adverse 

impacts could be 

greater. 

Cumulative impacts from development 

and catastrophic fire could have major, 

long-term adverse impacts from 

destruction of vegetation, invasion of 

exotic species 

Same as Alternative A Same as Alternative A 

Wetlands 

No wetlands would be disturbed or 

removed in building the fire cache. 

Same as Alternative A Same as Alternative A 

Fire management activities would have a 

minor short or long-term benefit by 

creating more open wildlife habitat and 

reducing the risk of catastrophic fire 

Moderate benefits 

compared to 

Alternative A 

Moderate to major 

benefits compared to 

Alternative A 

Minor short-term impacts from 

suppression of average sized wildfires 

would continue. 

Impacts would remain 

minor, but be greater 

than Alternative A 

Impacts would remain 

minor, but be greater 

than all alternatives 

Minor adverse impact to forest dwelling 

species from treatment 

Minor to moderate 

impacts compared to 

Alternative A 

Minor to moderate 

impacts compared to 

Alternative A 

Wildlife 

Cumulative impacts of development, 

habitat alteration and a catastrophic fire, 

should it occur, would all have major, long 

or short-term adverse impacts on wildlife. 

Same as Alternative A Same as Alternative A 
71 

Short-term, minor adverse impacts on 

wildlife in the vicinity of the planned fire 

cache could occur during construction 

from noise and the presence of humans 

Same as Alternative A Same as Alternative A 

No federally listed plants would be 

affected, as all known populations lie in 

the Minimum Management Zone, where 

treated is not planned. 

Same as Alternative A Same as Alternative A 

Plant species of concern would likely 

continue to experience minor landscape 

scale benefits from fire management 

activities 

Benefits would 

increase, but remain 

minor 

Benefits would be the 

greatest of the 

alternatives, but remain 

minor 

Special 

Status 

Species 

Plant species of concern may experience 

minor adverse effects from destruction, or 

inadvertent stimulation of exotic species 

during prescribed burns 

Same as Alternative A Same as Alternative A 

Treatment would offer negligible to minor, 

long-term benefits to northern spotted 

owls, red-legged frogs and California 

freshwater shrimp from a reduction in the 

risk of catastrophic fire 

Minor benefits Moderate benefits 

Hand thinning and pile burning could have 

minor short-term effects to spotted owls 

from disturbance, and on red legged frogs 

from inadvertently crushing them 

Same as Alternative A Same as Alternative A 

Spotted 

owls, redlegged 

frogs, 

California 

freshwater 

shrimp 

Cumulative effects of a large-scale 

wildfire would be long-term, major and 

adverse on spotted owls and red-legged 

frogs 

Same as Alternative A Same as Alternative A 

Fire management would not normally take 

place in riparian vegetation, so impacts to 

coho salmon and steelhead trout would be 

inadvertent, and remain negligible to 

minor. 

Same as Alternative A Same as Alternative A 

Negligible positive benefits to coho and 

steelhead from reducing the risk and 

intensity of a catastrophic fire 

Same as Alternative A Same as Alternative A 

Coho 

salmon and 

steelhead 

trout 

Siltation of streams and loss of riparian 

vegetation would have minor to major 

impacts 

Same as Alternative A Same as Alternative A 

Myrtle’s 

silverspot 

butterfly 

and snowy 

plovers 

Myrtle’s silverspot butterfly and snowy 

plovers occur in the Minimum 

Management Unit, where fire management 

activities are not anticipated. No impact 

from the FMP would occur 

Same as Alternative A Same as Alternative A 

Minor impacts to Point Reyes mountain 

beaver from fire management activities, 

including suppression of average sized 

wildfires would occur 

Pt. Reyes Same as Alternative A Same as Alternative A 

Mountain 

Beaver 

Large-scale wildfires could have short to 

long-term moderate to major adverse 

impacts from habitat destruction, and 

direct and indirect killing of animals 

Same as Alternative A Same as Alternative A 

No impact to any listed plant or animal 

species would occur from construction of 

Same as Alternative A Same as Alternative A 
72 

the fire cache 

Moderate benefits to historic buildings by 

reducing fuel building through fire 

management activities would occur 

Benefits would remain 

moderate, but be 

greater than in 

Alternative A 

Benefits would remain 

moderate, but be the 

greatest of any 

alternative 

Minor adverse impacts from ground 

disturbance associated with pre-treatment 

or mechanical thinning could occur 

Impacts would remain 

minor, but be greater 

than in Alternative A 

Moderate 

Moderate long-term benefits to cultural 

landscapes from the use of prescribed 

burning or mechanical treatment possible 

Benefits would remain 

moderate, but be 

greater than in 

Alternative A 

Benefits would remain 

moderate, but be the 

greatest of any 

alternative 

Suppression of average sized wildfires or 

of larger wildfires could have unknown 

negligible to major, permanent adverse 

impacts to cultural resources. Large 

wildfires could also destroy cultural 

resources. 

Same as Alternative A Same as Alternative A 

Cultural 

Resources 

No impacts from construction of the fire 

cache are anticipated 

Same as Alternative A Same as Alternative A 

Minor positive impacts from prescribed 

fire on visitor experience by opening 

scenic vistas 

Same as Alternative A Same as Alternative A 

Minor adverse effects on visitors from the 

site of blackened vegetation from 

prescribed burning 

Same as Alternative A Moderate impact on 

visitors possible 

Minor impact on visitor use from closures 

during prescribed burn 

Impact is greater than 

Alternative A, but 

remains minor (up to 

30 days/year) 

Moderate impact of up 

to 50 days of closures 

Minor impact to visitor use and experience 

from closures and noise during mechanical 

treatment. 

Impact is greater than 

Alternative A, but 

remains minor 

Moderate impact 

possible 

Minor short-term adverse impact to 

visitors from noise and dust associated 

with construction of fire cache 

Same as Alternative A Same as Alternative A 

Visitor Use 

and Visitor 

Experience 

Major, short to long-term adverse impacts 

on visitor use and visitor experience 

possible from large-scale wildfire 

Same as Alternative A Same as Alternative A 

Fire management operations require 13 

staff and account for about 15% of the 

park budget 

A 3.8% increase in 

funding and staffing 

would be required, a 

minor impact 

A 5.9% increase in 

funding and staff would 

be required, a minor 

impact 

Funding the fire cache would have a shortterm negligible adverse impact on the 

park’s budget, but would have long-term 

minor benefits in terms of increased staff 

efficiency. 

Same as Alternative A Same as Alternative A 

Park 

Operations 

Suppression of a large-scale wildfire 

would have short-term, major adverse 

impacts on park operations, management 

and budget 

Same as Alternative A Same as Alternative A 
73 

Impacts from prescribed burning and 

mechanical thinning on human health and 

safety, including the public and firefighters 

would be short-term and minor. 

Same as Alternative A Same as Alternative A 

Large, severe wildfires could have major 

adverse effects on the risk and impacts 

from smoke or fire to public and firefighter 

health and safety 

Same as Alternative A Same as Alternative A 

Negligible benefits from the reduction in 

risk or intensity of a large wildfire 

Moderate benefits Moderate benefits 

Public 

Health and 

Safety 

Completion of the fire cache would have 

minor benefits in increasing efficiency of 

response 

Same as Alternative A Same as Alternative A 

Minor benefits to the local economy from 

fire management program and staff 

spending 

Same as Alternative A Moderate benefits 

No or negligible impacts on local economy 

from loss of tourist dollars during closures 

from prescribed burning 

Impacts would remain 

negligible, but be 

greater than Alternative 

A 

Impacts would remain 

negligible, but be the 

greatest of all 

alternatives 

Negligible to minor impacts on local 

economy from loss of tourist dollars 

during closures from mechanical treatment 

Impacts would remain 

negligible, but be 

greater than Alternative 

A 

Impacts would remain 

negligible, but be the 

greatest of all 

alternatives 

Negligible, short-term impacts to the local 

economy from loss of tourist dollars 

during closures for suppression of average 

sized wildfires 

Same as Alternative A Same as Alternative A 

Socioeconomics 

A large wildfire could have major, short to 

long-term adverse impacts on the local 

economy, loss of property, but possible 

major benefits from increases in local 

spending from suppression program needs 

and personnel 

Same as Alternative A Same as Alternative A 
74 

CHAPTER 3: AFFECTED 

ENVIRONMENT 
75 

INTRODUCTION 

This chapter provides an understanding of both the general environmental setting of the project 

area and a more focused description of those resources that could be affected by the 

implementation of the FMP alternatives. The first section, Project Setting, is presented to foster 

a fuller understanding of the scope of the FMP. The Affected Environment is required (by the 

Council on Environmental Quality NEPA regulations, Sec. 1502.15) to succinctly describe the 

environment of the area(s) likely to be affected by the alternatives under consideration, and focus 

efforts and attention on important issues. Scoping determined that the areas of the environment 

that could be affected by the FMP are soil resources, air quality, water quality, vegetation, 

wildlife, cultural resources, park visitor experience, park operations and socioeconomics. 

PROJECT SETTING 

Overview 

The project area is located in central California, in western Marin County, approximately 40 

miles northwest of the city of San Francisco (see Figure 1 and Figure 2). It is comprised of 

federal lands managed by the Point Reyes National Seashore, a unit of the National Park System, 

and is within 50 miles of the nine-county San Francisco Bay Area, the 5th largest metropolitan 

area in the United States (see Figure 10). 

Generally, the more developed regions of the bay area surround the bay itself, with smaller cities, 

towns, open space and agricultural areas in an outer ring around the urban core. Forty-eight 

percent (159,044 acres) of the 332,800 acres in Marin County is held as parks, open space and 

watershed (Marin County Community Development Agency 2002). Thirty-six percent (119,808 

acres) is in agricultural use. Developed lands constitute only 11% of the county while 5% of the 

county has future development potential. 

While eastern Marin is heavily developed along the Highway 101 corridor, western Marin is 

primarily rural with scattered small unincorporated towns that serve agriculture, local residents 

and tourism. Roughly 90% of the quarter of a million residents of Marin County live in the 

eastern half of the County along the major transportation corridor -- State Highway 101. 
76 

Figure 10. Population Density for San Francisco Bay Area in 1990 
77 

Regional Context and Surrounding Communities 

The project area consists of 90,311 acres of the Point Reyes National Seashore (PRNS) and the 

northern lands of Golden Gate National Recreation Area (GGNRA). The total project area 

includes 86 miles of shoreline on both the Pacific Ocean and Tomales Bay. The 71,046-acre 

Seashore includes beaches, coastal cliffs and headlands, marine terraces, coastal uplands, 

woodlands, and forests on the Point Reyes Peninsula. 

PRNS is bounded to the north, west and southwest by the Pacific Ocean and to the east by the 

residential communities of Inverness, Inverness Park, Point Reyes Station, Olema, and Dogtown. 

The town of Bolinas is south of PRNS at the southern tip of the Peninsula (see Figure 11). An 

estimated 3,800 permanent residents live in the towns and communities close to the project area 

from the tip of Tomales Bay in the north to Stinson Beach in the south (US Census Bureau 

2000). The census population figure does not count the many part-time residents of western 

Marin who maintain second homes in the project area. 

Through a memorandum of agreement between the two national parks, PRNS manages the 

19,265 acres of Bolinas Ridge for GGNRA. Bolinas Ridge is a northwest/southeast trending 

ridge paralleling the Olema Valley and the San Andreas fault zone. The northwest-facing slope 

of the Ridge is primarily grassland and shrub with east facing slopes forested with Douglas-fir 

and coast redwood. 

East of the project area, land use is a mix of private residential and agricultural lands, publicly 

held watershed, and parks and open space. Adjacent to the park are areas managed by Audubon 

Canyon Ranch, Marin Municipal Water District, Tomales Bay and Samuel P. Taylor State Parks, 

and Marin County Open Space District (MCOSD) lands. Marine boundaries are shared with the 

Gulf of the Farallones and the Cordell Banks National Marine Sanctuaries, and Tomales Bay 

State Park. Some agricultural parcels are part of the Marin Agricultural Land Trust to which the 

owners have deeded development rights to protect rural agriculture from development pressures. 

Park Management Zoning 

PRNS and GGNRA share a general management plan (NPS, 1980), which uses the following 

zoning designations (see Figure 12) to guide park management. Prescribed fire and other fuel 

management strategies could be used to help achieve the desired future conditions described for 

some or all of these zones. 

Project area lands fall under one of two management zones: Natural Resource Zone or Historic 

Resource Zone. The Natural Resource Zone covers pastoral lands, natural landscape areas, 

sensitive resources, designated wilderness and marine reserves. Historic ranches, the Point 

Reyes lighthouse and the lifesaving station are included in the Historic Resource Zone. A third 

zone called Special Use Zone exists within the boundaries of PRNS and GGNRA, but is not 

applicable to fire management. These lands are managed by another entity such as Mt. Tamalpais 

State Park and Audubon Canyon Ranch. 
78 

Figure 11. Local Communities 
79 

Figure 12. Point Reyes National Seashore Ownership and Management Zones 
80 

Natural Resource Zones 

Pastoral Landscape Management Zone (northern Olema Valley and northern Point Reyes 

peninsula). Approximately 19,000 acres of PRNS have been retained in agricultural production 

within the pastoral zone that supports beef and dairy production. The Northern District of 

GGNRA contains an additional 10,500 acres leased for cattle grazing. Pastoral operations 

presently include seven dairy and ten beef cattle ranches. The GMP indicates that, at a 

minimum, agricultural buildings and open grasslands will be retained in these areas, and where 

feasible, livestock grazing will continue within the limits of carefully monitored range capacities 

(NPS, 1980, p. 18), and that future resource management studies could significantly alter the 

configuration of this zone. To help in carrying out these policies, the FMP may include small 

pilot projects within the pastoral lands geared towards techniques for the control of invasive 

exotic plant species such as Scotch and French broom and the maintenance of high-quality 

pasture for cattle grazing. The Estero and Headlands FMUs, the northern end of the Bolinas 

Ridge FMU and the southern end of the Palomarin FMU are in the Pastoral Landscape 

Management Zone. 

Natural Landscape Management Zone (southern Olema Valley and Bolinas Ridge, Limantour 

Road corridor and Limantour Beach, Tomales Bay shoreline north of the State Park, Bear 

Valley, recreational beaches, road corridors and select trail corridors). The Natural Landscape 

Management Zone applies to those lands containing important natural resources that are not 

within the designated wilderness of PRNS. The largest track is the southern half of the Bolinas 

Ridge, lands buffering Limantour Road and Limantour Beach and the Marshall Beach area north 

of Tomales Bay State Park. GMP direction for these areas is that natural resources and processes 

remain as undisturbed as possible given a relatively high level of park use (NPS, 1980, p. 18). 

The Olema Valley is to be managed to maintain the visual contrast between woodland and open 

grassland. (NPS, 1980, p. 96). Fire management strategies such as selective thinning, burning 

and mowing would be cautiously pursued in this zone with the objective of protecting scenic, 

ecological and recreational values. The Inverness Ridge, Limantour and Palomarin FMUs are 

within this zone as are the road corridors of the Wilderness North and South FMUs. 

Special Protection Zone (Philip Burton Wilderness Area. Gulf of the Farallones National Marine 

Sanctuary, State of California Marine Reserves, shorelines and riparian corridors). Special 

Protection Zones includes lands that have received legislative or special administrative 

recognition of exceptional natural qualities requiring strict protection measures. 

Wilderness Subzone. Public Law 94-567 designated more than half of PRNS as the 32,373-acre 

Philip Burton Wilderness Area, part of the National Wilderness Preservation System. As 

directed in NPS 2001 Management Policies (2000), fire management activities in wilderness 

areas must: 

• Conform to the basic purposes of wilderness, 

• Provide for the identification and reconciliation of the natural and historic roles of fire in 

the wilderness, and 

• Identify a prescription for response to natural and human-caused wildfires in the 

wilderness area. (NPS, 2000, section 6.3.9) 
81 

The Management Policies also state that suppression strategies for wildland fire in wilderness 

areas must use the “minimum requirement” concept, a process of identifying the least damaging 

tools or activities, to protect natural and cultural resources and minimize any lasting impacts of 

the suppression actions. The Tomales Point, North Wilderness, South Wilderness, Limantour, 

Highway One, Palomarin and Inverness Ridge FMUs contain designated wilderness lands. 

Marine Reserves Subzone. Marine reserves were established at the Point Reyes Headlands, 

Limantour Estero (Estero de Limantour) and Duxbury Reef Reserve (adjacent to PRNS’s 

southern boundary) in 1972 by the California Department of Fish and Game under Title 14 of the 

California Code. The purpose of the reserves is to preserve them in a natural condition and to 

protect the aquatic organisms and wildlife found thereon for public observation and scientific 

study. Management of the Headlands Reserve prohibits recreational fishing and places 

restrictions on commercial fishing. Commercial and recreational fishing and collecting are 

prohibited in the Estero de Limantour Reserve. The NPS maintains a standing proposal to the 

State to grant Research Natural Area status to the Double Point and Bird Rock areas of Point 

Reyes. The FMP must provide adequate protections for the marine reserve subzone areas from 

direct and indirect effects of plan implementation. The Headlands FMU, Limantour Road FMU, 

Tomales Point FMU, and Estero FMU border these marine reserves. 

Biotic Sensitivity Subzone. This subzone includes natural resources in the park that are 

particularly sensitive to human use or are especially valuable from an ecological or scientific 

point of view. Most of the areas covered by this subzone are watercourses or bodies of water 

recognized for their importance in sustaining wildlife and vegetation. The GMP states that use 

and development in these areas will be either discouraged or mitigated sufficiently to avoid 

significant levels of deterioration. The FMP must provide sufficient safeguards during 

implementation to protect this resource subzone from degradation and provide enhancement 

wherever possible. Potential beneficial and adverse effects on riparian areas and water resources 

are addressed in this EIS under the headings of water quality and vegetation in the 

Environmental Consequences Chapter. The Estero, Highway One and Palomarin FMUs contain 

lands with this designation. 

Historic Resource Zones 

Preservation Zone (including the Point Reyes Lighthouses and Lifeboat Station). Spaces and 

objects in this category primarily are managed and used for facilitating public enjoyment, 

understanding, and appreciation of their historic values. Since the adoption of the 1980 GMP, 

many of the historic structures in the park have been adaptively re-used under the agricultural 

leases. Others house visitor activities and associations, park administrative offices or provide 

housing for park employees. The GMP indicates these historic resources be protected from 

damage and deterioration, and the FMP includes actions such as roadside mowing and 

maintenance of defensible space around them to provide protection should an unplanned ignition 

occur. 

Geology and Topography 

The character of the Point Reyes Peninsula has been shaped and remains defined by its 

association with the San Andreas Fault System. The San Andreas Fault Zone (SAFZ) forms the 

active tectonic boundary between the Pacific plate and the continental North American plate. 
82 

Clark and Brabb (1997) describe similarities between Eocene and Miocene depositional 

sequences of the Point Reyes and Monterey peninsulas suggesting displacement of the Point 

Reyes Peninsula along the San Gregorio Fault of as much as 150 km (94 mi) in the last 11 

million years. Recent research on the San Andreas Fault has allowed researchers to document 

the occurrence of 10 additional large-scale land movement events in the past 2,500 year, with a 

recurrence interval on the order of one major event every 250 years (Zhang et al., 2003). Due to 

different rock types, the geomorphology, hydrology, weather, soils, and plant communities east 

of the fault differ in many ways from that of the peninsula. 

Salinian granite underlies nearly the entire peninsula, and is exposed in the areas of Inverness 

Ridge, Tomales Point, and the Point Reyes Headlands (see Figure 13). The granite is 

unconformably overlain by the Monterey Shale in the southern part of the peninsula which is 

exposed along the coastline from Drakes Bay south to Bolinas (Konigsmark, 1998). Coastal 

wavecut benches and flooded valleys are the result of sea level fluctuations during the 

Pleistocene and Quaternary tectonic uplift (Scherer and Grove, 2003). The Point Reyes plain, 

extending from Inverness Ridge west to the headlands is underlain by siltstone and mudstone of 

the Purisima Formation (Clark & Brabb, 1997), which also occurs in the Santa Cruz Mountains. 

The headlands present the most unique exposed formation within the park, the Point Reyes 

Conglomerate, a sandstone conglomerate with rounded chert, volcanic, and granitic cobbles. It 

is best exposed along the Lighthouse steps and is most similar to a conglomerate that occurs on 

Point Lobos, 100 miles to the south (Evens, 1993). 

The Olema Valley, extending from Bolinas Lagoon to Tomales Bay is representative of the 

SAFZ. The Valley ranges in width from 1,500 to 7,000 feet. The Olema Valley includes a 

variety of fault-associated topographic features including linear ridges and drainage patterns, 

parallel stream systems, offset rows of trees and fences, and a series of sag ponds. The surface 

rupture caused by the 1906 earthquake extended from Bolinas Lagoon to Tomales Bay, with 

lateral displacement ranging from 14 to 20 feet in the Olema Valley (Gilbert, 1908). 

Bedrock east of the fault (generally east of Highway 1) is the Franciscan Complex that makes up 

much of California’s Coast Range. The Franciscan Complex is believed to be a fossil 

accretionary wedge of sediment that used to fill the trench of a subduction zone. It is mostly 

composed of greywacke, sandstone and shale with different grades of metamorphosis. Some 

parts of the Franciscan Complex are a mélange, including highly metamorphosed, low-grade 

mudstone, siltstone, and sandstone with occasional inclusions of limestone, chert, serpentinite, 

eclogite, and amphibolite conglomerate (Galloway, 1977). The Franciscan Complex is highly 

unstable and is known for slope instability, thin soils, and high runoff rates. 

The topography within the project area is controlled by Inverness and Bolinas Ridge and the 

dominant San Andreas Fault. Watersheds draining from Inverness Ridge are perennial while 

those draining from Bolinas Ridge are nearly always intermittent. Most of the watersheds within 

the Olema Valley have drastically altered and unusual drainage patterns associated with the 

combination of stream capture and alterations to the topography caused by the strike-slip 

movement of the San Andreas Fault. Near their headwaters, Olema Creek and Pine Gulch Creek 

run parallel, but in opposite directions for nearly two miles. Near the head of Tomales Bay, Bear 

Valley Creek drains at an acute angle from Inverness Ridge (likely stream capture) and makes an 
83 

abrupt turn to the north adjacent to the 1906 fault rupture, running parallel to Olema Creek until 

they discharge into the Lagunitas Creek estuary. 

Inverness Ridge forms the backbone of the Point Reyes Peninsula, reaching a height of 1,407 

feet at Mount Wittenberg. The ridge is characterized by relatively consistent upland elevation 

with overly steep headwater stream systems. The only interruption in the ridge between Bolinas 

and Tomales Point is the 400-foot pass at Divide Meadow. The soils of the Monterey Shale and 

Purisima Formation have high rates of infiltration, allowing Inverness Ridge to support most of 

the perennial streams within PRNS. South of Laguna Creek, Inverness Ridge merges with the 

Bolinas Mesa, a wave-cut bench into Monterey Shale. The terrace is intersected by a number of 

steep ravines formed by actively downcutting stream channels. Some of the most spectacular 

landmarks in PRNS, including Arch Rock and Alamere Falls are a result of this interaction 

between small streams and bedrock along the rocky coastline. 

Bolinas Ridge to the east rises approximately 800 feet in elevations. The soil type, lithology, and 

climate combine resulting in far drier conditions on the west facing slopes. The ridge is 

primarily grassland with the steep, narrow ravines dominated by oak, bay laurel, and Douglas fir. 

Inverness Ridge forms the backbone of the Point Reyes Peninsula, reaching a height of 1,407 

feet at Mount Wittenberg. The ridge is characterized by relatively consistent upland elevation 

with sharp precipices dropping down into the river valleys. The only interruption in the ridge, 

between Bolinas and Tomales Point is the 400-foot pass between Bear Valley and Coast Creek 

drainages. Most of the perennial streams within PRNS originate from the ridge. South of 

Laguna Creek, the ridge merges with the Bolinas Mesa, an uplifted, wave-cut Monterey Shale 

bench. This terrace is intersected by a number of steep ravines caused by drainages cut down to 

current sea level. Some of the most spectacular landmarks in PRNS, including Arch Rock and 

Alamere Falls, are on this terrace. 

Bolinas Ridge to the east rises to approximately 800 feet in elevation. Due to soil type and 

climate, conditions are far drier on these west-facing slopes. Ridges are primarily grasslands 

with the steep tributary valleys dominated by oak and bay laurel. 

Fire Regime 

The term “fire regime” refers to a simplified description of characteristics of the fires that 

typically occur at a given site. Present fire regimes often differ from historic fire regimes. 

Descriptions of fire regimes are general and broad because of the enormous variability of fire 

over time and space (Whalen, 1995). The factors that are often used to determine and describe 

fire regimes in an area include fire type, intensity, extent or size, frequency, and/or season 

(Whalen, 1995, Brown, 2000). 

 
84 

 

Figure 13. Point Reyes National Seashore Geologic Formations 
85 

It is likely that prior to Euro-American settlement of the project area in the mid-1800s, forest and 

woodland plant communities were subject to a mixed severity fire regime, which can arise in one 

of three ways (Brown, 2000): 

Many trees are killed by mostly surface fire but many survive, usually survivors include 

fire-resistant species of relatively large size. 

Severity within individual fires varies between understory burning and standreplacement, which creates a fine-grained pattern of young and older trees. This type of 

regime probably is due to fluctuations in weather during fires, diurnal changes in burning 

conditions, and variation in topography, fuels, and stand structure within burns. Highly 

dissected terrain is conducive to this fire regime. 

Fire severity varies over time with individual fires alternating between understory burns 

and stand-replacement. This regime has also been termed “variable” and has been 

applied to redwood forests. 

Prior to Euro-American settlement, shrub-dominated or grassland plant communities in the 

project area may have been influenced by a stand-replacing fire regime, as most fires likely 

killed or removed most of the aboveground vegetation. The variability in topography, fuels, and 

diurnal weather fluctuations, however, could have resulted in a mixed severity fire regime, as 

described above for forests and woodlands. 

The current fire regime for the Point Reyes area has changed dramatically since the mid-1800s as 

a result of Euro-American settlement patterns and practices. Effective fire suppression has 

resulted in large accumulations of fuels in many forest, woodland, and shrub-dominated plant 

communities. Thus, when fires do burn, they often are stand-replacing, as evidenced by many 

areas within the perimeter of the 1995 Vision Fire. 

Following the cessation of winter rains in mid-April, fuels dry rapidly and the light fuels of the 

annual grassland (2,000-7,000 lbs/acre) cure. During the summer months, live, dead and downed 

round wood material and duff in the understory of PRNS’s forest stands gradually lose moisture. 

Fire season at Point Reyes begins in early June. At this time, high-pressure air masses frequently 

stagnate over the Great Basin. Strong foehn winds, referred to as Mono winds in central 

California, may develop if there is a low-pressure trough off the coast. These winds bring warm, 

dry air to Point Reyes and cause rapid drying of fuels. These episodes usually last 1-2 days and 

fire danger can be extreme. In typical years, a persistent coastal fog bank is formed by July l, 

following the stabilization of the Pacific high over central California. From July through early 

September fog moves inland and back out to sea in a 3-4 day cycle in response to heating and 

cooling in California's Central Valley. Fine fuel moisture fluctuates in this cycle, while wood 

fuels and duff remain relatively wet. In mid-September the fog pattern changes and fuel 

moistures drop steadily. It is at this time that conditions contributing to Mono winds occur. The 

combination of prolonged drought, low relative humidity and a peak in fuel production often 

causes fire danger to be high through September and October. In addition, almost one fifth of the 

area's annual lightning storms occur during this period (Martin and Sugnet, 1984). 
86 

The late fall fire season is one of the primary constraints limiting the number of days available in 

the project area during which prescribed burns can be conducted each year. Other constraining 

factors are air quality and disruption of wildlife breeding periods. 

In summary, the fire season at Point Reyes differs somewhat from most areas in the western 

United States. Bimodal peaks of fire danger occur in late spring and late summer/early fall. In 

most years, persistent fog keeps fire danger moderate in July and August when danger is highest 

in most of the western United States. The period from September 1 through October 31 can be 

considered the most critical time of fire danger for PRNS. 

Fire History 

Research into Historic Fire Cycles 

There is evidence from dendrochronological (tree ring) records and from sediment core analyses 

that periodic fire has occurred in the project area for the past several thousand years, and 

ecosystems in the area have developed under the influence of these fires. Several native plant 

species in the project area (e.g., Bishop pine, Marin manzanita) reproduce abundantly following 

fire. For the past 100 years, however, fire frequency has decreased, and most fires have been 

suppressed. The lack of periodic fire during this period has resulted in changes in vegetation 

structure and species composition. For example, it is generally assumed that forest stand density 

in many areas has increased, and shrub and grassland habitats in many areas are being reduced in 

size due to encroachment by conifers. Populations of the Marin manzanita are becoming 

increasingly rare as a result of habitat loss due to shading from increasing forest stand density. 

It has been well documented that fires in the Point Reyes area and within California coastal 

ranges were frequently set by Native Americans (Slaymaker, 1982; Keely, 2002) and European 

settlers. Fire history studies conducted in and around the peninsula show the northern coastal 

prairie was very important to the Coastal Miwok as a source of food. Seeds were harvested from 

the coastal prairie and other grasslands in late summer. Individual seed fields were the 

possession of specific families and were probably often burned after harvest to enhance growth 

the next year. Documentation of Coast Miwok culture indicates burning of grasslands for 

several purposes, but information on the extent and timing is minimal. Some sources indicate 

that fields were burned frequently, as often as once a year (Lewis, 1973; Slaymaker, 1982). Precontact burning along the coast may have focused on grasslands, while later burning during the 

Spanish and Anglo periods focused on shrublands to increase pasture acreage. The latter 

probably did not burn grasslands because of the need for winter livestock forage, leading to a 

very different fire regime (Greenlee and Langenheim, 1990). 

Conditions conducive to lightning-caused wildfire do occur in Point Reyes, but they are rare 

(Martin and Sugnet, 1984). The Bay Area averages about 3 lightning days a year. An average of 

two lightning storms occur annually in the vicinity of Inverness with 18 percent of these storms 

occurring in September (Martin and Sugnet, 1984). Between 1970 and 1989, 13 lightning-ignited 

fires occurred in the following areas: Inverness Ridge, Mt. Tamalpais, and Stinson Beach. On 

September 27, 2001 a lightning fire occurred on Bolinas Ridge above Stinson Beach. During 

this same September storm, an observer saw about 60 lightning strikes from the Mount Barnabee 
87 

Lookout near Samuel P. Taylor State Park, adjacent to the National Seashore. In addition, 

Pacific Gas and Electric staff counted 4,600 lightning strikes in the Bay Area during this storm 

(Freed, 2001). 

Regardless of the source of ignition, however, ecosystems of Point Reyes are not burning today 

with nearly the frequency they did in the past. This change in fire frequency can result in shifts 

from understory to overstory dominance, increases in fuel loads and changes in forest structure, 

including increases in ladder fuels, which may lead to increased incidence of overstory, standreplacing fires (Covington et al., 1994). 

The best records of Point Reyes fire history reside in fire-scarred tree rings in redwood, and to a 

lesser extent, in Douglas-fir trees. Bishop pines are relatively short-lived trees (100 to 120 

years), and generally occur in single-aged stands which arise after a stand-replacing fires. While 

the age of a Bishop pine stand can give solid evidence of a single large fire, it yields little insight 

into longer-term fire history. Shrubs respond to burning by either sprouting back from their 

stumps, or by regenerating via seeds in the soil so little record of the physical evidence of fire is 

retained. The same is true of grassland species. 

Due both to past logging and the relatively thin bark and low resistance to burning in Douglasfir, Douglas-fir forests are a limited source of data on fire history. However, at least one research 

team (Brown et al.,1999) was able to extract data from fire scars on Douglas-fir and redwood 

trees at three locations in Point Reyes. The researchers found that fire scars did not extend much 

beyond the late 1700s. The oldest Douglas-fir tree found in the park dated to 1680, but this 

individual had no fire scars. Within the approximately two hundred-year period of fire scars 

(roughly 1800 to the present), researchers calculated a mean fire interval ranging from 7.0 to 

13.0 years for the Douglas-fir forests. They were unable to cross-date any pre-settlement 

redwood trees, although some post-settlement trees did contain fire scars that successfully crossdated with the Douglas-firs. Researchers speculated these trees were likely basal sprouts that 

established after the original redwood stand was logged, or grew in response to fire. Using fire 

scar information for burns from the early 1800s to the early 1900s, the researchers calculated a 

mean fire return interval in the redwood groves of 7.7 to 8.5 years. 

Adjacent to Point Reyes, Finney (1990) found mean fire intervals between 1850 and 1900 that 

ranged from 6 to 33 years, with a mean of 14 years in coast redwood stands on Bolinas Ridge. 

He was able to document high fire frequency in the grove studied dating from the middle 1400s. 

Jacobs et al. (1985) calculated mean fire intervals of 22 to 27 years from stumps containing fire 

scars on ridges surrounding Muir Woods National Monument. 

Work at Humboldt Redwoods State Park revealed a larger range in fire intervals, although this 

area has higher precipitation levels than Point Reyes and so is not directly comparable. Stuart 

(1987) calculated mean pre-settlement fire intervals in Humboldt from fire scars and redwood 

sprouts varied between 11 and 44 years. In the same area, Fritz (1932) estimated that at least 45 

severe fires had burned during the previous 1,100 years, with a mean fire interval of 25 years. At 

Salt Point State Park, Finney and Martin (1989) found fire return intervals of 20.6 to 29.0 years. 

The authors state that all of these studies probably overestimate the actual mean fire interval. 
88 

Sediment taken from the bottoms of the lakes at the south end of Point Reyes Peninsula provides 

further evidence of forest fires over the past several centuries (Russell, 1983). In an on-going 

charcoal stratigraphy study by Anderson (2001), sediment cores from Glenmire and Wildcat 

lakes are being analyzed with radiocarbon dating. The Glenmire sample within the Douglas-fir 

forest; the Wildcat Lake area is dominated by coastal scrub. Sediments from both lakes 

indicated a near absence of fire during the past 100 years. Ongoing research is examining 

additional sediment cores from wetland areas in Point Reyes through radiocarbon dating and 

pollen analysis with the goal of constructing a more complete fire history. 

Recent Fire History 

The Marin County Fire Department has historically maintained a list of the larger fires in the 

county in the 20th century. Several of these fires have occurred in the project area. A fire in 

October 1917 burned 2,000 acres on the ridge west of Inverness. The largest fire, in September 

1923, burned 40,000 acres from Lucas Valley to Bolinas including 35 homes in Woodacre. 

More recently, the Mount Vision Fire burned more than 12,000 acres in 1995. It was started by 

an unattended campfire on October 3 at approximately 1:00 pm within Tomales Bay State Park. 

Driven by 40- to 50-mile per hour winds in steep terrain and heavy forest fuels, the fire rapidly 

burned 700 acres and spread to PRNS and the residential community of Paradise Ranch Estates 

where 48 structures were destroyed. By October 6, up to 1,200 firefighters had participated in 

suppressing the fire. The next night, October 7, 1995, the fire was declared contained after 

burning a total of 12,354 acres (11,598 acres NPS lands, 386 acres State Park lands, 370 acres of 

private lands). The fire was declared controlled 9 days later. 

Since 1997 an average of three wildland fires have occurred each year in the project area. In all 

cases, the burned area was less than ten acres and most were kept to less than one acre. Most of 

the fires occurred in the Olema Valley, and all but one was human-caused. 

AFFECTED ENVIRONMENT 

Soils 

The Marin County Soils Survey provides generalized baseline information on soils within the 

project area (SCS, 1985). Soils are classified into broad associations comprised of one or two 

major soil types, from which the name of the association is taken, and several minor soil types. 

As the FMUs share geologic substrate, they also share many of the same soil types. Generally, 

FMUs involve 3 general landscape types – alluvial fans and tidal flats, coastal dunes and 

uplands. However, the presence of the San Andreas fault zone and the opposing bedrock 

formations present on each side of the fault leads to a more complex mix of soil types. 

When considering potential impacts to soils from fire and fire management actions, the important 

indices include soil permeability, topsoil infiltration, degree of slope, soil texture, compositional 

stability, plant cover and rainfall intensity. These factors can contribute to an understanding of 

the erosion potential of disturbed soils and are used in the Natural Resources Conservation 

Service Erosion Hazard Rating (EHR). The EHR, the general text rating given in the 1979 Soils 

Survey and first hand observations of NPS staff are combined to describe potential erosion 
89 

hazard of Point Reyes soil types. Another important factor to consider is the potential for a soil 

type to develop hydrophobic (water-repellent) properties due to intense fires. Figure 14 shows 

soil types in the project area; they are described in more detail below. 

Tomales Point FMU. The principal soil type in the Tomales Point FMU, Kehoe Variant coarse 

sandy loam, is derived from the quartz diorite of the underlying granite bedrock. Soil formed 

from granitic bedrock or coarse-grained bedrock, such as the Kehoe Variant and Sheridan 

Variant (see discussion below - Inverness Ridge FMU) soils appear prone to developing surface 

or subsurface hydrophobic properties during intense fires. If the vegetation cover of Kehoe soils 

is disturbed, the potential for erosion is slight in areas of gentle slopes and high in the drainages 

and steeper slopes above Tomales Bay. Erosion is currently controlled by overlying vegetation, 

primarily grasses and coastal scrub. 

Headlands FMU has a complex soils map. Rock outcrops along the western and southern coast 

comprise nearly 1/3 of the land surface of the FMU. Found primarily west of Sir Francis Drake 

Highway, Sirdrak sand soils formed by wind-born (eolian) sands make up roughly 25% of the 

FMU. Kehoe Variant soils (described above for Tomales Point FMU) and Tocaloma McMullin 

complex soils make up much of the FMU east of Sir Francis Drake Highway. These two soil 

types have a high erosion potential when surface soils are disturbed. As previously noted, Kehoe 

Variant soils have potential to form a surface or subsurface hydrophobic layer under an intense 

fire. 

Estero FMU. Approximately 72% of the Estero FMU soils are Tomales fine sandy loam, 

derived from underlying sandstone. Tomales loam tends to seasonal saturation due to very slow 

permeability. Slow permeability leads to more rapid runoff and a high potential for erosion on 

slopes than 15%. Principal drainages flowing to the Drakes Estero are Rodeo clay loam, a deep, 

alluvial soil formed in narrow valleys. 

Inverness Ridge FMU. The northern half of the Inverness Ridge FMU is comprised primarily of 

Sheridan Variant soils, a coarse sandy loam derived from underlying quartz diorite bedrock. The 

soil type supports the bishop pine forests, grasslands and scrub. The erosion potential of these 

soils is high where slopes are greater than 50%. Sheridan Variant, supporting tanoak, Bishop 

pine and coastal scrub, often have a dense duff layer on the soil surface and a high percent of 

organic matter within the soil. Loss of the duff layer during a fire can exacerbate erosion 

potential of this soil. 

During the 1995 Vision Fire, Sheridan Variant soils were subject to intense heating and most 

organic material was burned away. Post-fire monitoring noted a crust-like hydrophobic layer 

had formed in patchy areas on the surface soil. This layer was water repellent for the first winter 

season (1995-1996) but was largely broken up by the second winter season, primarily by the 

force of vegetation pushing through the surface layer. Since this area was subject to the most 

intense burn during the Vision Fire, it was surprising how much of the seedbed survived in the 

surface soils. The area is now densely vegetated with dense stands of bishop pine, grassland and 

coastal scrub. 
90 

Figure 14. Point Reyes National Seashore Soil Map Unites 
91 

Compared to other Point Reyes soils, Sheridan Variant soils have high percent of organic matter 

in the upper surface soils and could be prone to nutrient volatilization (vaporization) or changes 

in soil chemistry that reduce nutrient capacity during an intense fire. 

The dominant soil type in the southern half of the FMU is the Inverness loam soils, another 

granite derived soil, which predominates throughout the central portion of the Inverness Ridge. 

Inverness loam soils were the major soil series in the area burned in the 1995 Vision Fire. Like 

the Sheridan Variant soils, they are of particular concern for potential high rates of surface runoff 

and very high potential for erosion where the vegetation cover is removed or burned away 

(BAER Team, 1996). 

Limantour FMU. The northern section and eastern sections of this FMU, extending from 

Inverness Ridge east to Bear Valley Road, share the Sheridan Variant Inverness loam soils that 

support the Bishop pine forest. The southern portion of the FMU has Palomarin-Wittenberg 

complex soils, supporting Douglas-fir forest, that predominate on the southern half of the 

Inverness Ridge. Both soil types have a very high potential for erosion on steeper slopes and 

have an organic content in the upper soil horizon making the soil susceptible to nutrient loss if 

exposed to intense heat from fire. Tomales fine sandy loam predominates on the uplands 

between the principal drainages and soils within the Muddy Hollow and Laguna Creek drainages 

are alluvial Rodeo Clay loam. 

The Vision Fire burned all of this FMU in the 1995. Post-fire monitoring noted pervasive 

hydrophobicity in soils in the upper drainage of Muddy Hollow extending from 2 to 8 inches in 

depth (Collins and Ketcham 2001). Hydrophobic properties broke down and nearly disappeared 

by the end of a second winter’s rains. Post-fire monitoring recorded accelerated upstream 

channel cutting and hillside rilling in the upper drainages of the Muddy Hollow Creek system 

during the first year after the fire. In the first two years following the fire, soils in the middle 

drainage of the Creek eroded primarily from exposed areas such as old roadbeds and channel 

banks. Eroded sediments were deposited in a wide channeled alluvial fan at the base of the 

drainage especially during the second rainy season after the fire. Soil erosion was largely 

controlled by the third year post-fire as eroded areas in the watershed revegetated (B. Ketcham, 

pers. com.). 

Wilderness North FMU is primarily Palomarin-Wittenberg complex soils supporting Douglas-fir 

forests on southern portion of the Inverness Ridge. The soils are derived from the underlying 

sandstone and shale and are deep and well drained with a 2 to 4 inch covering of Douglas-fir 

needles. The erosion hazard is very high on slopes greater than 50%. As noted previously, the 

high percent of organic content in the upper soil layer points to a potential for changes in soil 

chemistry in the event of a high intensity fire. The northern portion of the FMU burned in 1995. 

Wilderness South FMU is also dominated by the Palomarin-Wittenberg complex soils though 

slopes are generally less steep than in the Wilderness North FMU. Like the Limantour FMU to 

the north, the west-facing slopes are thin, erodible Pablo Bayview soils. Less than 10% of the 

FMU on the steepest eastern slopes of Inverness Ridge is Dipsea Barnabe gravelly loam soil 

supporting Douglas-fir and redwoods. These soils are considered highly erosion-prone due to 
92 

the high gravel content (SCS, 1979). The Dipsea soils have the highest average percent of 

organic matter in the upper soil layer of all the Point Reyes soil types. 

Highway One FMU. The Highway One FMU runs northwest to southeast along Highway 1 

overlying the San Andreas fault zone and the floodplain of Olema Creek. It extends west to the 

lower slopes of Inverness Ridge and east to the top of Bolinas Ridge. Bedrock type differs 

distinctly on each side of the San Andreas fault leading to distinct soil types on each ridge. The 

slopes of Inverness Ridge are primarily highly erodible Tomales or Tomales-Steinbeck fine 

sandy loams derived from the underlying sandstone. The Olema Creek floodplain is comprised 

of alluvial soils, mainly clay loams and silt loams (Blucher-Cole complex and Rodeo clay loam) 

that have high water capacity tending to become saturated with very low rates of erosion. Soils 

on the west-facing slope of Bolinas Ridge are primarily highly erosive Centissima Barnabe soils 

supporting Douglas-fir and Redwood forest and grasslands and Cronkhite-Barnabe soils 

supporting primarily grasslands. 

Bolinas Ridge FMU. The northern half of the Bolinas Ridge FMU shares the characteristics of 

the eastern portion of the Highway One FMU. Centissima Barnabe and Dipsea-Barnabe soils, 

both highly erosive, are on the ridgetops and steep side slopes of the Ridge and support Douglasfir and Redwood forests. More gently sloped areas of Cronkhite-Barnabe soils exist on the 

ridgetop. The southern half of the FMU has shallow Maymen-Maymen Variant gravelly loam 

soils on the long uplands side slopes which have a high hazard of erosion and siltation. 

Palomarin FMU. Similar to the Wilderness South FMU to the north, the spine of the Inverness 

Ridge in this FMU has Palomarin-Wittenberg soils and the rounded, west-facing slopes is 

composed of Pablo Bayview soils. Much of the southern half of the FMU consists of moderately 

sloped uplands. Side slopes in this region are covered with thick but erodible Cronkhite Barnabe 

soils supporting grasslands, and steeply sloped areas of Palomarin Wittenberg soils supporting 

Douglas-fir forest.

Table 7A. Erosion Hazard Potential Per FMU 

Low erosion 

potential 

Moderate erosion 

potential 

High erosion 

potential Very high erosion 

potential FMU 

Total 

Acres in 

FMU Acres per 

FMU 

% of each 

FMU 

Acres per 

FMU 

% of each 

FMU 

Acres per 

FMU 

% of each 

FMU 

Acres per 

FMU 

% of each 

FMU 

Tomales Point 2,783 717 26% 245 9% 1,821 65% -- -- 

Headlands 881 290 33% 347 39% 215 24% -- -- 

Estero 1,639 200 12% 528 32% 911 56% -- -- 

Inverness 1,250 225 18% 388 31% 466 37% 171 14% 

Limantour 4,144 828 20% 543 13% 1924 46% 824 20% 

Wilderness 

North 

1,591 27 2% 224 14% 313 20% 1027 64% 

Wilderness 

South 

2,298 179 8% 654 28% 777 34% 683 30% 

Highway 1 2,868 285 10% 246 9% 1798 63% 539 19% 

Bolinas 2,382 9 >1% 764 32% 1,054 44% 555 23% 

Palomarin 2,022 161 8% 420 21% 1082 53% 324 16% 

ALL FMUs 21,858 2,921 13% 4,359 20% 10,361 47% 4,123 19% 
93 

Air Quality 

PRNS is classified as a mandatory Class I area under the Federal Clean Air Act and 

Amendments. Title I of the Clean Air Act Amendments of 1990, Part C, “Prevention of 

Significant Deterioration of Air Quality,” Section 162, defines Class I areas as including all 

national parks greater than 6,000 acres. The areas must have been in existence on the date of 

enactment of the Clean Air Act Amendments in 1977. 

The NPS, as the Federal Land Manager (FLM) of PRNS, is responsible for the protection of the 

park from ambient air quality impacts, including air quality-related values (AQRVs) such as 

visibility and the protection of plants, animals, soils, water quality, cultural and historic 

structures from the effects of contaminants. The northern lands of the GGNRA, comprising 

Bolinas Ridge directly east of Highway One is administered by PRNS and included in the scope 

of this FMP, are a federal Class II area. 

PRNS is located in the San Francisco Air Basin and is under the jurisdiction of the Bay Area Air 

Quality Management District (BAAQMD). The BAAQMD is the agency that is directly 

responsible for the protection of air quality and implementation of local and State 

Implementation Plan (SIP) measures within the Bay Area region. The BAAQMD regulates air 

quality under the auspices of the California Air Resources Board (CARB) and the U.S. 

Environmental Protection Agency (EPA), Region 9. Both CARB and the EPA have general 

oversight responsibilities for the purpose of making sure local rules and regulations and 

stationary source permits issued are consistent towards attainment and maintenance of the 

California and National Ambient Air Quality Standards (AAQS). The AAQS are discussed later 

in this section. Mobile sources are not regulated at the local level except in certain instances 

where they are strongly associated with a stationary source project, such as a power plant. 

Otherwise, under the mandated authority of the EPA, mobile source emissions are regulated by 

CARB. 

In the 2000 Census, Marin County had a total population of 247,289 (U.S. Census Bureau, 

2000). Most of the population of Marin County lives to the south and east of the project area; 

other populated areas (including Petaluma, in Sonoma County) are located in a more easterly 

direction inland from Point Reyes. In the vicinity of PRNS, a scattered population lives in the 

small towns of Inverness, Inverness Park, Olema, and Bolinas, Point Reyes Station and along 

Highway 1. Private development on and/or west of Highway 1, especially near Bolinas and 

western Inverness, occurs in or near high fuel densities in and beyond the project area 

representing public/private land interfaces across which the propagation of fire and/or smoke can 

be a serious threat. 

Protecting public and firefighter health and safety, and protecting private and public property are 

primary goals of the FMP. In each of the alternatives, strategies to offer this protection include 

the use of prescribed burns and mechanical treatment, including firebreaks to limit the potential 

expansion of a future wildland fire. In addition to offering protection of property, this strategy 

would result in several smaller episodes of smoke, rather than a severe fire with severe smoke 

and pollutant emissions. 
94 

In 1993, the EPA adopted conformity regulations implementing Section 176 of the Clean Air 

Act, as amended. Section 176 requires that federal actions conform to state implementation 

plans for achieving and maintaining the national standards. Federal actions must not: 

• Cause or contribute to new violations of any standard, 

• Increase the frequency or severity of any existing violation, 

• Interfere with timely attainment or maintenance of any standard, 

• Delay emission reduction milestones, or 

• Contradict State Implementation Plan requirements. 

 

The conformity rule applies only in federal non-attainment areas. PRNS has historically ensured 

conformity by ensuring that all prescribed burning is planned and performed within the auspices 

of the BAAQMD Smoke Management Program. 

Regional Climate 

PRNS receives an average of 38.2 inches of rain annually. This amount is higher than much of 

the San Francisco Bay area due to the somewhat more elevated terrain along the coast. Most 

annual rainfall in Marin County occurs from November through March. The following general 

climate description is from “Climate, Physiography, and Air Pollution Potential – Bay Area and 

its Subregions (BAAQMD, 2003a)”: 

“Areas along the West Coast of Marin County are usually subject to cool marine air. In 

the summer months, the marine air is cooled as it passes over the offshore upwelling 

region, and forms a fog layer along the coast. In the winter, proximity to the ocean keeps 

the coastal regions relatively warm. Temperatures do not vary much over the year at 

these coastal areas: high 50s in the winter and low 60s in the summer. The warmest 

months are September and October, which are in the mid to high 60s.” 

“. . .Wind speeds are highest along the west coast of Marin, about 8 to 10 mph. Although 

most of the terrain throughout central Marin County is not high enough to act as a barrier 

to the marine airflow, the complex terrain creates sufficient friction to slow the airflow. 

Downwind, at Hamilton Air Force Base in eastern Marin County, the annual average 

wind speeds are only 5 mph. The prevailing wind directions throughout Marin County 

show less variation, and are generally from the NW.” 

Figure 15 illustrates predominant wind patterns occurring in California (Bell, 1958). The 

predominant regional surface winds during winter flow from the north-northeast. During spring 

and summer, stronger north-northwest winds dominate. These northwesterly winds are primarily 

caused and/or strengthened by the combination of high pressure offshore and the warmer air 

inland. During the fall transition, when warm easterly winds break through to the coast while 

inland conditions remain hot and dry, the coastal region faces its most significant fire threat. 
95 

Figure 15. Predominant Wind Patterns Occurring in California 
96 

Project Area 

Long-term average temperature and precipitation data have been collected at Bear Valley at the 

eastern part of the Point Reyes National Seashore (NPS, 2003). The Bear Valley monitoring 

station is the closest surface meteorological station to the project site. Surface climate data are 

presented in Table 8. Average temperatures (°F) during the summer vary from the high 40s to 

the low-to-middle 70s. Summer precipitation is low, averaging less than 0.2 inches per month, 

due to the strong stationary high-pressure system located off the coast and preventing weather 

systems from moving through the area. During the winter, average temperatures (°F) vary from 

the mid-to-upper 30s to the upper 50s-low 60s. About 84% of the precipitation in the area occur 

during November through March, generally in association with storm systems that move through 

the region. 

Table 8. Temperature and Precipitation Data for Bear Valley- Point Reyes National Seashore, 

California 

 

Average Daily Temperature (°F)a Average Precipitation 

Month Minimum Maximum Daily (inches) 

January 36.5 58.6 47.7 8.65 

February 39.5 62.1 50.8 6.69 

March 39.7 63.0 51.4 5.64 

April 39.5 65.4 52.4 2.42 

May 44.0 68.0 56.7 1.07 

June 46.6 71.1 58.9 0.20 

July 48.6 73.9 61.2 0.09 

August 49.4 74.4 61.9 0.14 

September 48.0 75.7 61.9 0.34 

October 44.1 72.3 58.2 2.10 

November 39.7 64.9 53.1 5.68 

December 35.9 59.0 47.5 6.27 

Annual Average 42.0 66.2 54.2 39.57 (total) 

Source: Pt. Reyes National Seashore, 2003. 

a

Average temperature and precipitation data for 1964-1989. 

Atmospheric stability and mixing heights are important parameters in determining pollutant 

dispersion. Atmospheric stability is a parameter that reflects the amount of atmospheric 

turbulence and mixing. In general, the less stable an atmosphere, the greater the turbulence, 

resulting in more mixing and better dispersion. Good ventilation results from deep vertical 

mixing and at least moderate wind speeds within the mixing layer. 

The frequent occurrence of temperature inversions over the project area and its surroundings 

limits the air mixing height and, consequently, could concentrate air pollution levels near the 

ground. Mixing heights generally increase as the air temperatures increase, so that more dilution 

occurs during hot weather or the heat of the day. Enhanced vertical mixing typically 

accompanies the warm easterly fall winds that lead to the most significant fire threats in the 

project area. Pollutants are comparatively more concentrated near the ground during colder 

weather or after sunset. The marine dominated cool spring and summer conditions feature 

limited vertical mixing, but the cool moist conditions are not conducive to fire generation or 
97 

propagation. The air pollution potential in the region is moderated by the strong westerly winds 

most of the year. 

The climate of the project area, along with much of the West Coast of the country, is controlled 

by a semi-permanent high-pressure system centered over the northeastern Pacific Ocean. The 

copious late fall through spring precipitation provides significant moisture. In the summer, the 

relatively northern location of this strong high-pressure system results in clear skies further 

inland and coastal fog. Very little precipitation occurs during the summer months because storm 

systems are blocked by the high-pressure system. Fog, humidity, and cool temperatures, though, 

help vegetation in the project area dry more slowly. Beginning in the fall, high pressure forming 

over the warmer inland areas breaks the summer pattern, introducing warm, dry winds from the 

northeast and east. These conditions lower vegetation moisture levels and significantly increase 

fire threat. Through the winter, the high-pressure system weakens and moves south, allowing 

storm systems to move through the area, replenishing the vegetation moisture levels and 

restarting the annual cycle. 

Regional Air Quality 

The project area lies within the Bay Area Airshed managed by the BAAQMD. Within 

California, compliance with federal and state AAQSs is determined by airshed. The BAAQMD 

encompasses urban, rural, coastal and inland settings. As would be expected, areas with high 

population density also tend to have higher ambient air quality impacts from stationary and 

mobile sources. 

California AAQS standards are values that are generally not to be exceeded. Federal standards 

are not to be exceeded more than once per year. The attainment status of the BAAQMD with 

regard to the federal and state AAQSs is shown in Table 9. 

Table 9. Ambient Air Quality Standards & Bay Area Attainment Status 

California Standards National Standards 

Pollutant Averaging Time Conc. Attainment 

Status Conc. Attainment Status 

Ozone 8 Hour 0.08 ppm U

1 Hour 0.09 ppm 

(180 μg/m3) 

N 0.08 ppm 

(235μg/m3) 

N

8 Hour 

9.0 ppm 

(10 mg/m3) A 

9 ppm 

(10 mg/m3) 

Carbon Monoxide A

1 Hour 

20 ppm 

(23 mg/m3) A 

35 ppm 

(40 mg/m3) 

A 

Annual 

Average 

 0.053 ppm 

(100 μg/m3) 

Nitrogen Dioxide A 

1 Hour 

0.25 ppm 

(470 μg/m3) 

A 

Annual 

Average 

 80 μg/m3 

(0.03 ppm) 

A 

24 Hour 

0.04 ppm 

(105 μg/m3) 

A 365 μg/m3 

(0.14 ppm) 

A 

Sulfur Dioxide 

1 Hour 

0.25 ppm 

(655 μg/m3) 

A 
98 

California Standards National Standards 

Pollutant Averaging Time Conc. Attainment 

Status Conc. Attainment Status 

Annual Arithmetic 

Mean 

 50 μg/m3 A 

Annual Geometric 

Mean 

30 μg/m3 N 

Particulate Matter 

(PM10) 

24 Hour 50 μg/m3 N 150 μg/m3 U 

Annual Arithmetic 

Mean 

Particulate Matter - 15 μg/m3 U 

Fine (PM2.5) 

24 Hour 65 μg/m3 U 

Sulfates 24 Hour 25 μg/m3 A 

Lead Calendar Quarter 1.5 μg/m3 A 

30 Day Average 1.5 μg/m3 A 

Hydrogen Sulfide 1 Hour 0.03 ppm 

(42 μg/m3) U 

 

Vinyl Chloride 

(chloroethene) 

24 Hour 0.010 ppm 

(26 μg/m3) 

No 

information 

available 

 

Visibility Reducing 

particles 

8 Hour (1000 to 

1800 PST) (See note 7) U 

 

NOTES 

A=Attainment N=Nonattainment U=Unclassified 

ppm=parts per million mg/m3=milligrams per cubic meter μg/m3=micrograms per cubic meter

Western Marin County Air Quality 

BAAQMD, describing air pollution trends in Marin County in 2000, does not address western 

Marin but focuses on the principal traffic corridors. 

“Air pollution potential is highest on the eastern side of Marin County. This is where the semisheltered valleys and largest population centers are located. Currently, most of the development 

has been along the bay, particularly in southern Marin. In the south, where distances to the ocean 

are short, the influence of the marine air keeps the pollution levels low. As development moves 

further north where the valleys are more sheltered from the sea breeze, it would encounter 

greater pollution potential (BAAQMD, 2003a).” 

The only air pollution currently measured at Point Reyes is PM2.5, small particulate aerosols that 

affect acid deposition and regional haze. Since no other ambient air pollutant is measured 

locally, air quality data were obtained from other BAAQMD monitoring stations within the 

Marin County Air Basin. The closest ambient air monitoring station to the project area is in San 

Rafael. However, as San Rafael is heavily urbanized, the data from that site would not be 

representative of the project area. Instead, data from the city of Santa Rosa (approximately 25 

miles to the northwest) is used to represent background concentrations of particulate matter of 10 

microns or less diameter (PM10), carbon monoxide (CO), ozone (O3), and nitrogen oxides (NOx) 

for the project area. Data from the Vallejo station (approximately 30 miles to the east) is used 

for background sulfur dioxide (SO2) (BAAQMD, 2003b). It is anticipated that actual ambient 

pollutant concentrations at the PRNS are lower than the background concentrations at Santa 

Rosa and Vallejo because the project area and surroundings feature less human and commercial 

activity and more steady onshore winds. However, the Santa Rosa and Vallejo monitoring 

station concentrations are used as conservative estimates. 
99 

In summary, the maximum 3-year average from the three most recent years (during 1999-2001) 

of 74 μg/m3

 in Santa Rosa complies with the federal standard for ambient particulates smaller 

than 10 microns of 150 μg/m3, but does not meet the stricter California standard of 50 μg/m3. It 

is well below both the maximum one-hour and eight-hour average federal and state standards for 

carbon monoxide, and the state and federal one-hour (state) and annual average (federal) 

standards for nitrogen dioxide. Vallejo is also well below the federal and California maximum 

24-hour and annual average standards for sulfur dioxide. Results for ozone are presented in 

Table 10 below. 

Table 10. Ambient Ozone Standards and Levels at Santa Rosa: 1999-2001 

 Federal Ambient 

Air Quality 

Standard 

California 

Ambient Air 

Quality Standard 

Maximum 

3-Year Average 

1999-2001 

Compliant with 

Ambient Air 

Quality Stds 

Maximum 1-Hour Average 0.12 ppm 

(235 μg/m3

) 

0.09 ppm 

(180 μg/m3) 

0.10 ppm - - - 

Number of Days Exceeding California 

Standard 

(0.09 ppm; 1-hour avg.) 

- - - - - - 1 Federal: Yes 

California: No 

Number of Days Exceeding Federal 

Standard 

(0.12 ppm; 1-hour avg.) 

- - - - - - 0 - - - 

Maximum 8-Hour Average 0.08 ppm 

(157 μg/m3

) 

- - - 0.08 ppm Yes 

Number of Days Exceeding Federal 

Standard Concentration 

- - - - - - 0 - - - 

Note: The maximum ambient air quality average concentrations occurred in 1999. 

Santa Rosa has exceeded the state’s maximum 24-hour average of 50 μg/m3 twice over the three 

year period measured, and the California one-hour ozone standard once. The PM10 data in Table 

10 reflects two exceedances of the California 24-hour AAQS. The area is in compliance with all 

other ambient air quality standards. 

The annual ambient air quality standard for particulate matter in California is about to become 

more stringent, upon approval by the Office of Administrative Law. (Refer to Table 9, 

footnotes.) The affect this may have on future compliance status of the region remains to be 

seen. Further, the federal and California standards for particulate matter of 2.5 μg/m3

 or less 

would be enforced pending sufficient baseline monitoring data collection, as determined by the 

U.S. Environmental Protection Agency. Currently, the PM2.5 standard is not enforced. Project 

activities are expected to be minimally affected since all prescribed burning would continue to 

occur under the auspices of the BAAQMD Smoke Management Program, which would be 

planned and managed to ensure conformity with all applicable rules and regulations. 

Project Area Air Quality 

The federal and state PM2.5 ambient air quality standards shown in Table 9 are proposed, but not 

yet in place. When fully implemented, the federal 24-hour standard will be attained when 98 

percent of the daily concentrations, averaged over 3 years, are equal to or less than the standard. 
100 

The NPS has been collecting PM2.5 data at the PRNS for several years. The most recent available 

years of data (1999 through 2001) indicate a daily average concentration of 8.330 μg/m3 or less 

averaged over these three years of data, well below the state and federal AAQSs of 12 and 15 

μg/m3 respectively. PRNS data available to date indicates 24-hour averages well below the 

proposed federal PM2.5 AAQS of 65 μg/m3. 

Water Resources 

The water resources within the project area include a significant number of perennial and 

intermittent streams, human-made impoundments, wetlands, natural lakes and sag ponds. The 

water resources support a variety of threatened and endangered species including coho salmon, 

steelhead trout, California freshwater shrimp, and California red-legged frog. Beginning in 

2000, the NPS began surface water quality monitoring at 23 stream locations and three 

recreational ponds within 12 watersheds. Implemented in conjunction with fisheries monitoring 

efforts, the water quality program is focused on identifying water quality impacts to the aquatic 

ecosystems on NPS managed lands. Results indicated distinct differences in monitored water 

quality parameters between watersheds that supported dairying, ranching or wilderness. Of the 

water quality parameters measured, two in particular – Total Suspended Solids (TSS) and 

nitrogen - could be exacerbated by fire management activities, so data that has been gathered on 

the water quality of creeks in the project area will be important when considering potential 

affect. 

Ash generated by fires is rich in nitrogen, a nutrient essential to biotic reproduction. Excess 

nitrogen in a water body can increase production of algae and aquatic plants. Decay of this 

excessive biomass can deplete a water body of oxygen and lead to fish kills. Ash is rich in 

nitrogen and could contribute to higher nutrients levels in stormwater runoff following burning. 

Following one year of water quality sampling, it was clear that at most of the 23 sites, current 

nitrogen levels, measured as nitrate and nitrite, were below detectable limits (>0.2 mg/l) 

(Ketcham, 2001). The exception was in one watershed supporting dairying operations. 

The activities in the FMP could also result in increases in erosion. Localized compaction, 

removal of vegetation and burning all cause changes in the proportion of water infiltrating into 

soil to that which is surface runoff. Increases in rates and velocity of runoff can increase erosion, 

which in turn can lead to elevated levels of TSS flowing to wetlands, ponds, and creeks in the 

project area. TSS is made up of sediments and other materials suspended in the water column. 

High TSS is common during storms and flooding. Extremely high level of sediments can also 

injure fish by clogging their gills, obscuring the presence of food, or covering the gravel surface 

of spawning areas. All watersheds sampled for the Point Reyes National Seashore Water Quality 

Monitoring Report (Ketcham, 2001) had TSS that exceeds the recommended standard. Sampled 

watersheds were Lagunitas Creek, Olema Creek, Drakes Estero, Drakes Bay, and Pacific 

Drainages. Sediment data was not collected from the Bolinas Drainages, Pine Gulch Creek or 

Tomales Bay watersheds. 

In addition to water quality, fire management activities can affect characteristics of a watershed. 

Individual watersheds are defined as the total area of land surface from which a body of water, 
101 

an aquifer or a river system collects its water. There are many scales of size by which 

watersheds can be defined; the watershed for a major river may encompass a number of smaller 

watersheds that ultimately combine at a common point. 

For purposes of planning for the management of NPS water resources, NPS staff scientists 

consider watersheds in relation to the extent of NPS resource management responsibility and the 

presence of sensitive biological resources. Overall, the NPS has management responsibility for 

portions of the Tomales Bay Watershed, the Lagunitas Creek watershed, the Pine Gulch Creek 

watershed, Bolinas Drainages, Olema Creek watershed, all of the Pacific Drainages (Kehoe, 

Abbotts Lagoon, etc.), Drakes Bay, and Drakes Estero watersheds. Study area watersheds are 

shown in relation to the 10 FMUs in Figure 16 and 6. Table 11 lists FMUs that either fully or 

partially within each watershed. This information is important in understanding how projects 

planned for distinct FMUs could potentially impact the same watershed. 

Table 11. Percent of Project Area in Project Watersheds 

Watershed FMU % of the Watershed in 

an FMU 

Percent of FMU in 

Watershed 

Tomales Bay Inverness Ridge 1% 26% 

 Limantour Road 3% 18% 

 Tomales Point 6% 67% 

 Wilderness North 4% 75% 

 14% of watershed w/in FMUs 

 

Lagunitas Creek Bolinas Ridge 3% 56% 

 3% of watershed w/in FMUs 

Olema Creek Bolinas Ridge 6% 25.446 

 Highway One 14% 25% 

 Wilderness South 8% 34% 

 28% of watershed w/in FMUs 

 

Drakes Bay Drainages Headlands 4% 52% 

 Limantour Road 6% 20% 

 Palomarin 0% 2% 

 Wilderness North 3% 21% 

 Wilderness South 11% 63% 

 24% of watershed w/in FMUs 

 

Drakes Estero Estero 9% 100% 

 Inverness Ridge 5% 74% 

 Limantour Road 14% 61% 

 Wilderness North 0% 0% 

 29% of watershed w/in FMUs 

 

Pacific Drainages Headlands 4% 48% 

 Tomales Point 9% 33% 

 13% of watershed w/in FMUs 

Bolinas Drainages Bolinas Ridge 3% 11% 

 Highway One 7% 18% 
102 

Watershed FMU % of the Watershed in 

an FMU 

Percent of FMU in 

Watershed 

 Palomarin 23% 90% 

 33% of watershed w/in FMUs 

 

Pine Gulch Creek Bolinas Ridge 3% 7% 

 Highway One 20% 35% 

 23% of watershed w/in FMUs 

Roughly 200 square miles of western Marin County drains to Tomales Bay, including Olema and 

Bear Valley creeks. For the FMP, this large drainage basin is split into its constituent 

subwatersheds to allow for a more detailed scrutiny of potential effects to sensitive resources 

located in distinct parts of the greater drainage area. Olema Creek and Lagunitas Creek are 

addressed as separate watersheds and the Tomales Bay Watershed itself is limited to the 45 

square miles of land encircling the Bay (see Figure 16). The following descriptions characterize 

water quality in each FMP watershed in the study area. 

Tomales Bay Watershed. The NPS manages approximately 28% or 13 square miles (8,266 acres) 

of the 45 square mile (29,219 acres) Tomales Bay Watershed shown on Figure 16. The 

remainder of the watershed lands is privately managed by either the Marin Municipal Water 

District or California State Parks, or privately held land. Tomales Bay and Drakes Estero are 

home to a number of oyster production operations accounting for nearly 35% of the oyster 

production in the state of California. The San Francisco Bay Regional Water Quality Control 

Board (RWQCB) has listed Tomales Bay and its major watersheds, Lagunitas Creek and Walker 

Creek, as impacted by sediment, nutrients, and pathogens under Section 303 (d) of the Clean 

Water Act. In addition, the RWQCB has also listed Tomales Bay and Walker Creek as impaired 

by mercury. The RWQCB is required by the EPA to develop and implement TMDLs for each 

pollutant parameter by 2010. FMP actions that could increase erosion have the potential to affect 

sediments and nutrients levels of Bay waters. Portions of the Inverness Ridge, Limantour, 

Tomales Point and Wilderness North FMUs are located in the Tomales Bay Watershed. 

Lagunitas Creek Watershed. The northern portion of the Bolinas Ridge FMU is in the 

northwestern portion of the Lagunitas Creek watershed. The 83-square mile watershed that 

drains to the head of Tomales Bay provides much of Marin County’s drinking water through the 

Marin Municipal Water District. Four dams with storage in excess of 60,000 acre-feet on 

Lagunitas and Nicasio creeks have significantly altered the hydrology and ecology of these 

creeks. The dams have also eliminated nearly two thirds of the spawning habitat of populations 

of the coho salmon and steelhead trout, listed as threatened species under the Endangered 

Species Act. Other federal threatened and endangered species in the watershed include the 

California red-legged frog and California freshwater shrimp. 

Olema Creek Watershed. The 14.5 square mile (37.5 square kilometers) Olema Creek watershed 

supports viable populations of coho salmon and steelhead trout. The Creek also supports 

California red-legged frogs. Approximately 90% of the lands in the Olema Creek Watershed are 

managed by the NPS. Olema Creek has been the subject of extensive monitoring to determine 
103 

the effectiveness of various stream protection measures – including riparian exclusion fencing 

and habitat restoration. Water quality sampling by the NPS found elevated levels of TSS in this 

watershed. The source of the elevated sediment levels may be soils disturbed by instability along 

the San Andreas fault zone, due to past logging, and a result of past and current agricultural land 

uses within the watershed. 

Drakes Bay Watersheds. Drakes Estero and the Estero de Limantour comprise a complex 

estuarine system capturing flow from more than 13.5 square miles (35 square kilometers) and 

draining through the Estero inlet. Steelhead trout are found in several of the contributing creeks 

draining to this watershed including Laguna, Muddy Hollow, Glenbrook, Home Ranch, East and 

North Schooner Creek. Several smaller creeks are characterized as rather small, steep drainages 

that discharge directly to the beach. The Estero is susceptible to nutrient and other inputs from 

grazed lands within the watershed and increased sediments from areas burned during the Vision 

Fire. Water quality monitoring by the NPS found the indicators for these potential pollutants 

currently within acceptable levels. 

Pacific Ocean Watersheds. The primary watersheds draining to the open ocean are from the 

north, and include McClures, Kehoe North, Kehoe South, E Ranch and Lighthouse. There are a 

significant number of smaller drainages north of Kehoe Beach that empty into the ocean such as 

Elk Fence, and others. There are a number of intermittent dune watersheds that are not included 

in this list but occasionally drain to the ocean across the ten-mile beach. North and South Kehoe 

Creeks converge approximately 1⁄4 mile upstream of Kehoe Lagoon. 

The Abbott’s Lagoon watershed drains across gently sloping terrain and into a unique lagoon 

environment. A human-made pond and a dual chambered lagoon separated by a bedrock sill 

provide a unique combination of brackish and freshwater environments in a system that often has 

the same surface water elevation. The lagoon does not breach regularly remaining closed for 

years at a time. 

Water quality monitoring, as part of a focused study by the USGS in partnership with the NPS, is 

underway in Abbott’s Lagoon to address pollutants flowing and develop prevention or reduction 

strategies. Current approximately 6.1% (or 188 acres) of the lands within the Abbotts Lagoon 

watershed is responsible for contributing most of the increased nutrient levels to the lagoon. 

Plans are proposed to construct facilities at a dairy within these lands that would reduce the 

levels of nutrients, sediments and pathogens flowing to the lagoon. 

Bolinas Drainages. The Bolinas drainages include Double Point, Arroyo Hondo, and RCA. 

Following the major drought (1976-77) the NPS allowed the Bolinas Community Public Utilities 

District to enact their appropriated water right from Arroyo Hondo, in order to protect stream 

flow and habitat in the Pine Gulch Creek Watershed. The upper watershed of Arroyo Hondo 

Creek are located within the Philip Burton Wilderness and are managed as a Public Water 

Supply Watershed. 

Pine Gulch Creek Watershed. Pine Gulch Creek is the largest watershed draining to Bolinas 

Lagoon. The Creek supports coho salmon, steelhead trout, and the California red-legged frog. 

Approximately 85% of the lands in this watershed are managed by the NPS. Of all the project 
104 

watersheds, Pine Gulch Creek was historically the most heavily logged and erosion from the past 

logging activities has been contributing sediment to Bolinas Lagoon for roughly 100 years. The 

lagoon is now the subject of an intensive restoration plan process coordinated through Marin 

County and the US Army Corps of Engineers exploring dredging to restore tidal prism. 

Important watershed management issues in the study are the protection of the stream and lagoon 

from additional sedimentation and deposition. 

Impoundments, Natural Lakes, and Sag Ponds 

The project area contains more than 75 impoundments and many are known to support the 

California red-legged frog. Most of these facilities were constructed by former landowners for 

stock watering or development. The condition of these many of these ponds is not well known 

and the stability of many is likely compromised by the presence of brush and trees on the dam 

structure. Activities conducted near pond facilities would protect pond edges and dam structures 

when planning specific prescription burns or mechanical fuel reduction projects. 

Within the Olema Valley, a number of naturally occurring sag ponds associated with the San 

Andreas Fault provide unique aquatic habitat. The southwestern part of the project area, from 

Palomarin to Double Point is dotted with ponds and lakes derived from massive slope failure 

events. These water bodies, such as Bass, Pelican, and Crystal Lake are naturally occurring. 

Vegetation 

PRNS owes much of its distinctive character to the assemblage of plants that occur on the 

Peninsula. Plant communities create patterns that reflect the underlying geologic formations and 

soils and the influence of a moist, maritime climate. PRNS is known to support over 910 plant 

species. Fifty-five of these are of management concern (see Table 12 and 13) in Special Status 

Species) and include the federally-listed endangered beach layia (Layia carnosa), Tidestrom’s 

lupine (Lupinus tidestromii), Sonoma alopecurus (Alopecurus aequalis var. sonomensis), 

Sonoma spineflower (Chorizanthe valida) and robust spineflower (Chorizanthe robusta). Of the 

910 plant species, roughly one third are not native to the area. 

Vegetation in the project area has been subject to human activities for 7,000 - 10,000 years, a 

time evidence suggests is concomitant with the first occupation of the area by the Coast Miwok. 

Although data are not available on the effects of Miwok activities on vegetation, it is assumed 

that they gathered plants for food and for shelter materials, and probably used fire to manipulate 

the growth of plant species. Beginning in the mid-nineteenth century and continuing into the 

present, activities such as land clearing, timbering, cultivation, cropping, road building, 

commercial development and livestock grazing have markedly affected the vegetation. 

For purposes of analysis, the 90,311-acre project area has been divided into 9 broad vegetation 

types. Acreage estimated for each type in the project area and brief descriptions are presented 

below. Acreage was estimated from the Point Reyes vegetation map and is rounded to the nearest 

100 acres. Vegetation types correspond most closely to the community level in the vegetation 

map classification hierarchy. 
105 

Table 12. Acres Within Each General Vegetation Class Within Each Fire Management Unit 

 Vegetation 

 Class 

FMU 

Bishop 

Pine 

Forest 

Douglasfir/ 

Coast 

Redwood 

Forest 

Hardwood

Forest 

Monterey

Pine/ 

Monterey

Cypress 

Riparian 

Woodland

Coastal 

Scrub 

Grassland Pasture Coastal 

Dune 

TOTAL

Tomales Point 0 0 24.9 5.6 64.3 1518.9 1006.7 0 12.5 2632.9 

Headlands 0 0 0 0 1.8 400.7 299.4 38.1 51.3 91.3 

Estero 2.2 0 5.3 37.0 37.9 520.2 913.1 16.9 0 1532.6 

Inverness Ridge 646.3 55.7 12.5 0 46.2 245.6 143.8 84.4 0 1234.5 

Limantour Road 140.9 748.4 216.9 12.1 371.5 2,040.3 462.2 13.6 0.2 4006.1 

Wilderness 

North 

0 1,262.3 103.5 0 4.0 130.6 88.4 0 0 1588.8 

Wilderness 

South 

0 1,673.3 128.0 0 54.0 303.6 85.5 0 0 2244.4 

Highway One 0 719.3 771.1 0 112.4 421.6 797.4 8.8 0 2830.6 

Bolinas Ridge 0 755.4 570.0 0 5.9 203.4 846.7 0 0 2381.4 

Palomarin 0 624.3 92.2 0.08 58.4 889.0 190.2 0.1 0 1854.3 

TOTAL 789.4 5,838.7 1924.4 54.78 756.4 6,673.9 4,833.4 161.9 64 21096.9

Bishop Pine Forest (3,700 acres). Bishop pine (Pinus muricata) is the dominant tree species in 

the forest/woodland community found on the northern portions of Inverness Ridge. Madrone 

(Arbutus menziesii), tanoak (Lithocarpus densiflorus), coast live oak (Quercus agrifolia) and 

California bay (Umbellularia californica) are often present in significant cover. Huckleberry 

(Vaccinium ovatum) is important to dominant in the shrub layer. Other species common in the 

understory include salal (Gaultheria shallon) and swordfern (Polystichum munitum). Stands of 

Bishop pine tend to be even-aged, usually originating after a stand-destroying fire. In the project 

area, approximately 65% of the Bishop pine forest is mature; the remaining 35% of the total 

forest area burned in the Vision Fire. The areas burned in 1995 are characterized by a patchwork 

of extremely dense stands of 12 to 15 foot tall, regenerating pines alternating with extremely 

dense stands of blue blossom (Ceanothus thrysiflorus) and Marin manzanita (Arctostaphylos 

virgata). 

This vegetation type also includes a small amount of non-native Monterey pine (Pinus radiata) 

and Monterey cypress (Cupressus macrocarpa) stands, amounting to less than 5% of the total 

forest/woodland acreage. These stands are characterized by planted groves dominated by either 
106 

tree species, invasive in some areas, usually with sparse to low shrub and herbaceous cover. The 

understory species in these stands are often non-native. 

Bishop pines are limited in distribution, and occur only in relict stands in California, from 

Humboldt to Santa Barbara counties, on Santa Cruz and Santa Rosa islands, and in isolated 

populations south to central Baja. Vegetation mapping in the park indicates approximately 3,570 

acres of Bishop pine forest occurring within Seashore boundaries. In 1995, approximately 35% 

(1,250 acres) of this acreage was burned in the Vision Fire. Following the fire, most of the pines 

in the area were dead and the formerly deep litter layer had been burned away. The bare, charred 

soil was covered with extremely large numbers of Bishop pine seeds. Regeneration in the 

burned area has been prolific, with dense stands of young Bishop pine growing up to replace the 

burned forests. One year following the fire, large dense patches of Bishop pine had recolonized 

the burned area. 

Fire plays an important ecological role in maintaining Bishop pine forests. Stands of Bishop 

pine are characteristically even-aged, originating after fires, and their cones persist for many 

years, usually opening as a result of fire. Bishop pine stands are often dense, and stand-replacing 

crown fire typically occurs in such stands. It is hypothesized that a fire-free period of 80+ years 

would allow trees to succumb to diseases and die without reproducing. Bishop pine is 

susceptible to rust gall infection and to secondary fungal infections. 

Douglas-fir/Coast Redwood Forest. The Douglas-fir (Pseudotsuga menziesii) and Coast 

redwood (Sequoia sempervirens) forest is the most common forest type in the project area. The 

forests reach a maximum height of 165 to 230 feet (50-70 meters) in the project area. 

Approximately 90% of this type of forest in the park is dominated by Douglas-fir while the other 

10% is primarily redwoods. 

In the project area, the Douglas-fir-dominated forest is characterized by a strong component of 

hardwood trees, usually California bay (Umbellularia california), but tanoak (Lithocarpus 

densiflorus) or individual coast live oaks (Quercus agrifolia) may be present. The shrub 

understory is highly variable, but is usually moderate to very dense. Coffeberry (Rhamnus 

californica), huckleberry (Vaccinium ovatum), California hazel (Corylus cornuta), poison oak 

(Toxicodendron diversilobum) and coyote brush (Baccharis pilularis). Swordfern (Polystichum 

munitum) often dominates the herbaceous layer. 

In those areas where redwood is the dominant tree in the forest canopy, tanoak is often a 

significant component, sometimes co-dominating with redwood. California bay or Pacific 

madrone (Arbutus menziesii) are also often present in significant cover. California hazel and 

huckleberry are the most common understory shrubs, with shrub cover usually sparse to 

moderate. Sword fern may dominate the herbaceous layer. 

Because this vegetation type is typified by its two dominant species, each is described in more 

detail below. 
107 

Douglas-fir (Pseudotsuga menziesii) 

Coast Douglas-fir is a large, coniferous, evergreen tree. Trees 5 to 6 feet in diameter and 250 

feet or more in height are common in old-growth stands. Trees often live more than 500 years 

and occasionally more than 1,000 years. Douglas-fir is shade intolerant and requires standdestroying disturbance (e.g., wildfire, logging, extensive windthrow) to initiate a new cohort of 

seedlings. This species is extremely long-lived. Stands 350 to 750 years old are subclimax and 

may contain a significant component of Douglas-fir for several more centuries. Without 

disturbance, these stands will give way to shade-tolerant associates such as western hemlock, 

western red cedar, and Pacific silver fir, but it may take 1,000 or more years for Douglas-fir to be 

fully replaced. This longevity allows Douglas-fir to persist until the next disturbance, ensuring a 

seed supply for postdisturbance establishment. 

Coast Douglas-fir can survive moderately intense fires. Thick, corky bark on the lower bole and 

roots protects the cambium from heat damage. In addition, tall trees have their foliage 

concentrated on the upper bole, which makes it difficult for fire to reach the crown; however, it 

should be noted that trees are typically not free of lower branches up to a height of 33 feet until 

they are more than 100 years old. Additionally, many stands in the project area have substantial 

ladder fuel accumulations, which could result in crown fire. 

Crown fires will commonly kill Douglas-fir trees over extensive areas. Rapidly spreading crown 

fires inflict damage to crowns, while slow spreading ground fires damage the boles and kill trees 

through cambial heating. Early or mid-summer fires are more damaging than late summer or fall 

fires because more buds are killed through crown scorching. During late summer buds are set 

and subsequent year needles are well-protected. Seedlings and saplings may be killed by even 

low intensity ground fires. Most seeds on the forest floor are killed by fire, but green cones are 

relatively well insulated and are not highly flammable. If cones are just scorched in a fire, seeds 

can mature in the cones and disperse onto the burned area. 

Coast Redwood (Sequoia sempervirens) 

Coast redwood is endemic to northern California and southwestern Oregon coastal areas. The 

trees occur on a narrow strip of land approximately 450 miles long and 5 to 35 miles wide. 

Coast redwood is a native, evergreen, long-lived (greater than 2,200 years) tree. Redwoods are 

among the world's tallest trees; trees over 200 feet are common, and many are over 300 feet. The 

largest tree measured to date was 364 feet tall and 20 feet in dbh. The tree’s root system is 

composed of deep, widespreading lateral roots with no taproot. The bark is up to 12 inches thick 

and quite fibrous. Redwood self-prunes well in dense stands, and the base of the bole is strongly 

buttressed. 

Hardwood Forest. This type of forest is comprised of hardwood species such as California bay 

(Umbellularia californica), coast live oak (Quercus agrifolia), eucalyptus (Eucalyptus globulus), 

tanoak (Lithocarpus densiflorus), madrone (Arbutus menziesii), and giant chinquapin 

(Chrysolepis chrysophylla). California bay is by far the most abundant, comprising roughly 75% 

of trees in this type of forest. Coast live oak makes up about 20%; these two species often 

associating with each other. Of the remaining forest, less than 5% is eucalyptus, and tanoak, 

madrone and giant chinquapin each comprise less than 1% of tree densities 
108 

California bay forest canopy is dominated by California bay or co-dominated by bay and coast 

live oak with each species comprising 30-60% relative canopy cover. Tanoak, Douglas-fir 

(Pseudotsuga menziesii) and California buckeye (Aesculus californica) may also have a 

significant presence. The understory is variable; it can be a moderately dense shrub understory 

often dominated by hazel (Corylus cornuta), coffeeberry (Rhamnus californica), elderberry 

(Sambucus racemosa) and/or poison oak (Toxicodendron diversilobum). If there is no 

significant shrub cover, swordfern (Polystichum munitum) usually dominates understory. 

Coast live oak woodlands are dominated by coast live oak usually with a significant component 

of California bay, sometimes co-dominating with bay. Individual Douglas-firs may be present. 

Understory is usually open to moderate with poison oak being the most commonly found shrub, 

often fairly high in cover. Coffeeberry, coyote brush (Baccharis pilularis), toyon (Heteromeles 

arbutifolia) and hazel can be present. Herbaceous cover is usually low. 

California Bay (Umbellularia californica) 

California bay occurs in the Klamath, Siskiyou, and Coast Ranges from Douglas County, Oregon 

south to San Diego County, California, and on the western slope of the Sierra Nevada from 

Shasta County south to Kern County. It grows along drainages in California’s Central Valley. It 

occurs from sea level to 4,000 feet in northern California and Oregon and from 2,000 to 5,000 

feet in southern California. 

A highly branched native evergreen tree, California bay grows from 40 to 80 feet tall. It grows 

in scrub form on poor sites. California bay begins reproducing by seed at 30 to 40 years. Seed 

crops are abundant in most years. Germination and establishment are favored in riparian areas 

where seed is buried by silt deposition or high water. Seedlings are good competitors against 

other species and grow under moderately dense canopies. Seedling recruitment, however, is 

poor under other California bay trees. California bay sprouts from the root crown, bole, or 

stump. 

Coast Live Oak (Quercus agrifolia) 

Coast live oak occurs along the Coast, Transverse, Peninsular, and Sierra de Juarez ranges from 

Mendocino County, California, south to Baja California. Limited inland populations occur along 

watercourses in California’s Central Valley. Coast live oak also is found on the Channel Islands 

of Santa Rosa and Santa Cruz. 

Coast live oak is a frequent dominant or codominant in mixed evergreen forests in the project 

area where it grows with tanoak, Pacific madrone, California bay, and coast Douglas-fir. 

Elevations of coast live oak populations range from sea level to 3,000 feet in central and northern 

California. 

Coast live oak is a drought-resistant, evergreen tree, ranging from 19 to 82 feet tall and from 1 to 

4 feet in diameter. The bark of young trees is smooth, and it develops deep furrows and ridges 

with age. The inner bark and cork layers are thick. Open-grown crowns are broad and dense, 

with foliage often reaching the ground. In open areas trunks are usually 4 to 8 feet tall; at this 

height, primary branches originate and grow horizontally. Coast live oak stands are typically 
109 

from 40 to 110 years old, and individual trees may live over 250 years. Coast live oak may grow 

where it can access groundwater, but most individuals have extensive shallow root networks. 

Ecologists refer to changes in the grassland, chaparral, and oak woodland mosaic of California as 

“non-directional fluctuations” rather than succession. Coast live oak may be considered seral or 

climax depending on habitat, but it is tolerant of shade throughout its life. Because deer and 

cattle prefer coast live oak, it is gradually replaced by California bay in some areas of coastal 

northern California where the two species codominate. 

In burned or logged mixed evergreen forest, a coast live oak phase is seral to the climax forest. 

However, on steep slopes or poor sites within this habitat type, coast live oak represents a 

topographic or edaphic climax. In the San Francisco Bay area coyote brush invades grasslands, 

and coyote brush subsequently facilitates coast live oak woodland development. In the absence 

of disturbance, coyote brush scrubland almost always gives way to coast live oak and California 

bay, as coyote brush seedlings do not develop beneath their own canopies. 

Coast live oak is exceptionally fire resistant. Adaptations include evergreen leaves, thick bark, 

and sprouting ability. Evergreen leaves allow this species to allocate greater amounts of energy 

to recovery from fire than to replacing the entire crown annually. Evergreens are often better 

able to conserve nutrients than deciduous species, and are favored in fire-prone environments. 

Coast live oak bark is the thickest among California oaks. Oaks are more likely to be damaged 

by fall fire than earlier fires. Because of mortality among small-diameter trees, frequent fire 

limits coast live oak invasion of grasslands. 

Eucalyptus (Eucalyptus spp.)

Eucalyptus is notable because it is an invasive non-native hardwood species in the park, and 

would be treated in some alternatives by thinning and herbicide application to prevent stump 

resprouting. Eucalyptus forests are dominated by the non-native Blue gum eucalyptus which 

have been planted in or have invaded native plant communities. Eucalyptus is usually highly 

dominant in the canopy. Monterey pine (Pinus radiata)/Monterey cypress (Cupressus 

macrocarpa) or individuals of Douglas-fir, California bay or coast live oak may be present. 

Understory is usually sparse often including remnants of the native community. Poison oak and 

non-native or native berries (Rubus spp.) are common shrubs. Other non-native shrubs and herbs 

are often present in low cover. The floor of the eucalyptus forests is characterized by a thick 

layer of litter made up of bark, seedpods, leaves and branches. 

Monterey Pine/Monterey Cypress (Pinus radiata/Cupressus macrocarpa) 

Monterey pine is an evergreen conifer. The typical variety of Monterey pine occurs along the 

California coast in three disjunct populations in San Mateo, Santa Cruz, Monterey, and San Luis 

Obispo counties. The Monterey pine trees in the project area were introduced. 

Monterey pine is cultivated for timber in numerous countries. Much of the Monterey pine 

planted as ornamentals comes from New Zealand stock. This stock originated from native 

California populations several generations ago. In Cambria and Monterey, California, this 

imported stock is crossbreeding with native individuals. Monterey pine also hybridizes with 
110 

knobcone pine and Bishop pine. The genetic effect of this crossbreeding on native trees is 

unknown, and preserving genotypes of native individuals is of management concern. 

Monterey pine attains a height of 49.5 to 115.5 feet and a dbh of 24 to 36 inches. The tree’s 

outer bark is narrowly ridged and the inner bark is resinous. The needles occur in clusters of 

three and are 4 to 6 inches long. They persist for approximately three years. Cones are 3 to 5.5 

inches long and occur in one or more clusters of three to five around the branch. Monterey pine 

lives a maximum of 80 to 90 years. 

The minimum seed-bearing age for Monterey pine is between 5 and 10 years. Maximum seed 

production begins at 15 or 20 years of age if trees are open-grown, and later if stands are dense. 

Cones are produced annually, with good cone crops produced every other year. Mature cones 

remain attached to the branch. They may remain closed for several years, depending on 

temperature and humidity. Cones open and release seed during warm, dry periods and close 

rapidly when temperature drops and relative humidity increases. Seedfall is heaviest in warm, 

dry years. Unreleased seed remains viable for decades. Seeds from cones up to 24 years old 

have germinated; but germination appears to fall off with progressing years. Seedling 

recruitment is best on mineral soil. Monterey pine does not reproduce by sprouting. 

Monterey pine cones are serotinous; seeds are released when cones are exposed to heat such as 

fire or high air temperature. Fire is particularly effective for opening cones and releasing seeds 

and it creates a favorable seedbed. Reproduction rates are greatest after surface fire in which the 

parent trees survive. Monterey pine is killed by severe surface or crown fire. Trees survive 

crown scorch, however, unless it is extensive. Young, thin-barked Monterey pine are often 

killed by fire, particularly when stands are dense and crown fire occurs. 

Monterey cypress (Cupressus macrocarpa) occurs in two natural stands in Monterey County, 

California. One stand is between Point Cypress and Pescadero Point on the north side of Carmel 

Bay, Monterey Peninsula. A smaller one is near Point Lobos on the south side of Carmel Bay. 

Monterey cypress is widely planted and naturalized on the California coast. The Monterey 

cypress in the project area were introduced. 

Monterey cypress is an evergreen tree that grows to 82 feet tall. The bark is thick and fibrous, 

becoming furrowed with age. A well-defined taproot and numerous laterals are formed the first 

year. Naturalists at the Point Lobos State Reserve have estimated the maximum age of Monterey 

cypress at 200 to 300 years. 

Riparian Woodland. These streamside forests and shrublands are dominated by broad-leaved 

deciduous trees or shrubs such as red alder (Alnus rubra), mixed willows, and arroyo willows 

(Salix lasiolepis). Red alder forest is the most abundant of this type comprising approximately 

70% of riparian areas. Understory is usually moderate to dense. Berry species (salmonberryRubus spectabilis, thimbleberry- R. parviflorus, California blackberry- R. ursinus) and red 

elderberry (Sambucus racemosa) are the common shrubs. Hedgenettle (Stachys ajugoides), 

sedges (Carex spp.), rushes (Juncus spp.), small-fruited bulrush (Scirpus microcarusp) and ferns 

(sword fern- Polystichum munitum, lady fern- Athyrium felix-femina) dominate the herbaceous 

layer. 
111 

Other forested riparian areas are dominated by mixed willow forest, represented in the project 

area by yellow willow (Salix lucida), often associating with other willows. Mixed willow forest 

makes up less than 5% of riparian areas. 

Arroyo willow shrublands make up approximately 25% of the riparian type. Arroyo willow in 

its shrub form stands between 16 and 23 feet high (5 to 7 meters), and strongly dominates the 

canopy. Other taller willows or alder may be present in small quantities. The understory is 

usually extremely dense because of the thicket- forming growth habit of this species. Shrubs 

such as berry species (Rubus parviflorus, R. spectabilis, R. ursinus) are most commonly found 

woven through the understory. Wax myrtle (Myrica californica) or poison oak (Toxicodendron 

diversilobum) may be present. Sedges, rushes, small-fruited bulrush along with hedgenettle, 

beeplant (Scrophularia californica) and the ferns (Lady fern, bracken fern- Pteridium aquilinum) 

dominate the herbaceous layer. Because they are dominant species in PRNS riparian woodlands 

and shrublands, red alder and arroyo willow are described in more detail below: 

Red Alder (Alnus rubra) 

Red alder occurs from southeast Alaska to southern California. Red alder communities were 

primarily restricted to streams and wet areas during presettlement times. Since then, 

disturbances such as logging have provided an abundance of open sites with bare mineral soil, 

which favor red alder colonization. 

Red alder grows in humid coastal climates characterized by cool wet winters and warm dry 

summers. Trees need more than 25 inches of precipitation annually, and most stands receive 

over 40 inches. Red alder is a rapidly growing, short-lived, medium-sized, deciduous tree, 

generally with one straight distinct trunk. It reaches a maximum height of about 120 feet, with a 

maximum trunk diameter of about 32 inches. Mature trees are typically from 80 to 100 feet tall 

and 14 to 18 inches in diameter. Maximum age is one hundred years. 

Red alder regenerates primarily by seed. Plants are monoecious and primarily are wind 

pollinated. Flowering generally occurs from late February to early May depending on latitude 

and climate. 

Seed dispersal begins soon after ripening in late summer, but most seeds are shed during fall and 

winter. The seeds are very lightweight and are normally carried up to several hundred yards in 

the direction of the prevailing winds. Seed production begins at about 10 years (but sometimes 

sooner), and continues throughout maturity, with optimum production at about 25 years of age. 

A prolific seeder, red alder produces peak crops about every four years, with moderate to light 

crops produced in between. Total seed crop failure is very rare. 

Germination is best on moist mineral soil in full sunlight. Seed also germinates well on rotten 

wood and duff, and to a lesser extent on soil organic horizons and on rock-surfaced logging 

roads, but the roots must quickly reach a moist nutritious substrate if seedlings are to survive. 

Sunlight is required for germination. Seeds under thick vegetation or buried deeply in the soil, 

will not germinate until the site is disturbed, exposing the seeds to sunlight. Germination 

percentages range from 59 to 84 percent. Seeds remain viable in storage for about three years. 
112 

Red alder is an early seral species. It quickly invades forest openings, such as those created from 

fires, logging, wind throws, or road cuts, and it also pioneers volcanic mud flows. Plants often 

reach 6 to 18 inches in 1 year and may reach 18 feet in 5 years. This rapid juvenile growth gives 

the shade-intolerant red alder a competitive edge over conifers, as it quickly overtops them. 

Red alder and Douglas-fir are reported as the principal pioneer tree species of lower and middle 

elevation forests from southwestern British Columbia to northwestern California. Thus they 

often dominate the first postfire community. Disturbed areas are naturally seeded, resulting in 

stands that start out with several thousand alder trees per acre. Due to red alder's shade 

intolerance, stands are self-thinning; trees that do not maintain their height in the canopy die, 

resulting in even-aged stands. Conifers such as Douglas-fir that become established at the same 

time are quickly overtopped by this extremely fast growing species. These early seral red alder 

communities suppress competing conifers, but after about 25 years, conifers equal red alder 

height and begin to overtop them. After about 40 years, Douglas-fir becomes dominant. Few 

red alder trees remain in stands past 60 years. As stands develop and trees mature, they prevent 

other red alder seedlings from becoming established, due to the seedlings’ shade intolerance. 

Information regarding the effects of fire on red alder generally is lacking. Red alder’s bark, 

although thin, is sufficiently fire resistant to protect trees from light surface fires. The foliage 

and leaf litter do not carry fires well. Red alder stands often lack flammable understory debris 

and are often on moist sites which burn infrequently. Red alder revegetates burned areas via 

seed from off-site plants. 

Red alder quickly invades burned areas. Off-site plants inhabiting fire resistant draws and 

streambeds provide an abundance of seed, which reportedly can travel several hundred yards via 

wind. Thus red alder quickly colonizes soils exposed after forest fires. Information regarding 

the sprouting response of red alder after above-ground plant parts have been killed by fire is 

lacking. However, response after cutting shows that red alder tends to sprout at the root collar or 

along the lower stem no matter where the stem is cut. Fire hazard is generally low in red alder 

stands and stands may be used as natural firebreaks. 

Arroyo Willow (Salix lasiolepis) 

Arroyo willow is a common shrub or small tree (<10 m tall) that occurs in streambeds and on 

riverbanks below 7000 feet. It occurs in the western United States, from Washington and Idaho 

south to Texas and Mexico. This species is abundant along shorelines, marshes, meadows, and 

springs. Flowers are produced from February to April. 

Most willows resprout from the root crown or stem base following fire. Severe fires can 

completely remove organic soil layers, however, leaving willow roots exposed and charred, thus 

eliminating basal sprouting. Severe fires probably occur infrequently in the moist habitats 

occupied by arroyo willow. Generally, willows tend to be prolific seeders, and off-site plants are 

important as a seed source for revegetating burned areas. 

Coastal scrub is a highly variable vegetation type including all of the shrublands of the study area 

and a small amount of chaparral. Coastal scrub is one of the most widespread plant community 
113 

types in the project area and is present to some degree in all FMUs. Approximately 90% of 

coastal scrub is dominated by coyote brush (Baccaris pilularis), a small-leaved evergreen shrub. 

Because it is dominant, it is discussed in more detail below. Coyote brush scrub is highly diverse 

and variable, ranging from fairly low open areas where coyote brush associates with grasses, to 

tall dense multi-species scrubs. Coyote brush scrub can be roughly equally divided in the project 

area between these open and dense variations. In its more open variation, coyote brush 

commonly associates with non-native and native grasses and California blackberry (Rubus 

ursinus). It may also be found in association with sedges (Carex spp.) and rushes (Juncus spp.). 

In its taller, denser variation, poison oak (Toxicodendron diversilobum) is the most commonly 

associating shrub, often in fairly high cover. Coffeeberry (Rhamnus californica), thimbleberry 

(Rubus parviflorus), California blackberry and California sagebrush (Artemisia californica) are 

common associates in dense coyote brush scrub. 

An additional 5% or so of coastal scrub is dominated by a diverse list of shrub species that 

includes coffeeberry, yellow bush lupine (Lupinus arboreus), hazel (Corylus cornuta), and blue 

blossom (Ceanothus thrysiflorus). 

Chaparral accounts for less than 5% of the coastal scrub type. The manzanitas (Arctostaphylos 

spp.), primarily Eastwood manzanita (Arctostaphylos glandulosa) and chamise, (Adenostoma 

fasciculatum) are the dominant shrubs here. These evergreen species tend to be in the hotter, 

drier areas with the largest occurrences in the project area found on the western slope of Bolinas 

Ridge and within the Vision Fire burn area on Inverness Ridge. 

Coastal sage and coastal scrub community types are fire-dependent, with prominent shrubs 

establishing by seed and sprouting. They are flammable vegetation types that may burn again 1 

to 2 years after fire if dry conditions exist. With fire in less than 5-year intervals, or with 

overgrazing, coastal scrub generally reverts to annual non-native grassland. Fire exclusion in 

coastal sage scrub and mesic chaparral communities allows coast live oak, California bay, and 

other shade tolerant species to increase in density and reduce understory diversity and 

abundance. In the absence of fire, coast live oak recruitment in chaparral and grassland is 

commensurate with their aerial extents; in coastal sage scrub, however, coast live oak 

recruitment exceeds that expected by chance alone. This is primarily because coyote brush is a 

nurse shrub for shade-tolerant tree seedlings, particularly coast live oak and California bay. With 

tree development, coyote brush is reduced or excluded. 

Coyote brush (Baccharis pilularis) 

Coyote brush occurs in the outer Coast Ranges from northern Baja California, Mexico, and San 

Diego County, California, north to Tillamook County, Oregon. The species occurs in the 

Channel Islands and as isolated populations in the Cascade and Sierra Nevada foothills from 

Butte County to Tuolumne County, California. It is a dominant shrub in northern coastal scrub 

communities and a minor component of coastal beach communities, coastal sage scrub, 

chaparral, foothill woodlands, closed-cone pine forests, and mixed-evergreen forests. 

Coyote brush grows a taproot up to 10.5 feet long; lateral roots are also well developed. 

Individuals live 10 to 15 years, but basal sprouting and layering may extend this lifespan. Seeds 

germinate well on mineral soil and have no stratification or temperature requirement. Most 
114 

germination occurs within about 15 to 30 days. Coyote brush sprouts from the root crown and 

roots. It may also grow roots where branch nodes contact soil. 

Coyote brush is shade-intolerant. Along with other small-seeded coastal sage shrubs, it colonizes 

actively eroding or alluviating areas such as dunes and gravel bars. Exposed mineral soil gives 

coyote brush an advantage over perennial grasses and chaparral shrubs. Coyote brush’s 

successional status varies with habitat type. In California grasslands, it is a late seral species that 

invades and increases in the absence of fire or grazing. Coyote brush invasion of grasslands is of 

structural importance because it facilitates the establishment of other coastal sage species. Shrub 

cover subsequently increases numbers of rabbits and small mammals that reduce herbaceous 

vegetation and favor shrub development. Thus, well-established coyote brush stands generally 

have depauperate understories. Coyote brush is a common dominant in coastal sage scrub, but 

because seedling growth is poor in shade, coyote brush does not regenerate under a closed shrub 

canopy. Coast live oak, California bay, or other shade tolerant species replace coastal sage scrub 

and other coyote brush-dominated areas, particularly when fire and grazing are excluded. 

Generally the transition from coyote brush-dominated scrub to mixed evergreen forest takes 

place in about 50 years and is reversible with periodic fire. 

Coyote brush is moderately fire tolerant. In areas of high shrub density, heat at root crowns is 

often too low to cause mortality, and coyote brush is able to resprout. Fires in such communities 

reduce crown cover but are not likely to reduce shrub density. Fires that occur in areas with low 

shrub density and high herbaceous biomass create enough heat at the root crown to girdle and 

kill plants. In oak woodlands and chaparral, most postfire recovery of coyote brush and other 

dominants is by sprouting. In coastal sage scrub, fire creates canopy gaps with exposed mineral 

soil that allow coyote brush and other coastal sage scrub species (most of which also have small, 

light seeds) to establish from seed and outcompete herbaceous vegetation. 

Fire frequency largely determines the extent of grasslands, coastal sage scrub, chaparral, and oak 

woodlands and whether or not coyote brush is present in each of these types. In grasslands, low 

fire frequency permits establishment of coyote brush and the gradual exclusion of herbaceous 

species. In coastal sage scrub, chaparral, and oak woodland, decreasing fire frequency allows 

coyote brush to be replaced by more shade-tolerant species. In mixed evergreen forests, closedcone pine stands, and coast Douglas-fir stands, coyote brush is only important in early seral 

vegetation after fire or logging. Transition from coyote brush scrub to mixed evergreen forest 

can occur in 50 years without fire. In some cases, however, tree recruitment is limited by crown 

closure, and fire exclusion does not result in type conversion but rather maintenance of a 

dynamic mosaic wherein reversion and succession allow both vegetation types to persist. 

Fire exclusion in coastal prairie allows coyote brush establishment, with best establishment in 

wet years. Prescribed burning has been used in coastal prairie to reduce invasion of coyote brush 

and other shrubs. 

In coastal sage scrub, prescribed fire reduces fuel loading, risk of property-damaging wildfire, 

and the establishment of coast live oak and other trees. Mature coyote brush stands in coastal 

sage scrub are generally replaced by shade-tolerant species, and maintenance of coastal scrub, if 
115 

desired, requires periodic disturbance. Grazing and/or prescribed fire have been recommended 

where the management objective is grassland maintenance. 

Grassland. Pristine coastal prairie in the study area is dominated by perennial bunchgrasses, but 

roughly 80% of the grasslands in the Seashore are dominated by non-native grasses. Most 

common is the invasive perennial purple velvet grass (Holcus lanatus), although annual Italian 

wild rye (Lolium multiflorum), farmer’s foxtail (Hordeum murinum) and rattail fescue spp. 

(Vulpia spp.) also cover large acreage. 

Pacific reedgrass (Calamagrostis nutkaensis) is the most common native grass in the project 

area, along with tufted hairgrass (Deschampsia cespitosa), California oatgrass (Danthonia 

californica), meadow barley (Hordeum brachyantherum), and California brome (Bromus 

carinatus). Where Pacific reedgrass is in association with rushes (Juncus spp.) and sedges 

(Carex spp.), it is included in the wetland vegetation type. Native grasses are often found in 

association with annual non-native grasses, coyote brush, California blackberry and a variety of 

native and weedy herbs. 

Pasture is distinguished from grazed grasslands and other grazed naturally occurring vegetation 

types in the project area as it is used to graze cattle or horses, or managed to produce silage for 

cattle, or used for other agricultural purposes. The Minimal Management FMU is predominately 

pasture. 

Coastal Dunes - The majority of dune habitat is dominated by non-native species. The western 

portion of the Linamtour FMU has the most extensive areas of coastal dunes; smaller patches are 

present in the Headlands and Tomales Point FMU. Non-native European beachgrass (Ammophila 

arenaria) represents roughly 50% of the coastal dune vegetation, and non-native iceplant 

(Carpobrotus edulis), roughly 25%. In areas where these two species dominate, they form dense 

monocultures, with few or no other species present. 

The remaining 25% of this vegetation type are remnant patches of native plant community 

comprised primarily of dune sagebrush (Artemisia pycnocephala), coast buckwheat (Eriogonum 

latifolium), dune lupine (Lupinus chamissonis), or goldenbush (Ericameria ericoides), often with 

significant cover of the two invasive species - European beach grass and/ or iceplant. Total 

vegetation cover is often low and interspersed with bare sand. 

Wetlands 

This vegetation class includes moist herbaceous wetlands, salt marshes and freshwater marshes. 

Moist herbaceous wetlands, dominated by rushes (Juncus spp.), sedges (Carex spp.), smallfruited bulrush (Sirpus microcarpus) and Pacific reedgrass (Calamagrostis nutkaensis) in 

association with these wetland species, make up approximately 70% of this type. Any of these 

species may dominate and may often be found in swales in a patchwork pattern. Other 

associating species include purple velvet grass (Holcus lanatus) and California blackberry 

(Rubus ursinus) in the drier areas, potentilla (Potentilla anserina), hedgenettle (Stachys 

ajugoides), lady fern (Athyrium felix- femina), and horsetail (Equisetum spp.) in the moister 

areas. 
116 

Table 13. Marsh and Other Wetland Acreage in each FMU Where Management Would Take 

Place 

FMU Acreage 

Tomales Point 74.3 

Headlands 7.7 

Estero 94.2 

Inverness Ridge 13.4 

Limantour Road 69.7 

Wilderness North 2.6 

Wilderness South 22.4 

Highway One 13.4 

Bolinas Ridge 0 

Palomarin 25.2 

TOTAL 322.9 

Salt marshes make up roughly 30% of wetlands in the project area. Pickleweed (Salicornia 

virginica) is the most common dominant, as well as saltgrass (Distichlis spicata); these species 

often co-dominate. Jaumea (Jaumea carnosa) is the most common associate. Sea lavender 

(Limonium californicum), arrow-grass (Triglochin concinna), alkali heath (Frankenia salina) and 

bird’s beak (Cordylanthus maritimus) are often associates as well. 

 

Freshwater marshes account for less than 5% of this type. Dominant species are the tall 

California bulrush (Scirpus californicus) and cattails (Typha spp.). These species are found in 

the wettest areas in or at the edge of standing water such as marshes or stock ponds. Bur-reed 

(Sparganium spp.) and water parsley (Oenanthe sarmentosa) are common associates. 

Wildlife 

The project area supports a wide diversity of wildlife species, including 28 species of reptiles and 

amphibians, 65 species of mammals, and breeding habitat for 130 species of birds. Nearly 490 

bird species (representing 45% of the avian fauna documented in the United States) have been 

sighted on land and over near shore waters at Point Reyes. PRNS is also home to innumerable 

invertebrates. The waters of the Pacific Ocean and Tomales Bay support rich and diverse 

fisheries. Many of the wildlife species present in the study area are listed by the federal or state 

endangered species acts as threatened or endangered by extinction from all or part of their range. 

Mammals 

A rich diversity of terrestrial mammals occupies the many habitats presented in the 10 Fire 

Management Units. More common mammalian species include dusky-footed woodrat (Neotoma 

fuscipes monochroura), bobcat (Lynx rufus), gray fox (Urocyon cinereoargenteus), black-tailed 

deer (Odocoileus hemionus columbianus), raccoon (Procyon lotor), striped skunk (Mephitis 

mephitis), black-tailed hare (Lepus californicus californicus), brush rabbit (Sylvilagus bachmani 

ubericolor) and many species of bats, shrews, mice and moles. Mountain lion (Felis concolor) 
117 

are present though rarely seen and coyotes (Canis latrans) are widespread. Tule elk (Cervus 

elaphus nannodes), once extirpated from the Peninsula, have been successfully reintroduced. 

They are a regular presence in several of the FMUs and are especially numerous in the Tomales 

Point FMU. 

The many marine mammals that inhabit or transit in the waters off of Point Reyes would not be 

affected by actions proposed in the Fire Management Plan and are therefore not described as part 

of the Affected Environment. FMP actions in each alternative have been developed to ensure 

marine mammal areas are not impacted by smoke produced from a prescribed fire. 

Amphibians and Reptiles 

Large populations of the California red-legged frog (Rana auroura draytonii) occur within the 

project area (see below). More common amphibians in the project area include bullfrogs (Rana 

caesbeiana), California newts (Taricha torosa), Pacific treefrog (Hyla regila) and rough-skinned 

newts (Taricha granulosa). It is not uncommon to find the Pacific giant salamander 

(Dicamptodon enstatus) near streams. 

Common reptiles include the Western fence lizard (Sceloporus occidentalis), Northern alligator 

lizard (Gerrhonotus coeruleus), Pacific gopher snake (Pituophis melanoleusus), Western 

terrestrial garter snake (Thamnophis elegans) and Western pond turtle (Clemmys marmorata). 

Birds 

Located along the Pacific Flyway and prominently jutting from the coast, the Point Reyes 

Peninsula supports a large number of resident and migratory birds. Though nearly 490 bird 

species have been documented at PRNS over half of the sightings were considered rare or 

extremely rare occurrences (i.e., unusual for this area). The project area provides breeding 

habitat for over 100 bird species. The park is recognized as a site of global significance for birds 

because of the great diversity and abundance of species. Some of the species of particular note 

that are resident and nesting include northern spotted owls, osprey, various raptors and owls, 

Neotropical migrant songbirds, several species of seabirds such as ashy storm-petrel, and western 

snowy plovers. Examples of significant migratory species include the Neotropical migrant 

songbirds, raptors, and brown pelicans. 

Fish 

Several important anadromous fish species are present in the creeks and watersheds within the 

study area. Anadromous species are those that migrate from the ocean to brackish or fresh water 

habitat to breed. Species present within the study area include coho salmon (Oncorhynchus 

kisutch) and steelhead trout (Oncorhynchus mykiss), an anadromous rainbow trout. Both species 

are listed as threatened under the federal Endangered Species Act (see below). The coho returns 

to the stream in which it was born to breed after spending two years in the open ocean. The 

Lagunitas Creek watershed population is host to one of the largest remaining populations in the 

central coast of California. Steelhead trout occur in most perennial watersheds in the study area 

(Ketcham, 2001). Other anadromous fish species include herring, the Pacific lamprey 

(Lampertra tridentata), a federal Species of Concern, the green sturgeon (Acipenser medirostris), 

a federal Candidate Species, the California roach (Hesperoleucus symmetricus), a state Species 

of Concern. 
118 

Non-native wildlife 

Several species of non-native wild and feral animals also occur in the project area. Axis deer 

(Axis axis) and fallow deer (Dama dama) were released in the 1940s and 1950s by a local 

landowner for hunting. Non-native and feral predators, such as red fox (Vulpes vulpes), Norway 

rat, possum and house cats (Felis domesticus) are present, as well as several non-native bird 

species including house sparrows, European starlings, wild turkeys (Meleagris gallopavo), and 

common peafowl (Pavo cristatus). 

Special Status Species 

The study area supports 47 listed animal species - 14 are federally listed as endangered, 8 as 

threatened and 24 as Species of Concern. Among these are the endangered Brown Pelican 

(Pelecanus occidentalis) and Myrtle’s silverspot butterfly (Speyeria zerene myrtleae). Federally 

threatened species include Northern spotted owl (Strix occidentalis), Western snowy plover 

(Charadrius alexandrinus), and the California red-legged frog (Rana aurora draytoni). 

