Dear EAC Membership,

This is an unusually long letter -- but necessary because the final opportunity to guide fundamental planning for the Point Reyes National Seashore is now. The Seashore needs to hear from you in the next two weeks!

We are writing you to give you information on the planning process and to enable you to submit comments that support the long-term protection of the Seashore’s resources, including the park’s scenery, natural and historic objects, wildlife, and the ecological processes and conditions that created the park.

Click here to read EAC’s quick list on submitting comments

The Seashore initiated a public planning process that seeks to establish guidance for the preservation of natural and cultural resources and the management of infrastructure and visitor use in the planning area. The Draft Environmental Impact Statement (Draft EIS), which is part of the General Management Plan Amendment (or GMPA) process, addresses the future management of Tule elk populations and all currently leased ranch lands. It will be revised into final form taking public comments into account.

What Does This Mean?

The Draft EIS released by the Seashore outlines a framework in which the National Park Service (or NPS) will manage 28,000 acres leased to 24 families operating beef and dairy businesses in the “Ranchland Zone” within the Seashore and the adjacent Golden Gate Recreational Area. These lands would be managed through four subzones categorized as Resource Protection, Range, Pasture, and Ranch Core subzones.

The Draft EIS is required to describe the effects of the proposed activities on the natural and physical environment and the relationship of people with that environment.

National Park Service Preferred Management Plan (alternative B)

The Draft EIS offers six alternative management strategies. The Seashore has designated Alternative B as the “preferred alternative”. This alternative employs the Ranchland zoning framework, adopts new management strategies to achieve desired conditions related to the preservation of resources in the planning area, provides new opportunities and infrastructure for public access, issues up to 20-year leases to existing ranch families to continue beef and dairy operations, authorizes diversification (new types of livestock, crops, and visitor experiences), requires each ranch to operate under a Ranch Operating Agreement (or ROA) that is negotiated with the Seashore and consistent with the Final EIS, preserves characteristics and adaptively reuse complexes or buildings within the Point Reyes Peninsula Dairy Ranches Historic District, and actively manages the Drakes Beach herd of tule elk by lethal removal to maintain a population threshold of 120 animals.

What Started This Whole Thing?

It’s important not to lose sight of the original framework that started this whole process in 2012 when then Secretary of the Interior, Ken Salazar, decided to not renew the lease for Drakes Bay Oyster Company in order to fully designate Drakes Estero as Marine Wilderness. He stated,

…”I direct that the Superintendent work with the operators of the cattle and dairy ranches within the pastoral zone to reaffirm my intention that, consistent with applicable laws and planning processes, recognition of the role of ranching be maintained to pursue extending permits to 20-year terms for the dairy and cattle ranches within the pastoral zone.”

Then in 2013, in his Delegation of Authority, NPS Director Jonathan Jarvis authorized,

“the issuance of lease/permits for the purpose of grazing cattle and operating beef and dairy ranches, along with associated residential uses by the lessees and their immediate families and their employees, and their employees' immediate families, within the pastoral zone of Point Reyes National Seashore and the northern District of Golden Gate National Recreation Area administered by Point Reyes National Seashore. Under this delegation, you may issue lease/permits with terms of up to twenty years. These long-term lease/permits will provide greater certainty for the ranches operating within the national park's pastoral zone and demonstrate the support of the National Park Service (NPS) and the Department of the Interior for the continued presence of dairy and beef ranching operations. (emphasis added)”

Following these directives, the Seashore began the planning process in 2014 to plan to issue long-term leases to the families operating beef and dairy ranches in the Seashore. The Draft EIS is the expression of the legal environmental review process (under the National Environmental Policy Act or NEPA) that is required when a proposed plan will impact park resources.

The Good

The Draft EIS does include several policies that will improve water and air quality, enhance visitor uses, and a framework to implement comprehensive Ranch Operating Agreements that establish environmental mitigations and management metrics that are required to be followed by each ranch and reviewed on an annual basis.

We anticipate that beef and dairy ranches within this framework will receive long-term leases and will be able to implement environmental mitigation measures through partnerships and conservation grant funding to restore and protect sensitive resources and make some improvements to protect and restore natural resources in the Ranchland Zone.

