Plan and Environmental Impact Statement 600+ Pages Explained in 2,000 Words

The Back Story
Ranches and cattle grazing comprise one-third of the Seashore’s 71,000 acres. Congress established Point Reyes National Seashore in 1962 “to save and preserve, for the purposes of public recreation, benefit, and inspiration, a portion of the diminishing seashore of the United States that remains undeveloped.” The ranchers were well compensated for their land and it was agreed that they could remain in the park for their lifetime or 25 years. They never left.

L Ranch

Endangered Snowy Plover chick

For going on six decades, ranchers and the National Park Service (NPS) have been meeting behind closed doors to decide the terms of the leases that enable ranchers to stay on the public’s land. In that time ranching, which NPS regards as a “historic and cultural resource,” expanded and its impacts continued unmitigated. The heart of the Seashore—once a rare coastal prairie ecosystem—has been transformed by 6,000 beef and dairy cows that eat, trample, and defecate on our national seashore and GGNRA, 365 days a year. They share the Seashore with one hundred native plant and animals species listed as rare, threatened, and endangered.

As the result of a lawsuit in 2016, the NPS is required to produce an Environmental Impact Statement (EIS) on ranching at these national parks. For the first time ever, the public has the opportunity to comment on if and to what extent damaging commercial beef and dairy operations will continue.
 
The Proposed Plan
Seashore management has long favored the ranches over wildlife. That has not changed In the NPS’s proposed General Management Plan Amendment (GMPA).  
 
The NPS considered six alternatives in the GMPA. Continued ranching is proposed in five of these alternatives--Alternatives A through E. One alternative, Alternative F, proposes to phase out ranching over five years.  

The NPS's “preferred alternative,” Alternative B, gives the ranchers what they have long demanded—20-year leases; “diversification” that allows previously unauthorized commercial livestock and crops the Seashore ranchers say they need for income; and the lethal removal of native elk that get in their way. 
 
In the EIS, the Park Service analyzes the Seashore’s carrying capacity based on the maximum number of cattle the land can support based on historical conditions. It determines how many elk the park can support based on what forage is left over—120.

Native Tule elk are the true historic occupants of the Point Reyes peninsula. Thousands were extirpated by the late 1800s as the coastal prairie was overtaken by cattle. The elk's reintroduction to the Seashore in 1978, after a 100-year absence, is a rare success story of species’ recovery.

Bachelor elk herd

In 2016, the NPS disclosed that 250 confined elk had perished during the drought. These elk were fenced off from pasture and water the NPS leases for cattle grazing. The majority of the elk remain confined at Tomales Point. It is a small “free-roaming” herd near Drakes Bay that the ranchers want removed.

Domestic cattle in the Seashore outnumber Tule elk 10-1.

The 6 Alternatives:

Coho, an endangered species

Alternatives A, B, C, D, E all perpetuate ranching, even as the EIS documents the incremental, long term, and cumulative impacts of ranching, such as introduction of invasive plants, destruction of native plants and animals, degradation of habitats, endangered species (fish, amphibians, reptiles, terrestrial and marine mammals), air and water quality.

There is little discussion of ranching’s impacts on the public’s use or enjoyment of the park. The NPS’s "preferred alternative” (B) is described in greatest detail.

Alternative A: No Action
This alternative, required by the National Environmental Policy Act, would allow ranching to continue under 5-10 year leases. The NPS would capture and move, or kill Tule elk that encroach on lands leased for cattle. 
 
Alternative B: NPS's “preferred alternative” 
Issue 20-year leases; establish a "Ranchland Zone" with 3 sub-zones. This would concentrate cattle in one subzone designated for that purpose; and convert some cattle grazing land for “diversification” (raising pigs, goats, sheep, chickens, and row crops). B&B’s and retail farm stands would constitute another subzone.  This alternative would “remove” (aka shoot) 10-15 Tule elk annually in order to maintain a herd of 120 elk at Drakes Bay, as well as any elk that graze on grass leased to ranchers.  
 
Alternative C: Lethal removal of all Drakes Bay Tule Elk
Same as B, but the entire Drakes Bay elk herd would be removed.
 
Alternative D: Reduced ranching  
Same as B; would grant 20-year leases and phase out those ranches with “minimal infrastructure” on 7,500 acres over one year. 
 
Alternative E: Phase out dairy ranches
Dairy farms have more impacts to the park than beef ranches. The six dairy farms would be phased out over 5 years and allowed to convert to beef ranching, eligible for 20-year leases. The Drakes Bay elk herd would be managed at a threshold population of 120.
 
Alternative F:  No ranching. 
Under Alternative F, land dedicated to ranching would be repurposed for "visitor opportunities.” The Tule elk would be allowed to expand their range in the park.
 
Submitting Your Comments  
Comments to the Draft GMPA must be submitted by September 23.
The NPS will only consider comments that are “substantive.” They won’t get counted unless you provide your reasons or facts to support your position, such as: "I come to the Seashore because I want see the wildlife.” "The mission of national parks is to protect native plants and animals.”  "The Environmental Impact Statement says that the land, water, and wildlife of the national seashore are being harmed by the cattle.”
 
Here are some of issues in the Draft GMPA you may wish to discuss in your comments.  

• Diversification: This is included in all the alternatives except No Action (A) and No Ranching (F). It allows each rancher to add crops and small livestock—pigs, sheep, goats, and up to 500 chickens—to their operations. There is no discussion of the impacts of this expanded agriculture on the park’s wildlife or natural resources, such as what happens should park predators take chickens, lambs or other small livestock. The plan takes a “wait and see” approach.

