The National Park Service’s preferred alternative for the management of historic ranchlands in the Point Reyes National Seashore and northern reaches of the Golden Gate National Recreation Area supports the continuation of agriculture with leases of up to 20 years and constraints on tule elk. The alternative is one of six options outlined in a draft environmental impact statement released last week and open for comment through Sept. 23.
In a statement last week, seashore superintendent Cicely Muldoon said that species diversity and agriculture can co-exist in the park. “The history of preserving Marin’s incredible open spaces is intertwined with ranchlands,” she said. “The two things come together here in Point Reyes unlike any other national park. It can work, and indeed has worked together for more than 50 years.”
The six alternatives, which guide how the park service will amend the 1980 general management plan for the seashore, align with preliminary concepts released last year but provide greater detail, including an analysis of environmental, economic and cultural impacts.
Though the park lays out extensive land management strategies, mitigation measures and a new zoning framework aimed to reduce the current environmental impact of agriculture in the park, the draft E.I.S. determines that reducing or eliminating agriculture would benefit the soil, water and air. The impacts on the flora and fauna, including federally protected species, are mixed, the report states.
Per the terms of a settlement agreement reached with three environmental advocacy groups, one of the six alternatives would shutter the ranch operations, which reflect a dairying legacy that began in the mid-1800s and now cover about 28,000 acres of park land.
Between the two ends of the spectrum—supporting existing operations and eliminating ranching altogether—the park fleshes out several other options. In one, the park would reduce the acreage for ranching by 7,500 acres; in another, it would discontinue the six operating dairies. Different elk management schemes pair with each of the six alternatives, ranging from letting elk herds grow without interference to eliminating one of the herds.
The park will host a community meeting to gather input at the West Marin School gym on Tuesday, Aug. 27, at 5 p.m.
The preferred alternative
The park’s preferred alternative proposes lease terms of up to 20 years for all existing cattle and dairy operations. Currently, the 24 families that hold leases for ranching on 18,000 acres in the seashore and 10,000 acres in G.G.N.R.A. are operating on one-year permits until 2022, by which time the park service must amend the general management plan.
Before the litigation, ranchers had different levels of security: after selling their lands to the park service in the 1960s and ’70s, most owners negotiated a reservation of use and occupancy, which evolved into leases with five- or 10-year terms.
The draft E.I.S. affirms that the seashore’s enabling legislation and subsequent amendments allow the park to authorize lease agreements to ranchers, and describes recent directives handed down from the top that have pushed the park service to standardize the agreements and allow for 20-year terms.
In 2012, in response to outcry over the closure of Drakes Bay Oyster Company, then-Secretary of the Interior Ken Salazar ordered the park to issue 20-year agreements to show a commitment to continuing the agricultural legacy.
Last fall, Representative Jared Huffman introduced a bill that sought to codify that directive by amending the seashore’s enabling legislation. Although it passed the House with bipartisan support, the bill never made it to the Senate floor. In February, Rep. Huffman and Senator Dianne Feinstein successfully pushed to add a new directive from Congress into the Consolidated Appropriations Act of 2019: “multi-generational ranching and dairying is important both ecologically and economically” and is “fully consistent with Congress’s intent for the management of Point Reyes National Seashore.”
The park cites this history in the draft, emphasizing congressional support for its preferred alternative.
In addition to proposing 20-year leases for ranching operations, the preferred alternative proposes a never-before-seen zoning framework by which the park would manage the agricultural lands.
A “ranchland zone” would replace the “pastoral land” and “pastoral landscape management” zones in the 1980 general management plan—the most recent comprehensive management document the park service has for the seashore.
The new ranchland zone would encompass 28,700 acres across the seashore and G.G.N.R.A., a number that roughly matches the currently leased lands and includes 7,600 acres not described in the 1980 plan. (For perspective, the two parks encompass 153,027 acres.)
Within the ranchland zone, the preferred alternative would create several designations: the ranch core subzone, the range subzone, the pasture subzone and the resource protection subzone.
