General Management Plan Amendment Initial Public Comments: Correspondence ID #s 2501–2750

←Comments 2001–2500

Comments 2751–2967→

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# 2501
Name: van der wal, sue and john
Correspondence: NPS-PRNS-GMP Amendment
Under the Park's initial proposal, we support existing ranch families to continue beef and dairy operations with 20 year leases. However, we do not support Tule elk in the Drakes Beach or Estero area. No Tule elk in the pastoral zone. The Limantour herd should be monitored and managed and fenced so some do not come over to the Estero and Drakes Beach areas or any other areas in the pastoral zone. It's obviously a poor idea to erect a long, high fence at high cost and it's doubtful any such funds will be coming from Washington. Also, the fencing would require park personnel to constantly check for break-outs, as occurs at the fenced Pierce Point elk range.
We support multigenerational sustainable ranching only for dairy and beef and if that becomes impossible we favor a return of the land to the Park. In the latter case, if financially feasible we could keep one or two historic structures and demolish the rest. The set up could be similar but on a smaller scale to Pierce Ranch, to make it educational for the public.
The terms "diversification" and "increased operational flexibility" concern us because that could mean changing from cattle/dairy to chickens (with many moveable coops over the pastoral zone) or to goats, llamas, water buffalo, an ice cream operation or other unknowns. Switching to organic farming with plowed fields would destroy the ambience of the pastoral zone.
We support protecting park resources - historic structures and cultural aspects. We oppose access to ranches by park visitors; ranchers are trying to make a living. We do not want any "visitor experience improvements" that would infringe on, disrupt, or cause stress to ranchers, their families and employees and the cattle.
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# 2502
Name: Girroir, Adi
Correspondence: I support the continuation of sustainable agriculture in Point Reyes National Seashore and the Golden Gate National Recreation Area.
I am deeply concerned about the future of ranching in the seashore because I believe removing agriculture on park land threatens all agriculture in the county. These farms and ranches make up about 24% of Marin's agricultural lands and production.
As a volunteer and supporter of Marin Agricultural Land Trust since 2006, I have seen how ranching operations have improved under the guidance and support of MALT. I have seen and helped with mitigation of cattle damage on some of MALT protected properties. I have also seen our local Farmer's Markets flourish because our "local" farmers bring their produce, cheese and meats to a public who obviously believes in buying local, organic and GMO-free products. I have walked on some of the ranches, protected under MALT easements, with members of the public. They bring their friends and families to find and catalogue native flowers, birds, bugs and other wildlife while enjoying the beauty of this county. I believe that we now have an opportunity to bring this MALT type model to the Park Service.
Farmers and ranchers deserve long term leases of at least 20 years so they can be secure in the knowledge that the work they are doing, that is improving the land and infrastructure, can be passed on to future generations.
Adi Girroir
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# 2503
Name: Rice, Craig
Correspondence: National Park Service
Comments re: Conceptual Range of Management Alternatives for Point Reyes National Seashore (Seashore)
For the following reasons I support the continuation of the current management of the Seashore.
- The economic benefits to Marin County farmers are significant. The ranching and farming on the Seashore represents 20% of the agricultural land and production. This enables the ranchers and farmers to maintain a critical mass that could disappear if the Seashore management is changed.
- The historic grazing at the Seashore has been shown to help maintain grassland habitat and conserve native plant and animal species.
- Another benefit is reduced wildfire threat from rangeland fires
- Additional benefits from these operations include soil carbon sequestration and increased soil water retention.
I am a wilderness enthusiast but I think it is entirely appropriate and consistent with the National Parks program to preserve an agricultural heritage.
Thank you for your attention to these comments.
Craig Rice
Cell [phone]
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# 2504
Name: French, Beverlee
Correspondence: National Park Service
Comments re: Conceptual Range of Management Alternatives for Point Reyes National Seashore (Seashore)
For the following reasons I support the continuation of the current management of the Seashore.
- The economic benefits to Marin County farmers are significant. The ranching and farming on the Seashore represents 20% of the agricultural land and production. This enables the ranchers and farmers to maintain a critical mass that could disappear if the Seashore management is changed.
- The historic grazing at the Seashore has been shown to help maintain grassland habitat and conserve native plant and animal species.
- Another benefit is reduced wildfire threat from rangeland fires
- Additional benefits from these operations include soil carbon sequestration and increased soil water retention.
I am a wilderness enthusiast but I think it is entirely appropriate and consistent with the National Parks program to preserve an agricultural heritage. I bicycle frequently through the park and am always thrilled with the bucolic ambience and scenery. The historic working ranches are part of what make Point Reyes very special to me.
Thank you for your attention to these comments.
Sincerely,
Beverlee French
cell phone: [phone]
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# 2505
Name: Eelen, Marta
Correspondence: Hello!
I'm very glad that I have opportunity to submit my comment about current situation with Tule Elk! I really hope that the General Management Plan update will allow to get more land for these wonderful animals and make that population grow.
Kind regards!
Marta
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# 2506
Name: Sinton, Stephen J
Correspondence: I urge the NPS to adopt management plans that utilize grazing as an integral part of the region. Sustainable grazing limits weedy and invasive plant species from taking over the hills and valleys, reduces wildfire risk and damage, provides local food for the nearby urban areas and provides for the long time residents and their families. Cattle grazing has been shown to be the functional equivalent of the large pre-historic herbivores that once existed in the region. Without them, the productivity of the land will be degraded and the capacity of the region to support wildlife will decline as well.
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# 2507
Name: Oei, Tamara
Correspondence: Dear Superintendent,
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
___________________________
# 2508
Name: N/A, N/A
Correspondence: Dear Superintendent,
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Growing up in the San Francisco Bay Area, Point Reyes was an amazing place that I got to visit regularly - and tule elk are an important part of the landscape of Point Reyes. Their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Cattle are an introduced, invasive species - tule elk are not. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Regards,
Heather Payne
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# 2509
Name: Scherer, Lisa J
Correspondence: Cynthia MacLeod, Acting Superintendent
Point Reyes National Seashore
National Park Service
1 Bear Valley Road
Point Reyes Station, CA 94956
RE: General Management Plan Amendment for Point Reyes National Seashore
Dear Ms. MacLeod:
As a fourth generation family farmer I am writing to provide input on the General Management Plan Amendment for Point Reyes National Seashore (PRNS). I support the continued operation of beef and dairy ranching operations under agricultural lease/permits with 20-year terms and improved management of the Tule elk herds to eliminate negative impacts on the environment and ranching families.
Ranchers have been raising cattle in Point Reyes for more than 150-years. It was ranchers' willingness to sell their properties to the federal government that allowed the creation of the PRNS. As part of the agreement, ranchers were supposed to be allowed to continue ranching on their family ranches within the PRNS.
The ranches in West Marin contribute significantly to the local economy and the local culture. According to any analysis by U.C. Cooperative Extension in 2009, ranches in PRNS and Golden Gate National Recreation Area (GGNRA) directly provide approximately 65 jobs and provide livelihoods for an additional 25 ranch family members. Additionally, agriculture in PRNS and GGNRA account for 17 percent of the agricultural income in Marin County. These jobs and income would be lost if further restrictions were placed on ranches within PRNS. These ranches are not just creating economic value, they are producing high quality food appreciated by consumers locally, regionally, and nationally. Further, providing 20-year terms for lease/permits allows for greater investment in improvements on these ranches. Shorter terms prevent the ability of ranchers to obtain financing for improvements.
would also like to see improved management of the PRNS elk herds. Elk cause thousands of dollars of damages and lost forage on ranches. Additionally, the elk carry Johne’s disease, which can be transmitted to cattle. USDA estimates that lost productivity from Johne’s disease in dairy cattle could be costing dairy producers between $200 and $250 million annually. Elk in the PRNS were reintroduced by humans and have been managed since their reintroduction. PRNS must improve its management by maintaining the roaming elk herds on the Limantour wilderness and preventing them from damaging ranches in the area. Additionally, PRNS should ensure that there is proper forage and water available to the herd in the Limantour wilderness to prevent a reoccurrence of the unfortunate loss of elk during the drought.
Ranches on PRNS provide important economic, cultural, and ecological values to the local community. Losing a significant portion of West Marin’s agricultural community would mean not only a loss of local food production, but a significant loss to its economy and culture. I urge you to offer 20-year lease/permits to ranchers on PRNS and to improve elk management and return the elk to the wilderness areas where they will not impact the ranches.
Sincerely,
Lisa J. Scherer
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# 2510
Name: Grossi, Jackie and Rich
Correspondence: We have been ranching all our lives. We know what it takes to be successful in the dairy and beef cattle operations. Elk and cattle are not compatible on the same lands. In 1972 Ray Arnett head of Department of Fish and Game would not bring elk to the Pierce Ranch until the fence was completed to keep the elk in their designated area. He knew the damage (broken fences, damage to water sources, transmission of diseases, damages infrastructure, etc.) the elk would cause to the rangelands. When the excess elk were moved to Limantour there was a verbal agreement from the NPS Superintendent assuring the ranchers that if the elk wandered on to the ranchlands they would be immediately be removed and returned to LImantour. Well, that certainly did not happen!
PRNS does not know what management decisions are required for the day to day ranching operations. The ranchers need the flexibility to make executive decisions that impact their operations. The ranchers should be in charge of the ranches and the PRNS should remain in charge of the beaches. Twenty year, or more, renewable leases are absolutely necessary for the stability that agriculture needs to survive. By the year 2050 the US population is projected to increase by 70 million people.
Agricultural lands are disappearing by approximately by 2-3% annually. Who is going to provide food for the growing population? Once land is taken out of agriculture it is never returned to grow food again. No additional PRNS agricultural lands should be taken out of production. Too many grazable acre have already been taken out of production. Perhaps some of these usable acres should be returned to agriculture production. Abbotts Lagoon is a prime example of eliminating grazing to protect endangered species. Cows were fenced out of an area where an endangered plant specie grew. NPS was trying to encourage additional plant growth: but instead all the plants in the ungrazed area died. Grazing is a necessary environmental tool.
If all or reduced ranching/ grazing was initiated in PRNS the lands would become unrecognizable. It would take a few years before the open green fields disappeared. Visitor experience would be affected. This land has always been managed by mankind: Indians, settlers, ranchers, and Point Reyes National Seashore. This is not the place for wilderness. The wilderness areas can only be accessed by visitors hiking or horseback riding if trails are maintained. Ranching/ dairying is an essential part of the AGRICULTURAL DESIGNATION issued by Congress for the public to view and use as a recreational area. The elimination of these ranches would have a significant impact on visitor experience and enjoyment. Agriculture in Marin County supplies 20% of the county revenue; not to mention loss or reduced income to all agriculture related businesses. For example local businesses, post office, grocery stores etc.
We don't think that any of the six alternatives are suitable for this National Seashore. We want to see if there is another solution to help keep us here for another six generations.
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# 2511
Name: Baldwin, Christina A
Correspondence: Please accept this letter as an endorsement for a General Management Plan (GMP) that maintains continuing sustainable agriculture and ranching in the Seashore and Golden Gate National Seashore Recreation Area (GGNRA).
cattle ranching and agriculture not only supports people and provides revenue for Marin County but, very importantly, also have critical environmental benefits. These managed coastal grasslands provide habitat for endangered species, help to protect endangered species, provide habits for pollinators, and help to keep invasive plant species in check. Furthermore and very importantly, they help to reduce wildfire danger. Ranching and agriculture are also part of the history and esthetics of West Marin and Marin County.
My family moved to Marin County in 1949. My brother lives in San Geronimo and uses the GGNRA weekly. I always go the GGNRA when I visit. Straus Dairy products and artisanal cheeses are carried in our local grocery store and bring smiles and pleasure to me and many here in Idaho.
Please support a GMP that maintains sustainable agriculture and ranching in the GGNRA for the people who live there now, for the environment, for the economy in Marin, and for future generations to enjoy.
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# 2512
Name: Haseltine, Michael
Correspondence: I am writing to you in regard to the General Management Plan (GMP). Although I am writing from Idaho now, I lived in Berkeley for 30 years and frequently used Marin County for recreation. I still visit relatives and friends in Marin County and still use Point Reyes National Seashore and the Golden Gate National Recreation Area.
From my experience, Marin benefits greatly from the current arrangement there, with sustainable agriculture as well as recreation. Ranching was a critical element in saving Marin County from Development more than 50 years ago, and it's still desired by the people of Marin County. Sustainable cattle ranching and agriculture not only support people and provides revenue for Marin County (over $49 million annually to the local economy in 2009, according to UC Cooperative Extension) but, very importantly, also has critical environmental benefits.
These managed coastal grasslands provide habitat for endangered species, help to protect endangered species, provide habits for pollinators, and help to keep invasive plant species in check. Furthermore, they help to reduce wildfire danger, surely an important factor considering this year’s fires. Ranching and agriculture are also part of the history and esthetics of West Marin and Marin County.
I support a GMP that maintains sustainable agriculture and ranching in the GGNRA for the people who live there now, for the environment, for the economy in Marin, and for future generations to enjoy.
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# 2513
Name: Bruegge, Debra E
Correspondence: Dear Superintendent,
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
Debra E Bruegge
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# 2514
Name: Breakstone, Enid
Correspondence: Dear Superintendent,
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
Enid Breakstone
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# 2515
Name: Newman, Gene
Correspondence: Dear Superintendent,
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
Gene Newman
___________________________
# 2516
Name: Moore, Catherine
The Point Reyes National Seashore (PRNS) was created in 1962 by the agreement with existing ranchers that their family operations would be able to continue within the park boundaries. Now, the NPS wants to weasel out of the deal. How typical.
The government is developing a bad history of dishonoring contracts. Why would any landowner enter into this sort of agreement in the future if this is the fate that awaits them?
Furthermore, as a timber landowner who has been on years of field trips where I saw private land abutting government land, I can assure you that the private land is always in better shape than the public land. Invasive species, fuel hazard, bugs and diseases - it's all on the public lands. Your best hope of good land management lies with continuing to honor the original agreement.
As for the environmentalists - we can all see the results of the lawsuits that have forced the government to adopt hands-off non-management of the public lands. This is where the wildfires are coming from. This is the breeding ground of the pine beetle infestations. They should be held accountable for their actions and their input should be discredited. I cannot believe that their grasp of seashore environments is any better than that of the forests.
I urge you to continue to honor the original contract. It's the right thing to do ethically, legally and environmentally.
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# 2517
Name: Rosen, Seth B
Correspondence: This comment is submitted November 13, 2017 by Seth B. Rosen, Member, Program and Trails Trust Committee and Member, Board of Directors of the Point Reyes National Seashore Association (PRNSA).
This comment is being submitted by me as an individual - - the PRNSA Program and Trails Trust Committee has already submitted a comment on behalf of PRNSA.
The Park Service GMP Amendment materials state: "The NPS would identify additional compatible opportunities to improve visitor experience in the planning area (e.g., enhanced trail connections, improved signage, and new interpretive waysides)."
Comments:
The definition of “enhanced trail connections” should be clarified and should be defined to specifically include all of the following for each and every alternative being considered by the National Park Service (including the “No Action” alternative):
the enhancement of trail connections through creation of new trails that connect trails to existing trails and/or to points of historical, cultural or natural interest in the Planning Area;
the enhancement of trail connections through creation of replacement trails through the Planning Area where such replacement is either
i. replacing an existing 'dirt road being used as a trail' for a new trail serving a comparable purpose but whose actual route would be set in the interests of a trail (not the interests of re-using a pre-existing farm road); or
re-routing of one or more existing trails to account for changed conditions (e.g., connecting the Estero trail to the former site of the oyster company);
to enhance visitor enjoyment, lower overall environmental impact and reduce medium and longer-term costs for road maintenance (since trails are less expensive to maintain than dirt roads);
the enhancement of trail connections through the creation of a North-South Trail plan that would link points of interest from Tomales Point in the north of the Seashore to the southern portions either or both via Estero Trail and/or Inverness Ridge Trail.
The scope of the planning process should include the creation of new overnight accommodations within the Planning Area. Possibilities could include backpacking campsites, car-camping sites, or other alternatives.
The scope of the planning process should include the creation of new interpretive sites:
at the site of historic Point Reyes (in today’s F Ranch) detailing the early history of Americans at Point Reyes
at the historic Schooner Landing located in Schooner Bay of Drakes Estero detailing the importance of the site to commerce and ranching. (F Ranch is a disturbed site due to historic uses and so should be considered as a prime location for shuttle access to western portions of the Seashore, possible overnight camping, and a central trail connection point.)
Highlighting the removal and/or relocation of Japanese, Italian and German American farmers from the Seashore lands during WWII
Historic Marconi/RCA (KPH Maritime) Radio Receiving Station
Historic dairy operations (tying it in to Schooner Landing)
Modern dairy operations
Historic pig and cattle ranching (tying it in to Schooner Landing)
Modern beef ranching & the local food movements
The scope of the planning process should also envision enhanced trails connections designed to reach significant cultural points of interest:
working ranches where visitors see dairy and beef ranching operations and make the connection to their food sources;
trail segments designed to reach sites showing how the Coastal Miwok re-shaped the land;
historic site of Point Reyes (on today’s F Ranch) with interpretive sites showing the connection between ranching, dairy product and meat commerce with San Francisco via shipping at Schooner Bay and access to the old piers at Schooner Landing;
Historic KPH Maritime Radio Receiving Station with its Art Deco-designed facility and interpretive sites explaining the importance of the receiving station history.
the Estero Trail alongside Home Bay and on Home Ranch lands, interpreting the cultural history of indigenous people, the history of the Shafter Home Ranch (once “possibly the largest butter dairy in the world”), rum-running at this site during Prohibition, followed by Japanese-style pea and artichoke farming until the internment of Japanese farmers during WWII and the restriction of German farmers to the eastern side of Route 1 during the same time period.
The scope of the planning process should also envision potential archeological activities at Schooner Landing to research the commerce activities of the mid-19th century and to engage high school, college, graduate and post-graduate level students in various levels of engagement with archeology and cultural anthropology.
Thank you for your consideration of these comments.
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# 2518
Name: Haarstad, Mona
Correspondence: Im a Norwegian citizen. I just get so concerned about the Tule elks future. Please don't put 5 million cattles in their habitat. It's a big mistake. Thank you for your time. Mona Haarstad, Norway.
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# 2519
Name: Zinzi, Shanti
Correspondence: No to using public land for more ranching or artichoke farms in Point Reyes.
No to destroying an ecosystem for profit and greed
Plans to do so will not only obliterate the land and wildlife but tourism.
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# 2520
Name: harlan, Blake
Correspondence: Cynthia MacLeod, Acting Superintendent
Point Reyes National Seashore
National Park Service
1 Bear Valley Road
Point Reyes Station, CA 94956
RE: General Management Plan Amendment for Point Reyes National Seashore
Dear Ms. MacLeod:
I am writing to provide input on the General Management Plan Amendment for Point Reyes National Seashore (PRNS). I support the continued operation of beef and dairy ranching operations under agricultural lease/permits with 20-year terms and improved management of the Tule elk herds to eliminate negative impacts on the environment and ranching families.
Ranchers have been raising cattle in Point Reyes for more than 150-years. It was ranchers' willingness to sell their properties to the federal government that allowed the creation of the PRNS. As part of the agreement, ranchers were supposed to be allowed to continue ranching on their family ranches within the PRNS.
The ranches in West Marin contribute significantly to the local economy and the local culture. According to any analysis by U.C. Cooperative Extension in 2009, ranches in PRNS and Golden Gate National Recreation Area (GGNRA) directly provide approximately 65 jobs and provide livelihoods for an additional 25 ranch family members. Additionally, agriculture in PRNS and GGNRA account for 17 percent of the agricultural income in Marin County. These jobs and income would be lost if further restrictions were placed on ranches within PRNS. These ranches are not just creating economic value, they are producing high quality food appreciated by consumers locally, regionally, and nationally. Further, providing 20-year terms for lease/permits allows for greater investment in improvements on these ranches. Shorter terms prevent the ability of ranchers to obtain financing for improvements.
would also like to see improved management of the PRNS elk herds. Elk cause thousands of dollars of damages and lost forage on ranches. Additionally, the elk carry Johne’s disease, which can be transmitted to cattle. USDA estimates that lost productivity from Johne’s disease in dairy cattle could be costing dairy producers between $200 and $250 million annually. Elk in the PRNS were reintroduced by humans and have been managed since their reintroduction. PRNS must improve its management by maintaining the roaming elk herds on the Limantour wilderness and preventing them from damaging ranches in the area. Additionally, PRNS should ensure that there is proper forage and water available to the herd in the Limantour wilderness to prevent a reoccurrence of the unfortunate loss of elk during the drought.
Ranches on PRNS provide important economic, cultural, and ecological values to the local community. Losing a significant portion of West Marin’s agricultural community would mean not only a loss of local food production, but a significant loss to its economy and culture. I urge you to offer 20-year lease/permits to ranchers on PRNS and to improve elk management and return the elk to the wilderness areas where they will not impact the ranches.
___________________________
# 2521
Name: Perry, Kathleen m
Correspondence: I strongly urge the National Park Service to continue allowing family run farming/ranching activities on Point Reyes Park Lands. I was born and raised around family farming operations in Mendocino County and can honestly say raising dairy and meat animals on coastal land has a minimal impact. Coastal climate and grasslands are ideally suited to raising farm animals that provide our society needs for meat, dairy, and produce.
I firmly believe park lands can be a balance of recreational lands along with family run working farm/ranch lands. Especially as human populations increase it is even more important that we encourage farming/ranching efforts instead of discouraging them.
Please contact me if you would like to discuss this further.
Kathleen Perry
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# 2522
Name: Rosen, Margaret
Correspondence: The Park Service GMP Amendment materials state: "The NPS would identify additional compatible opportunities to improve visitor experience in the planning area (e.g., enhanced trail connections, improved signage, and new interpretive waysides)." (emphasis added)
Comments:
The definition of “enhanced trail connections” should include for each alternative being considered by the National Park Service (including the “No Action” alternative): the enhancement of trail connections through creation of new trails, replacing existing 'dirt roads being used as a trail' and re-routing of one or more existing trails to account for changed conditions (e.g., connecting the Estero trail to the former site of the oyster company), and the creation of a North-South Trail plan that would link points of interest from Tomales Point in the north of the Seashore to the southern portions either or both via Estero Trail and/or Inverness Ridge Trail.
The scope of the planning process should include the creation of new interpretive sites at the site of historic Point Reyes (in today’s F Ranch) including Schooner Landing.
The scope of the planning process should also envision enhanced trails connections designed to reach significant cultural points of interest (working ranches, Coastal Miwok sites, historic site of Point Reyes, access to the old piers at Schooner Landing; historic KPH Maritime Radio Receiving Station, Shafter Home Ranch.
Thank you for your consideration of these comments.
___________________________
# 2523
Name: Miller, Jeff
Correspondence: The Center for Biological Diversity submits these scoping comments on the General Management Plan (GMP) amendment for lease lands at Point Reyes National Seashore (PRNS) and the north district of Golden Gate National Recreation Area (GGNRA). The Center is a nonprofit conservation organization dedicated to the protection of native species and their habitats through science, policy, and environmental law. The Center has more than 1.5 million members and supporters, including 216,000 in California and 3,800 in Marin County. The Center has worked to protect native wildlife and their habitats and other environmental resources of the Bay Area for more than two decades.
The Center has identified the following issues and questions which should be addressed by the National Park Service in the upcoming Environmental Impact Statement (EIS) for the GMP amendment. The Park Service should analyze existing data and information as well as conduct studies needed to inform the public of the full environmental impacts of agricultural leases and elk management strategies. The Park Service must determine which management alternatives and actions provide maximum protection, restoration, and preservation of the natural environment, and which are the environmentally superior alternative(s).
Purpose, Need and Structure of GMP Amendment
The scoping notice does not explicitly state a purpose and need for the GMP amendment and EIS, which makes it difficult for the public to adequately provide scoping comments. The notice states that the GMP amendment will update guidance for the preservation of natural and cultural resources, the management of infrastructure and visitor use in the planning area, and as appropriate, direct specific strategies for managing agricultural lease/permits and tule elk for lands in the planning area. This assertion, if representative of the purpose and need, fails to explain that a GMP is defined under Park Service policies as:
a broad umbrella document that sets the long-term goals for the park based on the foundation statement. The general management plan: (1) clearly defines the desired natural and cultural resource conditions to be achieved and maintained over time; (2) clearly defines the necessary conditions for visitors to understand, enjoy, and appreciate the parks significant resources; (3) identifies the kinds and levels of management activities, visitor use, and development that are appropriate for maintaining the desired conditions; and (4) identifies indicators and standards for maintaining the desired conditions. (2006 NPS Management Policies at 2.2)
Further, the defined purpose of a general management plan is to ensure that the park has a clearly defined direction for resource preservation and visitor use. (2006 NPS Management Policies at 2.3.1)
The Park Service must follow its policies that describe how the planning process should occur and what must be involved, which include:
This basic foundation for decision-making will be developed by an interdisciplinary team, in consultation with relevant NPS offices, other federal and state agencies, local and tribal governments, other interested parties, and the general public. The management plans will be based on full and proper use of scientific and scholarly information related to existing and potential resource conditions, visitor experiences, environmental impacts, and relative costs of alternative courses of action.
The approved plan will create a realistic vision for the future, setting a direction for the park that takes into consideration the environmental and financial impact of proposed facilities and programs and ensures that the final plan is achievable and sustainable. The plan will take the long view, which may project many years into the future, when dealing with the time frames of natural and cultural processes. The first phase of general management planning will be the development of the foundation statement. The plan will consider the park in its full ecological, scenic, and cultural contexts as a unit of the national park system and as part of a surrounding region. The general management plan will also establish a common management direction for all park divisions and districts. This integration will help avoid inadvertently creating new problems in one area while attempting to solve problems in another. (2006 NPS Management Policies at 2.3.1)
Each parks approved general management plan will include a map that delineates management zones or districts that correspond to a description of the desired resource and visitor experience conditions for each area of the park. Management zoning will outline the criteria for (or describe the kind of) appropriate uses and facilities necessary to support these desired conditions. For example, highly sensitive natural areas might tolerate little, if any, visitor use, while other areas might accommodate much higher levels of use. Even in historic structures, one floor might be most appropriate for exhibits, while another could accommodate offices or administrative uses. Some desired conditions may apply parkwide, but the delineation of management zones will illustrate where there are differences in intended resource conditions, visitor experiences, and management activities. (2006 NPS Management Policies at 2.3.1.2)
Park Service policies explain that a GMP is the most appropriate context for developing or reviewing a foundation statement because of the comprehensive public involvement and NEPA analysis. (NPS 2006 Management Policies at 2.2) The Park Service must formulate a foundational statement for the ranching lease areas as part of the GMP amendment.
Park Purposes
Discuss the ways and degree to which ranching leases and ranching activities and operations are in conflict with or support maximum protection, restoration, and preservation of the natural environment at PRNS and GGNRA.
Discuss the ways and degree to which ranching leases conflict with public recreation and public benefit at PRNS and GGNRA.
Discuss the ways and degree to which ranching leases and activities fail to conserve and provide for public enjoyment of the scenery, natural and historic objects, and wildlife of the PRNS and GGNRA lease areas.
Discuss the ways and degree to which ranching leases fail to leave natural resources at PRNS and GGNRA unimpaired for the enjoyment of future generations.
Discuss the ways and degree to which ranching leases and activities promote or conflict with recreational, educational, historical preservation, interpretation and scientific research opportunities at PRNS and GGNRA.
Impairment is defined as harm to the integrity of park resources or values, including the opportunities that otherwise would be present for the enjoyment of those resources or values. How has the Park Service determined which uses and activities within the ranching lease areas will not impair park values or resources? What information was used to determine that ranching activities will not cause impairment or unacceptable impacts?
For activities and uses within the ranch lease areas which have been determined not to impair natural values, how do such uses and activities fulfill the fundamental purpose of the National Park System, which is to conserve park resources and values and provide for the enjoyment of park resources and values by the people of the United States?
Discuss the legislative history of the Point Reyes Act, and whether the Act supports continuing or ending ranching, and under what circumstances.
Proposed Alternatives
No Ranching Alternative
The scoping notice states that a No Ranching alternative would consider continuing to allow prescriptive grazing in high priority areas to maintain native and rare plant communities. Describe the science that supports such grazing as beneficial for native and rare plant communities. Describe the science that determines what levels and practices of cattle grazing are compatible with or conflict with maintaining these native and rare plant communities.
Reduced Ranching Alternative
In a reduced ranching alternative, the Park Service should not choose ranching operations to eliminate based on the economic impact to private leaseholders and commercial facilities. Rather, the Park Service must be guided by its management policies to prevent impairment of natural resources and wildlife, by eliminating the most environmentally harmful ranches and ranching activities.
In a reduced ranching alternative, the Park Service should also analyze ranch leases for closure based on the lease-holders history of non-compliance with lease conditions, problems with overgrazing, the presence of threatened/sensitive species, the presence of tule elk, conflicts with recreational access, water pollution, impact on wilderness areas, and other environmental factors.
Discuss the 2008 draft GMP for PRNS which considering closing the ranches that drain to Drakes Estero, and the rationale for proposing to close these ranches.
No Dairy Alternative
The scoping notice suggests that the No Dairy alternative could consist of switching current dairy operations to beef cattle grazing. Discuss what the impacts would be in terms of reduction or increase in AUMs, RDMs and forage from switching from dairy to beef cattle. Discuss why if dairy ranches are eliminated, those lands should not be retired from all grazing, to give lease lands that suffer from cattle overuse and concentration and need time to heal. Discuss the environmental and public benefits from retiring dairy operations and giving lease lands over to public use and wildlife habitat, rather than beef cattle grazing.
Continued Ranching and Management of the Drakes Beach Tule Elk Herd w/ 20-Year Permits Alternative
There is serious concern that the Park Service has this alternative listed as an initial proposal, which suggests the agency may have already improperly identified it as a preferred alternative, which would foreclose a robust and fair consideration of alternatives.
Alternative with Removal of Drakes Beach Elk Herd
Discuss the futility of attempting to remove tule elk from the Drakes Beach and ranch lease areas through translocation to other areas of the park. Discuss Park Service research showing that translocated elk returned to the Drakes herd and the fact that elk can easily swim across Drakes Estero. Discuss the origin of the Drakes Beach herd from the Limantour herd and the likelihood that elk will or will not stay out of ranch lease areas. Discuss the annual expenditure of taxpayer dollars from Park Service employees moving and hazing elk from the ranch lease areas.
Continue Current Management Alternative
Continuing current management is not the no action alternative. A true no action alternative would let existing grazing leases expire and take no further action.
Issues Common to All Ranching Alternatives
How did the Park Service create the arbitrary number of acres to remove from ranching or include as resource protection buffers? It is impossible for the public to comment on these alternatives without some understanding of how these numbers were reached.
Why are maximum population thresholds needed for the Drakes Beach elk herd? Are these thresholds to benefit private lease holders, or is there some ecological justification for limiting the size of the elk herd?
The Park Service is proposing to establish broad management strategies for ranches, but the agency should also identify site-specific practices to fully consider unique resources and ranching impacts in each lease area.
Types of Authorizations (10 v. 20 year)
Most federal lands grazing permits, such as on U.S. BLM and U.S. Forest Service lands, are limited to 10 year leases. The 20-year lease directive issued by former Interior Secretary was arbitrary, illegal due to lack of NEPA compliance, and is inconsistent with NPS policies on ranching.
Annual grazing lease authorizations are needed for the Park Service to be able to control and manage cattle herd numbers and AUMs, and to include and modify Best Management Practices to respond to resource concerns such as drought, overgrazing, conflicts with wildlife, and public recreation needs.
Elk Management
Discuss the carrying capacity of the entire PRNS and GGNRA for tule elk and whether the current elk population is anywhere near that capacity.
Evaluate the potential for rebuilding large elk herds at PRNS and the benefits such herds would provide for the genetic diversity and long term persistence of the species.
Explain the scientific and ecological basis (not the economic basis to benefit ranchers) for managing tule elk in a national park using lethal methods, hazing, or sterilization.
Explain the scientific basis for fencing free-ranging elk populations on public land.
Explain the rationale for managing the pastoral zone for the exclusive use of private commercial cattle operations and excluding or removing native wildlife.
Discuss why the fenced elk herd in the Tomales Point Elk Preserve declined 47% during the drought years from 2012-2014, while the free-roaming elk herds at Limantour and Drakes Beach increased by 28% and 39%, respectively, during the same period.
Explain the consequences of continuing to keep the Tomales Point herd fenced or fencing out the Drakes Beach herd rather than allowing elk to move freely to find water and food.
Assess leaseholder claims about elk impacts, including: to what extent elk actually eat livestock forage; the potential damage from elk rubbing their antlers on agricultural equipment; and the possibility that elk have stabbed cattle to death with their antlers.
Endangered Species
Identify and map all habitats for wildlife and plants listed under the federal and state Endangered Species Acts as endangered, threatened or a species of special concern, as well as protective buffers needed to maintain ecological function for their suitable habitat.
Identify all designated critical habitat for federally listed species at PRNS and GGNRA and where ranching leases overlap or runoff drains into critical habitat.
Identify where ranching and dairying activities overlap with habitat for state listed species.
Discuss which ranching and dairying activities and uses within the ranch leases areas conflict with or support providing maximum protection for sensitive species or their critical habitat.
Discuss which ranching and dairying activities and uses within the ranch leases areas are compatible with or conflict with protection and recovery of federally listed species.
Discuss any adverse or potentially significant impacts (under NEPA) from ranching activities on designated critical habitat for any federally listed species.
Discuss what limitations or mitigation measures are needed for ranching activities that conflict with protection of listed species.
Identify where removal of important habitat areas from the designated pastoral zone is needed to protect listed species.
Identify where exclusionary fencing is needed to protect sensitive habitats for listed species from livestock.
Identify where reduced stocking levels of livestock in overgrazed areas is needed to protect listed species.
Identify where a prohibition on silage and mowing is needed to protect sensitive species.
Identify where removal and control of invasive species is needed to protect sensitive species.
Salmon and Steelhead
Identify any potentially significant impacts (under NEPA) from ranching activities on Central California Coast coho salmon, California Coastal Chinook salmon, or salmon habitat.
Identify any potentially significant impacts (under NEPA) from ranching activities on Central California Coast steelhead trout or trout habitat.
Identify any continuing or unresolved ranching impacts on salmonid habitat in Olema Creek and tributaries, Lagunitas Creek and tributaries, and tributaries of Drakes Estero.
Identify what salmonid protection measures from the 2004 NMFS Biological Opinion for salmonids have not been implemented.
Identify which stream reaches with livestock grazing do not have 15 to 30 meter riparian buffers.
Discuss the results of salmonid habitat and riparian monitoring, as required by the 2004 NMFS Biological Opinion for salmonids.
Identify any continuing problems and impacts to salmonid streams and habitat from cattle grazing in PRNS and GGNRA.
Discuss where and how often suspended sediment, nutrient or fecal coliform thresholds have been exceeded in salmonid streams, whether ongoing problems have been identified, and what remedies have been implemented.
Discuss where and how often water temperature thresholds have been exceeded in salmonid streams, whether ongoing grazing problems have been identified, and what remedies have been implemented.
Discuss whether excessive sedimentation issues and impacts to channel form and morphology have been identified in salmonid streams from grazing and what remedies have been implemented.
Discuss whether damage, loss or inhibition of growth of riparian vegetation has been identified in salmonid streams. Discuss whether the NPS has met the 2004 NMFS Biological Opinion success criteria for riparian vegetation.
Discuss whether erosion of streambanks or loss of habitat complexity has been identified in salmonid streams from grazing and what remedies have been implemented.
Discuss the results of monitoring for suspended sediment, fecal coliform, channel bed conditions, water temperatures, and riparian vegetation conditions in salmonid streams, as required by the 2004 NMFS Biological Opinion.
Discuss whether and how NPS has ensured that aquatic and riparian habitat conditions in salmonid streams continue to improve and remain in good condition.
California Red-legged Frog
Discuss any adverse or potentially significant impacts (under NEPA) from ranching activities on the California red-legged frog, or frog habitat.
Discuss livestock grazing impacts on red-legged frog habitat in terms of riparian and wetland habitat alteration, water pollution, damage to breeding sites, and trampling of estivation habitat.
Identify the measures the NPS has taken since 2002 to protect seasonal upland habitats and travel corridors for CRLF from impacts by cattle.
Western Snowy Plover
Discuss any adverse or potentially significant impacts (under NEPA) from ranching activities on western snowy plovers or plover habitat.
Discuss whether any cattle have had access to snowy plover nesting areas at PRNS since 2002, including trespass cattle.
Discuss changes in populations of common ravens at PRNS since the 2002 USFWS Biological Opinion, and the role dairies and ranches have in elevating raven populations.
Discuss raven predation on snowy plovers at PRNS since the 2002 Biological Opinion.
Identify what measures have been taken to reduce feeding opportunities for common ravens at ranches and dairies.
Discuss whether the NPS has allowed any increase in silage production or whether the NPS has returned any silage fields to permanent pasture, since the 2002 Biological Opinion.
Myrtles Silverspot Butterfly
Discuss any adverse or potentially significant impacts (under NEPA) from ranching activities on the Myrtles silverspot butterfly or butterfly habitat.
Discuss any evidence of livestock trampling host plants or butterfly larvae.
Identify NPS mapping and monitoring of Myrtles silverspot butterfly larval host and nectar plants, and responses of these plants to different grazing regimes.
Discuss any change in status of Myrtles silverspot butterfly populations and host plants at PRNS since the 2002 Biological Opinion.
Discuss the measures NPS has taken to remediate adverse impacts to Myrtles silverspot butterfly and host plants from cattle grazing.
Listed Plants
Discuss any adverse or potentially significant impacts (under NEPA) from ranching activities on Sonoma alopecurus, Sonoma spineflower, Marin dwarf flax, Tiburon paintbrush, Beach layia, or Tidestroms lupine.
Discuss the scientific evidence that excessive livestock grazing adversely affects Sonoma alopecurus. Discuss the trends of Sonoma alopecurus populations subject to livestock grazing.
Discuss the scientific evidence that livestock grazing negatively affects the Tiburon paintbrush. Discuss the trends of Tiburon paintbrush populations subject to livestock grazing.
Discuss the scientific evidence that livestock grazing may negatively affect the Sonoma spineflower. Discuss the trends of Sonoma spineflower populations subject to livestock grazing.
Discuss the scientific evidence that livestock grazing is a major threat to Tidestroms lupine, due to loss of dune habitat. Discuss the trends of Tidestroms lupine populations subject to livestock grazing.
Identify NPS mapping and monitoring of these listed plants, and discuss responses of these plants to different grazing regimes.
Discuss any change in the status of populations of these listed plants at PRNS since the 2002 Biological Opinion.
Discuss any measures taken to remediate adverse impacts from grazing to any of these listed plants, including: seasonal restrictions on grazing; exclusion fencing; and establishment and plantings.
Water Quality Impacts
Discuss the condition of fresh water resources within the ranching areas, and any impairment due to grazing and ranching activities.
Discuss impairment to water quality in creeks within PRNS and GGNRA from livestock grazing and dairies.
Discuss impairment to water quality in wetlands and other freshwater habitats within PRNS and GGNRA, including Drakes Estero and Abbotts Lagoon, from livestock grazing and dairies.
Discuss impairment to water quality in Tomales Bay due to livestock grazing and dairies at PRNS and GGNRA.
Discuss fecal coliform, ammonia and bacteria inputs to creeks and freshwater habitats from livestock grazing and dairies, and the impacts on aquatic wildlife and ecosystems.
Discuss nutrient inputs to creeks and freshwater habitats from livestock grazing and dairies, and the impacts on aquatic wildlife and ecosystems.
Discuss sediment inputs to creeks and freshwater habitats from livestock grazing and dairies, and the impacts on aquatic wildlife and ecosystems.
Discuss how dairies and livestock grazing leases control or fail to control livestock waste discharge and runoff.
Discuss what needs to be done to remediate the impairment of water quality by livestock grazing and provide aquatic resources with maximum protection, restoration and preservation as required by the parks enabling legislation and the Organic Act.
Discuss NPS plans to restore creek banks and riparian zones negatively impacted by former or current ranch operations.
What scientifically based buffer zones and setbacks are in place for grazing and ranching operations near streams, riparian areas and wetlands to ensure their ecological function?
Identify any uses of pesticides or other toxic chemicals at ranches and dairies.
Analyze and disclose the ecological impacts from dams and stock ponds on ranchlands.
Discuss how the NPS will ensure that ranching leases comply with water quality standards as required by the Federal Facilities provision of the Clean Water Act.
Discuss how the NPS will consider whether GMP alternatives comply with the Coastal Zone Management Act.
The San Francisco Bay Regional Water Quality Control Board commented on the previously proposed Ranch Comprehensive Management Plan and expressed concerns whether PRNS ranching operations operate in compliance with current federal and state regulations, including Waste Discharge Requirements and/or waivers of WDRs issued by the Water Board. The Board stated [w]e would like to see specific details developed in the Final NEPA document that address rangeland assessment and facility inspections, compliance monitoring, record-keeping, implementation of management practices, reporting, and, if necessary, enforcement. The Final NEPA document should also discuss NPS enforcement of State and federal regulations. Discuss how the GMP amendment will address these issues raised by the Water Board.
Discuss how the NPS will address specific issues raised by the Water Board, including: water supply development; impacts to riparian zones; performance standards for fencing; maintenance of dairy and ranch land infrastructure; farmstead storm water BMPs; and water quality monitoring program.
The Water Board requested evaluation of bacteriological water quality impacts associated with cattle being grazed near, or allowed direct access to creeks where they sometimes linger. How will the GMP amendment address this issue?
The Water Board noted that the NPS has prioritized and completed water pollution remediation actions in some tributaries, but cattle still gain access to several creeks not identified as "top-priority" tributaries. The Water Board stated that it isn't clear how the NPS determined what constitutes a "top priority" and if it has evaluated the water quality impacts of having cattle in "lower priority" tributaries. How will the GMP amendment address this issue?
Other Wildlife and Habitat Impacts
Discuss the science on livestock grazing impacts to native vegetation at PRNS and GGNRA.
Discuss the science on livestock grazing impacts to riparian areas at PRNS and GGNRA.
Identify the amount of water use needed for beef and dairy cattle production at PRNS and GGNRA; quantify how that impacts water available for native wildlife and plants.
Discuss whether pasture dogs are allowed on PRNS and GGNRA lease areas and the impacts on wildlife.
Discuss any rancher depredation of wildlife or requests for wildlife control at PRNS and GGNRA.
Identify whether the NPS pays or allows any other agency or entity to manage or depredate wildlife on PRNS and GGNRA lands.
Forage
Discuss how the NPS determines how much forage is available for livestock on each ranch lease, and identify the forage levels on each ranch lease.
Discuss and quantify the forage needs of tule elk, deer, and other native grazing and browsing animals in PRNS and GGNRA.
Discuss how the NPS determines what percentage of available forage should go to livestock rather than to native wildlife.
Discuss how the NPS determines whether cattle grazing leases and silage operations will leave adequate forage for native grazing and browsing animals during dry and drought years.
Discuss how RDM levels are established for lease areas and whether they are adequately protective of native ecosystems and wildlife.
Discuss the NPS analysis of PRNS grazing (RDM or Residual Dry Matter monitoring), which found overgrazing at several ranches.
Discuss why the NPS has chronically failed to enforce existing RDM standards for grazing leases, and how it will enforce them in the future to prevent overgrazing and erosion.
Discuss documentation of overstocking of cattle and other violations of lease conditions, and NPS failure to enforce lease stocking allowances.
Discuss whether current and proposed livestock stocking levels are maximally protective of creeks, wetlands, wildlife habitat and water quality.
Adjust and update the parks definition of AUMs to accurately reflect the current weights of dairy and beef cattle and their actual forage consumption.
Discuss the impact of mowing for silage on breeding birds, per the 2015 Point Blue report documenting declines in grassland bird abundance and nesting at PRNS.
Best Management Practices
What sort of Best Management Practices does the NPS require through grazing leases?
How does the NPS determine BMPs for grazing leases?
Are the BMPs adequate to protect natural resources?
How much are BMPs monitored? How are BMPs enforced? Disclose examples.
Assess the effectiveness of BMPs in protecting natural resources.
Invasive Species
Discuss the extent to which exotic and invasive plants exist in the ranch areas.
Discuss which invasive plants were brought to PRNS and GGNRA by cattle.
Identify where invasive plants are spread or maintained by cattle grazing and silage production.
Discuss how cattle grazing, importation of hay, and other ranching activities promote the spread of invasive plants.
Discuss how NPS intends to control invasive plants in the lease areas.
Discuss the science regarding whether and under what conditions cattle grazing can help control or spread invasive plants.
Identify where and under what circumstances cattle grazing would be used for invasive plant control, and whether the proposed grazing regimes are reflective of actual grazing practices in lease areas and are enforceable by NPS.
Discuss elevated populations of invasive starlings and native cowbirds due to ranching and dairy operations, and the impacts on nesting of native birds.
Discuss elevated populations of ravens due to ranching and dairy operations and impacts on native wildlife, particularly snowy plovers.
Disease Transmission
Discuss the presence and extent of Brucellosis in wildlife and livestock at PRNS and GGNRA, and the potential and most likely routes of transmission.
Discuss the relative potential for Brucellosis to be transmitted from to livestock to wildlife; and from wildlife to livestock.
Discuss the presence and extent of Johnes Disease in wildlife and livestock at PRNS and GGNRA, and the potential and most likely routes of transmission.
Discuss the relative potential for Johnes Disease to be transmitted from to livestock to elk and other wildlife; and from wildlife to livestock.
Discuss whether these diseases existed in the park before the reintroduction of elk.
Discuss the historical presence of these diseases in PRNS and GGNRA livestock and the conditions of dairying and ranching activities which can act as a vector for these diseases.
Discuss what role the ranching practice of spreading cattle manure on grasslands likely has in transmitting these diseases to native wildlife.
Discuss the NPS monitoring plan for PRNS and GGNRA livestock for presence of Brucellosis, Johnes Disease, and other livestock diseases which can harm native wildlife.
Discuss the NPS remediation plan for eliminating these diseases from PRNS and GGNRA livestock.
Fencing
Identify where exclusion fencing has been installed to keep livestock out of creeks, riparian areas, wetlands, and freshwater aquatic habitats. Discuss the condition, effectiveness, and monitoring of this exclusion fencing.
Identify where such exclusion fencing does not exist and where livestock have access to creeks, riparian areas, wetlands, and freshwater aquatic habitats.
Discuss issues with lack of maintenance and repair of cattle exclusion fencing, which allows trespass cattle into sensitive areas.
Identify which fences in PRNS and GGNRA are not wildlife friendly, and the potential impacts on elk and other native wildlife. Discuss injuries to and deaths of native wildlife from fencing.
Identify fencing that is unneeded or no longer in use for cattle and provide a timeline for derelict fence removal to improve movement of wildlife.
Roads
Discuss the science showing that ranch roads contribute to erosion, sedimentation of streams, and pollution.
Discuss the extent to which PRNS and GGNRA ranch roads fragment habitat or affect wildlife movement.
Identify ranch roads no longer needed or in use for ranching, for removal to reduce erosion, pollution and sediment.
Discuss the impact that ranching and dairying trucks have on roads, and the extent to which additional repairs are needed on main roads due to impacts from heavy ranching vehicles and equipment.
Fire
Discuss the science which supports the concept of using grazing to control fire fuels.
Discuss the California Department of Parks and Recreations comprehensive analysis of cattle grazing impacts and its minimal effect on standing biomass and fire hazard reduction on Mount Diablo State Park, and CDPRs experience in managing wildlands without livestock grazing.
Greenhouse Gasses
Discuss how ranching and dairying activities subvert PRNS goals in the Climate Friendly Parks campaign. Discuss 2005 PRNS analysis that 78% of the parks carbon emissions are from dairy wastes (or manure) in the form of methane gas. Identify what portion of the remaining park emissions from transportation sources are from ranching lease activities.
Update the parks outdated GHG emissions inventory conducted in 2005. Discuss current estimate of livestock and dairy ranching contribution to PRNS greenhouse gas emissions and what percentage that represents (include all CO2 contributions, including methane emissions from dairies, contributions from milk, hay and manure trucks, farm equipment, etc.).
Will the NPS require methane digesters at any continuing dairies?
Discuss the science showing that concentrated animal feeding operations such as dairies can have serious impacts on air pollution and human health from ammonia and other gases. Analyze and disclose those impacts at PRNS.
Discuss whether any peer-reviewed science supports the concept of carbon sequestration through livestock grazing, and what can realistically be sequestered versus the CO2 footprint of ranching operations.
The GMP amendment should ban compost use on rangelands before any CO2 offset impacts are proven. The GMP should promote native grassland restoration to sequester carbon.
Public Access/Recreation
Identify where dairying operations and facilities and fencing are not compatible with public access.
Discuss how ranching impedes recreational enjoyment due to cattle waste, unpleasant odors and sights, an industrialized landscape, mowing, reduced wildlife sightings, trail erosion, and a lack of hiking and biking opportunities.
Analyze in detail various alternative public uses for ranching lease lands, including wildlife habitat, wildlife viewing and photography, research, recreation, campgrounds, educational facilities, etc.
Discuss reports and complaints of ranchers closing public lands to recreationists, and fences impeding hiking and enjoyment of PRNS and GGNRA by the public.
Diversification
Fully analyze the damaging environmental impacts of permitting proposed diversification schemes, such as new kinds of exotic livestock, small animals, row crops, dairy processing, on-site slaughtering, hotel operations, and other proposed commercial activities within PRNS.
Fully analyze the impacts of allowing row crops, including reduced habitat for wildlife, creating conflicts with native birds and predators that may feed on them, requiring additional fencing, and use of water.
Fully analyze the impacts of allowing chickens, turkeys, ducks, geese, sheep, goats, rabbits and similar small animals, including creating conflicts with native predators.
Fully analyze what new structures and infrastructure would be required for different diversification schemes.
Discuss how various diversification schemes would negatively impact park wildlife.
Discuss whether allowing any additional private economic enterprises or activities would conflict with the purposes of PRNS.
Identify what diversification operations have already been approved, or are being illegally conducted in lease areas, including farm stay operations, chickens, and any agricultural activities other than cattle grazing.
Discuss how various diversification uses would limit or prevent public access.
Residential Facilities and Impacts
Disclose all commercial and residential structures in the grazing lease areas, including primary residences, employee housing, barns, etc. Discuss who pays for them and how much.
Disclose under what laws and regulations the NPS authorizes year-round residential facilities for ranchers and their employees in addition to grazing.
Disclose and analyze the environmental impacts and public costs of infrastructure/utilities that accompany the ranching, including septic tanks, wells, waste disposal, parking lots, electricity, fences, water developments, roads, elk management, environmental mitigation, etc.
What residential facility upkeep costs are the Park Service responsible for in the lease areas - roofs, plumbing, painting, renovations, septic tank pumping, etc.?
Does the Park Service inspect the residential facilities or otherwise ensure the ranchers are not harming these public buildings?
How many people live at all the ranches? How many annual visitors are there to the ranches? What are the greenhouse gas and other impacts?
Are off-road vehicles allowed on ranch lease areas? Do ranchers store gasoline for equipment? Are there spills?
Lease Enforcement Problems
Discuss concerns and evidence of grazing lease violations, such as illegal subleasing, overstocking, shooting or poaching wildlife, or blocking public access.
Discuss dumping of trash, including barbed wire, and improper disposal of livestock carcasses in the lease areas. Discuss the impacts on wildlife.
How does the NPS ensure compliance with lease conditions?
Has the NPS ever taken any enforcement action for lease violations?
Economics
Discuss the economic benefits to the local economy from park visitors and wildlife viewing. Contrast income from recreation versus income from park grazing leases, per the 2006 NPS Economic Impacts Study.
Evaluate the true economic costs of grazing leases, including: below-market grazing rates; subsidized housing; NPS funded improvements to ranches; NPS funded mitigation for ranch environmental impacts; costs of monitoring, compliance and enforcement of lease conditions; damage to roads and other infrastructure; etc.
How does the NPS determine Fair Market Value of grazing and housing leases? Is this consistent with federal policy and with other federal lands?
Compare the PRNS and GGNRA grazing lease and housing rental rates to equivalent grazing land rates and rents outside the park. Quantify the annual loss to PRNS from providing below-market leases for grazing and rent.
Quantify the annual loss to PRNS from ranching infrastructure improvements (such as fencing, road maintenance, erosion control, habitat restoration, monitoring, compliance, etc.).
Quantify the PRNS ranching contribution to the local, county and state economies.
Assess rancher claims that ending or reducing PRNS ranching would destroy the Marin agricultural economy.
Analyze and disclose how much staff time NPS spends on monitoring, compliance, working with ranchers on BMPs, and permitting in the lease areas, and the estimated annual costs.
Aesthetics
Analyze and disclose the aesthetic impacts to park visitors from ranching and dairying operations, including creating an industrialized environment, ranch vehicles, trash, fencing, damaged roads, lighting, cattle manure, etc.
Historic Resources
Analyze and disclose how ranching affects pre-ranching archaeological resources.
Discuss whether Point Reyes ranching operations and facilities have any unique value as historic resources, given that they are younger than almost every other ranch operation in the country. Discuss whether any of the ranches have historic attributes that cannot be found on nearby private ranches in Marin and Sonoma counties.
Transparency
Disclose how many meetings the NPS has had with ranchers, agricultural interests, and pro-ranching advocates in developing this plan. How many meetings since the July 2017 settlement was announced? How many meetings since 2014 when the Ranch Comprehensive Management Plan was launched?
Disclose how many meetings the NPS has had with ranching reform advocates, other users of the park, or wildlife interests in the same time periods, in developing this plan.
Discuss how the NPS will ensure that the GMP amendment and EIS will be a fair, open process that is not biased by political pressure or a backroom sweetheart deal for ranchers from the illegal Salazar decision.
Sincerely,
Jeff Miller
Conservation Advocate
Center for Biological Diversity
1212 Broadway, Suite 800
Oakland, CA 94612
[e-mail]
___________________________
# 2524
Name: Carlsen, Stacy K
Correspondence:
November 13, 2017
GMP Amendment c/o Superintendent
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes Station, CA 94956
Re: Point Reyes National Seashore General Management Plan Amendment
Dear Superintendent Cynthia MacLeod,
I greatly appreciate the opportunity to comment on the Point Reyes National Seashore (NPS) General Management Plan Amendment (GMPA). I recommend GMPA Alternative #5 Continued Ranching and Removal of the Drakes Beach Tule Elk Herd.
