The following letter from Sustainable TamAlmonte to the Marin County Board of Supervisors pertains to a DRAFT Memorandum of Understanding (MOU), a proposed agreement, between the County of Marin and the National Park Service, which would create a Muir Woods reservation system in conjunction with changes to public transit, roadside parking, and parking.
Letter from Sustainable TamAlmonte to the Marin County Board of Supervisors - June 9, 2015
Dear Marin County Board of Supervisors,
We have examined the DRAFT Memorandum of Understanding (MOU), a proposed agreement between the County of Marin and the National Park Service (NPS) regarding the Muir Woods National Monument, and have the following comments about the document.
The National Park Service's quest for greater revenue by increasing the number of visitors to Muir Woods is contrary to what is best for the preservation of the Muir Wood's habitat and what is best for the surrounding communities. Potential consequences from the increase in visitors include: destruction of sensitive habitat; harm to wildlife (including endangered species); increased traffic congestion; more pollution and debris; and greater risk of public harm due to more accidents, pollution, blocked evacuation routes and fires.
To maintain the current number of visitors to Muir Woods is also irresponsible as indicated by existing conditions (E.g. The rapid decline of coho salmon in Redwood Creek and unsafe traffic congestion along the roads leading to the national monument).
The MOU between the County and the NPS has the potential to lower visitation to Muir Woods, reduce traffic congestion and ensure safe parking for Muir Woods visitors and, in so doing, preserve the environment and protect public health and safety. We urge you to follow our below recommendations in order to further these worthwhile goals.
A. Concerns Regarding the Draft MOU:
1. There are no realistic compliance mechanisms in the MOU. We don't see regular checks and balances written into the MOU. We don't see any regular oversight written into the agreement for the County to oversee whether or not NPS is fulfilling its obligations. There is a section in the MOU that speaks about resolving disputes if either Party identifies a material failure of the terms and conditions of this agreement. However, we don't see how the County would find out if the NPS were to fail to meet its obligations. There are no penalties for non-compliance.
2. There is no mention or requirement for an "Independent Trustworthy Scientific Capacity Study" for Muir Woods and the surrounding communities to determine the number of visitors the park can sustainably handle.
3. **There are no enforceable Visitor CAPs. This is our biggest concern. Unless there are enforceable Visitor CAPs, the reservation system would most likely increase visitation and traffic.
Most organizations engage a reservation system to increase sales, among other objectives. Reservation systems have great advantages for boosting sales, including:
- The ease of online real time booking (24 hrs. / 7 days a week);
- Increased utilization of the destination by booking visits throughout the
entire day;
- Up-selling, cross-selling, offering package deals and promotional
discounts;
- Online performance measurement and sales matrix - A business story can
be measured and scaled as online systems will display the performance matrix and act as a critic for every move you make. Real-time reporting shows the number of prospects, and how many were converted to actual reservations. This builds a profile of customer behavior and identifies sales trends information that can be used for strategic planning purposes;
- Currency and language settings to appeal to a global audience; and
- Repeat business with more sales - The customer database generated through sales can also be used for targeting future marketing campaigns.
Yet, the reservation system could be used to lower sales, attendance, and related traffic and environmental impacts. However, the only way to ensure this is to establish sustainable, hourly, daily, monthly and yearly Visitation CAPs. Unfortunately, as currently written, the MOU lacks enforceable Visitor CAPs.
The MOU states; "The NPS agrees to... Manage the reservation resulting in visitation levels that are at or below those identified as "Total Capacity - This Alternative" in Attachment B." However, Attachment B allows approximately 1,030,000 Visitors per year (somewhat more than we have now) and up to 4000 or 4500 visitors per day on weekends for five months of the year. (**Please see our attached spreadsheet.) Such levels are too high. Rather than reducing the number of Muir Woods visitors, Attachment B simply spreads out a similar number of visitors throughout the year. Moreover, we don't see how the Capacity shown in Attachment B would be enforced by the County. At Huffman’s Stakeholders Forum, an NPS representative stated that they would not enforce any Visitor CAP and would only manage the vehicle reservation system and parking to meet visitation levels. Therefore, if parking and traffic enforcement is lax, those who park illegally would be rewarded with a ticket to enter the park. **Please note that up 'til now the NPS website has been promoting more visitation to the park. The proposed reservation system seems to ignore public input. Local residents have requested a reduction in visitation to Muir Woods rather than a redistribution or possible expansion of visitation.
