According to some of the ranchers in the Point Reyes National Seashore, the park service is poorly versed in the management of sustainable agricultural lands—and that is both a serious threat to their operations and a missed opportunity.
In a letter submitted this fall to seashore superintendent Cicely Muldoon, the Point Reyes Seashore Ranchers Association—which represents 13 of the 24 families who lease lands within the seashore’s jurisdiction—argues that the draft environmental impact statement associated with the impending update of the park’s general management plan fails to recognize the ecological benefits of their stewardship.
Due for publication next spring, the final environmental impact statement will amend the general management plan for the seashore and the northern reaches of the Golden Gate National Recreation Area. The document will determine how the 28,000 acres currently leased for ranching within that area will be managed into the future, including potentially discontinuing agriculture altogether.
Joining thousands of commenters nationwide, the association submitted feedback on the draft statement, released in August, which outlined six possible management schemes. Among the options, the ranchers generally support the park’s preferred alternative, which allows diversification, 20-year leases for existing operations, and population control of one of the three herds of elk that roam the peninsula.
Yet the association also called for significant changes. Their letter, as well as several others submitted by ranchers independently, illustrate how maintaining financially viable, organically certified businesses on the parkland is not possible within the terms of the alternative, which they say fails to determine a strategy to resolve conflicts between cattle and tule elk. And though few ranchers hope to diversify, they view the plan as too stringent to provide adequate economic or ecological benefit.
Some of the ranchers also dispute the environmental assessment of agriculture in the document, flagging in particular that the E.I.S. overlooked some key practices, including those shown to increase carbon sequestration.
The park’s preferred alternative lays out extensive land management strategies, mitigation measures and a new zoning framework aimed to reduce the current environmental impact of ranching and dairying in the park. Yet the document finds that reducing or eliminating agriculture would benefit the soil, water and air overall, and that the impacts on flora and fauna, including federally protected species, are mixed.
Lost expertise
On Sept. 20, the Point Reyes Seashore Ranchers Association submitted its letter with a long list of grievances and suggested changes.
Yet the association’s tone was measured. “We support the varied uses and environmental value of the [seashore] and the G.G.N.R.A. and believe the National Park Service has developed a draft environmental impact statement for the general management plan amendment that raises many of the important issues related to dairy and ranch management,” the association wrote in the introduction of the letter. “However, we believe the [amendment] and the preferred alternative have overlooked several key issues and must be better designed to recognize the historical, cultural, social, educational, scenic and environmental values and opportunities of the working dairies and ranches in the limited area of the [seashore] and G.G.N.R.A. recognized as the Point Reyes Peninsula Dairy Ranches Historic District and the Olema Valley Ranches Historic District.”
As its first recommendation, the association urged the park to establish an advisory committee to assist it in regard to agricultural issues, with possible representation from the state’s Natural Resources Conservation Service, the Marin Resource Conservation District, Marin’s agricultural commissioner’s office, the University of California’s cooperative extension and the Marin Agricultural Land Trust. The purpose of the committee would be to “advise [seashore] decision makers on all agricultural planning and management decisions.”
Melanie Gunn, a spokeswoman for the seashore, said many of those parties are already partners; pending the release of the final environmental document, she would not comment on the possibility of formalizing those collaborations in an advisory committee.
The idea was underscored by a sub-group of ranchers that submitted the same letter with more detailed commentary this fall. Signed by Richard and Jackie Grossi, Gino and Kathy Lucchesi, Kevin and Nancy Lunny, Ted and Rhea McIsaac, Paulette Percy, and Fred and Ginny Rogers, that group’s letter adds, “The occasional and informal contacts made by NPS with those having agricultural expertise is insufficient and we strongly support a formal agricultural advisory committee.”
On this topic, they also wrote, “In reading the [draft] E.I.S., had the NPS included experienced agricultural and resource advisors, it is clear that conclusions and impacts of the plan on the human environment would be different—and in most cases, showing reduced adverse effects and increased positive effects.”
The five couples and individual introduced their letter with more direct language. “On many topics, NPS seemed to have adequately analyzed the issues and arrived at reasonable conclusions. Alternatively, on agricultural issues, some of the analysis misses important facts and therefore arrives at wrong conclusions—conclusions and restrictions that nullify what appears to be a goal, [which is] viable and sustainable dairy and beef ranches within the historic dairy and ranching districts on Point Reyes and Olema Valley,” they wrote.
They continue that part of the problem is that the park did not look to the ranchers as the primary stewards of the land. “Point Reyes ranchers have spent countless hours over the past several years attempting to engage with the seashore’s ranch planning processes, but ranchers’ expertise and knowledge has been overlooked in this [draft] E.I.S.,” they wrote.
