Extended: Submit a comment by MAY 8, 2024

NPS WASTEWATER FACILITY PROTECTION PROJECT IS CLOSING RECREATION AT FORT FUNSTON

Many of us were caught off-guard by an Environmental Assessment (EA) being conducted by the National Park Service for a project by the City and County of San Francisco to protect the city’s wastewater treatment facility on the Great Highway at Ocean Beach, south of Sloat Blvd.

See sample comments below and instructions on how to submit them to NPS by May 8, 2024.

It turns out that recent changes to the proposed “Ocean Beach Climate Adaptation Project” could adversely affect recreation at Fort Funston. The project is being managed by the San Francisco Public Utilities Commission but requires a special use permit by NPS for construction on GGNRA-managed land at Ocean Beach.

SFDOG strongly supports the project’s core elements: 3,200-foot underground wall to protect the wastewater facility, new restroom, parking lot, and stairways on South Ocean Beach, and a connector trail along the Great Highway between Ocean Beach and Fort Funston.

RED FLAGS

But we see red flags with two of the components at Fort Funston that appear to have been added at the last minute and will close off areas to recreation in order to plant endangered and special-status plants:

1) New Plant Propagation Site on a half-acre within a 16-acre boundary near the south parking lot at Fort Funston. This plant propagation site will grow plants to revegetate slopes at South Ocean Beach and the northeast end of Fort Funston. It will also be used for future native plant restoration projects at other NPS units.

2) New Habitat Restoration Area with native grasses and endangered and special-status plants on 2 acres within an 8-acre boundary at the northern end of Fort Funston (note this is outside of the already existing 12-acre habitat protection area that was closed in 2005). This element is ostensibly to mitigate construction disturbances to the Bank Swallow colony that nests in the cliffs at Fort Funston and south Ocean Beach by restoring bluff-top foraging habitat.

The Fort Funston elements are vague and misleading. It’s not clear exactly where and how the sites will be constructed. Maps for each site show boundaries that are 8-10 times larger than the actual planting area. The rationale for the bank swallow habitat is ludicrous -- bank swallows don’t eat plants, native or not.

This much is clear: NPS has targeted these planting areas on land that is currently designated for recreation at Fort Funston. We know from decades of experience this could be a precursor to closures of these areas and potentially more closures in the future.

Please consider submitting a public comment about this plan to NPS by Wed., May 8, 2024. Comments must be submitted by webform: https://parkplanning.nps.gov/commentForm.cfm?documentID=135967

SAMPLE COMMENTS

• I am writing this public comment on the Draft Environmental Assessment for an NPS Easement and Special Use Permit for the Ocean Beach Climate Change Adaptation Project.

• While I support the overall project, I have serious concerns about both the proposed new Fort Funston Plant Propagation Site and the new Habitat Restoration Area at the northern end of Fort Funston.

• In particular, I am concerned that these two sites could require closure to recreational access. I do not believe this EA meets the requirement for a robust notice and comment period before closures can be implemented, as multiple federal lawsuits have confirmed is needed.

• In Figure 2d, the EA outlines areas for both the plant propagation site and the habitat restoration area that are significantly larger than the actual size of the two planting areas. Figure 2d should have shown exactly where the sites will be. Currently, each site shows a wide boundary within which planting will occur. Without that information, it is difficult to make an informed comment on the project.

• If any habitat restoration is done, why is it not taking place within the already closed 12-acre Habitat Protection Area, rather than in areas that are designated for recreational access?

• Fencing will likely be needed to protect both of these areas, yet it is not mentioned in the EA. I do not support fencing or closing off areas without a robust notice and comment process.

• I do not support the use of herbicides anywhere at Fort Funston to remove ice plant. Herbicide use is not acceptable within or near areas accessible and frequently used by people, children and dogs.

• I do not support the growing and planting of endangered or special-status plants at Fort Funston since they will necessitate closures in areas that currently allow recreational access.

• There is no justification for a new plant propagation site because the already existing plant nursery at the southern end of Fort Funston could be repurposed temporarily to grow plants to restore habitat destroyed by the construction project. According to the Golden Gate National Parks Conservancy, the Fort Funston nursery already has the capacity to produce 25,000 plants per year.

• The EA says that the project will restore bluff-top foraging habitat for the bank swallows. This is not a suitable mitigation step for disturbances by project construction that could have damaging effects on cliff and embankment nesting areas. However, bank swallows don’t eat plants, native or not. They eat insects, caught on the wing, over Lake Merced and then nest in cliffs. The new habitat will not benefit the bank swallows.

• The EA claims that endangered lessingia and other special-status plants have been found in this northern area of Fort Funston. This claim certainly could be used to justify the closure of those areas to recreational access, yet it is not explicitly discussed in the EA. The EA fails to discuss how these plants miraculously appeared since people have looked for the plant at Fort Funston for decades and never saw it until now.

• I question whether using money intended to protect the Ocean Beach wastewater treatment facility to create a new plant nursery to grow plants for other parts of the GGNRA is an appropriate use of funding.

• Unless my concerns are addressed, I do not support adoption of this EA with the new plant propagation site and new habitat restoration area at Fort Funston.