Nineteen federally listed plant species (seven of which also are state listed) and an additional 25 

listed or proposed for listing by the California Native Plant Society (CNPS) have been 

documented in the study area (Table 3). 

Many of the plant and wildlife species present in the project area are regulated or monitored by 

the US Fish and Wildlife Service (USFWS), National Marine Fisheries Service and/or the State 

of California. Regulatory protection is afforded to species listed or proposed as threatened or 

endangered under the federal and state endangered species acts, the Marine Mammal Protection 

Act and the Migratory Bird Treaty Act. Species listed as Species of Concern by the US Fish and 

Wildlife Service, and Species of Special Concern by the California Department of Fish and 

Game, do not have legal protection under Endangered Species Act but are considered as species 

with potential to require future listing. Rather, the listing as species of concern brings these 

species to the attention of the public and appropriate agency with the aim of obviating the need 

for future listing through wise management practices. 

This section is divided into a discussion of plants that are listed under the Endangered Species 

Act (Federally listed species), plants that are listed as Species of Concern by the USFWS or on 

California state lists only (Other Special Status plant species). Tables 3, 15, 21, and 22 list all 

plant special status species, and Tables 24 and 33 animals species with special status. 

Federally Listed Plant Species 

Federally listed plants in the study area that may be affected by fire management activities 

include Sonoma alopecurus (Alopecurus aequalis var. sonomensis), Sonoma spineflower 

(Chorizanthe valida), robust spineflower (Chorizanthe robusta), Tiburon paintbrush (Castilleja 

affinis ssp. neglecta), Marin dwarf flax (Hesperolinon congestum), beach layia (Layia carnosa) 

and Tidestrom’s lupine (Lupinus tidestromii [var. layneae]). These species are described below. 

Sonoma alopecurus (Alopecurus aequalis var. sonomensis) – Endangered 

Sonoma alopecurus is a perennial grass 9-47 cm tall that has spike-like flowers. It is a variety of 

the species found in wet meadows and shorelines in California, the eastern U.S., and Eurasia. 
119 

Because alopecurus individuals flower at different times throughout late spring and early 

summer within a given site, it is difficult to accurately estimate numbers of plants. 

Four occurrences of this species are currently known on the Point Reyes peninsula, all occurring 

within pastures on agricultural permit lands (Table 14). Two occur in the vicinity of Abbott’s 

Lagoon, on the G and H ranches, another on the F Ranch, and the fourth on a private in-holding 

within the PRNS owned by American Telephone and Telegraph (AT&T). 

All occurrences are within the low-lying coastal plain that occupies most of the west-central 

Point Reyes peninsula. Soils in these areas are of the highly sandy Sirdrak and Sirdrak variant 

series, the latter characterized by a weakly cemented discontinuous hardpan producing a seasonal 

high water table, which can support robust growth of wetland species such as small-fruited 

bulrush (Scirpus microcarpus) and bog rush (Juncus effusus). While the present range of this 

taxon within PRNS is restricted to sandy soils, the distribution of the taxa as a whole suggests 

that it could occur, or could have occurred in the past, in wetland sites dispersed over much of 

PRNS. 

Table 14. Sonoma alopecurus Occurrences and Numbers of Plants from 2000-2003 

 2000 2001 2002 2003 

G Ranch 1,572 3,405 7,530 8,386 

H Ranch 60-328 648 129 661 

F Ranch 53 336 340 1,042 

AT&T 

 Sub- occurrence 1 470 289 400 1,843 

 Sub- occurrence 2 1,696 243 800 1,774 

Table 15. Federal Threatened, Endangered, Candidate, and Proposed Plant Species that may 

occur in Areas Affected by PRNS's Fire Management Plan (per USFWS Letter, May 24, 2001). 

Common Name Scientific Name Listing 

Statusa 

Known to 

Occur 

Potentially 

Subject to 

Adverse 

Impacts 

Sonoma alopecurus Alopecurus aequalis var. 

sonomensis 

E yes yes, but unlikely b

Tiburon paintbrush Castilleja affinis ssp. neglecta E yes yes, but unlikely b

Robust spineflower Chorizanthe robusta var.

robusta 

E yes no 

Sonoma spineflower Chorizanthe valida E yes yes, but unlikely b

Baker’s larkspur Delphinium bakeri E no no 

Marin dwarf flax Hesperolinon congestum T yes yes, but unlikely b

beach layia Layia carnosa E yes noc

Tidestrom’s lupine Lupinus tidestromii (var.

layneae) 

E yes noc
120 

showy Indian clover Trifolium amoenum E extirpated no 

a Listing status: E: Endangered T: Threatened 

b These species do not occur within any of the FMUs except the Minimum Management Unit (where 

prescribed fire and mechanical treatments would not occur). The grazed grassland and wetland 

(Alopecurus) habitats supporting these species are unlikely to be affected by unplanned wildfire. 

c These species occur in coastal dunes, which is part of the Minimum Management Unit (where prescribed 

fire and mechanical treatments would not occur). The dune habitats supporting these species are very 

unlikely to be affected by unplanned wildfire 

The G Ranch occurrence is located in a back dune area near the southwest corner of Abbott’s 

Lagoon, in a swale that supports freshwater marsh vegetation. The swale is located along a fence 

built in 1989 to exclude cattle from the shores of the lagoon and from the dunes west of Abbott’s 

Lagoon. The occurrence numbered 33 plants in 1994, 38 plants in 1995, and 40+ plants in 1998. 

In June, 2000, a more thorough and systematic survey than previously conducted documented a 

peak population size of 1,572 individuals. 

The H Ranch occurrence is in a freshwater marsh/swale along a fence that borders an ungrazed 

area south of Abbott’s Lagoon. The fence was built in 1983 to keep cattle away from the 

eastern, freshwater lobe of Abbott’s Lagoon and from a trail running from Pierce Point Road to 

the beach. Alopecurus was sown in a part of the swale excluded from grazing after the fence 

was constructed. This fenced location is now overgrown with dense native wetland vegetation 

and no alopecurus is present. The site that does presently support plants, within the pasture, is 

immediately above a small berm carrying the trail across the swale. The berm may have altered 

the hydrology above it, making it wetter and more favorable for alopecurus, while cattle may 

remove competing taller wetland plant species. This occurrence was most recently surveyed 

several times over the summer of 2000, with plant numbers varying from 60 to 328 individuals. 

The third occurrence was newly discovered on F Ranch in 2000, in a wetland swale between 

semi-stabilized dunes. This occurrence supported 53 individuals when a census was conducted 

in July, 2000. This survey, however, was done late in the blooming season and may not have 

included all of the alopecurus present. 

This alopecurus occurrence is located on land that was recently purchased by the NPS from 

AT&T. This 521-acre tract previously served as a base for telecommunications transmission and 

reception, and has limited development of facilities. Poles bearing transmission wires are 

scattered over part of the parcel, and only minimal ground disturbance for maintaining poles 

takes place. The land is leased to one of the PRNS ranchers for cattle grazing. The two suboccurrences located on this tract supported a total of over 2,100 plants when last surveyed in 

May and July, 2000. 

One historic colony of Sonoma alopecurus, located in a pasture near Mesa Road north of 

Bolinas, has been extirpated since rare plant monitoring began in the park in 1983. Following 

exclusion of cattle from the site by fencing in 1985, it became overgrown with wetland and 

weedy vegetation. Alopecurus was last seen there in July, 1991. 
121 

Efforts to establish new occurrences of Sonoma alopecurus in several locations in PRNS took 

place in the late 1980’s at five sites. By 1990, no alopecurus were found in any of these sites. 

Results of monitoring of Sonoma alopecurus described above suggest that alopecurus thrives in 

wetlands that are grazed just enough to reduce competing vegetation. New occurrences of 

alopecurus may be found in areas of seasonally saturated soils as rare plant surveys continue. 

Such areas are most common in, but not exclusive to, the relatively gentle topography of the 

west-central Point Reyes peninsula. In 2002, four new introduction sites were established and 

are being monitored annually by park staff and volunteers. 

Sonoma spineflower (Chorizanthe valida) – Endangered 

Sonoma spineflower is an annual, growing 10-30 cm tall on sandy soils. A member of the 

Buckwheat family, it is named for its stiff involucral awns. It is thought to have originally been 

widespread in Marin and Sonoma counties, and was believed to have gone extinct during the 

mid-1900s due to agricultural and urban development. In 1976, the species was rediscovered in 

PRNS south of Abbott’s Lagoon in the same pasture on G Ranch in which Sonoma alopecurus is 

located. This population has been monitored by CNPS since 1983. These surveys provide only 

coarse estimates of plant numbers. Survey data show population size ranging from several 

hundred plants in 1983 to 30,000 plants in 1993 (Table 16). The Marin chapter of CNPS has 

actively searched other areas for this plant since its 1980 rediscovery without success, and it is 

considered unlikely that other populations of spineflower will be found. The closely related San 

Francisco Bay spineflower (C. cuspidata var. villosa) is also found at Point Reyes in greater 

numbers and over a larger area, primarily in dune habitat. 

Table 16. Population Estimates for Sonoma Spineflower on G Ranch 1980-2002 (intermittent) 

Year Estimated 

Numbers 

Year Estimated 

Numbers 

Year Estimated 

Numbers 

1980 100 1990 2,000 1998 5,400 

1984 1,000 1991 25,000 1999 23,000 

1986 2,500 1992 27,000 2000 6,200a 

1988 2,500 1993 30,000 2001 16,800a 

1989 3,000 1994 7,570 2002 25,300a 

a/ Survey of sub-population only. 

Monitoring conducted since the mid-1980’s has shown that the Sonoma spineflower can 

experience large variations in numbers from year to year, and estimated plant numbers have 

ranged from as low as several thousand individuals occupying less than 0.4 acres (0.85 ha) to as 

high as 30,000. 

One of the requirements for downlisting Sonoma spineflower is to establish and maintain two 

new populations (USFWS, 1998). Several efforts have been made to establish new occurrences 

from seed within grazed pastures at PRNS. In 1988 seeds were planted in three 2x2 meter plots 

within 100-200 meters of the existing population. Although reproducing spineflowers initially 
122 

grew in all three plots, two of the plots eventually failed. The third, however, has expanded 

outside the original seeded plot and had 690 individuals in 2000. Two smaller seed plots planted 

near the successful plot had 122 plants between them in 2000. 

In 1999, Sonoma spineflower was seeded at F Ranch, in the vicinity of an occurrence last 

observed in 1903. The site chosen for planting is regularly frequented by cattle to the extent that 

the soil is disturbed and competing vegetation is well grazed down. Although it is too early to 

know if the population will persist, 34 plants were counted there in 2000. In 2001, the original 

seeding had 182 plants, while a second and third seeding made in 2000 had 26 and 0 plants 

respectively. In 2002 the original seeding had 80 plants, the second and third seeding had 201 

and 4 plants respectively. In 2002 an additional three seed plots were installed. 

Tiburon paintbrush (Castilleja affinis ssp. neglecta) – Endangered, Marin dwarf flax 

(Hesperolinon congestum) – Threatened, and Robust spineflower (Chorizanthe robusta var. 

robusta) – Endangered 

Approximately 300 acres at the crest of Nicasio Ridge at the northern border of GGNRA’s North 

District contains serpentine soils and rocky outcrops that support a number of serpentine 

endemic plant species. Serpentine soils are found on a relatively flat ridgetop, most of which is 

on private land outside of GGNRA, and on smaller rocky outcrops within GGNRA. 

Tiburon paintbrush is a semi-woody perennial, with erect, branched stems 30 to 60 cm (1 to 2 ft) 

tall. It is known from six locations - one each in Napa and Santa Clara counties, three on Ring 

Mountain in eastern Marin County, and one on Nicasio Ridge. The Nicasio Ridge occurrence 

covers approximately 11 acres on the McIssac Ranch in GGNRA and adjoining private 

ranchland. Tiburon paintbrush grows in association with an evergreen, spiny-leafed ceanothus 

taxa that may be previously not described. The number of Tiburon paintbrush on Nicasio Ridge 

was 100 individuals in 1998, 41 in 1999, 84 in 2000, and 68 in 2001. A survey was not 

conducted in 2002. 

Table 17. Monitoring for Tiburon paintbrush (Nicasio Ridge) 

Year Number of Individuals 

1998 100 

1999 41 

2000 84 

2001 68 

2002 No survey 

Marin dwarf flax is an annual species growing 5-15 cm tall on serpentine grassland from Marin 

to San Mateo counties. It is known from six locations on Nicasio Ridge, with the largest 

occurrence overlapping with the Tiburon paintbrush area extending along the ridgetop from the 

McIssac Ranch into private land. The other five occurrences are located on small rocky outcrops 

on the Cheda, McIssac, and Zanardi ranches. Abundance of Marin dwarf flax on Nicasio Ridge 
123 

appears to vary widely from year to year (Table 18). Survey efforts in 1998-2000 were the same 

but the number of occurrences and estimates of individual plants differed substantially, with new 

occurrences found in 1999 and 2000. This suggests the distribution of Marin dwarf flax on 

Nicasio Ridge is not fully known, and it may appear in other sites in the future due to seed 

dispersal, weather, or localized disturbances. 

Table 18. Occurrences and Estimated Numbers of Marin Dwarf Flax on Nicasio Ridge. 

Occurrence 1998 1999 2000 2001 2002 

#1 157 87 2,000 178 No survey 

#2 56 0 350+b 0 No survey 

#3 a 2 740 No survey No survey 

#4 a a 285 No survey No survey 

#5 a a 350+b 130 No survey 

#6 a a 350+b 182 No survey 

a/ Occurrence not found. 

b/ Observers stopped counting at 350 plants.

Beach layia (Layia carnosa) – Endangered; and Tidestrom’s lupine (Lupinus tidestromii) – 

Endangered 

These two plant species occur in coastal dunes on the western edge of the PRNS peninsula. Both 

have been monitored by CNPS volunteers and PRNS staff since the 1980s. Monitoring reports 

include an estimate of plant numbers, a description of site characteristics, and apparent threats to 

each occurrence. These reports have been assembled in the PRNS Rare Plant Database (NPS, 

2001c). 

Beach layia is an annual, usually prostrate member of the Asteraceae family found in 19 dune 

sites on the northern and central California coast from Humboldt to Santa Barbara counties. It 

has been recorded at 14 sites within the dunes at PRNS, with estimated numbers of individual 

plants varying widely among occurrences (Table 19). Its habitat is the central foredune 

community characterized by some drifting sand and low growing herbaceous and perennial 

species. Beach layia can experience large fluctuations in plant numbers and local distribution 

associated with dune blowouts and restabilization. Such fluctuations have been observed in four 

of the five PRNS occurrences for which counts have been made over multiple years. Five of the 

thirteen beach layia occurrences at PRNS are located in pastures, but plant monitors did not 

consider cattle to be a threat to them. Twelve of the occurrences were considered to be 

threatened by the presence of the non-native European beachgrass (Ammophila arenaria), sea fig 

(Carpobrotus chilensis), and/or Hottentot fig (Carpobrotus edulis) nearby. These perennial, 

rhizomatous non-native species form monotypic stands that virtually exclude less competitive 

native species. 
124 

 Table 19. Beach layia Occurrences and Estimated Numbers of Plants, 2000-2003. 

Population Number 2000 2001 2002 2003 

1 2,140 289 >100 3,129 

2 250 >1,000 no count no survey 

3 667 no survey no survey 7,167 

4 36a 0 481 687 

5 <10 788 no survey 5,199 

6 792 >1,000 no count no surveys 

7 632 no survey >100 no surveys 

8 8 no survey 175 583 

9 1,879 >1,000 no survey no surveys 

10 350 no survey >1,000 9,029 

11 15,000 349 no survey no surveys 

12 15 no survey no survey 1,152 

no # 13 -- -- -- -- 

14 664 no survey no survey 4,427 

15b -- -- no count 8,070 

Total 22,433 >4,000 >2,000 39,444 

a/ Surveyed in 1988. 

b/ New occurrence in 2002.

Tidestrom’s lupine is a small (10-30 cm) decumbent shrub found in 11 areas in dunes from 

southern Sonoma County to Monterey County. It is known from seven occurrences at PRNS, of 

which four have been monitored since the 1980s by CNPS. 

The largest Tidestrom’s lupine occurrence is in the large stable plain behind dunes southwest of 

Abbotts Lagoon, where the taxa is found on an estimated 383 acres. This area was once part of G 

Ranch, but was fenced off from cattle in 1989. This occurrence has been monitored from 1983 to 

the present and appears to be stable. Other occurrences are located north of Abbotts Lagoon and 

further south, near the North Beach parking area and the Old Lifesaving Station. Three of the 

seven occurrences are within pastures but grazing was not considered a threat by plant monitors. 

Six of the occurrences are considered threatened by European beachgrass and ice plant. 

A project to remove non-native species near Abbotts Lagoon will be carried out from 2001-2003. 

The project is focused on areas where native vegetation is still relatively intact and may provide 

an effective means of protecting beach layia, Tidestrom’s lupine, and other native dune species 

from invading non-natives. 

Table 20. Tidestrom's lupine Occurrences and Estimated Numbers, 2000-2002. 

2000 2001 2002 

1 2,000 128,528 157,651 

2 79 12 34 

3 13 33 217 

4 7 35 28 
125 

5 0 0 no survey 

6 5,940 11,181 32,748 

7 64 151 214 

Total 8,103 139,940 190,892 

Robust spineflower (Chorizanthe robusta va. robusta) – Endangered 

In January 2002, plant taxonomists at the Jepson Herbarium confirmed that an unidentified 

Chorizanthe species found in Point Reyes National Seashore was the federally endangered robust 

spineflower (Chorizanthe robusta var. robusta). This is the first time that this species has been 

documented within Seashore lands, and the first time it had been identified within Marin County. 

Prior to this find, robust spineflower was known to occur only in Santa Cruz and Monterey 

counties, in four populations. It is most likely that this species was not identified in Point Reyes 

until recently because of its very similar appearance to two other species of Chorizanthe that 

occur within the same habitat. 

Between 2002 and 2004, surveys were conducted within Point Reyes to determine the species’ 

aerial extent, estimate the number of individuals, and to assess existing and/or potential threats to 

the species. Over 500 acres of potential habitat were surveyed and three robust spineflower 

populations were documented and mapped. In total, these populations were estimated to contain 

over 10,000 individuals. One population, located near Abbot’s Lagoon, occurs in a very popular 

visitor use area. The plants occur near a parking lot, along a roadside, and in a pasture grazed by 

cattle. The proximity of these plants to human activities may result in threats to the long-term 

survival of the population. A management plan, which includes a sampling strategy, is currently 

being developed in order to gather accurate estimates of individual numbers within each 

population. Surveys of potential habitat within the Seashore continue and it is anticipated that 

they will result in additional population locations. 

As noted in Table 15, impacts to this endangered plant are not analyzed in the Environmental 

Consequences section because the FMP does not treat the area where the robust spineflower is 

located. 

Other Plant Species of Concern 

Tables 21 and 22 below shows several plant species in the affected area are listed as federal 

“species of concern.” Species of concern are species for which USFWS is collecting additional 

information to determine if they warrant consideration for future listing. In addition, two species 

(Point Reyes blennosperma and Mason’s ceanothus) are considered rare by the state of 

California, one species is state endangered (Point Reyes meadowfoam) and all plant species in 

the table are on California Native Plant Society lists. In Alternative A, although no federal or 

state listed species have been found in FMUs that would be treated with prescribed fire, one state 

rare species (Mason’s ceanothus) is present in the Bolinas Ridge FMU. Bolinas ceanothus does 

not occur in any FMUs slated for mechanical treatment in this alternative. Several federal species 

of concern are present in Estero and Limantour Road FMUs, which would be treated with both 

prescribed fire and mechanical thinning. 
126 

Although these species are not listed under the federal Endangered Species Act, NPS 

Management Policies (2000) state that the Service will inventory, monitor and manage state and 

locally listed species in a manner similar to its treatment of federally listed species, and will 

inventory other species that are of special management concern to parks (such as rare, declining, 

sensitive or unique species). 

Table 21. Plant Species of Concern and California-listed Species that may Occur in Areas 

Affected by PRNS’s Fire Management Plan (per USFWS Letter, May 24, 2001). 

Common Name Scientific Name Known to 

Occur 

Potentially Subject 

to Adverse Impacts

Comments 

pink sand verbena Abronia umbellata 

ssp.breviflora 

yes no on coastal strand 

Blasdale's bentgrass Agrostis blasdalei var. 

blasdaleib

 

yes yes 

Tamalpais manzanita Arctostaphylos hookeri ssp. 

Montana 

no no 

Point Reyes stickyseed Blennosperma nanum var. 

robustum 

yes yes 

Thurber’s reedgrass Calamagrostis crassiglumisc yes no not in action FMUs 

swamp harebell Campanula californica yes yes 

Humboldt Bay owl'sclover Castilleja ambigua ssp. 

Humboldtiensis 

yes no in wetlands 

Mt. Vision ceanothus Ceanothus gloriosus var. 

porrectus 

yes yes 

Mason's ceanothus Ceanothus masonii yes yes 

San Francisco Bay 

spineflower 

Chorizanthe cuspidata var. 

cuspidata 

yes no in stabilizing dune 

habitats 

Mt. Tamalpais thistle Cirsium hydrophilum var. 

vaseyi 

no no not in action FMUs 

Tomales clarkia Clarkia concinna ssp. raichei no no 

northcoast bird's-beak Cordylanthus maritimus ssp. 

Palustris 

yes no in salt marsh habitat 

supple daisy Erigeron supplex extirpated no 

San Francisco 

wallflower 

Erysimum franciscanum no no 

fragrant fritillary Fritillaria liliacea yes yes 

San Francisco gumplant Grindelia hirsutula var. 

maritima 

yes yes 

Tiburon tarweed Hemizonia multicaulis ssp. 

Vernalis 

no no not in action FMUs 

Kellogg’s horkelia Horkelia cuneata ssp. sericea no no 

Point Reyes horkelia Horkelia marinensis yes no in grazed pastures 

Tamalpais lessingia Lessingia micradenia var. 

micradenia 

no no 

coast lily Lilium maritimum yes no in grazed pastures 

Pt. Reyes meadowfoam 

(CE)a 

Limnanthes douglasii ssp. 

Sulphurea 

yes yes 

Gairdner’s yampah Perideridia gairdneri ssp. 

Gairdneri 

yes yes 

northcoast phacelia Phacelia insularis var. 

continentis 

yes yes 

San Francisco 

popcornflower 

Plagiobothrys diffusus d yes no not in action FMUs 
127 

northcoast semaphore 

grass 

Pleuropogon hooverianus no no 

Marin knotweed Polygonum marinense yes no in salt marsh 

California beaked-rush Rhynchospora californica extirpated no 

valley sagittaria Sagittaria sanfordii no no 

Marin checkerbloom Sidalcea hickmanii ssp. 

Viridis 

no no 

Santa Cruz microseris Stebbinoseris decipiens no no 

Tamalpais streptanthus Streptanthus batrachopus no no 

San Francisco 

owl's-clover 

Triphysaria floribunda yes yes 

a/ CE: Listed as endangered under the California Endangered Species Act 

b/ Recognized by The Jepson Manual (1993) as A. densiflora 

c/ Recognized by The Jepson Manual (1993) as C. stricta ssp. inexpansa 

d/ Recognized by The Jepson Manual (1993) as P. reticulatus var rossianor 

 

Table 22. Additional Plant Species of NPS Management Concern that Occur in Areas Affected 

by PORE's Fire Management Plan 

Common Name Scientific Name CNPS List Potentially Subject 

to Adverse Impacts

Comments 

coast rock cress Arabis blepharophylla 4 yes 

Marin manzanita Arctostaphylos virgata 1B yes 

coastal marsh milk-vetch Astragalus pycnostachyus var. 

pycnostachyus 

1B no in coastal strand 

habitat 

coastal bluff morningglory Calystegia purpurata ssp. 

Saxicola 

1B yes 

Buxbaum’s sedge Carex buxbaumii 4 no in wetlands 

glory brush Ceanothus gloriosus var. 

exaltatus 

4 yes 

Point Reyes ceanothus Ceanothus gloriosus var. 

gloriosus 

4 yes 

unnamed ceanothus Ceanothus sp. nov. - no in grazed pastures 

woolly-headed 

spineflower 

Chorizanthe cuspidata var. 

villosa 

1B no in sandy dune habitat

Franciscan thistle Cirsium andrewsii 1B yes 

western leatherwood Dirca occidentalis 1B no not in action FMUs 

California bottlebrush 

grass 

Elymus californicus 4 yes 

Marin checker lily F. affinis var. tristulis 1B yes 

dune gilia Gilia capitata ssp. chamissonis 1B no in sandy dune habitat

dark-eyed gilia Gilia millefoliata 1B no in sandy dune habitat

white hayfield tarplant Hemizonia congesta ssp. 

Leucocephala 

3 yes 

short-leaved evax Hesperevax sparsiflora var. 

brevifolia 

2 no in grazed grassland 

perennial goldfields Lasthenia macrantha ssp. 

Macrantha 

1B yes 

delta mudwort Limosella subulata 2 no in mud flats 

large-flowered linanthus Linanthus grandiflorus 4 yes 

rosy linanthus Linanthus rosaceus 1B yes 

marsh microseris Microseris paludosa 1B yes 

Point Reyes rein-orchid Piperia elegans ssp. decurtata 1B yes 
128 

nodding semaphore 

grass 

Pleuropogon refractus 4 yes 

Point Reyes 

checkerbloom 

Sidalcea calycosa ssp. rhizomata 1B no in wet areas 

beach starwort Stellaria littoralis 4 yes 

Mt. Tamalpais 

jewelflower 

Streptanthus glandulosus ssp. 

Pulchellus 

1B no 

NOTES: 1 CNPS = California Native Plant Society (Skinner and Pavlik 1994) 

Listing Significance: 

List 1B: Plants Rare, Threatened, or Endangered in California and Elsewhere 

List 2: Plants Rare, Threatened, or Endangered in California, but More Common Elsewhere 

List 3: Plants About Which We Need More Information - A Review List 

List 4: Plants of Limited Distribution - A Watch List 

Special-Status Wildlife 

The following threatened or endangered animal species are those listed under the Endangered 

Species Act and considered likely or possible to experience impacts from fire management 

activities: Northern spotted owl (Strix occidentalis caurina), California red-legged frog (Rana 

aurora draytonii), Central California coho salmon (Oncorhynchus kisutch), Central California 

Coast steelhead (Oncorhynchus mykiss), California freshwater shrimp (Syncaris pacifica), 

Myrtle’s silverspot butterfly (Speyeria zerene myrtleae), Western snowy plover (Charadrius 

alexandrinus nivosus). All listed, proposed, or candidate animal species in the study area are 

listed in Table 24. A section on animal species not listed under the Endangered Species Act, but 

of concern to federal or state agencies follows. 

Federally listed animal species 

Northern Spotted Owl (Strix occidentalis caurina) - Threatened

Habitat within the project area supports one of the densest populations of Northern spotted owl 

in the world. In Marin County, the owls live in second growth Douglas-fir (Pseudotsuga 

menziesii), Bishop pine (Pinus muricata), coast redwood (Sequoia sempervirens), mixed coniferhardwood and evergreen hardwood forests as well as remnant old-growth stands of coast 

redwood and Douglas-fir. The habitat types for the Northern spotted owl are defined as multilayered, multi-species with >60% total canopy cover for nesting/roosting with large overstory 

trees, large amounts of down woody debris, presence of trees with defects or signs of decadence 

in the stand. Small isolated pieces of habitat are not regarded as suitable. Northern spotted owls 

are residents throughout PRNS and GGNRA and occur in habitat types that are atypical when 

compared to other areas of the species range. For example, owls have been observed nesting in 

young bay (Umbellularia californica) trees in small stands. Nevertheless, most nesting and 

roosting sites do occur in older, decadent stands of conifer and hardwood trees with large 

overstory trees. Preliminary pellet analyses indicate that spotted owls in Marin forage primarily 

on dusky-footed woodrats (Neotoma fuscipes) as well as other small mammals and forestdwelling birds (Chow and Allen, 1998). The Northern spotted owl is found in the Inverness 

Ridge FMU, eastern Limantour FMU, North and South Wilderness FMUs, Highway One and 

Bolinas FMUs. 

The Northern spotted owl (Strix occidentalis caurina) was federally listed as threatened in 1992 

(USFWS 1993). A 1⁄4 mile radius buffer zone must be protected around active nest sites to 

protect the birds from the impacts of noise and smoke. A severe wildfire may alter the owl's 
129 

habitat, making it unsuitable for the species. The degree of habitat modification that can occur 

within a given radius of an owl activity site is regulated by the California Code of Regulations, 

Title 14, §919.9(g)(1) addressing Wildlife Protection Practices for the Northern Spotted Owl. 

The parks contain approximately 35,000 acres of potential northern spotted owl habitat. 

Extensive surveys of habitat use, distribution and abundance have been conducted since 1993 by 

the NPS and these surveys will continue. A recent census estimated a population of 

approximately 49 owl activity centers (Chow and Allen, 1996, Chow and Allen, 1998, Fehring 

and Adams, 2001, NPS, 2002b). The parks initiated a demographic study of owls in 1998 and 

have been banding owls annually under permit from the USFWS (Permit # 842449). The overall 

population trend is unknown, but we believe the population is stable because the number of 

activity centers has been similar among years since 1998 when an inventory was completed of 

the park. Table 23 describes each of the occupied site’s history to date. 

While conducting an inventory of owls within the parks following USFWS protocols, biologists 

noted the habituation of owls to people, resulting in owls approaching people in campgrounds. 

Consequently, the parks developed a modified protocol from the USFWS protocol to reduce 

interactions with owls during surveys. The modified protocol was developed in collaboration 

with USFWS, and resulted in a reduction in the use of mice to confirm owl presence and 

productivity. 

No critical habitat for the spotted owl has been designated within PRNS or the Northern District 

of GGNRA, although much of the parks contain high quality owl habitat. Critical habitat was 

not designated because the park habitat is protected from adverse effects due to its National Park 

status. The park is in the process of analyzing habitat associations of occupied sites and nest site 

descriptions. The Point Reyes Bird Observatory, in collaboration with the NPS, will have a final 

report completed on this analysis in 2003. 

Table 23. Site History of Northern Spotted Owl Activity Centers within PRNS and the Northern 

District of GGNRA 

Marin County Spotted Owl Activity 

Site Number 

Landowner Survey Purpose Survey Years 

MR001 TBSP Demography 1997-2001 

MR002 TBSP Demography 1997-2002 

MR003 PVT Inv/Mgmt 1997-1998, 2002 

MR004 PRNS Demography 1997-2002 

MR005 PRNS Demography 1997-2002 

MR006 PRNS Inv/Mgmt 1997-1998,2001-2002 

MR007 PRNS Demography 1997-2002 

MR008 PRNS Inv/Mgmt 1998, 2002 

MR012 PVT Demography 1997-2002 

MR018 PRNS Demography 1997-2002 

MR021 PVT Inv/Mgmt 1997-1998, 2001-2002 

MR022 PRNS Demography 1997-2002 

MR023 PRNS Inv/Mgmt 1998, 2002 

MR024 PRNS Inventory 1997-1998 

MR026 PVT Inventory 1997-1998 
130 

MR027 TBSP Demography 1997-2002 

MR028 PVT Inv/Mgmt 1997-1998, 2002 

MR029 PVT Demography 1997-2002 

MR030 PRNS Demography 1997-2002 

MR031 PVT Demography 1997-2002 

MR032 PVT Inventory 1997-1998 

MR033 PVT Inventory 1997-1998 

MR034 GGNRA Demography 1997-2002 

MR035 GGNRA Demography 1997-2002 

MR039 GGNRA Demography 1997-2002 

MR040 GGNRA Demography 1997-2002 

MR041 GGNRA Demography 1997-2002 

MR046 PVT Demography 1997-2002 

MR047 TBSP Demography 1997-2002 

MR048 TBSP Inventory 1997-1998 

MR049 PRNS Demography 1997-2002 

MR050 PRNS Demography 1997-2002 

MR051 PRNS Demography 1997-2002 

MR052 PRNS Demography 1998-2002 

MR053 PVT Inventory 1997-1998 

MR054 GGNRA Demography 1997-2002 

MR056 TBSP Inv/Mgmt 1997-1998, 2001-2002 

MR057 PRNS Demography 1997-2002 

MR058 GGNRA Demography 1997-2002 

MR059 PRNS Demography 1997-2002 

MR063 PVT Inv/Mgmt 1998, 2002 

MR064 GGNRA Demography 1998-2002 

MR067 PVT Demography 1998-2002 

MR068 GGNRA Demography 1998-2002 

MR069 GGNRA Demography 1997-2002 

MR070 PRNS Inventory 1997 

MR072 GGNRA Demography 1998-2002 

TBSP (Tomales Bay State Park), PVT (Private land adjacent to Seashore boundaries). Source: Marin County Spotted Owl 

Database, PRNS, CA. 

Thirty-two sites in PRNS and North District GGNRA are included in a long-term demographic 

study. Other sites were included in an inventory of all spotted owl habitat on federal lands 

conducted in 1997 and 1998. A subset of these sites were monitored in 2001 and 2002 because 

of their proximity to Wildland-Urban Interface Hazardous Fuel Reduction Projects at PRNS. 

Red-legged Frog (Rana aurora draytonii) – Threatened

PRNS and GGNRA support one of the largest known populations of California red-legged frogs. 

This frog frequents marshes, slow parts of streams, lakes, stock ponds, and other usually 

permanent waters. The frog is generally found near water but disperses during rain events and 

after breeding season to non-breeding habitat adjacent to water bodies. The non-breeding habitat 

is usually a moist area with some cover such as a willow or blackberry thicket. 

The U.S. Geological Survey Biological Resources Division (USGS-BRD) has conducted surveys 

of aquatic habitats in PRNS and GGNRA since 1993 under the direction of Dr. Gary Fellers. 
131 

Survey protocol is adapted from USFWS practices and has been published as a NPS Technical 

Report (Fellers & Freel, 1995). 

Surveys have been conducted on virtually all sites containing aquatic habitat that could support 

amphibians. Field data includes information on habitat type (permanent or seasonal, natural or 

created), water characteristics, (depth, flow, turbidity, etc.), vegetation (emergent, floating, and 

surrounding the site), disturbance, including current grazing, and the age classes and physical 

condition of amphibians found. 

Field surveys have led to documentation of numerous sites used by the California red-legged 

frog; sites have been mapped in a geographically related database. Approximately 76 sites are 

located on ranch lands, with a large proportion located at stock ponds. A breakdown of sightings 

according to the type of habitat use observed (breeding vs. non-breeding, upland dispersal vs. 

other upland habitat use, etc.) has yet not been made, since survey work is ongoing and it is 

believed that new locations will be detected. It is likely that further surveys will document 

additional red-legged frog sites at PRNS/GGNRA. Several new breeding sites have recently been 

found along tributaries of Olema Creek. Several large bodies of water, such as Abbott’s Lagoon, 

are expected to yield new sites during a planned boat survey, which will allow more thorough 

coverage than has been attained by foot surveys. In FY04, PRNS plans to survey the wilderness 

area of the park to determine additional breeding and non-breeding habitat. 
132 

Table 24. Federal Threatened, Endangered, Candidate, and Proposed Animal Species that May 

Occur in Areas Affected by PRNS's Fire Management Plan (per Attachment A in USFWS Letter, 

May 24, 2001). 

Common Name Scientific Name Listing 

Statusa 

Known to 

Occur 

Potentially Subject to 

Adverse Impactsb 

Mammals 

 

blue whale Balaenoptera musculus E rare Nob

finback (=fin) whale Balaenoptera physalus E rare Nob

gray whale Eschrictus robustus D yes Nob

Guadalupe fur seal Arctocephalus townsendi T yes Nob 

humpback whale Megaptera novaeangliae E yes Nob 

right whale Eubalaena glacialis E no No 

sei whale Balaenoptera borealis E no No 

sperm whale Physeter catodon 

(macrocephalus) 

E yes Nob 

Steller (=northern) sea-lion Eumetopias jubatus T yes Noc 

Birds 

 

Aleutian Canada goose Branta canadensis E rare Nob 

American peregrine falcon Falco peregrinus anatum D yes No

bald eagle Haliaeetus leucocephalus T rare No

California brown pelican Pelecanus occidentalis 

californicus 

E yes No

California clapper rail Rallus longirostris obsoletus E yes No 

greater sandhill crane Grus canadensis tubida T rare No 

marbled murrelet Brachyramphus marmoratus T yes No 

northern spotted owl Strix occidentalis caurina T yes Yes

short-tailed albatross Diomedea albatrus PE rare Nob 

western snowy plover Charadrius alexandrinus 

nivosus 

T yes No 

Reptiles 

 

green turtle Chelonia mydas (incl. agassizi) T rare Noc 

leatherback turtle Dermochelys coriacea E yes Noc 

loggerhead turtle Caretta caretta T rare Noc 

olive (=Pacific) ridley sea 

turtle 

Lepidochelys olivacea T rare Noc 

Amphibians 

 

California red-legged frog Rana aurora draytonii T yes Yes 

California tiger salamander Ambystoma californiense C no No 

Fish 

 

central California coho 

salmon 

Oncorhynchus kisutch T yes Yes 

central California coast 

steelhead 

Oncorhynchus mykiss T yes Yes 

delta smelt Hypomesus transpacificus T unknown No 

Sacramento splittail Pogonichthys macrolepidotus T unknown No 
133 

So. OR/CA coastal chinook 

salmon 

Oncorhynchus tshawytscha T no No 

threespine stickleback Gasterosteus aculeatus 

williamsonii 

E no No 

tidewater goby Eucyclogobius newberryi E no No 

Invertebrates 

 

black abalone Haliotes cracherodii C yes Nob 

California freshwater shrimp Syncaris pacifica E yes Yes

Myrtle’s silverspot butterfly Speyeria zerene myrtleae E yes Yes 

white abalone Haliotes sorenseni PE no No 

a. Listing status: E: Endangered T: Threatened C: Candidate PE: Proposed Endangered D: Delisted 

b. Offshore marine species (e.g., whales, pelagic birds) are expected to receive little to no impact from fire management 

activities. Fire management activities such as prescribed fires and mechanical treatments are not planned to occur adjacent to

coastal bluffs, beaches, or dunes and smoke will be directed away from any marine mammal sites. Unplanned wildfire and 

associated suppression activities could occur in these areas and very minor impacts could occur if wildland fire reduces 

vegetation cover near coastal bluffs, and sediments are removed from the bluffs and deposited in coastal waters. These sediments 

would be quickly diluted when they reach the ocean, and impacts to marine species are expected to be insignificant. 

c. Species that use beaches as haulouts may be disrupted by unplanned wildfire and the associated suppression activities. Impacts 

could be caused by smoke or by sedimentation as mentioned in the previous paragraph. Among Threatened and Endangered 

species, however, such habitat use is restricted to marine turtles, which are unlikely to occur at PRNS. Steller’s sea-lions are 

more likely to use rocky shorelines as haulouts. 

Creation of stock ponds and other small impoundments on ranches over the past 100 years has 

likely resulted in increased numbers and an expansion in range for red-legged frogs in the PRNS 

area (G. Fellers, pers. comm.). Frogs appear to move readily between these ponds during periods 

when the ground is moist, which is prolonged on the foggy PRNS peninsula. Numerous wet 

swales, seasonal springs, and ephemeral pools provide dispersed travel and feeding habitats. In 

GGNRA, riparian habitat along creeks provides corridors for travel along the Olema Valley and 

its tributaries. 

PRNS, GGNRA, and adjoining areas of Marin County comprise one of the 57 core areas for 

focused recovery of red-legged frogs established in the Final Recovery Plan for the species. 

Much of the project area falls within the recently established criteria for red-legged frog critical 

habitat. The central peninsula has roughly 75 stock ponds in an area extending from the Kehoe 

Ranch near Pierce Point south to Point Reyes itself and east to Tomales Bay, Mt. Vision, and the 

Laguna Ranch (now the Clem Miller Environmental Education Center). Approximately 50 of 

these ponds are located on land currently used for ranching, with most of the remaining 25 on 

former ranch lands on Inverness Ridge and above Limantour Estero. Most of these ponds retain 

water at least 20” deep well into the summer, and a number are perennial in typical rainfall years. 

Evidence of breeding red-legged frogs has been observed in many of these ponds. Pond habitat 

and several perennial creeks are densely clustered on the Point. Distances of under 1.25 miles 

separate one or more adjacent aquatic habitats, and the ground between them is suitable for redlegged frog overland movement. Traffic along Sir Francis Drake Boulevard, the only major 

potential barrier to movement, is less than 30 cars per hour on late fall and winter nights, when 

adult red-legged frogs are most likely to be traveling overland. The habitat area for red-legged 

frogs on central Point Reyes encompasses all of the grazing land there. 
134 

A second interconnected habitat area extends along the Olema Valley, where the perennial 

segment of Olema Creek links scattered off-stream aquatic habitats from the vicinity of Point 

Reyes Station south approximately 13.5 km. Stock ponds are less common in the Olema Valley 

than on the peninsula, numbering less than 20. Red-legged frogs have been observed in most of 

the tributaries on the eastern side of Olema Creek, where ranching occurs. 

Suitable habitat along Olema Creek and its tributaries may have been adversely affected by 

geomorphologic instability associated with historic logging of parts of Inverness Ridge, channel 

alterations in the lower 2.8 km of Olema Creek, and the effects of highway culverting. Areas of 

downcutting, bank cutting, and sedimentation are present along the mainstem and its tributaries, 

resulting in a probable reduction in numbers of backwaters and pools. 

Red-legged frogs have also been found on Bolinas Mesa and at several ponds on top of Bolinas 

Ridge. Since frogs could be present in unsurveyed locations on Inverness Ridge, and could 

travel along seasonally wet riparian corridors over the ridge, all the red-legged frog sighting 

locations have been linked into one metapopulation. 

Potential impacts of projects on red-legged frog aquatic habitats is summarized in Table 25, 

which is based on pages 31-34 of the Draft Recovery Plan. 

Table 25. Potential Impacts on Red-legged Frog Aquatic Habitats 

Impact Potential Effect on CRLF Habitat 

Emergent vegetation removed 

Emergent vegetation necessary for amplexus and anchoring 

egg masses. Excessive levels may reduce sunlight needed 

for growth of algae, which is chief larvae food. 

Shading vegetation removed (emergent and bank 

side) 

Chiefly harmful to adults, for whom shaded refugia may be 

critical in drier inland areas during the summer. 

Insect habitat vegetation removal 

Harmful to adults and juveniles that mainly feed on 

invertebrates for which bank side vegetation is prime 

habitat. 

Excess water drawdown in ponds Leave egg masses stranded on vegetation 

Change hydrological regime by accelerating runoff Pools may dry before metamorphosis completed 

Riparian Areas 

Based on survey data, the most important riparian areas for red-legged frogs in PRNS/GGNRA 

are those with relatively low gradient that have late season water flow or water retention in 

pools. On Point Reyes itself, such creeks support relatively few of the documented occurrences 

of the frogs, but they may serve as connector and refuge habitats. The most important of these 

are Kehoe Creek and Abbotts Lagoon Creek on the north end of the peninsula, and Schooner 

Creek, which drains into Drakes Estero. 

In GGNRA and PRNS, Olema Creek is the most significant habitat for red-legged frogs. 

Approximately one-third of its length is outside of the ranching zone, while the remainder is 

fenced off from direct access by cattle along its entire length. The character of Olema Creek 

changes near the town of Olema, where it develops a substantial floodplain that extends to Sir 
135 

Francis Drake Blvd., just before the confluence with Lagunitas Creek. Several slough-like 

channels occur in the floodplain, fed either by Olema Creek or several tributaries that empty onto 

it. Since the mid 1990s, Olema Creek has recaptured its historic floodplain, to the north of the 

Olema Ranch Campground. This 9 acre floodplain is permanently excluded from livestock 

access and supports a diverse recovering riparian floodplain and willow flat. While these sloughs 

appear to be suitable as breeding habitat for red-legged frogs, there are no records from this area. 

Egg masses may be washed out by high flows or juveniles eaten by herons and other predators. 

A Biological Opinion regarding agricultural operations within the Seashore, completed by the 

USFWS in 2002, addresses all issues related to ongoing ranch operations within lands known to 

support the California red-legged frogs. 

Stock Ponds 

Red-legged frogs have been detected in over 40 of the stock ponds scattered over PRNS and 

another 10 in GGNRA. Many of the ponds have minimal shading vegetation, although this may 

be a characteristic of the pond site rather than cattle presence. This is especially true on the 

Point, where trees are relatively sparse in the grassland and dune areas. Emergent vegetation also 

varies by pond, but overall is considered to be enough for red-legged frog reproduction but not 

excessive, which would reduce open water needed by larvae and the algal growth they feed on 

(G. Fellers, pers. comm.). 

Observations on vegetation surrounding ponds, and on percent cover of pond surfaces by 

emergent and floating vegetation is part of the data collected in amphibian survey work. The 

extent to which presence of such vegetation beyond minimal levels is important to red-legged 

frog reproduction is not clear. In an effort to identify the optimal level of emergent and 

submerged vegetation for red-legged frogs, biologists at the East Bay Regional Park District used 

data from 265 ponds located in their parks, which together support an estimated 500-600 

breeding adult frogs. Presence of frogs was compared at ponds with three levels of vegetation 

cover: no cover, cover less than 15%, and cover more than 15%. No significant differences in 

the presence of red-legged frog larvae, juveniles, and adults were found (S. Bobzien, pers. 

comm.). 

Central California Coast Coho Salmon (Oncorhynchus kisutch) – Threatened and Central 

California Steelhead (Oncorhynchus mykiss) - Threatened

Central California coast coho salmon and Central California steelhead (hereafter referred to as 

coho and steelhead) occur in several creeks on the Point Reyes peninsula and in the Lagunitas 

Creek watershed that drains portions of PRNS and GGNRA. Coho salmon and steelhead trout 

are found in the Olema, Lagunitas and Pine Gulch Creek watersheds. Steelhead trout are also 

found in the Tomales Bay, Drakes Estero, and Bolinas watersheds. 

Designated critical habitat for coho in PRNS includes all accessible estuarine and stream areas in 

the coastal watersheds of Marin County except areas above longstanding, naturally impassable 

barriers or above Peters Dam on the mainstem of Lagunitas Creek and Seeger Dam on Nicasio 

Creek (NOAA Fisheries, 1996). Although critical habitat has not been established for central 

California steelhead, it is likely to be the same as that for coho in Marin County. 
136 

Dating back to the late 1800s, West Marin County was a popular destination for salmon fishing. 

Records of salmon hatchery releases to Lagunitas Creek and even Bear Valley Creek occurred 

even in the 1890s. Lagunitas Creek (then known as Papermill Creek) still holds the distinction 

as having produced the state record, 22 pound, coho salmon (caught by Milton T. Hain, January 

3, 1959). Interviews with long time residents and fisheries managers suggest that coho and 

steelhead in the project area have been declining since the turn of the century, with significant 

declines occurring as late as the mid-1950’s. Most historic information on salmonid numbers is 

anecdotal, while quantified data are lacking. Accounts by local residents of “excellent trout 

fishing” along Lagunitas and Olema creeks may refer to young steelhead, which are 

indistinguishable from rainbow trout during the three year period they typically spend in fresh 

water. Similarly, early accounts of “salmon runs” may refer to both coho and steelhead, which 

may not have been distinguished by fishermen. Such anecdotal information suggests that 

salmonids were abundant in the Lagunitas/Olema Creek drainage before extensive alteration by 

dam-construction, logging, and channelization. On its 1996 federal listing, the Lagunitas 

watershed, including Olema Creek, was documented to support 10% of the Central California 

Coast coho population (Brown et al., 1994, NOAA Fisheries, 1996). 

NOAA Fisheries designated critical habitat for coho salmon to include all accessible reaches of 

rivers (including estuarine areas and their tributaries) (NOAA Fisheries, 1999). Through this 

designation, NOAA Fisheries identified ten essential features of critical habitat including: 

substrate, water quality, water quantity, water temperature, water velocity, cover/shelter, food, 

riparian vegetation, space, and safe passage conditions. 

The Magnuson-Stevens Fishery Conservation and Management Act, as amended by the 

Sustainable Fisheries Act of 1996 (PL 104-267), established new requirements for Essential Fish 

Habitat (EFH). Coho salmon and Chinook salmon are managed under Federal Fishery 

Management Plans, steelhead are not. Therefore, EFH conservation recommendations address 

only coho salmon, and not steelhead trout. Watersheds supporting coho salmon associated with 

the project are also protected under EFH regulations. 

Reliable quantitative survey data for coho salmon dates from 1948, when the California 

Department of Fish and Game (CDFG) began annual surveys of coho numbers and spawning 

activity on Devil’s Gulch, a tributary of Lagunitas Creek. Survey work on the Lagunitas 

mainstem began in the winter of 1982-83 by consultants to the MMWD. Beginning in the mid 

1980s, biologists began collecting juvenile information and some smolt trapping was conducted 

on Lagunitas Creek. 
137 

Figure 16. Location of FMUs in Relation to FMP Watersheds 
138 

Historic and current data on coho and steelhead populations for Lagunitas, Olema, and Pine 

Gulch Creek watersheds have been gathered as part of the Coho salmon and Steelhead trout 

Restoration Program (CSRP) and the Marin Municipal Water District. Through the CSRP, the 

NPS has established a detailed fisheries monitoring program that is carried on through support 

from the Natural Resource Challenge Inventory and Monitoring Program, as well as monitoring 

support through California Department of Fish and Game managed grant programs. 

For most drainages, monitoring has focused on coho salmon, but includes equivalent information 

for steelhead trout. Differences between steelhead trout and coho salmon life cycles are 

pertinent to conservation efforts. While virtually all coho in project area watersheds have an 18 

month freshwater life cycle, steelhead juveniles may migrate to the ocean after 18 months or 

extend freshwater residence for up to three years. Most coho return to spawn after 18 months, 

but steelhead may spend several years in the ocean before returning to spawn. Additionally, 

steelhead may make several spawning migrations while all coho spawn once and die. The 

variable life cycle of steelhead makes population analysis more difficult, but also makes them 

more resilient to adverse environmental conditions. In general, if the habitat requirements for 

coho are met, steelhead habitat requirements will also be met. 

Estimates for adult coho escapement (numbers of spawning coho), were derived using the Peak 

Live plus accumulated Dead (PLD) index method, in which the highest count of living fish found 

in a single survey is added to the cumulative number of dead fish counted up to that time. The 

PLD index provides a minimum count of spawning fish in a season, based upon actual field 

observation. While the PLD index is best when peak numbers are counted, visibility and flow 

conditions are highly variable and can affect the quality of a field survey. The PLD is interpreted 

as an indication of spawning success, along with other monitoring parameters including redd 

counts, summer juvenile densities, and smolt outmigration, it can be used to as an indicator of 

population condition. 

In conjunction with adult escapement surveys, the NPS staff and volunteers document redds, or 

egg nests. Because redds are often visible long after fish have spawned, and they can be marked 

to avoid double counting, it has been used in the watershed as an indices of the spawning run. 

However, since coho and steelhead may construct false redds, and redds may be washed over or 

difficult to distinguish, these data are best used to indicate spawning activity between years and 

watersheds. In the last five years, adult escapement monitoring efforts by the MMWD, PRNS, 

and other local organizations have included detailed redd counts. 

Review of historical spawner abundance data supports anecdotal evidence of declining numbers 

of coho over the last 50 years. This corresponds to a similar trend region-wide. Since the mid1990s, current monitoring effort shows that populations of both coho salmon and steelhead trout, 

while fluctuating, within the project area, remain persistent, and are considered stable. 

Fisheries information are summarized by watershed areas as described in the Water Resources 

section. 

Tomales Bay Watershed. The Tomales Bay watershed includes all of the small watersheds 

draining from Inverness Ridge and Bolinas Ridge directly to the Bay. The largest of these 
139 

watersheds, Bear Valley Creek is included within the Limantour Road FMU. In addition, the 

watershed includes small portions of the Tomales Point, Wilderness North, and Inverness Ridge 

FMUs. The watersheds within the each of these FMUs, with the exception of Tomales Point, 

support habitat for steelhead trout. No quantitative fisheries monitoring beyond 

presence/absence surveys have been conducted in these systems. 

Lagunitas Creek Watershed. Lagunitas Creek and its tributaries (Nicasio Creek, San Geronimo 

Creek, Devil’s Gulch, Cheda Creek, Bear Valley Creek, and Olema Creek) drain more than 230 

square kilometers of western Marin County. The headwaters of the Lagunitas Creek mainstem 

lie within the 53,000 ha watershed lands administered by MMWD. The mainstem originally 

totaled about 40 km of perennial stream draining the northern slope of Mt. Tamalpais, but was 

reduced by more than 50% by construction of Alpine Dam in 1918 and Peters Dam in 1953. 

Because neither dam has provision for fish passage, their construction resulted in permanent loss 

of the upper portion of the drainage to anadromous fish. 

The portions of the Lagunitas drainage most significant for salmonids are under a number of 

ownerships. Approximately 12 km of the mainstem is bordered by lands within GGNRA. A 

major tributary, San Geronimo Creek, flows through privately held land in San Geronimo 

Valley. Devil’s Gulch lies almost entirely within Samuel P. Taylor State Park with its 

headwaters in GGNRA. Only one smaller tributary of Lagunitas Creek, Cheda Creek, lies 

entirely within GGNRA lands. Within the Lagunitas Creek watershed, the Bolinas Ridge FMU 

is the only active unit. 

Lagunitas Creek has long supported populations of coho salmon and steelhead trout. Recent 

monitoring efforts within Lagunitas Creek have identified the presence of Chinook salmon for 

the past four years (MMWD, 2003) with less frequent occurrences of chum and even pink 

salmon. 

Coho numbers for the Lagunitas watershed taken as a whole based on surveys of 36 km of the 

mainstem and its tributaries, including Olema Creek, Devil’s Gulch, and San Geronimo Creek, 

are shown in Table 26. Surveys were conducted during three periods between 1982-2003. 

Surveys differed in coverage and data gathered, but show an increasing trend in number of redds 

located. Total numbers of spawning coho using the drainage are suggested by PLD Index value 

high counts of 525 fish in 1996/97. 

Table 26. Coho Salmon Spawning Survey Data for Overall Lagunitas Creek Watershed 

Year Number of 

Surveys 

Survey Area 

(km) 

PL 

Indexc

Total 

Carcasses 

Total New 

Redds 

Source 

1982/83a 6 22.4 n.a. n.a. 139 Bratovich & Kelly 1988

1983/84a 6 22.4 n.a. n.a. 44 Bratovich & Kelly 1988

1991/92a

 1 20.0 n.a. n.a. 41 Wise 1992 

1995/96b 10 36 290 n.a. 86 Trihey & Assoc. 1996 

1996/97b

 8 36 525 92 254 Trihey & Assoc. 1997 

1997/98b

 10 36 241 112 360 MMWD, PRNS 

1998/99b

 10 36 147d 34 227 MMWD, PRNS 

1999/00b

 14 36 496d 65 220 MMWD, PRNS 

2000/01b

 14 36 380d 130 338 MMWD, PRNS 
140 

2001/02b

 15 36 463d 146 375 MMWD, PRNS 

2002/03b 13 36 463d 60 175 MMWD, PRNS 

a/ Does not include Olema Creek and its tributaries. 

b/ Includes Olema Creek and its tributaries. 

c/ PLD Index = Peak Live and Cumulative Dead Index; n.a. = not available. 

d/ Mainstem Lagunitas estimate based on total live coho observations and may include repeat sightings of same fish 

MMWD = Marin Municipal Water District data; PRNS = Point Reyes National Seashore data 

As discussed earlier, PL index data have not been consistently gathered for all creeks in the 

project area and can vary in quality depending on the number of surveys conducted and other 

factors. Data on the number of new redds provides a good overview of recent spawning activity 

in PRNS watersheds (Table 27). These data indicate the high annual variability in coho 

spawning activity and the relative importance of Olema Creek to spawning in the Lagunitas 

Creek drainage. 

Table 27. Total Coho Redds in Lagunitas Creek Watershed, 1995-2003 (MMWD & PRNS) 

Year Lagunitas Creek 

mainstem 

San Geronimo Creek 

(mainstem+tribs) 

Devil’s Gulch

(+ Cheda) 

Olema Creek 

(mainstem+tribs) 

Total new 

redds 

1995/96 70 6 10 n.a. 86 

1996/97 98 115 42 n.a. 255 

1997/98 80 107 + 14 46 126 + 7 380 

1998/99 92 46 + 14 31 42 + 1 226 

1999/00 139 58 + 3 3 10 + 7 220 

2000/01 119 56 + 18 11 86 + 48 338 

2001/02 79 102 + 43 59 + 3 58 + 31 375 

2002/03 71 39 + 22 24 + 2 5 + 12 175 

n.a. = not available. 

The contribution of the Lagunitas Creek mainstem to overall spawning activity in that drainage is 

indicated by data collected by MMWD since 1982 (Table 27). Coho spawner counts and redd 

data show that much spawning activity takes place on Lagunitas Creek tributaries. Spawning on 

the mainstem takes place largely in Samuel P. Taylor State Park, upstream of PRNSadministered grazing lands. 
141 

Table 28. Coho Salmon Spawning Survey Data for Lagunitas Creek Mainstem 

Year Number of 

Surveys 

PDL Index Total 

Carcasses 

Total New 

Redds 

Source 

1982/83 6 n.a n.a 65 Bratovich & Kelly 1988 

1983/84 6 n.a. n.a. 26 Bratovich & Kelly 1988 

1991/92 1 n.a. n.a. 34 Wise 1992 

1995/96 10 129a

 n.a. 70 Trihey & Assoc. 1996 

1996/97 8 170a 23 98 Trihey & Assoc. 1997 

1997/98 10 46 27 80 MMWD 

1998/99 8 56b

 6 92 MMWD 

1999/00 14 371b 37 139 MMWD 

2000/01 14 181b

 18 119 MMWD 

2001/02 15 214b

 25 79 MMWD 

2002/03 13 283b 18 71 MMWD 

a/ Peak live fish counts only, no cumulative dead. 

b/ Total live fish observations, may include repeat sightings of same fish 

n.a. = not available. 

MMWD = Marin Municipal Water District data

The mouth of Lagunitas Creek and adjacent floodplain supports activities associated with the 

Waldo Giacomini dairy. This 563-acre property, once tidal wetlands, was diked and drained in 

the early 1940s to create pastures. For many years, a gravel dam was constructed annually just 

below the confluence of Lagunitas and Olema creeks for irrigation and stock watering. The dam 

created an abrupt transition from fresh to saline water for smolts and spawning adults, 

eliminating the transition zone found in an unimpaired estuarine system. The transition zone 

allows smolting fish time to adjust to saline conditions and provides productive feeding zones 

where both freshwater and saltwater invertebrates are available. 

The dam and the levees concentrated the area where spawning fish could hold and smolts could 

feed, and increased the potential for predation. While the annual construction of the dam has 

been discontinued, the levees are still in place. PRNS is currently acquiring these lands and 

developing a floodplain restoration plan. A phased restoration project requiring from five to ten 

years is planned to begin after final acquisition in 2007. Such restoration is expected to improve 

estuarine smolt and adult emigration habitat for both coho and steelhead. 

Devil’s Gulch has the longest period of spawner survey records for the Lagunitas Creek 

watershed. CDFG biologist Eric Gerstung and warden Al Giddings noted live coho and 

steelhead observations from 1948 to 1977. Consultants for MMWD conducted surveys from 

1982-84 and 1995-97. PRNS expanded the sampling area further upstream in 1996-97 (Table 

29). Prior to 1982/83, no more than two surveys were conducted in a single season and carcasses 

and redd data were not consistently collected. During a single survey in 1948, 174 coho and 

steelhead were counted in a 2.6 km reach. Between 1957/58 and 1976/77, peak counts of live 

coho ranged between 70 and 130 fish. Coho numbers had dropped by the 1990s, with PL index 

values between 1995/96 and 2002/03 ranging from 10 to 78 fish. 
142 

Table 29. Coho Salmon Spawning Survey Data for Devil’s Gulch 

Year Number of 

Surveys 

Survey 

Area (km)

PDL 

Index 

Total 

Carcasses 

Total New 

Redds 

Source 

1948 1 2.6 174a n.a. n.a. Gerstung & Giddings 

1957/58 2 2.4 100b n.a. 74 Gerstung & Giddings 

1960/61 1 2.6 77b

 n.a. n.a. Gerstung & Giddings 

1961/62 1 2.6 70b n.a. n.a. Gerstung & Giddings 

1964/65 1 1.6 91 76 n.a. Gerstung & Giddings 

1965/66 2 2.6 130b

 n.a. n.a. Gerstung & Giddings 

1976/77 1 2.4 100 90 n.a. Gerstung & Giddings 

1982/83 6 2.4 n.a. n.a. 23 Bratovich & Kelly 1988 

1983/84 6 2.4 n.a. n.a. 11 Bratovich & Kelly 1988 

1995/96 6 2.4 19b

 n.a. 10 Trihey & Assoc. 1996 

1996/97 3 3.2 47 20 42 Trihey & Assoc. 1997; PRNS 

1997/98 8 3.2 27 9 46 PRNS 

1998/99 6 3.2 26 6 31 PRNS 

1999/00 2 3.2 10 1 3 PRNS 

2000/01 4 3.2 14 2 11 MMWD 

2001/02 11 3.2 46 12 59 MMWD 

2002/03 5 3.6 78 1 24 MMWD 

a/ Peak live fish count includes both coho and steelhead, does not include carcass data. 

b/ Peak live fish counts without accumulated carcass data. 

n.a. = not available. 

MMWD = Marin Municipal Water District data; PRNS = Point Reyes National Seashore data 

Cheda Creek, a Lagunitas Creek tributary, has been surveyed since 1996/97 by PRNS to detect 

the presence or absence of coho. Surveys were during peak migrations of coho in nearby 

drainages, when passage and attraction flows were sufficient and water clarity was not limiting. 

Coho presence in this creek appears to be sporadic, with no spawning activity detected during the 

winters of 98/99 and 00/01. However, coho spawning may be increasing, with four live fish and 

three redds seen in ‘01/02 and two fish and two redds in 02/03. 

Until recently, much of the creek’s potential spawning area was blocked by a failed sediment 

control structure. Construction of a fish passage structure consisting of a series of stepped pools 

was completed in 2000. Fencing to exclude cattle from 2.5 km of the creek above and below this 

structure has been completed. During fall, 2000, juvenile coho were observed in the project area. 

In anticipation of future spawning activity resulting from greater access to suitable habitat, 

monitoring of coho and steelhead juveniles on Cheda Creek will continue to be implemented. 

Olema Creek Watershed. Olema Creek flows through the rift valley created by the San Andreas 

fault and joins Lagunitas Creek within the estuarine area, roughly three kilometers south of 

Tomales Bay. It is the largest drainage within the PRNS administrative area, providing the 

greatest habitat area and diversity. Most of Olema Creek’s watershed is contained within the 

boundaries of GGNRA and PRNS, with only small pockets of private lands concentrated around 

the town of Olema. The Vedanta Society owns and manages 2,143 acres on the west side of the 

stream, but the land-use intensity on most of the property is very low. 
143 

The 37 km2 Olema Creek watershed consists of a linear drainage basin that is approximately 14.5 

km long and 3.2 km across at its widest point. The creek consists of 17.4 km of stream channel, 

which has several distinct sections. From its mouth to 11.9 km, it has continuous perennial flow, 

while above this section the creek becomes a series of isolated pools during the summer. Above 

15.0 km, the creek usually dries up entirely in the summer. Numerous short tributaries enter 

Olema Creek from the east and west. 

Olema Creek crosses the San Andreas Fault near Five Brooks, and again about 1 km 

downstream. At this location there are substantial natural landslides occurring on both sides of 

the creek. The west side of the drainage is largely covered by Douglas-fir forest. Extensive 

logging in this area prior to 1964 resulted in further instability of the channel. The hydrology of 

Olema Creek also has been altered by the straightening of the lower 3 km of its channel in the 

1920s, and by construction of levees on Lagunitas Creek below the confluence with Olema 

Creek. Channel instability caused by these factors continues to cause bank cutting and failure, 

which is dramatic in several locations. The east side of Olema Valley consists of deep canyons 

dissecting the extensive grasslands of Bolinas Ridge. These grasslands have been grazed by 

cattle for 150 years. 

Like Lagunitas Creek, Olema and its tributaries support both coho salmon and steelhead trout. 

Three FMUs, Bolinas Ridge, Highway One, and Wilderness South include portions of the Olema 

Creek watershed. These FMUs encompass 28% of the total watershed area (see Table 11). 

 

The perennial section of Olema Creek has been systematically surveyed for live adult coho, 

carcasses, and redds since the winter of 1994/95 (Table 30). Results have shown considerable 

variability from year to year. As in other creeks in the Lagunitas drainage, Olema Creek had a 

high count for coho salmon in the winter of 1996-97, with a PL Index value of 174. Numbers 

fell considerably below this level for the following three years, but in 2000/01 they rebounded, 

with a PL index value of 103 fish, total carcasses numbering 65, and a total redd count of 86. 

Table 30. Coho Salmon Spawning Survey Data for Olema Creek Mainstem 

Year Number of 

Surveys 

Survey 

Area (km)

PDL 

Index 

Total 

Carcasses 

Total New 

Redds 

Source 

1994/95 3 13.4 53 1 9 Tomales Bay Association 

(TBA) 

1995/96 2 13.4 106 37 n.a. PRNS; TBA 

1996/97 2 15.6 174 16 n.a. PRNS; TBA 

1997/98 8 13.4 88 39 126 PRNS 

1998/99 6 15.0 42a

 13 42 PRNS 

1999/00b

 2 7.2 9 9 10 PRNS 

2000/01 4 11.8 103 65 86 PRNS 

2001/02 4 11.8 90c

 28 58 PRNS 

2002/03 4 11.9 20 17 5 PRNS 

a/ Includes two peaks, 7 weeks apart. 

b/ Surveys missed peak numbers. 

c/ Includes two peaks, 4 weeks apart 

n.a. = not available. 
144 

Surveys have also been conducted on tributaries of Olema Creek and its headwaters, which is the 

section of creek above 17.4 km from its mouth. These surveys have confirmed spawning activity 

in five of the tributaries and in the Olema Creek headwaters. Except for the John West Fork and 

Quarry Gulch, coho observed have been within a few hundred meters of the mainstem 

confluence. 

The John West Fork (aka Blueline Creek) is the most significant of the Olema Creek tributaries, 

having a greater average flow and more potentially suitable spawning habitat (2.2 km) than any 

other. A sharp drop below a culvert under Highway 1 previously limited access to most of the 

spawning habitat; during the two winters from 1997 to 1999 only 9% (3 of 33) of the total coho 

observations in the creek were above the culvert. In 1999, a structure was constructed to aid fish 

passage through the culvert. In the following four winters, 75% the total coho observations (146 

of 194) were above the culvert. As part of this project, fencing to exclude cattle from 1 km of 

the creek was installed. 

Table 31. Coho Salmon Spawning Survey Data for the John West Fork 

Year Number of 

Surveys 

Survey Area 

(km) 

PDL 

Index 

Total Carcasses Total New 

Redds 

Source 

1995/96 ? ? 8a n.a. n.a. PRNS 

1996/97 n.a. n.a. n.a. n.a. n.a. PRNS 

1997/98 5 1.3 12 0 7 PRNS 

1998/99 2 ? 9 0 1 PRNS 

1999/00b

 3 1.1 18 0 7 PRNS 

2000/01 4 1.9 58 30 48 PRNS 

2001/02 6 1.8 20 5 31 PRNS 

2002/03 7 1.3 27c

 0 12 PRNS 

a/ Includes live fish only, no carcass data. 

b/ Surveys missed peak numbers. 

c/ Includes two peaks, 4 weeks apart 

n.a. = not available. 

Starting in 1997, the CSRP has undertaken intensive survey work on Olema Creek to assess 

salmonid habitat condition and reproductive success. The focus of the CSRP is to correlate 

salmonid abundance at three life stages with habitat conditions to ascertain limiting factors on 

overall abundance. Index sites have been established along stream reaches representative of fish 

habitats and electrofishing is being used to determine juvenile coho and steelhead numbers. 

Results will be used to prioritize habitat restoration efforts and buffer threatened salmonid 

populations against potentially detrimental environmental conditions. 

Data indicate that a high proportion of juvenile salmonids found in Olema Creek are located in 

the upstream, intermittent section above 11.9 km. A special study of the intermittent section of 

Olema Creek was conducted in 1999. Results indicate a significant loss of juveniles stranded in 

drying pools, which could be an important factor in reducing overall reproductive success in 

Olema Creek. Repeating this study, together with outmigrant trapping the following spring, 

could provide valuable information on the adequacy of Olema Creek juvenile salmonid habitat. 
145 

The CSRP also conducted a survey of in-stream salmonid habitat conditions on upper section 

Olema Creek (11.8-15.0 km). The survey found that much of the Olema Creek salmonid habitat 

may be sub-optimal due to high sediment loads that fill interstitial spaces in spawning gravel, fill 

pools, and reduce the overall stream volume. 

The CSRP survey work to date shows that Olema Creek and its tributaries contain viable habitat 

for salmonids but there is not yet enough information to determine whether coho and steelhead 

populations are stable, increasing, or decreasing. 

Drakes Bay Watersheds. The Drakes Bay watersheds include all those draining directly to the 

Bay from Double Point, north and west to Chimney Rock, with the exception of the watersheds 

within Drakes Estero (described as separate watershed unit). Watersheds south of Drakes Estero, 

such as Coast Camp Creek, Coast Creek, and Santa Maria Creek, are perennial systems known to 

support steelhead trout. In some watersheds, including Alamere Creek, rainbow trout (also 

Oncorynchus mykiss) occur above the natural migratory barriers. The watersheds to the west of 

Drakes Estero do not support either of the salmonid species within the park. The Drakes Bay 

watersheds include portions of five FMUs, including Headlands, Limantour Road, Palomarin, 

Wilderness North, and Wilderness South (see Table 11). Steelhead trout occur within all of the 

FMU areas with the exception of the Headlands. 

Drakes Estero Watersheds. Watersheds draining to Drakes Estero including East and North 

Schooner, Glenbrook, Muddy Hollow, Home Ranch, and Laguna Creeks are known to support 

steelhead trout. Many sites within the Drakes Estero watershed are identified for restoration of 

fish passage as part of the Coastal Watershed Restoration Project. The Drakes Estero watershed 

includes portions of four FMUs, including Estero, Inverness Ridge, Limantour Road, and 

Wilderness North (see Table 11). Steelhead trout occur within each of these management units. 

Pacific Drainages. While the Pacific drainages include portions of two FMUs, Headlands and 

Tomales Point, these watersheds do not support threatened salmonid species. 

Bolinas Drainages. The Bolinas drainages include Arroyo Hondo Creek draining to the ocean, as 

well as Lewis Gulch and McKinnon Gulch draining to Bolinas Lagoon. Many of the Bolinas 

watersheds support perennial stream flow and steelhead trout. The Bolinas Drainage area 

includes the Bolinas Ridge, Highway One, and Palomarin FMUs. These management units 

represent 33% of the total drainage area (see Table 11). Each of the FMUs includes areas known 

to support steelhead trout. 

The unique flow and fish habitat characteristics observed within Pine Gulch Creek. 

Approximately 75% of the watershed drains from Inverness Ridge, west of the San Andreas 

Fault. These perennial tributaries provide water to the mainstem, but climb immediately from the 

valley bottom, providing little to no salmonid habitat. The geologic formations west of the San 

Andreas Fault include the Santa Cruz Mudstone and Merced Formation (Clark et. al, 1984), 

which support deep soils with high infiltration capacity. The remaining 25% of the watershed 

drains from Bolinas Ridge east of the SAF. The Franciscan Complex, which supports very thin 

soils with very low capacity for infiltration, makes up Bolinas Ridge. Tributaries draining from 

Bolinas Ridge have topography and stream profiles appropriate to support salmonids. Except for 
146 

McCurdy Creek, all eastern tributaries are intermittent. The Pine Gulch Creek watershed 

includes two FMUs, Bolinas Ridge and Highway One, representing 23% of the total watershed 

area (see Table 11). 

The watershed supports a population of steelhead and it is generally accepted that it supported a 

native self-sustaining population of coho salmon into the 1970s. The last observation of coho 

salmon documented in July of 1968 reads, “coho salmon, 20 fish per 100 foot length of stream” 

(CDFG, 1968). The reasons for extirpation of coho salmon in Pine Gulch are uncertain. It is 

likely that the drought of the late 1970s coupled with in-stream damming during the same period 

severely depleted multiple year classes and led to unsuitable conditions for continued survival of 

the species within the Pine Gulch watershed. 

Following thirty years without documented coho sightings, recent NPS monitoring activities 

have detected the presence of three consecutive cohort year classes in Pine Gulch Creek. 

Beginning in winter 2000-2001, coho salmon spawners have been observed in low numbers (<5 

per year) within the watershed. Modified Hankin-Reeves surveys yielded estimates of 589 (± 

329) juvenile coho salmon in September 2001 and 1205 (± 337) juvenile coho salmon in 

September 2002. The 2002 survey results indicate higher abundance and wider distribution of 

coho than the 2001 survey. In response to juvenile presence in 2001, a smolt trap was operated in 

the spring of 2002 capturing 249 coho smolts (Ketcham & Brown, 2003). Evaluation of genetic 

samples indicate that coho salmon captured during summer 2001 in Pine Gulch Creek have a 

strong genetic affinity to coho in the Redwood Creek watershed, Marin County (Garza, personal 

communication), six miles to the south. 

California Freshwater Shrimp (Syncaris pacifica)- Endangered

The California freshwater shrimp is the only extant member of the genus and is listed by the U.S. 

Fish and Wildlife Service as endangered (55 FR 43884). The shrimp is endemic to 16 coastal 

streams in Marin, Sonoma, and Napa counties north of San Francisco Bay, California. The 

shrimp is found in low elevation (<116 meters), low gradient (generally <1 percent), perennial 

freshwater streams with structural diversity, including undercut banks, exposed roots, 

overhanging woody debris, or overhanging vegetation. Existing populations are threatened by 

introduced fish; deterioration or loss of habitat resulting from water diversion and impoundment; 

livestock, dairy, and other agricultural activities and developments; flood control activities; 

gravel mining; timber harvesting; migration barriers; and water pollution. A study was recently 

conducted in PRNS and GGNRA to determine the distribution of California freshwater shrimp 

within streams in the parks, to evaluate the effectiveness of three survey methods for the shrimp, 

and to provide recommendations for survey techniques for long-term monitoring. 

These shrimp reside in the Lagunitas and Olema Watersheds and depend on overhanging 

vegetation along the creek’s banks for habitat. The shade provided by this vegetation is also 

important to the protection of rare fish species. Prescribed burning would incorporate a fixed 

setback from water resources to protect the water quality, the sensitive plant community and the 

listed fish species. The setback would also avoid adverse effects to the creek bank habitat 

important to the California freshwater shrimp. 
147 

The current range of the shrimp within Lagunitas Creek extends from Shafter Bridge in Samuel 

P. Taylor State Park to roughly 1.6 km below the confluence with Nicasio Creek (Serpa, 1991). 

Shrimp habitat along the main stem of Lagunitas Creek within the Parks is generally protected 

from agricultural activities occurring within the watershed. Small numbers of shrimp were 

collected in 1996 and 1997 near the confluence of Olema and Lagunitas creeks (Fong, 1999). 

California Freshwater shrimp surveys detected small numbers of CA freshwater shrimp in lower 

Olema Creek in 2001. The USGS–BRD Dixon Field Station is conducting investigations of 

California freshwater shrimp habitat, survival, and predation within lower Olema and Lagunitas 

Creeks. This three-year investigation is looking at habitat and flow characteristics supporting the 

species and has found that native sculpin are a significant predator of the shrimp. Shrimp have 

not been found in the lower Olema Creek sections during this USGS investigation (LoBianco 

and Fong, 2002). 

Myrtle’s Silverspot Butterfly (Speyeria zerene myrtleae) – Endangered 

Myrtle’s silverspot butterflies inhabit coastal dune, coastal prairie, and coastal scrub habitats at 

elevations ranging from sea level to 300 meters, and as far as 5 kilometers inland (Launer et al., 

1992). It was federally listed as endangered in 1992. Its historic distribution is believed to have 

extended from near Fort Ross south to Punta Ano Nuevo. By the 1970s populations south of the 

Golden Gate were believed to be extinct and extant; populations of the butterfly were believed to 

exist only within PRNS. Reasons for this decline include urban and agricultural development, 

changes in natural fire patterns, successional changes in plant communities have reduced 

availability of host plants, invasive non-native plants, livestock grazing, overcollecting, and other 

human impacts. 

Following discovery of a population near the Estero de San Antonio in the early 1990s, field 

surveys were conducted by the Center for Conservation Biology at Stanford University. Two 

additional, apparently separate populations in PRNS were located and fieldwork was done to 

estimate populations’ sizes. One population, centered on North Beach, extended from Abbotts 

Lagoon to South Beach and east to Drakes Estero and Drakes Beach. The highest numbers were 

found along the dune-scrub interface in the back dune area of the central peninsula on F and G 

ranches and the AT&T property, and on the bluffs on either side of the Drakes Beach visitor 

center. The population was estimated to number in the low thousands in 1993. Survey work in 

1998 put the population estimate at 50-200 individuals, with no silverspots being found in 

portions of the 1993 range. The other population was found on the Tule Elk Reserve, with small 

numbers on the adjacent J Ranch. In 1993, the number of individuals in this population was 

estimated to be in the mid-hundreds. The 1997 survey of this northern Point Reyes population 

gave a population estimate of 250-500 (Launer et al., 1998). 

Silverspot numbers in the area outside of parklands around the Estero de San Antonio were 

estimated at 2,000-5,000 individuals in 1991. Other nearby areas with potentially suitable 

habitat was not surveyed. Together with those found at Point Reyes, estimated numbers for the 

three known populations of the species total less than 10,000 individuals (USFWS, 1998). 

Known Myrtle’s silverspot nectar plants include curly-leaved monardella (Monardella undulata), 

yellow sand verbena (Abronia latifolia), seaside daisy (Erigeron glaucus), bull thistle (Cirsium 
148 

vulgare), gum plant (Grindelia spp.), and mule ears (Wyethia spp.). Brownie thistle (Cirsium 

quercetorum) and groundsel (Senecio spp.) are also fed upon. Many of these species are 

commonly found at Point Reyes. Oregon silverspot (Speyeria zerene hippolyta) feeds on other 

common plant species that may also be used by Myrtle’s silverspot. 

Myrtle’s silverspot larvae are known to use only one species as a host plant, western dog violet 

(Viola adunca). It is possible that, like other subspecies of Speyeria zerene and other species of 

silverspots, Myrtle’s silverspot use other violet species as larval hosts, although this has not been 

observed. The perennial, rhizomatous western dog violet is found on open grassy slopes, sandy 

flats behind dunes, and on the edge of brush under pines (Howell, 1970). While it is described as 

“rather common near the coast,” including the Point Reyes dunes, distribution of the species is 

patchy. Abundance of western dog violet alone is not a good predictor of silverspot presence. 

Myrtle’s silverspot presence also is associated with protection from high coastal winds that are 

common during the summer flight season (Launer et al., 1992). The complex habitat needs of 

breeding Myrtle’s silverspots may be the species’ limiting factor. 

Populations of Speyeria butterflies experience large population fluctuations, and population 

increases of tenfold or more in a single year has been observed. In 1994/95, California’s central 

coast experienced a very wet winter that reduced numbers of many late-spring and summerflying butterflies (silverspots are the latter). Another wet winter occurred in 1997-98, which may 

have resulted in the low numbers for the central Point Reyes population observed in summer, 

1998. 

Due to the lack of historic data previous to the 1990s, it is not known if the silverspot has 

declined at Point Reyes. While surveys of the two populations during the period 1993-1997 

found that the Tule Elk Reserve population remained stable and the central Point Reyes 

population declined sharply, such variation is well within that normally found in Speyeria 

species (USFWS, 1998). 

A Masters thesis project, which will include mapping the distribution of larval host and nectar 

plants at PRNS and monitoring the response of these species to different grazing regimes is 

currently being developed by a member of PRNS Resource Management staff. Additionally, 

plant species composition response to tule elk grazing and to exclusion from grazing is being 

assessed as part of long-term monitoring of vegetation in the Tule Elk Reserve. Together with 

continued censusing of Myrtle’s silverspot numbers, this research will help provide the needed 

grazing management information identified by the Myrtle’s silverspot recovery plan (USFWS, 

1998). 

Western snowy plover (Charadrius alexandrinus nivosus) – Threatened 

Western snowy plovers use the Point Reyes peninsula as both wintering and nesting habitat. 

Wintering birds occur around Drake’s Estero and Abbott’s Lagoon, and along Limantour Spit 

and the Great Beach. During the 1980s nesting took place along the entire Great Beach, Drake’s 

Beach, and at Limantour Spit. In recent years, erosion along the southern portion of the Great 

Beach has diminished the upper beach area such that the entire beach can be washed by waves. 

Nesting is occurring on the northern portion of this beach, between the North Beach parking area 

and Kehoe Beach, which is backed by extensive dunes. Snowy plovers also nest along the 
149 

western edge of Abbott’s Lagoon. Although it had historically been used as nesting habitat by 

plovers, erosion has affected Limantour Spit and it no nests have been seen since 2000. In 2001 

and 2002, all snowy plover nests observed were located on the northern portion of the Great 

Beach. 

 

Monitoring of nesting snowy plovers in 1986-1989 and 1995-2002 indicates a decline in the 

number of nesting birds through 1996, followed by a gradual rebound (Table 32). Point Reyes 

Bird Observatory (PRBO) monitored individual nests at all nesting areas during this period. On 

the Great Beach, where most nesting took place, the number of chicks fledged per egg laid 

during 1986-89 and 1995 ranged from 1%-7%. 

Table 32. Snowy plover Nesting at PRNS. 

Year Number of nests Number of 

nesting birds 

Number of chicks 

fledged 

Percent chicks fledged 

per egg laid 

1986 41 41-44 5 5 

1987 74 50-54 15 7 

1988 63 40-42 5 3 

1989 60 34-37 1 1 

1995 20 12 4 7 

1996 9 10-11 14 58 

1997 25 25 20 45 

1998 14 16 21 58 

1999 21 20 22 47 

2000 28 31-37 14 19-20 

2001 34 27-36 10 11-12 

2002 30 34-37 17 22 

2003 22 25 19 

In 1996 a program to increase snowy plover nesting success was initiated, and this program 

continues to the present. Several nesting areas, including Limantour Spit and sections of the 

Great Beach accessed by the Abbott’s Lagoon and Kehoe Beach trails, experience regular visitor 

use. In response, PRNS ropes off sensitive habitat and posts signs to divert visitor traffic. 

Visitors are advised to avoid walking on upper beach areas used by plovers, and dogs are 

prohibited from nesting areas. In 2000, observers found a higher rate of snowy plover chick loss 

in these areas on weekends, when disturbance by human visitors and dogs is more likely. In 

2001, the Seashore initiated a snowy plover weekend docent program to increase awareness of 

plover habitat restrictions. Starting in 1996, exclosures were placed over plover nests to reduce 

avian and mammalian predation. Since the use of exclosures in 1995, the rate of chicks fledged 

per egg has increased to 20%-58% (Ruhlen and Abbott, 2000), and between one and three chicks 

per female have fledged. In 2000, although egg laying remained high, fledging rate started to 

decline. Causes for the decline likely includes predation by ravens, raptors, and disturbance by 

visitors. Ravens have been identified as the primary predator of eggs of plovers and any activities 

that increase the presence or productivity of ravens would potentially have a negative effect on 

the plovers. Ravens could benefit from prescribed fires by foraging on fleeing wildlife such as 

reptiles and rodents. 
150 

Fledging rates for snowy plovers before nest protection began were insufficient to maintain the 

species at PRNS, as indicated by declining numbers of nests and nesting adults in the period 

1986-1995. Continuation of such low nest success rates could have resulted in loss of the PRNS 

breeding population of snowy plover. The current nest protection program has raised nest 

success rates to levels similar to those at other coastal California locations. 

Additional Special Status Wildlife 

Table 33 lists several animal species in the project area that are federal Species of Concern or 

listed by the state of California. In the federal system, Species of Concern are those where 

USFWS is collecting additional information to determine whether they warrant consideration for 

future listing. Table 33 lists nine species of mammals, 22 species of birds, three reptiles, two 

species of amphibians, three fish, and ten species of invertebrates. The table also shows which 

species are potentially subject to adverse effects. Because it may be more likely than other 

species to experience effects from fire or fire management activities, the Point Reyes Mountain 

Beaver is discussed in more detail below. 

Point Reyes Mountain Beaver (Aplodontia rufa phaea) - Federal Species of Concern. 

The US Fish and Wildlife Service and the California Department of Fish and Game list the Point 

Reyes mountain beaver, a muskrat-sized rodent found only in scrub habitat in western Marin, as 

a Species of Concern. Mountain beaver may be adversely affected by actions described in the 

Fire Management Plan alternatives, but most particularly by large-scale unplanned ignitions. 

Studies conducted following the 1995 Vision Fire in Point Reyes revealed that Point Reyes 

mountain beaver suffered high mortality. Surveys indicated that pre-fire estimates of 

approximately 5,000 individuals were in the burned area. After the Vision Fire, major changes 

in the habitat occurred. For example, there was a reduction in coastal scrub to charred sword 

fern bases and blackened skeletons of coyote brush. Post Vision Fire surveys suggested that only 

19 mountain beavers survived within the surveyed fire area. This number represents only 0.4 – 

1.2% of the population that park staff estimate had previously inhabited the surveyed area 

(Fellers et al., 2003). It is likely that the post-fire mortality was related to dehydration as this 

species requires up to two cups of water per day, normally provided through roots and 

vegetation, to survive. Monitoring in the years following the fire indicate that recovery of the 

populations has been slow (Fellers, 2000). Populations on the peninsula outside of the area 

burned in the Vision Fire remain healthy (Fellers, pers. comm. 2003). 

Table 33. Animal Species of Concern and California-listed Species That May Occur in Areas 

Affected by PORE's Fire Management Plan (per USFWS Letter, May 24, 2001) 

Common Name Scientific Name Known to Occur Potentially 

Subject to 

Adverse Impacts 

Mammals 

 

California myotis bat Myotis californicus yes yes 

Fringed myotis bat Myotis thysanodes yes yes 

Greater western mastiff-bat Eumops perotis califomicus no no 

Long-eared myotis bat Myotis evotis yes yes 
151 

Long-legged myotis bat Myotis volans yes yes 

Pacific western big-eared bat Corynorhinus (Plecotus) 

townsendii townsendii 

yes yes 

Point Reyes jumping mouse Zapus trinotatus orarius yes yes 

Point Reyes mountain beaver Aplodontia rufa phaea yes yes 

Yuma myotis bat Myotis yumanensis yes yes 

Birds 

 

Allen’s hummingbird Selasphorus sasin yes yes 

American bittern Botaurus lentiginosus yes no 

Ashy storm petrel Oceanodroma homochroa yes no 

Bank swallow (CT)a Riparia riparia no no 

Bell's sage sparrow Amphispiza belli belli no no 

Bewick’s wren Thryomanes bewickii yes yes 

Black rail (CT)a Laterallus jamaicensis 

coturniculus 

yes no 

Black-crowned night heron Nycticorax nycticorax yes no 

Common loon Gavia immer yes no 

Ferruginous hawk Buteo regalis rare no 

Grasshopper sparrow Ammodramus savannarum yes yes 

Harlequin duck Histrionicus histrionicus rare no 

Little willow flycatcher (CE)b Empidonax traillii brewsteri no no 

Loggerhead shrike Lanius ludovicianus rare no 

Long-billed curlew Numenius americanus yes no 

Olive-sided flycatcher Contopus cooperi yes yes 

Pacific-slope flycatcher Empidonax difficilus yes yes 

Rufous hummingbird Selasphorus rufus no no 

Saltmarsh common yellowthroat Geothlypis trichas sinuosa yes no 

Short-eared owl Asio flammeus yes yes 

Tricolored blackbird Agelaius tricolor yes yes 

Vaux’s swift Chaetura vauxi yes no 

White-tailed (=black shouldered) kite Elanus leucurus yes yes 

Reptiles 

 

California horned lizard Phrynosoma coronatum frontale no no 

Northwestern pond turtle Clemmys marmorata 

marmorata 

yes no 

Alameda striped racer Masticophis lateralis 

euryxanthus 

no no 

Amphibians 

 

Foothill yellow-legged frog Rana boylii no no 

Northern red-legged frog Rana aurora aurora no no 

Fish 

 

Longfin smelt Spirinchus thaleichthys no no 

Pacific lamprey Lampetra tridentata yes no 

Tomales roach Lavinia symmetricus ssp. yes no 

Invertebrates 

 

Bumblebee scarab beetle Lichnanthe ursina yes 

Globose dune beetle Coelus globosus yes no 
152 

Marin elfin butterfly Incisalia mossii unknown unknown 

Nicklin’s peninsula Coast Range 

snail 

Helminthoglypta nickliniana 

awania 

unknown unknown 

Oplers longhorn moth Adela oplerella unknown unknown 

Point Reyes blue butterfly Icaricia icaridides ssp yes yes 

Ricksecker's water scavenger beetle Hydrochara rickseckeri no no 

sandy beach tiger beetle Cicindela hirticollis gravida yes no 

Sonoma arctic skipper Carterocephalus paleemon ssp unknown unknown 

William's bronze shoulderband snail Helminthoglypta arrosa 

williamsi 

unknown unknown 

a/ CT: Listed as threatened under the California Endangered Species Act b/ CE: Listed as endangered under the 

California Endangered Species Act

Habitats of Management Concern 

Numerous habitat types within the project area are afforded protection under various laws and 

regulations. Through the 1997 Magnesun-Stevens Act, the National Marine Fisheries Service 

(NMFS or NOAA Fisheries) has designated all streams on NPS lands as Essential Fish Habitat 

(EFH). EFH waters support a variety of fish species. The USFWS has designated critical habitat 

for the protection of the California red-legged frog, which includes nearly all of the land within 

the project area. 

Cultural Resources 

In addition to a diverse mosaic of natural and physical features, Point Reyes contains a varied 

array of cultural resources within its boundaries. The NPS recognizes five types of cultural 

resources: archeological resources, structures, ethnographic resources, cultural landscapes, and 

museum objects. Archeological resources “are the remains of past human activity and records 

documenting the scientific analysis of these remains.” These include artifacts, ecofacts, and 

features. Structures “are material assemblies that extend the limits of human capacity,” and 

comprise such diverse objects as buildings, bridges, vehicles, monuments, vessels, fences, and 

canals. Ethnographic resources “are basic expressions of human culture and the basis for 

continuity of cultural systems” and encompasses both the tangible (native languages, subsistence 

activities) and intangible (oral traditions, religious beliefs). The management of ethnographic 

resources entails the recognition that traditional cultures can have different worldviews and the 

right to maintain their traditions. Cultural landscapes “are settings we have created in the natural 

world.” They are intertwined patterns of natural and constructed features that represent human 

manipulation and adaptation of the land. Finally, museum objects “are manifestations and 

records of behavior and ideas that span the breadth of human experience and depth of natural 

history.” Examples of typical museum objects include field and laboratory notes, artifacts, and 

photographs. 

Historical Overview 

Cultural resources abound on the Point Reyes peninsula. The Coast Miwok people inhabited the 

area for more than 2000 years before European explorers arrived, and human population density 

before contact was probably greater than it is today (Cook, 1943). At least 124 Native American 

archeological sites exist within PRNS, primarily on the coastal lowlands. These known 
153 

prehistoric sites are primarily “shell middens,” voluminous deposits of soil with a relatively high 

content of local shell that were created as a byproduct of human habitation or use of the site. The 

shell reflects the harvest of shellfish by the Coast Miwok as both food and raw material for the 

manufacture of shell beads, ornaments, and tools. 

The interior core of the peninsula has not yet been surveyed for archeological sites, due in part to 

a combination of thick vegetation and rugged topography. The NPS recently estimated that 

between 41 and 123 additional Native American archeological sites are present within its 

boundaries. Ironically, these areas that have not been surveyed because of topographic 

constraints or thick vegetation may be those where fire would be most intense and likely to 

inflict damage. 

The ethnographic Coast Miwok were a hunting and gathering people who harvested diverse, 

naturally occurring terrestrial and aquatic foods and materials. They created tools, clothing, 

weapons, structures, ornaments, baskets, and other items of material culture using resources that 

were primarily local but sometimes traded (e.g., obsidian). In addition they likely manipulated 

the local environment through limited burning to favor the reproduction of selected plant and 

animal species. Their settlement pattern is thought to reflect the “tribelet” model common to 

many Californian groups. In this model comparatively fewer and larger permanent village sites 

were each affiliated with several or smaller, semi-permanent villages or seasonally occupied 

habitation sites. These smaller sites were devoted to the harvest of specific, localized natural 

resources as they became available during the annual cycle. Coast Miwok people currently live 

in the area and are federally recognized as the Federated Indians of Graton Rancheria. 

Most experts believe that Point Reyes contains the site of the first recorded English/Native 

American contact in North America. According to experts, Francis Drake is likely to have 

landed here in 1579 to careen his ship before sailing across the Pacific on a circumnavigation of 

the globe. In 1595 the first recorded shipwreck on the West Coast occurred when the Spanish 

galleon San Augustin wrecked in what is now Drake’s Bay. Since that year, Point Reyes history 

is replete with accounts of shipwrecks and underwater archeological surveys have been 

conducted to identify and record several of them. It was Spanish sailor explorer Sebastian 

Vizcaino who named Point Reyes (Punta de los Reyes) in 1602. 

In the late 1700s and early 1800s the Spanish colonized California using the “Mission System.” 

The key Missions affecting the Coast Miwok were San Francisco de Asís (1776), San Rafael 

Arcángel (1817), and San Francisco Solano De Sonoma (1823). The Coast Miwok were 

encouraged and sometimes forced to remove from their local lands to the missions where they 

were further indoctrinated in the Catholic religion and assimilated into the Spanish colonial 

culture and economy. The profound changes in land use and economy initiated by the Spanish 

generally left them little choice if they were to survive at all. This eventually resulted in the 

almost complete collapse of the Coast Miwok people and culture and included the loss of most of 

their oral tradition. 

In response to the many shipwrecks in treacherous coastal waters, the federal government 

established lighthouse and life-saving stations in the late 1800s and early 1900s. The historic 

Point Reyes Lighthouse was in service from 1870 to 1975. During that time, it endured many 
154 

hardships, including the 1906 earthquake. Forty-five shipwrecks occurred during the first 60 

years of the Lighthouse’s operation. Because of this ongoing problem, the U.S. Life-Saving 

Service established a life-saving station on the Great Beach in 1890. Four years later it was 

moved to Drakes Bay. The U.S. Coast Guard assumed the operation in 1915 and upgraded it in 

1927. The life-saving station was designated a National Historical Landmark in 1989. The 

Lighthouse was listed on the National Register of Historic Places in 1978. 

PRNS is home to the Marconi/RCA receiving and transmitting stations, which together with the 

Marconi receiving station site at Marshall (now the State Park-owned Marconi Conference 

Center) form the only known intact coast wireless station remaining in the United States dating 

from the birth of wireless communications. The Bolinas transmitting station was the site of the 

first trans-Pacific wireless communication in 1913. The two stations have been adaptively 

rehabilitated for park administrative and tenant office use, but retain significant historical radio 

equipment and antennas in operational condition. The sites are maintained and operated by park 

staff with significant assistance from park volunteers from the maritime Radio Historic Society. 

 

Archeological Resources 

Archeological resources typically consist of sites or isolated artifacts. In terms of location and 

period of origin archeological resources can be generally categorized as terrestrial or submerged, 

and either as prehistoric or historic. Prehistoric archeological sites may also include 

“protohistoric” components that reflect Coast Miwok occupation or use during the historic era, or 

that may contain early historic artifacts such as porcelain fragments originating from the Drake 

and Cermeno voyages. Historic archeological sites may also include or be in direct association 

with standing or ruined structures. Within PRNS, submerged archeological sites are typically 

historic shipwrecks that are either fully or partially submerged at high tide. Some sites include 

both prehistoric and historic components. Sites may singly or in combination contribute to, or 

even constitute cultural landscapes depending upon the character of their visible remains or 

landscape signatures. The Park estimates that approximately 87% of its terrestrial acres have not 

yet been surveyed for archeological resources. Archeological resources can be significant under 

any or all four criteria of the National Register of Historic Places. 

In 2002 the Park determined that there were at least 124 recorded prehistoric, terrestrial sites. It 

was also estimated that there were from 41 to 123 additional, unknown terrestrial prehistoric 

sites within current Park boundaries. The highest probability for unknown prehistoric sites 

would be in the Tomales Point FMU, Limantour FMU, Headlands FUM, Highway One FMU, 

and Palomarin FMU because of their proximity to water and food resources. These sites are 

either habitation or use sites that reflect Coast Miwok occupation or resource processing sites. 

As described in the above Historical Overview most of the known prehistoric sites are shell 

middens of various sizes. Shell middens often contain a wide variety of cultural resources 

including, for example, human remains; cooking or food processing features (e.g., bedrock 

mortars); obsidian, chert and bone tools; shell ornaments; and the faunal remains of species 

harvested for food and materials. The depositional history reflected by a site’s stratigraphy or 

layering, and the spatial organization of its contents are often critical for dating, understanding 

and interpreting Coast Miwok lifeways and cultural change over time. The geographic 

distribution of prehistoric sites on the land is important in itself for the information it can provide 

on Coast Miwok settlement systems. 
155 

The park also has counted 92 historic terrestrial archeological sites that have been recorded in 

various documents at different levels of intensity. In addition, it was estimated that 5 to 37 

additional, unknown, historic terrestrial sites are likely to exist within the boundaries of PRNS. 

These sites typically reflect historic occupations and use of the peninsula; first by homesteaders 

and dairy ranch communities, and later by government lighthouse and lifesaving personnel and 

private radio telecommunications companies. They range in size and complexity from discrete 

trash pits containing old bottles, tins, broken tools and crockery; to now buried corduroy roads, 

ruined ranch sites, and radio communication facilities complete with antennae farms. As with 

prehistoric archeological sites, maintaining the integrity of the deposits or remains is crucial to 

understanding and interpreting them. Historic archival research is often important in predicting 

the location of such sites and also understanding what they once were and how they functioned. 

Park cultural resource staff has also counted 9 known and recorded terrestrial archeological sites 

that contain both prehistoric and historic components (not necessarily related to each other). 

They estimate another 5 to 14 such sites within park boundaries exist but have not yet been 

identified. 

The recently completed Point Reyes National Seashore Cultural Affiliation Report examining 

Native American affiliation at Point Reyes concluded that the Federated Coast Miwok people 

have a clear, exclusive affiliation with the lands managed by Point Reyes National Seashore 

extending back more than 2000 years. The Federated Coast Miwok are politically recognized by 

the federal government as the Federated Indians of Graton Rancheria. 

Cultural Landscapes 

PRNS manages 39 cultural landscapes; 23 are within the boundaries of Point Reyes National 

Seashore and 16 are within the North District of GGNRA. The landscapes primarily reflect the 

maritime, ranching, communications, and military history of the park. Two are ranching 

districts, which together comprise approximately 30,000 acres of parkland in the northern district 

of Point Reyes and the Olema Valley. Two other landscapes have national significance: the 

Lifeboat Station is a National Landmark and the Marconi/RCA sites (described above) are in the 

process of being nominated to the national register. Cultural landscapes identified in the NPS 

Cultural Landscapes Automated Information Management System (CLAIMS) are listed below in 

Table 34. 

Table 34. Cultural Landscapes 

Landscape Name CLAIMS # Location 

Bolinas Copper Mines 725194 Hwy One FMU, Olema Valley, GOGA 

Hamlet 725193 Not in FMU, Tomales Bay, GOGA* 

North Pacific Coast Railroad Grade 725195 Bolinas Ridge FMU, Lagunitas Loop & 

Tomales Bay, GOGA 

Olema Valley Ranches Historic District 725001 Highway One FMU, Olema Valley, GOGA 

 Cheda Ranch 725209 Not in FMU, Lagunitas Loop, GOGA 

 Five Brooks 725197 Wilderness South FMU, Olema Valley 

,GOGA 

 Hagmaier Ranch 725212 Highway One FMU, Olema Valley, GOGA 

 McFadden Ranch 725203 Not in FMU, Olema Valley, GOGA 
156 

Landscape Name CLAIMS # Location 

 McIsaac Ranch 725206 Not in FMU, Lagunitas Loop, GOGA 

 Ralph Giacomini Ranch 725014 Highway One Fmu, Olema Valley, GOGA 

 Stewart Ranch 725199 Wilderness South FMU, Olema Valley – 

GOGA 

 Teixeira Ranch 725211 Highway One FMU, Olema Valley, PORE 

 Truttman Ranch 725200 Not in FMU, Olema Valley, GOGA 

 Wilkin's Ranch 725003 Highway One FMU, Olema Valley, GOGA 

 Zanardi Ranch 725191 Not in FMU, Lagunitas Loop, GOGA 

Tomales Bay Highway One 725482 Not in FMU, Tomales Bay, GOGA 

Coast Guard Facilities 725161 Not in FMU, North District – PORE 

 Coast Guard Lifesaving Station & 

Navy Radio Direction Finder Station 

725190 Not in FMU, South Beach – PORE 

 Point Reyes Lifeboat Station 725182 Headlands FMU, PORE 

 Point Reyes Lighthouse 725183 Headlands FMU, PORE 

Coastal Defense Sites 725160 North & South District , PORE 

 Bolinas Military Reservation 725185 Palomarin FMU, PORE 

 Drakes Bay Artillery Installation 725186 Not in FMU, North District , PORE 

 SCR Radar Site 725184 Not in FMU, North District, PORE 

 Wildcat Military Reservation 725187 Wilderness South FMU, North District, 

PORE 

Laird's Landing 725159 Not in FMU, Tomales Bay, PORE 

Olema Lime Kilns 725158 Highway One FMU, Olema Valley, PORE 

Point Reyes Ranches Historic District 725005 Not in FMU, North District, PORE 

 A Ranch 725012 Headlands FMU, PORE 

 B Ranch 725016 Not in FMU, North District, PORE 

 C Ranch 725017 Not in FMU, North District, PORE 

 D Ranch 725011 Not in FMU, North District, PORE 

 Home Ranch 725006 Estero FMU, North District, PORE 

 I Ranch 725167 Not in FMU, North District – PORE 

 L Ranch 725013 Not in FMU, North District, PORE 

 Upper Pierce Ranch 725177 Tomales Point FMU, North District, PORE 

RCA Marine Radio Station 725162 Not in FMU, North & South Districts, PORE

 RCA Receiving Station 725188 Not in FMU, North District – PORE 

 RCA Transmitting Station 725189 Not in FMU, Palomarin/Bolinas - PORE 

*Not in FMU indicates that cultural landscape area is outside a Fire Management Unit that is proposed for treatment. 

Structures 

Over 300 hundred historic structures are found on land managed by PRNS. The majority of these 

structures are located outside the FMUs to be treated; however, the Headlands, Tomales Point, 

and Highway One FMUs do have some historic structures. The structures range from simple 

timber-framed barns to the cast-iron Point Reyes Lighthouse to the concrete Mission Revival 

Marconi transmitting station. Historic structures are found throughout most of the park (none in 

the wilderness area) and mark the built history of PRNS. 

Approximately two thirds of PRNS’s listed structures are ranch structures managed under leases 

and permits. The remaining structures primarily reflect the Park’s maritime and radio 

communication history. Four sites are listed on the National Register, including the Point Reyes 

Lifeboat Station - a National Historic Landmark. Three additional properties have been 

determined eligible for the National Register and several additional properties are in review (see 

Table 35). 297 historic structures are on the List of Classified Structures, the NPS inventory of 

historic and prehistoric structures. 
157 

Table 35. National Register Status 

NR Status Property Name Property Type & Date 

National Register Listed Olema Lime Kilns, #76000217, 10/08/76 structure/site, c. 1850 

 Point Reyes Lifeboat Station, #85002756, 11/07/85 complex of buildings/features, c. 

1927 

 Designated as NHL 12/20/89 

 Upper Pierce Ranch, #85003324, 12/06/85 complex of buildings/features, c. 

1858-1935 

 Point Reyes Light Station, #91001100, 09/03/91 complex of buildings/features, c. 

1870-1960 

Determined Eligible Sarah Seaver Randall House (GOGA) 08/29/79 single house, c. 1880 

 Olema Valley Rural Historic District (GOGA) 

01/02/79. Revision & resubmittal in progress. 

district, c. 1834-present 

 Hamlet (Jensen's Oyster Beds) (GOGA) 01/24/90 complex of buildings/features, c. 

1900-1945 

 Point Reyes NS Rural Historic Landscape District 

04/03/95 

district c. 1834-present 

National Register Submittal 

Pending 

Point Reyes Peninsula Archeological District district, prehistoric 

Determination of Eligibility 

Pending 

Marconi/RCA Receiving and Transmitting Stations 

(in review) 

complex of buildings/features, c. 

1914-1945 

 Bolinas Copper Mines (GOGA) (in review) ruins/site, c. 1863-1918 

 North Pacific Coast RR Grade (GOGA) (in review) linear structure/sites, c. 1873-

1933 

 Tocaloma Bridge (GOGA) (in review) single structure, c. 1927 

Visitor Use and Visitor Experience 

The project area is unique not only in its assemblage of natural and cultural features, but also in 

its proximity to a major urban population. This juxtaposition makes PRNS’s resources and 

recreational opportunities readily accessible to a large number of people, and enhances the 

importance of the special qualities for which it was set aside. Over 2.25 million people visit 

PRNS annually. Visitation estimates for 2002 found that the North District of the park (north of 

Bear Valley) receives roughly 60% of the overall visitation. Over 700,000 visitors went to the 3 

park visitor centers and over 70,000 visitors have extended contacts with park interpretive staff 

through ranger-led programs. 

The area supports 147 miles of hiking trails, backcountry campgrounds, and numerous beaches. 

Activities include hiking, water sports, horseback riding, fishing, camping, wildlife viewing, and 

other interpretive opportunities. 

Hiking is primarily a day-use activity. Approximately 50 trails are designated throughout PRNS, 

and they encompass a range of habitat types from wooded mountains to sandy beaches. 

Overnight stays are available through 4 backcountry campgrounds, the Stewart Horse Camp, the 

Point Reyes Hostel, a private campground, and local hotels and inns. Dozens of visitors bring 

horses to ride on designated horse trails, and hundreds rent horses every week from commercial 

stables. 
158 

Water sports include kayaking, canoeing, boating, and swimming. The majority of paddle crafts 

use Tomales Bay as it provides protection from ocean waves and surf, while power boaters more 

freely use the ocean. Though Stinson Beach and Bolinas attract more surfers, North Beach is 

known as a challenging surfing area. Nature study and wildlife viewing are important activities 

at Point Reyes. Visitors make special trips to PRNS to see migrating whales, shorebirds, 

breeding elephant seals, tule elk, and spring wildflowers. Information received from visitor 

surveys conducted by Sonoma State University (NPS, 1997 and NPS, 1998) found that most park 

visitors spend 2-6 hours at PRNS in a variety of activities dependent upon the season, ranging 

from whale watching and kayaking to hiking and bird watching. 

The NPS gathers standardized annual surveys for each park unit to determine the percent of 

visitor satisfaction based on park facilities, visitor services, and recreational opportunities. 

During Fiscal Year 2002, based on a random visitor survey conducted by the University of 

Idaho, the park received a 98% visitor satisfaction ranking (NPS, 2002a). 

Tomales Point FMU. Approximately 500,000 visitors a year visit Pierce Point Ranch and use 

the trails in the Tomales Point FMU. An important draw to the area is the trail to the tip of 

Tomales Point and the opportunity to see the tule elk herds. One out of five visitors will also 

stop at McClures or Kehoe Beach while in this northernmost portion of the park. Kayakers from 

the east side of Tomales Bay will pull out along the east coast beaches; overnight camping on the 

beach is permitted. Tomales Point provides solitude and vistas of Tomales Bay and the Ocean. 

Park docents provide information to visitors during the Tule elk rutting season from August to 

early October. The area is designated wilderness (with the exception of a buffer along Pierce 

Point Road) and no bicycles are allowed. 

Headlands FMU. During the whale-watching season (December through April), the demand for 

visitation to the Headlands is so high and parking so limited that private vehicle use is restricted 

on weekends and visitors are shifted to a shuttle bus system. Sea lions, tule elk, shorebirds, and 

spring wildflowers all attract their share of eager observers. Year-round the historic lighthouse 

and Chimney Rock trail are heavily visited and unlike most areas of the park, visitors are 

relatively concentrated as they climb the lighthouse stairs or walk the short trail to Chimney 

Rock. Park staff provide interpretive programs on whales, wildflowers, pinnepeds, the lifeboat 

station, and the lighthouse. Lighthouse tours are also conducted once or twice a month in the 

evening. School programs are popular on weekdays during the school year. From June to 

September, most interpretive programs are held on the weekends. 

Inverness Ridge FMU. The principal visitor use in this FMU is hiking and some bicycling. The 

experience is largely one of solitude and of wide vistas taking in the 1995 burn area, Tomales 

Bay, and the Ocean. 

Estero FMU. The trail network in the Drakes Estero FMU does not receive high numbers of 

visitors according to monthly visitation counts. Portions of the trail network are open to 

bicyclists. The Estero is the site of harbor seal pupping from March 15 to June 30th. Other 

times of the year kayaks may put into the Estero from the area near Johnson’s Oyster Farm. The 

trail network is very popular year-round with birdwatchers and hikers. 
159 

Palomarin FMU. Primarily wilderness, visitors hike to the coast to see harbor seals and go down 

to the tidepools. The experience is largely solitary with a view of the coastline north to the 

lighthouse. Visitors hike into Bass Lake to swim. No bicycles are allowed. The area is popular 

with birdwatchers and PRBO runs volunteer programs and research mist netting programs. 

Highway One FMU. Visitors bicycle and horseback ride along the Olema Valley Trail and swim 

naked in Hagmeier Pond. Much of the visitation is from the highway corridor with occasional 

wildlife viewing at pulloffs. Mountain bikers can access the Bolinas Ridge Trail via McCurdy 

and Randall Trail. 

Bolinas Ridge FMU. Hiking and biking on the Bolinas Ridge Trail and connecting McCurdy 

and Randall Trails attracts roughly 35,000 visitors a year. Visitation is relatively light and the 

experience is solitary though traffic noise from Highway One is perceptible. 

Limantour FMU. The eastern portion of Limantour FMU includes the administrative offices and 

visitor center at Bear Valley. Nearly 700,000 visitors come to the visitor center annually and 

many continue to the Earthquake trail or Bear Valley trail. The Limantour and the Headlands 

FMUs have the highest visitor concentrations. Once visitors hike beyond the Bear Valley Trail 

to backcountry trails, the experience is remote from urban influences, though other hikers are 

seen regularly on the trails. Limantour Beach at the western end of the FMU is the closest beach 

to Highway One and the destination for approximately 180,000 visitors at year. The American 

Youth Hostel is sited in this FMU as is the Clem Miller Environmental Education Center. The 

Center has residential programs during the school year and service camps and weekend seminars 

in the summer months. The Limantour parking area is one of several points used to hike to the 

backcountry campsites. 

Wilderness North and South. Accessed from the Bear Valley Visitor Center, Five Brooks, and 

Limantour Road, the wilderness trails are popular with day hikers, backpackers, and horseback 

riders. A corridor through the wilderness permits mountain bikers to use trails to reach the 

backcountry campground. The trails get regular use and other trail users are frequently passed. 

Park Operations 

Staffing and Facilities 

The park has an outstanding and dedicated staff. Currently the park has about 90 permanent staff, 

23 term employees, and 47 temporary staff working on a variety of projects and programs. This 

represents about 115 FTE (full time equivalents or one person for a full year). During the peak 

summer months, the park staff increases to about 160 staff members, including Youth 

Conservation Corps enrollees who provide assistance in a number of ways to Point Reyes 

National Seashore. This work force is supplemented by 20,000 hours of Volunteers-in-Parks 

service, three Student Conservation Assistants, and AmeriCorps. 

The Fire Management Office is staffed by a Fire Management Officer, a program analyst, a 

hazardous fuels specialist, an eight-person hazard fuels crew, one engine foreman, and a fourperson engine crew. Three fire staff members are also trained as emergency medical technicians 
160 

at the basic life support level. Providing technical assistance to both the fire management offices 

at PRNS and GGNRA are technical staff including a GIS technical specialist, an education 

specialist, and an environmental planner. PRNS, GGNRA, and Pinnacles share a fire ecologist 

and a team of five fire effects monitors. PRNS has mutual aid agreements with Marin County 

Fire Department, Bolinas Fire Protection District, Inverness Public Utility District, and Nicasio 

Volunteer Fire Department. While PRNS has direct protection authority for federal lands, Marin 

County has been given “delegated initial attack responsibility” for these same lands. This allows 

Marin County to assume authority of initial suppression actions until Seashore firefighters arrive. 

PRNS (including GGNRA North District) maintains the necessary infrastructure to support an 

annual park visitation of 2.25 million people, provide offices, support structures and limited 

housing for the permanent and seasonal park staff. Park structures include: 

• 3 visitor centers 

• 2 environmental education centers 

• 30 restroom complexes 

• 4 backcountry campgrounds 

• 17 water systems 

• 147 miles of trails 

• Over 100 miles of roads 

• Over 100 public and administrative structures, and 

• 27 sewage treatment systems 

PRNS also manages and protects park cultural resources including: 

• 297 historic structures 

• 127 recorded archaeological sites 

• 11 identified cultural landscapes 

• 498,000 museum objects 

Financial resources available to achieve the park’s annual goals include a base-operating budget 

of approximately $4,900,000. In addition, the park receives supplemental support for fire 

operations, cyclic maintenance, special natural resource projects, and repair and rehabilitation of 

structures. Fire funding for operations is approximately $770,000 annually for wildfire 

suppression, mechanical treatments, and prescribed fire. For the last three years, Point Reyes 

and GGNRA have received an additional $700,000 annually for Wildland Urban Interface 

(WUI) projects. Staffing for all aspects for fire management is approximately 13 FTE’s. 

