The National Park Service next month will make a final recommendation regarding the future of ranching in the Point Reyes National Seashore.
The recommendation, presented in a final environmental impact statement that will be sent to the park’s regional director for a decision, must address the thousands of public comments the agency received on the draft document, published last fall. The vast majority of commenters asked the park to shutter ranching operations, but others threw their weight behind agriculture, including local organizations dedicated to preserving natural resources in Marin.
Representatives from the Marin Conservation League, the Marin Agricultural Land Trust, the Marin Resource Conservation District and the Environmental Action Committee of West Marin were among those who wrote in favor of the continuation of ranching, a legacy that dates back to the mid-1800s. The groups supported a proposal that the park service highlighted as its preferred alternative, which allows ranchers 20-year leases.
While the groups approved of the overall vision the park outlined in that alternative, they had many suggestions for how it could better align with their conservation strategies. Their comments were detailed and fine-tuned, asking that clarifications be added to the document largely so that ranchers have more security and flexibility. Many of their requests overlap with those made by the ranchers in their own comment letters.
The draft version of the environmental impact statement, which corresponds to an amendment of the seashore’s general management plan, presented six possible alternatives for the management of ranching and tule elk. The park undertook the analysis as a result of a settlement with three groups—the Center for Biological Diversity, the Western Watershed Project and the Resource Renewal Institute. Per the terms of the agreement, the park had to consider reducing grazed acreage, shuttering the dairies but keeping the beef operations, and phasing out all operations within five years.
Last month, the Mill Valley-based Resource Renewal Institute released a homemade analysis of the more than 7,600 comments submitted in regard to the draft E.I.S. According to the group’s assessment, 91 percent of the commenters from across the country opposed ranching.
The park’s analysis of the comments will be included in the final document. Melanie Gunn, an outreach coordinator for the seashore, explained to a meeting of the Marin Conservation League last month how the park incorporates feedback under the National Environmental Policy Act.
“It’s not a vote on the alternatives, for lack of a better way to describe it. We want to hear what people are thinking about them and we want to improve the document,” Ms. Gunn said. “We look for substantive comments, group them, and prepare responses.”
Covid-19 has not stalled the process, Ms. Gunn told the Light. She and other staff are working remotely on the document, which will likely be released in June, after which follows a 30-day waiting period before the park service’s regional director signs a record of decision.
The comments from the Marin groups that favored continued ranching advocate for a number of changes to the preferred alternative, many of which are overlapping. Overall, the groups’ suggestions pertain to best practices, the management of elk, diversification, and the way leases will be issued.
The Marin Conservation League has fought to protect open space from development throughout its 86-year history, including advocating for the creation of the seashore in 1962.
The group defined its position on agriculture in the comment letter it submitted last September: “To continue to support the role Marin’s agricultural community plays in maintaining open space, protecting wildlife corridors, managing carbon, preserving a valuable local heritage, and contributing to food security and the local economy,” wrote Lindy Novy, the president.
The group supports the park’s proposal to issue 20-year leases—the keystone of the preferred alternative—but expressed concern about how leases will be issued.
Currently, the 24 families with leases are operating on five-year permits or one-year, renewing permits through 2022, per the terms of the settlement. Before the lawsuit, which was filed in 2016, 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 terms of five or 10 years.
The draft E.I.S. states that the seashore’s enabling legislation and subsequent amendments allow the park to authorize lease agreements to ranchers, a topic that has sparked much controversy over the years. It references directives from the Interior Department and members of Congress that pushed the park to standardize the agreements and allow for 20-year terms.
Under the preferred alternative, only the existing operations would be allowed the leases. The current acreage ranched—18,000 acres in the seashore and 10,000 acres managed by the seashore in the Golden Gate National Recreation Area—would stay the same. Those areas are within the bounds of two historic districts designated last year, the Point Reyes Peninsula Dairy Ranches and the Olema Valley Dairy Ranches.
A draft lease the park provided as a supplement to the document says that six months before the 20-year agreement expires, the agency “may offer this lease, or a similar lease, to the leasee.”
Ms. Novy said that language was too ambiguous. What are the conditions that would lead to the park not offering another lease? What would a similar lease look like? “The [final document] should address and resolve this issue because not providing the analysis and approach for this impending decision at this time defers a lengthy debate and planning process to 20 years from now,” she wrote.