Food, People Place
The social basis for a democratic food policy lies in movements for employment and incomes, for safe and nutritious food, for environmentally sensitive agriculture (including treatment of animals) and for democratic participation & Democratic principles & emphasize proximity and seasonality - sensitivity to place and time. This means the use and development of technologies and markets to facilitate local enterprises in every link of agrofood chains. What is increasingly clear is that healthy food and environmentally sound agriculture must be rooted in local economies. (Friedmann 1993)
Point Reyes National Seashore Agriculture - An Economic Model of Necessity
Marin County agriculture is recognized as a leader in Californias agricultural sustainability movement and local food security. Farming in the Point Reyes National Seashore (NPS) contributes to the stability of our entire County of Marin farm system. NPS ranches and dairies account for nearly 20% ($20 million) of all gross agricultural production in Marin County. These ranches and dairies play a critical role in maintaining the viability of Marin County agricultural infrastructure and economic viability. The farming fabric infiltrates into every phase of community activities and virtually all economic transactions. Application of an Economic Input-Output Model (EIO) to NPS farms and ranches would have an economic multiplier impact of nearly four (4) times the gross production values or $80 million. The total gross Marin County agricultural production in 2016 was valued at greater than $100 million ($400 million total under the Input-Output Model). Marin is principally a grass based agricultural system where livestock and livestock products accounts for greater than 72% of the gross values equaling $72 million ($288 million EIO). The GMPA must evaluate the economic impact of losing 20% ($80 million) of the total agricultural output for the county including the impact on the remaining agricultural and infrastructure serving all other agriculture including services operations in the region. County-wide milk production accounts for 40%, cattle for 13%, poultry for 12%, pasture for 11%, aquaculture (oysters) for 6.5% and vegetables, lamb, silage, grapes, and nursery products make up the balance of the gross production value. It is essential the GMPA establish economic measures identifying agricultural resources including local community benefits and economic contribution of PRNS dairies, livestock, and other agricultural outputs.
The PRS Ranching Background and Needs
There are 16 livestock ranches and 6 Dairies operation in the NPS. Ranching and farm culture in West Marin Point has gone on for over 150 years. Their history stems from the Gold Rush-49er Era and framed by the Shafter Era giving way to todays multi-generations family operations.
Historically, farms in the Seashore have practiced all forms of agriculture. County of Marin Agricultural Crop reports show during the 1930-1950 a diverse production of fruits and vegetables in addition to todays livestock, poultry, and dairy operation. Diversification is a key aspect that NPS ranchers need to remain economically viable. The Park Administration should evaluate the benefits and support diversification, value added practices, and limited amount of processing consistent with regional allowed activities generally accepted outside the National Seashore boundary.
Interestingly, all dairies in the Seashore area are Certified Organic under the United States Department of Agriculture, National Organic Program (USDA,NOP) certified by the Marin County Agricultural Commissioner and other accredited organic certifiers demonstrating the progressive nature and willingness to support animal health, land stewardship, and environmental protection as mandated by the NOP. These practices and programs enhance existing PRNS environmental standards and with further review and adoption of these standards would generate an improved outcome of the GMPA. The general public trust the integrity of organic so should the NPS. Collectively the entire Pastoral area of the NPS Agricultural region represents one of the largest contiguous organically certified areas in Marin County, California, possibly the nation. This is a pinnacle in terms of production model and land sustainability and stewardship. This productivity coupled with the high biodiversity, ecological quilt, edge effect of multiple habitats, and topography gives exceptional resiliency for both agriculture and natural systems to flourish. This General Management Plan Amendment should recognize farm sustainability, production, marketing of the agricultural products raised in the NPS and to educate the public about the compatibility of farming and nature.
The Point Reyes National Seashore should acknowledge ranchers for their land management and stewardship.
This recognition would be in the form of adopting the GMPA Alternative #5 Continued Ranching and Removal of the Drakes Beach Tule Elk Herd.
Models for allowing these activities are identified by many highly successful local and regional farming businesses including value added cheese and other dairy processing activities. In addition, many local codes and policies and non-profit organizations established in Marin County support agriculture. The Marin County General Plan and the subtending Agricultural Element, Grass-fed Beef Ordinance, Organic Farm Certification Ordinance, Prohibition of Growing GMOs Ordinance, Right To Farm Ordinance and guidelines identified in Marin County Local Coastal Plan reflect the overall support of farming and natural resources protection. There are no higher standards for land use protection policies. Evaluation and adoption of these particular programs would improve overall performance and support of Seashore Ranchers and should be included in the GMPA. Inclusion would be consistent with farming activities outside the NPS and offer a consistency in regional farming policies.
Seashore ranchers are commercial operations competing with regional farming operations. They are not Hobby or Boutique Farms! They need the flexibility to create an identity for their regional products, a collaborative Seashore-Rancher Brand i.e., Seashore Rancher Cheese, etc. and the National Seashore should endorse and support such efforts. The NPS resides in Marin County where the local food movement has shaped our views of what organic agriculture really stands for, seriously investing in local grown and consumed product, knowing your farmer and recognizing the importance of our farms sequestering carbon closing the gap on carbon emissions and global warming. Allowing farms in the National Seashore to produce value added products, and sell local will demonstrate the willingness to walk the walk while lightning our carbon footprint. Losing any family farm operation, or limiting their ability to remain competitive, jeopardizes the economic viability of our entire agricultural system in Marin County.
Administration and Ranchers Share Compliance and Best Management Practices
The ranchers in the Seashore have basically the same challenges. They are trying to maximize the Coastal Prairie Grassland (Pastoral Zone) to produce livestock and dairy products for sale. Ranchers are Land Managers responding to changes in their social, political and economic conditions while finding means of bringing them under control. Ranchers in this state or condition have complied with NPS policies and mandates and improved the value of land through stewardship and BMPs for land management in partnership with NPS scientist/managers. Working in concert many restoration and improvement projects have been completed resulting in net benefits concerning local and downstream events. This land management team has together applied known or discovered skills to land in such a way to minimize or repair degradation, and ensure the capability of land is continued into the future. Ranchers are sensitive to land protection and have built resilience into agricultural system. Ranchers are asking the PRNS to recognize their operations as Historical Ranching Operation, Food Production Zones, or Permanent Agricultural Zones. These terms better reflect the nature of the activities and importance of their economic contribution and environment protection to the County of Marin. I believe the National Seashore Superintendent should harmonize with USDA Mission, Vision, and Goals and acknowledge that ranching is ever changing, market driven, and must be sustainable.
Correlation between Organic Act Mission and NPS Farm History
On August 25, 1916, President Woodrow Wilson signed, interestingly enough the Organic Act creating the National Park Service, a new federal bureau in the Department of the Interior, with a Mission that "the Service thus established shall promote and regulate the use of Federal areas known as national parks, monuments and reservations . . .. by such means and measures as conform to the fundamental purpose of the said park&& strives to meet those original goals, while filling many other roles as well: guardian of our diverse cultural and recreational resources; environmental advocate; world leader in the parks and preservation community; and pioneer in the drive to protect America's open space.
In our case GMPA area of concern- a fundamental purpose was to maintain Agricultural/Pastoral Region of the National Seashore, which historically was farmed long before National Park was establishment in 1962. The 1962 enabling legislation referred to ranching and dairying purposes of the PRNS. The 1978 Amendments broadened the terminology to agriculture, ranching and dairying purposes Every effort to promote and protect this agricultural resource is directly connected and consistent with the Organic Act Mission&. by such means and measures as conform to the fundamental purpose of the said park&. strives to meet those original goals of the PRNS.
Enacted in 1978, Public Law 95-625 provided standardized legislative language for the leasing of land for agricultural purposes within these NPS units (16 U.S.C. §§ 459c-5 and 16 §§ 460bb-2(j)). Following these mandates NPS managers have authorized ranching and dairying operations through agricultural lease/special use permits (lease/permits) issued to ranchers. The lease/permits include terms and conditions that ensure the protection of natural and cultural resources.
For nearly 40 years farmers have complied with Public Law 95-625 to ensuring the protection of natural and cultural resources have adhered to various mandates, regulations, policies including the following mandated range management activities and programs:
✔ Monitors various attributes, including vegetation, water quality, and ranch infrastructure.
✔ Works with ranchers to implement best management practices to protect sensitive resources, including water quality and rare and endangered species.
✔ Conducts residual dry matter monitoring each fall to assess the amount of plant material left at the end of the grazing season.
✔ Works with ranchers to monitor and manage invasive nonnative vegetation.
✔ Conducts permitting for individual management actions and improvements by ranch operators not covered under lease/permits, such as fence construction and water developments.
These stated program activities are higher standards than practiced throughout the farming region outside of the NPS boundaries. These exceptional standards cannot be compared to large dairy/livestock confinement operation found in other regions in the USA that do not have on site range management officials to determine compliance with NPS laws, regulations, policies and formal auditing of ranching procedures to determine compliance with lease agreements statutes. Plaintiffs in the lawsuit leading to this EIS/NOI process are misdirected- clearly lacking knowledge between outstanding land stewardship by ranchers and the co-relation with the NPS in complying with the highest farming standards in the USA.
In addition, the NPS should recognize that all the NPS organic dairy/livestock/poultry operations meet the highest livestock and poultry standards adopted under the National Organic Program (NOP) enforced by The U.S. Department of Agricultures (USDA) Agricultural Marketing Service (AMS). These standards when applicable should be considered in development of the GMPA. The NOP standards are transparent and enforceable as recently mandated.
On Jan. 18, 2017, USDA announced a final rule that strengthens the integrity of the organic label by clarifying production requirements for organic livestock and poultry. The final rule establishes a level playing field for organic producers, bolsters consumer confidence in the organic label, and ensures that all organic animals live in pasture-based systems utilizing production practices that support their well-being and natural behavior. Given all our dairies in Marin County, including the six (6) in NPS, are certified organic under USDA our consumers and PRNS managers can be confident that the highest measures to protect animal health and welfare and natural resources protection are implemented.
In addition, the final rule supports the core goal of the Organic Foods Production Act (OFPA), which instructs USDA to develop regulations - including detailed standards for organic livestock and poultry production - to ensure that organic products meet a consistent standard. The NPS managers should evaluate these standards and adopt them as Best Management Practices (BMPs) as strategies to preserve park resources and effective animal health standards. These standards fully vetted by the National Organic Standards Board (NOSB) are ready for adoption by the NPS to further enhance the Leases/Special Use Permits standards identified in the 1978 Public Law 95-625.
PRNS could explain in their NOI/EIS findings that all Dairies in the PRNS are compliant with USDA NOP organic farming standards highlighting the following major provision of the rule which:
✔ Clarifies how producers and handlers must treat livestock and poultry to ensure their health and well-being throughout life, including transport and slaughter.
✔ Specifies which physical alterations are allowed and prohibited in organic livestock and poultry production.
✔ Establishes minimum indoor and outdoor space requirements for poultry.
These rules can be viewed at www.regulations.gov or on the AMS website.
Issuance of Lease/Permits for 20 years
Some actions to further the support for agriculture should include developing long term lease documents (20 years) as directed in the November 29, 2012, memorandum for then Secretary Salazar. The Secretary of the Interior directed the NPS to pursue the issuance of lease/permits for terms up to 20 years.
This GMPA should fully evaluate the concept of a 20 year rolling renewal agreement. In this type of agreement, at the end of each year the lease is automatically renewed for the length of the initial 20 year term, unless either the landowner or the farmer decides that the current term will be last term. In this way, the parties can continuously capture the benefits of a long term lease. The benefits include:
✔ More commitment by the rancher to invest in infrastructure and repairs
✔ Improved public enjoyment of the seashore
✔ More likely that banks will offer loans to the rancher;
✔ More likely that ranchers will invest in long term rangeland improvements
✔ More likely that ranchers will invest in resource conservation projects
✔ More rancher eligibility for resource conservation project grants
✔ Reduced NPS staff time and paperwork
✔ Creation of more public trust
✔ Ranch intergenerational/ succession planning
This appears to be a perfect place and opportunity to utilize a rolling renewal agreement because the park has respected the relationship of the families with the land as part of the cultural landscape, and the leases/permits have been successfully adopted for nearly 40 years. Given the successful history of compliance with park mandates ranchers have demonstrated they are capable and willing to protect park resources while fulfilling the local and regional demand for food, livestock and dairy products.
Ranching is a commitment that requires day-in and day-out activity, year after year. Marin family farmers are trying to stay competitive, but shifts in farm production costs and the loss of farming neighbors can have a cascading affect. Family farms rely on neighbors so they may together generate a collective economy of scale to yield economic benefits, as well as provide a buffer against hard times. Allowing long term rolling 20 year leases are necessary to maintain long term farming operations, commitments from farm supply business, lenders, and other community support organizations.
Additionally, a need exists for consistent policies and procedures covering:
✔ capital improvements
✔ roads, fencing
✔ farm labor housing
✔ vegetative management
✔ water improvement projects
Ranchers and dairies should be given equal protection and treatment, allowed to adopt similar activities, (including those activities practiced outside the NPS) and use the best available science and management practices. An example is the ability to produce silage for livestock feed, brush and weed control, fencing repairs, and selective least toxic herbicide use to control invasive species, etc. The finished General Management Plan Amendment and resulting policies should be vetted with the Point Reyes Seashore Ranchers Association who should be allowed to be a partner in the discussion on implementation. The Ranchers Association should be the venue Park Superintendent uses to announce, discuss, and direct how the GMPA will be utilized once certified by the Department of Interior - NPS. Collectively ranchers need to understand what the Park can do that may be beneficial so they can individually and/or collectively make sound decisions. These activities should be shared with all ranches and freely discussed. Applying Best Ranching Practices should be celebrated and recognized; learning from each other should be a primary goal.
Federal, State, and Local Agency Resources
Many existing Federal, State, and local agencies are available to work in a cooperative manner with NPS administration, field staff, and ranchers to maximize productivity, resources management, and conservation practices. The United States Department of Agriculture - Natural Resources Conservation Services (NRCS), California Resources Agency, and Marin County Resources Conservation District (RCD), University of California Cooperative Extension (UCCE), and Marin County Agricultural Commissioner are great examples of locally available resources to assist with farm plans and project assistance. NRCS offers voluntary programs to eligible landowners and agricultural producers to provide financial and technical assistance to help manage natural resources in a sustainable manner. Through these programs the agency approves contracts to provide financial assistance to help plan and implement conservation practices that address natural resource concerns or opportunities to help save energy, improve soil, water, plant, air, animal and related resources on agricultural lands. The RCD has regional expertise in soil and waterway management and conservation practices including Carbon Sequestration tools and practices, UCCE has expertise in farm sustainability, livestock and rangeland management, the Agricultural Commissioner is the regulatory agency overseeing pesticide use and USDA Accredited Organic Farm Certification Agency. These agencies could enhance, improve, and benefit the NPS in land use, conservation, and resources management and marketing activities. Adoption of BMPs should be incorporated into the GMPA.
Ranchers identify the need for USDA assistance through an Environmental Quality Incentive Program (EQIP) project or conservation support programs. These activities have been evaluated within the agency of origin and comply with existing National Environmental Standards. The NPS should embrace and implement valuable projects without requiring a separate National Environmental Policy Act (NEPA) or other lengthy review before a project can be undertaken. The National Seashore General Management Plan Amendment should harmonize with other Federal and State agencies that have complied with legal procedures and allow for their utilization without further scrutiny. Many USDA projects are granted on an annual basis and delays in administrative approval eliminate the Seashore rancher to access while other ranchers in the region enjoy support and financial assistance. Between the PRNS, RCD, USDA, and other noted agencies a very successful and collaborative approach could be reached benefitting everyone. Ranchers in the Park want to be recognized as Class A and have access to all available resources.
Tule Elk Impacts on Ranching and Agency Compliance
There are now two independent free-ranging herds, one near Drakes Beach and one near Limantour that extends onto ranch lands in the Estero Road area.
Tule Elk are impacting ranchers (Drakes Beach Herd - 110 estimated total animals - 70 in 2014), an increase of 40 Elk. The main herd (consisting of females, juveniles, and a few males), and male bachelor groups, spend time on A Ranch, B Ranch, C Ranch, E Ranch, the former D Ranch, because they have migrated beyond the fenced wilderness boundary area onto ranch land, they compete for feed and water resources intended for livestock, disrupting operations, and increasing operating cost while potentially exposing the livestock to disease pathogens (Johnes).
migration of Tule elk onto pastoral lands is equivalent to supplemental feeding artificially increases the size and density of the elk herd, and this practice may contributed to the spread of disease among the elk and livestock including erosion of their habitat. The NPS must consider various goals for managing elk: (1) conserving their habitat in designated Wilderness areas, (2) making the population sustainable, and (3) managing the risk of disease. The NPS wilderness areas are prescribed as a boundary to allow elk to freely roam and to flourish. It is not truly a wilderness in a natural geographical resources context. As such these areas must have a well-designed integrated management plan to properly sustain the herd size and health within the designated wilderness areas. The most notable practices include brush management, enhancing grassland production, and water supplies. Creating a healthy habitat in NPS wilderness is superior to regularly hazing elk seeking supplemental feed on pastoral land.
The Historic C Ranch (Spaletta Dairy) is the most impacted ranch sustaining the constant Elk feeding pressure on their dairy pasture (2 Elk = 1 Cow) and causing fence damage and consuming water intended for their cows. Pasture loss must be replaced with feed purchased and trucked into the dairy significantly increase production cost. Elk interfere with normal cow management such as herding and they disrupt milking times/schedules. The Elk pasture consumption also places ranchers into the risk of not meeting NPS residual dry matter standards. Not meeting the requirements may subject the rancher to reduce animal stocking rates to meet NPS animal to available feed ratios. In addition, reduced pasture access to cows affects the ability to retain organic certification- if cows do not have access to open pasture as mandated under NOP standards dairies may lose certification.
Efforts to disperse Elk by NPS specialists come with a great level of labor and equipment use and have proven to be ineffective. Ranchers are left with the grinding pressures and must deal with Elk disrupting routine dairy activities increasing expenses otherwise spent on normal ranch activities.
Wilderness designated lands and Pastoral/Ranch leased lands should be given equal protection corresponding to their intended use and purpose. Wilderness Areas are intended for displaying nature and Resources Specialist to manage whereas the Pastoral Areas are intended to be managed for agricultural use by the rancher. There should be little allowance for commingling resources use and management styles between them. When livestock are found in Wilderness, they are removed. Likewise, when Elk are found in Pastoral Zones they too should be removed: not really that complicated to manage. A well designed plan to correct the imbalance of Elk in the Pastoral areas should be clearly defined in the GMPA to move Elk back to Wilderness Zone is a priority of ranchers.
There are many opportunities and success stories waiting to be told by this and future generations of ranchers if Park Officials embrace, partner, assist, and recognized the value that ranchers bring to the Point Reyes National Seashore Working Landscape and to the Mission of the National Park Service.
Respectively,
Stacy K. Carlsen
Marin County Agricultural Commissioner
Director of Weights and Measures
___________________________
# 2525
Name: Schneider, George
Correspondence: Dear Superintendent,
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
George Schneider
___________________________
# 2526
Name: Taylor, George E
Correspondence: Point Reyes National Seashore is very important to me and to my family. I have been visiting the Point Reyes area since the 1970s, my wife and I honeymooned there and travel there one to three times each year. We hike, walk, stay and eat on the peninsula each time we are there.
My principal concern with the management of the Point Reyes National Seashore is what has been the gradual erosion of the living cultural history inherent in the agricultural life there. Point Reyes National Seashore was established surrounding land that has been inhabited by people for generations - going back centuries of American, Spanish and Indigenous populations. People and the lives lived and work done there are embedded in what is important to the experience of visiting Point Reyes National Seashore and merit a higher priority than has been evident in the management to date. Attempting to "wild" much of Point Reyes or return it to some imagined wilderness state is offensive and deceptive.
I would urge the clear recognition of the obligation to preserve and nurture the living cultural history within the Point Reyes National Seashore as a principal priority - protecting the ranches and dairies and removing or carefully managing the intrusion of the elk herds that damage the prospects for ranching and farming. My extended family has farmed in another part of the country for generations - it is a part of our heritage that we value. We value wilderness and we value human enterprise - they are complementary and must both be honored and preserved.
___________________________
# 2527
Name: N/A, N/A
Correspondence: Dear Superintendent,
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
Gina Marano
___________________________
# 2528
Name: Marvel, Jonathan H
Correspondence: Thank you for the opportunity to comment.
As part of the development of the Environmental Impact Statement (EIS) the General Management Plan Amendment for the Pt. Reyes National Seashore and the Golden Gate National Recreation Area, the National Park Service (NPS) needs to provide a complete inventory and assessment of current conditions on the 28,000-acre project area. For example:
1. The NPS must provide a full assessment of the current impacts of all agricultural activities on other values including but not limited to existing fencing, surface water quality, ground water quality, all soils conditions, soil erosion and compaction, air quality, impacts to native plants and plant communities, impacts to native wildlife (including but not limited to Tule elk) and wildlife habitat, impacts to estuarine and ocean conditions caused by surface water run-off from agricultural fields and all other agricultural activities and impacts on recreational activities that may be thwarted or limited by authorized agricultural activities.
2. The NPS must provide all current written terms and conditions under which all project area authorized agricultural activities take place including any and all monitoring information on livestock ranching and dairying in the project area held by NPS and/or any other federal agency that describe whether agricultural activities are in compliance with current authorizations or not. For example, what do agricultural permittees pay the NPS for their leases? Are they responsible for 100% of maintenance on buildings or other ranching or dairying infrastructure like fencing, cattle guards, manure pits, dead animal disposal etc.? What consequences exist for non-compliance with existing lease terms and conditions, and have any penalties or other consequences ever been imposed?
The provision of this this and other information on current conditions will enable a much better analysis of the impacts on these values of each alternative to be assessed in the EIS especially if any alternative includes expanding the kinds of agricultural activities that could be authorized by NPS in the project area.
The NPS needs to assess as part of the EIS another reasonable alternative that would end all livestock ranching and dairying on the project area. Such an alternative will be useful to have in order to compare to the impacts of each proposed alternative that maintains or expands agricultural activities and may also be shown to be the most environmentally desirable alternative.
All alternatives analyzed in the EIS that propose to authorize any level of agricultural activities need to provide the written terms and conditions that will be required by the NPS for that activity to take place. For example what protections will be included as leaseholder terms and conditions to protect legally protected objects of the National Seashore and the National Recreation Area including native and non-native plant communities, water quality (both ground and surface), air quality, soils, micro fauna and flora including fungi and lichens and the visual and sound experiences of visitors, estuarine conditions, wildlife and wildlife habitat and recreational activities. Presumably the NPS does not just give potential agricultural leaseholders a lease without any terms and conditions at all!
Please keep me on the email list for all publications and opportunities for public involvement as this analysis process moves forward.
___________________________
# 2529
Name: N/A, N/A
Correspondence: Point Reyes National Seashore
National Park Service
1 Bear Valley Road
Point Reyes Station, CA 94956
RE: General Management Plan Amendment for Point Reyes National Seashore
Dear Ms. MacLeod:
I am writing to provide input on the General Management Plan Amendment for Point Reyes National Seashore (PRNS). I support the continued operation of beef and dairy ranching operations under agricultural lease/permits with 20-year terms and improved management of the Tule elk herds to eliminate negative impacts on the environment and ranching families.
Ranchers have been raising cattle in Point Reyes for more than 150-years. It was ranchers' willingness to sell their properties to the federal government that allowed the creation of the PRNS. As part of the agreement, ranchers were supposed to be allowed to continue ranching on their family ranches within the PRNS.
The ranches in West Marin contribute significantly to the local economy and the local culture. According to any analysis by U.C. Cooperative Extension in 2009, ranches in PRNS and Golden Gate National Recreation Area (GGNRA) directly provide approximately 65 jobs and provide livelihoods for an additional 25 ranch family members. Additionally, agriculture in PRNS and GGNRA account for 17 percent of the agricultural income in Marin County. These jobs and income would be lost if further restrictions were placed on ranches within PRNS. These ranches are not just creating economic value, they are producing high quality food appreciated by consumers locally, regionally, and nationally. Further, providing 20-year terms for lease/permits allows for greater investment in improvements on these ranches. Shorter terms prevent the ability of ranchers to obtain financing for improvements.
would also like to see improved management of the PRNS elk herds. Elk cause thousands of dollars of damages and lost forage on ranches. Additionally, the elk carry Johne’s disease, which can be transmitted to cattle. USDA estimates that lost productivity from Johne’s disease in dairy cattle could be costing dairy producers between $200 and $250 million annually. Elk in the PRNS were reintroduced by humans and have been managed since their reintroduction. PRNS must improve its management by maintaining the roaming elk herds on the Limantour wilderness and preventing them from damaging ranches in the area. Additionally, PRNS should ensure that there is proper forage and water available to the herd in the Limantour wilderness to prevent a reoccurrence of the unfortunate loss of elk during the drought.
Ranches on PRNS provide important economic, cultural, and ecological values to the local community. Losing a significant portion of West Marin’s agricultural community would mean not only a loss of local food production, but a significant loss to its economy and culture. I urge you to offer 20-year lease/permits to ranchers on PRNS and to improve elk management and return the elk to the wilderness areas where they will not impact the ranches.
___________________________
# 2530
Name: Atiles, Dennessa
Correspondence: Pt. Reyes is one of my favorite places on earth. The history and the beauty of the landscape and wildlife are almost unmatched. I saw an Elk once while on the Bear Valley trail. It was majestic and we should not kill them. Please let the wildlife live and not sell our reserves to more agri land
___________________________
# 2531
Name: Luckey, Amy
Correspondence: Dear Superintendent,
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
Amy Luckey
___________________________
# 2532
Name: N/A, N/A
Correspondence: This is another instance of overreach by government. The people who brought this law suit have no skin in the game. They use the Tule Elk as an argument to support their agenda. No one considers that these small businesses are a part of the fabric here and not to be casting disruptions on. People that live in this area matter. The Elk are doing fine and would probably do better if there was a natural predator like the Wolf to keep the heard genetics strong. Since the Wolf is now in CA and moving south they may well be in the park in as little as 10 years. Point being the management of such resources cannot be successful when done by those that do not work the land. Ask the people who live here how to do it better and they will help you get it done. I have seen Tule Elk doing just fine on MT. Oso CA. They were introduced there in the 1930's. It rains about 6 Inches on average each year there. The Elk here are healthy and live in concert with the agricultural practices here. They are protected by the rule of law for CA. Washington cannot manage an Indian reservation without the worst object poverty in the country suffered by the indigenous peoples that live there under their management. It will be the same for the Elk and people who live in this area when you exclude the people in the management plan who keep the poachers out to mention one very important benefit. They become your eyes and ears when you forge bonds of common interests. Make them your partners and the Elk will thrive.
___________________________
# 2533
Name: Perez, Lucio E
Correspondence: Cynthia MacLeod, Acting Superintendent
Point Reyes National Seashore
National Park Service
1 Bear Valley Road
Point Reyes Station, CA 94956
RE: General Management Plan Amendment for Point Reyes National Seashore
Dear Ms. MacLeod:
I am writing to provide input on the General Management Plan Amendment for Point Reyes National Seashore (PRNS). I support the continued operation of beef and dairy ranching operations under agricultural lease/permits with 20-year terms and improved management of the Tule elk herds to eliminate negative impacts on the environment and ranching families.
Ranchers have been raising cattle in Point Reyes for more than 150-years. It was ranchers' willingness to sell their properties to the federal government that allowed the creation of the PRNS. As part of the agreement, ranchers were supposed to be allowed to continue ranching on their family ranches within the PRNS.
The ranches in West Marin contribute significantly to the local economy and the local culture. According to any analysis by U.C. Cooperative Extension in 2009, ranches in PRNS and Golden Gate National Recreation Area (GGNRA) directly provide approximately 65 jobs and provide livelihoods for an additional 25 ranch family members. Additionally, agriculture in PRNS and GGNRA account for 17 percent of the agricultural income in Marin County. These jobs and income would be lost if further restrictions were placed on ranches within PRNS. These ranches are not just creating economic value, they are producing high quality food appreciated by consumers locally, regionally, and nationally. Further, providing 20-year terms for lease/permits allows for greater investment in improvements on these ranches. Shorter terms prevent the ability of ranchers to obtain financing for improvements.
I would also like to see improved management of the PRNS elk herds. Elk cause thousands of dollars of damages and lost forage on ranches. Additionally, the elk carry Johne's disease, which can be transmitted to cattle. USDA estimates that lost productivity from Johne’s disease in dairy cattle could be costing dairy producers between $200 and $250 million annually. Elk in the PRNS were reintroduced by humans and have been managed since their reintroduction. PRNS must improve its management by maintaining the roaming elk herds on the Limantour wilderness and preventing them from damaging ranches in the area. Additionally, PRNS should ensure that there is proper forage and water available to the herd in the Limantour wilderness to prevent a re-occurrence of the unfortunate loss of elk during the drought.
the recent wild fires here in Northern California you should also consider and recognize the added benefits of grazing and range management that occurs with livestock. These activities help keep fuel sources for fire from building up to dangerous levels and cause increased damage and destruction to all surrounding communities.
Ranches on PRNS provide important economic, cultural, and ecological values to the local community. Losing a significant portion of West Marin’s agricultural community would mean not only a loss of local food production, but a significant loss to its economy and culture. I urge you to offer 20-year lease/permits to ranchers on PRNS and to improve elk management and return the elk to the wilderness areas where they will not impact the ranches.
Sincerely,
Lucio E Perez
L Perez & Sons Vineyards
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# 2534
Name: Adams-Wiley, Mary
Correspondence: As a citizen of Elk Grove, CA (next door to Sacramento) I urge you to save the Elk. How about Right to Life for all Elks in all of California? We appreciate our Elk and our trees in groves - - both need to be around for future generations.
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# 2535
Name: Albiani, Adella
Correspondence: Dear Superintendent,
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
Adella Albiani
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# 2536
Name: Weber, Edward
Correspondence: I am writing to support the alphabet ranches as they are today at Pt Reyes National Seashore. I believe this historic use of land is appropriate for several reasons, including continuity, which should not conflict with national policies.
I am an equestrian, and have been pleased to enjoy the configuration of ranches as they are. We have easy access to ride horses on those properties, which offer unique recreation and views of the magnificent seashore, with lots of fingers and bays. The comingling with wildlife is awesome. I recall riding on one of these shoreline ranches with a group of equestrians and witnessing a mountain lion in pursuit of deer, unaware of our presence, on a finger of land across a small bay. I proffer that this experience reflects a proper use of these lands, which have only prospered in the hands of local ranchers as stewards.
These ranches represent generations of agricultural use, dating back to early settlements of America. From the time of Spanish land grants, hardworking immigrant families established their dairies and pastures, feeding the SF Bay Area and caring for the land. There is no conflict with nature here; rather, the sensitive care provided by local farmers and ranchers allows a wonderful symbiosis which is an entrenched part of Bay Area history.
While some purists lacking local experience may opine that this land should suddenly be pristine with limited access by their mandate, I would ask them to show me the damage caused by human presence and agriculture, which have existed here long before any current opinion makers arrived on the scene. The San Francisco Bay Area is on everyone's Top Ten list of amazing places in the world, as it is and has been for centuries. These lands are prospering as they are, so there is no legitimate cause for change.
The American people are the true owners of these lands. Those of us who frequent them and know and love them well, speak first hand from regular visits and informed use. We wish for them to remain in their historic use, which, thanks to the farmers care, is pristine, accessible and appropriate.
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# 2537
Name: Smith, Donald L
Correspondence: The language "Additional Preliminary Conceptual Alternatives" heading up the description of Continued Ranching is disturbingly tentative and dismissive, as if they are in there for form and not substance. And yet, private ranchers signed up decades ago to become part of PRNS only because of guarantees of continued ranching. It would be a disgraceful abandonment of these agreements not to make Continued Ranching the Preferred Alternatives and to work diligently and in good faith to resolve any issues surrounding that plan.
Ranching is foundational to both the pastoral landscape and the economy of West Marin. In deliberations about the GMPA, the Park Service should seriously consider the negative impact on the people of this County of undermining ranching. In particular, elk management is in dire need of improvement. It is startling to me that the problem of herds reproducing out of control appears not to have been thought about when they were introduced, given the prior bad experience in many other parks and the obvious lack of predators. Where a herd is confined, starvation results; and when it is not, it runs rampant well beyond its intended territory. The cost to ranchers of trucking in forage to replace what NPS's deliberately and thoughtlessly introduced elk have devoured should be paid back to the ranchers, and that should be included among the proposals in the GMPA.
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# 2538
Name: Webb, Janet
Correspondence: Please maintain grazing as a part of Point Reyes management. Grazing helps maintain open grasslands, which are an important ecosytem, while also providing some revenues that could be used to put back into stewarding the land. Grazing helps greatly to minimize the encroached of some agressive, non-native plant species such as Pampas grass and broom. In the coastal area I live in, I have noticed the rapid degradation of our coastal grasslands when grazing was removed from the landscape. Further,when the Point Reyes area was taken under federal ownership, the continuance of grazing was a part of the promised management. A strong commitment by the Park Service towards maintaining grazing as a permitted use, coupled with realistic management objectives that allow for economically viable ranching is what good ranchers will need to give them the confidence to invest in the livestock and infrastructure maintenance (fences, roads, water, etc) needed to help them acheive long term sustainable grazing.
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# 2539
Name: HUGHES, MICHAEL C
Correspondence: Dear Superintendent,
The Park Service's amendment to the General Management Plan for Point Reyes National Seashore should prioritize protecting the natural values of the area. It should therefore provide for the free-roaming tule elk herds is the area to survive and thrive. Tule elk are an important part of the landscape of Point Reyes and their recovery is a success for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
Sincerely,
Michael C Hughes
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# 2540
Name: Castignetti, Nancy
Correspondence: Dear Superintendent,
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
Nancy Castignetti
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# 2541
Name: N/A, N/A
Correspondence: Elk deserve total protection from harm
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# 2542
Name: N/A, N/A
Correspondence: Dear Superintendent,
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
Aurora Gardner-Murfin
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# 2543
Name: Geldhof, Joseph W
Correspondence: My spouse and I are frequent visitors to Pt. Reyes National Seashore and have been since 1992. It is one of our favorite national conservation system units in the country.
Both of us strongly believe dairy farming within Pt. Reyes National Seashore should be allowed to continue according to reasonable guidelines. We also believe the existing elk population should be managed in a manner that allows for the harmonious perpetuation of elk and diary cattle, if at all possible.
The issue of successfully perpetuating dairy farming within the confines of Pt. Reyes National Seashore requires careful balancing of interests that involve continued residency of dairy farmers and perpetuation of Pt. Reyes National Seashore as a wild land and seascape with full protection of indigenous animals and plant life as possible. We tend to favor wildlife values over human development but at Pt. Reyes, there is no reason not to continue existing dairy farming at the present level so long as the scope and scale of farming is not increased. It is also apparent to both of us that some management mechanism or technique needs to be deployed in the new plan that will encourage the dairy farmers leasing the property within the boundaries of the Pt. Reyes National Seashore to invest in superior maintenance of the farm structures and dwellings they live in or use. As someone who actually worked on a dairy farm when I was much younger, I have some apprehension on how hard dairy farming is and how marginal the business operations often are. While I don't have a specific recommendation on how to facilitate better maintenance of structures in the park, I do think care should be made in the new plan that will lead to better maintenance of existing structures or encouragement of new structures that are acceptable from a historic and aesthetic perspective. Also, some thought should be given to working with Marin County on whether or not some of the existing roads within the Pt. Reyes National Seashore might be rerouted and reconstructed over time in order to enhance the experience of visitors, for protection of wildlife and in order to afford for more efficient and safe dairy farm operations.
Best of luck devising a plan that will work for everyone. Regards,
Joe Geldhof and Corine Geldhof
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# 2544
Name: Von Dohre, Beverly J
Correspondence: The site is confusing, with six? proposals that have no numbers.
This is the alternative I'm voting for:
No Ranching and Limited Management of Tule Elk.
It's past time for Pt. Reyes to be as much of a natural wilderness as possible. (Though I do not support the nativists killing plants they deem non-native and agree with planting Monterey Cypress, etc.)
It's horrifying that eliminating any elk is even being considered. Stop the birth control and let them extend into their original range. Clearly they do well at Pt. Reyes, considering the increasing heat from climate change.
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# 2545
Name: Holmes, K
Correspondence: Please let the Tule Elk Live!
Let's not kill an eco-system that's already been disturbed thanks to humans.
Let's not the greed for $$ by the giant corporations ruin and destroy every thing that is naturally beautiful and sacred.
Thanks!
sincerely,
an outdoor and nature gal
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# 2546
Name: R, Rachel
Correspondence: I support the free-roaming tule elk herds at Point Reyes National Seashore; I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape and ecosystem of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands should not dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and should not harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens, or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely, Rachel
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# 2547
Name: Jones, Kyana
Correspondence: The National Park Service must demonstrate that you have the animals' interests at heart!
The welfare of wildlife MUST COME BEFORE profit from ranching activities. Please do the right thing and let the Tule Elk live!
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# 2548
Name: Cooper , Susan
Correspondence: I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
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# 2549
Name: Carlsen, Stacy
Correspondence: Conceptual Alternatives #4 and #5 (Cont. Reading manage Elk)
(Dairy/Ranching 20 yr lease) are both acceptable alternatives.
However, the removal of Elk using the methods established through planning processes would be favorable. The establishment of 1200 buffer depending on the location may allow elf to be managed and recovered from the pastoral zone know in existence. Set up a buffer for Elk but not allowing Elk on Ag. Designated land #5 option (preferred)
Also - for 40 years (1978 Public Law 95-625) unlike ranches outside the Park Boundary PRNS ranches have worked with PRNS staff to ensure the protection of natural and cultural resources following NPS guidelines for Range Management Pasture Activities including water quality, endangered species, residual dry matter, invasive non-native vegetation - give them credit - a lot of credit.
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# 2550
Name: King, Cassie
Correspondence: Please let the Tule Elk live and be free from human interference and violence. Murdering them or hurting them in any way is not the answer. They deserve to live.
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# 2551
Name: N/A, N/A
1) Rogers Ranch (David Evans Lease) operates continually and with his ATT leased pasture. The 2 leases are operates as a combined grazing plan and that combined use is memorialized within the Rogers Ranch lease whereby Stocking Rates are combined to include both leases as if they were on lease - because they are managed as one whole. Seasonal grazing is managed across both leases allowing proper rest and management of nature and endangered species. Rogers Ranch, being the smallest acreage Ranch requires additional acreage to manage effectively.
I will hope that these facts are considered as an amendment to the "Reduced Ranching" alternative.
I strongly support the NPS initial proposal. And want to see ranches allowed diversified uses as envisioned in the Comprehensive Ranch Management Plan - let ranches diversify uses to not only provide additional economic/ commercial use, but also provide better public access in the form of short term rentals, educational tours, specified farm product rental sales, multi species production, and events.
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# 2552
Name: Johnston , Bob
Correspondence: Please carefully consider the sediment and nitrogen runoff from the dairies. Also the impacts on listed species of mowing and other ranching and dairy practices.
Also, I believe the Secy of Interior's letter was not an order, but was a recommendation. And, I think he said "leases up to 20 years," not "20 years." That is important.
Please consider the impacts from grazing in the probable future (near +far) of more-variable rainfall. Droughts will be longer and so grazing permits should reduce numbers of cattle/cows in dry years.
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# 2553
Name: Wixsom, Margo
Correspondence: I am very grateful for the outstanding service of the PRNS staff and rangers.
As a resident of wilderness, I request the GMP supply where to the original agreements establishing the PRNS. All farmers / ranchers were paid for lifetime use. Once a farm family decides to no longer farm then all lands returned to the use of PRNS for native/natural environment.
No expansion of any commercial farm applications on PRNS as per original agreement. No leasing/subletting of any PRNS lands to any other farmers outside of original farmland.
Allow expansion of the Tule Elk herds because they are native species - reduce or discontinue use of lands for cattle as per original agreements. There are millions of CA acreage- both public and private available for ranch cattle. There is only ONE PRNS and its intent is to preserve this natural habitat for future generations.
Clarify that no one is "being kicked off" these lands. Farmers were paid for lifetime use - once that is o longer feasible, all lands returned for education / recreational use.
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# 2554
Name: Cleff, Adam
Correspondence: The area by lighthouse shows poor management.
#1 goal should be protection of the resources; the land and wildlife.
I do not think diary's are compatible with this goal.
Beef-ranch cattle may be a good management tool if applied properly.
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# 2555
Name: N/A, N/A
Correspondence: Dear Superintendent,
I am writing IN SUPPORT of the free-roaming tule elk herds at Point Reyes National Seashore, and I STRONGLY OBJECT to ANY fencing, removal, sterilization or killing of elk in the park!! Tule elk are a very important part of the landscape of Point Reyes, and their recovery has been an exciting SUCESS story for RESTORING native species and ecosystems, CONSISTENT WITH THE MISSION of the National Park Service.
Commercial lease holders on our public lands SHOULD NEVER dictate, or have a say in ANY wildlife removal or exclusion policies. They don't give a damn about the wildlife, they care only for themselves $$$$$$! Any cattle-ranching operations MUST be managed to accommodate elk and other native wildlife, and SHOULD NEVER harm habitat for endangered species! certainly YOU must know that!
I also STRONGLY URGE you to REJECT ANY CONVERSION of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality, and is NOT the way I want to ourPUBLIC LAND used!
The Park Service's amendment to the General Management Plan should PRIORITIZE protecting the natural values of Point Reyes National Seashore.
Sincerely,
Kari Freidig
tax payer, voter, and lifelong California resident
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# 2556
Name: Foehr, Alfreida G
Correspondence: Of the six Preliminary Draft Alternatives proposed I prefer the alternative #5. CONTINUED RANCHING AND REMOVAL OF THE DRAKES BEACH ELK HERD. I support continued ranching because the ranchland operations are an integral part of the history and beauty of the Point Reyes National Seashore. I support removal of the Drakes Beach Tule Elk Herd by the NPS because of the negative financial impact their presence has on all ranching operations. It makes sense to remove them and to contain and manage them elsewhere within the park, in conjunction with an implemented plan to control their population.
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# 2557
Name: Dolcini, Sam
Correspondence: Please count this letter as a letter of support for the option to allow that ranchers in the Point Reyes National Sea Shore to have all the flexibility that they need to keep their businesses moving forward.
I have been involved for many years working to preserve Family Farms and Ranches in Marin County and the greater North Bay Area.
All of the operations are critical including the ranches and dairies operating in the National Park. Please do everything that you can to keep them in business.
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# 2558
Name: Carnoll, Terence
Correspondence: Please define "Diversification" and explain why it is included in all the alternatives expect the "no ranching" alternative.
Please provide the legal justification for allowing agricultural activities other than ranching.
Please explain how removal of Tule Elk from public lands in order to benefit private commercial interest is consistent with applicable laws and policies, and how it would leave the park on impaired for future generations.
Please clarify where in the GMP process the issue of succession will be dealt with.
Please clarify the role and authority of California State Agencies in the GMP process, including the Coastal Commission, CA Fish and Wildlife, and the Regional Water Quality Control board.
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# 2559
Name: N/A, N/A
Correspondence: What is meant by "diversification"?
I'm not in favor of increasing ranching options to include row crops, chickens, or anything else.
 
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# 2560
Name: Powers, Kate
Correspondence: November 13, 2017
Cynthia MacLeod
Acting Superintendent
Point Reyes GMP Amendment
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes Station, CA 94956
Subject: First Phase Comments for the Point Reyes National Seashore General Management Plan Amendment
Dear Acting Superintendent MacLeod,
Introduction
Thank you for this opportunity to provide comments during the first phase of the Point Reyes National Seashore and Golden Gate National Recreation Area north district (PRNS/GGNRA) General Management Plan Amendment (GMP Amendment) planning process. The Marin Conservation Leagues mission since 1934 is to preserve, protect, and enhance Marins natural assets. In 2015, MCL approved its Agricultural Policy Statement (attached) which includes the following stated goal:
To continue to support the role Marins 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.
In accordance with our goal, and consistent with MCLs previous positions and actions regarding agriculture and our mission to conserve Marins national park assets, we are in full support of the continuation of ranching and dairy production on the PRNS and GGNRA. We hold that there is a direct and mutually supportive connection between the GMP amendment and our agricultural policy and seek to partner with the National Park Service and the farm families on the Seashore to realize this connection. We further hold the GMP Amendment as a timely opportunity for NPS, working with the ranchers who have managed the land for generations and Marin partners, to lead the nation again by providing a solution that achieves the multiple objectives society holds for safeguarding the unique natural resources as well as the working landscape within the Seashore.
Specific Comments
We offer the following specific comments as initial considerations and recommendations for issue identification and the refinement and analysis of alternatives during the GMP Amendment planning process and environmental review under the National Environmental Policy Act (NEPA). MCL will continue to participate in the GMP Amendment planning and review processes during coming years.
Land Allocation
Ranching and dairy farming should continue in the pastoral area on the greatest acreage possible as originally authorized. This will provide the best opportunity for each ranch to remain viable, assure the continued contribution of agricultural production on the Seashore to the local community and economy, and meet the larger goal of preserving this cultural and historic resource in the park. Additionally, any conversion of land from agricultural management by a farm family to alternative land uses would increase the management demands upon NPS staff which, in the face of a proposed 13% budget cut, would be difficult to provide.
Each of the three settlement-required alternatives represents real risks and compromises to these objectives. The six PRNS dairies represent 20% of the total number of dairies in Marin County and they ship to local processors such as Clover Sonoma and Straus Family Creamery. Removing them as proposed in the No Dairy Ranching alternative would eliminate an irreplaceable source of milk for the Marin-Sonoma milk shed, and would compromise this cultural use and landscape in both counties. The No Ranching alternative, in itself, acknowledges the ecosystem management role played by grazing livestock, with the point &NPS may coordinate prescriptive grazing in high priority areas to maintain native and rare plant communities. The proposed removal of 7,500 acres in the Reduced Ranching alternative would result in at least ten existing ranches being eliminated. The Environmental Impact Statement (EIS) should thoroughly analyze how the maximum allocation of land to grazing livestock and dairy farming provides needed on-the-ground resource management that might otherwise be beyond the capacity of NPS; how it maintains the contributions made to the strength of regional and local economy; and how it successfully achieves the cultural and natural resource preservation and management objectives of the NPS for PRNS and GGNRA.
The concept of buffers is, on its face, one that MCL supports. Buffers should be situated strategically to protect sensitive resources, but in ways that do not overly impact any single ranch. Additionally, significant consideration should be given to buffers that have already been put in place and not formally named. Management requirements of these buffers should be addressed, including the avoidance of undesirable invasive plant species and the unintended consequence of disrupting plant community structures and harming sensitive species that depend on a grazing regime for survival.
Leases
Lease length is directly related to the strength and viability of farming and ranching operations. Long leases promote long-term viability of ranching operations by providing the ability to reliably forecast economic costs and returns. This includes investments in infrastructure upkeep, natural resource management, maintenance of healthy water and air quality, and assurances of farm employees welfare. The proposed 20-year leases are a good first step to create this environment for success. Longer leases would contribute even greater confidence and stability. When structuring leases, NPS should give consideration to these points, and also describe methods for how the proposed 20-year leases could serve a longer time period (e.g., perhaps through 5-year incremental extensions). For example, when a lease runs for five years, the lease should be extended for another 20 years so that the ranchers will have
the "long term equity" to support their infrastructure upkeep, resource management, farm work force and necessary viable financing opportunities.
Elk
Significant conflicts exist between some of the free-ranging tule elk and some of the ranches at PRNS. We recognize that long-term management solutions to these conflicts, as well as other issues associated with the elk herds (e.g., Johnes disease), must be found. The elk and agricultural operations are both valuable resources at PRNS, and a management solution that would provide a level of co-existence acceptable to the affected ranches would be ideal. MCL recognizes that this ideal may be difficult and/or costly to achieve. The six alternatives presented to the public to date have options for addressing the issue that essentially range from management in one form or another to removal of one or more of the free-range elk herds.
NPS has indicated that it intends to analyze this issue carefully with qualified resource management professionals. MCL supports NPS in this approach. We look forward to seeing the results of this analysis and will comment on a preferred management approach once those results are available, hopefully in the Draft EIS.
Park Resources and Visitor Carrying Capacity
Much can be done to improve the PRNS/GGNRA visitor experience. Fundamental to this is an analysis of the annual, seasonal, peak-day, and even daily visitor volume that can be effectively supported by PRNS staffing and infrastructure resources. MCL views this GMP Amendment and EIS as an opportunity to explore and implement a variety of tools for visitor access and participation. Specifically, the EIS should examine visitor shuttle models that relieve congestion and parking constraints. This would contribute to a stronger visitor experience with PRNS/GGNRA by getting visitors out of their automobiles. This could also serve to mitigate environmental impacts by reducing vehicle traffic, idling time (emissions) resulting from congestion, etc. Examples and models are in operation throughout the NPS that achieve these objectives, so this is an important topic to evaluate in the EIS.
a visitors experience and participation at PRNS inevitably crosses the boundary between portions of PRNS inside and outside the GMP Amendment planning area. This is also the case for the conflict posed by the free-ranging elk. MCL recommends that the alternatives identify and consider integrated resource management solutions that also apply to regions outside the proposed planning area. These solutions would be more holistic and comprehensive, and would recognize the inherent visitor and resource connections and relationships that exist across the proposed planning area boundary.
Visitor Access and Experience
Coupled with our suggestions for Park Resources and Visitor Carrying Capacity, MCL supports enhancing visitor experience through the GMP Amendment. One specific option MCL recommends that the NPS explore is the growth of the trail network in the planning area. This could be implemented along the boundaries between ranch operations, and could include relevant cultural, historical, and natural interpretive information (e.g., brochures, audio tours, signage). Visitor experience would be expanded by providing access to selected portions of the pastoral area, and be made richer by the opportunity to learn about PRNS agriculture, its history, and the names and faces of the ranching community that continues the traditional historic family farms of the past - a tradition across the nation that is increasingly threatened by much larger industrial agriculture operations.
Another potential way to enhance visitor experience with respect to the ranching operations would be to consider some form of ranching and farming tours that would be available to the public. This could foster a better understanding of how ranching compatibly contributes to PRNS, NPSs mission for managing PRNS, the regional economy, and how the operations are managed to protect the natural environment of PRNS. MCL recommends that this be explored and analyzed in the GMP Amendment and EIS.
Cultural and Historic Resources
PRNS/GGNRA are unique among national park units in that they have successfully implemented the integration of a pastoral landscape and its active ranching traditions with large areas of natural landscape and wilderness. The cultural and historic resource that has been preserved in PRNS/GGNRA is the combination of the historic pastoral landscape and the multi-generational farm families that are managing them. se local community members are the most direct link and now, four and five generations later, are the legacy of the historic period of ranching and farming on the Point Reyes Peninsula which dates back to the mid 1800s. working landscapes they manage exemplify and manifest the national movement to strengthen local food systems and community agriculture. y are leaders in grass-fed and organic production. At the same time, they have contributed to maintaining the ecological richness that is the hallmark of PRNS/GGNRA and must comply with stringent state and federal environmental regulations. MCL recommends that the NPS, through the GMP Amendment and EIS process, recognizes this connection to historic agricultural operations, and describes the innovations in agricultural and resource management practices that are unique to the PRNS/GGNRA. These historic agricultural operations represent a tremendous resource and exceptional educational opportunity to the public. The environmental, cultural, educational, and economic benefits they bring to PRNS/GGNRA support NPSs mission for this area, and should be fully addressed and documented in the EIS.
Community and Agricultural Economy
Agriculture on the PRNS/GGNRA represents about 19% of the areal extent and 19% of total production in Marin County. Per the 2016 Marin County Crop Report, total gross production value was $96.5 M. Accordingly, the contribution of PRNS/GGNRA agricultural production to total county production is $18.3M. This does not include multiplier effects through processing and value-added production, which can be 3 to 4 times that amount, resulting in a value of about $73.2M. In terms of employment, every on-farm job is matched by 3 to 4 jobs in other off-farm related agricultural businesses. In 2012, Marin County employed 1,072 farm employees (USDA 2012 Ag. Census) resulting in as much as 4,288 off-farm jobs. PRNS/GGNRAs contribution to on-farm employment is 204 employees and a corresponding 815 off-farm employees. The loss of $73.2 M in annual production, and as many as 1,019 jobs, would be devastating to the agricultural community and the region as a whole. MCL asks that, in analyzing alternatives for the GMP Amendment, full consideration be given to the impacts each proposed alternative would have to this significant contribution to the local and regional economy. Proactively, we recommend that these benefits be referenced, as appropriate, in NPSs purpose and need statement for the GMP Amendment.
Sustainable Agriculture and Regulatory Compliance
The ranchers on PRNS/GGNRA rangelands and dairies are dedicated to achieving the synergy of working landscapes and environmental resource stewardship. To that end, they must comply with some of the most stringent and all-encompassing water quality management regulations for agricultural nonpoint source pollution in the United States. Two specific examples of federal and state environmental regulations are the respective Grazing Lands and Dairy Conditional Waivers for Waste Discharge Requirements approved and implemented by the San Francisco Regional Water Quality Control Board. In both cases, the agricultural manager must evaluate potential impacts to surface and groundwater from grazing livestock and manure management, and implement practices that mitigate those impacts. The EIS should describe the management measures that NPS staff and the ranchers are using to safeguard water quality. These include programs such as the US Environmental Protection Agencys 319(H) water quality grants, partnering with the Marin Resource Conservation District on other funding opportunities, and cost-share contributions from the individual ranchers and farmers. These implemented practices are providing the intended benefit and protections and represent the multi-objective solutions critical to achieving NPS goals and mandates for the PRNS/ GGNRA.
MCL, consistent with the State of California and beyond, is deeply concerned and committed to finding solutions for climate change, including greenhouse gas (GHG) emission reductions. Through its Climate Action Work Group, MCL has worked closely with the County of Marin and other stakeholders to develop a relevant Climate Action Plan (CAP) for Marin in response to California Assembly Bill 32. The Marin CAP provides an accurate inventory of GHG emissions for Marin County, including 5% from agriculture that is consistent with California and United States inventories. Furthermore, the Marin CAP recognizes the potential that agriculture represents, through conservation practices, to be a net sink of carbon and provide offsets that make significant contributions to obtaining Marin CAP GHG emission reduction objectives. To this end, the Marin County Board of Supervisors recently passed the Drawdown: Marin goal. MCL recommends that the GMP Amendment and EIS analyze GHG reduction strategies that can be implemented at agricultural operations on PRNS/GGNRA (e.g., carbon sequestration management practices).
Glossary and Index
We believe the GMP Amendment process would facilitate better community participation through the inclusion of a glossary of terms in the Draft EIS. Examples include but are not limited to terms like operational flexibility, carrying capacity, and visitor experience.
As described in the NPS NEPA Handbook (2015, page 95), we assume that an index will be included in the Draft EIS. MCL supports this and believes it would make it easier for the public to quickly find where specific topics are discussed.
Conclusion
MCL played a significant role in the initial establishment of both PRNS and GGNRA and has supported them for decades as incomparable public assets. MCL has also enjoyed a long, successful, and rewarding relationship with Marins agricultural community that united with the NPS to realize the shared goal of protecting an open and connected landscape from significant residential development that could have decimated that landscape. The success of this relationship, a working landscape with strong community ties, economy, and connected landscapes and ecosystems, is a model that has been studied in an attempt to replicate it nationally. Those original benefits and achieved goals are being multiplied forward through new, unforeseen benefits such as the opportunity for a vibrant local food system and provision of climate change solutions, among other ecosystem services. These are ideals held and pursued throughout California and nationally. They are already being realized in Marin County, including on the PRNS/GGRNA ranches and farms.