Commercial Leases/Permits 

Apart from the NPS program, there are numerous commercial leases within PRNS operating 

businesses, farms, ranches, and an aquaculture production. Leases include: 

• 7 dairies 

• 19 beef cattle ranches 

• Silage production on approximately 1,000 acres of land, 
161 

• Oyster production in Drakes Estero, and 

• Water supply to Bolinas Community 

Wilderness Operations 

More than half of PRNS, the 32,373-acre Philip Burton Wilderness Area, must be managed in 

conformance with the 1964 Wilderness Act, NPS Management Policies (NPS 2000, Chapter 6), 

and the Director’s Order and Reference Manual 41 for Wilderness Preservation and 

Management. Generally, the public purpose of wilderness in the national parks includes the 

preservation of wilderness character and wilderness resources in an unimpaired condition, as 

well as for the purposes of recreational, scenic, scientific, educational, conservation, and 

historical use. Management includes the protection of the areas, the preservation of the 

wilderness character, and the gathering and dissemination of information regarding their use and 

enjoyment as wilderness. 

The Wilderness Act requires that, except as necessary to meet the minimum requirements for the 

administration of a wilderness area, “there shall be no temporary roads, no use of motor vehicles, 

motorized equipment or motorboats, no landing of aircraft, or no other form of mechanical 

transport, and no structure or installation” within the wilderness. (16 U.S.C. 1131 et seq., Section 

4 (c)) 

Prescribed Fire and Fuel Reduction. Actions proposed under the FMP, such as prescribed burns 

and vegetation management actions, would be conducted to provide information to support 

objectives to return wilderness habitats to a more natural fire return internal conforming to data 

in the fire history record. 

As required by the Wilderness Act, actions necessary to prepare and execute prescribed burns, 

fuel reduction activities, and resource enhancement projects must be examined to assure that they 

are necessary. If so, the park is required to use the least invasive methods possible to carry out 

the needed treatment. This “minimum requirement” process is designed to ensure the least 

disturbance and disruption of wilderness values and maximum protection of natural and cultural 

resources. At PRNS, the examination of minimum requirements is undertaken and documented 

by the interdisciplinary team reviewing projects for compliance to the National Environmental 

Policy Act. 

NPS Management Policies (NPS, 2000, §6.3.5) outline the minimum requirement concept as a 

two-step process to determine: 1) whether the proposed management action is appropriate or 

necessary for administration of the area as wilderness and does not pose a significant impact to 

wilderness resources and character; and 2) which techniques and types of equipment should be 

used to ensure that impact to wilderness resources and character is minimized. 

If no strategy can be developed without seriously affecting wilderness resources or character, 

only actions that ultimately preserve wilderness character and/or have only localized, short-term 

adverse impacts can be implemented. In effect, the benefits must outweigh the impact and the 

decision must be well documented. 
162 

Use of motorized equipment and/or mechanical transport can be allowed only: If determined by 

the superintendent to be the minimum requirement needed by management to achieve the 

purposes of the area as wilderness, including the preservation of wilderness character and values; 

or In emergency situations (search and rescue) involving the health or safety of persons actually 

within the area. Such management activities would be conducted in accordance with all 

applicable regulations, policies, and guidelines, including minimum requirement protocols as 

practicable. 

Suppression of Wildland Fire. Director’s Order 41 (1999) states that all wildland fires within 

wilderness would be managed to include the application of minimum requirement suppression 

techniques, the consideration of firefighter and public safety, a cost/benefit analysis sensitive to 

natural and cultural resources, and the strategic and tactical options described in an approved fire 

management plan. Further, fire management plans must address the effects of fire management 

decisions on wilderness resources and character, air quality, smoke management, water quality, 

and other pertinent natural and cultural resource management objectives. Until a fire 

management plan is approved, all wildland fires in wilderness must be suppressed. 

Given the proximity of the Philip Burton Wilderness Area to developed areas and the potential 

for a wildland fire to spread beyond park boundaries, fire management planning at PRNS puts 

special emphasis on suppression of wildland fire in wilderness. According to Director’s Order 

41, if a wildland fire requires Point Reyes management to delegate fire-fighting authority, park 

personnel would first inform them of the appropriate emphasis on the protection of wilderness 

resources. The methods used to suppress all wildland fires should be those that minimize the 

impacts of the suppression action and the fire itself, commensurate with effective control and the 

preservation of wilderness values. 

Fire suppression actions in the wilderness would be directed by minimum requirement strategies 

geared to avoid resource impacts to the greatest extent feasible given the severity of the wildland 

fire. Information on the location of sensitive plant and wildlife habitats, cultural resources, 

wetlands, and creeks would be used to direct the construction of fire lines, siting of staging areas, 

water intake, and other potential impacting actions. Fire suppression teams at the park are 

trained in the concepts of wilderness fire management and minimum tool use. These techniques 

would be implemented to the extent feasible to control wildland fire and protect life and 

property. 

Current Activities in Wilderness. NPS activities in the Philip Burton Wilderness are restricted to 

those necessary to allow for safe recreational use of the area. Non-wilderness fire road corridors 

allow maintenance staff motorized vehicle access to clean the four backcountry campsites. 

Wilderness trails are brushed back every two to three years using hand tools to allow enough 

clearance for safe passage by recreational users. Special projects are implemented as needed and 

in conformance with minimum requirements assessments. For example, a bridge may be 

replaced on a hiking trail when needed for public safety and to prevent off-trail use and 

disturbance. Each project is assessed individually for potential effects on the environment and 

wilderness setting by an interdisciplinary team of park staff and in accordance with NEPA, the 

Endangered Species Act, the Wilderness Act, and NPS policies. Table 36 shows which of the 
163 

FMUs contain lands that are designated federal wilderness, how many acres of wilderness are 

included in each of these FMUs, and what percent of the FMU is federal wilderness. 

Table 36. Federal Wilderness in the Fire Management Units 

Wilderness Area Acreage 

FMUs within the Federal Wilderness Total 

Acres in FMU Acres of Wilderness in 

the FMU 

% of FMU in 

Wilderness 

Tomales Point 2,783 acres 2,746 acres 98.6% 

Headlands 881 acres 245 acres 28% 

Limantour 4,144 acres 2,518 acres 61% 

Wilderness North 1,591 acres 1,336 acres 84% 

Wilderness South 2,298 acres 1,480 acres 64% 

Highway 1 2,868 acres 67 acres 2% 

Palomarin 2,022 acres 843 acres 42% 

Source: Point Reyes National Seashore, GIS. 

Public Health and Safety 

The 2001 Federal Fire Policy sets the protection of human life as the first priority for federal 

wildland fire management; all federal Fire Management Plans and activities must reflect this 

commitment (Interagency Working Group, 2001). This is the reflected in the primary objective 

of the Point Reyes FMP - to protect firefighters and the public. Related FMP objectives are to 

protect private and public property, foster and maintain effective community and interagency fire 

management partnerships, and foster a high degree of understanding of fire and fuels 

management among park employees, neighbors, and visitors. 

The Federal Fire Policy is being implemented through the National Fire Plan, which recognizes 

that effective fire management requires close coordination of federal agencies with local 

communities, particularly those communities that are in the wildland-urban interface. As the 

management of private lands has become a key factor in the fire-risk equation, the federal 

government has recognized the importance of providing outreach, education, and support for 

local communities who play a primary role in reducing fire hazards in and near their 

communities. 

As part of the data gathering process in support of the National Fire Plan, the federal government 

identified key communities nationwide at risk from wildfire due to their proximity to federal 

lands managed by the Departments of Agriculture and Interior. An extensive listing was 

published in the Federal Register (Vol. 66, #160, Friday, 8/17/01) and included Inverness, 

Bolinas, and Olema, as well as communities near Point Reyes National Seashore. In recognition 

of potential risk, the National Park Service, through the Wildland Urban Interface Program, has 

been funding fire education, fuel reduction, and roadway improvement projects in these 

communities; 2002 is the third year of local National Fire Plan funding. 

Prioritization of projects needed in the wildland urban interface has been informed by a study of 

strategies for rehabilitating the resources in the Vision Fire burn area and preventing similar 

occurrences in the future. Prepared for the Environmental Action Committee of West Marin, 
164 

“After the Vision Fire,” prepared by the Phoenix Team, documented many of the projects that 

have subsequently been funded and implemented on private and federal lands with Wildland 

Urban Interface funding. 

Like the National Fire Plan, the EAC Phoenix Report (1996) recognizes that the most 

fundamental line of defense to increase public safety is to promote conformance with code 

requirements for defensible space and reduced fuels around homes and along streets providing 

emergency ingress and egress. No amount of fuel reduction on federal lands can compensate for 

the hazards presented by high fuel loading on private lots. Many of the fire education, 

community chipper programs, safety assessments, and roadway improvement projects funded by 

the NPS have focused facilitating code conformance on private property. 

In the first two years of Wildland Urban Interface (WUI) funding, projects in the interface with 

PRNS focused on public health and safety by: 

• Improving the safety of subdivision roads that would be used as evacuation routes by 

residents and for ingress and egress by emergency responders, 

• Providing assessments for individual homeowners on safety deficits on their properties, 

• Providing chipper days in several communities to facilitate disposal of vegetation cleared 

from private lots, and 

• The dissemination of fire education materials promoting defensible space concepts. 

In the Inverness/Inverness Park area, over 16 miles of subdivision roads, have had roadside 

vegetation brush cut or thinned to reduce fuels, overhanging branches limbed up to provide 

overhead vehicle clearance for emergency vehicles, trees presenting treefall hazard removed, and 

pullouts and turnarounds either re-established or constructed. Fire hazard assessments were 

completed for the Seahaven and Paradise Ranch Estates subdivisions with each private parcel 

rated under four safety categories. This information is provided to the homeowner to help them 

understand the relative hazard presented by the condition of their parcel and help the homeowner 

focus their efforts in productive directions. 

The next round of WUI funded projects focus on creating shaded fuel breaks between open space 

lands and residential areas in addition to continued chipper days, further education materials, and 

a hazard assessment program for Bolinas. The fuel breaks would serve as zones of reduced fuel 

to slow the progress of wildland fires, provide firefighters with an area from which to launch 

suppression actions, and provide alternate evacuation routes to residents. The proposed fuel 

break would cross state park, national park, and private-held lands. 

The FMP alternatives demonstrate a clear focus on reducing risk to neighboring communities by 

identifying project areas on the federal side of the interface that complement the WUI projects on 

private and state-owned lands. FMP projects in the Inverness Ridge, Limantour, Palomarin, and 

Olema FMUs would improve safety to responding firefighters, reduce fuels along existing fire 

roads, and create zones of reduced fuels to impede fire spread. 
165 

Following the completion of the EIS process, the park will select one alternative to become the 

FMP. It will be a procedural document outlining response, suppression, and proactive strategies 

for managing fire in PRNS. The FMP would be implemented by the Point Reyes Fire 

Management Office staff led by the Fire Management Officer under the direction of the 

Superintendent, a program analyst, a hazardous fuels specialist, a 10-person hazard fuels crew, 

and 1-2 engine technicians. The Fire Management Office staff and equipment has been housed 

in the southern portion of the Peninsula. As part of the current FMP EIS, PRNS is proposing to 

move the Fire Management Office to a new fire cache building at the central area of the park in 

Bear Valley (for further description see Alternatives, Actions Common to All Alternatives). The 

move would improve communication, response time, and facilitate coordinated efforts with the 

local fire departments in Inverness and Point Reyes Station. 

The principal effect of FMP activities on public health is generation of smoke, especially 

particulate matter, from prescribed fires and unintended wildland fire. Particulate matter, found 

in the air-liquid droplets and small solid particles of minerals and soot can penetrate deep into the 

lungs. In smoke, roughly 80% of the particulate matter is smaller than 2.5 micrometers in 

diameter. 

Healthy adults are not usually at risk from particulate matter; they may experience runny noses 

and coughing but these symptoms usually subside as the smoke disperses. People with heart or 

lung diseases, such as congestive heart disease, chronic obstructive pulmonary disease, 

emphysema or asthma, can be at risk. People with these conditions may find it difficult to 

breathe, may cough or feel short of breath. Children and the elderly are generally more 

susceptible to the harmful effects of smoke (CARB, 2003). 

Baseline air quality information is found in this chapter under the heading of Air Quality. The 

Bay Area Air Quality Management District (BAAQMD) in accordance with the California 

Smoke Management Guidelines manages the generation of smoke by prescribed burning. The 

goal of smoke management guidelines is to continue prescribed burning as a resource 

management tool while minimizing smoke impacts to public health in populated areas. 

Socio-Economics 

PRNS is one of the 30 most visited parks in the National Park System. It is a destination park for 

national and international visitors, as well as a regularly visited resource for the 5 million 

residents of the 9 counties that comprise the greater San Francisco Bay Area. Visitation to the 

park is approximately 2.5 million annually and unusually is consistent year round, averaging 

roughly 200,000 visitors monthly. 

Marin County has a $500 million annual tourist industry. It is estimated that PRNS contributes 

over $150 million to the regional economy visitor expenditures on dining, fuel, gifts, groceries, 

and lodging (NPS, 2002a). According to a visitor survey conducted by Sonoma State University 

(1997), 74% of the visitors to Point Reyes National Seashore are traveling to the Seashore as 

their main destination, 50% of park visitors are staying between 2-6 hours in the park (30% 
166 

overnight), and 40% of visitation comes from Marin, Sonoma, and San Francisco Counties 

(16.5% come from outside of California). 

Point Reyes National Seashore received 2.35 million visitors in 2000 accounting for 930 travel 

party days/nights in the area. An average visitor party spends $94 per party per night in the local 

area ($109 if locals excluded). Total visitor spending was $87 million in 2000, $80 million 

excluding local visitors. This spending of visitors from outside the local region generates $69 

million in sales by local tourism businesses, yielding $25.6 million in direct income and 

supporting 1,100 jobs. Each dollar of tourism spending yields another $.63 in sales through the 

circulation of spending within the local economy. Including these secondary effects, the total 

economic impact of the park on the local economy is $113 million in sales, $42 million in wages 

and salaries, and 1,800 jobs (Michigan State University, 2001). 

The park has not received complaints from visitors during past prescribed fires in the park (pers. 

comm. Neubacher, 2003). Park visitation dropped dramatically for the first few months after the 

1995 Vision Fire, but returned to normal within six months. 
167 
168 

CHAPTER 4: 

ENVIRONMENTAL 

CONSEQUENCES 
169 

INTRODUCTION 

This chapter provides a detailed analysis and discussion of the probable environmental 

consequences, or impacts, of implementing each of the three alternatives. The chapter begins 

with a discussion of methods used to conduct the environmental impact assessment, including 

general definitions related to the impact analysis. These are followed by a description of the 

methods used to assess impacts for each impact topic (e.g., air quality, water quality, etc.), 

including relevant policies, regulations, and assumptions. 

Following the sections on impact assessment methodology, the environmental impacts related to 

each impact topic for Alternatives A, B, and C are comprehensively addressed. 

The analysis for each impact topic includes the following: 

• Identification of the types of impacts associated with the various actions comprising the 

alternative; 

• Characterization of the impacts, including their duration and intensity; 

• Available mitigation measures that would be applied and the effectiveness of these 

measures on reducing impacts; 

• An assessment of cumulative impacts; 

• A statement on the potential for implementation of an alternative to impair resources 

(based on the National Park Service policy on impairment); and 

• A conclusion (Conclusions will be the last subsection). 

With the exception of the cultural resource analysis, all impacts have been assessed assuming 

that the mitigation measures that are discussed would be implemented. Cultural resource impact 

analysis in this EIS is described in terminology consistent with the regulations of the Council on 

Environmental Quality (CEQ) and will comply with requirements of both the NEPA and Section 

106 of the NHPA. The determination of effect for the undertaking (implementation of the 

alternative) required by the National Park Service Agreement is included in the “conclusion” 

section of each alternative. 

DEFINITION OF TERMS 

Three separate aspects of impacts are described for each impact topic for each alternative: the 

type of impact, the duration of impact, and the intensity of impact. For purposes of this analysis, 

these aspects are defined as follows: 

Type of impact - The type of impact describes the specific elements that could be subject to 

impacts and the nature of those impacts. Impacts can be either beneficial or adverse. 

Duration of impact - The duration of impact describes the relative length of time the impact 

would affect a given resource. Impacts can be either short-term or long-term, and are defined for 
170 

each impact topic in a range of years. It is important to note that an action that has short-term 

adverse effects on a resource may have long-term beneficial impacts on the same resource. 

Intensity of Impact - Identifies the degree to which a resource would be affected by an element 

of an alternative. Each impact is described as negligible, minor, moderate, or major. These four 

designations are used for beneficial as well as adverse impacts. 

NEPA requires consideration of the direct, indirect, and cumulative impacts of proposed actions. 

The CEQ regulations (Section 1508.7) define a cumulative impact as “the impact on the 

environment which results from the incremental impact of the action when added to other past, 

present, and reasonably foreseeable future actions regardless of what agency (federal or nonfederal) or person undertakes such other actions.” Cumulative impacts can result from 

individually minor but collectively significant actions taking place over a period of time. 

“Reasonably foreseeable future actions” include planning or development activities that currently 

are being implemented or would be implemented in the reasonably foreseeable future. 

A list of actions that could contribute to cumulative impacts is provided in Appendix C. In the 

cumulative impact analyses in this EIS, the impacts of these actions are assessed in conjunction 

with the impacts of each alternative for each impact topic. 

In the conclusion section is a statement regarding whether or not implementing the alternative 

would cause resource impairment. The NPS Organic Act of 1916 and the NPS General 

Authorities Act 1970, as amended, require park managers to ensure that park resources and park 

values remain unimpaired. Section 1.4.5 of the NPS Management Policies (NPS, 2000) states: 

“The impairment that is prohibited by the Organic Act and the General Authorities Act is an 

impact that, in the professional judgment of the responsible NPS manager, would harm the 

integrity of park resources or values, including the opportunities that otherwise would be present 

for the enjoyment of those resources or values.” 

The Management Policies further state, “An impact to any park resource or value may constitute 

an impairment. An impact would be more likely to constitute an impairment to the extent that it 

affects a resource or value whose conservation is: 

• Necessary to fulfill specific purposes identified in the establishing legislation or 

proclamation of the park; 

• Key to the natural or cultural integrity of the park or to opportunities for enjoyment of the 

park; or 

• Identified as a goal in the park’s general management plan or other relevant NPS 

planning documents. 

An impact would be less likely to constitute an impairment to the extent that it is an unavoidable 

result, which cannot reasonably be further mitigated, of an action necessary to preserve or restore 

the integrity of park resources or values.” 
171 

REGULATIONS AND METHODOLOGY BY IMPACT TOPIC 

Applicable regulations, policies, and methods used to assess the environmental consequences of 

the three alternatives on the following impact topics are described in the succeeding sections: 

• Soils 

• Air Quality 

• Water Resources and Water Quality 

• Vegetation 

• Wetlands 

• Wildlife 

• Special Status Species (e.g., Threatened, Endangered, Rare and Sensitive Species) 

• Cultural Resources 

• Visitor Use and Visitor Experience 

• Park Operations 

• Public Health and Safety 

• Socioeconomics 

Soils 

Policies and Regulations 

As directed by NPS Management Policies, soil resources are subject to the “no impairment” 

clause that guides NPS decision-making to protect of the integrity of the important resources and 

values within the parks (NPS, 2000, §1.4.6). The NPS is directed to protect geologic features 

from the adverse effects of human activity, while allowing natural processes to continue (NPS, 

2000, §4.1.5 and §4.8.2). Management action taken by the parks would prevent to the greatest 

extent possible the unnatural erosion, physical removal, contamination, and other potentially 

irreversible impacts to soil (NPS, 2000, §4.8.2.4). 

Hydric soils, associated with wetland features such as bogs, marshes, and some wetlands, are 

afforded special protection by Executive Order 11990, Protection of Wetlands and the Clean 

Water Act Section 404 as regulated by the U.S. Army Corps of Engineers, and the State 

Regional Water Quality Control Board. Specific procedural guidance to NPS staff on the 

protection of wetlands and areas of hydric soils is outlined in Director’s Orders 77-1, Wetland 

Protection. Assessment of potential FMP impacts to hydric soils is addressed as a water quality 

impact in this document. 

The NPS Natural Resource Management Guidelines (Director’s Order 77) contain objectives for 

the protection of soils in the four natural resource management zones used in NPS planning: 

Assessment Methodology 

The discussion of potential impacts to soils from implementation of the FMP alternatives will 

address degradation or depletion of soil resources. Sedimentation of creeks and water bodies is 

addressed under the heading of hydrology/water quality. 
172 

Determination of Effect. The primary source for information on Seashore soils is the 1979 Soil 

Conservation Service Soil Survey of Marin County. With few exceptions, limited information 

exists on specific baseline biotic, chemical, and compositional condition of the numerous soil 

units in the park beyond the generalized information provided in the Soil Survey. In this respect, 

the determination of effect on soils is based on both direct effects to soil resources and inferred 

from the observation of indirect effects manifested by a change in the vigor of the vegetation 

supported by soils or a change in the rate of sedimentation in runoff reaching creeks and ponds. 

The determination of the degree of impact on soils for the FMP was developed from the direct 

and repeated field experience of Seashore staff and/or the conservative application of generally 

accepted research findings on the effects that fire management actions have on soil. These 

include the reaction of soil resources to both well-established routine activities, such as 

mechanical clearing and controlled burning, and to non-routine fire suppression actions that vary 

greatly depending on the specific challenges of each occurrence. 

Long-term impacts to soils including changes to soil chemistry, creation of subsurface 

hydrophobic layers, changes in soil particle composition or mixing, or loss of the soil profile 

may take years or decades to recover. Short-term impacts are defined as effects to soil processes 

that are abated through natural processes or aided by use of standard protective practices within 

four years of the action. Soil productivity and slope stability is regained within this time period. 

The first winter season following the Vision Fire, runoff and erosion increased in the granitic 

soils of the Inverness Ridge due to increased hydrophobicity (water repellency) and an overlying 

crust–like layer. These characteristics diminished following the second year post-fire. 

Accelerated cutting of stream channels slowed markedly within three years post-fire (B. 

Ketcham, pers. comm). 

Actions with negligible impact are those that are either inherently benign or with effects 

mitigated to a less than detectable level by the procedural standards, such as erosion control 

practices, implemented as part of the proposal. Actions with minor impacts would be limited in 

scope and effect to soils. For example, a low intensity prescribed fire may have several limited 

affects on soils such as a short-term reduction in protective vegetation cover and consequent 

slight increase in the rate of soil erosion in an area remote from sensitive water resources. 

It is important to assess impacts to soil resources on a system and process level. Watershed scale 

allows consideration of soil loss and deposition to downstream water resources. Prescribed 

burns would also likely be designed within a watershed to avoid inclusion of higher, steeper 

slopes between two watersheds. A stable watershed requires 30% to 50% effective soil cover 

(ESC) (BAER, 1996). The Forest Service considers a watershed with more than 75% effective 

ground cover to be in good hydrologic condition wherein only about 2 percent or less of rainfall 

becomes surface runoff, and erosion is low (Robichaud et. al., 2000). 

Effective soil cover includes larger rock fragments, thick leaf litter, plant cover, and mat-forming 

vegetation in contact with the soil surface. As a conservative threshold with high confidence, 

impacts to soils within a watershed are deemed minor if FMP actions affect less than 10% of an 

FMP watershed. 
173 

A moderate impact results when more than 10% and less than 25% of the effective soil cover in 

an FMP watershed is disturbed in one year with impacts to soil resources that are readily 

correctable by the application of standard erosion control practices. Examples could include a 

prescribed fire in terrain that gradually slopes that requires erosion control only in limited areas 

that are oversteepened. Moderate impacts could also result from a wildland fire greater than 

10% of a watershed or that required limited use of heavy equipment but burned at a relatively 

low intensity with little effect on overall soil properties. 

Major impacts to soil resources are those that substantially change soil processes or vital soil 

characteristics in widespread areas of one or more resource watersheds and may trigger related 

important effects to other park resources such as plants, wildlife, visitor experience, or cultural 

resource sites. Major impacts to soil resources also include prescribed fire or wildland fire 

affecting more than 25% of a resource watershed in one year. 

Type of Impact 

Beneficial: Protects or enhances properties of native soils and promotes or restores natural 

soil processes. 

Adverse: Degrades the characteristics of native soils, exposes soils to accelerated rates of 

erosion, results in loss of native soils, or contributes to slope failure. 

Duration of Impact 

Short-term: Impacts are limited to the first four years after treatment or wildland fire. 

Long-term Impacts persist four years after treatment or wildland fire. 

Intensity of Impact 

Negligible: No quantifiable impact and/or reasonably anticipated type of effect based on 

current knowledge of soil characteristics. 

Minor: Fire management actions or incidents of wildland fire confined to plots 

comprising less than 10% of the total area of an FMP resource watershed wherein 

rate of post-action erosion can be controlled by standard practices; there is low 

potential for changes to soil productivity. 

Moderate: Fire management actions or wildland fires affecting more than 10% and less than 

25% of the total area of an FMP watershed wherein the rate of post-action erosion 

would be controlled by the application of standard erosion control practices, and 

little change in soil productivity. 

Major: Fire management actions or wildland fires affecting more than 25% of the total 

area in an FMP watershed or more than 10% of total area of the watershed with 

impacts that reduce soil productivity or produce rates of erosion that are not 

readily correctable by best management practices. 
174 

Air Quality 

Background. Similar to many other national parks near urban areas, the response to wildland fire 

in the PRNS has been full suppression. One of the results of suppression is the build up of areas 

of high fuel loading within the park that has increased the potential for a high intensity wildland 

fire to occur. The events of October 3 – 8, 1995, when the Vision Fire burned 12,354 acres 

provide a dramatic example of that potential. To address the existing hazard, the fire 

management program at PRNS has been conducting prescribed burns on several hundred acres 

within the park each year to reduce fuels in critical areas. 

Prescribed burning, proposed in the FMP alternatives, would continue this reduction of high fuel 

loading within the project area. Continued fuel reduction at key locations would reduce the 

potential for a large, uncontrollable fire that could generate substantial air pollution emissions 

and impact regional air quality. As required by the Clean Air Act regional haze provisions, all 

prescribed fires would continue to be planned and implemented within the Bay Area Air Quality 

Management District’s (BAAQMD) Smoke Management Program. 

The air quality assessment will evaluate the potential impacts of pollutants generated by the 

maximum allowable acreage that can be treated by prescribed burning and mechanical treatment 

for each FMP alternatives. 

Policies and Regulations 

National Ambient Air Quality Standards. PRNS is classified as a Class I area under the Clean 

Air Act (42 USC 7401 et seq.). The Act requires land managers of Class I areas to protect air 

quality and related values, including visibility, plants, animals, soils, water quality, cultural and 

historic structures, and visitor health from the effects of air pollution. Values must be protected 

from any future impairment and remedies sought for any existing impairment from humancaused sources of air pollution. A cooperative program, the Interagency Monitoring of Protected 

Visual Environments (IMPROVE), between the EPA, federal land managers, and state air 

agencies, was formed to monitor visibility in the Class I areas. 

Data published in a recent IMPROVE report shows that visibility at PRNS improved during the 

period of 1996 to 1999 primarily due to a decrease in nitrate particulates, a major component of 

visibility blocking material in coastal California. Particulate nitrate is formed from nitrogen 

oxide and hydrocarbon gases emitted into the atmosphere from fires, diesel engines, and other 

sources (Malm, 2000). Monitoring by the NPS found no exceedances for ozone at PRNS under 

either the California or federal standard. The park air resources are rated as having low exposure 

to ozone, sulfur, and nitrogen emissions and low potential for acidification of surface waters. A 

recent NPS report states, “There are no significant air pollution effects concerns in this park 

[PRNS] at the present time” (Sullivan, et.al., 2001). 

The Clean Air Act (CAA) charges the Environmental Protection Agency (EPA) with identifying 

national ambient air quality standards to protect public health and welfare. Standards have been 

set for seven pollutants: ozone (O3), carbon monoxide (CO), nitrogen dioxide (NO2), sulfur 
175 

dioxide (SO2), particulate matter less than 10 microns (PM10), very fine particulate matter less 

than 2.5 microns in diameter (PM2.5), and lead (Pb). Section 176 of the Act requires federal 

actions to conform to state implementation plans for achieving and maintaining the air quality 

standards. Federal actions cannot cause or contribute to new violations, increase the frequency 

or severity of any existing violation, interfere with timely attainment or maintenance of a 

standard, delay emission reduction milestones, or contradict the State Implementation Plan. The 

conformity rule applies to federal non-attainment areas, such as the Bay Area Air Basin. If a 

standard is exceeded more than three times in three years in an air basin it is considered a nonattainment area and is then be subject to more stringent planning and pollution control 

requirements. Table 37 presents the current federal and California ambient air quality standards. 

Table 37. Ambient Air Quality Standards & Bay Area Attainment Status 

California Standards1 National Standards2 

Pollutant Averaging Time Concentration Attainment 

Status Concentration3 Attainment 

Status 

8 Hour 0.08 ppm N

Ozone (O3) 

1 Hour 0.09 ppm (180 μg/m3

) N 0.12 ppm 

(235μg/m3

) N4 

8 Hour 9.0 ppm (10 mg/m3

) A 

9 ppm 

(10 mg/m3

) A5 Carbon Monoxide 

(CO) 

1 Hour 20 ppm (23 mg/m3

) A 

35 ppm 

(40 mg/m3

) A 

Annual 

Average 

0.053 ppm 

(100 μg/m3

) A Nitrogen Dioxide 

(NO2) 

1 Hour 0.25 ppm (470 μg/m3

) A 

Annual 

Average 

80 μg/m3

(0.03 ppm) A 

24 Hour 0.04 ppm (105 μg/m3

) A 365 μg/m3

(0.14 ppm) Sulfur Dioxide (SO2) A 

1 Hour 0.25 ppm (655 μg/m3

) A 

Annual Arithmetic 

Mean 20 μg/m3

 N6 50 μg/m3 Particulate Matter A 

(PM10) 

24 Hour 50 μg/m3

 N 150 μg/m3 U 

Annual Arithmetic 

Mean 12 μg/m3

 N6 15 μg/m3 Particulate Matter - U 

Fine (PM2.5) 

24 Hour 65 μg/m3

 U 

Sulfates 24 Hour 25 μg/m3 A 

Calendar Quarter 1.5 μg/m3 A Lead (Pb) 

30 Day Average 1.5 μg/m3

 A 

Hydrogen Sulfide 1 Hour 0.03 ppm (42 μg/m3) U 

Vinyl Chloride 

(chloroethene) 24 Hour 0.010 ppm (26 μg/m3

)

No 

information 

available 
176 

Visibility Reducing 

particles 

8 Hour (1000 to 1800 

PST) (See note 7) A 

A=Attainment N=Nonattainment U=Unclassified 

ppm=parts per million mg/m3=milligrams per cubic meter μg/m3=micrograms per cubic meter 

1

 California standards for ozone, carbon monoxide (except Lake Tahoe), sulfur dioxide (1-hour and 24-hour), nitrogen dioxide, 

suspended particulate matter - PM10, and visibility reducing particles are values that are not to be exceeded. The standards for 

sulfates, Lake Tahoe carbon monoxide, lead, hydrogen sulfide, and vinyl chloride are not to be equaled or exceeded. If the 

standard is for a 1-hour, 8-hour or 24-hour average (i.e., all standards except for lead and the PM10 annual standard), then some 

measurements may be excluded. In particular, measurements are excluded that ARB determines would occur less than once per 

year on the average. The Lake Tahoe CO standard is 6.0 ppm, a level one-half the national standard and two-thirds the state 

standard. 

2. National standards other than for ozone, particulates and those based on annual averages are not to be exceeded more than once 

a year. The 1-hour ozone standard is attained if, during the most recent three-year period, the average number of days per year

with maximum hourly concentrations above the standard is equal to or less than one. The 8-hour ozone standard is attained when 

the 3-year average of the 4th highest daily concentrations is 0.08 ppm or less. The 24-hour PM10 standard is attained when the 3-

year average of the 99th percentile of monitored concentrations is less than 150 μg/m3. The 24-hour PM2.5 standard is attained 

when the 3-year average of 98th percentiles is less than 65 μg/m3

. 

Except for the national particulate standards, annual standards are met if the annual average falls below the standard at every site. 

The national annual particulate standard for PM10 is met if the 3-year average falls below the standard at every site. The annual 

PM2.5 standard is met if the 3-year average of annual averages spatially-averaged across officially designed clusters of sites falls 

below the standard. 

3. National air quality standards are set at levels determined to be protective of public health with an adequate margin of safety. 

Each state must attain these standards no later than three years after that state's implementation plan is approved by the 

Environmental Protection Agency. 

4. In August 1998, the Bay Area was redesignated to nonattainment-unclassified for the national 1-hour ozone standard. 

5. In April 1998, the Bay Area was redesignated to attainment for the national 8-hour carbon monoxide standard. 

6. In June 2002, CARB established new annual standards for PM2.5 and PM10. 

7. Statewide VRP Standard (except Lake Tahoe Air Basin): Particles in sufficient amount to produce an extinction coefficient of 

0.23 per kilometer when the relative humidity is less than 70 percent. This standard is intended to limit the frequency and severity 

of visibility impairment due to regional haze and is equivalent to a 10-mile nominal visual range. 

Source: http://www.baaqmd.gov/pln/ambientairquality.asp. Updated January 2003. 

The EPA has developed regional haze regulations to improve visibility or visual air quality in 

national parks and wilderness areas across the country (EPA, 1999). In developing these rules, 

the EPA recognized that both prescribed and wildland fires contribute to regional haze; that there 

is a complex relationship between what is considered a natural source of fire versus a humancaused source of fire. In many instances, the purpose of prescribed fires is to restore the natural 

fire regime to forest ecosystems to prevent future catastrophic fires that can detrimentally affect 

air basin air quality. The EPA works to support state and federal land managers in the 

development of enhanced smoke management plans to minimize the effects of fire emissions 

from prescribed fires on pubic health and welfare. 

California Ambient Air Quality Standards. The Federal Government has ceded responsibility and 

authority to establish air quality standards and regulations to the States. Therefore all NPS areas 
177 

are required to comply with state laws on these matters regardless of the type of legal jurisdiction 

that applies to other activities within the NPS unit. 

To protect public health and welfare, the California Air Resources Board (CARB) has set stricter 

ambient air quality standards than national standards. Under the 1988 California Clean Air Act, 

air basins were designated as attainment, non-attainment, or unclassified for the state standards. 

State implementation plans identify measures designed to bring non-attainment areas into 

attainment. Basic components of state implementation plans include legal authority, an 

emissions inventory, an air quality monitoring network, control strategy demonstration 

modeling, emission limiting regulations, new source review provisions, enforcement and 

surveillance strategies, and other programs necessary to attain standards. 

The CARB is responsible for disseminating regulations about air quality, including state ambient 

air quality standards and area designations, emissions from motor vehicles, fuels and consumer 

products, and airborne toxic control measures. Title 17 of the California Code of Regulations, 

titled Smoke Management Guidelines for Agricultural and Prescribed Burning, provides 

direction to air pollution control and air quality management districts for the regulation and 

control of agricultural burning, which includes prescribed burning. The guidelines are intended 

to allow the use of prescribed burning as a management tool, while minimizing smoke impacts 

on the public. 

San Francisco Bay Area Air Quality Management District (BAAQMD). BAAQMD is the air 

quality management district for the project area and has primary responsibility for control of air 

pollution from prescribed burning. BAAQMD has procedures that must be followed prior to 

implementation of a prescribed burn plan. For all prescribed fires, BAAQMD requires 

submission of the individual burn plan at least one month prior to the proposed burn. BAAQMD 

then issues a forecast 72-hours prior to the proposed date and gives a final commitment to permit 

the burn on the day of the burn itself, though forecasts with increasing confidence can be 

obtained at 96-hours, 72-hours, 48-hours, and 24-hours prior to the burn day to support moving 

forward on all the logistical planning needed to conduct a prescribed burn. 

National Park Service Guidance and Policies. NPS Management Policies direct superintendents 

to comply with all federal, state, and local air quality regulations and permitting requirements 

when conducting prescribed burns (NPS, 2000, §4.7.1.). In addition to the requirements of the 

CAA, specific guidance has been developed by the EPA to address prescribed burning. These 

are supplemented by guidance and policies such as the Federal Wildland Fire Management 

Policy and the EPA’s Interim Air Quality Policy on Wildland and Prescribed Fires. These 

policies direct federal agencies to consider ambient air quality below the national ambient air 

quality standards for PM2.5 and PM10 as the principal indicator of adverse impacts to public 

health. Poor visibility is used as the principal indicator of adverse impact to public welfare. The 

Natural Events Policy addresses public health impacts from wildland fires. 

An objective of CARB and NPS directives is to minimize smoke impacts on people and on 

sensitive receptors in and near national parks. Sensitive receptors can include towns, villages, 

hospitals, schools, nursing homes, campgrounds, trails, scenic vistas, and Class I areas such as 
178 

PRNS. Selection of sensitive receptors is based on guidance from the California Code of 

Regulations Title 17, Smoke Management Guidelines for Agricultural and Prescribed Burning, 

and through consideration of the local setting including demographics, wind patterns, and local 

climatic conditions. 

NPS-77 (Natural Resource Management Guidelines) states: “The National Park Service will seek 

to perpetuate the best possible air quality in parks because of its critical importance to visitor 

enjoyment, human health, scenic vistas, and the preservation of natural systems and cultural 

resources. The Park Service will assume an aggressive role in promoting and pursuing measures 

to safeguard [air quality related values] from the adverse impacts of air pollution. In cases of 

doubt as to the impacts of existing or potential air pollution on park resources, the Park Service 

will err on the side of protecting air quality and related values for future generations.” 

Assessment Methodology 

Fire management actions could affect air quality in the project area through smoke emissions 

from wildland and prescribed fires, and from exhaust generated by machinery used in site 

preparation for prescribed burns, mechanical fuel reduction projects and suppression activities. 

Method of Estimating Smoke Emission. The First Order Fire Effects Model 5.0 (FOFEM) was 

used to generate emission factors for PM10, PM2.5, volatile organic compounds (VOC), CO 

(carbon monoxide), and CO2 (carbon dioxide) for the maximum allowable fire management 

actions under each alternative. FOFEM is a computer-based model that provides quantitative 

predictions for planning prescribed fires, conducting impact assessments, and for long-range 

planning and policy development. FOFEM is the standard modeling program used to 

demonstrate conformity with applicable environmental impact rules and regulations. The model 

also provides fire effects information on potential tree mortality, fuel consumption, mineral soil 

exposure, and smoke generation (Reinhardt, 1997). The smoke module of FOFEM does not 

predict smoke dispersion or model the impairment of local visibility. 

The FOFEM smoke module requires a number of inputs related to burn characteristics such as 

fuel category, cover type, fuel loading, moisture content, and percent of crown burn. For this 

assessment, PRNS fire management staff described representative burn parameters for each burn 

unit. The area of each cover type in a given prescribed burn unit was determined based on the 

expertise of the fire management staff draft and vegetation mapping of the project area. The 

burn unit cover types were then correlated with the Society for American Foresters 

(SAF)/Society for Range Management (SRM) vegetation types for use in the FOFEM model. 

Where a direct correlation between cover types was not possible, a surrogate SAF/SRM cover 

type was selected. Table 38 provides a cross-reference for cover types. 
179 

Table 38. Vegetation Cover Types Used in Air Quality Emissions Analysis 

FM Vegetation Class SAF1

/SRM2 Type 

Valley grassland, Annual grassland SRM 208 

Ceanothus, mixed chaparral SRM 215 

Pacific Douglas-fir SAF 229 1

Society for American Foresters (SAF) 2Society for Range Management (SRM) 

The results of the FOFEM model were used to develop average emission factors (per acre) that 

are used to quantify the amount of pollutants generated by the maximum prescription burning 

allowed for each alternative. For a given prescribed burn unit and pollutant, the emissions were 

quantified by the following equation: 

 n 

E = ∑ EFc*Ac, where 

 c=1 

E = emissions in tons/year 

Efc = emission factor for coverage c in tons/acre 

Ac = area of coverage in acres 

Separate FOFEM runs were used to develop emission factors for wildland fires, since these 

typically burn under drier conditions and consume more fuel, particularly crown and branch 

fuels, and produce higher emissions. PRNS staff provided burn parameters based on recent 

wildland fires to model these emissions. 

Both the prescribed and wildland fire emission factors predicted by FOFEM are higher than 

similar emission factors in the EPA’s Compilation of Air Pollution Emission Factors (AP-42) for 

the same region. However, the AP-42 derived emission factors are generalized for large regions 

and “can vary by as much as 50 percent with fuel and fire conditions” (EPA, 1996). Since fuel 

loading in many areas of PRNS may be heavier than normal due to decades of fire suppression, 

the emission factors used here can be considered better represent PRNS conditions. 

FOFEM does not provide emission factors for nitrogen oxide (NOx). According to EPA AP-42, 

the emission factors for NOx from wildland and prescribed fires are approximately 35 times less 

than those for CO emissions. Therefore, the CO emission factors produced by the FOFEM 

model were scaled down proportionately to estimate NOx emission factors. Table 39 provides 

the emission factors used for each fire type. 
180 

Table 39. Smoke Emission Factors by Fire Type 

EMISSION FACTOR (LBS/ACRE)1

Fire type Ecosystem PM10 PM2.5 VOC (CH4) CO NOx 

grass2 Prescribed Fire 11 9 3 23 1 

brush3 190 161 49 404 12 

Understory Fire forest4 5,046 4,276 2,595 56,899 1,626 

grass2

 11 9 3 23 1 

brush3

 190 161 49 404 12 

Low Intensity 

Wildfire 

forest4

 3,430 2,907 1,760 38,524 1,101 

grass2 11 9 3 23 1 

brush3

 190 161 49 404 12 

High Intensity 

Wildfire 

forest4

 5,108 4,329 2,622 57,419 1,641 

Notes 

1. PM10 = Suspended Particulate Matter, PM2.5 = Fine Particulate Matter, CH4 = Methane , CO = Carbon Monoxide, NOx 

= Nitrogen Oxides 

2. Grass = SRM 208 vegetation areas 

3. Brush = SRM 215 vegetation areas 

4. Forest = SAF 229 vegetation areas 

Annual inputs for wildland fire is based on 30 acres burned per year during 3 to 5 fire starts, a 

conservative estimate of wildland fire in the PRNS according to the PORE Fire Management 

Officer (pers. comm. Roger Wong, 7/29/03). The wildfire acreage is split up as 20 acres of 

grassland, 8 acres of shrubland, and 2 forested acres. The low incidence and limited acreage of 

wildland fire annually in the study area is due primarily to a very low incidence of deliberate fire 

starts on the part of the public and the wetter than usual summertime conditions of western 

Marin. The 30-acres of wildfire is consistent throughout the alternatives. Therefore, the 

difference in estimated annual emissions in the three alternatives is based on the maximum 

allowable prescribed fire under each. 

Emissions Modeling for Each Alternative. The results of the FOFEM representative burn 

analyses were interpreted to estimate the annual air pollutant emissions for each alternative, and 

also to estimate the emissions for the cumulative impact scenario under each alternative. To 

provide comparisons of the emissions under each alternative, the FOFEM model simulations was 

used to estimate the annual average emissions, and cumulative impact emissions from a 

conceivable catastrophic fire on the order of the 1995 Vision Fire. 

Conditions in the study area are such that the potential exists for the recurrence of a large, quick 

burning fire such as the Mt. Vision Fire of October 1995. Research into fire history in the park 

finds an absence of fire in lake sediments representing the last century. The fire interval in the 

Douglas-fir forests before suppression may have been every 7 to 15 years. As the potential 

exists in the project area for the reoccurrence of a large-scale wildfire, the acreage and burn 

regime of the 1995 Vision Fire (12,354 acres) is used as the basis from which to judge 

cumulative effects. The cumulative scenario for air quality impacts consists of annual project 

impacts plus the emissions generated by other reasonably foreseeable projects or events, such as 

a catastrophic fire, and the continuation of WUI projects in the communities adjacent to the 

project area. 
181 

If an increased level of prescribed burning and mechanical treatment is implemented, as 

considered under each of the action alternatives, there would be a transition period while the new 

fuel reduction program is being implemented, during which the annual emissions would increase 

due to increased prescribed burning. As more and more fuels are treated, the potential for a 

catastrophic fire with associated significant emissions gradually decreases as the risk declines 

with more and more pro-active vegetation treatment each year. That transition period would 

eventually lead to the desired long-term regime, where annual emissions would remain near the 

current long-term average, but the chance for large wildfires would be significantly diminished. 

The more acreage is treated annually, the faster the desired long-term stability regime is reached. 

To more accurately portray cumulative effects over the life of FMP implementation, the modeled 

scenario for each alternative compares average emissions generated during the transition period 

and emissions generated when a more natural fire regime is re-established and a more stable fire 

ecology is achieved. During transition, the aggregate of acreage treated results in a probable 

decrease in the median size of a potential wildfire. For the 1000-acre alternative (Alternative B), 

the cumulative effect during the transition period is based on the mid-way point of the transition 

– year 12 – that assumes a 5000-acre wildfire instead of a wildfire of the scale of the Vision Fire. 

The transition period for Alternative C, with the 2000 acres of prescribed burning, a 3500-acre 

wildfire is the basis of the assessment. 

Emissions from Mechanical Treatments

Air pollutants would be generated during the larger fuel reduction projects and during thinning 

prior to understory burns and site preparation for prescribed burns. Motorized equipment used in 

thinning and site preparation activities could include chainsaws, mowers, skidders, and haul 

trucks. These types of equipment are a representative sample of the types of equipment used in 

PRNS. Emissions associated with the use of motorized equipment were estimated for each 

alternative. Table 40 shows the AP-42 factors used to calculate emissions for the alternatives. 

Table 40. Emission Factors for Equipment Use in Fire Management Activities 

Operating Parameters Emission Factor (lbs/hour)1 

Machine 

Type 

Fuel Type Average HP CO PM NOx VOC 

Chainsaw Gasoline 6 3.4 0.05 0.01 1.1 

Mower Gasoline 50 30.6 0.26 0.26 0.39 

Skidder Diesel 200 4.4 0.57 3.0 0.95 

Haul truck Diesel 200 4.4 0.57 3.0 0.95 

Average HP = Average horsepower, CO = Carbon Monoxide, PM = particulate matter, NOx = Nitrogen Oxides, VOC = Volatile 

Organic Compounds (total hydrocarbons) such as methane (CH4). 

An assessment of the emissions from all mechanical treatment activities was prepared for each 

alternative. Mechanical emissions were calculated on a per acre basis based upon estimates from 

fire program managers on activity levels for each type of equipment under each fire scenario and 

ecosystem. Those emissions were generally a small contribution to ambient smoke emissions 

being modeled at the site. 
182 

Air Quality Descriptors 

Type of Effect. 

Beneficial: Improves or maintains air quality while lowering the potential for significant 

short-term pollutant release events 

Adverse: Degrades current air quality. 

Duration of Effect and Cumulative Impacts. The behavior of a smoke plume from a fire, 

including the direction and elevation that the smoke plume moves, and resulting concentrations 

at ground level, is highly dependent on elevation and dynamic meteorological conditions at the 

time. Under prescription conditions, air quality emissions generated by prescribed burning or 

other fire management actions would disperse within a time frame roughly the same as the 

duration of the fire management action. An exception to this would be if smoke from a wildfire 

became trapped at low altitudes in an inversion layer that can occur in the fall or winter. 

The emissions contributed annually by all actions under each alternative represent new, longterm contributions to regional haze. To achieve the goals of the PRNS FMP, the potential for a 

large-scale fire should be reduced or the scale of the potential fire should be reduced. The 

emissions contributed by the potential large-scale catastrophic fire represent the cumulative air 

quality scenario for the FMP assessment. The fire management plan should reduce the level of 

hazard of a catastrophic fire over the course of implementation of the plan. Eventually, the level 

of hazard would revert to a more natural fire return interval. During this period of progressively 

reducing cumulative effect, project implementation effects remain stable as the same amount of 

acreage is treated each year. 

Short-term Effects on air quality last less than 3 days beyond the duration of the fire 

management action. 

Long-term Effects on air quality persist beyond the duration of the fire management actions 

contributing additional pollutants to the air basin on an annual basis. 

Intensity of Effect: Localized Effects of Smoke

Negligible: Smoke would be barely perceptible or detectable and affect an undeveloped area 

(no recreational facilities or trails, no habitable structures, etc.). 

Minor: Smoke would be detectable but localized within an area of low-density 

development for recreational or private use, of short duration (several hours), and 

have no lasting effects. 

Moderate: Smoke would be readily perceptible but localized in an area of low-density 

development, be sufficient to limit use of the area for one day or less without 

damage to property or lasting effect. 
183 

Major: Smoke would be readily noticeable, occur in a developed area with a potential 

hazard to human health or creating property damage or lasting effect. 

Intensity of Effect: Regional Haze. 

As defined by the federal Clean Air Act and 1977 amendments, Point Reyes is a Class I airshed 

where visibility – the ability to see clearly across great distances and appreciate natural 

landscapes - must be protected from degradation (Malm, 2000). The increase in particulate 

matter and certain gases are the greatest influences on impairment of airshed visibility. As Point 

Reyes is in closer proximity to a heavily populated area than many national parks, regional haze 

is a very high concern. BAAQMD has adopted a Smoke Management Program to minimize 

regional haze and the PRNS FMP must conform to the requirements of that Program. The 

assessment of the annual average effect on air quality of the FMP alternatives is based on 

generation of particulate matter to reflect the potential contribution of FMP actions to regional 

haze. [Note: Management acres are equal to the extent of the full project area for the FMP 

(90,000 acres). Impact intensity is calculated based on emissions per acre/90,000. ] 

Negligible: All FMP actions generate less than 1 lb. PM10 annually per acre managed does. 

Minor: All FMP actions generate less than 5 lbs. PM10 annually per acre managed. 

Moderate: All FMP actions generate less than 10 lbs. PM10 annually per acre managed. 

Major: All FMP actions generate more than 10 lbs. PM10 annually per acre managed. 

Cumulative Impacts, Intensity of Effect. 

The intensity of cumulative impact for each alternative is assessed in comparison to the 

emissions that could be generated by a catastrophic fire (Vision Fire scale event) under 

Alternative A. This large-scale fire is modeled after the vegetation type and acreage affected by 

the 1995 Vision Fire. The following categories will be used to describe the intensity of the air 

quality impact at Year 1 and Year 10 of implementation of the FMP alternative. 

Negligible: Equal or greater than emissions generated by a Vision Fire-scale wildfire event. 

Minor: 5 to 20% change in emissions compared to the Vision Fire-scale fire event. 

Moderate: 21 to 50% change in emissions compared to the Vision Fire-scale fire event. 

Major: More than 50% change in emissions compared to the Vision Fire-scale fire event. 
184 

Water Resources and Water Quality 

Policies and Regulations 

The Clean Water Act requires the NPS to “comply with all Federal, State, interstate, and local 

requirements, administrative authority, and process and sanctions respecting the control and 

abatement of water pollution.” The NPS Freshwater Resource Management Guidelines (found in 

NPS-77) requires the NPS to “maintain, rehabilitate, and perpetuate the inherent integrity of 

water resources and aquatic ecosystems.” 

NPS Management Policies 2000 states: “The Service will manage watersheds as complete 

hydrologic systems, and will minimize human disturbance to the natural upland processes that 

deliver water, sediment, and woody debris to streams. These processes include runoff, erosion, 

and disturbance to vegetation and soil caused by fire, insects, meteorological events, and mass 

movement. The Service will achieve the protection of watershed and stream features primarily 

by avoiding impacts to watershed and riparian vegetation, and by allowing natural fluvial 

processes to proceed unimpeded.” 

 

Assessment Methodology 

The following three primary aspects of water resources were assessed when considering potential 

impacts: 

• Hydrology of the project area, 

• Aquatic habitat within the project area, and 

• Water quality. 

Hydrology refers to hydrologic processes such as flooding, erosion, deposition, and maintenance 

of channel patterns. Aquatic habitat refers to the attributes that support or provide habitat within 

stream or pond systems. Water quality refers to the suitability of surface water for beneficial 

use, including cold-water or warm-water aquatic wildlife habitat and recreational use. Particular 

consideration was given to actions with potential to affect the natural hydrology, aquatic habitat 

features, and surface water quality of cold-water streams. 

The San Francisco Bay Regional Water Quality Control Board (RWQCB) has listed Tomales 

Bay and its major watersheds, Lagunitas Creek and Walker Creek, as impacted by sediment, 

nutrients, and pathogens under Section 303 (d) of the Clean Water Act. In addition, the RWQCB 

has also listed Tomales Bay and Walker Creek as impaired by mercury. The RWQCB is 

required by the EPA to develop and implement TMDLs for each pollutant parameter by 2010. 

Specific watersheds supporting cold-water aquatic habitat include Lagunitas Creek, Olema 

Creek, Pine Gulch Creek, and most coastal drainages originating from Inverness Ridge. 

The Arroyo Hondo and upper Haggerty Gulch watersheds provide water supply to the Bolinas 

Community Public Utility District, and a few park residences near the Limantour Road. These 
185 

water supply diversions are permitted through the State Water Resources Control Board and are 

agreed to by the NPS and associated water users. 

Type of Impact 

Adverse: would alter natural hydrologic conditions (e.g., impede flood flows, cause 

unnatural erosion or deposition, etc.); degrade water quality (e.g., increase 

pollution or bacteria levels from recreational use); or degrade aquatic habitat. 

Beneficial: would restore natural hydrologic conditions (e.g., remove impediments to flood 

flows, stabilize riverbanks, etc.); improve water quality (e.g., reduce non-point 

source pollution); or improve or maintain aquatic habitat. 

Duration of Impact 

Short-term: would last two years or less. 

Long-term: would last longer than two years. 

Note: Since full implementation of an alternative would take place over a number of years, this 

section considers the duration of individual actions within each alternative (e.g., mechanical 

treatment of a specific area) instead of full implementation of the alternative. 

Intensity of Impact 

Negligible: would be imperceptible or not detectable. 

Minor: would be slightly perceptible, without the potential to expand if left alone; and 

would be localized (i.e., would occur in the immediate vicinity of an action). 

Moderate: would be apparent and would have the potential to become larger. 

Major: would be substantial, highly noticeable, and regional (i.e., would occur over a 

large area, such as the Tomales Bay watershed, or the Point Reyes National 

Seashore). Many water quality impacts are regional because an action could 

potentially affect water quality downstream. 

Vegetation 

Policies and Regulations 

NPS Management Policies 2001 state “The National Park Service will maintain as parts of the 

natural ecosystems of parks all native plants and animals.” The policies go on to state that the 

above statement includes flowering plants, ferns, mosses, lichens, algae, fungi, and microscopic 

plants. The NPS is to preserve and restore the natural abundances, diversities, dynamics, 

distributions, habitats, and behaviors of these native species. Additionally, the NPS is to prevent 

the introduction of exotic (non-native) species into units of the National Park System. The 

policy manual NPS-77 (Natural Resource Management Guidelines) also provides general 

guidelines on vegetation management. 
186 

Assessment Methodology 

Vegetation in the project area was digitally mapped using aerial photographs in 1999/2000. 

Field data on plant species composition were collected to characterize and classify plant 

communities delineated in the mapping effort. The classification describes the vegetation 

alliances and associations that occur in the study area, and was initially based on the 

classification system described by Sawyer and Keeler-Wolf. For purposes of this document, 

alliances and associations found in the project area have been grouped together into 10 broad 

vegetation classes that are described in Chapter 3 (Affected Environment). The alliances and 

associations that are grouped into a given vegetation class all share species with similar growth 

forms and structural attributes, thus it is assumed that they would respond similarly to treatments 

that would be applied under the FMP. The aerial extent of each vegetation class within each 

FMU was derived from the Seashore’s GIS. 

The primary assessment of impacts on vegetation considers potential impacts of fire management 

activities on all vegetation, regardless of vegetation class. This is followed by special 

considerations and impacts unique to individual vegetation classes. The following parameters 

were considered when assessing impacts on individual vegetation classes: 

• fire ecology of the dominant species in the vegetation class, 

• past and present fire regimes of the vegetation class, 

• aerial extent and relative abundance or rarity of the vegetation class in the project area 

and in the region, and 

• abundance and species richness of non-native plants within, or adjacent to the vegetation 

classes affected. 

The abundance, as defined by aerial extent, of an individual vegetation class is important when 

considering impacts because the Seashore is mandated to protect and maintain all native plant 

communities. If a vegetation class is very rare in the project area or the region, such as riparian 

woodland, adverse impacts to the vegetation class may be more significant. 

The presence and abundance of non-native (or exotic) plants in the affected vegetation classes is 

an important consideration as many non-native plant species are stimulated to grow and 

reproduce as a result of fire or other disturbance. The presence of some non-native plant species 

can have substantial adverse effects on native vegetation, including the following: 

• they can out-compete native plants for light, nutrients, water and growing space, which, 

in the worst case, can lead to extinction or local extirpation of rare plant species; 

• they can degrade the quality of wildlife habitat by out-competing native food sources, or 

altering nesting or resting habitat; 

• they can disrupt the genetic integrity of native plants if crossbreeding occurs; and 

• they can change fire regimes by converting habitat types (e.g., conversion of a shrub or 

forested landscape with little understory to one that has a continuous herbaceous layer). 

Much of the information on individual vegetation classes focuses on the dominant species within 

the classes, and the effects of fire on these species. Information on individual plant species 

largely was derived from the following source: U.S. Department of Agriculture (USDA), Forest 
187 

Service, Rocky Mountain Research Station, Fire Sciences Laboratory (U.S. Department of 

Agriculture, 2003). Fire Effects Information System (FEIS) is available online at: 

http://www.fs.fed.us/database/feis/, and includes comprehensive bibliographies for each species. 

Frequently referenced documents also are included in the References section of this EIS. 

Type, duration, and intensity of vegetation impacts are described as follows: 

Type of Impact 

Adverse: decreases the aerial extent or native species richness of a plant community, results 

in a plant community type conversion, or increases invasive non-native plant 

species abundance or richness. 

Beneficial: increases the aerial extent or native species richness of a plant community, or 

decreases invasive non-native plant species abundance or richness. 

Duration of Impact 

Short-term: would be measurable for two years or less. 

Long-term: would be measurable for longer than two years. 

Intensity of Impact 

Intensity of impact was determined for the various fire management activities by considering the 

degree to which such activities would affect the aerial extent of plant communities, or would 

change the abundance or species richness of native or non-native plant species within plant 

communities. 

Negligible: would result in no measurable changes in aerial extent, or in native or non-native 

species richness within a plant community. 

Minor: changes in aerial extent, or in native or non-native species richness within a plant 

community would be measurable, and would affect less than 5% of the total 

extent of that plant community in the project area. 

Moderate: changes in aerial extent, or in native or non-native species richness within a plant 

community would be measurable, and would affect from 5 to 25% of the total 

extent of that plant community in the project area. 

Major: changes in aerial extent, or in native or non-native species richness within a plant 

community would be measurable, and would affect 25% or more of the total 

extent of that plant community in the project area. 

Wetlands 

Policies and Regulations 

Wetlands are addressed separately from other vegetation types in this impact analysis as they are 

protected by a specific set of laws and regulations. Wetlands are lands that are transitional 
188 

between terrestrial and aquatic systems, where the water table is usually at or near the surface, or 

the land is covered by shallow water. Wetlands buffer the effects of hydrologic and erosional 

cycles, influence biogeochemical cycles of nitrogen and other key nutrients, and create unique 

microclimates for animal and plant species. 

The protection of wetlands within NPS units is facilitated through the following: 

• Executive Order 11990, Protection of Wetlands. 

• NPS Director’s Order 77-1, Wetland Protection and its accompanying Procedural Manual 

77-1 (DO 77-1 and PM 77-1). 

• Rivers and Harbors Act, Section 10. 

• Clean Water Act, Section 404. 

• The “no net loss” goal outlined by the White House Office on Environmental Policy in 

1993. 

Executive Order 11990 requires that agencies work to minimize the destruction, loss, or 

degradation of wetlands. Director’s Order 77-1 and Procedural Manual 77-1 provide specific 

procedures for implementing Executive Order 11990. Section 10 of the Rivers and Harbors Act 

and Section 404 of the Clean Water Act authorize the U.S. Army Corps of Engineers to grant 

permits for construction and disposal of dredged material in waters of the United States, which 

includes wetlands. 

Assessment Methodology 

For this assessment, wetlands that could be subject to impacts were identified using National 

Wetlands Inventory (NWI) information (USFWS, 1984), enhanced wetland mapping data 

recently acquired through intensive field inventory efforts, and information from the Seashore’s 

vegetation map (NPS, 2001). These data layers then were overlain with the boundaries of the 10 

fire management units. This information provided a conservative and broad estimate of the 

extent of known and potential wetlands within the planning area. The approximate number of 

acres that would be subject to impacts was estimated using the Seashore’s GIS. 

The parameters that were considered in the assessment of impacts on wetlands include the 

following: 

• plant species composition of the wetland, including abundance and species richness of 

invasive non-native plant species; 

• hydrologic features that maintain the wetland; and 

• wetland soils. 

These parameters parallel those used by the Army Corps of Engineers when defining wetlands. 

It is assumed that if these parameters are altered as a result of fire management activities, the 

wetland would be subject to impacts, which could be either beneficial or adverse. 

Type, duration, and intensity of wetlands impacts are described as follows: 
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Type of Impact 

Adverse: Shifts plant species composition to a higher percentage of non-wetland indicator 

species; alters hydrologic features/factors that are required to maintain the 

wetland; alters soil properties that are required to maintain the wetland; or reduces 

aerial extent of wetlands. 

Beneficial: Enhances wetland vegetation, soils, or hydrology, or increases aerial extent of 

wetlands. 

Duration of Impact 

Short-term: would be measurable for two years or less. 

Long-term: would be measurable for longer than two years. 

Intensity of Impact 

Negligible: would result in no measurable changes in the aerial extent of wetlands, or in 

wetland vegetation, soils, or hydrology. 

Minor: changes in the aerial extent, or in wetland vegetation, soils or hydrology would be 

measurable but would affect less than 5% of the total extent of the wetland type in 

the project area. 

Moderate: changes in the aerial extent, or in wetland vegetation, soils or hydrology would be 

measurable but would affect less than 20% of the total extent of the wetland type 

in the project area. 

Major: changes in the aerial extent, or in wetland vegetation, soils or hydrology would be 

measurable and would affect 20% or more of the total extent of the plant 

community in the project area. 

Wildlife 

Policies and Regulations 

NPS Management Policies 2001 state: “The National Park Service will maintain as parts of the 

natural ecosystems of parks all native plants and animals.” The policy statement includes 

bacteria, mammals, birds, reptiles, amphibians, fishes, arthropods, worms, and microscopic 

animals. The NPS is to preserve and restore the natural abundance, diversities, dynamics, 

distributions, habitats, and behaviors of these native species. Additionally, the NPS is to prevent 

the introduction of exotic (non-native) species into units of the National Park System. The 

policy manual NPS-77 (Natural Resource Management Guidelines) also provides general 

guidelines on wildlife management. 

The NPS also is required to comply with the Fish and Wildlife Coordination Act; the Marine 

Mammal Protection Act; the Bald and Golden Eagles Protection Act; the Wilderness Act; the 

Convention on International Trade in Endangered Species; and maritime and other international 

agreements. The NPS also is required to comply with The Migratory Bird Treaty Act (1918) as 
190 

amended, which prohibits taking, killing, or possessing migratory birds, nests, or eggs. As a 

refuge for tule elk, Point Reyes National Seashore is directed to participate in a Federal/State 

cooperative program for preservation and enhancement of tule elk in California under the Tule 

Elk Preservation Act (1976). 

Assessment Methodology 

Many wildlife concerns can be addressed by considering the effects of actions on wildlife habitat 

as represented by general vegetation types. In general, adverse effects on wildlife can be 

minimized by reducing and limiting habitat fragmentation; that is, by preserving and restoring 

large areas as well as patches of habitat, and maintaining connections within and among habitat 

types. Larger patches of habitat tend to support higher numbers and diversity of wildlife species 

than smaller ones, and connections between habitat patches enable the movement of wildlife 

between areas, enhancing reproduction and survival. Small patches of habitat can serve as 

stepping-stones for wildlife moving between larger blocks. 

The value of habitat patches for wildlife is also affected by adjacent human activities and 

development. Severe disruption of habitat corridors can impede wildlife movements. Impacts 

radiating into habitat patches, such as noise, non-native species, and human use, can adversely 

affect habitat quality. Wildlife tend to prefer a core of habitat that is more isolated from 

radiating impacts. 

Impacts on wildlife have been assessed in terms of the following: 

• Changes in the amount and distribution of wildlife habitat; 

• Changes in the size and connectivity of habitat patches; and 

• The existing integrity/quality of affected habitats (including past disturbances), and the 

relative importance of affected habitats. 

Type of Impact 

Adverse: would negatively affect the size, continuity, or integrity of wildlife habitat. 

Beneficial: would positively affect the size, continuity, or integrity of wildlife habitat. 

Duration of Impact 

Long-term: would last two years or longer. 

Short-term: would be expected to last for less than two years. 

Intensity of Impact 

Negligible: would not be measurable or perceptible. 

Minor: would be measurable or perceptible and would be localized within a relatively 

small area; however, the overall viability of the resource would not be affected. 

Without further impacts, minor adverse effects would be reversed, and the 

resource would recover. 
191 

Moderate: would be sufficient to cause a change in the resource (e.g., abundance, 

distribution, quantity, or quality); however, the impact would remain localized. 

The change would be measurable, but negative effects could be reversed in the 

long-term. 

Major: would be substantial, highly noticeable, measurable, and could be irreversible 

(permanent). The resource would be unlikely to recover. 

Special-Status Species 

Policies and Regulations 

Numerous species of plants and animals have undergone local, state, or national declines, which 

has raised concerns about their possible extinction if they are not protected. As a result, the U.S. 

Fish and Wildlife Service (USFWS) and the California Department of Fish and Game (CDFG) 

have established lists that reflect the species’ status and the need for monitoring, protection, and 

recovery. In addition to federal and state-listed species, potential impacts on plants listed by the 

California Native Plant Society (CNPS) also are considered for all programs and activities that 

the Seashore undertakes. The Seashore also recognizes a number of species as locally rare or of 

special concern, even though they are not officially listed. Collectively, species in all of these 

categories are referred to in this document as “special-status species.” 

The Federal Endangered Species Act (ESA) of 1973, as amended, requires federal agencies to 

consult with the USFWS before taking actions that (1) could jeopardize the continued existence 

of any federally listed plant or animal species (e.g., listed as threatened or endangered) or species 

proposed for listing, or (2) could result in the destruction or adverse modification of critical or 

proposed critical habitat. The USFWS provided upon request a list of species that must be 

considered for this EIS. 

The Council of Environmental Quality Regulations for Implementing the National 

Environmental Policy Act (Section 1508.27) also requires considering if an action may violate 

federal, state, or local laws or requirements imposed for the protection of the environment. For 

this reason, species listed under the California Endangered Species Act (i.e., those considered 

endangered or threatened) by the California Department of Fish and Game are included in this 

analysis. Species proposed for listing in either of the two categories are also included. 

NPS Management Policies (NPS, 2000) state: “The National Park Service will identify and 

promote the conservation of all federally listed threatened, endangered, or candidate species 

within park boundaries and their critical habitats.... The National Park Service also will identify 

all state and locally listed threatened, endangered, rare, declining, sensitive, or candidate species 

that are native to and present in the parks, and their critical habitats.... All management actions 

for protection and perpetuation of special status species will be determined through the park's 

resource management plan.” 

Additionally, park managers are to ensure that park operations do not adversely impact 

endangered, threatened, candidate, or sensitive species and their critical habitats, within or 
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outside the park and must consider federal and state listed species and other special-status 

species in all plans and NEPA documents (NPS-77 Natural Resource Management Guidelines). 

NPS-77 states: “The following legislation, policies, and agreements provide the authority for 

NPS policies on management of threatened and endangered species: the Endangered Species 

Act; state-specific endangered species acts; other state wildlife statutes or agreements pursuant to 

Section 6, ESA; the Migratory Bird Conservation Act; the Fish and Wildlife Coordination Act; 

the Wild and Scenic Rivers Act; the Marine Mammal Protection Act; the Bald and Golden 

Eagles Protection Act; the Wilderness Act; the Convention on International Trade in Endangered 

Species; and maritime and other international agreements.” 

The USFWS normally takes lead Departmental responsibility for coordinating and implementing 

provisions of the Endangered Species Act for all listed endangered, threatened, and candidate 

species, particularly for all terrestrial plants and animals and freshwater aquatic species. 

However, for certain listed taxa such as Cetacea (all whales and porpoises), most Pinnipedia

(Steller sea lions, Hawaiian monk seals, etc.), sea turtles, and anadromous fish (steelhead, coho 

salmon, etc), the NOAA Fisheries plays a very active role under provisions of both the 

Endangered Species Act (1973) and the Marine Mammal Protection Act (1972). For those 

marine species including fish it is often a case of shared USFWS\NOAA Fisheries 

responsibilities, with NOAA FISHERIES frequently assuming the lead role. In each instance 

discussed below, where the listed species in question is a fish, whale or pinniped, the term 

“FWS” might more accurately read “NOAA FISHERIES” or “NOAA FISHERIES and FWS.” 

This is particularly true for any activity that may involve the “taking” of a marine mammal of 

special status fish species such as threatened coho salmon and steelhead trout. 

The federal, state, and CNPS categories for special-status species are defined as: 

• Federal endangered: Any species that is in danger of extinction throughout all or a 

significant portion of its national range. 

• Federal threatened: Any species that is likely to become an endangered species within 

the foreseeable future throughout all or a significant portion of its national range. 

• California endangered: Any species that is in danger of extinction throughout all or a 

significant portion of its range in the state. 

• California threatened: Any species that is likely to become an endangered species with 

the foreseeable future throughout all or a significant portion of its state range. 

• California rare (plants only): A native plant that, although not currently threatened with 

extinction, is present in small numbers throughout its range, such that it may become 

endangered if its present environment worsens. 

CNPS List 1A: Presumed Extinct in California 

CNPS List 1B: Rare or Endangered in California and Elsewhere 

CNPS List 2: Rare or Endangered in California, More Common Elsewhere 
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CNPS List 3: Need More Information 

CNPS List 4: Plants of Limited Distribution 

Assessment Methodology 

Special Status Plants 

Fire plays a role in the life history of many special-status plant species by maintaining open 

habitat, encouraging reproduction, and affecting competing species. Fire may injure or kill 

individual plants while the effects on the species as a whole are beneficial because competition 

has been reduced or openings (i.e., habitat) created. Fire suppression activities can adversely 

affect these same species because of ground disturbance. Prescribed fires can be detrimental, 

especially when timing, frequency, and intensity of fire are outside of the natural fire cycle to 

which the species is adapted. Keeping these factors in mind, the following parameters have been 

used to evaluate the consequences of the various alternatives on special-status plants: 

• The species affected and its degree of local, regional, national, and global rarity. 

• The numbers of plants or proportion of the species range affected by the action. 

• The response of the species to fire or disturbance (if known). 

Type of Impact

Adverse: would lead to loss or alteration of habitat, loss of individuals or populations of 

special-status plants, or reduction in reproduction. 

Beneficial: would lead to increases in suitable habitat, an increase in aerial extent or density 

of plants, or an increase in reproduction. 

Duration of Impact

Short-term: would immediately affect the population or species, but would have no 

long-term effects to population trends or species viability. 

Long-term: would lead to a loss in population or species viability - exhibited by a 

trend suggesting decline in overall species aerial extent or abundance. 

Intensity of Impact

Negligible: Imperceptible or note measurable (undetectable). 

Minor: Small, measurable, perceptible and localized, without the potential to increase if 

left alone. 

Moderate: Apparent, measurable, and sufficient to cause a change in the resources (e.g., 

abundance, distribution, quantity, or quality). Less localized than a minor impact. 

Major: Substantial, highly noticeable, and with the potential for landscape-scale effects 

and major irreversible population effects. 
194 

Special Status Wildlife (including fish and other aquatic species) 

Like other wildlife species in the project area, special-status species have adapted to natural fire 

regimes. In many areas, however, a history of fire suppression has led to dense, overgrown 

stands, with high accumulations of forest fuels. This affects special-status species by altering 

habitat and placing these species and their habitats at risk of high-intensity, stand-replacement 

fire. In addition, stand-replacement fire could create unsuitable habitat conditions that would last 

for many years. 

Fire control activities could also adversely affect special-status species through direct 

disturbance of animals and habitats. Even management actions designed to benefit habitat, such 

as prescribed fire, can have inadvertent adverse effects on special-status species. With these 

factors in mind, the following parameters have been used to evaluate the effects on special-status 

animals of the various alternatives: 

• The species affected and its degree of local, regional, nationally and global rarity. 

• The rarity of the genotype or subspecies, regionally, nationally, or globally. 

• The numbers of animals or proportion of the species range affected by the action. 

• The response of the species to fire or disturbance (if known), on a population or subpopulation level. 

Type of Impact

Adverse: Likely to result in unnatural changes in the abundance or distribution of a specialstatus species. This could occur through direct disturbance, mortality, or through 

destruction or alteration of habitat. 

Beneficial: Likely to protect and/or restore the natural abundance and distribution of a 

special-status species. This could occur through protection and restoration 

of structure, successional state, or distribution of habitat. 

Duration of Impact

Short-term: would result in immediate changes in the abundance and distribution of a specialstatus species, but a return to the original condition occurs within two generations 

of that species. 

Long-term: would result in changes in the abundance and distribution of a special status 

species that persist for greater than two generations of that species. 

Intensity of Impact

Negligible: would be imperceptible or unmeasurable (undetectable). 

Minor: would be slightly perceptible and localized in extent; without further actions, 

adverse impacts would reverse and the resource would recover. 

Moderate: would be readily measurable (apparent) and extend further geographically than a 

minor impact, adverse impacts would eventually reverse and the resource would 

recover. 
195 

Major: would be substantial, highly noticeable, and affecting a large geographic area; 

changes would be irreversible with or without active management. 

Cultural Resources 

Policies and Regulations 

Fire management actions such as prescribed fire, suppression, and mechanical treatments have 

the potential to impact cultural resources such as archeological sites, structures, ethnographic 

resources, and cultural landscapes. Museum objects can also be threatened by such actions, both 

the physical well being of the objects themselves, and the ability to properly catalog and process 

those objects. 

Section 106 of the National Historic Preservation Act requires Federal agencies to consider the 

effects of its actions on properties listed in, or eligible for inclusion in, the National Register of 

Historic Places (i.e., Historic Properties), and allow the Advisory Council on Historic 

Preservation a reasonable opportunity to comment. Proper management of museum objects is 

dictated by 36 CFR 79. 

Presently the agencies comprising the DOI, including the National Park Service and the U.S. 

Department of Agriculture, are developing a nationwide Programmatic Agreement with each 

state’s respective Historic Preservation Office, the National Council of State Historic 

Preservation Offices, and Advisory Council on Historic Preservation. This document will follow 

procedures outlined in 36 CFR 800.14(b) of Section 106 of the National Historic Preservation 

Act. Among the core elements of the Programmatic Agreement include professional 

qualifications, standard protocols for cultural resources compliance for fire management actions, 

Indian Tribe and public participation, agency review procedures, and inadvertent effects. The 

benefit of Programmatic Agreement will be greatly expedited Section 106 compliance review for 

fire management actions, as well as the establishment of standard protocols for most effectively 

identifying, evaluating, and protecting cultural resources during planned and unplanned fire 

management actions. 

Terms found in Section 106 of the National Historic Preservation Act are used to describe 

cultural resource significance and effects in this section. However, it is important to distinguish 

Historic Properties (as defined above) from resources of interest, which are those classes of 

resources that have some potential to be important, and have the potential to be impaired by the 

fire management action. While Historic Properties are de facto resources of interest, these might 

also include sites, features, structures, or other phenomenon that do not meet National Register 

of Historic Places criteria of significance, the minimum age requirement, and/or possesses 

sufficient integrity, but contribute somehow to our understanding of prehistory, history, or 

traditional lifeways, and could be compromised. Each resource of interest is comprised of a set 

of attributes, called significant characteristics, which lend importance to that resource. 

Cultural Resource Impacts Defined 

NEPA recognizes three types of impacts - direct, indirect, and cumulative. Direct impacts are 

those that are caused at the same time and place as the action, indirect impacts occur later in time 
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and at a distance, while cumulative impacts are additive. In regard to cultural resources, direct, 

operational, and indirect effect categories are utilized. Direct effects are those where the fire 

itself is the cause of the impacts, operational effects occur as a result of associated operations 

like line construction or staging, while indirect effects are ones where fire and/or associated 

operations result in changes to local context such that cultural resources would be affected. As 

such, direct and operational effects for cultural resources are the equivalent of direct impacts 

under NEPA, while indirect effects on cultural resources correspond to indirect and cumulative 

impacts. 

NEPA also dictates that potential impacts are considered in regard to type (adverse, beneficial) 

duration (short-term, long-term, permanent), and intensity. The Section 106 process considers 

only the adverse effects upon cultural resources, not potentially beneficial ones. An ordinal scale 

of impact intensity (negligible, minor, moderate, major) is also foreign to the Section 106 

process - effects are either adverse (when the integrity of the historic property is diminished due 

to the undertaking) or they are not. Duration is not typically factored when assessing effects 

during the Section 106 process. These issues are considered in greater detail below in relation to 

direct, operational and indirect effects. 

Assessment Methodology 

Archeological research ranging from site survey to complex archeological excavations has taken 

place primarily from the early 1900s through the present. Thirty-two archeological sites on the 

Point Reyes peninsula were partially excavated from the 1940s through the 1960s by 

archeologists from the University of California at Berkeley, San Francisco State University, 

Santa Rosa Junior College, and the Drake Navigators Guild. Information gained from these 

excavations was critical in placing the Coast Miwok culture within local and regional 

chronologies and in gathering evidence of early Coast Miwok contacts with Drake and Cermeno. 

The following measures are employed to assess impacts of fire management actions on cultural 

resources. Further rationale for each measure is provided in discussions of direct, operational, 

and indirect effects that follow. 

Type of Impact 

Adverse: Changes to the significant characteristics of a resource of interest. These changes 

may be perceptible and measurable, or, in the case of certain archeological and 

ethnographic resources, imperceptible, and psychological. 

Beneficial: Changes on or in the vicinity of a resource of interest such that the significant 

characteristics of the resource are protected against adverse impacts of fire 

management actions and/or restored to some desired condition. 

Duration of Impact 

Archeological Resources 

Short-term Adverse: Changes that result in permanent or temporary loss of data 

potential in the significant characteristics of a resource of interest, 

but do not manifest for a period of 10 or fewer years following the 

fire management action. 
197 

Short-term Beneficial: Changes that afford protection to the significant characteristics of a 

resource of interest from fire management actions for a period of 

no more than 10 years. 

Long-term Adverse: Changes that result in a permanent or temporary loss of data 

potential in the significant characteristics of a resource of interest, 

and manifest in more than 10 years following the fire management 

action. 

Long-term Beneficial: Changes that afford protection to the significant characteristics of a 

resource of interest from fire management actions for a period of 

no more than 10 to 20 years. 

Permanent Adverse: Changes that result in permanent loss of data potential in the 

significant characteristics of a resource of interest, and manifest 

immediately following the fire management action. 

Permanent Beneficial: Changes that result in permanent protection to the significant 

characteristics of a resource of interest from fire management 

actions. 

Structures 

Short-term Adverse: Changes that result in a permanent or temporary loss of data 

potential in a resource of interest, but do not manifest for a period 

of 10 or fewer years following the fire management action. 

Short-term Beneficial: Changes that afford protection to the significant characteristics of a 

resource of interest from fire management actions for a period of 

no more than 10 years. 

Long-term Adverse: Changes that result in a permanent or temporary loss of data 

potential in a resource of interest, and are manifest in more than 10 

years following the fire management action. 

Long-term Beneficial: Changes that afford protection to the significant characteristics of a 

resource of interest from fire management actions for a period of 

no more than 10 to 20 years. 

Permanent Adverse: Changes that result in permanent loss of data potential in a 

resource of interest, and that are manifest immediately following 

the fire management action. 

Permanent Beneficial: Changes that result in permanent protection to the significant 

characteristics of a resource of interest from fire management 

actions. 
198 

Cultural Landscapes 

Short-term Adverse: Temporary alteration of the significant characteristics of a resource 

of interest for a period lasting no more than 10 years. Short-term 

alterations will almost always involve living vegetation. 

Short-term Beneficial: Temporary protection, restoration, or maintenance of the 

significant characteristics of a resource of interest for a period 

lasting no more than 10 years. 

Long-term Adverse: Temporary alteration of the significant characteristics of a resource 

of interest for a period lasting more than 10 years. Short-term 

alterations will almost always involve living vegetation. 

Long-term Beneficial: Temporary protection, restoration, or maintenance of the 

significant characteristics of a resource of interest for a period 

lasting more than 10 years. 

Permanent Adverse: Permanent alteration of the significant characteristics of a resource 

of interest. Permanent alterations will often encompass both living 

vegetation and other landscape features. 

Permanent Beneficial: Permanent protection, restoration, or maintenance of the 

significant characteristics of a resource of interest. 

Intensity of Impact 

In this analysis, intensity of impact is measured relative only to adverse resource impacts. 

Archeological Resources 

Negligible: No or barely perceptible and changes to the significant characteristics of a 

resource of interest. 

Minor: Perceptible and measurable changes to the significant characteristics of a resource 

of interest, but those changes do not inhibit interpretive potential and/or a minor 

percentage of the significant characteristics would be affected. Resources prone 

to impacts in this category might include archeological resources containing a 

high percentage of resources of interest with low vulnerability to the effects of 

fire management actions and/or possessing subsurface components. 

Moderate: Perceptible and measurable changes to the significant characteristics of a resource 

of interest, but those changes do not inhibit interpretive potential and/or a 

moderate percentage of the significant characteristics would be affected. 

Resources prone to impacts in this category might include archeological sites 

containing a moderate percentage of resources of interest with low vulnerability 

to the effects of fire management actions and/or possessing subsurface 

components. 
199 

Major: Perceptible changes to the significant characteristics of a resource of interest, and 

those changes inhibit interpretive potential of a major percentage of the 

significant characteristics. Resources prone to impacts in this category might 

include archeological sites containing a large percentage of resources of interest 

with high vulnerability to the effects of fire management actions. 

Structures 

Negligible: Barely perceptible and not measurable changes confined to a single resource of 

interest or contributing element of a larger National Register district. Changes do 

not adversely affect significant characteristics. 

Minor: Perceptible and measurable changes to a single resource of interest or contributing 

element of a larger National Register district. Changes do not adversely affect 

significant characteristics. 

Moderate: Perceptible and measurable changes in the significant characteristics of a single 

resource of interest or small group of contributing elements in a larger National 

Register district. 

Major: Perceptible and measurable changes of substantial magnitude in significant 

characteristics of a single resource of interest or large group of contributing 

elements in a National Register district. 

Cultural Landscapes 

Negligible: Barely perceptible and not measurable changes to a resource of interest. 

Minor: Perceptible and measurable minor changes to a resource of interest. For example, 

a severe wildfire kills a highly visible concentration of non-contributing oak trees 

located on the boundary of a rural historic cultural landscape. 

Moderate: Perceptible and measurable moderate changes in the significant characteristics of 

a resource of interest. For example, a fire crew cuts down several contributing 

fruit trees in a rural historic cultural landscape in preparation for a prescribed 

burn. 

Major: Perceptible and measurable changes of substantial magnitude in significant 

characteristics of a resource of interest. For example, extreme fire behavior and 

aggressive suppression action destroys a large number of contributing elements 

within a rural historic cultural landscape. 

Visitor Use and Visitor Experience 

Policies and Regulations 

NPS Management Policies 2001 makes numerous references to aspects of aesthetics as central 

issues in the considerations that go into resource management. It includes, under the natural 
200 

resources and values that the NPS must protect, “aesthetic values, such as scenic vistas, natural 

quiet, and clear night skies.” 

Scenic resources are extremely sensitive to air pollution. Even a very small amount of fine 

particulate matter (less than 2.5 microns in diameter or one tenth the diameter of a human hair) in 

the air can affect the ability to perceive colors, contrast, texture, and form of features, landmarks, 

and panoramas. Visual air quality is very important to park visitors. Specific vistas are often 

mentioned in legislation or Congressional reports concerning the establishment of an NPS unit. 

Visibility in mandatory class I areas is also specifically protected by the Clean Air Act 

(Director’s Order-77: Natural Resource Management Guidelines). 

This Director’s Order #47 addresses the problem of excessive/ inappropriate levels of noise. It 

directs park managers to (1) measure baseline acoustic conditions, (2) determine which existing 

or proposed human-made sounds are consistent with park purposes, (3) set acoustic management 

goals and objectives based on those purposes, and (4) determine which noise sources are 

impacting the park and need to be addressed by management. Furthermore, it requires park 

managers to (1) evaluate and address self-generated noise, and (2) constructively engage with 

those responsible for other noise sources that impact parks to explore what can be done to better 

protect parks. 

Assessment Methodology 

The effects of each alternative were evaluated by analyzing potential impacts on the physical 

component of the landscape and how the change may be experienced using best professional 

judgment. The following aspects of actions within the alternatives were assessed as directed by 

NPS-77: 

Could the action or activity be seen from the park? From a developed overlook, road, or 

trail? Would the action or activity be continuously or intermittently seen? Are there any 

alternative sites that are less visible or not visible from the park? 

Could the action impact a scenic vista along a road or a scenic view? How long would 

the fire management treatment impact an area? 

Could the action or activity be heard in the park? Where in the park would the sound be 

most noticeable or intrusive? From developed overlooks, headquarters areas, or trails? 

Would the sounds be continuous or intermittent? Are there any ways in which the effects 

of the sound could be mitigated or lessened? 

As these questions indicate, systematically looking at the effects of proposed activities or actions 

aims at evaluating what may be lost, rather than what has been generally thought to describe the 

existing resource condition. For example, routine baseline monitoring of natural resources 

would not ordinarily take into account the degree of quiet that characterizes a park or the clarity 

of night sky, but these are precisely the kinds of issues that come under the framework of 

aesthetics. 
201 

Aesthetic considerations can be quantitatively monitored. It is possible to map viewsheds and 

photograph visibility. Air quality and weather data can provide limited modeling for visibility 

and odor concerns. Various characteristics of natural- and human-caused sounds can also be 

measured. 

Unfortunately, there is no objective, numerical standard or threshold that can be employed to 

state what constitutes an aesthetic effect. As is often the case in NPS management, judgment is 

necessary. Effects on aesthetics also should be analyzed in the context of cumulative effects of a 

number of different activities or actions, both within and outside parks. What could be 

insignificant alone (for example, one helicopter trip near a popular overlook) could become 

significant in the context of other activities or actions (one helicopter trip in combination with 

nine diesel buses and a nearby, audible, and visible clearcutting operation). 

It is often the case that frequency or duration of an activity or action causes it to be transformed 

from being acceptable in the park or its vicinity, in aesthetic terms, to being unacceptable. For 

example, scenic overflights were considered to be acceptable over the Grand Canyon until the 

numbers and duration of the flights caused a deterioration of the aesthetic experience for other 

park visitors. Limitations on backcountry use may be based, in part, on the potential for adverse 

effects on visitor aesthetic experience from too many other users. Sociological studies can be 

useful to evaluate visitor preferences and aesthetic effects. 

Visitor experience is also directly affected by actions influencing natural resources such as air 

quality, scenic resources, and cultural resources. Though impacts to these resources are not 

considered again in this analysis of visitor experience, enhancement, or degradation of these 

resources also enhances or degrades the quality of the visitor experience. 

Impacts on visitor experience and visual quality have been assessed using professional judgment 

to develop a qualitative analysis of the effects of actions on the activities of park visitors. These 

conclusions have been considered in combination with data on the proportion, when known, of 

visitors who participate in different activities while in the park. 

Type of Impact 

Beneficial: would enhance visitor participation, quality of visitor experience, service level, or 

the visual quality of the landscape. 

Adverse: would reduce visitor participation, or degrade the quality of visitor experience, 

service level, or the visual quality of the landscape. 

Duration of Impact 

Short-term: would be temporary (less than 90 days) and due to fire management activities 

such as prescribed burns or mechanical clearing of vegetation. 

Long-term: would be permanent and/or continuous. 

Intensity of Impact 

Negligible: would result in little or no noticeable change in visitor experience. 
202 

Minor: would be detectable but localized within a relatively small area (less than 250 

acres in one area); would result in changes in visitor experience but would not 

appreciably limit or enhance critical characteristics. 

Moderate: would be highly noticeable, and/or change the visual character of the landscape in 

areas larger than 500 acres, but affected areas would be located away from 

heavily used roads or trails; would change the desired visitor experience 

appreciably, (i.e., changes one or more critical characteristics, or appreciably 

reduces/increases number of participants). 

Major: would be highly noticeable, and/or change the character of the landscape in areas 

larger than 1000 acres, and affected areas would be visible from heavily used 

roads or trails; would eliminate or greatly enhance multiple critical characteristics 

or greatly reduce or increase participation. 

Park Operations 

Policies and Regulations 

Congress established the National Park Service (NPS) in 1916. To fulfill its mission, the NPS 

receives funding from both the federal appropriations process and other federal revenue sources. 

Like most federal agencies, the NPS relies on Federal appropriations to fund its core activities, 

although there is increasing use of alternative revenue sources, such as fees, to supplement 

operations. The NPS requests direct Congressional funding and reports on the other federal 

revenue sources through an annual budget document submitted to Congress entitled “Budget 

Justifications,” or more popularly called, the “Green Book.” 

Financial resources currently available to PRNS include a base-operating budget of 

approximately $4,949,000, which represents about 115 FTE (full time equivalents or one person 

for a full year). This work force would be supplemented by 20,000 hours of Volunteers-in-Parks 

service, 2-4 Student Conservation Assistants, and AmeriCorps volunteer work groups and 

special project and program funds distributed by the National Park Service regional and 

Washington offices. 

In addition to the above operational funding, the park receives fee revenues and special national 

park funding for specific maintenance and other projects. For example, the park is expected to 

receive about $1.6 million in this one-time funding this year for cyclic maintenance on historic 

structures and other natural resources projects. As part of the San Francisco Bay Network, the 

National Seashore will have access to approximately $900,000 for natural resource challenge 

inventory and monitoring funds. Also, the park will receive about $625,000 in fee revenues for 

other maintenance projects and operation of the whale shuttle system and campground 

reservation system. In addition, the park receives approximately $1,000,000 in FirePro and 

Wildland Interface funding for hazardous fuel reduction and fire prevention activities. 
203 

Assessment Methodology 

Impacts were evaluated by assessing changes that would be required to meet the operational 

requirements outlined in each of the alternatives. Relative costs were generated, using staff 

estimates of funding and labor required to implement these actions. These effects were compared 

to existing operations, staffing, and funding at the Seashore. 

Existing staffing levels were inventoried and assessments were made of current park operations. 

In addition, professional judgments by individuals who are most knowledgeable about various 

activities were used to anticipate the operational changes that would be needed under each action 

alternative. Estimates were made of the personnel required to: 

• provide education and information services to the public regarding fire activities; 

• conduct mechanical treatments to reduce hazardous fuels; and 

• conduct prescribed fires to preserve natural and cultural resources and reduce hazardous 

fuels. 

These assessments were compared to existing staffing levels. It should also be noted that staffing 

and funding impacts for the action alternatives are difficult to project until final plans are 

completed. Thus, the estimates are intended to provide a general description of potential effects, 

considering the variability within the range of possible operational scenarios. 

The discussions of impacts are for operations that would be new, undergo major change, or show 

susceptibility to increases or decreases in operational activity. 

Type of Impact 

Adverse: would represent an increase in operating costs. 

Beneficial: would represent a decrease in operating costs. 

Duration of Impact 

Short-term: would last only until all actions are completed. 

Long-term: would have a permanent effect on operations. 

Intensity of Impact 

Negligible: there would not be a measurable difference in costs from existing levels. 

Minor: additions or reductions in cost would be less than 15% of existing levels. 

Moderate: additions or reductions in cost would be between 16% and 30% of existing levels. 

Major: additions or reductions in cost would be more than 30% of existing levels. 
204 

Public Health and Safety 

Policies and Regulations 

The health and safety of firefighters and the public is the highest priority in every action 

undertaken as it relates to firefighting strategy and tactics. Director’s Order #18 states, 

“...firefighter and public safety must be the first priority in all fire management activities.” 

National Park Service Management Policies states “all wildland fires would be effectively 

managed, considering resource values to be protected and firefighter and public safety....” All 

actions taken involving wildland fire have as their overriding goal providing for firefighter and 

public safety. 

Assessment Methodology 

Fire management activities and the potential for injury, illness, and other direct and indirect 

impacts are evaluated for their potential to affect public and fire personnel during fire 

management activities at Point Reyes National Seashore. The analysis includes the impacts of 

prescribed fire, suppression, wildland fire use and mechanical treatment on the health and safety 

of the public and fire personnel. 

Type of Impact 

Beneficial: would result in a reduction in human health and safety concerns; or would 

improve human health or safety. 

Adverse: would result in additional or exacerbated public health and safety concerns. 

Duration of Impact 

Long-term: would have a permanent effect on human health and safety (i.e., contamination of 

a water source for domestic use would be a long-term impact). 

Short-term: would be temporary (less than one month) and would be associated with 

transitional types of impacts (e.g., safety concerns related to smoke from a 

prescribed burn). 

Intensity of Impact 

Negligible: Imperceptible or undetectable effect upon public or fire personnel. 

Minor: Minor impacts would be slightly detectable or localized, upon public or fire 

personnel within a portion of the body. 

Moderate: Moderate impacts would be those that are readily apparent but that would not 

result in limits on activities. Would be clearly detectable and could have an 

appreciable effect on public health and safety (i.e., introduction of noise, public 

health hazards or safety hazards). 

Major: Major impacts would be substantial, highly noticeable impacts and/or impacts that 

would result in limits on activities. Would be clearly introducing a significant 

public health hazard such as the introduction of significant air or water pollution. 
205 

Socioeconomics 

Policies and Regulations 

The NPS regulations for NEPA say “social and economic impacts are considered an integral part 

of the human environment in the NPS and should be analyzed in any NEPA document where 

they are affected. Socioeconomic impacts include those to minority and low-income 

communities as specified in the Environmental Justice Executive Order (EO 12898; Feb. 11, 

1994).” This executive order - Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations - requires all federal agencies to incorporate 

environmental justice into their missions by identifying and addressing disproportionately high 

and adverse human health or environmental effects of their programs and policies on minorities 

and low-income populations and communities. 

Assessment Methodology 

In addition to any possible effects on minority and low-income populations and communities, 

alternatives were evaluated for their potential direct impacts, such as property loss, and indirect 

economic effects, such as from park closures. 

Type of Impact 

Adverse: Degrades or otherwise negatively alters the characteristics of the existing 

environment, as it relates to local communities including minority and lowincome, visitor population, regional economies, and concessioners and 

contractors. 

Beneficial: Improves on characteristics of the existing social and economic environment, as it 

relates to local communities including minority and low-income, visitor 

population, regional economies, and concessioners and contractors. 

Duration of Impact 

Short-term: Temporary and typically transitional; associated with implementation of an 

action. 

Long-term: Permanent impacts on the social and economic environments. 

Intensity of Impact 

Negligible: Undetectable and expected to have no discernible effect on the social and 

economic environment. 

Minor: Slightly detectable and not expected to have an overall effect on the character of 

the social and economic environment. 

Moderate: Detectable and could have the potential to initiate an increasing influence on the 

social and economic environment. 
206 

Major: Substantial, highly noticeable influences on the social and economic 

environments, and could be expected to alter those environments permanently. 

The action alternatives are anticipated to slightly increase annual air pollutant emissions but 

lower the potential for a large, uncontrolled wildfire with excessive emissions of air pollutants. 

It is anticipated that after a transition period, natural fire ecology would be closer to presuppression return intervals, and the risk of large, catastrophic fires would gradually decline. 

IMPACT ANALYSIS 

IMPACTS TO SOILS 

Alternative A 

The actions associated with Alternative A could affect soil resources within the Estero, 

Limantour Road, Highway One, and Bolinas Ridge FMUs (prescribed fire only). 

Types of Impacts 

The types of impacts soils can experience from burning are varied, and can include changes to its 

physical, biological, and chemical properties. The degree of effect on soil is related in large part 

to the intensity of a fire, although this can change with the property of the soil when a burn takes 

place as well. Because the types of effects are the same, they are discussed together in this 

introductory section. The degree of impact, as well as other specific information, is then broken 

out in the sections on the impacts of prescribed fire and wildland fire. 

Soil characteristics 

As noted above, the features of soils help in determining the degree of effect of a prescribed burn 

or wildland fire. Features include biological characteristics, such as the type of vegetation soils 

support; physical characteristics, such as soil moisture; and chemical characteristics, or soil 

composition. 

Vegetation and Organic Matter. High heat intensities from slow moving fires in heavy fuels can 

detrimentally affect physical, biological, and chemical properties of soil to varying degrees. 

Grass fires typically burn quickly over an area and cause little or no soil heating. For example, 

grassland thatch one centimeter high can serve to insulate soils from heating as a low intensity, 

fast moving, fire most common in grassland, burns quickly across the top of the litter. Less litter 

and ground cover can therefore result in greater effects on soil resources. Even the heat 

generated by heavier fuels involved in chaparral fires in southern California was found to be 

largely restricted to the surface soil layer and damage to soils was limited (DeBano, et al., 1998). 

Severe fires can result when humus and large fuels are dry and near the ground conducting much 

heat into the soil from slow, smoldering fires; recovery in areas that supported heavy dry surface 

fuels may take years (McNabb and Swanson, 1990; Stanturf, 2002; Christensen, 1994). 

Soil Moisture. Under similar fire conditions, dry surface soils will rise to higher temperatures 

and experience higher impacts than moist surface soils. In the project area, dry surface soils 

would be more common during wildfire season and moist surface soils common in the seasons 
207 

when most prescribed burns are conducted. Subsurface saturated soils can actually slow the 

diffusion of heat and protect underlying soils as heat will be poorly transmitted until moisture in 

the soil evaporates (Stanturf, 2002). 

Soil Type. Granitic soils, such as those found in the Tomales Point and Inverness Ridge FMUs 

(having Kehoe Variant and Sheridan Variant soils) conduct heat faster than clay-rich soils or 

soils with a high organic content (Agee, 1993). In the project area, these granitic soils also 

support some of the more fire dependent plant communities, such as Bishop pine and Marin 

manzanita. The granitic soils and the overlying vegetation type are thought to contribute to postfire hydrophobicity. 

Range of Effects 

The characteristics of soil are important in determining effects, but fires can change the factors 

described above, as well as other physical, chemical, and biological processes operating in soils. 

For example, high intensity, slow-moving burns kill soil biota, alter soil structure, consume litter 

and humus above ground and organic matter within soils, change the rate of water infiltration, 

reduce the ability of soil to retain water, vaporize important nutrients such as nitrogen and sulfur, 

and increase erosion of productive top soils (Robichaud, 2000b; Pyne, et.al., 1996; Christensen, 

1994). 

Erosion. The most common effect on soils is erosion by water, wind, or gravity following the 

removal of overlying vegetation by fire, whether it is prescribed or wild. The severity and 

duration of the accelerated erosion depend on several factors, including soil texture, slope, 

recovery time of protective cover, the amount of residual litter and duff, and post-burn 

precipitation intensity (Clark, 2001). Erosion selectively removes nutrients, organic materials 

and fine particles from topsoil reducing soil productivity. A decrease in productivity can have a 

consequent effect on the density, vigor and range of plant species that will survive or repopulate 

an area. Reduced productivity may also allow for the establishment or expansion of populations 

of opportunistic invasive exotic plant species that thrive in poor soils. On a larger scale, the 

transportation of soils through erosion can result in changes to the landscape such as the 

formation of gullies or the sedimentation of ponds and wetlands and clogging of stream 

channels. 

The soils with the highest potential for erosion are on the steepest slopes – greater than 50% - 

along the top of Inverness Ridge. This area primarily supports forests, where replacement of 

vegetation cover is normally slow in comparison to grasslands or shrublands. De Bano and 

others (1996) specifically monitoring rates of erosion following a wildfire in ponderosa pine, 

found sediment yields from a low severity fire recovered to normal levels after 3 years, but 

moderate and severely burned watersheds took 7 and 14 years, respectively. Areas of the Vision 

Fire supporting fire dependent species, such as Bishop pine and Marin manzanita, as well as 

sandy loam soils supporting hardwoods and riparian vegetation appeared to have largely 

recovered effective soil cover by the second winter following the fire but long-term investigation 

into recovery of surface soil properties was not conducted. 

Hydrophobicity. Hydrophobicity can result when fire increases soil temperatures causing the 

volatilization of hydrophobic materials into the soil. It is thought that the hydrophobic materials 
208 

may be deposited by certain plants or are by products of decay (Christensen, 1994). The 

phenomenon has been highly reported following chaparral fires in Southern California where the 

gases that result from combustion move downward in the soil as vapors until condensing when 

cooler soils are encountered forming a nonwettable layer (Pyne et al., 1996). Some soils in the 

park may be particularly vulnerable to developing deep water repellent layers of soils. These 

include granitic soils or soils formed from coarse-grained sandstone (such as Kehoe Variant and 

Sheridan Variant soils) with heavy fuel loads, such as shrubs or trees (Oster, 2003). Granitic 

soils with a grass cover experience low intensity burns and develop little hydrophobicity. In a 

hot wildfire, these layers can be quite deep. Following the Vision Fire, erosion and channel 

cutting was observed in areas of granitic soils cleared of overlying vegetation and exhibiting 

hydrophobicity from 2 to 8 inches in depth (Collins and Ketcham, 2001). However, the 

impermeable layer that develops in the upper soil horizon may have beneficial impacts by 

controlling the loss of moisture to evaporation. This maintains soil moisture and encourages 

seedling establishment (Clark, 2001). Such a positive impact was observed following the Vision 

Fire, as by year two, only small areas of hydrophobicity remained having been broken up by the 

action of sprouting vegetation, decay of organic oils on the soil surface and rilling. 

Slope Failures. In addition to increasing erosion, hydrophobicity can also be associated with fireassociated slope failures (DeBano et al., 1998). This happens when the accelerated runoff 

flowing downslope is circumvented by natural preferential flow-paths within the soil resulting 

from soil cracks or root channels. When heavy rains occur in areas with susceptible soils, the 

layer between the surface and the hydrophobic layer can become saturated (Pyne et al., 1996). 

After a high intensity fire, when roots have burned or are decaying, runoff finds the vertical 

tunnels left by the roots and moves quickly on these macropore routes causing localized 

saturation and increasing the potential for landslides and debris flows. 

Nutrient Loss and Deposition. Fires can release important plant nutrients, such as phosphate, 

sulfate and nitrogen, as organic matter is volatilized through combustion both into the air and 

forced down into the soil (Pyne et al., 1996). Conversely, ash deposits from the fires themselves 

can increase the amount of nutrients available to plants post-fire, especially nitrogen, and can 

spur rapid plant growth following the fire. Where rains quickly follow a wildland or prescribed 

burn, much of the beneficial ash layer can be lost to stormwater runoff. Nutrients are replaced in 

part by rainfall, dust, pollen, decomposition of downed material, and growth of nitrogen-fixing 

plants such as Lupinus, Lotus, Alnus (Alder) and Ceanothus (DeBano, 1998; Agee, 1993). 

Post-fire Increase in Soil Temperature. Fires that consume most understory vegetation, reduce 

canopy cover, and and/or leave a deposit of dark ash can also lead to a subsequent increase in 

soil temperature from increased absorption and exposure to the sunlight. Under similar moisture 

regimes, warmer soils increase the rate of decomposition, and nutrient availability to post-fire 

vegetation and may increase microbial activity and rates of decomposition (Clark, 2001; 

Christensen, 1994). 

Loss of Organic Matter. One of the most noticeable effects of fire on soil is the combustion of 

organic matter, both on the soil as litter and buried within the soil. Organic matter helps regulate 

the hydrologic cycle and the carbon/nitrogen ratio, provides a site for nitrogen fixation by Nfixing bacteria, and maintains soil structure porosity and the cation exchange capacity. In Marin 
209 

soils, the percent of organic matter in the surface mineral layer varies from less than one percent 

up to ten percent. The Reyes and Sheridan Variant soils have the highest percent organic matter 

in the duff or surface mineral layer. Other soils with high level of organic matter include 

Centissima, Dipsea, Maymen, Maymen Variant, McMullin, Palomarin, and Wittenberg soils 

(Oster, 2003). 

Loss of Beneficial Organisms. A small percentage of combustion energy is expended in 

radiating downward during a fire causing higher temperatures in the upper soil layers. In a hot 

fire, beneficial fungi and bacteria that live in the soil can be destroyed, and subsurface dwelling 

wildlife, such as tunneling rodents, can be killed. Populations of microfauna and microflora 

typically decline following a severe fire but the increase in available nitrogen spurs plant growth 

which in turn fosters the reestablishment of the soil microorganisms. Often high intensity fires 

can serve to sanitize soils of pathogens over the short-term and may locally improve soil 

productivity (Pyne et al., 1996). Prescribed fire may reduce or increase plant pathogens found 

close to the surface. An increase in populations of Trichoderma, a soil fungus, was found by 

sampling a ponderosa pine forest following a prescribed burn (Reaves, 1990). Through 

laboratory analysis, it was determined that these fungi inhibited the growth of Armillaria 

ostoyae, responsible for serious root diseases in coniferous forests and plantations. 

Analysis 

Prescribed fire 

Prescribed fires generally burn at lower intensities than wildland fires and have fewer associated 

effects on soil resources. In the project area, prescribed burns are typically scheduled for the fall, 

winter, or spring - seasons which provide the environmental conditions that fit into the 

parameters (sufficient fuel moisture, low ambient temperatures, low wind speed, etc.) required to 

conduct a prescribed burn. The same parameters that permit implementation of prescribed burns 

also tend to reduce the intensity of a spreading fire, reducing the severity of effects on soil 

resources. Research has found that, in addition to negative effects, low intensity fire 

occasionally had beneficial effects on soil, often had no measurable effect and, further, the 

negative effects often were short-lived (Clark, 2001; Stanturf et al., 2002). These negative 

effects are primarily erosion and changes in the soil itself, and are described in more detail 

below. 

Erosion. As noted above, the severity and duration of the accelerated erosion depend on several 

factors, among them, slope, soil type, and the recovery time of protective cover (Clark, 2001). 

Prescribed burns in the project area would be conducted primarily in moderately sloped 

grasslands and shrubs and in forested areas to reduce understory growth. These low intensity 

fires do not fully combust overlying vegetation, duff, and litter; and resultant erosion is limited 

largely to small patches, even on slopes (Stanturf, 2002). A research project that monitored the 

post-fire effects following a low intensity prescribed burn over a three-year period found no 

noticeable increase in either erosion or surface runoff in the burn area (Biswell, 1989, p. 151). 

Generally, it is thought that slopes that are currently stable would show little increase in erosion 

after a fire, whereas steeper slopes with soils that currently are subject to erosion would 

experience accelerated erosion post-fire (Pyne, 1996). 
210 

Three of the four FMUs where actions would occur under Alternative A contain areas where 

soils have a very high erosion potential based on the Natural Resources Conservation Service 

Erosion Hazard Rating (EHR). Erosion rating indicates that these soils have a very high 

potential of eroding if disturbed – whether by mechanical means or a natural event. The soils 

support primarily forests of Douglas-fir, Bishop pine, or redwood and, having slopes ranging 

from 50% to 75%, are some of the steepest areas in the project site. Roughly one-fifth of the 

total acreage of the Limantour, Highway One, and Bolinas Ridge FMU contain these soils. 

A prescribed burn conducted in the forested areas of the FMUs would target reduction of 

understory fuels, and although burned areas may experience negligible or minor short-term soil 

loss until vegetation returns, it is likely areas would be readily revegetated under the near ideal 

climatic conditions at the Seashore if the burn intensity is low. Prescribed burning would have a 

relative positive impact on soils by re-introducing more natural fire intervals and intensities to an 

ecosystem where they have been suppressed. This and the reduction of fuel loading can have an 

important impact in reducing the potential for more damaging high intensity wildland fires to 

occur. 

Erosion may also occur as a result of the formation of hydrophobic soils. As noted above, this 

phenomenon can be quite short lasting, even following high intensity wildfires such as the 

Vision Fire. Because the degree to which hydrophobic soils form is related largely to the 

intensity of the fire, prescribed burns would result in less severe formation of these water 

repellent soils for an even shorter period of time (Robichaud, 2000b; De Bano, et al., 1998). 

The degree of impact to soils from erosion as a result of prescribed burning would never exceed 

minor, as defined in the Methodology section for soils. This means fewer than 10% of soils in 

any given watershed would be affected each year by prescribed burning activities. To ensure no 

greater than minor impacts, the park would continue its current practice of writing and approving 

burn plans. 

To assure that attention is also given to the protection of soil resources, mitigation measures 

require that burn plans and associated erosion control plans prepared by the NPS be reviewed by 

a subject matter expert, such as a hydrologist or erosion specialist, prior to approval for 

implementation. The subject matter expert would determine whether the erosion control plan 

submitted is sufficient to prevent long-term moderate or major impacts on the rate of soil 

erosion. In other words, the expert would determine whether the proposed erosion control 

strategy would be sufficient to ensure no greater than minor impacts to soils from erosion. If the 

assessment finds that standard erosion control strategies would be insufficient to avoid a longterm moderate or major effect on the rate of erosion, a separate environmental process would be 

initiated for that burn plan. Some of the strategies used to minimize impacts to soils are to avoid 

steep slopes, time burns to maximize favorable environmental conditions, and erosion control 

devices during burns. 

Park fire management personnel focus prescribed burns on areas with gradual to moderate 

slopes, avoiding steeper areas and ridgetops where fire behavior is less predictive. In doing so, 

the areas with the more erosion prone soils (granitic soils on the ridgetops) are also avoided (K. 
211 

Riggs, pers.comm.). Any prescribed burn proposed for the forested areas would be designed to 

avoid the steeper slopes not only to reduce potential erosion but also to avoid losing control of 

the fire and placing firefighters and park and private resources at risk. 

In addition to the steepness of the slope, the time it takes for a burn area to revegetate also 

influences the degree of erosion. In the project vicinity, the Seashore minimizes the time soil is 

exposed by conducting most prescribed burns in early fall just prior to the winter rains that result 

in quick revegetation. The park also leaves unburned strips of vegetation along riparian areas in 

its prescribed burns to reduce soil erosion in steeper slopes leading into drainages. Because 

prescribed fires are low intensity, they leave behind large woody debris and duff that act as 

barriers parallel to slopes and trap eroding soils. 

Where existing roads and trails do not provide an adequate barrier to help contain a prescribed 

fire, fire lines are created with hand tools at the perimeter of the burn area. If not rehabilitated 

following the burn, the linear area cleared for the fire line could become a new drainage channel 

during heavy rains leading to accelerated soil erosion and a localized change in drainage 

patterns. The use of standard best management practices, such as the placement of erosion 

control blankets, sterile rice straw, contour felled logs, and material chipped on site to serve as 

mulch help to control impacts both during and following prescribed burns. Fire lines would also 

be scarified to promote revegetation and sufficient large woody debris left within the site to 

promote nutrient recycling. 

The burn plan itself would be reviewed to make sure the yearly prescribed burning in any 

targeted watershed does not exceed 10% of the total acreage or otherwise have the potential to 

result in more than minor impacts to soil from erosion. This check would also ensure minimal 

impacts to water quality or aquatic wildlife. Alternative A would result in the prescribed burning 

of 500 acres or less, which, as Table 41 shows, is smaller than 10% of the acreage any of the 

watersheds proposed for treatment. Even if the annual plan for prescribed burning proposed 

work takes place in a single watershed, it would not be possible to exceed 10% of the acreage. 

Therefore, the effect of prescribed burning on 10% or less of the vegetation cover would 

normally be a negligible or minor short-term adverse effect. As noted above, if park review 

indicated that potential erosion would be greater than this even with the use of mitigation 

described above, additional environmental analysis would occur. 

Table 41. Alternative A, Potential Watershed Level Effects 

Watershed (Total 

Acreage) 

Alternative A 

FMUs in each 

Watershed 

Alt. A FMU 

acreage within this 

Watershed 

% of Watershed 

within this FMU

Potential for Moderate or 

Major Impact on 

Watershed Soils 

Bolinas Drainages 

Watershed (7,902 acres) 

Bolinas Ridge 

Highway One 

259 acres 

521 acres 

3.3% 

6.6% 

No. 10% of watershed = 790 

acres which is > 500 acres 

(annual limit Alt. A). 

Drakes Bay Drainages 

Watershed (12,758 acres) 

Limantour Road 820 acres 6.4% No. 10% of watershed = 

1,276 acres which is > 500 

acres (annual limit Alt. A). 
212 

Watershed (Total 

Acreage) 

Alternative A 

FMUs in each 

Watershed 

Alt. A FMU 

acreage within this 

Watershed 

% of Watershed 

within this FMU

Potential for Moderate or 

Major Impact on 

Watershed Soils 

Drakes Estero Watershed 

(17,720 acres) 

Estero 

Limantour Road 

1636 acres 

2543 acres 

9.2% 

14.3% 

No. 10% of watershed = 

1,772 acres which is > 500 

acres (annual limit Alt. A). 

Lagunitas Creek 

Watershed (53,161 acres) 

Bolinas Ridge 1339 acres 2.5% No. 10% of watershed = 

5,316 acres which is > 500 

acres (annual limit Alt. A). 

Olema Creek Watershed 

(9,397 acres)` 

Bolinas Ridge 

Highway One 

606 acres 

1347 acres 

6.4% 

14% 

No. 10% of watershed = 940 

acres which is > 500 acres 

(annual limit Alt. A). 

