A private firm has sorted the nearly 3,000 comments submitted last fall on the initial concepts for the amendment to the general management plan for the Point Reyes National Seashore and the north district of the Golden Gate National Recreation Area.
The New Jersey-based firm Louis Berger Group, which was contracted by the National Park Service in the planning process for the never-completed ranch comprehensive management plan, assisted with the analysis report that was released last week.
The group combed through and categorized all the correspondence the park service received during the 37-day window it opened last fall for the public to weigh in on the initial six concepts for ranch and elk management on 28,000 acres of the seashore and G.G.N.R.A. This included comments sent by mail, online and made during two open houses in Point Reyes Station and Sausalito.
Park spokeswoman Melanie Gunn said the group pulled out “substantive” comments only. As defined by National Environmental Policy Act guidelines, these comments are solution-oriented and “focus on the purpose and need of the proposed action, the proposed alternatives, the assessment of the environmental impacts of those alternatives and the proposed mitigation.”
Ms. Gunn underscored that comments do not constitute a vote; the park service is more concerned with the content of comments than how often an idea was presented.
The park will use the report to inform and refine the range of alternatives and the initial proposal it presented to the public last October. As the next step in the amendment process, the park expects to publish a notice of intent to prepare an environmental impact statement this fall.
The report divides the comments into categories on a range of topics, including each of the proposed alternatives and a range of specific issues the amendment will tackle, including elk, diversification of agricultural operations, cultural resources, wildlife and species of special concern, visitor use and experience, water resources, lease and permit issues, and others. There are also more general buckets, such as socioeconomics and public health and safety.
Within each category, ideas are listed as “concerns” and it is not specified whether they reflect one or more commenters’ thoughts.
Comments on the alternatives
For the park’s proposed alternative that would eliminate ranching and offer limited elk management, one group of commenters wanted a shorter phase-out period than the park’s proposed five years, and another disapproved of the proposed conversion of some ranchlands for non-profit education, research and recreation activities in favor of an elk preserve. A third urged the park to take down existing elk fences.
About a second park-proposed scenario that includes decommissioning 7,500 of the 28,000 acres leased for ranching as well as increased elk management, there was a suggestion to mitigate any impacts from elk with financial compensation for ranchers.
For the same alternative, the report included comments this newspaper recognized as belonging to the three environmental groups that sued the park in 2016 over the general management plan. Instead of choosing to eliminate ranching on lands where families are not currently living, as the park had suggested, the groups wanted the agency to decommission operations that are “the least compliant with permit terms and conditions, or those operations that are most environmentally harmful.”
Still others suggested removing ranches operated by families that were not the original lessors.
In regard to the park’s initial proposal, which would provide 20-year leases and increased elk management, there was a suggestion to make two revisions. The first was that “ranch families should be free to transfer their ranch interests to appropriate non-family members, including entities that would facilitate the basic goal of prosperous long-term, well-managed ranch operations.” The second was for ranch permits to be extended past 20 years.
For the fourth alternative, which parallels the initial proposal with the addition that the Drakes Beach herd of elk would be removed, commenters wanted the park to develop a plan to contain elk and manage their population.
Others recommended the park evaluate the potential difficulty of removing that herd, including research showing that translocated elk have returned to the Drakes Beach herd, that elk can swim across Drakes Estero and the annual amount of taxpayer dollars used for moving and hazing elk from ranchlands.
There were also a number of ideas for entirely new alternatives. One group of commenters presented a scenario with leases of up to 60 years, requiring the relocation of elk off of the ranching areas and re-evaluating all ranches removed from grazing within the last 20 years. Another suggested that the park encourage the reuse of ranches that have gone out of operation, including the Horick, Wilkins and Jewel Ranches. And a third envisioned an alternative that “ensures that elk and other wildlife have a corridor through which to move between larger habitat areas of Point Reyes.”
Comments on ranching and elk
The analysis report includes a bucket for ranching in general; it primarily includes suggestions for different means of evaluating and managing the impacts of operations.
“Commenters state that carrying capacity of individual ranches for both dry and wet seasons should be determined by independent scientific experts and based on the current condition of grazing lands and climate change. The goal should include allowing the land to recover, restore, and sustain the resource value of the pastoral zone,” the report states.