The Bad

Along with the good, there are several areas that we believe have been overlooked and require alterations prior to the issuance of a final EIS. We offer some of our high level thoughts below:

Diversification

Bobcat - Point Reyes National Seashore © Carlos Porrata

Diversification is a movement away from the historic beef and dairy ranching that is stated as a cultural and historic value in the Seashore. Agricultural diversification would introduce a new range agricultural activities, like grazing sheep, goats, keeping pigs, developing row crops, and farm stays and farm stands throughout the Ranchland zone. Diversification activities are limited to the ranch core and pasture subzones and occurs in all alternatives (except in those that would eliminate dairy operations or remove all ranching activities) in the Seashore.

Despite diversification being limited in scope, It is EAC’s opinion, the Draft EIS goes far beyond Secretary Salazar’s “recognition of the role” of established families’ continued beef and dairy ranching to allow new uses in the Ranchland zone based on economic considerations for private businesses.
This is like proposing to manage Yosemite National Park to ensure that hotel operators maintain profitability regardless of market conditions.

Commercial sustainability is not a legitimate NPS management goal. The proposed changes would allow “ranchers to react to fluctuations in the economic market” through a menu of diversification options and lead, foreseeably, to ranchers converging on the highest profit-margin options in the future.

EAC does not believe “buffering market conditions” is an appropriate goal of the Management Plan. Moreover, the proposal for diversification fails to meet that goal even by the NPS’ own analysis, because it fails to identify impacts to park resources in several areas including:

Predation on ranch animals leading to conflicts with wildlife,
Impacts on roads and park infrastructure with increases in commercial traffic,
Damage to the scenic and historic values of the Seashore as the ranch cores and historic pastures will be changed to support new uses,
And the application of adaptive reuse plans within the historic district to buildings, structures, objects, and landscapes (outside of priorities for interpretation, visitor use, or administrative use) is probably inconsistent with NPS management guidance for historic preservation.

EAC does not support diversification activities that would allow the Seashore to authorize non-beef and dairy ranching agricultural practices in the future based on market conditions.

EAC does not oppose ranch leases that ensure that multi-generational, environmentally sustainable beef and dairy ranching, as long as the leases protect the natural resources and visitor experiences within the park, continues.

Diversification needs to be removed from all alternatives as it is outside the scope of the Draft EIS. The Seashore lacks the authority to consider diversification, and fails to analyze all foreseeable impacts of the proposed changes in use on Seashore resources.

Succession

The Seashore’s proposed policy for managing rancher succession policy will determine who will take over a ranch lease once it has expired or if the primary lease holder is no longer able to ranch or has passed away.

The Seashore’s proposed policy again strays away from the directives that emphasize multi-generational beef and dairy ranching. Rather, the proposed policy creates a new opportunity for any individual (a rancher from outside the Ranchland Zone) to apply to take over a lease through an open Request for Proposals that would continue ranching activities. In keeping with the original intentions of the public planning process, continuation of ranching should focus on the cultural and historical significance of multi-generational beef and dairy ranching.

This moves away from the historic and cultural values to allow existing ranch families to continue to operate and opens up the opportunity for anyone to come in and operate in the park.

Finally, the Seashore failed to analyze the impacts of outside commercial operations in facilitating ongoing ranching activities and/or subletting activities that could occur with the proposed diversified uses.

Just these two topic areas – diversification and rancher succession – beg the question, how is this plan compatible with the park values for historic multi-generational ranching?

The framework allows for a future where the Seashore could be fundamentally altered and has a high potential to be incompatible with the purpose of the Seashore and the Organic Act to preserve the park unimpaired for the use and enjoyment of future generations.

Increased Visitor Usage in Marine Wilderness

Overlooking Drakes Estero Marine Wilderness (Schooner Bay) © Sarah Killingsworth

Drakes Estero Marine Wilderness, the most pristine estuary in the Bay Area, according to a new study by the National Ocean and Atmospheric Administration, where 97% of the historic tidal habitats remains. In stark comparison to San Francisco Bay where only 17% of historic habitats remain. Since 2013, the Seashore has spent millions of dollars restoring the Estero following the closure of the oyster farm.

The Seashore proposes expanding visitor uses by allowing boat-in camping within Drakes Estero and camping along the shores of Schooner Bay. Over the years, the Seashore has had to close boat in camping facilities along Tomales Bay at locations like Jacks Landing, due to human waste, garbage, and destruction of cultural resources.

The Seashore does not have the resources to manage boat-in camping along the shores of the Estero and has failed to explore all of the environmental impacts to the marine wilderness area in the Draft EIS. The Seashore should remove any consideration of camping and boat-in camping along the shores of the Estero to increase visitor uses.

