General Management Plan Amendment Initial Public Comments: Correspondence ID #s 2751–2967

←Comments 2501–2750

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# 2751
Name: James, Douglas W
Correspondence: The introduction of tule elk on the Point Reyes peninsula has been controversial from the start. The northern herd on Tomales Point has surpassed the carrying capacity of the land. Between 2012 and 2104 during the drought a third to a half of the herd starved to death. WHAT KIND OF MANAGEMENT IS THIS? If a rancher allowed this to happen to her cattle, she would be prosecuted and put in jail. [After reading the account of these magnificent animals being left to a cruel death (Point Reyes Light, March 2015; New York Times, May 18, 2015), I personally called the Marin Humane Society to report the problem]. It is clear to me that the National Park Service at Point Reyes National Seashore needs some expert help in managing the Tule Elk because they are not doing a very good job currently.
Meanwhile, the plant life on Tomales Point has been decimated. Large expanses of broken up soil are evident, species of invasive grasses and broad-leafed weedy species have replaced native grasses and annuals. Trampled shrubs have very little ability to hold the soil from eroding when the winter rains begin.
The Drakes Beach herd has become a costly nuisance for ranchers as the elk trample fences and eat scarce forbes and drink water that is supposed to be for cattle or dairy cows. It has been recently reported that the Elk have tested positive for Johne's Disease. The disease could easily wipe out dairy and cattle operations. Complaints to the park service by ranchers have not produced satisfactory results. This all adds to the many problems that small ranch operators face that makes staying in business very difficult.
When John F. Kennedy established the Pt. Reyes National Seashore in 1962, it was seen as one of several 'urban parks' i.e., near urban areas. The charge of the NPS was to maintain the working landscape while increasing recreational opportunities for the general public. If it were not for the activities of the ranchers who's families have been stewards of these lands since the middle 1800s, there wouldn't have been the basis for a park in the first place. As the decades have rolled by the bureaucratic behemoth that the NPS is has essentially been managing the ranches to go broke. They have been on short leases at least for the last 15 years. Ranchers need to finance their operations. It is virtually impossible to get a bank to approve a loan when a business only has a five year horizon. The Secretary of the Interior under Obama promised 20 year leases for the dairies and ranches at Pt. Reyes. Nothing has happened since. As the park sits on its hands, these farm operations have grown more precarious.
The most attractive Conceptual Alternative Under Consideration is: Continued Ranching and Removal of the Drakes Beach Tule Elk Herd. The park should also remove the Limantour-Estero Road Herd because there is no way the animals can be kept from moving over to Drakes Beach. Furthermore, elk that have escaped from the Tomales Point herd should be removed, or at least put them back behind the fence. The Tule Elk herd at Point Reyes are more akin to a zoo or wild animal park, therefore, the animals remaining at Tomales Point should be managed accordingly. Allowing them to starve to death is inhumane.
The 20 year agricultural leases are long overdue. The NPS should be assuring that sustainable agriculture continue at Point Reyes National Seashore. It is imperative that the NPS offer operational flexibility and allow the ranches to diversify their operations to include compatible row crops. I would like to see interpretive exhibits to educate the public about sustainable practices. To further the educational opportunities for the public allowing the ranches to host 'farm stays' on their land (B & Bs on the farms so visitors can see firsthand the day to day operations and learn where their food comes from).
Point Reyes National Seashore as a place where sustainable small family farms can and does coexist with the protection of natural resources. Let's get back to the original vision of an urban national park where it is managed to maintain the working landscape, that is, the ranching and dairying (and bringing back the oyster farm), while creating recreation for nearby urban dwellers.
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# 2752
Name: N/A, N/A
Correspondence: This species must be protected and no ammendment should soften the laws or infringement punishments
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# 2753
Name: Johnson, Helen
Correspondence: Please maintain protections for the Tule elk. A small protected population survives in California. They will be threatened with decimation if plans move forward to restrict their movements. Past experience shows that this leads to starvation.
This native species has been allotted a relatively small amount of public land. Please maintain protection on this land and the elk so that they can survive and remain free-roaming.