The GMP Amendment process is a timely opportunity to again embrace the purpose and intent of preserving ecosystems and protecting working landscapes and the families that manage them because of the dividends this will pay going forward for the environment and community. MCL recommends that an alternative be considered and thoroughly analyzed in the EIS that embraces these mutual and integrated benefits, and reflects our comments above to continue PRNS/GGNRA ranching and dairy farming.
Thank you for considering these comments.
Respectfully,
Kate Powers
President
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# 2561
Name: Maendle, Tom
Correspondence: I believe ranching is an important part of our cultural history. Sustainable farming is one of, if not the most important, environmental causes of our time. In a time when most of our food is formed in extremely destructive ways, for our health and our planet's health, the ranches in Point Reyes seem very low impact. With that said, there is impact on the land, this needs to be recognized, something to be aware of.
I would look to the land to see what impact is made, the diversity of species and the health of the populations. All in all, it's pretty amazing example of integration between agriculture and the preservation of the land. This is a statement that needs to be made, an important example for our country. We should rally behind sustainable agriculture, support the ranches right to be here. We also should push to be better, to create the most integrated regenerative relationship we can. We have a very important Tule Elk population, I would love to see them spread, and inhabit their historic range, become so abundant they no longer need endangered protection status. Point Reyes is a unique place, the land, the diversity of life and the community.
As someone who works in sustainable agriculture and who has worked for 2 different National Parks, I recognize that Preservation and Sustainable Agriculture both need to be empowered both are causes to rally around, and for a healthy abundant existence here on this planet we need both to grow.
Therefore, I want our energy and resources to work together in an integrated system.
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# 2562
Name: Pettigrew, Fiona
Correspondence: I don't think that all dairy and cattle ranches should be lumped into the same group. Some ranches are implementing more environmental practices, these should be recognized. Many are leading the way in sustainable ranching!
Implementing agrotourism in ranches that are interested. This will make them a larger part of the park - they have an important place here. Also, tourists can have a better understanding of why they are here. Ranch tours can also give urban folk a lesson on sustainable food production / make them feel more connected to the food system.
It is a beautiful example of the intersection of humans and nature (and how it can all work together).
People (tourists) come to PRNS expecting to see beautiful beaches and wildlife, but they could be exposed to so much more.
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# 2563
Name: Livingston, Kerry
Correspondence: If we faze out the ranches, we will be doing our land a big disservice. I do not want to see cogate brush, junk trees, thistle take over the grasslands more than they already have. So much proper balance depends on grazing.
We need to keep producing food. We need to work together to make sure we as a species survive. We must work together (I wish I felt the Federal Gov / National Park was a responsive entity.
We need to model having both ranching and natural lands - the park was formed on this very good idea.
Work together
Work together
Work together
Please have a public meeting where we can hear all these conversations - we need to feel you care about the community you are surrounded by. We have been effected by you. Please talk to us.
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# 2564
Name: N/A, N/A
Correspondence: Why are ranching leases suggested for 20 years? 5 seems more reasonable, not to be renewed if the ranches don't follow BMPs.
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# 2565
Name: Wimpfhelmer, David
Correspondence: All the alternatives include diversification. I feel that's a major problem because nowhere is the term diversification spelled out and defined. I realize it means increased agriculture growing crops like artichokes and more animals like pigs, sheep, and goats. I insist that it's important to quantify the impacts of increased agriculture; how many acres will be put into crops? How many predators will be killed to protect sheep and goats??
A follow up question is why diversification is included in every alternative. Clearly a large number of people feel there will be significant negative impacts on the ecosystem and wildlife with increased agriculture and we need a way to express that.
Other terms that need to be defined are sensitive resources, park resources, and sustainable.
It is important to define those terms so we in the public can see how any changes in management may come into conflict with protection of natural resources.
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# 2566
Name: Mitchell, B
1) Unpack the differentiate "diversification" for seashore ranches.
Commercial crops vs. personal farm house gardens
Animals, by species, other than - - - - - -
Define "succession" of lease holders- immediate family succession vs non-family persons
Enumerate alternatives for land use when lease has no succession.
A restoration to pre-farm conditions.
Grazing to promote and sustain native plants and fauna.
Define "sustainable ranching"
Does not further impair natural resources
Reduces impacts on natural resources to a de minimis level
May - - - - incorporate measures that reduce ranch - - - - income to accomplish environmental objectives.
Provide for sufficient long-term PRNS staff and individual resources to monitor and implement ranch management
Why is dairy ranching distinguished in the alternatives? What is the environmental basis for this distinction from beef ranching?
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# 2567
Name: N/A, N/A
Correspondence: The ranchers and their families are a critical and celebrated part of the Point Reyes National Seashore. Encouraging a positive and interactive relationship between the ranches and the NPS staff and the public should be the goal of this GMP.
Work collaboratively with ranches to manage critical habitat and the pastoral zone is a win-win or all. Educating the public about the history of and continued ranch operations is a much needed addition to NPS practices. Encourage educational tours of the ranches, use of farms for educational events, etc. These families have been investing in these lands and ranches for generations. It is time we should them the respect they deserve and invest back in them.
Thank you
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# 2568
Name: N/A, N/A
Correspondence: On NPS (public) lands - why is there any consideration of "managing" (killing) tule elk in order to make ranching easier?
There are already enough ranch lands for cattle. We don't need them in our national parks. Ranching is absolutely not something I support on the lands I pay for. On the other hand, I fully support a healthy, free-ranging elk population.
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# 2569
Name: N/A, N/A
Correspondence: As an ecologist researching in various areas of PORE, my experience is that the cattle are not well-managed. I'm out there once or twice a week, every month of the year.
I see trashed ranches with barbed wire everywhere, fences not properly maintained for wildlife passage, cattle allowed to escape and not collect for months as they trash the landscape, overgrazing, and worst of all, an utter disregard for the care and preservation of our public lands by the ranches.
I would like to see many changes, and particularly the reduction if not complete removal of ranching in our park.
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# 2570
Name: Patton, Morgan
Correspondence: Permits: References to succession planning are missing. Will this be addressed?
BMPS: How are the BMPs developed, implemented, measured, and enforced?
Diversification: What does this mean? What is the actual scope being considered by the park? Why is it included in almost all alternatives?
Natural Resources:
• Please define "sensitive resources".
• Please define "Park resources".
• What does the statement "promotion of sustainable agriculture mean?
• Restoration needs to be discussed, especially if setting aside resource protection suffers.
• Needs to include references to measurable, repeating standards for habitat and water quality.
• Needs to include references to protect endangered species and habitats.
• How does NPS determine overgrazing? What baseline is used to inform management of habitat conditions.
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# 2571
Name: N/A, N/A
Correspondence: It is so important to have beef and dairy ranching continue within the PRNS. We in Point Reyes are so lucky to have the ranchers in our backyard, providing locally raised food products at our abundance. The farmers, dairy ranchers, and beef farmers are truly the best environmentalists, they are good land stewards. Maintaining our historic ranches with the Park. It would be a travesty to get rid / eliminate a single farm. Farms and ranches have been here for nearly 100 years on the same ranches, farming the land for sustainably longer leases.
Park please listen!
Keep all farms / ranches.
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# 2572
Name: Quattlander, Jave
Correspondence: It is time for the Park to be a considerate and supportive organization of the local community. The importance of using sustainable practices for raising animals for beef and dairy products is clear. The place we do that is here. Limiting or removing what is best practice in ranching is a step backward.
Here we move into the future providing excellent foods, employment, wilderness area, as a model for sustainability the world over.
Stopping and/or limiting ranching is like going back to coal powered electric production instead of using solar and wind power.
Even Prince Charles came to study how to do farming and ranching. Take a clue from the royal family.
Support ranching and farming in the National Seashore. Provide healthy systems for the local community and state.
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# 2573
Name: Torrance, Anthony
Correspondence: It should be looked at as an opportunity to show that public-private partnerships can work.
Historic operations (ranching) should be valued and saved if possible.
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# 2574
Name: N/A, N/A
Correspondence: Ranching in the Seashore provides a critical mass of dairy and beef business in our community that is necessary for the continuation of agriculture as a whole in our area. Additionally, the job and tax base are critical to the economic viability of our community. Furthermore, the housing and people lost if ranching were reduced or removed would have a detrimental community impact. The NPS should uphold its original agreement and support the continuation of ranching in our area. These hard working people are great community members and produce needed and delicious food for our community.
Elk are a beautiful part of our landscape and they should be here. Fact, they need management. Facing reality, the Seashore is not large enough to mimic vast rangelands with predation that would allow the elk to behave naturally. As such, these beautiful animals should be allowed to thrive, but should also be viewed as a potential source of food for our area and revenue for the NPS. Tags should be sold on animals culled in partnership with the USDA and our local slaughterhouse.
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# 2575
Name: Nwa, Ed
Correspondence: The ranches should remain with 20 yr leases.
Tule elk may not eat as much forage as the extirpated axis and fallow deer. Tule elk should be managed in Limantour and Drakes area to minimize effect on ranchers. If they start eating up too much forage, the Park should bring some in for the ranchers.
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# 2576
Name: Fabry, Pam
Correspondence: Comments on GMP Amendment Process
I feel that the proposals are adequately fleshed out to include all relevant points and I have no criticism of the process suggested.
I do, however, wish to express a strong preference for two proposals (Continued Ranching and Management of the Drakes Beach Tule Elk Heard (NPS Initial Proposal), Continued Ranching and Removal of the Drakes Beach Tule Elk Herd).
Ranching is an integral and historic part of Point Reyes National Seashore and a model for proper ranch management and for creative diversification.
RE: Elk: I think it's unfortunate that the park released the Tule Elk into the park proper creating a problem for itself down the road. I would hope that those wishing to return the park to "wilderness" would understand that these elk are not native to the area any more than the axis and fallow deer were and that the dream of "wilderness" is just that.
It's important to keep historical ranching as an active part of the Park and I feel the two alternatives listed above could do that very well.
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# 2577
Name: Dean, Jane B
Correspondence: Please, let the Elk live! Protect them unconditionally. It's the obligation of us all for their future and our children's. Thank you.
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# 2578
Name: Gifford, Andrew R
Correspondence: Point Reyes National Seashore-General Management Plan Amendment 15 November 2017
To: Cynthia MacLeod—Point Reyes National Seashore
It has come to my attention that the National Park Service wants to change the reason why Point Reyes National Seashore was established. The end result being the elimination of ranching and dairy farming with the establishment of more wilderness.
Point Reyes National Seashore was established to provide open space and outdoor recreational opportunities for residents of the Bay Area. Congress established Point Reyes National Seashore as a recreational Area not a National Park. The reason was clear; Congress did not want the Seashore to be managed under the strict rules that govern a National Park. Wilderness is very restrictive and eliminates a number of uses that may be needed to maintain the Seashore in an open, usable and safe condition. Mechanical equipment use will be necessary for fire suppression, heavy brush removal, trail up keep, search and rescue operations, etc.
Cattle ranching and dairy operations were allowed to continue, with a lease back arrangement, which helped keep the county economy and labor force employed, and provided meat and milk for the central portion of California. The spin off from the ranching operations involves many other business activities. These business provide employment for a number of people in the local area. By eliminating the agricultural operations the NPS is not considering the loss of employment by a number of people in surrounding area who the haul, feed, equipment, livestock, whole milk, Clover milk pasteurizing and bottling operations, feed production, equipment repair and veterinary services and many other services.
Flexibility in NPS management is required. To be effective NPS managers need farm/ ranch education in order to carry out ranch management plans and to communicate effectively with the different ranchers in order to carry out various ranch projects. In depth educational needs include degrees in soils, wildlife, range management, ranch management, fisheries and forestry not general biology. The NPS never did step up to the plate and appoint top seashore managers with this type of educational and experience background. The end result is a constant tug of war between Seashore Managers and seashore farmers, ranchers and fisheries business.
When the National Seashore was originally purchased by Land and Conservation Act funds there were two species of non-native deer roaming the Seashore farm lands. These deer were obtained from a local zoo and were put on the seashore by ranchers for hunting purposes. The deer species were Fallow deer originally from Europe, and Axis deer originally from Asia.
The deer had multiplied into fairly substantial herds by the 1960's and competed for grazing on several ranches, The Park Service instituted a study where both species of deer were shot and autopsied to determine food usage, general health, parasite problems and diseases that may affect grazing cattle. Along with the non-native deer, Black-tail deer were also, collected for comparison purposes. The Axis and Fallow deer were found to be very healthy with very few parasites. The native Black tail deer who are browsers were full of parasites; tape worms, liver flukes, etc.
Those deer shot were given to a food kitchen in San Francisco in dressed carcass form. After the study, the NPS went out and shot all of the remaining exotic deer.
In the Mid 70's, Tule Elk were being discussed. It was determined by the NPS that Point Reyes would be a good place to locate the Tule Elk since they were supposedly native to Point Reyes in the early 1800's. The elk were to be placed on the Pierce Point Ranch. Fencing was placed across the point but elk soon forced their way through or swam around the fence in Tomales Bay.
Elk are many times more difficult to manage than deer. They are difficult to herd and keep in designated areas. To be confined in a certain area, elk will have to be constantly monitored and removed to keep the herd size in check. Disease and parasites will have to be continually looked for; in breeding will become a problem and have to be attended to. If the NPS thinks that removing the ranchers will solve their elk problem they are sadly mistaken. Wilderness is not an option.
In conclusion, I am against eliminating ranching and farming from Point Reyes National Seashore. I am also against changing the nature or designation of the Seashore so that it is no longer an open space for the San Francisco Bay area to recreate is wrong. Cutting out profitable business does not make sense in a day and age when we are trying to put the economy of the U.S. back in order. By not renewing the leases makes it harder for the ranches to operate and borrow money need for improvements in ranch operations.
The NPS lied when it closed down the Drakes Bay Oyster Farm. The NPS used material that had been continually determined to be false. This company did no wrong, they were very profitable. The Oysters actually cleaned the waters of the bay while growing. No entity public or private should be allowed to benefit from false information in a court of law. It appears that the NPS is attempting to get rid of the ranches and lessees under the same guise.
The government goal must be good resource management by well educated public servants. Communication between all parties will be better facilitated. If after approximately 60 years the National Park Service cannot seem to rise above the fray; then perhaps another Natural Resource Agency, with qualified ranch/resource management personnel should take over management.
Andrew R Gifford
Former National Park Ranger, Point Reyes National Seashore
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# 2579
Name: Hoffman, Walter
Correspondence: I'm for Wilderness and all things wild. Let the Tule elk roam freely throughout the park and beyond (across Highway 1) and onward to the Bolinas Ridge and Mt. Tam. Have plenty of warning signs to let people and drivers know about large animals on the roads.
The ranches have had their day. It's time to move the cattle out of the Park and make it truly wild for native animals and plants. To see what I would term over grazing year after year is not consistent with good land management. We need to clean-up the mess left by the ranches, make a concerted effort to get rid of the invasives and plant natives like the Giacomini wetlands and the GG NRA Lands around Bolinas lagoon and beyond without the use of pesticides or herbicides.
Thank you for making this a new day for our beautiful Point Reyes National Seashore.
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# 2580
Name: Gates, Nancy
Correspondence: Cynthia MacLeod, Acting Superintendent
Point Reyes National Seashore
National Park Service
1 Bear Valley Road
Point Reyes Station, CA 94956
RE: General Management Plan Amendment for Point Reyes National Seashore
Dear Ms. MacLeod:
I am writing to provide input on the General Management Plan Amendment for Point Reyes National Seashore (PRNS). I support the continued operation of beef and dairy ranching operations under agricultural lease/permits with 20-year terms and improved management of the Tule elk herds to eliminate negative impacts on the environment and ranching families.
Ranchers have been raising cattle in Point Reyes for more than 150-years. It was ranchers' willingness to sell their properties to the federal government that allowed the creation of the PRNS. As part of the agreement, ranchers were supposed to be allowed to continue ranching on their family ranches within the PRNS.
The ranches in West Marin contribute significantly to the local economy and the local culture. According to any analysis by U.C. Cooperative Extension in 2009, ranches in PRNS and Golden Gate National Recreation Area (GGNRA) directly provide approximately 65 jobs and provide livelihoods for an additional 25 ranch family members. Additionally, agriculture in PRNS and GGNRA account for 17 percent of the agricultural income in Marin County. These jobs and income would be lost if further restrictions were placed on ranches within PRNS. These ranches are not just creating economic value, they are producing high quality food appreciated by consumers locally, regionally, and nationally. Further, providing 20-year terms for lease/permits allows for greater investment in improvements on these ranches. Shorter terms prevent the ability of ranchers to obtain financing for improvements.
would also like to see improved management of the PRNS elk herds. Elk cause thousands of dollars of damages and lost forage on ranches. Additionally, the elk carry Johne’s disease, which can be transmitted to cattle. USDA estimates that lost productivity from Johne’s disease in dairy cattle could be costing dairy producers between $200 and $250 million annually. Elk in the PRNS were reintroduced by humans and have been managed since their reintroduction. PRNS must improve its management by maintaining the roaming elk herds on the Limantour wilderness and preventing them from damaging ranches in the area. Additionally, PRNS should ensure that there is proper forage and water available to the herd in the Limantour wilderness to prevent a reoccurrence of the unfortunate loss of elk during the drought.
Ranches on PRNS provide important economic, cultural, and ecological values to the local community. Losing a significant portion of West Marin’s agricultural community would mean not only a loss of local food production, but a significant loss to its economy and culture. I urge you to offer 20-year lease/permits to ranchers on PRNS and to improve elk management and return the elk to the wilderness areas where they will not impact the ranches.
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# 2581
Name: Murdock, Dorothy
Correspondence: Dear Cynthia MacLeod,
I received your letter of October 16th regarding a General Management plan, and with the note that you are going digital. I'm an old native San Franciscan born 90 years ago this month and I am not on the internet.
In any case I would like to take this opportunity to thank you for all the service you and Park Service have done for the people of the Bay area and would in the fifty odd years since you began the wonderful project of keeping this beautiful coast pure and free of invasive species like developers and white deer. At the same time you have preserved the fine elements like the Vedanta Society religious retreat and the responsibly ranchers, and made the land welcoming to visitors.
Good luck to you in the future.
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# 2582
Name: Gates, Nancy
Correspondence: 1) provide 20-year renewable leases to all ranchers at the Point Reyes National Seashore, and (2) properly manage the Tule elk population, including removing all roaming Tule elk from ranches and placing them back in the Limantour wilderness.
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# 2583
Name: Sinkkonen, Mary Ann
Correspondence: Dear Park Superintendent,
The demise of the Drakes Bay Oyster Company was an indicator that the Park Service has little to no interest in co-operating or co-existing with any commercial enterprises. All research aside, it is clear there is a pre-existing bias of the Park Service to pull away from any alliance with farmers, ranchers, and in general any commercial or private citizens living with space and renting from the Park Service.
The people who are leasing land are also stewards of those areas. They maintain areas of land that create a bucolic environment in Maris and Snow- - -.
The farmers and ranchers are making decisions in conjuncture with environmental protections. The bias, which have been and probably are pre-determined by the Point Reyes Seashore Park Service Personnel have a history that is remembered specifically from the Drakes Bay Oyster Co. decision.
The hearing on Oct 25 and 26, 2017 are an opportunity to listen to the people. I am unable to attend those Public meetings and so I am sending this letter to you.
I support co-existing and cooperating with farmers and ranchers. I urge the Park Service to listen to comments. I support the alternative to have existing ranch families to continue beef and dairy operation / 20 yr lease / permits. Managing the Tule elk is important as well. There is only so much vegetation so native deer should be given priority.
Cooperate and co-exist.
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# 2584
Name: Duhan, Deirdre
Correspondence: Dear Sir or Madam,
I am concerned about the fate of the Point Reyes tule elk, and ask that these elk populations be left intact, and unmolested. If the most effective way to achieve this is to let ranch leases expire, then the NPS should follow this course of action.
Human population expansion, with its concomitant land grab for housing, and the exploitation of other species for food continue to destroy living space for wild animals. Please don't let the NPS foster this accelerating, world-wide process of destruction.
Sincerely yours,
Deirdre Arima Duhan
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# 2585
Name: Sparks/Torquemada, Wendy/Jeff
Correspondence: We have spent a lot of time reviewing the Point Reyes National Seashore General Management Plan and have some grave concerns regarding amending this plan.
We are vehemently opposed to any plan that would significantly impact or eliminate the Tule elk herd. The elk have been successfully reintroduced after being exterminated in the 19th century. This is their natural habitat and we would prefer the cattle and dairy ranches be removed in a respectful and timely manner from the Point Reyes National Seashore (PRNS) so the elk/ cattle conflict issues are no longer a problem.
We are totally opposed to any additional farming or ranching leases being granted in the Point Reyes National Seashore. We are in PRNS on a regular basis and our main concern is any additional encroachment from humans and domestic animals (cows, chickens, sheep, farm dogs, etc.) will significantly impact the native wildlife such as bobcats, coyotes and badgers. This is one of the few pristine places where these predators can safely exist and not contend with human influenced intrusion, which would significantly impact their survival.
PRNS took a strong stand to remove the oyster farm on this land, based on the need to protect the diminishing seashore and re-establish the natural habitat of the shoreline. Why not take a strong stand against further development of the land in PRNS? Allowing additional land to be leased for farming, cattle or dairy seems contrary to the vision of why PRNS was formed. It clearly states that PRNS was created to "save and preserve for purposes of public recreation, benefit, inspiration, a portion of the diminishing seashore of the United States that remains undeveloped."
The PRNS is a very special place that provides a rich ecosystem for the public to enjoy while observing an abundance of wildlife. We do not want to see more of the land scarred by human encroachment
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# 2586
Name: Sands, Anne
Correspondence:
As a 36 year resident of MARIN COUNTY and a long time environmental consultant specializing in riparian habitats and past Marin County Planning Commission chair, I strongly support Alternative 4: Continued Ranching and Management of the Drakes Beach Tule Elk Herd (NPS Initial Proposal) BECAUSE of the following specific reasons:
1. The ranches can be managed to maintain grasslands and their associated wildlife which benefits wildlife and the Public enjoyment thereof.
2. The dairies and beef ranches are very important economically to Marin County because of their network of feed suppliers, veterinarians, and other supporting businesses and it is necessary to recognize the importance of having a critical mass of dairies in order for milk pickup and delivery to remain economically feasible.
3. Allowing diversification of ranching to include small scale farming and creative ways to educate the public about subjects like organic farming and carbon sequestration offers opportunities to improve park visitor experiences.
4. Elk herds should be managed within the wilderness areas and cattle should be managed in the pastoral zones.
5. Marin Agricultural Land Trust has scientifically shown positive effects of range and watershed management on wildlife and MALT supports continued ranching and diversification which also encourage multi-generational responsibility for maintaining best management practices on the land for the long term.
6. Marin Conservation League has studied the issues of ranching in PRNS and after years of detailed research has concluded that supporting managed ranching in the Park with allowance for diversification of small crops and controlling the elk herds are the best practices for PRNS.
Thank you for considering my comments.
Anne Sands
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# 2587
Name: Cinino, Rich
Correspondence: I am concern that the ranching community will begin to float lies about what N.P. staff in planning process are really trying to produce for a final plan. I am also concern that the ranching community will drag in the alt-right firebrands to create a social impact on the urban community.
I am again ranching, I am against BANDY type extremist being brought into our community to ranch can have their way with the conservation community and county supervisors and the editorial staff at the I.J. newspaper.
I do not want to see another rancher influenced Elk program like Grand Teton N.P. where we the tax payer ends up feeding hundred (maybe more) Elk so the ranchers have control over our park.
The N.P. planning staff must realize that Americans already paid once to the P.R.N.P. to grant 20 years leases for production for profit on publicly own lands require that ranchers acknowledge that Elk have a priority over cattle for minor conflict like down fences. N.P. need to raise grazing fees in park to cover NP increase management cost.
___________________________
# 2588
Name: Eagle-Gibbs, Ashley
Correspondence: I have a few questions, concerns and comments: why are all the minimum leases all defined by 20 year lease extensions? How will permit succession be handled? What is the decision basis for removal of dairy ranching rather than beef ranching? How will the BMPs be implemented, measured and enforced? Will the enforcement budget be increased? Are BMPs specific to the type of ranching? I would like more clarification around the concept of diversification and what this means (sooner rather than later) please. Examples should be included and possibly the definition should be limited (in some/all of the alternatives). In other words, what is the scope of diversification? I do no support diversification to other commercial uses. How will visitor serving uses be addressed in the pastoral zone?
More clarification is needed regarded natural resource including a definition for "promotion of sustainable agricultural operations."
What type of restoration will be proposed? What standards will be used for habitat and water quality? The standards must be both measurable and enforceable. What other agencies will be involved and consulted regarding enforcement of these standards? How will overgrazing be addressed? Protections for endangered and threated species habitat must be included.
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# 2589
Name: Stewart, Boyd
Correspondence: Mr. Stewart: Well, the ranchers, all of this time, were paying a very competent lawyer to go to Washington every time there was a hearing of any kind about the park, and oppose them taking it over.
Lage: Does it pass to the heirs under the Park Service arrangement?
Stewart: My daughter was an owner. My granddaughter is not. She will have the right to negotiation a lease that you can not bid against on this ranch. They negotiated leases, and there are a number of them, are on a very, very fair basis. It's on a per head basis.
Mr. Stewart: I asked them if, when they sold their land to the parks assuming that the made an agreeable sale, would they want to put in a provision that they would be allowed to continue operating their dairies and their answer without exception, again was, lets sell the land, and never mind putting in provisions. We will take our chances and decide whether or not we want to operate dairies after we have sold the land.
Senator Bible- Let me get that last answer.
Mr. Stewart: They are willing to deal with the park for the sale of their land without any conditions, meaning that they recognize they aren't going to dairy indefinitely in Marin County. None of us are. People are going to take over our land, and dairying will eventually go away from there.
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# 2590
Name: Tippett, James J
Correspondence: Dear Superintendent,
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore. The Tule elk were native to this area prior to the arrival of people of European descent. Tule elk are an important part of the ecology and landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species. I object to any fencing, removal, sterilization or killing of elk in the park.
I also urge you to reject any conversion of national park lands. These lands are our legacy to the future, our children, grandchildren and their grandchildren. Expansion of commercial agriculture at the detriment to native flora and fauna violates the mission of the National Park service and would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
James Jade Tippett
___________________________
# 2591
Name: Smith, Alexandra J
Correspondence: Dear Superintendent,
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
Lexi Smith
___________________________
# 2592
Name: Edelson, Eve
Correspondence: Dear Superintendent,
The elk herds of California are a magnificent sight (and tourist attraction). I support the free-roaming elk herds at Point Reyes and oppose their removal or killing, or handing-over of more land for livestock and commercial agriculture. We can buy milk & beef and artichokes elsewhere. It's not Point Reyes Dairies or Truck Farms, it’s Point Reyes National Seashore.
Thank you for your efforts to protect our beautiful natural resources.


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# 2593
Name: Thompson, Jill
Correspondence: Dear Superintendent,
I was appalled to hear that the National Park Service is considering opening up even more land to cattle at the expense of the native tule elk herds at Point Reyes National Seashore. I lived for many years in the Bay Area and there was no place I loved more than Point Reyes. I spent many weekends up there, hiking, kayaking, and enjoying the unique wildlife. Although I now live in Southern California, I have made a point to return there as often as possible with my family. Seeing the elk is always a highlight of any trip. Over the years we have noticed how much the herds are dwindling - and know it is not all because of natural causes!
The mission of the National Park Service should be to conserve our wilderness areas and protect wildlife for future generations, not to bow to the commercial interests of farmers and ranchers. Commercial lease holders can share our land, where appropriate, but should not dictate policy on wildlife. Any cattle-ranching or farming operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species. Surely there are plenty of places to raise livestock and vegetables other than our beautiful and endangered national parks!!!
As you go about your planning processes, I urge you to consider the interests of regular American families who utilize these parks and highly value the protection of wilderness areas. Please do NOT adopt policies that will threaten or remove the tule elk from their native areas in Point Reyes national park. Please do NOT allow row crops or new commercial animal farming. And finally, please ensure that cattle ranching operations accommodate elk and other native wildlife and not the other way around.
I thank you for your attention to this important matter, and pray that you will prioritize nature over other interests.
Sincerely,
Jill Thompson
US Citizen, California resident, Point Reyes fan, frequent visitor, mother of 2.
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# 2594
Name: Glauz, Dacia
Correspondence: Dear Superintendent,
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The national parks should be about the natural environment - not about commercial use - especially if the two are at odds. They are protected for everybody, not for economic gain. The limitation of even a single species can damage the whole ecosystem. The re-introduction of the wolf in Yellowstone is a prime example of how one animal can effect the entire environment.
On a personal note, I've yet to see an elk in Pt. Reyes despite my many trips. They're unusual enough as is, don't make them rarer and ruin all possibility I have of seeing the beautiful creature at home.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
Dacia Glauz
Vacaville, California
___________________________
# 2595
Name: Sydow, Tom
Correspondence: Please continue to protect the Tule Elk of Pt Reyes. We need wild animals, not more ranch land. Ranching benefits only the ranchers. Wildlife benefits everyone. Predators need elk as a food source. Citizens want to see wild animals. The world is overrun with livestock. We need to consume less meat, and have more wild animals.
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# 2596
Name: Densmore, Robert
Correspondence: To Whom It May Concern,
I am writing to support agriculture within Pt Reyes National Seashore. I believe that organic, sustainable agriculture is an asset for PRNS and should be showcased. Supporting wilderness and proper food production is cutting edge when you think about how grazing rotations can help heal the land, help store carbon in the ground, and reduce climate change (Marin Carbon Project).
It is in the best interest of the park to work with the ranchers to continue food production.
Thank you,
Robert Densmore
___________________________
# 2597
Name: N/A, N/A
Correspondence:
Dear Superintendent,
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Thank you,
Mshabbott
___________________________
# 2598
Name: Greslie, Cheryl M
Correspondence: To the National Parks Service,
I support ranching in Point Reyes. Ranching has been in Point Reyes for 150 years and has not hurt the environment. We need ranching in California. Also the management of elk herds. Please do not close down the Point Reyes area to the ranchers.
Thanks You Sincerely
Cheryl M Greslie
___________________________
# 2599
Name: Dunn, Jonnalee
Correspondence: I am writing to provide input on the General Management Plan Amendment for Point Reyes National Seashore (PRNS). I support the continued operation of beef and dairy ranching operations under agricultural lease/permits with 20-year terms and improved management of the Tule elk herds to eliminate negative impacts on the environment and ranching families.
Ranchers have been raising cattle in Point Reyes for more than 150-years. It was ranchers' willingness to sell their properties to the federal government that allowed the creation of the PRNS. As part of the agreement, ranchers were supposed to be allowed to continue ranching on their family ranches within the PRNS.
ranches in West Marin contribute significantly to the local economy and the local culture. According to an analysis by U.C. Cooperative Extension in 2009, ranches in PRNS and Golden Gate National Recreation Area (GGNRA) directly provide approximately 65 jobs and provide livelihoods for an additional 25 ranch family members. Additionally, agriculture in PRNS and GGNRA account for 17 percent of the agricultural income in Marin County. se jobs and income would be lost if further restrictions were placed on ranches within PRNS. se ranches are not just creating economic value, they are producing high quality food appreciated by consumers locally, regionally, and nationally. Further, providing 20-year terms for lease/permits allows for greater investment in improvements on these ranches. Shorter terms prevent the ability of ranchers to obtain financing for improvements.
Ranches on PRNS provide important economic, cultural, and ecological values to the local community. Losing a significant portion of West Marin’s agricultural community would mean not only a loss of local food production, but a significant loss to its economy and culture. I urge you to offer 20-year lease/permits to ranchers on PRNS and to improve elk management and return the elk to the wilderness areas where they will not impact the ranches.
Thank you,
Jonnalee
___________________________
# 2600
Name: Negranti, Anna
Correspondence:
SAN LUIS OBISPO COUNTY FARM BUREAU
4875 MORABITO PLACE, SAN LUIS OBISPO, CA 93401
PHONE [phone]
November 13, 2017
From:
Executive Committee
The San Luis Obispo County Farm Bureau
To:
Cynthia MacLeod, Acting Superintendent
Point Reyes National Seashore
National Park Service
1 Bear Valley Road
Point Reyes Station, CA 94956
RE: General Management Plan Amendment for Point Reyes National Seashore
Dear Ms. MacLeod:
San Luis Obispo County Farm Bureau and its members have a long history of organizational support of farming and leadership in the stewardship of the land. Before our local Farm Bureau became an organization, nearly 100 years ago, our pioneer families became caretakers, so that the lands would be healthy - providing food and sustaining the environment for future generations. We have a strong understanding and interest in management of other areas of California, as well.
Our Executive Committee Officers have reviewed the General Management Plan Amendment for Point Reyes National Seashore (PRNS) and have voted to send comments supporting the continued operation of beef and dairy ranching operations under agricultural lease/permits with 20-year terms. Additionally, we are in support of improved management of the Tule elk herds to eliminate negative impacts on the environment and ranching families. Return the elk to the wilderness areas where they will not impact the ranches.
PRNS history should be brought into the discussion in a more vigorous manner, since ranchers, who have been raising cattle in Point Reyes for more than 150-years, provided the willingness to sell their properties to the federal government that allowed the creation of the PRNS. As part of the agreement, ranchers were supposed to be allowed to continue ranching on their family ranches within the PRNS. It is bad faith on the part of the Park Service to renege on that agreement.
The ranches contribute significantly to the local economy and the local culture. These ranches are not just creating economic value, they are producing high quality food appreciated by consumers locally, regionally, and nationally. Further, providing 20-year terms for lease/permits allows for greater investment in improvements on these ranches. Shorter terms prevent the ability of ranchers to obtain financing for improvements. We strongly urge the Park Service to offer 20-year lease/permits to ranchers on PRNS, and abandon this drive to remove a significant element that has made Point Reyes what it is and what it should be.
Sincerely,
Anna Negranti
President
San Luis Obispo County Farm Bureau
___________________________
# 2601
Name: Florenzen, Cynthia
Correspondence: Dear Superintendant:
I am writing to request that the tule elk in Point Reyes National Seashore be left intact without any move to reduce their numbers or to remove them entirely from that area. They are an important part of the ecology of the park, are unique to California and should be allowed to remain free and and exist as a remarkable symbol of what can be achieved when humans work together to make sure that all wild creatures are secure for future generations. Thank you for your consideration concerning this matter.
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# 2602
Name: Perry, David
Correspondence: Cynthia MacLeod, Acting Superintendent
Point Reyes National Seashore
National Park Service
1 Bear Valley Road
Point Reyes Station, CA 94956
RE: General Management Plan Amendment for Point Reyes National Seashore
Dear Ms. MacLeod:
I am writing to provide input on the General Management Plan Amendment for Point Reyes National Seashore (PRNS). I support the continued operation of beef and dairy ranching operations under agricultural lease/permits with 20-year terms and improved management of the Tule elk herds to eliminate negative impacts on the environment and ranching families.
Ranchers have been raising cattle in Point Reyes for more than 150-years. It was ranchers' willingness to sell their properties to the federal government that allowed the creation of the PRNS. As part of the agreement, ranchers were supposed to be allowed to continue ranching on their family ranches within the PRNS. The ranches in West Marin contribute significantly to the local economy and the local culture. According to any analysis by U.C. Cooperative Extension in 2009, ranches in PRNS and Golden Gate National Recreation Area (GGNRA) directly provide approximately 65 jobs and provide livelihoods for an additional 25 ranch family members. Additionally, agriculture in PRNS and GGNRA account for 17 percent of the agricultural income in Marin County. These jobs and income would be lost if further restrictions were placed on ranches within PRNS. These ranches are not just creating economic value, they are producing high quality food appreciated by consumers locally, regionally, and nationally. Further, providing 20-year terms for lease/permits allows for greater investment in improvements on these ranches. Shorter terms prevent the ability of ranchers to obtain financing for improvements.
I would also like to see improved management of the PRNS elk herds. Elk cause thousands of dollars of damages and lost forage on ranches. Additionally, the elk carry Johne’s disease, which can be transmitted to cattle. USDA estimates that lost productivity from Johne’s disease in dairy cattle could be costing dairy producers between $200 and $250 million annually. Elk in the PRNS were reintroduced by humans and have been managed since their reintroduction. PRNS must improve its management by maintaining the roaming elk herds on the Limantour wilderness and preventing them from damaging ranches in the area. Additionally, PRNS should ensure that there is proper forage and water available to the herd in the Limantour wilderness to prevent a reoccurrence of the unfortunate loss of elk during the drought.
Ranches on PRNS provide important economic, cultural, and ecological values to the local community. Losing a significant portion of West Marin’s agricultural community would mean not only a loss of local food production, but a significant loss to its economy and culture. I urge you to offer 20-year lease/permits to ranchers on PRNS and to improve elk management and return the elk to the wilderness areas where they will not impact the ranches.
___________________________
# 2603
Name: Pullen, Creta d
Correspondence: The Ranchers should be given long term (at least 20 yr) leases and be allowed diversification as needed and supervised by an outside agency.
Tule Elk should be kept off and not be allowed on Ranch Land.
___________________________
# 2604
Name: Sands, Anne
Correspondence: I submitted comments already today and need to make one clarification to Comment ID: 1295791-83408/2586
In comment #6. I did not intend to imply that MCL supported any particular alternative. Only that MCL did extensive study of the issues.
So, please delete my comment #6.
Thank you,
Anne Sands
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# 2605
Name: Borg, Carolyn
Correspondence: Please accept my comments on the GMP Amendment process for Point Reyes National Seashore.
I believe that this national seashore must be managed in the national interest to fully protect its diverse and abundant native wildlife and plant species, incredibly beautiful natural scenery, and ecological systems and processes.
Domestic livestock grazing and farming operations are private commercial enterprises that have no place in this national seashore. Indeed, such grazing and farming activities can and do have adverse impacts on the national seashore's native species, scenery, and ecology. As such, grazing and farming pose fundamental conflicts with proper national seashore management.
Given these fundamental conflicts, I do not understand how NPS thinks that it may even have the discretion to authorize future grazing and farming operations. If fidelity to law, science, and the national interest are important to NPS, then the only proper alternative would be for NPS to prohibit future grazing and farming in amending the GMP.
I realize that President Trump and Interior Secretary Zinke are bending over backwards to please wealthy corporate interests and favor those with political influence and a strong profit motive, but I nevertheless hope that NPS will somehow find the courage to do the right thing. I also hope that most of the California Congressional delegation would support NPS in such an effort. This is and will be a true test of NPS' integrity, credibility, and effectiveness.
Thank you very much for considering my comments.
___________________________
# 2606
Name: Madden, meg
Correspondence: Please protect our Tule Elk in Point Reyes.
It is short-sighted to run them off to allow more cattle to graze.
There is room in the park for both.
So many were already let die during the drought when they were fenced away from water sources.
Please save these noble animals!!!
___________________________
# 2607
Name: herbert, Lisa
Correspondence: I am very concerned with the fuel loads within the park and close to our town. The cattle and horses were taken off the Rancho Bolinas and Holter properites and the grasses are not mowed which presents a problem for fire suppresion. In many areas of the park the forest is sick, such as along the Bay View trail. Also many dead and dying Oaks hang over highway one creating a danger to drivers. I feel that the park has bitten off more then it can chew in regards to the proper managment of these lands. I would like to see more grazing in the park rather than less. I would like to see better forestry practices too. Perhap through more public and private partnership you would have the ability and resources to manage these lands and protect the communites like mine fron wild fires like we saw in Sonoma and Napa counties.
I also want you to keep the Stewart horse camp open. It is one of only a few near the coast and many people living in the hoter parts of our state rely on going there to get some relief from the heat. With global warming this is going to be even more important to them.
In closing I want to say I like having the historical ranches still working as ranches.I think they add to the park and the communites around it.
Thank you,
Lisa Herbert
___________________________
# 2608
Name: Murray, Gia
Correspondence: I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
Gia Murray
___________________________
# 2609
Name: Benson, Mary Kay
Correspondence: I moved to San Francisco from MN in 1980. One of my favorite nature getaways was Pt. Reyes for the 25 years I lived there. The rare free-roaming Tule Elk there were part of the magic of the place. I cannot believe they are being fenced in and killed off for cattle! Let me say we never stood transfixed in awe for long periods of time when we saw cows grazing there.
I am so disappointed in the Park Service in this matter. Please reverse course. "Livestock contribute about 14.5 percent of global greenhouse-gas emissions, according to the Food and Agriculture Organization of the United Nations. Methane accounts for about 44 percent of these emissions, of which cows contribute the lion's share." https://www.csmonitor.com/Science/2016/0920/Apocalypse-Cow-Will-California-bill-cut-gassy-livestock-emissions
___________________________
# 2610
Name: Lavine , Sanford
Correspondence: Please continue to allow sustainable farming and ranching on Point Reyes National Seashore (Seashore) and Golden Gate National Recreation Area (GGNRA). It keeps the area natural and enhances the experience of visiting these precious public areas.
Thank you
___________________________
# 2611
Name: Kalousi, Maria
Correspondence: Dear Superintendent,
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
Maria Kalousi
___________________________
# 2612
Name: Clyde, George
Correspondence: Dear Acting Superintendent MacLeod:
I am an Associate Director of the Marin Resource Conservation District (the "Marin RCD"), a position I have held for quite a few years. I am submitting these comments as an individual, not on behalf of that organization.
I have seen the comment letter dated November 13, 2017 by Nancy Scolari, Executive Director of the Marin RCD, and I want to express my support for all of those comments.
I would like to particularly focus on this recommendation:
5. Establish a Rancher Advisory Council to support stewardship-based agricultural land management activities. An advisory council can work with NPS to help inform and guide a sustainable future for agriculture including the diversification of agricultural activities adjacent to sensitive environments. ... . An advisory council can guide a robustly supported land stewardship program and provide the perfect opportunity to model ranching and ecosystem health and the mutual benefits offered by both.
In the past, efforts by groups of ranchers to meet collectively with Park officials to discuss ranching issues have been frustrated by a bureaucratic response - that such meetings would violate the Federal Advisory Committee Act ("FACA").
Unfortunately, without the ability to meet as a group with Park officials, good ideas and information cannot effectively be discussed and developed. The prohibition of meetings with several ranchers at the same time hurts communication and understanding, and also makes it more difficult to find good solutions to difficult problems as they emerge.
The situation is exacerbated because the ranchers have a landlord-tenant relationship with the Park. As such, sometimes problems and ideas that would make good sense are not expressed by ranchers to the Park managers, for concern that the individual lease relationship could be affected. Requiring ranchers to rely only on one-one-one communications compromises their abilities to express their concerns and makes it less likely that the Park will have a full understanding of their needs and opportunities for improvement.
Fortunately, there are many ways that the Park and ranchers as a group could communicate effectively with each other without violating FACA, if the Park would make the effort to do so. The “National Park Service Guide to the Federal Advisory Committee Act” issued by NPS Office of Policy (Updated February 18, 2011), describes various ways in which collective input can be received by the Park and discussed with ranchers. See https://www.nps.gov/bicy/parkmgmt/upload/NPS_FACA_Guide_2010.pdf.
These are some excerpts, although the full document should be read for a complete understanding:
• ... be aware that (a) many of the meetings the federal government typically holds are with groups that are not "established or utilized" within FACA's meaning and that (b) there are ways to avoid implicating FACA.
• GSA regulations (41 CFR Part 102-3) recognize some kinds of advisory meetings are not covered by FACA. These include meetings with:
o 2. Any group where advice is sought from the attendees on an individual basis and not from the group as a whole (this includes public meetings). In meetings of this sort, remind the group that you are seeking individual views and are not looking for the group to agree on a particular course of action.
o 3. Any group that meets with federal officials for the purpose of exchanging facts or information.
o 4. Any committee or group created by non-federal entities (such as a contractor or private organization), provided that these committees or groups are not actually managed or controlled by the executive branch.
• If you are careful, there are two additional ways (beyond those specifically recognized by GSA) to obtain public participation in review of agency matters without establishing a FACA committee.
o First, a policy discussion group or "roundtable" can be formed to solicit individual (as opposed to group) opinions on draft proposals, option papers, or specific issues.
o Second, focus groups may be used to solicit individual (as opposed to group) opinions when there is a need for quick, anecdotal information about how different approaches to solving a problem would work in practice.
I hope that the Park and its attorneys can in the future take a more flexible approach - - to actually try to make it possible to meet with groups of ranchers in the manners described above. Ask your attorneys for advice as to how to make it work, not just what their concerns would be. For the sake of the Park and the ranchers, the Park and their counsel should find ways for group communications and discussions as allowed under the NPS Guide quoted above, and this process should be included in the General Management Plan Amendment.
Thank you for considering my comments.
Sincerely,
George Clyde
Marshall, CA
___________________________
# 2613
Name: Markuson, Denise
Correspondence: Dear Superintendent,
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
Denise Markuson
___________________________
# 2614
Name: jones, christy
Correspondence: Dear Superintendent,
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
Christy Jones
___________________________
# 2615
Name: Medbury, Theresa
Correspondence: Dear Superintendent,
Our most precious resource is a healthy environment. I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Public land belongs to each and every citizen. We hold it in trust for future generations. It is destructive practice to allow few commercial lease holders dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
Theresa Medbury
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# 2616
Name: Duley, Ted
Correspondence: Spare the Point Reyes Tule Elk. There's plenty of cattle grassland elsewhere.
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# 2617
Name: N/A, N/A
Correspondence: Cynthia MacLeod, Acting Superintendent
Point Reyes National Seashore
National Park Service
1 Bear Valley Road
Point Reyes Station, CA 94956
RE: General Management Plan Amendment for Point Reyes National Seashore
Dear Ms. MacLeod:
I am writing to provide input on the General Management Plan Amendment for Point Reyes National Seashore (PRNS). I support the continued operation of beef and dairy ranching operations under agricultural lease/permits with 20-year terms and improved management of the Tule elk herds to eliminate negative impacts on the environment and ranching families.
Ranchers have been raising cattle in Point Reyes for more than 150-years. It was ranchers' willingness to sell their properties to the federal government that allowed the creation of the PRNS. As part of the agreement, ranchers were supposed to be allowed to continue ranching on their family ranches within the PRNS.
The ranches in West Marin contribute significantly to the local economy and the local culture. According to any analysis by U.C. Cooperative Extension in 2009, ranches in PRNS and Golden Gate National Recreation Area (GGNRA) directly provide approximately 65 jobs and provide livelihoods for an additional 25 ranch family members. Additionally, agriculture in PRNS and GGNRA account for 17 percent of the agricultural income in Marin County. These jobs and income would be lost if further restrictions were placed on ranches within PRNS. These ranches are not just creating economic value, they are producing high quality food appreciated by consumers locally, regionally, and nationally. Further, providing 20-year terms for lease/permits allows for greater investment in improvements on these ranches. Shorter terms prevent the ability of ranchers to obtain financing for improvements.
would also like to see improved management of the PRNS elk herds. Elk cause thousands of dollars of damages and lost forage on ranches. Additionally, the elk carry Johne’s disease, which can be transmitted to cattle. USDA estimates that lost productivity from Johne’s disease in dairy cattle could be costing dairy producers between $200 and $250 million annually. Elk in the PRNS were reintroduced by humans and have been managed since their reintroduction. PRNS must improve its management by maintaining the roaming elk herds on the Limantour wilderness and preventing them from damaging ranches in the area. Additionally, PRNS should ensure that there is proper forage and water available to the herd in the Limantour wilderness to prevent a reoccurrence of the unfortunate loss of elk during the drought.
Ranches on PRNS provide important economic, cultural, and ecological values to the local community. Losing a significant portion of West Marin’s agricultural community would mean not only a loss of local food production, but a significant loss to its economy and culture. I urge you to offer 20-year lease/permits to ranchers on PRNS and to improve elk management and return the elk to the wilderness areas where they will not impact the ranches.
Best regards,
Diane Meyer
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# 2618
Name: filipponi, KATHLEEN
Correspondence: Hello Park Service I am a member of the cattle business. Please support cattle grazing on the lands in the Point Reyes park boundaries. Being in this business is very difficult for cattlemen to find grazing lands, stay solvent and meet current regulations set by the government and public. Please allow cattle to be a part of your management plan and please support our industry. Respectfully Kathleen Filipponi
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# 2619
Name: Bradford, Patricia
Correspondence: I would like to express my support for continued ranching, dairies and farming in the Park, with controls placed on elk herds. I believe that the ranchers and the park service together can sort out and agree on the best way to do this. Thank you very much.
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# 2620
Name: Dreskin, Wendy
Correspondence: I feel ranching is detrimental to the National Seashore. I do not believe that historical use is important. Should we reopen a paper mill at Samuel P Taylor State Park because papermaking was done historically? Or start logging redwoods in parks where redwoods were historically logged. I think not.
On the trail to Abbott's Lagoon one side of the fence has endangered and threatened plants like Point Reyes Checkerbloom and CA Harebells. The ranched side is barren, other than the area fenced for Sonoma foxtail.
If the Park belongs to us, why do ranchers get the final say on trail improvements? My husband and I have done the Abbott's Lagoon area for the Point Reyes Christmas Bird Count for decades. He can no longer climb under or over the fence, a necessity to circle the lagoon. We even offered to pay for a Z-gate ourselves. We were told it couldn't be done because the rancher did not want it. The park should not only be open to people who can climb under and over fences!
Many of the ranchers have outdoor cats even though one purpose of the National Park is to provide habitat for native birds and opportunities for bird watching. The problems of outdoor cats slaughtering birds is well documented. Point Reyes is a home and a migratory rest area for threatened and endangered birds.
I believe the ranches should be phased out for the benefit of native plants, native animals, visitor access.
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# 2621
Name: Campbell, K
Correspondence: To whom it may concern
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
Karla Campbell
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# 2622
Name: McClure, Robert
Correspondence: McClure Dairy
November 13, 2017
Point Reyes GMP Amendment
Superintendent Cynthia MacLeod
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes Station, CA 94956
Dear Superintendent MacLeod:
The McClure Family appreciates the opportunity to comment on the Point Reyes National Seashore (PRNS) and North District of Golden Gate Recreation Area (GGNRA) General Management Plan (GMP) Amendment environmental review during this public scoping period. The McClure family offers the following high level comments for consideration in this public comment period and will participate fully with additional details in subsequent comment periods during the release of the Notice of Intent and Draft Environmental Impact Statement.
McClure family has operated a dairy farm on the Point Reyes peninsula for over 130 years occupying seven different ranches on the Point during that time. We are currently leasing the Historic I Ranch. We have operated a dairy here for the past 87 years. Our children are the fifth generation involved in the dairy. We have a history of good relations with NPS staff and administration. We hope that the new GMP Amendment will continue to foster the working relationship between the McClures and NPS.
we milk a herd of organic Holstein milk cows. We also raise dairy replacement heifers. The dairy was certified organic in 2006. We also manage pastures and raise silage for our livestock. We have 8 non-family employees which are provided housing on the ranch for them and their families.
have reviewed the alternatives currently presented by NPS. The three Settlement Required Alternatives will have huge negative impacts on the ranches, the ranchers and their families, the employees and their families, the local community and neighboring areas as well. With reduced or no ranching in the PRNS, nearly 100 families will be displaced. This would result in possible closure of support services for the ranches to operate such as feed mills, veterinary services and ranch supply companies because of reduced business/lack or volume and lack of critical mass from fewer customers. Additionally, local schools would be impacted as a result of significantly lower enrollment which may result in the closure of local schools. Because of the displaced families, other local businesses, such as doctors, hardware store, grocery stores, veterinarians and the pharmacy will be impacted as will service providers such as plumbers, electricians, etc.
We ask that the additional Preliminary Conceptual Alternatives consider a range of alternatives that include the consideration of the complete removal of the free-ranging tule elk herd from the pastoral zone.
Some of the most important issues that we would like to see addressed within the range of alternatives that allow continuation of ranching and farming include:
Leases: We welcome the opportunity to engage in a 20 year permit. This will allow us security for our business continuity. It will allow us to continue to make long term improvements to the ranch. The 20 year term is important in order to secure funding for the capital projects from banks and for us to get the full benefit of the improvements (i.e. Driveways, roofs, etc). We ask that consideration be made such that the ranches have renewable 10 year lease options that can be exercised at every 20 year midterm, allowing lease updates every 10 years and a new 10 year term added to the 20 year lease, but never exceeding 10 years into the future.
Operational Flexibility: We ask that guidelines be established that allow for action to be taken, without delay, on regular infrastructure, maintenance, repair and replacement such as fences, roofs, etc. and implementation of best management practices for agricultural and natural resource management.
Range management practices known to be effective for improving forage quality and quantity should be allowed for all ranches. These should include mowing, grazing, management intensive (rotational) grazing and seeding. Additionally, we believe that in certain cases, plowing, discing and reseeding may be the only way to eliminate invasive plant species such as velvet grass. Mowing of thistles is essential for control. Manure application is important as a fertilizer and must continue to be allowed to be applied in a responsible manner (appropriate rates, away from waterways). Some ranches may already have a Comprehensive Nutrient Management Plan in place through the Natural Resource Conservation Service. We ask that the ranchers be directly involved in the collaboration with PRNS and GGNRA staff to develop these guideline in the GMP Amendment process so that the end result is a decision making process that supports effective range management.
Diversification. Please consider allowing conversion to other livestock species (ex. Dairy to beef, etc) or other historic uses as market conditions dictate. Other examples could be consideration for diversification that include selected planted or naturally occurring crops, additional livestock productions, farm stands and retail sales, processing and value-added production, farm stays and farm educational tours.
Most dairies outside the Park utilize their ground for growing forage and is a key to sustainability. The cost of importing forage from places as far away as Eastern Nevada is costly and growing feed locally reduces the carbon footprint by eliminating trucking. We ask that those that are currently raising silage in the PRNS be able to maintain their acreage and those that wish to begin be allowed to raise up to 25% of their leased acres as silage. This farming practice also combines the benefit of utilizing and preserving seasonal forage production with effective weed management.
Succession. The ranch GMP Amendment should establish a procedure for lease succession in the event that the tenant dies or leaves the business. In order to keep the ranches in agriculture, preference should be given to immediate family members first. The continuation of agriculture in PRNS is critical to maintaining the current rural character of the entire North Bay area by maintaining critical mass for trade and agricultural services.
We ask that the lessee/rancher have a decision-making role when selecting who should succeed in the lease agreement.
Environmental Stewardship and Best Management Practices: We ask that the NPS collaborate with ranchers to establish programmatic approaches for streamlines implementation of best management practices. We believe this is critical to Operational Flexibility and successful management of the multiple resource objectives on PRNS and GGNRA ranches and farms.
We ask that in analyzing alternatives that the current participation and compliance of the ranches and dairy farms in the San Francisco California Regional Water Quality Control Board jurisdiction be integrated with any approaches developed.
We ask that approaches to integrate methane and climate change management include the emission inventories, goals and action items for agriculture in the Marin Climate Action Plan. This plan provides a path, in conjunction with the Marin Carbon Projects Carbon Farm Plans, for realizing the benefits as carbon sinks and offsets that ranching and farming can provide for the NPS and the broader community.