Considerations for Funding

The Draft EIS is missing a budget and financial overview that outlines how any of the alternatives and actions will be implemented and paid for. The Seashore funding has been in decline, without a proposed budget it is impossible for the public to understand how the Ranch Operating Agreements will be implemented. Without this information made available to the public there may be negative impacts to to natural resources management, visitor services, and other vital existing park programs to protect the environment that have been overlooked.

The Ugly

Tule Elk

The Seashore is the only National Park with a native population of tule elk. The elk have been prevalent in the Bay Area and Marin for thousands of years, long before their extirpation in the 19th century. Tule elk are considered natural resources and constitute an important part of the Seashore’s ecosystem. Although tule elk are not a listed pursuant to the state or federal Endangered Species Acts, they are an important natural resource for the Seashore that should be considered in addition to the lease/permit obligations that the Seashore holds. Removal of the Drakes Beach herd will have negative impacts on visitor experiences within the Seashore and brings back unsettling memories of the removal of the nonnative axis deer.

Any strategies to manage the elk populations should be in the context of managing resources like other natural resources within the Seashore and not for the benefit of commercial lease holders.

The GMPA should protect and manage natural resources, including tule elk, with conservation of these resources as the highest priority, as mandated by the Seashore’s mission and current NPS management policies. Long-term leases and overall management strategies should strive to reduce conflicts and find non-lethal management strategies to balance and accommodate the presence of elk and cattle.

Finally, an impact not analyzed by the Draft EIS includes future conflicts with other Seashore wildlife to protect commercial rancher interests. In the future, if sheep, goats, and chickens are added to the pastoral zones, there will be wildlife conflicts.

The Draft EIS outlines a concerning future guidance for NPS to manage wildlife to protect commercial interests. How long before management of coyotes, foxes, bobcats and badgers are implemented as well if diversification is allowed to occur?

EAC’s Comments

EAC is currently working on our comments and will not support any proposed alternative. Our comments will provide a comprehensive and legal review of the Draft EIS. Please contact our office with questions. We do not plan to have comments ready until September 20, 2019.

Thank you for your continued support of EAC. Our work is made possible by our membership support.

In gratitude,

Morgan Patton, Executive Director
Bridger Mitchell, Board President & Lands Committee Chair
Terence Carroll, Treasurer & Lands Committee Member
Sarah Killingswoth, Esq. Director & Lands Committee Member
David Wimpfheimer, Director & Lands Committee Member

Why You Must Get Involved, NOW!

This is the last stage for public involvement. The Draft EIS and public comment will be used to inform the Final EIS. Your voice is needed to provide comments on the Draft EIS that will not be ignored. In order to do this, you need to let the Seashore and NPS know that they have not analyzed all foreseeable impacts in their plan.

To comment effectively, focus your comments on the purpose and need of the proposed action, the proposed alternatives, the assessment of environmental impacts, and proposed mitigations. What did they overlook, what was not considered, etc. Comments are not a form of voting for an alternative and template form letters are not useful tools at this stage.

suggestions for your comments

Diversification Impacts:

Predation on ranch animals leading to conflicts with wildlife,
Impacts on roads and park infrastructure with increases in commercial traffic,
Damage to the scenic and historic values of the Seashore as the ranch cores and historic pastures will be changed to support new uses,
And the application of adaptive reuse plans within the historic district to buildings, structures, objects, and landscapes (outside of priorities for interpretation, visitor use, or administrative use) is probably inconsistent with NPS management guidance for historic preservation.

Succession Impacts:

The Request for Proposals from the public changes the context and values of the Ranchland zone being multi-generational beef and dairy operations, and these impacts are not sufficiently addressed.
Failed to analyze outside the interest of outside commercial operations in facilitating ongoing ranching activities and/or subletting activities that could occur with the proposed diversified uses.

Increased Visitor Use in Drakes Estero:

Environmental impacts such as human waste, garbage, and potential for destruction of park and cultural resources has not been fully examined as part of the draft EIS.
In light of NPS requirements to close down boat-in camps in other areas of the Seashore due to these problems new boat in sites near sensitive Marine Wilderness should not be considered.

FUNDING CONSIDERATIONS

The Draft EIS is missing a budget or financial overview that outlines how any of the alternatives and actions will be implemented and paid for. Without this information made available to the public there may be negative impacts to to natural resources management, visitor services, and other vital existing park programs to protect the environment that have been overlooked.