4. There are no enforceable CAPs on the number of buses. The current Draft MOU allows a 4-fold increase in bus traffic on a grade LOS “F” road. Buses do not have to park and therefore allow limitless numbers of tourists to visit the park.
5. There are no enforceable CAPs on car reservations in order to reduce the number of visitors to Muir Woods. If all the parking spaces were used every hour of the day throughout the year, the number of visitors to Muir Woods would increase.
6. The MOU slowly (over a period of 7 years) limits BUT does not eliminate parking along Muir Woods Road. Parking on the road presents a safety hazard, threatens the health of the redwood creek watershed, and diminishes the visitor experience. The parking limitation is supposed to help address this concern. However, the coho salmon who live in the creek, both upstream and downstream of the Redwood Creek Bridge, are facing extinction and 7 years isn't quick enough. It is noteworthy that parking will still exist upstream and downstream of the bridge at the termination of this agreement. Furthermore, there is no agreement when this MOU becomes null and void in 7 years and therefore no guarantees regarding future parking and jurisdiction on Muir Woods Road. Moreover, according to an NPS spokesperson, the National Park Service plans to INCREASE parking within the park.
7. The County will give away too much control. Control of Muir Woods Road is one of the main negotiation and oversight tools the County has. In contrast, the County does not have jurisdiction over the national monument or over Hwy 1.
According to the MOU, revenue generated from parking fees on Muir Woods Road (a County road) will be collected and controlled by the National Park Service (NPS). As a result, the County loses a huge potential revenue stream. Parking and traffic enforcement around Muir Woods and along Muir Woods Road (a County road) will be provided by the National Park Service and NOT the County.
Officially the MOU states that the County Sheriff does not relinquish or reduce any of its existing authority to enforce traffic and parking regulations throughout the Parking Enforcement Corridor. However, if the Sheriff Dept. does not regularly patrol the area, it will not be able to enforce such regulations. Besides which, the County has given away the parking revenue that could pay for additional Sheriff officers to patrol the area.
The MOU states; The National Park Service (NPS) will: "Assume routine day-to-day operational responsibilities with the Parking Management Corridor (including Muir Woods Rd.), which includes, but is not limited to, parking management, parking enforcement, nontoxic vegetation management, litter collection, and routine maintenance (surface treatment) of shoulder and pedestrian areas." However, according to an NPS spokesperson, the revenue generated from parking fees on Muir Woods Rd. would be used by NPS for many purposes and not just those related to the road. Yet, the long-term maintenance of the road would continue to be the County's liability and financial responsibility.
8. The National Park Service has a conflict of interest in regulating parking because the more parking allowed (whether legal or not) brings more revenue to the park through increased visitation.
9. Proposed parking lots (on Panoramic Dr., Santos Meadows, and White Gate Ranch) have been put on hold. However, we understand that this is only a verbal agreement and that the parking lots have not yet been eliminated from the NPS General Management Plan that was adopted many months ago.
10. Bus length restrictions are too lax. Currently, buses are limited to 35 feet long or shorter but 35 feet is too long for a bus to be able to remain inside its lane on the winding roads leading to Muir Woods.
11. Additional parking fees on top of entrance fees may be a burden for lower income households.
12. The National reservation system could severely limit local visitation to the monument. A national reservation system would be biased towards one-time visitors (90% of visitation) and could restrict locals’ visitation to Muir Woods.
B. Recommendations Regarding the MOU:
1. Insert realistic compliance mechanisms into the MOU: Regular oversight and checks and balances should be included in the document. Specific penalties for non-compliance should also be included.
2. Require an Independent Scientific Carrying Capacity Study: Require a trustworthy INDEPENDENT Scientific Carrying Capacity Study of Muir Woods and the surrounding communities, including impacts on adjacent habitats and traffic.