This concern was echoed by the Marin Agricultural Land Trust in a letter signed by Jamison Watts, the executive director, and Ralph Grossi, the board chair. They recommended rolling leases with 20-year terms that renew at least one-year in advance of expiring. Continuation should depend on whether the rancher is meeting the performance standards established in the existing lease as well as in the ranch operating agreements, they suggested.
Nancy Scolari, the executive director of the Marin Resource Conservation District, envisioned even more security. She recommended 20-year leases renewed five years before the expiration date. Longer leases are essential to conservation goals, she argued.
In addition to the Marin R.C.D., many organizations and agencies already collaborate with seashore ranchers to implement best practices, but longer leases would open up more funding streams for ranchers to tackle new conservation projects. The majority of federal and state environmental grant programs, such as those offered through the California State Water Resources Control Board and California State Coastal Conservancy, require 20-year commitments.
Like the Marin Conservation League, the Marin R.C.D. does not see agriculture and environmental stewardship at odds. But that is not the perspective of the park’s environmental assessment.
Notably, the draft E.I.S. determines that reducing or eliminating agriculture would benefit the soil, water and air, and that agriculture’s impacts on flora and fauna, including federally protected species, are mixed.
David Lewis, who directs the University of California’s Cooperative Extension in Marin, commented on those findings, in addition to making a lengthy list of technical improvement.
Mr. Lewis disputed the draft E.I.S.’s interpretation of a Natural Resources Conservation Service soil survey, arguing it had been misapplied; the survey was among several troubles he saw with the park’s analysis. “There is no evidence that careful grazing practices in California leads to adverse soil impacts, yet these statements persist in the [draft]. The result is a document that reads with an extremist view on the effects of management on soil,” he wrote.
Regarding air pollution, he thought the document was correct in stating, “While emissions of criteria pollutants and greenhouse gases would vary among alternatives, these emissions would continue to be a small contributor to overall impacts when compared to emission sources and transport of emissions from outside the planning area.” He recommended the park strengthen that point in the document.
The park’s preferred alternative lays out extensive land management strategies, mitigation measures and a new zoning framework it says would reduce the current environmental impact of ranching and dairying in the park.
All three of the Marin environmental groups weighed in, emphasizing that the park missed some key practices that are already common elsewhere in the county.
The draft adopts many standards from the Marin R.C.D.’s permit coordination program, which was designed to help ranchers plan, permit, fund and implement practices that will minimize impacts to wildlife and water quality. But Ms. Scolari says some of the program’s practices were left out in the park’s draft, including mulching, hedgerow planting, silvopasture and conservation cover. She encouraged the park to include them.
The Marin Conservation League and MALT ask for the E.I.S. to explicitly permit ranchers to conduct the practices that enhance carbon sequestration, known collectively as carbon farming.
The Marin Carbon Project—a consortium of agricultural groups, university researchers, county and federal agencies and nonprofits—launched in West Marin in 2013, and since then 19 farms throughout the county have benefitted from the carbon farm plans designed through the program. Although some ranchers in the seashore have expressed strong interest in carbon farming, the park has not yet allowed it.
MALT and the Marin R.C.D. help spearhead the carbon farm plans, which create an inventory of the natural resources on each farm and set conservation goals. The methodology is supported by the N.R.C.S., the State of California’s Healthy Soils Initiative and Marin County.
Although the draft E.I.S. mentions carbon farming, Ms. Scolari said it should have fully evaluated the practices.
Carbon farming provides extensive environmental benefits, Ms. Scolari said, including enhancing sensitive ecosystems, improving water quality and reducing greenhouse gases.
The environmental groups believed the park’s proposal to manage tulk elk, which some ranchers have said threaten their operations, is acceptable, though they foresee continued conflict.
Under the preferred alternative, park employees would lightly manage one of the park’s three tule elk populations, the Drakes Beach herd. To keep the Drakes Beach herd at 120 individuals, the park estimates that employees would have to cull 10 to 15 elk each year. Park employees would be tasked with shooting the elk.
Some other alternatives would make no effort to contain the elk from lands leased for ranching.
“Wilderness designated lands and leased ranchlands should be given equal protection corresponding to their intended use and purpose,” Mr. Watts and Mr. Grossi wrote. “When livestock are found in Wilderness, they are removed. Likewise, when elk are found on leased ranches, management methods should be used to control their population and remove their impacts.”
