Comments on the Great Redwood Trail Draft Master Plan

FOER worked hard to provide detailed comments on the Great Redwood Trail Agency’s (GRTA) nearly 600-page Draft Master Plan for the Great Redwood Trail. In addition to the comments linked below, we submitted location-specific comments using the GRTA’s pdf commenting application focused on locations to expand equitable river access, camping or access sites popular with the rafting community, suggestions for potential partnerships, appropriate opportunities for rerouting the trail, and sites of potential toxic contamination.

The Draft Master Plan has been in the works for about a year and a half and the GRTA plans to publish the final version in summer of 2025.

An old wooden rail structure crosses over a winding stream and cuts into a green hill full of trees.
Future path of the Great Redwood Trail crossing Blue Slide Creek near its confluence with the mainstem Eel River.


A Responsibility for Environmental Remediation

We open our comments with a discussion of the responsibilities of the GRTA, as the successor agency to the North Coast Railroad Authority (NCRA). In 1999 the NCRA entered into an Environmental Consent Decree with several state agencies. This Decree required the NCRA to conduct various types of remediation to address the many environmental harms caused by a century of lawless railroading. Our comments emphasize the legal necessity of environmental restoration. We also encourage the GRTA to evaluate the required remediation through a scientific lens, rather than ranking priority “opportunities” based on available funds or ease of access.


Tribal Consultation and Inclusion

Our comments acknowledge the history of horrible violence and injustice that the State of California has historically perpetuated, as well as the importance of the GRTA making every effort to work collaboratively with Indigenous people. In the Eel River watershed many Indigenous people are not affiliated with formally recognized Tribes, so we encourage the GRTA to go above and beyond the legal requirements for Tribal consultation. Our comments also suggest ways in which the GRTA could clarify communications, for example relating to feasibility of rerouting the trail and the cooperation from private landowners that is necessary to negotiate easements around cultural heritage sites.


Public Safety and Trail Amenities

Public safety is an issue that many locals have raised concerns about. We recognize that backcountry trails are not a new idea and that public safety has been addressed at other trails and publicly-accessible wild spaces around the country. Our comments in this section are largely supportive of recommendations made in the Draft Master Plan to enhance public safety efforts, including the use of backcountry permits, planning for the inevitability that wildfires will impact trail use, using natural elements for access control, and recognizing the difference between public safety concerns associated with illegal cannabis grows and liability concerns of trespassing on legal cannabis cultivation sites.


River Access

The Eel River is a navigable stream and as such public property, up to the high water mark. However, access to the river, which is largely surrounded by private property, is hard to come by. So our comments emphasize the importance of expanding access to the river in the spirit of enhancing equitable access to the outdoors. In both the full comments linked at the end of this post, and in several location-specific comments made on the GRTA’s master planning website, we suggest locations along the right of way that are ideal opportunities for providing river access to the public.


Restoration and Habitat Enhancement

At the very end of the Draft Master Plan is a restoration and habitat enhancement technical memo that we had a number of comments for. Our feedback begins with addressing several inaccurate statements about the future of Eel River dam removal, which even at the time the memo was written were at least a year outdated.

Regarding remediation of fish passage barriers, we had critiques of the GRTA’s methodology in prioritizing restoration projects. The plan largely relies on prioritizations done by others through the lens of competitive fisheries restoration grant funding, but the GRTA bears a different level of responsibility to remediate these problems. Our comments also emphasize that prioritizing stream restoration based on available upstream habitat or a benefit to more than one species is not appropriate at this stage. While we understand that some system for prioritization needs to exist, a master plan document should be evaluating all necessary remediation and leaving the prioritization for later. It’s also important to note that the memo does not consider the benefit of off-channel rearing habitat as necessary to juvenile salmonid growth in making prioritizations based on upstream habitat suitable for spawning.

Finally, we remind the GRTA that per the terms of the 1999 Environmental Consent Decree, the agency is responsible for removing “all visible railroad ties, steel rails, culverts, and/or debris generated by railroad operations that are present in [the] right-of-way, within 150 feet of the high-water mark of the Eel River…or in a place where they can pass into waters of the state.” Again we emphasize that whether railroad debris is removed should not be determined by ease of access or cost, it all must go. We understand that prioritization is necessary, but the master plan should include plans to remediate all environmental harms before prioritization begins.

Click here to read our full comments to the Great Redwood Trail Agency.