Still other ranchers expressed their alternate viewpoints. Bolinas ranchers Bill and Nicolette Hahn Niman, who submitted their own letter in September and are not members of the association, looked beyond the park service and the document at hand. Instead, they called for a larger paradigm shift among those in the environmental community who have been critical of ranching.
“A grossly over-simplified narrative runs through much of the environmental advocacy surrounding the [park], and specifically the management plan currently under consideration. It goes something like this: A unique, vibrant ecology is threatened by farming and ranching and can be restored only by agriculture’s removal,” the Nimans wrote. “This idea, which has permeated much of the litigation and activism about the seashore for years, is not only false, it is dangerous. If accepted, it would lead to a far less beautiful, less ecologically vibrant park and region.”
Elk
The ranchers’ association voiced concerns about the park’s proposed method of managing elk.
First, the association disputes the way that the environmental document characterizes the current presence of tule elk in the seashore, arguing that it falsely leads the public to believe that the populations represent a longstanding agreement.
The association points to the last living document that governs elk management in the park, a plan released in 1998 before elk ranged freely on ranchlands. That plan features a recommendation from a scientific panel that advised the park to pull individuals from the herd it established in a fenced enclosure on Tomales Point in 1978 to create a free-ranging herd in the Phillip Burton Wilderness.
The plan did not advise allowing elk on the ranches, instead opining that if elk were allowed to remain in the Point Reyes National Seashore into the future, “they should eventually become free ranging throughout most of the seashore’s natural zones where conditions allow.”
It added that removing the fence at Tomales Point would only be considered “if and when ranching ceases on the adjacent lands” because “to open the Tomales Point elk range with adjacent lands under ranching could negatively impact both ranching and the elk habitat.”
The park followed the recommendation to relocate several individuals from the fenced enclosure to an area above Limantour Beach. Within weeks, a few of the elk migrated to ranches near Drakes Beach. The herd that established there has posed the greatest conflict with the ranchers, a conflict that has never been formally resolved in a planning document.
In its letter to Ms. Muldoon, the association wrote, “Given that the 1998 elk plan did not provide for elk on ranchland, the E.I.S. must disclose that the alternatives that allow elk on ranchland amount to a huge and significant increase in elk. The failure to accurately characterize the current elk plan limitation that precludes elk on ranchland, distorts the effects of the alternatives in violation of the National Environmental Policy Act.”
The preferred alternative does propose managing beyond current practices two herds—the Limantour and Drakes Beach herds—that currently graze on ranchlands.
The alternative proposes establishing a population threshold of 120 individuals for the Drakes Beach herd, which park employees estimate will mean culling up to 15 elk per year; there are currently 124 elk in that herd. Though it doesn’t set a population limit for the Limantour herd, the preferred alternative allows for lethal removal if individuals in that herd wander from their current range, which is mapped.
But in its letter to Ms. Muldoon, the association presented an entirely different proposal. “Elk should be allowed [in the seashore] but the Drakes Beach herd and the Limantour herd should not be present on the limited area of the [seashore] which has ranches,” they said. “This is because over the last 30 years, NPS has not figured out how to effectively separate elk from cows; it would be better for elk if they are allowed to roam undisturbed in a much larger natural habitat in the Phillip Burton Wilderness instead of being subject to harassment, hazing, and lethal removal on ranch land.”
In order to separate elk from the ranchlands and keep them within the Phillip Burton Wilderness, the ranchers propose a four-mile-long fence leading up to the Inverness Ridge from Limantour Estero. “We believe the cost would be reasonable and, together with maintenance costs, would be much less costly than ongoing hazing, repair of ranch fences damaged by elk, and lethally removing elk.”
The ranchers’ association emphasizes that the elks’ search for forage threatens the organic certification of ranches, damages fences and reduces forage otherwise available for cattle. “If elk consume livestock pastures and supplemental forage for cattle [it is] necessary that NPS bear the cost of that forage,” they implore.
Albert Straus, whose Straus Family Creamery in Marshall is supplied by two dairies on Point Reyes, stressed the threat to organic certification in his own letter to the seashore this fall.
Mr. Straus explains that the presence of elk on rangelands reduces available pasture for livestock that is essential to meet requirements under the National Organic Program. Certified organic farming operations must follow an extensive set of regulations around grazing and pasture management standards, including pasturing animals for a minimum of 120 days per year.