Ms. Novy was concerned the proposed strategy would inadequately protect the ranches. The park developed a forage model to help evaluate how many elk and cattle the pasture lands can sustain, but she said it was “untested.” She added, “there should be very clear procedures specified regarding how adjustments, exceptions, and professional judgment would be applied quickly in the event that any of the affected ranchers can demonstrate that it is not working as intended for their individual operations.”
Mr. Lewis, who also chairs the agricultural land use committee for the Marin Conservation League, recommended the forage model be peer-reviewed.
Ms. Scolari said the document needed to further evaluate the economic losses caused by the elk, including to fences and other infrastructure.
Another key topic—diversification—was touched on by the Marin Conservation League, the university extension and the Environmental Action Committee of West Marin.
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 only without irrigation or tilling. They might be allowed to conduct ranch tours or farm stays.
Some of these activities are now allowed; the preferred alternative standardizes what currently differs from lease to lease.
Ms. Novy and Mr. Lewis both expressed concern. Mr. Lewis wrote, “Some of the most common crops grown without irrigation are also high-acreage crops such as grains, vines and tree fruit—a clear mismatch with the 2.5-acre cap.” He suggested allowing the 2.5 acres of row crops to be farmed either in the ranch core or in the pasture, another larger zone the park will designate on each ranch.
Second, Mr. Lewis asked the park to loosen the restriction on tillage for the row crops. Third, he said the E.I.S. only allowed fencing to ward off pests, and instead recommended the guidelines used in the University of California’s integrated pest management program.
He asked the park to clarify its position on how ranchers could sell the new products yielded from diversifying. “The opportunity for members of the public to engage with agricultural operations directly as consumers of local products draws them closer to the region’s long ranching history and yields both economic and cultural benefits,” Mr. Lewis urged.
The executive director of the E.A.C., Morgan Patton, and board president Bridger Mitchell had an entirely different perspective. In general, their input diverged the most from the other groups, though it still professed support for the preferred alternative.
Ms. Patton and Mr. Mitchell argued that allowing diversification “exceeds the [park service’s] authority by allowing for new agricultural uses to be developed.”
Diversification was one of the group’s chief concerns with the preferred alternative. The letter asks the park to “Remove all types of diversification from [the document, as it does not] evaluate cumulative, direct or indirect impacts, connected actions, or reasonably foreseeable outcomes of diversification.”
The E.A.C. was the only one of the groups that found the park’s plan to cull elk intolerable. Ms. Patton and Mr. Mitchell said the alternative should be changed so that elk can continue without management. The group called on the reduction of cattle numbers should there be competition for forage.
Environmentalism takes many forms, and in the thousands of comments the park service received, the shooting of tule elk proved to be one of the most common objections. According to the analysis from the Resource Renewal Institute, 20 percent of the comments were critical of the park’s plans to cull elk.
“I am strongly opposed to this idea. Killing native elk in favor of cows and dairy farming seems completely opposite to being good stewards of a spectacular natural resource like Point Reyes. The elk are an integral part of why visitors derive so much enjoyment from the shoreline. Please save the elk and do not destroy natural habitat to further dairy farming,” one commenter wrote.
A second represented another common sentiment, stating, “Public lands belong to the public, not ranchers. Having ranchers fence off public lands for individual gains, is not good use of MY tax dollars. I don’t want my money going to the protection of ranchers.”
The three groups that sued the park service have remained steadfast in their opposition.
“We support Marin’s agricultural community and farming practices that nourish both people and the planet,” Deborah Moskowitz, president of Resource Renewal Institute, said in a statement. “By the park service’s own studies, including the E.I.S. on the impacts of ranching, it’s clear that ranching is taking a toll on our national seashore.”
She continued, “Hundreds of species depend on this park, yet the creeks are polluted with cattle waste and native wildlife face a death sentence when they come into contact with livestock. It’s a sad commentary on a national park.”
National environmental groups took a similar stand.
The Sierra Club thought the park needed a new document altogether. The letter stated, “The Sierra Club’s position is that all the ranching alternatives involve the impairment of natural resources and that three [park service] laws prohibit actions that will impair natural resources.” It continued, “Under these circumstances it makes no sense for the park service to go forward with a final E.I.S.”
Jack Truesdale contributed reporting to this article.