California Senate Bill 1383, passed into law in September 2016 requires methane reduction from dairies statewide and will result in the implementation of specific regulations and financial and technical assistance programs to manage dairy manure and achieve reduction goals. Recognizing this as an opportunity and facilitating connection with these resources through the GMP Amendment process will make the NPS and the PRNS and GGNRA leaders in sound state-of-the-art management.
Information and Analysis from Previous Planning and Scoping Efforts: Ranches in the PRNS have participated in previous public comment and scoping periods during the development of a full GMP Update in the early 2000s and in the involved and thorough process to develop the Ranch Comprehensive Management Plan from 2012-2015. That earlier scoping and environmental analysis studied many, if not all of the topics introduced in this first phase, producing relevant information, details, and options for the successful mutually beneficial continuation of the PRNS and GGNRA historic cultural resources. We ask that this information be considered and used during the GMP Amendment process including development of the NOI and Draft EIS.
Sincerely,
Robert J. McClure
Historic I Ranch
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# 2623
Name: Hoskins, Richard
Correspondence: My family discovered the beauty of Point Reyes after the birth of our son, 20 years ago. We fell in love with the community and their commitment to preserving the agricultural roots, opening their ranches and oyster and vegetable farms to us and all visitors. Our community's strong environmental and social values have made us leaders in organic farming and a variety of other conscientious land practices. Our son was deeply touched by the nature, the animals, the people and even its wilderness. Despite coming from a family of city slickers, he found a Native American mentor to teach him tracking and hunting skills. Along the way, he has learned about man’s responsibility to the land and the ever changing challenges that we confront. He is now a freshman at Kenyon College, majoring in environmental studies.
Why does this matter? Point Reyes is our home and the ranchers are valued members of our community. We cherish the agricultural history of our area. We were devastated when the fight over Drakes Bay Oyster Community cost us many friendships and a wonderful resource directly at our door step. Drakes Bay has been neutered and our community has been raided thanks to the efforts of organizations who now seek to extend their wrong minded hegemony over ranches operating in PRNS. PRNS can be a shining example of good stewardship and beauty, or it can reinforce the actions taken against Drakes Bay Oyster Company and show the next generation the strength of bigotry, government agency hegemony and misguided obsequiousness.
The Tule Elk are also our responsibility and I believe we must find a way to coexist with and manage the herds present in PRNS. Seeing them and their interesting mating habits was one of the tales my son frequently told his friends.
I strongly support the NPS initial proposal that calls for "continued ranching and management of Drakes Beach Tule Elk Herd."
Regards,
Rick Hoskins
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# 2624
Name: Gilmore, Brian
Correspondence: I support the option to allow sustainable ranching and agriculture in the Point Reyes National Seashore and GGNRA, and to continue to manage the Drake's Bay elk herd.
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# 2625
Name: Guillot, Janine
Correspondence: I am writing to strongly support the continuation of ranching in the Pt. Reyes National Seashore. As a 30 year resident of the Bay Area, I have seen first hand how the Seashore ranches positively contribute to quality of life in the Bay Area. The Seashore ranches enable the existence of a high quality local food movement and a thriving agricultural economy in Marin, built around sustainable and organic agriculture. They provide numerous environmental benefits, including sequestering carbon and providing habitat for endangered species.
After the devastating North Bay fires, it is also very important that the Park Service consider the positive impact grazing has on reducing wildfire danger. Any planning process should consider the cost to mitigate fire danger if the land is not grazed.
Thank you for your consideration.
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# 2626
Name: Anerson, Ashley N
Correspondence: To Whom It May Concern:
I am not sure if I am adding my comments to the correct place, however, I strongly urge you to not allow ranchers to take over the land at Point Reyes National Seashore. The Tule Elk are a beautiful species and should be able to roam the land freely and safely. Please let the park remain wild and reduce the amount of cattle ranching, which is harmful to the environment and should not be allowed on federal lands. The areas surrounding Point Reyes rely heavily on tourism and eradicating these marvelous creatures from the park is sure to take its toll on the local communities. I am a California resident who frequents the park and enjoys the wonderful wildlife it has to offer.
Thank you,
Ashley Anderson
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# 2627
Name: Wilson, Shannon
Correspondence: Thank you for the opportunity to provide input to the Park's General Management Plan (GMP). I support continued ranching in the Seashore and GGNRA. I also support long-term leases that will enable the ranchers to make the capital investments needed to succeed over the long term. Bay Area residents are lucky that the ranches exist and that passionate people are producing healthy, local, sustainable food in close proximity to a major metropolitan area. In many areas of the country, agriculture and the environment are opposing forces. In the Bay Area, we have proven that agriculture and the environment can successfully co-exist and that both Bay Area residents and the environment benefit from sustainable agriculture. I encourage the Park Service to adopt options that allow ranching to continue in the Seashore and the GGNRA.
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# 2628
Name: Merritt, Curtis J
Correspondence: November 13, 2017
Cynthia MacLeod, Acting Superintendent
Point Reyes National Seashore
National Park Service
1 Bear Valley Road
Point Reyes Station, CA 94956
RE: General Management Plan Amendment for Point Reyes National Seashore
Dear Ms. MacLeod:
The "Friends of Point Reyes Morgan Horse Ranch" wholeheartedly support the continued operation of beef and dairy ranch operations by way of agricultural leases/permits with a minimum 20 year term, as well as to improve management of the Tule elk herds to help eliminate any adverse effects on the environment.
Ranchers have been raising beef and dairy cattle in Point Reyes for over 150 years. It was the ranchers' negotiations with the federal government that allowed the creation of Point Reyes in the first place. As part of the agreement of the sale, ranchers were assured they would be allowed to continue ranching operations on their family properties within Point Reyes.
These ranches create economic value and produce high quality food appreciated by consumers nationwide. Furthermore, providing minimum 20 year terms for leases/permits allows for investment in improvements on these properties.
We would also like to see improvement in the management of the Point Reyes Tule elk herds. Tule elk were placed in Point Reyes after they almost became extinct in the mid-1800s. Point Reyes could and should improve its management of the Tule elk herds. Additionally, Point Reyes should ensure that there is proper food and water available to the herd as needed.
We would like to urge you to continue to honor the terms of the original agreement when the land was purchased by NPS by offering minimum 20 year leases/permits at the current levels to ranchers on Point Reyes and to improve the Tule elk management.
Friends of Point Reyes
Morgan Horse Ranch
(a subcommittee of Sacramento
Valley Morgan Horse Club
Connie Barker
Mary Brown
Curtis Merritt
Co-Chairs
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# 2629
Name: Breiner, Dorothy L
Correspondence: We support the 20 year agricultural lease/permits with diversification & increased operational flexibility.
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# 2630
Name: Scott, Peggy L
Correspondence: Dear Superintendent,
I support the free-roaming tule elk herds at Point Reyes National Seashore. I live near there and they delight me. There should be no fencing, removal, sterilization or killing of elk in the park. One they were almost extinct and now they are back although the herd is tiny. Tule elk are an important part of the Point Reyes landscape. Bringing them back from the brink of extinction has been important. Biodiviersityis an important part of the mission of the National Park Service.
We've got cattle a-plenty. Cattle are fine. We don't need to protect them. We need to protect endangered species. Besides, the ranchers on our public lands shouldn't dictate any wildlife policies. Cattle-ranching operations must accommodate elk and other native wildlife, and shouldn’t harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service’s amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
Peggy Lee Scott
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# 2631
Name: Tacherra, Jan P
Correspondence: Ranching and parks do not work well together. Rangers do not appear to hold ranchers to the terms of their lease agreements. Some ranchers lease out parkland properties for carpentry shops and other for profit rentals such as housing to private parties. TWENTY years is too long and will only benefit ranchers not the public. The park does not appear able to handle the properties they have and should consider selling the ranches so we could have a smaller park that the Rangers could handle. Perhaps, the ranchers could buy their ranches back! In Bolinas there are many problems with the park and we see very rarely see a ranger. When we do they are usually driving by on Mesa Road way too fast. They do nothing to address the traffic issues the park has caused for those of us living on Mesa Road. In forty years of living here I have never seen a ranger stop a car for speeding or reckless driving! I see one ranger drive by in the morning and 10 minutes later they are gone. Another drives by in the afternoon and then quickly leaves town. Take steps to let Ranchers be Ranchers and Rangers be Rangers! The Park should not be in the business of subsidizing or supervising ranching! These should be two distinct and seperate enterprises. Thank you
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# 2632
Name: Callaway, Kathy
Correspondence: November 14, 2017
Cynthia MacLeod
Acting Superintendent
Point Reyes GMP Amendment
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes Station, CA 94956
Subject: First Phase Comments for the Point Reyes National Seashore General Management Plan Amendment
Dear Acting Superintendent MacLeod,
Mainstreet Moms is a West Marin citizen action non-profit. We have, since 2004, been committed to securing a more viable future for our children through the education, engagement, bite-sized actions, and leadership of moms and honorary moms everywhere. It is through that lens that we are responding to this first phase of the General Management Plan Amendment planning process. Thank you for this opportunity.
Support of the Ranches and Dairy Operations
We believe that ranching and dairy farming should continue in the Park, as originally authorized. This is the best and only way to ensure the continuation of the benefits of vital agricultural production to the community, the local economy, and visitor education and experience.
Three of the alternatives presented propose no- or reduced-ranching options. We are concerned that, among other problems, removing the agricultural management that the ranchers now provide would result in an increase in invasive plants like thistle, broom, and eucalyptus - problems that will erupt without the Parks ability to control them. These lands would also become a nursery for weeds and would require significant management demands on the Park. Facing already tight budgets and understanding that a proposed 13% Park budget cut is anticipated, how would the Park pay for the necessary increased management? We ask that a thorough environmental and cost analysis be done to show how much it would cost the Park to manage these lands. Several Mainstreet Moms participate in ongoing habitat restoration efforts in the Park and are all too aware that the Park is already struggling to manage its existing invasive weed problems.
Economic and community impact of the proposed alternatives
Agriculture in the Park represents $18.3MM (19%) of Marins total $96.5MM gross production value (according to the 2016 Marin County Crop Report). The no- or reduced-ranching alternatives need to consider not just the loss of this huge economic value, but must also undertake a thorough economic analysis of the rolling cultural and economic impacts that removal of ranches would have on the community and across Marin. Shuttering the ranches would displace ranch families and would inevitably lead to the shutting of at least some local schools, leaving the remaining kids without a nearby option for public education - along with displacing teachers. The disappearance of on- and off-farm jobs, lack of local affordable housing and school closures need to be evaluated in the next phase EIS.
Elk
While we dont dispute the historic value of Tule Elk in the Park, three of the alternatives propose either management of the Drakes Beach Tule Elk herd or removal of the herd. A thorough economic and environmental analysis needs to be done to understand, under the management alternatives, where the herd would be moved to in order to avoid the current and historical conflicts with ranches - and how the Park would pay for the significant costs of management or removal.
Conclusion
Mainstreet Moms is deeply embedded and active in the local community of West Marin and highly supportive of our Park. We also support our local ranchers and the benefits they bring to our communities. We hope that through this General Amendment Process, the Park will find a balance that integrates the benefits of our dairies and ranches and the families that support them with the natural resources and value that the Park brings
Thank you for this opportunity to comment.
Kathy Callaway
Board Chair
Mainstreet Moms
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# 2633
Name: Hyde, Kathryn
Correspondence: I would like my comments to stay anonymous if possible. My recommendations:
1) Ranchers
- Coordinate meeting with the NPS, the ranchers and land management professionals to plan for "sustainable lands."
- Fence ranch area to keep cattle from grazing near the shoreline.
- Offer training for ranchers in organic, sustainable cattle and dairy farm techniques
- Let the ranchers stay in the family. Once the family no longer want to ranch, then the land should return to the NPS
2) Historic Buildings
- Either keep them in use as they are, or restore them for the public to view (like Pierce Point)
- Do not turn them into museums, cafes, conference centers or shops. The NPS does not need more areas for the public to gather, that require, public services and more roads and parking lots.
3) Tule Elk
- Move them to the original locations in Pt. Reyes (where they were re-introduced), keep them away from the Drakes bay Area.
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# 2634
Name: Eichstaedt, Amanda
Correspondence: The Point Reyes National Seashore would not exist if it were not for the agreement with the ranchers. This unique relationship is worth preserving . Please explore ways in which the ranching can continue to exist. Longer leases would be beneficial for ranchers to create longer term plans. People have been a part of the landscape of West Marin for a very long time, the relationship of the people to the land via history should be more greatly explored and explained for the visitors to this unique park.
More access into areas currently not served by trails should be explored, including more point to point hiking and additional backpacking campsites for visitors to the Point Reyes National Seashore.
Grazing lands are important to the park. Please explore ways that ranching and grazing can continue in the park.
Thank you for including the public in this initial scoping process.
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# 2635
Name: Biss, Jeffery J
Correspondence: I support the free-roaming tule elk herds at Point Reyes National Seashore.
I oppose any fencing, removal, sterilization or killing of elk in the park.
I support a reduction in the human load, developing policies to get people to stop having kids to drive the human population to a sustainable level. We are the problem, not wildlife.
I support efforts to restrict resource extraction activities in wildlife habitat. We need to develop a sustainable economy and that includes ensuring that extractors are regulated to the benefit of wildlife.
Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service. People are a problem for the ecosystem and must be controlled for the benefit of wildlife.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
___________________________
# 2636
Name: N/A, N/A
Correspondence: Cynthia MacLeod, Acting Superintendent
Point Reyes National Seashore
National Park Service
1 Bear Valley Road
Point Reyes Station, CA 94956
RE: General Management Plan Amendment for Point Reyes National Seashore
Dear Ms. MacLeod:
I am writing to provide input on the General Management Plan Amendment for Point Reyes National Seashore (PRNS). I support the continued operation of beef and dairy ranching operations under agricultural lease/permits with 20-year terms and improved management of the Tule elk herds to eliminate negative impacts on the environment and ranching families.
Ranchers have been raising cattle in Point Reyes for more than 150-years. It was ranchers' willingness to sell their properties to the federal government that allowed the creation of the PRNS. As part of the agreement, ranchers were supposed to be allowed to continue ranching on their family ranches within the PRNS.
The ranches in West Marin contribute significantly to the local economy and the local culture. According to any analysis by U.C. Cooperative Extension in 2009, ranches in PRNS and Golden Gate National Recreation Area (GGNRA) directly provide approximately 65 jobs and provide livelihoods for an additional 25 ranch family members. Additionally, agriculture in PRNS and GGNRA account for 17 percent of the agricultural income in Marin County. These jobs and income would be lost if further restrictions were placed on ranches within PRNS. These ranches are not just creating economic value, they are producing high quality food appreciated by consumers locally, regionally, and nationally. Further, providing 20-year terms for lease/permits allows for greater investment in improvements on these ranches. Shorter terms prevent the ability of ranchers to obtain financing for improvements.
would also like to see improved management of the PRNS elk herds. Elk cause thousands of dollars of damages and lost forage on ranches. Additionally, the elk carry Johne’s disease, which can be transmitted to cattle. USDA estimates that lost productivity from Johne’s disease in dairy cattle could be costing dairy producers between $200 and $250 million annually. Elk in the PRNS were reintroduced by humans and have been managed since their reintroduction. PRNS must improve its management by maintaining the roaming elk herds on the Limantour wilderness and preventing them from damaging ranches in the area. Additionally, PRNS should ensure that there is proper forage and water available to the herd in the Limantour wilderness to prevent a reoccurrence of the unfortunate loss of elk during the drought.
Ranches on PRNS provide important economic, cultural, and ecological values to the local community. Losing a significant portion of West Marin’s agricultural community would mean not only a loss of local food production, but a significant loss to its economy and culture. I urge you to offer 20-year lease/permits to ranchers on PRNS and to improve elk management and return the elk to the wilderness areas where they will not impact the ranches.
Thank you,
Michael Vellutini
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# 2637
Name: Kline, Matthew
Correspondence: I have invested much of my time in Point Reyes National Seashore. This unique stretch of picturesque coastline has left an everlasting impression on me. After spending years looking for a way to get closer to this area, the same area my grandpa cherished years before me, my wife and I finally made our dream happen. We couldn't be happier, living and working near the place we share so many countless memories of and the place that has captured both of our hearts. I’m mentioning this because I think it’s important that you know a little bit about where I’m coming from. I know it’s a subject that has divided the community and some say it’s only personal for them, but it’s a subject I too care deeply about and it’s also personal for me.
The story of the Tule Elk is one that is truly remarkable. Their close call with extinction or should we say extermination by our hands, mostly by way of hunting and large scale cattle ranching, is a story that should never be forgotten. Today, the pressure on this species continues even when there are less than 5,000 of these majestic animals left in the world. This is a native and endemic California species that numbered an estimated 500,000 strong not all that long ago. Meanwhile 5.5 million head of cattle spread out across the entire State of California and close to 95 million roam the United States. Where is the level-headed, critical thinking, and sustainably balanced approach in that? Is there any room left for our iconic native wildlife in our iconic national parks? The Seashore is the only National Park where Tule Elk can be found. For those of us who enjoy spending time around wildlife and see the significant role they play in dynamic and healthy ecosystems, we are thankful Tule Elk still exits, but we are not naive either and understand well the research, management decisions, protections and priority they deserve going forward.
The Seashore’s own website states "as wild land habitat is lost elsewhere in California, the relevance of the Point Reyes Peninsula increases as a protected area with notable rich biological diversity." There are over 50 threatened, rare, or endangered species located within this park, nevertheless ranching interests get priority. I’d like to be empathetic to the ranchers, but where is their empathy for the Tule Elk, the surrounding ecosystems, and the other rare and endangered wildlife? It’s frustrating that ranchers have continually pressured our elected officials to do something about the elk “problem." But what if cattle is the problem. Why is our access diminished with fences everywhere in sight, along with fences for the elk, when it’s the cattle that should be fenced in? We should be discussing the establishment of corridors for the elk to move, connect with and maintain a healthier population, not criticizing their grazing of “silage meant for cattle” as ranchers like to put it. Many of us are well aware of the negative impacts ranching has on our last wild places and critically important sanctuaries; one only has to do their homework. Let’s discuss the flow of tourism dollars into the park because people want to spend time immersed in and surrounded by more wild settings, not cows and fences.
Learning about the many environmental issues we face as well as the ones numerous wildlife species are confronted with, not just here, but in other parts of the state and country, as well as abroad is very important to me. I’ve learned a lot about declining populations, shifting baselines and threatened species in the process, and truly the learning doesn’t stop, it motivates me to do more. Wildlife and healthy ecosystems are being diminished everywhere. This is not fake news, this is a real significant problem facing all of us, and my guess is that you and the others working on behalf of our parks are well aware of it. Unfortunately it seems that for every single positive environmental step forward there’s an overwhelming amount of negative developments also occurring. Our progress is slow and not nearly enough to turn this tide and I feel that it’s upon us to push ourselves to earnestly do more.
I strongly recommend that the National Park Service pursue the “No Ranching and Limited Management of Tule Elk Alternative” in updating its General Management Plan. Although I doubt this pioneering step will be taken for fear of backlash from ranching interests and its supporters, I cannot in good conscience recommend a less enlightened “alternative.” Subsidizing ranching on public lands makes little sense, especially when the volume of land set aside for ranching interest (everywhere) already exceeds such an enormous amount and when the negative impacts associated with extensive ranching has been documented. Phasing out ranching over a fair and more than ample period should be considered, as well as exploring the issue of rancher compensation (even though ranchers have been subsidized for years already). For anyone who may criticize this approach, I would ask you to look around, study the issues and learn what is happening to our ever-diminishing ecosystems and declining wildlife populations in-whole. Head off in any direction and observe the countless spaces already set aside for agriculture, many right here at home in other parts of our community. Where is the sustainability in this approach? This is a subject that undoubtedly matters to many of us in the community, but it’s also a subject that extends beyond, and rightfully so, because in the end there’s always a much larger picture to consider, and just imagine for a moment what a special picture it could be.
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# 2638
Name: Page, Jeff C
Correspondence: To Staff,
We believe farming still has a place in the Point Reyes National Seashore. The farm families operating there have a personal stake in maintaining an ecologically healthy environment, in order for their business to survive through generations, and an understanding of their environment that cannot be matched by people or idealistic interest groups from outside the community .
As do we here in Napa, staying up to date on the latest ecological practices enhances our operation and the environment we live and work in. We trust these farm families are doing the same, and we urge the park service to keep the farms in place for the future.
Keep those farms in the PRNS!
Sincerely,
Jeff Page
Manager, Trubody Ranch, Napa
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# 2639
Name: Morse, Connie C
Correspondence: The park service must consider issuing 20 year rolling leases and every year the lease renews. This gives the ranchers and the public 20 year notice if PRNS chooses to evict the rancher. This gives the ranchers more security to better care for the natural resources on their ranches. Most importantly this gives the next generation a hope of continuing their family ranches. I also support removing the Elm from the ranch areas.
Connie morse
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# 2640
Name: Rodriguez, Andrea
Correspondence: Sonoma County Farm Bureau, a general farm organization representing nearly 3,000 family farmers, ranchers, rural landowners and agricultural businesses in Sonoma County works to promote and protect policies that provide for a prosperous local economy while preserving natural resources and a long standing county agricultural heritage.
United States Department of the Interior
National Park Service
Point Reyes National Seashore
Point Reyes GMP Amendment
1 Bear Valley Road
Point Reyes Station, CA 94956
IN REPLY REFER TO: L7617 - GMP Amendment
Sonoma County Farm Bureau, a general farm organization representing nearly 3,000 family farmers, ranchers, rural landowners and agricultural businesses in Sonoma County works to promote and protect policies that provide for a prosperous local economy while preserving natural resources and a long standing county agricultural heritage.
The preservation of agriculture should remain the focus of public policy planning. The Sonoma County Farm Bureau believes protecting the ranching practices along the Point Reyes National Seashore is in the best interest of the land and agriculture. Utilizing the full 20 year lease terms provide ranchers with stabilized farm practices and also maintains the lands.
It is the Sonoma County Farm Bureau's position that the Tule Elk need to be placed back into the 18,000 acres set aside for them according to the 1998 Point Reyes National Seashore Tule Elk Management Plan and Environmental Assessment. By placing the Tule Elk in the Limantour Wilderness area, as identified in alternative A, they will have natural forage and away from ranches.
As a prominent stakeholder in Sonoma County agriculture, the Sonoma County Farm Bureau strongly supports preserving the long standing agriculture practices of Point Reyes National Seashore. I urge you to give this recommendation your full and careful consideration.
Respectfully,
Andrea Rodriguez
Government Relations Director
Sonoma County Farm Bureau
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# 2641
Name: Martin, Paul e
Correspondence: We support the continued ranching and dairying in the Seashore because:
1) It provides a unique and hard to find rural-urban connection where visitors may see and experience sustainable agricultural activities.
2) The ranching and dairying managed grazing programs enhance the Natural Capital or Ecosystem Services beyond what wild lands can provide - such as carbon storage, wildflowers, fire hazard reduction - and especially local food.
3) The Seashore dairies and ranches are important to maintain the critical mass to sustain local support businesses that are not only necessary for the Seashore ranchers and farmers but also the entire Marin agricultural community. Impact on the support infrastructure for the remainder of Marin County must be addressed.
4) The current Management Plan Amendment process should respect the historical perspective. If it were not for the farmers and ranchers of the Point, there would be no National Seashore. Their vision and concept for this most unique partnership should be maintained.
We request that an alternative that provides for a continuation of sustainable and responsible ranching and dairying within the Seashore be selected
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# 2642
Name: Meyer, Amy W
Correspondence: The National Park Service is the leading agency for natural resource protection and historic preservation that results in public enjoyment of outstanding scenic areas and opportunities for public recreation and education. This is called for in the legislative mandates for Point Reyes National Seashore (PRNS) and Golden Gate National Recreation Area (GGNRA). A portion of GGNRA that is administered by PRNS is included in this General Management Plan Amendment (GMPA).
Some of the Alternatives included in this GMPA document contravene these mandates or diminish them. Continuation of ranching was explicitly called for at PRNS and should be allowed to continue with more explicit provisions for succession in ranch management. A museum of dairy history or a similar interpretation of dairy history is far less valuable than the presence of two working dairy districts whose presence is now being finalized for inclusion on the National Register. (I am puzzled: on page 5 there is reference to "Olema Valley Dairy Ranches " because it seems well north of that valley and no dairy is shown in that valley on the page 9 map. On page 8 it is called the Olema Valley Historic District.)
To avoid misunderstanding and conflict, if up to 7,500 acres are to be removed from ranching, there should be defined criteria for doing so- - and those criteria should be in support of the reasons for preserving these lands in a national park..
PRNS staff has tried to fulfill the mission described in its enabling legislation and of their portion of GGNRA. The criteria for successful management should become more explicit through this GMPA process.
But in the first paragraph of the Background statement of this first GMPA paper, a crucial phrase is left out of the first paragraph of the GGNRA legislation: "In the management of the recreation area, the Secretary [of Interior] shall utilize the resources in a manner which will provide for recreational and educational opportunities..." If not as explicit in the PRNS legislation, the concept is just as important, so as to have a public that is educated about the park's mission. It is unfortunate that visitors to PRNS learn little about what they are seeing. There is great need to interpret the scene to visitors because it is more complex than it appears from the road or trail. It has helped lead to the present conflicts over ranching in the park.
The historic roads in the park all go close to or through the core of the ranches (unlike ranches in the rest of Marin County). This creates the opportunities for major learning experiences. While enhanced trail connections, improved signage and new interpretive waysides are mentioned in some of the Alternatives, what is missing is the sense of how important it is to have a fully developed program of public education that includes ranching. It would be possible to explain the apparently-natural but actually grazed vistas and what visitors are seeing in the core portion of the ranches. An imaginative educational program that includes ranching done with Best Management Practices (BMP) and fulfilling criteria for Sustainable Ranching, could be important learning experiences for visitors and a model for ranching elsewhere. The NPS has been paying more attention to cultural landscapes since when the legislation for these parks were written in the 1960s-1970s. Interpretation of various scenes could have national value for sustainable ranching and farming elsewhere under different circumstances. Showing how various scenes fulfill requirements for sustainable ranching could serve as exemplary models worthy of a national park.
The good programs sponsored by the Point Reyes National Seashore Association (PRNSA) are generally about natural resources and art, and provide outdoor recreation. PRNSA needs to offer a more comprehensive educational program, one that includes the ranching that takes place on more than 25% of PRNS land.
This GMPA paper asks What types of specific strategies can/should be considered for managing tule elk?
A successful plan for management of tule elk would take into account their size and reproductive abilities. Ten elk were given to Point Reyes as a precaution for keeping this native species from becoming extinct and now there are several hundred in the park. We need to learn how other transplanted tule elk have fared elsewhere and the depth of PRNS responsibility for being sure the species survives. In the absence of large predators or hunting, the population cannot just naturally continue to increase. Public hunting in Point Reyes was rejected several times by the former GGNRA/PRNS Advisory Commission for reasons of safety. Therefore culling, fencing, and other means of control need to be re-examined and reviewed in more detail. Wildlife-friendly fencing that has been used by other public agencies should be considered to minimize rancher/tule elk conflicts while allowing smaller wildlife to move freely.
The GMPA paper also asks "What types of specific strategies can/should be considered for managing agricultural lease/permits?" We support continuation of beef and dairy ranching at PRNS. Therefore we also have to be aware of the economic matrix that makes it possible for ranching to continue. Ranching is dependent on suppliers of farm materials and distribution of ranch products. There have to be a certain number of ranches in existence to allow them to continue.A system of succession for ranch management beyond the original families of 55 years ago needs to be developed so the economic system does not collapse by attrition and ranching does not "die by a death of 1,000 cuts."
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# 2643
Name: Parnay, Stefan
Correspondence: November 13, 2017
GMP Amendment c/o Superintendent
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes Station, CA 94956
Re: Point Reyes National Seashore General Management Plan Amendment
Dear Superintendent Cynthia MacLeod,
Thank you for the opportunity to comment on the Point Reyes National Seashore General Management Plan Amendment (GMPA). I support the following GMPA alternative for the Point Reyes National Seashore General Management Plan Amendment:
" Continued Ranching and Removal of the Drakes Beach Tule Elk Herd
Ranching on the Point Reyes National Seashore (PRNS) has been a way of life for families for at least two millennia, whether for the Coast Miwoks, their successors, or our current ranching families. It wasnt until 1962 that PRNS was established by John F. Kennedy, a mere 55 years ago. Ranching in the Pastoral Zone of the PRNS is vital part of what makes the park so beautiful, inviting, and a national treasure. A testament to this is the fact that the number of visitors to the PRNS has steadily increased over time to around 2.5 million a year.
Protecting ranching on the PRNS is in the best interest of our community because of the following considerations, which support ranching as is on the PRNS, including the removal of the Drakes Beach Tule Elk Herd:
1. Grazing benefits are well documented, such as this excerpt from the University of
California ANR Publication 8517 - Understanding Working Rangelands - The Benefits
of Livestock Grazing Californias Annual Grasslands:
" Livestock grazing is the most effective, efficient way to manage Californias
grasslands on a landscape scale, particularly when the land is being managed
with conservation objectives in mind (Huntsinger et al. 2007). It is proving
both a useful buffer against development (and, therefore, against loss or
fragmentation of habitat) and a practical way to enhance native biodiversity)
Bartolome et al. 2014). Grazing controls the mass, height, and cover of non-
native herbaceous vegetation, which is essential for the maintenance of habitat
for many of Californias native plants and animals, including many that are
listed as threatened and endangered. In addition, grazing can reduce the
encroachment of shrubs into grassland, which when present increases fire and
fuel loads (Russell and McBride 2003) and diminish open grassland habitat (Ford
and Hayes 2007).
2. As if ranching is not already very demanding and challenging, ranchers must also
comply with the California Coastal Act, PRNS restrictions, and other federal
requirements. This puts these ranchers at a significant disadvantage compared to
other ranchers located outside of the PRNS. We must strive for greater equity
between these ranching zones to help ensure ranchers on the PRNS remain viable and
competitive.
3. Another significant issue for several PRNS ranchers is having to contend with the
migration of Tule Elk onto their land. The Drakes Beach Tule Elk Herd needs to be
removed, including all other free-range elk. There are already designated
wilderness areas for elk populations within the park, which is thousands of acres.
Tule elk are migrating onto several ranches taking away precious resources for
livestock, which includes grass and water. They also cause a substantial amount of
damage to fencing that is costly to fix and takes away from their other
responsibilities. This means the ranchers must provide additional feed and water
to their livestock and pay for fence repairs. There is also the potential to
spread Johnes disease from the Drakes Beach Tule Elk Herd to livestock, which has
been confirmed in this herd.
I support removing all free-range elk herds because of the significant amount of
grass and water they consume on working dairy and livestock ranches. There should
be another option for removing the other free-range elk herds besides just the
Drakes Beach Tule Elk Herd because this will greatly improve the long-term
viability of the affected ranching operations, and could substantially reduce the
costs to the public of managing these elk.
4. All dairies on the PRNS are certified organic operations. This means theyve met
the highest standards of USDAs National Organic Program (NOP) to protect air
quality, water quality, soil health, and use of best sustainable practices. One of
the key requirements of being a certified livestock operation is that your animals
meet the NOP requirement of 120 days on pasture each year. This requirement can be
extremely challenging to meet because of the competition from elk feeding on the
grass where livestock graze. The PRNS requires ranchers to leave a specified
amount of residual dry matter (RDM) as a grazing condition to work the land and
keep it protected from soil erosion and nutrient losses.
5. The economic value from ranchers on the PRNS is approximately 20 million in gross
dollar amount (or ~20% of the total agricultural production in Marin County). If
value-added products are included, that value jumps to about 64 million. These are
impressive agricultural production numbers. The importance of our seashore
ranchers cannot be understated.
What would the PRNS look like without continuing ranching as is? It would be very different. I believe the public would be disappointed with the transformation of their national park because of the following changes:
" Reduced biodiversity
" Less grasslands due to the encroachment of native coyote brush and poison oak
" Greater risk of catastrophic wildfires due to increased fuel-loads
" Fewer threatened and endangered species
" Significant economic losses to ranchers
" Reduced overall soil health since nutrients are not replenished to the soil
through livestock manure
We have a duty and responsibility to protect our natural resources, parks, and wilderness areas. This means protecting and supporting our ranchers on the PRNS, and continuing what has been done by ranching families on this land for hundreds of generations.
Sincerely,
Stefan Parnay
190 Barrio Way
Windsor, CA 95492
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# 2644
Name: Rumpf, Lori J
Correspondence: Dear Superintendent,
I have been an animal and environmental advocate for more than three decades and am writing to you now on behalf of the Center for Biological Diversity and in support of the free-roaming tule elk herds at Point Reyes National Seashore. I object to any fencing, removal, sterilization or killing of elk in the park. I just learned that the Park Service allowed half of the park's herd die during the 2012 to 2014 drought by keeping them fenced in without adequate water and forage and that the Service then shot 26 elk during 2015 and 2016. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been a welcome success story for restoring native species, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands should not be allowed to dictate wildlife policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife. Native habitat and endangered species come first. This is law.
I also urge you to reject any conversion of national park lands to row crops or for expansion of commercial livestock farming. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
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# 2645
Name: Burke, Kathleen J
Correspondence: I have lived in Marin County for over 20 years. I am also a long-time supporter of the Marin Agricultural Land Trust. I fully support the continuation of sustainable agriculture in the Seashore and GGNRA. I agree with Marin County Supervisor Steve Kinsey, who has said that there is "broad, diverse interest in our county to see that ranching in the park can continue for generations to come, and that the requirements to be able to do so are fair and economically viable for the ranching families whose livelihood depends upon that."
There are economic and environmental benefits to sustainable ranching in the Seashore. Please adopt a pan that continues sustainable agriculture for the benefit of all.
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# 2646
Name: McClelland, Jolynn
Correspondence: R & J McClelland Dairy
Operating on the Historic L Ranch in Point Reyes National Seashore
Robert and Jolynn McClelland and Family
November 11, 2017
Cynthia MacLeod, Acting Superintendent
Point Reyes National Seashore
One Bear Valley Road
Point Reyes Station, CA 94956
Re: Point Reyes National Seashore General Management Plan Amendment
Dear Superintendent MacLeod,
I appreciate the opportunity to comment on the Point Reyes National Seashore (PRNS) and North District of Golden Gate National Recreation Area (GGRNA) General Management Plan (GMP) Amendment environmental review during the current public scoping period. I am a fourth-generation rancher to operate on the lands of the Point Reyes Peninsula. My great-grandparents, JV and Zenia Mendoza, migrated here from the Azores in the early 1900s. They met while living on Point Reyes, were married, and started their families and businesses on the A and B Ranches. My grandparents, Joe and Scotty Mendoza, purchased the L Ranch in the 1950s and ran a dairy farm there until their passing. Since 2011, my husband and I have been milking approximately 150 head of certified organic dairy cattle. We employ three full time employees who reside on the farm along with their families.
Before I begin with some of my thoughts, I would like to bring to your attention my endorsement of the Point Reyes Seashore Ranchers Association (PRSRA) letter that has been submitted for this exercise- -the General Management Plan (GMP) Amendment. I strongly urge you to consider and act upon all of the points raised in that letter. That letter represents the thoughts and needs of the over twenty ranchers within the Seashore and GGNRA that the PRSRA represents-the historic L Ranch being one of those ranches.
Alternatives
Alternatives Required by the Settlement Agreement-no ranching and limited management of Tule Elk, no dairy ranching and management of Drakes Beach Tule Elk herd, reduced ranching and management of the Drakes Beach Tule Elk herd.
I am highly opposed to the alternatives that are listed above. If the said alternatives were carried out it would be to the detriment of the cultural and social landscapes, the economy of the region, and the visitor experience:
How are we going to feed people?
than 2% of the population in the United States are farmers and ranchers. We are a part of an important national, state, county and local infrastructure. The USDA reported that in 2015, 43,584 licensed dairy farms operated in the United States. That is 18% fewer dairy farms in 2015 than in 2010. In California that same year, the number of dairy operations dropped 16% in one year. The trend for decades has been that every year, the United States and California lose dairy farms. According to the U.S. Census Bureau, at the start of 2016, the estimated population of the U.S. was 322,762,018. There had been an addition of more than 2.4 million people to the population that year resulting in an increase of 0.77%. That is just in the United States alone-world wide the population only continues to grow resulting in more people needing to be fed. With an increase in population and decline in farms-how are we going to feed our citizens? The United States has some of the strictest food safety guidelines in the world. We produce safe, affordable food that is readily available to our communities. The more US farms that are closed down, the more we will have to begin to import our food from foreign countries. With doing so we will be subjecting ourselves to sub-par food standards, higher food costs, and environmentally un-friendly means of transport because of the distance from the foreign food source. Our strength as a nation has always been we have been able to feed ourselves. We would be putting our safety and security at risk if we begin to rely on other countries for food.
How does this tie into the PRNS and GGNRA ranchers? These ranchers are a part of a local, state and national food system. The farmers and ranchers within the Seashore are stellar examples of people who have learned to adapt to an ever-changing industry. The local food movement has taken the Marin County Ag industry by storm the past ten years. More and more people want to support local farmers and ranchers. The farmers and ranchers of PRNS are producing high quality organic milk, grass fed, and traditional beef. We are a huge player in producing a local product that people in the North Bay want to have access to.
Special consideration and more exploration on the impacts to the local, state and national food system needs to be looked into when studying the above alternatives.
How do the PRNS and GGNRA ranchers help the economy?
is it devastating for our state to lose even one dairy? Dairies are a vital part of our economy and provide stability in our communities. For every four dairy cows, one job is created. The dairies in the PRNS are not only making milk for consumers, we are providing jobs within our local economy. As I mentioned in my opening paragraph, on the L Ranch alone we provide three stable, full time jobs to our employees. Not only are on farm jobs available, but we also create jobs within the entire community infrastructure. Supply companies, veterinarians, dairy processing plants, distributors, milk truck drivers, feed farmers, retailers, feed supply companies all depend on a thriving dairy industry. Marin and Sonoma Counties have a long-standing tradition of being intertwined agriculturally speaking. There are now roughly 85 dairies left in the two counties. Over time, various support industries have developed in order to serve these dairies. These businesses depend on a stable ranching environment. The farmers and ranchers of PRNS make up roughly 20% of Marin Countys agriculture economy. The loss of even one farm can have a devastating effect on the entire Marin/Sonoma infrastructure. We all depend on each other to stay viable in order to keep these support systems in place. Other business benefit from having farming in their community as well. Restaurants, doctors offices, banks, retail stores all service farmers and the families they employ. Having thriving farms in a rural community like West Marin is crucial to our local economy. A comprehensive analysis of the impacts of closing down or reducing ranching to the economy and agriculture infrastructure needs to made during this process.
How would removing/reducing ranching effect the community?
For generations the historic families of PRNS have played an important role in the West Marin community. We have helped build this community and support the infrastructures and traditions that make Point Reyes unique. We and the families on our ranches are active members of the school, church, and other community organizations. There are 53 students that attend our local Shoreline Unified School District (SUSD) who reside on the PRNS/GGNRA ranches. Closing down/reducing ranching would result in our families and those of our employees having to relocate, most likely out of the area, due to the lack of affordable housing, availability of local dairy farms on the real estate market, and inflated costs of farmland. This would have a substantial impact on the enrollment at SUSD. Losing 53 students would have an impact on not only the students that would have to relocate, but would change the dynamics and culture of the school for the students and staff that remain. Allowing these 24 historic families to continue their operations in a sustainable way is necessary to allow the families to remain in West Marin and continue to support the overall community beyond the Seashore boundaries. We are the backbone of the community; we hold the key to West Marins past and will play an important role in its future.
The impacts of closing/reducing ranching to our local community organizations and especially the impact to Shoreline Unified School District must be analyzed and considered during this process. There are currently 40 students at Inverness School, seven of whom reside in PRNS and GGNRA. 145 students attend West Marin Elementary School in Point Reyes Station where 32 of the students live in PRNS/GGNRA lands. Tomales High School in Tomales educates 144 students, 14 of which are travel from their homes in the PRNS and GGNRA. A full assessment needs to made and considered looking into the impacts losing those students would have on the districts funding, enrollment, class sizes, ability to continue to employ the staff they currently employ, and impact on the programs the schools provide-such as student clubs, sports, and other school activities.
How would these alternatives impact the visitors?
many times a day do you have to milk the cows? much milk does one cow produce? Do brown cows make chocolate milk? These are all questions that are on the minds of the American public. When the PRNS came to be more and more people got into their cars and made the journey to visit the majestic peninsula. As they make their way out to the various points of interest in the Seashore, they have the opportunity to pass by these historic farms and ranches. As expressed in a previous bullet point, a huge portion of the American population is not involved in farming and has not been for generations. A trip out to PRNS not only gives them the chance to see a historic way of life, they also get to see firsthand where their food comes from. They have an opportunity to meet the people who manage these small family farms and get out onto the farm to take in all of the sights, sounds and smells around them. The PRNS has an opportunity to protect this very unique Park by rejecting the alternatives above. There is a huge opportunity to continue to be a place where the public can experience small scale agriculture. As more and more farms go out of business-mainly small-scale family farms, more and more large-scale farms are started every day. The average size of the six organic dairy farms in the PRNS is approximately 200 head of milking cows. There are organic dairy farms opening up across the country that milk upwards of 15,000 cows, not to mention the conventional dairy farms that are also consolidating into the 10s of thousands of cows. The American and International tourists that visit PRNS have the unique opportunity to see another dying niche of the US Agricultural history-small scale, multigenerational farms. During this process, the impacts to the visitor experience and education on the history of Point Reyes need to be looked at if the ranches were to be reduced/removed.
In closing, all of these points need to be thoroughly research and evaluated. The outcome of the analysis needs to be fully considered when making a final recommendation regarding the closing of or reduction in ranching.
Additional Preliminary Conceptual Alternatives under consideration-continued ranching and management of the Drakes Beach Tule Elk herd, continued ranching and removal of the Drakes Beach Tule Elk herd, continue current management (no action).
I commend that PRNS chose to go beyond the alternatives required by the settlement. They have decided to pursue studying alternatives that would allow the historic dairy and beef operations to have equal opportunity to remain open without having to face the challenge of being reduced or removed. While all three of these alternatives allow ranching to continue-they do not do enough to address a huge topic that alone could harm the future of ranching and the cultural heritage on Point Reyes-the Tule Elk in the pastoral zone. These alternatives address varying degrees of managing the Tule Elk, but we ranchers believe there is another alternative that should be considered that would not jeopardize the future of our farms while at the same time offering more clarification for the PRNS so the Tule Elk can be managed in a very clear way.
A seventh proposed alternative-where ranching will continue and removal of all Tule Elk off of the 28,000 acres of the pastoral/planning zone.
The ranchers have worked long and hard on another alternative. This is what we propose should be included and explored during the consideration of this alternative:
Collaboration- -development of guidelines and clarity in decision making authority so that NPS field staff and ranchers can partner and collaborate on agricultural, cultural, and natural resource management decisions in a timely and effective way.
Free-range Tule Elk in Pastoral Areas- -I ask that the GMP Amendment process
study the removal of the free-range elk herd from the pastoral zone. There have been numerous discussions and documentation on the conflicts have risen due to competition over forage, damage to infrastructure and cattle that have happened over the years. It is for these reasons this should be included in the NOI and Draft EIS. It is very important to note that this proposed alternative refers to the free-range elk as Tule Elk, not just the Drakes Beach herd. All elk within the Pastoral Zone need to be addressed and removed off the agricultural grazing lands. A plan needs to be developed to prevent them from returning to the pastoral zone as well. Any rogue Elk that enter the pastoral zone need to be returned in real time in order to prevent a herd developing in the future. This may mean that the scope of this process needs to broaden to look into how to enhance the wilderness area in order to accommodate the elk and become a place where they want to remain.
20-year leases- -the proposed 20-year leases are something that can help ensure the future of our farms and ranches. This would give the historic ranching families, our employees and lenders confidence about our stability and longevity. In turn we would be able to make more improvements knowing our future is sounder. When analyzing the 20-year leases I encourage the following terms to be considered: rolling lease agreements like those used in California for the Williamson Act.
Diversification-being able to diversify is what has kept these multi-generational farms in existence. Over the years they have morphed from growing hay, hogs, row, crops and making on farm products to the practices we see today. Recently, having the opportunity for the dairy farms to transition their herds to organic is what has kept their farms open. The ability for us to diversify on the L Ranch by becoming certified organic allowed us to re-open the dairy in 2011. The conventional herd that my grandparents and Lobaughs had established was sold in 2009 after years of trying to compete on the conventional market with large scale dairies in other areas of California. If we were unable to diversify by becoming organic, we would have never been able to run a dairy farm on L Ranch again-never again would we be providing jobs and food for our community. In todays global economy, it is harder for small family farms to compete. Allowing us to explore different opportunities on our farms will be another way to ensure the future of our cultural heritage. Allowing us to diversify will also help enhance the visitor experience allowing them to see a broader variety of agricultural practices and more on farm experiences. This diversification would happen on a limited scale and on certain locations. Not every farm has the desire to diversify-but lets not limit those who want to explore the possibility. Collaboration with the NPS would occur to identify planted or naturally occurring crops, additional livestock production, farm stands and retail sales, processing and value-added production, and on farm visitor experiences. Again, not every farm will want to take on each and every model. On our particular location, we understand how important it is for human beings to have a connection to their food. The L Ranch would consider hosting educational tours in the future.
Another consideration that would be beneficial to the L Ranch, and other ranches, is the opportunity to grow and store on farm silage and hay. This practice would allow us to have better weed management, balanced herd nutrition and the ability to store excess pasture that grows that we may not be able to graze off quickly enough. Having the ability to do this would result in less wasted forage and also fire prevention. Being able to grow and store our own feed will reduce the need for us to purchase imported supplemental feed.
Operational Flexibility- - We ask that best management guidelines be established that allow for action to be taken, without delay, on:
Low impact and maintenance projects need to happen in real time. There needs to be a way to make the approval process go faster so we can make the proper improvements.
For larger projects either done through NRCS and RCD or by the rancher independently the approval process needs to be streamlined and happen in a timely manner.
The opportunity to develop new agriculture infrastructures such as new barns, feed storage buildings, buildings related to diversification, etc.
As it is now, projects have been delayed and even halted, because there are no guidelines or tools set in place to streamline these requests. This has resulted in impacts to multiple PRNS and GGNRA cultural agricultural infrastructures. Individual ranchers should be allowed to work collaboratively with PRNS and GGNRA staff to develop these guidelines in the GMP Amendment process so there is consensus identified on subjects such as but not limited to: effective management of weeds and fire prevention, water quality, livestock watering and pasture rotation opportunities that all require timely responses and management.
Succession Planning- - Develop a succession plan for each ranch in collaboration with each rancher in order to preserve and protect our cultural and historical integrity. Special consideration during the analysis phase should be given to include strategies that would help secure the continuation of the existing ranches and the ranching families going forward.
Environmental Stewardship and Best Management Practices-There should be opportunities for NPS to collaborate with ranchers to brainstorm and establish ways to streamline the ability to implement best management practices. Having a smother process in place will allow the ranchers to be even more effective in the management of their farms and PRNS and GGNRA resource management goals. Acknowledgement should be given to the six PRNS dairies who all currently participate and comply with the Conditional Waivers to Waste Discharge Requirements and additional regulatory requirements imposed by the San Francisco California Regional Water Quality Control Board. These are the most stringent regulations in the United States for nonpoint sources of pollution from livestock agriculture. The six dairies participation in these programs demonstrates our commitment to honoring the PRNS natural resources.
In order to further comply with these requirements and future identified PRNS best practices, here at L Ranch we would also request the possibility of our building a new loafing barn to be considered. Loafing barns have long been used and proven effective during periods of inclement weather to manage herd health, protect wet pastures, and to better control the flow of manure. In recent years the Park has acknowledged the benefits of dairies having these management structures when they approved the most recent one to be built. We have identified locations with Park staff regarding the placement of said loafing barn-among already existing buildings with in the ranch core. When analyzing the GMP Amendment, we request the study of the possibility of the L Ranch building a new loafing barn and other proposed projects from others to be considered that would support our abilities to be good stewards of the land.
The Point Reyes National Seashore is a unique example of government and ranchers working together to protect the land and continue to produce high quality food for a growing population. During the 1900s more and more families left the farms and countryside to move into the suburbs. We are now meeting people who are three, four, five generations removed from the farm. PRNS can continue to be a place that not only protects the natural landscape, but highlights the cultural and historical landscape as well. PRNS can give visitors the opportunity to experience a way of life that is the backbone of American history and to learn where their food comes from. The PRNS has the opportunity right now through this GMP Amendment process to continue to protect this vital part of American culture-the small family farm- -by considering and fully studying the PRSRA recommended alternative.
Sincerely,
Jolynn McClelland, L Ranch
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# 2647
Name: MAY, ELIZABETH
Correspondence: I support cattle grazing and management of the elk herds in the Pt. Reyes area. Please do not alter the historic lease agreements. Thank you.
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# 2648
Name: Cardwell, Jackie H
Correspondence: I support the option that is entitled:"Continued Ranching and Removal of the
Drakes Beach Tule Elk Herd." Ranching is very important to California, and it is a part of the cultural landscape of the park, and this community; without which, we would all be the poorer. It is difficult to operate a business with cattle without elk intruding. If elk were not destructive, and only grazing, I would go for the lesser alternative of managing them, but they are destructive, and so this seems the most practical option.
I personally support all that lies within this option, except that I would like to see leases increased in number of years, and extended to more than direct family, in the way a trustee could be assigned, as long as it was a family, preferably of local lineage and not a corporation or corporate affiliated. I would also like to state a preference that the elk management/removal, be non lethal.
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# 2649
Name: ives, susan
Correspondence: Thank you for the opportunity to provide input into the alternatives for the Point Reyes Seashore GMP Update. My comments apply to the proposed alternatives, which I believe need to be further clarified. I also submit an additional alternative that I believe needs to be among those offered for public consideration this planning process.
I have lived in Marin County for 40 years and have worked and volunteered for the National Park Service. As a birder, photographer, hiker, and kayaker, I frequently visit PRNS to enjoy the unique natural beauty and wildlife of the National Seashore.
National parks are among the few remaining havens for wildlife, and I, like millions of park visitors, go to the Seashore hoping to see wild animals in a place that, by law, is dedicated to their preservation and wellbeing.
While I understand that ranching historically has played a role at Point Reyes, as it currently exists, ranching is at variance with the expressed mission of the National Park Service and the purposes for which Point Reyes National Seashore was established.
I have visited dozens of national parks throughout the country. I've never seen a national park landscape so visibly degraded.
It saddens me to see the park’s rolling grasslands trampled and grazed to dirt by domestic cattle herds; junked cars along park roads; dairy cows standing in deep mud and manure; ranch workers living in substandard housing, and industrial-sized buildings erected without public comment for the sake oft so-called "family ranching."
The GMP scoping documents reveal a persistent bias of the NPS at Point Reyes National Seashore for private ranching over the preservation of the public’s right to recreation, and unimpaired scenery, wildlife and natural resources-the founding purposes of the NPS.
Five of the six alternatives in the initial scoping document for the GMP include ranching in some form.
• None of the continued ranching alternatives makes any mention of the climate crisis, even though domestic cattle are the major source of greenhouse gas emissions at the Seashore.
• Seashore ranches place many demands on limited park personnel and budgets. None of the alternatives reveal the actual costs to the public, though public funds are used to pay for staff, roads and other park infrastructure that serves ranchlands to which the public is denied access.
• None of the scoping materials currently online or distributed at two recent public meetings explains opaque terms that the public is unlikely to be familiar with, such as “diversification and operational flexibility,” which is applicable in four of the six scoping alternatives.
One wonder is this might be because the NPS doesn’t want the public to understand that this would bring intensive crop farming and the addition of livestock heretofore not permitted in the park-activities that many park users likely would find objectionable.
In fact there are no public benefits discussed in any of the continued ranching alternatives nor in any of the NPS the scoping materials.
To enable the public to make informed comments to the scoping process, I’m requesting that the NPS address these serious omissions, to include:
• Define and explain in lay language any terms the public is not likely to be familiar with, such as “diversification and operational flexibility.”
• Several maps were missing from the document circulated at the scoping hearings. Please include maps for each alternative.
• Under “No Change” alternative, include the currently known conditions of the land, water and wildlife based on available data.
• Explain the economic implications of each of the proposed alternatives.
• Disclose the National Seashore budget allocations for staff, infrastructure, and maintenance related to both ranching and visitor services; and all income to the Seashore, including grazing fees and any rental income paid by ranchers.
I submit the following additional alternative for inclusion in the GMP Update scoping process:
ALTERNATIVE: No Ranching-and the active restoration of the Seashore’s natural resources including land, native wildlife, and waterways, yo include:
• Reallocate NPS resources from ranching to active restorative management.
• Remove ranch infrastructure that is non-historic.
• Remove where possible, and replace where necessary, fencing in order to allow safe passage for wildlife.
• Provide maximum protection for native wildlife throughout the National Seashore.
• Provide maximum access to parklands for public recreation and education.
• Establish a demonstration ranch for research and testing methods to restore native grasslands and wildlife, and carbon farming.
• Provide interpretation for park visitors of “historic” ranching practices compared with with 21st century ranching practices.
• Provide interpretation of climate change impacts on the Seashore and how they are being addressed.
• Make improvements to visitor services, including visitor center, interpretative displays, trails, campgrounds, bathrooms, restaurants, and lodging.
Sincerely,
Susan Ives
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# 2650
Name: N/A, N/A
Correspondence: Last month, with a few friends, I spent the day photographing the various animals we found. At the end of the day, we tallied a list and identified 38 different animals. All of these would be at risk if the National Park proceeds with any of the plans outlined.
Public land inside Point Reyes National Seashore should not be converted to NEW land uses that jeopardize wildlife and public access. Any additional uses will jeopardize the fragile landscape that is already showing signs of over grazing and create more conflicts between the free-roaming animals. Expansion of the existing cattle operations will similarly impact the native species.
And the existing Tule elk populations should not be slaughtered to control their population or otherwise removed from any ranching areas to allow cattle sole access to the public land.
Thank you.
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# 2651
Name: Lyman, Eleanor
Correspondence: Regarding the future of the Park I totally support allowing for INDEFINITE leases, operational flexibility and diversification on ranches, along with increased elk management of numbers to protect the grazing cattle and agriculture in the pastoral zone.
Working together so that both the public recreation and the publics enjoyment of the fruits of the ranches labors is the way to go. It doesn't have to be either or it can be BOTH!
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# 2652
Name: Gordon, Rick
Correspondence: Regarding the future of the Park, I want to assure that support for agriculture within the Park continues for the life of the Park.
I support allowing for LIFETIME LEASES (as before) for the ranches, along with increased elk management of numbers to protect the grazing cattle and agriculture in the pastoral zone.
Working together so that both the public recreation and the public's enjoyment of the fruits of the ranches' labors is the way to go. It doesn't have to be either or it can be BOTH!