“This subzoning framework is based on resource sensitivity,” the draft E.I.S. states. “The subzones were developed based on analysis of topography, existing sensitive resource information, and ranch management activities. By implementing a subzoning framework, [the park] can better ensure resource protection by directing where more intensive activities are conducted.”
Accounting for less than 1 percent of the total projected leased area, the ranch core subzone is identified as the already-developed complex of buildings and structures on ranches. In the core, ranchers would be allowed to board horses and raise chickens, pigs, sheep and goats, and have small-scale dairy processing operations, such as for cheese.
They would also be able to grow up to 2.5 acres of row crops, though without irrigation or tilling. In the cores, they might also be allowed to conduct ranch tours or farm stays, in alignment with the park’s goals for education and interpretation.
The second subzone, the range, accounts for 65 percent of the total leased area. Here the park would authorize grazing, but not other agricultural activities, due to the presence of sensitive resources: slopes greater than 20 percent, rare plants, wetlands, riparian and pond habitats, forested areas and critical habitat for threatened and endangered species.
The third subzone, the pasture, accounts for 9,000 acres—nearly 34 percent of the area under lease. In this zone, ranchers could diversify, producing hay, haylage and silage, and raise chickens, sheep and goats.
The last subzone, resource protection, would prohibit grazing; it is designed to protect park resources, including surface waters, threatened and endangered species habitat, and cultural resources. To create this 2,600-acre subzone, the park would discontinue ranching on 1,200 acres.
Under the preferred alternative, each ranching family would be required to enter into a ranch operating agreement, or R.O.A., which would identify the types of allowed ranching and diversification activities, maintenance requirements and any environmental mitigation measures. An R.O.A. would be developed with each rancher and updated or reauthorized following an annual meeting.
If the park adopts the preferred alternative, it projects maintaining the number of cattle in the park today: 2,400 heads of beef cattle and 3,130 dairy cows.
Yet the park says it will also make annual adjustments to these numbers based on ongoing research—including the use of a rangeland forage production model, input from ranchers and the park’s range program manager, guidelines from the United States Department of Agriculture, and a continued analysis of ground conditions, weather and climate.
What about elk? Under the preferred alternative, park employees would manage just one of the park’s three tule elk populations, the Drakes Beach herd. That population would be brought down by just four individuals, from its current 124 to 120—a number that California Fish and Wildlife and the park service determined would not conflict with current ranch operations. The agencies based that number on the elk’s estimated forage consumption, forage productivity on ranches, the time elk spend on ranches and the park’s projected management capacity.
To keep the Drakes Beach herd at 120 individuals, the park estimates that employees would have to cull 10 to 15 elk each year, in addition to continuing current hazing practices to contain the herd to one area, which the draft defines as stretching from Barries Bay in Drakes Estero to the boundary between B and C Ranches.
Park employees would be tasked with shooting the elk; the draft E.I.S. discounts other means of population control, including translocation, contraceptives, introducing natural predators like wolves, improving habitat and increased fencing.
Besides managing the Drakes Beach herd, the preferred alternative would not allow any new elk herds to establish, but it would allow for lethal removal should the Limantour herd wander from its current range, which the draft E.I.S. defines as an expansive area extending from near Coast Camp north all the way to L Ranch.
For context, the park service introduced tule elk to a fenced area on Tomales Point in 1978 and, 20 years later, moved some individuals to an area above Limantour Beach to establish a free-ranging herd. Some of those elk wandered into the pastoral zone, establishing what is now referred to as the Drakes Beach herd.
Besides elk and lease agreements, there are several other provisions in the preferred alternative.
The park service this year designated two historic districts—the Point Reyes Peninsula Dairy Ranches and the Olema Valley Dairy Ranches—which includes much of the area discussed in the draft E.I.S. The park must follow standards defined by the Secretary of the Interior’s “Treatment of Historic Properties,” which includes guidelines for preservation, rehabilitation, restoration and reconstruction.