Pine Gulch Creek 

Watershed (5,064 acres) 

Bolinas Ridge 

Highway One 

177 acres 

1,012 acres 

3.5% 

14% 

No. 10% of watershed = 506 

acres which is > 500 acres 

(annual limit Alt. A). 

Tomales Bay Watershed 

(29,218 acres) 

Limantour Road 755 acres 2.6% No. 10% of watershed = 

2,922 acres which is > 500 

acres (annual limit Alt. A). 

Source: NPS GIS Database, 2003. Calculations are based on the total acreage within each FMP watershed and the 

total acreage of the FMUs sited either fully or partially within that watershed. 

Changes in Soil Characteristics. Though usually more limited in effect than wildland fires, low 

intensity prescribed burns can result in changes to the upper few inches in the soil horizon 

(Christensen, 1994). As noted above, impacts can include the loss of nitrogen through 

combustion and volatilization and changes in subsurface biological activity. Offsetting these 

adverse impacts would be nitrogen deposited in fire ash and the function of large woody debris, 

which, when left within the perimeter of a burn promotes nutrient cycling and nutrient exchange 

between beneficial fungi and plant roots (DeBano, 1998). In addition, although the total amount 

of nitrogen and other nutrients available at a site may decrease after a fire, volatilization 

(producing an ammonium form of nitrogen), conversion to organic nitrogen by bacteria and 

nodules of legumes, such as ceanothus, and a reduction in competing vegetation (Pyne et al., 

1996; Christensen, 1994) all act to increase the amount of nutrients readily available to 

remaining plants. Overall, the impacts of prescribed burning under Alternative A to soil 

productivity and chemistry would be adverse, short-term and negligible to minor in intensity. 

Depending on temperatures reached in the upper few inches of soil, beneficial insects, bacteria, 

and fungi can be killed, and seeds and plant roots close to the surface can be damaged (DeBano, 

et al., 1998). Prescribed fire may also have indirect impacts by decreasing the number of soil 

organisms that hold others in check, ultimately resulting in an increase in what may be harmful 

pathogens. This was the case in a ponderosa pine forest following a prescribed burn (Reaves, 

1990). Overall, Alternative A may result in negligible to minor short-term impacts on organisms 

in the soils and nutrients in the upper few inches of the soil horizons. 

Unplanned Ignitions, Wildfire and Suppression 

Wildland fire is both an anticipated element and a variable in the FMP. Wildland fire and the 

suppression and restoration actions that follow wildland fire all have the potential to affect park 
213 

soils. Wildland fire typically burns with a higher intensity than prescribed fire due to the dryer 

conditions of the fuels, higher ambient temperature and the potential for spread to more 

flammable types of vegetation and landscape conditions. Depending on the intensity and 

duration of a wildland fire, immediate and long-term changes in soil properties and processes can 

occur. Suppression activities may also have adverse impacts on soils. In the following section, 

impacts are described generally for wildfires, which are not expected to exceed 10-30 acres in an 

average year at the Seashore. These same types of impacts would occur, but be much more 

serious, in a catastrophic or large-scale wildfire, such as the 1995 Vision Fire. Because these are 

not part of the 10-15 year planning horizon for this plan, the impacts of catastrophic fire are 

analyzed throughout this EIS in the section on cumulative impacts. 

High intensity, slow-moving wildland fires can effect numerous changes on the physical, 

chemical, and biological processes operating in soils. Severe burns can have all of the types of 

impacts described above in the introduction to this analysis and in the section of prescribed 

burns. The extent of the impact is likely to be more severe in the localized area of the burn, 

although the acreage burned through wildland fires in this alternative would on average be far 

less than 10% of that burned in prescription. 

Erosion. High intensity wildland fires can remove nearly all of the protective vegetation 

covering soils, exposing soils to wind or water erosion. As noted above, erosion ultimately 

reduces soil productivity and vegetation. It can also create conditions under which exotic plant 

species are better competitors than native vegetation. Bare ground can remain bare for a longer 

period of time on steeper slopes, or when soils are susceptible to becoming hydrophobic. Clay 

rich soils subject to very high fire intensity may fuse at the soil surface, decreasing porosity, 

slowing infiltration of water, and increasing the rate of surface soil erosion. Rain can exacerbate 

erosion through the rilling of slopes and channel cutting, as well as through slope failure as 

described above for hydrophobic soils. However, it can also encourage rapid replenishment of 

organic matter though revegetation. 

Changes in Soil Characteristics. A wildfire is likely to burn hotter than a prescribed burn, and 

can start in a wider variety of vegetation types and under drier conditions. As noted above, 

certain types of soils in the park are more vulnerable to become hydrophobic following a fire. A 

hot wildfire, such as may occur in forested areas of the park or where fuels have built up, may 

create hydrophobic soils deeper in these soils. In particular, granitic soils or soils formed from 

coarse-grained sandstone (such as Kehoe Variant and Sheridan Variant soils) which support 

forests of Bishop pine, tan oak, and a brush cover, could become water repellent with resulting 

erosion of top layers including through rilling, channel cutting and even slope failures. However, 

based on the short period of time soils remained hydrophobic following the Vision Fire, it is 

unlikely that the small acres burned by wildfire in a normal year would have more than 

negligible effects on soil through the formation of water repellent layers. 

This is also true of plant nutrients that may be lost through volatilization during a fire. Organic 

matter on and in soil is also lost or changed through combustion. In a hot wildfire, the loss would 

be greater than in prescribed burn, as the effects would extend deeper into the soil and would not 

leave much organic matter on the surface. As noted above, hot fires may also kill beneficial fungi 

and bacteria that live in soils or wildlife that tunnel near the surface. Because the acreage 
214 

affected by wildfire is small, and because ash deposits can increase the amount of nutrients to 

plants following a fire, impacts to soil nitrogen, phosphate, sulfate, organic matter in soils, or 

biological microfauna or flora from wildfire in a typical year would not be more than negligible 

or minor. 

Unlike prescribed burning, wildfires usually involve suppression activities, such as driving 

vehicles offroad to reach the site quickly. The weight of these vehicles compacts soils, increasing 

density and reducing pore size so that both water absorption and root growth are slowed and 

reduced. Clay and loam soils compact more readily and to a greater degree than sandy soils, and 

moist soils compact more easily than dry soils. Thick vegetation cover helps reduce potential 

soil compaction. Compacted areas may revegetate very slowly and tree recovery may take 

decades (McNabb and Swanson, 1990). 

In addition to compaction, suppression activities can cause soil profile mixing, erosion, 

contamination, and overheating of soils. Manual or mechanized earthmoving to create firebreaks 

and roads or smother burning materials can mix the layers of the soil horizon, bury the fertile 

topsoil layer, and the native seedbed within the topsoil reducing the success of post-fire native 

plant revegetation. Uprooting trees and shrubs and scraping away covering vegetation during 

these actions expose soils to erosion by wind and water. Removal of covering vegetation and 

uprooting of plants and tree roots by heavy equipment exposes disturbed soils to erosion by 

water and wind. 

In some cases, suppression activities can be responsible for the most intense impacts to soils. 

After the Oakland Hills fire, for example most erosion occurred as the result of ground disturbing 

activities from fire suppression (fire roads, firebreaks) and post-fire reconstruction. Because soil 

and soil productivity is slow to replace in human timescales, measures to prevent or minimize the 

impact of suppression are the most effective. Current practice has therefore shifted to limited 

scope projects that protect specific down-slope resources, such as areas of prior slope failure, 

water bodies, creeks and structures (Oster, 2003). For example, with the exception of response to 

a life threatening wildland fire, fire suppression vehicles or heavy equipment used for fire line 

construction should be directed away from stream channels, riparian areas, wetlands, sensitive 

biological areas, or perpendicular to slope contours. Park resource advisors working at the fire 

command center would provide the data and expertise to help fire command minimize impacts 

during suppression. Assuming these standardized mitigation measures and the small area of the 

park burned by wildfire each year, impacts to soils from suppression activities would be no more 

than negligible or minor. 

Mechanical Treatments 

Erosion. Mechanical clearing is performed by roadway mowing or by power tools. In most 

cases, plants are cut above ground leaving roots in place to prevent mixing the soil horizon, 

reduce erosion potential and stabilize slopes. Removal of large non-native trees, such as 

eucalyptus, often requires heavy equipment and could result in compaction of soils as trees are 

shifted to staging areas and hauled from the site by large trucks. Following the use of heavy 

equipment, all compacted areas should be scarified to encourage resprouting from the native 

seedbed. Standard erosion control strategies, such as erosion control blankets, should be 
215 

installed as required to prevent erosion. In most cases, these standard erosion control practices 

are effective in controlling erosion and reducing the effects of compaction that occur during 

mechanical treatment actions. 

Changes in Soil Characteristics. In some instances, it is preferable to manage invasive non-native 

vegetation by removing the entire plant to prevent the resprouting of cut stalks and reduce the 

need for repeated treatments. When soils are saturated, plants such as French and Scotch broom 

pull out with little resistance causing little soil disturbance. This can results in a limited amount 

of soil horizon mixing as subsurface soils are pulled up with the plant roots. However, 

mechanical treatment actions rarely result in more than negligible soil disturbance with the 

exception of large-scale tree removal projects where heavy equipment is employed. 

Mechanical treatment for fuel reduction generates large quantities of non-native and native plant 

material. There are several means of disposal of the vegetation. Chips and other plant material 

left on the surface soil will eventually degrade and contribute to organic matter and nutrients that 

improve soil productivity and ability to absorb runoff. Often vegetation is chipped up onsite 

where it can then be rebroadcasted for weed abatement and erosion control, chipped and 

removed from the site for use elsewhere for weed abatement, as biomass fuel, or disposal at a 

greenwaste recycling facility or a landfill. Wood can be left for use as firewood for the 

community in the project vicinity. A certain amount of wood can be left on site to decompose 

and provide habitat. The wood should be left in contact with the soil so as not to contribute to 

ladder fuels. Isolated snags may be left standing for habitat purposes. Broadcasting chips and 

leaving large debris parallel to the slope all constitute effective soil cover and contribute to 

controlling erosion by wind, water, and gravity. 

Often larger rounds and branches are piled for burning onsite at a time when prescription 

requirements can be met. Burn piles burn for long periods of time at high temperatures and can 

impact soils close to the site of the burn (DeBano, 1998). The location of burn piles should be 

carefully sited away from slopes not only to prevent logs from rolling out of the fire, but to avoid 

creating a hydrophobic area on a slope that could result in a localized area of hydrophobicity that 

could accelerate runoff and erosion as well as be more likely to loss nutrient fire ash to 

stormwater erosion. 

Wood from trees infected with Sudden Oak Death has the potential to continue the spread of the 

disease if wood is transported away from the site of origin. For that reason, all infected wood 

would be chipped or burned in piles onsite of the fuel reduction project. 

Overall, impacts to soil resources from mechanical treatment projects would be adverse, shortterm, and negligible to minor in impact intensity. 

Wildland Urban Interface Initiative Program 

Under Alternative A, projects would be restricted annually to 500 acres of prescribed burning 

and 500 acres of mechanical treatment in the Limantour Road, Highway One, Bolinas Ridge (fire 

only), and Estero FMUs. Projects within the Highway One FMU have the opportunity to build 

upon community projects proposed for the small community of Dogtown. Additional work 
216 

funded under the WUI initiative for the Dogtown area should considered during annual planning 

for FMP projects to identify the affected watersheds and assure than no more than 10% of the 

watershed is affected. 

Maintenance of Fire Roads and Trails 

Mowing, debris clearing, tree felling along roadways and other actions necessary to maintain 

reduced fuels and emergency vehicle access on park roads and trails would not affect soil 

resources in the project area. Actions occur within a 10-foot corridor on each side of the 

roadway and involve chainsaws, lopers, overhead pruning saws, weedwhips, small trucks, and a 

mower. With the exception of the mower, maintenance vehicles stay within the margins of the 

roadway and the actions do not affect soil resources. The mower could disturb restricted areas of 

surface soil while navigating along the corridor or occasionally cut into surface soils with the 

changes in topography. Mowing normally occurs after nourishing winter rains have ceased and 

prior to the beginning of fire season, to be able make the single pass of the mower as efficient as 

possible. Soils within the 10-foot corridor are largely protected from the action of the mower by 

the accumulation of the newly cut grass, thatch from previous years and the dense near-surface 

root system of annual grasses and forbs. Because of the timing of the mowing and the protection 

afforded by vegetation, thatch, and roots, any erosion of exposed surface soils would be 

negligible. 

Vegetation Clearing Around Buildings 

Clearing around buildings can involve pickup trucks, a mower, chain saws, overhead pruning 

saws, weedwhips, riding mowers, and lopers. Soil disturbance would be limited to occasional 

contact of the mower blade with soil depending on the topography. Vegetation is cleared around 

buildings in early spring so residual growth of cut vegetation occurs and the limited areas where 

soils are exposed would be protected against erosion by wind or water by regrowth, existing 

thatch cover, and the near-surface root system of annual grasses and forbs. Because of this 

protection and the timing of the mowing, any erosion of exposed surface soils would be 

negligible. 

Public Information and Education 

Fire information and education actions proposed for all alternatives would have no beneficial or 

adverse effects on soil resources in the project area. 

Fire Cache/Park Headquarters Relocation and Construction 

The proposed structure would cover approximately 3000 square feet of ground surface. 

Additional concrete aprons and paved surfaces would be approximately 1000 square feet. 

Vehicle parking would be gravel. Vehicle washing would occur within curbed paved area and 

runoff and accidental spills would be captured and wastewater suctioned into a holding tank. 

The 4,000 square feet of soil affected are located in the most developed area of the park. The 

ground surface is nearly level and loss of soils during construction could be minimized through 

the application of standard erosion control practices such as erosion control fabric placed to 
217 

prevent soil movement. Orange habitat fencing set back from the building envelope and 

delineating the extent of the working area would prevent unwarranted soil compaction and 

surface disturbance by heavy equipment. 

Cumulative Impacts 

Cumulative impacts are those that would occur not as a direct result of this planning effort or 

actions proposed in the alternative, but in the vicinity of the project area. Appendix C has a list of 

other planning activities in the project area that are unrelated to this fire management plan. In 

addition, the Seashore experiences a major wildland fire every few decades. Such a fire would 

affect all of the same resources described in this EIS under the sections Prescribed Fire and 

Wildfire and Suppression. It is therefore included in the discussions of cumulative impacts. 

Erosion. Assuming a moderate to fairly large wildland fire, the effects to soil resources would be 

adverse, short- to long-term and moderate to major in intensity. Depending on the severity of the 

burn, slopes and rainfall intensity, productive topsoil could be lost through erosion throughout 

the burn area. The soils with the highest potential for erosion are on very steep slopes along the 

top of Inverness Ridge in Bishop pine, Douglas-fir, and redwood forests. During the very large 

and catastrophic 12,000+ acre Vision Fire, forested areas and woodlands accounted for roughly 

75% of the vegetation burned. Fire intensity was highest on the steep slopes of Inverness Ridge 

which also have highly erosive granitic soils (BAER, 1996). Active upstream channel cutting 

was observed in drainages on the west slope of Inverness Ridge. Evidence of erosion was 

recorded particularly in the granitic soils on the steeper slopes. Many of the soil types within the 

project area were outside of the burn perimeter of the 1995 fire and the potential effects of fire on 

rates of erosion have not been observed. Monitoring of other post-fire areas reports elevated 

erosion rates for two or more years following fires. From research on the Vision Fire, it should 

be noted that the burn area ranged from 50 to 100% of many watersheds in the burn area. The 

impacts to soil in these watersheds were major, but within three years, many conditions were 

trending back to normal (soil chemistry, hydrophobicity, etc.) 

Major impacts to soil resources during the Vision fire resulted from compaction and erosion 

from the use of heavy equipment to construct fire lines, staging areas, and travel corridors for 

emergency vehicles during fire suppression. Potential effects from heavy equipment include: 

soil compaction, concentration of runoff water by roads, landings and yarding corridors, mixing 

of native soil horizon from fire line creation, loss of productive surface soils to erosion due to 

loss of soil anchoring vegetation cover, increase in potential for surface soil failures (debris 

flows), soil contamination from the application of fire suppression and retardant compounds, 

alteration of soil properties as a result of prescribed or wildland fire (e.g., hydrophobicity/water 

repellency, death of soil organisms, reduced water storage by removal of large woody material, 

and organic matter overlying and within the soils. De Bano and others (1996) found that 

moderately and severely burned watersheds took 7 and 14 years, respectively to recover from 

full effects of the loss of surface soils in the post-fire period of accelerated erosion. Although this 

is potentially a serious impact, the soils would recover, preventing an impairment of park 

resources. 
218 

Changes in Soil Characteristics. The granitic soils of Inverness Ridge and soils supporting 

certain chaparral species, such as manzanita, may be prone to develop hydrophobicity. Research 

has shown that effects of hydrophobicity may last as long as three to four years, but 

investigations following the Vision Fire experience indicated that water repellency was noted in 

areas that experience severe fire intensity but had significantly diminished in effect by the second 

winter storm season following the fire. Areas prone to hydrophobicity and high rates of runoff 

and low rates of infiltration may also experience mass slope failures and debris flows in steeply 

sloped areas. 

Reduced populations of beneficial organisms and occasionally pathogens follow fires. Also, an 

immediate decrease in organic material and available nutrients occurs; this is corrected over time 

by nutrient recycling. Elevation in soil temperatures may contribute to a slower re-establishment 

of effective soil cover. 

As noted above, the use of heavy equipment and other suppression activities can have a variety 

of adverse effects on soils, some of which can be long lasting. Soil and soil productivity is slow 

to replace in human timescales; therefore, post-burn management activities that accelerate 

erosion or create soil compaction must be avoided or minimized to the greatest extent possible. 

While large-scale erosion control projects are sometimes implemented after a large fire, this has 

not always proved to be effective from a safety or cost-perspective. Practices that increase soil 

infiltration and reducing runoff (e.g., seeding) may also increase water storage in the soil and 

increase the hazard of landslides (Booker et al., 1993). This is why suppression activities are 

currently more focused on avoiding specific down-slope resources, such as areas of prior slope 

failure, water bodies, creeks and structures (Oster, 2003). Sensitive resources, such as stream 

channels, riparian areas, wetlands, or other special biological areas, are also avoided if possible. 

Beyond a large-scale wildfire, cumulative impacts to soils would occur from some of the 

building projects identified in Appendix C. The Giacomini Wetlands Project converts grazing 

lands to wetlands inundating 560 acres of soils largely formed under wetland conditions. Rather 

than an impact to soil resources, this represents a restoration of wetland soil resources to a native 

state. The series of riparian protection projects proposed for the Olema Valley would reduce 

erosion into the riparian corridors and include exclusionary fencing on Blueline Creek, 

Giacomini Creek, Cheda Creek, and other tributaries. 

Conclusion 

The impacts of prescribed burning under Alternative A to rate of soil erosion would be negligible 

to minor depending on the amount of effective soil cover that remains after the fire and the 

steepness of the slopes involved. Impacts from erosion would be kept to no more than 10% of 

soils in the watershed through the use of annual burn plans and NPS review. Soil productivity 

and chemistry would experience adverse, short-term and negligible to minor impacts from 

prescribed burning. In the short-term, there may be negligible to minor short-term impacts on 

organisms in the soils and nutrients in the upper few inches of the soil horizons. 

The same types of impacts to soils, e.g., erosion and changes in soil productivity and chemistry, 

would result from typical wildland fires in the park each year. Suppression activities would add 
219 

impacts to soils primarily from compaction. Because the number of acres burned by wildfires 

each year remains quite low, impacts to soils would be short-term, adverse and negligible or 

minor. 

Soil disturbance from mechanical treatment is not expected to result in more than negligible or 

minor short-term adverse impacts. 

Moderate to major short- to long-term adverse impacts to soils from a very large or catastrophic 

wildland fire are possible. Increases in erosion, formation of hydrophobic soils, gullying, channel 

cutting, slope failure, and changes to the physical, chemical, and biological nature of soils in the 

project area are likely in the event of this type of fire. Suppression activities could have 

additional adverse, short- to long-term moderate to major impacts from soil compaction, mixing, 

reduced infiltration, loss of vegetation and changes in soils that prevent quick revegetation. 

Avoiding sensitive resources could keep impacts from becoming major and adverse. 

No impairment to park soil resources is expected. 

Alternative B 

The actions associated with Alternative B could result in both beneficial and adverse effects on 

soil resources within all 10 of the FMUs within the project area though actions in certain FMUs 

are limited to either prescribed fire or mechanical treatment. Actions would be permitted within 

the following FMUs: Tomales Point (mechanical only), Estero, Inverness Ridge (prescribed fire 

only), Limantour Road, Highway One, Bolinas Ridge (prescribed fire only), Wilderness North, 

Wilderness South, Palomarin, and Minimum Management FMUs (mechanical treatment only). 

Alternative B calls for prescribed burning of up to 1000 acres each year, and mechanical 

treatment of up to an additional 1000 acres. 

Analysis 

Prescribed Fire 

As in Alternative A, impacts to soil resources from prescribed fire projects would be adverse, 

short-term, and negligible to minor in intensity primarily because the conditions that permit a 

prescribed burn to proceed also limit the intensity that the fire typically achieves. As noted 

above, fire intensity is the factor that most affects soil productivity and soil stability by the 

combustion of organic matter, beneficial organisms, and overlying vegetation cover, 

volatilization of nutrients, and pulsing of hydrophobic compounds into surface soils. In 

prescribed burns, fire intensities are would be low with only scattered areas of where readily 

ignitable fuels burn with a higher intensity. Prescribed fires are also conducted on moderately 

sloped terrain. These factors all combine to limit the amount of ensuing erosion. Changes to soil 

characteristics would be similar to Alternative A and limited primarily to the upper soil horizon 

and correctable through natural processes such as nutrient recycling. 

Typically, prescribed fires do not burn with sufficient intensity in the project area to fully 

combust effective soil cover and expose bare mineral soil except in very limited areas. However, 
220 

the Seashore nevertheless proposes to limit the aerial extent of annual burning within one FMP 

watershed to 10% or less of the total watershed area to ensure no greater than minor impacts to 

soils from erosion resulting from prescribed burns. 

While the annual 500-acre cap of prescribed burning under Alternative A automatically limits 

the potential watershed level effects on erosion to a negligible or minor effect, larger projects are 

permissible under the 1,000-acre annual cap in Alternative B. Ten percent of the total acreage of 

three of the watersheds where FMUs slated for prescribed burning in Alternative B is less than 

1,000 acres per year. If a group of projects proposed for several FMUs were sited within one of 

these three watersheds, there is a potential for more than 10% of the effective soil cover in that 

watershed to be affected. 

Mitigation measures relative to watershed level planning are proposed to assure that erosion rates 

within any one watershed would conform to the conclusions of environmental effect reached in 

this EIS, e.g., would be no more than moderate in intensity. It would be triggered when proposed 

actions have the potential to exceed 10% of the total area of one or more FMP watersheds in one 

year. Mitigation Measure S-2 assures that planning considers the watershed scale, and if a 

potential effect is identified, that a specific assessment be conducted for the work plan to assure 

the conformance of watershed level effects with this EIS. Under Alternative B, Mitigation 

Measure S-2 would be triggered if the annual work plan includes projects that account for more 

than 10% of the Bolinas Drainages, Olema Creek Watershed, or the Pine Gulch Watershed. As 

shown in Table 42, the combined project acreage must exceed 790 acres in Bolinas Drainages, 

939 acres in Olema Creek Watershed, and 506 acres in Pine Gulch Watershed. 

Once it is confirmed that an annual plan for prescribed burning would exceed the 10% level of 

area in these smaller watersheds, Mitigation Measure S-2 requires an interdisciplinary team 

evaluation, chaired by the Fire Management Officer, to document the degree of conformance of 

the proposed actions with the assessment conducted for this EIS. 

Table 42. Alternative B: Potential Watershed Level Effects 

Watershed (Total 

Acreage) 

Alternative B FMUs 

in each Watershed 

Alt. B FMU 

acreage within 

this Watershed

% of 

Watershed 

within this 

FMU 

Potential for More than Minor Impact 

on Watershed Soils 

Bolinas Drainages 

Watershed (7,902 

acres) 

Bolinas Ridge 

Highway One 

Palomarin 

259 acres 

521 acres 

1,823 acres 

3.3% 

6.6% 

23.1% 

Yes. 10% of watershed = 790 acres 

which is < 1,000 acres (annual cap Alt. 

B) and 

Total FMU acreage in watershed = 33% 

which could exceeds the 10% target. 

Mitigation S-2 is triggered. 

 

Drakes Bay 

Drainages 

Watershed (12,758 

acres) 

Limantour Road 

Palomarin 

Wilderness N 

Wilderness S 

820 acres 

35 acres 

327 acres 

1,439 acres 

6.4% 

0.3% 

2.6% 

11.3% 

No. 10% of watershed = 1,276 acres 

which is >* 1,000 acres (annual cap Alt. 

B). 

 
221 

Watershed (Total 

Acreage) 

Alternative B FMUs 

in each Watershed 

Alt. B FMU 

acreage within 

this Watershed

% of 

Watershed 

within this 

FMU 

Potential for More than Minor Impact 

on Watershed Soils 

Drakes Estero 

Watershed (17,720 

acres) 

Estero 

Inverness Ridge 

Limantour Road 

Wilderness N 

1636 acres 

924 acres 

2543 acres 

74 acres 

9.2% 

5.2 % 

14.3% 

0.4% 

No. 10% of watershed = 1,772 acres 

which is >* 1,000 acres (annual cap Alt. 

B). 

Lagunitas Creek 

Watershed (53,161 

acres) 

Bolinas Ridge 1339 acres 2.5% No. 10% of watershed = 5,316 acres 

which is >* 1,000 acres (annual cap Alt. 

B). 

 

Olema Creek 

Watershed (9,397 

acres) 

Bolinas Ridge 

Highway One 

606 acres 

1347 acres 

6.4% 

14% 

Yes. 10% of watershed = 940 acres 

which is <* 1,000 acres (annual cap Alt. 

B) and 

Total FMU acreage in watershed = 

20.4% which could exceed the 10% 

target. Mitigation S-2 is triggered. 

 

Pine Gulch Creek 

Watershed (5,064 

acres) 

Bolinas Ridge 

Highway One 

Wilderness S 

177 acres 

1,012 acres 

780 acres 

3.5% 

14% 

8.3% 

Yes. 10% of watershed = 506 acres 

which is <* 1,000 acres (annual cap Alt. 

B) and 

Total FMU acreage in watershed = 

25.8% which could exceed the 10% 

target. Mitigation S-2 is triggered. 

 

Tomales Bay 

Watershed (29,218 

acres) 

Inverness Ridge 

Limantour Road 

Wilderness N 

326 acres 

755 acres 

1,190 acres 

1.1% 

2.6% 

4.1% 

No. 10% of watershed = 2,922 acres 

which is >* 1,000 acres (annual cap Alt. 

B). 

There are two findings that could result from the watershed level assessment. Either the annual 

work plan would conform to or would exceed the level of effect predicted in the FMP EIS. 

Conformance would show that the proposed actions do include more than 10% and less than 

25% of one FMP watershed but effects on the rate of erosion would be readily correctable by 

standard erosion control practices and would not result in a major impact. Documentation 

prepared by the interdisciplinary team must be sufficient to demonstrate that the project or 

projects conformance for the impact areas addressed in the EIS: soils, water quality, vegetation, 

rare or threatened species, aesthetics, park operations, or visitor experience. The definition of 

effect must conform to the methodologies applied in this EIS. Documentation would include 

project-level conditions sufficient where necessary to minimize or avoid major impacts to 

resources. The completed documentation will be signed by the Superintendent and added to the 

administrative record for this NEPA process, demonstrating conformance with this EIS. If the 

assessment found that the work plan does not conform to the findings of this EIS, a separate 

NEPA review process would be initiated. 
222 

Wildland Fire and Suppression 

The level of impact to soils from wildland fires or suppression actions in an average year would 

not change from the level of impacts under Alternative A. 

Mechanical Treatments 

Alternative B permits twice the level of mechanical treatment than Alternative A. Despite the 

increase in acreage, the potential effects to soil resources are essentially the same as in 

Alternative A, as mechanical treatments normally do not disturb surface soils. As with 

Alternative A, burning of piled materials is used to dispose of cut vegetation. Under Alternative 

B, roughly twice as much material would need to be recycled chips or firewood, burned in piles, 

reused as biomass fuel or lumber, or legally disposed. Native plant materials and certain nonnatives such as broom can be chipped and broadcast back into the area treated and contributes to 

effective soil cover. Areas supporting broom typically have such a large number of broom seeds 

in the soil that the chipped material can serve to help abate the resprouting of seedlings. 

Soils below the burn piles can be subject to changes in productivity due to the concentrated 

effects of high intensity fire. Areas affected would be very limited in extent and would not 

significantly contribute to increase in soil erosion or decreases in soil productivity. Under 

Alternative B, impacts to soil resources from mechanical treatment would be adverse, short-term 

and negligible to minor in intensity. 

Actions Common to All Alternatives 

Wildland Urban Interface Initiative Program 

Under Alternative B, there is much greater potential for in-park projects to complement those 

community projects funded by the WUI program. By definition, WUI projects are approved in 

part due to the proximity of the proposal area to the federal wildland interface. The potential to 

develop projects across management boundaries improves the effectiveness of the individual 

federal efforts and the community efforts. For example, fuel reduction projects within the 

Inverness Ridge FMU would build upon risk reduction achieved through matching efforts in 

Paradise Ranch Estates. Work in the Palomarin and Pine Gulch FMUs would improve the 

overall effectiveness of efforts funded for the Bolinas community. The overall fuel reduction 

achieved in Alternative B would provide greater beneficial effects than the limited opportunities 

provided under Alternative A, however, there is potential for soil disturbance to occur in a 

limited area where projects overlap jurisdictional boundaries. Mitigation measures require that 

the Superintendent assure that NPS funded projects for fire management actions in the PRNS 

Wildland Urban Interface retain sufficient funding in reserve from the full budget to purchase 

and install erosion control measures found to be required as conditions of NPS project review. 

Equivalent erosion control must be built into and funded for park and community projects 

affecting essentially the same soil resource area. 
223 

Maintenance of Fire Roads and Trails 

Maintenance actions for fire roads and trails would be identical to Alternative A and, as in 

Alternative A, the limited exposed of surface soils from mowing actions would negligibly affect 

the rate of erosion. Other soil characteristics would not be affected. 

Vegetation Clearing Around Buildings 

Clearing around buildings would involve identical actions to those described for Alternative A 

and would result in negligible effects to the rate of erosion. 

Public Information and Education 

Fire Information and Education actions proposed for all alternatives would have no beneficial or 

adverse effects on soil resources in the project area. 

Fire Monitoring 

Actions associated with the fire-monitoring program are largely observational and non-invasive 

and would not affect soil resources in the project area. 

Fire Cache/Park Headquarters Relocation and Construction 

No change to the fire cache proposal occurs under Alternative B. Impacts under Alternative B 

are the same as those assessed under Alternative A. 

Cumulative Impacts 

Under Alternative B, impacts from a catastrophic wildland fire event similar to the 12,354-acre 

Vision Fire would have adverse, major, and long-term impacts to soil resources similar to under 

Alternative A. As Alternative B permits a higher amount of mechanical treatment and 

prescribed burning annually than Alternative B, twice as much acreage is treated to reduce fuels 

than in Alternative A. A primary focus of the actions would be to reduce fuels in the interface 

area with residential and commercial development. Over time, as more and more acreage is 

treated and maintained, potential effects from high fire intensity to soil resources would be 

reduced in the treated areas. 

Conclusion 

The impacts of prescribed burning under Alternative B on the rate of erosion of park soil 

resources would be negligible to minor depending on the amount of effective soil cover 

remaining after a fire and the steepness of the slopes involved. Although impacts from erosion 

would be greater than those in Alternative A, they would be kept to no more than 10% of soils 

within a watershed through the use of annual burn plans and NPS review as proscribed in 

Mitigation Measure S-2. As in Alternative A, soil productivity and chemistry would experience 

adverse, short-term and negligible to minor impacts from prescribed burning, although the 
224 

acreage experiencing these impacts would increase. In the short-term, there may be negligible to 

minor short-term impacts on organisms in the soils and nutrients in the upper few inches of the 

soil horizons. 

Impacts to soils from wildland fires and suppression in an average year in the park would be the 

same as in Alternative A. 

As in Alternative A, soil disturbance from mechanical treatment is not expected to result in more 

than negligible or minor short-term adverse impacts. 

Moderate to major short- to long-term adverse impacts to soils from a very large or catastrophic 

wildland fire are possible. Increases in erosion, formation of hydrophobic soils, gullying, channel 

cutting, slope failure, and changes to the physical, chemical, and biological nature of soils in the 

project area are likely in the event of this type of fire. Suppression activities could have 

additional adverse, short- to long-term moderate to major impacts from soil compaction, mixing, 

reduced infiltration, loss of vegetation, and changes in soils that prevent quick revegetation. 

Avoiding sensitive resources could keep impacts from becoming major and adverse. 

No impairment to park soil resources is expected. 

Alternative C 

The actions associated with Alternative C could result in both beneficial and adverse effects on 

soil resources within all project area FMUs though actions. 

Analysis 

Prescribed Fire 

As in Alternative A, impacts to soil resources under Alternative C would be adverse, short-term 

and negligible to minor in intensity. Prescribed burns could be conducted in up to 2,000 acres 

per year but the increase in acreage would not translate to fourfold increase in effect to soil 

resources. Mitigation Measure S-1 assures that burn plans address erosion potential and that 

erosion control plans developed for the burn plans are reviewed by a qualified subject matter 

expert. Mitigation Measure S-2 assures that impacts on the rate of erosion on a watershed scale 

disturb no more 10 % of the watershed area unless a specific assessment is conducted to assure 

that resultant erosion would be readily correctable by standard erosion control practices. 

Under Alternative C, the annual cap of 2,000 acres per year is larger than 10% of the area of 

nearly all of the FMP watersheds with the exception of the two largest watersheds – Lagunitas 

Creek and Tomales Bay. Under Alternative C, Mitigation Measure S-2 would be incorporated 

into the preparation process for the prescribed burning annual work plan. When submitted for 

consideration, the Fire Management Officer would identify the amount of total acres proposed 

for prescribed burning in each watershed. If the total amount of project acreage exceeds 10% of 

the total watershed acreage, an interdisciplinary team as directed by Mitigation Measure S-2 

would conduct a conformance assessment. The findings of the assessment would be approved 
225 

by the Superintendent, responsible for NEPA compliance on the park level (NPS, 2000). The 

conformance assessment would be added to the administrative record for the FMP EIS. 

Table 43. Alternative C: Potential Watershed Level Effects 

Watershed (Total 

Acreage) 

Alternative C FMUs 

in each Watershed 

Alt. C FMU 

acreage within 

this Watershed

% of 

Watershed 

within this 

FMU 

Potential for Moderate or Major 

Impact on Watershed Soils 

Bolinas Drainages 

Watershed (7,902 

acres) 

Bolinas Ridge 

Highway One 

Palomarin 

259 acres 

521 acres 

1,823 acres 

3.3% 

6.6% 

23.1% 

Yes. 10% of watershed = 790 acres 

which is <* 2,000 acres (annual cap Alt. 

C) and 

Total FMU acreage in watershed = 33% 

which exceeds the 10% target. 

Mitigation S-1 is triggered. 

Drakes Bay 

Drainages 

Watershed (12,758 

acres) 

Headlands 

Limantour Road 

Palomarin 

Wilderness N 

Wilderness S 

462 acres 

820 acres 

35 acres 

327 acres 

1,439 acres 

3.6% 

6.4% 

0.3% 

2.6% 

11.3% 

Yes. 10% of watershed = 1,276 acres 

which is <* 2,000 acres (annual cap Alt. 

C) and 

Total FMU acreage in watershed = 50% 

which exceeds the 10% target. 

Mitigation S-1 is triggered. 

Drakes Estero 

Watershed (17,720 

acres) 

Estero 

Inverness Ridge 

Limantour Road 

Wilderness N 

1636 acres 

924 acres 

2543 acres 

74 acres 

9.2% 

5.2 % 

14.3% 

0.4% 

Yes. 10% of watershed = 1,772 acres 

which is <* 2,000 acres (annual cap Alt. 

C) and 

Total FMU acreage in watershed = 

29.1% which exceeds the 10% target. 

Mitigation S-1 is triggered. 

Lagunitas Creek 

Watershed (53,161 

acres) 

Bolinas Ridge 1339 acres 2.5% No. 10% of watershed = 5,316 acres 

which is >* 2,000 acres (annual cap Alt. 

C). 

Olema Creek 

Watershed (9,397 

acres)` 

Bolinas Ridge 

Highway One 

606 acres 

1347 acres 

6.4% 

14% 

Yes. 10% of watershed = 940 acres 

which is <* 2,000 acres (annual cap Alt. 

C) and 

Total FMU acreage in watershed = 

20.4% which exceeds the 10% target. 

Mitigation S-1 is triggered. 

Pacific Drainages 

Watershed (10,503 

acres) 

Headlands 

Tomales Point 

419 acres 

923 acres 

4.0% 

8.8% 

Yes. 10% of watershed = 1,050 acres 

which is <* 2,000 acres (annual cap Alt. 

C) and 

Total FMU acreage in watershed = 

12.8% which exceeds the 10% target. 

Mitigation S-1 is triggered. 

Pine Gulch Creek 

Watershed (5,064 

acres) 

Bolinas Ridge 

Highway One 

Wilderness S 

177 acres 

1,012 acres 

780 acres 

3.5% 

14% 

8.3% 

Yes. 10% of watershed = 506 acres 

which is <* 2,000 acres (annual cap Alt. 

C) and 

Total FMU acreage in watershed = 

17.8% which exceeds the 10% target. 

Mitigation S-1 is triggered. 

Tomales Bay 

Watershed (29,218 

acres) 

Inverness Ridge 

Limantour Road 

Wilderness N 

326 acres 

755 acres 

1,190 acres 

1.1% 

2.6% 

4.1% 

No. 10% of watershed = 2,922 acres 

which is >* 2,000 acres (annual cap Alt. 

C). 
226 

Wildland Fire and Suppression 

No changes in impacts to soils from average annual wildland fires and suppression compared to 

Alternative A are expected. 

Mechanical Treatments 

Alternative C permits three times the level of mechanical treatment than Alternative A. Despite 

the increase in acreage, the potential effects to soil resources are essentially the same as in 

Alternative A. The key is targeting erosion prone areas within an area to be treated for fuel 

reduction. Standard erosion control strategies would be sufficient to correct minor erosion 

problems. Areas with highly erodible soils and steep slopes would not be suitable for 

mechanical treatments. As with Alternative A, burning of piled materials is used to dispose of 

cut vegetation. Under Alternative C, roughly three times as much material would need to be 

recycled chips or firewood, burned in piles, reused as biomass fuel or lumber, or legally 

disposed. Native plant materials and certain non-natives such as broom can be chipped and 

broadcast back into the area treated and contributes to effective soil cover. 

Actions Common to All Alternatives 

Wildland Urban Interface Initiative Program 

Under Alternative C, projects within NPS managed lands could treat 2,000 acres annually with 

prescribed burning and 1,500 acres of mechanical treatment. Compared to Alternative A, 

Alternative C presents many more opportunities for in-park projects to complement those 

community projects funded by the WUI program. Projects that benefit Inverness, Inverness 

Park, Dogtown, Olema, Bolinas, and Point Reyes Station could be paired with extension projects 

within the park. Projects within the park could target not only fuel reduction but also alternative 

evacuation routes for both park visitors and area residents. Impacts to soil resources would be 

controllable by standard erosion control practices and project siting away from steep slopes and 

highly erodible soils. 

Maintenance of Fire Roads and Trails 

 

Maintenance actions for fire roads and trails would be identical to Alternative A and, as in 

Alternative A, the limited exposed of surface soils from mowing actions would negligibly affect 

the rate of erosion. Other soil characteristics would not be affected. 

Vegetation Clearing Around Buildings 

Clearing around buildings would involve identical actions to those described for Alternative A 

and would result in negligible effects to the rate of erosion. 
227 

Public Information and Education 

Fire information and education actions proposed for all alternatives would have no beneficial or 

adverse effects on soil resources in the project area. 

Fire Monitoring 

Actions associated with the fire-monitoring program are largely observational and non-invasive 

and would not affect soil resources in the project area. 

Fire Cache/Park Headquarters Relocation and Construction 

No change to the fire cache proposal occurs under Alternative C. Impacts under Alternative C 

are the same as those assessed under Alternative A. 

Cumulative Impacts 

Alternative C permits four times as much prescribed burning and three times as much 

mechanical treatment as is allowed under Alternative A. Ideally, after 5 years of 

implementation, 2,500 acres and 10,000 acres could be treated by prescribed fire in Alternative 

A and Alternative C, respectively. The caps on mechanical treatment would allow 2,500 acres 

and 7,500 acres of fuel management under Alternative A and Alternative C, respectively. 

Alternative C treats 12,500 more acres for fuel reduction over a five-year period than Alternative 

A. If fuel reduction targets critical areas important for wildland fire containment and 

suppression, Alternative C would be more effective than either Alternative A or B in lowering 

the risk of a catastrophic fire with its associated effects on soil erosion and productivity. In the 

long-term, though the potential impacts to soil resources from wildland fire and suppression 

actions would persist, the risk of a wildland fire and the overall fuel loading would be reduced in 

the project area in comparison to Alternative A. Despite this reduction in risk, the chance of a 

moderate, large, or catastrophic fire similar to the Vision Fire would remain with the potential 

for moderate to major short- to long-term adverse impacts to soil through erosion and changes in 

soil characteristics as the other alternatives. 

Conclusion 

The impacts of prescribed burning under Alternative C on the rate of erosion of park soils would 

be negligible to minor depending on the amount of effective soil cover that remains after the fire 

and the steepness of the slopes involved. Typically, prescribed fires burn cooler than wildland 

fire and leave more effective soil cover in place. Prescribed burns are not planned for either 

gentle or moderately sloped areas that are less prone to erosion. Further, prescribed burns 

incorporate erosion control techniques as part of the burn proposal. These best management 

practices are implemented and monitored once installed. 

Although impacts from erosion would be greater than those in Alternative A, they would be kept 

to no more than 10% of soils in the watershed through the use of annual burn plans and NPS 

review as described in Mitigation Measure S-2. With the exception of the two largest watersheds 
228 

in the project area - Tomales Bay and Lagunitas Creek – FMU lands constitute more than 10% of 

the total acreage in the remaining 6 watersheds. Annual plans would be subject to mitigation 

measures to assure that no more than 10% of a FMP watershed is proposed for FMP actions each 

year. 

As in Alternative A, soil productivity and chemistry would experience adverse, short-term and 

negligible to minor impacts from prescribed burning, although the acreage experiencing these 

impacts would be greater than in Alternative A. The impacts are reversible in the short-term and 

the areas affected have a scattered distribution that reflects overlying burn piles or long-burning 

fuels. In the short-term, there may be negligible to minor short-term impacts on organisms in the 

soils and nutrients in the upper few inches of the soil horizons. Beneficial effects can also result 

from the destruction or reduction of harmful pathogens and fungi that attack plants and roots. 

Impacts to soils from wildland fires and suppression in an average year in the park would be the 

same as in Alternative A. 

As in Alternative A, soil disturbance from mechanical treatment is not expected to result in more 

than negligible or minor short-term adverse impacts. 

Moderate to major short- to long-term adverse impacts to soils from a very large or catastrophic 

wildland fire are possible. Increases in erosion, formation of hydrophobic soils, gullying, channel 

cutting, slope failure, and changes to the physical, chemical, and biological nature of soils in the 

project area are likely in the event of this type of fire. Suppression activities could have 

additional adverse, short- to long-term moderate to major impacts from soil compaction, mixing, 

reduced infiltration, loss of vegetation and changes in soils that prevent quick revegetation. 

Avoiding sensitive resources could keep impacts from becoming major and adverse. 

No impairment to park soil resources is expected. 

IMPACTS TO AIR QUALITY 

The standard smoke management techniques listed below are incorporated into all proposed 

FMP alternatives. Prescribed burns, controlled wildland fire, and suppression actions would be 

conducted incorporating these best management practices to lessen the effects of smoke and 

other emissions on human health, ecological health, air quality, and visibility. 

If recommended by BAAQMD, burn plans submitted for review could be modified to provide 

reduced production of pollutants. Recommendations for reducing pollutants are described in the 

2002 US Department of Agriculture General Technical Report, Wildland Fire in Ecosystem, 

Effects of Fire on Air Quality. Recommendations include modifying burn plans reducing the 

area burned, reducing fuel loading (e.g., mowing and understory thinning away), or managing 

fuel consumption. Treatments to reduce overall air emissions would include: 

• Mowing grass and reducing density of vegetation in brushlands. 
229 

• Mechanical treatment of forested areas by removing standing or downed trees, understory 

thinning, thinning of forests, and creation of shaded firebreaks. 

• More frequent, less intense burns to prevent unwanted vegetation from becoming 

established in clearings or in forest understory. 

• Scheduling burns prior to the appearance of new growth. 

Increasing combustion efficiency or shifting the majority of combustion away from the 

smoldering phase and into the more efficient flaming phase would reduce emissions, except 

NOx, which is produced in greater quantities at higher temperatures. Methods to accomplish this 

would include pile or windrow burning, rapid mop-up, and shortened fire duration. Pile or 

windrow burning would generate more heat and burn more efficiently and be most effective in 

reducing forest fuel rather than brush type fuels. 

The park would develop a Smoke Communication Strategy to guide management of smoke 

events during prescribed fires, managed wildland fires, suppression actions, and fires occurring 

outside the park. Notification of proposed burns would be disseminated through local media and 

posting to provide adequate advance notice to persons with sensitivities to smoke that burning is 

planned. Information would be provided to visitors, employees, and residents in smoke affected 

areas regarding health issues and concerns. The park would monitor particulate levels in the 

park during large smoke events to provide data for future assessments. 

PM2.5 monitoring data would be collected at Bear Valley in the Point Reyes National Seashore. 

Data collected would be shared with local, regional, and national air quality agencies and 

databases, and can provide a basis for planning fire management or fire fighting activities. 

To reduce smoke and pollutant generation during the late summer, early fall, efforts would be 

made to burn fuel concentrations, piles, landings, and jackpots outside of the prescribed burning 

season to increase the number of units that can be burned without overloading the airshed on 

days with good dispersal conditions (NWCG, 2001). 

To avoid impacts to visibility in the Class I PRNS portion of the project areas, burning would be 

avoided on holidays or other periods when recreational visitation is typically high (NWCG, 

2001). 

To avoid public health and nuisance impacts to neighboring communities prescribed burns would 

be conducted under meteorological conditions that would avoid smoke drifting into sensitive 

residential areas and transport smoke away from populated areas. Planning for prescribed 

burning would also consider the smoldering period to avoid siting fires where downslope winds 

during the night could carry smoke into residential areas at the base of ridges (NWCG, 2001). 

Alternative A 

Under Alternative A, a maximum of 500 acres of prescribed burning and 500 acres of 

mechanical treatment could occur annually within the FMUs. 
230 

All prescribed burning at PRNS and the northern lands of GGNRA has been, and would continue 

to be planned and performed under the auspices of the BAAQMD Smoke Management Program. 

That program is incorporated in the State Implementation Plan (SIP) for the BAAQMD. The SIP 

is managed by BAAQMD staff to ensure that all ambient air quality standards and Clean Air Act 

provisions are met and public health is protected. Prior to igniting a prescribed fire, PRNS Fire 

Management staff must submit a burn plan to the BAAQMD Smoke Management Program, and 

obtain meteorological approval to burn from that program. It is the responsibility of these 

permitting agencies to coordinate the numbers of fires burning in one area. These efforts would 

ensure that annual emissions from fire management actions implemented under the PRNS FMP 

do not exceed state or federal standards. 

Analysis 

Prescribed Fire and Unplanned Ignitions 

Emissions. Smoke from unplanned ignitions and prescribed fire is a complex mixture of carbon, 

tars, liquids, and gases. The major pollutants from fire that are monitored under the Clean Air 

Act by the BAAQMD are particulates (PM10 and PM2.5), volatile organic compounds (VOC), 

and carbon monoxide (CO), and nitrogen oxides (NOx). NOx is produced in relatively small 

quantities compared to the other pollutants. 

As described in the Methodology section, air emissions associated with the amount of burning 

under Alternative A were estimated using the FOFEM model. The vegetation types used in 

modeling the emissions are based the principal vegetation communities found at actual 

prescribed burning project sites in the project area. The burn sites modeled were selected to 

equal the annual maximum allowable acreage – 500 acres - of prescribed burning under 

Alternative A. The vegetation type modeled is based on an estimate of the composition of the 

actual burn sites - roughly 58% grassland, 41% shrublands, and 1% forest. This translates into 

291 acres of grasslands, 204 acres of shrublands, and 5 acres of understory burns conducted 

forested areas as part of limited trials. Included in the model are emissions produced by 30 acres 

wildland fire occurring annually and split between the three primary vegetation types – 20 acres 

of grassland, 8 acres of shrublands, and 2 acres of forest. 

Transport and fire vehicles such as trucks, engines, and water tenders, etc. would be onsite at the 

fire to patrol and stand by on alert. For wildfires, air emissions would be generated by chainsaws 

and graders clearing fuels or providing access, transporting fire fighters, and by heavy equipment 

and engines used to fight the fire. Wildfire emissions listed may be underestimated since they do 

not include emissions from fire-fighting aircraft. 

The annual levels of emissions produced by prescribed and wildfire burning for Alternative A 

are summarized in Table 44. The emissions shown represent a conservative estimate; it was 

assumed that all acres are being burned for the first time. In the event that a prescribed fire unit 

is burned more than once in the 7-year period, the emissions from that unit would be reduced by 

approximately 33%. 
231 

Table 44. Projected Annual Fire Management Emissions Under Alternative A 

Fire Emissions (tons/yr) a

Action Type Acres PM10 PM2.5 VOC CO NOx 

Prescribed Fire b 495 acres 21.0 17.8 5.5 45.7 1.3 

Prescribed Fire Understory Burn 5 acres 2.9 2.4 1.4 28.3 0.8 

Wildfire 30 acres 6.0 5.1 2.9 59.4 1.7 

Equipment Use During 

Prescribed Burning or Wildfire 

Suppression 

N/A 0.1 0.1 0.1 1.3 0 

Mechanical Treatment 500 acres 0.1 0.1 0.1 1.2 0 

Total 1030 acres 30.1 25.9 9.8 134.8 3.8 a

 PM10 = Suspended Particulate, PM2.5 = Fine Particulate Matter, VOC = volatile organic compounds (methane), CO = Carbon 

Monoxide, NOx = Nitrogen Oxides 

b

 Includes grass and coastal scrub ecosystems and their respective emission factors for prescribed burning. 

Source: URS, 2003. 

All prescribed burns proposed by the park are approved for ignition by BAAQMD with the 

objective of maintaining Bay Area Air Basin air pollutant emissions within the national ambient 

air quality standards listed in Table 44. BAAQMD’s decision to permit ignition of prescribed 

burns is supported by the best available meteorology and forecasting at the time of ignition and 

allows the agency to coordinate the location and amount of emissions generated simultaneously 

by prescribed burning in one air basin. 

Particulates and Regional Haze. Air quality at the project site is generally good due to the 

prevailing westerly winds. The air quality of the project area can become degraded when the 

east Pacific high pressure system becomes displaced; this typically occurs in late summer and 

early fall when the major atmospheric systems undergo a seasonal change. The result can be a 

general haze in the air basin, significantly impairing visibility (Sullivan et al., 2001). 

The behavior of a smoke plume from a fire, including the direction and elevation that the smoke 

plume moves, and resulting concentrations at ground level, is highly dependent on elevation and 

dynamic meteorological conditions at the time. Generally, the higher the elevation of the burn, 

the greater the mixing volume of air to dilute it is required. Higher elevation winds also tend to 

better dilute and disperse smoke at lower concentrations. High-level winds may transport 

dispersed smoke particles large distances. Complex geography and weather patterns complicate 

the ability to exactly predict the quantity and destination of smoke particles in the plume. Fall 

and early winter generally have climatic conditions least favorable to smoke dispersion, while 

spring and summer generally have better conditions for dispersing smoke. Within the project 

area, prescribed burning is scheduled from early fall through late spring with specific 

meteorological requirements in the burn prescription for conditions with lower potential for loss 

of control of the fire and smoke dispersal. 

The level of regional haze is an important issue for PRNS, a Class I airshed. The effect of 

Alternative A on regional haze is assessed by the contribution of additional particulate matter to 

the airshed through implementation of allowable actions and relative to the size of the 
232 

management area. As shown in Table 44, all actions under Alternative A could contribute an 

additional 30.1 tons of PM10 to the airshed annually or 0.7 pounds per acre managed based on the 

FMP management area of 90,000 acres. This additional contribution would be a long-term 

adverse but negligible effect on regional haze as the additional contribution of PM10 would be 

less than 1 pound per year per acre managed.1

 

Localized Smoke Effects. Generally, smoke effects from prescribed burning last only as long as 

the duration of the fire management action. Smoke behavior varies with the amount and type of 

fuel burned. In areas such as the Douglas-fir forests on Inverness Ridge, the fuel load consists of 

decades of accumulated duff. Because it tends to smolder, duff produces relatively more 

particulates than burning vegetation. Areas of fire-dependent vegetation, such as the Bishop pine 

forest that burned in the Vision Fire, have high fuel loading due to fire-induced regrowth but the 

duff layer would have been lost in the 1995 fire. A higher percentage of fuels would therefore 

burn in the flaming phase if another fire occurred in this forest, resulting in a significantly lower 

rate of emissions and smoke generation. 

Dense smoke would likely occur in the vicinity closest to wildfire operations. Unhealthful 

concentrations of smoke would be most likely to affect fire personnel immediately adjacent to 

the fire. Most smoke plumes from fire suppression operations would disperse at middle to upper 

elevations and, occasionally, under unfavorable wind conditions, into the more heavily populated 

areas of Marin County. 

In Alternative A, prescribed burning would be conducted primarily in grass and shrub 

ecosystems. Burns to thin understory in forested areas would be roughly 5 acres per year. 

Burning would occur in the Limantour, Estero, Highway One, and Bolinas FMUs. Under 

prevailing wind conditions, smoke generation would generally be confined to the southwest of 

Highway One or the interior of the park away from the principal residential communities of 

Olema Valley, Inverness and Inverness Park, and Bolinas. Ranches and residences along 

Highway One and ranches east of Estero FMU would experience short-term, negligible or minor 

adverse smoke impacts from prescribed burning. 

Mechanical Treatment 

Emissions from mechanical treatments were calculated from two sources. The primary source is 

from equipment used to remove or control vegetation. Mechanical treatments could include 

mowing roadside vegetation, limbing up trees along roads and trails, creating or maintaining 

defensible space around structures, and creating or maintaining shaded fuel breaks. Emissions 

could be generated by the transport vehicles for staff, use of wood chippers, chain saws and weed 

whips to cut and mulch vegetation, and skidders and excavators to move cut trees. 

The second source of emissions is generated by machines used to prepare for and control 

prescribed burns. Air emissions would be generated by mowers, chain saws and weed whips 

used to reduce vegetation height and density along the fire perimeter and pre-treat the burn area. 

 

1 Based on total tons per year of PM10 emissions divided by 90,000-acre project area. 30.1 tons per year X 2000 lbs per ton/ 

90,000 acre project area = 0.7 pounds produced per acre managed. 
233 

The PM10 emissions generated by machinery, vehicles and tools contribute to the adverse, longterm negligible effect on regional haze. Particulate emission levels are shown in Table 44 and 

discussed under Particulates and Regional Haze. 

Fire Information/Education 

Actions involved with the fire education program would have neither beneficial nor adverse 

effects on air quality. 

Fire Cache/Park Headquarters Relocation and Construction 

The construction of the fire cache building at Bear Valley would have effects on local air quality 

during the construction period. Construction would generate dust during site preparation that 

could be controlled through routine watering of dry surface soils and stockpiles. The site is 

nearly level so only minor site recontouring would be required. Equipment used to construction 

the buildings would include a front loader, grader, trucks, cement mixer, portable generators, and 

hand power tools. Construction actions would be short-term lasting three months with limited 

ground disturbance. Impacts to air quality from emissions of construction-related equipment and 

grading would result in an adverse, short-term, negligible effect on air quality. 

Fire Effects and Fuel Management Research 

Actions involved with monitoring, fire effects, and fuel management research would have neither 

beneficial nor adverse effects on air quality. 

Cumulative Effects 

Ongoing effects to air quality would occur from implementing Wildland Urban Interface (WUI) 

projects, maintenance of fire roads and trails, vegetation clearing around buildings, traffic in the 

park and region, and other sources. The same types of equipment as described above under 

Mechanical Treatment could be used for clearing, roads and trails and WUI projects, and 

approximate emissions are included in Table 45 below. 

The assessment of cumulative impacts includes the occurrence of a large, high intensity, 

catastrophic fire similar to the 1995 Vision Fire, which burnt 12,500 acres – 6,000 acres of 

grasslands, 4,000 acres of shrubs, and 2,500 acres of woodlands. Inclusion of a catastrophic fire 

of the scale of the Vision Fire as part of the cumulative impact scenario is recognition that 

current fuel loading within the project area is at a high enough level to support the possibility of 

a recurrence within the lifetime of the Fire Management Plan. 
234 

Table 45. Determination of Cumulative Effect on Air Quality Alternative A 

Emissions (tons/year) a

PM10 PM2.5 VOC CO NOx 

Alt A: Emissions from FMP Actionsb 30 25.4 9.9 134.8 3.9 

Large-scale Wildfirec 6,801 5,763 3,395 72,689 2,077 

WUI Community Projectsd 0.0 0.0 1.0 3.0 0.1 

Total Cumulative Emissions @ FMP Year 1 6,831 5,789 3,406 72,826 2,081 

Total Cumulative Emissions @ FMP Year 10 6,831 5,789 3,406 72,826 2,081 

Cumulative Effect on Air Quality Alt. A, Year 1 Short-term, adverse, major effect on air quality 

% Change in Emissions @ Year 10 of Alt. A 

Compared to Year 1 of Alt. A 0% change or essentially equivalent to Year 1 

Cumulative Effect on Air Quality Alt. A, Year 10 Short-term, adverse, major effect on air quality a

 PM10 = Suspended Particulate, PM2.5 = Fine Particulate Matter, VOC = volatile organic compounds, CO = Carbon Monoxide b

 includes acres of 500 acres of prescribed burning with associated mechanical preparation, 500 acres of mechanical treatment and

30 acres of wildfire and mechanical treatment during suppression. c equivalent in scale to the 1995 Vision Fire. d Mechanical treatment only; no prescribed fire. 

Source: URS. 2003 

As shown in Table 45, the cumulative scenario of a large-scale fire occurring in conjunction with 

routine FMP actions would constitute a short-term, major, adverse effect on air quality. 

Modeling indicates the fire hazard potential in Year 10 of the FMP would remain essentially 

unchanged from that in Year 1. The number of acres treated each year under Alternative A is too 

limited to make substantial gains on overall fuel reduction within the project area. The 

cumulative effects on air quality of emissions generated at Year 1 would be essentially the same 

as in Year 10. 

Prescribed burning and mechanical thinning would be geared to controlling exotics and reducing 

fuels primarily along roadways in four FMUs rather than park-wide. Some of the areas untreated 

by Alternative A actions include the Douglas-fir forest in the Wilderness FMUs and the bishop 

pine and shrub communities adjacent to Inverness Ridge residential areas. These untreated areas 

would continue to be a source of high concern under Alternative A. The potential would 

continue to exist for large wildfires sufficient to cause significant air quality impacts regionally, 

especially in the late summer and early fall after vegetation dries and warm, dry easterly winds 

are common. Smoke impacts from large wildfires could be noticeable at considerable distances 

inland or along the coast, including in populated areas. The potential adverse, short-term major 

cumulative effect on air quality is essentially the same in Year 10 of Alternative A 

implementation as in Year 1. 

Conclusion 

Particulate emissions generated annually under Alternative A from all FMP actions and wildfires 

would have a long-term, adverse, but negligible effect on regional haze. Ranches and residences 

along Highway One and ranches east of Estero FMU could experience infrequent short-term, 

negligible to minor adverse smoke effects from prescribed burning. 

The annual acreage treatment under Alternative A would not appreciably reduce the potential 

size or severity of a catastrophic wildfire even after a decade of implementation. The cumulative 
235 

effect on air quality would be short-term, adverse and major at both Year 1 of implementation 

and at Year 10. 

The effects of the fire management program would not represent an impairment of important 

park resources including the Class I airshed status of PRNS including protection of resources 

from the effects of contaminants. 

Alternative B 

Under Alternative B, a maximum of 1,000 acres of prescribed burning and 1,000 acres of 

mechanical treatment could occur annually within the FMUs. 

Analysis 

Prescribed Fire and Unplanned Ignitions 

Emissions. FOFEM modeling for Alternative B is based on a mock annual work plan of actual 

prescribed fire project sites comprised of 491 acres of grasslands, 358 acres of shrubs, and 153 of 

forested understory. The work plan sites are both in PRNS and northern GGGNRA lands with a 

total acreage equivalent to the maximum annual allowable 1,000 acres. As with Alternative A, 

representative annual occurrence of unplanned ignitions is 30 acres per year of high intensity 

wildfire occurring in 20 acres of grassland, 8 acres of shrublands, and 2 acres of forest. 

Prescribed burning activity under Alternative B would expand the annual acreage in grass and 

brush ecosystems compared to Alternative A and include more than 150 acres of understory 

clearing and pile burning in the forested areas. In addition to the FMUs that would be treated 

under Alternative A, Alternative B includes the two Wilderness FMUs supporting forested areas 

that have not burned in at least a century. On a per acre basis, the forested areas in Alternative B 

produces much higher emission rates on a per acre basis than the grassland/scrublands that 

comprise nearly all of the acreage treated in Alternative A. The greater level of emissions 

generated by Alternative B would allow the reduction of fuels at a faster rate than allowed under 

Alternative A. The goal of the fuel reduction is to reduce the overall potential severity, rate of 

spread and air pollution emissions that could occur with a large-scale forest fire in the park. 

Table 46. Projected Annual Fire Management Emissions under Alternative B 

Fire Emissions (tons/yr) a

Fire Type Acres PM10 PM2.5 VOC CO NOx 

Alt B: Prescribed Fires b 849 acres 36.8 31.1 9.7 80.0 2.3 

Alt B: Prescribed Burns in Forested 

Understoryc 153 acres 87.4 74.1 41.8 866.5 24.8 

Wildfire 30 acres 6.0 5.1 2.9 59.4 1.7 

Equipment Use During Prescribed 

Burning and Wildfire Suppression N/A 0.2 0.2 1.5 6.3 0.2 

Alt. B: Mechanical Treatment c 1,000 acres 0.1 0.1 0.2 2.4 0.1 

Totals for Alternative B 2,032 acres 130.5 110.6 56 1,012.6 29 
236 

a

 PM10 = Suspended Particulate, PM2.5 = Fine Particulate Matter, VOC = volatile organic compounds (methane), CO = Carbon 

Monoxide, NOx = Nitrogen Oxides 

b

 Includes grass and coastal scrub ecosystems and their respective emission factors for prescribed burning. 

c. Includes 1,000 acres of mechanical treatment annually in addition to emissions generated from equipment use during 

suppression actions and in preparation and execution of prescribed burning. 

Source: URS, 2003. 

Particulates and Regional Haze. Alternative B would produce nearly 3 times more particulates 

than Alternative A. PM10 could be generated at an annual rate of 2.86 pounds per acre managed.2

 

This constitutes a long-term, adverse, minor effect on regional haze. A minor effect occurs with 

particulate generation between 1 and 5 pounds per acre managed per year. The effect is 

considered long-term as FMP actions would continue to contribute particulates on an annual 

basis until a level of ecological stability is reached when fuels on half of the FMU acreage is 

effectively reduced. This would occur at approximately 23 years into FMP implementation. At 

that point, annual levels of FMP actions could be reduced with associated reductions in 

particulate generation. During the life of the FMP, roughly 10 to 20 years, the particulate rate 

would continue to be generated at approximately 2.86 pounds per managed acre per year and 

constitute a long-term, minor adverse effect on regional haze that should be considered in 

calculations for long-range, air basin-wide planning goals. 

Localized Smoke Effects. Impacts of prescribed fire activity in the surrounding communities 

would be similar to those described under Alternative A, but with greater frequency. Smoke 

dispersal from prescribed fires could affect the residents of Inverness, Inverness Park, and 

possibly the ranches in the north of PRNS as well as ranches along Highway 1 as in Alternative 

A. The same may be true for residents on the mesa area north of Bolinas. The requirements of 

burn prescriptions call for conditions that maximize smoke dispersal to the extent allowable 

without compromising control of the prescribed burn. As a precaution, prescribed burn 

perimeters would be generously buffered from any developed areas as a precaution. However, 

prevailing winds could result in smoke being blown towards the communities in the vicinity of 

the project area. In cases such as this, residents and the community at-large would be notified in 

advance of prescribed burning. Potential effects of nuisance smoke in the general locality of the 

prescribed burn would constitute a short-term, adverse, negligible to moderate impact from 

nuisance smoke. 

Mechanical Treatment 

Emissions produced by the mechanical treatment of 1,000 acres were modeled using standard 

generation factors for typical equipment used in these projects. Hours of use per acre are based 

on the experience of the PRNS Fire Management Officer. Projects included a mix of mowing, 

understory treatment, shrub density reduction, creation of shaded fuel breaks and roadside 

clearance treatment. Also modeled was equipment use in support of preparation and control of 

prescribed burns and the emissions generated by equipment and vehicle use in suppressing 

wildfire. As shown in Table 46, emissions from mechanical treatment are a negligible 

component of overall emissions generated annually under Alternative B but still contribute to the 

 

2 Based on total tons per year of PM10 emissions divided by 90,000-acre project area. 129.6 tons per year x 2000 lbs per ton/ 

90,000 acre project area = 2.88 pounds produced per acre managed.
237 

long-term, adverse, minor effect on regional haze, which is assessed on an annual basis as one 

emission level. 

 

Fire Information/Education 

Actions involved with the fire education program would have neither beneficial nor adverse 

effects on air quality. 

Fire Cache/Park Headquarters Relocation and Construction 

Effects of the construction of the fire cache building at Bear Valley are equivalent to those noted 

for Alternative A. Dust and emissions generated by heavy equipment during construction of the 

fire cache would be an adverse, short-term, negligible effect on air quality. 

Fire Effects and Fuel Management Research 

Actions involved with monitoring, fire effects, and fuel management research would have neither 

beneficial nor adverse effects on air quality. 

Cumulative Effect 

Several assumptions needed to be made in order to analyze the cumulative effects of annual fire 

management actions and a large-scale, catastrophic wildfire. The maximum allowable acreage 

of annual treatment under Alternative B would double the amount of fuel reduction achieved 

each year compared to Alternative A, the No Action Alternative. This doubling of annual 

treatment produces a progressive reduction in the size and severity of the large-scale fire until 

eventually the project area is returned to a more balanced return fire interval approximately 23 

years into project implementation when half of the FMU acreage would have been treated and 

maintained. An important assumption is that the 2,000 acres treated annually under Alternative 

B would results in a corresponding reduction in the scale and severity of the large-scale wildfire 

that comprises the cumulative scenario. 

If a large fire occurred within a few years of implementation of Alternative B, its scale is more 

likely to be similar to that generated under Alternative A. Three years into implementation, 

Alternative B would have begun to yield a noticeable reduction in fuel loading throughout the 

project site. The scale and intensity of a large-scale wildfire could reasonably be assumed to be 

proportionally downsized so that three years into implementation, the potential air emissions 

generated by a large-scale fire would be reduced roughly 17% compared to the emission 

potential in Year 1. By the Year 10 of implementation, sufficient fuel reduction actions would 

have occurred to reduce potential emissions 55% compared to Alternative A representing a 

short-term, major, beneficial cumulative effect on air quality. 

By Year 23 (and beyond the planning horizon of this FMP), a more natural fire regime over a 

wide portion of the park would be accomplished by consistently expanding the treated acreage 

and reducing the size and severity of a large-scale wildland fire. A catastrophic fire at Year 23 
238 

would affect 2,500 acres rather than 12,500 acres (equivalent to the Vision Fire) and would 

produce 84% less emissions than the Vision Fire equivalent. . 

Cumulative effects are assessed at both FMP inception (Year 1) and Year 10 of implementation, 

nearly halfway towards the goal of more natural fire regime. By year 10, FMP actions would 

have been effective in reducing the scale of a potential catastrophic fire by 50% to 6,250 acres. 

Table 47. Determination of Cumulative Effect on Air Quality Alternative B 

Emissions (tons/year) a

# PM10 PM2.5 VOC CO NOx 

1 Alt B: Emissions from FMP 

Actionsb 130.5 110.6 56 1,012.6 29 

2 Emissions of Large-scale Wildfire, 

Year 1c 6,801 5,763 3,395 72,689 2,077 

3 WUI Community Projectsd 0.0 0.0 1.0 3.0 0.1 

4 Total Cumulative Emissions @ 

FMP Year 1 (1+2+3) 6,931.5 5,873.6 3,452 73,704.6 2,101.1 

5 Emissions of Large-scale Wildfire, 

Year 10e 3,050 2,585 1,517 32,405 926 

6 Total Cumulative Emissions @ 

FMP Year 10 (1+3+5) 3,180.5 2,695.6 1,574 33,420.6 955.1 

7 % Change in Emissions @ Year 10 

Compared to Year 1 (6÷4)-1.0 54.1% reduction in potential emissions 

8 Cumulative Effect on Air Quality 

of Alt. B, Year 10 Compared to 

Alt. A Year 10 

Short-term, major, beneficial, cumulative effect on air quality 

a

 PM10 = Suspended Particulate, PM2.5 = Fine Particulate Matter, VOC = volatile organic compounds, CO = Carbon Monoxide b

 includes acres of 1,000 acres of prescribed burning with associated mechanical preparation, 1,000 acres of mechanical treatment, 

30 acres of wildfire. 

c equivalent in scale to the 1995 Vision Fire. d Mechanical treatment only; no prescribed fire. 

e 10 years of FMP actions have effectively reduced the potential size of the large-scale wildfire by 50% to 6,250 acres. 

Source: URS. 2003 

At Year 1 of FMP implementation, the potential scale of a catastrophic wildfire is the same for 

all alternatives. Alternative B doubles the number of acres treated annually to reduce fuel 

loading compared to the No Action Alternative. Unlike treatments under Alternative A, the 

annual cap on acreage treatment in Alternative B is sufficient to begin effectively reducing the 

potential risk of a large-scale fire in the project area. Each year, as a larger area of the FMUs are 

treated and maintained, the potential severity and extent of a catastrophic wildfire is 

correspondingly reduced. This would also reduce the level of emissions produced each year as 

the FMP is implemented. At Year 10 of Alternative B, the size of a potential large-scale fire 

would be half that under Alternative A. This 6,250-acre fire would present a short-term, major 

adverse effect on air quality in and of itself. However, relative to the potential emissions that 

would be generated under the No Action Alternative, Year 10 of Alternative B would be a 

relative short-term, major, beneficial effect on air quality by producing nearly 46% less 

emissions than under Alternative A. 
239 

Conclusion 

On an annual basis, Alternative B would generate higher levels of particulate emissions than the 

No Action Alternative; twice as many acres would be subject to FMP actions each year. 

Alternative B would produce 2.86 pounds of PM10 per acre managed a long-term, adverse, minor 

effect on regional haze. This additional contribution would be offset by the long-term 

opportunity presented by Alternative B to achieve a major, beneficial reduction in the emissions 

that could result from a catastrophic fire as compared to the cumulative effect under Alternative 

A. Nuisance smoke would be an infrequent, short-term, adverse, negligible to moderate air 

quality impact for residents near prescribed burns during the duration of the burn. 

The effects of the fire management program would not represent an impairment of important 

park resources including the Class I airshed status of PRNS including protection of resources 

from the effects of contaminants. 

Alternative C 

Under Alternative C, a maximum of 2,000 acres of prescribed burning and 1,500 acres of 

mechanical treatment could occur annually within the FMUs. 

Analysis 

 

Prescribed Fire and Unplanned Ignitions 

Emissions. Modeling of emissions under Alternative C is based on a representative work plan 

comprised of actual project area burn sites totaling 2,000 acres. The project sites include 968 

acres of grasslands, 756 acres of shrublands, and 276 acres of understory forest burns annually. 

Understory burning produces very high emissions compared to prescribed burns in grass or 

coastal scrub. The No Action Alternative included only 5 acres of understory prescription 

burning compared to the 276 acres modeled for Alternative C. So even if the annual acreage 

permitted for prescribed burning is only four times greater under Alternative C compared to the 

No Action Alternative, the levels of emissions produced are many times greater than the 

difference in the acreage amounts alone. For example, understory burning of 5 acres under 

Alternative A would generate 2.9 tons per year of PM10 while understory burning of 276 acres 

per year in Alternative C would produce 157.7 tons per year of PM10. So there is no direct 

correlation between the amounts of emissions produced and increasing the allowable acres 

fourfold. The increase in emissions is more dependent on the type of fuels treated than the 

amount of acreage included. 

Table 48. Projected Annual Fire Management Emissions under Alternative C 

Fire Emissions (tons/yr) a

Fire Type Acres PM10 PM2.5 VOC CO NOx 

Alt C: Prescribed Fires b 1,724 acres 77.1 65.2 20.0 163.8 4.7 

Alt C: Prescribed Burns in Forested 

Understoryc 276 acres 157.7 133.7 75.3 1,563.1 44.7 

Wildfire 30 acres 6.0 5.1 2.9 59.4 1.7 
240 

Equipment Use During Prescribed 

Burning and Wildfire Suppression N/A 0.3 0.3 2.8 11.8 0.3 

Alt. C: Mechanical Treatment c 1,500 acre 0.2 0.2 0.3 3.6 0.1 

Totals for Alternative C 3,530 acres 241.3 205 101.3 1,801.7 51.5 

a

 PM10 = Suspended Particulate, PM2.5 = Fine Particulate Matter, VOC = volatile organic compounds (methane), CO = Carbon 

Monoxide, NOx = Nitrogen Oxides 

b

 Includes grass and coastal scrub ecosystems and their respective emission factors for prescribed burning. 

c. Includes 1,000 acres of mechanical treatment annually in addition to emissions generated from equipment use during 

suppression actions and in preparation and execution of prescribed burning. 

Source: URS, 2003. 

Particulates and Regional Haze. All actions under Alternative C would generate 5.3 pounds per 

acre managed of PM10. The contribution to regional haze would be considered long-term, as the 

contribution would be an addition to current ambient emissions over the implementation period 

of Alternative C. However, Alternative C has the shortest predicted implementation period of 

the FMP alternatives. Because the amount of acreage treated is the highest in Alternative C and 

the greatest number of forested acres are treated, a more stable fire condition – i.e., successful 

FMP implementation - is achieved in the shortest time period. The more stable fire condition is 

considered attained when half of the FMU acres have been treated and are being maintained at 

low fuel levels. Allowable annual actions under the No Action Alternative A are so limited both 

in acreage and FMUs treated that little or no progress is made towards the effective reduction of 

fuel loading in the project area. Alternative B achieves the lower hazard stable fire condition at 

Year 23 of implementation. Alternative C would greatly accelerate the process, achieving stable 

fire ecology at Year 13. 

As a result of a shorter implementation period, the long-term contribution of additional PM10 to 

regional haze from implementation of Alternative C would be relatively short compared to 

Alternative A, which has no predictable length until goals are met. Over the 13-year period of 

implementation, PM10 emissions from Alternative C would be a long-term, adverse, moderate 

effect on regional haze. The 5.3 pounds per acre managed meets the criterion for moderate 

effect, i.e., greater than 5 pounds and less than 10 pounds annually per acre managed. 

Localized Smoke Effects. Impacts of nuisance smoke due to prescribed fire in the surrounding 

communities would be similar to those described under Alternative A, though occurring with 

more frequency and, in the case of understory burns, more intensity. Nuisance smoke could be 

noticeable during the period of active burning to residents in Inverness, Inverness Park, the 

northern ranches, and residents of homes and ranches along Highway 1, and in Bolinas. If burns 

are conducted adjacent to one or more residences, it may be necessary to advise these residents 

to remain indoors during the course of the burn, perhaps for one day. Residents within fifteen 

miles of the park might occasionally notice a brief impact from prescribed burning activities, 

possibly in slightly increased haze or light smoke impacts. Visitors to the park would also 

encounter haze or smoke more frequently during late fall through early spring when burns are 

conducted. Beyond that range, prescribed burning impacts are unlikely to be noticeable with any 

frequency. Alternative C could have a short-term, adverse, minor to moderate effect on park 

visitors and area residents. 
241 

Mechanical Treatment 

The annual emissions generated under Alternative C for mechanical treatment of 1,500 acres are 

shown in Table 48. Also shown are the emissions produced by equipment and vehicles used 

preparing for and controlled prescribed burns and during the suppression of wildfires. 

Emissions generated by mechanical treatment are a short-term, negligible adverse effect on 

regional haze when viewed in isolation. As contribution to regional haze is assessed by pounds 

per acre managed on an annual basis, these emissions are considered part of the full contribution 

of all actions under Alternative C to regional haze. These emissions would have a moderate, 

adverse, long-term effect on regional haze of which emissions from mechanical treatment are a 

negligible component. 

Fire Information/Education 

Actions involved with the fire education program would have neither beneficial nor adverse 

effects on air quality. 

Fire Cache/Park Headquarters Relocation and Construction 

The construction of the fire cache building at Bear Valley would have short-term, minor adverse 

effects on local air quality during the construction period as in Alternative A. 

Fire Effects and Fuel Management Research 

Actions involved with monitoring, fire effects, and fuel management research would have neither 

beneficial nor adverse effects on air quality. 

Cumulative Effects 

Past, present, and reasonably foreseeable projects that might have a cumulative impact under 

Alternative C would be the same as those for Alternative A for the first year of FMP 

implementation. As each year’s fire management actions are completed, it is assumed that a 

corresponding reduction in the scale and intensity of a potential large-scale wildland fire is 

achieved. Because Alternative C treats the highest number of acres per year, the highest amount 

of forested acres, and includes all FMUs within the project area, this alternative would achieve 

more significant in-roads in reducing fuel loading in the shortest time period. A more stable fire 

ecology and less hazardous condition would be achieved by Year 13 of FMP implementation 

under Alternative C. 

To compare the estimated emission potential under Alternative C, the level of effect on air 

quality achieved in Year 1 and Year 10 is compared to the cumulative effect of Alternative A 

and are presented in Table 49. At Year 10, 35,000 acres would have been either treated or 

retreated for maintenance under Alternative C. The corresponding reduction in the potential size 

of a large-scale wildland fire would be roughly 3,000 acres. This size fire event would produce 

approximately 80% less emissions than the Vision Fire-scale event possible under Alternative A 

or Year 1 of implementation of Alternative C. A 3000-acre wildfire, though much smaller than 
242 

the Vision Fire-scale event, would still produce a short-term, adverse and major effect on air 

quality and regional haze. However, relative to the 12,500-acre fire possible under Alternative 

A, Alternative C represents a short-term, major beneficial cumulative effect on air quality and 

regional haze. 

Table 49. Determination of Cumulative Effect on Air Quality Alternative C 

Emissions (tons/year) a

# PM10 PM2.5 VOC CO NOx 

1 Alt C: Emissions from FMP 

Actionsb 241.3 205 101.3 1,801.7 51.5 

2 Emissions of Large-scale Wildfire, 

Year 1c 6,801 5,763 3,395 72,689 2,077 

3 WUI Community Projectsd 0.0 0.0 1.0 3.0 0.1 

4 Total Cumulative Emissions @ 

FMP Year 1 (1+2+3) 7,042.3 5,968.5 3,497.3 74,493.7 2,128.6 

5 Emissions of Large-scale Wildfire, 

Year 10e 1,359 1,152 674 14,372 385 

6 Total Cumulative Emissions @ 

FMP Year 10 (1+3+5) 1,600.3 1,357 776.3 16,176.7 436.6 

7 % Change in Emissions @ Year 10 

Compared to Year 1 (6÷4)-1.0 77.3% reduction in potential emissions 

8 Cumulative Effect on Air Quality 

of Alt. C, Year 10 Compared to 

Alt. A Year 10 

Short-term, major, beneficial, cumulative effect on air quality 

a

 PM10 = Suspended Particulate, PM2.5 = Fine Particulate Matter, VOC = volatile organic compounds, CO = Carbon Monoxide b

 includes acres of 1,000 acres of prescribed burning with associated mechanical preparation, 1,000 acres of mechanical 

treatment, 30 acres of wildfire. 

c equivalent in scale to the 1995 Vision Fire. d Mechanical treatment only; no prescribed fire. 

e 10 years of FMP actions have effectively reduced the potential size of the large-scale wildfire by 50% to 6,250 acres. 

Source: URS. 2003 

Conclusion 

On an annual basis, Alternative C would generate the highest levels of particulate emissions 

compared to the No Action Alternative and Alternative B. This is a result of the greater number 

of acres treated each year and the larger number of forested acres, which produce the highest 

emission levels. Alternative C would produce 5.3 pounds of PM10 per acre managed a long-term, 

adverse, moderate effect on regional haze. Contributions of PM10 to regional haze would be a 

long-term, adverse, moderate effect for 13 years rather than the indeterminate period under 

Alternative A. 

This additional contribution would be offset by the long-term opportunity presented by 

Alternative C to achieve a short-term, major, beneficial, cumulative effect on regional haze 

relative to the emissions produced under the cumulative scenario in Alternative A. 

Nuisance smoke would be an infrequent, short-term, adverse, negligible to moderate air quality 

impact for residents near prescribed burns during the duration of the burn. 
243 

The effects of the fire management program would not represent an impairment of important 

park resources including the Class I airshed status of PRNS including protection of resources 

from the effects of contaminants. 

IMPACTS TO WATER RESOURCES AND WATER QUALITY 

Alternative A 

Under this alternative, 500 acres of prescribed burning and approximately 500 acres of 

mechanical treatment would occur over an average year. The actions associated with Alternative 

A could affect water resources and water quality within the Estero, Limantour Road, Highway 

One, and Bolinas Ridge (mechanical treatment only) FMUs. 

Analysis 

Prescribed Fire 

Prescribed fire could have impacts on water resources and water quality during site preparation 

(e.g., fire line construction) or as a direct result on the fire itself. As noted in the Affected 

Environment discussion, water quality can be affected by increases in total suspended solids 

(TSS) or increases in nutrients results from a fire. The features of a watershed, including soil 

conditions, overland flow, and other hydrologic variables could also be affected. 

Fire changes vegetation, forest floor cover (e.g., ground vegetation, litter, or duff), structure, and 

soil properties, all of which can alter the movement of water over, or into, the soil. In the first 

years following a fire, watershed storage capacity is reduced and net surface runoff is increased 

as a result of reduced soil cover, lack of soil cover, and/or increased soil hydrophobicity (water 

repellency). These changes can result in channel extension, upland erosion, and stream channel 

incision. These changes to hillslope process result in increased discharges, soil erosion, and 

higher sediment yield, affecting aquatic habitat conditions within the watershed. 

The heating of soils from prescribed or wildland fires can lead to development of a water 

repellent layer at or below the surface of the soil, a condition called hydrophobicity. This layer 

reduces the infiltration capacity of the soil and increases the potential for overland flow. The 

higher the fire intensity/severity, the deeper in the soil this layer will form. A water repellent 

layer below the soil surface is likely to cause more soil erosion than such a layer at the surface, 

as the soils that lie above the water repellent layer can be moved as a debris flow. Fire 

associated hydrophobic conditions decay over time as the integrity of the hydrophobic layer is 

reduced. In the case of the Vision Fire on Inverness Ridge, the hydrophobic layer was patchy by 

the end on the second winter after the fire (Collins and Ketcham, 2001). Water repellency is 

more common in coarse-textured soils, such as those derived from granite parent material. 

Hillslope process in burn areas with high fire intensities is most acutely affected by hydrophobic 

soil conditions. 

Fire can reduce the capacity of slopes to attenuate rainfall through loss of vegetation and soil 

cover, and through reduction in soil permeability. After fire, overland flow and rills often 
244 

develop in areas where surface flow did not previously occur. Observations in the granitic soils 

of Inverness Ridge following the Mt. Vision Fire showed the effects of the fire to include 

channel network extension through rilling. Hydrologic storage capacity (ratio of runoff to 

precipitation) is further decreased through delivery of water through flow tubes consisting of 

abandoned animal burrows or rotted out root paths (Collins and Ketcham, 2001). In addition, the 

Vision Fire area after the first rains displaced most of the ash; the exposed soil quickly developed 

a crust of tine particles that essentially sealed the surface from infiltration. This was observed by 

Onda et al. (1996) who determined that during the initial storm of the season after the fire, the 

runoff ratio was 10 times higher than normal and 50% of the runoff was caused by the surface 

crust, not the hydrophobicity. Collins and Ketcham (2001) also found in the lower Muddy 

Hollow watershed after the Vision Fire minimum sediment increases of 2,626 tons/sq/mi/yr 

occurred. Sediment supply to lower Muddy Hollow Creek in the second year was 2.7 times 

higher to the lower watershed during second year after the fire than the first year. This is likely 

due to the lag time of sediment transport through a watershed. 

Under prescribed fire, fuel moisture, weather conditions, time of day, spatial pattern of ignition, 

and other factors are effective means of controlling the fire. Given these controlling factors, 

prescribed fire would not generally result in high severity fire that would alter watershed 

conditions. Burn blocks would be limited in size (less than 200 acres). Burns would not be 

continuous up the vertical gradient of the watershed (meaning from the bottom/riparian area 

through mid-slope, and into or through the slope of the ridge. 

Under prescribed fire parameters, fire in the duff layers would spread under variable conditions, 

but not with enough severity to cause extensive areas of hydrophobic soil. 

In addition, prescribed fire in the duff layers would spread across the watershed under variable 

conditions so that burn severity would range locally from light to severe. Patches of extremely 

hydrophobic soils would be created in areas of high fuel loading where soils would be exposed to 

heating for a longer time and at a higher temperature than where fires burned in lighter fuels. 

However, these hydrophobic areas would be patchy in burned areas and not extensive because of 

the controlled burning conditions that are required to conduct prescribed fire. For example, 

weather, fuel moisture, and wind speed must be within certain limited parameters. 

The effects would not typically be on a watershed scale because prescribed fires are less than 200 

acres and the program would not treat more than 10% of the watershed in any one year. In 

addition, prescribed burning would be only in part of the watershed, either upper, lower, or 

middle sections, with limited intrusions into riparian areas. Increases in water yield and peak 

flows would occur on a watershed scale but would be within the natural range of variability. 

Because of the temperate climate in Point Reyes, vegetation growth is rapid and increases in 

sediment and nutrient yield fluctuations would be short-term (Wong, 2003). As a result, there 

would be only negligible erosion of primary and secondary stream channels as a result of 

increased runoff, and the recovery of riparian systems would occur quickly, in one to two years. 

Therefore, short-term and negligible to minor water quality impacts would result from increased 

surface runoff and soil erosion on a watershed scale. 
245 

Periodic prescribed fire would help keep plant communities within their natural range of 

variability. Fire frequency was about every 8-14 years before European settlement. Where fire 

return intervals are out of cycle, fuel accumulations can be well outside their natural range of 

variability, and when catastrophic fire occurs the impacts to water quality are severe (Ketcham, 

2003). 

Prescribed fire would be used as a means to reduce the severity and intensity of large-scale 

catastrophic fire that directly causes negative impacts to water quality such as increasing 

sediment loads. In addition prescribed fire would also limit the potential for catastrophic fire that 

could burn along the entire vertical gradient in the watershed and creating extensive hydrophobic 

soils resulting in increased sediment loads to watersheds (Ketcham, 2003). Because of the 

above, prescribed fire in the long-term would have beneficial effects on watersheds by reducing 

the severe impacts of a catastrophic fire that could extensively burn an entire watershed. 

To sum, the effects of prescribed fire on watershed conditions would be beneficial, long-term, 

and moderate because of the restoration of natural hydrologic process. Effects on water quality 

would be adverse, minor and short-term from prescribed fire due to some limited degradation of 

water quality from soil disturbance, removal of the duff layer, and altered flow patterns. 

Mechanical Treatments 

Under this option, 500 acres would be treated by mechanical means, including hand cutting and 

mowing. Because of the labor-intensive nature of hand cutting, no more than about 100 acres 

could be treated by this means each year. Hand cutting activities would lead to soil compaction 

on a localized scale and would likely have a negligible effect on duff and topsoil layers, resulting 

in negligible direct impacts on watershed characteristics, including water yield, peak flows, 

sediment yield, nutrient yield, and stream system response. Thus, the effects of hand cutting 

would be adverse and short-term, but only negligible in intensity to water quality. 

Hand cutting projects would be limited in size, with boundaries typically associated with only 

one portion of the slope (top, mid-slope, or bottom). Water yield and peak flows would increase 

only slightly, and within a small range of variability, thus sediment and nutrient yield would only 

see short-term fluctuations. As a result, there would be negligible channel response, with shortterm effects, if any, in riparian systems. 

Piles of cut wood debris would be burned. Pile burning could create small patches of 

hydrophobic soils, which, depending on conditions, could experience light to severe changes. 

Biological and physical characteristics of these patches would be expected to change. However, 

because of the small areas, the biological function of these areas would return very quickly, and 

the effect on a watershed scale would not be noticeable. The impact of pile burning on water 

quality would be adverse, short-term, and minor. 

Mowing would be used in this alternative to treat the majority of acres. Mowing would be used 

where air quality, visitor use, or other management concerns prohibit burning or where mowing 

is the preferred option, such as where maintaining a cultural landscape. Mowing would lead to 

soil compaction on a localized scale, but would likely have a negligible effect on duff and topsoil 
246 

layers, resulting in negligible direct impacts on watershed characteristics, including water yield, 

peak flows, sediment yield, nutrient yield, and stream system response. Water quality impacts 

from mowing overall would be adverse, short-term, and negligible. 

Overall, the watershed effects within these areas would be beneficial, long-term, and minor to 

moderate by reducing fuel loads and reestablishing the natural hydrological cycle as described 

under prescribed fire above. Where fire return intervals are out of cycle, fuel accumulations can 

be well outside their natural range of variability and when a watershed level wild fire occurs the 

impacts to water quality are severe (Ketcham, 2003). 

Mitigation Measures 

W-1. Individual burn plans would be written with enough detail to determine the extent of 

erosion within the burn area due to a) the prescribed burn and/or, b) mechanical treatments. 

Subject matter experts would determine if the erosion control plan submitted is sufficient to 

prevent long-term moderate or major impacts to the water resources and water quality. 

Strategies to minimize erosion and sediment transport to water resources associated with 

prescribed burning include avoiding oversteep slopes, timing burns to minimize erosion 

potential, or using erosion control devices after burns. Strategies to minimize erosion and 

sediment transport to water resources associated with mechanical treatment include avoiding 

oversteep slopes, avoiding scraping or clearing to bare mineral soil (leave duff layer), or 

installing erosion control devices as part of mechanical treatment (if necessary). 

W-2. Watershed level planning would be used to assure that prescribed burning and/or 

mechanical treatment within any one watershed would conform to the conclusions of the 

environmental effect reached in this EIS (e.g., the impacts would be no more than moderate in 

intensity). Watershed level planning would be triggered when proposed actions have the 

potential to exceed 10% of the total area of one or more FMP watersheds in one year. This 

mitigation measure assures that planning considers the watershed scale and, if a potential effect 

is identified that a specific assessment be conducted for the burn plan to assure the conformance 

of the watershed level effects within this EIS. 

The above two mitigation measures would ensure minimal impacts to water quality or aquatic 

wildlife. Alternative A would result in the prescribed burning of 500 acres or less, which, as 

Table 41 shows, is smaller than 10% of the acreage any of the watersheds proposed for 

treatment. Even if the annual plan for prescribed burning proposed work takes place in a single 

watershed, it would not be possible to exceed 10% of the acreage. Therefore, the effect of 

prescribed burning on 10% or less of the vegetation cover would normally be a negligible or 

minor short-term adverse effect. As noted above, if park review indicated that potential erosion 

would be greater than this even with the use of mitigation described above, additional 

environmental analysis would occur. 

W-3. Helispots, staging areas and spike camps will be located at least 100 feet away from 

streams, creeks, and other water bodies. 
247 

W-4. All fireline (both handline and dozer line) would be rehabilitated as quickly as possible, 

which would include application of Burned Area Emergency Rehabilitation (BAER) techniques 

such as recontouring, soil stabilization as needed, and monitoring for erosion and treatment as 

necessary in the first winter following disturbance. 

W-5. When developing prescribed burn boundaries, non-treatment buffer areas would be 

established around perennial, intermittent, and ephemeral channels associated with Lagunitas 

Creek, Olema Creek, Pine Gulch Creek, and other coastal drainages originating from Inverness 

Ridge. Some treatment within buffer areas, including hand removal of non-native species and 

“cool” burns of non-native grasses, may occur within these areas. Fire lines around these areas 

would be mowed - not graded or scraped - in order to leave a 100-foot vegetated buffer strip 

from burn areas. 

Unplanned Ignitions, Wildfire, and Suppression 

Annually, the park has approximately three unplanned ignitions resulting in 30 acres of 

vegetation impacted. Suppression activities in these areas would have potential to alter flow 

patterns and increase soil erosion because vegetation and organic litter would be removed to stop 

or hold a fire. 

Erosion would be greatest along stretches of fire line that run down slope. Soil compaction and 

disturbance would occur with activities during both hand line preparation (a hand line is usually 

several feet wide where vegetation is removed to bare soil to stop a fire) and mop-up (clean-up 

after a fire is suppressed). Water bars and check dams would continue to be used as mitigation, 

to dissipate runoff and reduce erosion. Downed snags would create locally heavy areas of fuels 

that would, on a very small-scale, affect the temperature and residence time of a fire. 

Holding Action and Monitoring Effects (water and retardant drops, helispots, and spike 

camps). 

Helispots would be located at least 100 feet away from any stream or waterbody and typically on 

or near a topographic high. Because of the relatively small surface area and location, helispots 

would typically have little effect upon water quality or other watershed attributes. Spike camps 

for monitoring and holding crews would be located in similar areas as helispots. They have the 

potential to be larger, especially as crew-size increases, but even so, effects would be generally 

localized. Both helispots and spike camps would contribute to areas of increased compaction 

and disturbance in the soils if needed. Water quality effects of these actions would be adverse, 

short-term, and minor. 

Retardant and suppressant compounds would not typically move into ground water or into 

surface water from runoff as they would be used carefully around surface waters because of 

potential effects upon aquatic organisms. Most fire retardants contain fertilizer type compounds, 

including ammonia and nitrogen. Although the half-life of these compounds in soil is short, they 

can cause changes in pristine terrestrial and aquatic ecosystems, especially to bodies of water 

that are otherwise low in nitrate/ammonia type nutrients like those in the study area. 

Additionally, ammonia itself can be quite toxic in aquatic habitats. Some retardants also contain 

preservatives that release cyanide that can be fatal to aquatic life. To minimize impact, pilots and 
248 

engine crews would be directed to avoid dropping retardants within 300 feet of wetlands, 

streams, and lakes. This buffer zone would eliminate any potential direct discharge to these 

water resources because soil would quickly absorb the retardant and vegetation would also 

impede flow to any water resource. The use of such a wide buffer zone would prevent moderate 

or major adverse effects from the use of retardants and suppressants, and would keep impacts to 

water quality and watersheds to short-term negligible or minor adverse effects. 

Fire Information/Education 

This would have no beneficial or adverse effects on water resources, the hydrology of the area, 

or water quality. 

Fire Cache/Park Headquarters Relocation, and Construction 

The proposed structure would cover approximately 3000 square feet of ground surface. 

Additional concrete aprons and paved surfaces would be approximately 1000 square feet. 

Vehicle parking would be gravel. Vehicle washing would occur within curbed paved area and 

runoff and accidental spills would be captured and wastewater suctioned into a holding tank. 

The 4,000 square feet of soil affected are located in the most developed area of the park. The 

ground surface is nearly level and loss of soils during construction could be minimized through

the application of standard erosion control practices such as erosion control fabric placed to 

prevent soil movement. Orange habitat fencing set back from the building envelope and 

delineating the extent of the working area would prevent unwarranted soil compaction and 

surface disturbance by heavy equipment. Overall, the construction of a fire cache at Bear Valley 

would not have a beneficial or negative impact on water quality and water resources. 

Fire Effects and Fuel Management Research 

This would have no beneficial or adverse effects on water resources, the hydrology of the area, 

or water quality. 

Cumulative Impacts 

Cumulative impacts to water quality could occur from construction or compaction from activities 

described in Appendix C, or from a wild fire. When considered in combination with the minor to 

moderately beneficial impacts of projects (except a large-scale fire) of other projects listed in 

Appendix C, the cumulative impacts from Alternative A would be adverse, short-term, and 

minor. The majority of the impacts are related to short-term compaction of soils and disturbance 

to duff layers. 

Extensive burned areas that may be continuous from ridgeline to slope bottom and include 

riparian areas characterize high-severity fires in Point Reyes such as the Vision Fire. Water yield 

and peak flows increase following high severity fire because soil infiltration rates decrease and 

there is little vegetation to intercept precipitation or organic litter (duff) to slow water runoff. 

Extensive and continuous areas of hydrophobic soils are created, further decreasing infiltration 

and increasing water yields. This was observed by Onda et al. (1996) who determined that during 
249 

the initial storm of the season after the fire, the runoff ratio was 10 times and the surface crust, 

not the hydrophobicity, caused 50% of the runoff. Collins and Ketcham (2001) also found in 

the lower Muddy Hollow watershed after the Vision Fire minimum sediment increases of 2,626 

tons/sq/mi/yr occurred. Sediment supply was 2.7 times higher to the lower watershed during 

second year after the fire than the first year. 

A large-scale fire would cause an increase in sediment and nutrient yields in the watershed and 

corresponding increased rates of erosion and sediment deposition in channels. This would 

impact both water quality and the physical characteristics of channels and their associated 

aquatic habitats. Channels would not reestablish their pre-fire character until the vegetation recolonized and stabilized hill slopes and channel banks. However, because of burn severity in the 

riparian areas, reestablishment of vegetation would take several years. During extreme weather 

events, debris torrents would potentially scour streams, delaying restoration of the riparian 

community for even longer. Thus, with the cumulative impacts of a large-scale catastrophic fire, 

the effects of Alternative A on water resources and water quality include areas of adverse, 

potentially long-term, and major change. However, vegetation would return in the long run, as it 

has following the 12,000+ acre Vision Fire, and scouring and overland flow would return to rates 

within the natural rate of variability, preventing impairment of park resources. 

Conclusion 

 

To sum, the effects of prescribed fire on watershed conditions and natural hydrology of the burn 

areas through reducing the risk of catastrophic fire and returning more natural fire intervals 

would be beneficial, long-term, and moderate. Effects of prescribed fire to water quality related 

to increased erosion would be adverse, minor and short-term until vegetation is reestablished. 

Impacts from soil disturbance related to mechanical treatments would be adverse, short-term, and 

negligible to minor. However, the watershed effects within these areas treated by mechanical 

means would be beneficial, long-term, and minor to moderate. 

In aggregate, actions implemented under this alternative would have adverse, short-term, and 

minor effects to water quality. In the long-term, the actions of Alternative A would have a 

beneficial, long-term, moderate to major effect in restoring the natural hydrology of the area. 

 

A large-scale unplanned fire could have adverse, potentially long-term, and major impacts to 

both water quality and features of watersheds, including riparian zones and watercourses. 

No impairment to park water resources would result from implementing Alternative A. 

Alternative B 

Analysis 

Prescribed Fire 

In this alternative 1000 acres of prescribed burning would occur over an average year. Although 

the number of acres treated by prescribed fire is increased above Alternative A, the types of 
250 

impacts from Alternative B are the same as those described for Alternative A. Also, because the 

burn units are dispersed throughout the park in the various FMUs (no concentration of impacts 

within a watershed) the total acres treated in relationship to the 90,000 acres within park 

boundaries is still relatively small (less than 2%). Therefore, beneficial impacts to the watershed 

from the removal of large fuel loads (protection from catastrophic fire) and the reestablishment 

of a natural hydrological process due to treatment with prescribed burning would still fall in the 

moderate range in the context of the entire study area. However, compared to Alternative A, 

benefits would be twice that of Alternative A because of the additional acres treated. Although 

effects on water quality from prescribed fire would occur over a larger area in this alternative 

relative to the No Action alternative, they would remain adverse, minor and short-term in the 

context of the entire study area. They may be quite noticeable on a localized basis compared to 

Alternative A, however. 

Unplanned Ignitions, Wildfire, and Suppression 

Same as Alternative A. Water quality effects of these actions would be adverse, short-term, and 

minor due to soil compaction and use of fire retardants. However, the overall acres, 

approximately 30, are minor compared to the total acres (90,000) within the park (less than 1%). 

Mechanical Treatments 

Under Alternative B, the total acres treated by mechanical means would increase to 1000. 

Although this is double that treated in Alternative A, it is still a relatively small (less than 2%) 

percentage of the 90,000 acres in the study area. In addition, treatment would be dispersed 

among eight FMUs (Alternative A would include mechanical treatment in three FMUs). 

Therefore in the context of the entire study area, benefits to watershed characteristics from 

mechanical treatment by reducing fuel loads and reestablishing the natural hydrological cycle 

would remain long-term, and minor to moderate as they are in Alternative A. 

Water quality impacts from mechanical treatments would be adverse, short-term, and negligible 

due to soil disturbance and vegetation removal that may cause erosion. Overall, long-term, minor 

to moderate beneficial effects on the watershed would result from reestablishing natural 

hydrological cycles, eliminating exotic vegetation, and reducing the potential for catastrophic 

fire. Compared to alternative A, the relative impacts to both water quality and watershed 

characteristics may be readily noticeable on a localized basis as the number of acres treated 

would double. 

Mitigation Measures 

Same as Alternative A. While the annual 500-acre cap of prescribed burning under Alternative 

A automatically limits the potential watershed level effects on erosion to a negligible or minor 

effect, larger projects are permissible under the 1,000-acre annual cap in Alternative B. Ten 

percent of the total acreage of three of the watersheds where FMUs slated for prescribed burning 

in Alternative B is less than 1,000 acres per year. If a group of projects proposed for several 

FMUs were sited within one of these three watersheds, there is a potential for more than 10% of 

the effective soil cover in that watershed to be affected. 
251 

The W-2 mitigation measures relative to watershed level planning are proposed to assure that 

erosion rates within any one watershed would conform to the conclusions of environmental 

effect reached in this EIS, e.g., would be no more than moderate in intensity. It would be 

triggered when proposed actions have the potential to exceed 10% of the total area of one or 

more FMP watersheds in one year. Mitigation Measure W-2 assures that planning considers the 

watershed scale and, if a potential effect is identified, that a specific assessment be conducted for 

the work plan to assure the conformance of watershed level effects with this EIS. Under 

Alternative B, Mitigation W-2 would be triggered if the annual work plan includes projects that 

account for more than 10% of the Bolinas Drainages, Olema Creek Watershed, or the Pine Gulch 

Watershed. As shown in Table 42, the combined project acreage must exceed 790 acres in 

Bolinas Drainages, 939 acres in Olema Creek Watershed, and 506 acres in Pine Gulch 

Watershed. 

Once it is confirmed that an annual plan for prescribed burning would exceed the 10% level of 

area in these smaller watersheds, Mitigation Measure W-2 requires an interdisciplinary team 

evaluation, chaired by the Fire Management Officer, to document the degree of conformance of 

the proposed actions with the assessment conducted for this FEIS.

Fire Information/Education 

Same as Alternative A. Fire education and information programs would have no beneficial or 

adverse effects on water resources, the natural hydrologic process, and water quality. 

Fire Cache/Park Headquarters Relocation, and Construction 

Same as Alternative A. The construction of a fire cache at Bear Valley would not have a 

beneficial or negative impact on water quality and water resources. The building would be 

located at least 100 feet from riparian zones and temporary construction plastic fencing would be 

used to eliminate any sediment reaching the creek during rain events. 

Fire Effects and Fuel Management Research 

Fire research would have no beneficial or adverse effects on water resources and quality. 

Cumulative Impacts 

No cumulative impacts beyond those described for Alternative A would occur. 

Conclusion 

In the context of the 90,000 acre study area, the impacts to water quality and watershed 

characteristics of Alternative B would be nearly indistinguishable from Alternative A. Treatment 

with prescribed fire and through mechanical means would result in long-term, moderate to major 

benefits to watersheds from the reestablishment of the natural hydrological processes, 

elimination of exotics, and reduction of fuel loads and potential for catastrophic wildfire. 

Compared to No Action, the benefits could be quite noticeable on a localized basis. 
252 

Impacts to water quality over the entire study area from soil disturbance, erosion and 

sedimentation from these same activities would have similar adverse, short-term, and negligible 

to minor impacts to water quality as Alternative A. However, because the treated acreage would 

double in this alternative, localized impacts to water quality may be quite noticeable. 

A large-scale unplanned fire could have adverse, potentially long-term, and major impacts to 

both water quality and features of watersheds, including riparian zones and watercourses. 

No impairment to park water resources would occur from implementing Alternative B. 

Alternative C 

Analysis 

Prescribed Fire 

In this alternative 2000 acres of prescribed burning would occur over an average year. In the 

context of the 90,000 acre study area, treatment of 2000 acres would not have impacts to 

watersheds or water quality readily distinguishable from those in No Action. As in both 

Alternatives A and B, treatment would have beneficial, long-term and moderate impacts to water 

resources through reducing fuel loads and the potential for catastrophic fire, controlling exotic 

vegetation and reestablishing natural hydrological processes. However, even though the number 

of acres burned would remain relatively small, it would be four times the number treated in the 

No Action alternative, and twice that in Alternative B. Smaller scale positive changes in fuel 

loading, ground cover, soil condition and other features contributing to hydrologic processes may 

therefore be much more noticeable under Alternative C than the other alternatives. 

This is true of short-term impacts to water quality as well. Although soil disturbance and 

resulting sedimentation from activities necessary to carry out or control prescribed burns would 

have on negligible or minor park wide adverse effects to water quality, localized erosion may be 

more noticeable or longer lasting under this alternative. 

Unplanned Ignitions, Wildfire, and Suppression 

Same as Alternative A. Water quality effects of unplanned ignitions and fire suppression actions 

would be adverse, short-term, and minor due to soil compaction and use of fire retardants. 

However, the overall acres, approximately 30, are minor compared to the total acres (90,000) 

within the park (less than 1%). 

 

Mechanical Treatments 

Although the total acres treated mechanically in this alternative is 1500 acres, this is still a small 

percentage (less than 2%) of the total study area, and compared to it would have only the same 

minor to moderate benefits to hydrological processes by controlling exotics, reducing the 

potential for catastrophic fire, and helping to reestablish natural hydrologic cycles as either 

Alternative A or C. Mechanical treatment would also be dispersed over a wider area than in the 
253 

No Action alternative, and so benefits to watersheds would be difficult to distinguish from other 

alternatives. However, as noted above, 1500 acres is significantly greater than the 500 acres 

Alternative A would treat, and on a local basis, improvements to hydrologic processes may be 

quite noticeable. 

The same is true for water quality. Over the entire study area, water quality impacts from 

mechanical treatments would be adverse, short-term, and negligible to minor due to soil 

disturbance and vegetation removal that may cause erosion. However, because more acres are 

treated, it is likely that either a greater number of streams or other bodies of water would 

experience temporary sedimentation or higher turbidities in others than in the No Action 

alternative would occur. 

Mitigation Measures 

Same as Alternative A. FMP watersheds with the exception of the two largest watersheds – 

Lagunitas Creek and Tomales Bay. Under Alternative C, Mitigation Measure W-2 would be 

incorporated into the preparation process for the prescribed burning annual work plan. When 

submitted for consideration, the Fire Management Officer would identify the amount of total 

acres proposed for prescribed burning in each watershed. If the total amount of project acreage 

exceeds 10% of the total watershed acreage, an environmental analysis would be conducted by 

an interdisciplinary team as directed by Mitigation Measure W-2. 

Fire Information/Education 

Same as Alternative A. Fire education and information programs would have no beneficial or 

adverse effects on water resources, the natural hydrologic process, and water quality. 

Fire Cache/Park Headquarters Relocation, and Construction 

Same as Alternative A. The construction of a fire cache at Bear Valley would not have a 

beneficial or negative impact on water quality and water resources. The building would be 

located at least 100 feet from riparian zones and temporary construction plastic fencing would be 

used to eliminate any sediment reaching the creek during rain events. 

Fire Effects and Fuel Management Research 

The actions under this alternative would have no beneficial or adverse effects on water resources 

and quality. 

Cumulative Impacts 

No cumulative impacts different from those described under the No Action alternative would 

occur in Alternative C. 
254 

Conclusion 

In the context of the 90,000 acre study area, the impacts to water quality and watershed 

characteristics of Alternative C would be difficult to distinguish from Alternative A. Treatment 

with prescribed fire and through mechanical means would result in long-term, moderate to major 

combined benefits to watersheds from the reestablishment of the natural hydrological processes, 

elimination of exotics, and reduction of fuel loads and potential for catastrophic wildfire. 

Compared to No Action or Alternative B, the benefits could be quite noticeable on a localized 

basis. 

Impacts to water quality over the entire study area from soil disturbance, erosion, and 

sedimentation from these same activities would have similar adverse, short-term, and negligible 

to minor impacts to water quality as Alternative A. However, because the treated acreage would 

be quite a bit larger in this alternative, temporary localized impacts to water quality may be more 

noticeable. 

A large-scale unplanned fire could have adverse, potentially long-term, and major impacts to 

both water quality and features of watersheds, including riparian zones and watercourses. 

No impairment to park water resources would occur from implementing Alternative C. 

IMPACTS TO VEGETATION 

Types of impacts 

Numerous activities associated with wildland fire, prescribed fire, wildland fire suppression, and 

mechanical treatments can have either adverse or beneficial impacts on vegetation. Impacts can 

be sustained by individual plants, or by plant communities. Examples of impacts to individual 

plants include direct mortality or physical damage resulting from burning, or from mowing or 

cutting vegetation for fireline. A plant community level impact would occur if cutting fireline or 

prescribed burning led to the establishment or spread of non-native invasive plants, which could 

alter plant community species diversity and function. Mitigation such as monitoring and the 

removal of non-native plants would limit these effects. 

The impacts of fire on vegetation are a function of the severity of the fire itself and 

characteristics of the plants on the site. The ultimate response of a plant or a plant community to 

fire is related to the type of fire (e.g., surface vs. crown), fire behavior, fire duration, fire 

intensity, the season in which the fire burns, and how recently the area burned in the past. Fuel 

quantity and arrangement, fuel moisture content, topography (e.g., slope and aspect), wind speed, 

and the structure of the plant community itself cause the lethal heat zone to vary significantly in 

time and space (Miller, 2000). This means fire effects on plants can vary not only widely among 

fires, but also among different areas on the same fire. 

Species and individual plants respond uniquely to fire based on plant age, vigor, morphology, 

reproductive strategies (e.g., seeders vs. sprouters), germination requirements, and phenological 

state at the time of the fire. Trees, shrubs, and herbaceous species all respond differently to fire, 
255 

and exhibit numerous strategies for post-fire colonization, including sprouting and seeding. The 

amount of subsurface heating that occurs, as well as the amount of organic matter removed from 

the soil surface affects plants and regeneration. Post-fire weather also influences post-fire 

species establishment (e.g., which species will recolonize the site and how quickly) and affects 

the success of newly established plants. 

For the major groups of vascular plants (trees, shrubs, herbs, and grasses), the post-fire plant 

community, at least for the first few years following the fire, is comprised of species that have 

the following regeneration strategies: 

• plants that survived the fire; 

• plants that produced sprouts or suckers from the base or from protected aerial 

reproductive structures; or 

• plants that established from seed (Miller, 2000). 

Seedlings that establish on a burned site are derived from one of the following sources: 

• seed was dispersed from plants that survived the fire (usually trees); 

• seed was dispersed onto the site from adjacent unburned areas; 

• seeds that were in the soil seed bank that were stimulated to germinate by the fire; or 

• seeds that came from plants within the fire that resprouted following the fire (Miller, 

2000). 

Types of Effects From Prescribed Burning 

Prescribed fire can result in direct mortality, can damage plants or seeds, and can change plant 

community structure and species composition. The primary difference, however, between 

unplanned wildland fire and prescribed fire is that prescribed fires are conducted under a rigid set 

of prescriptive parameters including air temperature, fuel moisture, wind speed, etc. Prescribed 

fire planners and managers, therefore, exercise careful control over when and where the burns 

occur, and site-specific prescriptions are developed to meet set objectives relative to vegetation. 

The impacts associated with line construction, holding, monitoring, and mop-up of prescribed 

fires would be similar to those described in the following section for suppression of unplanned 

wildland fire. These impacts, however, would be less substantial with prescribed fire because 

they would be carefully planned to minimize impacts, and they would be implemented under 

controlled conditions. 

Types of Effects from Wildland Fires and Suppression 

The direct effects of unplanned wildland fires on vegetation can be substantial, including longterm, possibly permanent changes in plant species composition or percent cover, and the 

introduction or spread of non-native invasive plant species. However, in burned areas with a 

high component of surviving trees and resprouting native understory vegetation, within a few 

years it can be difficult to determine that a fire recently occurred (Miller, 2000). 
256 

Activities associated with suppression of wildland fire can kill or damage native vegetation. 

These activities include construction of fire control lines, firebreaks, or access roads; aerial drops 

of water or retardant; and post-suppression mop up. 

Aerial drops of water or retardant release liquids onto burning or unburned areas. Most fire 

retardant contains fertilizer type compounds, including ammonia, nitrogen, and phosphorous that 

can change vegetation, especially in areas low in nitrate/ammonia type nutrients. Added 

nutrients can decrease growth of native vegetation and increase the establishment of non-native 

species that favor higher nutrient levels. Impacts can be mitigated by avoiding use of retardant 

or by using “clear” retardant that has minimal active nutrients within the mix. Physical damage 

to vegetation can be avoided by requesting that pilots fly aircraft quickly enough to dissipate 

water and retardant over larger, more linear areas. 