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# 2653
Name: Mellano, Michael A
Correspondence: Cynthia MacLeod, Acting Superintendent
Point Reyes National Seashore
National Park Service
1 Bear Valley Road
Point Reyes Station, CA 94956
RE: General Management Plan Amendment for Point Reyes National Seashore
Dear Ms. MacLeod:
I am writing to provide input on the General Management Plan Amendment for Point Reyes National Seashore (PRNS). I support the continued operation of beef and dairy ranching operations under agricultural lease/permits with 20-year terms and improved management of the Tule elk herds to eliminate negative impacts on the environment and ranching families.
Ranchers have been raising cattle in Point Reyes for more than 150-years. It was ranchers' willingness to sell their properties to the federal government that allowed the creation of the PRNS. As part of the agreement, ranchers were supposed to be allowed to continue ranching on their family ranches within the PRNS.
The ranches in West Marin contribute significantly to the local economy and the local culture. According to any analysis by U.C. Cooperative Extension in 2009, ranches in PRNS and Golden Gate National Recreation Area (GGNRA) directly provide approximately 65 jobs and provide livelihoods for an additional 25 ranch family members. Additionally, agriculture in PRNS and GGNRA account for 17 percent of the agricultural income in Marin County. These jobs and income would be lost if further restrictions were placed on ranches within PRNS. These ranches are not just creating economic value, they are producing high quality food appreciated by consumers locally, regionally, and nationally. Further, providing 20-year terms for lease/permits allows for greater investment in improvements on these ranches. Shorter terms prevent the ability of ranchers to obtain financing for improvements.
would also like to see improved management of the PRNS elk herds. Elk cause thousands of dollars of damages and lost forage on ranches. Additionally, the elk carry Johne’s disease, which can be transmitted to cattle. USDA estimates that lost productivity from Johne’s disease in dairy cattle could be costing dairy producers between $200 and $250 million annually. Elk in the PRNS were reintroduced by humans and have been managed since their reintroduction. PRNS must improve its management by maintaining the roaming elk herds on the Limantour wilderness and preventing them from damaging ranches in the area. Additionally, PRNS should ensure that there is proper forage and water available to the herd in the Limantour wilderness to prevent a reoccurrence of the unfortunate loss of elk during the drought.
Ranches on PRNS provide important economic, cultural, and ecological values to the local community. Losing a significant portion of West Marin’s agricultural community would mean not only a loss of local food production, but a significant loss to its economy and culture. I urge you to offer 20-year lease/permits to ranchers on PRNS and to improve elk management and return the elk to the wilderness areas where they will not impact the ranches.
Sincerely,
Michael A. Mellano
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# 2654
Name: Ross, Pamela M
Correspondence: Subject: First Phase Comments for the Point Reyes National Seashore General Management Plan Amendment
Dear Acting Superintendent MacLeod,
We are responding to this first phase of the General Management Plan Amendment planning process. Thank you for this opportunity. We have lived in Inverness Park since 2003 and have been members of PRNSA and volunteers in the Park since then.
WE SUPPORT THE CONTINUANCE OF RANCHING AND DAIRY OPERATIONS IN PRNS
We believe that ranching and dairy farming should continue in the Park, as originally authorized. This is the best and only way to ensure the continuation of the benefits of vital agricultural production to the community, the local economy, and visitor education and experience.
Three of the alternatives presented propose no- or reduced-ranching options. We are concerned, that among other problems, removing the agricultural management that the ranchers now provide would result in an increase in invasive plants like thistle, broom, and eucalyptus - problems that will erupt without the Parks ability to control them. These lands would also become a nursery for weeds and would require significant management demands on the Park. Facing already tight budgets and understanding that a proposed 13% Park budget cut is anticipated, how would the Park pay for the necessary increased management? We ask that a thorough environmental and cost analysis be done to show how much it would cost the Park to manage these lands. We personally have worked as volunteers in invasive plant removal and in native plant seed collection and propagation, and are all too aware that the Park is already struggling to manage its existing invasive weed problems.
Most of the land currently leased for dairy and ranching is not suitable for recreational use and would be underutilized if those operations were to cease. The visitor experience is enhanced rather than diminished by these traditional uses of the land.
WE ARE CONCERNED ABOUT THE ECONOMIC AND COMMUNITY IMPACT OF THE PROPOSED ALTERNATIVES
Agriculture in the Park represents $18.3MM (19%) of Marins total $96.5MM gross production value (according to the 2016 Marin County Crop Report). The no- or reduced-ranching alternatives need to consider not just the loss of this huge economic value, but must also undertake a thorough economic analysis of the rolling cultural and economic impacts that removal of ranches would have on the community and across Marin. Shuttering the ranches would displace ranch families and would inevitably lead to the shutting of at least some local schools, leaving the remaining kids without a nearby option for public education - along with displacing teachers. The disappearance of on- and off-farm jobs, lack of local affordable housing and school closures need to be evaluated in the next phase EIS. The dairy industry of Marin County requires a critical mass number of ranches and would likely disappear from the whole county if dairy ranching is not encouraged in PRNS.
WE SUPPORT THE CONTINUED EXISTENCE OF THE ELK PRESERVE AT PIERCE POINT, BUT "MANAGEMENT" OF THE OTHER HERDS IS A DIFFICULT PROSPECT
While we dont dispute the historic value of tule elk in the PRNS, three of the alternatives propose either management of the Drakes Beach herd or removal of the herd. A thorough economic and environmental analysis needs to be done to understand, under the management alternatives, where the herd would be moved to to avoid the current and historical conflicts with ranches , and how the Park would pay for the significant costs of management or removal. Although the management of the Pierce Point herd is not on the table in this phase of the Plan, it is clear that culling will be necessary to maintain a healthy herd there, regardless of what is done with the descendants of the elk that PRNS moved out of the preserve.
CONCLUSION
We are great supporters of our national seashore. We also support our local ranchers and the benefits they bring to our communities. We hope that through this General Amendment Process, NPS will find a balance that integrates the benefits of our dairies and ranches and the families that support them with the natural resources and values of our national seashore.
Sincerely,
Pamela M. Ross
Charles W. Gay
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# 2655
Name: Stahnke, Wendy
Please keep agriculture in point Reyes national park. . It's vital to the health of the park, and our county.
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# 2656
Name: Augustine, Leah D
Correspondence: I support all the ranches in the point raise national seashore. Because, without them we would have no food or dairy products. We need these products to keep us healthy and fed. These ranchers have been serving us and doing these jobs for hundreds of years. and because of that are hard work we have fresh milk on our tables. They know what's best for their animals in taking good care of them, and work hard at keeping their pastors up and free of debris. I would hope to see them all continue ranching and to receive 20 year leases . Also remove all elk off of all ranches in the drakes beach area to preserve ranching history and placed also back in wilderness care. thank you ,
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# 2657
Name: N/A, James
Correspondence: I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn’t harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service’s amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
James
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# 2658
Name: N/A, N/A
Correspondence: As an individual raised in Inverness, California, I believe that the strongest alternative is the "Continued Ranching and Management of the Drakes Beach Tule Elk Herd (NPS Initial Proposal)".
Our community, and the landscape in which it exists, is fundamentally one that incorporates cattle and dairy ranching; environmental and wildlife protection, conservation and management; and tourism. This is a working landscape, and it should remain one, even as we work to protect and manage wildlife in the area. Barring that alternative, I believe that the next best path forward is "Continue Current Management (No Action)".
Thank you for your consideration of my comments.
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# 2659
Name: Elliott, Ann L
Correspondence: Additional or Modifications to Conceptual Alternatives:
• Modify current livestock management practices to enhance native biodiversity of wildlife and plant species and their associated plant communities. Look at models of other working landscapes, e.g. Zumwalt Prairie Preserve in northeastern Oregon, Consumnes River Preserve in southern Sacramento County, Dye Creek Preserve in Tehama County; all managed by The Nature Conservancy.
• Compensate ranchers for the adverse economic effects of practices that enhance native biodiversity. For example, ranches negatively impacted by Tule Elk could pay reduced rent to cover loss of forage and water or be reimbursed for maintenance of fencing and the occasional cow affected by Johne's disease.
• Modify the Reduced Ranching alternative. Instead of the lands currently identified for removal of livestock, consider removing lands from livestock that are most impacted by Tule Elk now and in the future.
All Conceptual Alternatives should consider the following:
The Pastoral Zone is public land, so ranching practices should be required to meet the highest standards:
• Agricultural operations of any type on Park Service land should use the latest techniques, not necessarily to enhance agricultural production but to integrate agricultural practices that enhance soil, water, and air quality; wildlife; native and rare plants; and associated plant communities.
• Some pastures are currently over grazed. They have low native plant diversity, inadequate residual dry matter, and evidence of rill and gully erosion. Consider lowering allowed stocking rates on these lands.
• Stop vegetation type conversion for pasture and silage production. Related issues include threat to native biodiversity, probable impacts on ground-nesting birds, increased raven populations with associated predation on Snowy Plover chicks, and an unsightly landscape much of the year.
• Restore areas converted from coastal prairie and coastal scrub using an adapted resource management approach.
• Sacrifice areas on current dairy operations lack the aesthetics of a National Recreation Area. They appear less pleasing than some dairies of inland Marin and Sonoma Counties. Consider requiring fencing to hide calf pens, feedlots, and miscellaneous equipment (as marijuana grows are fenced in other counties). Consider moving those unsightly operations away from public roads.
Ranch Operators
• Ranch operators (existing or new permit holders) should embrace the honor and the challenge of operating in a National Seashore / Recreation Area. Improvement of the natural resources, enhancement of visitor experiences, and cooperatively working with public agencies should be included in their operational goals.
• Develop incentives (grants, reduced rent, and permission for infrastructure development) for ranchers to cooperate with the Park Service and actively enhance natural systems on the land they lease.
Tule Elk Management
• Removal or control of the Drakes Beach Tule Elk Herd is a key component of most of the identified conceptual alternatives. Recognize that control of herd size or removal of the herd would be an ongoing and costly management task for the Park Service.
• Consider retiring the areas most used by Tule Elk from ranching or reducing the stocking rates of cattle.
• Consider recreational hunting to control the Tule Elk population throughout the Seashore.
• Consider allowing herds to expand naturally and compensating ranchers for the Tule Elk’s adverse economic effects.
Infrastructure Maintenance
• Maintenance of ranch infrastructure should be proactive, scheduled, and timely.
• Improve cooperation and communication between Park Service and lessees.
Visitor Experiences
• Plan and fund better maintenance of roads and trails used by visitors.
• Create more trails through the pastoral zone (e.g. link Muddy Hollow Road to Drake’s Estero trailhead through Home Ranch, to Drake’s Estero through D and E Ranches, Vision Road to Drake’s Estero, Sir Francis Drake to historic lifeboat station (between B and C Ranches), more loops connecting the Bolinas Ridge Trail and Highway 1. )
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# 2660
Name: Spaletta, James L
Correspondence: Point Reyes National Seashore
GMP Amendment
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes Station, CA 94956
Cynthia Macleod and Cicely A. Muldoon and To Whom It May Concern,
We support : Continued Ranching, and Removal of the Drakes Beach Tule Elk Herd
We support Continued Ranching of all ranching practices, beef & dairy in the PRNS and GGNRA with 20 year- Lease /Permits. We wish for renewable lease/permits if possible to support the historical cultural and natural resources that ranchers have been caring for well over 100 years.
These Ranches and dairies account for nearly 20% of agriculture production in Marin County. If ranches were to shut down or be reduced, a large portion of agriculture products from this area would be gone forever. These ranches contribute to the sustainability of West Marin's economic viability and farther. People want a local product and want to see where it comes from.
We would like to see if Tule elk can also be removed in the Limantour-Estero road area for those ranchers as well? If this was added to this alternative, it would give all ranches relief from elk conflicts. The elk that are out of their 18,000 acres of designated wilderness according to the 1998 Elk Management Plan need to be placed back. These elk traveled out of the wilderness and now have established several "Sub-herds" on rancher's rented pastures. This action was not to happen according to the 1998 Elk Plan. The impacts that elk are causing on ranches is very costly. Damage that the elk have done for years is increasing as the elk population continues to expand. Ranchers have given the National Park Service many detailed costly damages that the elk have incurred within the Pastoral Zone. We ask that all elk be taken off the ranches and be placed in a wilderness area safely and managed.
Thank you,
Spaletta Families
Point Reyes and Valley Ford
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# 2661
Name: Clysdale, Matthew
Correspondence: Greetings,
I'm a big fan of the National Park Service. It's one of America's greatest inventions and institutions. I've been to numerous parks, including Sleeping Bear Dunes, Yellowstone, Isle Royale, Denali, Olympic, Point Reyes and many more. I loved my time at each and every one of them, but if I were to rate them, my one experience at Point Reyes was by far the worst. It stands as the only National Park to allow active, continued commercial operations, agricultural no less. The biggest negative impact for me personally was expecting a wild, open space and instead encountering a maze of fences and public/private barriers. It was bizarre. Sleeping Bear Dunes (in my home state) has historic farms, but they're no longer in use and park visitors have complete access to the surrounding grounds and landscape. It's unlikely that I'll return to Point Reyes. I also discourage others for the reasons mentioned above. It's a shame, because it has features and virtues found virtually no where else in the park system. One of those distinctions is the strong likelihood of spotting a bobcat.
I can't even believe it was allowed to reach this point. My understanding (correct me if I'm wrong) is that the only reason the park has these commercial ranching operations is because Park management capitulated to pressures from ranchers and politicians to extend the leases. Otherwise, the original plan was to phase out these operations in the same manner all other National parks have and continue to do.
It's for these reasons I highly encourage the "No Ranching and Limited Management of Tule Elk" alternative. Establishing models for successful, sustainable, mix-use land management should be reserved for other government properties, NOT national parks.
Thank you for your time and consideration.
I trust you'll make the right decision.
Matt Clysdale
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# 2662
Name: Longstreth, Carolyn K
Correspondence: Introduction.
The following comments are submitted on behalf of the Marin Chapter of the California Native Plant Society (Marin CNPS) regarding Phase 1 of the General Management Plan Amendment process (GMPA). The California Native Plant Society is an organization of nearly 10,000 members statewide dedicated to conserving native plants and their natural habitats and to increasing the understanding, appreciation, and horticultural use of native plants. Marin CNPS has 350 members.
Marin CNPS would first like to thank the Point Reyes National Seashore (PRNS) for providing this opportunity to step back and consider larger questions about ranching and its role in the Seashore. When the Park was founded over fifty years ago, there was excitement and optimism about a unique partnership between ranchers, who sought to remain in business and in their long-time homes, and conservationists, who sought protection for the unique natural resources at Point Reyes, consistent with that which occurs in other national parks.
We hope that the General Management Plan Amendment process will provide a thorough and forthright assessment of how the arrangement is or is not working in terms of natural resource protection. While current practices result in adequate protection of native plants and plant communities in many instances, in others, there is room for improvement. For example, according to local native plant expert Doreen Smith, the spraying of manure slurry on pastures has contributed to the conversion of native grassland to pastures of non-native weedy annuals. It is our hope that the GMPA planning process will help pinpoint all problematic situations and set forth a realistic plan for improvement going forward.
the outset, Marin CNPS offers its vision for the GMPA planning area (approximately half of the total acreage shown on Page 3 of the NPS Brochure that describes the GMPA process): If ranching is to continue at PRNS, Marin CNPS would like to see it managed in a more proactive way to promote the protection and restoration of native vegetation and rare plants. Rather than relegating healthy plant communities to the natural areas outside the pastoral zone, we hope that all areas of the Seashore can achieve thriving plant communities, including rarities, with the careful institution of improved practices, buffers, restoration efforts and, where necessary, adjustments to the number of grazing animals. Such modifications would not only enhance recreational birding, botanizing and hiking for nature lovers like ourselves but also sustain the diverse native wildlife and plant species, as required by National Park Service mandates.
Other California land managers have grappled with the balance between agriculture, public access and natural resource protection and there are successful models to be emulated at such places as Tejon Ranch, Rush Ranch and various Nature Conservancy properties.
As you undertake this important project, it is also well to remember that these are public lands, dedicated by Congress "for purposes of public recreation, benefit, and inspiration, ...." and are to be preserved in their natural setting. Brochure at 2. For its part, the GMP process also emphasizes natural resource protection as a primary focus. Brochure at 4.
The Environmental Impact Statement
Marin CNPS offers the following general observations about the forthcoming EIS:
• Based on its experience with Program EIRs under CEQA, Marin CNPS urges PRNS staff to make this Program EIS as detailed as possible; doing so will help assure that later-tiered actions go smoothly. Significant environmental impacts should be identified early on and mitigation and monitoring measures defined. We are hoping for a robust dialog on all adverse impacts currently occurring and how they can be avoided or mitigated.
• In our view, a one-size-fits -all approach would be ill-suited to the PRNS ranches, given the wide range of plant communities that underlie the various ranches, specifically coastal bluffs, coastal prairie, coastal scrub, “paleodunes” and native bunchgrass stands.
• The question of ranch succession is not mentioned in the Brochure other than to say that any ranch to be discontinued will be phased out in five years. Nuanced approaches to succession, however, may offer less disruptive alternatives, such as a mechanism for PRNS to reabsorb any ranch when the current ranching family lacks a member that is willing and able to continue. Different mechanisms could perhaps be incorporated into the various alternatives.
• In the past, advocates for agriculture in the Seashore have asserted that the reduction or elimination of ranching in the Park would have adverse economic impacts on ranching elsewhere in Marin County. If feasible, the EIS should analyze this point.
Marin CNPS also requests that the EIS address, clarify and elaborate on the following points:
• The process for compiling a detailed inventory of rare plant populations and native plant communities in the GMPA planning area.
• What would be the nature of “not-for-profit education, research, outdoor experiential activities” that could potentially take place on ranches that are closed? Brochure at 4.
• What is the nature of the diversification of agricultural production that could occur on the ranches?
• What management actions will be taken on any ranches to be closed and in the “resource protection buffers”? Specify what resources would be protected by such buffers and how. Effective control of non-native invasive plants in these areas is of paramount concern to CNPS; without it, native plant communities will be unable to reestablish themselves.
• What areas can/should be restored to native plant communities and how might such restoration be accomplished?
• Concerning grazing on the ranches, Marin CNPS hopes the EIS will separately analyze the grazing impacts of cows versus elk.
- - Essential to an informed choice among the alternatives is an analysis of the forage preferences of each species and how their grazing styles differ, if at all. This should assess competition for forage between cattle and elk and the effect of grazing on plant species composition. For example, what would be the effect of removing cattle from the Bull Point area on the unusual native plants that grow there? What would be the effect on native coyote brush, on the one hand, or on non-native velvet grass and other weeds on the other?
- - Similarly, what would be the effect on native plants and vegetation of replacing the cows with elk?
- - If cows were to be removed and elk left largely unmanaged, would the PRNS attempt to prevent the latter from expanding over Inverness Ridge into the residential areas and if so, what measures would be taken?
• How will the carrying capacity for cattle and/or elk be determined and how will this determination take into account the goal of protecting rare plants and plant communities?
• How will the various alternatives address adverse water quality impacts of cattle and elk?
CNPS looks forward to reviewing the forthcoming EIS with all of these points in mind and to our continued participation in this exciting endeavor.
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# 2663
Name: Patton, James J
Correspondence: Dear Superintendent,
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
James and Tammy Patton
___________________________
# 2664
Name: N/A, N/A
Correspondence: As a former California resident, I support the free-roaming Tule Elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule Elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. These business interests already get sweetheart deals for grazing and other fees. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn’t harm habitat for endangered species. America and its parks are for everyone, including coexisting with wildlife. Our parks are not the property of big business!
Likewise, I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality. Ultimately, the predators that have been in the area for many years would be blamed for conflicts with the newly introduced livestock animals, and the predators would then be unfairly hunted and killed to extinction.
The Park Service’s amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
___________________________
# 2665
Name: Maurice, Vaughn
Correspondence: November 14, 2017
Cynthia MacLeod, Acting Superintendent
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes Station, CA 94956
RE: Comments on General Management Plan for Point Reyes National Seashore
Dear Superintendent MacLeod,
WildCare is a nonprofit organization located in Marin County. Our programs include a licensed wildlife hospital, environmental education, advocacy and humane nonlethal wildlife conflict resolution. Our programs and services extend to all nine Bay Area counties. Every year we treat nearly 4,000 wild animals of more than 200 species in our wildlife hospital, and educate more than 50,000 children and adults through our environmental education programs.
On behalf of WildCares 20,000 members and supporters, I am writing to provide comment on the General Management Plan (GMP) for the Point Reyes National Seashore (PRNS).
PRNS is currently home to badgers, bobcats, coyotes, burrowing owls and other predators. Tule Elk, songbirds and ground-nesting birds, gophers, snakes, insects and many other animals also call PRNS home. These public lands are hunting and feeding grounds for hawks, falcons, Barn Owls, Great Horned Owls, Great Blue Herons, egrets, Western Bluebirds, warblers and many other species of wildlife. The Park Service's amendment to the General Management Plan should prioritize protecting these natural resources of PRNS.
Any cattle-ranching and other agricultural operations must be managed to accommodate elk and other native wildlife, and should not harm wildlife habitat. We are opposed to the removal of any Tule Elk from PRNS. Commercial lease holders on our public lands should not dictate wildlife removal or exclusion policies.
We urge you to reject any conversion of National Park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. Any conversion of these public lands to agriculture will increase conflicts with wildlife, and degrade wildlife habitat and water quality.
We appreciate the opportunity to provide our comments on the General Management Plan and encourage the National Park Service to protect and preserve wildlife, including the free-roaming population of Tule Elk, as well as to have the insight to implement a humane, long-term and sustainable plan to mitigate any conflicts with wildlife, including the growing population of Tule Elk-wherever they may roam.
Sincerely,
Vaughn Maurice
Executive Director
WildCare
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# 2666
Name: Carlton, Alan
Correspondence: SIERRA CLUB COMMENT ON PT. REYES NATIONAL SEASHORE GENERAL MANAGEMENT PLAN AMENDMENT
"CONCEPTUAL RANGE OF PRELIMINARY DRAFT ALTERNATIVES"
The Sierra Club requests that the National Park Service analyze a new alternative as part of its current effort to “refine concept range of alternatives and initial proposal” and to “gather necessary information to meaningfully evaluate the impacts of the concept alternatives.” The proposed alternative - Alternative R - calls for Regenerative Livestock Management coupled with rigorous and improved monitoring, management, and enforcement by the National Park Service staff.
Here are a some of the elements that should be core elements of Alternative R:
1) All leased lands should be managed so that the range condition, where less than desirable, is improving. Range condition should be reassessed every 5 years and if range condition is not improving, lease management terms should be adjusted to protect the park. No leased lands should be allowed to remain in poor condition. Residual dry matter standards should be enforced and grazing limited where they are violated.
2) All park lands should be managed primarily for the benefit of park wildlife and native plants. Tule elk should be managed to levels to protect the herd and the range, but should not be fenced out of large portions of the seashore to provide more forage for livestock. Endangered species should be regularly monitored to ensure they are not being impacted. The “wildlife protection provision” that is in each ranching lease must be complied with by each lease holder and must be enforced by NPS.
3) There should be no conversion of ranching and dairying rangeland to cropland for artichokes or other produce, other commercial livestock, vineyards. or other inappropriate proposals. Cropping on seashore lands will reduce the rangelands available to wildlife and only lead to additional erosion, conflicts with wildlife, and an expansion of agricultural conversion of the natural landscape. Any diversification should be limited to the ranch core.
4)Livestock grazing and manure spreading should be done in a manner that builds the soil carbon content and topsoil. Soil carbon sequestration and restorative agriculture programs should be for the sole purpose to protect and enhance park natural values, not for the purpose of increasing livestock, and should be implemented in the pastoral zone to help solve our climate change crisis.
5) Alternatives to manure spreading, which presents adverse impacts (including visual and health impacts) to the park, wildlife, and public, should be investigated and, if feasible, then required. Manure spreading and storage should not take place in any location where it is likely to contaminate surface waters. Also manure spreading should not take place in any location frequented by Tule elk, to reduce the risk of spreading disease. Yearly water testing in all streams or ponds for nutrients and pathogens should be conducted and reported by NPS to assure the public that aquatic and terrestrial wildlife and habitats are not at risk.
6) Ranch operations are on public land and, except for "core" ranch areas, the public should have access to the leased land for recreation.
7) If an original leaseholder and the heirs to that family choose to no longer continue ranching, the lease should be terminated and the land managed to restore grassland biodiversity. Expired leases should not be transferred to other leaseholders, new leaseholders, or some other defacto privatization scheme.
8) It is unavoidable to have heavily used land in close proximity to dairy barns. But all other parts of each lease holding, both dairy and beef operations, should be managed to avoid overgrazing, severe trampling, erosion, topsoil loss, and adverse impacts to scenic values and resources. Grazing should be rotated periodically to allow rest and restoration of leased lands. All ranching activities should be managed in a way that minimizes impacts to the Park.
9) If there is degradation to surface water and riparian zones due to livestock grazing, permit conditions should require those lands be fenced to protect the aquatic and riparian habitats and water quality. All livestock fencing shall be converted, within a reasonable period of time not to exceed three years, to “wildlife friendly” fencing.
10) If planting and harvesting grass for silage is allowed, it should be done so as to protect bird and wildlife habitat. No mowing should be permitted during nesting season.
11) A grazing advisory board including representatives of local and national conservation groups, ranchers, and scientists should be established to regularly review progress in implementing the conditions found within this Regenerative Ranching option, and to recommend any changes needed to better protect the Park.
___________________________
# 2667
Name: Cediel, Bonnie
Correspondence: It is always a joy to see native elk at Point Reyes. It is a reminder that we haven't yet destroyed everything good on the planet!
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# 2668
Name: Redmond, Richard A
Correspondence: I support a GMP that provides for continuing sustainable agriculture in the Point Reyes National Seashore and the GGNRA. I am a frequent - almost weekly - visitor to the PRNS, and I find no conflict between the ranching operations and the utility and enjoyment of the vast and beautiful public lands in West Marin. The ranches in PRNS are models for local, sustainable food production. Their presence enhances the lives of many different communities, including agricultural workers, environmentally conscious consumers of organic milk, grass-fed beef, and organic cheese, and everyone involved in the chain that brings those foods to market. There are also a host of environmental benefits to sustainable ranching on these lands. I am hopeful that the plan that emerges from these discussions continues to support agricultural use in a way that gives security to the ranchers through longer-term leases while maintaining constructive oversight of their operations.
___________________________
# 2669
Name: Gower, Kathryn A
Correspondence: Please consider the alternative that continues ranching and management of the drakes beach tule Elk herd
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# 2670
Name: Royce, Tammy
Correspondence: I write in support of the Tule elk herds at Point Reyes National Seashore. They are an important part of the landscape of Point Reyes, a native species that supports the ecosystem. Those elks are coming back from the brink of extinction, a success story that aligns with the mission of the Parks Service.
I do not support having commercial lease holders on our public lands dictate wildlife removal or exclusion policies. Any and all cattle-ranching or farming operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
I also urge you to reject any conversion of national park lands that would create conflicts with predators and degrade wildlife habitat and water quality.
Thank you, Tammy
___________________________
# 2671
Name: N/A, N/A
Correspondence: The Point Reyes National Seashore (PRNS) was created in 1962 by the agreement with existing ranchers that their family operations would be able to continue within the park boundaries. The ranches in Point Reyes have been in place for over 150 years, but are currently at risk of significant restrictions being placed on their operations.
Please leave the agreement in place it would be best for all parties.
To not back such agreements, without continuous serious violation being performed by those that are a part of the agreement, would be detrimental to the trust placed in the National Park Service with whom the original agreement was made; can folks who enter into an agreement with the Park Service trust they will keep such agreements; and can the public who place their trust in the Park Service, trust them to make such agreements or do changes need to be made that call for public vote for such said agreements.
Leave the agreements in place without proof of serious violation to original agreement by Ranchers; it seems things have worked pretty well for the last 150 years. I know things can change but it does not seem it is required at this time or in the near future for the original agreement ,with adjustments to prevent great disaster to both parties having been made, to be messed with; a man's or organization's "Word" defines the Man or the organization.
Was there agreement? Then both parties need to abide by it and if and when necessary be willing to work out a new agreement that can and will benefit both parties; one party should not force a change just because they have the power to do so or are themselves being strong armed.
The groups that sued should be required to make compensation to both the National Park Service and the Ranchers for loss of time, finances and legal fees and necessary changes needed if they believe they are need that much and are going to such great lengths to see they are made. Such groups can be a tremendous help and protectors of our world at times or just a pain to those who try to work together keep the environment, economy and things in general running smooth.
Thanks for letting me rant and give my thoughts on the matter.
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# 2672
Name: Aramayo, Robert
Correspondence: Park Service,
Please consider this opinion with regard to the planning process for the General Management Plan Amendment for Point Reyes National Seashore and the north district of Golden Gate National Recreation Area.
I have been fortunate to enjoy the Point Reyes National Seashore many times each year, and recognize this park as one of the natural jewels of the San Francisco region. Professionally, I am an ecologist, and value the natural history of the park.
I admit to being somewhat confused as to the legal basis for the ranch inholdings within the park. I believe that they were allowed for a period of time under the management rules developed at the time of park establishment. That said, I was always under the impression that the ranches were allowed to continue for a finite period of time. Those initial / existing contracts should be honored, but not extended.
As clearly spelled out in the legislation authorizing the park, the NPS's management directive is to "preserve the recreation area, as far as possible, in its natural setting, and protect it from development and uses which would destroy the scenic beauty and natural character of the area"(Public law 920589, 16, USC 460bb). It is important that the NPS manage the park with this directive as a guiding principal in all decisions.
Through the years, I have noticed that the ranch lands show signs of heavy grazing, most notably in terms of erosion. This is not consistent with the park mandate. There are currently too many cattle for the space.
Several of the management alternative under discussion call for 'managing’ the elk herd to be more compatible with the overall grazing impacts to the land. This is backwards. The cattle should be managed to be compatible with the native wildlife. Remember the mandate for managing the park.
Dairy vs. Grazing. As I indicated above, I believe that the current agreements regarding the ranching need to be honored, but not expanded. Within that, I do not see any advantages to promote one version of ranching over another (with respect to the current cattle ranching). However, I have also heard that some alternatives under consideration include the expansion of ranching/agricultural activities within the park. I am firmly opposed to the expansion of any agricultural activities within the park. Continuing or expanding the agricultural leases within the park is inconsistent with the NPS’s mandate to ‘protect it from development and uses which would destroy the scenic beauty.’
___________________________
# 2673
Name: DeSante, David F
Correspondence: Many are now becoming aware that all beef and dairy operations are unsustainable and contribute greatly to climate change. Indeed, the Climate Diet Team of 350Marin.org, which studies issues having to do with relationships between climate and diet, has noted that scientists at the World Watch Institute report that up to 51% of all anthropogenic greenhouse gases are connected with animal agriculture. Moreover, recent research has found that grass-fed beef will not effectively address climate change because grass-fed cattle produce four times more methane than conventionally grown cattle and occupy far more land which should be habitat for native plants and animals.
A General Management Plan for Point Reyes National Seashore which includes continued cattle ranching would be incompatible with the National Park Service's goal of a reduced carbon footprint as stated on the NPS Point Reyes website, https://www.nps.gov/pore/learn/nature/climatechange.htm: 'The Seashore is doing its part by putting innovative energy technologies to use and looking for ways to reduce its carbon "footprint." ... With a combination of local, national, and international action to halt global warming, we can all help ensure that millions of Americans will be able to enjoy these national treasures for generations to come.'
We realize that the cessation of cattle grazing will, in some places on the Seashore, lead to an increase in invasive plant species, but there are methods, other than cattle grazing, which are available to the NPS to combat this problem. We also recognize that removing cattle will, in other places on the Seashore, encourage the regrowth of native coastal scrub habitat and its associated flora and fauna which are threatened throughout California.
People across the globe are switching to a more plant-based diet as they learn about the health benefits, animal welfare issues and, especially, the reduced impact on the climate of such a diet.
We encourage the Point Reyes National Seashore to fulfill its stated intentions regarding climate change. Thank you very much.
Brad Gaffney, Zhenya Spake, and David DeSante
350Marin.org
___________________________
# 2674
Name: N/A, N/A
Correspondence: I am writing to provide input on the General Management Plan Amendment for Point Reyes National Seashore (PRNS). I support the continued operation of beef and dairy ranching operations under agricultural lease/permits with 20-year terms and improved management of the Tule elk herds to eliminate negative impacts on the environments and ranching families.
Ranchers have been raising cattle on Point Reyes for more than 150-years. It was ranchers' willingness to sell their properties to the federal government that allowed the creation of the PRNS. As part of the agreement, ranchers were supposed to be allowed to continue ranching on their family ranches with the PRNS.
I'm sure the loss of the tax base for Marin County is significant. The most important effect on the tax base occurred when the land transaction took place, but additional tax base loss will happen when the cattle and other assets the ranchers own are removed. I know a payment in lieu of taxes is usually an attempt to address this issue, but often this obligation is not met in a timely fashion by the various government agencies involved.
Although we live in the Sacramento Valley, my family and I have visited the PRNS on several occasions during the past five years and have enjoyed the Park. However, we have noted the decline in the condition of the rancher's facilities in the Park. I expect this results from the uncertainty on the part of the ranchers regarding the short term lease situation and whether they will be allowed to continue their operations. Therefore, I believe it is imperative to adopt the 20 year lease arrangement so these people can invest in their operations and have the certainty they will be able to continue ranching.
Ranches on PRNS provide important economic, cultural, and ecological values to the local community. Losing a significant portion of West Marin's agricultural community would mean not only a loss of local food production, but a significant loss to its economy and culture. I urge you to offer 20-year lease/permits to ranchers on PRNS, to improve elk management and return the elk to the wilderness areas where they will not impact the ranches.
___________________________
# 2675
Name: DeRousse, Marcia
Correspondence: Dear Ms MacLeod:
I support the continued operation of beef and dairy ranching operations under agriculture lease/permits with 20 year terms and improved management of the Tule elk herds to eliminate negative impacts on the environment and ranching families.
Ranchers have been raising cattle in Point Reyes for more than 150 years. It was the rancher's willingness to sell their properties to the federal government that allowed the creation of PRNS.
These Ranches provide jobs and benefit the local community and the economy. It also provides jobs and is the livelihood of 25 ranching families.
I urge you to offer 20 year lease/permits to the ranchers on PRNS and to improve elk management and return the elk to the wilderness areas where they will not impact the ranches.
I love to drive along the coast there, it's almost like going back in time 100 years and see all those Happy cows grazing next to the ocean. This was part of an agreement, California is a huge Ag state and we need to keep it that way.
Thank you
Marcia DeRousse
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# 2676
Name: Bishop, Norman A
Correspondence: Dear Superintendent,
I support free-roaming tule elk at Point Reyes, and I reject fencing, removal, sterilization or killing of elk there. Tule elk have become an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Wildlife removal or exclusion at Point Reyes should not be determined by concessioners. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I hope you will reject the use of national park lands for row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. Any of thsese would create conflicts with predators and degrade wildlife habitat and water quality.
As a retired park ranger, I would hope that the Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Thank you.
___________________________
# 2677
Name: Karnos, Kristine
Correspondence: One of the joys of visiting Point Reyes National Seashore is watching the free-roaming tule elk there.
I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
___________________________
# 2678
Name: Saarman, James D
Correspondence:
WEEDS HAVE BECOME THE MAJOR PROBLEM in the park. Exotic plants are continuing to arrive. And impossible to control.
And the problem is getting worse with exotic grasses crowding out native plants and wildflowers. New exotic plants are moving into the park wherever people travel. This is a new reality, and a "hands off" management strategy is no longer relevant. Hands off approaches let the weeds florish. "Hands Off" does not address the expansion of annual weeds that are crowding out native grasses and other native perennials.
Cattle appear to be less discriminate in their diet than Tule Elk. They will eat the introduced annual grasses more predictably than the Elk. Many of these exotics were introduced specifically for cattle grazing. While it is nice to bring the Elk back, it is a mistake to remove the cattle grazing which can keep the weeds under control. When the Cattle grazing pressure is controlled and annual exotic grasses are grazed short in the spring, native plants can get the light necessary to grow. Without grazing they are overwhelmed and do not get the necessary light to survive. Since the elk do not eat these grasses, they do not help control the weeds that overwhelm and out compete the native plants.
believe the best future for the park is to eliminate Dairy Ranching but allow beef cattle with their lighter impact on the land than Dairy. Also continue to manage the Tule Elk herd. Light to moderate grazing by beef cattle can help maintain the native flowers still found in the park.
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# 2679
Name: boesch, gayle a
Correspondence:
Dear Superintendent,
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
Gayle Boesch
___________________________
# 2680
Name: Vollmer, Alex B
Correspondence: Cynthia MacLeod, Acting Superintendent
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes, CA 94956
RE: Comments on General Management Plan Amendment Newsletter
Dear Acting Superintendent MacLeod,
As an almost 40 yearlong resident of Marin County, and a frequent user of the Point Reyes National Seashore, I thank you for the opportunity to submit comments concerning the General Management Plan Amendment (GMPA) Newsletter. I understand the six concepts presented in the GMPA Newsletter mark the commencement of a process intended to engage public feedback and ideas, a process that, at this time, is deficient in definitions, baselines, and scope. Therefore, the public is not limited or constrained by the conceptual alternatives and should use this comment period to seek clarification, question the conceptual choices, and present information that is missing. Based on this understanding, I submit the below comments.
1. Protection of Natural Resources
The GMPA should protect, restore, and preserve park resources using ranch leases that ensure that multi-generational, environmentally sustainable ranching is complementary to the natural resources and visitor experiences within the park. Based on the management policies, what criteria and processes will the Point Reyes National Seashore (Seashore) utilize to ensure the preservation of natural resources and the prevention of habitat degradation?
2. Diversification
I am unclear on this term, what it means, and what impacts this will have on park resources in the pastoral zone. My understanding is that ranching in the Seashore is for dairy and cattle-ranching purposes as outlined by the enabling legislation. How is the Seashore making decisions to potentially expand the land use from dairy and cattle ranching, and how will those changes impact the natural and cultural resources of the park?
3. Tule Elk
The Seashore is the only national park with a native population of tule elk that existed for thousands of years before they were hunted out of their natural habitats. The tule elk should be managed just like the Seashore's other natural resources. I am concerned that the proposed concepts all mention managing the elk, but a definition and strategies of management are not included. How will the elk be managed? Will the management methods align with other natural resource management strategies?
4. Climate Change
Climate change is important to consider as part of this GMPA process. This process focuses on where ranching activities will occur within the pastoral zone of the Seashore and in ranching lands within the Golden Gate National Recreational Area (GGNRA). Does this planning process take into consideration the best available science to understand where sea-level rise will impact park resources? By drawing lines where ranching activities can occur today, do those lines consider where and when marine wilderness areas may migrate further into the current pastoral zone?
Thank you for the opportunity to submit my comments.
Regards,
Alexander B. Vollmer
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# 2681
Name: N/A, N/A
Correspondence: As a local resident and 4th generation Marinite I have always appreciated the PRNS and value its natural beauty and valuable agricultural production.
I feel that sustainable dairies and ranches should remain with long term leases. This will enable the lease holders to invest in their operations with confidence for their future. These ranchers work very hard and produce much needed locally sourced food.
If the drakes beach elk herd are interfereing with agricultural production then mitigating measures should be taken to control the herd.
Please consider this option.
Thank you,
Karen Hooper
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# 2682
Name: Mendez, Monica
Correspondence: Dear Superintendent,
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
This place has been very important for me and my family and so many others. Please do not allow it to be degraded. There are so few wild natural places left, and we sorely need them.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Thank you,
Monica M.
___________________________
# 2683
Name: Straus, Albert
Correspondence: November 14, 2017
Cynthia MacLeod
Acting Superintendent
Point Reyes GMP Amendment
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes Station, CA 94956
Subject: Point Reyes National Seashore and North District of Golden Gate National Recreation Area General Management Plan Amendment, First Phase, High-Level Considerations
Superintendent MacLeod,
I appreciate the opportunity to submit comments during the first phase of the Point Reyes National Seashore and Golden Gate National Recreation Area north district (PRNS/GGNRA) General Plan Amendment (GMP Amendment) planning process.
Background
Im was born in Marshall. Im an organic dairy farmer, who grew up on a family dairy farm in west Marin County. I converted our family dairy farm, which my father originally started in 1941, to a certified organic dairy in 1994, which is the first certified dairy west of the Mississippi River.
In 1994, I founded Straus Family Creamery, the first 100 % certified organic creamery in the United States. For more than 23 years, we have produced high-quality organic dairy products at our creamery with values consistent with our organic farming model.
In addition to my certified organic dairy, eight other certified organic dairies in Marin and Sonoma Counties produce organic milk for Straus Family Creamery. Fourth-generation owner Jarrod Mendoza of Double M Dairy, which is located on 1,200 acres at the Historic B Ranch on the Point Reyes Peninsula, has provided certified organic milk to Straus Family Creamery since 2014.
Family members or myself have been lifelong participants in the agricultural and environmental communities here. I know the significant work it has taken our farmers and ranchers to gain national prominence as a working agricultural landscape. Fortunately, we also have become a crucial contributor to the Northern California foodshed and an internationally esteemed model for organic and sustainable agriculture.
Farming and ranching in Point Reyes National Seashore is now at a critical juncture in its existence. From the perspective of farming and food-producing rural communities, comprised of families that work the land, I recommend a different alternative because its urgently necessary to enact sensible, practical and economic solutions to ensure that agriculture and the people who live here continue to have an essential role in our region for generations to come.
My proposal for solutions includes the following:
A cooperative partnership in which all PRNS and GGNRA agricultural operations are managed by a non-profit third party.
Lease periods of 60 years or 20-year evergreen that stabilizes historic rural communities, allowing them to thrive both as economic engines and as conservation stewards, encouraging best ranch management practices and motivating the next generation to continue producing food for our local and regional foodshed.
A successful and replicative educational model within the PRNS and GGNRA operations that teaches the environmental benefits of organic agricultural practices, building a local, regional foodshed, and preserving natural resources.
Prioritizing climate change results with organic farming practices such as carbon farming which are practical and actionable solutions to this unprecedented threat.
Removing the Tule Elk herd, which disrupts the parks natural balance and is in direct conflict with federal requirements for organic agricultural practices.
A Non-Profit Third Party
First, I recommend a proposed action of developing a model of cooperation between a non-profit conservancy organization such as MALT (Marin Agricultural Land Trust), for-profit farms and the National Park Service. In this model, MALT or another Agricultural non-profit would manage all agricultural operations in PRNS and GGNRA. This model has already been successful in other regions of the country, notably the Cuyahoga Valley National Park in Ohio, where since 1999 a non-profit has acted as a third-party manager and facilitator for commercial agriculture within park boundaries. http://bit.ly/2zFh6ga
need this model because the current model has not been effective at balancing the needs of the agricultural community and natural resources. MALT, which was co-founded by my mother Ellen Straus, has facilitated a widely respected collaboration between environmentalists and ranchers, preserving Marin County farmland to make it one of the nations most revered food producing regions and a showcase of both its natural and agricultural treasures.
Leases Result in Economic Viability and Longevity
Secondly, my proposed action is allowing 60-year leases or 20-year evergreen leases in the GMP Amendment process to help stabilize our rural communities. Because by investing in a stable infrastructure for farmers and ranchers and offering affordable housing for working families then we can fully maintain best agricultural management practices, retain a stable labor force and make farming a viable profession for the next generation.
Over the past 50 years, more than 130 homes where rural families live, raise their children, and work as an integral part of Marins local agricultural economy have been torn down or abandoned when PRNS leases are terminated. Working families have been evicted and have left our area permanently to seek stable housing. This lack of housing, uprooting of workers and disruption of basic community resources is destroying our schools, medical facilities and other public services that rural populations depend on to survive.
Without workers, our local food economy cannot thrive because farming and ranching in PRNS and GGNRA contributes to the stability of our entire County of Marin farm system. PRNS ranches and dairies account for nearly 20% ($20million) of all gross agricultural production in Marin County. These ranches and dairies play a critical role in maintaining the viability of Marin County agricultural infrastructure and economic viability. Application of an Economic Input-Output Model to NPS farms and ranches would have an economic multiplier impact of nearly four (4) times the gross production values, or $80 million.
A leasing policy that permits affordable, stable housing for families will keep good workers on our farms and ranches and create resilience for our agricultural community.
Since the 1800s, dairy has been important to the Marin County economy and to the Bay Area foodshed. In 1994, I established the first organic dairy west of the Mississippi, setting an example of a local successful green business and regional sustainable food production. Today, six dairies in the Park are certified organic out of the 22 organic dairies in Marin. This counts for more than 25% of Marin Countys organic milk production. According to the 2016 Marin County Livestock and Crop report, the dollar value of organic milk production is $39,144,000. This almost $40 million dollars is the highest value crop in the county, and thus deserves to be protected as an important county resource. Organic dairy farming has created a proven stable price model and market for dairy farmers in this region.
A Successful and Replicative Educational Model within the Park
Third, my proposed action is creating a model within the park to teach all California residents and visitors from around the country and globe about the benefits of strong agricultural communities.
Its essential to showcases successful and progressive farming and ranching businesses and integrate these success stories into educational programs because it helps sustain these agricultural practices and natural resources and our foodshed, and rural communities.
When ranches and farms are stable, an enhanced program of education and outreach by PRNS about the history and value of agriculture in the park and the value of working landscapes should be established. These educational programs should focus on the environmental impact of good agricultural practices, the economic and social benefits of a resilient local food system, and the profound contributions to our region of thriving rural communities.
Sustainable Organic Farming Practices are a Solution to Climate Change
Fourth, my proposed action is a plan that prioritizes climate change results because using organic farming practices such as carbon farming is a proven solution. http://bit.ly/2zDI4oW
Climate change is a threat facing our own communities and our planet. Unless we take concrete action to reduce global warming emissions, the impacts will continue to grow ever costlier and damaging, increasingly affecting our natural heritage, wildlife habitat and biodiversity, and our local economies.
Scientists have published extensive studies in support of livestock farming as a primary solution to reversing climate change. Livestock grazing has been shown to benefit Californias grasslands by reducing risk of catastrophic wildfire and maintaining habitat for native plants and animals. Grazing promotes soil health by restoring its carbon content, captures carbon dioxide from the air through photosynthesis, and has been described as the most effective mechanism known to humankind in addressing global warming. (sources: Drawdown Solution #19: Managed Grazing/Rodale Institute)
Techniques already practiced on my dairy farm that could be implemented throughout the PRNRS are focusing on organic farming methods that include carbon farming, methane digester installation, rotational grazing of one to three days and the use of electric vehicles (the latter powered by methane from cow manure).
Carbon Farming has produced impressive results on my dairy farm, with 350 metric tons of CO2E per year removed from the atmosphere and returned to the soil. Using cornerstone techniques of organic farming, carbon farmings practical, affordable and simple practices include compost application on rangeland, hedgerows and wind break planting, water troughs and fencing to allow for rotational grazing, and seed planting.
To further illustrate how a solution as simple and affordable as compost application fights climate change, scientists have shown that increasing organic matter in the soil allows for more water retention and increased pasture and plant growth. A statistic presented by the Marin Carbon Project states that if we apply a quarter of an inch of compost on � of the rangeland in California, we would offset all the residential and commercial energy impact on climate change in California.
Installing methane digesters on dairies is another solution that I have successfully implemented on my own dairy farm. California dairy farmers are under pressure to lower emissions under the states new greenhouse gas reduction law. Governor Jerry Brown signed legislation in July 2017 mandating that the state must cut greenhouse gas emissions by 40% below 1999 levels by 2030.
As part of my commitment to sustainable agriculture, I installed my methane digester in 2004. Just this year, our digester has removed 1650 metric tons of CO2E from the atmosphere. Today, the entire farm including our hot water, several small farm vehicles and our 33,000-lb. heavy-weight feed truck which closes the loop are powered by electricity generated from the digester. To meet the state requirements, I envision farmers and ranchers working with 3rd party vendors to install and operate digesters on all dairies. Funding could come through a pay-as-you -save model that is funded through energy income.
Removal of Free-Range Tule Elk
Fifth, as part of prioritizing organic agriculture as a vital contributor to Marin Countys economy, I ask that GMP Amendment process includes removing all free-range Tule elk from the Pastoral Zone and all farmlands. Tule elk are today a plentiful species in California, thriving due to a California Department of Fish and Wildlife (CDFW) reintroduction program that now measures 21 herds of approximately 3800 elk, a significant increase since 1970 when only three herds totaling 500 existed. According to CDFW, the elk reintroduction program has been a tremendous success.
The elk currently impacting ranching operations in PRNS were never authorized to be in the area that they now occupy. Removal is necessary because their presence is in direct conflict with organic farming practices, making farming in our region less viable. Under the NOPs (National Organic Program) Pasture Rule, as established by USDA Organic Label requirements, certified organic farming operations must follow an extensive set of regulations around grazing and pasture management standards. Animals must graze at least 120 days per year and obtain at least 30 percent dry matter intake by grazing.
Further evidence of the need to remove elk is that these animals destroy fences, reduce pasture for livestock that is essential to meet federal law requirements, and the elk injure livestock, causing even more direct conflict with agricultural operations. Therefore, the removal of the elk should be included in the NOI and Draft EIS.
The Tule Elk need to be kept on the 18,000 acres set aside for them according to the 1998 PRNS Tule Elk Management Plan and Environmental Assessment. The other 21 Elk herds in California are managed effectively by California Fish & Wildlife, and no issues. PRNS must allow CDFW to manage the Elk in PRNS. Sensitive species such as the California Red Legged Frog and native grasses thrive on ranches where good management practices are in place, proving that wildlife habitat and ranching can be highly compatible.
As we prepare to decide the future of the PRNS and GGNRA GMP Amendment planning process. I urge serious consideration of what is at stake. It is time to re-establish strong local communities, sustain regionally important food production from internationally respected agricultural operations leading by example and preserve historical treasures including wildlife habitats, natural plants, wildflowers, and more, as active educational resources for generations to come.
Sincerely,
Albert Straus
Founder/CEO & Organic Dairy Farmer
Straus Family Creamery
Marshall and Petaluma, California
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# 2684
Name: Conley, John
Correspondence: Work toward getting rid of all the ranches leased in Point Reyes National Seashore. They belonged there historically, but history moves on. They are currently welfare realty for ranchers: cheap leases with little environmental oversight or enforcement of lease terms by the NPS.
In the meantime, in managing existing leases, leave the Tule Elk alone. They literally were there first, and I'm happy they have extended their range from the reserve at Tomales Point into the Limantour area. Good for them, and more power to them. It is the cattle that are foreign to this area.
The ranchers in Point Reyes are generally not good stewards of the areas that they lease; any person who has hiked the area extensively, as I have, will tell you of the mounds of trash deposited by ranchers: tires, wheel rims, appliances, wood debris (plywood, etc.). Kevin Lunny's cattle have overgrazed their allowed allotment a number of times. Where is the enforcement of existing protections and prohibitions? This is not the time to loosen restrictions on ranching/grazing in the Seashore. Quite the opposite.
Thank you for your consideration of these comments. I know you're listening, Mr. Zinke ... and you care about Public input, right?
John H. Conley
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# 2685
Name: Walsh-Barrett, Alvin & kathleen
Correspondence: We endorse the NPS initial proposal, providing for continued ranching and management of the Drakes Beach Tule Elk Herd. The area under consideration constitutes almost 1/5 of the County's productive agricultural acreage. If this area is removed from production, we will lose the critical foundation needed to support suppliers, processors and essential services. The seashore ranches account for significant areas of managed coastal grasslands, providing habitat for endangered species, water storage, support for pollinators, keeping invasive species in check and reducing danger of wildfires. We cannot afford to lose these benefits.
We understand that GGNRA has developed a comprehensive plan to engage in the GMP process. We support continued ranching in the Seashore and GGNRA. We hope that you will adopt the alternatives stated in your initial proposal.
Alvin & Kathy Walsh-Barrett
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# 2686
Name: Dietrich, Daniel
Correspondence: Dear Superintendent,
Thank you for allowing this public comment period so that all may share their thoughts, support and concerns. The GMP amendment process is covering a tremendous amount of topics. Keeping in mind our obligation to provide "maximum protection, restoration and preservation of the natural environment", I'd like to share some personal thoughts on a few topics.
DIVERSIFICATION
Each of the new alternative plans proposed by the National Park Service that include ranching include the statement:
“Lease/permits would identify authorized measures for operational flexibility and diversification”
The National Park Service has not provided a definition of either term, “operational flexibility” or “diversification”. Based on the past several years of submitted public documents, public workshops and personal discussions with park staff, I understand that the park may consider under the term “diversification” the following activities (among many others):
1) Current land within the National Seashore being converted to commercial row crops
2) The allowance of new domestic livestock to be raised in the National Seashore, possibly including pigs, chickens, goats and/or other domestic livestock not currently allowed in the National Seashore
I urge the park to not allow the conversion of any public land within the National Seashore to allow planting of any row crops. Animals will be killed, animal habitat will be lost, public access to this land will be lost, conflicts with native wildlife will be immediate, scenic beauty will be lost, water quality will suffer among many other concerns. As a park employee told me at the recent public meetings, a consideration could be to allow some number of acres around the ranch core for this purpose. The size of the allowance, be it 1 acre or 100 acres does not change the fact that animal habitat will be lost, public access to this land will be lost and native wildlife conflicts will happen.
The introduction of any new domestic livestock should not be allowed. Native wildlife such as bobcats, coyotes, foxes, badgers and others will be in immediate conflict with the new domestic livestock. History has shown us that this conflict nearly always ends poorly for native wildlife.
It would be very helpful for the National Park Service to define the term diversification as it is being included in all new ranching alternatives. If one can’t be provided, then a partial list of what could possibly be included or what is already being considered under the term would provide the public more clarity to be able to comment more specifically on this topic.
TULE ELK
In each of the new alternative plans proposed that include ranching include the statement, “The elk population would be managed at a level compatible with authorized ranching operations.”
Can the park please define “managed” as it is used in this manner?
From my personal discussions with park staff, the term 'managed’ may include the killing of elk in the National Seashore. In 3 of the 4 new plans, it is stated that maximum population thresholds would be established. When this maximum population number is crossed, tule elk will be removed from the herd, possibly using lethal methods.
In the 4th plan, the entire Drakes Beach tule elk herd would be removed, again, possibly using lethal methods.
It is known that our tule elk have a disease called Johnes Disease. This most likely prevents them from being relocated to any land outside of Point Reyes National Seashore to prevent the disease from spreading. As I have been told, killing the elk is a consideration in the ‘management’ of the native animal.
I understand there may be a need to manage tule elk for certain reasons by the NPS. But I disagree with any method of population control that is used in a manner to control their numbers to satisfy any conflict with ranching operations. The tule elk are native to this peninsula. They are adored by millions of visitors each year. Any effort to reduce their numbers will significantly reduce visitor experience. It is the responsibility of the park service to prioritize and protect them.
There are several other topics that I look forward to discussing with the Park Service as this process continues. But these are a few of my bigger personal concerns. These are my concerns as an individual and may or may not differ from any organization I may be a part of including EAC.
