In our op-ed last month, we criticized Point Reyes National Seashore officials for spending millions of taxpayer dollars on planning efforts that produce many documents but few binding results. For example, the 1998 elk management plan and environment assessment gained the status of law when it was registered with the federal government through a record of decision. Yet that plan is apparently not being used, either to manage tule elk or as a baseline for current elk-management planning.
In this piece we explore the details of one of the ranch planning documents, a grazing plan prepared for the park service by the University of California, Berkeley and published in August 2018. The plan is more a report about how to plan than a plan in itself. Although its recommendations for action sound as if they are meant to be imposed broadly (“Develop a comprehensive monitoring plan,” “Require wildlife escape ramps in all troughs,” “Include land use regulations in [seashore] leases,”) the report also states, “Most rangeland management objectives are best addressed in individual ranch management plans.” Later it adds, “Grazing capacity, stocking rate calculations, and recommendations are best developed at the ranch scale.”
Dr. James Bartolome, head of Berkeley’s Range Ecology Lab, which prepared the report, confirms that ranch-scale planning is the intent. “The key is how the individual plans will be written,” he told us. “The overall plan sets the benchmarks,” while final decisions require “direct interaction with individual ranchers.” Dr. Bartolome expects to be personally involved in the development of these individual plans, and we hope that will happen: he is an experienced rangeland manager with deep knowledge of Point Reyes.
Although our review of the Berkeley report found an anti-ranching bias, Dr. Bartolome sees things differently. One of the recommendations that strikes us as entirely inappropriate is to “incorporate tule elk use into stocking rate and residual dry matter calculations for individual ranch plans as applicable.” We read that as a clear indication that the elk will be allowed to stay in the pastoral zone, a major point of contention. Dr. Bartolome disagreed with this assessment, saying “that doesn’t bother me; it doesn’t imply a level of use.”
It’s certainly true that, technically, this recommendation presents no threat if the tule elk use of ranch forage is zero. Nevertheless, it makes us uneasy. We view the report with frank suspicion because of its resemblance to the documents used to justify the shutdown of Drakes Bay Oyster Company. For example, just as in the environmental impact statement on the oyster farm, the Berkeley report discusses environmental impacts that are merely potential impacts, often based on sheer speculation.
The grazing report’s tables 2 and 3 summarize “possible grazing effects” on the “numerous special status wildlife species that occur in [seashore]-managed grazing areas.” The data itself makes it clear that livestock grazing improves conditions for several of these species, including the Myrtle’s silverspot butterfly, San Francisco owl’s clover, and the endangered Sonoma alopecurus, Sonoma spineflower and Marin western flax. For all of these plants, livestock grazing is known to be helpful. For everything else listed in the tables, the impact is either unknown or speculative. For example, the report states that “Livestock may trample eggs” of Western pond turtles; we can see how they might, but there is no data here or anywhere that we know of to suggest that the pond turtle is a problem in Point Reyes.
Based on the data, the report could have easily included a paragraph about the benefits of livestock grazing for special-status species. Instead, the data is presented in tables, with a column labeled “Potential effects of livestock grazing and associated impacts.” Because the general public tends to assume that such effects and impacts are negative rather than positive, presenting the material in this way creates the impression that livestock grazing is causing problems for the environment. After all, although elk are discussed throughout the report, the tables do not list the impacts elk have on special-status species. Aren’t they just as likely to trample on turtle eggs?
This pattern of over-emphasizing the impact of cattle and ignoring the impact of elk is found throughout the report. There is no mention of elk depredations that have been harming ranch resources and cattle for years, despite the fact that the 1998 elk plan—the controlling legal document on elk management at Point Reyes—says on page 1 that “issues of special concern to reviewers were the effects of the elk on the carrying capacity of their environment, the effect of elk on adjacent landowners, ranchers, and threatened and endangered species, and the need to continually monitor potential impacts.”
Fast-forward to the Berkeley report again, and elk grazing is presented as if it is just as beneficial to pasture as livestock grazing is. This language will likely be used to justify the displacement of agriculture from the pastoral zone, as it suggests that elk provide the same ecosystem benefits as cattle. But while cattle can be managed to meet precise ecosystem objectives (implicit in the concept of a grazing management plan), elk clearly cannot, as graphically demonstrated by the abject failure of the 1998 elk management plan. Cattle can be monitored and moved as needed to meet management goals; elk go wherever they want, graze selectively and impact the environment, for better or worse, as they please.
We believe there is room for both elk and agriculture at Point Reyes. Socially, economically and for the health of the ecosystem, it makes sense to keep both. But although 100 years of range-management science make it clear that cattle can be a powerful and beneficial tool for the management of rangeland ecosystems—including by improving habitat for native grazers—20 years of empirical evidence from throughout California, Oregon, Washington and Idaho makes it clear that the failure to prevent elk impacts in the pastoral zone will mean the end of agriculture at Point Reyes.
This grazing report is just one of the many examples of how the park service stacks the deck to favor its preferred outcome; it’s a standard tactic to commission a report from a source the public trusts and then use the results in a highly selective manner. The park service has a history of misusing scientific information. Keep this in mind when reviewing the newly released draft of the ranch-planning environmental impact statement. Read with a critical eye, then make your voice heard, both within the formal process and with your elected officials.
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.