Vegetation that may have survived the fire itself may be adversely affected by mop-up activities 

through soil disturbance, damage to aboveground plant parts, or uprooting. 

Types of Effects From Mechanical Treatment 

Generally, the impacts of mechanical treatments include direct mortality or damage to individual 

plants, the introduction or spread of non-native plants, and trampling or burial of plants. 

Mowing occasionally kills plants, but also can stimulate growth of grasses. Adverse impacts 

could occur if the mowing stimulated growth or spread of invasive non-native plant species. 

Piles of cut vegetation may be burned following hand thinning. Impacts associated with pile 

burning include soil disturbance associated with dragging materials to each pile; localized, 

intense burn effects upon surface fuels, litter and duff, and soil layers; and long lasting effects on 

soil chemistry and structure due to extreme heating over long time periods. Pile burning can 

result in extremely hot temperatures in localized areas, which can kill aboveground vegetation, 

roots, and seeds in the soil. These superheated areas also may be subject to invasion by nonnative plant species. 
257 

Figure 17. Vegetation in Tomales Point FMU 
258 

Figure 18. Vegetation in the Headlands FMU 
259 

Figure 19. Vegetation in the Estero FMU 
260 

Figure 20. Vegetation in Inverness Ridge FMU 
261 

Figure 21. Vegetation in the Limantour Road FMU 
262 

Figure 22. Vegetation in Wilderness North FMU 
263 

Figure 23. Vegetation in Wilderness South FMU 
264 

Figure 24. Vegetation in Highway One FMU 
265 

Figure 25. Vegetation in Bolinas Ridge FMU 
266 

Figure 26. Vegetation in the Palomarin FMU 
267 

Alternative A 

Analysis 

Prescribed Fire 

The FMUs that would be treated with prescribed fire in this alternative include Estero, 

Limantour Road, Highway One, and Bolinas Ridge. As noted in the Alternatives section of this 

EIS, the primary focus of treatment would be to manage hazardous fuels along primary roads and 

reduce the aerial extent and density of non-native invasive plant species, including Scotch 

broom, French broom, and Monterey pine. The impact analysis for fire management activities 

and cumulative impacts is discussed by vegetation type to follow the subsections of Affected 

Environment. 

Bishop Pine Forest 

Although Bishop pine forest occurs in Limantour Road FMU, it would not be treated with 

prescribed fire in this alternative. 

Douglas-fir/Coast Redwood Forest 

This vegetation type occurs in three of four FMUs slated for treatment in Alternative A, but 

because of the more narrow focus and fewer acres treated, would not be burned with prescribed 

fire. 

Hardwood Forest 

Hardwood forests occur in all FMUs except Headlands and would, therefore, be affected by fire 

management activities in all Alternatives. Limited prescribed burning could be conducted in 

small areas supporting hardwood forest in Alternative A, but this would occur only where such 

forest borders grasslands, Scotch or French broom stands, Monterey pine stands, or research 

plots as described in the Alternatives section of this document. Therefore the analysis of fire 

effects on species dominant in hardwood forests is covered under Alternatives B and C, where 

fire would be used to reduce fuels in this vegetation type. Prescribed burning may have 

negligible beneficial long-term impacts to these forests resulting from improved forest health. 

Monterey Pine/Monterey Cypress 

These trees occur as stands and as individuals throughout the Seashore. Although severe surface 

or crown fires only kill Monterey pine adults, young trees are thin-barked and can be killed with 

prescribed burning. Monterey pine cones are serotinous; seeds are released when cones are 

exposed to heat such as fire or high air temperature. Fire is particularly effective for opening 

cones and releasing seeds and it creates a favorable seedbed. Reproduction rates are greatest 

after surface fire in which the parent trees survive. In this alternative, the density and extent of 

stands of Monterey pine in Estero and Limantour Road FMUs would be managed in part through 

controlled burning. Prescriptions would be carefully controlled to kill young trees without 

creating conditions under which reproduction rates for remaining adults would increase. 
268 

Monterey pine and Monterey cypress were introduced into the project area as ornamentals and to 

provide windbreaks. Because the NPS seeks to eliminate non-native species and restore 

vegetation communities to a natural state, removal of individual trees in Estero and Limantour 

Road would have a localized minor to moderate long-term beneficial impact to native vegetation. 

For these beneficial impacts to persist, however, follow-up activities must be conducted to 

remove new recruits that come into the site in years following prescribed burning or mechanical 

treatments. Adverse, minor, short- to long-term impacts also could occur as a result of 

application of fire management activities if other non-native invasive plant species invade or 

spread on treated sites. 

Mitigation Measures

Follow-up non-native plant monitoring and removal would be conducted to remove new recruits 

that come into the site in years following prescribed burning or mechanical treatments. 

Riparian Woodland 

Riparian vegetation occurs alongside rivers, streams, and creeks. In Point Reyes, riparian 

woodlands and shrublands would not be treated with either prescribed fire or mechanical means, 

and a 100-foot buffer would be maintained if fire management activities were to occur in the 

vicinity. Riparian vegetation could be burned by wildfires and potential impacts are discussed in 

Cumulative impacts below. 

Coastal Scrub 

Prescribed fire would be used to continue efforts to reduce the extent and density of non-native 

invasive plants Scotch broom and French broom, which are common inhabitants of both 

grasslands and coastal scrub (see Table 50). Prescribed fire would be used in both Estero and 

Highway One to control this invasive species. 

Table 50. Broom Acreage within Fire Management Units 

Fire Management Unit Alternative A Alternative B Alternative C 

Tomales Point 

Headlands 

Estero 1,436 1,436 1,436 

Inverness Ridge 

Limantour Road 

Wilderness North 

Wilderness South 

Highway One 988 988 988 

Bolinas Ridge 

Palomarin 

 

 

Totals 2,424 2,424 2,424 

 

Earlier work reported in the park’s 1993 Fire Management Plan (PRNS, 1993) indicated the 

temperature attained during a prescribed burn was important in killing seeds of both species of 

broom. Heat greater than 150 degrees C for more than two minutes killed the majority of the 

Scotch broom seed and those greater than 100 degrees C for one minute increased susceptibility 

of this species to fungal pathogens. However, temperatures of less than 65 degrees C for two 
269 

minutes significantly increased germination. French broom seeds are killed when soil 

temperatures reach 125 degrees C for one minute. Effective control appears to involve a 

combination of cutting at the end of the dry season to decrease the rate of resprouting, and a fall 

or spring burn repeated every year for several years. This is the approach the park has been using 

for Scotch broom. Preliminary monitoring has indicated the combination of cutting or mowing 

followed by prescribed burning has reduced the extent of Scotch broom shrubs on average by 

84% since 1990 (PRNS, 2002a), a potential moderate benefit if applied throughout the range of 

this species. Fire management activities have not been as successful with French broom, as 

preliminary monitoring indicates what may be an increase in the frequency of this species in 

plots that have been mechanical treated and then burned. However, unlike Scotch broom, 

treatment regimes for French broom have been inconsistent across study plots and data do not 

reveal a statistically significant trend. Graphing the existing data show mechanical treatment 

followed by prescribed fire may be an effective means of exhausting the seed bank, although it 

remains to be seen if subsequent burns would reduce shrub frequencies to levels where 

mechanical removal of individual remaining shrubs would be feasible (PRNS, 2002a). Based on 

the information PRNS has to date, overall treatments would have a long-term moderate 

beneficial effect on vegetation. 

Grassland 

Prescribed burns and mechanical treatments would occur in grasslands in four FMUs under 

Alternative A. Treatments would occur primarily along road edges, and around structures to 

reduce fire hazard. Impacts of these activities on vegetation are expected to be adverse, 

negligible to minor, and short- to long-term if non-native species expand in density or aerial 

extent as a result of treatments. 

Dominant non-native plant species in grasslands in the project area include velvet grass, annual 

wild rye, perennial ryegrass, small fescue, foxtail fescue, and Farmer’s foxtail. Dominant native 

grass species include tufted hairgrass, California brome, Pacific reedgrass, California oatgrass, 

and meadow barley. Monitoring results and other, published, information indicate annual wild 

rye adults are likely killed by fire, although their seeds may survive. The remainder of the 

dominant non-native species of grasses at the Seashore either are largely undamaged by 

prescribed fire, or appear to be stimulated by it. This is because seeds are either buried and 

unaffected by all but very hot fires, or the plant sprouts from buried structures, such as rhizomes 

or root crown in the growing season following the burn. As noted in Affected Environment, 

roughly 80% of the grasslands at the Seashore are dominated by non-native grass species. 

In keeping with NPS and Seashore objectives to reduce the aerial extent of non-native species 

and encourage natives, prescribed fire has been used in combination with mowing, grazing, 

seeding, and/or herbicides with varying degrees of success to try to shift the balance. A recent 

meta-analysis (Twedt, 2003) of such attempts did not identify any strategy that consistently 

favored native species relative to non-native species. Rather, the outcomes were very case- and 

site-specific. For example, while a combination of prescribed fire and mowing has been 

successful in removing scotch broom from some grassland communities, prescribed burning of 

the high invasive purple velvet grass may be increasing its abundance. 
270 

The results of monitoring more than a decade of fire management efforts at the park remain 

preliminary, and additional control plots and data need to be gathered before a particular 

management approach for each vegetation type can be linked to a conclusive result; however 

these initial results show prescribed burning can result in an increase in non-native species as 

easily as a decrease. As part of this plan (and as noted in Mitigation sections), the effects of all 

prescribed burning carried out on grasslands would be carefully monitored to assess post-burn 

plant species cover and composition. If monitoring shows prescribed burning is definitively 

linked to an increase in non-native plant cover or distribution, either the prescription would 

change (e.g., burn during different seasons), it would be combined with other treatments (such as 

mowing, seeding of natives, etc.), or another strategy would be employed to restore native 

grassland vegetation. 

Mitigation Measures

All grassland burns would be carefully monitored to ensure burn objectives (= recruitment and 

long-term maintenance of native species without introduction of invasive non-native plant 

species) are being met. 

To enhance grassland plant species composition, and reduce the chance of invasion or spread of 

non-native species, native seeding trials would be conducted following fire management 

treatments in some areas. 

Pasture 

The majority of pasture is within the Minimum Management Unit, and is used to graze cattle or 

horses or managed to produce silage for cattle. In the FMUs slated for treatment with prescribed 

fire in this alternative, all but Bolinas Ridge have small amounts of pasture. In general, no fire 

management activities are planned for these areas, except clearing of vegetation around 

structures and clearing along roads and fire roads. However, small areas of non-native species, 

including Scotch broom, French broom, or Monterey pine in pasture vegetation may be burned 

or mowed to reduce the density and aerial extent of these invasive species. Impacts associated 

with these efforts would be beneficial, minor to moderate, and long-term as a result of removal 

of invasive non-native plants. For these beneficial impacts to persist, however, follow-up 

activities must be conducted to remove new recruits that come into the sites in years following 

prescribed burning or mechanical treatments. Because results vary when prescribed fire is used 

to treat non-native invasive species, some unexpected spread of a particular population may also 

occur. If so, this would result in adverse, minor, short- to long-term impacts. 

Coastal Dune 

No coastal dune vegetation occurs in the FMUs that would be treated with prescribed fire in this 

alternative. 

Unplanned Ignitions, Wildland Fire, and Suppression 

The average number of unplanned ignitions at Point Reyes has been three fires annually, with 

each of these fires burning less than ten acres. The actual extent and magnitude of impacts are 

impossible to predict, however, as these fires are unplanned. Information on direct effects 

would, in most cases, be obtained after the fire, and would involve documenting effects on 
271 

resources for which little pre-burn data were available. All of these impacts would be mitigated 

following a fire with assistance from the NPS Burned Area Emergency Rehabilitation (BAER) 

program. 

The impacts on vegetation associated with these small, unplanned wildfires and their suppression 

are expected to be both adverse and beneficial. Adverse impacts are expected to be minor and 

short-term, and result from the loss of individuals of native species through mortality or 

decreases in reproductive ability. It is possible that small invasions of non-native plants would 

result from these fires, which could result in a longer-term impact, but the impact would be 

localized. Small unplanned wildland fires in the project area may have some beneficial impact 

on vegetation in localized areas if non-native plants are killed, and native plants establish on the 

site following the fire. 

Suppression activities would also have direct but localized impacts. Fire control lines involve 

clearing all vegetation within an 18 to 24 inch-wide swath down to bare mineral soil. In 

grassland habitat, a weed whacker, mower, or tractor may be used. In shrub or forested habitats 

the vegetation is cut and the fireline is cleared using chainsaws, shovels, Pulaskis, and McLeods. 

Fire line construction also can include cutting brush, limbing trees, and cutting snags. Inward 10 

to 20 feet from the fire’s perimeter line, vegetation density (and consequently fire intensity) is 

reduced by cutting down all trees and cutting shrubs to a 15 to 20-foot wide separation using 

chainsaws, shovels, Pulaskis, and McLeods. In emergency situations, bulldozers are used to 

create fuel breaks to stop wildfire. Vegetation clearing can create conditions that are favorable 

for the establishment of non-native plant species. 

Aerial drops of water or retardant release liquids onto burning or unburned areas. Vegetation can 

be physically damaged from the impact of the liquid, but the areas affected tend to be small and 

the effects relatively local. Although the chemical components of retardant only remain for a 

few months at most, and long-term, chemical alteration of the soil would not occur, there could 

be localized long-term impacts to areas if non-native plants become established or spread. 

Fire suppression activities may require development and use of helispots and spike camps, which 

could disturb vegetation. In forested areas, trees and/or snags may be removed to open areas for 

safe operation of aircraft or to make camps safe for fire personnel. These impacts generally are 

local. Aircraft skids or wheels, boots, equipment, and camp and base supplies could be 

contaminated with non-native seed, providing vectors for non-native species that would not 

otherwise disperse to these sites. 

Post-suppression mop-up involves digging, cutting, trenching (to prevent debris from rolling), 

chinking (taking a pulaski and clearing burning material off a log), chunking (putting smoldering 

material into one pile and letting it burn up), and mixing dirt with water from backpack pumps or 

from hoses. Any smoldering that is causing nuisance smoke is extinguished. 

Mitigation Measures

Adverse impacts to vegetation would be mitigated to the greatest extent possible during all fire 

management activities using the following measures: 
272 

Pre-Treatment Measures 

Individual prescribed burns would be conducted within the framework of a multidisciplinary 

planning effort. Personnel from fire management and from resources management would work 

together to identify areas that are expected to benefit from prescribed burning. Existing data on 

the response of plant communities in the Seashore to fire would be consolidated and analyzed to 

determine optimal areas, configurations, and times for burns. Clear objectives would be 

developed for prescribed burns that would include measurable parameters to determine the 

effects of the burns on vegetation. Following burns, vegetation would be analyzed to determine 

the effects of the burn, which would aid in future burn planning. 

Impacts associated with all fire management treatments would be minimized through pre-project 

planning and coordination with vegetation managers within the Resource Management Division. 

Prescribed burns would be conducted at a time of year when introduction or spread of non-native 

plants would be minimized, and mortality of non-native plant species would be maximized. 

Whenever possible, existing roads or trails would be used as firebreaks for prescribed burns and 

for wildland fire suppression. 

Prescribed burns would be planned to minimize adverse impacts to vegetation to the greatest 

extent possible (e.g., in areas supporting invasive non-native plants, spring burns may be less 

likely to result in spread of the non-natives and should be considered; in these cases, however, 

other factors also must be considered such as whether or not spring burning would adversely 

affect soil seed of native plant species). 

Vegetation managers would work with fire management staff to develop maps of areas that 

support plant communities of special management concern (e.g., uncommon communities, 

wetlands, riparian areas, dunes, areas with no non-native plants that need to be kept intact, areas 

with highly invasive non-native plants that should not be spread) so fire personnel can attempt to 

avoid such areas when making decisions about fire management tactics. 

During Treatment Measures 

Soil disturbance would be minimized to the greatest extent possible to reduce potential for 

introduction or spread of invasive non-native plant species. 

The aerial extent of disturbance associated with mechanical treatments would be kept to the 

minimum necessary to reduce fire risk. 

Known populations of special-status plant species would be avoided when locating helispots or 

spike camps. 

Previously disturbed sites and open areas would be used for helispots or spike camps whenever 

possible to minimize additional disturbance. 
273 

Burn piles would be kept small to minimize the area disturbed and to allow for the recolonization 

of sterilized patches by mycorrhizal fungi and other soil organisms in adjacent areas. 

Post-Treatment Measures 

Areas subject to fire management treatments would be monitored periodically for the presence of 

invasive non-native plant species, and if such species have established or spread as a result of 

such activities, the non-natives would be removed. 

All fireline (both handline and dozer line) would be rehabilitated as quickly as possible, which 

includes application of Burned Area Emergency Rehabilitation (BAER) techniques such as 

recontouring, soil stabilization as needed, and monitoring for and removal of invasive non-native 

plant species for a minimum of three years following a fire. 

Litter and duff would be replaced on disturbed sites to make them less susceptible to invasion by 

non-native species. 

Post-treatment surveys for non-native plants would be conducted in areas subject to mechanical 

treatments, and measures to remove non-native species in disturbed areas would be undertaken. 

Mechanical Treatment 

Up to 500 acres of vegetation would be mechanically treated in Estero, Limantour Road, and 

Highway One FMUs in Alternative A. The focus of treatment would be mowing grasslands to 

reduce hazardous fuels and control Scotch and French broom, and cutting Monterey pine to help 

eliminate this non-native species. 

Vegetation would be mowed around structures and along roads to reduce fire hazard, and, in 

some cases, around the perimeter of a planned prescribed burn to contain the burn. Mowing 

occasionally kills plants, but also can stimulates growth of grasses. Adverse impacts could occur 

if the mowing stimulated growth or spread of invasive non-native plant species. Mowing has 

been used to some degree of success in helping control the spread of scotch broom (see coastal 

scrub, below). This would continue in Alternative A. 

In the past, cutting and thinning of vegetation has been conducted in small, developed areas of 

the Seashore, primarily around structures and along roads. Under this alternative, thinning 

would continue in these areas to remove small diameter trees and brush to reduce the risk of 

unplanned ignitions, to safeguard structures, and to make travel on roadways safer in the event of 

an unplanned wildfire. Some soil disturbance would occur during this work and there would be 

a potential for non-native plant species establishment or spread. The minimum requirement for 

defensible space along roadways is 10 feet on each side. 

For clearing along roads, trees along the sides of the roadways are limbed up to 10 feet in height 

as needed. Native tree species commonly subject to limbing include Douglas-fir and Bishop 

pine. Trees less than four inches in diameter (dbh) are removed from a corridor 10 - 15 feet wide 
274 

on each side of the road (measured from the edge of the roadway). This width can increase to 20 

feet wide where roads cross topographic saddles. Downed trees in or near the roads are cleared. 

Grass growing up within roads is cut or mowed. 

 

Defensible space required at each structure is based on individual site topography, and usually 

ranges from 30 - 50 feet around structures. In some cases, a larger cleared area may be required 

to protect the structure from potential fire hazard due to prevailing winds or the presence of 

drainages or swales close to the structure. For defensible space large trees are pruned or 

removed if the tree poses a threat, grasses are cut to stubble, and smaller trees are pruned or 

removed based on individual site topography. The health of all trees within the defensible space 

is assessed and any dead and dying trees are removed. 

Piles of cut vegetation may be burned following hand thinning. Impacts associated with pile 

burning include soil disturbance associated with dragging materials to each pile; localized, 

intense burn effects upon surface fuels, litter and duff, and soil layers; and long lasting effects on 

soil chemistry and structure due to extreme heating over long time periods. Pile burning can 

result in extremely hot temperatures in localized areas, which can kill aboveground vegetation, 

roots, and seeds in the soil. These superheated areas also may be subject to invasion by nonnative plant species. 

Bishop pine, Douglas-fir, and Hardwood forests 

Under Alternative A, impacts from mechanical treatment to forest vegetation, including bishop 

pine, Douglas-fir, and hardwood forests, would come from the thinning and fuel reduction 

activities described above. These impacts would be adverse, negligible to minor, and short-term 

(potentially long-term if non-natives are introduced or spread). 

Monterey Pine/Monterey Cypress 

Monterey pine and Monterey cypress were introduced into the project area as ornamentals and to 

provide windbreaks. Because the NPS seeks to eliminate non-native species and restore 

vegetation communities to a natural state, removal of individual Monterey pine trees in Estero 

and Limantour Road would have a localized minor to moderate long-term beneficial impact to 

native vegetation. For these beneficial impacts to persist, however, follow-up activities must be 

conducted to remove new recruits that come into the site in years following mechanical 

treatments. 

Mitigation Measures

Follow-up non-native plant monitoring and removal would be conducted to remove new recruits 

that come into the site in years following prescribed burning or mechanical treatments. 

Riparian Woodland 

No mechanical treatment would occur in riparian woodland in any alternative. 

Coastal Scrub 

Under Alternative A, mechanical means would be used in coastal scrub in areas that require 

treatment around structures or along roads or fire roads. Adverse negligible to minor short-term 
275 

impacts could result. In addition, mowing to target both Scotch and French broom in Limantour 

and Highway One FMUs would continue (see discussion of prescribed burning in coastal scrub 

above), with possible moderate benefits to native coastal scrub species. 

Grassland 

Scotch and French broom also occur in grasslands in the above mentioned FMUs, where 

mechanical treatment by mowing would be used to help control the spread of these species. 

Pasture 

As noted above, treatment would generally not occur in pasture, although some mowing of 

Scotch and French broom is possible. 

Coastal Dune 

No coastal dune vegetation occurs in the FMUs that would be mechanically treated in this 

alternative. 

Fire Information/Education 

This would have no beneficial or adverse effects on vegetation. 

Fire Cache/Park Headquarters Relocation and Construction 

The construction of a fire cache at Bear Valley would not have a beneficial or negative impact on 

vegetation. The building would be located at least 100 feet from riparian zones and temporary 

construction plastic fencing would be used to eliminate any impacts to this vegetation zone. In 

addition, the site is a former trailer pad and nearly unvegetated. 

Fire Effects and Fuel Management Research 

Research burns would continue on velvet grass and Scotch and French broom to help Seashore 

ecologists refine burning prescription parameters to control these species. This could have 

substantial benefits to the park’s natural coastal scrub and grassland communities in Estero and 

Highway One FMUs, as well as to these communities both within the entire study area and in the 

region where these species are currently invading. Alternative A does not include any research or 

test plots in other vegetation communities, or to test other factors in grasslands and coastal scrub. 

To the extent that no additional research is conducted, fire-dependent native vegetation would 

continue to decline. 

Cumulative Impacts 

Perhaps primary among the combination of factors influencing vegetation at Point Reyes is the 

century of fire suppression beginning in the late 1800s. Evidence from tree rings show periodic 

fire (ranging from every 6 to perhaps as long as 30 years) in the project area is a natural 

occurrence, and several native species in the project area reproduce abundantly only following 

fire. Suppression of periodic fire has favored fire-intolerant species, non-native species and 

allowed the unnatural buildup of both dead and live fuels. Shrub and grassland habitats for 
276 

example, are experiencing encroachment by fire intolerant conifers. Native Marin manzanita 

populations are becoming rare as a result of shading from increasing forest stand density. As 

noted in other locations in this EIS (see Fire History, for example) the build up of fuels, or 

change from understory (grasses and forbs) dominance to overstory (trees and shrubs) 

dominance, and changes in forest structure generally increases the risk of a large-scale wildfire, 

which can affect vegetation in the extreme by completing replacing existing vegetation 

(Covington et al., 1994). In some cases, replaced vegetation would not return; in others, a climax 

seral stage may return after many years. 

Logging, grazing and development of land in the region have also contributed to changes in 

composition and density of key species. For example redwood forest is estimated to have 

covered 1,976, 000 acres.150 years ago. Today, approximately 1,570,000 acres is left, and only 

11% of that is protected park land (Jensen, 1993). Analysis of pollen from coast live oak (the 

dominant tree of the park’s hardwood forests) show that oak woodlands were stable for up to 

four centuries before major European-American settlement. Fire suppression efforts beginning in 

1870 and extending into recent years resulted in a two-fold increase in oak pollen and oak 

density. Today, recruitment of most oaks in California has declined, with some species not 

regenerating rapidly enough to maintain current density (Jensen, 1993). Monterey pine, 

Monterey cypress, and eucalyptus have all been imported by European-American settlers for 

lumber or other reasons. Eucalyptus in particular has been a prolific “weed tree” over much of 

California. Coastal sage scrub is present in about 15% of its former habitat, primarily because of 

agricultural, industrial, and residential development. Grasslands in California have been invaded 

by exotic species in part because of the displacement of native elk by domestic livestock, the 

introduction of exotic plant species adapted to livestock grazing and the clearing and plowing of 

land for agriculture (PRNS, 1993). Scotch and French broom are escaped ornamental shrubs 

brought from Europe and velvet grass is imported from Eurasia. All are highly invasive species 

that occur in grasslands and coastal scrub in the study area. In the immediate study area, the 

projects cited in Appendix C have removed some vegetation, and park needs may continue to 

result in minor impacts to vegetation from removal, or from disturbance that allows non-native 

invasive species to take hold in some localized areas. 

Fuel build-up from a century of fire suppression increases the potential that a large crown fire 

could occur. In Alternative A, the treatment of 500 acres through mechanical means or 

prescribed fire would do little to reduce the risk of such a fire. These larger fires could result in 

establishment and spread of non-native plants, or habitat type conversion. Activities to suppress 

large wildland fires would be the same as those described above in the Unplanned Ignitions 

section and could have substantial, although localized, impacts on vegetation if extensive areas 

are treated with retardant, or if extensive dozerline is constructed. The actual extent and 

magnitude of impacts are impossible to predict, as these fires are unplanned. However, a largescale fire similar to the Vision Fire could have major adverse and potentially long-term effects 

on some native park vegetation communities. In others, such as Bishop pine, wildfires may 

actually stimulate reproduction and increase density, with resulting long-term positive impacts. 

Bishop pine 

Fire plays an important ecological role in maintaining Bishop pine forests. Stands of Bishop 

pine are characteristically even-aged, originating after fires, and their cones persist for many 
277 

years, usually opening as a result of fire. Bishop pine stands are often dense, and stand-replacing 

crown fire typically occurs in such stands. 

A recent vegetation mapping project, conducted from 1996 through 2001, revealed 

approximately 3,570 acres of Bishop pine forest occurring within Seashore boundaries. In 1995, 

approximately 35% (1,250 acres) of this acreage was burned in the Vision Fire. Following the 

fire, most of the pines in the area were dead and the formerly deep litter layer had been burned 

away. The bare, charred soil was covered with extremely large numbers of Bishop pine seeds. 

Regeneration in the burned area has been prolific, with dense stands of young Bishop pine 

growing up to replace the burned forests. One year following the fire, large dense patches of 

Bishop pine had recolonized the burned area. This suggests that the increased risk of a crown fire 

at the Seashore would have a relatively beneficial impact on bishop pine forest. 

Douglas-fir/coast redwood forests 

In some areas supporting Douglas-fir forest in the Seashore, fuel loads have increased as a result 

of fire suppression. Vertical separation between surface fuels and the conifer overstory has been 

eliminated or substantially reduced by the growth and development of a midstory conifer layer. 

In many areas, duff layers and woody debris have increased while the biomass of the ground 

vegetation layer has decreased. This increases the potential for crown fire. 

Seedling establishment following fire depends on the spacing and number of surviving seed 

trees. Seedling establishment in stand-destroying fires is slow because seed trees are killed over 

large areas. Where seed trees are scarce, it may take 100 years or more for Douglas-fir to 

reoccupy the burned area. Conversely, Douglas-fir can quickly establish seedlings if there are 

numerous, well-spaced surviving seed trees within the burned area. Mineral soils exposed by 

fire are generally considered favorable seedbeds. 

Hardwood Forest 

Both of the dominant species of park hardwood forests, California bay and Coast live oak, are 

able to survive and/or repopulate following most wildfires. While bay is not protected from even 

moderately severe fires by virtue of its thin bark, it does resprout from the root crown or bole 

following fires, a characteristic typical of most California hardwoods. Sprouting in California 

bay occurs after fire in virtually any season, and reproductive ability is regained quickly; flowers 

have been noted on first-year sprouts. Seedlings are established the first year, and California bay 

continues to produce seedlings until the next fire. In the coast redwood forest of Muir Woods 

National Monument, for example, 567 seedlings per acre were observed at postfire year 134. 

The dense understory was co dominated by redwood and California bay trees that began as 

sprouts and seedlings following the 1845 fire. 

Adult coast live oaks are more protected from wildfires than California bay. They are evergreens, 

have thick bark, have roots that are protected from fire by an outer corky layer, and generally 

recover well from fire. Evergreen leaves allow this species to allocate greater amounts of energy 

to recovery from fire than to replacing the entire crown annually. Evergreens are often better 

able to conserve nutrients than deciduous species, and are favored in fire-prone environments. 
278 

Coast live oaks sprout from the main trunk and upper crown even after severe burning. When 

trees are top-killed, they sprout from the root crown. Vigorous sprouting is supported by food 

reserves stored in the extensive root system. Resprouting from the root crown often occurs 

during the first two months after being blackened by fire, but some charred trees do not resprout 

for 2 to 3 years. Prefire crown volume is generally recovered, or nearly so, in about 8 to 10 

postfire years. 

Coast live oak seedlings and saplings less than three inches in diameter may be top-killed by 

low- to moderate-severity fire, and severe fire kills trees of this size. Because of vascular 

cambium protection, mature trees have high fire survival rates, even with crown fire. Trees 

greater than 6 to 8 inches in diameter resist top-kill. An “extremely hot” crown fire on the San 

Bernardino National Forest caused only 4% coast live oak mortality. Ninety percent of the oaks 

less than 3 inches in diameter were top-killed, and 2% were killed. Of trees greater than 6 inches 

in diameter, the trunks and crowns of all but 5% survived the fire without top-kill (the 5% 

includes 3% that were top-killed and 2% killed). Generally mortality of coast live oak is greater 

when there is a considerable shrub understory or when trees are adjacent to chaparral. 

Coast live oak generally recovers well from fire, although severely burned crowns, trunks, and 

root crowns may require several years to sprout. If sprouting occurs within several postfire 

months, basal sprouts can be 2 to 3 feet tall in 2 years, and crown density can be 80 to 100% of 

prefire levels within 10 years. The most common fire damage to the trunk is a basal wound 

resulting in potential cambium death. Wounds less than a few inches in size may eventually heal 

with no accompanying heart rot, but larger wounds are susceptible to fungal and bacterial 

pathogens and insect infestation. 

Although it is difficult to predict the impacts of unplanned wildland fire in these forest types, 

such impacts could be beneficial, moderate to major, and long-term. 

Monterey pine/Monterey cypress 

Monterey pine and cypress adults are killed by severe surface or crown fire. Because the adults 

would normally be the seed source from which new trees grow, their destruction can effectively 

eliminate several individuals of a population. Follow-up prescribed burns or removal through 

mechanical means of any juveniles could mean the eventual elimination of these non-natives 

from the park, a long-term moderate benefit. 

Riparian woodland 

Red alder and willow dominate riparian woodlands in Point Reyes. Red alder is an early seral 

species and quickly invades forest openings, such as those created from fires. Young plants 

grow quickly, which gives the shade-intolerant red alder a competitive edge over conifers, such 

as Douglas-fir. Because it is shade intolerant, red alder trees that do not maintain their height in 

the canopy die, resulting in even-aged stands. After about 25 years, conifers equal red alder 

height and begin to overtop them, and by about 40 years, Douglas-fir becomes dominant. Few 

red alder trees remain in these formerly mixed stands past 60 years. As stands develop and trees 

mature, they prevent other red alder seedlings from becoming established, due to the seedlings’ 

shade intolerance. 
279 

Red alder’s bark, although thin, is sufficiently fire resistant to protect trees from light surface 

fires. The foliage and leaf litter do not carry fires well. Red alder stands often lack flammable 

understory debris and are often on moist sites that burn infrequently. Red alder revegetates 

burned areas via seed from off-site plants. Fire hazard is generally low in red alder stands and 

stands may be used as natural firebreaks. 

Arroyo willow (Salix lasiolepis) resprouts from the root crown or stem base following fire. 

Generally, willows tend to be prolific seeders, and off-site plants are important as a seed source 

for revegetating burned areas. Severe fires can completely remove organic soil layers, however, 

leaving willow roots exposed and charred, thus eliminating basal sprouting. Severe fires 

probably occur infrequently in the moist habitats occupied by arroyo willow. 

Both red alder and arroyo willow are highly adapted to periodic, lower intensity fires, and by 

virtue of their location near rivers or in moist soils are also somewhat resistant to hotter fires. 

However, high-severity fires in Point Ryes such as the Vision Fire are characterized by extensive 

burned areas that may be continuous from ridgeline to slope bottom and include riparian 

areas. Once the seed stock of red alder, or the root crown or seed source of arroyo and other 

willows is destroyed from this type of very hot and all consuming fire, reestablishment of 

vegetation would take several years or longer. In addition, during extreme weather events, 

debris torrents would potentially scour streams, delaying restoration of the riparian community 

for even longer. It should be noted that in the spring following the Vision Fire, a burned section 

of the riparian corridor had alders send out leaves, but by the end of the summer many of those 

trees had died. By year four following the fire nearly all of the alders burned in the fire had died 

and fallen. They were being followed up by new sprouts; however, the riparian corridor was far 

more narrow due to the incised channel. Unplanned wildland fire could have adverse, moderate 

to major, long-term impacts to vegetation in riparian areas if fuel accumulations are large and 

fires burn very hot. 

Coastal scrub 

Wildfires are most detrimental to coyote brush, the dominant shrub of coastal scrub, when high 

temperatures are present at stem bases. At lower temperatures, or if only the above ground 

portion of the plant is killed, it can reproduce from seed for by spouting from the root crown. 

Very hot ground fires, however, girdle and kill root crowns, particularly those less than 1 inch in 

diameter. This means a crown fire, which may be more likely in scrub where ladder fuels have 

built up, would leave this dominant relatively unharmed and even stimulate resprouting. A hot 

ground fire, however, would kill adults (McBride and Heady, 1968). A large-scale fire like the 

Vision Fire because it was a crown fire coastal scrub vegetation had only minor adverse impacts. 

Most coastal scrub habitat stimulated resprouting. 

Grassland 

The grassland fuel complex at Point Reyes has changed considerably since European settlement. 

Over much of the park, evenly spaced perennial bunchgrasses have been displaced by dense 

stands of annual grasses. The separation between bunch grasses traditionally kept fires to 

moderate intensity with low to moderate rates of spread, but the dense stands of non-native 

annuals burn with greater intensity and more rapid rates of spread. In addition, annual species 

cure rapidly with the onset of the drought in mid-April resulting in a longer fire season that that 
280 

which existed prior to European habitation (Greenlee, 1983). A large-scale wildfire in Point 

Reyes could result in damage to non-native species by killing rhizomes from which they sprout 

and seeds if soil temperatures are high enough. For example, annual wild rye (Lolium 

multiflorum) decreases on burned sites, and non-native perennial ryegrass (Lolium perenne) 

rhizomes are killed in severe fires. Other non-natives are better adapted to fire; fescues (Vulpia 

spp.) produce abundant seed and drop them early enough in the season that they avoid damage 

from coastal wildfires. Native dominants, such as tufted hairgrass (Deschampsia caespitosa) and 

California brome (Bromus carinatus) appear to able to survive all but the most severe burns and 

spout from root crowns following a fire. As with prescribed burning, impacts to grassland 

species from wildfires would likely be variable. 

Pasture 

Although pasture is essentially grassland, fuel loading is significantly lower because of grazing 

by cattle. The relative intensity of a wildfire would be lower, and species adapted to cooler 

ground fires would presumably benefit. 

Coastal Dune 

Coastal dunes are largely dominated by non-native European beachgrass and iceplant. Although 

these species are mechanically removed, a wildfire may be helpful in reducing the extent of these 

populations. The chances of wildfire reaching them are considered low, however. 

Conclusion 

Limited prescribed burning may have negligible beneficial long-term impacts to hardwood 

forests resulting from improved forest health. Removal of individual non-native Monterey pine 

trees in Estero and Limantour Road would have a localized minor to moderate long-term 

beneficial impact to native vegetation. For these beneficial impacts to persist, however, followup activities must be conducted to remove new recruits that come into the site in years following 

prescribed burning or mechanical treatments. Adverse, minor, short- to long-term impacts also 

could occur as a result of application of fire management activities if other non-native invasive 

plant species invade or spread on treated sites. Treatment of non-native Scotch broom has been 

successful, and may provide minor to moderate benefits to coastal scrub and grassland habitat in 

Highway One and Estero FMUs if applied throughout the area where it occurs. Prescribed burns 

and mechanical treatments in grasslands could have beneficial or adverse impacts, as results are 

highly variable. Monitoring and adaptive management would keep these impacts from becoming 

more than minor if they are adverse. Treatment of small patches broom and Monterey pine in 

pastures with mowing and prescribed fire could have moderate benefits if follow up activities are 

conducted. 

Average unplanned wildfires and their suppression could have minor, short-term adverse or 

beneficial impacts on vegetation. Benefits may result from stimulation of fire dependent native 

species, or from the destruction of non-natives. Adverse impacts come from the loss of native 

species, as well as from crushing, removal or other physical impacts of suppression. 

Mechanical fuel reduction in Bishop pine, Douglas-fir, and hardwood forests would result in 

negligible to minor short-term adverse impacts. Localized minor to moderate long-term benefits 
281 

to native vegetation would result from the mechanical removal of Monterey pine in Estero and 

Limantour Road FMUs. Moderate to major benefits to coastal scrub, grasslands and pasture from 

the continued removal of Scotch broom and French broom would result from the combination of 

mechanical mowing and prescribed burning techniques. The continuation of research and wide 

application of its results would increase these benefits over a wider geographic area. 

Fuel build up and fire suppression continue to increase the chances and likely extent and 

intensity of a large wildfire under this alternative. In some native vegetation communities, such 

as Bishop pine or hardwood forest, large-scale fire could be beneficial by eliminating non-native 

species or otherwise creating conditions favoring the spread of native plants. In others, such as 

Douglas-fir/coast redwood forests, hot crown fires can destroy the seed source for a large area, 

making re-establishment difficult. Riparian areas may also experience major adverse impacts 

from hot fires from the destruction of seed source or root crown. The effect of a wildland fire in 

coastal scrub or grassland is more complex and less well understood, as some native and nonnative species are benefited and some are adversely affected. Overall, the cumulative effects of a 

large-scale fire and all other activities such as development, historic logging, disease, and the 

introduction of exotics have and would continue to have major, long-term adverse impacts on 

native vegetation communities in the park. 

No impairment to vegetation would result from this alternative. 

Alternative B 

Analysis 

Prescribed Fire 

Alternative B would treat vegetation in eight FMUs with prescribed fire, and would burn twice 

as many acres as Alternative A. Fire would be used in Inverness Ridge, Wilderness North and 

South, Bolinas Ridge, and Palomarin FMUs in addition to those identified in Alternative A. 

In addition to continuing to use prescribed fire to reduce hazardous fuels along primary roads 

and to reduce the extent of broom and Monterey pine, Alternative B also would treat sites where 

fuel accumulations have created unsafe situations, and where reduction of fuel could help 

firefighters slow or stop the spread of fires in the event of an unplanned ignition, such as along 

Highway One. Burning would be conducted in the same FMUs for the same reasons as in 

Alternative A, although significantly more burning in shrublands and grasslands in Limantour 

Road and Bolinas Ridge FMUs would occur, primarily to reduce fuels. 

Bishop Pine Forest 

Alternative B includes the use of prescribed burns of less than 30 acres in Bishop pine forest in 

the Inverness Ridge FMU to determine if such burns effectively reduce understory biomass and 

dead and downed fuels, and if burning results in invasion by non-native species. 

Bishop pine is relatively rare inside the park and in the region. The species occurs as relict stands 

in California along much of the coastline, on Santa Cruz and Santa Rosa islands, and in isolated 
282 

populations south to central Baja. As noted above, fire plays an important ecological role in 

maintaining Bishop pine forests. Stands of Bishop pine are characteristically even-aged, 

originating after fires, and their cones persist for many years, usually opening as a result of fire. 

Bishop pine stands are often dense, and stand-replacing crown fire typically occurs in such 

stands. It is hypothesized that a fire-free period of 80+ years would allow trees to succumb to 

diseases and die without reproducing. 

Of the approximately 3,570 acres of Bishop pine forest in the park, 35% (1,250 acres) burned in 

the Vision wildfire. Following the fire, most of the pines in the area were dead and the formerly 

deep litter layer had been burned away. The bare, charred soil was covered with extremely large 

numbers of Bishop pine seeds. Regeneration in the burned area has been prolific, with dense 

stands of young Bishop pine growing up to replace the burned forests. One year following the 

fire, large dense patches of Bishop pine had recolonized the burned area. 

Bishop pine burned in the Vision Fire were 26-45 years old. If additional testing finds stands 

nearing or exceeding 80 years, these sites would be ideal candidates for the pilot prescribed 

burns described above, as disease would likely otherwise take the adults. Prescribed fire would 

stimulate reproduction in these areas that would otherwise not take place. 

Mitigation Measures 

Prescribed burning in Bishop pine stands would occur only if the burns can be conducted under 

conditions that would result in germination and recruitment of new stands of Bishop pine. 

Relatively cool fires under moist conditions may not meet this objective. 

Initially, prescribed burns in Bishop pine forest habitat would be small and would be carefully 

monitored to ensure burn objectives (= recruitment and long-term maintenance of Bishop pine 

and associated native species without introduction of invasive non-native plant species) are being 

met. 

If pilot burns are successful in stimulating reproduction and keeping non-natives from invading, 

prescribed burning would have a minor long-term benefit to Bishop pine stands in Inverness 

Ridge FMU under this alternative. 

Douglas-fir/Coast Redwood Forest 

In this alternative, pilot burns to help managers determine how best to burn Douglas-fir and coast 

redwood would be conducted in at least three FMUs - Wilderness North, Wilderness South and 

Palomarin. To date, prescribed burns have not been conducted in any of these three FMUs. 

Douglas-fir forests and coast redwood forests are the most common forest type in the project 

area, with Douglas-fir forest occupying approximately 90% of the forested area. Coast Douglasfir can stand 250 feet or more and span 5-6 feet in diameter. They can live hundreds of years and 

are common in old-growth stands. The species is intolerant of shade, and requires fire or other 

disturbance to initiate a new cohort of seedlings. Mature Douglas-fir can be killed by ground 

fires, but thick bark offers enough protection of the majority of adult trees. Young Douglas-fir 

are susceptible to fire, and can also act as ladder fuels to carry fire to crowns of trees. When stem 

density is high, an intense crown fire can develop. Crown fires, or slow spreading ground fires 
283 

will commonly kill Douglas-fir trees over extensive areas. A prescribed burn of light to 

moderate intensity would remove ladder fuels, build-up of debris and could stimulate 

reproduction, as fir seeds ripen in burned cones and require relatively open conditions to sprout 

(Franklin and Dyrness, 1973), with resulting minor benefits to Douglas-fir forests. 

 

Coast redwood (Sequoia sempervirens) is well adapted to fire. In other forests in Northern 

California (Annadel and Humboldt Redwood state parks), the fire regime prior to fire exclusion 

varied from every 2 to 6 years at one site to every 5 to 25 years at another. Recent prescribed 

burns resulted in stump sprouting where adults had been top killed. As redwoods achieved 

greater dbh, the probability of top-kill decreased. Flame length and fuel consumption were found 

to be the most important parameters in determining top-kill and basal sprouting. These 

parameters can easily be controlled by use of different firing patterns and fuel moisture to 

achieve the desired effects from a prescribed fire. 

Seashore resource and fire managers are still working to determine the most effective methods 

for conducting prescribed burns in Douglas-fir and coast redwood forests in the project area. It 

would be beneficial, from both ecological and fire prevention perspectives, to reduce the density 

of some Douglas-fir stands, and to reduce the accumulations of ladder fuels. To do so safely, 

however, presents challenges. The NPS is considering the option of thinning smaller trees in 

selected stands of Douglas-fir prior to conducting prescribed burns. These trees would be no 

larger than 10 inches in diameter, and the thinning would be pre-approved by the Seashore’s 

vegetation management staff prior to cutting. Removal of small-diameter trees removes the 

ladder fuels that carry fire into the crowns of larger trees, making prescribed burns safer to carry 

out. 

Mitigation Measures

If pre-burn thinning of trees were required in forested stands, the trees to be thinned would be no 

larger than 10” in diameter. 

Prior to conducting prescribed burning in Douglas-fir or coast redwood forests, Seashore fire and 

vegetation managers, and wildlife and plant ecologists would collaborate to fully develop 

rationale, objectives, prescriptions, and plans for conducting burns in the redwood forests within 

the project area. 

Hardwood Forest 

The responses of hardwood forests and their associated species to fire and fire suppression are 

variable, depending largely on characteristics of the dominant species. As most of the hardwood 

stands in the project area are strongly dominated by California bay and coast live oak, the effects 

of fire management activities on these species were primary considerations in this analysis. 

California bay increases fuel loading by the continual shedding of its bark. Prescribed fire in 

hardwood forests has the potential to reduce this fuel load, and to stimulate reproduction, as 

studies indicate that germination of buried seed may slightly increase following light to moderate 

fire due to the cracking of the thin seed coat. Based on its prolific seedling ability and its ability 
284 

to stump sprout, it is unlikely that California bay in the project area would suffer any long-term 

adverse effects associated with prescribed fire, and may experience negligible or minor benefits. 

 

As noted above in cumulative impacts (for Alternative A), coast live oak displays several 

characteristics that make it highly resistant to damage from fires. These features ensure that few 

large trees are killed by low to moderate-severity prescribed fire. Use of fire is recommended for 

managing coast live oak woodlands, and to maintain natural borders between Douglas-fir forests 

and coastal sage scrub or mesic chaparral communities. For example, Douglas-fir encroaches 

into hardwood forest in the park where fire has been suppressed. In scrub communities, the 

exclusion of fire has allowed coast live oak to increase in density, with resulting reductions in the 

diversity and abundance of understory species. Prescribed fire can be useful in both eliminating 

Douglas-fir in hardwood habitat and eliminating coast live oak in scrub habitat. 

Alternative B does not include any prescribed burning in hardwood forests for the purposes of 

re-establishing more natural boundaries of this vegetation type, but instead would be used to treat 

fuel build-up as it is in other vegetation communities. Hardwood forest occurs in all FMUs 

slated for treatment with prescribed burning. The focus of prescribed burning would be to 

reduce fuels in all vegetation types, but primarily in scrub and grassland. Therefore, prescribed 

burning deliberately targeting fuel build-up in hardwood forests is unlikely. Instead, this 

vegetation type would experience negligible to minor benefits from incidental reductions in fuels 

and possibly from the stimulation of dormant seeds. 

Overall, treatments are expected to result in beneficial, minor to moderate (depending on the 

number of acres treated) long-term impacts as a result of improved forest health. 

Mitigation Measures

Site-specific objectives would be developed for prescribed burns in hardwood forest habitat. The 

intent of such burns may be to reduce density or abundance of this vegetation type to encourage 

coastal scrub development, or may be to enhance the ecological health of the hardwood plant 

communities. Unique, site-specific burn prescriptions and timing would be required to meet 

these differing objectives. 

Monterey Pine/Monterey Cypress 

Monterey pine would be treated by prescribed burning in Estero and Limantour Road FMUs as it 

is in Alternative A. 

Riparian Woodland 

No prescribed burning would take place in riparian woodland in any alternative. 

Coastal Scrub 

In addition to continuing and expanding the use of fire to control non-native broom and other 

species in coastal scrub, prescribed burns would take place in several FMUs to either reduce 

fuels or achieve resource objectives. There also may be incidental benefits to coastal scrub and to 

grasslands where scrub is encroaching through prescribed fires primarily intended to reduce 

fuels. 
285 

Coastal scrub is largely fire-dependent, with prominent shrubs establishing by seed and by 

sprouting. It is a flammable vegetation type that may burn again 1 to 2 years after fire if dry 

conditions exist. With fire in less than 5-year intervals, or with overgrazing, coastal scrub 

generally reverts to annual non-native grassland. Fire exclusion in coastal sage scrub and mesic 

chaparral communities allows coast live oak, California bay, and other shade tolerant species to 

increase in density and reduce understory diversity and abundance. 

Fire exclusion in coastal prairie allows coyote brush establishment, with best establishment in 

wet years. Complete conversion of purple needlegrass tussock grassland to coyote brush/ripgut 

brome stands has been observed with 24 years of fire exclusion. Coyote brush forms a closed 

canopy in about 2 to 3 years after invasion. 

As noted in cumulative impacts, the dominant species in coastal scrub in the project area is 

coyote brush. This species sprouts from its root crown and roots after above ground vegetation is 

killed by fire. Sprouting ability lessens when it is reburned. 

In this alternative, coastal scrub in the Palomarin FMU would be burned to remove encroaching 

Douglas-fir and to maintain habitat for birds around the Point Reyes Bird Observatory. Burns 

would be less than 50 acres and effects would be monitored to determine if benefits of prescribed 

burning warrant a wider scale application. Douglas-fir trees less than 10” dbh would be cut 

before the area is burned to reduce risk of fire spread and to increase Douglas-fir mortality. 

Small prescribed burns in the Limantour Road corridor to reduce fuel accumulations in coastal 

scrub could have secondary resource benefits. Prescribed burns in the southernmost portion of 

Bolinas Ridge FMU in coastal chaparral and mixed scrub habitat to reduce fuels also would help 

stimulate reproduction in the rare, fire adapted species Marin manzanita and Mason’s ceanothus. 

In addition to minor to moderate benefits to this community from removing Scotch and French 

broom, additional minor benefits to coastal scrub health and reproductive rates are likely due to 

pilot burns at Palomarin and the use of prescribed fire to reduce fuels. 

Mitigation Measures

Small pilot burns (> 50 acres) would be conducted in coastal scrub. These burns would be 

carefully monitored to ensure burn objectives (= recruitment and long-term maintenance of 

native species without introduction of invasive non-native plant species) are being met. If pilot 

projects determine objectives can be met using prescribed fire, individual burn size would 

increase to a maximum of 200 acres. 

Grassland 

Prescribed burns and mechanical treatments would occur in grasslands in numerous FMUs under 

Alternative B. In Limantour Road FMU, additional burning specifically to reduce fuels in 

grasslands would take place along the road corridor and around developed areas in the park. The 

same is true of Highway One FMU. Grasslands and shrublands along Bolinas Ridge and in 

grasslands along the Bolinas Ridge Fire Road would be burned to reduce fuels. Treatments 

would occur primarily along road edges, and around structures to reduce fire hazard. 
286 

As noted in Alternative A, prescribed burning in grasslands must be precise and monitored 

carefully to achieve desired results as non-native grasses are sometimes favored by fire. For 

example, while a combination of prescribed fire and mowing has been successful in removing 

Scotch broom from some grassland communities, prescribed burning of the highly invasive 

purple velvet grass may be increasing its abundance. Monitoring and adaptive management (e.g., 

changing the prescription if non-natives are not destroyed) are mitigation measures that would be 

used to minimize potential adverse effects of prescribed burning in grasslands. 

Mitigation Measures

All grassland burns would be carefully monitored to ensure burn objectives (= recruitment and 

long-term maintenance of native species without introduction of invasive non-native plant 

species) are being met. 

To enhance grassland plant species composition, and reduce the chance of invasion or spread of 

non-native species, native seeding trials would be conducted following fire management 

treatments in some areas. 

Impacts of these activities on vegetation are expected to be adverse, negligible to minor, and 

short- to long-term if non-native species expand in density or aerial extent as a result of 

treatments. Beneficial, minor to moderate, long-term impacts to vegetation would occur in some 

areas of grassland habitat as stands of Scotch or French broom are reduced. 

Pasture 

Under this alternative, small areas supporting the non-native species Scotch broom, French 

broom, or Monterey pine within pasture may be burned or mowed to reduce the density and 

aerial extent of these invasive species. Impacts associated with these efforts would be beneficial, 

minor to moderate, and long-term as a result of removal of invasive non-native plants. For these 

beneficial impacts to persist, however, follow-up activities must be conducted to remove new 

recruits that come into the sites in years following prescribed burning or mechanical treatments. 

Adverse, minor, short- to long-term impacts also could occur as a result of application of fire 

management activities if other non-native invasive plant species invade or spread on treated sites. 

Unplanned Ignitions, Wildland Fire, and Suppression 

The impacts described above from average wildland fire and suppression for Alternative A 

would be true of this alternative as well. 

Mechanical Treatment 

Alternative B would treat twice as many acres as Alternative A with mechanical means, and 

would add mechanical treatment in the following FMUs: Tomales Point, Inverness Ridge, 

Wilderness North and South and Palomarin. As in Alternative A, the focus of mechanical 

treatment would be to control non-native species and reduce fuels. In addition, mechanical 

treatment would be used where reduction of fuel could help firefighters slow or stop the spread 

of fires in the event of an unplanned ignition, such as along Inverness Ridge. 
287 

Bishop pine 

In addition to the mechanical treatment identified in Alternative A, concentrations of fuels would 

be reduced by limbing bishop pine along primary roads and along secondary fire roads. A 3 mile 

long fuel break in Inverness FMU also may result in some removal of Bishop pine. The fuel 

break would be 50-60 feet wide. Within it, dead and downed woody debris would be reduced by 

60%, trees would be limbed up to 10 feet in height, trees up to 4 inches in diameter would be 

thinned and brush would be cut in a mosaic pattern to break up fuel continuity. The creation of 

the fuel break could mean a reduction in the risk of a catastrophic fire spreading. It also may 

provide minor benefits to Bishop pine by opening the canopy to sunlight and promoting the 

opening of this species’ cones 

Douglas-fir/Coast redwood 

Under this alternative, thinning of Douglas-fir/coast redwood would take place along the sides of 

roads, including Limantour Road and Highway One. Trees less than four inches in diameter 

would be removed from a corridor 10-15 feet wide on each side of the road, and larger trees 

would be limbed up to a height of 10 feet. This would help to create a corridor of defensible 

space along these roads. Douglas-fir/redwood forests also would be subject to mechanical 

thinning prior to prescribed burning in Wilderness North and Wilderness South FMUs to 

increase the ability to control prescribed and wildland fire. Mechanical treatments are expected 

to cause beneficial, minor to major (depending on the number of acres treated) long-term impacts 

as a result of improved forest health and reduced risk of large-scale unplanned catastrophic 

wildland fire. 

Monterey pine/Monterey cypress 

Both Monterey pine and Monterey cypress would be treated by mechanical means in Alternative 

B. Monterey pine would be cut and the stumps treated with herbicide in both Estero and 

Limantour FMUs. Monterey cypress would be cut and stump treated in Tomales Point and 

Estero FMUs. Because the distribution of both species is limited, this approach of treating 

individual trees could substantially reduce their extent, and impacts to native vegetation could be 

minor to moderate, long-term and beneficial. For these beneficial impacts to persist, however, 

follow-up activities must be conducted to remove new recruits that come into the site in years 

following mechanical treatments. 

Hardwood Forest 

Thinning along roadsides would continue in Alternative B as it does in Alternative A, and some 

hardwood species would be removed or limbed. Alternative B would also target non-native 

eucalyptus for mechanical removal in several FMUs. 

Eucalyptus forests in the park are dominated by the non-native blue gum eucalyptus, which has 

been planted and has encroached on native plant communities. Eucalyptus is usually highly 

dominant in the canopy. Monterey pine, Monterey cypress, or individual Douglas-fir, California 

bay, or coast live oak also may be present. Understory vegetation usually is sparse, often 

including remnants of the native community, because eucalyptus creates a deep litter containing 

chemicals that discourage growth of other species. Poison oak and non-native or native berries 

(e.g., Rubus spp.) are common shrubs. Other non-native shrubs and herbs often are present with 
288 

low cover. The floor of eucalyptus forests is characterized by a thick layer of eucalyptus litter 

comprised of bark, seedpods, leaves, and branches. 

The combination of thick litter, hanging strips of bark, and volatile chemicals in the wood and 

litter of eucalyptus mean a fire in these forests is highly likely to burn hot and reach the crown. 

Fire does not kill adult trees, but does open seedpods and prepare the seedbed, enhancing 

regeneration. As noted above, it is the policy of the NPS to promote native species and remove 

non-native plants and animals as parks are able to do so. In Alternative B, eucalyptus stands in 

Tomales Point, Estero, and Highway One would be targeted for thinning or removal, with larger 

trees stumps treated with herbicides to prevent resprouting. Mechanical removal of individual 

eucalyptus trees could have minor to moderate benefits for native vegetation. 

Table 51. Eucalyptus Acreage occurring within Fire Management Units. 

Fire Management Unit Alternative A Alternative B Alternative C 

Tomales Point 17 17 

Headlands 

Estero 11 11 11 

Inverness Ridge 

Limantour Road 14 14 14 

Wilderness North 3 3 

Wilderness South 

Highway One 94 94 94 

Bolinas Ridge 

Palomarin 26 26 

 

Totals 119 165 165 

 

Riparian Woodland 

No mechanical treatment would occur in riparian woodland in any alternative. 

Coastal Scrub 

Impacts from mechanical treatment of coastal scrub would be the same as described for 

Alternative A. Mowing to target Scotch and French broom would continue and expand, with 

possible moderate or even major beneficial impacts to native coastal scrub species. 

Grassland 

Scotch and French broom also occur in grasslands, where mechanical treatment by mowing 

would be used to help control the spread of these species. Possible moderate benefits to 

grasslands would occur from their removal. 

Pasture 

As noted above, treatment would generally not occur in pasture, although some mowing of 

Scotch and French broom is possible with minor or moderate benefits. 
289 

Coastal Dune 

Coastal dunes occur in the Tomales Point FMU. These dunes are largely dominated by the nonnatives plants European beachgrass and iceplant. The Seashore is undergoing a large-scale dune 

restoration program that involves manual and mechanical removal of European beachgrass. 

Mechanical removal of this non-native would have minor beneficial effects on native dune 

species. 

Fire Information/Education 

Same as Alternative A. 

Fire Cache/Park Headquarters Relocation and Construction 

Same as Alternative A. 

Fire Effects and Fuel Management Research 

Alternative B includes the use of pilot burns in Douglas-fir and coastal scrub communities to 

determine effects in promoting native species and reducing or removing fuels and non-native 

species. In Bolinas Ridge FMU, the effects of prescribed burning on native plant species richness 

would be explored, and in Palomarin FMU, the effects on birds would be assessed. If effects are 

beneficial, and such treatments are later applied to large areas of the park, widespread minor to 

major benefits to vegetation could result. 

Cumulative Impacts 

The risk of unplanned wildland fire would be slightly less under Alternative B (as compared to 

Alternative A) as mechanical treatments and prescribed burning would be designed and 

implemented to reduce such risk. However, the impacts described above for Alternative A would 

be the same for this alternative, with short- to long-term, major adverse impacts to vegetation 

possible. 

Conclusion 

Similar impacts to those for Alternative A from prescribed burning would occur in Monterey 

pine forests and pasture. Minor to moderate benefits from prescribed burning in hardwood 

forests are possible. Pilot burns in Douglas-fir forests could provide minor benefits by removing 

ladder fuels and debris and stimulating reproduction. Removal of non-native Monterey pine trees 

in Estero and Limantour Road FMU would have a localized minor to moderate long-term 

beneficial impact to native vegetation, but minor adverse impacts could also occur from burning 

if non-native species increase their aerial extent. Continued treatment of non-native Scotch 

broom may provide minor to moderate benefits to coastal scrub and grassland habitat if applied 

throughout the area where it occurs. Additional minor benefits to coastal scrub from prescribed 

burning to increase native species richness would occur in Palomarin and Bolinas Ridge FMUs. 

Prescribed burns and mechanical treatments in grasslands could have beneficial or adverse 
290 

impacts, as results are highly variable. Monitoring and adaptive management would keep these 

impacts from becoming more than minor if they are adverse. 

Average unplanned wildfires and their suppression could have minor, short-term adverse or 

beneficial impacts on vegetation. Benefits may result from stimulation of fire dependent native 

species, or from the destruction of non-natives. Adverse impacts come from the loss of native 

species, as well as from crushing, removal or other physical impacts of suppression. 

Mechanical fuel reduction in Bishop pine, Douglas-fir and hardwood forests would result in 

negligible to minor, short-term adverse impacts. Addition minor long-term beneficial or adverse 

impacts from the removal of several acres of bishop pine to create a fuel break in Inverness FMU 

would occur. Localized minor to moderate long-term benefits to native vegetation would result 

from the mechanical removal of Monterey pine in Estero and Limantour Road FMUs, of 

Monterey Cypress from Tomales Point and Estero FMUs, and of eucalyptus from Tomales Point, 

Estero, and Highway One FMUs. Moderate to major benefits to coastal scrub, grasslands, and 

pasture from the continued removal of Scotch broom and French broom would result from the 

combination of mechanical mowing and prescribed burning techniques. The continuation of 

research and wide application of its results would increase these benefits over a wider geographic 

area. 

The risk of a large wildfire, and its likely extent should it occur, would be less under Alternative 

B, as compared to Alternative A, especially after several years of treatment have taken place. In 

some native vegetation communities, such as Bishop pine or hardwood forest, large-scale fire 

could be beneficial by eliminating non-native species or otherwise creating conditions favoring 

the spread of native plants. In others, such as Douglas-fir/coast redwood forests, hot crown fires 

can destroy the native seed source over a large area, making re-establishment difficult. Riparian 

areas also may experience major adverse impacts from very intense fires due to destruction of 

seed source or root crown. The effect of a wildland fire in coastal scrub or grassland is more 

complex and less well understood, as some native and non-native species are benefited and some 

are adversely affected. Overall, the cumulative effects of a large-scale fire and all other activities 

such as development, historic logging, disease and the introduction of non-native plant species 

have and would continue to have major, long-term adverse impacts on native vegetation 

communities in the park. 

No impairment to vegetation would result from this alternative. 

Alternative C 

Alternative C would include all activities as described above for Alternative B, and would 

include prescribed burning on an additional 1000 acres per year (to total 2000 acres of prescribed 

burning) and would include mechanical treatment on up to 1500 acres per year. In addition to 

more treatment to reduce fuels and increase the ability to fight wildfires, under Alternative C, the 

Seashore would use fire and mechanical means to enhance the condition of natural and cultural 

resources. Some treatment of natural resources would involve the widespread attempt to 

eliminate non-native species, but treatment to improve species richness and wildlife habitat also 
291 

would occur. Alternative C is the only alternative to use prescribed fire in Tomales Point and 

Headlands FMUs. 

Analysis 

Prescribed Fire 

Bishop Pine Forest 

The same treatment and resulting impacts of incidental use of prescribed fire in Bishop Pine as 

described in Alternative B are expected. However, additional research would be conducted to 

determine the effects of burning on Bishop pine populations and associated plant species, as well 

as on dusky-footed woodrats (Northern Spotted Owl prey species) and on Point Reyes mountain 

beavers. 

Douglas-fir/Coast Redwood Forest 

Additional pilot burns in Douglas-fir/coast redwood forests may be conducted in this alternative, 

with resulting benefits from reductions in ladder fuels and increased reproductive response. 

Eventually, fire would be reintroduced to Douglas-fir forests in some FMUs (Wilderness North 

and Wilderness South), returning a natural environmental process that has been lost or altered for 

at least a century. The benefits to these stands of Douglas-fir/coast redwood could be major and 

long-term, depending on the aerial extent of treatment. 

Hardwood Forest 

Prescribed burning could occur in hardwood forests in nine of the ten FMUs subject to 

treatments under Alternative C (the remaining FMU - Headlands - does not support these forest 

types). Because eucalyptus is a non-native hardwood species highly adapted to fire, treatments 

would include consideration of eucalyptus ecology and whether or not treatment would cause it 

to spread. In both this alternative and in Alternative B, eucalyptus would be mechanically 

thinned or removed for this reason. Because other California hardwood species are also fireadapted, removing exotics mechanically and then burning would result in beneficial, moderate to 

major (depending on the number of acres treated) effects. Beneficial impacts under Alternative 

C would be greater than under Alternative B because twice the acreage could be treated. 

Monterey Pine/Monterey Cypress 

Both Monterey pine and Monterey cypress would be subject to prescribed burning in Alternative 

C. Monterey cypress (see Alternative A for information on Monterey pine) is fire-adapted in that 

its cones require heat to open, but it is capable of establishing seedlings with or without crown 

fire. In California, late summer or early fall fires are followed by winter rains. These provide 

exposed mineral soil for seeds and moist conditions ideal for germination. Although some larger 

Monterey cypress adults may survive fire, the majority of wildfires would kill most individuals. 

The frequency of fire is important in managing non-native Monterey cypress. If groves are 

burned with prescribed fire often, reproduction could be eliminated, as remaining trees would be 

unable to mature and produce cones. Fire followed by intensive grazing also could eliminate a 

cypress grove. Prescribed burning of Monterey cypress would occur in Estero FMU, and could 

have a minor to moderate benefit on native vegetation in areas where this species now 

dominates. 
292 

Coastal Scrub 

In addition to the impacts described above for Alternative B, this alternative includes small 

prescribed burns in the Tomales Point FMU to determine the response of plant communities, 

including plant species of special concern. 

Grassland 

In addition to the use of fire as described in Alternatives A and B, small prescribed burns in 

grasslands in Tomales Point and Headlands FMUs would occur in Alternative C. In Tomales 

Point, fire would be applied based on previous research results in other California grasslands to 

encourage a larger proportion of native species to become established. In Headlands FMU, pilot 

burns on velvet grass would be conducted to determine if burning will reduce the aerial extent 

and density of this species. As in other alternatives, the prescriptions would be fine-tuned in 

grasslands to ensure native species are favored. Minor to moderate benefits from these pilot 

burns are possible if they are successful and applied widely. 

Mitigation Measures 

In the Tomales Point FMU, small pilot burns (less than 100 acres) would be conducted in 

grassland to determine plant community response. These burns would be carefully monitored to 

ensure burn objectives (= recruitment and long-term maintenance of native species without 

introduction of invasive non-native plant species) are being met. If pilot projects determine 

objectives can be met using prescribed fire, individual burn size would increase to a maximum of 

150 acres. 

Pasture 

Impacts would be similar to those described above for Alternative B. 

Coastal Dune 

Coastal dunes cover a small number of acres in the FMUs slated for treatment, primarily in the 

Headlands FMU, and to a lesser degree in the Tomales Point FMU. These dunes are largely 

dominated by the non-native plants European beachgrass and iceplant. The Seashore is 

undergoing a large-scale dune restoration program that involves manual and mechanical removal 

of European beachgrass, and piles of beachgrass that have been pulled may be burned. Because 

they are non-native, removing these species through burning would be beneficial, minor, and 

long-term. 

Unplanned Ignitions, Wildfire, and Suppression 

The impacts described above from average wildland fire and suppression for Alternative A 

would be true of this alternative as well. 

Mechanical Treatment 

Alternative C would treat three times as many acres as Alternative A with mechanical means, 

and would treat more acres within the same FMUs as Alternative B. The focus of mechanical 

treatment would be the same as in Alternative B, and the reasons for mechanical treatment would 
293 

remain virtually the same as in Alternative B. Only the extent of treatment would change. 

Because of this, vegetation types are not analyzed individually in Alternative C. 

Fire Information/Education 

Same as Alternative A. 

Fire Cache/Park Headquarters Relocation, and Construction 

Same as Alternative A. 

Fire Effects and Fuel Management Research 

Under Alternative C, the fire management program would be guided to a greater degree than in 

other alternatives by the results of research on the ecological effects of fire and mechanical 

treatments. Ongoing research on Scotch broom, velvet grass, and rare chaparral plants would 

continue, and research on the effects of prescribed burning would expand into additional habitat 

types, including coastal grassland, Douglas-fir forest, riparian woodland, and Bishop pine forest. 

If the results of these studies are ecologically favorable (e.g., lead to increased native species 

richness, create areas supporting a variety of age classes within habitat types, and/or result in 

increases in rare species abundance or distribution) additional prescribed burning would occur in 

subsequent years in those habitat types. 

Under this alternative, the research program also would be expanded to include studies on the 

effects of mechanical fuels treatments on ecological parameters. Vegetation would be 

selectively removed from within Douglas-fir forests and in shrub-dominated habitats such as 

coastal scrub and chaparral to determine the effects of such removal on physical and biological 

elements (e.g., soils, selected plant species). 

Cumulative Impacts 

The risk of unplanned wildland fire would be moderately reduced under Alternative C (as 

compared to Alternative A) as mechanical treatments and prescribed burning would be designed 

and implemented to reduce such risk. However, the types of impacts described for Alternative A 

would be the same for this alternative should a wildfire occur, with short- to long-term, major 

adverse impacts to vegetation possible. 

Conclusion 

In the FMUs treated with prescribed fire, minor, short-term adverse impacts associated with loss 

of vegetation, and the possibility of introduction or spread of non-native plants could be greater 

than under other alternatives. However, the burns also would result in minor to moderate 

beneficial impacts as burns would stimulate growth of many native plant species, and would kill 

non-native vegetation. Although they would remain moderate, the potential for beneficial effects 

from Alternative C are greater than Alternative A or Alternative B because 2000 acres would be 

treated. 
294 

Mechanical fuel reduction would have minor short-term adverse impacts on native vegetation 

through crushing or other physical impacts, but clearing of dense vegetation also would have 

possibly long-term, minor to moderate benefits on most plant communities as well. The effects 

would be greater under this alternative than under Alternative A or Alternative B because more 

acres would be treated. 

All of the beneficial impacts for prescribed burning and mechanical treatment described for 

specific vegetation types in Alternative B also would occur in this alternative. These include 

minor benefits to Douglas-fir forests by removing ladder fuels and debris and stimulating 

reproduction, minor to moderate benefits from removal of Monterey pine and Monterey cypress 

through prescribed burning and mechanical means, minor to major benefits to coastal scrub and 

grassland habitat from the removal of Scotch and French broom, and minor benefits to coastal 

scrub from prescribed burning to increase native species richness. Additional possibly major 

benefits to Douglas-fir forests from the return of natural fire intervals following treatment with 

prescribed burning are likely, and minor benefits to coastal dune vegetation from the burning of 

non-native beachgrass is possible. 

Average unplanned wildfires and their suppression could have minor, short-term adverse or 

beneficial impacts on vegetation. Benefits may result from stimulation of fire dependent native 

species, or from the destruction of non-natives. Adverse impacts come from the loss of native 

species, as well as from crushing, removal or other physical impacts of suppression. 

Adverse and beneficial impacts from mechanical treatment would be very similar to those in 

Alternative B. These include negligible to minor short-term impacts to forest vegetation from 

killing individuals, balanced with minor to moderate beneficial impacts associated with fuel 

reduction and thinning; localized minor to moderate long-term benefits to native vegetation from 

the mechanical removal of Monterey pine, Monterey cypress and eucalyptus; and moderate to 

major benefits to coastal scrub, grasslands, and pasture from the continued removal of Scotch 

broom and French broom. The continuation of research and wide application of its results would 

increase these benefits over a wider geographic area. 

The risk of a large wildfire, and its likely extent should it occur, would be reduced under 

Alternative C (compared to Alternative A), especially after several years of treatment have taken 

place. In some native vegetation communities, such as Bishop pine or hardwood forest, largescale fire could be beneficial by eliminating non-native species or otherwise creating conditions 

favoring the spread of native plants. In others, such as Douglas-fir/coast redwood forests, fires 

could either have substantial beneficial effects or hot crown fires could destroy the seed source 

over a large area, making re-establishment difficult. Riparian areas may also experience major 

adverse impacts from hot fires from the destruction of seed source or root crown. The effect of a 

wildland fire in coastal scrub or grassland is more complex and less well understood, as some 

native and non-native species are benefited and some are adversely affected. Overall, the 

cumulative effects of a large-scale fire and all other activities such as development, historic 

logging, disease, and the introduction of exotics have and would continue to have major, longterm adverse impacts on native vegetation communities in the park. 
295 

No long-term impairment to vegetation would result from this alternative. 

IMPACTS TO WETLANDS 

Alternative A 

Analysis 

Impacts to wetlands associated with fire management activities are similar in many respects to 

impacts described in the preceding sections on soils and vegetation. Impacts on wetland sites, 

however, can differ from impacts on upland sites because wetlands usually have a higher level of 

soil moisture and denser vegetation cover than non-wetlands, which can result in variable 

impacts. These conditions can result in wetlands being more vulnerable to impact from certain 

activities. For example, fire suppression activities such as cutting handline or dozerline in 

wetlands can be very destructive if conducted when soils are wet. Although any site, either 

upland or wetland, can have high soil moisture at certain times of the year, it is more likely that 

wetland sites will be wetter year round, and therefore these sites require additional consideration, 

and different mitigation measures, to ensure their protection. Additionally, the higher level of 

legal protection that is afforded wetlands requires that additional care be taken to protect these 

sites. 

There is little literature available that describes the specific effects of fire on wetland ecosystems, 

particularly for wetlands in the western United States. This lack of information is discussed by 

researchers with the United States Geological Survey Northern Prairie Wildlife Research Center, 

who compiled the web-based “Fire in North American Wetland Ecosystems and Fire-Wildlife 

Relations: An Annotated Bibliography.” In the Introduction to the bibliography, they state: 

“Surprisingly few papers have addressed aspects of fire-wetlands relations; fewer yet have had 

this subject as a major focus of investigation. In general, fire has been treated as one of a number 

of management tools appropriate for wetlands, with its major use that of eradication of 

undesirable vegetation. Unlike the literature on fire in terrestrial upland communities, however, 

specific fire prescriptions, knowledge of fire behavior under different fuel loadings and 

environmental conditions, and the detailed consequences of differing fire frequencies, fire 

intensities, and fire severities in wetlands are largely unknown.” 

Despite this lack of specific information, as with all vegetation types, impacts of fire on wetlands 

are a function of 1) the severity of the fire itself, and 2) characteristics of the particular plants on 

the site. 

Two pieces of evidence suggest burning in wetlands has some benefits. First, the landscape of 

Point Reyes is one that has periodically burned over time (see Fire History in Affected 

Environment), and fires have included wetlands. Second, research of effects in wetlands shows 

that, if burned areas retain seed of native species in the soil, or if burns create a mosaic pattern 

with some surviving native vegetation or resprouting native vegetation, within a few years it can 

be difficult to determine that a fire recently occurred (Miller, 2000). It is also known that some 
296 

species of wetland plants are stimulated to reproduce through seed germination, and by sprouting 

from stems, roots or rhizomes following fires. 

Prescribed Fire 

Burn plans that include prescribed burning in wetland areas are subject to the conformance with 

additional regulations when applying to BAAQMD. In addition to the SMP and other 

submittals, Regulation 5, Section 410, Marsh Management Burn Requirements, asks for an 

evaluation of non-burning alternatives that could achieve land management objectives in keeping 

with resource management plans that apply to the project area. Regulation 5, Section 401.13 

includes more detailed guidance for planning prescribed burns that involve wetland acreage. 

This alternative would not specifically burn wetland areas with prescribed fire, although it would 

not include any measures specific to keep nearby burns from entering wetlands. Marsh and other 

wetlands occur in three of the four FMUs that could be receive prescribed burning (Estero, 

Limantour Road and Highway One). Prescribed fire would be used in these three FMUs to treat 

Scotch broom, French broom, and Monterey pine. These would be low to moderate intensity 

burns, which generally burn near or around moist wetland soils, rather than in the wetlands 

themselves. However, burning in grasslands to eradicate broom for example could result in some 

encroachment of non-native grasses or other plant species, which may also invade the adjacent 

wetland. If burns are prescribed in the summer or fall, when seasonal wetlands are dry, some 

impact from the loss of vegetation is possible. In dry years, prescribed fire may burn into 

perennial wetlands as well. These are possible minor adverse impacts, but the burns could also 

have minor to moderate beneficial impacts on wetland vegetation by stimulating growth and 

reproduction in native wetland species, and possibly by killing non-native species. 

Unplanned Ignition, Wildfire, and Suppression 

The potential impacts of wildland fire suppression on wetlands are similar to potential impacts of 

wildland fire suppression on other vegetation classes as described in the previous section 

(Impacts on Vegetation). Due to increased moisture levels often present in wetlands, however, 

such impacts can be more severe. 

Point Reyes has had an average of three unplanned fires annually, with each fire burning less 

than ten acres. As these are unplanned events, information on direct effects can only be obtained 

after the fire, and would involve documenting effects on resources for which little pre-burn data 

may exist. The impacts on wetlands associated with these small unplanned wildfires and their 

suppression are expected to be both adverse and beneficial. Adverse impacts are expected to be 

minor and short-term. It is possible that small invasions of non-native plants would result from 

these fires, which could result in a longer-term impact, but the impact would be localized. Small 

unplanned wildland fires in the project area may have some beneficial impact on wetlands in 

localized areas if non-native plants are killed, and native plants establish on the site following the 

fire. 
297 

Mechanical Treatment 

Up to 500 acres of mechanical treatment in Estero, Limantour Road, and Highway One FMUs 

would be conducted under this alternative. All of these FMUs have wetland acreage, although no 

treatment of wetlands specifically would take place. 

Mechanical treatments would avoid wetland areas to the greatest extent possible. If such 

treatments in wetlands were deemed necessary to ensure fire safety around structures or along 

roads, these treatments would have adverse impacts on vegetation. Some native vegetation would 

be killed or damaged, and treatments could result in localized introduction or spread of nonnative species. These impacts would be considered adverse, negligible to minor, and short-term. 

In some cases, clearing of dense vegetation could result in increased growth or establishment of 

native wetland species by creating gaps or openings in canopy cover, and could result in a 

decrease in non-native plants on treated sites. These impacts would be considered beneficial, 

minor, and short- to long-term. 

Fire Information/Education 

This would have no beneficial or adverse effects on wetlands. 

Fire Cache/Park Headquarters Relocation, and Construction 

The construction of a fire cache at Bear Valley would not have a beneficial or negative impact on 

wetlands. The building would be located at least 100 feet from the Bear Valley Creek riparian 

zone and temporary construction plastic fencing would be used to eliminate any impacts to 

resources in this zone. In addition, the site is a former trailer pad and nearly unvegetated and no 

wetlands are located on the construction site. 

Fire Effects and Fuel Management Research 

This would have no adverse effects on wetlands. Any post-treatment monitoring would have an 

indirect benefit by providing greater knowledge of the effects of prescribed fire and mechanical 

treatments on wetlands in the project area. 

Mitigation Measures

Burns would be allowed to back into and burn around wetlands and meadows or through them if 

the vegetation is dry enough to carry fire. Wetlands would be avoided to the greatest extent 

possible during fire confinement and containment. 

Fire suppression activities would not occur in wetlands unless there are no alternatives available 

to control the spread of a wildland fire. 

Fires near wetlands would be ignited when wetlands are too moist to sustain fire spread, thereby 

minimizing impacts to wetlands. 
298 

To the greatest extent possible, mechanical treatments would not occur in wetlands. 

Wetlands may be used as a natural boundary for prescribed fires. When a wetland area is being 

used as a boundary, line construction would occur in adjacent uplands, not in wetlands. 

Prescribed fires would not occur more frequently than the time required for native plant species 

to set seed. 

Foams or other fire retardants would not be used in or near wetlands. 

Firebreaks or firelines would be constructed in previously disturbed areas whenever possible. 

Chipped material would not be spread in wetlands. 

 

Cumulative Impacts 

Cumulative impacts to wetlands include pollution, runoff, encroachment of non-native species, 

and draining or deepening for development on land or of marinas. In the park, projects listed in 

Appendix C could have combined impacts on wetlands, but the chance of this is remote, since 

wetlands are protected by special legislation and NPS policies prohibit development within a 

wetland when other options are available. Therefore impacts to wetlands in the study area from 

all but a large wildfire, should it occur, are negligible or minor. 

Treatment of 1000 acres per year by prescribed fire and mechanical means to reduce fuel loads 

would have little effect in reducing the risk of a large wildfire, even over several years. Highseverity fires in Point Ryes such as the Vision Fire are characterized by extensive burned areas 

that may be continuous from ridgeline to slope bottom and include riparian areas and wetlands. 

The direct effects of high intensity wildland fires on wetlands can be substantial, including the 

destruction of both wetland vegetation and the seeds, roots, and rhizomes that would have 

allowed native species to repopulate. Over the long-term, permanent changes in plant species 

composition or percent cover, and the introduction or spread of non-native invasive plant species 

can result. Revegetation of wetlands could take many years. During extreme weather events, 

debris torrents would potentially scour streams, further delaying restoration of the riparian 

community and associated wetlands. Because non-native species also exist in the park, 

colonization of wetlands by these species or even habitat type conversions is possible with 

intense wildfires. 

Large, high-intensity fires also can cause ecosystem fragmentation, which can create barriers to 

wildlife movements and affect seed sources, nutrients, and plant distribution patterns in wetland 

communities. Loss of vegetation in a wetland can reduce the ability of the wetland to filter 

incoming surface water flows, resulting in changes in water quality; can lead to increased soil 

erosion in or near the wetland; and can cause an increase in water temperatures if the wetland 

supports open water. 
299 

Activities to suppress large wildland fires could have substantial, although localized, impacts if 

wetlands are treated with retardant, or if a fireline is constructed. Such activities would not occur 

in wetlands to the greatest extent possible. The actual extent and magnitude of impacts are 

impossible to predict, however, as these fires are unplanned. All of these impacts would be 

mitigated following a fire with assistance from the NPS Burned Area Emergency Rehabilitation 

(BAER) program. 

Overall, impacts to wetlands from a large wildfire could be major, long-term, and adverse. 

Conclusion 

Minor adverse impacts are possible from prescribed fires burning near and into wetlands in dry 

years. Minor to moderate benefits on wetland vegetation are possible if fire intensity is low to 

moderate due to reduction of non-native plant species or stimulation of germination and 

resprouting in native species. 

Minor adverse impacts from unplanned wildfires and their suppression could occur. Minor 

beneficial effects also could occur due to reduction of non-native plant species or stimulation of 

germination and resprouting in native species. 

Mechanical treatments would avoid wetland areas to the greatest extent possible. If such 

treatments in wetlands were deemed necessary to ensure fire safety around structures or along 

roads, these treatments would have negligible to minor adverse impacts on vegetation. Clearing 

vegetation also could have minor benefits to wetland species if native species establishment is 

enhanced. 

Cumulative impacts from development in the park may have a minor adverse impact on 

wetlands. However, a large-scale wildfire could have major, long-term, adverse impacts on 

wetlands from destruction of vegetation and reproductive ability, and invasion by non-native 

species. 

No long-term impairment to wetlands would result from this alternative. 

Alternative B 

Analysis 

Prescribed Fire 

Under Alternative B, up to 1000 acres per year would be treated using prescribed fire in the 

Estero, Inverness Ridge, Wilderness North, Wilderness South, Limantour Road, Highway One, 

Palomarin, and Bolinas Ridge FMUs. Wetlands are present in all of these FMUs except Bolinas 

Ridge, although no treatment directed at wetlands would occur. 

Wetland areas would generally be avoided and buffered from burns. However, if prescribed 

burns are allowed to burn into adjacent wetlands, minor impacts from killing wetland vegetation 
300 

occur. These would be offset by minor to moderate benefits from killing non-native species and 

from stimulating reproduction of many native plant species. The effect of Alternative B would 

be greater than Alternative A because 1000 acres would be treated. 

Unplanned Ignition, Wildfire, and Suppression 

Same as Alternative A. 

Mechanical Treatments 

Mechanical fuel reduction techniques would have both adverse and beneficial impacts on 

wetland vegetation. Some native vegetation would be killed or damaged, and treatments could 

result in localized introduction or spread of non-native species. These impacts would be 

considered adverse, short-term, and minor. The impacts would be minor because wetland areas 

would be avoid and buffered from mechanical treatments. In some cases, however, clearing of 

dense vegetation could result in increased growth or establishment of native and rare species. 

These impacts would be considered beneficial, possibly long-term, and minor to moderate. The 

effects would be greater under this alternative than under Alternative A because twice as many 

acres would be treated. 

Fire Information/Education 

Same as Alternative A. 

Fire Cache/Park Headquarters Relocation, and Construction 

Same as Alternative A. 

Fire Effects and Fuel Management Research 

Same as Alternative A. 

Cumulative Impacts 

Same as Alternative A. 

Conclusion 

Although wetland vegetation would be avoided and buffered from nearby prescribed burning or 

mechanical treatment for the most part, some of each of these treatments may take place for 

resource management or safety reasons. If so, minor localized adverse impacts from either to 

vegetation could occur from crushing, removal, or burning. However, minor to moderate benefits 

from killing non-native vegetation or stimulating reproduction is also possible. 
301 

Minor adverse impacts from unplanned wildfires and their suppression could occur. Minor 

beneficial effects also could occur due to reduction of non-native plant species or stimulation of 

germination and resprouting in native species. 

Cumulative impacts from development in the park may have a minor adverse impact on 

wetlands. However, a large-scale wildfire could have major, long-term adverse impacts to 

wetlands from destruction of vegetation and reproductive ability, and resulting invasion by nonnative species. This is true despite the reduced risk of such a fire related to fuel reduction 

activities across the project area in this alternative. 

No long-term impairment to wetlands would result from this alternative. 

Alternative C 

Analysis 

Prescribed Fire 

Under Alternative C, a total of 2000 acres per year would be treated using prescribed fire in all 

of the same FMUs as in Alternative B, and in Tomales Point and Headlands FMUs as well. 

Wetlands are present in all but the Bolinas Ridge FMU. 

Impacts would be similar to those described above for Alternatives A and B. Although adverse 

impacts may be greater than other alternatives, they would remain short-term and minor because 

wetlands are largely kept unburned and are buffered from nearby prescribed burns. Benefits from 

killing non-native plants or stimulating regrowth of natives would be minor to moderate as they 

are in Alternative B. 

Unplanned Ignition, Wildfire, and Suppression 

Same as Alternative A. 

Mechanical Treatments 

Adverse and beneficial impacts from mechanical treatment in this alternative would be similar to 

those described above for other alternatives. Minor adverse effects from killing or damaging 

wetland vegetation are possible but unlikely, and minor to moderate benefits from clearing dense 

vegetation and encouraging establishment of wetland vegetation may occur. The effects would 

be greater under this alternative than under Alternatives A and B because more acres would be 

treated. 

Fire Information/Education 

Same as Alternative A. 
302 

Fire Cache/Park Headquarters Relocation, and Construction 

Same as Alternative A. 

Fire Effects and Fuel Management Research 

Same as Alternative A. 

Cumulative Impacts 

Same as Alternative A. 

Conclusion 

Prescribed burns would have minor, short-term adverse impacts because fire would kill some 

wetland plant species, and could result in the introduction or spread of non-native vegetation. 

The effect of Alternative C would be greater than Alternatives A and B because 2000 acres 

would be treated. 

Minor adverse impacts from unplanned wildfires and their suppression could occur. Minor 

beneficial effects also could occur due to reduction of non-native plant species or stimulation of 

germination and resprouting in native species. 

Mechanical fuel reduction techniques would have both adverse and beneficial impacts on 

wetland vegetation. Some native vegetation would be killed or damaged, and treatments could 

result in localized introduction or spread of non-native species. These impacts would be 

considered adverse, short-term, and minor. 

Cumulative impacts from development in the park may have had a minor impact on wetlands. 

However, a large-scale wildfire could contribute major, long-term adverse impacts to wetlands 

from the destruction of vegetation and reproductive ability, and resulting invasion by non-native 

species. This is true despite a moderate reduction in risk of such a fire related to fuel reduction 

activities across the study area in this alternative. 

No long-term impairment to wetlands would result from this alternative. 

IMPACTS TO WILDLIFE 

Types of Impacts 

The types of impacts on wildlife caused by prescribed fire and small-scale wildland fire are 

similar. Quantifying or accurately predicting such effects is difficult because fire is inherently 

unpredictable. For example, fire intensity (which strongly influences the degree of impacts) 

varies substantially in response to season, wind, air temperature, relative humidity, composition 

of fuels, topography, and other parameters. Because of the inability to predict the nature of 
303 

wildland fires, this analysis of the effects of wildfire on wildlife is qualitative. The effects of 

prescribed burning on wildlife are somewhat more predictable and easier to mitigate through 

careful planning and implementation; nonetheless credible scientific data on such effects in the 

project area are scant. 

Generally, the effects of fire on wildlife depend on the characteristics of the fire itself (e.g., 

intensity, duration, frequency, size, shape, season, and time); the characteristics of the vegetation 

or habitat burned; and on species characteristics (e.g., size, mobility, habitat preferences). 

Modification of habitat, food, water sources, and cover would determine if a given species 

persists, thrives or declines in response to fire. Changes in vegetation structure and composition 

in the understory and overstory, as well as resultant changes in microclimates within and 

adjacent to burn units, will also affect wildlife species (McMahon and deCalesta, 1990). 

The types of impacts to wildlife can be direct or indirect. Direct impacts include incineration, 

asphyxiation, injury, or avoidance of an area, and are most often experienced by less mobile 

species of life stages. Wildlife may also experience indirect effects. For example, fish or aquatic 

invertebrates can be harmed by sedimentation in a creek due to post-fire soil erosion, or 

carnivores can suffer from reductions in the prey base as a result of either direct mortality of the 

prey, or a reduction in the food and cover resources used by the prey species. 

Habitat loss itself is a possible adverse indirect impact from fire, and can be short- or long-term. 

Changes in vegetation structure and composition, down and dead woody material, and snags that 

occur after the fire can all affect wildlife. In particular, the loss of down and dead woody 

material and snags during a prescribed burn remove essential structural habitat components for a 

variety of wildlife and reduces species diversity (McMahon and deCalesta, 1990). Depending on 

the season, a fire can also have adverse effects on a species’ nesting or reproductive success. The 

nature of the fire, e.g., its severity, patchiness, whether it is a crown or understory fire, etc., will 

also determine if ground-dwelling or canopy-dwelling species are affected. If wildland fires 

burn extensive areas, and/or the fire is of high intensity, entire populations or subpopulations of 

wildlife can be affected. 

Wildlife can also benefit from fire. For instance, populations of species dependent on early seral 

stage vegetation increase following a burn. Vegetation that grows in the first 2-10 years after a 

burn often contains higher levels of nitrogen, which can cause increases in some herbivore 

populations. Decreased cover can improve the growth of forage and can improve predator 

hunting success. Decreased parasite loads and increased dispersion in some species can diminish 

disease levels. Fire, depending on its severity, can either increase or decrease the availability of 

tree snags, which are used by many species for nesting, for shelter, and for foraging. 

Fires that are patchy - those that result in a mosaic of burned and unburned or lightly burned 

areas - will maintain more heterogeneous environments with broader faunal diversity than will 

larger-scale, high-intensity fires that burn over large areas. Hot, stand replacing fires, which 

become more likely with increased fuel loads, will have entirely different impacts on the 

landscape and the fauna within it than will patchy or less intense fires. Intense hot fires can type 

change the vegetation, e.g., a forest to brush/grassland change after a severe fire can have a longterm adverse impact on fauna that thrive in dense forest habitat. Patchy low intensity fires do not 
304 

dramatically alter landscapes and remaining unburned vegetation provides habitat for existing 

species and impacts are relatively minor and short-term. Lack of fire and the resultant late seral 

stage vegetation will encourage species that thrive in such environments (see subsections on each 

class of wildlife below) at the expense of species favoring early or mid-seral habitats. Evidence 

suggests that maintenance of a variety of successional stages with patchy fire patterns ensures the 

highest levels of wildlife biodiversity (Nichols and Menke, 1984). 

Invertebrates, Amphibians, and Reptiles 

Direct lethal effects of fire on wildlife, in which animals are destroyed by incineration or 

asphyxiation are generally considered to be limited to smaller, relatively immobile species. In the 

Seashore, less mobile species include invertebrates, amphibians, and reptiles include the federal 

threatened red-legged frog. While most invertebrates that live in the surface soil layers and 

invertebrate eggs are likely to be killed by fire, some, including ants and flying surface insects, 

may increase in numbers after a fire. Fire may injure trees and encourage decay, attracting a 

variety of wood-boring insects that in turn attract insectivorous birds, such as woodpeckers. 

Because amphibians and their eggs have evolved in moist environments and often require forest 

debris as habitat, fire impacts are a consequence of loss of litter and changes in water quality. 

Reptiles that occupy heat refugia during the day are usually not directly affected by fire. Along 

with reptiles, most amphibian populations show little response to mixed severity understory fires 

although species favoring open habitats are clearly favored in the first few years after a fire, 

before understory and shrub vegetation regenerates (USDA, 2000). The park has 28 species of 

reptiles and amphibians; however because the limited number of acres treated (500 acres 

prescribed burns; 500 acres of mechanical treatment under alternative A, the effect of the overall 

impact would be adverse, minor, and short-term. The impact to amphibians would be minor 

because effects would be localized and not burning riparian areas will provide protection zones, 

and impacts would be short-term because populations are expected to rebound within two years. 

Fisheries and Aquatic Species 

For fish, the primary concerns relative to fire are increases in water temperature and sediment, 

and the long-term loss of woody debris from stream channels. The most long-lasting and severe 

effects on fish habitat from fire occur when it is associated with the loss of streamside forest 

(McMahon and deCalesta, 1990). Of concern are the effects of burning in or near headwater 

channels that facilitate the transport of sediment and debris downslope into fish-bearing streams 

when stream networks expand during periods of high runoff. 

Fire may affect the abundance and diversity of fish habitat and populations in streams by 

affecting the composition and structure of riparian vegetation and influencing water quality and 

quantity in a stream (McMahon and deCalesta, 1990). Loss of riparian vegetation can lead to 

elevated water temperatures, reducing the ability of the water to hold dissolved oxygen. The 

most susceptible species to these potential impacts are the federally listed coho salmon and 

steelhead trout. However, stream buffers of 100 feet would be left along creek areas to ensure 

impacts are mitigated to an acceptable level. 
305 

Birds 

Because they are mobile, birds are usually affected only by changes in habitat following a fire, 

except during the nesting season, March 15 through July 15. Fire in California shrublands and 

forests have been shown to maintain or increase avian species diversity but to alter species 

composition. Some species, such as California quail, Swainson’s thrush, scrub jay, and certain 

owls (northern spotted owl, see below) are known to decline in the first few years after fire 

(Lawrence, 1966, Lyon and Marzluff, 1985). Other species such as raptors, woodpeckers, and 

other owl species (burrowing, western screech) have been shown to increase in numbers after 

fires (USDA, 2000). Species adapted to early seral stages would clearly be favored. Ground - 

dwelling birds in the park such as California quail, northern harrier, and savannah sparrow -

would be short-term negatively impacted by most fires while canopy-nesters such as red-tailed 

hawks, white-tailed kites, sparrow hawks, and ravens - would be negatively affected only by 

crown fires. Because prescribed burns are conducted primarily after the nesting season and 

regrowth occurs within months these impacts should be short-term and minor. Because snags 

are such an important determinant of avian diversity and abundance, the variable consequences 

of fire intensity and patterns on snag numbers would result in variable persistence of cavity 

nesters and those species which feed on wood-boring insects (USDA, 2000). 

Mammals 

Most mammals, because of their ability to escape the direct heat and smoke of fires, are only 

affected by the consequences of fire to vegetation, water and cover. During the first few growing 

seasons after a fire, improved vegetation growth usually provides increased food for herbivores 

(Ahlgren and Ahlgren, 1960). Reduced cover can provide increase risks for prey species, 

increased availability of seeds for small mammals and increased hunting opportunities for 

predators. Some species of rodents are known to decrease after stand-replacing fires, including 

the Western harvest mouse, brush mouse, and woodrat species (Schwilk and Keeley, 1998). 

Other species are known to increase after such fires including pocket gopher and deer mouse 

species (Sims and Buckner, 1973, Kaufman et al., 1988). Carnivores that depend on any of these 

impacted species would be similarly impacted. Ungulates often benefit from increased 

nutritional quality of recently burned vegetation, with positive impacts decreasing in five or more 

years post-burn. Fire may reduce disease rates in mammalian and avian populations by killing 

ground dwelling parasites and causing dispersion of individual animals, thereby reducing disease 

transmission (Peek et al., 1985). The park has 65 species of mammals from mountain lions, gray 

fox, brush rabbits, black-tailed deer, dusky-footed woodrats, deer mice, to pocket gophers and 

numerous species of bats. The majority of these species inhabit the four FMUs to be treated. 

Limantour FMU also has a small tule elk herd. Tule elk, brush rabbits, black-tailed deer, and 

other herbivores are expected to be positively impacted by fire and regrowth of vegetation. 

Dusky-footed woodrats, western harvest mouse shrews, and other small mammals are expected 

to have short-term impacts. Because the prescribed fires are cool, small areas that impacts are 

considered minor. 
306 

Alternative A 

Under this alternative, 500 acres of prescribed burning and approximately 500 acres of 

mechanical treatment would occur over an average year. Treatment would be conducted within 

the Estero, Limantour Road, Highway One, and Bolinas Ridge FMUs. The only impacts to 

Tomales Point, Headlands, Inverness Ridge, Wilderness North, Wilderness South, and Palomarin 

FMUs would be from those actions common to all alternatives, such as road maintenance. 

Analysis 

For purposes of this analysis, the term wildlife includes fish and other aquatic species. The four 

primary activities associated with implementation of Alternative A, prescribed fire, wildland fire, 

fire suppression, and mechanical treatments can have adverse or beneficial impacts on wildlife, 

and these impacts can be direct or indirect. Impacts to wildlife are discussed primarily in terms 

of impacts to individuals, because the scale of the actions proposed within the plan are small 

enough that it is very unlikely that any wildlife populations or sub-populations would be 

affected. It is important to note, however, that unplanned large-scale wildland fire can affect 

populations as well as individuals, and from an ecological perspective, impacts to populations or 

subpopulations are considered more important than impacts to individuals. 

Prescribed Fire 

The primary use of prescribed burning under this alternative would be to reduce fuel loads along 

major road corridors to minimize unplanned ignitions, and to control non-native Scotch and 

French broom, as well as Monterey pine. No acreage would be burned to benefit wildlife, 

although in some cases burning may offer secondary benefits to wildlife. As noted above, fire 

can improve nutrient content of vegetation and restore habitat for some species of wildlife. It can 

also reduce the threat of catastrophic unplanned wildfire and the long-term destruction of 

habitat. Under Alternative A, prescribed fire would have beneficial, long-term, and minor 

impacts to some wildlife species from its effects in providing open or early seral stage habitat in 

areas of the Seashore most severely altered by fire suppression, and by continuing to reduce the 

risk of catastrophic fire, especially along roadways in the park. The benefits are no more than 

minor because the treated acreage would remain small, and would lie in large part along roadway 

corridors, where habitat is already disturbed by human activity and so is of lower quality for 

many species. Conversely, species that depend on down wood or dense forests, such as 

salamanders, some small mammals, and ground nesting birds would experience localized 

adverse impacts in the treated areas from displacement. Because only 500 acres would be burned 

and 500 acres are mechanically thinned, an abundant supply of down wood or more closed 

canopy woodlands would remain in the park, providing habitat for these species and preventing 

the impact to them of becoming more than negligible or minor and short-term. 

Prescribed fires would be started when conditions are favorable for their control. This is often in 

spring or fall, which is outside of the dry season when most natural fires occur. This would have 

an adverse effect on species of wildlife that are adapted to the natural timing of fires, for 

example, small mammals that hibernate in leaf litter. Also, high levels of fuel loading in some 
307 

areas of the Seashore may cause prescribed fires to burn at higher than natural intensities, even 

when fire prescriptions are designed to minimize intensity. Both the unnatural seasonality, and in 

some cases intensity, of prescribed fires could result in greater direct lethal impacts for immobile 

or hibernating species (USDA, 2000), such as invertebrates, amphibians or small mammals, than 

under a pre-European natural fire interval. Again, because the area treated is small, impacts to 

these species in the park would be no more than minor. 

The activities involved in controlling prescribed fires, such as hand line construction, snag 

removal, water drops, etc., can have short-term adverse effects on wildlife. Because they are 

similar to (but less intense than) activities associated with controlling unplanned ignitions, they 

are discussed below. 

Unplanned Ignitions, Wildfire, and Suppression 

Fire suppression activities, such as construction and use of staging areas, helispots, or spike 

camps; construction of firelines using hand tools or bulldozers; cutting of snags; and mop-up can 

have adverse effects on wildlife. Maintaining control of prescribed fires can also involve hand 

line construction, snag removal, water drops, and other actions, but such efforts are likely to be 

much less intense, and have less impact, than they would be during wildland fire suppression. 

Small species of mammals, reptiles, or amphibians can be injured or killed when vehicles are 

accessing sites or staging areas, or when bulldozers are constructing line. It is anticipated that in 

most cases these impacts would occur infrequently. Removal or trampling of vegetation in 

temporary staging areas used for suppression activities could adversely affect wildlife until 

vegetation in such areas regrows. Noise, dust, and light emanating from suppression staging 

areas could affect the use of surrounding habitats by wildlife. Spills of fuel, oil, hydraulic fluid, 

antifreeze, and other toxic chemicals at staging areas could affect wildlife, especially those in 

aquatic environments. Personnel at fire camps or on suppression crews could provide a source of 

human food to wildlife, resulting in conditioning of wildlife and in human/wildlife conflicts. 

These activities and the impacts they cause are discussed in greater detail below. 

Dropping water or retardants on fires from helicopter buckets could result in a variety of impacts 

to wildlife. Water removed from small water bodies could have temporary seasonal impacts on 

aquatic organisms by reducing the size of wet or wetland habitat, or more serious and possibly 

permanent impacts on the inhabitants if the pond is completely drained or dried prematurely. 

Transfer of water from one area to another can also have impacts to wildlife. For example, in the 

Sierra Nevada, chitrid fungus has been identified as a factor in the disappearance of mountain 

yellow-legged frog populations. Federal land management agencies in the region have expressed 

concern that helicopter buckets dipping in separate water bodies could add to the problem by 

spreading the fungus to currently non-infected populations of frogs. In Point Reyes, the use of 

several water bodies to fight a wildfire could result in the spread of non-native bullfrogs, which 

prey heavily on native frog species, or contribute to the spread of unknown pathogens or other 

exotic species. 
308 

The physical impact of a water drop could adversely affect individual animals through crushing. 

One advantage of water drops is in their use in some circumstances, instead of hand lines (“wetlining”) to control fire movement. This tactic would result in less impact to soil, forest litter, and 

vegetation than hand line construction and, therefore, would have less impact on wildlife, both in 

intensity and duration. Under Alternative A, the impact of water drops on wildlife would be 

adverse, long-term, and minor based upon possible impacts to aquatic ecosystems, especially in 

relation to amphibians. The potential impact is minor because the historic occurrence of 

unplanned ignitions has been only three per year and most do not involve water drops. However, 

if they did occur, the impact would be limited to a relatively small area. Water drops are not 

used in prescribed fire activities at the park. 

Retardant drops have the same potential for physical injury, but may also be toxic, particularly in 

aquatic habitats. Studies have shown that the ecological effects of retardant and fire Suppressant 

Forms can be adverse to algae, aquatic invertebrates, and fish (Hamilton et. al., 1996). The lowflying aircraft could also disturb wildlife. Under Alternative A, impact to wildlife from retardant 

drops is expected to be negligible, adverse, and short-term because of its limited application in 

the park, and protocols for its use designed to protect aquatic resources. 

 

Construction of helispots can result in the felling of trees and snags, which are potential wildlife 

habitat. Snags are especially important wildlife habitat. In addition, helicopter traffic would 

likely disturb wildlife, such as nesting raptors. Under Alternative A, the impact of helispots on 

wildlife is expected to be adverse, long-term, and minor, based upon their likely very limited use 

(if at all). With mitigation, limiting helispot construction and site helispots away from sensitive 

resources can reduce these impacts. 

Fire crews staying in spike camps can have an adverse effect on wildlife by allowing them access 

to human food. This would lead to wildlife becoming conditioned to human foods and could 

result in human-wildlife conflicts. In such cases, animals often must be killed to protect human 

safety. Presence of hand crews in more remote areas would introduce an element of disturbance, 

which could affect sensitive species, such as nesting raptors. Under Alternative A, impacts to 

wildlife from spike camps are expected to be adverse, short-term, and minor. However, placing 

site spike camps away from sensitive resources and providing strict control of availability of 

food to wildlife at camps can reduce these impacts. Since spike camps are rarely used for 

prescribed fire activities, impacts are going to be adverse, short-term, and negligible. 

Hand line construction would remove and disturb soil and forest litter, possibly affecting animals 

such as small mammals, amphibians, invertebrates, and ground-nesting birds. The presence of 

hand line crews in remote locations could cause direct disturbance of some wildlife species and 

introduce unnatural food sources (see spike camps above). Removal of forest litter and 

vegetation can also lead to soil erosion and increased siltation in adjacent lakes and streams. 

This could have an adverse effect on aquatic species, including invertebrates, amphibians, and 

fish. Impact of hand line construction in association with managed wildland fire and prescribed 

fire under Alternative A would be adverse, short-term, and negligible given the present limited 

amount of wildland fire and the limited use for prescribed fire (most line is cut by mowing only 

for prescribed fire). 
309 

Snags are an extremely valuable tree-form to some wildlife (Brown and Bright, 1997). They 

provide cavities and loose bark for nesting and roosting and food in the form of wood-boring 

insects. Any holding action that requires the felling of snags to protect human safety and the 

integrity of the fire line would potentially affect wildlife by reducing the availability of snags to 

species such as pileated woodpeckers and several bat species. Felling would likely kill some 

animals. The number of snags lost would vary, depending upon factors such as the type and age 

of tree stand, its history of fire and/or disease or insect infestation, and the intensity of the fire. 

Under Alternative A, snagging associated with holding actions for wildfires would potentially 

have minor, long-term, and adverse impacts because of the relatively small areas that would be 

affected (30 acres average per year). 

 

Mop-up, or the churning of soil and forest litter to extinguish residual hot spots along the 

periphery of a fire, would cause some mortality of buried organisms by exposing them to heat 

and flames. Such impact, however, would be along short sections of the lined perimeter and 

affect few species. Impact of mop-up would therefore be adverse, short-term, and negligible for 

both prescribed burn and wildfires. 

Mechanical Treatments 

Mechanical fuel reduction techniques, such as mowing or brush clearing, can have adverse 

impacts on wildlife. Local mechanical treatments may affect ground-dwelling or brush-dwelling 

species by direct mortality or injury to individuals or their eggs, or by altering cover and food 

sources. Brush clearing can also increase foraging opportunities for some herbivores and 

predators. 

 

Hand cutting of understory vegetation, down fuels, and small-diameter trees in the 

wildland/urban interface would have mixed effects on wildlife and habitat. Hand cutting trees 

and brush to attain target conditions provides a less woody and more natural habitat and helps 

reduce the threat of catastrophic fire; especially from human-caused ignitions that occur in 

developed areas. For a few species, such as ground and understory nesters and rodents, the loss 

of low-lying cover and more dense brush or small trees may have temporary impacts. However, 

other canopy nesters, avian predators, and several bat species would remain unaffected or benefit 

from a more open forest habitat. This type of habitat is less common in the park because of a 

history of fire suppression and fuel build-up. Creating more of it might result in species requiring 

this type of habitat moving into the thinned forests, with possible overall increases in species 

diversity in the area. Because no more than 500 acres per year are to be treated mechanically 

under Alternative A, the extent of adverse impacts to wildlife living in more densely wooded 

lands is likely to be negligible and short-term. If the same areas continue to be mechanically 

treated, the impact would be long-term. Negligible benefits would result to wildlife species 

requiring open habitats. Additional negligible benefits from a reduction in the risk of catastrophic 

fire in the treated area would also result from this alternative. 

Short-term adverse impacts to wildlife during hand-thinning and mowing operations include 

human presence and use of chainsaws and other tools during thinning operations. Chipping 

would have the same effects. These actions may disturb wildlife, although such disturbance 

would be short-lived and negligible. 
310 

When removed biomass cannot be burned on site or removed for logistical, administrative, or 

ecological reasons, it may be chipped and distributed over the site. When chips are spread 

deeply enough to affect the growth of native plants, wildlife would be adversely affected. Such 

impacts, however, would be limited to areas adjacent to roads and developed areas, and standard 

mitigation for chipping calls for chips to be spread as thinly as possible on the site - usually to a 

depth of not more than 1 inch. Impact to wildlife from chipping would therefore be negligible, 

adverse, and short-term 

Piling and burning of downed trees and shrubs may have an adverse effect on some wildlife. 

Some species, such as small rodents and reptiles, may take up residence in burn piles between 

the time they are stacked and the time they are burned; which can be several months. Many of 

these animals are likely to escape fire once the piles are ignited, but some may perish. 

Fire Information/Education 

Impacts associated with fire information and education would largely be indirect, beneficial, 

although highly dependent on the nature of the fire management action. Pre-planned events such 

as prescribed fires and mechanical treatment provide the opportunity to demonstrate the 

effectiveness of natural resource management to local communities and the interested public. 

During unplanned events, such as wildfires, time for effective communication is often more 

limited and can be more controversial since resources are often damaged. However, the effects 

of education usually do not have a direct effect - positive or negative - on impacts to wildlife. In 

some cases, education can be used to enforce a closure of an area to ensure wildlife quickly 

recovers. 

Fire Cache/Park Headquarters Relocation, and Construction 

The construction of a fire cache at Bear Valley would have no influence on the direct effects of 

fire management actions on wildlife. However, relocating fire management personnel to a more 

centralized location would allow for faster response time to natural resources in the event of 

wildfires. 

No adverse or beneficial indirect effects are anticipated with the construction of the new fire 

cache. The building site is in the main developed area of the park at Bear Valley and heavily 

impacted. The site is a former trailer pad that was recently removed. There may be some shortterm, adverse, negligible impacts to wildlife caused by noise during the construction. 

Fire Effects and Fuel Management Research 

No adverse or beneficial effects are anticipated on wildlife from the implementation of 

Alternative A research projects. 
311 

Cumulative Impacts 

Cumulative impacts to wildlife could occur from construction or compaction from activities 

described in Appendix C, or from a large-scale wild fire. When considered in combination with 

the minor to moderately adverse impacts of projects (except a large-scale fire) listed in Appendix 

C, the cumulative impacts from Alternative A would be adverse, short-term, and moderate. 

When the effects of a large-scale fire such as the 1995 Vision Fire and the high levels of fuel 

loading from lack of fire over the last 150 years, some areas in a large-scale wildfire may burn at 

higher than natural intensities. This could create extensive forest gaps, discontinuous habitat, 

and greater consumption of large woody debris than what would be expected under natural fire 

conditions. In addition, there would be a type conversion of habitat in some areas - forest to 

brush/grassland and some long-term loss of forest habitat. This change to habitat could have 

short-term major adverse impacts or long-term moderate impacts to wildlife in the burned area. 

For example, the Vision Fire had a major adverse effect on mountain beaver, but the population 

is slowing recovering (Fellers, 2003) 

Extensive burned areas that may be continuous from ridgeline to slope bottom and include 

riparian areas also characterize high-severity fires in Point Reyes. In addition, sediments loads 

would be expected to be at least twice the normal load under normal natural conditions 

(Ketcham, 2003). The sediment loads and lack of riparian vegetation would have adverse, 

moderate, long-term impacts (more than two years) to fish and aquatic species. However, 

vegetation would return in the long run, as it has following the 12,000+ acre Vision Fire, and 

erosion overland flow would return to rates within the natural rate of variability, preventing longterm impairment of park resources. 

In summary, suppression impacts from a large fire would be adverse, moderate, and long-term. 

Changes to habitat would have an adverse, long-term, moderate to major effect on wildlife, but 

negative effects would be reversed in the long-term. 

Conclusions 

Under Alternative A, prescribed fire would have a beneficial, short- or long-term minor impact 

on wildlife by creating more open habitat and reducing the risk of catastrophic fire. A similar 

adverse, short-term minor impact on species using existing down wood or dense forest habitat is 

also likely. 

Mechanical treatment would also offer short- to long-term negligible benefits to wildlife species 

requiring early seral stage habitat, and have adverse short- to long-term negligible impacts on 

some forest dwelling wildlife. The machinery used for chipping and shredding would be loud, 

which would have negligible, short-term impacts to some species, such as nesting birds, through 

disturbance. 

Some suppression activities or actions to control prescribed burns, such as spike camps, access or 

creating fire lines, would have short-term adverse and therefore minor impacts on wildlife. 

Others, such as creating helispots or the use of helicopter buckets of water or retardants, may 
312 

have longer lasting impacts. Overall, these activities are not expected to have more than minor 

impacts to wildlife. Actions to suppress large fires would likely be more intense, with short-term 

major or long-term moderate adverse impacts to wildlife. 

No impairment to park wildlife would occur from implementing Alternative A. 

Alternative B 

Analysis 

Prescribed Fire and Suppression 

In this alternative 1000 acres of prescribed burning would occur over an average year. As in 

Alternative A, the primary purpose of burning would be to reduce fuels and the chance of a 

catastrophic wildfire. Wildlife would therefore primarily be the recipient of secondary benefits 

related to the creating of early seral stage or more open habitat, which is now quite rare, or of a 

reduced risk of large-scale unplanned fires. However, Alternative B would also include some 

small-scale test burns in Douglas-fir and Bishop pine forests to determine the effects. This may 

later lead to larger-scale prescribed burns and improved habitat in these heretofore untreated 

areas, with additional benefits for wildlife native to these forests. In addition, Alternative B 

includes burning in the Palomarin fire management unit to control the encroachment of Douglasfir forest on what is now coastal scrub habitat in the Point Reyes Bird Observatory field station. 

This would help continue to maintain a mosaic of habitat for a variety of bird species, and should 

improve both habitat and species diversity, a moderate localized benefit to wildlife relative to 

Alternative A, but negligible or minor benefit relative to the entire study area. 

As in Alternative A, prescribed fire would have a beneficial, long-term, minor impact on wildlife 

compared to the entire study area because this action provides habitat improvement in areas 

where natural fire cycles have been severely restricted by fire suppression and some reduction in 

the risk of catastrophic fire. When compared to the entire study are, the effects are comparatively 

minor because benefits are limited by the relatively small number of acres (1000) treated. Also, 

because the burn units are dispersed throughout the park in the various FMUs (no concentration 

of impacts within a watershed and only 10% or any watershed would be treated annually), the 

total acres treated in relationship to the 90,000 acres within park boundaries is still relatively 

small (approximately 1%). 