Thank you
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# 2754
Name: Barinaga, Marcia
Correspondence: Dear Superintendent Macleod,
I own and manage a sheep and cattle ranch on the East Shore of Tomales Bay. Our pastures are certified organic and our ranch is protected by a MALT conservation easement. I appreciate the chance to submit comments on the PRNS/GGNRA GMP Amendment planning process.
I am writing to urge you to support a GMP Amendment that supports the economic viability and survival of the ranches within the PRNS. These ranches are an important part of the human and cultural history of Point Reyes. The ranches, and the families that they support, are essential to the sustainability of our entire West Marin community, to the strength of the businesses that depend on agriculture, to the strength of our schools, services and health-care system. The PRNS was founded on a model of agriculture in partnership with the Park System, and today Marin County leads the nation in progressive agricultural practices in partnership with environmental preservation. The ranches on the Point are essential in many ways to the success of that model.
To support the ranches on the Point, the GMP Amendment needs not only to allow ranching to continue, but needs to adopt measures that enable the ranches to be economically and environmentally viable. There need not be a choice between supporting the ranches and sustaining the ecosystem of the Point. Indeed, the creation of Point Reyes National Seashore in 1962 was a historic collaboration between environmentalists and agriculturalists, representing a vision in which the production of wholesome food can exist in harmony with the protection of the environment. It set the stage for the birth of MALT in 1980, and started our community on the path toward the example it has set of sustainable agriculture in harmony with the environment. A GMP Amendment that embraces and supports the ranches has the promise to sustain the natural environment within the PRNS, to enhance the food-production community of the Bay Area, and to use this partnership as an educational resource to enlighten visitors to the Seashore the positive role that responsible agriculture can play in local ecosystems.
Proposal: Initiate 20-year rolling leases for the health of the ranches and the environment.
The current uncertainty experienced by the ranchers on the Point with regard to the length and renewal of their leases is a disincentive to ranchers to invest in the long-term stewardship of the Points precious natural resources. It is impossible to maintain a healthy operation while living under the year-to-year threat of losing ones lease to the land that the operation has always occupied. The Seashore should issue 20-year rolling leases to the ranches; leases that renew each year for a 20-year period. Such an arrangement would be similar to the Williamson Act agreements, and would give ranchers and the public 20-year notice if ranching were to be discontinued in the PRNS. This would give ranchers the long-term security they need for planning, and the incentive to put valuable money and time into preservation and stewardship of their natural resources. It would give the next generation the hope that they can continue their family businesses. It would stabilize our entire West Marin community.
Proposal: allow the ranches to create worker housing.
The GMP Amendment needs to allow the creation of worker housing to support not only the ranching operations but our entire community. Over the past 50 years, more than 130 homes in PRNS have been lost when ranches on the Point lost their leases. The families who lost their homes have relocated elsewhere. This exodus weakens our entire community, as the loss of the PRNS ranches themselves would weaken the community. The ranches and dairies in the PRNS make up almost 20% of the agricultural production of Marin County. These ranches-and the working families they support-are essential to drive the economic and social engine of our community. Loss of that production will weaken all the businesses in our county that serve the agricultural community. Continued loss of the worker population weakens all of our community services, from schools to clinics. Freedom for the ranches to create housing for the workers they need can reverse that trend.
Proposal: Allow the ranches the flexibility to respond to trends in food production and land management, for the economic viability of the ranches as well as for the best stewardship of the land.
The ranches on the Point, like ranches everywhere, need to be able to diversify and evolve to keep their operations healthy. As best practices continue to evolve for everything from brush and weed control to the incorporation of carbon into the soil known as carbon farming, the PRNS ranchers need the freedom to incorporate these best practices into their land management. For example, ranchers should not be subjected to arbitrary livestock limits. Instead, they should be encouraged to use best practices for resource management, including use of residual dry matter (RDM), plant diversity and plant density measurements to determine optimal stocking rate and to vary that rate based on annual conditions. Fixed maximum stocking rates set too low can lead to resource degradation from invasive weed and brush proliferation, and loss of soil carbon. Indeed, there is an increasing body of scientific evidence that appropriately managed grazing not only promotes healthy soils, but can counteract global warming by incorporation carbon into the soils. Marin County is leading the nation in carbon farming practices, and with a GMP Amendment designed to encourage innovative practices, the ranches of the Point can be an important component of this trend.