3. **Most importantly, Establish Visitor CAPs: Don't just keep the number of Muir Woods visitors at current levels but LOWER the number of visitors to Muir Woods by establishing hourly, daily, monthly, and yearly CAPs on the number of tourists allowed to visit Muir Woods BEFORE implementation of a reservation system occurs. Such CAPs should be based on findings from the Independent Scientific Carrying Capacity Study to set levels of visitation that will be sustainable over time and NOT based on NPS marketing studies. Until the study can be completed, temporary CAPS, based on an annual CAP of 750,000 visitors, should be used. Adherence to the Visitor CAPs must be verifiable and enforceable.
4. Establish bus CAPs: The current Draft MOU allows a 4-fold increase in bus traffic on a grade LOS “F” road. While supportive of public transit, there needs to be a limit on the number of buses driving to Muir Woods due to their traffic impacts, including issues of size, safety and volume. Moreover, buses do not have to park and therefore allow limitless numbers of tourists to visit the park. Establish CAPs on buses (per year / per season / per day / per hour) in order to reduce the number of buses driving to Muir Woods and subsequently reduce visitation to the park. The Bus CAPs and the Car CAPs (below) should be consistent with and help achieve the above referenced Visitor CAPs (Recommendation #3). Adherence to the bus CAPs must be verifiable and enforceable.
5. Establish car reservation CAPs: If all the Muir Woods parking spaces were used every hour of the day throughout the year, the number of visitors to Muir Woods would increase. This is contrary to the goal of significantly reducing visitation. Establish CAPs on cars (per year / per season / per day / per hour), in order to reduce the number of cars driving to Muir Woods and subsequently reduce visitation to the park. The Car Caps and Bus Caps (above) should be consistent with and help achieve the above referenced Visitor Caps (Recommendation #3) Adherence to the car CAPs must be verifiable and enforceable.
6. Eliminate parking along Muir Woods Road: Rather than slowly lowering (and never eliminating) the number of cars parking along Muir Woods Road, reduce parking along Muir Woods Rd., both downstream and upstream of the Redwood Creek Bridge, to 80 parking spots within one year and totally eliminate parking in perpetuity along Muir Woods Road within three years.
7. Retain County control of shuttles and parking enforcement: Retain local control (Marin County's control) over shuttles and law enforcement related to managing and controlling Muir Woods' visitor load and parking on County roads. This will allow locals to maintain oversight and help control how much traffic is generated by Muir Woods in order to prevent adverse impacts on the environment, public health and safety, and quality of life in our residential communities. Also, make certain that no illegal parking is allowed and parking regulations are enforced near Muir Woods and along Muir Woods Rd. and Hwy 1.
8. Require a regional ‘Point of Origin’ shuttle system: If an Independent Scientific Carrying Capacity Study on visitor load for Muir Woods and related parking & traffic proves the need for a more robust shuttle system, establish a Muir Woods Shuttle System (using small shuttle buses) that picks up and drops off Muir Woods’ visitors at regional points of origin (E.g. San Francisco, East Bay, and North Bay) and NOT within the Tamalpais Area Community Plan area. The number of vehicles exiting off Hwy 101 and entering onto congested Hwy 1 (with an LOS “F”) must be reduced.
9. Prevent new parking lots and visitor centers in writing: Include in the MOU a clause stating that the National Park Service shall NOT establish any new parking lots or visitor centers at Panoramic Drive, Santos Meadows, White Gate Ranch, and Manzanita.
10. Lower bus lengths to 25 feet.
11. Establish social equity measures: Establish social equity measures to lower the entrance and parking fees for lower income households.
12. Establish a special provision for locals: Since a national reservation system would be biased towards one-time visitors (90% of visitation), there should be a special provision made for locals to visit the National Monument.
13. Ensure transparency: Reservation and admission statistics should be posted daily on a public website to ensure transparency and provide a means to evaluate the success or failure of the MOU agreement.
For the sake of preserving the environment and protecting pubic health and safety, we urge you to follow our above recommendations.
Thank you in advance for your conscientious consideration.
Very truly yours,
Sharon Rushton, Chairperson