Kevin Lunny, a third-generation rancher who submitted an independent letter to the seashore in addition to signing several others, also disputes the seashore’s finding—based on computer modeling—that there is enough forage for 120 elk from the Drakes Beach herd, as well as for the roughly 50 elk from the Limantour herd that the seashore says wander onto ranches.
“Knowing this failure of this new model, as well as other inaccuracies that are likely to become evident in a brand new, theoretical model, NPS [in] the final E.I.S. must allow for some years of testing and improving this model before it is used in any way to help determine carrying capacity,” he wrote.
Diversification
On the subject of diversification, the ranchers’ association letter also rings with frustration. “We appreciate the consideration of allowing ranches to diversify with some row crops. However, the limitations are so restrictive that they will not allow NPS to meet its goal for ranchers to respond to poor forage production years and fluctuations in economic markets,” they argue.
Some alternatives in the draft E.I.S. prohibit any agricultural production outside of ranching and dairying, but the preferred alternative allows for diversification primarily within the area immediate to the ranch buildings and homes referred to as “the ranch core.”
In the core, ranchers would be allowed to board horses and raise chickens, pigs, sheep and goats, and to 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—but without irrigation or tilling. They might be allowed to conduct ranch tours or farm stays, in alignment with the park’s goals for education and interpretation.
Most of these activities are now allowed in some capacity; the preferred alternative presents a standardization of what currently differs from lease to lease.
Yet the ranchers say that the proposed prohibition of irrigation severely limits crop varieties. The restriction of row crops to the ranch core is also unreasonable, they argue, considering there may be more suitable soil for crops elsewhere.
“The baseline restriction should be relaxed to allow up to 75 acres of row crops, on suitable soils within a mile of the ranch core, using mulch, and irrigation if excess water is available,” the association wrote.
For 24 families, the allotted 2.5 acres amounts to 60 acres; yet, considering not everyone would like to use the acreage, they propose instead allowing interested ranchers to make proposals and split a total of 75 acres between them.
Diversification does not just bring economic benefits, they emphasize, but also important conservation benefits that were overlooked. For example, vegetable waste from row crops can be fed to hogs, whose manure can be composted with other organic materials to use on row crops or pastures. “Diversified agriculture can provide important wildlife habitat and soil conservation benefits that should be considered in the [draft],” they wrote.
The ranchers appreciate the allowance for sheep and goats, but they point out that the proposed prohibition of their use on the zone that includes most of the rangelands doesn’t make sense, considering that is “where there is more significant threat to grassland by wildfire and brush encroachment and fewer tools available to control the brush.”
Mr. Lunny, who is one of just a few ranchers with a strong interest in diversification, has been permitted to grow six acres of row crops—primarily artichokes—since 2003. He has requested to expand into 30 acres with the hope of cultivating a variety of grains, including possibly to supply the Point Reyes Station bread company Brickmaiden Breads.
He says diversifying honors the historic use of his family’s land. The period of significance for the Point Reyes Peninsula Dairy historic district—which was codified earlier this year in the National Historic Register of Historic Places—is between 1856 and 1958. When the seashore was established, Mr. Lunny’s family had around 500 acres in crop production, including barley, oats, vetch and beans.
Historically, ranchers in the seashore grew all manner of irrigated and non-irrigated row crops—beans, peas, barley, artichokes and other vegetables—and raised livestock like hogs and sheep. Following World War II, there was a move toward monoculture, but Mr. Lunny argues that this is not an economically or environmentally sustainable approach.
“The reality for the family farm has changed,” he wrote in his letter. “Over the past decade or so, the U.S. is losing approximately 50 family farms per week and big industrial agriculture is getting bigger. Small family farms have realized that the secret to survival is to begin to move away from large-scale single-commodity monoculture and refocus on small-scale diversified agriculture. The local marketing allows small farmers to build local relationships, and to collaborate with other ranchers on value-added products, processing and distribution.”
Carbon farming
Mr. Straus, whose business boasts several cutting-edge carbon-emission reduction strategies, holds firm on his disappointment with the park’s management. “The NPS has a passive approach to land management and restricts and prohibits a pasture management system that includes maximizing pasture productivity with proactive ranchland practices such as carbon farming, compost application, mowing and seeding,” he wrote.
The ranchers’ association also bemoans that the draft environmental impact statement does not further evaluate the potential benefits to soils from carbon farming.
One of the document’s only mentions of carbon farming includes, “Not all carbon farming practices may be appropriate for implementation in the park, but to the extent that compatible practices are implemented voluntarily by ranches and with NPS approval, carbon farming could reduce [greenhouse gas] emissions from ranching activities.”
The ranchers urged the seashore to consult with the Marin Carbon Project, the Carbon Cycle Institute and the Marin Resource Conservation District. “There is no excuse [for] ignor[ing] the beneficial effects of carbon farming,” they wrote.