Sincerely,
Daniel Dietrich
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# 2687
Name: Atwood, Bob
Correspondence: November 14, 2017
Cynthia MacLeod, Acting Superintendent
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes, CA 94956
RE: Comments on General Management Plan Amendment Newsletter
Dear Acting Superintendent MacLeod,
Thank you for the opportunity to submit comments concerning the General Management Plan Amendment (GMPA) Newsletter. I understand the six concepts presented in the GMPA Newsletter mark the commencement of a process intended to engage public feedback and ideas, a process that, at this time, is deficient in definitions, baselines, and scope. Therefore, the public is not limited or constrained by the conceptual alternatives and should use this comment period to seek clarification, question the conceptual choices, and present information that is missing. Based on this understanding, I submit the below comments.
1. Protection of Natural Resources
The GMPA should protect, restore, and preserve park resources using ranch leases that ensure that multi-generational, environmentally sustainable ranching is complementary to the natural resources and visitor experiences within the park. Based on the management policies, what criteria and processes will the Point Reyes National Seashore (Seashore) utilize to ensure the preservation of natural resources and the prevention of habitat degradation?
2. Diversification
I am unclear on this term, what it means, and what impacts this will have on park resources in the pastoral zone. My understanding is that ranching in the Seashore is for dairy and cattle ranching purposes as outlined by the enabling legislation. How is the Seashore making decisions to potentially expand the land use from dairy and cattle ranching, and how will those changes impact the natural and cultural resources of the park?
3. Tule Elk
The Seashore is the only national park with a native population of tule elk that existed for thousands of years before they were hunted out of their natural habitats. The tule elk should be managed just like the Seashore's other natural resources. I am concerned that the proposed concepts all mention managing the elk, but a definition and strategies of management are not included. How will the elk be managed? Will the management methods align with other natural resource management strategies?
4. Climate Change
Climate change is important to consider as part of this GMPA process. This process focuses on where ranching activities will occur within the pastoral zone of the Seashore and in ranching lands within the Golden Gate National Recreational Area (GGNRA). Does this planning process take into consideration the best available science to understand where sea-level rise will impact park resources? By drawing lines where ranching activities can occur today, do those lines consider where and when marine wilderness areas may migrate further into the current pastoral zone?
Of the different options listed I support the "Reduced Ranching and Management of the
Drakes Beach Tule Elk Herd".
I refer to cattle below I am not referring to the dairy herds.
non-dairy beef cattle ranches should only be offered 10 year leases. Dairies should be offered 20 year leases.
am an environmentalist but I would like the Park Service to do what is necessary to keep the diaries operating in the Park. They provide locally produced dairy products. support the beef cattle ranches east of the san andreas fault but much less so the ones west of Limantour. There is more than enough cattle grazing land through out California to require it to be in PORE. The dairies are much more special than grazing beef cattle operations.
would like to see kayakers only be allowed to access Drakes Estero from where the old Drakes Bay Oyster company used to be. Many of them are causing damage by entering from the Limantour Beach Parking area.
Part of the Estero Trail is turned into an impassible mud pie by cattle in the winter at GPS 38.0636781,-122.9193002 - could the area be fenced off with gates to keep the cattle off this portion of the hiking trail?
are also rare native plants in Bull Point Trail area that are being trampled by Cattle. Could you work with Marin CNPS to see if something could be done about that.
dairy building at gps 38.1336502,-122.938939 is an eyesore. Could something be done so it blends in better with the natural surroundings? Perhaps plant Cypress trees around it?
The 1960’s residential house close to 38.0385711,-122.9647457 (on road to Drake’s Beach) is a real eyesore on the landscape. Could it be removed or at the very least be completely surrounded by Cypress trees? When you look out at the vistas from Chimney rock or up on Mt. Wittenburg it is an obvious stain on the viewshed.
the “Respect Residents Privacy” signs be removed from the old white residence building at Fish Docks. Most of the time there is no one living there and the public should be able to freely walk around the outside the structure. There was no public comment period before those signs went up.
I’ve heard some the Dairies and Cattle Ranches want to operate other commercial businesses such as Bed and Breakfasts, Air BnB, and other commercial enterprises - I am against this from happening. They should be limited to dairies and beef cattle.
former cattle ranch or dairy should be brought back into operation. new land should be opened up to grazing. Tenants should agree to pay all Park Service legal fees incase of a legal dispute where they don’t prevail.
I think it would be ok to maintain Tule Elk populations to their current population levels and locations and relocate any increase to other parts of California. So just take a census of how many and where they are currently and make that the baseline to maintain into the future.
If any of the non-dairy beef cattle ranches west of the san andreas fault goes out of business or the leasee just wants to sell their business, the Park Service should seriously look at the benefits of just returning that land to nature and be legally free to do so.
don’t see any special benefit to permanently having beef cattle grazing operations in PORE west of the San Andreas fault. believe the beef cattle ranches east of the San Andreas Fault should continue long term with new tenants as needed. The currently operating beef cattle grazing ranches west of the San Andreas fault should be able to continue their operations with 10 year leases that are not transferable but are renewable at the discretion of the Park Service.
Thank you for the opportunity to submit my comments.
Best regards,
Bob Atwood
San Anselmo
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# 2688
Name: Cluff, Susan A
Correspondence: This is important! These Point Reyes ranches, many 150 years old, were protected from development in the 1960s by President Kennedy when Congress purchased the land in a historic deal that promised to keep agriculture here forever. The ranchers pay fair market rent, work closely with Park rangers, and follow prescribed practices that protect wildlife and ecosystems. Without them, the land would soon be overrun with thistles, broom, and other invasive species. And the Park Service could sell off property or negotiate other less-responsible leases, as they've tried to before. Let's keep sustainable agriculture and wide open spaces at Point Reyes!
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# 2689
Name: Morse, Dan
Correspondence: I have lived in Inverness for 48 years. Prior to that, we vacationed here all summer during my youth. I spent many days on the RCA (Lunny) Ranch, learning about their cattle, their work ethic, and the keen sense of family shared by generations. I was struck by the hard work involved in their everyday lives.
I support 20 year leases, automatically renewable each year, so that until the lessees were informed otherwise, by the park service, they would always have a 20 year lease ahead of them. This would allow ranchers the ability to borrow funds for capital improvements, and infrastructure that is so needed in a ranching environment. All ranching, both beef and dairy operations need to stay! It is the backbone of the Point Reyes National Seashore. At the time of it's creation, it was lauded as becoming a great partnership between ranches and parks. 2.5 million visitors a year drive through ranching operations on their way to the beaches of the seashore. 20 year leases would ensure these ranches would remain and be maintained in a way that visitors can appreciate. It would also save the park service money in overall operating expenses.
20 year leases would give hope to the next generation of ranchers. Without them, they would have no guarantee that their family ranch would be there for them to manage in the future.
The elk outside the Pierce Point enclosure, need to be actively managed, to keep them from adversely affecting the ranching operations anywhere outside their original enclosure. I have to believe, that the architects of the re-entry of the elk to the seashore, never thought that this would ever, adversely affect the ranching community outside the original enclosure.
Ranchers need a firm commitment from Department of the Interior that ranching on the Point Reyes peninsula is here to stay.
Thank you, Dan Morse
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# 2690
Name: Gray, Jeffrey
Correspondence: I would like to weigh in to support continued ranching and dairying in the Point Reyes National Seashore. The agricultural heritage of this area is every bit as important a history to maintain as is the beauty of Drakes Estero and the seal colonies of double point and Tomales Bay. I further support non-lethal management of the Tule Elk herds within the park in light of the carrying capacity of the land. I support compromise to allow the agricultural sector to not only survive but to also strengthen and serve as an example of what can be achieved when public policy works in concert with local community.
The Point Reyes peninsula is a treasure of both human and natural symbiosis. Please work to ensure there is a balance to the revision of the management plan.
Thank you,
Jeffrey Gray
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# 2691
Name: Painter, Michael J
Correspondence: November 14, 2017
Point Reyes GMP Amendment
Superintendent
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes Station, CA 94956
Dear Ms. MacLeod:
I am writing on behalf of the more than 850 members and supporters of Californians for Western Wilderness (CalUWild), a citizens organization dedicated to encouraging and facilitating participation in legislative and administrative actions affecting wilderness and other public lands in the West. Our members use and enjoy the public lands in California and all over the West.
We appreciate this opportunity to comment on the start of the planning process for a General Management Plan Amendment (GMP Amendment) for Point Reyes National Seashore and the north district of Golden Gate National Recreation Area.
The most important criterion that Park Service must stress in its planning is protection of the natural environment, regardless of whether it continues to allow ranching and dairying or not. Agriculture cannot be allowed to have adverse effects on the Seashore's environment, whether dairy run-off, erosion, or spreading of non-native invasive plants, to name just a few possibilities.
This will be difficult to achieve, given the history of the Seashore, but in every case, the environment must be given priority. This needs to be set out clearly and repeatedly. All alternatives proposed need to stress this principle.
Related to this, no plan alternative should allow for increased agricultural activity, either quantity or type of use, in comparison to present-day levels, regardless of how the land might have been used in the past. New types of agriculture, such as poultry raising or vegetable crops for commercial sale, as well as on-site sales of produce should not be allowed. The legislation establishing the Seashore specifically states: "The term 'ranching and dairying purposes’, as used herein, means such ranching and dairying, primarily for the production of food, __as is presently practiced in the area__ (emphasis added)." The legislation clearly did not provide for increased levels in the future, and the fact that restrictions were placed on the subsequent ownership within families, etc., indicates that levels of commercial agricultural use were expected to decrease over time, by retiring leases or simple attrition as family members left or died.
As long as the Park Service is leasing land to ranchers, it must ensure that it is receiving a fair rent. It must also ensure that the original leaseback agreements are adhered to, for example, who is allowed to continue ranching within families.
Other uses of properties, such as overnight accommodations, meeting or retreat venues, etc., should not be allowed under any alternative.
Natural restoration must be emphasized if agricultural uses decrease or cease.
Although the ranches may be eligible for listing on the National Register of Historic Places, they are not significant or unique enough to warrant their nomination. Having them listed may limit the Park Service’s options in the future, should it need to revise a management plan.
The Park Service should emphasize those visitor experiences associated with the natural world: hiking, bird- and wildlife-watching, beach visits, and such. Activities such as tours of ranches should not be allowed for the general public, although visits by school kids would be acceptable, as part of a field trip to Pt. Reyes.
Overall, visitor facilities seem adequate as they are. There’s no need for new visitor centers; the main one at Bear Valley and smaller ones at Drake’s Beach and the Lighthouse are fine and in keeping with the undeveloped nature of the main peninsula.
Elk management should be undertaken using natural predators (i.e., mountain lions) where feasible.
Thank you for the opportunity to comment. Please inform us when formal scoping begins and of further opportunities to be involved in your public decision-making processes.
Respectfully submitted,
Michael J. Painter, Coordinator
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# 2692
Name: Holmes, Ellen W
Correspondence: I support whatever is best for the indigenous flora and fauna of the seashore. My position on all specific points is identical to EAC's.
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# 2693
Name: N/A, N/A
Correspondence: The Park Service's amendment to the General Management Plan should focus on protecting the free-roaming, native Tule Elk population. I understand that cattle-ranching has been a historic part of the national seashore, but commercial cattle ranching should not be the driving force for this plan.
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# 2694
Name: Ptak, Elizabeth
Correspondence: "Under this alternative, existing ranch families would be
authorized to continue beef cattle and dairy ranching
operations under agricultural lease/permits with 20-
year terms."
1. What happens at the end of the 20-year lease? Would the lease be renewable at that point?
2. How is "existing ranch families" defined?
3. If there is no member of an "existing ranch family" to take over operation of the ranch, what happens? Does the land revert to NPS? Could another ranching family take it over?
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# 2695
Name: Moffett, Erika A
Correspondence: I am a third generation chid born and raised in the National Seashore. I have witnessed the ranchers and park service working together to preserve this beautiful land. I no longer live there, but visit my family that still resides and continues to prevent any damage of the land and water. The National Seashore has always drawn people that want to hike, whale and bird watch, enjoy the beaches and view sustainable ranching. All of these activities educate the public, in particular the ranching and dairy farming, because it helps the general public know where their food comes from and how it is produced. It is important to provide grazing and organic property to these ranchers, because the demand is going toward organic and most families want to be healthy and eat foods coming from properties like the ones on the National Seashore. Unfortunately, I have also witnessed in the last ten years the Tule Elk taking over the pastoral zones that these ranchers have worked extremely hard to preserve. The Elk are destroying fences, injuring cattle and themselves, stealing hays, and spreading disease. In addtion to this over population of Elk on the Sir Francis Drake Blvd. area of the point, the National Park is wasting money hazing these animals. The Tule Elk should be placed back into their original habitat at Limantor and Tomales Point where they have plenty of room. This will continue to have visitor access and allow the Elk to have more of a wilderness area so they can be free ranging. Keep in mind that Elk are very new to most ranching areas and therefore should not be included in the 150 year environmental basesline. Along with removing the Elk, the National park service needs to give the ranchers their rights and issue twenty year leases that automatically renew. This is because the ranchers provide the general public not only fantastic organic foods, but also education. The Point Reyes National Seashore provides little education on this subject. The ranchers keep all of this land lush by praticing erosion control, highest quality fresh water standards and a thriving habitat for all wildlife. I have lived on the Point Reyes National Seashore and have experienced this all first hand. I want to give my sons the opportunity to move there with their grandparents some day and work, learn and educate the public and give back to the land as the land has given to us.
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# 2696
Name: Goldeen, BJ
Correspondence: I urge the NPS to preserve and continue to protect the Point Reyes National Seashore as it is. This includes all of the land, existing dairy and cattle ranching and preservation of the tule elk population without interference. The Seashore needs to be left alone for everyone to enjoy without commercialization. It stands as testimony to not only California's history but to that of our Country. There are no words to express how strongly I and many others feel about guarding the integrity and specialness of this place. Thank you.
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# 2697
Name: N/A, N/A
Correspondence: To: Superintendent Park Service
I grew up frequently going to the Point Reyes National Seashore with my family. This is a spectacularly beautiful area and much loved both by people who live here and visitors from all over the world.
I AM AGAINST REMOVAL OF TULE ELK. ROW CROPS AND NEW COMMERCIAL ANIMAL FARMING SHOULD NOT BE ALLOWED (THIS IS A BELOVED NATURAL PLACE, NOT AN INDUSTRIAL FARMING AREA), AND TULE ELK AND NATIVE WILDLIFE SHOULD COME FIRST BEFORE ANY CATTLE INDUSTRY!!!!!
Sincerely, a long-time admirer of the Point Reyes National Seashore.
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# 2698
Name: Bennett, Gordon
Correspondence:   Save Our Seashore  
A 501(c)(3) Charitable Organization (EIN 94-3221625)
Founded in 1993 to Protect Marin County's Ocean, Coasts, Estuaries, Watersheds and Creeks
November 15, 2017
Save Our Seashore offers the following comments on the six PRNS GMP Concepts:
No Ranching Concept and No Dairy Ranching Concept
Save Our Seashore (SOS) cannot support these settlement-required concepts because we believe they conflict with the PRNS enabling legislation and contemporaneous records indicating congressional intent that families who were owners or lessors of land sold to create PRNS should be allowed to continue "ranching and dairying."
Attempts have been made to re-characterize the record of congressional intent by claiming that the intent extended only to the initial Reservation of Use (RUO), but not to subsequent Special Use Permits. We disagree. A ROU is a real property agreement available to every seller of land to NPS that enables the seller to continue to use and occupy the land. Thus it would have been superfluous and pointless for Congress to assure that ranching and dairying could continue (but only to the end of the ROU) because continued ranching and dairying would already have been secured by the terms of the RUO. Thus congressional intent must have and did extend past the RUOs to subsequent SUPs.
Reduced Ranching Concept
cannot support this settlement-required Reduced Ranching Concept because its criteria are primarily based on lack of residency. This concept thus removes unoccupied ranches operated by families who were owners or lessors of land sold to create PRNS (e.g. F Ranch) and thus conflicts with the PRNS enabling legislation and contemporaneous records indicating congressional intent. Instead, the criteria should be revised to create the settlement-required reduction by removing ranches that are not operated by families who were owners or lessors of land sold to create PRNS (e.g. Ranch 31).
areas selected for removal should not include ranchland otherwise eligible for removal under these revised criteria that was swapped for ranchland operated by families who were owners or lessors of that land (e.g. southern portion of K ranch). Residencies on ranches removed under these revised criteria can, if deemed necessary or appropriate, be separated from the ranchlands (e.g. as the Murphy residence was from the Home Ranch acreage) and addressed though other management actions.
SOS cannot support this settlement-required Reduced Ranching Concept even with these revised criteria if the settlement language (“will not be conditioned or dependent on rancher’s discretionary termination of their leases...”) means that NPS will force the rancher out. This concept appears ignorant of the fact that since NPS purchased these ranches, many operations have terminated though death or retirement...neither of which appears to be “discretionary.” Thus this Reduced Ranch Concept could be accomplished by simply letting nature take its course over the lifetime of any rancher who is not the owner or lessor of the land sold to create PRNS. Such a Reduced Ranch Concept would provide an equivalent guarantee of a reduction of ranching, but gracefully and over time, instead of forcefully and immediately. This would also allow time for PRNS to determine how it will maintain the endangered coastal prairie habitat and cultural landscape without commercial grazing (e.g. prescriptive grazing, fire, mowing, etc).
Continued Ranching and Management of Drakes Beach Tule Elk Herd Concept
SOS supports the NPS Initial Proposal because we believe it is consistent with PRNS enabling legislation, contemporaneous records indicating congressional intent, Secretary Salazar’s Order and existing NPS policies for public access and for cultural and natural resource protection.
Ranching at PRNS should have as its goal to be exemplary and highly sustainable. The Public should not expect instant achievement of these goals, but rather evidence of continued progress.
Thus NPS management of ranching must be more transparent in order to restore public confidence in NPS protection of public access, cultural and natural resources. Permits, Water Quality Reports, Fair Market Evaluations, Public Health Inspections and Progress Reports should be posted on the web, rather than available only by a FOIA Request. As examples:
• The un-released 2010 GMP Figure 24 describes “Fenced and Unfenced Riparian Corridors,” but there has been no easily accessible follow up as to (wildlife-friendly) fencing progress.
• Likewise Figure 25 shows cattle damage to wetlands, but there has been no easily accessible follow up as to how many of PRNS’s 440 herbaceous wetland acres have been protected.
• Likewise Table 34 lists nine “Degraded Water Quality Locations,” but there has been no easily available follow up as to how these nine problems have been addressed.
Continued Ranching and Removal of Drakes Beach Tule Elk Herd Concept
SOS cannot support this concept because we see removal of the Drakes Beach herd as a conclusion from a yet-to-occur study on elk impacts and elk management options. Further, The prior Concept’s “Management” (vs this Concept’s “Removal”) of the herd could conceivably result in only a handful of animals that would have minimum impact on ranching. Further still, removal of the current Drakes Beach herd does not ensure that elk from the growing population in the Limantour wilderness will not re-populate Drakes Beach creating renewed ranch conflicts or spread to areas outside the Seashore creating other conflicts. Seashore management of its free-range elk herd is going to be a continuous need that is merely postponed but not permanently solved by the removal of Drakes Beach Tule Elk Herd.
Continued Current Management Concept
cannot support the Current Management Concept because we believe that continued “limited” management of the elk herd affecting ranch lands is not feasible as the already-large herd size continues to grow. This growing herd size puts ever more pressure on Point Reyes Ranchers and PRNS staff forced to deal with the continuing un-resolvable conflicts that could ultimately force ranchers out of business. Thus this Continued Current Management Concept conflicts with the PRNS enabling legislation and contemporaneous records indicating congressional intent that families who were owners or lessors of land sold to create PRNS should be allowed to continue “ranching and dairying.”
Further this Current Management Concept conflicts with the intent of Secretary Salazar’s Order to offer as long as 20-year leases in order to incentivize ranchers to invest in actions that offer better interpretation of public access and better protection of natural and cultural resources. This Concept also conflicts with existing NPS policies for public access and for cultural and natural resource protection. Lastly, Current Management has proceeded with a lack of transparency that has diminished public confidence in NPS management of ranching.
Thank you for allowing us to comment on the six “Concepts.” After the NOI is published, we look forward to submitting considerably more detailed comments on the “Alternatives.”
Sincerely,
Gordon Bennett, SOS President
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# 2699
Name: Hish, Lisa
Correspondence: I love visiting West Marin and Point Reyes National Seashore. I love that we are protecting the natural beauty, sustaining habitats while allowing sustainable farming to co-exist within the area. One of the reasons I visit the area quarterly is for the farming. I love seeing the historic farms along the peninsula. I spoke to one of the farmers while waiting for his cows to cross the road back to the barn st sunset. He told me he is a third generation farmer, farming his grandfather's farm after his father. Said he hadn’t travelled much, but didn’t need to as he could see the ocean and the estuary from his farm. Where else does an inner city Chicagoan who sets up community gardens and a farmer havevthese conversations? But on the road to the lighthouse, of course.
Sustainable agriculture can co-exist within nature just as both nature and farming can co-exist in cities.
We must think big to co-exist, harmonize and thrive together.
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# 2700
Name: N/A, Christin
Correspondence: I feel very strongly that the ranches within Pt.Reyes Natioal Seashore should be alowed to remain. This was an agricultural area long before the park was established. We need to retain as much agricultural land as possible in Marin, and these dairy ranches contribute greatly to our local economy. The park has worked perfectly well with both ranches and parkland for years now and I don't see why it should have to change. Currently there are plenty of trails and beaches for visitors to use and enjoy in Pt.Reyes National Seashore, and the ranchers are conciencious stewards of their land.
I have been a frequent visitor to the park for over 40 years and always enjoy my hikes and drives while photographing the land, sea, ranches, cows and wildlife. Let it be....Christin
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# 2701
Name: N/A, N/A
Correspondence: Dear Superintendent,
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
Sarah Castaneda
___________________________
# 2702
Name: Custer, Marcy
Correspondence: Hello. Thank you for the opportunity to comment on future plans for Point Reyes National Park.
I would like to see Point Reyes National Park transition away from ranching and become more of a park again. Ranching in a National Park is incompatible with the mission of the National Park Service (NPS). According to the NPS website, "The National Park Service preserves unimpaired the natural and cultural resources and values of the National Park System for the enjoyment, education and inspiration of this and future generations. The Park Service cooperates with partners to extend the benefits of natural and cultural resource conservation and outdoor recreation throughout the country and the world."
My understanding is that more than 25 years ago, the federal government purchased each ranch at around a cost of one million dollars each, only to then lease the ranches back to the ranchers at below market costs. The federal government and we tax payers have more than met the obligation of the 25 year leases. It is also hardly “fair” to ranchers who operate outside of the park to compete with ranchers inside the park who are being subsidized by we, the tax payers. During the transition back to a National Park, ranches should be charged rates consistent with those operating outside of the park. In addition, funding is in short supply to operate many national parks. Even Point Reyes closed access to parts of the park Tuesdays through Thursdays. Therefore, why are we, the tax payers financially supporting ranches inside this National Park?
Now to describe what it is like to visit a National Park with active ranches. Two words: cow pies.
I visited Point Reyes National Park on November 8 & 9, 2017. These dates were a Wednesday and Thursday, so parts of the park were closed. At Abbotts Lagoon we saw a river otter, blue heron, other wild birds, and cow pies on the beach and rocky shore. At Estero by Home Bay, the cow pies were prolific at the water's edge. We also walked up some of the hillsides to get a view of the wildlife, carefully stepping to avoid cow pies.
I also understand the plan proposes to cull elk when they reach certain numbers. I totally oppose this and request no killing of the elk. If we can transition to close the ranches and restore the National Park, there will be no need to cull the elk.
Please let the mission of the National Park Service guide your plan for Point Reyes National Park. Transition the ranches outside of the park so we can all enjoy the unimpaired natural and cultural resources of this National Park.
Respectfully,
Marcy Custer
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# 2703
Name: Kohler, Cass
Correspondence: We love Point Reyes and have spent many vacations there. In fact, it's where we honeymooned. Among the many things we appreciate is the unique and abundant natural beauty including the Tule elk. And from many visits over the
years, we have come to learn that a key to their success for reintroduction was the fact that there was no fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
___________________________
# 2704
Name: Bear, Rev. Charlotte
Correspondence: I SUPPORT free roaming tule elk herds at Point Reyes National Park. NO FENCING, CONFINEMENT OR PREDATION UPON THE WILDLIFE THERE.
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# 2705
Name: Zontek, Kenneth S
Correspondence: Please ensure the growth and health of the Tule Elk population even if it means prohibition of livestock grazing. The Tule Elk, a legacy species, deserve as much habitat as possible. Thank you.
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# 2706
Name: Carlton, Alan
Correspondence: Alan Carlton
Attorney at Law
COMMENT ON PT. REYES GENERAL PLAN AMENDMENT
I have been visiting Pt Reyes for almost 60 years and have observed the damage done to the Seashore by ranching.
In planning ranch management, the Park Service must consider that the statutory purpose of National Parks, including Seashores, under the National Parks Organic Act is: " To conserve the scenery and the natural and historic objects and the wild life therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations."
existing condition of the Pastoral Zone in the Park does not meet this purpose. scenery, natural conditions, public access and enjoyment, and wildlife have been adversely affected and impaired by the existing ranching operations se effects include erosion in the pastures from the cattle; pollution from cattle excrement and urine affecting water quality; disturbance of native plants and wildlife (including endangered species) by the cattle operations and the silage mowing, release of methane from cattle, and proliferation of fencing, structures, and debris on the land. amendment and the proposed alternatives should address these adverse effects and how they are to be mitigated by improved ranching practices, oversight, and enforcement.
All of the proposed alternatives at provide for continued operation of the ranches include “authorized measures for operational flexibility and diversification “ To the extent these additional measures proposed by the ranchers result in increased or additional uses of the land, they are contrary to the statutory purpose because they would fail to conserve the scenery and natural and historic objects therein. Additional uses such as sheep and goats, row crops, bed and breakfasts, weddings, farm stands, and processing would only detract from the scenery, natural objects, and wildlife, the protection of which is the purpose of the Park. They should not be included in all the alternatives.
management alternatives should list a number of criteria to be examined in evaluating the alternatives. They include scenic values, natural conditions to be conserved, erosion and other degradation, sustainability, status of habitat and wildlife, succession of management permits, protection of historical and cultural values, and opportunities for public enjoyment of the parks. Examination using these criteria will then make it possible to see what has been conserved by the present level of use and what has been adversely affected.
The range of options proposed for the General Management Plan Amendment do not include an option of continued ranching in a manner that will protect the Park and its wildlife and improve the degraded condition of the rangeland. Such an alternative is legally required.
___________________________
# 2707
Name: Reynolds, Rozlyn L
Correspondence: Dear Superintendent,
The purpose of public land was to protect some part of our national wild spaces and animals from the constant land grabbing of cattle corporations and corporate farmers.
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
___________________________
# 2708
Name: N/A, N/A
Correspondence:
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Thank you.
___________________________
# 2709
Name: Maguire, Noele
Correspondence: My name is Noele Maguire. I grew up in West Marin and though I no longer live there I want to preserve it. All my family still lives there. I believe that the best option is the one that provides a way for both the ranchers and the Elk to co-exist as they are both important parts of the community. Placing the Elk in a contained area at Limatour would give them the grazing they need without impacting the ranchers ability to provide quality food for the local community as well as further areas. It seems like a win- win to me. Ranching does not take away from the beauty of the National Park but adds to it. PLEASE consider this the best option.
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# 2710
Name: N/A, N/A
Correspondence: Marin Counry farmers have been doing so for many generations which has proven to not be a threat to any wildlife or land. To create such chaos after a tradition which has taken place for hundreds of years is a disgrace to the farming community and the general population who consumes local food. Continue dairy farming in West Marin for the generations to come.
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# 2711
Name: Schlickman, Andrew
Correspondence: Nov. 15, 2017
Dear Superintendent,
Thank you for the opportunity to comment on the Point Reyes GMP Amendment process.
My Connection to Point Reyes
My name is Andrew Schlickman, and I live in Wheaton, Illinois. I have been visiting and exploring Point Reyes National Seashore since 1974. Since, then, I have visited Point Reyes at least 20 times. I have hiked many of the trails and beaches there, and I have witnessed abundant and diverse wildlife, including bobcat, Tule elk, sea lion, and harbor seal, and dozens of species of birds and waterfowl. I look forward to continuing to visit the park over the upcoming years.
have had many special experiences during my visits to Point Reyes. n 1976 I witnessed for the first time migrating whales in the ocean from the headlands above the lighthouse. n 2003 I kayaked Tomales Bay and paddled from Marshall to the beach at the mouth of White Gulch. We were accompanied by harbor seals, and we witnessed a herd of Tule elk at White Gulch. A few years later drove in the fog and wind along the road to Pierce Point Ranch. Out of the mist appeared dozens of Tule elk. Just two years ago, watched at sunset as a bobcat quietly crouched through a meadow looking for food, and then pounced on a rodent it trapped. will never forget these special moments, and the park should be managed in such a way that other visitors will have the opportunity to experience what I have seen and felt there.
My General comments on GMP Amendment Process
Since my first visit to Point Reyes, it has been my understanding that over time the ranching activities in the park would gradually be phased out. I recall being told by park personnel that the ranches would continue to exist for a reasonable and limited period of time as long as they continue to be owned, managed and operated by the families who were there when the park was established, but that they would not be there forever. I continue to be surprised that the ranches are still there - over 40 years after my first visit and almost 60 years after the park was first established. Point Reyes is a national park and should be treated like our other treasures in the national park system.
Ranching is a relatively new activity on Point Reyes, and NPS should be seeking to restore, preserve and make accessible to the public the environment and ecosystem that thrived on Point Reyes for the hundreds and thousands of years before European immigrants came to the area. The overall goal should be to restore the park, as much as possible, to the condition in which it existed before the mid-1800s. The ranching operations should be given a reasonable time frame in which to wind down, and the hardships on the families who continue to live and actively ranch in the Park should be minimized, but this should have been done during the first few decades after the Park was established, not 60 years later. Such a phase-out should now be a high priority.
My Specific comments on Amendment
I am surprised that there are management alternatives that would permit continued ranching activities in the park for more than just a few more years, and distressed to see alternatives that would allow the ranching activities to expand, and possibly to include activities beyond the traditional ranching activities existing at the time the park was established.
First alternative - No Ranching and Limited Management of Tule Elk
This is by far the most sensible and appropriate alternative. I am surprised it took a lawsuit to force NPS to include this alternative. It seems like an obvious one.
Second alternative - No Dairy Ranching and Management of Drakes Beach Tule Elk Herd
It make no sense to phase out dairy ranching and to continue to allow beef cattle ranching. The latter would continue to be a use of the park that is inconsistent with restoring the environment and ecosystem to it's pre-ranching condition.
While NPS claims it will "identify broad management strategies to preserve park resources, as well as indicators and standards to guide visitor carrying capacities," and "also identify additional compatible opportunities to improve the visitor experience in the planning area (e.g. enhanced trail connections, improved signage, and new interpretive waysides)," the bottom line is that ranching activities are fundamentally inconsistent with preserving park resources and improving the visitor experience. How can these goals be achieved when habitat is denied to the indigenous and wild species, and access to public land for visitors is restricted to protect the ranching activities?
For comments on the management of the Tule Elk herds, see separate section below.
Third Alternative - Reduced Ranching and Management of the Drakes Beach Tule Elk Herd
This alternative suffers from the same problems as the second.
Moreover, this alternative provides that leases and permits for ranching “would identify authorized measures for operational flexibility and diversification and establish programmatic approaches for streamlined implementation of best management practices.” What in the world does this mean? It seems like a way of saying “anything will go.” The NPS needs to be clearer and much more transparent about what it would consider allowing ranchers to do under this alternative (and the others that permit some sort of continued ranching) so the public fully understands the possible impacts.
Fourth alternative - Continued Ranching and Management of the Drakes Beach Tule Elk Herd (NPS Initial Proposal)
Frankly, I am shocked that this was the NPS' initial proposal. As set forth above, all ranching in the Park should be phased out on an expeditious time schedule.
Fifth alternative - Continued Ranching and Removal of the Drakes Beach Tule Elk Herd
This alternative suffers from the same problems as the other alternatives that would permit ranching to continue. Moreover, the Drakes Beach herd should not be removed (see discussion of Tule Elk heard management below).
Sixth alternative - Continue Current Management (No Action)
This alternative suffers from the same problems as the other alternatives that would permit continued ranching. Moreover, while it may sound benign - i.e., no action - the status quo is still fundamentally inconsistent with what should be the preferred approach - the first alternative.
Comments on Management of Tule Elk Herds
The Tule Elk lived on this land long before there was any ranching. Even though the elk had to be reintroduced, they are an integral part of the Park’s natural heritage and historic ecosystem. As ranching is phased out, Tule elk should be allowed to live as naturally as possible on the entirety of their original habitat (with some allowances made for visitor facilities). To the extent the herds cannot naturally be kept in balance (recognizing natural ebbs and flows) as a result of natural factors - weather, habitat, food, predation, etc. - some management techniques that would replicate an appropriate balance could be considered.
There will be a transitional period as ranching activities are phased out and the lands occupied by ranches are restored to their natural condition, but as the end of this transitional period is approached any artificial management of the herds should be minimal. In any event, there should be fuller discussions of what is meant by elk herd “management” as it is used in each of the alternatives.
It is surprising to me that the sub-section entitled “Tule Elk Management Activities” only addresses conflicts between the Tule elk herds and the ranching operations. Does this suggest that the NPS has already concluded that ranching will not be phased out? Why is there not a discussion of how the herd will be managed during the transitional period as ranching is phased out and what the management (or non-management) principles would be once there is no further ranching?
Conclusion
While I have expressed my views on what I believe should be the final outcomes of this process, I understand there are additional steps to be undertaken before final decisions are made. What strikes me about the GMP Amendment materials I have seen (the Amendment newsletter and the slide presentation for public meetings) is how inadequate they are for understanding what the NPS is thinking. Much of the language is so vague, opaque and ill-defined that it is not possible for a public commenter like me to understand fully what the NPS has in mind.
Nonetheless, based on what I understand, the first alternative is clearly the best of the six alternatives presented. As the other alternatives are fleshed out further, I have no doubt they will highlight the benefits of the first alternative.
Thank you for the opportunity to comment on this very important matter.
Andrew Schlickman
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# 2712
Name: N/A, N/A
Correspondence: Cynthia MacLeod, Acting Superintendent
Point Reyes National Seashore
National Park Service
1 Bear Valley Road
Point Reyes Station, CA 94956
RE: General Management Plan Amendment for Point Reyes National Seashore
Dear Ms. MacLeod:
I am writing to provide input on the General Management Plan Amendment for Point Reyes National Seashore (PRNS). I support the continued operation of beef and dairy ranching operations under agricultural lease/permits with 20-year terms and improved management of the Tule elk herds to eliminate negative impacts on the environment and ranching families.
Ranchers have been raising cattle in Point Reyes for more than 150-years. It was ranchers' willingness to sell their properties to the federal government that allowed the creation of the PRNS. As part of the agreement, ranchers were supposed to be allowed to continue ranching on their family ranches within the PRNS.
The ranches in West Marin contribute significantly to the local economy and the local culture. According to any analysis by U.C. Cooperative Extension in 2009, ranches in PRNS and Golden Gate National Recreation Area (GGNRA) directly provide approximately 65 jobs and provide livelihoods for an additional 25 ranch family members. Additionally, agriculture in PRNS and GGNRA account for 17 percent of the agricultural income in Marin County. These jobs and income would be lost if further restrictions were placed on ranches within PRNS. These ranches are not just creating economic value, they are producing high quality food appreciated by consumers locally, regionally, and nationally. Further, providing 20-year terms for lease/permits allows for greater investment in improvements on these ranches. Shorter terms prevent the ability of ranchers to obtain financing for improvements.
would also like to see improved management of the PRNS elk herds. Elk cause thousands of dollars of damages and lost forage on ranches. Additionally, the elk carry Johne’s disease, which can be transmitted to cattle. USDA estimates that lost productivity from Johne’s disease in dairy cattle could be costing dairy producers between $200 and $250 million annually. Elk in the PRNS were reintroduced by humans and have been managed since their reintroduction. PRNS must improve its management by maintaining the roaming elk herds on the Limantour wilderness and preventing them from damaging ranches in the area. Additionally, PRNS should ensure that there is proper forage and water available to the herd in the Limantour wilderness to prevent a reoccurrence of the unfortunate loss of elk during the drought.
Ranches on PRNS provide important economic, cultural, and ecological values to the local community. Losing a significant portion of West Marin’s agricultural community would mean not only a loss of local food production, but a significant loss to its economy and culture. I urge you to offer 20-year lease/permits to ranchers on PRNS and to improve elk management and return the elk to the wilderness areas where they will not impact the ranches.
___________________________
# 2713
Name: Meyer , Heather
Correspondence:
Dear Superintendent,
As a frequent visitor to the National Sea Shore, I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
Heather Meyer
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# 2714
Name: Miller, Jeff
Correspondence: PROTECT POINT REYES ELK AND WILDLIFE
Our 115 organizations from 30 states strongly support the management of Point Reyes National Seashore to protect its outstanding natural values and to provide for public recreation, benefit, and inspiration.
We support allowing free-roaming tule elk herds to remain at Point Reyes National Seashore, and object to any fencing, removal, hazing, sterilization, or killing of elk in the park. The General Management Plan amendment for Point Reyes National Seashore should prioritize restoration of the park's elk herds to historic numbers. There is immense public value to the native tule elk at Point Reyes, the only tule elk herds within the National Park system. Elk are an ecologically important part of the landscape of Point Reyes and their recovery is a success story for restoring native ecosystems, consistent with the mission of the National Park Service.
Commercial leases or activities in the park should not conflict or interfere with protection of natural resources or public uses. Commercial lease holders on our public lands in the park should not dictate wildlife removal or exclusion policies that harm park wildlife. Any cattle ranching operations in the park must be managed to accommodate elk and other native wildlife, and should not harm habitat for endangered species. Any ongoing cattle grazing leases must be managed in a way that does not damage ecosystems or negatively impact wildlife habitat, water quality, native vegetation, public recreation or the aesthetic beauty of the park.
We object to any conversion of Point Reyes National Seashore lands to row crops, which would degrade wildlife habitat and water quality in the park and prevent public access. We also oppose expansion of commercial livestock farming to introduce sheep, goats, pigs, turkeys or chickens, which would create conflicts with predators and pressure to kill bobcats, coyotes and foxes.
The National Park Service is charged with managing Point Reyes National Seashore in a manner which provides maximum protection, restoration, and preservation of the natural environment. The Park Service's amendment to the General Management Plan should prioritize protecting the native wildlife and natural values of Point Reyes National Seashore.
Sincerely,
Center for Biological Diversity
Randi Spivak, Public Lands Program Director
Washington, DC
Resource Renewal Institute
Deborah Moskowitz, President
Mill Valley, CA
Western Watersheds Project
Erik Molvar, Executive Director
Laramie, WY
Marin/Sonoma Organizations:
Animal Legal Defense Fund
Stephen Wells, Executive Director
Cotati, CA
Defense of Place
Nancy Graalman, Director
Mill Valley, CA
Fund for Wild Nature
Marnie Gaede, President
Sebastopol, CA
Golden West Women Flyfishers
Cindy Charles, Conservation Chairperson
San Rafael, CA
In Defense of Animals
Elliot M. Katz, Founder and President Emeritus
San Rafael, CA
Madrone Audubon Society
Susan Kirks, President
Santa Rosa, CA
Oceanic Preservation Society
Louie Psihoyos, Executive Director
Greenbrae, CA
Paula Lane Action Network
Susan Kirks, Board Member
Petaluma, CA
Sonoma County Wildlife Rescue
Desiree McGunagle, Volunteer & Community Support Coordinator
Petaluma, CA
Turtle Island Restoration Network
Todd Steiner, Executive Director
Olema, CA
WildCare
Vaughn Maurice, Executive Director
San Rafael, CA
Yellowbilled Tours
Richard Cimino
Larkspur, CA
Other Organizations:
350 New Orleans
Renate Heurich, Vice President
New Orleans, LA
Advocates for Snake Preservation
Melissa Amarello, Co-founder
Tucson, AZ
Alameda Creek Alliance
Jeff Miller, Director
Fremont, CA
All-Creatures.org
Veda Stram, Administrator
Athens, NY
Animals Are Sentient Beings
Sarah Stewart, President
Cambridge, MA
Basin and Range Watch
Laura Cunningham, Executive Director
Cima, CA
Blue Sphere Foundation
Candace Crespi, Campaigns Manager
New York, NY
California Water Impact Network
Carolee Krieger, President and Executive Director
Santa Barbara, CA
Cascadia Wildlands
Josh Laughlin, Executive Director
Eugene, OR
Citizens Coalition for a Safe Community
Paul Ferrazzi, Executive Director
Culver City, CA
Citizens Committee to Complete the Refuge
Carin High, Co-chair
Palo Alto, CA
Ciudadanos Del Karso
Abel Vale, President
San Juan, PR
Coastal Conservation League
Dana Beach, Executive Director
Charleston, SC
Committee for the Preservation of the Tule Elk
Bruce Keegan, Secretary
San Francisco, CA
Conservation Congress
Denise Boggs, Director
Chico, CA
Cool Planet
Paul Thompson, Co-founder and Co-Director
Edina, MN
Cumberland Chapter of Sierra Club
Tom Morris, Chapter Chair
Lexington, KY
Eastern Coyote/Coywolf Research
Jonathan Way, Founder
Osterville, MA
Ecologistics
Stacey Hunt, Chief Executive Officer
San Luis Obispo, CA
Endangered Habitats League
Dan Silver, Executive Director
Los Angeles, CA
Endangered Species Coalition
Leda Huta, Executive Director
Washington, DC
Environmental Protection Information Center (EPIC)
Tom Wheeler, Executive Director
Arcata, CA
Fairmont Minnesota Peace Group
Judi Poulson, Chair
Fairmont, MN
Farmworker Association of Florida
Jeannie Economos
Apopka, FL
Federation of Western Outdoor Clubs (42 Member Clubs and Organizations)
George Milne, President
Oak Grove, OR
Food & Water Watch
Wenonah Hauter, Executive Director
Washington, DC
Friends of Animals Wildlife Law Program
Michael Harris, Director
Denver, CO
Friends of Bell Smith Springs
Sam Stearns, Public Education Coordinator
Stonefort, IL
Friends of the Black-tail Prairie Dog
David Orr, President
Austin, TX
Friends of Del Norte
Joe Gillespie, President
Crescent City, CA
Friends of the Earth - US
Gary Graham Hughes, Senior California Advocacy Campaigner
Berkeley, CA
Friends of the Santa Clara River
Ron Bottorff, Chairman
Newbury Park, CA
GARDEN (Growing Alternative Resource Development and Enterprise Network)
Susan Silverman, Executive Director
Tucson, AZ
Global Justice Ecology Project
Ruddy Turnstone
Buffalo, NY
Golden Gate Audubon Society
Cindy Margulis, Executive Director
Berkeley, CA
Great Salt Lake Audubon
Heather Dove, President
Salt Lake City, UT
Green Peace Corps
Tom Thirion
Albuquerque, NM
Hilton Pond Center for Piedmont Natural History
Bill Hilton Jr., Executive Director
York, SC
Howling For Wolves
Maureen Hackett, President
Hopkins, MN
Idle No More SF Bay
Pennie Opal Plant, Co-founder
San Francisco, CA
Independent Environmental Conservation & Activism Network
Leslie Perrigo, Executive Director
Muncie, IN
inNative
David Jaber, Principal
Berkeley, CA
Interfaith Council for the Protection of Animals and Nature
Lewis Regenstein, President
Atlanta, GA
International Society for the Preservation of the Tropical Rainforest
Arnold Newman, Executive Director
Los Angeles, CA
Kettle Range Conservation Group
Timothy Coleman
Republic, WA
Kickapoo Peace Circle
Marcia Halligan
Viroqua, WI
Klamath Forest Alliance
Kimberly Baker, Executive Director
Orleans, CA
The Lands Council
Mike Petersen, Executive Director
Spokane, WA
Long Branch Environmental Education Center
Paul Gallimore, Director
Leicester, NC
Louisiana Bucket Brigade
Anne Rolfes, Founding Director
New Orleans, LA
Massachusetts Forest Watch
Chris Matera
Springfield, MA
Minnesota River Valley Audubon Chapter
Matthew Schaut, President
Bloomington, MN
Mission Peak Fly Anglers
Steve Schramm, Conservation Chair
Fremont, CA
Moloka'i Community Service Council
Karen Holt
Kaunakakai, HI
Monterey Coastkeeper
Steve Shimek, Executive Director and Founder
Monterey, CA
Mount Diablo Audubon Society
Nancy Wenninger, Conservation Chair
Walnut Creek, CA
National Whistleblower Center
Stephen M. Kohn, Executive Director
Washington, DC
National Wolfwatcher Coalition
Nancy Warren, Executive Director
Duluth, MN
Nature Abounds
Melinda Hughes, President
DuBois, PA
North County Watch
Susan Harvey, President
Templeton, CA
Northcoast Environmental Center
Larry Glass, Executive Director
Arcata, CA
Northeast Oregon Ecosystems
Wally Sykes, Co-founder
Joseph, OR
Northlake Unitarian Universalist Church
Rev. Jim VanderWeele
Kirkland, WA
Northwest Animal Rights Network
Rachel Bjork, Board Member
Seattle, WA
Northwest Arkansas Audubon Society
Carol Joan Patterson, Vice-President and Conservation Chair
Fayetteville, AR
Ocean Outfall Group
Joey Racano, Director
Los Osos, CA
Ohlone Audubon Society
William Hoppes, President
Hayward, CA
The Otter Project
Steve Shimek, Executive Director
Monterey, CA
Pacific Environment
Domenique Zuber, Advancement Director
San Francisco, CA
Pasadena Audubon Society
Laura Garrett, President
Pasadena, CA
Pelican Media
Judy Irving, Executive Director
San Francisco, CA
Prairie Rivers Network
Carol Hays, Executive Director
Champaign, IL
Predator Defense
Brooks Fahy, Executive Director
Eugene, OR
Public Lands Project
Mike Hudak, Director
Binghamton, NY
Rainier Audubon Society
Dan Streiffert, Conservation Chair
Auburn, WA
Raptors Are The Solution
Lisa Owens Viani, Director
Berkeley, CA
Regional Parks Association
Amelia Wilson, President
Berkeley, CA
RESTORE: The North Woods
Michael Kellett, Executive Director
Hallowell, ME
San Luis Obispo Coastkeeper
Gordon Hensley
San Luis Obispo, CA
Santa Cruz Climate Action Network
Pauline Seales, Organizer
Santa Cruz, CA
Save Our Shores
Katherine O'Dea, Executive Director
Santa Cruz, CA
Save Our Sky Blue Waters
Lori Andresen, President
Duluth MN
Save Richardson Grove Coalition
Barbara Kennedy, Campaign Coordinator
Weott, CA
Save The Frogs!
Kerry Kriger, Executive Director
Laguna Beach, CA
Seven Generations Ahead
Gary Cuneen, Executive Director
Oak Park, IL
Solar Wind Works
Chris Worcester
Truckee, CA
Spottswoode Estate Vineyard & Winery
Beth Novak Milliken, President
St. Helena, CA
Supporters for Del Norte Roosevelt Elk
Phoebe Lenhart
Crescent City, CA
Sustainability Leaders Network
Edie Farwell, Executive Director
Norwich, VT
Topanga Peace Alliance
Julie Levine, Co-Director
Topanga, CA
Wholly H2O
Elizabeth Dougherty, Director
Oakland, CA
Wild Horse Education
Laura Leigh, President
Reno, NV
Wild Nature Institute
Derek Lee, Principal Scientist
Concord, NH
Wild and Scenic Rivers
Alyssa Babin, Executive Director
Brookings, OR
Wildcoast
Zachary Plopper, Conservation Director
Imperial Beach, CA
WildEarth Guardians
Marla Fox, Rewilding Attorney
Portland, OR
Wilderness Watch
George Nickas, Executive Director
Missoula, MT
The Wildlands Conservancy
Dan York, Vice President
Oak Glen, CA
Wildlife Rehabilitation Center of Northern Utah
Buz Marthaler, Chairman and Co-Founder
Ogden, UT
The Wildlife Trust
Edward Loosli, President
Walnut Creek, CA
___________________________
# 2715
Name: Lloyd, Cynthia
Correspondence: Thank you for this opportunity to submit comments concerned the General Management Plan Amendment Newsletter. The six concepts presented in the Newsletter raise many questions. Without much more detailed information about best management practices (including the response of the agriculture sector in California to state mandated reductions in methane and CO2),the meaning of terms such as diversification, operational flexibility and visitor carrying capacities among many others are unclear. In the context of rapid changes in our climate along with rapid changes in technology to address these changes, it will be important to factor into the plan for the future some guidelines about expected changes and recommended responses to an uncertain future.
What criteria and processes are going to be developed to assess the various alternatives once they are more clearly defined? How will we be assured that the new plan moving forward guarantees the preservation of natural resources and the prevention of habitat degradation in the pastoral zone. In particular, with climate change bringing sea level rise, we have to expect that the pastoral zones bordering wilderness areas will be affected and this needs to be planned for.
Diversification is a troublesome concept particularly given my understanding that current regulations limit ranching to dairy and cattle. I would be strongly against diversification.
The tule elk are native to the sea shore and therefore part of the natural resources of the park, requiring the same level of consideration as the support and protection of other natural resources of the park.
The Point Reyes National Seashore is a national and international treasure and its careful management into the future is key to its preservation for future generations.As a Bay Area resident, I care deeply about the future of the National Seashore.
___________________________
# 2716
Name: Bonnie Tank, Douglas Haner and
Correspondence:
November 14, 2015
Cynthia MacLeod
Acting Superintendent
Point Reyes GMP Ammendment
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes Station, CA. 94956
We have been full time residents of Point Reyes Station for 13 years. We are both retired San Francisco teachers who brought over 250 elementary students to the Pt. Reyes National Seashore for overnight visits to the Clem Miller Environmental Ed Center. In addition we have coordinated a bi-annual volunteer trails maintenance program in the PRNS that has brought over 300 Returned Peace Corps Volunteers to work in the park.
We fully support the continuation of sustainable multigenerational farming and ranching in the pastoral zone of the Point Reyes National Seashore as originally authorized, that ensures the protection, restoration and preservation to the natural environment of the seashore.
We prefer the alternative of "Continued ranching and management of the Drakes Beach Tule Elk Herd"-NPS Initial Proposal” but only with the 4 additions listed below.
To support this alternative and to make it successful, we feel the following must be included in the plan:
1. The Tule Elk must be removed and relocated from the ranching lands to wilderness areas so they don't compete with the cattle for feed, risk the spread of diseases, or damage ranch property. The elk should be limited to the wilderness areas in the designated elk range near Limantour Beach. This would allow the public to view these beautiful animals and not cause conflicts with the ongoing ranching activities in the pastoral zone. The NPS needs to develop a plan for the containment of the elk and for the management of their population.
2. Twenty year rolling leases with automatic renewals every 5 years are necessary for ranchers to be able to plan and budget effectively and feel secure that there is a future for the next generations. Renewal would be contingent on annual compliance meetings with the Park Service to ensure proper stewardship of the land. The current 30 day cancellation clause for non-compliance should be retained to safeguard the NPS and the public.
3. Operational flexibility for the ranchers should be encouraged by the Park Service. This will encourage good stewardship of the land and allow them to implement best management practices through brush and weed control, stocking rates/density, water system improvements and fencing. This will ensure the preservation of sensitive habitats, protect the land and resources and help to improve the working landscape for future generations.
4. Educational opportunities should be maximized for helping the public understand the unique partnership between the NPS and the historical working ranches and dairies. The Visitor Center at Bear Valley should showcase best management practices and how the implementation of these benefit both the land and the working ranches.
The PRNS has the opportunity to embrace the uniqueness of a national park that can wisely balance the integration of our special natural resources with the benefits of our historic ranches and dairies. Thank you for your consideration of our comments and input as you continue to make these important decisions.
Doug Haner and Bonnie Tank
___________________________
# 2717
Name: pendleton, deborah
Correspondence: Please do all you can to save all wildlife!
___________________________
# 2718
Name: Johnson, Rachael R
Correspondence: I am writing to provide input on the General Management Plan Amendment for Point Reyes National Seashore (PRNS). I support the continued operation of beef and dairy ranching operations under agricultural lease/permits with 20-year terms and improved management of the Tule elk herds to eliminate negative impacts on the environment and ranching families.
Ranchers have been raising cattle in Point Reyes for more than 150-years. It was ranchers' willingness to sell their properties to the federal government that allowed the creation of the PRNS. As part of the agreement, ranchers were supposed to be allowed to continue ranching on their family ranches within the PRNS.
The ranches in West Marin contribute significantly to the local economy and the local culture. According to any analysis by U.C. Cooperative Extension in 2009, ranches in PRNS and Golden Gate National Recreation Area (GGNRA) directly provide approximately 65 jobs and provide livelihoods for an additional 25 ranch family members. Additionally, agriculture in PRNS and GGNRA account for 17 percent of the agricultural income in Marin County. These jobs and income would be lost if further restrictions were placed on ranches within PRNS. These ranches are not just creating economic value, they are producing high quality food appreciated by consumers locally, regionally, and nationally. Further, providing 20-year terms for lease/permits allows for greater investment in improvements on these ranches. Shorter terms prevent the ability of ranchers to obtain financing for improvements.
would also like to see improved management of the PRNS elk herds. Elk cause thousands of dollars of damages and lost forage on ranches. Additionally, the elk carry Johne’s disease, which can be transmitted to cattle. USDA estimates that lost productivity from Johne’s disease in dairy cattle could be costing dairy producers between $200 and $250 million annually. Elk in the PRNS were reintroduced by humans and have been managed since their reintroduction. PRNS must improve its management by maintaining the roaming elk herds on the Limantour wilderness and preventing them from damaging ranches in the area. Additionally, PRNS should ensure that there is proper forage and water available to the herd in the Limantour wilderness to prevent a reoccurrence of the unfortunate loss of elk during the drought.
Ranches on PRNS provide important economic, cultural, and ecological values to the local community. Losing a significant portion of West Marin’s agricultural community would mean not only a loss of local food production, but a significant loss to its economy and culture. I urge you to offer 20-year lease/permits to ranchers on PRNS and to improve elk management and return the elk to the wilderness areas where they will not impact the ranches.
___________________________
# 2719
Name: Molvar, Erik
Correspondence: November 15, 2017
GMP Amendment c/o Superintendent
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes Station, CA 94956
Submitted electronically via https://parkplanning.nps.gov/poregmpa
Dear Acting Superintendent MacLeod:
The following are the scoping comments of Western Watersheds Project on the Point Reyes National Seashore General Management Plan (GMP) Amendment. WWP members and supporters have lodge numerous complaints with us to the effect that commercial livestock grazing and associated operations have a major negative impact on their recreational experiences at Point Reyes National Seashore. Commercial livestock grazing cannot be reconciled with National Park Service mandates, and Point Reyes legislation, which requires your agency to manage these lands to protect, preserve, and restore ecological health and natural communities of plants and wildlife, and for the recreational use, enjoyment, and inspiration of the public. Commercial livestock operations have proven themselves fundamentally incompatible with healthy native ecosystems and optimal visitor use and enjoyment on Point Reyes National Seashore. For 55 years, private livestock operations have clung to leases on public lands which they sold, accepting generous taxpayer payments to relinquish. It is long past time for these operations to take those monies and use them to move their commercial operations to private lands outside Point Reyes National Seashore.