However, the number of acres treated and resulting benefits to wildlife would be twice those of 

Alternative A. In addition, Alternative B treats acreage in four more FMUs - Inverness Ridge, 

Wilderness North, Wilderness South, and Palomarin - not treated in Alternative A. As noted 

above, compared to the entire study area or entire park, benefits are minor. But, compared to 

beneficial impacts resulting from the 500 acres burned in the No Action alternative, Alternative 

B could offer moderate short- to long-term positive impacts to wildlife. 

Fire suppression activities and those needed to maintain control of prescribed fires would result 

in the same types of direct and indirect impacts described above for Alternative A. These include 

injury or death from heavy equipment or vehicles accessing a site; removing vegetation for 
313 

staging areas or hand lines; noise, dust, and light from staging areas; accidental spills of fuel or 

other chemicals; the use of helicopter drops of water or retardants; noise from low flying aircraft 

or helicopters; and the construction of helispots. Fire crews occupying an area would also disturb 

wildlife and could result in the conditioning of some individual animals to the presence of 

humans. Indirect impacts would also be similar to those described above for the No Action 

alternative, and could include increased erosion of soil and siltation of lakes or streams and the 

loss of snags as habitat. 

Although these adverse effects on wildlife from prescribed fire would occur over 1000 acres, 

they would remain minor and short-term in the context of the entire study area. However, they 

may be quite noticeable on a localized basis, and compared to the No Action alternative, may be 

locally moderate. 

As in Alternative A, suppression actions from small-scale wildfires would potentially have 

minor, long-term, and adverse impacts because of the relatively small areas that would be 

affected. The impacts are identical to Alternative A as the acreage of wildfires that the park 

suppressed in an average year is not expected to change. 

Mechanical Treatments 

Under Alternative B, the total acres treated by mechanical means would increase to 1000. No 

mechanical thinning specifically to benefit wildlife would be undertaken; therefore benefits or 

adverse impacts from mechanical treatment would be related primarily to the increased acreage 

treated. Although twice the acreage as in Alternative A would be thinning, this is still a relatively 

small (approximately 1%) percentage of the 90,000 acres in the study area. In addition, treatment 

would be dispersed among seven FMUs (Alternative A would include mechanical treatment in 

three FMUs). The FMUs to receive additional treatment over Alternative A are Tomales Point, 

Wilderness North, Wilderness South, and Palomarin. Although this may provide some 

additional benefits to the tule elk population in the Tomales Point FMU, in the context of the 

entire study area, benefits to wildlife from mechanical treatment would likely be short- to longterm (depending on whether the same areas would be routinely treated) and negligible to minor. 

The secondary benefits of clearing down wood or thinning branches to those species requiring 

more open habitat could be much more noticeable in some locations and compared to these same 

benefits in Alternative A. This is also true of adverse impacts associated with the thinning 

activities themselves, as well as from the loss of dead logs or other habitat for forest dwelling 

species. Either localized benefits or adverse impacts could range from minor to moderate 

compared to those related to Alternative A. 

Fire Information/Education 

As in Alternative A, the impacts associated with fire information and education would largely be 

indirectly beneficial, although highly dependent on the nature of the fire management action. 
314 

Fire Cache/Park Headquarters Relocation, and Construction 

As in Alternative A, the construction of a fire cache at Bear Valley would have no influence on 

the direct effects of fire management actions on wildlife. There may be some short-term 

adverse, negligible, impacts to wildlife caused by noise during the construction. 

Fire Effects and Fuel Management Research 

No direct adverse or beneficial effects are anticipated on wildlife from the implementation of 

Alternative B research projects. However, depending on the results, test burns may result in the 

creation of additional open or early seral stage habitat in Douglas-fir or Bishop pine forests. 

Cumulative Impacts 

No cumulative impacts beyond those described for alternative A would occur. 

Conclusion 

In the context of the 90,000 acre study area, the impacts to wildlife of Alternative B would be 

nearly indistinguishable from Alternative A. Treatment with prescribed fire and through 

mechanical means would result in short- to long-term, negligible to minor benefits to wildlife 

from the reestablishment of the natural fire cycle, reduction of fuel loads, and reduction of the 

potential for catastrophic wildfire. However, compared to No Action, Alternative B could offer 

moderate short- to long-term benefits to wildlife because twice as many acres would be treated 

(2000 total; 2% of total acres managed) and noticeable on a local scale. Forest dwelling species 

would suffer negligible to minor short-term adverse impacts from reductions in habitat overall, 

and minor to moderate impacts relative to those from the No Action alternative. 

Some suppression activities (retardant use) or actions to control prescribed burns, such as spike 

camps, access or creating fire lines, would have short-term adverse and therefore minor impacts 

on wildlife. Others, such as creating helispots or the use of helicopter buckets of water or 

retardants, may have longer lasting impacts. Overall, these activities are not expected to have 

more than minor impacts to wildlife. Compared to Alternative A, the degree of impact from 

actions to prepare for or control prescribed burns would be greater. Since all of these actions are 

those associated with short-term, more controlled minor impacts, it is unlikely that more than 

moderate adverse impacts compared to Alternative A would occur. As in Alternative A, actions 

to suppress large fires would likely be more intense, with short-term major or long-term 

moderate adverse impacts to wildlife. 

In the context of the entire study area, Alternative B would result in negligible to minor short- to 

long-term benefits to wildlife from creating open habitat using mechanical thinning. Compared 

to Alternative A, these benefits could be moderate. 

No impairment to park wildlife would occur from implementing Alternative B. 
315 

Alternative C 

Analysis 

Prescribed Fire and Suppression 

In this alternative 2000 acres of prescribed burning would occur over an average year. To the 

extent it is possible, prescribed burns would be conducted to approximate historic natural fire 

intensity and fire intervals. The intent is to allow the process of fire to act on the landscape as it 

has for thousands of years to the greatest extent possible, while ensuring human safety and 

protecting property. In both Wilderness North and Wilderness South fire management units, 

prescribed fire would be used to open up forested areas to increase forage for herbaceous 

wildlife. The goal under Alternative C is to reintroduce fire into forests in these FMUs that have 

historically burned on a regular basis (estimated fire return interval: 7-14 years), but which have 

not burned for 50-100 years. Fire would be used in the Tomales Point FMU to encourage the 

growth of native plant species, with expected positive effects on the Tule elk population in the 

area. Fire would also be used to help control non-native and highly invasive velvet grass in this 

FMU. As in Alternative B, prescribed burning in the Palomarin fire management unit would be 

used to maintain and improve habitat for a variety of bird species. Beyond these specific 

changes, Alternative C would simply treat a greater number of acres with the intent of reducing 

fuels and controlling non-native and invasive plant species than either of the other alternatives. 

As noted in the analysis of these alternatives, wildlife would experience benefits from these 

activities even though they are not specifically directed at improving wildlife habitat. These 

benefits include creating more open habitat, increase nutrition in forage, an emphasis on native 

plant species, some of which are likely to have been food for native wildlife species, and a 

decreased risk of large-scale catastrophic fires. 

In this alternative, prescribed fire would have a beneficial, short- to long-term moderate impact 

on wildlife compared to the entire study area even compared to the entire study area. The effects 

would be noticeable because 2000 acres would be treated, and because the goal of this alternative 

is to return as much of the park’s fire dependent vegetation as possible (given no more than 2000 

acres per year would be treated) to its natural fire interval and intensity. As in other alternatives, 

burn units would be dispersed throughout the park in the various FMUs (no concentration of 

impacts within a watershed and only 10% or any watershed would be treated annually) and the 

total acres treated in relationship to the 90,000 acres within park boundaries would be relatively 

small (approximately 2%). 

In another context, that is, related to the benefits of prescribed fire in the No Action alternative, 

Alternative C would treat four times the area. This combined with the focus of Alternative C on 

improving conditions for natural resources could result in major benefits on a local scale 

compared to Alternative A. If the treated areas are eventually returned to their natural fire cycles, 

wildlife may experience very long-term or permanent positive impacts. 

Fire suppression activities and those needed to maintain control of prescribed fires would result 

in the same types of direct and indirect impacts described above for Alternative A. These include 

injury or death from heavy equipment or vehicles accessing a site; removing vegetation for 
316 

staging areas or hand lines; noise, dust, and light from staging areas; accidental spills of fuel or 

other chemicals; the use of helicopter drops of water or retardants; noise from low flying aircraft 

or helicopters; and the construction of helispots. Fire crews occupying an area would also disturb 

wildlife and could result in the conditioning of some individual animals to the presence of 

humans. Indirect impacts would also be similar to those described above for the No Action 

alternative, and could include increased erosion of soil and siltation of lakes or streams and the 

loss of snags as habitat. 

These activities would occur on 2000 acres per year, and may result in moderate adverse 

impacts, even in the context of the entire study area. On a localized basis, the impacts may be 

quite noticeable, and compared to the No Action alternative, may be moderate or even major in 

their intensity. Actions associated with controlling prescribed burns are likely to have less 

intense impacts of shorter duration than those needed to suppress wildfires. Construction of 

helipads or the use of helicopter drops for water or retardants could have long-term and more 

severe effects on wildlife. 

Mechanical Treatments 

Under Alternative C, the total acres treated by mechanical means would increase to 1,500. No 

mechanical thinning specifically to benefit wildlife would be undertaken; therefore benefits or 

adverse impacts from mechanical treatment would be related primarily to the increased acreage 

treated. Although three times the acreage as in Alternative A would be thinning, this is still a 

relatively small (approximately 1.5%) percentage of the 90,000 acres in the study area. In 

addition, treatment would be dispersed among the same eight FMUs as in Alternative B 

(Alternative A would include mechanical treatment in three FMUs). As in Alternative B, the 

Tomales Point FMU would receive thinning treatment, which may offer specific benefits for tule 

elk by improving the quantity and quality of forage available. Otherwise, the same type of 

benefits as described in the other alternatives of creating more open habitat and reducing the risk 

of catastrophic fire would occur if this alternative were selected. Because more acreage would be 

treated, benefits are likely to be minor to moderate. If treated areas continue to be treated, the 

benefits would be long-term. 

The secondary benefits of clearing down wood or thinning branches to those species requiring 

more open habitat could be much more noticeable in some locations and compared to these same 

benefits in Alternative A. This is also true of adverse impacts associated with the thinning 

activities themselves, as well as from the loss of dead logs or other habitat for forest dwelling 

species. Either localized benefits or adverse impacts could be moderate compared to those 

related to Alternative A. 

Fire Information/Education 

As with other alternatives, fire information and education would largely be indirect and 

beneficial, although highly dependent on the nature of the fire management action. 
317 

Fire Cache/Park Headquarters Relocation, and Construction 

As in other alternatives, construction of a fire cache at Bear Valley would have no influence on 

the direct effects of fire management actions on wildlife. There may be some short-term, 

adverse, negligible impacts to wildlife caused by noise during the construction. 

Fire Effects and Fuel Management Research 

No direct adverse or beneficial effects are anticipated on wildlife from the implementation of 

Alternative C research projects. However, depending on the results, test burns may result in the 

creation of additional open or early seral stage habitat in Douglas-fir or Bishop pine forests. 

Cumulative Impacts 

No cumulative impacts beyond those described for alternative A would occur. 

Conclusion 

Treatment with prescribed fire and through mechanical means would result in short- to longterm, minor to moderate benefits to wildlife from the reestablishment of the natural fire cycle, 

reduction of fuel loads, and reduction of the potential for catastrophic wildfire. However, 

compared to No Action, Alternative C could offer moderate to major short- to long-term benefits 

to wildlife because four times as many acres would be treated (2000 total; 2% of total acres 

managed) and be noticeable on a local scale. Forest dwelling species would suffer minor to 

moderate short-term adverse impacts from reductions in habitat overall, and moderate or even 

major localized impacts relative to those from the No Action alternative. 

Some suppression activities (retardant use) or actions to control prescribed burns, such as spike 

camps, access or creating fire lines, would have short-term, adverse, and therefore minor impacts 

on wildlife. Others, such as creating helispots or the use of helicopter buckets of water or 

retardants, may have longer lasting impacts. Overall, these activities are not expected to have 

more than moderate impacts to wildlife. Compared to Alternative A, the degree of impact from 

actions to prepare for or control prescribed burns would be greater. Since all of these actions are 

those associated with short-term, more controlled impacts, it is unlikely that more than moderate 

adverse impacts compared to Alternative A would occur. As in Alternative A, actions to suppress 

large fires would likely be more intense, with short-term major or long-term moderate adverse 

impacts to wildlife. 

In the context of the entire study area, Alternative C would result in minor short- to long-term 

benefits to wildlife from creating open habitat using mechanical thinning. Compared to 

Alternative A, these benefits could be moderate. 

No impairment to park wildlife would occur from implementing Alternative C. 
318 

IMPACTS ON SPECIAL-STATUS SPECIES 

Alternative A 

The project area contains numerous plant and wildlife species that are nationally, regionally, or 

locally rare. These species span a spectrum of rarity from being federally listed as Endangered 

or Threatened under the Endangered Species Act, to being recognized by the California Native 

Plant Society (CNPS) or local area species experts as uncommon or rare. For purposes of this 

document, all of these species are collectively referred to as “special-status species.” These 

species all require consideration when management actions are taken to ensure that actions do 

not harm the species or their habitats. 

 

Fire management activities have potential to affect many of these species. For example, stream 

or riparian species could be adversely affected by increased sedimentation in creeks and/or 

persistent turbidity following wildland or prescribed fire. Fire management activities such as 

cutting fire line or removing vegetation to reduce fuel accumulations could destroy or harm 

individuals or damage their habitat. Conversely, as is the case for common plants and wildlife, 

many special-status species in the project area are adapted to periodic fire, and application of fire 

to the ecosystems could benefit these species by providing a wider diversity of habitats, by 

stimulating seed germination, or by improving habitat for prey species. 

In May 2001, in response to PRNS’s request to initiate consultation on revision of the park’s fire 

management plan, the U.S. Fish and Wildlife Service sent a list of Federally-listed Threatened 

and Endangered animal and plant species that may occur in the Project Area (dated 5/24/01). The 

following tables of special-status species (see Affected Environment) were generated from the 

USFWS list, from State of California lists, and from California Native Plant Society lists to 

facilitate this impact analysis: 

Table 15. Federal Threatened, Endangered, Candidate, and Proposed plant species that may 

occur in areas affected by PRNS’s Fire Management Plan 

Table 21. Federal Plant Species of Concern and California-listed plant species that may 

occur in areas affected by PRNS’s Fire Management Plan 

Table 22. Additional Plant Species of NPS Management Concern known to occur in areas 

affected by PRNS’s Fire Management Plan. 

Table 24. Federal Threatened, Endangered, Candidate, and Proposed animal species that 

may occur in areas affected by PRNS’s Fire Management Plan 

Table 33. Federal Animal Species of Concern and California-listed animal species that may 

occur in areas affected by PRNS’s Fire Management Plan 

These tables present summary information on whether or not the species are known to occur in 

PRNS and/or GGNRA and whether or not they are likely to be adversely impacted by fire 
319 

management plan activities, based on PRNS’s best professional judgment. Species listed in 

these tables were evaluated to determine whether or not fire management activities could affect 

either individuals of the species or their habitat. 

Federally listed Threatened and Endangered Species Covered in this EIS 

The following sections discuss probable impacts to species listed as threatened or endangered by 

the federal government that may occur from implementing actions in the fire management plan 

alternatives. All plant or animal species on this list and present in the project area were 

considered in the analysis. 

PLANTS 

Sonoma alopecurus (Alopecurus aequalis var. sonomensis) 

Sonoma spineflower (Chorizanthe valida) 

Tiburon paintbrush (Castilleja affinis ssp. neglecta) 

Marin dwarf flax (Hesperolinon congestum) 

Beach layia (Layia carnosa) 

Tidestrom’s lupine (Lupinus tidestromii [var. layneae])

WILDLIFE 

Northern spotted owl (Strix occidentalis caurina) 

California red-legged frog (Rana aurora draytonii) 

Central California coho salmon (Oncorhynchus kisutch) 

Central California Coast steelhead (Oncorhynchus mykiss) 

California freshwater shrimp (Syncaris pacifica) 

Myrtle’s silverspot butterfly (Speyeria zerene myrtleae) 

Western snowy plover (Charadrius alexandrinus nivosus) 

Federally Listed Plants 

For each federally listed plant species, Table 52 summarizes the most current information on the 

number of occurrences of the species in the project area and the population size trend that PORE 

botanists have estimated from available data. Narratives on each species status, potential 

impacts, and impact mitigation measures are presented following the table. 

Table 52. Number of Occurrences and Estimated Population Trends for Listed Plant Species in 

the Project Area 

Species # of Occurrences in 

Project Area 

Population Trends 

PRNS 

 

Sonoma alopecurus (E) 

Alopecurus aequalis var. sonomensis 

4 Unknown – need more data 

Sonoma spineflower (E) 

Chorizanthe valida 

2 Stable or increasing 

Beach layia (E) 13 Stable 
320 

Layia carnosa 

Tidestrom’s lupine (E) 

Lupinus tidestromii (var. layneae) 

7 Stable 

 

North District GGNRA 

Tiburon paintbrush (E) 

Castilleja affinis ssp. neglecta 

1 Stable 

Marin dwarf flax (T) 

Hesperolinon congestum 

6 Increasing 

a/ Population size trends are based on very limited data as described in the following sections. 

Sonoma alopecurus (Alopecurus aequalis var. sonomensis) – Endangered 

Sonoma alopecurus, a perennial grass that grows in the park on pastures in agricultural areas, 

favors moist or wet sandy soils. Results of monitoring at the Seashore suggest it thrives in 

wetlands that are grazed just enough to reduce competing vegetation. New occurrences of 

alopecurus may be found in areas of seasonally saturated soils as rare plant surveys continue. 

Such areas are most common in, but not exclusive to, the relatively gentle topography of the 

west-central Point Reyes peninsula. 

As noted in Affected Environment, the four known locations of this species consist of 

populations ranging from about 600 to more than 8000 individuals. The G Ranch population is 

located in a back dune area near the southwest corner of Abbott’s Lagoon, in a swale that 

supports freshwater marsh vegetation. As of 2000, a systematic survey found a peak population 

size of over 1,500 individuals. By 2003, the population had increased to over 8,000. The H 

Ranch population is in a freshwater marsh/swale along a fence that borders an ungrazed area 

south of Abbott’s Lagoon. Immediately above a small berm carrying the trail across the swale is 

a population that numbered 60 in 2000, but which has now grown to more than 600 plants. A 

third population of 50+ plants on F Ranch was discovered in 2000 in a wetland swale between 

semi-stabilized dunes. In 2003, this population numbered more than 1000. The fourth population 

exists on a 521 acre tract recently purchased by the NPS from AT & T and currently leased for 

cattle grazing. Two patches occur on this tract, and together they numbered over 3,500 plants 

when last surveyed in 2003. 

The long-term population trend for this species is unknown, as two of the populations were 

recently discovered, and more intense monitoring and surveying of the remaining two 

populations was not completed until 2000. Additional monitoring over time of these populations, 

and a broad based survey of the study area for as yet undiscovered populations is needed to know 

whether the population park-wide is stabilized, or is increasing or decreasing in size. However, 

in the short-term all four populations have increased from the year 2000 to 2003. 

Because all known populations of Sonoma alopercurus in the park lie within the Minimum 

Management Fire Management Unit (a former population in the Palomarin FMU has been 

extirpated), they would not be subject either to prescribed burning or mechanical fuels 

treatments. The populations could be adversely affected by an unplanned wildfire or by 

suppression activities associated with such a fire, but this is considered unlikely given they occur 

in wet sites within pastures routinely grazed by cattle where fire is unlikely to carry. 
321 

Sonoma spineflower (Chorizanthe valida) – Endangered 

Sonoma spineflower was thought to have been extirpated in Marin and Sonoma counties from 

agricultural and residential development, but was rediscovered in the park in 1976 in the same 

pasture on G Ranch in which Sonoma alopecurus is located. Coarse estimates of size indicate 

this population size has grown from several hundred plants in 1983 to 30,000 plants in 1993. 

The Marin Chapter of California Native Plant Society has actively searched other areas for this 

plant since its 1980 rediscovery without success, and it is considered unlikely that other 

populations of spineflower would be found. 

As noted in Affected Environment, the park has attempted to establish new populations by 

seeding grazed pastures in several locations in the park. To date, one population has been 

successful, and a second appears to be taking hold. Overall, the population in the park appears to 

be stable and increasing. 

As with Sonoma alopecurus, all known populations of Sonoma spineflower are growing in the 

Minimum Management Fire Management Unit, where no fire management activities are 

planned. Although it is possible they could be subject to impacts associated with an unplanned 

wildfire or its suppression, it is considered unlikely given their location in a wet and low fuel 

(e.g., grazed) environment. 

Tiburon paintbrush (Castilleja affinis ssp. neglecta) – Endangered and Marin dwarf flax 

(Hesperolinon congestum) – Threatened 

Both Tiburon paintbrush and Marin dwarf flax are species that grow in the serpentine soils and 

rocky outcrops of Nicasio Ridge at the northern border of GGNRA’s North District. Tiburon 

paintbrush is a semi-woody perennial; recent data suggests the population may be in decline (see 

Table 17). Marin dwarf flax has been found in six locations on Nicasio Ridge, and overlaps at 

one point with Tiburon paintbrush in and near the McIsaac Ranch. The abundance of Marin 

dwarf flax on Nicasio Ridge varies from year to year, and new populations were found in 1999 

and 2000. This suggests the distribution of Marin dwarf flax on Nicasio Ridge is not fully 

known, and that it may appear in other sites in the future due to seed dispersal, weather, or 

localized disturbances. 

All of the occurrences of Marin dwarf flax and Tiburon paintbrush are within the Minimum 

Management Fire Management Unit, and would not be subject to either prescribed burning or 

mechanical fuels treatments. The populations could be subject to impacts associated with an 

unplanned wildfire or by fire suppression activities, but this is unlikely because the populations 

occur on rocky outcrops where fire is unlikely to carry. 

Beach layia (Layia carnosa) – Endangered and Tidestrom’s lupine (Lupinus tidestromii) – 

Endangered 

These two plant species occur in coastal dunes on the western edge of the PRNS peninsula. Both 

have been monitored by CNPS volunteers and PRNS staff since the 1980s. Monitoring reports 

include an estimate of plant numbers, a description of site characteristics, and apparent threats to 

each occurrence. These reports have been assembled in the PRNS Rare Plant Database. 
322 

Beach layia has been recorded at both dune and pasture sites in the park. Its habitat is the central 

foredune community, which, because of dune blowouts and restabilization, can cause large 

fluctuations in plant numbers and local distribution. Table 19 in Affected Environment shows 

this is true for populations in the park. Some patches of beach layia in the park are considered 

threatened by the presence of non-native invasive species such as European beachgrass 

(Ammophila arenaria), sea fig (Carpobrotus chilensis), and/or Hottentot fig (Carpobrotus 

edulis) nearby. 

Tidestrom’s lupine also occurs in seven dune and pasture sites in the park. The largest population 

at the Seashore is located behind dunes southwest of Abbott’s Lagoon. Others are located north 

of Abbott’s Lagoon and further south, near the North Beach parking area and the Old Lifesaving 

Station. Three of the seven occurrences in the park are located in pastures, but as with beach 

layia, grazing is not considered a threat to their continued existence. Six of the populations are 

considered threatened by European beachgrass and ice plant. The total number of individuals has 

increased in the last three years, from an estimated 8,000+ in 2000 to nearly 200,000 in the year 

2002. The population is considered stable. 

All of these occurrences are within the Minimum Management Fire Management Unit, and 

would not be subject to either prescribed burning or mechanical fuels treatments. The 

populations could be subject to impacts associated with an unplanned wildfire or by fire 

suppression activities, but this is unlikely because the populations occur in sandy dunes 

surrounded by pastures routinely grazed by cattle where fire is unlikely to carry. 

Other Special Status Plant Species 

Table 21 in Affected Environment (of all plant species) shows several plant species in the 

affected area are listed as federal Species of Concern. Species of Concern are those where 

USFWS is collecting additional information to determine whether they warrant consideration for 

future listing. In addition, three species (Point Reyes blennosperma, Marin Manzanita, and 

Bolinas ceanothus) are considered rare by the state of California, one is state endangered (Point 

Reyes meadowfoam) and all plant species in the table have been watchlisted by the California 

Native Plant Society. In Alternative A, although no federal or state listed species have been 

found in FMUs that would be treated with prescribed fire, one state rare species (Bolinas 

ceanothus) is present in the Bolinas Ridge FMU. Bolinas ceanothus does not occur in any FMUs 

slated for mechanical treatment in this alternative. Several federal species of concern are present 

in Estero and Limantour Road FMUs, which would be treated with both prescribed fire and 

mechanical thinning. Because these species are not listed or proposed for listing as threatened or 

endangered by the state or federal government, they are treated together below. 

Analysis

Under Alternative A, 4 FMUs - Estero, Limantour, Highway One, and Bolinas Ridge - are 

treated with prescribed fire. Three of these - Estero, Limantour, and Highway One FMUs - 

would also be treated mechanically. 
323 

Prescribed Fire 

The effects of fire on the species listed in Table 21 are not fully known. However, the park’s 

mean surface fire intervals of 7 to 13 years (Brown et al., 1999) indicate fire is an integral part of 

the natural ecosystem at Point Reyes. Research has demonstrated that fire plays a critical role in 

the management of many threatened and endangered species in areas with regular burn intervals. 

For example, fire helps maintain open areas, can stimulate or is required for reproduction, and 

removes non-native competitors. Ceanothus, for example, is most often a fire dependent genus. 

Even though individuals of some species of concern may be killed by prescribed fire, the 

removal of competitors has a long-term beneficial effect as fire dependent native species return, 

while the competitors often do not (National Biological Service, 1995). 

Because prescribed fire would be limited in scope, it would not involve a large component of the 

total population of each species of concern. This means both the potential for adverse or 

beneficial impacts would be no more than minor. Adverse impacts would be short-term for the 

most part, but beneficial impacts may be long-term. 

Unplanned Ignitions, Wildfire, and Suppression

Wildland burns may have the same type of effects as prescribed burning, but may also cause type 

conversions or help facilitate the spread of exotic species. Suppression activities during a 

wildfire would also potentially result in crushing, shearing, or destruction of unburned 

individuals of some of the species listed in Table 21 or indirect effects on these same species 

through soil compaction. The average acreage burned by wildfire in the study area is less than 30 

acres; because it is small in scope, the chance of wildfire or suppression in an average year 

having more than a negligible or minor adverse impact is low. Impacts may be short- or longterm depending on the intensity of the fire or location and extent of suppression activities. 

Mechanical Treatments

Mechanical thinning activities such as mowing are not expected to have any adverse impacts on 

the special status species on Table 21. This is because mowing would be done in the fall after 

plants have flowered and gone to seed, and rare plants populations would be excluded from 

treatment areas. Areas are surveyed each year before they are treated to determine whether any 

special status plants exist on site. 

Fire Information/Education

No impact to any plant special status species is expected from the distribution of fire information 

or education. 
324 

Fire Cache/Park Headquarters Relocation, and Construction

Because the area where the fire cache is planned would be surveyed prior to construction, 

impacts to protected plant species would be minimized. It is possible that individuals would be 

affected, but the extent of the effect would be minor. 

Fire Effects and Fuel Management Research

No effects to any special status plant species from fuel management research under Alternative A 

are expected. 

Federally Protected Wildlife 

Northern Spotted Owl (Strix occidentalis caurina) - Threatened 

The northern spotted owl (Strix occidentalis caurina) was federally listed as threatened in 1990 

(USFWS, 1990). Most nesting and roosting sites occur in older, decadent stands of conifer and 

hardwood trees with large overstory trees, and about 35,000 acres of potential habitat exists in 

the study area. A recent census estimated a population of approximately 49 owl activity centers 

(Chow, 1997, Fehring et al., 2001, NPS, unpubl. data). Data on the number of activity centers 

collected since 1998 appears to indicate a stable population. 

While the acreage in the study area is not designated critical habitat for the spotted owl, this is 

only because the species is already considered protected by virtue of the lands designation as 

National Park status. In addition to protection offered by NPS policies, the Seashore is 

implementing the following mitigation measures to minimize any adverse impact from 

prescribed or wildland fire, or from mechanical treatment. 

Mitigation Measures Routinely Used for Activities in Spotted Owl Habitat

• annually identify and map areas where spotted owls are nesting, 

• protect occupied and previously used nest sites from unplanned ignitions, 

• do not conduct prescribed burns within 400 meters of an occupied or previously used nest 

site, 

• do not conduct mechanical treatments with mechanized equipment within 400 meters of 

an occupied or previously used nest site between February 1 and July 31 (breeding 

season), and 

• conduct post-treatment monitoring to ascertain any impacts. 

Analysis

Under this Alternative, potential effects on northern spotted owls are extremely limited because 

only two of the FMUs to be treated - Highway One and Bolinas Ridge - are considered habitat. 
325 

Prescribed Fire

Under a natural fire regime, spotted owl habitat in the project area was subject to periodic, lowintensity fires. However, fire in the study area has been suppressed for 150 years, and high fuel 

loadings make large, stand-replacing fires possible. These hot fires can result in type conversions 

and the loss of spotted owl forest habitat for many years. 

Prescribed fire can be an effective tool in protecting and improving spotted owl habitat in the 

park by helping to reduce unnatural accumulations of fuels and ladder fuels. Spotted owls can 

coexist with extensive fires of varying intensities within their habitats (Weatherspoon et al., 

1992). Because of the existing high level of fuel loading in many areas of the park, even fires 

that are burning within prescription are likely to burn small areas at intensities high enough to 

have an adverse effect on some spotted owls by reducing prey items. This is no more than a 

negligible or minor, short-term, adverse impact, however, especially compared to the increased 

risk and relatively serious impacts of wildland fire under a regime of fire suppression. 

In the old growth stands favored by spotted owls, the dense canopies maintain a higher relative 

humidity, which reduces heating and drying of surface fuels, thus reducing flammability. 

Adverse effects from wildland fire would be minimized if fuel loads were reduced in and near 

spotted owl nesting and roosting areas. This could be done by application of spring prescribed 

fires that would disrupt fuel continuity and reduce the potential for stand-replacing fires 

(Weatherspoon et al., 1992). 

Adverse impacts on spotted owl territories that are identified prior to ignition of a prescribed fire 

would be minimized through preparatory burns and mechanical fuel reduction in nesting and 

roosting habitat to control fire intensity in these areas. In addition, no treatment would occur 

within 400 meters of a nesting or known roosting site to mitigate any potential impacts. 

Prescribed fire planning also takes into account other important habitat components, such as 

down, woody debris that provide habitat for dusky-footed woodrats, which are an important prey 

species for northern spotted owls in the project area. Fires of an intensity that would reduce the 

amount of woody debris, or would otherwise adversely affect woodrat habitat or nests would 

have an indirect minor short-term adverse effect on spotted owls. 

Currently, no program elements exist for the management of prescribed fires for the benefit of 

spotted owls. The use of prescribed fire under Alternative A, would, nonetheless, have a 

beneficial, long-term, and minor impact on California spotted owls, primarily through reduction 

in the threat of catastrophic fire in some areas. 

Unplanned Ignitions, Wildfire, and Suppression

As noted above, high fuel loadings make hot fires or hot spots within lower intensity prescribed 

burns more likely. These hot fires can have adverse impacts on habitat by reducing canopy 

closure or destroying owl prey or their habitat. However, given that the average annual acreage 

burned from wildfires at the park is quite low, any more than minor adverse impacts from 

average annual wildland fires are unlikely. 
326 

Mechanical Treatments

Under Alternative A, hand thinning or mechanical treatments in the vicinity of development and 

roads such as on Bolinas Ridge and Highway One FMUs could have an adverse effect on spotted 

owls through a reduction in canopy closure. This is especially true where developed areas 

interface with dense forest that provides roosting and nesting habitat. Under Alternative A, 

cutting large trees would be limited because techniques would be confined to hand thinning and 

then piling and burning. In some areas, clearing understory vegetation could, in fact, improve 

foraging conditions for spotted owls and habitat for woodrats. 

Chipping is conducted occasionally in this alternative. Chipping involves cutting material and 

then distributing it over a site where air quality, visitor use, or other management concerns 

prohibit burning. The equipment used to chip material is extremely loud and, if operated nearby, 

may disturb spotted owls. Because only a maximum of 500 acres would be treated with 

mechanical equipment and because only two of the FMUs proposed for mechanical treatment 

include spotted owl habitat, the impact would be a minor, short-term, adverse one on the owl 

population in the park. 

Fire Information/Education

No impact to spotted owls from the distribution of fire information or education is expected. 

Fire Cache/Park Headquarters Relocation, and Construction

The fire cache would not be located in the vicinity of spotted owl activity centers or potential 

habitat, so no impact is expected. 

Fire Effects and Fuel Management Research

No effects to spotted owls from fuel management research under Alternative A are expected. 

Red-legged Frog (Rana aurora draytonii) – Threatened 

The study area supports one of the largest known populations of California red-legged frogs in 

the state. A comprehensive survey of aquatic habitat in the study area has located numerous sites 

in riparian areas, wet swales, seasonal springs, and stock ponds on ranch lands. The survey is 

ongoing, and is expected to locate many more frog habitats in the Seashore and GGNRA. 

PRNS, GGNRA, and adjoining areas of Marin County comprise one of the 57 core areas for 

focused recovery of red-legged frogs established in the Final Recovery Plan for the species 

(USFWS, 2002). Much of the project area falls within the recently established criteria for redlegged frog critical habitat (USFWS, 2002). For example, the central peninsula contains 

numerous stock ponds which retain water at least 20 inches deep well into the summer. Pond 

habitat and perennial creeks are also clustered, particularly at the Point. These concentrated 

aquatic habitats and the fact that ground between them is suitable for overland travel by frogs has 

created an interconnected and critical habitat for this species in the study area. A second 
327 

interconnected habitat area extends along the Olema Valley, where the perennial segment of 

Olema Creek links scattered off-stream aquatic habitats from the vicinity of Point Reyes Station 

south approximately 13.5 km. Olema Creek runs through the Wilderness South and Highway 

One FMUs. 

Red-legged frogs have also been found on Bolinas Mesa and at several ponds on top of Bolinas 

Ridge. Since frogs could be present in unsurveyed locations on Inverness Ridge, and could 

travel along seasonally wet riparian corridors over the ridge, all the red-legged frog sighting 

locations have been linked into one metapopulation. 

Based on survey data, the most important riparian areas for red-legged frogs in the study area are 

those with a relatively low gradient that have late season water flow or water retention in pools. 

On Point Reyes itself, such creeks support relatively few of the documented occurrences of the 

frogs, but they may serve as connector and refuge habitats. The most important of these are 

Kehoe Creek and Abbott’s Lagoon Creek on the north end of the peninsula, and Schooner Creek, 

which drains into Drakes Estero. 

Analysis

The types of impacts fire management activities could have on red-legged frog aquatic habitats 

are summarized in Table 53, which is based on the Draft Recovery Plan. 

Table 53. Potential Impacts on Red-legged Frog Aquatic Habitats from Fire Management 

Activities 

Impact Potential Effect on CRLF Habitat 

Emergent vegetation removed. Emergent vegetation necessary for amplexus and anchoring 

egg masses. Excessive levels may reduce sunlight needed 

for growth of algae, which is chief larvae food. 

Shading vegetation removed (emergent and bank side) Chiefly harmful to adults, for whom shaded refugia may be 

critical in drier inland areas during the summer. 

Insect habitat vegetation removal Harmful to adults and juveniles that mainly feed on 

invertebrates for which bank side vegetation is prime 

habitat. 

Excess water drawdown in ponds Leave egg masses stranded on vegetation 

Change hydrological regime by accelerating runoff Pools may dry before metamorphosis completed 

Nearly all of these potentially adverse impacts would result from wildland fire suppression 

activities or from a wildfire itself. This is because all prescribed burn plans and plans for 

mechanical treatment in a given year are reviewed and any important riparian areas or other 

habitat for red-legged frogs avoided. All fire management actions would adhere to a setback 

from breeding and non-breeding habitat for red-legged frogs 
328 

Prescribed Fire

The species appears to be thriving under the current PRNS management, including fire 

management actions that have been conducted over the past several years and will be continued 

under this alternative. Prescribed fire, because it is used to restore the natural vegetation structure 

in park habitats and reduce the risk of catastrophic fire, would have long-term benefits to redlegged frogs and their habitat. These benefits, however, would be limited by the relatively small 

area (500 acres) that would be burned annually under Alternative A in just four FMUs - Estero, 

Limantour, Highway One, and Bolinas Ridge. 

High levels of fuel loading in some areas may cause prescribed fires to burn at higher than 

natural intensities, even when fire prescriptions were designed to minimize high-intensity fires. 

Hotter fires, or fires that may more readily burn unintended areas, could burn riparian habitat and 

have the effects described in Table 53 above. Higher intensity burns could also result in 

increased sedimentation in frog habitat. However, the extent of these types of impacts under the 

prescribed burn program proposed in this alternative would be quite small, or perhaps even 

largely non-existent. Adverse impacts to frogs would therefore be short-term and negligible 

because of the small amount acreage burned in each FMUs per year. 

Unplanned Ignitions, Wildfire, and Suppression

Because unplanned ignitions may burn in frog habitat, some of the types of impacts identified in 

Table 53 above could result. Suppression activities - water drops, line construction, retardant 

drops - could also inadvertently have adverse effects on red-legged frogs, but because of the 

small acres (30 acres) of wildfire each year, the effects are expected to be short-term and 

negligible. 

Mechanical Treatment

Mechanical treatment such as hand thinning, line construction, and pile burning could disturb 

frogs or alter their habitat. Frogs may shelter in piles and be killed when they are burned. 

However, the impact to the park’s frog population would be no more than negligible because 

breeding areas and adjacent non-breeding areas would be identified and avoided before any 

mechanical treatment is taken. 

Reduction in fuel loading by hand thinning or mechanical treatment would have a beneficial 

effect on red-legged frogs by reducing fuel loads and the threat of catastrophic fire. This 

treatment, however, would be used in very small areas of potential red-legged frog habitat near 

buildings for defensive space, otherwise all breeding habitat of red-legged frogs would not be 

treated. Mechanical treatments by inadvertently killing a red-legged frog could be adverse, but 

would be short-term, and negligible. 
329 

Central California Coast Coho Salmon (Oncorhynchus kisutch) – Threatened and Central 

California Steelhead (Oncorhynchus mykiss) - Threatened 

Central California coast coho salmon and Central California steelhead (hereafter referred to as 

coho and steelhead) occur in several creeks on the Point Reyes peninsula and in the Lagunitas 

Creek watershed that drains portions of PRNS and GGNRA. The Bolinas Ridge FMU is located 

within the Lagunitas Creek, Olema Creek, and Pine Gulch Creek watersheds. The Highway One 

FMU is located within the Olema, Pine Gulch, and Bolinas Drainage watersheds. The Estero 

FMU is located within the Drakes Estero watershed and the Limantour Road FMU includes the 

Drakes Estero, Drakes Bay, and Tomales Bay Watersheds (see Figure 16). Lagunitas Creek 

watershed is part of the Highway One, Bolinas Ridge, and Wilderness South FMUs. Designated 

critical habitat for coho in PRNS includes all accessible estuarine and stream areas in the coastal 

watersheds of Marin County except areas above longstanding, naturally impassable barriers or 

above Peters Dam on the mainstem of Lagunitas Creek and Seeger Dam on Nicasio Creek 

(NMFS, 2000). Although critical habitat has not been established for central California 

steelhead, it is likely to be the same as that for coho in Marin County. 

For most drainages presence/absence salmonid surveys have been conducted, while in 

watersheds supporting coho salmon, abundance data on both species is available. The variable 

life cycle of steelhead makes population analysis more difficult, but also makes them more 

resilient to adverse environmental conditions. In general, if the habitat requirements for coho 

were met, steelhead habitat requirements would also be met. 

Tomales Bay Watershed

The Tomales Bay watershed includes all of the small watersheds draining from Inverness Ridge 

and Bolinas Ridge directly to the Bay. The largest of these watersheds, Bear Valley Creek, is 

included within the Limantour Road FMU. In 1999, the CSRP conducted a smolt trap survey of 

Bear Valley Creek confirming the presence of steelhead trout. 

Under Alternative A, the Limantour Road FMU would be subject to mechanical treatment and 

prescribed fire. This FMU represents 3% of the total watershed area (see Table 41). 

Lagunitas Creek Watershed

Lagunitas Creek has long supported populations of coho salmon and steelhead trout. Recent 

monitoring efforts within Lagunitas Creek have identified the presence of Chinook salmon for 

the past four years (MMWD, 2003) with less frequent occurrences of chum and even pink 

salmon. Lagunitas Creek, and its tributaries, including Olema Creek, Devil’s Gulch, and San 

Geronimo Creek support 10% of the remaining wild coho population within the central 

California coast ESU (Brown et al., 1994, NOAA Fisheries, 1996). 

Reliable quantitative survey data for coho salmon dates from 1948, when the California 

Department of Fish and Game (CDFG) began annual surveys of coho numbers and spawning 

activity on Devil’s Gulch, a tributary of Lagunitas Creek. Despite the potentially tenuous nature 

of spawning survey data and inconsistencies in data collection, review of historical spawner 

abundance data supports anecdotal evidence of declining numbers of coho over the last 50 years. 
330 

Devil’s Gulch, the only drainage for which long-term data are available, has experienced a sharp 

decline in numbers (specifically of the PLD Index, in which the highest count of living fish 

found in a single survey is added to the cumulative number of dead fish counted up to that time) 

since 1948. More recently, data for both the PL Index and the number of redds (fish “nests” dug 

in gravel) over the entire Lagunitas watershed indicate an increase. Total numbers of spawning 

coho using the drainage are suggested by PLD Index value high counts of 525 fish in 1996/97 

(see Table 27). 

Under Alternative A, the Bolinas Ridge FMU would be subject to prescribed fire. This FMU 

represents 3% of the total watershed area (see Table 41). 

Like Lagunitas Creek, Olema and its tributaries support both coho salmon and steelhead trout. 

The perennial section of Olema Creek has been systematically surveyed for live adult coho, 

carcasses, and redds since the winter of 1994/95 (Table 30). Cumulative monitoring results 

within the Olema Creek watershed, including the mainstem and John West Fork (see Table 31), 

show considerable variability from year to year and within the cohort years. As in other creeks 

in the Lagunitas drainage, Olema Creek had a high count for coho salmon in the winter of 1996-

97, with a PLD Index value of 174 and the lowest count three years later with a PLD index value 

of 27. This variability encompasses the range observed within the watershed since 1994/95. In 

recent years, the coho PLD index numbers have shown a rebound with a PLD index value of 161 

fish and 134 redds in 2000/01 and 110 fish and 84 redds in 2001/02. 

Under Alternative A, the Bolinas Ridge FMU would be subject to prescribed fire while the 

Highway One FMU would receive both prescribed fire and mechanical treatment within the 

Olema Creek watershed. These FMUs encompass 20% of the total watershed area (see Table 

41). 

Drakes Bay Drainages

The Drakes Bay watersheds include all those draining directly to the Bay from Double Point, 

north and west to Chimney Rock, with the exception of the watersheds within Drakes Estero 

(described as separate watershed unit). Watersheds south of Drakes Estero support steelhead 

trout. While no quantitative surveys have been conducted in the watershed, presence/absence 

surveys have confirmed steelhead trout to the watersheds south of Drakes Estero. 

Under Alternative A, the Limantour Road FMU would be subject to mechanical treatment and 

prescribed fire. This FMU represents 6% of the total watershed area (see Table 41). 

Drakes Estero Watershed

Watersheds draining to Drakes Estero including East and North Schooner, Glenbrook, Muddy 

Hollow, Home Ranch, and Laguna Creeks support steelhead trout. 

Under Alternative A, the Estero and Limantour Road FMUs would be subject to mechanical 

treatment and prescribed fire. These FMUs represent 23% of the total watershed area (see Table 

41). 
331 

Bolinas Drainages

The Bolinas drainages including Lewis Gulch and Arroyo Hondo support perennial stream flow 

and steelhead trout. 

Under Alternative A, the Bolinas Ridge FMU would be subject to prescribed fire while the 

Highway One FMU would receive both prescribed fire and mechanical treatment within the 

Bolinas Drainages. These FMUs represent 10% of the total watershed area (see Table 41). 

Pine Gulch Creek

Pine Gulch Creek supports a population of steelhead and it is generally accepted that it supported 

a native self-sustaining population of coho salmon into the 1970s. Following thirty years 

without documented coho sightings, recent NPS monitoring activities have detected the presence 

of three consecutive cohort year classes in Pine Gulch Creek. Beginning in winter 2000-2001, 

coho salmon spawners have been observed in low numbers (<5 per year) within the watershed. 

Modified Hankin-Reeves surveys yielded estimates of 589 (± 329) juvenile coho salmon in 

September 2001 and 1205 (± 337) juvenile coho salmon in September 2002. The 2002 survey 

results indicate higher abundance and wider distribution of coho than the 2001 survey. In 

response to juvenile presence in 2001, a smolt trap was operated in the spring of 2002 capturing 

249 coho smolts (Ketcham & Brown, 2003). Evaluation of genetic samples indicate that coho 

salmon captured during summer 2001 in Pine Gulch Creek have a strong genetic affinity to coho 

in the Redwood Creek watershed, Marin County (Garza personal communication), six miles to 

the south. 

Under Alternative A, the Bolinas Ridge FMU would be subject to prescribed fire while the 

Highway One FMU would receive both prescribed fire and mechanical treatment within the Pine 

Gulch Creek watershed. These FMUs represent 23% of the total watershed area (see Table 41). 

35% of the Highway One FMU is within the Pine Gulch Creek watershed. 

Analysis

Under Alternative A, the treatments proposed could affect coho salmon and steelhead trout 

because all four FMUs to be treated have one or both species of fish. Highway One FMU has 

the greatest potential for possible impacts because of its proximity to Olema Creek and Pine 

Gulch Creek. The FMU surrounds the road corridor and includes more than 8 kilometers of 

mainstem habitat supporting coho salmon and steelhead trout. 

Prescribed Fire

Fire can modify the quantity, quality, and use of salmonid habitat by altering riparian cover, 

water temperatures, sedimentation rates, nutrient availability food resources, and woody debris in 

streams. Because the small to medium sized streams that provide habitat to coho salmon and 

Central California coast steelhead have narrow valley floors, steep hillsides, and abundant 
332 

rainfall, they are particularly sensitive to the effects fire can have of removing vegetation and 

increasing erosion. Riparian zones and fish populations can be influenced by fire and fire 

management activities occurring upslope as well as along the stream, although a 100 foot buffer 

between any prescribing burning or mechanical treatment is maintained. 

Water temperature is a major factor affecting fish survival, distribution, and production, and can 

lead to alterations in the timing of critical life history events such as emergence of fry from 

spawning beds and smolt migration, or to changes in fish species composition in streams. These 

indirect, longer lasting impacts on water temperature can significantly affect fish populations. 

Research indicates streamside vegetation can play an important role in maintaining water 

temperatures. Evidence shows that when streams are protected from fires by a buffer strip of 

vegetation there is no increase in water temperature during burning (McMahon and deCalesta, 

1990). As noted in Alternatives, park scientists would review any given burn plan and determine 

whether riparian vegetation along streams in the area may need to be retained during a prescribed 

burn. It is likely this mitigation measure would be added if coho or steelhead are present, 

preventing more than minor impacts from water temperature changes. 

High levels of fuel loading in some areas of the park may create hot spots, or prescribed fires that 

burn at higher than natural intensities. This would decrease over time as more and more acreage 

is cumulatively treated, but could cause increased run-off and nutrient loads, even when fire 

prescriptions are designed to minimize high-intensity fires. 

Many studies have assessed the effects of fine sediment on salmonid populations. Direct effects 

of suspended sediments on fish begin to be observed between 50 and 100 milligrams per liter. 

(Herbert and Merkens, 1961; Newcombe and MacDonald, 1991; Newcome and Jensen, 1996). 

Chronic exposures to concentrations greater than 100 milligrams per liter impaired feeding and 

caused reductions in growth rates, avoidance, and downstream displacement. Adult anadromous 

fish may avoid concentrations greater than 350 milligrams per liter, impeding upstream 

migrations (Brannon et al., 1981, Whitman et al., 1982). Stress, as measured by changes in blood 

chemistry, was reported in fish exposed for short periods to sediment concentrations as low as 50 

milligrams per liter (McLeay, et al., 1983). Despite these indications of adverse effects, 

salmonids thrive in turbid rivers of the northwest, and are able to both live and reproduce in 

them, even when sediment concentrations are quite high. For example, steelhead were able to 

spawn in the North Fork of the Toutle River in August 1980, only three months after the eruption 

of Mount Saint Helens in Washington. 

As noted above, PRNS always includes a minimum 100 foot buffer between any prescribed 

burns and riparian areas. Despite this mitigation measure, prescribed burning could result in 

increased turbidities in some streams or creeks in the park. Vegetation in the burned areas would 

return quickly and sediment loss would slow over time. In addition, if upon review of a particular 

burn plan by park specialists, turbidity increases for coho or steelhead is considered a possible 

moderate or major adverse impact of prescribed burning, the burn may be cancelled or a series of 

mitigation measures put in place to bring sediment levels down. 

To assure that anadromous salmonid species are protected, Mitigation Measure S-1 would be 

implemented. This mitigation measure requires that burn plans prepared by the NPS and be 
333 

reviewed by a subject matter expert such as a hydrologist, erosion specialist, or fisheries 

biologist to assure that associated erosion control plans and riparian protection corridors are 

adequate to protect sensitive habitat and resources, prior to approval for implementation. The 

subject matter expert would determine whether the erosion control plan and riparian protection 

corridors are sufficient to prevent long-term moderate or major impacts to salmonid habitat. In 

other words, the expert would determine whether the proposed erosion control strategy would be 

sufficient to ensure no greater than minor impacts to salmonid from erosion or impacts to the 

riparian corridor. If the assessment finds that standard setbacks would be insufficient to avoid a 

long-term moderate or major effect on the salmonid habitat, wider buffers or staggered burning 

regimes would be implemented. Some of the strategies used to minimize impacts to soils are to 

avoid steep slopes, time burns to maximize favorable environmental conditions, and erosion 

control devices during burns.

Coho salmon and steelhead trout appear to be stable under the current PRNS management, 

including fire management actions that have been conducted over the past several years and 

would be continued under Alternative A. Prescribed fire, because it is used to restore the natural 

vegetation structure of park habitats and reduce the risk of catastrophic fire, would have a longterm benefit by protecting dense riparian habitat, keeping water temperature in appropriate 

ranges, and controlling sediment loading to the stream for these two species. This benefit would 

be limited by the relatively small area that would be burned annually (500 acres) under 

Alternative A. 

Unplanned Ignitions, Wildfire, and Suppression

As noted above, fire can modify the quantity, quality, and use of salmonid habitat by altering 

water temperatures, sedimentation rates, riparian vegetation, nutrient availability, food resources, 

and woody debris in streams. Also, the small to medium sized streams that provide habitat to 

coho salmon and Central California coast steelhead in the study area are particularly vulnerable 

to the effects of fire because they are located in steep confined valleys. Whereas prescribed 

burning is controllable, and can therefore be planned to avoid burning riparian vegetation, 

unplanned ignitions cannot. In addition, since unplanned ignitions can start anywhere, wildfires 

can burn hotter when they start. Suppression activities, including line construction, and drops of 

water or retardant, could also affect water quality or increase erosion temporarily. However, 

because wildfires in the study area are quite small on average, these adverse effects on coho or 

steelhead would be no more than minor and short-term. The effects of a larger wildfire are 

discussed in cumulative impacts. 

Mechanical Treatment

Hand thinning and pile burning actions taken to manage prescribed fire would have no-effect or 

negligible adverse effect on coho and steelhead trout and would not increase sedimentation. The 

impact is considered negligible because riparian areas and 100 foot buffer strips would not be 

treated and would reduce or eliminate any sedimentation increase. 
334 

California Freshwater Shrimp (Synacaris pacifica)- Endangered 

The California freshwater shrimp is found only in sections of a few coastal streams in Marin, 

Sonoma, and Napa counties. All are low gradient and low elevation streams with undercut banks, 

exposed roots, woody debris, or overhanging vegetation. They inhabit stream pools one to three 

feet deep and away from the main current where they hide among willow, blackberry, or other 

roots (Serpa, 1991). They feed on detritus, including fish that may die as streams dry to isolated 

pools in the later summer. Existing populations are threatened by introduced fish; deterioration 

or loss of habitat resulting from water diversion and impoundment; livestock, dairy, and other 

agricultural activities and developments; flood control activities; gravel mining; timber 

harvesting; migration barriers; and water pollution. In the study area, the shrimp is found in a 

portion of the main stem of Lagunitas Creek where it is generally protected from agricultural 

activities occurring within the watershed. All of Lagunitas Creek occurring in the park is located 

in the Bolinas Ridge FMU, which would receive treatment from prescribed burning in all 

alternatives, and from mechanical treatment in Alternative C. Small numbers of shrimp were 

collected in 1996 and 1997 near the confluence of Olema and Lagunitas creeks (Fong, 1999). 

Analysis

Prescribed Fire

The most important features of the environment inhabited by this species in the park are likely to 

be the continued presence of a structurally diverse stream environment and slower flowing or 

pooled water. Each of these is dependent on the presence of intact riparian vegetation. As noted 

above in the discussion of federally listed fish species and red-legged frogs, prescribed burning is 

generally not conducted in riparian vegetation. If a particular prescribed fire in the Bolinas Ridge 

FMU may affect riparian vegetation along Lagunitas Creek, park staff would make use of 

mitigation measures or other standard practices to ensure no habitat of the California freshwater 

shrimp is affected either directly or indirectly. In addition, prescribed fire, because it is used to 

restore the natural vegetation structure of park habitats and reduce the risk and possible extent of 

catastrophic fire, could offer long-term benefits for shrimp. Because the benefit to shrimp would 

be localized to sections of the Lagunitas Creek and would cover a small area, they would be 

negligible. These benefits could be short- or long-term, depending on whether the treated areas 

return to natural fire intervals quickly or need additional treatment. 

Unplanned Ignitions, Wildfire and Suppression

As noted in other sections, although the type of impacts from wildland fire and prescribed 

burning can be similar, their location and intensity can be quite different. The chance of an 

unplanned ignition burning riparian vegetation on the Lagunitas Creek is higher than prescribed 

burning and so impacts from changes in vegetation cover or stream flow characteristics are also 

higher. However, since so few acres burn from wildfire in the study area in an average year, it is 

both unlikely that riparian vegetation in the habitat area of the shrimp would be affected, and that 

the impact would be more than negligible if a fire did burn some of this vegetation. The same is 

true for suppression activities, which could have adverse effects from increases in erosion from 

line construction, or changes in water quality from retardant drops. Again, because of the small 
335 

size of most wildfires, the expected impact to shrimp habitat would be non-existent or negligible 

and short-term. 

Mechanical Treatment

No mechanical treatment of Bolinas Ridge FMU is planned for this alternative. Therefore, no 

impact to California freshwater shrimp is anticipated. 

Myrtle’s Silverspot Butterfly (Speyeria zerene myrtleae) – Endangered 

Myrtle’s silverspot butterflies inhabit coastal dune, coastal prairie, and coastal scrub habitats in 

the study area. It is believed to be extinct everywhere except inside and nearby PRNS. Reasons 

for its extinction include urban and agricultural development, invasive non-native plants, 

livestock grazing, over collecting, and other human impacts. Also, although the species uses 

several plants in the area to obtain nectar, it has only been known to use one, western dog violet 

(Viola adunca), to feed its larvae. The patchy nature of this plant in the area may also have 

contributed to the rarity of silverspot butterflies. 

Three populations are known in the area. One is near the Estero de San Antonio, a second is 

centered on North Beach, but extends from Abbott’s Lagoon to South Beach and east to Drakes 

Estero and Drakes Beach, and the third is on the Tule Elk Reserve. The highest numbers have 

been found along the dune-scrub interface in the back dune area of the central peninsula on F and 

G ranches and the AT&T property, and on the bluffs on either side of the Drakes Beach visitor 

center. All known populations inside the park are located in the Minimum Management Unit of 

the park, and would not be affected by prescribed fire or mechanical treatment. 

Silverspot numbers in the area outside of park lands around the Estero de San Antonio were 

estimated at 2,000-5,000 individuals in 1991. Other nearby areas with potentially suitable 

habitat were not surveyed. Together with those found at Point Reyes, estimated numbers for the 

three known populations of the species total less than 10,000 individuals (USFWS, 1998). Due to 

the lack of historic data previous to the 1990s, it is not known if the silverspot has declined at 

Point Reyes. While surveys of the two populations during the period 1993-1997 found that the 

Tule Elk Reserve population remained stable and the central Point Reyes population declined 

sharply, such variation is well within that normally found in Speyeria species (USFWS, 1998). 

Analysis

While it is difficult to determine the status of Myrtle’s silverspot population at PRNS given 

current information, the species does not appear to be at risk of extinction in the near future 

(Launer et al., 1992). In addition, the PRNS does not know if the population is stable, 

increasing, or declining because of lack of historical data. 

Cattle grazing has been identified as only one of a number of possible reasons for the species 

decline, but is also considered valuable in maintaining Myrtle’s silverspot habitat. While several 

areas have been identified where grazing may be adversely affecting the species’ habitat at 

PRNS, overall grazing management has helped maintain a variety of plant cover conditions in 

Myrtle’s silverspot habitats. 
336 

Under Alternative A, all of the occurrences of Myrtle’s silverspot are within the Minimum 

Management Fire Management Unit, and would not be subject to either prescribed burning or 

mechanical fuels treatments. The populations could be subject to impacts associated with an 

unplanned wildfire or by fire suppression activities, but this is unlikely because the populations 

occur within pastures routinely grazed by cattle where fire is unlikely to carry. 

 

Western snowy plover (Charadrius alexandrinus nivosus) – Threatened 

Western snowy plovers use the Point Reyes peninsula as both wintering and nesting habitat. 

Wintering birds occur around Drake’s Estero and Abbott’s Lagoon, and along Limantour Spit 

and the Great Beach. Nesting is occurring on the northern portion of Great Beach and along the 

western edge of Abbott’s Lagoon. 

 

Monitoring of nesting snowy plovers in 1986-1989 and 1995-2002 indicated a decline in the 

number of nesting birds through 1996, followed by a gradual rebound. This rebound is at least in 

part due to a program initiated in 1996 to increase nesting success. The program includes the use 

of signs, closures to dogs and/or human visitors, exclosures over nests and the use of docents to 

monitor visitor use and increase visitor education. The current nest protection program has raised 

nest success rates to levels similar to those at other coastal California locations. 

Analysis

All of the occurrences of western snowy plovers are within the Minimum Management Fire 

Management Unit, and would not be subject to either prescribed burning or mechanical fuel 

treatments. The populations could be subject to impacts associated with an unplanned wildfire 

or by fire suppression activities, but this is unlikely because the plovers occur in beach areas 

where fire is unlikely to carry. 

Ravens are the primary predator on eggs and small chicks of plovers. Ravens and crows may be 

attracted to fires because potential prey are exposed and concentrated around fires. Fires may 

indirectly affect plovers if ravens concentrate in burned areas adjacent to plover nesting habitat 

and if raven populations are enhanced by a boost in prey available during a fire. 

Additional Wildlife Species of Management Concern 

This section analyzes impacts to wildlife that are not federally listed, but may be affected by fire 

management activities. Because Point Reyes Mountain Beaver is most likely to experience 

impacts, it is treated separately. 

Point Reyes Mountain Beaver (Aplondontia rufa phaea) 

The Point Reyes mountain beaver, a muskrat-sized rodent found only in scrub habitat in western 

Marin and almost entirely in Point Reyes National Seashore, is listed as a Species of Concern by 

the US Fish and Wildlife Service and the California Department of Fish and Game. Two small, 

geographically isolated populations of mountain beaver live along the California coast, both of 

which are distinct subspecies. The Point Arena mountain beaver (A. r. phaea) is federally listed 

as Endangered. Its entire range encompasses approximately 60 km2

. Mountain beaver may be 
337 

adversely affected by actions described in the Fire Management Plan alternatives, but most 

particularly by large-scale unplanned ignitions. 

Analysis

Prescribed Fire

The mountain beaver was severely affected by the 1995 Vision wildfire in Point Reyes, 

presumably through direct destruction and dehydration, as roots and vegetation from which is 

obtains water was destroyed on over 12,000 acres. This species is known to require up to two 

cups of water per day to survive. However, prescribed fires in this alternative and all alternatives 

in this EIS would not burn large areas of brush, or burn with the kind of high intensity 

characteristic of the Vision wildfire. Mountain beaver would be able to outrun or avoid a 

prescribed burn over most of its habitat, and would be able to survive on neighboring plants until 

its habitat is revegetated. Revegetation would occur quickly, as prescribed burns are timed to fall 

before the rainy season in most cases. Ultimately, the kind of succulent plant material mountain 

beavers require would be more abundant as a result of controlled burning over the up to 500 

acres allowable under Alternative A. Mountain beaver are known to occur in Estero and 

Limantour FMUs, slated for prescribed burning in this alternative, and so a negligible to minor 

long-term benefit from using prescribed fire to reduce the risk and extent of a large-scale wildfire 

is likely. 

Unplanned Ignitions, Wildfire and Suppression

Studies conducted before and following the 1995 Vision Fire in Point Reyes revealed that Point 

Reyes mountain beaver suffered high mortality. Pre-fire estimates indicated about 5,000 

individuals in the area ultimately burned. Following the fire, only 19 live mountain beavers, or 

less than 1% of the pre-fire population, were located over this same area (Fellers et al., 2003). 

Major vegetation changes occurred in parts of the beavers’ habitat, including a reduction in 

coastal scrub and coyote brush. Monitoring in the years following the fire indicate that recovery 

of the populations has been slow (Fellers, 2003). 

Fellers (2003) recommended that fires in the vicinity Point Reyes mountain beaver not be 

allowed to burn substantial portions of areas occupied by mountain beaver. Periodic small fires, 

such as prescribed burns or wildfires in an average year at the park, would allow for normal 

changes in mountain beaver habitat by mimicking what was probably the natural fire regime with 

which these animals evolved. 

The following mitigation measures would be implemented: 

 

• identify and map areas known to support Point Reyes mountain beaver and areas that 

have habitat suitable for supporting Point Reyes mountain beaver, 

• protect known and potential habitat from unplanned ignitions, 

• establish buffer areas 30 feet wide around known habitat areas, and 

• conduct small burns (less than 100 acres) of mountain beaver habitat each year. 
338 

Implementing these mitigation measures would keep impacts of average wildfires in the study 

area to no more than minor and short-term. 

Mechanical Treatment

The presence of humans thinning brush or conducting other activities such as chipping could 

disturb mountain beavers, but the impacts would be minor and temporary. Mechanical treatment 

would help to remove fuels and reduce the risk of another catastrophic wildfire in the park. 

Because mechanical treatment would be limited in scope in this alternative, this beneficial 

impact would also be no more than a minor one, although over several years the reduction in risk 

could be a larger and more permanent one. 

Other Special Status Wildlife 

Analysis

Table 33 in Affected Environment lists several animal species in the project area that are listed as 

federal Species of Concern. Species of Concern are those for which USFWS is collecting 

additional information to determine if they warrant consideration for future listing. The animal 

Species of Concern lists 9 mammals, 23 birds, 3 reptiles, 2 amphibians, 3 fish, and 10 

invertebrates. The table also shows which species are potentially subject to adverse effects. 

Prescribed Fire 

The effects of fire on the animal species listed in Table 33 are not fully known. However, the 

park’s mean surface fire intervals of 7 to 13 years (Brown et al., 1999) indicate fire is an integral 

part of the natural ecosystem at Point Reyes. Fire research has demonstrated that fire plays a 

critical role in the management of many species of concern with regular burn intervals. For 

example, fire helps maintain open areas, creates a diversity of habitats, can create food sources, 

and in some cases, removes non-native competitors. Even though individuals of some Species of 

Concern may be killed by prescribed fire, the removal of competitors has a long-term beneficial 

effect as fire dependent native species will return, while the non-native competitors often will not 

(National Biological Service, 1995). 

Regarding effects on mammal species of concern, Ream (1981) summarized information in 237 

references about effects of fire on fauna. She concluded that populations of ground squirrels, 

pocket gophers, and deer mice generally increase after stand-replacing fire. On the other hand, 

Wirtz (1977) found that populations of brush mouse, western harvest mouse, and woodrat 

species decrease or disappeared in burned chaparral and grasslands. At Point Reyes, the 

mammals of concern are primarily bat species. Based on the limited number of acres to be 

burned and the ability o f bats to leave an area, minor short-term impacts could be both beneficial 

(creates food sources) and adverse (some mortality may occur in roosting sites). 

The species of concern Table 33 includes 23 species with only eight species that have the 

potential to be affected. The olive-side flycatcher and Pacific-slope flycatcher could be 

beneficially affected because studies have shown flycatchers (Wirtz, 1977) increased the first 
339 

year after a burn. White-tailed kites could be beneficially affected because raptors in general are 

unaffected or respond favorably to burned habitat (Smith, 2000). It is not known how other 

species of birds Allen hummingbird, short-eared owl, tricolored blackbird will respond to fire; 

however, because of the limited number of acres burned each year, the effects on populations of 

these species would be minor. 

Amphibians and reptiles Species on Concern on the USFWS list should not subject to adverse 

effect because most do not occur in the project area. Only one species, the northwest pond turtle, 

is known to occur and it major habitat - ponds - would not be subjected to burn treatments. 

No fish Species of Concern would be impacted by prescribed fire. 

There are ten invertebrate Species of Concern. The potential to impact these species is primarily 

unknown. However, soil protects most soil macrofauna and pupae of many insects from fire. In 

addition, a study by Evans (1971) indicates 40 species of arthropods are attracted to fire and 

many uses burned trees for breeding and food. 

To sum, based on the above and because prescribed fire would be limited in scope and would not 

involve a large component of the habitat of any population of animal Species of Concern, 

impacts to animal Species of Concern would be limited. This means both the potential for 

adverse or beneficial impacts would be no more than minor. Adverse impacts would be shortterm for the most part, but beneficial impacts could be long-term. 

Unplanned Ignitions, Wildfire, and Suppression 

The average acreage burned by wildfire in the study area is less than 30 acres; because it is small 

in scope, the chance of wildfire or suppression in an average year having more than a negligible 

or minor adverse impact to other special status wildlife is low. Impacts may be short- or longterm depending on the intensity of the fire or location and extent of suppression activities. 

Mechanical Treatments

Mechanical thinning activities such as mowing are not expected to have any long-term adverse 

impacts on the other special status species on Table 33. 

Regarding effects on mammal Species of Concern, at Point Reyes, the mammals of concern are 

primarily bat species. Based on the limited number of acres to be mechanically treated and the 

ability of bats to leave an area, minor short-term impacts could be both beneficial (creates food 

sources) or diverse (some food sources many be lost). 

The bird Species of Concern table includes 22 species with only eight species that have the 

potential to be affected. However, because of the limited number of acres to be mechanically 

treated each year and mowing would be done after the nesting season, the effects on populations 

of these species would be short-term and minor. There may be long-term beneficial effects 

because of the maintenance and creation of a mosaic of habitats. 
340 

Amphibians and reptiles species on concern on the USFWS list should not subject to adverse 

effect because most do not occur in the project area. Only one species, the northwest pond turtle, 

is known to occur and it major habitat - ponds - would not be subjected to mechanical treatments. 

No fish Species of Concern would be impacted by mechanical treatments. 

There are ten invertebrate Species of Concern. The potential to impact these species is primarily 

unknown. However, because soil disturbance would be minimal and the total number of acres 

to be treated is small, impacts would be short-term and negligible to minor. 

To sum, based on the above and because mechanical treatments would be limited in scope 

(compared to total park acres) and would not involve a large component of the habitat of any 

population of animal Species of Concern, impacts to animal Species of Concern would be 

limited. This means both the potential for adverse or beneficial impacts would be no more than 

minor. Adverse impacts would be short-term for the most part, but beneficial impacts could be 

long-term. 

Effects of Fire Information/Education on Special Status Wildlife 

Impacts associated with fire information and education would largely be indirect and beneficial, 

although they would be highly dependent on the nature of the fire management action on special 

status species. Pre-planned events such as prescribed fires and mechanical treatment provide the 

opportunity to demonstrate the effectiveness of natural resource management to local 

communities and the interested public. During unplanned events, such as wildfires, time for 

effective communication is often more limited and can be more controversial since resources are 

often damaged. However, education does not usually have a direct effect - positive or negative - 

on impacts to special status species. In some cases, education can be used to enforce a closure 

of an area to ensure a special status species is protected or to ensure voluntary compliance for 

actions that would help ensure the survival of the special status species. 

Effects of Fire Cache/Park Headquarters Relocation and Construction on Special Status Wildlife 

No adverse or beneficial indirect effects are anticipated with the construction of the new fire 

cache. The building site is a former trailer pad that was recently removed in the main developed 

area of the park at Bear Valley and has already been heavily impacted. The area has been 

surveyed and has no special status species in the construction footprint. 

Fire Effects and Fuel Management Research

No adverse or beneficial direct effects are anticipated on wildlife from the implementation of 

Alternative A research projects. There are indirect beneficial effects for conducting research that 

would help identify future management prescriptions for special status species protection. 
341 

Cumulative Impacts of Alternative A to special status plant and animal species 

This section describes impacts from sources other than the fire management plan that have or are 

adversely affecting the special status species analyzed above, or that may adversely affect them 

over the life of this plan. The known sources of impact are human development and human 

activities both inside and outside the park, construction activities listed in Appendix C, and a 

large-scale wildfire in the region. 

Perhaps the largest threat to these species from park activities is the risk of a large-scale fire 

similar to the 1995 Vision Fire. The effects of such a fire would be intensified by the fuel 

buildup in the park associated with a policy of fire suppression over the last 150 years. As did the 

Vision Fire, another very large and hot fire could create a multitude of habitat changes and 

serious impacts for park wildlife, including extensive forest gaps, discontinuous habitat, and 

greater consumption of large woody debris than what would be expected under natural fire 

conditions. High-severity fires in Point Reyes are characterized by extensive burned areas that 

may be continuous from ridgeline to slope bottom and include riparian areas, eliminating habitat 

for several of the species identified above, such as red-legged frogs, coho, steelhead and 

California freshwater shrimp. In addition, there would be a type conversion of habitat in some 

areas - forest to brush/grassland and some long-term loss of forest habitat. This change in habitat 

could have short-term major adverse impacts or long-term moderate impacts to species status 

species in the burned area. For example, the Vision Fire had a major adverse effect on mountain 

beaver, and the population is only slowing recovering (Fellers, 2003). 

A secondary widespread and serious consequence of catastrophic fire is the increase in erosion 

and turbidity that follows the loss of vegetation. Sediment loads following a wildland fire similar 

to the Vision Fire would be expected to be at least twice the normal load under natural conditions 

(Ketcham, 2003). The sediment loads and lack of riparian vegetation would have adverse, 

moderate, long-term impacts (more than two years) to special status fish and aquatic species such 

as coho salmon, steelhead trout, and red-legged frogs. However, vegetation would return in the 

long run, as it has following the 12,000+ acre Vision Fire, and rates of erosion would return to 

rates within the natural rate of variability, preventing long-term impairment of park resources. 

Species specific cumulative impacts from both large-scale fire and other relevant sources are 

described below: 

Northern Spotted Owl. Cumulative impacts to spotted owls come from development, visitor use, 

habitat changes, and can come from large-scale fire. 

Visitor use in the park is expected to increase along with the projected human population 

increase in the San Francisco Bay Area. With increased visitor use of the park, the potential for 

human disturbance of owls along trails may increase. To reduce visitor impacts to owls, the park 

does not publish the location of owl activity centers and distributes a flyer on how to behave 

around owls. 
342 

Oaks in Marin and Sonoma counties have been dying suddenly over the past few years as a result 

of a fungus. The die-off, called Sudden Oak Death (SOD), has spread throughout Marin county 

and is currently in some owl habitat in the park. The death of the oaks results in local changes in 

percent cover and in food availability of the dusky footed woodrat, the primary prey of owls, at 

PRNS (Chow and Allen, 1996). Widespread habitat conversion is not expected from SOD in the 

study area; however, park biologists are monitoring the distribution of the die-off. Additionally, 

UC Berkeley (P. Gong, Professor, ESPM, UCB, pers. com.) is mapping the spread of the disease 

throughout Marin County. 

An ongoing threat to spotted owls is development, which removes habitat and creates smaller 

blocks of forest, or forest that is discontinuous. As noted in Affected Environment, smaller 

isolated tracts of forest that would otherwise be suitable do not meet the needs of spotted owls, 

which require large contiguous blocks. Of the four categories of land described below, private 

land without conservation easements or other protection is most vulnerable to development. 

Public land protected from development in perpetuity. These include the 2,700 acre Samuel P. 

Taylor State Park and the 21,250 acres held as watershed and public recreation areas by the 

Marin Municipal Water District (MMWD). These lands border the Northern District of GGNRA 

along Nicasio and Bolinas Ridges and provide unbroken habitat connections to an extensive area 

of central Marin County. The Tomales Bay State Park provides unbroken habitat along the east 

side of the bay contiguous to GGNRA lands at and near the mouth of Lagunitas Creek. 

Privately owned conservation land. Land that has been purchased by non-profit groups for 

conservation purposes offer long-term habitat protection only slightly less secure than that of 

publicly held land. The Audubon Canyon Ranch (ACR) includes an inholding on Bolinas 

Lagoon that connects GGNRA lands adjoining it. Other ACR holdings on Tomales Bay protect 

undeveloped bay frontage adjoining State Park lands. A second non-profit group, the Vedanta 

Society, holds a 2,143 acre parcel in the Olema Valley bounded by PRNS and GGNRA lands. 

Acquisition of this land by the NPS has not been pursued because the Vedanta Society conducts 

only low impact activities on the property. Acquisition could still take place if management of 

the land was considered inconsistent with NPS policies. 

Private land. In 1971, county supervisors enacted A-60 zoning (one house per 60 acres) for much 

of western Marin, significantly limiting the development potential of agricultural properties. 

Such zoning covers extensive areas of private land adjoining public park and watersheds, 

including San Geronimo Valley, Nicasio Valley, and the northwestern portion of the county. 

Since that time, zoning for the West Marin Planning Area has been elaborated to include a 

variety of zoning densities in areas adjacent to established towns, with minimum lot sizes 

ranging from one unit per acre to one unit per 60 acres. 

While these policies provide substantial protection for owl habitats, they could be overturned by 

the county Board of Supervisors, and so cannot be regarded as permanent protection. At this 

time, support for low-growth, low-density development policies in Marin County is high and it 

seems highly unlikely that this will change in the future. 
343 

Private land with conservation agreements. Agricultural land in west Marin has been and 

continues to be at risk of being broken up into the large residential lots permitted by county 

zoning. To prevent this, a private non-profit land trust, the Marin Agricultural Land Trust 

(MALT), has been acquiring development rights to agricultural land since 1980. At present, this 

group holds the rights for over 30,000 acres on 43 ranches in western Marin County. Like other 

conservation lands held by non-profit groups, the security of protection of these lands depends 

on the future financial condition of the non-profit, which in the case of MALT appears to be 

secure. 

The impact of a large wildfire on spotted owls would be habitat destruction. As noted in Affected 

Environment, this species requires greater than 60% total canopy cover for nesting/roosting with 

large overstory trees, large amounts of down woody debris and the presence of trees with defects 

or signs of decadence in the stand. This old growth type forest in the park may have the high 

fuel loading and ladder fuels to feed a hot stand-replacing fire, which would eliminate the habitat 

for many years. In a large wildfire, such as the Vision Fire, the chances of directly destroying 

nests or habitat could be quite high. Suppression activities such as water and retardant drops 

would have an adverse effect on spotted owls if they occurred over nesting habitat and, 

especially, nests. Such events are less likely than direct destruction of nests or habitat to occur, 

and impacts would be mitigated if nest sites and probable nesting habitat could be avoided. 

Helispots and spike camps would potentially have an adverse effect on spotted owls if they were 

located close to nesting or roosting areas and the level of disturbance were high. Hand-line for 

suppression, if constructed through a spotted owl nesting or roosting area, would potentially 

cause adverse effects from disturbance and habitat alteration, especially if trees were felled. 

Snags are often used by spotted owls as nest sites. As such, snagging operations to protect 

human safety and the integrity of fire lines would potentially have an adverse effect on spotted 

owls. 

Red-legged Frogs. As described above, lands outside of PRNS and GGNRA offer substantial 

protection for wildlife through conservation easements, zoning, and low-impact land use 

practices. Extensive areas adjoining the study area preserve continuous habitat and much of that 

land is occupied by the red-legged frog. These parcels include nearly 25,000 acres of public land, 

thousand of acres of conservation land privately held by non-profit groups, and over 30,000 acres 

of private land with conservation easements preventing development. In addition, much of 

western Marin is zoned at a very low density, particularly where it adjoins watersheds where redlegged frog habitat exists. 

Additional impacts to frogs may come from actions listed in Appendix C, including some 

restoration projects such as of the Giacomini wetlands or of fisheries in streams where frogs are 

known to occur. Impacts would be avoided, minimized, or mitigated however, and all project 

sites would be reviewed prior to implementation with the park GIS database. If there was 

potential for a take, the park would have staff specialists survey the site and provide 

recommendations for avoidance or mitigation. In the long-term, these fisheries restoration 

projects would benefit frogs by enhancing natural processes, including reduction of erosion and 

stream temperature and enhanced water quality. 
344 

Human activities may have had both direct and indirect effects on red-legged frogs. 

Development has removed habitat, and logging or other activities may have adversely affected 

geomorphological stability, erosion rates or river channels. For example, historic logging of parts 

of Inverness Ridge, channel alterations in the lower 2.8 km of Olema Creek, and the effects of 

highway culverting have removed suitable habitat along Olema Creek and its tributaries may 

have been. Areas of downcutting, bank cutting, and sedimentation are present along the 

mainstem and its tributaries, resulting in a probable reduction in numbers of backwaters and 

pools. 

Ranching may also have adversely affected frog habitat, although since coming under NPS 

ownership and oversight, ranching practices on PRNS ranchland have been modified in ways 

that have likely benefited California red-legged frogs. Especially effective have been the 

reductions of cattle numbers on excessively grazed ranchlands and exclusion of cattle from a 

number of wetland sites. The species appears to be thriving under the current PRNS management 

of grazing lands, although cattle may be having adverse impacts in some locations. Current 

information supports the conclusion that grazing may both benefit and harm red-legged frogs, 

and that more research on optimal habitat conditions for the species is needed. Because 

cessation of grazing may be more deleterious to the species than its continuation, however, 

ranching permits would be renewed. Efforts to identify and protect potentially vulnerable 

habitats and to develop research that would improve knowledge of the best habitat conditions for 

the species, as described in the Draft Recovery Plan (USFWS, 2000), would be undertaken. 

As noted above, fire can adversely affect frogs by removing riparian vegetation, and through the 

increase in sedimentation accompanying vegetation removal. Both of these effects would be 

more likely and more severe in a large-scale wildland fire than under a regime of prescribed 

burning or average wildland fire conditions. 

PRNS is currently conducting a wetland mapping and assessment project within the public lands 

of the Tomales Bay watershed, including Olema Creek, Lagunitas Creek, and Tomales Bay FMP 

watersheds. The purpose of this project is to map wetlands and to conduct functional 

assessments of the wetland features within the watershed. Wetlands were previously 

documented using National Wetlands Inventory (NWI) procedures, which produced incomplete 

wetland mapping for PRNS and some areas of GGNRA. Only larger, more visible wetland types 

were mapped, while many of the variety of wetland types found at Point Reyes were missed. 

When completed, this work would provide data needed for future wetland protection, restoration, 

and planning. Such protection would likely benefit red-legged frogs and water quality within the 

project area. 

Dating back to the late 1800s, West Marin County was a popular destination for salmon fishing. 

Records of salmon hatchery releases to Lagunitas Creek and even Bear Valley Creek occurred 

even in the 1890s. Lagunitas Creek (then known as Papermill Creek) still holds the distinction 

as having produced the state record, 22 pound, coho salmon (caught by Milton T. Hain, January 

3, 1959). Interviews with long time residents and fisheries managers suggest that coho and 

steelhead in the project area have been declining since the turn of the century, with significant 

declines occurring as late as the mid-1950’s. Most historic information on salmonid numbers is 

anecdotal, while quantified data are lacking. Accounts by local residents of “excellent trout 
345 

fishing” along Lagunitas and Olema creeks may refer to young steelhead, which are 

indistinguishable from rainbow trout during the three year period they typically spend in fresh 

water. Similarly, early accounts of “salmon runs” may refer to both coho and steelhead, which 

may not have been distinguished by fishermen. Such anecdotal information suggests that 

salmonids were abundant in the Lagunitas/Olema Creek drainage before extensive alteration by 

dam-construction, logging, and channelization. On its 1996 federal listing, the Lagunitas 

watershed, including Olema Creek, was documented to support 10% of the Central California 

Coast coho population (Brown et al., 1994; NOAA Fisheries, 1996). 

The mouth of Lagunitas Creek and adjacent floodplain supports activities associated with the 

Waldo Giacomini dairy. This 563-acre property, once tidal wetlands, was diked and drained in 

the early 1940s to create pastures. For many years, a gravel dam was constructed annually just 

below the confluence of Lagunitas and Olema creeks for irrigation and stock watering. The dam 

created an abrupt transition from fresh to saline water for smolts and spawning adults, 

eliminating the transition zone found in an unimpaired estuarine system. The transition zone 

allows smolting fish time to adjust to saline conditions and provides productive feeding zones 

where both freshwater and saltwater invertebrates are available (SWRCB, 1995). 

The dam and the levees concentrated the area where spawning fish could hold and smolts could 

feed, and increased the potential for predation. While the annual construction of the dam has 

been discontinued, the levees are still in place. PRNS is currently acquiring these lands and 

developing a floodplain restoration plan. A phased restoration project requiring from five to ten 

years is planned to begin after final acquisition in 2007. Such restoration is expected to improve 

estuarine smolt and adult emigration habitat for both coho and steelhead. 

The Coastal Watershed Restoration Project, proposed for nine sites within the Drakes Estero 

Watershed is planned for construction in 2006. The activities proposed through this project will 

remove or replace facilities such as road culverts and impoundments that impede natural 

freshwater and estuarine process. All treatment sites will meet fish passage design guidelines 

established by the NOAA Fisheries and CDFG (NOAA Fisheries, 2001; CDFG, 2003). 

A large-scale wildfire could have moderate impacts on either species by removing riparian 

vegetation, increasing water temperature and removing upslope vegetation, with resultant 

increases in erosion and sedimentation. As noted above, the streams in which coho and steelhead 

exist in the study area are often in narrow, confined valleys with steep, vegetated slopes. A large, 

hot wildfire in such a valley would be difficult to suppress, and could quickly destroy riparian or 

slopeside vegetation. Suppression activities could also have short-term moderate effects through 

retardant drops and resultant changes in water quality. 

Western Snowy Plover. Along the California coast, western snowy plovers have been extirpated 

from 33 of 53 nesting sites since 1970, and now number approximately 1,400 birds (USFWS, 

1993). Although it is not one of the eight areas that support 78 percent of the California coastal 

breeding population, PRNS is 1 of only 20 remaining plover breeding areas in coastal California 

(USFWS, 1993). The Point Reyes peninsula is one of the largest relatively undisturbed beach 

habitats on the California coast, providing a large area of potential snowy plover habitat free of 
346 

threats that have impaired habitat elsewhere, such as development, ORV use, and heavy visitor 

use. 

Fledging rates for snowy plovers before nest protection began were insufficient to maintain the 

species at PRNS, as indicated by declining numbers of nests and nesting adults in the period 

1986-1995. Continuation of such low nest success rates could have resulted in loss of the PRNS 

breeding population of snowy plover. The current nest protection program has raised nest 

success rates to levels similar to those at other coastal California locations (USFWS, 1999a), but 

would be costly to maintain indefinitely. 

Myrtle’s Silverspot Butterfly. The largest numbers of Myrtle’s silverspot butterflies documented 

in the early 1990s occurred on private land in the vicinity of Estero de San Antonio in Marin 

County northeast of PRNS. A golf course development proposed at that time was withdrawn, 

and the area is currently ranchland grazed by cattle and sheep. It is given a measure of 

protection from development by Marin County’s agricultural zoning and policies to maintain the 

integrity of ranchlands in the western half of the county. Several of the ranches in the habitat 

area have sold development rights to the MALT, an organization seeking to preserve agricultural 

land in western Marin County. Any proposed development would have to comply with 

requirements of the ESA to protect the Myrtle’s silverspot. 

While it is difficult to determine the status of Myrtle’s silverspot population at PRNS given 

current information, the species does not appear to be at risk of extinction in the near future 

(Launer et al., 1992; A. Launer, Stanford University, pers. com.). Cattle grazing has been 

identified as only one of a number of possible reasons for the species decline, but is also 

considered valuable in maintaining Myrtle’s silverspot habitat. 

Cattle grazing has been identified as only one of a number of possible reasons for the species 

decline, but is also considered valuable in maintaining Myrtle’s silverspot habitat. While several 

areas have been identified where grazing may be adversely affecting the species’ habitat at 

PRNS, overall grazing management has helped maintain a variety of plant cover conditions in 

Myrtle’s silverspot habitats. 

Conclusion 

All known individuals of the seven federally listed as threatened and endangered plant species in 

the study area occur in the Minimum Management Fire Management Unit, and so would not be 

subject to either prescribed burning or mechanical fuels treatments. The populations could be 

subject to impacts associated with an unplanned wildfire or by fire suppression activities, but this 

is unlikely because the populations occur in wet sites, within pastures routinely grazed by cattle, 

or on beaches or rocky outcroppings where fire is unlikely to carry. 

Plant species that are not federally listed, but are of concern would likely continue to receive 

minor long-term benefits from prescribed burning and mechanical treatment, and the eventual 

return of natural fire cycles. Some patches or individuals of these species may experience minor, 

adverse effects from destruction through fire or suppression, or from the inadvertent stimulation 

of invasive exotic species from burning. 
347 

Prescribed fire and mechanical treatments would offer negligible to minor, long-term benefits on 

a limited scale to northern spotted owls, red-legged frogs, and California freshwater shrimp (the 

latter from fire only) by reducing the threat of catastrophic fire and the habitat destruction it 

would bring. Mechanical treatments such as hand thinning and pile burning to manage prescribed 

fire would have a minor, short-term, adverse effect on owls through possible human disturbance, 

reduction of prey species, and habitat alteration in unknown roosting and nesting sites, and on 

frogs from inadvertently killing individuals. No mechanical treatment is planned in the Bolinas 

FMU, in which habitat of the freshwater shrimp occurs. Large-scale wildfires could have more 

serious adverse effects on owls by eliminating habitat, and on frogs by burning riparian 

vegetation and increasing sedimentation. Both these species experience a positive cumulative 

impact from the large blocks of conservation land adjacent to the study area. 

Adverse impacts to coho salmon and steelhead trout from prescribed burning would be 

negligible to minor, as riparian vegetation would be retained. Negligible positive benefits from 

reducing the risk and extent of a catastrophic burn would result from both prescribed burning and 

mechanical thinning. A large-scale wildfire would have more serious adverse effects by 

increasing siltation of streams and burning riparian vegetation, which in turn would increase 

water temperature. 

Both Myrtle’s silverspot butterfly and snowy plovers occur only in the Minimum Management 

FMU, and so would not be subject to either prescribed burning or mechanical fuel treatments. 

The populations could be subject to impacts associated with an unplanned wildfire or by fire 

suppression activities, but this is unlikely because the populations occur within pastures routinely 

grazed by cattle (silverspot) or beach areas (plover) where fire is unlikely to carry. 

The impacts of fire management activities, including those of average size and intensity wildfires 

in the study area on Point Reyes mountain beaver would be kept to no more than minor and 

short-term through the use of mitigation measures. Large-scale wildfires could have moderate 

adverse impacts that may be long-term. 

There would be some indirect long-term benefits by conducting research and fire education. 

There are no adverse impacts to special status species by the construction of the fire cache. 

No impairment to park special status species would occur from implementing Alternative A. 

Alternative B 

Impacts on Federally Listed Plant Species 

Analysis

All of the plants identified above in Alternative A as on the federal list of threatened and 

endangered species are located primarily in the Minimum Management FMU, which is not 

treated by prescribed fire or mechanical thinning. These species include the Sonoma spineflower, 

Robust spineflower, Tiburon paintbrush, Marin dwarf flax, beach layia and Tidestrom’s lupine. 
348 

Although this FMU may have some small wildfires, on average no more than about 30 acres of 

the entire study area burns in a given year. Since most of these plants are located in well grazed 

pastures or rocky outcrops, they are unlikely to be burned by wildfires in the park in average 

years. The impacts of Alternative B are the same as Alternative A on all of these species, with 

the exception of Sonoma alopecurus, which does occur in the Palomarin FMU. It is treated 

separately below. 

Sonoma alopecurus (Alopecurus aequalis var. sonomensis) – Endangered 

Sonoma alopecurus is a perennial grass that grows in the park primarily on pastures in 

agricultural areas. It favors moist or wet sandy soils. 

 

Other Special Status Plant Species 

Analysis

Under Alternative B, 9 FMUs are treated for a total of up to 2,000 acres per year. Estero, 

Inverness Ridge, Limantour, Wilderness North, Wilderness South, Highway One, Inverness 

Ridge, and Palomarin FMUs would be treated with both prescribed fire and mechanical thinning. 

Tomales Point would only be mechanically treated, and Bolinas Ridge FMU treated only with 

prescribed fire. 

Prescribed Fire

As noted in the analysis in Alternative A, fire is an integral part of the natural ecosystem at Point 

Reyes and likely plays a critical role in the management of many plant and animal species of 

concern by maintaining open areas or stimulating reproduction. Prescribed burning may kill 

some individuals of these species, but it would also remove competitive non-native species and 

would have a beneficial impact in the long-term because of this. While this benefit would remain 

minor, it could conceivably be double or more that of Alternative A depending on the location of 

populations of each species. For example, Alternative B would use prescribed fire to treat areas 

in Inverness Ridge FMU, Wilderness South, and Palomarin FMUs. All of these FMUs have 

Marin manzanita, a species considered rare and declining inside the park because it requires fire 

to flourish. Adverse impacts would also be no more than minor and short-term, but could be 

more severe or widespread than in Alternative A, again because additional acreage would be 

burned. 

Unplanned Ignitions, Wildfire, and Suppression

No changes in impacts from unplanned ignitions, average annual wildfires or their suppression 

are expected in this alternative from those described for Alternative A. 

Mechanical Treatments

Mechanical treatment is not expected to have any adverse impacts on special status plants as 

mowing would be done in the fall and rare plants populations would be excluded from treatment 

areas. 
349 

Fire Information/Education

No impact to any plant special status species is expected from the distribution of fire information 

or education. 

Fire Cache/Park Headquarters Relocation, and Construction

Because the area where the fire cache is planned would be surveyed prior to construction, 

impacts to protected plant species would be minimized. It is possible that individuals would be 

affected, but the extent of the effect would be minor. 

Fire Effects and Fuel Management Research

No specific effects to any special status plant species from fuel management research under 

Alternative A are expected. However, small controlled burns in Bolinas Ridge and Palomarin 

FMUs would be conducted to determine post-burn species richness of native plants, and to 

determine if reducing the density of non-native species is possible using prescribed fire. Two 

special status plant species occur in these two FMUs. Although the federally endangered Sonoma 

alopecurus did occur at one time in the Palomarin FMU, this population has been extirpated. 

Federally Listed Wildlife 

Northern Spotted Owl (Strix occidentalis caurina) - Threatened 

Under Alternative B, potential effects on northern spotted owls are greater than Alternative A 

because additional FMUs are being treated that are considered habitat. Two additional FMUs to 

be treated, in particular, Wilderness North and South, have considerable spotted owl habitat, and 

owls nest in the Inverness Ridge FMU as well. 

Prescribed Fire

As noted in Alternative A, fuels have built up in spotted owl habitat making catastrophic, standreplacing fire more likely. Such as fire would destroy spotted owl habitat for many years; 

prescribed burning is considered an important tool in helping to reduce these unnatural 

accumulations of fuels and ladder fuels and preserve owl habitat. 

Preparatory burns and mechanical fuel reduction would be used to control fire intensity in areas 

in owl habitat, and no treatment would occur within 400 meters of a nesting or known roosting 

site. Prescribed fire planning also takes into account other important habitat components, such as 

down, woody debris that provide habitat for dusky-footed woodrats, which are an important prey 

species for northern spotted owls in the project area. If a prescribed burn does reduce the amount 

of woody debris, or would otherwise adversely affect woodrat habitat or nests, it would have an 

indirect minor, short-term, adverse effect on spotted owls. 
350 

Currently, no program elements exist for the management of prescribed fires for the benefit of 

spotted owls. The use of prescribed fire under Alternative B, would, nonetheless, have a 

beneficial, long-term, and minor impact on northern spotted owls, primarily through reduction in 

the threat of catastrophic fire in some areas. 

Unplanned Ignitions, Wildfire, and Suppression

No impacts different than those described above for Alternative A would result from unplanned 

ignitions, wildfires or suppression in Alternative B. To sum, because average annual acreage 

burned from wildfires at the park is quite low, any more than minor adverse impacts from 

average annual wildland fires is unlikely. 

Mechanical Treatments

Under Alternative B, hand thinning or mechanical treatments in the vicinity of development and 

roads such as on Bolinas Ridge, Wilderness North, Wilderness South, and Highway One FMUs 

could have an adverse effect on spotted owls if canopy closure was substantially reduced. This 

is especially true where developed areas interface with dense forest that provides roosting and 

nesting habitat. Under Alternative B, cutting large trees would be limited because techniques 

would be confined to hand thinning and then piling and burning. In some areas, clearing 

understory vegetation could, in fact, improve foraging conditions for spotted owls and habitat for 

it prey item - woodrats. Overall, impacts would remain localized and therefore minor. 

Chipping over a wider area of the park and in more owl habitat than in Alternative A would be 

conducted under Alternative B. Chipping cut material and then distributing it over a site could 

occur where air quality, visitor use, or other management concerns prohibit burning. The 

equipment used to chip material is extremely loud and, if operated nearby, may disturb spotted 

owls. Although more chipping would take place in this alternative, impacts to owls would still be 

localized and temporary, and would therefore be no more than minor. 

Fire Information/Education

No impact to spotted owls from the distribution of fire information or education is expected. 

Fire Cache/Park Headquarters Relocation, and Construction

The fire cache would not be located in the vicinity of spotted owl activity centers or potential 

habitat, so no impact is expected. 

Fire Effects and Fuel Management Research

No effects to spotted owls from fuel management research under Alternative B are expected. 
351 

Red-legged Frog (Rana aurora draytonii) – Threatened 

Analysis

Prescribed Fire

Prescribed fire, because it is used to restore the natural vegetation structure of park habitats and 

reduce the risk of catastrophic fire, would have a long-term benefit to red-legged frogs and their 

habitat. Although this benefit would remain somewhat limited, it would be greater than 

Alternative A. In particular, frogs in the Palomarin, Inverness Ridge, Wilderness South, and 

Wilderness North FMUs would be benefited, as these FMUs are not subject to prescribed fire in 

alternative A. 

High levels of fuel loading in some areas may cause prescribed fires to burn at higher than 

natural intensities, even when fire prescriptions were designed to minimize high-intensity fires. 

Higher intensity burns could inadvertently kill individual frogs or dry out pond habitat or 

vegetation the frogs need to move between ponds. They could also increase sedimentation. 

However, the extent of these types of impacts under the prescribed burn program proposed in 

this alternative would be quite small, or perhaps even largely non-existent, and adverse impacts 

would be negligible. In addition, burn plans in frog habitat would be reviewed and important 

frog habitat avoided if prescribed fire would be damaging. 

Unplanned Ignitions, Wildfire, and Suppression

The same short-term and negligible adverse impacts from small wildfires as described in 

Alternative A would be possible in this alternative as well. 

Mechanical Treatment

Mechanical treatment such as hand thinning, line construction, and pile burning could disturb 

frogs or alter their habitat. However, impacts would be no more than negligible because breeding 

areas and adjacent non-breeding areas would be identified and avoided before any mechanical 

treatment is taken. 

Reduction in fuel loading by hand thinning or mechanical treatment would have a negligible, 

long-term, beneficial effect on red-legged frogs by reducing fuel loads and the threat of 

catastrophic fire. 

Central California Coast Coho Salmon (Oncorhynchus kisutch) – Threatened and Central 

California Steelhead (Oncorhynchus mykiss) - Threatened 

Central California coast coho salmon and Central California steelhead (hereafter referred to as 

coho and steelhead) occur in several creeks on the Point Reyes peninsula and in the Lagunitas 

Creek watershed that drains portions of PRNS and GGNRA. In addition to treatments in the 

Bolinas Ridge, Highway One, Estero, and Limantour Road FMUs, five new treatment areas are 
352 

identified in Alternative B. The Wilderness North FMU is included in the Tomales Bay, Drakes 

Bay, and Drakes Estero watersheds. The Wilderness South FMU is included in the Drakes Bay, 

Olema Creek, and Pine Gulch Creek watersheds. The Inverness Ridge FMU is included in the 

Drakes Estero and Tomales Bay Watersheds. The Palomarin FMU is located in the Drakes Bay 

and Bolinas Drainage watersheds. The Tomales Point FMU is located on the Tomales Bay and 

Pacific Drainage watersheds (see Figure 16). Designated critical habitat for coho in PRNS 

includes all accessible estuarine and stream areas in the coastal watersheds of Marin County 

except areas above longstanding, naturally impassable barriers or above Peters Dam on the 

mainstem of Lagunitas Creek and Seeger Dam on Nicasio Creek (NMFS, 1999). Although 

critical habitat has not been established for central California steelhead, it is likely to be the same 

as that for coho in Marin County. 

Tomales Bay Watershed

Under Alternative B, the Limantour Road, Wilderness North, and Inverness Ridge FMUs would 

be subject to mechanical treatment and prescribed fire. The Tomales Point FMU would be 

subject to mechanical treatment. These FMUs represent 8% of the total watershed area (see 

Table 42). 

Lagunitas Creek Watershed

Treatment under Alternative B would be the same as under Alternative A. 

Olema Creek Watershed

Under Alternative B, the Bolinas Ridge FMU would be subject to prescribed fire while the 

Highway One FMU would receive both prescribed fire and mechanical treatment within the 

Olema Creek watershed. These FMUs encompass 20% of the total watershed area (see Table 

42). 

Drakes Bay Drainages

Under Alternative B, the Limantour Road, Palomarin, Wilderness North, and Wilderness South 

FMUs would be subject to mechanical treatment and prescribed fire. These FMUs represent 

20% of the total watershed area (see Table 42). 

Drakes Estero Watershed

Under Alternative B, the Estero, Limantour Road, Inverness Ridge, and Wilderness North FMUs 

would be subject to mechanical treatment and prescribed fire. These FMUs represent 31% of the 

total watershed area (see Table 42). 

Pacific Drainages 

The Pacific drainages do not support threatened salmonid species. Under Alternative B, the 

Tomales Point FMU would be subject to mechanical treatment. 
353 

Bolinas Drainages

Under Alternative B, the Bolinas Ridge FMU would be subject to prescribed fire while the 

Highway One and Palomarin FMUs would receive both prescribed fire and mechanical treatment 

within the Bolinas Drainages. These FMUs represent 33% of the total watershed area (see Table 

42). 

Pine Gulch Creek

Under Alternative B, the Bolinas Ridge FMU would be subject to prescribed fire while the 

Highway One and Wilderness South FMUs would receive both prescribed fire and mechanical 

treatment within the Pine Gulch Creek watershed. These FMUs represent 26% of the total 

watershed area (see Table 42). 

Analysis

Under Alternative B, the treatments proposed could affect coho salmon and steelhead trout 

because eight of the nine FMUs to be treated have one or both species of fish. Highway One 

FMU has the greatest potential for possible impacts because of its proximity to Olema Creek and 

Pine Gulch Creek. The FMU surrounds the road corridor and includes more than 8 kilometers of 

mainstem habitat supporting coho salmon and steelhead trout. 

Prescribed Fire

Prescribed fire is more controllable than wildfires, and through the use of mitigation measures 

identified in the review of each burn plan, impacts would be minimized so they are no more than 

negligible or minor. For example, riparian vegetation is important in protecting fish and keeping 

water temperatures lower. Burn plans for fires where coho or steelhead habitat is present would 

include a no-treatment buffer to protect riparian vegetation. Research indicates leaving a buffer 

would eliminate any increases in water temperature during or following burning (McMahon and 

deCalesta, 1990). 

High levels of fuel loading in some areas of the park may create hot spots, or prescribed fires that 

burn at higher than natural intensities. This would decrease over time as more and more acreage 

is cumulatively treated, but could cause increased run-off and nutrient loads, even when fire 

prescriptions are designed to minimize high-intensity fires. Some fish species can begin to 

experience stress at relatively low sediment concentrations of 50 mg/l, but salmonids are know to 

thrive even in highly turbid rivers. The impacts from any increases in sediment loading resulting 

from prescribed burning are likely to be no more than minor, and would be short-term, lasting 

only until slopes are revegetated. 

In addition to mitigation measures identified in Alternative A, Mitigation Measure S-2 would 

need to be considered for treatments in the Bolinas Drainages, Olema Creek, and Pine Gulch 

Creek watersheds, where the 1,000 acre potential annual treatments exceed more than 10% of the 

total watershed area. Mitigation Measure S-2 would be triggered when proposed actions have 

the potential to exceed 10% of the total area of one or more FMP watersheds in one year, which 
354 

could result in a minor to moderate impact to salmonids in a given watershed. Mitigation 

Measure S-2 assures that planning considers the watershed scale and, if a potential effect is 

identified, that specific adjustments to the burn density and schedule are included in the 

workplan. As shown in Table 42, the combined project acreage must exceed 790 acres in 

Bolinas Drainages, 939 acres in Olema Creek Watershed, and 506 acres in Pine Gulch 

Watershed. 

Once it is confirmed that an annual plan for prescribed burning would exceed the 10% level of 

area in these smaller watersheds, Mitigation Measure S-2 requires an interdisciplinary team 

evaluation, chaired by the Fire Management Officer, to document the plan and identify actions 

that may reduce the potential burn or mechanical treatment impacts either spatially or 

temporally. 

Prescribed fire, because it is used to restore the natural vegetation structure of park habitats and 

reduce the risk of catastrophic fire, would have long-term benefits for coho and steelhead by 

protecting dense riparian habitat for these two species, maintaining vegetated slopes and keeping 

water temperature in appropriate ranges. This benefit would be limited by the relatively small 

area that would be burned annually (1000 acres) under Alternative B, but over time this benefit 

could become quite widespread. Compared to negligible benefits offered under Alternative A, 

benefits to coho and steelhead from prescribed burning in this alternative would be long-term 

and minor. 

Unplanned Ignitions, Wildfire, and Suppression

No impacts beyond those described for Alternative A from unplanned ignitions or their 

suppression would be expected. 

Mechanical Treatment

Hand thinning and pile burning actions taken to manage prescribed fire would have no-effect or 

negligible adverse effect on coho and steelhead trout and would not increase sedimentation. The 

impact is considered negligible or minor because riparian areas and 100 foot buffer strips would 

not be treated and would reduce or eliminate any sedimentation increase. The benefits offered by 

mechanical treatment in this alternative by reducing the risk of a catastrophic fire would be 

greater than those in Alternative A because double the number of acres would be treated. 

California Freshwater Shrimp (Synacaris pacifica)- Endangered 

The California freshwater shrimp is found in a portion of the main stem of Lagunitas Creek in 

the Bolinas Ridge FMU. 
355 

Analysis

Prescribed Fire

The most important features of the environment inhabited by this species in the park are likely to 

be the continued presence of a structurally diverse stream environment and slower flowing or 

pooled water. Each of these is dependent on the presence of intact riparian vegetation. As noted 

above in the discussion of federally listed fish species and red-legged frogs, prescribed burning is 

generally not conducted in riparian vegetation. If a particular prescribed fire in the Bolinas Ridge 

FMU may affect riparian vegetation along Lagunitas Creek, park staff would make use of 

mitigation measures or other standard practices to ensure no habitat of the California freshwater 

shrimp is affected either directly or indirectly. In addition, prescribed fire, because it is used to 

restore the natural vegetation structure of park habitats and reduce the risk and possible extent of 

catastrophic fire, could offer long-term benefits for shrimp. Because the benefit to shrimp would 

be localized to sections of the Lagunitas Creek and would cover a small area, they would not be 

greater than minor as defined in the Methodology section. These benefits could be short- or longterm, depending on whether the treated areas return to natural fire intervals quickly or need 

additional treatment. 

Unplanned Ignitions, Wildfire, and Suppression

No impacts beyond those analyzed in Alternative A would be expected from unplanned ignitions 

or their suppression in this alternative. 

Mechanical Treatment

No mechanical treatment of Bolinas Ridge FMU is planned for this alternative. Therefore, no 

impact to California freshwater shrimp is anticipated. 

Myrtle’s Silverspot Butterfly (Speyeria zerene myrtleae) – Endangered 

All of the occurrences of Myrtle’s silverspot are within the Minimum Management Fire 

Management Unit, and would not be subject to either prescribed burning or mechanical fuels 

treatments. The populations could be subject to impacts associated with an unplanned wildfire 

or by fire suppression activities, but this is unlikely because the populations occur within 

pastures routinely grazed by cattle where fire is unlikely to carry. 

Western snowy plover (Charadrius alexandrinus nivosus) – Threatened 

All of the occurrences of western snowy plovers are within the Minimum Management Fire 

Management Unit, and would not be subject to either prescribed burning or mechanical fuel 

treatments. The populations could be subject to impacts associated with an unplanned wildfire 

or by fire suppression activities, but this is unlikely because the plovers occur in beach areas 

where fire is unlikely to carry. 
356 

Additional Special Status Wildlife 

As noted above in Alternative A, Pt. Reyes Mountain Beaver is treated separately because it is 

more likely than other additional special status wildlife species to experience impacts from fire 

management activities. 

Point Reyes Mountain Beaver (Aplondontia rufa phaea) 

Analysis

Prescribed Fire

As noted above in the discussion of impacts to mountain beaver from prescribed burning in 

Alternative A, mountain beaver would be helped rather than harmed by prescribed fire in their 

habitat. In fact, small burns in mountain beaver habitat are used as mitigation for the effects 

wildfire can bring when fuels build up. This species was severely affected by the 1995 Vision 

wildfire, and prescribed burns would reduce the risk and extent of this kind of catastrophic fire 

recurring. Prescribed burns can also stimulate the growth of forbs and succulent plants used as 

food by mountain beaver. In this alternative, twice the acreage as in Alternative A would be 

treated with prescribed burning, including in Inverness Ridge FMU, where mountain beaver 

habitat exists and was burned in the Vision Fire. 

Unplanned Ignitions, Wildfire, and Suppression

Unplanned ignitions and wildfires can burn hotter than prescribed burns, and so can cause major 

vegetation changes. The mitigation measures identified above would help keep unplanned 

ignitions from becoming large-scale wildfires, and with them in place impacts to mountain 

beavers are expected to remain negligible or minor. No changes in impacts from those described 

in Alternative A are therefore expected from average scope wildfires in the study area. 

Mechanical Treatment

Impacts to mountain beavers from noise and the presence of humans during thinning or chipping 

operations could cause minor adverse impacts. Although these impacts would be more 

widespread than in Alternative A, they would remain localized and temporary. Mechanical 

thinning would also reduce the risk of catastrophic wildfire and offer minor benefits to mountain 

beavers in this regard. 
357 

Other Wildlife Species of Concern (excluding Mountain Beaver) 

Analysis 

Prescribed Fire

Same as Alternative A, adverse and beneficial impacts would also be no more than minor and 

short-term, but could be more widespread than in Alternative A, again because additional 

acreage would be burned. 

Unplanned Ignitions, Wildfire, and Suppression

No changes in impacts from unplanned ignitions, average annual wildfires or their suppression 

are expected in this alternative from those described for Alternative A. 

Mechanical Treatments

Same as Alternative A, adverse and beneficial impacts would also be no more than minor and 

short-term, but could be more widespread than in Alternative A, again because additional 

acreage would be burned. 

Effects of Fire Information/Education on Special Status Wildlife 

No changes from the possible slight benefits to special status wildlife from fire information and 

education described in alternative A would occur if this alternative were implemented. 

Effects of Fire Cache/Park Headquarters Relocation, and Construction on Special Status Wildlife

No differences between the impacts of Alternative A and this alternative from the building of the 

fire cache are expected. 

Fire Effects and Fuel Management Research on Special Status Wildlife

No differences between the impacts identified in Alternative A and this alternative from fire 

effects or fuel management research are expected. 

Cumulative Impacts 

No differences between the cumulative impacts identified in Alternative A and this alternative 

are expected. 

Conclusion 

Regarding plants that are federally listed as threatened and endangered species, all of the 

occurrences of Sonoma alopecurus, Sonoma spineflower, Tiburon paintbrush, Marin dwarf flax, 
358 

beach layia, and Tidestrom’s lupine are within the Minimum Management Fire Management 

Unit, and would not be subject to either prescribed burning or mechanical fuels treatments. The 

populations could be subject to impacts associated with an unplanned wildfire or by fire 

suppression activities, but this is unlikely because the populations occur in wet sites within 

pastures routinely grazed by cattle where fire is unlikely to carry. 

Plant species that are not federally listed, but are of concern would likely continue to receive 

minor, long-term benefits from prescribed burning and mechanical treatment, and the eventual 

return of natural fire cycles. Some patches or individuals of these species may experience minor, 

adverse effects from destruction through fire or suppression, or from the inadvertent stimulation 

of invasive exotic species burning may sometimes have. 

Prescribed fire and mechanical treatments would offer minor, long-term benefits on a limited 

scale to northern spotted owls, red-legged frogs, and California freshwater shrimp (from fire 

only) by reducing the threat of catastrophic fire and the habitat destruction it would bring. 

Mechanical treatments such as hand thinning and pile burning actions taken to manage 

prescribed fire would have a minor, short-term, adverse effect on owls through possible human 

disturbance, reduction of prey species, and habitat alteration in unknown roosting and nesting 

sites, and on frogs from inadvertently killing individuals. No mechanical treatment is planned in 

the Bolinas FMU, habitat of the freshwater shrimp. Large-scale wildfires could have more 

serious adverse effects on owls by eliminating habitat, and on frogs by burning riparian 

vegetation and increasing sedimentation. Both these species experience a positive cumulative 

impact from the large blocks of conservation land adjacent to the study area. 

Adverse impacts to coho salmon and steelhead trout from prescribed burning would be 

negligible to minor, as riparian vegetation would be retained. Minor positive benefits from 

reducing the risk and extent of a catastrophic burn would result from both prescribed burning and 

mechanical thinning. A large-scale wildfire would have more serious adverse effects by 

increasing siltation of streams and burning riparian vegetation, which in turn would increase 

water temperature. 

Both Myrtle’s silverspot butterfly and snowy plovers occur only in the Minimum Management 

FMU, and so would not be subject to either prescribed burning or mechanical fuel treatments. 

The populations could be subject to impacts associated with an unplanned wildfire or by fire 

suppression activities, but this is unlikely because the populations occur within pastures routinely 

grazed by cattle (silverspot) or beach areas (plover) where fire is unlikely to carry. 

The impacts of fire management activities, including those of average size and intensity wildfires 

in the study area on Point Reyes mountain beaver would be kept to no more than minor and 

short-term through the use of mitigation measures. Large-scale wildfires could have moderate 

adverse impacts that may be long-term. 

There would be some indirect long-term benefits by conducting research and fire education. 

There are no adverse impacts to special status species by the construction of the fire cache. 

No impairment to park special status species would occur from implementing Alternative B. 
359 

Alternative C 

Impacts on Federally Listed Plant Species 

Analysis

All of the plants identified above in Alternative A as on the federal list of threatened and 

endangered species are located primarily in the Minimum Management FMU, which is not 

treated by prescribed fire or mechanical thinning. These species include the Sonoma spineflower, 

Robust spineflower, Tiburon paintbrush, Marin dwarf flax, beach layia, and Tidestrom’s lupine. 

Although this FMU may have some small wildfires, on average no more than about 30 acres of 

the entire study area burns in a given year. Since most of these plants are located in areas in well 

grazed pastures or rocky outcrops, they are unlikely to be burned by wildfires in the park in 

average years. The impacts of Alternative B are the same as Alternative A on all of these species, 

with the exception of Sonoma alopecurus, which does occur in the Palomarin FMU. It is treated 

separately below. 

Sonoma alopecurus (Alopecurus aequalis var. sonomensis) – Endangered 

Sonoma alopecurus is a perennial grass that grows in the park primarily on pastures in 

agricultural areas. It favors moist or wet sandy soils. 

Other Special Status Plant Species 

Analysis

Under Alternative C, 10 FMUs are treated for a total of 3,500 acres. Compared to Alternative B, 

prescribed fire would be used to treat two additional FMUs - Tomales Point and Headlands. 

Mechanical treatment would be used in the same FMUs as in Alternative B. Five additional 

special status plant species of concern grow in the Headlands FMU. These species are perennial 

goldfields, Point Reyes meadowfoam, North Coast phacelia, Point Reyes rein orchid, and beach 

starwort. 

Prescribed Fire

As noted above, fire is an integral part of the natural ecosystem at Point Reyes and likely plays a 

critical role in the management of many plant and animal Species of Concern by maintaining 

open areas or stimulating reproduction. Prescribed burning may kill some individuals of these 

species, but it would also remove competitive non-native species and therefore would have a 

beneficial long-term impact. While this benefit would remain minor, it could conceivably be 

triple or more that of Alternative A depending on the location of populations of each species. 