• Historic and cultural resources: The NPS cites its obligation to preserve historic and cultural resources. The ranch buildings and infrastructure are historic, not the cows. It’s neither required nor necessary to permit 6,000 cattle in the park or allow additional agriculture that never before existed at the Seashore in order to preserve the Seashore’s history. This can be done through interpretation. There has never before been interpretation of ranching at the Seashore—historic, cultural or otherwise, other than at Pierce Point, a non-working ranch at Tomales Point. The public has historically been unwelcome at the ranches, some of which have posted No Trespassing signs on land that belongs to the public. Preserving and interpreting historic buildings and perhaps a cow to demonstrate how ranches historically operated, would be sufficient, thereby ending the environmental damage, climate impacts, and other public costs that commercial ranching in the Seashore exacts today.

• Succession: The plan proposes changes regarding “succession” that would, in effect, permanently commit this national park to ranching. Allowing for "multi-generational ranching" was an early accommodation to the ranchers who sold their land for the park. In addition to generous compensation (the equivalent of $340 million in today’s dollars), ranchers were allowed to lease back their land for 25 years or their lifetime. The NPS later agreed to allow ranchers’ offspring to stay on in the park as long as they continued ranching.  After that, the ranches would be retired. In its “preferred alternative” (B) the NPS will not retire the ranches when the offspring of the ranchers retire. Instead, it will offer those leases to other relatives; and if they decline, to neighbors; and if they decline, to anyone who wants to lease land in the park--no prior connection to the Seashore would be required. 

• Mitigation and Restoration: More than a century of ceaseless cattle grazing has altered and diminished the natural ecosystems of the park. The EIS notes impacts to plant and animal species and their habitat from cattle grazing; water pollution from cattle manure runoff; and greenhouse gases and air pollution from cattle operations. None of the alternatives discusses the costs or timeline for mitigating these impacts.  None of the alternatives considers the Seashore’s restoration--what it might cost; where the NPS might focus attention; what the benefits would be to wildlife, water, climate change mitigation, or public visitation and use.

• Organic vs Sustainable: “Organic” certifies that ranchers don’t use synthetic fertilizers, pesticides, antibiotics, or hormones. Sustainable agriculture is not a certification. It is a way of life that sustains the productivity of the land for future generations and minimizes damage to the environment.  Manure runoff polluting the only marine wilderness south of Alaska is not sustainable. Illegally disposing of cattle carcasses around the national seashore is not sustainable. Allowing cattle to give elk and other wildlife life-threatening diseases is not sustainable. Subsidizing and endorsing methane-producing confined animal feeding operations (CAFOs) in an era of climate change is not sustainable. Trucking hay for hundreds of miles as a supplemental feed, because pastures are overstocked and overgrazed, is not sustainable. And yet these practices continue.

• The cost of ranching to our park. The National Park Service has not provided any information on the dollar amount or portion of its budget that goes to ranching-related expenses. Ranching places increasing demands on dwindling park budgets, while park improvements and a backlog of maintenance, along with public programs and interpretation,  go unfunded. Meanwhile, scarce resources go to support 24 ranchers operating in the Seashore, including killing wildlife to benefit their operations. Ranching’s environmental impacts have an untallied economic impact on the Seashore. Internal Park Service memos indicate monitoring the ranches for lease compliance and environmental damages already places outsized demands on the Seashore’s staff and budget. The NPS has failed to enforce lease agreements when leases are violated. Can we expect that expanded agricultural practices will be met with responsible oversight with no expansion of budget to enforce these more complex leases?

• Subsidizing Seashore ranchers: The NPS mission does not include guaranteeing commercial operators a living. Yet, every alternative except No Action (A) and No Ranching (F) allows “diversification” for the purpose of shoring up the ranchers’ bottom line. There is no discussion of diversification impacts to the park. Ranchers in the Seashore already have a competitive advantage over ranches outside the park. Seashore ranchers benefit from discounted grazing fees, below-market-rate housing, and maintenance and improvements to roads, homes, and farm buildings covered at public expense. Seashore ranches pay no property taxes.

• Climate change: Cattle are the leading source of greenhouse gases at the Seashore. Methane, produced by cattle, is a greenhouse gas 25x-100x worse than carbon dioxide. There is no discussion of mitigation for cattle’s impacts to the climate in any of the NPS’s ranching alternatives. 

• Wildlife impacts: Removing native Tule elk from the park to benefit the ranchers is built into four of the NPS alternatives, including the NPS’s “preferred alternative." The EIS says that the Seashore’s land, water and wildlife would benefit were ranching to “cease.” But there is no plan for protecting wildlife from ranching’s impacts or mitigating habitat loss from cattle grazing or growing crops. Other than killing Tule elk, there is no discussion of avoiding wildlife conflicts.

 
Read and comment on the NPS’s Draft plan for the Seashore. The comment deadline is September 23.  

MAKE A 2 MINUTE PHONE CALL!
If you vote in Congressman Jared Huffman’s district (Marin County and coastal counties north to the Oregon border) call him NOW. Huffman is leading the charge to “remove” Tule elk from the Seashore and says he will reintroduce his bill to permanently instate ranching at the Seashore if the Park Service doesn’t give ranchers what they want. He’s heard from the cattle interests. He needs to hear from us. Let Huffman know what you want the future of the Point Reyes Seashore and its native wildlife to be. 415.258.9657