In the preferred alternative, the park would interpret the preservation of buildings in those districts as allowing possible new uses, including expanding day use and overnight accommodations. “These activities would be focused in previously developed areas, such as former ranch complexes, and would take advantage of adaptive reuse of historic buildings where possible,” the draft states.
Concessions—such as a hostel in buildings or a campground in pastures—would be considered, along with new locations for administrative and volunteer accommodations, educational camps and sites for day-use activities.
The park also hopes to improve hiking, biking and equestrian access in the planning area through enhanced trail connections. The preferred alternative would explore additional or expanded shuttle use, seek improvements to parking at trailheads to improve visitor safety and facilitate access to trails and other park destinations.
The E.I.S. finds several visitor-related problems—parking, crowding and congestion, trash and waste—and commits to monitoring visitor use. It outlines a methodology for determining a visitor threshold based on guidelines from the Interagency Visitor Use Management Council, a collaborative six agency council that includes the park service.
The alternatives
The preferred alternative is one of six alternatives.
The second option mimics the first, except that the park would fully remove the Drakes Beach herd either by “using agency-managed, contractor-led lethal removal methods” or translocating them.
The draft E.I.S. describes cooperation with Fish and Wildlife for this process: “Removal of the Drakes Beach herd, which would occur during daylight hours and outside the calving and rut seasons, is anticipated to be a one-time event, lasting approximately four to six months.” During the removal, portions of roads would be closed for short durations, and the park would evaluate options to donate the meat.
The third alternative would keep things as they are—a possibility the park had to define as a requirement of the California Environmental Quality Act.
In this no-action alternative, the park service would issue new leases with terms of five or 10 years to the families who have current beef and dairy operations.
Park employees would continue to try to reduce the impact of elk on ranches by hazing, habitat enhancements and fence repairs; they would not alter or limit population levels or geographic reaches. In collaboration with Fish and Wildlife, however, the park might also capture and move or lethally remove any elk that leave the seashore.
Under this option, the park would continue to rely on the 1980 general management plan for guidance. That 55-page document—which does not address many of the issues kicked up in the last few decades, such as the expansion of tule elk, climate change, increased visitation and more—was the subject of the lawsuit that resulted in the park’s preparation of the draft E.I.S. in the first place.
In recent years, rather than updating the general management plan, which national parks seek to do every 15 years, the park service was busy writing a narrower plan, the Ranch Comprehensive Management Plan, in response to Sec. Salazar’s directive. The environmental groups that sued the park—the Center for Biological Diversity, the Resource Renewal Institute and the Western Watershed Project—argued that plan was biased toward continued ranching and had not considered a “full range of alternatives” as mandated by the National Environmental Quality Act.
Initially seeking a complete update of the seashore’s general management plan, the groups agreed on the amendment in a settlement. According to the agreement, the amendment must consider at minimum three predetermined scenarios that would eliminate or reduce ranching and dairying.
The other alternatives in the draft E.I.S. correspond to this agreement.
The fourth scenario aligns with the preferred alternative, with the exception that the ranchers would not be allowed to diversify and a total of 7,500 acres would be phased out of ranching over a one-year period. That acreage—which focuses on areas where ranchers currently do not live or that are outside the historic district boundary areas—would become part of the resource protection subzone, which would then total 9,800 acres.
The area that would be decommissioned includes two life estates that would be discontinued following their expiration, the Percy and Niman Ranches.
With the removal of 7,500 acres of ranching, the park’s heads of beef cattle would shrink from 2,400 to 1,700, while the 3,130 dairy animals would remain. For pastures removed from grazing, “the determination of need and level of prescribed grazing would be driven by [park] resource management goals and objectives,” the draft E.I.S. states.
In the fifth, no-dairying alternative, dairies would be phased out over a period of up to five years, though dairy ranchers would be eligible to convert to cattle operations. Diversification activities would not be authorized, and the park service would not take action to limit the growth or geographic extent of tule elk.
