Eight astonishing things you might not have noticed in the D.E.I.S

09/18/2019

We have been reading the draft environmental impact statement for the amendment to the Point Reyes National Seashore’s general management plan, and we are angry.

The document is deceptive. It creates the impression that the park has carefully studied the issues, taken into account everything raised during the scoping process, relied on the best available science, determined the best course of action, and clearly explained the advantages and disadvantages of each alternative. It seems to say the park’s preferred alternative will allow the diversification of operations that the agricultural community seeks and will manage tule elk to prevent harm to cattle and property. For those who care about agriculture, this seems like good news. At the same time, it seems to agree with the anti-ranch contingent that the no-ranching alternative would bring a host of environmental benefits. 

None of this is true. The detailed analyses that will be submitted to the park during the public comment period will make that abundantly clear. In the meantime, here are eight of the most astonishing and outrageous things you might not have noticed. 

1. The preferred alternative seems designed to micro-manage the ranches to death. The pastoral zone described in the park’s enabling legislation would be replaced with a new set of zones that allow the seashore to deny ranchers use of their properties. Sheep and goats are supposedly allowed, but not in the areas where they are needed to control brush. Row crops are supposedly allowed, but the new zoning requires them to be grown in the wrong areas; row crops can’t be irrigated, they must be sown by hand and are limited to two and a half acres. Lethal control of gophers is prohibited. All these restrictions are buried in the 436-page document that makes up the D.E.I.S. appendices.

2. The park is justifying this formal planning process on the basis of a lie. The D.E.I.S. says on page 4: “In 2013, at the direction of the Secretary of the Interior, the NPS Director issued a Delegation of Authority authorizing lease/permit terms for up to 20 years and directing NPS to initiate a National Environmental Policy Act (NEPA) process to evaluate the issuance of long-term leases.” The second part of that sentence is not true. There is no mention of NEPA in either then-Secretary Salazar’s Nov. 29, 2012 decision memo or then-National Park Service Director Jon Jarvis’s Jan. 13, 2013 delegation of authority. More likely, the park used these directives as an excuse to begin a NEPA process to validate the recent proliferation of elk on ranchlands and to further restrict ranching.

3. The elimination of ranching would not benefit the environment; it would endanger native plants and create an enormous fire hazard. You’ll find that on page 139, tucked into the middle of a paragraph about the environmental consequences of the no-ranching alternative: “Over the long term, however, the cessation of ranching may not result in overall beneficial impacts, especially in grasslands, which constitute 48% of the planning area. Rates of shrub encroachment into grasslands, invasive perennial grasses, vegetative fuels (both herbaceous and woody), and the consequent risk of large, intense wildfires are all likely to increase, resulting in adverse impacts on vegetation.” It seems that large, intense wildfires would also result in adverse impacts to wildlife, property and visitor use, and pose a threat to human life. We think those impacts ought to have been mentioned, and we think they ought not be risked.

4. The benefits of livestock grazing on grasslands are so important that if ranching were reduced or eliminated, the park would need to make up for its loss by doing extensive mowing and/or “prescribed grazing”—in other words, it would hire its own herd of cows. (Page 125: “The use of limited prescribed grazing is considered under alternatives with no or reduced livestock grazing because this would mitigate some undesirable impacts of grazing reduction or removal.”)

5. The seashore is not planning to use lethal methods to control or prevent elk depredations on ranches. The preferred alternative includes a plan for controlling the population of the so-called Drakes Beach herd, using lethal control if necessary. That herd is estimated at 124 elk, and the park says it will limit it to 120, strictly as an elk-management issue. When it comes to keeping elk off the ranches, the D.E.I.S. proposes to continue its ineffectual use of hazing. This method does not work, and is cruel to the animals.

6. The D.E.I.S. uses the current range of the roaming elk as its baseline. But the elk were never supposed to be allowed into the pastoral zone. The baseline should be the conditions described under the 1998 elk management plan and environmental assessment, which is just as much of a formal NEPA document as the current D.E.I.S. The park is brazenly disregarding that E.A., using the ridiculous excuse that it didn’t realize things would turn out the way they have; the 1998 plan itself belies that.

7. None of the claims about the environmental impacts of ranching are based on valid data. The D.E.I.S. claims that eliminating ranching would improve water quality and make life better for coho salmon, but on page 44 of the biological assessment prepared by the park as part of this project (found in the appendices) we learn that “the actual effects are likely far reduced from those noted” for six different reasons; in short, cattle are not allowed anywhere near streams. 

The D.E.I.S. claims its March 2019 Natural Resources Condition Assessment found the “total number of invasive plant species and the number of new introductions are high enough to warrant significant concern in the park.” But the assessment also says, “Information was insufficient to determine the trend for invasive plant and rare plant populations,” “the PORE range data set provides information about only one small part of the overall Point Reyes landscape,” and, further, that “none of the indicator rankings were considered to have a high degree of certainty.” 

The D.E.I.S. claims that the elimination of ranching would be beneficial for the California red-legged frog, citing the trampling around stock ponds. But the data clearly shows that the only reason Point Reyes is full of these frogs is that they thrive in the stock ponds: they wouldn’t be here without the ranches.

8. Finally, the D.E.I.S. does not address the viability of the ranches as businesses—not in the purpose and need statement, not in the plan objectives, and not in the dishonest socio-economic analysis, which minimizes the value of production in the seashore by comparing it to the whole region, including Sonoma County vineyards and wineries. The park should consider whether its plan would adversely affect ranch viability. The preferred alternative would implement new restrictions on and requirements of ranchers, add natural resource protections, force ranchers to accept competition with elk, and limit allowed agricultural activities without any consideration of business viability. Twenty-year permits are worthless if the historic ranches can’t survive.

 

Phyllis Faber, of Mill Valley, is a wetlands biologist and co-founder of the Marin Agricultural Land Trust. Sarah Rolph, based in Carlisle, Mass., is writing a book about the shutdown of Drakes Bay Oyster
Company.