Proposal: Exploit the educational value of the ranches by allowing ranchers to give tours to the public, and sell their products to PRNS visitors.
The ranches in PRNS are in a unique position to interact with the millions of visitors to the Seashore. Such interactions between the ranches and the visiting public would help to connect the ranchers to the local food community, to educate that community about the historic role of the ranches in the Seashore, and to provide a platform for teaching the next generation about progressive agricultural practices and their role in environmental preservation.
Proposal: Remove Tule Elk from the Pastoral Zone.
The Tule Elk on the Point are a growing threat to the ranches. They destroy fences, compete with livestock for precious resources, and present a disease and injury threat to livestock. The elk that have spread into the pastoral area were not historically present on the ranches, and so should not be included in the 150-year environmental baseline. Damage by the Tule Elk to the ranching operations should be an included element in the EIS, and the NPS should consider an alternative that removes the elk from the ranching areas and controls their number in the Seashore. The elk were never authorized to occupy the Pastoral Zone. The 1998 PRNS Tule Elk Management Plan and Environmental Assessment set aside 18,000 acres for the elk. The elk population should be restricted to that area and their numbers managed within that area. Responsible ranching is completely compatible with a balanced wildlife ecosystem, and the presence of many endangered species on Marin ranchland is evidence of this. The Tule Elk represent a population that is out of balance, without natural predators, and their management is essential not only for the survival of the ranches but for the balance of the environment on the Point.
The ranches in the Seashore are an important part of the human and cultural history from 1860-1960 that the Seashore was established to preserve. They are an integral part of Point Reyes and of our greater Marin community. The GMP Amendment has the potential to embrace and support these ranches, thus strengthening our community, showcasing the working relationship between agriculture and environment that Marin is known for, and setting an example for the rest of the country of a human community in harmony with the natural environment.
Thank you for your consideration.
Sincerely,
Marcia Barinaga
Barinaga Ranch
Marshall
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# 2755
Name: N/A, N/A
Correspondence: The story of the Tule Elk is one that is truly remarkable. Their close call with extinction or more accurately extermination by our hands, 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. This should be a simple decision based on the numbers above, but unfortunately everything seems to need a debate these days. Please put aside your own personal wants and needs and think about those that do not have a voice, be their voice and stand up for the Tule Elk.
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# 2756
Name: Moreland, Crystal
Correspondence: November 15, 2017
Acting Superintendent Cynthia MacLeod
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes Station, CA 94956
Re: Point Reyes National Seashore General Management Plan Amendment
Dear Acting Superintendent MacLeod:
On behalf of The Humane Society of the United States (The HSUS) and our California supporters, we appreciate the opportunity to comment on the conceptual range of management alternatives wed like to see included in the Point Reyes National Seashores General Management Plan Amendment (hereinafter, GMP Amendment).
The HSUS has a long history of involvement in human-wildlife conflict resolution, and are subject matter experts in creating sustainable, humane and fiscally responsible solutions to wildlife-population issues. When issues involving the management of wild animals arise, it is essential that agencies engage in a full and open dialogue with all affected stakeholders and that a fair, rational and objective information collection and assessment process take place before proceeding with any proposed management action or plan. As such, we are thankful for the opportunity to comment on the Seashores GMP Amendment, and appreciate the agencys consideration of our comments.
1. The National Environmental Policy Act (NEPA) has commonsense requirements for environmental impact statement (EIS) planning, including preparing a full range of alternatives
NEPA requires that agencies analyze a sufficient range of alternatives so as to defin[e] the issues and provid[e] a clear basis for the choice among options by the decisionmaker and the public. 40 C.F.R. § 1502.14. A reasonable range of alternatives, including a no action alternative and alternatives that restore and conserve the natural environment, are necessary to ensure that an agency has not define[d] its objectives in unreasonably narrow terms, and eliminated consideration of viable options for action. Carmel-by-the-Sea v. U.S. Dep't of Transp., 123 F.3d 1142, 1155 (9th Cir. 1997). NEPA also requires that a federal agency analyze all reasonable foreseeable future actions. 40 C.F.R. § 1508.7.