Ranchers throughout the county have benefitted from an endeavor orchestrated by the Marin Carbon Project—a consortium of agricultural groups, university researchers, county and federal agencies and nonprofits. In 2013, the project launched a pilot carbon farming program on three farms in West Marin: Stemple Creek Ranch, the Straus dairy and the Corda ranch.
After performing extensive baseline soil sampling and rangeland assessments, the ranchers applied close to 4,000 cubic yards of compost on nearly 100 acres of rangelands across their three farms. They established windbreaks, restored riparian habitat and planted grass, plants and trees, among other improvements.
Their example has shown that the application of compost in conjunction with the other practices can increase the capacity for vegetation to capture and store carbon in the soil, while providing other benefits such as improving the soil’s water-holding capacity and resilience during drought.
Nancy Scolari, who directs the Marin R.C.D., said preliminary data show that these demonstration ranches are sequestering 3,362 metric tons of CO2 annually, a number equal to the total emissions from 720 passenger vehicles a year.
Although ranchers within the park’s boundaries have applied to participate in the program, the park stalled their efforts pending the finalization of the environmental impact statement.
Some aspects of carbon farming are already part of the extensive conservation work that takes place on the ranches in collaboration with other agencies and nonprofits. But the park’s preferred alternative places restrictions on the application of compost—a key component of carbon sequestration.
Currently, stored manure or compost generated onsite is spread across approximately 2,500 acres, primarily by the dairy ranchers.
Under the preferred alternative, the dairies would need an approved nutrient management plan to continue this practice, and there would be no expansion, either by use of commercial compost or in acreage.
The ranchers would not be allowed to spread it on the zone identified as “the range,” which accounts for 65 percent of the leased area and where the majority of the cattle grazing occurs.
The preferred alternative prohibits both the application of commercial compost and fertilizer—a decision that shows how the document fails to understand the benefits of soil amendments and inputs on soil health, the ranchers association argues.
Regarding soils, the document found that all the alternatives that continue ranching and dairying “would continue to affect soils because of erosion, compaction, and alteration of soil fertility, primarily from livestock grazing, forage production, high intensity use areas, and manure spreading.”
In most of the alternatives, impacts on soils are projected to be reduced compared to existing conditions “by establishing management activity standards and mitigation measures, and implementing a zoning framework that would ensure more intense land uses occur in areas without sensitive resources, such as soils with high erosion potential, throughout the planning area.”
Alternatively, “cessation of ranching would eliminate all impacts on soils associated with ranching activities.” A similar determination is made for air and water quality.
Mr. Straus describes a missed opportunity. “The draft E.I.S. inadequately addresses the ecological and economic benefits of pasturelands used by livestock and doesn’t recognize livestock agriculture as a solution to climate change,” he wrote.
Mr. Straus cites a recent study from the University of California, Davis, which found that grasslands and rangelands are more resilient carbon sinks than forests: the study indicates that grasslands should be given opportunities in the state’s cap-and-trade market, which is designed to reduce California’s greenhouse gas emissions to 40 percent below 1990 levels by 1930.
In their letter, the Nimans describe carbon sequestration as among the ecological benefits of ranching. They say that historically, 19 species grazed the area and that cattle are suited to continue this legacy.
“Without the once-abundant large predators…it is no longer feasible for this urban-fringe area to maintain significant populations of large wild grazing animals,” they wrote. “Domesticated grazing animals, however, can serve as the proxies for those disappeared wild grazers and browsers. Indeed, for this ecosystem to function at its best, large populations of grazing animals are necessary.”
They went on, “A large body of scientific evidence shows that grazing, including by cattle, enhances biodiversity, from soil micro-organisms to megafauna. Grazing animals’ hooves help press seeds into the soil, their mouths clip vegetation, stimulating plant growth and helping later-sprouting species of plants to germinate, and their manure and urine provide nutrients, moisture, and organic matter that help soil biology.”
Revisiting leases
The ranchers’ association raised several other grievances, including over the proposed process for re-authorizing ranch operating agreements, which spell out all of these terms for each ranch on an annual basis. (Ranch leases, a separate document, would have 20-year terms under the preferred alternative.)
“The annual meeting about the [ranch operating agreements] and related documentation should be referred to as ‘implementation’ of decisions previously made in the GMP record of decision and not an update or reauthorization,” the ranchers wrote. “Otherwise, you are creating an annual opportunity to attack and stall the decisions, which is not in the interest of good resource management.”
This story was corrected and clarified on Dec. 11.