Adverse impacts from loss of individuals or small patches of special status plants would also be 

no more than minor and short-term, but could be more severe or widespread than in Alternative 

A or B, again because additional acreage would be burned. Prescribed burns in both Tomales 

Point and Headlands FMUs would be kept small (less than 50 acres), and carefully monitored to 
360 

determine the response of plant communities, including plants of special concern. In particular, 

the burns would be monitored to see if they reduce the aerial extent of invasive non-native plants 

and increase the percentage of natives in the headlands communities. 

Unplanned Ignitions, Wildfire, and Suppression

No changes in impacts from unplanned ignitions, average annual wildfires, or their suppression 

are expected in this alternative from those described for Alternative A. 

Mechanical Treatments

Mechanical treatment would be used to accomplish the same objectives in this alternative as in 

Alternative B - that is, primarily to help control non-native species and to prepare wooded areas 

for prescribed burning. Although the extent of mechanical treatment would increase in this 

alternative over both A and B, it is not expected have any adverse impacts on special status 

plants as mowing would be done in the fall and rare plants populations would be excluded from 

treatment areas. 

Fire Information/Education

No impact to any plant special status species is expected from the distribution of fire information 

or education. 

Fire Cache/Park Headquarters Relocation, and Construction

Because the area where the fire cache is planned would be surveyed prior to construction, 

impacts to protected plant species would be minimized. It is possible that individuals would be 

affected, but the extent of the effect would be minor. 

Fire Effects and Fuel Management Research

In addition to small controlled burns in Bolinas Ridge and Palomarin FMUs to increase native 

species richness, a study of the effects of prescribed burning on fragrant fritillary in Limantour 

Road FMU would take place under this alternative. Also, the effects of both prescribed burning 

and mechanical treatment on Marin manzanita would be assessed in the Wilderness South FMU. 

If treatment is successful, minor positive benefits to these species could result in the long run. 

Special-Status Wildlife 

Northern Spotted Owl (Strix occidentalis caurina) – Threatened 

Prescribed Fire

Under Alternative C, potential effects on northern spotted owls are greater than Alternative A 

because more acres (1,500) are being treated that are considered habitat and possible disturbance 

could occur. 
361 

As noted in Alternative A, fuels have built up in spotted owl habitat to the point that a 

catastrophic, stand-replacing fire is more likely. Such as fire would destroy spotted owl habitat 

for many years; prescribed burning is considered an important tool in helping to reduce these 

unnatural accumulations of fuels and ladder fuels and preserve owl habitat. 

Preparatory burns and mechanical fuel reduction would be used to control fire intensity in areas 

in owl habitat, and no treatment would occur within 400 meters of a nesting or known roosting 

site. Spring prescribed fires in the moist conditions of old growth forests would also minimize 

damage, yet reduce fuel loads (Weatherspoon et al., 1992). Prescribed fire planning also takes 

into account other important habitat components, such as down, woody debris that provide 

habitat for dusky-footed woodrats, which are an important prey species for northern spotted owls 

in the project area. If a prescribed burn does reduce the amount of woody debris, or would 

otherwise adversely affect woodrat habitat or nests, it would have an indirect minor, short-term, 

adverse effect on spotted owls. 

Currently, no program elements exist for the management of prescribed fires for the benefit of 

spotted owls. The use of prescribed fire under Alternative C, would, nonetheless, have a 

beneficial, long-term, and minor impact on northern spotted owls, primarily through reduction in 

the threat of catastrophic fire in some areas. 

Unplanned Ignitions, Wildfire, and Suppression

No impacts different than those described above for Alternative A would result from unplanned 

ignitions, wildfires or suppression in Alternative C. To sum, because average annual acreage 

burned from wildfires at the park is quite low, any more than minor adverse impacts from 

average annual wildland fires is unlikely. 

Mechanical Treatments

Under Alternative C, hand thinning or mechanical treatments in the vicinity of development and 

roads such as on Bolinas Ridge, Wilderness North, Wilderness South, and Highway One FMUs 

could have an adverse effect on spotted owls if canopy closure was substantially reduced. This 

is especially true where developed areas interface with dense forest that provides roosting and 

nesting habitat. Under Alternative B, cutting large trees would be limited because techniques 

would be confined to hand thinning and then piling and burning. In some areas, clearing 

understory vegetation could, in fact, improve foraging conditions for spotted owls and habitat for 

it prey item - woodrats. Overall, impacts would remain localized and therefore minor. 

Chipping conducted under Alternative C would be greater than Alternative A or B. Chipping cut 

material and then distributing it over a site could occur where air quality, visitor use, or other 

management concerns prohibit burning. The equipment used to chip material is extremely loud 

and, if operated nearby, may disturb spotted owls. Although more chipping would take place in 

this alternative, impacts to owls would still be localized and temporary, and would therefore be 

no more than minor. 
362 

Fire Information/Education

No impact to spotted owls from the distribution of fire information or education is expected. 

Fire Cache/Park Headquarters Relocation, and Construction

The fire cache would not be located in the vicinity of spotted owl activity centers or potential 

habitat, so no impact is expected. 

Fire Effects and Fuel Management Research

No effects to spotted owls from fuel management research under Alternative C are expected. 

Red-legged Frog (Rana aurora draytonii) – Threatened 

Analysis

Prescribed Fire

Prescribed fire, because it is used to restore the natural vegetation structure of park habitats and 

reduce the risk of catastrophic fire, would have a long-term benefit to red-legged frogs and their 

habitat. Because red-legged frogs are widely disturbed among several FMUs in the study area, 

the benefits of prescribed burning and returning habitat to a more natural fire intensity and 

interval could be moderate. 

As noted in Alternatives A and B, until broad areas have been treated, fuel loading may remain 

high and prescribed fires may burn at higher than natural intensities, even when fire prescriptions 

were designed to minimize high-intensity fires. These fires could kill individual frogs or have 

short-term adverse effects on frog habitat. Because of monitoring and avoidance of known frog 

habitat, adverse impacts would be negligible. 

Unplanned Ignitions, Wildfire, and Suppression

The same short-term and negligible adverse impacts from small wildfires as described in 

Alternative A would be possible in this alternative as well. 

Mechanical Treatment

Mechanical treatment such as hand thinning, line construction, and pile burning could disturb 

frogs or alter their habitat. However, impacts would be no more than negligible because breeding 

areas and adjacent non-breeding areas would be identified and avoided before any mechanical 

treatment is taken. 
363 

Reduction in fuel loading by hand thinning or mechanical treatment would have a negligible, 

long-term, minor effect on red-legged frogs by reducing fuel loads and the threat of catastrophic 

fire. 

Central California Coast Coho Salmon (Oncorhynchus kisutch) – Threatened and Central 

California Steelhead (Oncorhynchus mykiss) - Threatened 

Central California coast coho salmon and Central California steelhead (hereafter referred to as 

coho and steelhead) occur in several creeks on the Point Reyes peninsula and in the Lagunitas 

Creek watershed that drains portions of PRNS and GGNRA. In addition to treatments in the 

Bolinas Ridge, Highway One, Estero, Limantour Road, Wilderness North, Wilderness South, 

Inverness Ridge, Palomarin, and Tomales Point FMUs, one new treatment area is identified in 

Alternative C. The Headlands FMU is included in the Drakes Bay and Pacific Drainage 

watersheds(see Figure 16). Designated critical habitat for coho in PRNS includes all accessible 

estuarine and stream areas in the coastal watersheds of Marin County except areas above 

longstanding, naturally impassable barriers or above Peters Dam on the mainstem of Lagunitas 

Creek and Seeger Dam on Nicasio Creek (NMFS, 1999). Although critical habitat has not been 

established for central California steelhead, it is likely to be the same as that for coho in Marin 

County. 

Tomales Bay Watershed

Under Alternative C, all treatment would be the same as those evaluated in Alternative B. 

Lagunitas Creek Watershed

Under Alternative C, the Bolinas Ridge FMU would be subject to prescribed fire and mechanical 

treatment. This FMU represents 3% of the total watershed area (see Table 42). 

Olema Creek Watershed

Under Alternative C, all treatment would be the same as those evaluated in Alternative B. 

Drakes Bay Drainages

Under Alternative C, most treatments would be the same as those evaluated in Alternative B. In 

addition, the Headlands FMU would be subject to prescribed fire. These FMUs represent 24% 

of the total watershed area (see Table 43). 

Drakes Estero Watershed

Under Alternative C, all treatment would be the same as those evaluated in Alternative B. 
364 

Pacific Drainages 

The Pacific drainages do not support threatened salmonid species. Under Alternative C, most 

treatments would be the same as those evaluated in Alternative B. In addition, the Headlands 

FMU would be subject to prescribed fire. 

Bolinas Drainages

Under Alternative C, all treatment would be the same as those evaluated in Alternative B. 

Pine Gulch Creek

Under Alternative C, all treatment would be the same as those evaluated in Alternative B. 

Analysis

Under Alternative C, the treatments proposed could affect coho salmon and steelhead trout 

because eight of the ten FMUs to be treated have one or both species of fish. Highway One 

FMU has the greatest potential for possible impacts because of its proximity to Olema Creek and 

Pine Gulch Creek. The FMU surrounds the road corridor and includes more than 8 kilometers of 

mainstem habitat supporting coho salmon and steelhead trout. Although these are the same 

FMUs with these species as are treated in Alternative B, more acres would be affected and so the 

potential for impact, both positive and adverse, is greater. 

Prescribed Fire

As in other alternatives, mitigation measures including S-1 and S-2, identified in the review of 

each burn plan, to evaluate the erosion control plan and retain riparian vegetation would keep 

adverse impacts from prescribed fire minimized so they are no more than negligible or minor. 

Initially, high levels of fuel loading in some areas of the park may create hot spots, or prescribed 

fires that burn at higher than natural intensities, with resulting increases in sedimentation. This 

would decrease over time at a rate that is faster in this alternative than any other as more and 

more acreage is cumulatively treated. The impacts from any increases in sediment loading 

resulting from prescribed burning are likely to be no more than minor, and would be short-term, 

lasting only until slopes are revegetated. 

Prescribed fire, because it is used to restore the natural vegetation structure of park habitats and 

reduce the risk of catastrophic fire, would have long-term moderate benefits for coho and 

steelhead by protecting dense riparian habitat for these two species, maintaining vegetated 

slopes, controlling sediment, and keeping water temperature in appropriate ranges. 

Unplanned Ignitions, Wildfire, and Suppression

No impacts beyond those described for Alternative A from unplanned ignitions or their 

suppression would be expected. 
365 

Mechanical Treatment

Hand thinning and pile burning actions taken to manage prescribed fire would have no-effect or 

negligible adverse effect on coho and steelhead trout and would not increase sedimentation. The 

impact is considered negligible or minor because riparian areas and 100 foot buffer strips would 

not be treated and would reduce or eliminate any sedimentation increase. The benefits offered by 

mechanical treatment in this alternative by reducing the risk of a catastrophic fire would be 

greater than those in Alternative A or B and would approach moderate levels as defined in 

Methodology because these benefits would be widespread. 

California Freshwater Shrimp 

The California freshwater shrimp is found in a portion of the main stem of Lagunitas Creek in 

the Bolinas Ridge FMU. 

Analysis

Prescribed Fire

As noted above, prescribed burning is generally not conducted in riparian vegetation. If a 

particular prescribed fire in the Bolinas Ridge FMU may affect riparian vegetation along 

Lagunitas Creek, park staff would make use of mitigation measures or other standard practices to 

ensure no habitat of the California freshwater shrimp is affected either directly or indirectly. In 

addition, prescribed fire, because it is used to restore the natural vegetation structure of park 

habitats and reduce the risk and possible extent of catastrophic fire, could offer benefits for 

shrimp. Because these benefits could extend over the entire range of shrimp habitat in the park, 

they may be long-term and moderate as defined in the Methodology section. 

Unplanned Ignitions, Wildfire, and Suppression

No impacts beyond those analyzed in Alternative A would be expected from unplanned ignitions 

or their suppression in this alternative. 

Mechanical Treatment

No mechanical treatment in Bolinas Ridge FMU is planned under Alternative C. 

Myrtle’s Silverspot Butterfly (Speyeria zerene myrtleae) – Endangered 

All of the occurrences of Myrtle’s silverspot are within the Minimum Management Fire 

Management Unit, and would not be subject to either prescribed burning or mechanical fuels 

treatments. The populations could be subject to impacts associated with an unplanned wildfire 

or by fire suppression activities, but this is unlikely because the populations occur within 

pastures routinely grazed by cattle where fire is unlikely to carry. 
366 

Western snowy plover (Charadrius alexandrinus nivosus) – Threatened 

All of the occurrences of western snowy plovers are within the Minimum Management Fire 

Management Unit, and would not be subject to either prescribed burning or mechanical fuel 

treatments. The populations could be subject to impacts associated with an unplanned wildfire 

or by fire suppression activities, but this is unlikely because the plovers occur in beach areas 

where fire is unlikely to carry. 

Other Wildlife Species of Concern 

Mountain beaver is treated separately in this section because it may experience impacts from fire 

management activities. 

Point Reyes Mountain Beaver (Aplondontia rufa phaea) 

Analysis

Prescribed Fire

As noted above in the discussion of impacts to mountain beaver from prescribed burning in 

Alternative A, mountain beaver would be helped rather than harmed by prescribed fire in their 

habitat. In fact, small burns in mountain beaver habitat are used as mitigation for the effects 

wildfire can bring when fuels build up. This species was severely affected by the 1995 Vision 

wildfire, and prescribed burns would reduce the risk and extent of this kind of catastrophic fire 

recurring. Prescribed burns can also stimulate the growth of forbs and succulent plants used as 

food by mountain beaver. In this alternative, 2000 acres would be treated with prescribed 

burning, including in Inverness Ridge FMU, where mountain beaver habitat exists and was 

burned in the Vision Fire. Small prescribed burns conducted over a wide area of beaver habitat 

would result in minor benefits by maintaining suitable habitat and reducing potential for 

catastrophic wildfire. 

Unplanned Ignitions, Wildfire, and Suppression

Unplanned ignitions and wildfires can burn hotter than prescribed burns, and so can cause major 

vegetation changes. The mitigation measures identified above would help keep unplanned 

ignitions from becoming large-scale wildfires, and with them in place impacts to mountain 

beavers are expected to remain negligible or minor. No changes in impacts from those described 

in Alternative A are therefore expected from average scope wildfires in the study area. 

Mechanical Treatment

Impacts to mountain beavers from noise and the presence of humans during thinning or chipping 

operations could cause minor adverse impacts. Although these impacts would be more 

widespread than in Alternative A, they would remain localized and temporary. Mechanical 
367 

thinning would also reduce the risk of catastrophic wildfire and offer minor benefits to mountain 

beavers in this regard. 

Other Wildlife Species of Concern (excluding Mountain Beaver) 

Analysis 

Prescribed Fire

Same as Alternative A, adverse and beneficial impacts would also be no more than minor and 

short-term, but could be more widespread than in Alternative A and Alternative B, because 

additional acreage would be burned under Alternative C. 

Unplanned Ignitions, Wildfire, and Suppression

No changes in impacts from unplanned ignitions, average annual wildfires or their suppression 

are expected in this alternative from those described for Alternative A. 

Mechanical Treatments

Same as Alternative A, adverse and beneficial impacts would also be no more than minor and 

short-term, but could be more widespread than in Alternative A and Alternative B, again because 

additional acreage would be treatment by mechanical means. 

Effects of Fire Information/Education on Special Status Wildlife 

No changes from the possible slight benefits to special status wildlife from fire information and 

education described in alternative A would occur if this alternative were implemented. 

Effects of Fire Cache/Park Headquarters Relocation, and Construction on Special Status Wildlife

No differences between the impacts of Alternative A and this alternative from the building of the 

fire cache are expected. 

Fire Effects and Fuel Management Research on Special Status Wildlife

No differences between the impacts identified in Alternative A and this alternative from fire 

effects or fuel management research are expected. 

Cumulative Impacts 

No differences between the cumulative impacts identified in Alternative A and this alternative 

are expected. 
368 

Conclusion 

Regarding plants that are federally listed as threatened and endangered species, all of the 

occurrences of Sonoma alopecurus, Sonoma spineflower, robust spineflower, Tiburon 

paintbrush, Marin dwarf flax, beach layia, and Tidestrom’s lupine are within the Minimum 

Management Fire Management Unit, and would not be subject to either prescribed burning or 

mechanical fuels treatments. The populations could be subject to impacts associated with an 

unplanned wildfire or by fire suppression activities, but this is unlikely because the populations 

occur in wet sites within pastures routinely grazed by cattle where fire is unlikely to carry. 

Plant species that are not federally listed, but are of concern would likely continue to receive 

minor long-term benefits from prescribed burning and mechanical treatment, and the eventual 

return of natural fire cycles. Some patches or individuals of these species may experience minor, 

adverse effects from destruction through fire or suppression, or from the inadvertent stimulation 

of invasive exotic species burning may sometimes have. 

Prescribed fire and mechanical treatments would offer moderate, long-term benefits on a limited 

scale to northern spotted owls, red-legged frogs, and California freshwater shrimp (from fire 

only) by reducing the threat of catastrophic fire and the habitat destruction it would bring. 

Mechanical treatments such as hand thinning and pile burning actions taken to manage 

prescribed fire would have a minor, short-term, adverse effect on owls through possible human 

disturbance, reduction of prey species, and habitat alteration in unknown roosting and nesting 

sites, and on frogs from inadvertently killing individuals. No mechanical treatment is planned in 

the Bolinas FMU, habitat of the freshwater shrimp. Large-scale wildfires could have more 

serious adverse effects on owls by eliminating habitat, and on frogs by burning riparian 

vegetation and increasing sedimentation. Both these species experience a positive cumulative 

impact from the large blocks of conservation land adjacent to the study area. 

Adverse impacts to coho salmon and steelhead trout from prescribed burning would be 

negligible to minor, as riparian vegetation would be retained. Moderate benefits from reducing 

the risk and extent of a catastrophic burn would result from both prescribed burning and 

mechanical thinning. A large-scale wildfire would have more serious adverse effects by 

increasing siltation of streams and burning riparian vegetation, which in turn would increase 

water temperature. 

Both Myrtle’s silverspot butterfly and snowy plovers occur only in the Minimum Management 

FMU, and so would not be subject to either prescribed burning or mechanical fuel treatments. 

The populations could be subject to impacts associated with an unplanned wildfire or by fire 

suppression activities, but this is unlikely because the populations occur within pastures routinely 

grazed by cattle (silverspot) or beach areas (plover) where fire is unlikely to carry. 

The impacts of fire management activities, including those of average size and intensity wildfires 

in the study area on Point Reyes mountain beaver would be kept to no more than minor and 

short-term through the use of mitigation measures. Large-scale wildfires could have moderate 

adverse impacts that may be long-term. 
369 

There would be some indirect long-term benefits by conducting research and fire education. 

There are no adverse impacts to special status species by the construction of the fire cache. 

No impairment to park special status species would occur from implementing Alternative C. 

IMPACTS TO CULTURAL RESOURCES 

Alternative A 

Analysis 

Several factors influence the degree of damage a cultural resource might experience as a result of 

the actions in a particular alternative. Some of these factors are discussed below for the actions 

of prescribed or wildland fire (direct effects), operations such as the use of equipment during 

thinning (operational effects), and from actions that result from fire or mechanical thinning, 

called “indirect effects.” Indirect effects occur later in time than the fire itself but result from the 

fire or thinning. Examples of indirect effects include erosion of artifacts following the loss of 

vegetation in a fire, long-term deterioration of a structure related to damage initially suffered 

during a fire, etc. 

The intensity of a fire and susceptibility of resources to heat is one factor that ultimately 

determines the degree of damage from the direct effect of fire. For example, obsidian hydration 

rinds are generally impacted at temperatures in excess of 100 to 150° C, dimensional lumber 

ignites at 350° C, glass melts at around 500° C, and cast iron at 1400° C. The degree to which 

duration of heating plays a role is less well understood, but in general, the longer a resource is 

exposed to heat, the greater the likelihood of damage. Fire can result in the complete elimination 

of an artifact or feature (e.g., through consumption), or can alter attributes of an artifact or 

feature such that important research (e.g., obsidian hydration rinds, residues on pottery, bone 

burning) is hindered, or traditional (e.g., Native American spiritual sites), or other values are 

impacted. 

Fires tend to burn in a complex manner depending on fuels, weather, and terrain (Ryan and 

Noste, 1985). Fire intensity is generally greater under conditions of heavier fuel (e.g., dead and 

down timber, brushfields), low fuel moisture, high air temperatures, high winds, low humidity, 

and/or rugged terrain. It is the behavior of a fire (ground, surface, and crown) and proximity to a 

cultural resource that determines the amount and type of damage that could occur. While running 

surface fires and crown fires reach extreme temperatures (500 to 1500° C) and have high energy 

release rates, relatively little of that heat is directed towards the surface of the ground, and 

ground fires can result in long duration heating (400 to 700° C) within the upper 15 cm. of the 

soil profile. Only under rare conditions (e.g., burning tree roots) will elevated temperatures 

penetrate more deeply beneath the ground surface. Ground or creeping active surface fires are 

usually associated with prescribed burns, whereas running surface and crown fires occur 

primarily during wildfires. Very generally, cultural resources located above the ground surface 

(e.g., rock imagery panels, historical structures) are most vulnerable to direct fire effects during 

crown and active surface fires, while ground and creeping surface fires threaten those found at or 

just below the ground surface (e.g., archeological sites). Because of this, the chances of 
370 

adversely affecting a high percentage of cultural resources found exclusively on or near the 

ground surface are often greater. This is significant because cultural resources generally 

considered to have high data potential, such as Native American villages with subsurface 

components, may actually have a far lower percentage of artifact classes or attributes exposed to 

direct fire effects than a lithic scatter, often considered to have low data potential that is 

restricted to the ground surface. While it is the village that would probably receive the greatest 

amount of attention in regard to a planned or unplanned fire management action, it is the lithic 

scatter that has the potential to undergo the greatest intensity of impact. 

In general, direct effects of fire management actions on cultural resources would be adverse. 

This is particularly true of archeological resources, structures, and museum objects. While direct 

fire effects can also adversely impact ethnographic resources and cultural landscapes, fire can 

also be used to restore, enhance and maintain them. For example, in regard to ethnographic 

resources, some plants important for basketmaking benefit from the proper application of fire 

(Anderson, 1999). In cultural landscapes with a vegetation component, fire can be applied to 

replicate and maintain historic scenes. Adverse direct effects are more likely to occur during 

extreme fire behavior such as wildfires, although cultural resources with high vulnerability to fire 

are susceptible to low intensity burns often associated with prescribed fire. 

Operational effects to cultural resources are most likely to occur as a result of fire management 

actions associated with prescribed burns, wildfires and mechanical thinning. The operational 

effects on cultural resources have been quantified in only a relatively few cases. However, 

several generalizations can be made: 

Impacts resulting from the operation of heavy equipment on and in close proximity to cultural 

resources will correlate directly with the nature and extent of the disturbance, nature of local 

sediments, and nature and extent of cultural resources. Heavy equipment would not be used 

except to help extinguish a wildfire. 

With the exception of those that result in more intense fire behavior (e.g., slash piles, firing 

techniques), impacts resulting from operational effects would generally be restricted to the 

displacement, breakage and/or destruction and looting of cultural resources. In this sense, 

operational effects tend to be less encompassing than direct effects. For example, an obsidian 

projectile point displaced by construction of a fire line would probably retain its hydration rind, 

morphology, and other attributes. 

Except in rare situations, operational effects are likely to be most pronounced on cultural 

resources found on and near the ground surface. 

Operational effects would be most likely to occur, and at the greatest intensity, during wildfires. 

This is due primarily to the fact that such actions are often carried out with little or no preplanning and without consultation or supervision by a cultural resource specialist. 

Operational effects of fire management actions on cultural resources would, in most cases, be 

adverse. However, the degree of impact depends greatly on the nature of the operation and the 

cultural resource or resources in question. Adverse operational effects are of particular concern 
371 

during and after wildfire events. With proper planning, operations can also be used for 

beneficial purposes. For example, mechanical thinning can effectively remove hazardous fuels 

from and in the vicinity of cultural resources, as well as restore, enhance or maintain 

ethnographic resources and cultural landscapes, in cases where the risk of direct effects is too 

high. 

Indirect effects may be delayed and incremental, and are related most strongly to the intensity of 

the fire management effort, although context and the nature of the resource play important roles. 

For example, intense fire behavior and major suppression efforts associated with wildfires would 

often mean indirect effects, such as loss through erosion, would occur relatively quickly and to a 

larger degree than following a smaller prescribed burn or mechanical thinning. Over time, these 

smaller actions can have adverse consequences of similar magnitude to wildfire suppression. 

The indirect effects of fire management actions related to high intensity wildfires would be 

generally adverse. 

As noted in Affected Environment, cultural resource surveys as Point Reyes are not 100% 

complete. The areas that are less likely to have been surveyed are those that are difficult to 

access, either because of rugged topography, thick vegetation or both. Because these areas have 

not been surveyed, they are vulnerable to the loss of resources and information during what 

could be quite intense burns. On the other hand, settlement in the area has by in large taken place 

where topography is less steep, along fresh and saltwater sources, and vegetation is not dense, 

and it is these areas where cultural resource data is more likely to have been recorded. The 

combination of less dense vegetation and more intense surveys in these areas mean these 

resources are not likely to suffer more than minor or moderate impacts, even in a wildland fire. 

Mitigation Measures

Mitigation measures are actions that reduce the impact of the planned activities on a particular 

resource. In this case, all of the measures listed below would be employed at Point Reyes 

National Seashore, and would be part of agreements between state and federal cultural resource 

protection agencies and the NPS. They are divided in measures taken before actions in the 

alternatives (prescribed fire or thinning, suppression of unplanned ignitions) occur, during these 

actions and following them. Because they are mandatory, the alternatives are analyzed assumed 

each would be put into place. 

Pre-Action 

Cultural resources would be considered during all fire management planning efforts. 

Fire management personnel and other staff would receive annual training on cultural resources 

and fire management actions. 

All cultural resources would be evaluated with respect to hazardous fuel loads. As needed, fuel 

loads would be reduced using methods commensurate with avoiding or minimizing adverse 

effects. Maintaining light fuel loads on and in close proximity to cultural resources would be 
372 

emphasized. All areas slated for ground disturbing activities would be subjected to pre-action 

field surveys. This includes areas likely to be disturbed during future wildfires. 

Pre-burn survey would be conducted prior to all prescribed burns as dictated by resource 

distribution and vulnerability, vegetation and topography, and expected fire behavior. 

Consultation with local Native American communities would continue to occur in the context of 

fire management actions. Spiritual sites and important plant communities would be identified 

and appropriately managed for preservation, maintenance, and/or enhancement. 

Computer and other databases containing cultural resources data would be created and 

maintained, and made available to fire management personnel in the event of emergencies. 

Cultural resources specialists from adjacent land management agencies would be consulted in 

order to coordinate mitigation efforts prior to planned and unplanned fire management actions. 

Appropriate cultural resources monitoring protocols would be established and implemented. 

Potential research opportunities to study the effects of fire management actions on cultural 

resources would be identified. 

During-Action 

A cultural resource specialist or resource advisor would be present during all fire management 

actions where recorded and unrecorded resources of interest are considered at risk. Additional 

surveys would be conducted on an as-needed basis. 

Observations of fire behavior and other variables would be made with respect to recorded 

cultural resources and/or areas with high probability of containing unrecorded cultural resources. 

Cultural resources data would be shared with fire management personnel as needed to avoid or 

minimize adverse effects. 

A cultural resource specialist or resource advisor would educate fire management personnel 

about cultural resources and the potential impacts of fire management actions. 

Post-Action 

The post-action condition of all recorded cultural resources would be assessed. Resources 

requiring stabilization or other treatment would be mitigated. 

As appropriate, post-action survey would be conducted in previously surveyed and unsurveyed 

areas. Previously unrecorded cultural resources would be assessed for condition, and 

stabilization and other protection needs. 
373 

Monitoring and research data would be compiled, evaluated, and used to help refine cultural 

resource compliance for fire management actions. 

Prescribed Fire 

Under this alternative, a maximum of 500 acres/year, which would all be treated in Estero, 

Limantour Road, Highway One, and Bolinas Ridge FMUs, would be burned using prescribed 

fire. This is the same as under existing conditions. 

Prescribed burning could offer some benefits to cultural resources. For example, areas that are to 

be burned are surveyed, and staff can locate and evaluate the significance of cultural resources 

they would not otherwise have had an opportunity or reason to assess. The ability to conduct preburn inventories also allows the park to quantitatively and spatially document fuel conditions and 

require mechanical treatment of particularly dense vegetation to avoid damage to important 

cultural sites. If this is not possible, the information about fuel conditions can be used to direct 

post-burn survey and more meaningfully assess damage to cultural resources that could not be 

mitigated prior to the burn. These benefits are expected to be minor because it is not expected 

that significant archeological or historic resources will be found. In addition, prescribed burns 

can be conducted in areas to obtain cultural landscape objectives, offering long-term and shortterm moderate benefits if a landscape is restored. The benefit is moderate because prescribed 

burning could provide a measured change in the significant characteristic of the landscape. For 

example, prescribed burning could open up a historic view-shed (part of a cultural landscape) 

that has been lost because of vegetation growth. 

Prescribed burns can also be used to improve conditions at or safety of a cultural resource, and in 

particular of historic buildings. For example it is possible, through varied timing or operational 

procedures (e.g., heading or backing fire) to achieve lower or higher fire intensities. A low 

intensity fire might be utilized on or immediately adjacent to a particular cultural resource such 

as a historic structure; while a high intensity fire could significantly reduce hazardous fuels 

surrounding the resource. Prescribed burns are implemented at times when the likelihood of 

escape is low, thereby minimizing potential effects to those cultural resources in close proximity 

to a burn unit. Reducing fuel loads from around historic structures could offer short-term 

moderate benefits for cultural resources. 

As noted above, a standard mitigation measure for prescribed burns in the park is the presence of 

a cultural resource specialist, who would be able to monitor fire behavior and the effectiveness of 

mitigation measures during the burn for future reference. The specialist would also be on site in 

the case of an escape to help mitigate or minimize potential adverse effects of suppression. 

Preparation activities, such as line construction, would also be monitored by a cultural resource 

specialist. The specialist would survey the site where these activities are planned and collaborate 

on the best location for them, monitor construction to ensure minimal damage, and brief fire 

personnel on the proper protocol in and around cultural resources. The presence of a specialist is 

likely to keep impacts to archeological sites from these activities low, so they are no more than 

minor and short-term. 
374 

The benefit of pre-burning planning allows the cultural resources specialist to account for 

potential indirect effects. For example, if high tree mortality is a concern following the burn, 

efforts can be taken to reduce the number of trees in proximity to a cultural resource. Some 

indirect effects like erosion are exacerbated by intense fire behavior, the type that is unlikely to 

occur over large areas during prescribed burns. 

Unplanned Ignitions, Wildfire, and Suppression 

Due to often extreme fire behavior, the direct effects of wildfires on cultural resources can be 

substantial, including adverse damage. However, at Point Reyes, an average of only three small 

(less than 10 acres/year) unplanned ignitions has taken place for most years, although very large 

fires can occur under unusual conditions. As these are unplanned events, cultural resource 

specialists rarely have the luxury of benefits conveyed by pre-planning efforts during wildfires. 

For example, because all of the park has not been intensely surveyed (approximately 87% of the 

park has not been surveyed; however, the 13% surveyed covers the most likely areas for 

archeological sites) of Point Reyes has been fully inventoried for cultural resources, it is highly 

likely that wildfires will occur in areas that lack or have few recorded cultural resources. 

Information regarding direct effects would in most cases be obtained during the post-burn phase, 

and involve evaluating those effects on resources for which no pre-burn condition data were 

available. It is possible that an uncontrolled large wildfire could destroy or remove all 

information from cultural resources or have a short- or long-term effect on the integrity of 

cultural landscapes. See impacts section under Cumulative Impacts below. 

Operational effects associated with wildfire suppression can often be adverse, major, and 

permanent. The acts of constructing fire lines with a dozer, helispots, staging areas, mopping-up 

and other ground disturbing processes can have major adverse permanent impacts on cultural 

resources, particularly those that are on the ground or buried. Even with low impact techniques, 

the placement of fire lines and related phenomenon can be quite unsystematic when compared to 

planned fire management actions. Although the use of heavy equipment for fire suppression is 

prohibited unless authorized by the Point Reyes superintendent, it is a standard tool for agencies 

charged with fire management on adjacent lands, and would almost certainly be employed in 

cases where life or property was at risk. 

Large numbers of personnel, from varied backgrounds, are present at any fire. Crews are often 

spread across a vast area. Cultural resource looting and vandalism can potentially occur during 

wildfire events. However, these adverse impacts would be minor because most archeological 

sites have been recorded and surface artifacts removed. In addition, NPS resource advisors 

would be on-site quickly after a burn to ensure looting and vandalism does not occur. 

During suppression activities some cultural landscape elements may be altered. However, most 

would be a temporary alteration that could be restored and most suppression activities would not 

alter a significant number of characteristics of a particular cultural landscape. Therefore, by 

suppression activities, cultural landscapes would have short-term, minor, adverse effects because 

a small percentage of the historic landscapes would likely to be lost and should not last more 

than 10 years. 
375 

To sum, from uncontrolled wildfire this alternative could have permanent adverse major effects 

to historic buildings due to loss during an uncontrolled wildfire. Archeological sites may receive 

permanent, adverse, major from suppression effort because heavy equipment such as a tractor 

and blade may inadvertently impact a archeological or historical site. Cultural landscapes would 

have only short-term, minor, adverse effects because a small percentage of the historic 

landscapes would likely to be lost and should not last more than 10 years. For impacts under a 

large-scale fire, see Cumulative Impacts section below. 

Mechanical Treatments 

Under this alternative, 500 acres/year in Estero, Limantour Road, Highway One, and Bolinas 

Ridge FMUs would be treated by mechanical means. 

Although fire itself is not technically a component of mechanical treatments, prescribed burning 

of vegetation piles would be undertaken. Fuel loads in these piles would be substantial, would 

tend to burn at very high intensities, and any cultural resources found in proximity would almost 

certainly suffer direct effects. With the ability to pre-plan, the cultural resource specialist can 

ensure that piles are not created on or near cultural resources, and impacts would be no more 

than minor. 

Operational effects present the greatest concern in regard to the potential impacts of mechanical 

treatment. Ground disturbance could result in substantial impacts to cultural resources. 

However, mechanical treatments offer the benefit of pre-planning in that the location(s) of 

ground disturbance can be specifically delineated, and known cultural resources avoided. In the 

event that an area cannot be subjected to adequate pre-burn survey due to thick vegetation, a 

cultural specialist could monitor the mechanical treatment for cultural resources that become 

exposed. Likewise, less intensive mechanical treatments can be employed in highly sensitive 

areas. While looting by fuels crews is also a concern, these effects could be minimized through a 

combination of education and avoiding known resources. Together, these activities would 

prevent impacts to archeological resources from mechanical thinning from becoming more than 

short-term and minor. 

A variety of indirect effects could arise as a result of mechanical treatments. The use of heavy 

equipment could result in soil compaction, and potential soil erosion on and near cultural 

resources. The act of thinning vegetation on or near cultural resources might leave them 

vulnerable to looting. Again, however, the ability to perform pre-treatment survey means that 

equipment can be excluded from or near cultural resources and vegetation can be strategically 

left in place to discourage looting. Mechanical treatments also offer the potential short-term 

moderate benefit of reducing fuel loads in proximity to cultural resources. They would also offer 

long-term moderate benefits by restoring and/or maintaining historical scenes associated with 

structures and cultural landscapes, especially in situations where it is not desirable or possible to 

accomplish these tasks with the direct application of fire. 
376 

Fire Information/Education 

Impacts associated with fire information and education would largely be beneficial, although 

highly dependent on the nature of the fire management action. Pre-planned events such as 

prescribed fires and mechanical treatment provide the opportunity to demonstrate the 

effectiveness of cultural resources compliance to local Native American communities and the 

interested public. During unplanned events, such as wildfires time for effective communication 

is often more limited and can be more controversial since resources are often damaged. 

Fire Cache/Park Headquarters Relocation, and Construction 

The construction of a fire cache at Bear Valley would have no influence on the direct effects of 

fire management actions on cultural resources. However, relocating fire management personnel 

to a more centralized location would allow for faster response time to cultural resources in the 

event of wildfires. 

Operational effects associated with the construction of the new fire cache are unlikely to occur. 

The Bear Valley developed area has been surveyed in its entirety on several occasions (Kelly, 

2003) and no cultural resources have been documented at the proposed fire cache location. 

No adverse or beneficial indirect effects are anticipated with the construction of the new fire 

cache. 

No adverse or beneficial effects are anticipated with the construction of the new fire cache on 

historic structures, archeological sites, or cultural landscapes. 

Fire Effects and Fuel Management Research 

No adverse or beneficial effects are anticipated on cultural resources from the implementation of 

Alternative A research projects. All historic structures, archeological sites, or cultural 

landscapes would be avoided and treated areas located away from any known sites. 

Cumulative Impacts 

Based on an analysis of the list of projects in Appendix C, the cumulative impacts of all the 

projects listed would not change the potential intensity or duration of the impacts to cultural 

resources. Most of the projects building projects listed have beneficial effects on cultural 

resources. However, a large-scale high-intensity, uncontrolled fire such as the 1995 Vision 

would dramatically increase all impacts to cultural resources (see impacts above). Extremely 

high fire temperatures can be expected, with the implication that even the most durable cultural 

resources are vulnerable to major, permanent damage. A large number of significant historic 

structures could be loss and soil erosion from hydrophobic soils could severely damage 

archeological resources. Large fires would often encompass a high number of cultural resources 

including historic structures, cultural landscapes, and archeological sites resulting in permanent, 

major, adverse cumulative effect. 
377 

Conclusions 

Alternative A would have short-term, moderate, beneficial effects to historic buildings by 

reducing fuels around these structures, both through prescribed burns and mechanical treatment. 

Moderate, long-term, benefits to cultural landscapes from the restoration or maintenance of them 

through prescribed fire or mechanical treatments are also likely. Mitigation measures would keep 

impacts to archeological resources (from pre-treatment for prescribed burns, or mechanical 

thinning activities) from becoming more than short-term and minor. 

Suppression activities associated even with smaller, more average sized wildfires could have 

negligible to major permanent major adverse effects to cultural resources because no preplanning occurs and suppression, rather than resource protection, is the top priority. 

Archeological sites could have permanent adverse major from suppression effort because heavy 

equipment such as a tractor and blade may inadvertently impact an archeological or historical 

site. Cultural landscapes would have only short-term, minor, adverse effects from average 

wildfires because a small percentage of the historic landscapes would likely to be lost and should 

not last more than 10 years. 

No adverse or beneficial effects are anticipated with the construction of the new fire cache or 

implementing research activities on historic structures, archeological sites, or cultural 

landscapes. 

A large-scale uncontrolled wildfire as described in the Cumulative Impact section could have 

long-term, major, adverse effects to historic buildings and cultural landscapes due to significant 

loss of numerous historic features and structures. The alternative would not result in long-term 

impairment to cultural resources. 

Alternative B 

Analysis 

The same type of activities as described above for Alternative A would take place. However, up 

to 1000 acres/year in 8 FMUs including Estero, Inverness Ridge, Limantour Road, Wilderness 

North, Wilderness South, Highway One, Bolinas Ridge, and Palomarin would take place. 

Mechanical treatments of 1000 acres/year could occur in FMUs at Tomales Point, Estero, 

Limantour Road, Wilderness North, Wilderness South, Highway One, and Palomarin. The same 

factors as described above would influence the degree of damage cultural resources might 

sustain, and the same mitigation measures would be applied to minimize this damage. 

Prescribed Fire 

Same as Alternative A, except 500 additional acres/year would be treated by prescribed fire. 

Therefore, beneficial effects to cultural landscapes and historic structures would be greater. 

Regarding archeological resources, the potential for a minor, short-term, adverse effect from 

inadvertently burning an archeological site would be greater. The potential for these impacts has 
378 

increased because prescribed fire would be used in Inverness Ridge, Wilderness North, 

Wilderness South, and Palomarin FMUs in addition to the four FMUs (Estero, Limantour Road, 

Highway One, and Bolinas Ridge) in Alternative A. Palomarin FMU probably has the greatest 

potential for additional archeological sites to be inadvertently impacted. 

Unplanned Ignitions, Wildfire, and Suppression 

The chance of an unplanned ignition or wildfire occurring in this alternative is very close to the 

same as in Alternative A, and the long-term, major, adverse impacts to historic structures or 

cultural landscapes from direct effects of the fire, and to archeological resources from 

suppression or mop-up would be the same as well. 

Mechanical Treatments 

The same types of impacts as described in Alternative A, both beneficial and adverse, would 

occur as a result of mechanical treatments. However, an additional 500 acres/year would be 

treated. Although the benefits to cultural landscapes and historic structures would be greater than 

in Alternative A, they would still be considered short-term and moderate. Also, although impacts 

to subsurface archeological resources from operations associated with mechanical treatment 

would potentially cover a wider area than in Alternative A, they would remain minor and shortterm because of the implementation of the mitigation measures described above. However, the 

potential for these impacts has increased because mechanical treatment would be used in 

Tomales Point, Wilderness North, Wilderness South, and Palomarin FMUs in addition to the 

four FMUs (Estero, Limantour Road, and Highway One) in Alternative A. 

Fire Information/Education 

No differences compared to Alternative A in the benefits to fire education are anticipated from 

implementing Alternative B. 

Fire Cache/Park Headquarters Relocation, and Construction 

No differences compared to Alternative A in the impacts of constructing and operating a fire 

cache are anticipated from implementing Alternative B. 

Fire Effects and Fuel Management Research 

No additional benefits from conducting research identified as part of this alternative are expected 

compared to Alternative A. 

Cumulative Impacts 

No additional cumulative impacts beyond those described above for Alternative A are expected. 
379 

Conclusions 

Alternative B would have short-term, moderate, beneficial effects to historic buildings by 

reducing fuels around these structures, both through prescribed burns and mechanical treatment. 

These benefits would be greater than in Alternative A, but would remain in the moderate 

category. Moderate long-term benefits similar but greater than in Alternative A to cultural 

landscapes from the restoration or maintenance of them through prescribed fire or mechanical 

treatments are also likely. As in Alternative A, mitigation measures would keep impacts to 

archeological resources from pre-treatment for prescribed burns, or mechanical thinning 

activities from becoming more than short-term and minor. However, the potential for these 

impacts is greater because both mechanical and prescribed fire programs are treating more 

FMUs. 

A large-scale uncontrolled wildfire could have long-term, major, adverse effects to historic 

buildings and cultural landscapes. Suppression and/or mop-up of such a fire could have longterm, major, adverse effects to archeological resources. Suppression activities associated with 

more average wildfires could also have negligible to major impacts to cultural resources. 

No adverse or beneficial effects are anticipated with the construction of the new fire cache or 

implementing research activities on historic structures, archeological sites, or cultural 

landscapes. 

The alternative would not result in long-term impairment to cultural resources. 

Alternative C 

Analysis 

This alternative would allow prescribed burning of 2000 acres/year in 10 FMUs including 

Tomales Point, Estero, Headlands, Inverness Ridge, Limantour Road, Wilderness North, 

Wilderness South, Highway One, Bolinas Ridge, and Palomarin and mechanical treatment in all 

except the Point Reyes Headlands for a total of 1,500 acres/year. 

Prescribed Fire 

Same as Alternative A, except 1,500 additional acres/year would be treated by prescribed fire for 

a total of 2000 acres/year. Therefore, beneficial effects to cultural landscapes and historic 

structures would be greater than A. Regarding archeological resources, the potential for a shortterm adverse effect from inadvertently burning an archeological site would be greater than 

Alternative A or B. The impacts are moderate because they could affect a moderate percentage 

of significant resources; however, because of mitigation measures these resources still have low 

vulnerability. In addition, this alternative, above the eight treated in Alternative B) treats the 

Headlands and Tomales Point FMUs that have high potential for archeological resources. 
380 

Unplanned Ignitions, Wildfire, and Suppression 

The chance of an unplanned ignition or wildfire occurring in this alternative is very close to the 

same as in Alternative A, and the long-term major adverse impacts to historic structures or 

cultural landscapes from direct effects of the fire, and to archeological resources from 

suppression or mop-up would be the same as well. 

Mechanical Treatments 

Same as Alternative A, except 1000 additional acres/year would be treated by mechanical means 

for a total of 1500 acres/year. Therefore, beneficial effects to cultural landscapes and historic 

structures would be greater than Alternative A and B. Regarding archeological resources, the 

potential for a short-term, adverse, effect from inadvertently mechanically treating an 

archeological site would be greater than Alternative A or B. The impacts are moderate because 

they could affect a moderate percentage of significant resources; however, because of mitigation 

measures these resources still have low vulnerability. In addition, this alternative, above the 

seven treated in Alternative B) treats the Inverness Ridge, Bolinas Ridge and Tomales Point 

FMUs that could have archeological resources that have not be surveyed or located. 

Fire Information/Education 

No differences compared to Alternative A in the benefits to fire education are anticipated from 

implementing Alternative C. 

Fire Cache/Park Headquarters Relocation, and Construction 

No differences compared to Alternative A in the impacts of constructing and operating a fire 

cache are anticipated from implementing Alternative C. 

Fire Effects and Fuel Management Research 

No additional benefits from conducting research identified as part of this alternative are expected 

compared to Alternative A. 

Cumulative Impacts 

No additional cumulative impacts beyond those described above for Alternative A are expected. 

Conclusion 

Actions included in Alternative C include prescribed burn projects encompassing up to 2000 

acres/year, mechanical treatment projects covering up to 1500 acres/year and a suppression 

program. The fire cache would be located at park headquarter at Bear Valley and education and 

research are similar to Alternative A and B. Beneficial impacts of this alternative include the 

ability to pre-plan for increased prescribed burns and mechanical treatments. On the other hand, 
381 

additional prescribed burning means that those cultural resources vulnerable to direct fire effects 

could be adversely impacted in situations where adequate pre-burn survey and/or mitigation 

could not be employed. Among the beneficial impacts of this alternative are the ability to preplan for prescribed burns, mechanical treatments, defensible space, and road maintenance. 

This alternative would result in short-term, moderate, beneficial effects from prescribed fire and 

mechanical thinning to historic buildings by reducing fuels around these structures. The effects 

would be greater than Alternative A and B. Archeological sites would experience short-term, 

moderate, adverse effects if an area were inadvertently impacted. The potential for these impacts 

to archeological resources is greater than Alternative A and B because more acres and FMUs are 

being treated. Cultural landscapes would have long-term, moderate, beneficial effects because 

historic landscapes such as grasslands could be perpetuated over time. The effects would be 

greater than Alternative A and B. 

No adverse or beneficial effects are anticipated with the construction of the new fire cache on 

historic structures, archeological sites, or cultural landscapes. 

Suppression of average sized wildfires could have negligible to major long-term, major, adverse 

effects to historic buildings or archeological sites. A major wildfire could have major long-term 

impacts from the loss of historic structures during burning, or archeological sites during 

suppression and mop-up. Cultural landscapes could experience long-term, major, adverse effects 

because historic landscapes could be dramatically changed by uncontrolled wildfire. 

The alternative would not result in long-term impairment to cultural resources. 

IMPACTS TO VISITOR USE AND THE VISITOR EXPERIENCE 

Alternative A 

Analysis 

This alternative continues the current fire management program treating 500 acres by prescribed 

fire and 500 acres with mechanical means. There would continue to be visual and visitor 

experience impacts from fuel reduction projects underway, prescribed burns that are conducted 

annually in the spring and fall, and unplanned suppression activities. Two FMUs - Limantour 

and Highway 1 have areas within designated wilderness. 

 

Prescribed Fire 

Prescribed fire can be used as a tool to maintain visual quality and enhance the visitor 

experience, such as in maintenance of view sheds and cultural landscapes, and it can also have 

effects that would be considered potentially adverse to the visitor. Under Alternative A, 

prescribed fire would continue to be used infrequently as a tool for maintaining open scenic 

views. This acreage treated in three FMUs - Limantour, Highway One, and Bolinas Ridge would 

potentially increase scenic vistas from trails and major roadways. In this case, effects of 
382 

prescribed burning on visual resources would be generally beneficial and long-term, but minor, 

because of the limited number of acres treated. 

Some visitors would see the local effects of burning as adverse, but public acceptance of the 

prescribed fire program has increased to the point that this view would be atypical. For those 

individuals that are adversely impacted by burned areas, visual impacts such as charred 

vegetation, blackened earth, or fire lines would be minor because burned areas become green and 

revegetated with a few months (often by the next winter). 

Some visitors would also be impacted by noise from fire management actions, smoke, or the 

closure of an area (usually less than 200 acres and for one or two days) for a prescribed fire. 

Sources of noise during prescribed burns may include the operation of fire engines or other 

heavy equipment, which would move along roads and burn boundaries. A diesel truck traveling 

at 40 miles per hour at 50 feet can have sound levels of 80 dB (16 times as loud as reference 

loudness). Noise would be generated for less than 20 days each year on an average to complete 

projects. 

Effects of closures on visitor activities, including hiking, nature study, and scenic touring, would 

generally be limited to small-scale and temporary restrictions. Visitors would remain able to 

recreate outside of the prescribed fire project boundary, and very few people would be unable to 

partake in their chosen activity, although some may need to experience them in another part of 

the park. 

Smoke would affect a wider area, and thus more visitors, than closures and restrictions. 

However, because prescribed fires would be ignited only under certain atmospheric conditions, 

the effects of concentrated smoke would generally be localized. 

In addition, some visitors expecting a wilderness experience may be adversely impacted from 

smoke, noise and the sight of a burned area; however, this impact would be short-term and 

minor. 

Overall, effects on the visitor experience from activities associated with prescribed burning in 

this alternative would be adverse, short-term, and minor. 

Unplanned Ignitions, Wildfire, and Suppression 

Wildland fires would continue to burn approximately 30 acres per year on average, mostly along 

major roadways. To some, the effect of managed wildland fire on scenic resources would be seen 

as adverse. Other visitors would see the effects as beneficial and natural. Fire in plant 

communities that are within their natural range of variability rarely result in extreme events with 

major effects on visual or scenic quality. The typical effects of fire include blackened bark, cat 

faces on some trees, opening of the understory, cleaning (through burning) of the litter and duff 

layer, and the scorching of some trees, resulting in scattered kill and opening of the canopy. It is 

likely that some park users would see these as non-natural effects and they would consider them 

adverse visual impacts: however, the impact would be short-term and minor because of the small 

number of localized acres suppressed each year and the quick growth of new vegetation. 
383 

Holding Actions (water and retardant drops, helispots, and spike camps) 

These actions have the potential to have short-term effects on visual resources, in the form of 

evidence of helispots and spike camps. These effects would be local in scale and probably not 

encountered by most visitors. Effects on visual quality and visitors would be adverse, short-term, 

and minor. 

During wildland fire incidents, helicopters would be used as needed for reconnaissance, 

monitoring, and moving people and supplies. At least one flight per day would normally be 

flown over fires, many of which would be in wilderness. If the fire grows, the reconnaissance 

area and flight duration would increase as well. Helicopters 100 feet from a person would be as 

loud as 100 dB, a sound that would be uncomfortably loud. In relative terms, this would be 128 

times as loud as an urban, daytime ambient noise level of 40 dB. Should it occur, the effect on 

visitors in the vicinity would be adverse, but since it would be localized and temporary, would 

remain minor. In addition, areas may be closed for short periods (less than five days) for 

unplanned wildfire suppression activities, but the adverse impacts to visitors would be minor and 

short-term. 

Mechanical Treatment 

Mowing, hand cutting, chipping and pile burning actions could adversely affect visitors in both 

the immediate area during treatment, and those who pass through or view the area shortly after 

treatment is completed. Mowing and hand cutting is currently used as a tool to reduce fuels 

around building and along Highway One FMU and in the Estero FMU. Noise from equipment, 

air emissions and the presence of human activity in natural areas are examples of short-term 

adverse impacts to visitors. Chainsaws in close proximity would be the loudest typical 

equipment, with sounds as loud as 100 dB. This noise, especially in a park setting, would be an 

adverse impact on the park visitor experience, but would be short-term and minor. Because 

some areas would be closed during mechanic treatments, the visitor would be impacted only a 

few days (less than 20 per year), and the impacts would be minor because they would be 

extremely localized. 

Pile burning has two potential effects on visual quality. First, piles of stacked fuels would be 

visible, potentially within major scenic views. Second, piles once burned would leave a pattern 

of burned area that would appear unnatural. Both effects would be adverse, short-term, and 

minor because they would be small areas (less than five acres) that are burned and the piles 

would be burned and have new vegetation by the next winter. 

The area treated would also appear different; this may be perceived as an adverse impact as well, 

although with public information and education, some visitors would view treatment as a 

beneficial impact. In either case, the impact would be minor, because vegetation would return 

quickly and the visual change would be localized. 
384 

In addition, some visitors expecting a wilderness experience may be adversely impacted from 

noise and the sight of a mechanically treated area; however, this impact would be short-term and 

minor. 

Fire Information/Education 

The PRNS has staff to assist with fire education to provide information to the visiting public and 

community. Providing information to the public to increase understanding of the objectives of 

the fire program would be beneficial, minor and long-term. 

Fire Cache/Park Headquarters Relocation, and Construction 

Relocation of the fire cache and construction in the present park headquarters compound would 

not have any adverse impacts to viewsheds. The construction of a new building would be 

completed with a site design that incorporates an appreciation of the green space in the 

headquarters area and the site is not accessible to the public. The relocation of the fire cache 

would be completed in an area formerly occupied by a trailer. Although some temporary adverse 

impacts associated with noise of construction are expected, this would be no more than minor 

and temporary. 

Fire Effects and Fuel Management Research 

The PRNS has staff to assist with fire research and document the effects of mechanical and 

prescribed fire treatments and provide this information to the visiting public and community. No 

impacts to visual resource would occur from fire research; however, providing information to the 

public to increase understanding of the objectives of the fire program would be beneficial, minor, 

and long-term. 

Cumulative Impacts 

There have been very few actions taken inside or outside the park in the past to affect the visitor 

experience. Past fire management and fuels treatment activities have resulted in burned areas, 

cut stumps, evidence of holding lines, burned area rehabilitation work, and others that some may 

view as adverse. Some of these impacts are potentially visible from highways entering the park 

such as Sir Francis Drake and Highway One, if passersby knew where to look for them. 

Based on an analysis of the list of projects in Appendix C, the cumulative impacts of all the 

projects listed with this proposed action would have a minor adverse effect on park visual quality 

and the visitor experience. The projects listed do not have long-term impacts to visual quality or 

experience. However, a large-scale wildfire such as the Vision Fire would have a major adverse 

effect on visual quality and the visitor experience. 

Under all alternatives, large, high-intensity, high severity fires would continue to occur 

infrequently in the park until the majority of the park is restored to its natural function. Because 

fires have been, and would continue to be, suppressed, fuels build up and the plant community 

structure changes. It is unlikely that this situation would change markedly during the life of this 
385 

revised Fire Management Plan. If these conditions resulted in a large, high severity fire, there 

may be both short and long-term major adverse impacts. 

During catastrophic fires, large numbers of firefighting personnel and equipment would be 

deployed to control the fire, as needed. Helicopters, chain saws, and other sources of sometimes 

very loud noise could be used over very large areas for several days or weeks. During 

suppression actions that are brought about because of large, high severity fires, noise effects 

would be adverse, short-term, and major. 

Over the longer term, scenic quality and recreational opportunities, including sightseeing, hiking 

in natural areas, and viewing wildlife, may experience large-scale changes that last for many 

years, resulting in major long-term adverse impacts under all alternatives. 

Conclusion 

Prescribed burning would have minor positive effects by opening and restoring scenic vistas, but 

to some visitors the short-term blackening of vegetation from prescribed fires may be a minor 

adverse effect. Smoke and closures would also have temporary, minor, adverse impacts on 

visitors. 

Mechanical treatment may adversely affect nearby visitors through noise. Changes in the treated 

area from mowing or hand cutting would be adverse for some visitors, but beneficial for others. 

Pile burning may also cause localized changes that some visitors find to be negative and other 

positive. Overall, impacts from mechanical treatment would be short-term and minor, regardless 

of whether they are adverse or beneficial. 

Actions to suppression wildfire have the potential to have short-term effects on visual resources, 

in the form of evidence of helispots and spike camps. These effects would be local in scale and 

probably not encountered by most visitors. Effects would be adverse, short-term, and minor. 

Providing information to the public to increase understanding of the objectives of the fire 

program would be indirectly beneficial, minor, and long-term. 

The relocation of the fire cache would have short-term adverse impacts to visitors from noise and 

dust associated with construction. 

While construction projects or past fire management activities would have no more than minor 

short-term impacts to visitors, a large-scale wildfire could result in major adverse impacts to 

recreational activities or scenic quality for several years. Eventually, these resources would 

recover, and no permanent loss of their integrity, e.g., impairment, would occur. 
386 

Alternative B 

Analysis 

The impacts of this alternative on scenic resources would be similar to that of the No Action 

(Alternative A), except in the following areas: 

Prescribed Fire 

While Alternative B has no specific intent to use prescribed burning to improve scenic vistas or 

other components of the visitor experience, it would result in twice the acreage treated with 

prescribed fire as in Alternative A. It would also treat in four FMUs - Inverness Ridge, 

Wilderness North and South, and Palomarin - where treatment to reduce fuels could have side 

benefits to visitors by clearing scenic views from forest fuels that have become overstocked and 

degraded over the past century. Because these benefits would only occur in a small portion of the 

up to 1,000 acres treated each year, the potential to enhance visual resources would be only a 

minor benefit. 

As noted above, these same changes could also be interpreted by some visitors, including 

backcountry visitors in this alternative, as negative. However, public acceptance of the 

prescribed fire program has increased to the point that changes in vegetation resulting from 

prescribed burning would not be seen as adverse by most visitors; education of visitors would 

continue this acceptance and perception of prescribed fire as a benefit. Even so, visual impacts 

such as charred vegetation, blackened earth and fire lines would be adverse, short-term, and 

minor to some park users. 

Visitors would experience minor, short-term, adverse impacts from noise and smoke, and from 

closures, total up to 30 days in this alternative. 

A detectable benefit to scenic or recreational resources by reducing the risk of destruction 

through catastrophic fire is likely with this alternative as well. Prescribed burning would be 

lower intensity than wildfire, resulting is fewer noticeable changes in scenery and the ultimate 

protection of visual resources. Over time, the benefit would be minor. 

Unplanned Ignitions, Wildfire, and Suppression 

No changes in impacts from unplanned ignitions, average annual wildfires, or their suppression 

from those described in Alternative A are expected. 

Mechanical Treatments 

This alternative increases mechanical treatment to 1000 acres, including highly scenic FMUs 

(Wilderness North and South, Tomales Point, and Palomarin). Treatment and closures would last 

for about 30 days each year. Noise from mowing, hand-cutting and chipping equipment, air 

emissions, and the presence of human activity in natural areas could have adverse, localized, 

short-term impacts on visitors. Because some areas would be closed during mechanic treatments, 
387 

visitors would be affected for only a few days (less than 30 per year) and impacts would be 

minor. 

The same effects of pile burning described above would occur under this alternative over a wider 

area of the park. Because the burned areas would quickly revegetation, the impact would be 

short-term and minor. 

The area treated would also appear different; this may be perceived as an adverse impact as well, 

although with public information and education, some visitors would view treatment as a 

beneficial impact. In either case, the impact would be minor, because vegetation would return 

quickly and the visual change would be localized. 

Fire Information/Education 

No changes in impacts from those described for Alternative A would be expected. 

Fire Cache/Park Headquarters Relocation, and Construction 

No changes in impacts from those described for Alternative A would be expected. 

Fire Effects and Fuel Management Research 

No changes in impacts from those described for Alternative A would be expected. 

Cumulative Impacts 

No changes in impacts from those described for Alternative A would be expected. 

Conclusion 

Prescribed burning would have minor positive effects by opening and restoring scenic vistas, but 

to some visitors the short-term blackening of vegetation from prescribed fires may be a minor 

adverse effect. Smoke and closures (up to 30 days) would also have temporary minor adverse 

impacts on visitors. 

Mechanical treatment may adversely affect nearby visitors through noise (closures up to 30 days 

of small areas). Changes in the treated area from mowing or hand cutting would be adverse for 

some visitors, but beneficial for others. Pile burning may also cause localized changes that some 

visitors find to be negative and other positive. Overall, impacts from mechanical treatment would 

be short-term and minor, regardless of whether they are adverse or beneficial. 

Actions to suppression wildfire have the potential to have short-term effects on visual resources, 

in the form of evidence of helispots and spike camps. These effects would be local in scale and 

probably not encountered by most visitors. Effects would be adverse, short-term, and minor. 
388 

Providing information to the public to increase understanding of the objectives of the fire 

program would be indirectly beneficial, minor, and long-term. 

The relocation of the fire cache would have short-term adverse impacts to visitors from noise and 

dust associated with construction. 

While construction projects or past fire management activities would have no more than minor 

short-term impacts to visitors, a large-scale wildfire could result in major adverse impacts to 

recreational activities or scenic quality for several years. Eventually, these resources would 

recover, and no permanent loss of their integrity, e.g., impairment, would occur. 

Alternative C 

Analysis 

The impacts of this alternative on scenic resources would be similar to that of the No Action 

Alternative, except in the following areas: 

Prescribed Fire 

Under this alternative, prescribed fire would be significantly increased (2000 acres) and could be 

used as a major tool for restoring and maintaining scenic resources. Although PRNS does not 

have any specific plans in place to address scenic vistas, there are areas (Limantour, Highway 

One, Wilderness North and South FMU, Palomarin FMU) in which prescribed fire could be 

employed to improve aesthetics and vistas. This acreage would only be a small portion of the 

2,000 acres per year treated on average for resource and hazardous fuel reduction, but the actions 

would clear scenic views of forests that have become overstocked and degraded over the past 

century. Prescribed fire would be used in all ten FMUs and have the potential to change the 

landscape character of an area and therefore has the potential to affect more visitors in the park. 

For visitors who perceive these changes and/or the use of prescribed fire as a tool to return 

systems to natural conditions, moderate benefits are possible in this alternative. For those who 

believe the changes are negative, moderate adverse impacts may result. 

Short-term adverse impacts from blackened earth, charred vegetation, fire lines, smoke, and 

closures for up to 50 days could be moderate because of the larger number of acres treated. 

A larger benefit to scenic or recreational resources by reducing the risk of destruction through 

catastrophic fire than in Alternatives A or B would result from implementing this alternative. 

Prescribed burning would be lower intensity than wildfire, resulting is fewer noticeable changes 

in scenery and the ultimate protection of visual resources. Over time, the benefit could be 

moderate. 

Unplanned Ignitions, Wildfire, and Suppression 

No changes in impacts from those described for Alternative A would be expected. 
389 

Mechanical Treatments 

This alternative increases mechanical treatment to 1500 acres, including several highly scenic 

FMUs (Wilderness North and South, Tomales Point, and Palomarin). Treatment and closures 

would last for about 50 days each year. Noise from mowing, hand-cutting and chipping 

equipment, air emissions, and the presence of human activity in natural areas could have adverse, 

localized, short-term impacts on visitors. The combination of these short-term impacts from 

noise and closures may become quite noticeable and moderately adverse to visitors. 

Pile burning would occur on cut fire lines as the primary method of brush disposal but on a much 

larger scale than in Alternative A and Alternative B. The piles of stacked fuels would be visible 

in the immediate area of work, and potentially within some scenic views. When burned, the 

piles would leave a pattern of burned area that would not appear natural. As in Alternative A 

and B, impacts would be adverse, short-term, and moderate. 

The area treated would also appear different; this may be perceived as an adverse impact as well, 

although with public information and education, some visitors would view treatment as a 

beneficial impact. In either case, the impact would be minor to moderate, and vegetation would 

return quickly. 

Fire Information/Education 

No changes in impacts from those described for Alternative A would be expected. 

Fire Cache/Park Headquarters Relocation, and Construction 

No changes in impacts from those described for Alternative A would be expected. 

Fire Effects and Fuel Management Research 

No changes in impacts from those described for Alternative A would be expected. 

Cumulative Impacts 

No changes in impacts from those described for Alternative A would be expected. 

Conclusion 

Prescribed burning would have minor positive effects by opening and restoring scenic vistas, but 

to some visitors the short-term blackening of vegetation from prescribed fires may be a moderate 

adverse effect. Smoke and small closures of areas (up to 50 days) would also have temporary 

moderate adverse impacts on visitors. 

Mechanical treatment may adversely affect nearby visitors through noise and small closures of 

areas up to 50 days. Changes in the treated area from mowing or hand cutting would be adverse 

for some visitors, but beneficial for others. Pile burning may also cause localized changes that 
390 

some visitors find to be negative and other positive. Overall, impacts from mechanical treatment 

would be short-term and moderate, regardless of whether they are adverse or beneficial. 

Actions to suppression wildfire have the potential to have short-term effects on visual resources, 

in the form of evidence of helispots and spike camps. These effects would be local in scale and 

probably not encountered by most visitors. Effects would be adverse, short-term, and minor. 

Providing information to the public to increase understanding of the objectives of the fire 

program would be indirectly beneficial, minor, and long-term. 

The relocation of the fire cache would have short-term adverse impacts to visitors from noise and 

dust associated with construction. 

While construction projects or past fire management activities would have no more than minor 

short-term impacts to visitors, a large-scale wildfire could result in major adverse impacts to 

recreational activities or scenic quality for several years. Eventually, these resources would 

recover, and no permanent loss of their integrity, e.g., impairment, would occur. 

IMPACT TO PARK OPERATIONS 

Alternative A 

The park currently has about 115 full-time employees (FTEs) and an operating budget of 

approximately $4.9 million, excluding the fire budget. In addition, the park receives annually 

about $2.6 million in one-time funding from fees, and from special NPS funds for natural 

resource, education, cultural resource, and maintenance projects (maintenance projects include 

repair and rehabilitation funding for buildings). 

Fire funding for operations is approximately $770,000 annually for wildfire suppression, 

mechanical treatments, and prescribed fire. For the last three years, Point Reyes and GGNRA 

have received an additional $700,000 annually for Wildland Urban Interface (WUI) projects. 

Staffing for all aspects for fire management is approximately 13 FTEs (Wong, 2003). 

The total operations budget for Point Reyes is $5.67 million. 

Analysis 

Prescribed Fire 

Under this alternative, 500 acres/year at FMUs Estero, Limantour Road, Highway One, and 

Bolinas Ridge would be treated with prescribed fire. Only actions described in the section 

Actions Common to All Alternatives, including road maintenance and brushing around 

buildings, would occur in the other FMUs. Because this is a continuation of existing practices, no 

additional funding or FTEs would be needed. Because the FMUs on Inverness Ridge, Palomarin, 

Wilderness North and South would not be treated, facilities at Five Brooks (horse campground, 

horse stables), housing along Inverness Ridge, and park facilities (Point Reyes Bird Observatory 
391 

Visitor Center and Commonweal housing) at Palomarin would be more susceptible to a largescale fire. The reduction of hazardous fuels around park facilities in these FMUs would reduce 

the risk of a catastrophic fire and the potential for loss of a structure. 

Unplanned Ignitions, Wildfire, and Suppression 

The park relies heavily on Marin County Fire Department for structural fire and wildland fire 

protection. The NPS is considered support and back up for large-scale events. For the most part, 

this arrangement has been highly effective in controlling unplanned ignitions and wildfires. As 

noted in other sections of the EIS, on average the park has only three smaller unplanned ignitions 

(of about 10 acres) each year. Because the No Action alternative would continue this 

arrangement and level of effort, no additional funding or FTE is needed. Therefore no beneficial 

or adverse impacts are anticipated. 

Mechanical Treatments 

Under this alternative, 500 acres/year at FMUs Estero, Limantour Road, Highway One, and 

Bolinas Ridge would be treated by mechanical means. Actions in the other FMUs would be those 

described in the Actions Common to All Alternatives section of the EIS, including road 

maintenance and creating defensible space around structures. Because this is a continuation of 

existing practices, no additional funding or FTEs would be needed. Therefore no beneficial or 

adverse impacts are anticipated. Because the FMUs on Inverness Ridge, Palomarin, Wilderness 

North and South would not be treated, facilities at Five Brooks (horse campground, horse 

stables), housing along Inverness Ridge, and park facilities (Point Reyes Bird Observatory 

Visitor Center and Commonweal housing) at Palomarin would be more susceptible to a largescale fire. The reduction of hazardous fuels around park facilities in these FMUs would reduce 

the risk of a catastrophic fire and the potential for loss of structures. 

Fire Information/Education 

The NPS has one staff and additional interns to assist with fire education. No change in this 

staffing level would occur under the No Action alternative. 

Fire Cache/Park Headquarters Relocation, and Construction 

The construction of a fire cache at Bear Valley would have a one-time cost of approximately 

$500,000. This is a one-time negligible adverse impact to the park’s budget. Existing staff 

would be relocated to this facility. No additional operating costs are necessary. The park would 

receive operational benefits by having a facility and fire staff close to park headquarters. Having 

a fire cache at park headquarters would have beneficial effects on park operations; it would allow 

for more efficient use of staff time (At present, staff travel to and from Hagmaier Fire Cache; 

approximately 7 miles from Bear Valley.) and the fire program would be closer to the major park 

assets such as the Bear Valley Visitor Center and major maintenance facilities. In addition, there 

would be long-term minor beneficial effects by having a more energy efficient building. 
392 

Fire Effects and Fuel Management Research 

No new staffing or funding is necessary; therefore no beneficial or adverse impacts would be 

anticipated. 

Cumulative Impacts 

Based on an analysis of the list of projects in Appendix C, the cumulative impacts of all the 

projects listed with this proposed action would have a negligible adverse effect on park 

operations and management. The projects listed do not require additional operating funds or 

staff except for minor adjustments to the park’s operating budget. However, a large-scale 

wildfire such as the Vision Fire would have a short-term adverse major effect on park operations 

and management. The cost to suppress the Vision Fire is estimated to have been $6.4 million. 

Conclusion 

Because funding and staffing levels would remain the same for all aspects of the fire 

management program, no positive or adverse impacts to either are expected from No Action. The 

one time funding of a new fire cache would have a short-term negligible adverse impact to the 

park’s budget, but would have long-term minor benefits in terms of fire management operations 

by creating new efficiencies. 

The cumulative impacts of all the projects listed with this proposed action (except large-scale 

wildfire) would have a negligible adverse effect on park operations and management. 

Suppression of a large-scale wildfire would a short-term adverse major effect on park operations, 

management, and budget. 

The alternative would not result in long-term impairment to park operations and management. 

Alternative B 

Alternative B would allow prescribed burning of 1000 acres/year in 8 FMUs including Estero, 

Inverness Ridge, Limantour Road, Wilderness North, Wilderness South, Highway One, Bolinas 

Ridge, and Palomarin. 

Analysis 

Prescribed Fire 

To accomplish the level of treatment described above, $105,000 in additional funding and 1.5 

FTEs would be needed (Wong, 2003). This is a 1.9% increase in funding compared to No 

Action, and a minor adverse impact on park operations and management. Because the FMUs on 

Inverness Ridge, Palomarin, Wilderness North and South are treated (above Alternative A), 

facilities at Five Brooks (horse campground, horse stables), housing along Inverness Ridge, and 

park facilities (Point Reyes Bird Observatory Visitor Center and Commonweal housing) at 

Palomarin would be less susceptible to a large-scale fire. The reduction of hazardous fuels 
393 

around park facilities in these FMUs would reduce the risk of a catastrophic fire and the potential 

for loss of a structure. 

Unplanned Ignitions, Wildfire, and Suppression 

As noted in Alternative A, the park relies heavily on Marin County Fire Department for 

structural fire and wildland fire protection and the NPS is considered support and back-up for 

large-scale events. The arrangement has worked well over all to suppress unplanned ignitions 

and keep wildfires to about 30 acres or less per year on average. Therefore no changes are 

anticipated and no beneficial or adverse impacts relative to No Action would occur. 

Mechanical Treatments 

Under this alternative, 1000 acres/year at FMUs Tomales Point, Estero, Limantour Road, 

Highway One, Wilderness North and South, and Palomarin would be treated by mechanical 

means. To accomplish this level of treatment, $105,000 in additional funding and 1.5 FTEs 

would be needed (Wong, 2003). This is a 1.9% increase in operation funding and a minor 

adverse impact on park operations and management. Because the FMUs on Tomales Point, 

Palomarin, Wilderness North and South would be treated by mechanical means (above 

Alternative A), facilities at Five Brooks (horse campground, horse stables), and park facilities 

(Point Reyes Bird Observatory Visitor Center and Commonweal housing) at Palomarin would be 

treated to be less susceptible to a large-scale fire. The reduction of hazardous fuels around park 

facilities in these FMUs would reduce the risk of a catastrophic fire and the potential for loss of 

structures. 

Fire Information/Education 

No changes in staffing or funding from those in No Action are anticipated. 

Fire Cache/Park Headquarters Relocation, and Construction 

As in Alternative A, the construction of a fire cache at Bear Valley would have a one-time cost 

of approximately $500,000. Existing staff would be located to this facility. No additional 

operating costs are necessary and some beneficial impacts to park operations would occur as 

described in Alternative A. 

Fire Effects and Fuel Management Research 

No new staffing or funding is necessary; therefore no beneficial or adverse impacts are 

anticipated. 

Cumulative Impacts 

No cumulative impacts except those described above for Alternative A would occur. 
394 

Conclusions 

Small increases in budget in Alternative B to conduct additional prescribed burning and thinning 

would have minor adverse impacts to park operations and management compared to Alternative 

A. This alternative requires a $211,000 in annual operating funds, a 3.8% increase to overall 

park funding. The one time funding of a new fire cache would have a short-term, negligible, 

adverse impact to the park’s budget, but would have long-term minor benefits in terms of fire 

management operations by creating new efficiencies. 

 

The cumulative impacts of all the projects listed with this proposed action (except large-scale 

wildfire) would have a negligible adverse effect on park operations and management. 

Suppression of a large-scale wildfire would a short-term, adverse, major effect on park 

operations, management, and budget. 

The alternative would not result in long-term impairment to park operations and management. 

Alternative C 

Alternative C would allow prescribed burning of 2000 acres/year in 10 FMUs including Tomales 

Point, Estero, Headlands, Inverness Ridge, Limantour Road, Wilderness North, Wilderness 

South, Highway One, Bolinas Ridge, and Palomarin and mechanical treatment in all except the 

Point Reyes Headlands for a total of 1,500 acres/year. 

Analysis 

Prescribed Fire 

To accomplish the prescribed burning of 2000 acres/year in the FMUs described above, 

$227,000 in funding (3.9% increase) and 4.0 additional FTEs would be needed (Wong, 2003); 

therefore, there would be minor adverse impacts on park operations and management. Because 

the FMUs are treated, facilities at Five Brooks (horse campground, horse stables), housing along 

Inverness Ridge, and park facilities (Point Reyes Bird Observatory Visitor Center and 

Commonweal housing) at Palomarin would be less susceptible to a large-scale fire. In addition, 

treatment at Tomales Point would provide some protection to facilities at Pierce Point Ranch and 

treatments at the Headlands would provide some fire protection for the Lifeboat Station 

Complex. The reduction of hazardous fuels around park facilities in these FMUs would reduce 

the risk of a catastrophic fire and the potential for loss of a structure. 

Unplanned Ignitions, Wildfire, and Suppression 

As noted in Alternative A, the park relies heavily on Marin County Fire Department for 

structural fire and wildland fire protection and the NPS is considered support and back-up for 

large-scale events. The arrangement has worked well over all to suppress unplanned ignitions 

and keep wildfires to about 30 acres or less per year on average. Therefore no changes are 

anticipated and no beneficial or adverse impacts relative to No Action would occur. 
395 

Mechanical Treatments 

Under this alternative, 1,500 acres/year at FMUs Tomales Point, Estero, Limantour Road, 

Highway One, Wilderness North and South, Highway One, Palomarin, and Bolinas Ridge would 

be treated by mechanical means. To accomplish this level of treatment, $113,000 in additional 

funding (1.9 % increase) and 1.0 FTEs would be needed (Wong, 2003); therefore, there would be 

minor adverse impacts on park operations and management. Because all the FMUs would be 

treated by mechanical means except the Headlands, facilities at Five Brooks (horse campground, 

horse stables), housing along Inverness Ridge, and park facilities (Point Reyes Bird Observatory 

Visitor Center and Commonweal housing) at Palomarin would be treated to be less susceptible to 

a large-scale fire. By treating Bolinas Ridge, the ability of the park to stop a fire from traveling 

from the east or west would be enhanced; therefore, facilities in Olema Valley would have 

greater protection. The reduction of hazardous fuels around park facilities in the FMUs listed 

would reduce the risk of a catastrophic fire and the potential for loss of structures. 

Fire Information/Education 

No changes in staffing or funding from those in No Action are anticipated. 

Fire Cache/Park Headquarters Relocation, and Construction 

As in Alternative A, the construction of a fire cache at Bear Valley would have a one-time cost 

of approximately $500,000. Existing staff would be located to this facility. No additional 

operating costs are necessary and beneficial impacts to park operations are anticipated as 

described in Alternative A. 

Fire Effects and Fuel Management Research 

No new staffing or funding is necessary; therefore no beneficial or adverse impacts are 

anticipated. However, because additional research is proposed, one-time research projects would 

need funding. Therefore, there would be a minor impact to the park’s budget. 

Cumulative Impacts 

No cumulative impacts except those described above for Alternative A would occur. 

Conclusions 

An overall 5.9% increase in budget and additional 5 FTEs in staffing in Alternative C to conduct 

additional prescribed burning and thinning would have minor adverse impacts to park operations 

and management compared to Alternative A. These increases would be larger than in Alternative 

B. However, the beneficial impacts to providing fire protection for park facilities are greater 

than Alternative A and B. The one time funding of a new fire cache would have a short-term, 

negligible, adverse impact to the park’s budget, but would have long-term minor benefits in 

terms of fire management operations by creating new efficiencies. 
396 

The cumulative impacts of all the projects listed with this proposed action (except large-scale 

wildfire) would have a negligible adverse effect on park operations and management. 

Suppression of a large-scale wildfire would a short-term adverse major effect on park operations, 

management, and budget. 

The alternative would not result in long-term impairment to park operations and management. 

IMPACTS TO HUMAN HEALTH AND SAFETY 

Alternative A 

Human health may be affected by prescribed burning and wildland fire through the inhalation of 

smoke. During a prescribed burn, visitors would remain outside the area through the use of 

temporary trail closures, signing, public information about the fire, and other temporary closures 

of areas and facilities. In the case of an “average” wildland fire (e.g., the park on average 

experiences fires in fewer than 30 acres), visitors or community members may require 

evacuation. In either case, they would not be exposed to the fire itself and safety risks would be 

minimized. However, firefighting personnel would be much closer to either prescribed burns or 

wildland fires, and so may be subject to increased risk to their safety. 

All individual wildland fire use and prescribed fire projects would be managed under the same 

conditions and constraints under all alternatives. Each project would be implemented only with 

the concurrence of the Bay Area Regional Air Quality Control District, and managed to maintain 

smoke emissions in communities below the legal thresholds as defined by the State of California 

and the Environmental Protection Agency. Because of these restrictions, alternatives with more 

acres burned under prescription, and therefore where timing, placement and conditions under 

which they burn, would be more successful at minimizing smoke impacts over the long-term. 

Analysis 

Prescribed Fire 

The principal effect of FMP activities on public health is generation of smoke, especially 

particulate matter, from prescribed fires and unintended wildland fire. Particulate matter, found 

in the air-liquid droplets and small solid particles of minerals and soot can penetrate deep into the 

lungs because it is small. In smoke, roughly 80% of the particulate matter is smaller than 2.5 

micrometers in diameter. Smoke impacts are not related only to acreage burned, but to 

vegetation type, fuel loading and weather conditions, among other factors. For example, 

grassland fires produce much less smoke per acre than do forest fuels. Even areas of similar 

vegetation types in forested areas may have significantly different amounts of emissions due to 

lower fuel load and smoke production in restored areas compared to areas that have missed 

several cycles of wildland fire and contain unnaturally heavy fuel loadings. 

Healthy adults are not usually at risk from particulate matter; they may experience runny noses 

and coughing but these symptoms usually subside as the smoke disperses. People with heart or 

lung diseases, such as congestive heart disease, chronic obstructive pulmonary disease, 
397 

emphysema, or asthma can be at risk. People with these conditions may find it difficult to 

breathe, may cough, or feel short of breath after inhaling smoke from a prescribed burn or 

wildland fire. Children and the elderly are generally more susceptible to the harmful effects of 

smoke (CARB, 2003). 

Most byproducts of wildland and prescribed fire combustion of health concern are concentrated 

at the fire line, and decrease to negligible levels in very short distances. Local weather patterns 

affect smoke mixing and movement, especially at night. Generally, the greater distance from the 

fire, the larger the volume of air available to dilute smoke below levels considered harmful to 

humans. Despite this apparent relative benefit, fine particulates also travel much greater 

distances from firelines, making them of most concern to public health. 

Firefighters are exposed to the highest health risk from smoke on or near the firelines. The risks 

are well studied and include inhalation of carbon monoxide, hydrocarbons, and particulates. 

Standard firefighting practices are employed to minimize firefighter exposure. These practices 

include: planning the location of firelines to minimize exposure and rotating firefighters out of 

smoky segments of the fire line at frequent intervals. Firefighter safety may also be at risk, 

although prescribed burns are well planned and risks are minimal. Sources of risk, in addition to 

the fire itself, include tree felling, fire line construction, helicopter transport, and handling 

petroleum products. 

Fire management personnel would be exposed to increasingly hazardous conditions at the 

Seashore over time as fuels continue to accumulate in untreated areas of the parks and the risk of 

high severity fire grows. Efforts at direct attack or suppression of intense fires can become 

increasingly difficult the hotter and quicker a fire burns. 

Because Alternative A would only result in a maximum of 500 acres burned each year, impacts 

to fire fighting personnel, visitors and community members from smoke would remain shortterm and minor. However, this alternative would do relatively less than the other alternatives to 

address the continued accumulation of fuels in the park, and the risk of a large and hot wildfire 

similar to the Vision Fire. Should such a fire burn, both health and safety may be seriously 

threatened. 

Wildland Fire and Suppression 

Wildland fires on average burn less than 30 acres at the Seashore each year. Although the 

location at which these fires may burn is not controlled, they are quickly suppressed and are 

small. Therefore the smoke impacts from average wildland fires to visitors, community 

members, or firefighting personnel would be short-term, minor, and localized. 

Mechanical Treatment 

Up to 500 acres of land would be mechanically thinned, some of it to reduce accumulated fuels. 

To the extent that the risk of a catastrophic fire is reduced by mechanical treatment, some 

negligible benefit to long-term safety and human health is possible, as both the risk of injury 

from the fire itself and to human health from inhaling smoke would be reduced. Mechanical 
398 

treatment projects in the Limantour, Highway One, and Bolinas Ridge FMUs would also 

improve safety to responding firefighters by reducing fuels along existing fire roads and creating 

zones of reduced fuels to impede wildfire spread. 

Any potential safety impacts to visitors from equipment use would be eliminated or minimized 

through posted closures during mechanical treatment. 

Public Education and Research/Fire Cache Construction 

Public education, fire research, and the building of a fire cache would all have beneficial, longterm impacts on human health and safety. Public education would provide timely information on 

fire management actions and inform the public about prescribed or wildland burns and closures. 

Research could help in providing guidance on how to best avoid smoke or danger to residents or 

fire fighters. Locating a cache closer to other park administrative offices would reduce response 

time. Together, these offer negligible to minor benefits to human health and safety. 

Cumulative Impacts 

The projects listed in Appendix C would not have adverse impacts to human health and safety. 

However, a large-scale wildfire such as the Vision Fire could have a short-term adverse major 

effect on the health and safety of firefighters, visitors, and local communities. 

A large wildfire has the potential to increase the exposure of visitors, employees, and 

communities to ground level smoke, particularly during late night and morning periods when 

smoke plumes collapse, descend and concentrate in low-lying areas or canyon bottoms. Wildland 

fires similar to those in 1999, when numerous wildland fires were burning simultaneously 

throughout northern California could affect the park and, thus, the health and safety of visitors 

and park employees for several weeks. 

During catastrophic fires, large fire organizations would be employed to control the fire, as 

needed. When this occurs, a larger amount of equipment, including helicopters and fire engines, 

would be used to accomplish fire control objectives. Complex fire operations can extend their 

activities over large areas, sometimes tens of thousands of acres. An increase in the number and 

extent of suppression fires would cause an increase in the rate of exposure of fire personnel to 

hazardous conditions - both fire and smoke. This exposure would be unplanned with the 

potential for a higher rate of injury to firefighters and the public. Efforts at direct attack or 

suppression of intense fire would also pose a threat to firefighter safety due to the nature of such 

activities. Additional hazards of fighting wildfires include fire line construction, tree falling, 

helicopter transport, direct flame exposure, and respiratory problems due to smoke inhalation. To 

help mitigate impacts, firefighters would be frequently rotated and allowed to rest or sleep when 

needed, and firelines would be used to minimize exposure. Even with these mitigation measures, 

exposure to risk from the fire itself and from heavy smoke to firefighter, visitors and community 

members could be major and adverse during the time the fire is burning. 
399 

Conclusion 

The actions of this alternative would have direct adverse, short-term, and minor impacts upon the 

health and safety of both the public and firefighters, except during large, high severity fire 

events, when the proximity of people to smoke and flame would result in major, short-term, and 

unavoidable adverse impacts. Alternative A minimizes smoke impacts in the short-term, but 

offers no more than negligible benefits in addressing the continued accumulation of fuels that is 

a wildfire risk to adjacent communities. 

Public education, fire research, and fire cache construction would provide minor benefits by 

informing the public of prescribed burns and by reducing response time and increasing response 

effectiveness. 

Alternative B 

Analysis 

The impacts of this alternative on human health and safety would be similar to that of the No 

Action (Alternative A), except in the following areas: 

Prescribed Fire 

Double the acreage burned in Alternative A would be treated with prescribed fire. The same 

types of impacts identified in Alternative A, e.g., inhalation of smoke and particularly of fine 

particulates by visitors or community members, and of carbon monoxide, hydrocarbons, and 

particulates by firefighters, would occur. Because more acreage would be burned, the chances of 

exposure to visitors, employees and the public would be greater. This would particularly be true 

of ground level smoke, especially during late night and morning periods when smoke plumes 

collapse, descend and concentrate in low-lying areas or canyon bottoms. 

Firefighters would be exposed to the same type of impacts from fire and smoke as described 

above over a wider acreage. Fire line construction, tree falling, and firing operations would be 

conducted in a relatively safe and orderly fashion compared to a wildland burn, and prescribed 

fires are generally of lower intensity and less threatening than wildfires. However, risks would 

remain, as they would from handling petroleum products and other tasks associated with 

preparing for and conducting prescribed burns. Although treated acreage would be doubled, 

mitigation described above would minimize impacts. Injuries may increase, but the rate of such 

an increase is not possible to predict with any certainty. 

Both public and firefighter exposure to wildfire hazards, including smoke, would be 

progressively reduced over time because of the reduction in fuels associated with the prescribed 

burning of up to 1,000 acres. The effect would be minor to moderate and long-term. 
400 

Wildland Fire and Suppression 

Overall, there is no expected increase in fire-caused injuries to visitors, employees, and the 

public due to current suppression activities that average 30 acres per year. 

Mechanical Treatment 

Double the acreage in Alternative A would be mechanically treated in this alternative. 

Mechanical treatment (expanded to 1000 acres) would occur which has the potential to increase 

the exposure of visitors, employees, and the public to equipment activity. However, because 

areas to treated are to be temporarily closed, any increase in direct impacts to human health and 

safety would be short-term and minor. 

Mechanical treatment in the Limantour, Highway One, Inverness Ridge, Wilderness North and 

South, Bolinas Ridge, and Palomarin FMUs would improve safety to responding firefighters, 

reduce fuels along existing fire roads and create zones of reduced fuels to impede fire spread. 

Public Education, Fire Research, and Fire Cache Construction 

No differences beyond those identified in Alternative A would occur. 

Under this Alternative, fire personnel would be exposed to additional hazards in their work 

above Alternative A. The effect would be minor, short-term, but greater than Alternative A. 

Cumulative Impacts 

No cumulative impacts beyond those described under Alternative A would be expected. 

Conclusion 

Alternative B would have direct adverse, short-term, and minor impacts upon the health and 

safety of both the public and firefighters, except during large, high severity fire events, when the 

proximity of people to smoke and flame would result in major, short-term, and unavoidable 

adverse impacts. 

A minor to moderate long-term benefit to public and park staff health and safety greater than that 

in Alternative A from the reduction of fuels through both prescribed fire and mechanical thinning 

and reduction in the risk of catastrophic fire would occur. 

Public education, fire research, and fire cache construction would provide minor benefits by 

informing the public of prescribed burns and by reducing response time and increasing response 

effectiveness. 
401 

Alternative C 

Analysis 

Prescribed Fire 

Up to 2000 acres per year would be treated with prescribed burning in this alternative. The same 

types of impacts identified in Alternative A, e.g., inhalation of smoke and particularly of fine 

particulates by visitors or community members, and of carbon monoxide, hydrocarbons, and 

particulates by firefighters would occur. Because more acreage would be burned, the chances of 

exposure to visitors, employees and the public would be greater than in either Alternative A or B. 

This would particularly be true of ground level smoke, especially during late night and morning 

periods when smoke plumes collapse, descend and concentrate in low-lying areas or canyon 

bottoms. The public and firefighting personnel may also be at slightly greater risk of prescribed 

fire burning outside its prescription. If this happens, heavier fuel loads could burn with resulting 

increases in smoke. In the extreme, the fire itself could be threatening, although preparation and 

the presence of a crew and firefighting apparatus on site means the extent of an escape would be 

minimal. 

Firefighters would be exposed to the same type of impacts from fire and smoke as described 

above over a wider acreage. Although treated acreage would be expanded, mitigation described 

above would minimize impacts. Injuries may increase, but the rate of such an increase is not 

possible to predict with any certainty. 

Both public and firefighter exposure to wildfire hazards, including smoke, would be 

progressively reduced over time because of the reduction in fuels associated with the prescribed 

burning of up to 2,000 acres. Although this alternative would treat more acres through prescribed 

burning (and mechanical treatment), additional acreage over that identified in Alternative B may 

be treated not just to reduce fuels, but to enhance or protect natural and cultural resources. The 

degree of beneficial impact in reducing the risk and/or extent of a large and intense wildfire 

would therefore be somewhat, but not significantly greater than that if Alternative B were 

implemented. 

Wildland Fire and Suppression 

Overall, there is no expected increase in fire-caused injuries to visitors, employees, and the 

public due to current suppression activities that average 30 acres per year. 

Mechanical Treatment 

Up to 1500 acres per year would be mechanically treated each year under this alternative. The 

foci of mechanical treatment would be primarily to control the spread of invasive exotic species 

and to reduce the risk or potential for spread of a wildfire. Forests would be thinned prior to 

prescribed burning and a fuel break along Inverness Ridge would be maintained. In combination 

with the reduced fuel loads from prescribed burning described above, firefighters and the public 
402 

may experience a moderate benefit in the reduction of risk and extent of a large-scale and 

potentially dangerous wildfire. 

As in other alternatives, closures and public information would prevent or minimize any impacts 

to the public from mechanical thinning or mowing equipment. 

Public Education, Fire Research, and Fire Cache Construction 

No differences beyond those identified in Alternative A would occur. 

Under this Alternative, fire management personnel would be exposed to hazards of firefighting, 

smoke inhalation and the use of mechanical equipment over more acreage than in either of the 

other alternatives. 

Cumulative Impacts 

No cumulative impacts beyond those described under Alternative A would be expected. 

Conclusion 

Alternative C would have direct adverse, short-term, and minor impacts upon the health and 

safety of both the public and firefighters, except during large, high severity fire events, when the 

proximity of people to smoke and flame would result in major, short-term, and unavoidable 

adverse impacts. 

A moderate benefit to public and park staff health and safety greater than that in Alternative B 

from the reduction of fuels through both prescribed fire and mechanical thinning and reduction in 

the risk of catastrophic fire would occur. 

Public education, fire research, and fire cache construction would provide minor benefits by 

informing the public of prescribed burns and by reducing response time and increasing response 

effectiveness. 

SOCIOECONOMIC IMPACTS 

Alternative A 

Impacts on Regional Economy 

Under this alternative, the fire management program may have both direct and indirect impacts 

on the local economy (West Marin County) that is primarily driven by tourism spending. Direct 

impacts include the park’s transactions with local businesses that supply goods and services for 

fire management activities. Additional direct impacts come from employees on the fire program 

payroll who procure personal housing, food, goods, and services from local businesses. Indirect 

impacts include the impact of fire management activities on tourism. 
403 

The analysis in this section primarily evaluates the costs and jobs associated with the core fire 

program envisioned under each alternative and compares it to the local economy. The core fire 

program includes preparedness and initial attack suppression capabilities and the costs associated 

with implementing a prescribed fire and mechanical treatment program. The analysis also 

compares the potential impacts of the actions proposed on the local economy and the potential 

loss or creation of jobs. 

As noted in the Affected Environment, Point Reyes National Seashore received 2.35 million 

visitors in 2000 accounting for 930 travel party days/nights in the area. An average visitor party 

spends $94 per party per night in the local area ($109 if locals excluded). Total visitor spending 

was $87 million in 2000, $80 million excluding local visitors. This spending of visitors from 

visitors from outside the local region generates $69 million in sales by local tourism businesses, 

yielding $25.6 million in direct income and supporting 1,100 jobs. Each dollar of tourism 

spending yields another $.63 in sales through the circulation of spending within the local 

economy. Including these secondary effects, the total economic impact of tourism on the local 

economy is $113 million in sales, $42 million in wages and salaries, and 1,800 jobs (Michigan 

State University, 2001). 

Under Alternative A, overall fire funding for operations is estimated at approximately $770,000 

annually for wildfire suppression, mechanical treatments and prescribed fire. For the last three 

years, Point Reyes and GGNRA have received an additional $700,000 annually for Wildland 

Urban Interface (WUI) projects in the local community. Staffing for all aspects for fire 

management is approximately 13 Full Time Equivalents (FTEs; one person for a work year) 

(Wong, 2003). Employees may contribute to the economy as well by renting or buying housing 

and purchasing goods and services locally. Compared to the existing $155 million benefits of 

tourism overall, an additional $1.5 million would have only minor beneficial impacts. This is 

also true with jobs, as 13 staff compared to the 1,800 jobs created by tourism would have only 

minor benefits on the local economy. In addition, the 13 fire employees created compared to the 

120,000 jobs in Marin County indicates beneficial impacts are minor (Marin County, 2003). 

In any agency EIS, a section analyzing any impacts to minority or low-income populations from 

the proposed actions is required. The actions proposed in this alternative, including prescribed 

fire, mechanical treatment, and suppression of small or large wildfires, would have no 

disproportionate impact on minorities or low-income populations. In fact, most of the homes in 

the vicinity of the park are in the half-million dollar and up range. 

Prescribed Fire Impacts on Local Economy 

Under this alternative, 500 acres/year would be treated with prescribed fire. Based on past 

prescribed fires conducted at PRNS over the past 15 years, this Alternative would not result in 

the closure of any areas (usually 200 acres or less) for more than one or two days. Therefore, 

any adverse economic impacts from prescribed fire to tourism are short-term, negligible to the 

local economy. Some portion of the fire management budget and staffing is attributable to 

prescribed fire, with resulting negligible to minor beneficial impacts from fire operations 

spending, jobs and the purchase of goods and services by fire management staff. 
404 

Unplanned Ignitions, Wildfire, and Suppression Impacts on Local Economy 

The park relies heavily on Marin County Fire Department for structural fire and wildland fire 

protection. The NPS is considered support and back up for large-scale events. In past years, 

unplanned ignitions (except large-scale fires) have not impacted the regional economy or the 

visitor population of the park. However, there have been short-term negligible impacts due to 

minor closures of areas during suppression for short periods, usually less than one day. 

Under any of the alternatives, the build-up of fuels would continue as no alternative treats the 

entire study area; therefore, a large-scale wildfire at infrequent intervals in always a possibility. 

Socioeconomic impacts of such a fire may be similar to those associated with the Vision Fire in 

1995. It consumed 48 homes and damaged an additional 18, resulting in property damage to 

structures estimated at $37 million. The economic impact to business is estimated to have been 

$1.365 million. The estimated for public service recovery (includes road repairs, water control 

facility repairs, debris removal, emergency protection measures) was estimated at $1.781 

million. The total economic loss estimate was $40.146 million. Total suppression costs were 

estimated at $6.4 million (Marin County Fire Department, 1995). 

Mechanical Treatments Impacts of Local Economy 

Under this alternative, 500 acres/year at FMUs Estero, Limantour Road, Highway One, and 

Bolinas Ridge would be treated by mechanical means. Tomales Point, Headlands Inverness 

Ridge, Wilderness North, Wilderness South, Palomarin would only receive actions common to 

all alternative such as road maintenance and defensible space around structures. This level of 

treatment would not have a measurable effect on the regional economy or the visitor population. 

However, there have been short-term negligible impacts to the visitor experience and possibly 

therefore to the tourism economy due to minor closures of areas during mechanical treatment for 

safety reasons. As in prescribed burning, some portion of the fire management budget and 

staffing is attributable to mechanical treatments, with resulting negligible to minor beneficial 

impacts from fire operations spending, jobs and the purchase of goods and services by fire 

management staff. 

Fire Information/Education on Local Economy 

There are no beneficial or adverse impacts anticipated under this alternative. 

Fire Cache/Park Headquarters Relocation, and Construction on Local Economy 

The construction of a fire cache at Bear Valley would have a one-time cost of approximately 

$500,000. This would have a one-time beneficial, minor, economic effect on the local economy 

in terms of jobs and one time funding. . 

Fire Effects and Fuel Management Research 

There are no beneficial or adverse impacts to the local economy anticipated under this 

alternative. 
405 

Cumulative Impacts 

Based on an analysis of the list of projects in Appendix C, the cumulative impacts of all the 

projects listed with this proposed action would have a beneficial minor effect on the local 

economy by the influx of some additional federal funding and a few jobs. 

A large-scale wildfire that may or may not include land inside the project area would have a 

short-term adverse moderate effect on the regional economy and visitor population. For 

example, parts of the park could be closed for up to two months for rehabilitation, resulting in 

moderate negative impact to the local economy. In addition, the total damage to structures and 

public facilities resulting from the Vision Fire was estimated $40.146 million. Therefore, a 

large-scale fire would have a major impact on the local economy, both beneficial and adverse. 

The Vision Fire, for example, created a building surge due to reconstruction of the lost 

structures; however, as noted above, several homes were lost and millions spent to suppress the 

fire. 

Conclusions 

Under Alternative A, direct fire funding and staffing would have minor, long-term, beneficial 

impacts compared to dollars and staff positions generated from tourism in the local economy. No 

disproportionate impacts to low-income or minority populations would occur. 

The prescribed burn program is not expected to result in more than very short-term closures of 

small areas, with no or negligible adverse impacts on tourism and the local economy. Areas may 

be closed during mechanical treatment, which because it lasts longer, may result in negligible to 

minor short-term impacts to tourism and the local economy. 

In past years, unplanned ignitions (except large-scale fires; see cumulative impacts) have not 

impacted the regional economy or the visitor population of the park. However, there have been 

short-term, negligible impacts to the local economy due to minor closures of areas during 

suppression for short periods (less than one day). 

Additional building and other projects in the Seashore would have a minor beneficial cumulative 

effect on the local economy. Cumulative effects from a larger wildfire, should it occur, could be 

major and both adverse and beneficial. Adverse impacts would result from the loss of property 

and money spent to suppress the fire, but benefits would also result from rebuilding and the 

influx of federal money. 

Alternative B 

Impacts on Regional Economy 

Under Alternative B the number of acres treated by both prescribed burning and mechanical 

treatment would double to up to 1000 acres/year. Suppression activities would remain the same 

as in Alternative A. Based on the analysis, operating funds for fire management under this 
406 

option would increase by $211,000 to about $1.7 million. Three additional jobs, or 16 FTEs 

would be created compared to No Action. With this level of spending and comparing it the jobs 

(1,800) and economic benefits of tourism ($155 million), direct fire operations spending and job 

creation has a beneficial long-term, but minor impact of the local economy. However, compared 

to No Action, spending would increase by 13%, and 23% more fire management personnel 

would be required. Compared to the entire regional economy, these increases would be 

negligible or minor; compared to the park’s fire management operations in Alternative A, they 

would be minor to moderate increases. 

The actions proposed in this alternative, including prescribed fire, mechanical treatment, and 

suppression of small or large wildfires, would have no disproportionate impact on minorities or 

low-income populations. 

Prescribed Fire Impacts on Local Economy 

Under this alternative, 1000 acres/year would be treated with prescribed fire. Based on past 

prescribed fires conducted at PRNS over the past 15 years, this alternative would not result in the 

closure of any areas (usually 200 acres or less) for more than one or two days. Therefore, any 

adverse impacts to the local economy from prescribed fire are short-term and negligible. This 

alternative would add some portion of the $1.7 million fire management budget to the local 

economy, and some or all of the 16 staff would spend money in the local communities for goods 

and services. While this is a minor benefit compared to spending overall in neighboring 

communities, it is possibly as much as a moderate benefit compared to these features of the No 

Action alternative. 

Unplanned Ignitions, Wildfire, and Suppression Impacts on Local Economy 

No changes in impacts from the implementation of Alternative B compared to Alternative A are 

expected. 

Mechanical Treatments Impacts of Local Economy 

Under this alternative, double the acres treated in No Action would be mechanically thinned. 

This level of treatment would not have a measurable effect on the regional economy or the 

visitor population. However, there have been short-term negligible impacts to the visitor 

experience and possibly therefore to the tourism economy due to minor closures of areas during 

mechanical treatment for safety reasons. Based on past experience in the park, visitors use other 

park areas with small areas are closed and do not leave the park; therefore impacts from 

reductions in tourism spending would not be more than negligible. As in prescribed burning, 

some portion of the fire management budget and staffing is attributable to mechanical treatment, 

with resulting beneficial impacts from fire operations spending, jobs and the purchase of goods 

and services by fire management staff. Although these would be negligible or minor compared to 

total local spending, they may be moderate benefits compared to similar spending conducted 

under No Action. 
407 

Fire Information/Education on Local Economy 

As in Alternative A, there would be no beneficial or adverse impacts anticipated under this 

alternative. 

Fire Cache/Park Headquarters Relocation, and Construction on Local Economy 

As in Alternative A, construction of the fire cache would have a one-time beneficial, minor, 

economic effect on the local economy in terms of jobs and one time funding. 

Fire Effects and Fuel Management Research 

As in Alternative A, there would be no beneficial or adverse impacts to the local economy 

resulting from research. 

. 

Cumulative Impacts 

No additional cumulative impacts beyond those described under Alternative A are anticipated if 

Alternative B were implemented. 

Conclusions 

Under Alternative B, direct fire funding and staffing would have minor, long-term, beneficial 

impacts compared to dollars and staff positions generated from tourism in the local economy. 

Compared to spending in No Action, these benefits may be more moderate. No disproportionate 

impacts to minority or low-income populations would occur. 

The prescribed burn program is not expected to result in more than very short-term closures of 

small areas, with no or negligible adverse impacts on tourism and the local economy. Areas may 

be closed during mechanical treatment, which because it lasts longer, may result in negligible to 

minor short-term impacts to tourism and the local economy. 

In past years, unplanned ignitions (except large-scale fires; see cumulative impacts) have not 

impacted the regional economy or the visitor population of the park. However, there have been 

short-term, negligible impacts to the local economy due to minor closures of areas during 

suppression for short periods (less than one day). 

Additional building and other projects in the Seashore would have a minor beneficial cumulative 

effect on the local economy. Cumulative effects from a larger wildfire, should it occur, could be 

major and both adverse and beneficial. Adverse impacts would result from the loss of property 

and money spent to suppress the fire, but benefits would also result from rebuilding and the 

influx of federal money. 
408 

Alternative C 

Impacts on Regional Economy 

Under Alternative C, actions include prescribed burn projects encompassing up to 2000 

acres/year, mechanical treatment projects covering up to 1500 acres/year and a suppression 

program. Operating funds for fire management under this option would increase by $230,000 

and five extra fire jobs would be created. With this level of spending and comparing it the jobs 

(1,800) and economic benefits of local tourism ($155 million), direct fire operations spending 

and job creation has a beneficial long-term, but minor impact of the local economy. However, 

compared to No Action, this is a 15% increase in direct spending and an increase of 38% in 

staffing. These benefits are moderate compared to No Action. 

The actions proposed in this alternative, including prescribed fire, mechanical treatment, and 

suppression of small or large wildfires, would have no disproportionate impact on minorities or 

low-income populations. 

Prescribed Fire Impacts on Local Economy 

Under this alternative, 2000 acres/year would be treated with prescribed fire. Based on past 

prescribed fires conducted at PRNS over the past 15 years, this alternative would not result in the 

closure of any areas (usually 200 acres or less) for more than one or two days. Therefore, any 

adverse impacts to the local economy from prescribed fire are short-term and negligible. This 

alternative would add some portion of the $1.8 million fire management budget to the local 

economy, and some or all of the 18 staff would spend money in the local communities for goods 

and services. While this is a minor benefit compared to spending overall in neighboring 

communities, it is likely a moderate benefit compared to these features of the No Action 

alternative. 

Unplanned Ignitions, Wildfire, and Suppression Impacts on Local Economy 

No changes in impacts from the implementation of Alternative C compared to Alternative A are 

expected. 

Mechanical Treatments Impacts of Local Economy 

Under this alternative, triple the acres treated in No Action would be mechanically thinned. This 

level of treatment would not have a measurable effect on the regional economy or the visitor 

population. However, there have been short-term negligible impacts to the visitor experience and 

possibly therefore to the tourism economy due to minor closures of areas during mechanical 

treatment for safety reasons. Based on past experience in the park, visitors use other park areas 

with small areas are closed and do not leave the park; therefore impacts from reductions in 

tourism spending would not be more than negligible. As in prescribed burning, some portion of 

the fire management budget and staffing is attributable to mechanical treatment, with resulting 

beneficial impacts from fire operations spending, jobs and the purchase of goods and services by 

fire management staff. Although these would be negligible or minor compared to total local 
409 

spending, they would be moderate benefits compared to similar spending conducted under No 

Action. 

Fire Information/Education on Local Economy 

As in Alternative A, there would be no beneficial or adverse impacts anticipated under this 

alternative. 

Fire Cache/Park Headquarters Relocation, and Construction on Local Economy 

As in Alternative A, construction of the fire cache would have a one-time beneficial, minor, 

economic effect on the local economy in terms of jobs and one time funding. 

Fire Effects and Fuel Management Research 

As in Alternative A, there would be no beneficial or adverse impacts to the local economy 

resulting from research. 

. 

Cumulative Impacts 

No additional cumulative impacts beyond those described under Alternative A are anticipated if 

Alternative C were implemented. 

Conclusions 

Under Alternative C, direct fire funding and staffing would have minor, long-term, beneficial 

impacts compared to dollars and staff positions generated from tourism in the local economy. 

Compared to spending in No Action, these benefits are likely to be moderate. No 

disproportionate impacts to minority or low-income populations would occur. 

The prescribed burn program is not expected to result in more than very short-term closures of 

small areas, with no or negligible adverse impacts on tourism and the local economy. Areas may 

be closed during mechanical treatment, which because it lasts longer, may result in negligible to 

minor short-term impacts to tourism and the local economy. 

In past years, unplanned ignitions (except large-scale fires; see cumulative impacts) have not 

impacted the regional economy or the visitor population of the park. However, there have been 

short-term, negligible impacts to the local economy due to minor closures of areas during 

suppression for short periods (less than one day). 

Additional building and other projects in the Seashore would have a minor beneficial cumulative 

effect on the local economy. Cumulative effects from a larger wildfire, should it occur, could be 

major and both adverse and beneficial. Adverse impacts would result from the loss of property 

and money spent to suppress the fire, but benefits would also result from rebuilding and the 

influx of federal money. 
410 

MANDATORY SECTIONS 

The following is a summary of three types of impacts that is required by the NEPA regulations 

that apply to all agencies. The first describes what each alternative sacrifices in terms of longterm sustainability to achieve short-term gain. The second section discusses the commitment of 

any irreversible (permanent loss or non-renewable resource) or irretrievable (short-term loss or 

loss of renewable resource) commitments of resource an alternative would require. The final 

section is a summary of any remaining more than minor adverse impacts that cannot be further 

mitigated. 

Alternative A 

Short-term Use Versus Long-term Enhancement of Resources 

Fire management activities would result in some mortality of wildlife and vegetation, but would 

reduce threat of large, intense wildland fires. Short-term adverse impacts related to project 

activity would result in long-term beneficial impacts to restore more natural forest conditions. 

Without prescribed fire actions under Alternative A, the loss of fire as a factor in the long-term 

development of the forest ecosystem could adversely affect long-term productivity. Long-term 

adverse impacts are acceptable due to the beneficial impacts provided, and most long-term 

adverse impacts would be mitigated to less than significant. Prescribed fires may escape to 

become wildland fires. However, this risk is offset by the reduced risk of wildland fire ignition 

and high severity wildland fires when projects are completed. 

Irreversible/Irretrievable Commitments of Resources 

No irreversible/irretrievable commitments of resources would occur under Alternative A. 

Unavoidable Adverse Impacts 

Some native vegetation would be removed to reduce fuel levels and suppress wildland fires and 

indirectly affect wildlife. These adverse impacts are short-term and would be mitigated to a 

minor to moderate impact. Mitigation measures would minimize exotic plant species 

introduction and expansion, however, some adverse impact would still occur. 

Alternative B 

Short-term Use Versus Long-term Enhancement of Resources 

Fire management activities under Alternative B that are greater than Alternative B and occur in 

more areas in the park would result in some mortality to wildlife and vegetation, but would 

reduce threat of large, intense, wildland fire (more than Alternative B). Short-term impacts 

related to project activity would restore more natural forest conditions and have long-term 

benefits to the natural ecosystem preservation. Prescribed fires may escape to become wildland 

fires. However, this risk is offset by the reduced risk of wildland fire ignition and high severity 

wildland fires when projects are completed. 
411 

Irreversible/Irretrievable Commitments of Resources 

No irreversible/irretrievable commitments of resources would occur under Alternative B. 

Unavoidable Adverse Impacts 

Some native vegetation and wildlife would be adversely impacted to reduce fuel levels and 

suppress wildland fires. Mitigation measures should minimize any adverse impacts to minor or 

moderate over the long-term. Exotic plant species introduction and expansion would be 

mitigated to reduce any adverse impacts; however, some impact would still occur. Expanded 

prescribed burning (spring burns) could result in decreased reproduction of herbaceous species, 

depending on plant stage of development, phenology, and timing. 

Alternative C 

Short-term Use Versus Long-term Enhancement of Resources 

Fire management activities under Alternative C would result in some mortality, but would 

greatly reduce threat of large, intense, wildland fire over the long run. This Alternative treats 

3,500 acres per year. Short-term impacts related to project activity would restore more natural 

forest conditions and have long-term benefits to ecosystem preservation. Prescribed fires may 

escape to become wildland fires. However, this risk is offset by the reduced risk of wildland fire 

ignition and high severity wildland fires when projects are completed. 

Irreversible/Irretrievable Commitments of Resources 

No irreversible/irretrievable commitments of resources would occur under Alternative C. 

Unavoidable Adverse Impacts 

Some native vegetation would be removed to reduce fuel levels and suppress wildland fires and 

some associated wildlife would be adversely impacted. Mitigation measures would minimize any 

impacts to both vegetation and wildlife. Mitigation measures would minimize exotic plant 

species introduction and expansion, however, some adverse impact would still occur. Expanded 

spring burning and natural resource prescribed burning could result in decreased reproduction of 

herbaceous species, depending on plant stage of development, phenology, and timing. However, 

altering the timing of the burn to increase native species as research is conducted would mitigate 

these impacts. 
412 

 

CHAPTER 5: 

CONSULTATION AND 

COORDINATION 
413 

PUBLIC INVOLVEMENT AND SCOPING

During a series of scoping meetings, the NPS requested input from the public, from federal, 

state, and local agencies, and from park resource specialists on fire management concerns, the 

types of issues that should be addressed in the EIS, and the range of fire management alternative 

strategies that should be considered. 

On January 27, 2000, a “Notice of Scoping for Fire Management Plan at Point Reyes National 

Seashore” was published in the Federal Register. On January 29, 2000, at a public meeting of 

the Point Reyes National Seashore Citizen Advisory Commission, a presentation was given 

announcing the scoping period for the plan. Scoping comments were solicited from January 27, 

2000 to March 28, 2000. 

In addition to the Federal Register Notice, the scoping period was publicized through a mass 

mailing to the public that included background information on the FMP and a notice of a scoping 

workshop held March 9, 2000. Notices posted in the communities surrounding the park and a 

notice in the local weekly newspaper, the Point Reyes Light, also advertised the workshop. The 

two-hour March 9 public scoping workshop was attended by five citizens. 

On February 14, 2000 and on February 22, 2000, internal scoping sessions were conducted to 

identify staff issues and concerns. These meetings were attended by an interdisciplinary group 

of resource and fire specialists from the PRNS and GGNRA staff. 

On March 28, 2000, a two-hour scoping session was held for local fire agencies. In addition to 

representatives of the NPS Fire Management Office, members of the Marin County Fire 

Department, Inverness Volunteer Fire Department, California State Parks, and Marin Municipal 

Water District were in attendance. Also invited, but not attending, were the Marin County Open 

Space District, Bolinas Fire Protection District, Nicasio Volunteer Fire Department, and Stinson 

Beach Fire Department. 

In spring of 2001, the NPS conducted a two-hour meeting to provide an overview to the Marin 

County Fire Department of the preliminary alternatives, and consulted on possible changes 

and/or modifications. 

The draft EIS for the Fire Management Plan was released for public comment on February 20, 

2004. The comment period closed April 20, 2004. Seven written comment letters were 

received; they are addressed below. 

The Federated Indians of Graton Rancheria have been consulted for compliance with the Native 

American Graves Protection and Repatriation Act. 