Another group recommended the park “set resource goals for the pastures and rangeland and require ranchers to meet the resource goals rather than using a strict maximum number of cattle as a management tool.” They continued, “Ranchers could then implement management that would optimize forage production and resource conservation by adapting a year-to-year change.”
Other commenters focused on the park’s stated intention to develop best management practices, encouraging the agency to include carbon farm planning and residual dry matter guides tailored to each ranch and to involve other groups such as the Natural Resources Conservation Service and Marin Resource Conservation District.
Concerning elk, there were suggestions to relocate them from the pastoral zone to the Limantour Wilderness, Tomales Point, the headlands or other state or national parks.
As far as management strategies, fertility control, culling, fencing, designated feeding and watering areas, the introduction of predators, sport hunting and establishing a 1,200-foot buffer around the pastoral zone were all put forth.
Another request was to make elk meat available to local markets.
Still another idea was for the park to “consider use of Miwok management practices to manage tule elk, such as extensive burning, vegetation management and hunting.”
Leases and permits
Commenters offered numerous suggestions regarding what conditions the ranching permits should include. These suggestions included stipulations that ranchers use the land to protect and keep environmental values; the development of best management practices and other natural resource protections; maintenance requirements for road and other park facilities on and around ranches; and guidelines on the acceptable number of livestock.
There was also the request that agreements should clearly state responsibilities, timing and locations for practices as well as provide detailed budgets.
Commenters also suggested that the park develop incentives—such as grants, reduced rent and infrastructure development—for ranchers who actively enhance natural systems.
Others asked for information on lease enforcement problems, past enforcement actions and how the park ensures lease compliance. Commenters suggested that enforcement activities should be performed on a case-by-case basis.
As far as permit lengths, recommendations included 20-year, 20-year with rolling renewal agreements, 10-year exercised at every 20-year midterm, five-year incremental extensions, 25 to 30-year, 50-year, 60-year, 99-year and lifelong leases.
Socioeconomics, visitors, safety
Commenters implored the park service to analyze the benefits of local agricultural production—including the resource management benefits that ranching and dairying provide and the contributions of the industry to the local and regional economy—and how cultural and natural resource preservation and management objectives are successfully met.
Others wanted the park to determine the fair market value of grazing and housing leases and whether that process is consistent with federal policy and processes on other federal lands.
Additionally, the report includes that, “Commenters state that ranching is necessary to keep the economy diverse and note that an over-emphasis on tourism could adversely affect water, sewage and garbage disposal in the park.”
Yet the opposite view on the impact of ranching in relation to tourism was also expressed, with commenters claiming that the presence of fencing, gates, excrement, odors from manure and urine and trampled ground adversely affect visitor use.
Still other commenters argued that if ranching were discontinued, the land would be underutilized because ranch areas are unsuitable for visitors.
There was just one health and safety concern voiced. “Commenters state that the grazing activities, from both cattle and elk, reduce the amount of fuels in the park, thereby preventing wildfires. Commenters also note that the NPS should consider the cost to mitigate fire danger and discuss the concept of using grazing to control fuels,” the report states.
Comments on the process
There were also numerous concerns about the planning process itself.
Commenters suggested that the process should yield a complete update to the park’s general management plan from 1980 “rather than an amendment focused on ranchlands, and that the plan should articulate an overall vision for all resource types and land uses.”
Additionally, they requested that the park clearly define terms whose meaning is not obvious, such as “diversification and operational flexibility,” and that both a glossary and index be provided in the amendment. Other terms they wanted to be defined include “sensitive resources,” “park resources,” “sustainable,” and “promotion of sustainable agriculture.”
Commenters also asked about the establishment of baselines, particularly for new leases and natural conditions. There was the suggestion that the baseline for new leases should be the conditions and practices allowed in the existing leases, as long as leaseholders had not violated their permits. Another suggestion was that an appropriate baseline be established that recognizes that an environment with no human uses at Point Reyes has not existed for centuries.
Commenters also urged the park to use the information gathered for the now-defunct ranch comprehensive management plan in the amendment process. “Commenters suggest that a slow planning process places financial strain on the ranchers because of ongoing uncertainty, and the planning process needs to be completed as quickly as possible,” the report states.