According to the National Park Service Organic Act of 1916, the mission of the National Park Service is to conserve the scenery and the natural and historic objects and the wild life therein [within the national parks] and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations. 16 U.S.C. § 1. This legislative mandate was further elucidated in a letter from Secretary of Interior Franklin K. Lane to National Park Service (NPS) Director Stephen Mather in 1918. This has been characterized in the legal scholarship of Ross (2013: 71) as follows:
The Lane letter, as it is known, lays the foundation for park management:
For the information of the public, an outline of the administrative policy to which the new Service will adhere may be announced. This policy is based on three broad principles: First that the national parks must be maintained in absolutely unimpaired form for the use of future generations as well as those of our own time; second, that they are set apart for the use, observation, health, and pleasure of the people; and third, that the national interest must dictate all decisions affecting public or private enterprise in the parks.
Every activity of the Service is subordinate to the duties imposed upon it to faithfully preserve the parks for posterity in essentially their natural state (emphasis added).
Thus, the Lane letter makes clear that the first and paramount principle of park management is non-impairment, and especially preservation of the natural conditions of parks.
This mandate is not currently beings implemented at Point Reyes National Seashore, and it is the legal obligation of the Park Service to ensure that the forthcoming General Management Plan guarantees that these principles are fully applied.
The Park Service may issue regulations that allow the agency to grant the privilege to graze livestock within a System unit, such as Point Reyes, but only when the use is not detrimental to the primary purpose for which that System unit was created. 54 U.S.C. § 102101(a)(2) (previous version at 16 U.S.C. § 3). Subsequently, the Park Service issued regulations in 1983 that prohibit livestock grazing for agricultural purposes within System units, unless a) specifically authorized by Federal statute, b) required under a reservation of rights, or c) designated as a necessary and integral part of a recreational activity or as required to maintain a historic scene. 36 C.F.R. § 2.60(a). These exceptions do not apply on Point Reyes National Seashore.
Point Reyes National Seashore (hereinafter PRNS) was established in 1962 by Public Law 87-657, the Point Reyes National Seashore Act (16 USC LXIll 459c) for "purposes of public recreation, benefit, and inspiration, a portion of the diminishing seashore of the United States that remains undeveloped." In 1976, legislation that amended the 1962 enabling act established a wilderness area and instructed the Secretary to administer the Point Reyes National Seashore "without impairment of its natural values, in a manner which provides for such recreational educational, historic preservation, interpretation, and scientific research opportunities as are consistent with, based upon, and supportive of the maximum protection, restoration, and preservation of the natural environment within the area."
The 1980 General Management Plan (GMP) called for the following: Restoration of historic natural conditions (such as reestablishment of tule elk) will continue to be implemented when such actions will not seriously diminish scenic and recreational values." The Park Service has failed to fully live up to this directive, particularly by extending grazing leases beyond the original terms of livestock grazing reservations put in place when private ranch lands were acquired into public ownership. We fully expect the new GMP to fully comply with the foregoing laws and regulations, and prioritize public recreation and enjoyment, as well as the restoration of native wildlife and native ecosystems.
Livestock Ranching is No Longer a Legitimate Use of Point Reyes National Seashore
Ranching was never intended to become a permanent, or even long-term, use of public lands on Point Reyes National Seashore. The Park Services 2006 Management Policies declare that the agency will phase out the commercial grazing of livestock whenever possible. 2006 NPS Management Polices § 4.4.4.1. These policies explain that the agency will only allow commercial grazing where it does not cause unacceptable impacts on park resources and values. Id. at § 8.6.8.2. Today, as will be discussed in detail in these comments, commercial livestock operations are causing multiple unacceptable impacts on National Seashore resources and values, and are in conflict with the Park Services multiple legal mandates to protect and preserve lands and native wildlife for the use and enjoyment of the public. The National Park Service (NPS) must fully analyze and disclose the extent to which livestock grazing operations are currently causing direct and cumulative impacts on native plant communities, native wildlife, public recreation and inspiration, water quality, and all other aspects of the human and natural environment of PRNS. Of currently extant ranching, only two operations are still operating under Reservation of Use and Occupancy (by right conferred in the original legislation), while the remaining ranch operations no longer possess Reservation of Use rights and are leasing federal lands on a temporary basis at the discretion of the NPS.
The Mexican government ceded the lands of Point Reyes into private ownership in 1832, and the introduction of longhorn cattle and horses began shortly thereafter (Gogan and Barrett 1986). Dairy ranching began in the area in 1858 (id.). By the time PRNS was established in 1962, there were 27 ranching operations within its bounds; by 1993, there were 7 dairy ranches and 6 beef and/or sheep ranches (Livingston 1993). Livestock operations currently cover 33,000 acres, about half of non-wilderness lands, and silage croplands have converted 950 acres of native grassland to non-native crop monoculture (Pawley and Lay 2013).
In 2012, Interior Secretary Salazar issued a memorandum illegally instructing the Park Service to extend 20-year leases to ranch operations, stating Because of the importance of sustainable agriculture on the pastoral lands within Point Reyes, I direct that you pursue extending permits for the ranchers within those pastoral lands to 20-year terms (DOI 2012). Because this memorandum contradicts the black-letter law established in 1962 and amended in 1976 by Congress for Point Reyes National Seashore, this memorandum is (and always has been) legally invalid. The extension of ranch leases for a 20-year period is particularly irresponsible, preventing NPS from removing livestock when major ecological or recreational conflicts develop. Even the Bureau and Land Management and Forest Service have maximum lease terms of 10 years, and the Forest Service applies Annual Operating Instructions which can alter stocking rates from year to year in response to drought, fire, or other stochastic events.
Congress has appropriated more than $50 million in taxpayer funds to be paid to the former owners of private ranchlands when Point Reyes National Seashore was established, and the private landowners took the money with the express understanding that their former lands would become part of the National Park system. In 1978, Congress permitted former owners of agricultural property within PRNS to obtain a reservation of use and occupancy for 25 years, or the life of the owner or spouse, as a condition to acquisition of the property into public ownership. Pub. L. No. 95-625, § 318(b), 92 Stat. 3487 (1978) (codified as amended at 16 U.S.C. § 459c-5(a)). Based on our current understanding, only two of these Reservations of Use and Occupancy remain in effect, of the 13 private ranch and dairy operations currently on PRNS.
We are concerned that commercial livestock grazing has multiple and severe impacts on the lands, vegetation communities, native wildlife, water quality, scenery, invasive weeds, natural smells and scents of PRNS, as outlined in further detail throughout these comments. In addition, please disclose the extent to which agricultural operations use wildlife killing and hazing, herbicides, fertilizers, rodenticides, and other commonly employed means and tools that degrade native ecosystems and water quality, potentially endanger National Seashore visitors, decrease or kill native plants, or kill, harm, or displace native wildlife.
In addition, we are concerned that public access to its own lands on PRNS is impaired in significant measure by agricultural operations. Visitors may feel, from a psychological standpoint, a natural reluctance to cross fences, travel through gates, or approach facilities constructed by or for the benefit of grazing lessees. In addition, we have received reports of public visitors being harassed or chased away by grazing lessees. The impact of livestock grazing operations on the free and unfettered access and enjoyment of PRNS by the public must be fully analyzed and disclosed in the forthcoming EIS.
Several of the abandoned ranches have become historical sites with NPS interpretive information. It has been suggested that at least one ranch be retained in working form on PRNS for educational or cultural value. However, there is no justification for maintaining even one working livestock operation on PRNS, as many working ranches and dairy operations will remain on private lands outside the bounds of the National Seashore (where they belong), and these farms and ranches readily fulfill this purpose already without further impinging on PRNS legal mandate to return the National Seashore to a natural and unimpaired condition.
In regard to silage fields, NPS should carefully consider the impact of silage operations on native ecosystems. Please disclose the impacts of outright removal of native plants, and how this is or is not allowable under the NPS Organic Act and the PRNS Act. Please disclose and fully evaluate the use of herbicides, insecticides, rodenticides, and fertilizers on silage on PRNS, and the degree to which these artificial chemicals affect native plants, animals, and ecosystems. Please assess the degree to which the use of such agricultural chemicals does or does not comply with NPS legal and regulatory standards applicable to PRNS.
In the forthcoming GMP, the Park Service must correct the errors of the past by abolishing the so-called Pastoral Zone and its emphasis on excluding, hazing, and/or removing tule elk and any other native wildlife.
Tule Elk
Tule elk are native to Point Reyes, but the ability of reintroduced populations to expand and reoccupy their native and natural range on PRNS has been frustrated by limitations and restrictions on their movements, primarily to benefit commercial livestock operations. The NPS has as part of its statutory requirements and past management commitments the obligation to return tule elk to all parts of PRNS, and we support expediting this process. According to NPS (1998: 4), Elk are an attraction for many who visit the area, and although visitors have never been surveyed on the subject, abundant experience from visitor comments and public meetings shows that the elk are a highly visible attraction that draws visitors to Tomales Point. Getting rid of commercial livestock operations on these public lands managed by the National Park Service is the first step toward restoring this elk population, and the native coastal grasslands upon which it depends, to health.
In 1976, Congress declared the protection and maintenance of Californias tule elk in a free and wild state is of educational, scientific, and esthetic value to the people of the United States and thus the restoration and conservation of a tule elk population in California of at least two thousand . . . is an appropriate national goal. 16 U.S.C. § 673(d); Pub. L. No. 94-389, 90 Stat. 1189 (1976). Congress required the NPS to develop a plan for tule elk. The agencys Tule Elk Management Plan (NPS 1998: 40) included a goal of attaining a free-ranging tule elk herd by 2005, stating:
Their limitation to Tomales Point is an historical artifact of their reintroduction onto an area bounded by. historic ranches and the intent to restrict their movements to a protected preserve. If they are to remain as part of the Seashore's fauna and ecological processes, they should eventually become free-ranging throughout most of the Seashore's natural zones where conditions allow.
This provision of the Tule Elk Management Plan has not been implemented, in large measure due to resistance by the small but highly vocal livestock industry that continues to lease public lands on PRNS.
McCullough (1969) projected that in 1850 approximately 500,000 tule elk roamed California. In the 1850s and 1860s, there was heavy market hunting of tule elk for the hide and tallow industry, and tule elk were extirpated on Point Reyes by 1862 (Gogan and Barrett 1986). By the late 1870s, only 10 individuals remained on Earth, in Kern County (Watt 2015), and this bottlenecked population became the seed source for all tule elk present in California today. According to McCullough et al. (1993: 25), Thus, individual tule elk are genetically quite similar and the entire population is inbred. According to NPS (1998: 39), The population of tule elk at Point Reyes' has been estimated to contain the lowest level of genetic variation (or heterozygosity) of all the herds in the state, based upon an analysis of translocations and bottlenecks (McCullough et al. 1996). This heterozygosity would be enhanced by removing the fence at Tomales Point and thereby allowing all tule elk on Point Reyes National Seashore to commingle and interbreed.
Cattle (both dairy and beef) are non-native species that compete for forage with elk, to the detriment of elk growth and reproduction. According to McCullough et al. (1993: 6), Early growth of the [Tomales Point] herd was slow due to over-utilization of the range by domestic cattle. This situation remains in the so-called Pastoral Zone, where cattle grazing continues to interfere with the expansion and recovery of tule elk. According to NPS (1998: 8)
Tule elk were eliminated from the Point Reyes area by the middle 1800s as agriculture, logging, and hunting took their toll. When plans to conserve tule elk statewide were being made, Point Reyes was discussed as a possible reintroduction site (Phillips 1976). Absent for over 150 years, elk were reintroduced at Point Reyes in 1978 with the transfer of 10 individuals from San Luis National Wildlife Refuge to Tomales Point. The erection of a three-mile-long fence across the peninsula from the Pacific Ocean to Tomales Bay isolated the herd from adjacent dairy ranches. This created a 2,600-acre enclosure that constitutes the current elk range in the Seashore.
The NPS, in the forthcoming EIS, must disclose any scientific basis for fencing a free-ranging elk population, and for maintaining an isolated elk population on such a small, constricted, and limited spatial area. This appears to be an unnatural and harmful practice that should be ended through the removal of the Tomales Point fence.
Livestock competes with native wildlife for habitat and forage, and indeed the best tule elk habitat on Point Reyes National Seashore shows a strong overlap with lands currently leased for agricultural purposes (see Figure 1). According to Cobb (2010: 70),
elk were observed avoiding pastures when cattle were present and cattle were seen chasing elk from pastures on multiple occasions. These observations were supported by concurrent GPS collar data that showed Pt. Reyes tule elk almost entirely avoided pastures occupied by cattle (unpublished data).
Since 2012, elk have been hazed away from high-value pastures (presumably for livestock producers) into adjacent areas not used for livestock grazing (NPS 2014). Ranchers have advocated keeping elk entirely out of the Pastoral Zone (see, e.g., NPS 2014), even though the Pastoral Zone is made up of National Seashore lands that are supposed to be managed for a return to natural conditions.
The Tomales Point elk herd, separated from the rest of PRNS by a tall, 3-mile-long fence, has ranged from 350 to 500 animals since 1998 (NPS 2016). Currently, in the Pastoral Zone, there are an estimated 95 elk in the D Ranch Herd and 110 animals in the Limantour Herd (NPS 2014). NPS needs to estimate the total carrying capacity of PRNS for tule elk in the absence of competition with non-native livestock and non-native cervids, as a baseline for estimating the current negative impacts of livestock grazing leasing and operations on tule elk.
WWP supports the elimination of livestock grazing through non-renewal as leases and reservations expire, the removal of all fences erected by the livestock industry or for the purpose of restricting the access of elk to the full extent of Point Reyes National Seashore, and the future management of elk through natural increase and population limitation in the absence of culling or contraception of any kind. The forthcoming EIS should fully investigate and disclose the extent to which fences have impaired the movements and health of tule elk, and require that any fences that remain for administrative purposes be built to maximize wildlife safety and passage. Tule elk roamed at will throughout Point Reyes prior to the arrival of human management, and native ecosystems were much healthier than they are today with the questionable benefit of humanitys interference.
Gogan (1986) projected that the carrying capacity of elk in this small, enclosed Tomales Point area is 140 animals. However, McCullough et al. (1993: 7) asserted that the carrying capacity derived by Gogan (140) was artificially low due to the prior impact of excessive cattle grazing, and postulated a carrying capacity of 346 animals. We are concerned that this number is below the Minimum Viable Population (MVP) size from genetic and ecological standpoints.
MVP from a genetic standpoint is an effective population size (Ne) of 50 breeding animals, subtracting subadults (as they are not genetically contributing to the breeding population) and then correcting for skewed sex ratios of breeding animals such that there is a 1:1 ratio between breeding males and breeding females. This is expressed by the following equation:
Ne = (4 x Nm x Nf)/(Nm Nf)
In the case of tule elk, one bull does virtually all the breeding with all of the cows in a given harem, leading to a highly-skewed sex ratio of breeding animals. Tule elk are harem breeders, with a single dominant bull copulating with most if not all of the females in his harem during the breeding season. The harem masters genetic contribution to the next generation far outweighs the genetic contribution of each individual cow. Using this example, if we have a breeding population of 100 tule elk (excluding subadults and non-breeders) with 96 breeding cows and 4 breeding bulls, the Ne for that population would be 15.4, far closer to the population of breeding bulls than to the population of breeding cows. It is important to note that this formula will yield misleading results if all members of each sex, rather than only the breeding animals, are input. Please include calculations of Ne for the tule elk population resulting from each alternative treatment analyzed in the forthcoming EIS, and provide analysis of how this compares to ecological and genetic MVP for the herd. Managing the herd for a resulting Ne size below 50 would be expected
Figure 1. Predicted relative probability of tule elk use within Point Reyes National Seashore using Resource Selection Function outputs from radio-telemetry data from 2005-2008 (reproduced from Cobb 2010).
(based on the best available science) in inbreeding depression, elevated presence of deleterious alleles in the remaining gene pool, and an increase in incidence of birth defects. This would render the decision vulnerable from a scientific and also a legal perspective.
We are also concerned that elk at Point Reyes may be suffering from dietary deficiencies as a result of their confinement in the small area of Tomales Point. Gogan et al. (1989) found that plants and soils at Tomales Point were deficient in copper (an essential trace element), molybdenum, and sulfur-sulfates, and that elk were showing gross signs of copper deficiency, which may have been a contributing factor in the death of two elk in Spring of 1979. Gogan et al (1988) reported antler deformities in elk on Tomales Point, which they related to copper deficiencies. Cobb (2010) found that the most common cause of death for tule elk at Point Reyes was starvation, often accompanied with copper and selenium deficiencies. Twelve soil types underlie PRNS, based on differences in parent rock (NPS 1998). One of these, the Sheridan-Baywood soil type, is associated with the Tomales Point area (id.), where copper deficiencies are known to occur. Removing the fence at Tomales Point and allowing elk free and unfettered access to all of PRNS permits elk to graze on vegetation growing from multiple geological substrates, thereby eliminating the specter of copper deficiencies and other dietary problems and disease vulnerabilities caused by confinement on Tomales Point.
According to NPS policy, The National Park Service will seek to perpetuate the native animal life as part of the natural ecosystems of parks. Management emphasis will be on minimizing human impacts on natural animal population dynamics. Specifically addressing the management of California tule elk, Public Law 94-389, Preservation of Tule. Elk Population-California in 1976 states that:
The Secretary of the Interior, the Secretary of Agriculture, and the Secretary of Defense shall cooperate with the State of California in making lands under their respective jurisdictions reasonably available for the preservation and grazing of tule elk in such manner and to such extent as may be consistent with Federal Law.
The agency currently is not living up to these policy and statutory requirements on PRNS, but can correct this deficiency by permitting tule elk full and unfettered access to all of PRNS.
We are concerned that elk limited to the Tomales Point enclosure lack adequate sources of water during dry periods. NPS (1998: 12) itself recognized this problem:
The peninsula of Tomales Point ranges from a narrow tip to over a mile and a half wide at the fence line enclosing the elk range. There are no natural year-round streams. The natural streams have significant flows only during the rainy winter months. From late spring to late autumn, only spring-fed seeps would provide water for elk if not for the existence of eight water impoundments originally built for cattle.
It has been reported that during the drought of 2012-2014, the Tomales Point elk herd declined by 47%, while over the same period the Limantour and Drakes Beach Herds increased by a combined 32% over the same period. In the forthcoming EIS, please present your analysis comparing the decline of elk in the Tomales Point Herd with corresponding population figures for the Drakes Beach and Limantour Herds, and provide scientific analysis of the role that water availability had in the decline of tule elk on Tomales Point. Removing the fence at Tomales Point and allowing the Tomales Point Herd full and unfettered access to all of PRNS would eliminate water scarcity problems that appear to have had a major negative effect on this herd in years past.
Shortly after the original reintroduction of tule elk in 1978, a number of subadults died from Johnes disease, or paratuberculosis, a disease they contracted from cattle (Watt 2015, Gogan and Barrett 1986, and see Gogan et al. 1989). As of 1993, the possibility that Johnes disease still infected the Tomales Point elk population was possible but unproven (McCullough et al. 1993).
We concur with the conclusions of the Point Reyes Scientific Advisory Panel (McCullough et al. 1993: 34):
The long-range goal of elk management at PRNS should be the re-establishment of free-ranging elk throughout the seashore and associated public lands. This would involve elimination of exotic cervids and removal of the fence across Tomales Point. NPS and CDFG should develop a long-range management plan with the goal of achieving a large, healthy, free-ranging elk population subjected to a minimum of management intervention.
Cobb (2010) projected that the greatest potential for elk population growth on Point Reyes was on ranchlands, and predicted increasing future conflicts. Phasing out domestic livestock on the National Seashore would eliminate this source of conflict.
The National Park Service should comply with its legal, regulatory, policy, and past planning mandates and remove all barriers to tule elk expansion and recolonization of all lands within PRNS. The expansion of elk herds to all of their former native range would provide the herbivory with which all native plant communities (including rare native plants) evolved, therefore optimizing the opportunity for native plant and ecosystem recovery. The forthcoming EIS should fully analyze the differences between native and non-native plants and communities (evaluating richness, diversity, and presence/absence of rare plants and exotic weeds), with field data gathered from representative sampling of lands with tule elk only, those areas with domestic livestock, and those areas lacking both tule elk and domestic livestock.
No elk population should be constrained in its population numbers or distribution within PRNS, and there are no scientifically defensible maximum population thresholds that can be legitimately applied on a scientific basis. Over time, all populations of tule elk should be permitted to expand and interbreed, and likewise, populations of blacktail deer should be permitted to expand in the absence of domestic livestock and other non-native herbivores.
Exotic Deer Species
Axis deer and English fallow deer were introduced to the area in the 1940s, and are known to be carriers of Johnes disease (McCullough et al 1993). As of 2003, there were estimated to be 860 fallow deer at Point Reyes (NPS 2006b) and an estimated 2006 axis deer population of 250 (NPS 2006a). At 2006 exotic deer levels, a 46% reduction of native black-tailed deer was estimated, with 900 fewer native deer present than ought to be supported (NPS 2006b). The 1999 Resource Management Plan (NPS 1999: 40) specified the following for non-native deer:
Due to the non-native nature of fallow and axis deer, and to the potential for forage competition with native deer and elk and disease transmission to them, a determination of the feasibility of complete removal of the fallow and axis deer should be undertaken. The issue of exotic deer management consumes a considerable amount of staff time that could
be devoted to other resource management needs. Removal of the exotic deer from the Seashore would reduce a continual burden on the small natural resources staff, improve a major component of the ecosystem, provide additional habitat for native ungulates, and eliminate the potential for disease transmission from these exotics to native deer and elk.
In 2006, NPS selected a management alternative for non-native deer to remove all axis and fallow deer from PRNS by 2021 (NPS 2006b). To the extent that these exotic species still occur on PRNS (see NPS 1998), they should be removed completely under the GMP Amendment by non-lethal means.
Native Predators
The wolf (Canis lupus) was originally native to Point Reyes, but has been extirpated for many years (NPS 1998). Today, California is being colonized by wolves, with a breeding population on the Lassen National Forest. The return of the wolf would be beneficial to re-establish natural predator-prey assemblages that include the tule elk, for which population control has been a thorny question for decades. However, the presence of domestic livestock on PRNS renders the return of the wolf a likely source of future conflict and controversy. This conflict and controversy is readily avoided by eliminating livestock grazing as holders of original grazing reservation privileges term out.
Agricultural Pollutant Runoff and Manure Spreading
Dairy and beef operations often entail concentrations of livestock that result in high outputs of urine and feces, which then have multiple impacts on the environment. On PRNS, livestock waste is leaking into wetlands, ponds, and streams, causing contamination and nutrient imbalances, and the spreading of manure causes a severe stench that impairs visitor enjoyment and inspiration, and disrupts native plant communities. According to USFWS (2002:3),
Milk cows are kept close to dairy headquarters. They produce large quantities of manure waste that must be managed to avoid pollution of nearby streams through excessive nutrient loading. Small pastures where cows are held between milking are typically scraped and the manure is stockpiled. On most dairies cows are kept in barns through winter. The barns, milking parlors, and travel corridors between them are cleaned by washing manure into holding ponds, where the manure slurry is stored during the wet season. During the dry season stored manure form the dairies is spread as fertilizer on rangelands and silage fields. Dairies dispose of accumulated manure by spreading it on fields from trucks or pumping it through pipes which drain waste onto fields.
This activity has potentially serious consequences for rare native plants:
Excessive feces and urine deposition within or adjacent to areas inhabited by the Sonoma alopecurus, the spineflower, beach layia, Tidestrom's lupine, Tiburon paintbrush, and Marin dwarf flax may alter habitat conditions by fertilizing the nutrient poor soils, thereby making colonization by invasive species easier, which could ultimately out-compete the paintbrush and/or dwarf flax. Alteration of the habitat conditions through deposition of nitrogen derivatives may also lead to the extirpation of the paintbrush and dwarf flax from the site due to their adaptation to survive only on serpentine soils.
(USFWS 2002:20). In addition, manure spreading could have serious impacts on red-legged frog habitats:
Excessive urine and fecal matter deposited by equine and other domestic animals may flow into the tributaries and stockponds. Nutrient loading associated with such runoff may result in alteration of pH, dissolved oxygen, excessive nitrogen, or pathogens which may adversely affect all lifestages of red-legged frogs.
(USFWS 2002: 22). The runoff of effluent from dairy operations into nearby streams, wetlands, and estuaries can (and has been known to) cause serious water pollution problems, including public safety hazards (see, e.g., NPS 2002, Pawley and Lay 2013). According to Pawley and Lay (2013: xl),
PORE [Point Reyes] and northern GOGA contain numerous ranches, dairies and pasture lands that contribute to water quality degradation through bacteria and nutrient loading from animal waste and runoff. Horse stables and corrals are also a source of elevated nutrients and failing septic system leach fields result in nutrient and pathogen loading in some areas (i.e., Lagunitas Creek in PORE).
More specifically,
Agricultural runoff from dairy and range animals, wildlife and failing septic systems contribute to high levels of fecal coliform recorded in tributaries during the rainy season. Over 50 percent of the samples collected from 1999 to 2005 exceeded 1 mg/L (1 part per million [ppm]) nitrate and the contact recreation criteria for fecal coliform (400 MPN/100 mL). Extremely high turbidity occurred along the mainstem and tributaries of Olema Creek. Almost one-fourth of the measurements by NPS in PORE exceeded the WRD screening criteria of 50 nephelometric turbidity units (NTU). (Pawley and Lay 2013: xliv).
Furthermore,
Tomales Bay, Drakes Estero and Abbotts Lagoon of PORE and northern GOGA exhibit high levels of fecal coliform loading following heavy rainfall from sources including wildlife and cattle on ranches and dairies. This often results in harvest closures for cultured shellfish and must be monitored closely during rainy winter months. (Pawley and Lay 2013: xlii).
Even dispersed livestock grazing on public lands has been found to cause major water pollution problems stemming from E. coli and other contaminants (Myers et al. 2017).
These factors also are contributing to declines of abalone species and kelp forests in adjacent marine environments (id.). In addition, pollutant levels have exceeded water quality objectives at Chicken Ranch Beach on Tomales Bay and at Kehoe Lagoon at Kehoe Beach. Thus, agricultural waste products are posing a health hazard for beachgoers at some parts of the National Seashore.
Finally, agricultural runoff and manure spreading impair the natural smells of PRNS, substituting the stench of urine and feces for the salt breezes, wildflower scents, and other natural smells of the environment. This constitutes impairment of visitor use and enjoyment of PRNS pursuant to the Organic Act and NPS Policy 2006 § 1.4.6. The forthcoming EIS must fully analyze and disclose the impacts of livestock wastes and disposal practices, and render determinations on whether these practices are lawful under the various statutory and regulatory mandates under which NPS must operate.
Myrtles Silverspot Butterfly
The Myrtles silverspot butterfly inhabits coastal dunes, coastal prairie, and coastal shrubland, feeding as adults on the nectar of a variety of wildflowers, and requiring western dog violet (Viola adunca) as a host to its caterpillars (USFWS 2002). We are concerned that livestock grazing suppresses the growth, vitality, and distribution of native flowering plants, and has therefore for years been impairing the viability of the Myrtles silverspot butterfly populations on Point Reyes National Seashore. The forthcoming EIS, as part of its NEPA hard look, should include field surveys of native flowering plants in pastures grazed by livestock and corresponding control areas where livestock are currently excluded, such that the magnitude of this negative effect on this endangered butterfly can be fully understood and disclosed. According to Launer et al. (1992: 140),
Viola adunca, the presumed larval hostplant, is patchily distributed through-out the region, and inhabits a range of biological communities, including grassland, scrub, and dune plant communities. The presence of Viola adunca, therefore, is not a reliable predictor of the presence of Myrtles silverspot butterflies. Determinations of habitat suitability must be based on multiple factors, including, but not limited to, distribution of larval hostplants.
NPS should map the spatial extent of this obligate violet species on PRNS, and determine the extent to which livestock grazing has any effect on this plants distribution and abundance. According to Launer et al. (1992: 136), At PRNS, Myrtles silverspot butterflies were found at the Tomales Point tule elk range and throughout the bluffs, hills, grasslands, and back-dunes west of Drakes Estero and Schooner Bay (Map 2). USFWS (2002) determined that livestock are likely to have significant negative effects on the Myrtles silverspot butterfly, and recommended remediation by reducing the number of cattle, moving fencing, and/or changing the grazing regime. According to USFWS (2002: 21),
Grazing activities within the habitat of the Myrtle's silverspot butterfly may result in trampling of eggs, larvae, and adults. Additionally, grazing within the habitat may result in destruction of host or nectar plants via consumption, trampling, soil compaction, erosion, and other deleterious effects. Conversely, grazing activities may assist in habitat maintenance by removing competitive vegetation and minimizing vegetative cover which could improve the ability of Myrtle's silverspot butterfly to detect host and nectar plants. The presence of cattle in dune areas does little to control the spread of invasive species such as ice plant and European beach grass. Point Reyes National Seashore has minimized the effects of grazing at some ranches by restricting access to dune habitats. However, cattle may be damaging Myrtle's silverspot butterfly habitat and limiting population expansion south of the Tule Elk Reserve (Launer et al. 1998, as cited in the biological assessment).
Pointing to the propensity for livestock grazing in back-dune communities to enhance the spread of invasive weeds, Launer et al. (1992: 143) said, In that these dune communities apparently provide nectar resources critical to the long-term persistence of Myrtles silverspot butterflies, programs of iceplant control and dune restoration
need to be initiated. Launer et al. (1992: 143), concluded:
Long-term persistence of Myrtles silverspot butterfly, however, is not guaranteed because the cumulative impacts of grazing (from both domestic livestock and tule elk), invasive alien plant species, and possibly the suppression of natural disturbances, are not well understood. The region- wide decline of the butterfly implies that such cumulative impacts have been significant and may eventually threaten the existence of the butterfly even at PRNS.
WWP and our members are concerned that the welfare of this rare species is currently being impaired by livestock grazing operations negatively affecting native flowering plants on PRNS. We are unconvinced that the spread of invasive weeds such as Italian thistle compensates for the loss or reduction of the native wildflowers, and would project that the elimination of cattle (and invasive thistles), paired with the recovery of native flowering plants, would result in a strong net benefit to the Myrtles silverspot. Please provide scientific analysis confirming or contesting this assertion in the forthcoming EIS.
California red-legged frog
The California red-legged frog is the largest western frog species, and is associated with pond, creek, and wetland habitats, typically associated with slow-moving water 2 feet deep or deeper (USFWS 2002b). It is a listed species under the Endangered Species Act. According to USFWS (2002: 17),
The grazing program is located within the proposed North San Francisco Bay/North Coast recovery unit which includes portions of watersheds at Point Reyes National Seashore and Golden Gate National Recreation Area. Within this recovery unit, red-legged frogs are threatened primarily by water management and diversions, non-native species, livestock, and urbanization.
The USFWS (2002b: 1) provided a synopsis of potential impacts to the species:
The California red-legged frog is threatened within its remaining range, by a wide variety of human impacts to its habitat, including urban encroachment, construction of reservoirs and water diversions, contaminants, agriculture, and livestock grazing. These activities can destroy, degrade, and fragment habitat.
According to USFWS (2002: 14), Accessability [sic] to sheltering habitat is essential for the survival of California red-legged frogs within a watershed, and can be a factor limiting frog population numbers and survival. Please provide a complete analysis on the impacts of livestock grazing and related operations on sheltering habitat for this species.
In general, the USFWS (2002: 21) found livestock grazing to be compatible with red-legged frogs, but observed the following potential impacts:
However, red-legged frogs may be killed or injured by livestock that may crush them in both aquatic and upland habitats. Livestock activity in stockponds or streams may mobilize sediments or contribute to erosion or deposition of sediments. If heavy sedimentation occurs in pools where red-legged frogs breed, it is possible that red-legged frog egg masses will suffocate from being buried under sediments. Heavy loss of sediments from the streambed may result in down-cutting of channels which could further degrade the stability of banks, and functions of the riparian ecosystem. Additionally, degradation of riparian habitat and functions may result in the colonization of exotic predators such as bullfrogs.
USFWS (2002b) pointed that red-legged frogs may use stock ponds created by ranching operations. However, In other areas, however, observations suggest that grazing activities pose a serious threat to the suitability of aquatic habitats for California red-legged frogs (id.: 21). This source includes a full catalog of the multiple impacts of livestock on this amphibian species, ranging from overgrazing and degradation of frog habitats to direct crushing of eggs and tadpoles and draining of ponds, dessicating egg masses. The forthcoming EIS must fully evaluate livestock impacts to red-legged frogs and their habitats.
Essential upland habitats include all lands within 300 feet from essential aquatic habitats, and essential dispersal habitats include those free of barriers connecting essential breeding habitats within 1.25 miles of each other (USFWS 2002). Red-legged frogs exist fluctuating populations within metapopulations, and have a high rate of reproduction, such that they often decrease markedly or are extirpated in a given locality, to be repopulated from neighboring habitats (USFWS 2002b). Indeed, Overall, populations are most likely to persist where multiple breeding areas are embedded within a matrix of habitats used for dispersal (USFWS 2002b: 12). Thus, it is extremely important to maintain connectivity habitats. The EIS must analyze the extent to which connectivity habitats are negatively impacted by livestock grazing, and provide measures to ensure that such connectivity habitats are maintained in the future with tall native vegetation to provide hiding cover for frogs as they disperse among wetland habitats.
Threatened Native Salmonid Species
Chinook and coho salmon as well as steelhead runs are found in the streams on PRNS, and each of these runs is listed as threatened under the Endangered Species Act due to past and ongoing human impacts on their habitats. As of 2004, steelhead had declined in abundance by 94% in the local region, while coho runs are extirpated in more than half of the regions streams that once supported them (NMFS 2004). According to NPS (2103: xliii),
The effects of past land use practices (development, logging, agriculture and grazing) have changed watershed conditions and reduced habitat for many aquatic invertebrates, fish and amphibians. Loss of native perennial vegetation, soil compaction and loss, hillside trailing, gullying and incision of swales and meadows have changed the runoff patterns and reduced the capacity of the watershed to attenuate pollutant loading and surface runoff to streams.
While the National Marine Fisheries Service downplayed the impacts of livestock grazing to anadromous salmonid runs, they noted a variety of types of negative impacts including increased stream temperatures, siltation of spawning gravels, and changes to stream morphology, and observed that 16% of spawning stream reaches were unfenced, giving livestock direct access to streambanks (NMFS 2004). According to NMFS (2004: 40),
NOAA Fisheries has directly observed a variety of stream reaches adjacent to grazing leases, including areas with and without riparian vegetation. Some of the adjacent stream reaches lack the habitat complexity needed for healthy juvenile salmonid rearing. Instream wood is largely absent. These conditions are locally limiting the amount of juvenile salmonids that survive to smolt age. These conditions also impact any adults that may migrate and spawn in these areas.
NMFS (2004: 41) concluded,
Once the NPS implements the actions described above, and continues resource monitoring and response, adverse effects to salmonids are expected to slowly reduce until in many cases they are mini mal and unlikely to result in take. However, there are potential long term impacts from the grazing lease program that could result in harm to listed salmonids.
NPS has estimated in the past that 16% of stream reaches occupied by native salmonids remain unfences and accessible to domestic livestock. We are concerned that, because cattle in particular concentrate their grazing impacts along riparian corridors and wallow in streamcourses, that continued livestock grazing on PRNS will continue to suppress the recovery of these listed fish species.
Cattle are known to have the following negative impacts on stream habitats occupied by salmonids: (1) Suppression and removal of streamside shrubs that stabilize streambanks and shade stream reaches. (2) Overgrazing of herbaceous vegetation, resulting in loss of overhanging cover used by juvenile salmonids. (3) Increased erosion and siltation of streams, resulting in increased turbidity as well as smothering of spawning gravels with silt that results in suffocation of salmonid eggs and alevin. (4) Wallowing in streams resulting in disturbance or displacement of spawning adults and the physical crushing of salmonid eggs and alevin in their redds. (5) Physical breakdown of streambanks, converting narrow, deep streams to wide, shallow streams with little hiding cover from overhanging banks. (6) Raising of water temperatures above thermal optima for salmonids, resulting in stress, retarding growth, or causing death. (7) loss of instream hiding cover as a result of factors 1, 2, and 5 above, resulting in unnaturally high levels of predation on adults and young from avian, aquatic, and/or terrestrial predators. Please provide detailed, current, science-based analyses of the extent to which current and future livestock use on PRNS are causing or contributing to each of these causes of habitat degradation or direct impact on salmonids. Please pay particular attention to impacts to Olema Creek and its tributaries, Lagunitas Creek and its tributaries, and the tributaries of Drakes Estero, in addition to estuarine habitats which may be important staging areas.
Western Snowy Plover
Western snowy plovers are a listed species that inhabits dunefield plant communities on Point Reyes National Seashore. They are vulnerable to negative effects from livestock grazing. According to USFWS (2002: 22),
Grazing activities within the habitat of the western snowy plover may adversely affect the animal via trampling individuals or crushing eggs. Presence of cattle within nesting areas may result in nest failure due to western snowy plovers being flushed from their nests for extended periods of time. For the most part, Point Reyes National Seashore has minimized the likelihood of such impacts by installing exclusion fencing in suitable habitat areas.
An increase in the number of ravens as result of ranching activities likely could lead to higher levels of predation on western snowy plovers by these corvids. Ravens are known predators or western snowy plover chicks and eggs (Roth et al. 1999). Ongoing research at Point Reyes National Seashore has documented the interrelationship between ranching activities and ravens. Specifically, ravens opportunistically feed upon left over grains, afterbirths, carcasses, and organisms killed or injured during silage harvest."
Coates et al. (2016) found that raven occurrence increased 45.8% in areas where livestock were present. Please provide detailed analysis that includes the extent to which livestock have access to habitats used by western snowy plovers, the comparative abundance of ravens in PRNS livestock pastures versus areas where livestock are absent, and the extent to which livestock are having a negative impact on snowy plover populations.
Impacts to Native Plants and Ecosystems
The Park Service has numerous statutory and management obligations to protect and restore native plant communities, and to prevent their continued impairment by livestock grazing, manure spreading, and other activities associated with private agricultural operations on public lands. Point Reyes National Seashore is home to a number of plant communities that are rare, unique, exemplary, or otherwise of very high ecological importance and therefore public value. According to Pawley and Lay (2013: 108),
Pristine coastal prairie, dominated by perennial bunchgrasses, is considered one of the most decimated ecosystems in California. Much of the native vegetation has been replaced by European Mediterranean region annual species that arrived with domestic cattle and their feed. Remaining native grasslands are threatened by disturbance and invasions by non-native plant species. ... Roughly 80% of PORE grasslands are currently dominated by non-native grasses (NPS 2004a); however some portions of the parks remain pristine.
Livestock grazing causes widespread damage through erosion and sedimentation. According to Pawley and Lay (2013: 56),
Grazing increases erosion by decreasing the amount of vegetation available to capture water, and by compacting the soil, thus deterring infiltration. This compaction increases runoff, which carries topsoil and sediments into the creeks. Riparian degradation also affects the hydrology of streams, enhancing flow during storms, which causes more flashy runoff patterns. The conversion of many areas to annual versus perennial bunch grasses may have reduced the capacity of the vegetation to hold soils during precipitation events.
According to USFWS (2002: 20),
Grazing activities in moderation within habitats for Sonoma alopecurus, the spineflower, beach layia, Tidestrom's lupine, Tiburon paintbrush, and Marin dwarf flax may be both adverse and beneficial in moderation. Specifically, grazing activities may result in trampling of individual plants, soil compaction, consumption, erosion, and impacts which may influence presence of invasive species. Trampling may reduce the plant's reproductive output by breaking immature inflorescence before fruit ripening. Alternatively, trampling may scarify seed present in the soil which would be beneficial to recruitment into the population. Soil compaction may affect the plant's rhizosphere, minimizing the uptake of nutrients. Additionally, soil compaction may reduce the ability for seeds to germinate. Overgrazing of foliage could limit the plant's ability to photosynthesize, which could result in death or diminished reproductive output. Consumption of inflorescence or seed could reduce the genetic variability of plants within a given population and could decrease the overall reproductive output of the individual plant. However, grazing may reduce competition from more abundant or invasive species. Erosion may result in burial of seed or individual plants, thus reducing the genetic variability of the population. Although seed banks may persist over time, germination of seeds may be subject to stochastic events which may occur over geologic time (such as shifting dunes).
Davis and Sherman (1992) found Sonoma spineflower in a grazed pasture, but showed declines in a grazing exclosure where non-native plants increased. Thus, grazing could in some cases be beneficial (although it is mysterious why the Sonoma spineflower is so rare in the face of heavy grazing across much of PRNS), either by cattle or elk. In addition, Remote feeding may concentrate cattle within habitat and result in excessive trampling or degradation of habitat (USFWS 2002: 21). The forthcoming EIS must fully analyze impacts of livestock operations on this and other rare native plant species, and craft and adopt an alternative that fully protects them, and allows the restoration of rare native plants on lands currently degraded by livestock operations.
Sonoma alopecurus
This grass species is listed as an endangered species, is known from only 16 populations, and grows in riparian stream communities (USFWS 2002). According to USFWS, Populations of this species are declining due to competition from nonnative plant species, trampling and grazing by cattle, and low regeneration (id., p. 6). That agency observed that both livestock grazing, and also exclosures (which sometimes became choked with blackberries) had had detrimental effects on the species. Subsequent studies found that no type of livestock grazing produced consistent, statistically significant positive results for this species (Ryan and Parsons 2015). The obvious solution is to remove the livestock, remove the fences, and let tule elk do the grazing, which they had done in a manner compatible with this species since time immemorial, prior to 1850.
Impacts to Fragile Dune Communities
We are concerned that livestock trampling and grazing has a disproportional impact in fragile dunefield plant communities, suppressing native plants, and encouraging the spread of invasive species such as iceplant. According to NPS (2015a: i), The Seashore preserves some of the last remaining high quality coastal dune habitat in the United States. The NPS has undertaken a program to begin to try to eradicate non-native weeds from diunefield communities (NPS 2015b). The USFWS (2002) found that livestock grazing is likely to have adverse effects on beach layia and Tidestroms lupine, listed species which inhabit these dunefield communities, and recommended exclusion of cattle from most dune habitats. Launer et al. (1992: 143) warned against livestock grazing in dune areas:
Unfortunately, managed grazing will not be a complete solution. In the back-dune areas, use of grazing to minimize the impacts of non-native species, particularly iceplant, will not be appropriate. It is unlikely that native plant species dwelling on the physically loose substrates of the dune areas would benefit from livestock, and such disruption could exacerbate the transition from native to non-native plant species.
NPS (2015b: 2) characterized the threats to rare native plants in dunefield habitats as follows:
These rare species and habitat types are imminently threatened by both physical and ecological changes associated with the presence and spread of European beachgrass and iceplant.
Any GMP Amendment must fully incorporate a moratorium on domestic livestock grazing in and near dune communities, and fully analyze all alternatives with regard to the potential impacts of livestock on these fragile ecosystems.
Invasive Weeds and Other Non-native Plants
Of the approximately 900 species of plants on Point Reyes National Seashore and Golden Gate National Recreation Area, approximately 300 are non-native invaders (Pawley and Lay 2013). Important among the non-native plants in Point Reyes National Seashore that are spread by livestock are Italian thistle (Carduus pycnocephalus) and milk thistle (Silybum marianum), which are known to increase with the presence of grazing (NPS 1998). Iceplant (Carpobrotus edulis) is invading dune habitats, and is known to have a negative impact on Tidestroms lupine and beach layia, both listed plants (USFWS 2002). According to Pawley and Lay (2013: 41), Manure spreading areas are correlated with the increased presence of invasive and noxious weed species. NPS must fully analyze the role of domestic livestock in introducing, spreading, and perpetuating infestations of invasive weeds, and has a legal obligation to select a final alternative that eliminates these non-native weed species to the greatest extent possible.
Farm and Ranch Operations on PRNS Should Not Be Expanded to Include Additional Commercial Activities
In general, the Park Service should not permit current lessee and reservation ranch operations to be expanded to include any new types of agricultural operations beyond what is currently permitted under lease terms. Permits for lodging or bed and breakfast operations (including AirBnB) within Point Reyes National Seashore should not be conveyed unless and until all livestock operations cease.
Helicopter Use in Wilderness
In the past, the National Park Service has suggested that the use of helicopters in wilderness might be desirable in the context of tule elk management (NPS 1998). However, the use of helicopters in wilderness associated with elk management is flatly illegal under the Wilderness Act. The Court has found above that the Forest Service violated NEPA and the Wilderness Act in approving the helicopter elk collaring project proposed by the IDFG. The IDFG also violated the terms of that approval by collaring wolves. Wilderness Watch v. Vilsack, Memorandum Decision, Slip Op., Case No. 4:16-CV-012-BLW, D. Ida. January 18, 2017. Thus, the GMP must by law preclude the use of helicopters for elk management in wilderness areas under the forthcoming GMP.
The Need to Prioritize Public Recreation, Not Private Livestock Operations
Point Reyes National Seashore was originally established in part for the purposes of public recreation, benefit, and inspiration. NPS must fully analyze the extent of livestock impacts to these National Seashore legal obligations, and also the extent to which further leasing of public lands on PRNS is incompatible with this primary mission of the NPS on this unit. By 2020, it is projected that more than 8 million people will live in the San Francisco Bay Area (Pawley and Lay 2013). As of the late 1990s, Point Reyes National Seashore was receiving more than 2.5 million visitors per year (Ferry and LaFayette 1997). The latest figures, from 2016, are consistent with this total. It beggars the imagination that NPS would even consider impairing the interests of millions of Americans on public lands they own, to extend the for-profit interests of a dozen or so families who have already accepted payment to give up their former lands.
The recreational uses and values highlighted in the organic legislation for PRNS are subject to the nonimpairment standard of the Park Services organic act. According to NPS policy,
The park resources and values that are subject to the no-impairment standard include
" the parks scenery, natural and historic objects, and wildlife, and the processes and conditions that sustain them, including, to the extent present in the park: the ecological, biological, and physical processes that created the park and continue to act upon it; scenic features; natural visibility, both in daytime and at night; natural landscapes; natural soundscapes and smells; water and air resources; soils; geological resources; paleontological resources; archeological resources; cultural landscapes; ethnographic resources; historic and prehistoric sites, structures, and objects; museum collections; and native plants and animals;
NPS Policy 2006 § 1.4.6.
Under Park Service regulation and policy, a GMP
is a broad umbrella document that sets the long-term goals for the park based on the foundation statement. The general management plan (1) clearly defi nes the desired natural and cultural resource conditions to be achieved and maintained over time; (2) clearly defines the necessary conditions for visitors to understand, enjoy, and appreciate the parks significant resources, and (3) identifies the kinds and levels of management activities, visitor use, and development that are appropriate for maintaining the desired conditions; and (4) identifies indicators and standards for maintaining the desired conditions.
2006 NPS Management Policies at 2.2. Further The purpose of each general management plan& will be to ensure that the park has a clearly defined direction for resource preservation and visitor use. 2006 NPS Management Policies at 2.3.1.
The Park Service must follow its policies that describe how the planning process should occur and what must be involved, which include the following requirements:
This basic foundation for decision-making will be developed by an interdisciplinary team, in consultation with relevant NPS offices, other federal and state agencies, local and tribal governments, other interested parties, and the general public. The management plans will be based on full and proper use of scientific and scholarly information related to existing and potential resource conditions, visitor experiences, environmental impacts, and relative costs of alternative courses of action.
The approved plan will create a realistic vision for the future, setting a direction for the park that takes into consideration the environmental and fi nancial impact of proposed facilities and programs and ensures that the final plan is achievable and sustainable. The plan will take the long view, which may project many years into the future, when dealing with the time frames of natural and cultural processes. The first phase of general management planning will be the development of the foundation statement. The plan will consider the park in its full ecological, scenic, and cultural contexts as a unit of the national park system and as part of a surrounding region. The general management plan will also establish a common management direction for all park divisions and districts. This integration will help avoid inadvertently creating new problems in one area while attempting to solve problems in another. 2006 NPS Management Policies at 2.3.1.
Each parks approved general management plan will include a map that delineates management zones or districts that correspond to a description of the desired resource and visitor experience conditions for each area of the park. Management zoning will outline the criteria for (or describe the kind of) appropriate uses and facilities necessary to support these desired conditions. For example, highly sensitive natural areas might tolerate little, if any, visitor use, while other areas might accommodate much higher levels of use. Even in historic structures, one floor might be most appropriate for exhibits, while another could accommodate offices or administrative uses. Some desired conditions may apply parkwide, but the delineation of management zones will illustrate where there are differences in intended resource conditions, visitor experiences, and management activities.
2006 NPS Management Policies at 2.3.1.2
The public has a strong interest in returning PRNS to a natural and pristine state, to maximize public enjoyment of rare native ecosystems and view native wildlife which livestock compete with and displace. According to NPS (1998: 27), Nature study and wildlife viewing are important activities at Point Reyes. These activities include viewing of whales and pinnipeds, visiting historic structures, enjoying spectacular views and a diversity of wildflowers including rare species, birdwatching, and beachgoing (NPS 1997). NPS must fully analyze the extent to which leasing for todays livestock operations fails to conserve areas currently leased for livestock grazing, and the degree to which further livestock and agricultural leasing fails to provide for the public enjoyment of scenery, historic objects and sites, natural landscapes, natural smells, and wildlife in areas where further leasing is contemplated in the future.
NPS has made past commitments to return PRNS to native ecosystems, for the use and enjoyment of visitors, as noted above. Point Reyes National Seashore has 147 miles of trails, and several designated wilderness areas (NPS 2003). But public access to and enjoyment of areas currently dedicated to pasturing livestock is lessened and impaired by the presence of livestock. In the forthcoming EIS, NPS must fully analyze, deeply examine, and publicly disclose ways and degrees to which leases for ranching or other agricultural uses fail to leave lands and resources unimpaired for the use and enjoyment of future generations.
Having undertaken such analysis (as Western Watersheds has already done), NPS will arrive at the inescapable conclusion that the only people benefiting from continued ranch leases on PRNS are the ranch operators themselves, and that the public interest has suffered and is continuing to suffer from an impairment of recreational use and enjoyment of the public lands at the hands of grazing lessees, across the full spectrum or recreational uses and users on PRNS. With this in mind, granting no further leases for livestock use on Point Reyes National Seashore, and allowing current livestock use to sunset as current leases and reservations expire, should be the Preferred Alternative under the forthcoming EIS.
The Importance of Analyzing the Legal Compliance of Each Alternative
NEPA provides that agencies should examine a full range of reasonable alternatives, including those beyond the agencys authority to implement. With this in mind, it is notable that several of the alternatives suggested by the NPS (2017) are not in compliance with the Park Service Organic Act or the Point Reyes National Seashore Act. It will be important for the agency to fully disclose for each alternative the compatibility of the proposed management in the alternative with the NPSs legal mandates.
The Park Service should not allow the extension of livestock grazing operations based on economic or social impacts to private, commercial facilities or operations. These commercial operations were fully compensated years ago for the fair-market value of their entire operations when they sold their lands and facilities to the federal government as part of the establishment of Point Reyes National Seashore. These operators have already been made whole, and no further economic consideration should be given to any economic claims on their part. These operators are free to take the enormous sums of taxpayer funding that they received in exchange for surrendering title to their former properties and vacating PRNS, and they remain free to take those funds and purchase private lands outside PRNS where they will be free to continue their livestock production operations (should they so choose) without the need to comply with Park Service requirements to return PRNS to a natural and ecologically healthy state, requirements with which their operations are (and always have been ) fundamentally incompatible.
The leasing of Point Reyes National Seashore to commercial livestock operations has been rife with violations of Park Service policies, overgrazing problems, water pollution, decimation of rare native plants and wildlife, conflicts with tule elk, and other issues that frustrate the publics recreation and enjoyment of PRNS and the NPSs ability to meet management objectives. For each remaining ranch operation, please list (by individual ranch or owner name) all ecological problems and legal and regulatory violations that have occurred associated with these operations.
NPS also is considering an alternative that would sunset dairy operations but switch them to beef cattle operations. While dairy operations entail high concentrations of livestock, beef cattle operations entail similar impacts, and therefore simply switching from dairy cows to beef cows accomplishes little in terms of ecological restoration or compliance with PRNS legal and regulatory mandates.
We are concerned that the proposed No Action alternative would continue ranching and dairy operations, presumably by further extending commercial leases for livestock on the National Seashore lands. This is not no action; no action would entail no further lease extensions and allowing leases to be closed as they expire.
The Park Service appears to be considering prescriptive grazing in certain areas to maintain rare native plant communities. There is no scientific evidence that livestock grazing can accomplish this in a superior way to grazing by tule elk, and indeed, grazing by tule elk and blacktail deer is what these native plant communities evolved with in the first place. Please provide any available analysis that indicates that grazing by non-native, exotic livestock would be superior to grazing by native ungulates to provide a scientific basis of support for prescriptive livestock grazing. If a definitive scientific justification cannot be made that domestic livestock are in some way necessary or superior to grazing by native herbivores, then prescriptive grazing should not be permitted.
Conclusions
Extension of ranching leases on Point Reyes National Seashore presents an ongoing violation of the national park impairment standards under statute, is incompatible with maintaining and restoring healthy native ecosystems, interferes with the recovery of healthy and natural populations of tule elk and numerous other rare and imperiled species of plants, wildlife, and fishes native to Point Reyes, and extends and continues unacceptable levels of impact on public recreation and visitor experiences. Each of the problems and conflicts elucidated in these comments is readily solved by the simple measure of sunsetting commercial livestock operations by declining to issue any new or extended leases for livestock operations on public lands. Waiting 5 years before phasing out livestock grazing entails illegal extension of livestock grazing leases, and should not be undertaken. As Reservations of Use and/or current existing agricultural leases term out, lessees can take the monies they received when they sold their lands to the National Park Service and make a fair transition to abundantly available private lands of their choice, which are better-suited to agricultural operations. Point Reyes is, and was always intended to be, a National Seashore, not a National Barnyard. Its time for the National Park Service to start managing these publicly owned lands with this priority, and the legal requirements that go along with it, in mind.
Thank you for providing the opportunity to provide input into setting the scope for the Point Reyes GMP Amendment. Please address each issue raised in the foregoing comments with detailed environmental analysis compliant with NEPAs hard look requirements, and please consider range of alternatives requirements in crafting and analyzing alternative GMP management scenarios. Please read carefully each scientific study and technical report referenced in the Literature Cited section of these comments, address each in the forthcoming EIS, and enter them into the administrative record for the GMP.
Please note that some formatting from these comments has been lost due to the lack of a simple file upload option in your comment solicitation forms. Please provide a file upload option in future comment processes. Please notify us of all future opportunities to participate in this planning process.