COMPLIANCE STATUS 

Documentation of NPS compliance with federal and state laws and regulations is incorporated 

into the text of the FEIS. Compliance with the nine major federal laws, executive orders, and 

associated state regulations is summarized here. 
414 

National Environmental Policy Act (NEPA) of 1970. PL 91-190, 83 Stat. 852, 42 USC §4341 et 

seq. The Final EIS provides disclosure of the planning and potential environmental consequences 

of the proposed action and alternatives, as required by NEPA. All substantive comments 

received on the draft EIS are responded to in this final EIS. In addition, an alternative is 

identified as preferred. A record of decision will be published 30 days following publication of 

the final plan and environmental impact statement. It will identify the selected alternative, which, 

barring unforseen circumstances, will be the same as the preferred alternative in the final EIS 

(Alternative C). At that time, the selected alternative will be implemented. 

Endangered Species Act of 1973, as amended, PL 93-205, 87 Stat. 884, 16 USC §1531 et seq. 

The Endangered Species Act protects threatened and endangered species, as listed by the U.S. 

Fish and Wildlife Service, from unauthorized take, and directs federal agencies to ensure that 

their actions do not jeopardize the continued existence of such species. Section 7 of the act 

defines federal agency responsibilities for consultation with the U.S. Fish and Wildlife Service 

and National Marine Fisheries Service (for fish) and requires preparation of a Biological 

Assessment to identify any threatened or endangered species that is likely to be affected by the 

proposed action. The National Park Service initiated consultation on February 9, 2001 and 

continues consultation with the U.S. Fish and Wildlife Service and the National Marine Fisheries 

Service. See Appendix D for biological opinion from the USFWS. 

Archeological Resources Protection Act of 1979, PL 96-95, 93 Stat. 712, 16 USC §470aa et seq. 

and 43 CFR 7, subparts A and B, 36 CFR. This act secures the protection of archeological 

resources on public or Indian lands and fosters increased cooperation and exchange of 

information between private, government, and the professional community in order to facilitate 

the enforcement and education of present and future generations. It regulates excavation and 

collection on public and Indian lands. It requires notification of Indian tribes who may consider a 

site of religious or cultural importance prior to issuing a permit. The NPS will meet its 

obligations under this Act in all activities conducted in the Fire Management Plan. 

National Historic Preservation Act of 1966, as amended, PL 89-665, 80 Stat. 915, 16 USC §470 

et seq. and 36 CFR 18, 60, 61, 63, 68, 79, 800. The National Historic Preservation Act requires 

agencies to take into account the effects of their actions on properties listed in or eligible for 

listing in the National Register of Historic Places. The Advisory Council on Historic 

Preservation has developed implementing regulations (36 CFR 800), which allow agencies to 

develop agreements for consideration of these historic properties. The NPS, in consultation with 

the Advisory Council, the California State Historic Preservation Officer (SHPO), American 

Indian tribes, and the public has developed a Programmatic Agreement for operations and 

maintenance activities on historic structures. This Programmatic Agreement provides a process 

for compliance with National Historic Preservation Act, and includes stipulations for 

identification, evaluation, treatment, and mitigation of adverse effects for actions affecting 

historic properties. The NPS sent a scoping notice to the state historic preservation officer and 

the Advisory Council for Historic Preservation to initiated consultation. Consultation will 

continue throughout the planning process. 
415 

American Indian Religious Freedom Act, PL 95-341, 92 Stat. 469, 42 USC §1996. This act 

declares policy to protect and preserve the inherent and constitutional right of the American 

Indian, Eskimo, Aleut, and Native Hawaiian people to believe, express, and exercise their 

traditional religions. It provides that religious concerns should be accommodated or addressed 

under NEPA or other appropriate statutes. The National Park Service, as a matter of policy, will 

be as nonrestrictive in permitting Native American access to and use of an identified traditional 

sacred resource for traditional ceremonies. 

Executive Order 11988: Floodplain Management. This Executive Order requires federal agencies 

to avoid, to the extent possible, adverse impacts associated with the occupancy and modification 

of floodplains, and to avoid development in floodplains whenever there is a practical alternative. 

If a proposed action is found to be in the applicable regulatory floodplain, the agency shall 

prepare a floodplain assessment, known as a Statement of Findings. All of the actions proposed 

in the Fire Management Plan are consistent with this executive order. 

Executive Order 11990: Protection of Wetlands. This Executive Order established the protection 

of wetlands and riparian systems as the official policy of the federal government. It requires all 

federal agencies to consider wetland protection as an important part of their policies and take 

action to minimize the destruction, loss or degradation of wetlands, and to preserve and enhance 

the natural and beneficial values of wetlands. All of the actions proposed in the Fire Management 

Plan are consistent with this executive order 

Executive Order No. 13112: Invasive Species. This Executive Order prevents the introduction of 

invasive species and directs federal agencies to not authorize, fund, or carry out actions that it 

believes are likely to cause or promote the introduction or spread of invasive species. Actions 

proposed in the FEIS include measures to prevent the introduction and spread of invasive 

species. 

California Coastal Zone Management Act. This act protects coastal environments. While this act 

transferred regulatory authority to the States and excluded federal installations from the 

definition of the “coastal zone,” it requires that federal actions be consistent with state coastal 

management plans. Activities taking place within the coastal zone under the definition 

established by the California Coastal Management Plan require a federal consistency 

determination. The FEIS will be submitted to the Coastal Commission for federal consistency 

determination. 
416 

LIST OF PREPARERS 

Dawn Adams, Inventory and Monitoring Coordinator, BS, General Biology, University of 

Illinois. 

Barbara Moritsch, Plant Ecologist; BS, Resource Planning and Interpretation, Humboldt State 

University; MS, Environmental Science, Oregon State University. 

Natalie Gates, Wildlife Biologist; BA, Biology, Harvard University; DVM Cornell University; 

MS, Environmental Science and Policy, University of California, Berkeley Campus. 

Sarah Allen, Ph.D, Science Advisor, University of California, Berkeley Campus, MS at 

University of California, Berkeley Campus; BS, Conservation of Natural Resources, University 

of California, Berkeley Campus. 

Don Neubacher, Superintendent; BS, Environmental Planning, University of California, Davis 

Campus; MS Resource Management, Humboldt State University. 

Brannon Ketcham, Hydrologist, BA, Geology, Ponoma College; MEM, Water Resources 

Management, Duke University. 

Wendy Poinsot, Environmental Planner, BA, Park History, Colorado State University. 

Roger Wong, Fire Management Specialist, BS, Forestry, University of California, Berkeley. 

Gary Fellers, Ph.D, Research Scientist, US Geological Services, Biological Resources Division. 

Gordon White, Historical Architect, MA, Architecture, University of California, Berkeley. 

Jane Rodgers, Plant Ecologist, BS, Forestry, University of California, Berkeley. 

LIST OF CONSULTANTS 

URS: Jeremy Rowlands, Air Quality 

Chris Johnson, Air Quality 

Heidi West, Ph.D., Total Quality NEPA 

PARTICIPATING GOVERNMENTAL AGENCIES 

List of Agencies and Organizations to Whom Copies or Notice of the Final Environmental 

Impact Statement have been Sent 

Federal Agencies 

U. S. Army Corps of Engineers 
417 

U. S. Coast Guard 

U. S. Department of Commerce National Oceanic and Atmospheric Administration 

U. S. Geological Service 

U. S. Fish and Wildlife Service 

U. S. Natural Resources Conservation Service 

U. S. National Marine Fisheries 

Federal Advisory Groups 

Advisory Council for Historic Preservation 

Elected Officials 

California State Assemblyperson Joe Nation 

California State Senator John Burton 

Marin County Supervisor Steve Kinsey 

U. S. Representative Lynn Woolsey 

U. S. Senator Barbara Boxer 

U. S. Senator Dianne Feinstein 

State Agencies 

Bay Area Air Quality Management District 

Bodega Marine Lab 

California Coastal Commission 

State of California Department of Environmental Science 

State of California Department of Fish and Game 

State of California Department of Parks and Recreation 

State of California Department of Transportation 

State of California Office of Planning and Resources State Clearinghouse 

State Historic Preservation Office 

University of California, Berkeley 

University of California Cooperative Extension 

Regional, County, and Municipal Agencies 

Bolinas Fire Department 

Bolinas Community Public Utility District 

Inverness Fire Department 

Marin Humane Society 

Marin County Community Development Agency 

Marin County Fire Department 

Marin County Open Space 

Marin County Planning and Acquisition 

Marin County Sheriff’s Department 

Marin County Resource Conservation District 

Marin Municipal Water District 

Nicasio Fire Department 

San Francisco Regional Water Quality Control Board 

Sonoma County Agriculture Preservation and Open Space District 
418 

Sonoma County Water Agency 

Non-Governmental Organizations, Non-Profit Organizations, etc. 

Animal Protection Institute 

Audubon Canyon Ranch & Cypress Grove Preserve 

Bay Area Ridge Trail Council 

Bay Institute 

Bayrose Morgans 

Bicycle Trails Council 

Bolinas Community Parks Planning 

California Native Plant Society 

Coastwalk 

Committee for the Preservation of Tule Elk 

Defenders of Wildlife 

East Shore Planning Group 

Environmental Action Committee of West Marin 

Environmental Forum of Marin 

Federated Indians of Graton Rancheria 

Friends of the Estero 

Gardener’s Guild 

In Defense of Animals 

Inverness Association 

Inverness Ridge Association 

Marin Agricultural Land Trust 

Marin Audubon Society 

Marin Conservation League 

Marin County Farm Bureau 

Marin Horse Council 

Mow Our Weeds 

National Parks and Conservation Association 

National Trust for Historic Preservation 

North American Trail Ride Conference 

Point Reyes Bird Observatory 

Point Reyes Light 

Point Reyes Village Association 

Preserve Historic Olema Valley 

Sierra Club, Marin Group 

Sonoma Horse Council 

Sonoma County Farm Bureau 

Sustainable Conservation 

Tomales Bay Advisory Committee 

Trout Unlimited 

Trust for Public Lands 

Vedanta Society 

Waste Watch 

West Marin Chamber of Commerce 
419 

West Marin Community Radio 

West Marin Paths 

Wilderness Society 

Libraries 

Bolinas Library 

Inverness Library 

Marin County Library 

Point Reyes Library 

Stinson Beach Library 

Marin County Civic Center Library 

San Francisco Main Public Library 
420 

COMMENTS RECEIVED AND NPS RESPONSES TO 

COMMENTS 

I. Introduction 

In accordance with the National Environmental Policy Act (NEPA) and National Park Service 

(NPS) policy on compliance with NEPA, all substantive comments received during the 60-day 

public comment period for the Point Reyes National Seashore Fire Management Plan, 

Environmental Impact Statement (EIS), were considered and responded during the preparation of 

this Final EIS. Substantive comments are generally defined as those that raise, debate or 

question, within a reasonable basis, the accuracy of the information presented or adequacy of the 

range of alternatives or assessment conducted. Other comments received, such as those that 

focus on agency policy, express a preference for an alternative or address issues beyond the 

scope of fire management planning at Point Reyes National Seashore (PRNS) are noted without 

specific response. 

A notice of availability for the Draft EIS was published in the federal register and the document 

made available for public review on February 20,2004. The 60-day public comment period 

ended on April 20, 2004. A public workshop to provide information to the public on the Draft 

EIS was held at the Red Barn meeting room at PRNS on the evening of March 18,2004. No 

verbatim recording of the discussion at the meeting was made in order to allow an informal 

question and answer format, which is difficult to transcribe. NPS staff gave a presentation on fire 

management planning actions at PRNS and more specifically on the proposed alternatives 

presented in the Draft EIS. The presentation was followed by an open question and answer 

period with the public. The public was encouraged to submit comments on the FMP Draft EIS to 

NPS offices at PRNS by email, fax or regular mail. 

The FEIS will be mailed to the same distribution list as the DEIS. Both the DEIS and this FEIS 

will be available on the PRNS website at: www.nps.gov/pore/pphtml/documents.html. 

This section of the Final EIS is structured as follows: 

I. Introduction 

II. Comment Letters. Seven comment letters on the Draft EIS were received. Each 

letter is numbered, as is each specific comment within the letter. The markup on 

the letters in this chapter should be used as an index to find the appropriate 

response to that comment in Chapter III. 

III. Comments Received and Response to Comments. Responses are presented for

substantive comments. Solely to facilitate the matching of comments and 

responses between the two chapters, each specific comment is presented in a brief 

paraphrase. The full comment can be referenced in Chapter II. Any changes 

needed to Draft EIS text based on the specific comment are noted in the response 

with underline marking new text and strikeout noting deleted text. 
421 

II. Comment Received and Response to Comments 

[Note: Changes to be made to Draft EIS text are presented as strikeout for removed text 

and underline for new or replacement text.] 

Comment Letter 1. United States Environmental Protection Agency, San Francisco, CA. 

Lisa B. Hanf, Manager, Federal Activities Office. 
422 

Comment 1-1. In light of exceedences of levels of total dissolved solids (TSS) noted in the 

DEIS for PRNS watershed, the US EPA recommends that NPS work closely with the RWQCB 

and develop specific management measures to offset potential effects of fire management actions 

and to improve water quality overall. 

Response to Comment I- I. The NPS is working in conjunction with the RWQCB, and in 

partnership with ranchers leasing lands within PRNS, to implement agricultural improvements 

aimed at reducing impacts on water quality. The park and leaseholders have developed several 

initiatives to reduce the levels of TSS and other pollutants and correct source areas for erosion on 

the ranchlands. Examples of these initiatives include the McClure diary barn, funded entirely by 

the leaseholder, which will house their herd during the winter, permitting their removal from 

several open pastures during rainy season. On this and other ranches, PRNS has fenced cattle out 

of creek channels, seasonal drainages and wetlands. On the Stewart Ranch, a grassed buffer strip 

was construction between high use horse pens and Olema Creek to filter out sediment from 

runoff. Sediment basins were constructed at the Nunes and Giacomini Ranches to trap runoff 

from the concentrated use areas of the ranches and avoid deposition of the runoff into creeks and 

drainages. 

Comment 1-2. US EPA recommends that the NPS work with RWQCB to assure that FMP 

actions not only offset potential project affects but work to improve water quality in the Tomales 

Bay, Lagunitas Creek and Walker Creek watersheds. The NPS should assure that prescribed burn 

plans remain consistent with the Total Maximum Daily Level (TMDL) implementation plans 

currently being developed. 

Response to Comment 1-2. Mitigation measures to protect water quality and water resources are 

listed in the Draft EIS on pages 57-58. Measure W-1 calls for a review of the erosion control 

plan for each prescribed burn. In response to Comment 1-2, the following text change will be 

made to Mitigation Measure W- 1 in the Final EIS: 

W-1. Individual burn plans will would be written with enough detail to determine the extent of 

erosion within the burn area due to a) the prescribed burn and/or, b) mechanical treatments. 

Subject matter experts will would determine if the erosion control plan submitted is sufficient to 

prevent long-term moderate or major impacts to the water resources and water quality and will 

assure project compliance with the TDML implementation plans for Tomales Bay, Lagunitas 

Creek and Walker Creek, according to availability through adoption by the EPA. Strategies to 

minimize erosion and sediment transport to water resources associated with prescribed burning 

include avoiding overly steep slopes, timing burns to minimize erosion potential, or using 

erosion control devices after bums. Strategies to minimize erosion and sediment transport to 

water resources associated with mechanical treatment include avoiding overly steep slopes, 

avoiding scraping or clearing to bare mineral soil (leave duff layer), or installing erosion control 

devices as part of mechanical treatment (if necessary).
423 
424 

Comment 1-3. US EPA recommends that the biological opinion from the US Fish and Wildlife 

Service for the PRNS FMP be included in the FEIS. 

Response to Comment 1-3. The biological opinions received from the US Fish and Wildlife 

Service and the National Oceanic and Atmospheric Administration on the FMP are included in 

this Final EIS. The biological opinions present the conclusions of these agencies on the potential 

affect of the FMP on species listed by the federal government under the Endangered Species Act. 
425 

Comment Letter 2. Bay Area Air Quality Management District, San Francisco. Jack 

Broadbent, Executive Officer/APCO. 
426 

Comment 2-1. Please revise Draft EIS text on page 31 to conform with BAAQMD Regulation 5

which does not allow the movement of vegetation debris to a central location for pile burning 

unless approved by the Air Pollution Control Officer. 

Response to Comment 2-1. Draft EIS text on page 31 is revised as follows in the Final EIS: 

“Tools used for these tasks include weed-whackers, chain saws, pole saws, and a chipper 

towed to the site by a truck. Vegetation debris can be cut up and broadcast in the 

immediate area, or piled and bumed. Debris that is not broadcast on site is chipped and 

hauled to Beebe Ranch and stockpiled. In accordance with BAAQMD Regulation 5,

debris piles are burned at could only be burned at Beebe Ranch with the approval of the 

Air Pollution Control Officer. Chipped material is not burned.” 

Comment 2-2. Please revise Draft EIS text on page 34 to include reporting wildland fires to 

BAAQMD. 

Response to Comment 2-2. Draft EIS text on page 34 is revised as follows in Final EIS: 

“In the event of wildland fire, the P/FIO would work closely with visiting FIOs who may 

be part of Incident Management Teams to assure the park message is delivered accurately 

and effectively. Wildland fires will also be reported to the BAAQMD as soon as possible. 

Media and public queries would receive prompt replies and would contain information 

about the fire, the fire management plan, and ecosystem restoration as appropriate.” 

Comment 2-3. Please revise Draft EIS text on pages 36 to 37 and page 177 to reflect BAAQMD 

approval procedures for prescribed bums and correct that all prescribed bums require BAAQMD 

approval and submittal of a bum plan. 

Response to Comment 2-3. Draft EIS text on pages 36-37 is revised as follows in Final EIS. 

Note that the order of some of the text has been changed. 

The bum plan is submitted to an outside expert, and both the expert and the park’s Fire 

Management Officer provides a recommendation to the superintendent. After the burn plan is 

approved by the superintendent, an application for permission to conduct a prescribed bum is 

made to the BAAQMD. 

The bum plan estimates the percentage of the unit covered by different fuel types and of the tons 

of material to be burned. This information is fed into an air quality model for the bum, which is 

submitted as part of the application for approval submitted application to the Bay Area Air 

Quality Management District (BAAQMD). BAAQMD approval requires that the NPS submit a 

smoke management plan (SMP) and completed application materials for all prescribed bums at 

least 30 days prior to the proposed burn date. 

With the approval of the smoke management plan, the NPS begins final planning for the 

prescribed bum and the project site is prepped for the burn. To prepare for a burn in grassland 

habitat, a line is mowed around the perimeter of the burn by cutting grasses with either a weed 
427 

whacker, mower, or tractor. In shrub or forested habitats a fire line (approximately 18 to 24 

inches wide) is cut and cleared and vegetation density reduced as described above under the 

heading “Suppression of Unplanned Ignitions”. Whenever possible, roads and trails are used as 

fire lines to reduce the amount of line that must be created. A hose lay is set up along the burn 

perimeter no more than one week prior to the bum. If the bum is being conducted in non-native 

tree or shrub stands (e.g., Monterey pine or Scotch broom), the non-natives may be cut down or 

mowed and left in the burn unit to dry before burning. This increases mortality of the targeted 

non-native species. 

As the proposed burn day approaches, NPS staff contact BAAOMD’s Meteorology and Data

Analysis section which provides forecasting services to assist with tentative scheduling of 

prescribed bums. The MDA section will provide 96-hour, 72-hour, 48-hour and 24-hour 

forecasts and a 24-hour confidence level of receiving the final approval on the day of the burn 

itself. The NPS telephones BAAQMD between 8:30 a.m. and 1:30 p.m. on the burn day to 

receive final approval and an acreage burning allocation for that day. BAAQMD requires 

verification that the meteorological conditions fall within the range described in the SMP. On the 

day of the prescribed fire, The BAAQMD makes a final decision based on wind and weather as 

to whether it would permit the burn. 

Prescribed fire personnel monitor the fire until dark or until the perimeter is secured. Personnel 

would stay on site overnight for burns in forested habitats. The burn area is patrolled the day 

after burning by walking the perimeter and doing any additional mop up activities required. As 

required by BAAOMD, the total acreage of burned vegetation is reported by telephone to them 

noon the day following the prescribed burn.” 

Revisions on Page 176, paragraph 4 in DEIS. 

“San Francisco Bay Area Air Quality Management District (BAAQMD). BAAQMD is the air 

quality management district for the project area and has primary responsibility for control of air 

pollution from prescribed burning. BAAQMD has procedures that must be followed prior to 

implementation of a prescribed bum plan. For all prescribed fire, fires less than 100 acres, 

BAAQMD requires that burns be conducted on an “allowable burn day” unless the district has 

granted a variance I advance. Notice of an allowable burn day is posted by the BAAQMD each 

afternoon for burns planned for the following day. Following the burn, the fire agency must 

submit information on the fuel types burned to BAAQMD. Burns 100 acres or larger in size

BAAQMD requires submission of the individual bum plan to the BAAQMD at least one month 

prior to the proposed bum. BAAQMD then issues a forecast 72 hours prior to the proposed date 

and gives a final commitment to permit the burn on the day of the bum itself though forecasts 

with increasing confidence can be obtained at 96-hours, 72-hours, 48-hours and 24-hours prior to 

the burn day to support moving forward on all the logistical planning needed to conduct a 

prescribed burn. 48 hours prior to the date allowing flexibility in planning needed for larger 

burns.”
428 
429 

Comment 2-4. Burning in wetlands requires conformance with BAAQMD Regulation 5,

Sections 40 1.13 and 410 which describe marsh management fire requirements. 

Response to Comment 2-4. The following additional text will be inserted as a new paragraph in 

the Final EIS on page 298, paragraph 1, Prescribed Fire. 

Burn plans that include prescribed burning in wetland areas are subject to the conformance with 

additional regulations when applying to BAAQMD. In addition to the SMP and other submittals,

Regulation 5, Section 410, Marsh Management Burn Requirements, asks for an evaluation of 

non-burning alternatives that could achieve land management objectives in keeping with 

resource management plans that apply to the project area. Regulation 5, Section 401.13 includes 

more detailed guidance for planning prescribed burns that involve wetland acreage.

Comment 2-5. Table 37 does not reflect current attainment status. 

Response to Comment 2-5. Table 37 is revised as requested.

California Standards1 National Standards2

Pollutant Averaging 

Time Concentration Attainment 

Status Concentration3 Attainment 

Status 

 8 hour 0.08 ppm N

Ozone 

(O3

) 1 hour 0.09 ppm (180 

μg/m3

) N 0.l2 ppm (235 

μg/m3

) N4

Comment 2-6. More detail is needed on how the preferred alternative’s impacts on regional haze 

can be mitigated. 

Response to Comment 2-6. Mitigation measures that address the impacts of the preferred 

alternative on regional haze are found on DEIS pages 56 and 57, particularly measures A-1, A-2, 

A-5, A-6 and A-7 and are included in the Final EIS. 

Comment 2-7. Please provide estimates on the number of burn days per year and the associated 

amount of daily emissions in tons per day. 

Response to Comment 2-7. The Point Reyes National Seashore Fire Management Officer, 

Roger Wong, has provided a per event breakdown of the annual estimated emissions listed in the 

FMP EIS. 

Daily Emissions for FMP Alternatives 

(all emission levels given in tons per burn day) 

Alternative Acres treated Burn Days per year PM10 PM2.5 Methane CO NOx

Alternative A 500 acres 10 total burn days 

Grass scrub 495 acres 9 2.3 2.0 0.6 5.1 0.1 

Understory 5 acres 1 2.9 2.4 1.4 28.3 0.8 

Alternative B 1000 acres 20 total burn days 

Grass scrub 849 acres 15 2.5 2.0 0.6 5.1 0.1 

Understory 153 acres 5 17.5 15.0 8.4 173.3 5.0 
430 

Alternative C 2000 acres 35 total burn days 

Grass scrub 1,724 acres 20 3.9 3.3 1.0 8.2 0.2 

Understory 276 acres 15 10.5 8.9 5.0 104.2 3.0 

The annual maximum acreages of prescribed burning were developed with the assumption that 

the program described in the alternative would be implemented with optimum funding and 

staffing to support this level of activity from an operational stand point. For purposes of these 

emission estimates, “per event” should be considered equivalent to “per day”. If, subsequent to 

the NEPA process, the park does not receive optimum funding for implementation of the FMP, 

the amount of acreage treated annually could be considerably less than proposed in the EIS. 

With that possibility acknowledged, the emissions presented in the EIS may overstate emissions 

generated as the FMP is implemented. 

Comment 2-8. Please provide information on the monitoring site where IMPROVE data cited on 

page 174 was collected. 

Response to Comment 2-8. Air quality monitoring at Point Reyes National Seashore has 

included particulate matter (PM2.5 and PM10), hourly ozone, and SO2 (see Table VII-3 below). 

The aerosol sampler in the park began operation in March of 1988. It is located at the North 

District Ranger Station, south of Tomales Bay State Park and north of Point Reyes Hill in the 

Inverness Ridge FMU. The location of the aerosol sampler is shown in Figure VII-3 excerpted 

from Assessment of Air Quality and Air Pollutant Impacts in Class I National Parks of California 

(April 2001). The status of Point Reyes air quality is Chapter VII of the full report which can be 

found on the NPS Air Quality website at: 

http://www2.nature.nps.gov/air/Pubs/CAreview/CAreport.pdf. The automatic 35mm camera was 

located on a peninsula at the south-west comer of Drakes Bay and operated from June 1987 

through April 1995. The camera viewed east across Drakes Bay towards the Point Reyes 

Wilderness area.

Table VII-3. Air quality monitoring at PORE 

Species Site within park Site within 50 km

Ozone, hourly NPS** 

Ozone, passive NPS* 

SO2 NPS 

PM10 IMPROVE 

PM2.5 IMPROVE 

Wet deposition ARB** 

Dry deposition 

Visibility 

* New site 

** Closed before 1994 
431 
432 
433 

Comment Letter 3. State Clearinghouse and Planning Unit, Sacramento, CA. Terry 

Roberts, Director. 
434 

The letter received from the State Clearinghouse states that no comments were received from the 

list of state agencies that received a copy of the FMP/EIS by the close of the commenting period 

on April 20,2004. The Clearinghouse also notes that the PRNS FMP/EIS has complied with the 

review requirements of the California Environmental Quality Act (CEQA) for environmental 

documents. 

Response to Letter 3. No response required. 
435 

Comment Letter 4: Board of the Inverness Ridge Association, Inverness, CA. Anthony 

Prud’homme, Director.
436 

Comment 4-1. The Inverness Ridge Association supports Alternative C, the preferred alternative 

of the NPS. Alternative C has three advantages: 

a) Permits fuel reduction on a greater amount of acres, thereby proceeding in the 

reduction of hazardous fuels at a more rapid rate and allows Bishop pine regrowth stands 

to be thinned while still small. 

b) Allows for more fuel reduction along the Inverness Ridge 

Trail, and 

c) The accelerated pace permitted under Alternative C allows 

the NPS and adjacent 

WUI communities to benefit from the current availability of federal funding for fire 

hazard reduction programs. 

Response to Comment 4-1. Comment and preference noted. 
437 
438 

Comment 4-2. The membership of Inverness Ridge Association would like the opportunity to be 

apprised of the availability of email notification lists for prescribed burning. 

Response to Comment 4-2. The Education Specialist for the Fire Program will continue to 

advertise the availability of the NPS email notification list notifying residents of upcoming fire 

management activities that could affect the local community, including the Inverness Ridge 

Association and other local homeowners’ groups.
439 

Comment Letter 5. Susan and John Van Der Wal, Inverness, CA. 
440 

Comment 5-1. Fire management actions will generate smoke, a health hazard, and increase 

noise from ground equipment and aircraft used in fire response. 

Response to Comment 5-1. Prescribed burning does generate smoke but under conditions 

meeting the criteria of the Bay Area Air Quality Management District. Smoke generation is a 

short-term impact, lasting the duration of active prescribed fire and is localized in effects. Smoke 

generation would have greatest effects when prescribed burning is conducted in close proximity 

to residential areas. The primary residential areas adjacent to park lands are the Bolinas mesa and 

Paradise Ranch Estates. The BAAQMD requires a Smoke Management Plan for all prescribed 

fire as a means to assess potential affects of the fire on air basin air quality and potential health 

effects of smoke on adjacent residents. In conformance with BAAQMD requirements, the SMP 

includes the following project information: 

• location and specific objectives of each proposed bum; 

• acreage, tonnage, type, and arrangement of vegetation to be burned; 

• directions and distances to nearby sensitive receptor areas; 

• fuel condition, combustion and meteorological prescription elements for the project; 

• projected bum schedule and expected duration of project ignition, combustion, and bum 

down 

• (hours or days); 

• specifications for monitoring and of verifying critical parameters including 

meteorological 

• conditions and smoke behavior before and during the bum; 

• specifications for disseminating project information to public; 

• contingency actions that will be taken during the burn to reduce exposure if smoke 

intrusions impact any sensitive receptor area; 

• certification by a qualified professional resource ecologist, biologist, or forester that the 

proposed burning is necessary to achieve the specific management objective(s) of the 

plan; 

• a copy of the environmental impact analysis prepared for the plan that includes an 

evaluation of alternatives to burning, if such an analysis was required by state or federal 

law or statute; 

• project fuel loading estimate (tons vegetation/acre) by vegetation type(s) and a 

description of thecalculation method; and 

• particulate matter emissions estimate including referenced emission factor(s) and a 

description of the calculation method used. (BAAQMD, Regulation 5, Open Burning, 

Section 408). 

The Draft EIS addressed the impacts of smoke on air quality and on human health on pages 232, 

and 395-396 (Alternative A), pages 236 and 398 (Alternative B) and pages 240 and 400 

(Alternative C). Impacts from increased noise generated by heavy equipment and chainsaws, 

particularly during suppression actions is addressed on page 380-384 (Alternative A), 385-386 

(Alternative B) and 387-389 (Alternative C). The FMP does not propose use of aircraft. Noise 

generation from aircraft would occur as part of wildfire suppression actions that could occur with 
441 

or without the FMP and is not an effect of the FMP. 

Comment 5-2. Prescribed burning will leave areas looking unsightly until the rains. 

Response to Comment 5-2. The assessment is accurate. Given the potential for a large-scale 

wildfire to drastically alter the park setting, prescribed burning resulting in scattered areas of 

blackened acreage that revegetates quickly would be preferable to the effects of hotter, more 

damaging wildfire that would burn indiscriminately altering sensitive viewsheds. Areas subject 

to prescribed fire would appear blackened until regrowth occurs with winter rains. These shortterm, moderate, adverse impacts are described for the three alternatives on pages 380-381 

(Alternative A), page 385 (Alternative B) and page 387 (Alternative C). 

Comment 5-3. Removing non-native vegetation will eliminate shade for humans and animals 

alike, remove screening understory vegetation and valuable habitat provided by the understory. 

Response to Comment 5-3. As discussed in the Draft EIS, mechanical removal and prescribed 

burning of understory vegetation would have both adverse and beneficial short-term impacts on 

wildlife. Certain species, such as woodrats, may be attracted to temporarily stockpiled vegetation 

debris and displaced later during pile burning. Other wildlife species, such as deer, could benefit 

from improved foraging in clearings. In addition, the project actions themselves, involving 

vehicles and chainsaws among other equipment, would generate noise and locally disturb 

wildlife in the vicinity of projects over the short-term. Discussion of impacts of fire management 

actions on wildlife is addressed on pages 302 to 316. Impacts to special status wildlife species, in 

addition to special status plant species, are discussed on pages 323 through 368. 

Comment 5-4. Commenters are not in favor of experimental pilot burns; reducing understory 

brush takes away individual privacy. The potential fire hazard has been exaggerated. 

Response to Comment 5-4. As described on Draft EIS pages 87-89, recurring wildfires are part 

of the ecology of the Point Reyes peninsula. It’s true that the degree of fire hazard varies 

throughout the year, but the Vision Fire and other conflagrations in the Bay Area have shown 

that extreme fire hazard conditions can develop in late summer and early fall. 
442 
443 

Comment 5-5. Commenters are concerned about the exact location of areas where disturbance 

would occur such as staging areas and fire lines around prescription burns. 

Response to Comment 5-5. The FMP has a broad focus and does not identify the location of 

specific projects but rather ways to mitigate the effects of specific future projects by reducing the 

level of affect on soils, vegetation and viewshed by careful siting. For example, on Draft EIS 

page 58, under Mitigation Measure W-3, helispots, staging areas, and spike camps would be 

located at least 100 feet away from streams, creeks, and other water bodies. Measure V-1 

requires that existing roads or trails be used as firebreaks for prescribed burns and for wildland 

fire suppression whenever possible in order to reduce disturbance, vegetation removal and 

aesthetics effects. Additional measures to rehabilitate lands disturbed by project actions are 

found on pages 55 through 59. All specific projects would be assessed for conformance with the 

guidelines and mitigation measures described in the Draft EIS. 

Comment 5-6. The FMP DEIS should consider the affects of fire management actions on nearby 

residential communities as well as the visitor experience. 

Response to Comment 5-6. Both the Draft and Final FMP addresses the effects of fire 

management actions on residential neighborhoods as part of the air quality assessment (localized 

smoke effects), impacts to visitor use and visitor experience (noise and visual effects) and public 

health and safety (smoke inhalation). 

Comment 5-7. The Commenters prefer Alternative A; annual acreage amounts under 

Alternatives B and C are too large. 

Response to Comment 5-7. Comment and preference noted. 
444 

Comment Letter 6. Department of Commerce, National Oceanic and Atmospheric 

Administration, National Marine Fisheries Service. Rodney R. McInnis, Acting Regional 

Administrator 
445 

Comment 6-1. The National Marine Fisheries Service (NMFS) concurs that the project as 

proposed is not likely to adversely affect threatened fish species or adversely modified critical 

fish habitat. If the project plans change or new information on the listed species indicates a 

potential adverse effect, further consultation may be necessary. 

Response to Comment 6-1. The following text for mitigation measure SS-7 is added to the FMP 

Final EIS. 

SS-7 The annual work plan for FMP implementation will be provided to NOAA Fisheries each 

year to allow that agency to monitor the types of project proposed. 
446 
447 

Comment 6-2. NMFS administers section 305(b)(2) of the Magnuson-Stevens Fishery 

Conservation and Management Act requiring federal agencies to consult with NMFS regarding 

the potential of projects to adversely affect “essential fish habitat.” The project area is part of the 

EFH for Pacific Salmon. The FMP as proposed does not require conservation recommendations 

but if the proposed work plan is modified, PRNS will need to reinitiate consultation with NMFS. 

Response to Comment 6-2. See response to Comment 6-1.
448 

Comment Letter 7. Environmental Action Committee of West Marin. Catherine Caufield, 

Executive Director.
449 

Comment 7-1. Commenter expresses preference for the Preferred Alternative. 

Response to Comment 7-1. Comment and preference noted. 

Comment 7-2. Commenter recommends NPS coordinate fire management planning efforts with 

Tomales Bay State Park as outlined in the Draft TBSP General Plan. 

Response to Comment 7-2. Comment noted. The NPS has cooperated with Tomales Bay State 

Park through the federal Wildland Urban Interface Program and will continue to work 

cooperatively with State Parks to reduce fire hazards in West Marin. 
450 

 
451 

Appendix A: 

Glossary of Terms and 

Acronyms 
452 

NEPA TERMINOLOGY 

The controlling definitions for terms under CEQ’s NEPA regulations are contained at 40 

CFR. The numbers in parentheses refer to the appropriate section of 40 CFR. These definitions 

are provided as a supplement to those regulatory definitions. 

Categorical exclusion (CE) (1508.4)—An action with no measurable environmental 

impact which is described in one of the categorical exclusion lists in section 3-3 or 3-4 and for 

which no exceptional circumstances (section 3-5) exist. NPS also uses the acronym “CX” to 

denote a categorical exclusion. 

Connected actions (1508.25)—Actions that are closely related. They automatically 

trigger other actions that have environmental impacts, they cannot or will not proceed unless 

other actions have been taken previously or simultaneously, or they are interdependent parts of a 

larger action and/or depend on the larger action for their justification. 

Conservation planning and impact assessment—Within NPS, this process is synonymous 

with the NEPA process. This process evaluates alternative courses of action and impacts so that 

decisions are made in accord with the conservation and preservation mandate of the NPS 

Organic Act. 

Cooperating agency (1508.5)—A federal agency other than the one preparing the NEPA 

document (lead agency) that has jurisdiction over the proposal by virtue of law or special 

expertise and that has been deemed a cooperating agency by the lead agency. State or local 

governments, and/or Indian tribes, may be designated cooperating agencies as appropriate (see 

1508.5 and 1502.6). 

Cultural resources (NPS-28, Appendix A)—Aspects of a cultural system that are valued by or 

significantly representative of a culture or that contain significant information about a culture. A 

cultural resource may be a tangible entity or a cultural practice. Tangible cultural resources are 

categorized as districts, sites, buildings, structures, and objects for the National Register of 

Historic Places, and as archeological resources, cultural landscapes, structures, museum objects, 

and ethnographic resources for NPS management purposes. 

Cumulative actions (1508.25)—Actions that, when viewed with other actions in the past, the 

present, or the reasonably foreseeable future, regardless of who has undertaken or will undertake 

them, have an additive impact on the resource the proposal would affect. 

Cumulative impact (1508.7)—The impacts of cumulative actions. 

Direct effect (1508.8)—An impact that occurs as a result of the proposal or alternative in the 

same place and at the same time as the action. 

Environmental assessment (EA) (1508.9)—A brief NEPA document that is prepared to (a) help 

determine whether the impact of a proposal or alternatives could be significant; (b) aid NPS in 
453 

compliance with NEPA by evaluating a proposal that will have no significant impacts, but that 

may have measurable adverse impacts; or (c) evaluate a proposal that either is not described on 

the list of categorically excluded actions, or is on the list but exceptional circumstances (section 

3-5) apply. 

Environmental impact statement (EIS) (1508.11)—A detailed NEPA document that is prepared 

when a proposal or alternatives have the potential for significant impact on the human 

environment. 

Environmental screening process—The analysis that precedes a determination of the appropriate 

level of NEPA documentation. The minimum requirements of the environmental screening 

process are a site visit, consultation with any agency that has jurisdiction by law or special 

expertise, and the completion of a screening checklist. The process must be complete for all NPS 

actions that have the potential for environmental impact and are not described in section 3-3. 

Environmentally preferred alternative (1505.2, Q6a)—Of the alternatives analyzed, the one that 

would best promote the policies in NEPA section 101. This is usually selected by the IDT 

members. It is presented in the NPS NEPA document (draft and final EIS or EA) for public 

review and comment. 

Exceptional circumstances—Circumstances that, if they apply to a project described in the NPS 

categorical exclusion lists (sections 3-3 and 3-4), mean a CE is inappropriate and an EA or an 

EIS must be prepared because the action may have measurable or significant impacts. 

Exceptional circumstances are described in section 3-5. 

Finding of no significant impact (FONSI) (1508.13)—A determination based on an EA and other 

factors in the public planning record for a proposal that, if implemented, would have no 

significant impact on the human environment. 

Human environment (1508.14)—Defined by CEQ as the natural and physical environment, and 

the relationship of people with that environment (1508.14). Although the socioeconomic 

environment receives less emphasis than the physical or natural environment in the CEQ 

regulations, NPS considers it to be an integral part of the human environment. 

Impact topics—Specific natural, cultural, or socioeconomic resources that would be affected by 

the proposed action or alternatives (including no action). The magnitude, duration, and timing of 

the effect to each of these resources is evaluated in the impact section of an EA or an EIS. 

Indirect impact (1508.8)—Reasonably foreseeable impacts that occur removed in time or space 

from the proposed action. These are “downstream” impacts, future impacts, or the impacts of 

reasonably expected connected actions (e.g., growth of an area after a highway to it is complete). 

Issues—In NEPA, issues are environmental, social, and economic problems or effects that may 

occur if the proposed action or alternatives (including no action) are implemented or continue to 

be implemented. 
454 

Lead agency (1508.16)—The agency either preparing or taking primary responsibility for 

preparing the NEPA document. 

Major federal action (1508.18)—Actions that have a large federal presence and that have the 

potential for significant impacts to the human environment. They include adopting policy, 

implementing rules or regulations; adopting plans, programs, or projects; ongoing activities; 

issuing permits; or financing projects completed by another entity. 

Memo to file—A memo to the planning record or statutory compliance file that NPS offices may 

complete when (a) NEPA has already been completed in site-specific detail for a proposal, 

usually as part of a document of larger scope, or (b) a time interval has passed since the NEPA 

document was approved, but information in that document is still accurate. 

Mitigated EA (Q40)—An EA that has been rewritten to incorporate mitigation into a proposal or 

to change a proposal to reduce impacts to below significance. 

Mitigation (1508.20)—A modification of the proposal or alternative that lessens the intensity of 

its impact on a particular resource. 

NEPA process—The objective analysis of a proposal to determine the degree of its 

environmental and interrelated social and economic impacts on the human environment, 

alternatives and mitigation that reduce that impact, and the full and candid presentation of the 

analysis to, and involvement of, the interested and affected public. 

Notices of availability—Separate notices submitted to the Federal Register that the draft EIS and 

the final EIS are ready for distribution. 

Notice of intent (1508.22)—The notice submitted to the Federal Register that an EIS will be 

prepared. It describes the proposed action and alternatives, identifies a contact person in NPS, 

and gives time, place, and descriptive details of the agency’s proposed scoping process. 

Preferred alternative (1502.14 (e))—The alternative an NPS decision-maker has identified as 

preferred at the draft EIS stage or EA. Identification of the preferred alternative helps the public 

focus its comments during review of the NEPA document. 

Programmatic documents—Broader scope EAs or EISs that describe the impacts of proposed 

policy changes, programs, or plans. 

Proposal (1508.23)—The stage at which NPS has a goal and is actively preparing to make a 

decision on one or more alternative means of accomplishing that goal. The goal can be a project, 

plan, policy, program, and so forth. NEPA begins when the effects can be meaningfully 

evaluated. 

Record of decision (ROD) (1505.2)—The document that is prepared to substantiate a decision 

based on an EIS. It includes a statement of the decision made, a detailed discussion of decision 

rationale, and the reasons for not adopting all mitigation measures analyzed, if applicable. 
455 

Scoping (1508.25)—Internal NPS decision-making on issues, alternatives, mitigation measures, 

the analysis boundary, appropriate level of documentation, lead and cooperating agency roles, 

available references and guidance, defining purpose and need, and so forth. External scoping is 

the early involvement of the interested and affected public. 

Tiering (1508.28)—The use of broader, programmatic NEPA documents to discuss and analyze 

cumulative regional impacts and define policy direction, and the incorporation by reference of 

this material in subsequent narrower NEPA documents to avoid duplication and focus on issues 

“ripe for decision” in each case. 

ACRONYMS 

CE Categorical exclusion 

CEF Categorical exclusion form 

CEQ President’s Council on Environmental Quality 

CX Categorical exclusion 

DEC Division Environmental Comment request issued by NPS Environmental Quality 

Division-WASO 

DM Departmental manual 

DOI Department of the Interior 

EA Environmental assessment 

ECM Environmental compliance memorandum 

EIS Environmental impact statement 

EO Executive order 

EPA Environmental Protection Agency 

ER Environmental Review issued by the Department of the Interior 

ERM Environmental review memorandum 

ESA Endangered Species Act 

ESM Environmental statement memorandum 

ESF Environmental screening form 

EQD Environmental Quality Division 

FONSI Finding of no significant impact 

GGNRA Golden Gate National Recreation Area 

GMP General management plan 

IDT Interdisciplinary team 

NEPA National Environmental Policy Act 

NHPA National Historic Preservation Act 

NMFS National Marine Fisheries Service (New name is NOAA Fisheries) 

NOA Notice of availability 

NOI Notice of intent 

NPS National Park Service 

PORE Point Reyes National Seashore 

REO Regional environmental officer 

ROD Record of decision 

SSO System support office 
456 

WASO Washington, D.C., Office of the National Park Service 

FIRE TERMS AND DEFINITIONS 

AFFIRMS. (Administrative and Forest Fire Information Retrieval and Management System): A 

user-oriented interactive computer program which permits entry of fire weather observations and 

fire weather forecasts and which computes danger indices. 

Backing fire. A prescribed fire or wildfire burning into or against the wind or down the slope 

without the aid of wind. 

BEHAVE. A refinement of the Fire Behavior Prediction System that allows development of 

customized fuel models that can access the Rothermel fire spread equation (Burgan and Rothermel 

1984). 

Blackline. Preburning of fuels, either adjacent to a control line before igniting a prescribed fire or 

along a roadway or boundary as a deterrent to human-caused fires. Blacklining is usually done in 

heavy fuels adjacent to a control line during periods of low fire danger to reduce pressure on 

holding forces; blackline denotes a condition in which there is no unburned fine fuel remaining. 

Burning index (BI). A relative number related to the contribution that fire behavior makes to the 

amount of effort needed to contain a fire in a specified fuel type. Doubling the BI indicates twice 

the effort will be required to contain a fire in that fuel type as was previously required providing all 

other parameters are held constant. 

Cold trail. Method of controlling a partly-dead fire edge by careful inspection and feeling with the 

hand to detect any fire and extinguishing it by digging out every live spot and trenching any live 

edge. 

Complex fire management program. A program involving prescribed burning, in addition to 

wildland fire suppression. 

Density. The number of individuals, usually by species, per unit area. 

Fire behavior. The response of fire to its environment of fuel, weather, and terrain including its 

ignition, spread, and development. 

Fire effects. Physical, biological, and ecological impacts of fire on the environment. 

Fire effects monitoring. A process that allows managers to evaluate whether environmental goals 

and objectives are being achieved and to adjust prescriptions to achieve a desired range of effects on 

the biotic and physical environment. Fire effects monitoring does not necessarily prove cause-andeffect associations. However, such monitoring will indicate if specific prescribed burn objectives 

were met and help management assess long-term change in these fire management areas. 
457 

Fire hazard. A fuel complex, defined by volume, type condition, arrangement, and location, that 

determines the degree of ease of ignition and of resistance to control. 

Fire intensity. A general term relating to the heat energy released in a fire. 

Fire resistance. A botanical adaptation that results in a lower probability of being injured or killed 

by fire. (e.g., thick platy or corky bark, or buds protected by long needles). 

Fire return interval. Length of time necessary for an area equal to the entire area of interest to burn; 

size of the area of interest must be clearly specified. 

Fire monitoring. The systematic process of collecting and recording fire-related data, particularly 

with regards to fuels, topography, weather, fire behavior, fire effects, smoke, and fire location. 

Fire weather. Weather conditions which influence fire ignition, behavior, and suppression. 

Fireline. Generally, any cleared or treated strip used to control a fire's spread; more specifically, 

that portion of a control line from which flammable materials have been removed by scraping or 

digging to mineral soil. 

Flame height. The average maximum vertical extension of flames at the leading edge of the fire 

front. Occasional flashes that rise above the general level of flames are not considered. This 

distance is less than the flame length if flames are tilted due to wind or slope. 

Flame length. The distance between the flame tip and the midpoint of the flame depth at the base of 

the flame (generally the ground surface); an indicator of fire intensity. 

Flammability. The relative ease with which a substance ignites and sustains combustion. 

Fuel. The materials which are burned in a fire: duff litter, grass dead branch wood, snags, logs, 

stumps, weeds, brush, foliage, and to a limited degree, green trees. 

Fuel break. Generally wide (10-1000 feet) strips of land on which native vegetation has been 

permanently modified so that fires burning into them can be more readily controlled. Some 

fuelbreaks contain firelines (e.g., roads, handlines) which can be quickly widened with hand tools or 

by burning out. 

Fuel loading. Amount of dead fuel present on a particular site a given time; the percentage of fuel 

available for combustion changes with the season. 

Fuel model. Simulated fuel complex for which all fuel descriptors required for the solution of a 

mathematical rate of spread model have been specified. 

Hazardous fuels. Fuels that, if ignited, could threaten park developments, human life and safety, 

natural resources, or carry fire across park boundaries. 
458 

Head fire. A fire front spreading or ignited to spread with the gradient (downwind or upslope). 

Human-caused fire. Any fire caused directly of indirectly by person(s). 

Mean Fire Interval. Arithmetic average of all fire intervals determined, in years in a designated 

area during a specified time period; size of the area and the time period must be specified. 

NFDRS. (National Fire Danger Rating System) Multiple index scheme designed to provide fire 

suppression and land management personnel with a systematic means of assessing various aspects 

of fire danger on a day-to-day basis. 

NIFQS. (National Interagency Fire Qualification System) Fire management qualifications systems 

which describes for a particular large fire suppression organization the acceptable standards for 

experience, training, and physical fitness required for principal jobs within the system. NIFQS, 

when coupled with a large fire suppression organization, provides a complete system for fire 

management. 

NIIMS. (National Interagency Incident Management System) Common command system designed 

to be used by any agency as a day-to-day operational procedure which can be expanded in scope to 

provide management for major single or multi-jurisdictional emergencies. 

Natural fire. Any fire of natural origin (e.g., lightning, spontaneous combustion, volcanic activity). 

Prescribed burning. The deliberate ignition of a fire in accordance with an established management 

plan to accomplish specific objectives under given prescriptions for weather and fuel conditions. 

Prescribed fire. The skillful application of fire to natural fuels under conditions of weather, fuel 

moisture, soil moisture, etc., that will allow confinement of the fire to a predetermined area and at 

the same time will produce the intensity of heat and rate of spread required to meet certain overall 

objectives in the areas of silviculture, wildlife management, grazing, hazard fuel reduction, etc. The 

overall objective of prescribed fire is to employ fire scientifically to realize maximum net benefits 

with minimum damage and acceptable cost. 

Presuppression. Activities undertaken in advance of fire occurrence to help ensure more effective 

fire suppression; includes over-all planning, recruitment and training of fire personnel, procurement 

and maintenance of firefighting equipment and supplies, fuel treatment, and creating, maintaining, 

and improving a system of fuelbreaks, roads, water sources, and control lines. 

Prevention. All activities concerned with minimizing the incidence of wildfires. 

Rate of spread. Relative activity of a fire in extending its horizontal dimensions, expressed as rate 

of increase of the perimeter, rate of increase in area, or rate of advance of its head, depending on the 

intended use of the information; generally in chains or acres per hour for a specific period in the 

fire's history. 
459 

Rehabilitation. The activities necessary to repair damage or disturbance caused by wildfire or the 

fire suppression activity. 

Smoke Management. Application of knowledge of fire behavior and meteorological processes to 

minimize degradation of air quality during prescribed fires. 

Smokechaser. Person whose principal function is fire suppression. 

Suppression. All actions intended to extinguish or limit the growth of fires, regardless of the 

strategies and tactics chosen. 

Timelag. Time necessary, under specified conditions, for a fuel particle to lose approximately 63% 

of the difference between its initial moisture content and its equilibrium moisture content. 

Providing conditions remain unchanged, a fuel will reach 95% of its equilibrium moisture content 

after 4 timelag periods. 

Urban/Wildland Interface. Line, area, or zone where structures and other human development 

meets or intermingles with undeveloped wildland or vegetation fuels. 

WIMS. (Weather Information Management System). This new computerized system will replace 

the current AFFIRMS program in 1992. 

Wet line. A line of water, or water and chemical retardant, sprayed along the ground, and which 

serves as a temporary control line from which to ignite or stop a low-intensity fire. 

Wildfire. Any fire occurring on wildland that is not meeting management objectives and thus 

requires a suppression response. 
460 
461 

Appendix B: 

List of Classified Structures 
462 

List of Classified Structures in Project Area 

 Struct. # LCS # Structure Name NR Status Significance 

Level 

Cond. Park 

1 BO1940 9234 Olema Lime Kilns Entered - 

Documented 

State Good PORE 

2 BO1945 56471 Randall Ranch Olema-Bolinas 

Road 

Undetermined Not Evaluated Fair PORE 

3 BO1950 56415 Hagmaier Ranch Main 

Residence 

Determined 

Eligible - SHPO 

State Good PORE 

4 BO1951 56416 Hagmaier Ranch Manager's 

House 

Determined 

Eligible - SHPO 

State Good PORE 

5 BO1952 56417 Hagmaier Ranch Old Milking 

Barn 

Determined 

Eligible - SHPO 

State Good PORE 

6 BO1953 56418 Hagmaier Ranch North Shed Determined 

Eligible - SHPO 

State Fair PORE 

7 BO1954 56419 Hagmaier Ranch South Shed Determined 

Eligible - SHPO 

State Fair PORE 

8 BO1980 9264 Teixeira Ranch Main House Determined 

Eligible - SHPO 

State Good PORE 

9 BO1981 9265 Teixeira Ranch Grade A Dairy Undetermined Local Good PORE 

10 BO1982 9266 Teixeira Ranch Original 

Milking Barn 

Determined 

Eligible - SHPO 

Local Fair PORE 

11 BO1983 22725 Teixeira Ranch Horse Barn Undetermined Local Fair PORE 

12 BO1984 22727 Teixeira Ranch Foot Bridge Undetermined Local Poor PORE 

13 BO1985 22728 Teixeira Ranch Bridge Undetermined Local Good PORE 

14 BO1986 22729 Teixeira Ranch Garage/Shed Undetermined Not Evaluated Fair PORE 

15 BO1987 22730 Teixeira Ranch Fuel Storage 

Shed 

Undetermined Not Evaluated Fair PORE 

16 BO1988 22711 Teixeira Ranch Stock Shed Undetermined Not Evaluated Fair PORE 

17 BO1989 56412 Teixeira Ranch Water Tank Undetermined Not Evaluated Fair PORE 

18 BO1990 56413 Teixeira Ranch Small Shed Undetermined Not Evaluated Fair PORE 

19 BO1991 56414 Teixeira Ranch Wood Shed Undetermined Not Evaluated Poor PORE 

20 BO2040 56475 Marconi Station Transmitter 

Building 

Undetermined Not Evaluated Fair PORE 

21 BO2041 56476 Marconi Station Hotel Undetermined Not Evaluated Good PORE 

22 BO2042 56477 Marconi Station Cottage #1 Undetermined Not Evaluated Good PORE 

23 BO2043 56478 Marconi Station Cottage #2 Undetermined Not Evaluated Good PORE 

24 BO2044 56479 Marconi Station Tennis Court Undetermined Not Evaluated Fair PORE 

25 BO2045 56480 Marconi Station Radio Tower 

Bases 

Undetermined Not Evaluated Fair PORE 

26 BO2050 56481 RCA Station Transmitter 

Building 

Undetermined Not Evaluated Good PORE 

27 BO2051 56482 RCA Station Service Station Undetermined Not Evaluated Poor PORE 

28 BO2052 56483 RCA Station Power House Undetermined Not Evaluated Fair PORE 

29 BO2053 56484 RCA Station Cooling Tower Undetermined Not Evaluated Fair PORE 

30 BO2070 56474 Ingermann Ranch House Determined 

Eligible - SHPO 

State Fair PORE 

31 BV1600 56405 W Ranch Milking Barn Determined 

Eligible - SHPO 

State Good PORE 

32 BV1700 56406 W Ranch John Rapp House Determined 

Eligible - SHPO 

State Good PORE 
463 

 Struct. # LCS # Structure Name NR Status Significance 

Level 

Cond. Park 

33 BV1740 56423 Bear Valley Dedication Plaque Ineligible - 

Managed as 

Resource 

Not Significant Good PORE 

34 BV1741 56424 Bear Valley Phillip Burton 

Wilderness Plaque 

Ineligible - 

Managed as 

Resource 

Not Significant Good PORE 

35 BV1742 56485 Morgan Horse Ranch 

Dedication Plaque 

Ineligible - 

Managed as 

Resource 

Not Significant Fair PORE 

36 BV1750 57556 Kule Loklo Ineligible - 

Managed as 

Resource 

Not Significant Fair PORE 

37 BV1751 56408 W Ranch Z Ranch Road Determined 

Eligible - SHPO 

State Fair PORE 

38 BV1752 56409 W Ranch Old Pine Trail Determined 

Eligible - SHPO 

State Fair PORE 

39 BV1815 56411 Z Ranch Water System Determined 

Eligible - SHPO 

State Fair PORE 

40 BV1845 56433 Glen Ranch Road Determined 

Eligible - SHPO 

State Fair PORE 

41 BV1865 56434 Wildcat Ranch Road Determined 

Eligible - SHPO 

State Good PORE 

42 BV1890 56425 Bear Valley Clem Miller Grave Ineligible - 

Managed as 

Resource 

Not Significant Good PORE 

43 HE0012 9227 Point Reyes Light Station 

Stairway and Winch 

Entered - 

Documented 

Contributing Good PORE 

44 HE0013 56300 Point Reyes Light Station East 

Rainshed 

Entered - 

Undocumented 

Contributing Poor PORE 

45 HE0014 16043 Point Reyes Light Station West 

Rainshed & Cistern 

Entered - 

Documented 

Contributing Fair PORE 

46 HE0015 56301 Point Reyes Light Station Oil 

House 

Entered - 

Documented 

Contributing Good PORE 

47 HE0016 9228 Point Reyes Light Station Fog 

Signal Equipment Bld 

Entered - 

Documented 

Contributing Good PORE 

48 HE0017 9229 Point Reyes Light Station 

Keeper's Garage 

Entered - 

Documented 

Contributing Good PORE 

49 HE0018 56302 Point Reyes Light Station East 

Water Tank 

Entered - 

Undocumented 

Contributing Good PORE 

50 HE0020 56303 Point Reyes Light Station 

Weather Bureau Building 

Entered - 

Undocumented 

Contributing Fair PORE 

51 HE0021 9231 Point Reyes Light Station Fuel 

and Paint Storage 

Entered - 

Documented 

Contributing Fair PORE 

52 HE0022 9232 Point Reyes Light Station 

Pumphouse 

Entered - 

Documented 

Contributing Fair PORE 

53 HE0023 56304 Point Reyes Light Station Trail 

to Old Fog Signal 

Entered - 

Undocumented 

Contributing Poor PORE 

54 HE0024 56305 Point Reyes Light Station Fog 

Signal Building Ruin 

Entered - 

Undocumented 

Contributing Poor PORE 

55 HE0025 9233 Point Reyes Light Station 

Lighthouse 

Entered - 

Documented 

State Good PORE 
464 

 Struct. # LCS # Structure Name NR Status Significance 

Level 

Cond. Park 

56 HE0026 56306 Point Reyes Light Station 

Laundry Bldg Foundation 

Entered - 

Undocumented 

Contributing Poor PORE 

57 HE0027 56307 Point Reyes Light Station Road 

to Gov't Landing 

Determined 

Eligible - SHPO 

State Good PORE 

58 HE0028 56308 Point Reyes Light Station Scr 

682 No. 1 Radar Site 

Undetermined Not Evaluated Fair PORE 

59 HE0029 56309 Point Reyes Light Station Cart 

House Platform 

Entered - 

Undocumented 

Contributing Fair PORE 

60 HE0030 56310 Point Reyes Light Station 

National Register Plaque 

Ineligible - 

Managed as 

Resource 

Not Significant Good PORE 

61 HE0031 56299 Point Reyes Light Station 

Granite Survey Monument 

Entered - 

Undocumented 

Contributing Good PORE 

62 HE0115 9240 Point Reyes Lifeboat Station 

Officer-In-Charge Res 

Entered - 

Documented 

Contributing Good PORE 

63 HE0116 16044 Point Reyes Lifeboat Station 

Water Storage Tank #1 

Entered - 

Documented 

Contributing Fair PORE 

64 HE0117 16045 Point Reyes Lifeboat Station 

Water Storage Tank #2 

Entered - 

Documented 

Contributing Poor PORE 

65 HE0118 9235 Point Reyes Lifeboat Station 

One-Car Garage 

Entered - 

Documented 

Contributing Fair PORE 

66 HE0119 9236 Point Reyes Lifeboat Station 

Pumphouse 

Entered - 

Documented 

Contributing Good PORE 

67 HE0120 16046 Point Reyes Lifeboat Station 

Stone Faced Wall 

Entered - 

Documented 

Contributing Good PORE 

68 HE0121 16047 Point Reyes Lifeboat Station 

Water Storage Tank #3 

Entered - 

Documented 

Contributing Good PORE 

69 HE0122 16048 Point Reyes Lifeboat Station 

Water Storage Tank #4 

Entered - 

Documented 

Contributing Good PORE 

70 HE0123 9237 Point Reyes Lifeboat Station 

Fire Pumphouse 

Entered - 

Documented 

Contributing Good PORE 

71 HE0124 16049 Point Reyes Lifeboat Station 

Low Rock Wall 

Entered - 

Documented 

Contributing Fair PORE 

72 HE0125 9238 Point Reyes Lifeboat Station 

Boathouse 

Entered - 

Documented 

National Good PORE 

73 HE0126 9239 Point Reyes Lifeboat Station 

Three Stall Garage 

Entered - 

Documented 

Contributing Good PORE 

74 HE0127 56311 Point Reyes Lifeboat Station 

Road 

Entered - 

Undocumented 

Contributing Good PORE 

75 HE0128 56312 Point Reyes Lifeboat Station 

Fuel Tanks 

Entered - 

Undocumented 

Contributing Fair PORE 

76 HE0129 56313 Point Reyes Lifeboat Station 

Concrete Walks 

Entered - 

Undocumented 

Contributing Fair PORE 

77 HE0130 56314 Point Reyes Lifeboat Station 

Drake Plaque 

Ineligible - 

Managed as 

Resource 

Not Significant Good PORE 

78 HE0131 56315 Point Reyes Lifeboat Station 

NHL Plaque 

Ineligible - 

Managed as 

Resource 

Not Significant Good PORE 

79 HE0132 55741 36-foot Motor Lifeboat No. 

36542 

Entered - 

Documented 

Contributing Good PORE 
465 

 Struct. # LCS # Structure Name NR Status Significance 

Level 

Cond. Park 

80 HE0133 22267 Point Reyes Lifeboat Station 

Marine Railway 

Entered - 

Documented 

National Poor PORE 

81 LI1519 56426 Clem Miller Environmental 

Education Center Plaque 

Ineligible - 

Managed as 

Resource 

Not Significant Good PORE 

82 LI1535 56432 Point Reyes Old Coast Road Determined 

Eligible - SHPO 

State Fair PORE 

83 PA0215 56331 A Ranch Calf Shed Determined 

Eligible - SHPO 

State Fair PORE 

84 PA0216 56332 A Ranch Gates, Fences, Corrals Determined 

Eligible - SHPO 

State Fair PORE 

85 PA0250 56333 B Ranch Old House Determined 

Eligible - SHPO 

State Fair PORE 

86 PA0251 56334 B Ranch Creamery Determined 

Eligible - SHPO 

State Poor PORE 

87 PA0252 56335 B Ranch Horse Barn Determined 

Eligible - SHPO 

State Fair PORE 

88 PA0253 56336 B Ranch Old Milking Barn Determined 

Eligible - SHPO 

State Fair PORE 

89 PA0254 56337 B Ranch Grade A Barn Undetermined Not Evaluated Fair PORE 

90 PA0255 56338 B Ranch Shed 1 Determined 

Eligible - SHPO 

State Fair PORE 

91 PA0256 56339 B Ranch Shed 2 Determined 

Eligible - SHPO 

State Fair PORE 

92 PA0257 56340 B Ranch Shed 3 Determined 

Eligible - SHPO 

State Fair PORE 

93 PA0270 56341 B Ranch Gates, Corrals, Fences Determined 

Eligible - SHPO 

State Fair PORE 

94 PA0320 22268 C Ranch Main House Determined 

Eligible - SHPO 

State Good PORE 

95 PA0321 22269 C Ranch Old Milking Barn Determined 

Eligible - SHPO 

State Fair PORE 

96 PA0322 22270 C Ranch Chicken House Determined 

Eligible - SHPO 

State Poor PORE 

97 PA0323 56342 C Ranch Garage/Shed Determined 

Eligible - SHPO 

State Fair PORE 

98 PA0324 56344 C Ranch Bunk House Determined 

Eligible - SHPO 

State Poor PORE 

99 PA0329 56343 C Ranch Gates, Corrals, Fences Determined 

Eligible - SHPO 

State Fair PORE 

100 PA0390 56345 D Ranch Old Ranch House Determined 

Eligible - SHPO 

State Fair PORE 

101 PA0391 56346 D Ranch Old Creamery Determined 

Eligible - SHPO 

State Poor PORE 

102 PA0392 56347 D Ranch Horse Barn Determined 

Eligible - SHPO 

State Fair PORE 

103 PA0393 56348 D Ranch Old Milking Barn Determined 

Eligible - SHPO 

State Fair PORE 

104 PA0394 56349 D Ranch Bunk House Determined 

Eligible - SHPO 

State Fair PORE 

105 PA0395 56350 D Ranch Shed Determined 

Eligible - SHPO 

State Fair PORE 
466 

 Struct. # LCS # Structure Name NR Status Significance 

Level 

Cond. Park 

106 PA0396 56351 D Ranch Old Garage Determined 

Eligible - SHPO 

State Fair PORE 

107 PA0397 56352 D Ranch Grade A Milking Barn Determined 

Eligible - SHPO 

State Good PORE 

108 PA0400 56354 D Ranch Fences, Corrals, Gates Determined 

Eligible - SHPO 

State Fair PORE 

109 PA0460 56420 Drakes Beach 1946 Drake 

Monument 

Ineligible - 

Managed as 

Resource 

Not Significant Good PORE 

110 PA0461 56421 Drakes Beach Drake Navigators 

Guild Monument 

Ineligible - 

Managed as 

Resource 

Not Significant Fair PORE 

111 PA0462 56422 Drakes Beach Nova Albion 

Plaque 

Ineligible - 

Managed as 

Resource 

Not Significant Good PORE 

112 PA0490 56356 E Ranch Old Milking Barn Determined 

Eligible - SHPO 

State Fair PORE 

113 PA0498 56358 E Ranch Road Determined 

Eligible - SHPO 

State Fair PORE 

114 PA0499 56359 E Ranch Fences, Gates, Corrals Determined 

Eligible - SHPO 

State Fair PORE 

115 PA0530 56361 F Ranch Schooner Landing 

(Ruin) 

Determined 

Eligible - SHPO 

State Poor PORE 

116 PA0531 56362 F Ranch Schooner Landing 

Road 

Determined 

Eligible - SHPO 

State Poor PORE 

117 PA0600 56365 G Ranch Cemetery Hinrik 

Claussen Grave 

Ineligible - 

Managed as 

Resource 

Not Significant Good PORE 

118 PA0601 56366 G Ranch Cemetery Agneta 

Claussen Grave 

Ineligible - 

Managed as 

Resource 

Not Significant Fair PORE 

119 PA0602 56367 G Ranch Cemetery Christiane 

Claussen Grave 

Ineligible - 

Managed as 

Resource 

Not Significant Fair PORE 

120 PA0603 56368 G Ranch Cemetery Capt. Peter 

Henry Claussen Grave 

Ineligible - 

Managed as 

Resource 

Not Significant Fair PORE 

121 PA0604 56369 G Ranch Cemetery Claussen 

Graveyard Fence 

Ineligible - 

Managed as 

Resource 

Not Significant Good PORE 

122 PA0605 56370 Life-Saving Service Cemetery 

Fred Carstens Grave 

Ineligible - 

Managed as 

Resource 

Not Significant Fair PORE 

123 PA0606 56371 Life-Saving Service Cemetery 

John Korpala Grave 

Ineligible - 

Managed as 

Resource 

Not Significant Fair PORE 

124 PA0607 56372 Life-Saving Service Cemetery 

Andrew Anderson Grave 

Ineligible - 

Managed as 

Resource 

Not Significant Fair PORE 

125 PA0608 56373 Life-Saving Service Cemetery 

George Larson Grave 

Ineligible - 

Managed as 

Resource 

Not Significant Poor PORE 
467 

 Struct. # LCS # Structure Name NR Status Significance 

Level 

Cond. Park 

126 PA0609 56374 Life-Saving Service Cemetery

Unidentified Grave 

Ineligible -

Managed as 

Resource 

Not Significant Poor PORE 

127 PA0610 56375 Life-Saving Service Cemetery

Fence 

Ineligible -

Managed as 

Resource 

Not Significant Fair PORE 

128 PA0690 9267 Home Ranch Main House Determined 

Eligible - SHPO 

State Good PORE 

129 PA0691 9268 Home Ranch Milking Barn Determined 

Eligible - SHPO 

State Fair PORE 

130 PA0693 9270 Home Ranch Hog and Hen

House 

Determined 

Eligible - SHPO 

State Fair PORE 

131 PA0694 9271 Home Ranch Wood Shed Determined 

Eligible - SHPO 

State Good PORE 

132 PA0695 9272 Home Ranch Lee Murphy

Residence 

Undetermined Not Evaluated Good PORE 

133 PA0696 9273 Home Ranch Machine Shop Determined 

Eligible - SHPO 

State Fair PORE 

134 PA0697 9274 Home Ranch Old Dairy House Determined 

Eligible - SHPO 

State Poor PORE 

135 PA0698 9278 Home Ranch Dog Shed/Storage Undetermined Not Evaluated Fair PORE 

136 PA0699 9279 Home Ranch Garage Undetermined Not Evaluated Fair PORE 

137 PA0700 9280 Home Ranch Pumphouse Undetermined Not Evaluated Fair PORE 

138 PA0701 9281 Home Ranch Granary/Shed Determined 

Eligible - SHPO 

State Poor PORE 

139 PA0702 9282 Home Ranch Horse Barn Determined 

Eligible - SHPO 

State Fair PORE 

140 PA0703 56427 Home Ranch Gates, Corrals,

Fences 

Undetermined State Fair PORE 

141 PA0720 56428 Home Ranch Old Point Reyes

Road 

Determined 

Eligible - SHPO 

State Fair PORE 

142 PA0721 56429 Home Ranch Glenbrook/New

Albion Road 

Determined 

Eligible - SHPO 

State Fair PORE 

143 PP0850 56400 M Ranch Horse Barn Determined 

Eligible - SHPO 

State Fair PORE 

144 PP0851 56401 M Ranch Old Milking Barn Determined 

Eligible - SHPO 

State Fair PORE 

145 PP0855 56402 M Ranch Gates, Corrals, FencesDetermined 

Eligible - SHPO 

State Fair PORE 

146 PP0856 56403 M Ranch Road Determined 

Eligible - SHPO 

State Fair PORE 

147 PP0940 56390 L Ranch House Determined 

Eligible - SHPO 

State Good PORE 

148 PP0941 56391 L Ranch Dairy House Determined 

Eligible - SHPO 

State Fair PORE 

149 PP0942 56392 L Ranch Horse Barn Determined 

Eligible - SHPO 

State Fair PORE 

150 PP0943 56393 L Ranch Calf Barn Determined 

Eligible - SHPO 

State Fair PORE 

151 PP0944 56394 L Ranch Milking Barn Determined 

Eligible - SHPO 

State Fair PORE 
468 

 Struct. # LCS # Structure Name NR Status Significance 

Level 

Cond. Park 

152 PP0945 56395 L Ranch Shed Determined 

Eligible - SHPO 

State Poor PORE 

153 PP0946 56396 L Ranch Garage Determined 

Eligible - SHPO 

State Fair PORE 

154 PP0947 56397 L Ranch East Barn Undetermined Not Evaluated Fair PORE 

155 PP0955 56398 L Ranch Gates, Corrals, Fences Determined 

Eligible - SHPO 

State Fair PORE 

156 PP0956 56399 L Ranch Road to Sacramento

Landing 

Determined 

Eligible - SHPO 

State Fair PORE 

157 PP1090 56389 Old Pierce Point Road Determined 

Eligible - SHPO 

State Fair PORE 

158 PP1100 56387 Lairds Landing House Determined 

Eligible - SHPO 

State Fair PORE 

159 PP1101 56388 Lairds Landing Shed Determined 

Eligible - SHPO 

State Fair PORE 

160 PP1102 56386 Lairds Landing Road Undetermined Not Evaluated Fair PORE 

161 PP1120 56379 I Ranch Old Milking Barn Determined 

Eligible - SHPO 

State Good PORE 

162 PP1121 56380 I Ranch Creamery Determined 

Eligible - SHPO 

State Good PORE 

163 PP1122 56381 I Ranch Main Residence Determined 

Eligible - SHPO 

State Good PORE 

164 PP1123 56382 I Ranch Feed Shed Determined 

Eligible - SHPO 

State Good PORE 

165 PP1134 56383 I Ranch Gates, Fences, Corrals Determined 

Eligible - SHPO 

State Fair PORE 

166 PP1135 56384 I Ranch Road Determined 

Eligible - SHPO 

State Fair PORE 

167 PP1220 9241 Pierce Ranch Main House Entered -

Documented 

State Good PORE 

168 PP1221 9242 Pierce Ranch Tank House Entered -

Documented 

State Good PORE 

169 PP1222 9243 Pierce Ranch Wash House Entered -

Documented 

State Good PORE 

170 PP1223 9244 Pierce Ranch School House Entered -

Documented 

State Good PORE 

171 PP1224 20000 Pierce Ranch School Outhouse Entered -

Documented 

State Good PORE 

172 PP1225 9245 Pierce Ranch Carriage Shed Entered -

Documented 

State Good PORE 

173 PP1226 9246 Pierce Ranch Carpenter Shop Entered -

Documented 

State Good PORE 

174 PP1227 9247 Pierce Ranch Blacksmith Shop Entered -

Documented 

State Good PORE 

175 PP1228 9248 Pierce Ranch McClure Calf

Shed 

Entered -

Documented 

State Good PORE 

176 PP1229 9249 Pierce Ranch Hay Barn Entered -

Documented 

State Good PORE 

177 PP1230 9250 Pierce Ranch New Dairy House Entered -

Documented 

State Good PORE 

178 PP1231 9251 Pierce Ranch Horse Barn Entered -

Documented 

State Good PORE 
469 

 Struct. # LCS # Structure Name NR Status Significance 

Level 

Cond. Park 

179 PP1232 9252 Pierce Ranch Old Garage Entered -

Documented 

State Good PORE 

180 PP1233 9253 Pierce Ranch Old Wagon Shed Entered -

Documented 

State Good PORE 

181 PP1234 9254 Pierce Ranch Chicken House

"A" 

Entered -

Documented 

State Good PORE 

182 PP1235 9255 Pierce Ranch Chicken House

"B" 

Entered -

Documented 

State Good PORE 

183 PP1236 9256 Pierce Ranch Old Dairy House Entered -

Documented 

State Fair PORE 

184 PP1238 9257 Pierce Ranch Corrals and

Fences 

Entered -

Documented 

State Fair PORE 

185 PP1239 9258 Pierce Ranch Cistern Entered -

Documented 

State Good PORE 

186 PP1240 56320 Pierce Ranch Lath House Entered -

Documented 

State Good PORE 

187 PP1241 56321 Pierce Ranch Road to White

Gulch Landing 

Entered -

Documented 

State Fair PORE 

188 PP1242 56322 Pierce Ranch Road to Lower

Pierce Ranch 

Entered -

Documented 

State Fair PORE 

189 PP1243 56323 Pierce Ranch Entrance Road Entered -

Documented 

State Good PORE 

190 PP1244 56324 Pierce Ranch Cattle Guard Entered -

Documented 

State Fair PORE 

191 PP1245 56325 Pierce Ranch Ruins of

Schooner Landing 

Determined 

Eligible - SHPO 

State Poor PORE 

192 PP1246 56326 Pierce Ranch Ruins of Quail

Clubhouse 

Determined 

Eligible - SHPO 

State Fair PORE 

193 PP1247 56327 Pierce Ranch Hog Shed Ruins Determined 

Eligible - SHPO 

State Fair PORE 

194 PP1248 56328 Pierce Ranch Feed Storage

House 

Entered -

Undocumented 

State Fair PORE 

195 PP1249 56319 Pierce Ranch Rock Wall

Remains 

Entered -

Undocumented 

State Fair PORE 

196 PP1250 56318 Pierce Ranch National Register

Plaque 

Ineligible -

Managed as 

Resource 

Not Significant Good PORE 

197 OV0101 10160 Wilkins Ranch Main House Determined 

Eligible - SHPO 

Local Good GOGA

198 OV0102 22277 Wilkins Ranch Granary Determined 

Eligible - SHPO 

Local Fair GOGA

199 OV0104 10163 Wilkins Ranch Creamery Determined 

Eligible - SHPO 

Local Fair GOGA

200 OV0105 10164 Wilkins Ranch Main Barn Determined 

Eligible - SHPO 

Local Fair GOGA

201 OV0106 10162 Wilkins Ranch Shed/Garage Determined 

Eligible - SHPO 

Local Fair GOGA

202 OV0107 10161 Wilkins Ranch Horse Barn Determined 

Eligible - SHPO 

Local Fair GOGA

203 OV0109 22278 Wilkins Ranch Bull House Undetermined Not Evaluated Fair GOGA

204 OV0111 22279 Wilkins Ranch Well House Undetermined Not Evaluated Fair GOGA
470 

 Struct. # LCS # Structure Name NR Status Significance 

Level 

Cond. Park 

205 OV0112 56444 Wilkins Ranch Fences, Gates,

Corrals 

Determined 

Eligible - SHPO 

Local Fair GOGA

206 OV0113 56445 Wilkins Ranch Roads Determined 

Eligible - SHPO 

Local Fair GOGA

207 OV0501 10165 Randall Ranch Sarah Seaver

Randall House 

Determined 

Eligible - Keeper

Local Fair GOGA

208 OV0601 10167 Giacomini Ranch House Determined 

Eligible - SHPO 

Local Good GOGA

209 OV0602 22271 Giacomini Ranch Carriage

House 

Determined 

Eligible - SHPO 

Local Fair GOGA

210 OV0603 22272 Giacomini Ranch Grade A

Dairy 

Determined 

Eligible - SHPO 

Local Fair GOGA

211 OV0606 10169 Giacomini Ranch Horse Barn Determined 

Eligible - SHPO 

Local Poor GOGA

212 OV0607 10170 Giacomini Ranch Barn Determined 

Eligible - SHPO 

Local Fair GOGA

213 OV0608 10171 Giacomini Ranch Creamery Determined 

Eligible - SHPO 

Local Fair GOGA

214 OV0611 10172 Giacomini Ranch Wood Shed Determined 

Eligible - SHPO 

Local Fair GOGA

215 OV0612 56469 Giacomini Ranch Water Tank Undetermined Not Evaluated Fair GOGA

216 OV0613 56470 Giacomini Ranch Gates,

Fences, Corrals 

Determined 

Eligible - SHPO 

Local Fair GOGA

217 OV0907 56468 Parsons Ranch Gates, Corrals,

Fences 

Determined 

Eligible - SHPO 

Local Fair GOGA

218 OV0908 56446 Parsons Ranch Roads Determined 

Eligible - SHPO 

Local Good GOGA

219 OV1001 10177 Five Brooks Pinkerton

Residence 

Undetermined Not Evaluated Good GOGA

220 OV1002 56461 Five Brooks Pinkerton Large

Shed 

Undetermined Not Evaluated Fair GOGA

221 OV1003 56462 Five Brooks Pinkerton Tractor

Shed 

Undetermined Not Evaluated Fair GOGA

222 OV1004 56463 Five Brooks Pinkerton

Outhouse 

Undetermined Not Evaluated Fair GOGA

223 OV1005 56464 Five Brooks Pinkerton

Pumphouse 

Undetermined Not Evaluated Fair GOGA

224 OV1201 10178 Stewart Ranch Main House Determined 

Eligible - SHPO 

Local Good GOGA

225 OV1202 22712 Stewart Ranch Shed Storage Determined 

Eligible - SHPO 

Local Fair GOGA

226 OV1204 22714 Stewart Ranch Carriage House Determined 

Eligible - SHPO 

Local Fair GOGA

227 OV1205 22715 Stewart Ranch House No. 3

"Squatters House" 

Determined 

Eligible - SHPO 

Local Fair GOGA

228 OV1207 56465 Stewart Ranch Laundry Determined 

Eligible - SHPO 

Local Fair GOGA

229 OV1208 56466 Stewart Ranch Gates, Fences,

Corrals 

Determined 

Eligible - SHPO 

Local Fair GOGA

230 OV1210 22716 Stewart Ranch House No. 1 Determined 

Eligible - SHPO 

Local Fair GOGA
471 

 Struct. # LCS # Structure Name NR Status Significance 

Level 

Cond. Park 

231 OV1211 22717 Stewart Ranch Equipment

Shed/Shop 

Undetermined Not Evaluated Fair GOGA

232 OV1212 10179 Stewart Ranch Old Barn Determined 

Eligible - SHPO 

Local Good GOGA

233 OV1213 22718 Stewart Ranch Silo Undetermined Not Evaluated Fair GOGA

234 OV1214 22719 Stewart Ranch Barn/Stables Determined 

Eligible - SHPO 

Local Good GOGA

235 OV1217 22720 Stewart Ranch Grade A Barn Determined 

Eligible - SHPO 

Local Fair GOGA

236 OV1219 22721 Stewart Ranch Open Front ShedDetermined 

Eligible - SHPO 

Local Fair GOGA

237 OV1220 22722 Stewart Ranch Water Storage

Tank 

Undetermined Not Evaluated Fair GOGA

238 OV1505 10159 Truttman Ranch Grade A Dairy

Barn 

Determined 

Eligible - SHPO 

Local Fair GOGA

239 OV1512 22284 Truttman Ranch Grain Shed Undetermined Not Evaluated Fair GOGA

240 OV1516 10152 Truttman Ranch Bunk House Determined 

Eligible - SHPO 

Local Fair GOGA

241 OV1520 10156 Truttman Ranch Hay Barn Determined 

Eligible - SHPO 

Local Poor GOGA

242 OV1530 56430 Truttman Ranch Fences, Gates,

Corral 

Determined 

Eligible - SHPO 

Local Good GOGA

243 OV1531 56431 Truttman Ranch Roads Determined 

Eligible - SHPO 

Local Good GOGA

244 OV1600 10150 Olema Valley East Copper

Mine 

Undetermined Not Evaluated Fair GOGA

245 OV1601 57571 Olema Valley Copper Mine 

Ruins 

Undetermined Not Evaluated Fair GOGA

246 OV1602 57572 Olema Valley Copper Mine 

Road 

Undetermined Not Evaluated Fair GOGA

247 OV1700 10151 Olema Valley West Copper

Mine 

Undetermined Not Evaluated Fair GOGA

248 OV3001 56435 McIsaac Ranch Main House Undetermined Not Evaluated Fair GOGA

249 OV3002 56436 McIsaac Ranch Shafter House Undetermined Not Evaluated Fair GOGA

250 OV3003 56437 McIsaac Ranch Barn Undetermined Not Evaluated Fair GOGA

251 OV3004 56438 McIsaac Ranch Calf Barn Undetermined Not Evaluated Poor GOGA

252 OV3005 56439 McIsaac Ranch Shelter Shed Undetermined Not Evaluated Fair GOGA

253 OV3006 56440 McIsaac Ranch Water Tank Undetermined Not Evaluated Fair GOGA

254 OV3007 56441 McIsaac Ranch Roads Undetermined Not Evaluated Fair GOGA

255 OV3008 56442 McIsaac Ranch Gates, Corrals,

Fences 

Undetermined Not Evaluated Fair GOGA

256 OV3009 56443 McIsaac Ranch Tocaloma

Bridge 

Undetermined Not Evaluated Fair GOGA

257 OV3101 56447 Zanardi Ranch Main House Undetermined Not Evaluated Good GOGA

258 OV3102 56448 Zanardi Ranch

Creamery/Dwelling 

Undetermined Not Evaluated Fair GOGA

259 OV3103 56449 Zanardi Ranch Old Milking

Barn 

Undetermined Not Evaluated Fair GOGA

260 OV3104 56450 Zanardi Ranch Horse Barn Undetermined Not Evaluated Fair GOGA

261 OV3105 56451 Zanardi Ranch Shed Garage Undetermined Not Evaluated Fair GOGA

262 OV3106 56452 Zanardi Ranch Cooler Shed Undetermined Not Evaluated Good GOGA
472 

 Struct. # LCS # Structure Name NR Status Significance 

Level 

Cond. Park 

263 OV3107 56453 Zanardi Ranch Shed next to

Garage 

Undetermined Not Evaluated Fair GOGA

264 OV3108 56454 Zanardi Ranch Large Shed Undetermined Not Evaluated Fair GOGA

265 OV3109 56455 Zanardi Ranch Shed at

Roadside 

Undetermined Not Evaluated Fair GOGA

266 OV3110 56456 Zanardi Ranch Old Shed in

Yard 

Undetermined Not Evaluated Fair GOGA

267 OV3111 56457 Zanardi Ranch Small House Undetermined Not Evaluated Fair GOGA

268 OV3112 56458 Zanardi Ranch 1923 Shed Undetermined Not Evaluated Fair GOGA

269 OV3113 56459 Zanardi Ranch Water Tank Undetermined Not Evaluated Fair GOGA

270 OV3114 56460 Zanardi Ranch Gates, Corrals,

Fences 

Undetermined Not Evaluated Fair GOGA

271 OV3200 56472 Lagunitas Creek/Tomales Bay 

Railroad Grade 

Undetermined Not Evaluated Fair GOGA

272 OV3300 56473 Old Olema Trail Undetermined Not Evaluated Fair GOGA

273 OV8001 57587 Rogers Ranch Old Milking

Barn 

Undetermined Not Evaluated Fair GOGA

274 OV8002 57588 Rogers Ranch Old Dairy House Undetermined Not Evaluated Poor GOGA

275 OV8003 57589 Rogers Ranch Wagon Shed Undetermined Not Evaluated Fair GOGA

276 OV8004 57590 Rogers Ranch Garage/Shed Undetermined Not Evaluated Good GOGA

277 OV8005 57591 Rogers Ranch Fire Truck Shed Undetermined Not Evaluated Fair GOGA

278 OV8006 57592 Rogers Ranch Gates, Corrals,

Fences 

Undetermined Not Evaluated Good GOGA

279 OV9001 57593 McFadden Ranch Hay Barn Undetermined Not Evaluated Good GOGA

280 OV9002 57594 McFadden Ranch Grade A BarnUndetermined Not Evaluated Good GOGA

281 OV9003 57595 McFadden Ranch Old Dairy Undetermined Not Evaluated Fair GOGA

282 OV9004 57596 McFadden Ranch Garage Undetermined Not Evaluated Good GOGA

283 OV9005 57597 McFadden Ranch Shed Undetermined Not Evaluated Fair GOGA

284 OV9006 57598 McFadden Ranch Road Undetermined Not Evaluated Good GOGA

285 OV9007 57599 McFadden Ranch Gates,

Fences, Corrals 

Undetermined Not Evaluated Good GOGA

286 TB3503 57574 Hamlet Lacey Cabin Determined 

Eligible - SHPO 

Local Poor GOGA

287 TB3504 57579 Hamlet Outhouses Determined 

Eligible - SHPO 

Local Poor GOGA

288 TB3505 57575 Hamlet Bean Cabin Determined 

Eligible - SHPO 

Local Poor GOGA

289 TB3506 57576 Hamlet Boat Ways Determined 

Eligible - SHPO 

Local Poor GOGA

290 TB3507 57577 Hamlet Storage Shed Determined 

Eligible - SHPO 

Local Poor GOGA

291 TB3510 57578 Hamlet Jensen House Determined 

Eligible - SHPO 

Local Poor GOGA

292 TB3511 57580 Hamlet South Fisherman's

Cabin 

Determined 

Eligible - SHPO 

Local Poor GOGA

293 TB3513 57581 Hamlet Middle Fisherman's

Cabin 

Determined 

Eligible - SHPO 

Local Poor GOGA

294 TB3515 57582 Hamlet North Fisherman's

Cabin 

Determined 

Eligible - SHPO 

Local Poor GOGA

295 TB3521 57585 Hamlet Water Tank House Determined 

Eligible - SHPO 

Local Fair GOGA
473 

 Struct. # LCS # Structure Name NR Status Significance 

Level 

Cond. Park 

296 TB3522 57586 Hamlet Old County Road Determined 

Eligible - SHPO 

Local Fair GOGA

297 TB3523 57573 Hamlet Remains of Railroad

Grade 

Determined 

Eligible - SHPO 

Local Fair GOGA
474 
475 

Appendix C: 

Other Projects Considered in 

Cumulative Impacts Analysis 
476 

Projects Included in the Cumulative Analysis of the FMP 

• The proposed McClure dairy barn and resource enhancement project, located in the North 

District of Point Reyes NS, involves construction of an 81,000 square foot loafing barn and 

development of manure holding ponds to enhance water quality. The project would enhance 

the viability of the ranch and exclusionary fencing will increase natural resource protection in 

the project area. One housing unit will be added to the complex. 

• The Pacific Coast Learning Center has been initiated in existing buildings in Olema Valley at 

the former Hagmaier Ranch. The site is used for office space, housing, and fire fighting and 

maintenance equipment. No new construction has occurred and park and visitor use has 

occurred on the site for over 20 years. 

• Sewage systems upgrades have been conducted at one residential unit on NPS lands and 

three new systems in residential units are planned for this fiscal year. The three units are all 

located in upper Olema Valley. The NPS headquarters buildings are receiving a new sewage 

system. 

• Riparian protection projects in Olema Valley for coho salmon and steelhead restoration. 

These projects include riparian exclusionary fencing on Blueline Creek, Giacomini Creek, 

Cheda Creek, and other tributaries. The park should receive funding in FY05 for additional 

creek restoration in the Limantour Beach area. 

• The Giacomini Ranch Wetlands Restoration Project planning is underway. The project 

involves restoring to wetlands approximately 560 acres of grazed land. The property was 

purchase in 2000. The wetlands restoration will be completed in FY07 or FY08 after public 

review and the completion of an EIS. 

• Cultural resource preservation projects have been conducted in the Olema Valley within the 

last five years. The historic bunkhouse at Truttman Ranch, northern Olema Valley, has been 

reroofed and rehabilitated. The Giacomini Ranch house, in southern Olema Valley, and main 

barn have received preservation treatments to ensure long-term preservation. In 1997, the 

main barn at the Wilkins Ranch was stabilized. The main barn at Truttman will be stabilized 

in FY2001. 

• The MCI building in the North District of Point Reyes National Seashore is receiving 

rehabilitation and will provide office space for district rangers. Ranger staff will be moved 

from existing office. Fire staff will also use the office space. No additional construction will 

occur. 

• The Point Reyes Hostel has developed a proposal for upgrading housing, a new sewage 

system, and for providing additional overnight lodging. The proposal will increase lodging 

capability from 44-52 persons. Housing for staff will increase from 2 to 4 units. 

• The Red Barn at park headquarters has been rehabilitated for curatorial storage and 

classroom space. There will also be office space for existing Marine Sanctuary staff. 
477 

• An average of 20 Wildland Urban Interface projects per year are being conducted in 

conjunction with FireSafe Marin, Marin County Fire Department, and other community 

organizations. These projects are primarily vegetation treatments along roadways for 

evacuation routes, creation of defensible space around homes, and fuel load reductions in 

strategic areas. 

• The Point Reyes Lighthouse has been rehabilitated by repairing key structures such as the 

stairway and other site features. The Lighthouse is receiving a new water system and 

buildings are being repaired and painted. 

• The Historic Lifeboat Station is scheduled in FY05 to receive approximately $1.0 million to 

restore the boat launching facility. The project involves the rehabilitation of pilings and 

railway rescue boat launching structures. 

• The Vision Fire, a large wildlife that occurred in October of 1995 was started by an illegal 

campfire, and burned approximately 12,500 acres and destroyed roughly 45 structures on 

Inverness Ridge. 
478 
479 

Appendix D: 

Biological Opinion United 

States Fish and Wildlife 

Service 
480 
481 
482 
483 
484 
485 
486 
487 
488 
489 
490 
491 
492 
493 
494 
495 
496 
497 
498 
499 
500 
501 
502 
503 

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533 

Index 

Agriculture, 504 

Beach layia, 123, 124, 319, 321, 322 

Bishop pine, xiv, xvi, 11, 27, 28, 30, 42, 43, 46, 48, 

50, 52, 53, 59, 69, 86, 87, 89, 91, 105, 106, 110, 

207, 210, 213, 217, 232, 267, 273, 274, 276, 277, 

280, 281, 282, 287, 290, 291, 293, 294, 312, 314, 

317 

Bolinas ridge, 29 

burn plans, xi, 38, 42, 47, 54, 55, 56, 210, 218, 223, 

224, 227, 228, 246, 327, 332, 351 

California freshwater shrimp, xx, xxi, 53, 71, 100, 

102, 128, 133, 146, 147, 319, 334, 335, 341, 347, 

354, 355, 358, 365, 368, 527 

carbon monoxide, xii, 98, 99, 174, 176, 178, 230, 

397, 399, 401 

catastrophic fire, xii, xviii, xxi, xxvii, 13, 69, 70, 71, 

180, 181, 182, 183, 213, 227, 233, 237, 238, 239, 

245, 249, 250, 252, 287, 306, 309, 311, 312, 316, 

325, 328, 333, 334, 341, 347, 350, 351, 354, 355, 

356, 358, 361, 362, 363, 364, 365, 366, 368, 386, 

388, 391, 393, 394, 395, 397, 400, 402 

ceanothus, xx, 27, 29, 39, 40, 44, 46, 51, 53, 122, 

125, 126, 127, 285, 322 

Coast Miwok, xxi, 28, 86, 104, 152, 153, 154, 155, 

196, 527 

coastal dunes, xiv, 88, 115, 120, 123, 321 

Coastal scrub, xiv, 112, 279, 285 

coho, xx, xxi, 12, 28, 29, 53, 71, 100, 102, 103, 117, 

128, 132, 135, 136, 138, 139, 140, 141, 142, 143, 

144, 145, 146, 192, 304, 319, 329, 330, 331, 332, 

333, 341, 344, 345, 347, 351, 353, 354, 358, 363, 

364, 365, 368, 476, 506, 529, 531 

cultural landscapes, iii, xxii, xxiii, 12, 72, 152, 154, 

155, 160, 195, 370, 371, 374, 375, 376, 377, 378, 

379, 380, 381, 452 

Douglas-fir, xiv, xvi, 1, 27, 28, 29, 30, 42, 43, 44, 45, 

46, 48, 50, 51, 52, 53, 59, 77, 87, 88, 91, 92, 105, 

106, 107, 108, 109, 112, 114, 128, 143, 179, 180, 

210, 217, 232, 234, 267, 273, 274, 277, 278, 280, 

281, 282, 283, 284, 285, 287, 289, 290, 291, 293, 

294, 312, 314, 317, 512, 514, 520, 524, 528 

environmentally preferred, 64 

erosion, x, xi, xiii, xviii, 11, 31, 54, 55, 56, 57, 68, 

69, 88, 89, 91, 92, 100, 102, 104, 148, 171, 172, 

173, 184, 185, 207, 208, 209, 210, 211, 213, 214, 

215, 216, 217, 218, 219, 220, 221, 222, 223, 224, 

226, 227, 228, 243, 244, 246, 247, 248, 249, 250, 

251, 252, 253, 254, 298, 303, 308, 311, 313, 316, 

332, 333, 334, 341, 343, 344, 345, 364, 369, 371, 

374, 375, 376, 519 

Estero FMU, xii, 25, 26, 39, 40, 81, 89, 156, 158, 

232, 234, 259, 291, 329, 383 

Eucalyptus, xiv, 45, 107, 109, 276, 287, 288 

fire cache, viii, xxi, xxiii, xxiv, xxvi, xxvii, 30, 67, 

68, 69, 70, 71, 72, 73, 165, 223, 227, 233, 237, 

241, 248, 251, 253, 275, 297, 310, 314, 317, 324, 

326, 340, 347, 349, 350, 357, 358, 360, 362, 367, 

369, 376, 377, 378, 379, 380, 381, 384, 385, 388, 

390, 391, 392, 393, 394, 395, 398, 399, 400, 402, 

404, 407, 409 

Fire Management Tools 

Prescribed Fire, 526 

French broom, vii, viii, xv, 18, 29, 37, 39, 40, 42, 43, 

44, 45, 51, 80, 267, 268, 269, 270, 273, 275, 276, 

281, 285, 286, 288, 290, 294, 296, 306 

General Management Plan, 5, 8, 521 

GGNRA, iii, v, vi, ix, xxii, xxv, 1, 4, 5, 9, 10, 29, 32, 

77, 80, 93, 122, 128, 129, 130, 131, 133, 134, 135, 

139, 142, 146, 155, 160, 230, 318, 320, 321, 326, 

329, 342, 343, 344, 351, 363, 390, 403, 413, 455 

goals, iii, vi, xxv, 4, 7, 9, 17, 35, 37, 41, 47, 93, 160, 

182, 200, 236, 240, 456 

grassland, xv, xvi, xviii, 1, 24, 25, 28, 29, 42, 43, 46, 

48, 50, 52, 53, 59, 70, 77, 80, 83, 85, 86, 87, 89, 

109, 113, 115, 120, 122, 127, 135, 179, 180, 206, 

230, 235, 269, 270, 271, 275, 279, 280, 281, 284, 

285, 286, 289, 290, 292, 293, 294, 303, 311, 341, 

396 

habitat loss, xviii, 303 

hardwood forest, xvi, 28, 59, 107, 267, 277, 281, 283, 

284, 290, 294 

Headlands FMU, 25, 42, 81, 89, 156, 158, 258, 292, 

359, 363, 364 

Highway One, xii, 24, 27, 29, 34, 37, 39, 40, 42, 43, 

44, 45, 51, 52, 53, 66, 81, 92, 93, 101, 102, 105, 

116, 128, 143, 145, 146, 154, 155, 156, 159, 206, 

210, 211, 212, 215, 219, 220, 221, 225, 232, 234, 

243, 264, 267, 268, 273, 275, 280, 281, 285, 287, 

288, 290, 296, 297, 299, 306, 322, 324, 326, 327, 

328, 329, 330, 331, 348, 350, 351, 352, 353, 361, 

363, 364, 373, 375, 377, 378, 379, 381, 383, 384, 

388, 390, 391, 392, 393, 394, 395, 398, 400, 404 

historic structures, iii, xxiii, 81, 93, 156, 160, 174, 

202, 373, 376, 377, 378, 379, 380, 381, 414 

hydrophobicity, xiii, 91, 172, 207, 208, 215, 217, 

218, 243, 244, 249 
534 

Interagency Federal Wildland Fire Policy Review 

Working Group, 6, 515 

Inverness Ridge, xxvi, 7, 19, 24, 27, 28, 31, 38, 42, 

43, 44, 45, 46, 50, 51, 52, 53, 57, 66, 80, 81, 82, 

83, 86, 89, 91, 92, 101, 102, 105, 113, 116, 128, 

133, 134, 138, 145, 158, 164, 172, 184, 207, 217, 

218, 219, 221, 222, 225, 232, 234, 243, 244, 247, 

260, 268, 281, 282, 286, 288, 299, 306, 312, 327, 

329, 344, 348, 349, 351, 352, 356, 363, 366, 377, 

378, 379, 380, 386, 390, 391, 392, 394, 395, 400, 

401, 404, 418, 477, 508, 510, 529 

Lagunitas Creek, xiii, 57, 83, 100, 101, 102, 117, 

135, 136, 139, 140, 141, 142, 143, 147, 184, 212, 

221, 224, 225, 228, 247, 253, 329, 330, 334, 342, 

344, 345, 351, 352, 354, 355, 363, 365, 472, 506, 

518, 528, 529, 531 

Limantour Road, xv, xx, 24, 26, 28, 31, 39, 40, 43, 

44, 45, 50, 51, 52, 53, 66, 80, 81, 101, 105, 116, 

125, 139, 145, 159, 184, 206, 211, 212, 215, 219, 

220, 221, 225, 243, 261, 267, 268, 273, 274, 280, 

281, 284, 285, 287, 288, 289, 290, 296, 297, 299, 

306, 322, 329, 330, 351, 352, 360, 363, 373, 375, 

377, 378, 379, 390, 391, 392, 393, 394, 395, 404 

manzanita, 11, 26, 27, 28, 29, 39, 40, 44, 46, 51, 53, 

86, 105, 113, 126, 127, 207, 218, 276, 285, 322, 

348, 360 

Marin County, iii, vii, ix, xxv, 1, 9, 10, 19, 30, 31, 32, 

33, 75, 77, 88, 93, 94, 98, 102, 104, 122, 128, 129, 

130, 133, 135, 136, 139, 146, 160, 165, 172, 232, 

326, 329, 331, 342, 343, 344, 346, 352, 363, 391, 

393, 394, 402, 403, 404, 413, 417, 418, 419, 477, 

506, 508, 509, 510, 511, 512, 516, 518, 522, 527, 

529 

Marin dwarf flax, xx, 118, 119, 122, 319, 320, 321, 

347, 357, 359, 368 

mechanical fuel reduction, xvi, 19, 36, 104, 178, 325, 

349, 361 

mechanical treatment, v, vii, xiii, xv, xvii, xviii, xx, 

xxiii, xxiv, xxviii, 37, 39, 40, 44, 45, 51, 52, 56, 

57, 69, 72, 73, 93, 125, 174, 181, 185, 204, 215, 

219, 222, 223, 224, 226, 227, 228, 229, 234, 235, 

236, 238, 239, 240, 241, 242, 243, 246, 250, 269, 

274, 275, 286, 287, 288, 290, 292, 294, 297, 300, 

301, 304, 306, 310, 313, 316, 322, 324, 326, 327, 

328, 329, 330, 331, 332, 334, 335, 338, 340, 346, 

347, 351, 352, 353, 354, 355, 358, 360, 362, 363, 

365, 368, 373, 375, 376, 377, 378, 379, 380, 385, 

386, 387, 389, 390, 394, 397, 398, 401, 403, 404, 

405, 406, 407, 408, 409 

Minimum Management Unit, 19, 29, 38, 42, 48, 71, 

120, 270, 335 

Monterey cypress, xiv, 45, 50, 51, 69, 105, 109, 110, 

268, 274, 276, 278, 287, 291, 294 

Monterey pine, xiv, xv, xvi, 25, 37, 39, 40, 43, 45, 

50, 51, 52, 69, 105, 109, 110, 267, 268, 270, 273, 

274, 276, 278, 280, 281, 284, 286, 287, 289, 290, 

291, 294, 296, 306, 519 

mountain beaver, xxi, 8, 12, 25, 61, 71, 150, 151, 

311, 336, 337, 341, 347, 356, 358, 366, 368 

mowing, vii, xv, xxiv, 8, 11, 12, 18, 25, 36, 45, 46, 

52, 55, 63, 69, 80, 81, 214, 216, 223, 226, 228, 

232, 236, 245, 254, 256, 269, 270, 273, 275, 280, 

281, 286, 288, 290, 308, 309, 323, 339, 348, 360, 

385, 386, 387, 389, 402 

Myrtle’s silverspot, xix, xx, xxi, 12, 48, 71, 118, 128, 

133, 147, 148, 319, 335, 336, 346, 347, 355, 358, 

365, 368 

Northern spotted owl, xx, 128, 319 

NPS Management Policies, 5, 6, 7, 13, 126, 161, 170, 

171, 177, 184, 185, 189, 191, 199 

Olema Valley, ix, 7, 29, 32, 33, 77, 80, 82, 88, 104, 

133, 134, 143, 155, 156, 157, 159, 218, 232, 327, 

342, 395, 418, 471, 476, 517 

Palomarin, xvi, xxvi, 19, 24, 27, 29, 38, 43, 44, 45, 

46, 51, 52, 53, 66, 69, 80, 81, 91, 92, 101, 102, 

104, 105, 116, 145, 154, 156, 159, 163, 164, 209, 

219, 220, 222, 225, 268, 281, 282, 285, 286, 288, 

289, 299, 306, 312, 313, 315, 320, 348, 349, 351, 

352, 353, 359, 360, 363, 377, 378, 379, 386, 388, 

389, 390, 391, 392, 393, 394, 395, 400, 404 

particulates, xi, 68, 99, 174, 176, 230, 232, 236, 397, 

399, 401 

pasture, xiv, xv, 80, 86, 115, 120, 121, 270, 275, 280, 

281, 286, 288, 289, 290, 294, 321, 322 

Philip Burton Wilderness Area, 80 

Point Reyes Mountain Beaver, xx, 61, 150, 336, 356, 

366, 511 

preferred alternative, iii, 64, 454 

prescribed burning, v, vii, viii, xi, xii, xiii, xv, xvi, 

xvii, xx, xxi, xxv, 4, 8, 11, 13, 17, 18, 19, 24, 33, 

35, 37, 38, 39, 40, 42, 43, 44, 45, 46, 47, 48, 50, 

51, 52, 53, 56, 57, 58, 59, 68, 69, 72, 73, 94, 99, 

165, 174, 177, 181, 182, 210, 211, 212, 214, 215, 

218, 219, 220, 223, 224, 226, 227, 228, 229, 230, 

231, 232, 234, 235, 236, 238, 239, 240, 242, 243, 

244, 246, 249, 250, 251, 252, 253, 254, 267, 268, 

269, 270, 272, 274, 275, 280, 281, 282, 283, 284, 

285, 286, 287, 289, 290, 291, 293, 294, 296, 300, 

303, 306, 312, 315, 320, 321, 322, 323, 332, 333, 

334, 336, 337, 344, 346, 347, 349, 353, 354, 355, 

356, 358, 360, 361, 362, 364, 365, 366, 368, 373, 

375, 379, 381, 382, 386, 392, 394, 395, 396, 399, 

401, 404, 405, 406, 408, 411, 456 

PRNS, iii, v, vi, ix, x, xi, xiv, xvii, xxii, xxiii, xxiv, 

xxv, xxvi, 1, 4, 5, 7, 8, 9, 10, 11, 12, 13, 30, 32, 

33, 42, 54, 56, 77, 80, 81, 83, 85, 86, 88, 93, 94, 

98, 100, 104, 111, 116, 117, 119, 120, 121, 123, 

124, 126, 128, 129, 130, 131, 132, 133, 134, 135, 

138, 139, 140, 141, 142, 143, 144, 146, 147, 148, 

149, 150, 152, 154, 155, 156, 157, 158, 160, 161, 

162, 164, 165, 174, 178, 179, 180, 181, 182, 183, 
535 

202, 222, 229, 230, 231, 235, 236, 239, 243, 268, 

276, 318, 319, 321, 326, 328, 329, 332, 333, 335, 

342, 343, 344, 345, 346, 351, 363, 384, 388, 403, 

406, 408, 413, 516, 522, 531 

red-legged frog, xix, xx, 12, 100, 102, 103, 104, 117, 

118, 128, 131, 132, 133, 134, 135, 151, 152, 304, 

319, 326, 327, 328, 343 

regional haze, xii, 68, 98, 174, 176, 182, 183, 231, 

233, 234, 236, 237, 239, 240, 241, 242 

riparian forests, xiv 

riparian vegetation, xxi, 69, 71, 136, 184, 207, 304, 

311, 332, 333, 334, 341, 344, 345, 347, 353, 355, 

358, 364, 365, 368 

riparian woodland, 52, 186, 274, 278, 284, 288, 293 

risk, 7, 9, 19, 20, 21, 22, 518 

safety, iii, v, vii, ix, xvii, xxvi, xxvii, 6, 7, 9, 10, 13, 

30, 31, 32, 47, 48, 63, 64, 73, 93, 162, 164, 176, 

204, 218, 297, 299, 300, 308, 309, 315, 343, 373, 

396, 397, 398, 399, 400, 402, 404, 406, 408, 457 

scoping, vi, vii, x, 4, 10, 13, 17, 34, 75, 413, 414, 

454, 455 

Scotch broom, viii, xv, 18, 25, 39, 40, 43, 45, 46, 50, 

51, 52, 67, 215, 267, 268, 270, 280, 281, 286, 289, 

290, 293, 294, 296 

scrubland, 109 

sediment loads, 145, 245, 311, 341 

smoke, xii, xxvi, xxvii, 8, 13, 36, 56, 73, 93, 117, 

128, 133, 162, 165, 176, 177, 178, 181, 182, 204, 

228, 229, 231, 232, 234, 236, 239, 240, 242, 271, 

305, 382, 386, 388, 396, 397, 398, 399, 400, 401, 

402, 457 

Sonoma alopecurus, xx, 104, 118, 119, 120, 121, 

319, 320, 321, 348, 349, 357, 359, 368 

Sonoma spineflower, xx, 12, 104, 118, 119, 121, 122, 

319, 321, 347, 357, 359, 368 

spawning habitat, 102, 144 

spending, xxvii, 73, 117, 166, 402, 403, 404, 406, 

407, 408, 409 

staff, v, vi, vii, ix, x, xxii, xxiii, xxv, xxvii, 4, 5, 10, 

12, 17, 31, 32, 33, 34, 36, 37, 38, 42, 58, 62, 72, 

73, 87, 88, 101, 121, 123, 138, 148, 150, 154, 155, 

157, 158, 159, 160, 162, 165, 171, 172, 178, 179, 

203, 230, 232, 272, 283, 321, 334, 343, 355, 365, 

371, 373, 384, 391, 392, 393, 395, 400, 402, 403, 

404, 405, 406, 407, 408, 409, 413, 476 

Staffing, xxv, 8, 159, 160, 390, 403 

steelhead, xx, xxi, 8, 12, 28, 29, 53, 71, 100, 102, 

103, 117, 128, 132, 135, 136, 138, 139, 141, 142, 

143, 144, 145, 146, 192, 304, 319, 329, 330, 331, 

332, 333, 341, 344, 345, 347, 351, 353, 354, 358, 

363, 364, 365, 368, 476, 506 

suspended solids, xiii, 68, 243 

thinning, xi, xiii, xiv, xix, xx, xxi, xxii, xxiii, xxv, 

xxvii, 8, 40, 45, 51, 52, 55, 59, 63, 68, 69, 71, 72, 

73, 80, 109, 112, 125, 181, 228, 229, 234, 256, 

273, 274, 283, 287, 288, 294, 309, 313, 314, 316, 

317, 322, 323, 326, 328, 333, 338, 339, 347, 348, 

350, 351, 354, 356, 358, 359, 361, 362, 363, 365, 

366, 368, 369, 370, 371, 375, 377, 379, 381, 394, 

395, 400, 402 

Tiburon paintbrush, xx, 118, 119, 122, 319, 320, 321, 

347, 357, 359, 368 

Tidestrom’s lupine, xx, 104, 118, 119, 123, 124, 319, 

320, 321, 322, 347, 358, 359, 368 

Tomales Point FMU, 25, 48, 59, 81, 89, 115, 117, 

154, 156, 158, 257, 289, 292, 313, 315, 316, 352 

tule elk, xxiv, 28, 48, 61, 148, 158, 305, 313, 316 

velvet grass, viii, 18, 39, 40, 46, 48, 50, 52, 67, 115, 

269, 275, 276, 286, 292, 293, 315 

Vision Fire, xiv, xxvi, xxvii, 25, 27, 32, 85, 88, 89, 

91, 103, 105, 106, 113, 150, 163, 166, 172, 174, 

180, 181, 183, 207, 208, 210, 213, 217, 218, 223, 

227, 232, 233, 234, 238, 241, 242, 243, 244, 248, 

249, 277, 279, 282, 298, 311, 337, 341, 343, 356, 

366, 384, 392, 397, 398, 404, 405, 477, 505, 508, 

510, 522, 523, 529 

visitors, vi, xxiii, xxiv, xxv, xxvii, 5, 7, 13, 33, 56, 

64, 65, 72, 149, 157, 158, 159, 163, 165, 166, 200, 

201, 226, 229, 240, 336, 382, 383, 384, 385, 386, 

387, 388, 389, 390, 396, 397, 398, 399, 400, 401, 

403, 406, 408 

volatile organic compounds, 178, 230, 231, 234, 236, 

238, 240, 242 

watershed, xi, xiii, 54, 57, 68, 69, 75, 77, 91, 100, 

101, 102, 103, 117, 135, 136, 138, 139, 141, 142, 

143, 145, 146, 147, 172, 173, 184, 185, 210, 211, 

212, 216, 218, 220, 221, 223, 224, 225, 227, 243, 

244, 245, 246, 247, 249, 250, 251, 253, 254, 312, 

315, 329, 330, 331, 334, 342, 344, 345, 351, 352, 

353, 363 

western snowy plover, xx, 118, 128, 148, 319, 336, 

345, 355, 366 

wetlands, iii, xvi, xvii, xx, 1, 11, 37, 58, 60, 70, 100, 

115, 116, 121, 126, 127, 141, 162, 171, 188, 189, 

207, 214, 218, 248, 272, 295, 296, 297, 298, 299, 

301, 302, 320, 343, 344, 345, 415, 476 

Wilderness, x, 6, 12, 19, 24, 26, 28, 29, 38, 43, 44, 

45, 46, 50, 51, 52, 53, 63, 66, 80, 81, 91, 92, 101, 

102, 103, 105, 116, 128, 139, 143, 145, 155, 156, 

159, 161, 162, 163, 189, 192, 219, 220, 221, 225, 

234, 235, 262, 263, 268, 281, 282, 286, 287, 288, 

291, 299, 306, 312, 313, 315, 327, 329, 348, 349, 

350, 351, 352, 353, 360, 361, 363, 377, 378, 379, 

386, 388, 389, 390, 391, 392, 393, 394, 395, 400, 

404, 419, 463, 521, 526 

Wilderness North, x, 19, 24, 26, 38, 43, 44, 45, 46, 

50, 51, 52, 53, 66, 80, 91, 92, 101, 102, 105, 116, 

139, 145, 159, 163, 219, 262, 268, 281, 282, 286, 

287, 288, 291, 299, 306, 312, 313, 315, 348, 349, 

350, 351, 352, 361, 363, 377, 378, 379, 386, 388, 

389, 390, 391, 392, 393, 394, 395, 400, 404 
536 

Wilderness South, 19, 24, 26, 38, 43, 44, 45, 46, 50, 

51, 52, 53, 66, 91, 92, 101, 105, 116, 143, 145, 

155, 156, 163, 219, 263, 268, 282, 287, 288, 291, 

299, 306, 312, 313, 315, 327, 329, 348, 350, 351, 

352, 353, 360, 361, 363, 377, 378, 379, 392, 394, 

404 

Wildland Urban Interface Initiative, viii, 29, 30, 215, 

222, 226 

WUI, viii, xxv, xxvi, 30, 160, 164, 180, 216, 222, 

226, 233, 234, 238, 242, 390, 403 




US Department of Interior—National Park Service