In the last scenario, ranch operations with developed complexes would be phased out over a five-year period or, for the two life estates, after those estates expire. Under the alternative, the park would create a new management zone called the “Point Reyes Peninsula/Olema Valley” zone, which would replace the pastoral zones in the 1980 general management plan.
This 28,700-acre zone would be managed to support five desired conditions: the preservation of ecological function; the preservation of native species, including threatened and endangered species; the management of invasive and non-native species; the preservation of cultural resources; and public use and enjoyment and visitor experience.
In this scenario, grazing would be conducted through park contracts, at a scale of 100 to 200 animals or fewer and only in the spring through fall to avoid the wet season.
A “historic ranch preservation” subzone would be newly managed for the adaptive reuse of ranch complexes associated with the two historic districts.
The park would first consider if the structure or complex is needed and could be sufficiently used for park operational uses, including housing, operations, visitor services, or partner uses. If the park does not find a use, it could issue a request for proposals. If ultimately no use could be found, the park would consider demolishing the structures after consulting the State Historic Preservation Office.
Once it eliminated ranching, the park would need to conduct additional planning for increased visitor use that comprehensively evaluates an expansion of trail-based recreation, day use and overnight opportunities. In this no-ranching scenario, the park would release the fenced herd at Tomales Point. Based on preliminary modeling, the existing free-range herds at Drakes Beach and Limantour could potentially expand to 2,000 individuals over a 20-year period. With the absence of cattle, the herds likely would not grow to a level that would require population management.
Environmental impacts
The draft E.I.S. analyzes the beneficial and adverse impacts on the “human environment”—which it defines as the physical, natural, cultural, and socioeconomic resources—that would result from implementing any of the options considered.
Reducing ranchlands by 7,600 acres—through the reduced-ranching alternative—would result in the loss of $500,000 in beef cattle sales in Marin and 19 jobs on the ranchlands. Converting the dairies to beef cattle operations, as outlined in the fifth alternative, would result in the loss of $14.4 million in annual revenue and 27 jobs. The cessation of ranching altogether would mean a loss of $16 million in annual revenue and 63 jobs.
All the alternatives that maintain ranching align with the requirements of the two historic districts. Eliminating ranching, on the other hand, would be problematic: “Low-priority structures may deteriorate or be demolished if in poor condition, potentially resulting in long-term, adverse impacts on those properties and the National Register districts to which they contribute.” The report adds, “Loss of pastures that are considered contributing sites could cause them to lose the integrity necessary to retain eligibility for listing in the National Register.”
The park projects that removing the Drakes Beach elk herd and reducing ranching would negatively impact visitor use. In the case of eliminating ranching, the park saw it two ways. On the one hand, “removing ranching operations would eliminate a unique experience for visitors to experience the role of coastal prairie ranching in California and in the historic districts,” and on the other hand, other visitor opportunities related to “experiencing natural sights and sounds would be expanded,” the report states.
The environmental consequences of continued ranching and dairying—including soil health and air and water quality—are painted in a largely negative light. Removing dairies and reducing or eliminating ranching would be largely beneficial on these three counts, the draft asserts.
Yet by establishing new management activity standards and mitigation measures, and by implementing a zoning framework that would ensure more intense land uses occur in areas without sensitive resources, the park said the impact to soils, air and water quality would improve from today’s conditions.
In terms of the impact on endangered and threatened species, the E.I.S. found both pros and cons to agriculture. Dairies and ranches impact habitat by disturbance, trampling, erosion and nutrient inputs; however, without the cattle, “ecological succession would occur as grassland habitats transition into shrubland or forested habitats, which would increase habitat for some but decrease it for others.”
Without grazing, the park described a possible increase in invasive annual and perennial species, such as thistles and grasses; a decrease in the abundance and richness of native forb species; shrub encroachment into coastal prairie areas; and an increase in vegetative fuels.
The General Management Plan Amendment Draft Environmental Impact Statement”can be found and commented upon on the seashore’s website, under “amendment and environmental impact statement,” under “document list,” under “document contents.”