Respectfully yours,
/s/
Erik Molvar
Executive Director
Literature Cited
Coates P. S., B. E. Brussee, K. B. Howe, K. B. Gustafson, M. L. Casazza, and D. J. Delehanty. 2016. Landscape Characteristics and livestock presence influence common ravens: Relevance to greater sage-grouse conservation. Ecosphere 7(2): e01203.10.1002/ecs2.1203.
Cobb, M.A. 2010. Spatial Ecology and Population Dynamics of Tule Elk (Cervus elaphus nannodes) at Point Reyes National Seashore, California. PhD Diss., U. Calf. Berkeley, 202 pp.
Davis, L.H., and R.J Sherman. 1992. Ecological study of the rare Chorizanthe valida (Polygonaceae) at Point Reyes National Seashore, California. Madroño 39: 271-280.
DOI. 2012. Memorandum from Secretary Ken Salazar to Director, National Park Service regarding Point Reyes National Seashore - Drakes Bay Oyster Company, Nov. 29, 2012.
Ferry, D., and C. LaFayette. 1997. Point Reyes National Seashore Visitor Use Survey. Sonoma State Univ., 59 pp.
Gogan, P.J.P. 1986. Ecology of the tule elk range, Point Reyes National Seashore. PhD. Diss., Univ. of California, Berkeley.
Gogan, P.J.P., and R.H. Barrett. 1986. Tule Elk at Point Reyes National Seashore. Pp. 32-81 in Proc. Of the Conf. on Science in the National Parks, Fort Collins, CO, July 13-18, 1986.
Gogan, P.J.P., D.A. Jessup, and R.H. Barrett. 1988. Antler anomalies in tule elk. J. Wildl. Dis. 24: 656-662.
Gogan, P.J.P., D.A. Jessup, and M. Akeson. 1989. Copper deficiency in tule elk at Point Reyes, California. J. Range Manage. 42: 233-238.
Launer, A.E., D.D. Murphy, J.M. Hoekstra, and H.R. Sparrow. 1992. The endangered Myrtle's silverspot butterfly: present status and initial conservation planning. J. of Res. Lep. 31 (1-2): 132-146.
Livingston, D.S. 1993. Ranching on the Point Reyes Peninsula: A history of the dairy and beef ranches within Point Reyes National Seashore, 1834-1992. National Park Service Historic Resource Study, 544 pp.
McCullough, D.R., R.A. Garrot, J.F. Kirkpatrick, E.D. Ploka, K.D. Ralls, and E.T. Thorne. 1993. Report of the Scientific Advisory Panel on control of tule elk on Point Reyes National Seashore. Final Report, October 18, 1993, 39 pp.
Myers, L., M. Fiske, and M. Layhee. 2017. Elevated stream pathogenic indicator bacteria concentrations in livestock grazing areas across a single national forest. Natural Resources 8: 657-670. https://doi.org/10.4236/nr.2017.810042.
NMFS. 2004. Biological Opinion: The Continued Issuance of Grazing leases at Point Reyes National Seashore and the Golden Gate National Recreation Area in Marin County, California.
NPS. 1997. Headlands Area Draft Interim Visitor Management Plan and Environmental Assessment.
NPS. 1998. Point Reyes National Seashore Tule Elk Management Plan and Environmental Assessment.
NPS. 2002. Finding of No Significant Impact (FONSI): McClure Dairy Barn and Resource Enhancement Project.
NPS. 2003. Trail Inventory and Condition Assessment with Recommendations: Point Reyes National Seashore and the North District of Golden Gate National Recreation Area.
NPS. 2006a. Point Reyes National Seashore Non-Native Deer Management Plan: Protecting the Seashores Native Ecosystems, Final Environmental Impact Statement, July 2006.
NPS. 2006b. Record of Decision, Final Non-Native Deer Management Plan Environmental Impact Statement, Point Reyes National Seashore, Marin County, California.
NPS. 2014 Ranch CMP Tule Elk Workshop, PowerPoint presentation.
NPS. 2015a. Coastal Dune Restoration Environmental Assessment.
NPS. 2015b. Finding of No Significant Impact (FONSI): Coastal Dune Restoration EA.
NPS. 2016. Tule elk at Tomales Point FAQ.
Pawley, A. and M. Lay. 2013. Coastal watershed assessment for Golden Gate National Recreation Area and Point Reyes National Seashore. Natural Resource Report NPS/PWR/NRR-2013/641. National Park Service, Fort Collins, Colorado.
Ross, M.N. 2013. The Requirement to Leave Park Resources and Values Unimpaired. George Wright Forum 30: 67-84.
Ryan, A., and L. Parsons. 2015. Improving habitat management for Sonoma alopecurus: Developing the Optimal grazing regime. National Park Service, unpubl. rep., Grant Project: MO #4500035592; NPS Agreement #G8530120004, 17 pp.
USFWS. 2002. Formal Consultation on the Grazing Permit Renewal Program, Point Reyes National Seashore and the Golden Gate National Recreation Area, Marin County, California.
Watt, L.A. 2015. The Continuously Managed Wild: Tule Elk at Point Reyes National Seashore. J. Intl. Wildl. Law and Policy 18: 289-308.
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# 2720
Name: Despina, Eleanore
Correspondence: I see many values in preserving the ranches in the Point Reyes National Seashore. Here are they ways that I believe the ranches to be central to our local economy:
1. The Seashore ranches contribute to the critical mass that makes ranching in Marin County feasible: The Seashore ranches are 17 to 20% of Marin County ranching, in both acreage and production, according to the Marin Economic Forum's 2005 Targeted Industry Study.
Without a large number of ranches, services such as feed mills, feed stores, farm supply stores, and milk trucks for dairy ranches, cannot continue to serve West Marin. So, the loss of the Seashore Ranches could destroy the agricultural economy in our community - permanently changing the nature of the county from agricultural to suburban. For example, I understand that Dairymen's Feed must mill 8,000 tons per month to break even. They are about at that point right now, and any decrease in customers could cause their demise. I'm sure this is not an isolated case. There would be a similar impact on ranch-related businesses in both Marin and Sonoma Counties. Ranches should have 20 year leases and options to renew, so that ranchers can borrow to upgrade their operations, making them more sustainable and better stewards of the land, in terms of improved pasture and the resulting carbon sequestration.
2. The Seashore ranches contribute to the small farming culture that is so traditional and historic in our county and country - not only because there are ranches in the Seashore, but because these support ranches in our county and Sonoma County. If our small ranches fail, those in MALT have no option but to sell to large agricultural entities - corporate farming, with its disregard for the health of the land. Isn't part of the Seashore's mandate to demonstrate how ranching was carried on historically? There are now few places in this country where the public can see how ranching works. With both its beauty and its warts, ranching supplies us all with the food we eat, and we should know where that food comes from. I think the Visitor's Center should focus more on local agriculture.
3. Impact on ranch worker families. This is a central concern for me. I've not yet had time to research the number of persons impacted by a potential closing of Seashore ranches, but there are many, many families who rely on the ranches for work, housing - a livelihood and a life. The displacement of these families would cause havoc for them. Further, their displacement would be one more economic and social nail in the coffin for this community. These people buy their groceries locally, bank locally, and send their children - at least 50 - to our local schools. This population is crucial to the funding of the schools, which depends on student numbers.
4. Elk. Without major predators, a healthy elk herd is difficult to sustain. The elk appear to be incompatible with the West Marin landscape at this point in history. We have returned the elk, but not to their native habitat, which is long gone. I am uncertain that the elk can ever be healthy here, even if there were no ranches. The elk herd has certainly been shown to be incompatible with the Seashore in its current manifestation, and I believe that preserving our agricultural community is a higher goal than grazing three hundred elk on these lands.
This is what I have for now. I expect to comment further as the Park refines and provides details of its Alternatives. Thank you for your attention to these comments.
Sincerely,
Eleanore Despina
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# 2721
Name: Starritt, Jeanine
Correspondence: Point Reyes is a treasure and, I believe, should be managed to accommodate the current uses. The Tule Elk are an important part of this resource. I strongly oppose containment behind the fence, or culling. I believe the herd must be managed, perhaps by birth control methods. However I also believe in preserving the historic farms. I spend time at PR on regular basis and notice the many muddy trampled areas. More like feed lots than grazing areas. I believe there are too many domestic animals per acre,and this should be better managed. l think other uses, such as organic farming should be allowed to give the next generation of residents more options than dairy.
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# 2722
Name: Hunting, Kathy L
Correspondence: November 15, 2017
Cynthia MacLeod
Acting Superintendent
Point Reyes GMP Amendment
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes Station, CA 94956
Subject: First Phase Comments for the Point Reyes National Seashore General Management Plan Amendment
Dear Acting Superintendent MacLeod,
I am a resident of Point Reyes Station, CA and appreciate the opportunity to comment for this first phase of the General Management Plan Amendment planning process. I believe that agricultural production in the Point Reyes National Seashore contributes vitally to our community, and especially to our local economy. The ranches and dairy farms also enhance the educational experiences of our many local visitors. I wish to raise three issues that must be considered by the Park in its Environmental Impact Statement and decision-making process.
" The 2016 Marin County Crop Report notes that agriculture in the Park represents $18.3MM (19%) of Marins total $96.5MM gross production value. The no- or reduced-ranching alternatives must consider the direct impact of this substantial economic loss. It must also analyze the indirect economic and cultural impacts from prospective removal of ranches. Chief among these could be displacement of ranch families in our region where affordable housing is scarce. Farm jobs would disappear, and in turn the impact could also ripple out and negatively impact other local businesses.
" If ranching is eliminated or reduced, how would the Park control the invasive plants that would undoubtedly increase without the agricultural management currently provided by ranching? And would the Park have the resources to control these additional invasive plants, beyond the already-considerable resources it already invests? A thorough environmental and cost analysis must be conducted to show how much it would cost the Park to manage these lands in the case of reduced- or no-ranching alternatives.
" A thorough economic and environmental analysis needs to be done to understand, under the Tule elk management alternatives, where the herd would be moved to avoid the current and historical conflicts with ranches. Also, how would the Park pay for the significant costs of management or removal?
I love our Park; it greatly enhances my life as a full-time local resident. I also support our local ranchers and the many benefits they bring to our West Marin communities. I hope that the Park can find a balance that integrates the benefits of our dairies and ranches with the natural resources and value of the Point Reyes National Seashore.
Thank you for this opportunity to offer input to this phase of the General Management Plan.
Kathy Hunting
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# 2723
Name: meral, Jerry h
Correspondence: Please make this letter part of the official record regarding the preparation of the GMP amendment.
Here are several things to consider in preparing the ranch plan.
1. The spread of weeds into the Seashore should not be made worse by the importation of livestock feed that contains weed seeds. Ranchers should be required to purchase only feed that is free of weed seeds. Any seed imported into the Seashore should also be free of weed seeds.
2. Marshall Beach Road is the only unpaved road that is frequently used by both the public (to access Marshall Beach) and ranchers (L Ranch). That road is frequently a washboarded mess until the L Ranch turnoff due to heavy use by milk trucks. The Ranch Plan should include paving the Marshall Beach Road at least to the L Ranch turnoff to prevent erosion and degradation of water quality, and a diminished visitor experience.
3. The Plan must include specific compliance with the migratory bird treaty act. The Plan should prohibit mowing of silage and other crop harvesting until the end of bird nesting season, or at least require a survey of prospective mowing sites for nesting birds before mowing. If birds are nesting, mowing must be postponed.
For example, in recent years mowing near Abbott's Lagoon for silage resulted in the destruction of nests of a colony of grasshopper sparrows. This is a species of concern in California, and is migratory throughout North America, so it is covered by the migratory bird treaty act.
4. The amount of cultivation in the Seashore in a given year should be limited. Ranchers should not be allowed unlimited cultivation. An overall acreage should be determined, limiting impacts to native species. The allocated acreage would then be distributed to ranchers who wish to undertake cultivation.
5. One element that should be considered in all options is gasification of manure from dairies. The present practice of spreading it in fields may cause several bad effects:
Odor problems in the Seashore, over Tomales Bay, and in residential neighborhoods near the Seahshore
Disruption of the ecology of the fields, including impacts on mirgratory birds protected by the mirgratory bird treaty act
Water quality degradation of Abbotts Lagoon, Kehoe Creek, nearshore coastal waters and other wetlands and waters of the Seashore.
Visitors in the pastoral zone are forced to wade through cow manure if they want to walk the fields.
6. No diversification into field or vegetable crops should be allowed. Only crops needed for ranch or dairy purposes should be allowed.
Thank you for considering these requests. I look forward to reading the Park’s response in forthcoming documents. Please be sure our organization is on the list of parties to receive all documents relating to the Ranch Plan.
Best regards,
Jerry Meral, Ph.D.
Director, California Water Program, Natural Heritage Institute
415-717-8412
PO 1103 Inverness, CA 94937
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# 2724
Name: Livingston, Robin
Correspondence: I support the NPS Initial Proposal:
Continued Ranching and Management of the Drakes Beach Tule Elk Herd
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# 2725
Name: Mitchell, Bridger
Correspondence: November 15, 2017
Cynthia MacLeod, Acting Superintendent
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes, CA 94956
RE: Comments on General Management Plan Amendment Newsletter
Dear Acting Superintendent MacLeod,
Thank you for the opportunity to submit comments concerning the General Management Plan Amendment (GMPA) Newsletter. I understand the six concepts presented in the GMPA Newsletter mark the commencement of a process intended to engage public feedback and ideas, a process that, at this time, is deficient in definitions, baselines, and scope. I understand that the public is not limited or constrained by the conceptual alternatives and should use this comment period to seek clarification, question the conceptual choices, and present information that is missing. I submit the following comments.
Climate Change
It's imperative that the GMPA anticipate and plan for climate. This process focuses on where ranching activities will occur within the pastoral zone of the Seashore and in ranching lands within the Golden Gate National Recreational Area (GGNRA). Does this planning process take into consideration the best available science to understand where sea-level rise will impact park resources? By drawing lines where ranching activities can occur today, do those lines consider where and when marine wilderness areas may migrate further into the current pastoral zone?
Protection of Natural Resources
The GMPA should protect, restore, and preserve park resources using ranch leases that ensure that multi-generational, environmentally sustainable ranching is complementary to the natural resources and visitor experiences within the park. Guided by the NPS management policies, what criteria and processes will the Point Reyes National Seashore (Seashore) utilize to ensure the preservation of natural resources and the prevention of habitat degradation?
Diversification
What does "diversification" mean, and what impacts this will different types of diversification have on park resources in the pastoral zone. My understanding is that ranching in the Seashore is for dairy and cattle ranching purposes as outlined by the enabling legislation. How is the Seashore making decisions to potentially expand the land use from dairy and cattle ranching, and how will those changes impact the natural and cultural resources of the park?
Tule Elk
The Seashore is the only national park with a native population of tule elk that existed for thousands of years before they were hunted out of their natural habitats. The tule elk should be managed just like the Seashore’s other natural resources. I am concerned that the proposed concepts all mention managing the elk, but a definition and strategies of management are not included. How will the elk be managed? Will the management methods align with other natural resource management strategies?
Thank you for the opportunity to submit my comments.
Best regards,
Bridger Mitchell
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# 2726
Name: Jackson, G
Correspondence: I'd prefer no change be made. Ranching is part of Marin County history.
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# 2727
Name: Linn, Anne
Correspondence: Dear NPS,
Thank you for giving me the opportunity to comment on the General Management Plan Amendment for Point Reyes National Seashore.
Although the Vice Chair of the City of Goleta, California Parks and Recreation Commission, I am commenting as a member of the public who visits and enjoys the amenities of Point Reyes and has observed and experienced the park fully as a hiker and kayaker.
Please adopt the NO RANCHING alternative, eliminating all discretionary operations.
The current ranching operations that the public must drive through to visit the park are dirty, poorly maintained and polluting to air, land and water. These eyesore ranching operations do not enhance the park in any way and appear to be extremely insensitive to the priorities of a beautiful national park: maintenance of the environmental values and service to the visiting public.
I look forward to the day when tule elk freely roam the entire peninsula, the rangelands have been restored to their nature state and we can visit museums to see what ranching there was like. We have lots of ranches, but very few National Seashores.
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# 2728
Name: N/A, N/A
Correspondence: Dear Superintendent,
I am writing in support of the free-roaming Tule elk herds at Point Reyes National Seashore. They don't have the ability to defend themselves against human insanity but I sure do. My voice is their voice and I'm using it to object to any fencing, removal, sterilization or killing of elk in the park.
The Tule elk recovery process has been a success story and putting an end to this story is a truly sickening display of how much some people care nothing for the natural world. Public lands by definition should be "open to all persons."
I am fully aware that cattle ranching and farming are needed to feed the community but that doesn't mean these operations get to dictate how PUBLIC lands are used. There are ways for commercial operations and wildlife to exist peacefully, it takes some ingenuity and serious conversations which I know for some people can be a daunting task but it needs to be figured out.
The mission of the National Park Service, as listed on your own site, is as follows:
"The National Park Service preserves unimpaired the natural and cultural resources and values of the National Park System for the enjoyment, education, and inspiration of this and future generations. The Park Service cooperates with partners to extend the benefits of natural and cultural resource conservation and outdoor recreation throughout this country and the world." I wanted to remind you of that as it seems like the new directive of the NPS is very much going against its own purpose for being. Prioritizing the protection of natural areas should be first and foremost, not an afterthought.
I don't know if you've ever been to Point Reyes so I'm going to tell you about a very powerful experience I had while hiking there one foggy morning. My boyfriend and I headed out on the Tomales Point Trail that morning and could barely see the trail ahead of us never mind off to the sides where we heard the Tule elk calling out to each other. Their bugling is eerie under normal circumstances and even more so when you can't see them through the fog. Upon hearing the sound we both stopped to appreciate the moment we were given. We continued on and out of the fog we started to see a dark shape materialize out of nowhere. A couple of the elk were making their way down the hill and across the trail to the other side to graze. The elk were just as surprised to see us as we were to see them as the fog hindered all visibility. Not wanting to scare the elk we stayed back to respect their space and waited until they passed to the other side. Before completely clearing the trail one of them spotted us, saw that we weren't a threat, and continued grazing. To be acknowledged in such a way by a majestic creature is an experience like no other. To honor that special moment I got a tattoo of a stag with magnificent antlers that provides me with a daily reminder that nature is both strong and fragile.
The lands that are designated as National Parks are treasures not to be squandered to the highest bidder. I urge you to remind yourself of the NPS mission and the real reason for your existence. I feel blessed to be able to access such natural beauty and can relate to Theodore Roosevelt when he said, "There are no words that can tell the hidden spirit of the wilderness, that can reveal its mystery, its melancholy, and its charm."
Sincerely,
Carree Michel
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# 2729
Name: Martin, Barbara
Correspondence: Cynthia MacLeod, Acting Superintendent
Point Reyes National Seashore
National Park Service
1 Bear Valley Road
Point Reyes Station, CA 94956
RE: General Management Plan Amendment for Point Reyes National Seashore
Dear Ms. MacLeod:
I am writing to provide input on the General Management Plan Amendment for Point Reyes National Seashore (PRNS). I support the continued operation of beef and dairy ranching operations under agricultural lease/permits with 20-year terms and improved management of the Tule elk herds to eliminate negative impacts on the environment and ranching families.
Ranchers have been raising cattle in Point Reyes for more than 150-years. It was ranchers' willingness to sell their properties to the federal government that allowed the creation of the PRNS. As part of the agreement, ranchers were supposed to be allowed to continue ranching on their family ranches within the PRNS.
The ranches in West Marin contribute significantly to the local economy and the local culture. According to an analysis by U.C. Cooperative Extension in 2009, ranches in PRNS and Golden Gate National Recreation Area (GGNRA) directly provide approximately 65 jobs and provide livelihoods for an additional 25 ranch family members. Additionally, agriculture in PRNS and GGNRA account for 17 percent of the agricultural income in Marin County. These jobs and income would be lost if further restrictions were placed on ranches within PRNS. These ranches are not just creating economic value, they are producing high-quality food appreciated by consumers locally, regionally, and nationally. Further, providing 20-year terms for lease/permits allows for greater investment in improvements on these ranches. Shorter terms prevent the ability of ranchers to obtain financing for improvements.
would also like to see improved management of the PRNS elk herds. Elk causes thousands of dollars of damages and lost forage on ranches. Additionally, the elk carry Johne’s disease, which can be transmitted to cattle. USDA estimates that lost productivity from Johne’s disease in dairy cattle could be costing dairy producers between $200 and $250 million annually. Elk in the PRNS was reintroduced by humans and have been managed since their reintroduction. PRNS must improve its management by maintaining the roaming elk herds on the Limantour wilderness and preventing them from damaging ranches in the area. Additionally, PRNS should ensure that there is proper forage and water available to the herd in the Limantour wilderness to prevent a reoccurrence of the unfortunate loss of elk during the drought.
Ranches on PRNS provide important economic, cultural, and ecological values to the local community. Losing a significant portion of West Marin’s agricultural community would mean not only a loss of local food production but a significant loss of its economy and culture. I urge you to offer 20-year lease/permits to ranchers on PRNS and to improve elk management and return the elk to the wilderness areas where they will not impact the ranches.
Barbara Martin
Community Relations Coordinator
King County Farm Bureau
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# 2730
Name: Smith, Judith
Correspondence: lI have received the preliminary comments of EAC and they reflect many of my concerns at this early stage - particularly about commercial diversification and protection of the elk.
Thank you
Judith
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# 2731
Name: Walker, Christine
Correspondence: I would like to submit my support for continued but improved ranching in the Point Reyes National Seashore. Although there are few precedents for shared public and farmed land in the United States, European countries like France and Switzerland have found productive intersections that build an appreciation for both open space and food production in a celebration of agro-ecology.
In France, the National Park of the Cevennes and the Regional Park of the Grand Causses combine within a UNESCO World Heritage Site that preserves and interprets the agricultural and natural heritage. According to a November 15, 2017 Chicago Tribune article by Rick Steves entitled Swiss Bliss "Alpine farms welcome hikers to witness cheese-making in action" and "The milk from those cows grazing in the high meadows is destined to become treasured Alp cheese ("Alpkase"). People say that the character of the cheese is shaped by the wild herbs and flowers that the cows munch. Some locals claim they can tell which valley the cows grazed in just by the taste."
In addition to the carrying capacity of visitors, the livestock carrying capacity should be carefully determined and stewardship practices monitored, developing long term plans for the sustainable management of all resources.
Thank you for your consideration
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# 2732
Name: Jensen, Jim I
Correspondence: I prefer the alternative of "Continued Ranching and Removal of the Drakes Beach Tule Elk Herd."
The ranches and families are part of the culture that helped to form the park and deserve to live out their legacy and carry on the family tradition. National parks and federal lands are full of working landscapes and this should be a model for what can be accomplished to provide local sustainable food and an opportunity for conservation, preservation, and public access in moderation. When the families no longer want to carry on the Ag operation the Park can consider the next best alternative. But should be warned that the impacts of increased visitation and visitor experience do not equate to "preservation". Just look at Yosemite Valley, hardly preserved. Is that what we want the planning area to look like? We cannot tell ourselves we will enhance the visitor experience while restoring the natural ecosystem, these lands have been altered and require management. The Vision fire of 1995 is another great example.
The elk no longer have a natural instinctive sense of existence, they don't migrate and are far from their native relatives that historically traversed the coast and valleys of California with Grizzly bears. They are essentially a cross-bread cow, breeding out of cycle, that likely has been inbred over the years from being locked on Pierce point without management. They are going to consistently forage where pastures have been improved by the ranches and dairies.
How can Point Reyes protect and manage the diverse and important natural and cultural resources in the planning area? The NPS can require the highest level of organic certification, or nutrient management plans, or grazing plans but they need to support and allow for the implementation of the infrastructure to accomplish this. In fact NPS is somewhat responsible for providing the necessary conservation practices in collaboration with the ranch and dairy operations. The lease should clearly spell out who, what, when, and where practices should be implemented with detailed budgets. The ranches can actually save the NPS a significant amount of expenses and staff time by managing these operations. The park already can't maintain it's infrastructure, invasive species, fuels, and general maintenance. The ranches should be required to maintain some of these items important to their operation within the leases.
"Natural and cultural resource management must occur
simultaneously and, in general, interdependently. Such resource
management when practiced holistically embodies the basis of
sound park stewardship. Artificial division of the National Park
System into "natural parks" and "cultural parks" is ineffective and
a detriment to successful resource management. "
https://www.nps.gov/calltoaction/pdf/leopoldreport_2012.pdf
Significant Opportunities exist for NRCS Conservation plans to enhance the future stewardship of the planning area. Certified Range managers could work with lessees and the NPS as a neutral third party to develop best management practices and protect sensitive habitats for each operation and establish and optimal/sustainable heard size. This is only viable with the 20 year lease option as many of these practices will take several years to implement. Their are local matching funds available.
What types of visitor experiences, activities, and facilities should be available in the planning area?
occasional farm tour for school groups. hiking trials in a few areas. Informative signs about the history of ranching and the importance of our food systems. An entrance fee possibly. Every one of these ranch and dairy operations should be a candidate for the Aldo Leopold award. They should aim towards that goal and be supported by the park in getting there. Some may need more time and support than others but they may be able to work together with the NPS to reach this level of land stewardship. https://sandcountyfoundation.org/our-work/leopold-conservation-award-program
specific strategies can and should be considered for managing the agricultural lease/permits. Clear leases with required conservation planning goals, herd numbers, and sensitive area protection. Quarterly monitoring to evaluate goals and assist the ranches/dairies with implementation and funding sources.
What types of specific strategies can/should be considered for managing tule elk?
The elk should be left in the areas where they have a routine that does not impact ag operations or unsustainable herd numbers. They will require management of some sort and on-going monitoring. What was the plan when they were released? Maybe that should be revisited with further science and wildlife biology to determine how they can integrate with visitors and the pastoral zone. I thought we could do this with the fallow and axis deer, reaching an equilibrium, unfortunately the park decided to take lethal extermination measures to remove them.
Thank you for taking the time to consider the local social, cultural, and economic impacts the Ag operations in the pastoral zone bring to this community.
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# 2733
Name: Johnston, Bob
Correspondence: Comments on the the Conceptual Alternatives for the PRNS GMP Amendment
to update guidance on ranching lands, including the N. District of the GGNRA
Bob Johnston,
Background:
The NPS held pubic open house meetings in late October to display preliminary conceptual alternatives for ranch management. The meetings outlined these alternatives, but did not provide historical data on water quality, range condition, number of cattle and cows permitted each year, and other attributes of the existing environment, essential for the public to decide what the problems on these lands are and what kinds of management alternatives should be examined to address them. The meetings also did not outline the types of impacts that the NPS intends to evaluate in the DEIS. This lack of information on the impacts of past ranching leases seriously weakened this stage of public participation. One cannot design alternatives in a vacuum.
My Qualifications:
case law, NEPA comments from experts should be given more weight, so I will give a short statement on my experience. I have an MS degree in Renewable Natural Resources, a field that includes grazing management. I was a professor of environmental planning at UC Davis, 1971-2005, and taught a course on environmental impact assessment to students for 33 years and also gave several extension classes to mid-career professionals on NEPA law and practice. These classes included USFS, NPS, BLM and other Federal land management agency staff people as students. I published several articles and book chapters on impact assessment methods and was on State advisory committees re. CEQA practice in the 1970s. I have been an expert in NEPA cases for over 40 years.
I have read the meeting materials (handouts and easels), and all materials on the PRNS web site in October for the amendments, including the Bartolome report on residual dry matter on the ranches, the report on the effects of mowing silage on birds, the FAQs page, the summary of comments from the 2015 workshops, and the first few pages of the legal settlement.
Comments on the Conceptual Alternatives Documents and Meetings Materials:
1. The motivation for the GMP amendments
First, any GMP amendment process should tell the reader what laws command the NPS or guide it, in general, and in ranch management specifically. The NPS has a narrow mandate "....to conserve the scenery and the natural and historic objects and the wildlife therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations." (1916 Organic Act, 16 USC 1) Also, in the founding statute, we find: "...the Secretary of the Interior may, under such rules and regulations and on such terms as he may prescribe, grant the privilege to graze live stock within any national park, monument, or reservation herein referred to when in his judgment such use is not detrimental to the primary purpose for which such park, monument, or reservation was created... These provisions make it clear that all activities in parks must not impair natural resources.
The NPS Management Policies (2006) (180 pages) summarizes the Underlying Principles as including: 1. Prevent impairment of park resources and values; and 2. Pass on to future generations natural, cultural, and physical resources that meet desired conditions better than they do today, along with improved opportunities for enjoyment. (p. 2) This document is the highest-level policy statement in the NPS. The mandate to restrict recreation and other human uses so as to not impair natural resource values was restated in the "Redwood amendment" to the Organic Act in 1978. It actually requires that resources be improved. The act establishing the Seashore (PL 87-657) restates this policy in Sec. 459(c)(6): " &the property acquired by the Secretary under such sections shall be administered by the Secretary without impairment of its natural values, in a manner which provides for such recreational, educational, historic preservation, interpretation, and scientific research opportunities as are consistent with, based upon, and supportive of the maximum protection, restoration, and preservation of the natural environment within the area..." So, the NPS must not only protect its lands, but must restore them to an improved state.
The Management Policies book says, in discussing various uses allowed in parks in Sec. 8.6.7, that "In general, agricultural activities should be conducted in accordance with accepted best management practices." Sec. 8.6.8 says that "Agricultural livestock grazing will use best management practices to protect park resources, with particular attention being given to protecting wetland and riparian areas, sensitive species and their habitats, water quality, and cultural resources. Managers must regulate livestock so that ... ecosystem dynamics and the composition, condition, and distribution of native plants and animal communities are not significantly altered or otherwise threatened..." Note the mandatory verbs which require these actions.
Please describe these statutory and administrative mandates in the DEIS as they motivate the GMP amendments and define the standards that apply to ranch management. BMPs are often described as advisory by agricultural organizations, but in the NPS case must be interpreted as mandatory, because of the policies described above. Range conditions must be improved, in each lease.
2. The affected environment
In order for a commenter to understand the intent of the GMP amendments, they must be informed about the history of grazing in the PRNS and all problems that have occurred, regarding water quality, wetland and riparian areas, sensitive species and their habitats, and all other environmental issues. This information was completely lacking in the meetings and related documents. Fortunately, as noted above, reports on residual dry matter (range condition) and mowing impacts on nesting birds are on the web site. No data on water quality, wetland conditions, riparian conditions, and other issues were made available. These long-term trend data are essential in a DEIS as part of the affected environment discussion as a baseline against which to measure changes (impacts), are necessary to identify (scope out) alternatives, which are intended to remedy those past problems, and are necessary for the NPS to set standards for each environmental indicator that mitigation measures must then meet. Indeed, this is the basic rationale and structure of an EIS and one cannot discuss any part in isolation.
It is clear from reading the Bartolome report that many ranches regularly violate the Residual Dry Matter minimum required in the fall, intended to prevent erosion. Fencing cattle away from creeks also seems to be insufficient to protect water quality. Tomales Bay is in non-attainment for coliform, nitrogen, and sediment, all of which come primarily from ranching and dairying operations. The N. District of the GGNRA grazing lands drain into Olema and Lagunitas Creeks, which deliver coliform, sediments, and nitrogen into Tomales Bay. When driving through this park, one can easily see that the rangelands are degraded, with almost no grasses left in many fields in the fall. Erosion channels are widespread and manure is near to many ephemeral creeks. In Bartolome, J.M. et al., "1987-2014 Residual Dry Matter Analysis..." for the seashore, done at UC Berkeley, Figure A.2 shows the residual dry matter data for the grazing leases and most violate the minimum RDM standard for the fall period every few years. Several ranches violate the standard for all, or almost all, years in 2000-2016 period. It seems that the NPS is not enforcing the policy, as described to NOAA (see below), to limit grazing on ranches that violate their lease conditions.
The NOAA Fisheries Biological Opinion for the NPS livestock grazing program in PRNS (4/5/04) says that grazing in the Seashore and related GGNRA leases in Olema Valley damages (incidentally takes) the coho and chinook salmon and steelhead threatened species, but are not likely to jeopardize their continued existence. This Opinion says that residual dry plant material is measured in the fall and where the standard is not met, "the duration of grazing or the allowed number of cattle is reduced" (p. 3). As noted above, the RDM data seem to show that the NPS does not require the lessees to reduce herd size and/or grazing duration, to improve vegetation. The NPS is said to have committed to monitoring water quality and managing permits accordingly. The NPS "will incorporate" specific salmonid protection measures such as improving stream buffers and reducing excessive sedimentation from roads. The NPS "proposes" to undertake several mitigation measures focusing on grazing damage to Olema Creek and Schooner Creek and Home Ranch Creek. Table 2 in the Opinion shows that cattle have access to about 3% of Lagunitas Creek that is bordered by grazing, about a quarter of Olema Creek bordered by grazing, and a third of Drakes Estero similarly. The average for all creeks was 16%. NOAA staff observed bare soils in pastures adjacent to creeks. Another problem documented is lack of shade plants near to the creeks. Some efforts were made in the early 2000s to fence cattle away from creeks and to plant trees next to creeks. Another related issue discussed is the dewatering of creeks due to wells taking groundwater for cattle use, in a few areas. These are all rudimentary problems in grazing management, revealing poor overall practices and weak lease enforcement.
Tomales Bay is a Wetland of International Importance under the Ramsar convention. It is in the UNESCO Golden Gate Biosphere Reserve and is a California Critical Coastal Area. It is within the Gulf of the Farallones National Marine Sanctuary. It is a critical resting and feeding area for several species of shore birds during migration periods. The Tomales Bay Wetlands Restoration&(2007-2012) report by the State Water Resources Control Board (2013) found no downward trends (improvements) in coliform, N, or sediment, which are some of the standards violated there. Indeed, the aquaculture operators are not allowed to sell their shellfish for 60-100 days per year, due to coliform pulses after winter rainstorms. The Tomales Bay Water Quality Status and Trends Report (2002) found that dairies and cattle ranches contributed to coliform, N, and sediment loading in the Bay. The Regional Water Quality Control Boards discharge permit waivers for the dairies and ranches in this watershed have increased the regulation of manure, especially for the dairies, steadily over the past 30 years, but water quality has not improved for these pollutants. To not even mention the basic facts about these important receiving waters below some of the grazing permits being evaluated seriously hampers the publics ability to understand the problems with current grazing leases and to propose alternatives to improve the situation. Since this history must be included in the Affected Environment section of the DEIS, the NPS should have provided this information, all of which the staff possesses.
Please include detailed background information regarding the historic trends in environmental quality pertaining to range condition, water quality, bird abundance, wetland and riparian land conditions, and other issues in the DEIS affected environment section, so that the public can understand the motivation for the GMP amendments, what alternatives may be successful in improving environmental quality in the Seashore, and what standards are needed for mitigation measures.
3. Impact categories
From the above description of the NPS mandates, both general and specific to grazing leases, we can see that improving the status of natural resources is required. From the above brief and incomplete discussion of the history of the affected environment, we can see that the impacts of grazing on wetland conditions; riparian area conditions; erosion; sediment, nitrogen, and coliform levels in creeks, Tomales Bay and Drakes Estuary; and other types of impacts historically experienced should be identified and evaluated in detail. Newer concerns, such as net impacts on greenhouse gases should also be discussed. The NPS is also required to evaluate the visual and noise impacts of all of its activities.
In the DEIS please perform a detailed evaluation of the environmental impacts discussed here.
4. Mitigation measures.
If the EIS includes a detailed description of the NPS mandates and the history of ranching and its impacts on the affected environment, the NPS can then evaluate the impacts of the various Ranching Alternatives, the mitigation measures required in each, the impacts resulting after mitigation, and whether the alternative will restore the environment to an improved state. Since the leases were not adequately enforced in the past, specific implementation mechanisms must be adopted in the mitigation measures for the ranch leases, enforceable by third parties.
Thank you for considering these comments.
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# 2734
Name: Cornelia, Maureen
Correspondence: I would like to voice my strong support for continued beef cattle and dairy ranching operations under agricultural lease/permits with 20-year terms. In reviewing the preliminary conceptual alternatives under consideration for the General Management Plan Amendment, I believe consideration must be given to developing a management plan for ALL the Tule Elk herds within PRNS, not simply the Drakes Beach Tule Elk herd. The current unimpeded movement of these animals onto the pasturelands actively managed by the seashore ranchers is not compatible with the authorized ranching operations. A comprehensive management plan for all the Tule Elk within PRNS is an essential component to A General Management Plan Amendment that will fairly serve all constituencies.
Maureen Cornelia
Inverness, CA
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# 2735
Name: Brown, Kristine E
Correspondence: Re: Pt Reyes National Seashore Ranch management planning
I am a 30 year resident of Inverness CA. I support the National Seashore Park and local ranchers and ranchers and ranch workers. Both the park and the ranches bring benefits-both economic and human in terms of individual and family well being and the health of our community,
Please find a balance that fully includes the benefits our dairies, ranches and their families and workers with the benefits of natural resources, The historical and cultural dimensions are important and must be quantified as much as possible.
Since you are considering a no-ranch or reduced ranch option, please fully evaluate the down sides of this in terms of what the ranches bring economically and in terms of the people.
Also, cattle remove invasive weeds. How would invasive weeds be managed and at what cost?
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# 2736
Name: N/A, N/A
Correspondence: My family has visited Point Reyes National Seashore twice over several decades. We have high expectations of visiting multiple times more within the next two years, hoping to explore many other areas of the park. We love the varied plant and animal life found in the park, both marine and terrestrial.
We would like the park to remain, or even return to the most natural state possible to be enjoyed by future generations. To achieve this, we would hope for minimal impacts to be made by agricultural and ranching businesses. We would not want to see expanded agriculture or ranching in the park, particularly through the growing of crops. This would put additional stresses on the land and the wildlife within the seashore boundaries.
We would like minimal management of the tule elk, and decreased ranching.
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# 2737
Name: Zischke, Michael
Correspondence: Please be sure to fully evaluate the NPS original proposal as part of the GMP analysis, in full detail such that NPS can elect to adopt that as the final action.
As a frequent visitor to the area, in my view it is the combination of longstanding agricultural use and a beautiful environment that make Point Reyes special, and the National Seashore was established long ago to preserve both of those features. The ranches are part of the vibrant food production and sustainable food production communities in the north Bay Area.
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# 2738
Name: N/A, N/A
Correspondence: Cattlemen have had way too much free reign in the Point Reyes park for way too long to the detriment of numerous species and especially the Elk. They need to be controlled and their questionable influence curtailed.
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# 2739
Name: Bacci, André Henrique
Correspondence: Dear superintendent,
The main task in this century will be to apply our ecological knowledge and systemic thinking to the fundamental redesign of our social technologies and institutions in order to fill the gap between human action and ecologically sustainable systems of nature.
I am writing in support of flocks of free-moving tulle elk at Point Reyes National Seashore, and I oppose any fences, removal, sterilization or death of elk in the park. Tulle elk is an important part of the landscape of Point Reyes, and its recovery has been an exciting success story to restore native species and ecosystems in line with the mission of the National Park Service.
Leaseholders on our public lands should not dictate the removal of wildlife or exclusionary policies. Any livestock operations should be managed to accommodate moose and other native wildlife, and should not harm the habitat of endangered species.
I also urge you to reject any land conversion of the national park to row crops or expansion of commercial livestock to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The change of park service to the General Management Plan should prioritize the protection of the natural values of Point Reyes National Seashore.
Regards,
André Benrique Bacci
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# 2740
Name: Wilson, Tom A
Correspondence: I have a second home in Inverness, so I am very familiar with the peninsula. I strongly support the continuation of ranching and the use of 20 year leases. Ranching is an important component of the Point Reyes experience and must be maintained. I also feel the Elk should be managed so that herds (small) can be maintained at Drakes and Limintour. If they get too large why can't they be culled to keep the populations in check.
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# 2741
Name: Rempel, David
Correspondence: November 15, 2017
Point Reyes GMP Amendment
Superintendent MacLeod
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes Station, CA 94956
Dear Superintendent MacLeod:
ranches currently in the GMP Amendment Planning Area contribute to the West Marin economy and culture. unique pasture lands provide high quality milk and beef which support quality local diary and meat products. Local production means less transportation and a smaller carbon footprint. Besides the employment provided at the farms, the farm products also help support the livelihood of hundreds of people in West Marin who milk and beef to develop special cheeses and other foods. ranches are one of the major employers in West Marin.
I have owned property in Inverness since 1986 and love to hike in PRNS, walk on the beaches, and kayak in Tamales Bay. The unique look and feel of the park would change if the ranches were removed. The wide open pasture lands, which the public can walk through, would gradually be filled in with brush that would make them impassable. This unique look and feel of the pasture lands in the park, represented on your own website pictures, are one of the factors that attracts visitors to the park.
Introducing elk into PRNS requires constant management of the elk herd by the park because there are no natural predators (wolf, bear, mountain lion). Therefore, the number will just continue to expand and ultimately will be limited by disease. This is not a natural process. The elk must be managed (culled) so that ranches can survive. The elk currently break down ranch fences and eat the hay and other foods meant for cattle. On some dairy ranches near Drakes By, there are as many cattle as elk. This is not sustainable. In order for the ranches to be economically viable, the elk in the ranch areas should be managed and reduced to some a small number, somewhere between 0 and 5.
Thank you for establishing the open process for exchanging information on the Amendment Planning and the opportunity to provide input into the process.
Sincerely,
David Rempel
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# 2742
Name: romanowski, christa
Correspondence: We do treasure these public lands and visit often at the Pt. Reyes National Seashore. I do support continued grazing and ranching, in an environmentally sensitive way, not least because some of the families who have ranched on these lands for decades, are in part responsible for the very fact that these lands were not paved over and covered with houses, etc., in the 1970s.
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# 2743
Name: Coulter, A
Correspondence: Dear Superintendent,
I am writing to support the preservation of the free-roaming tule elk herds at Point Reyes National Seashore. I object to any actions that put agriculture ahead of the wellbeing of the natural wildlife, include fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the ecosystem of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Cattle ranching is a highly polluting and destructive use of land and our public lands shouldn't dictate wildlife removal or exclusion policies in order to accommodate this activity. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. We already have lots of land in California that doesn't endangered a wildlife popution, along with preventing the degradation of habitat for all animals in the area.
If you haven't yet watched this video, this would be a great time to do it. (https://www.youtube.com/watch?v=ysa5OBhXz-Q). The lesson is not just about one animal, but about how the loss of an important animal changes the environment in unexpected ways.
Let the Park Service’s do its job, which is protecting the natural values of Point Reyes National Seashore.
Sincerely,
A. Coulter
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# 2744
Name: Coulter, A
Correspondence: Dear Superintendent,
I am writing to support the preservation of the free-roaming tule elk herds at Point Reyes National Seashore. I object to any actions that put agriculture ahead of the wellbeing of the natural wildlife, include fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the ecosystem of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Cattle ranching is a highly polluting and destructive use of land and our public lands shouldn't dictate wildlife removal or exclusion policies in order to accommodate this activity. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. We already have lots of land in California that doesn't endangered a wildlife popution, along with preventing the degradation of habitat for all animals in the area.
If you haven't yet watched this video, this would be a great time to do it. (https://www.youtube.com/watch?v=ysa5OBhXz-Q). The lesson is not just about one animal, but about how the loss of an important animal changes the environment in unexpected ways.
Let the Park Service’s do its job, which is protecting the natural values of Point Reyes National Seashore.
Sincerely,
A. Coulter
___________________________
# 2745
Name: Coulter, A
Correspondence: Dear Superintendent,
I am writing to support the preservation of the free-roaming tule elk herds at Point Reyes National Seashore. I object to any actions that put agriculture ahead of the wellbeing of the natural wildlife, include fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the ecosystem of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Cattle ranching is a highly polluting and destructive use of land and our public lands shouldn't dictate wildlife removal or exclusion policies in order to accommodate this activity. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. We already have lots of land in California that doesn't endangered a wildlife popution, along with preventing the degradation of habitat for all animals in the area.
If you haven't yet watched this video, this would be a great time to do it. (https://www.youtube.com/watch?v=ysa5OBhXz-Q). The lesson is not just about one animal, but about how the loss of an important animal changes the environment in unexpected ways.
Let the Park Service’s do its job, which is protecting the natural values of Point Reyes National Seashore.
Sincerely,
A. Coulter
___________________________
# 2746
Name: Coulter, A
Correspondence: Dear Superintendent,
I am writing to support the preservation of the free-roaming tule elk herds at Point Reyes National Seashore. I object to any actions that put agriculture ahead of the wellbeing of the natural wildlife, include fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the ecosystem of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Cattle ranching is a highly polluting and destructive use of land and our public lands shouldn't dictate wildlife removal or exclusion policies in order to accommodate this activity. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. We already have lots of land in California that doesn't endangered a wildlife popution, along with preventing the degradation of habitat for all animals in the area.
If you haven't yet watched this video, this would be a great time to do it. (https://www.youtube.com/watch?v=ysa5OBhXz-Q). The lesson is not just about one animal, but about how the loss of an important animal changes the environment in unexpected ways.
Let the Park Service’s do its job, which is protecting the natural values of Point Reyes National Seashore.
Sincerely,
A. Coulter
___________________________
# 2747
Name: Bateson, Gail
Correspondence: Dear Acting Superintendent MacLeod,
Thank you for the opportunity to comment on the conceptual range of management alternatives for a General Management Plan Amendment (GMP) for PRNS.
am a lifelong Bay Area resident who grew up in Terra Linda and now live full-time Inverness. started coming to Point Reyes before the park was established, riding my bike on the Bear Valley trail as a younf child; in high school we often visited Limantour, driving up and over Balboa before the current road was built. While raising a family in the East Bay, convinced my husband to buy land and then build a house on Inverness Ridge for our retirement, as there is simply no other place I would rather live given its great scenic beauty. Trained as an environmental scientist, am also a long-term member of Sierra Club and supporter of NRDC although the views and comments expressed below are my own. am also a member of Main Street Moms and support our group comments.
Tule Elk
the six outlined options, it appears that the main issue facing the Park Service is to determine the role or fate of the tule elk, an issue that began over fifteen years after the creation of the park, when they were introduced to Tomales Point, and then in 1998 when a small herb was relocated to Drakes Beach and then later migrated to Limantour. There needs to be a thorough and thoughtful analysis of the options to manage the herds and the associated costs, and how the NPS will cover these costs. In addition, there should be a clear identification of the specific benefits of keeping these two herds in the study area and who will derive these benefits. What are the specific added benefits to visitors given the current opportunity there is to view the elk already out at Pierce Point? For example, some people enjoy hiking in the Pierce Point area in order to see the tule elk, while others are more fearful of the large animals and avoid that area. How will the visitor experience near Drakes and Limantour beaches change if the tule elk herds are allowed to multiply near these two heavily used areas? Will it require any additional park resources to manage the elk near these high use areas?
If the intent is to create more of a true wilderness experience, is the Park Service considering introducing more of its natural predators to create a more authentic experience? What would be the costs and challenges to bring in mountain lions and coyotes into these areas to naturally control the elk population? While encouraging natural predators might make sense in a more isolated area of our nation, it seems ill-suited for a park located so close to a large urban area. If this is not being considered as an option, perhaps it provides a clue about the challenge of trying to recreate PRNS into a wilderness area, particularly in light of historical uses over the past 150 years.
No Action/Continue Current Management
While understanding that this is a required alternative option for the EIS, the stated assumption that current park management resources would remain at current levels seems unrealistic given that the tule elk populations will continue to grow and therefore require increased management. Someone must pay for this. If projected budget for PRNS cannot cover this, to what extent will the costs be shifted to the ranches and dairies to repair and replace damaged fencing and other adverse impacts?
If the Park Service was to continue to issue only short-term agricultural lease/permits, as proposed under this option, how will this impact the economic viability of the ranches, such as their ability to get loans to purchase needed equipment and supplies, as well as implement best management practices? These costs should be explored and included in the EIS.
Support of the Ranches and Dairy Operations
Ranching and dairy farming is part of the living history of the Park and should continue, as originally authorized. It is the landscape created by these operations that created the scenic environment that inspire efforts to create the park in the first place. This is the best and only way to ensure the continuation of the benefits of vital agricultural production to the community, the local economy, and visitor education and experience.
What would be the long-term visual impact on the peninsula if ranching ceased? How can the value of the potentially diminished visual impact be addressed? What would the landscape look like over time - and would it require Park resources to managed? Would shrub brush be allowed to take over, reducing the wide-open spaciousness that is symbolic of the National Seashore? How much would it cost the Park Service to control invasive species?
Economic and community impact of the proposed alternatives
Agriculture in the Park represents almost 20% of Marin Countys gross production value (according to the 2016 Marin County Crop Report). The no- or reduced-ranching alternatives need to consider not just the loss of this huge economic value but also the downstream and indirect costs to the local community. These may include displacing ranch families, reducing the cultural diversity of the region, and adversely impacting local stores and other businesses supported by local families. Schools may be impacted as well, requiring remaining students and teachers to commute longer distances if the reduced population leads to local school closures.
What impact would a loss of the ranch or dairy farm population have on popular local events that celebrate the historic and current ranching and farming populations, such as Cinco de Mayo to Western Weekend and many other events that attract visitors from the region?
If one of the goals is to enhance future stewardship in the planning area, options that increase the economic viability of ranchers should be encouraged. Issuing long leases/permits to the ranches will help ensure this, as will allowing some diversification such as return to growing more row crops, simple on-site limited food processing, and farm visits.
Suggestions for Proposed Visitor Experiences, Activities and Facilities
Among the activities I would like to see made available in the park are:
* a couple of sites with easy boat access for kayaks and similar small craft, similar to the launch area available at Hearts Desire Beach, with a short-term unloading area
* for new trails: clear designation of areas for hiking and those for mountain biking - separation of these uses where appropriate and enforcement of those rules to prevent trail erosion.
* bring back a snack bar to Drakes Beach - can be prepared sandwiches and drinks vs. cooked food, but provide more than there is there now
* build any new structures for visitors adjacent to current structures, such as at Drakes Beach vs. building in new areas of the peninsula (with the possible exception of adding bathrooms near the Pierce Point trailhead)
* increase the parking area in the south end of the park by Bolinas or provide alternative means of public access to the popular hiking trails in this area
* more interpretive signs - - like the great the wildflower chart at Chimney Rock trailhead
* clarify with signage the public access along the headlands near Commonweal
* continue current balance of beaches accessible to dogs
Conclusion
I hope that through this General Amendment Process, the Park will find a balance that integrates the benefits of our dairies and ranches and the families that support them with the natural resources and value that the Park brings. The Park is large and there is already a big middle section that provides a different type of wilderness experience, with existing hiking trails and backpacking camps.
Thank you for this opportunity to comment.
Gail Bateson
Inverness
___________________________
# 2748
Name: N/A, N/A
Correspondence: Dear Cynthia MacLeod
Acting Superintendent Point Reyes, National Park Service
I support the no ranching and limited management of tule elk. My second choice would be to continue as is. The ones I particularly don't like are the ones that change the leases to 20 years. I do not see why they need longer leases. The more improvements they make, the more they think they have the right to stay forever.
Gary Sorgen
Mill Valley, CA
___________________________
# 2749
Name: Garsson, Jane A
Correspondence:
Dear Superintendent,
I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore, and I object to any fencing, removal, sterilization or killing of elk in the park. Tule elk are an important part of the landscape of Point Reyes, and their recovery has been an exciting success story for restoring native species and ecosystems, consistent with the mission of the National Park Service.
Commercial lease holders on our public lands shouldn't dictate wildlife removal or exclusion policies. Any cattle-ranching operations must be managed to accommodate elk and other native wildlife, and shouldn't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops or expansion of commercial livestock farming to introduce sheep, goats, turkeys, chickens or pigs. This would create conflicts with predators and degrade wildlife habitat and water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
Jane A. Garsson
Mill Valley, CA
___________________________
# 2750
Name: Gilardi, Brian
Correspondence: To whom it may concern:
My name is Brian Gilardi, a fifth generation farmer in the Sonoma Marin area. My story starts in the 1880's when my great, great grandfather Peter Campigli emigrated from Switzerland and started milking cows on the U Ranch, the present site of the coast camp. As his family grew they eventually moved to the Burdell Ranch in Point Reyes in 1905. Five years later they were able to buy their own ranch also located off Hwy. 1 in Point Reyes. My grandmother (Evelyn Genazzi Gilardi) and her brother (Herald Genazzi) ran the dairy until 1988 when they sold the ranch to the Park Service.
I am a hay and grain farmer in Petaluma. We grow organic hay and silage that helps support the local dairy and beef industries.
Many of the dairy farmers on the point are friends of mine. I can relate to their current struggles. I farm reclaimed farmland that is adjacent to the Petaluma River and San Pablo Bay. I face the same environmental threats they do. I realize that in both instances these lands were much different before they became farms and ranches. But the streets of San Francisco and Sacramento looked much differently too. It has been the farmers and ranchers that have protected these lands from development thru the centuries.
In 1972 it was the ranchers, environmentalists, and government leaders that all came together to protect the Point Reyes Seashore from the possibility of resort type developments. We all had a common goal then and had to make compromises to achieve it.
Eliminating ranching on the point is no compromise. These families have spent generations on these ranches and have deep connections to the land. The farmers and ranchers know the land like nobody else. They make their living on it and understand all aspects of the ecosystems.
In 1900 over 35% of the population was directly involved in agriculture. Today less than 2% of the population produces our food and fiber. This increase in efficiency comes at a cost. The cost being that the public has a disconnect with the people that produce their food.
The number of dairies in our area have been on the decrease since the 1980's. As huge factory dairies were growing in the Central Valley local dairymen could not compete with such low profit margins. In the early 2000's something changed, the organic marked exploded. This was the opportunity that we needed to save farming and ranching in the North Bay. Dairies in the valley cannot meet organic standards because their cows are never on pasture, they rarely even leave the barns. Here we have beautiful rolling hills that provide excellent pasture. When they say happy cows come from California, they actually mean happy cows come from Marin County. Farmers here have found a niche market that has helped keep their businesses viable.
The economic impact would be great if the ranchers were forced to leave. I would be directly affected because the majority of my crop is sold to local dairy and beef operations. But I am just a small piece of the puzzle. You also have the hired help, refrigeration techs, feed mills, hay dealers, breeders, dairy suppliers, veterinarians, hardware stores, insurance agents, truck drivers, barn builders, financial planners, book keepers, and many other professionals and businesses that support and serve the ranchers on the point.
In conclusion, it is not just the wildlife, scenic views, and rolling hills that make up the Point Reyes National Seashore. It is also the people, their families, their history, and their legacies that make the Point Reyes National Seashore the special place that it is. I would suggest that ranchers be offered 20 year leases on their current ranches. I believe that their children should also have the opportunity to stay on their families ranches and continue farming and ranching into the future. The Park Service should, in partnership with the ranchers, create an educational center that explains the benefits of the local ranches and how they coexist with wildlife and the surrounding ecosystems. The center would be a great place to showcase the vast ranching history on the point. The elk herd should remain and be managed in such a way that it can coexist in a healthy way with the surrounding ranches.
Lets not forget were we came from and let a small group of activists with loud voices and deep pockets dictate the future of this local treasure.

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