The mythical park planning process


For decades now, National Park Service officials at the Point Reyes National Seashore have been conducting formal planning processes, one after another. But for all the time and money spent on planning, nothing seems to stick.

In 1998, the seashore published an elk management plan and environmental assessment that stated, “The Park Service has a responsibility to be a good neighbor to adjacent and nearby landowners. Anticipating the effects of tule elk management strategies on the property or perceptions of neighbors is an important consideration. Any depredations by elk on fences, crops or other property would require mitigation actions to correct or avoid problems.”

But when the elk wreaked havoc on the ranches in the park’s pastoral zone, goring cows, damaging fences and grazing illegally on privately managed agricultural land, park officials said their elk management plan was irrelevant. What are these plans for, if not to be followed?

In addition to creating plans it doesn’t follow, the seashore has a habit of creating plans it doesn’t need.

In 2006, shortly after rancher Kevin Lunny revitalized the oyster farm in Drakes Estero, then-Superintendent Don Neubacher falsely accused him of environmental crimes. When Mr. Lunny went through channels to set the record straight, a strange thing happened: The seashore decided to conduct a formal planning process to create an environmental impact statement on the oyster farm.

The National Environmental Protection Act requires an environmental impact assessment for “major federal actions significantly affecting the environment.” 

But no changes to the environment were being contemplated. At issue was a simple permit for a farming activity that had been going on since at least the 1930s. Why did the seashore spend several years and millions of taxpayer dollars writing an environment impact statement for Drakes Bay Oyster Company’s special use permit?

Perhaps because it provided cover for the false park service narrative about the oyster farm. A 750-page document full of charts and figures published by a federal agency looks credible. And most people aren’t going to read it. 

Despite clear evidence of fraud in the report, on November 30, 2012, then-Interior Secretary Ken Salazar denied the permit, shutting down the historic oyster farm.  

At the same time, citing the historical importance of agriculture at Point Reyes, Secretary Salazar also directed the park service to provide 20-year permits to the seashore ranches. 

The seashore’s response was to launch yet another planning process. The ranch comprehensive management plan began in April 2014, and was stopped in 2016 by a complicated lawsuit that was settled in 2017. The groups that sued argued that the seashore should be forced to update its general management plan, last issued in 1980, rather than initiating the ranch planning process. Park service policy calls for updating G.M.P.s every 15 years, but, after 40 years, instead of updating its general plan, the seashore is now writing an amendment to the plan, along with an environmental impact statement focused mostly on ranching. 

So the new ranch planning process looks quite a bit like the old ranch planning process, but after four years of planning, we’re still at the beginning. The draft E.I.S. is expected to be published this month. 

The public is being told that this planning process is on track and that the next step is this formal document that spells out the studied alternatives, which will formally be submitted for public review. Yet two other documents are being circulated without fanfare:  A so-called grazing plan, prepared last summer by a group of University of California, Berkeley graduate students, and a 344-page natural resources condition assessment for the seashore, also written by U.C. Berkeley and dated March 2019. 

If you happen to stumble upon the existence of these two documents, you will read that they “will help inform the General Management Plan Amendment and the individual ranch operating agreements for Point Reyes National Seashore.” Yet neither document appears on the planning page with the other background documents. Both are unabashedly biased against ranching. 

To those of us who lived through the Drakes Bay Oyster Company tragedy, this is all frighteningly familiar.

The Secretary of the Interior’s decision memo didn’t direct the park service to conduct a planning process; it directed the seashore to issue 20-year ranch agreements. Jon Jarvis, the national director of the park service at the time, wrote the authorization memo for those agreements on Jan. 31, 2013. The seashore could have issued 20-year leases the next day. 

It’s time to end this expensive charade. Congress should order the seashore to protect agriculture at Point Reyes and to provide the 20-year agreements that were promised seven years ago. 


Phyllis Faber, of Mill Valley, is a wetlands biologist, a former member of the California Coastal Commission 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.