EAC Generally Supports Alternative B for the Tomales Point Area Plan

Amina Khribeche, Legal & Policy Intern | Photo: Grace Milstein

Last month, we submitted comments to the National Parks Service (NPS) regarding changes to the Tomales Point Area Plan. Once finalized, this plan will replace the 1998 Tule Elk Management Plan and the 1980 General Management Plan for the park. The current outdated management plan does not address key issues related to the management of the wildlife resources within Tomales Point amidst the current impacts of climate change. 

We have been involved in reviewing the plan and previously submitted public comments to NPS during the public scoping comment period in fall 2023. In our most recent comments, we are generally supportive of the removal of the elk fence (Alternative B), while raising several additional concerns.

Background

In 1978, NPS reintroduced ten of California’s last surviving tule elk (Cervus elaphus nannodes) to the National Seashore. The reintroduction of the tule elk to the Seashore was a success. Today, Tomales Point is home to hundreds of tule elk. 

Over the past decade, Marin County has experienced two historic droughts with alarming severity and frequency. Within the 2,900-acre planning area of Tomales Point, there is a confined herd of tule elk. The elk are blocked by a three-mile-long fence that prevents them from traveling beyond the reserve to forage and find water sources. Because of the confinement, the elk at times have struggled to find food and water. The established management plan for the Tomales Point area does not include guidance for these drought conditions or consider the future impacts of climate change. 

Since the beginning of the project in spring 2022, the NPS has been updating its management plan and environmental assessment to address this issue, as well as wilderness management, visitor use at the historic Pierce Ranch, and co-stewardship with the Federated Indians of Graton Rancheria (FIGR). The primary issue of interest in the plan for EAC is the management plan for the tule elk. 

We Generally Support Alternative B, Removing the Elk Fence (the NPS Preferred Alternative)

In May of this year, NPS released the Tomales Point Area Plan Environmental Assessment. The Environmental Assessment proposed a no-action alternative, alternative A, along with two action alternatives, alternatives B and C. 

While alternatives B and C shared common elements, each proposed different approaches to addressing the needs for the proposed action by NPS. Over the 30-day comment period that began on May 6th, EAC staff and interns collaborated with members of our Board of Directors to write a letter of general support for the NPS preferred alternative, Alternative B, while raising some concerns. Alternative A does not address the emergent challenges of conserving the resources in the Tomales Point area. Alternative C would allow for the retention of the elk enclosure fence and population controls for the tule elk herd, including lethal methods (culling).

Alternative B prioritizes removing the existing elk enclosure fence, improving visitor amenities, and exploring adaptive reuse of the Pierce Ranch core area. This alternative most closely adheres to several fundamental principles for managing National Park resources, the Point Reyes National Seashore enabling legislation, Phillip Burton Wilderness Area, science-based management requirements, and interagency cooperation. 

Further Comments for Consideration

Although we generally support Alternative B, we proposed additional revisions and comments to NPS to address gaps in the environmental assessment: 

1. request for NPS to provide additional information on planned methods of elk management; 

2. additional information on the planned use and implementation of “wildlife-friendly” fences; 

3. provide additional clarity in the environmental assessment (EA), that before additional development actions are taken at Tomales Point, there will be additional analysis and public comment opportunities; 

4. add a discussion to the EA related to existing data related to human or visitor carrying capacity; 

5. moving to a location-specific overnight camping reservation system; 

6. monitoring human interaction with wilderness for impact and exploitation while supporting accessibility and; 

7. preservation, enhancement, and restoration of habitat for threatened and endangered wildlife within the planning area and limit pesticide usage.

The final decision for the Tomales Point Area Plan is anticipated this summer. 

Read our comments and partner sign-on letter