Further, the Council on Environmental Quality (CEQ) regulations provide that an agency must consider cumulative impacts as part of its evaluation of federal actions. The definition of cumulative impacts is, the impact on the environment which results from the incremental impact of the action when added to the other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such actions 40 C.F.R. § 1508.7.
In light of this background, we would recommend the inclusion of the alternatives suggested below.
2. If NPS determines that tule elk management is required, it should consider a modified alternative that focuses on managing elk populations at historical numbers and maintaining native carnivore populations and/or implementing an immunocontracpetion program to maintain a healthy ecosystem
Tule elk (Cervus canadensis nannodes), the smallest subspecies of North American elk which once numbered 500,000 have recuperated to only a few thousand and exist only in California. The Point Reyes herd was extirpated in the 1860s, and in 1978, tule elk were reintroduced into a fenced 2,600 acre wilderness reserve on Tomales Point, which comprises more than 300 individuals. Additionally, on Point Reyes, two other herds exist, the Drakes Beach Herd (110 estimated total animals) and the Limantour-Estero Road Herd (130 estimated total animals). These herds are an important economic asset that the NPS must consider in its new GMP Amendment and EIS.
While we understand the National Park Service (NPS) may have concerns over the potential adverse harms caused by tule elk within Point Reyes National Seashore, we are concerned with any potential amendments to the GMP that would strive to drastically reduce their populations within the Seashores boundaries.
As the NPS itself notes, tule elk are native to the Point Reyes National Seashore area, and before their eradication in the 1800s as many as 1,000 existed in the area. As tule elk were dominant grazer in this area before their extermination, populations were reintroduced to help maintain healthy ecosystems within the Seashore.
The GMP Amendment and new EIS should focus on managing tule elk populations at historic levels within the Seashore and consider maintaining natural native carnivore populations and/or implementing an immunocontraception program to ensure their populations are in balance with their carrying capacity.
A. Use of fertility control to limit population growth humanely
While we would prefer that the NPS allow the tule elk population to remain at current or even increased levels within the National Seashore, we understand that this may not be politically viable and some form of management may be required. If this is the case, we firmly believe within our nations iconic parks and seashores, the NPS must proceed with population management methods that control wildlife population numbers in humane ways and that are supported by the American public.
In light of this, we cannot overstate the value of implementing a comprehensive humane wildlife management approach by placing a central focus on increasing the use of fertility control. The appropriate and proportionate use of fertility control tools could reduce the tule elk populations growth rates, which will, in turn, gradually decrease the herd size over time.
the NPS structures a management program properly, and efforts are made to either capture and vaccinate or remotely dart a high proportion of female elk (above 70-80%), the herds reproductive rate could be immediately reduced. Elk could be remotely darted, as they have been within Point Reyes National Seashore in the past, or gathered and treated by hand. With this treatment structure, the Park could initially reduce the elk population humanely to their desired level, and then maintain a stable population thereafter. Because of the small size and unique geography of Point Reyes National Seashore, we strongly believe the benefit of program would be swift, and the NPS would achieve their objectives quickly. Indeed, past and recent field studies show that management of cervid populations with the immunocontraceptive vaccine PZP can be achieved, and work at Point Reyes National Seashore itself has shown that PZP is a viable option and could be implemented to manage tule elk populations.
Indeed, tule elk treated with PZP at Point Reyes National Seashore between 1997-1999 had a pregnancy rate of approximately 5%, whereas untreated elk can have pregnancy rates as high as 77% a year.
Culling programs offer a short-term fix and humans are poor at detecting which animals are the healthiest. While PZP and other reproductive control agents and procedures effectively reduce fertility, lethal control may sometimes have the opposite effect. Swihart et al. (1998) found that reproductive rate of cervids is greatly reduced at high population densities, while cervids in areas subjected to periodic lethal removal have enhanced fertility rates resulting in increased population growth to compensate for animals killed. Further research also indicates that lethal removal of both sexes does nothing to stop fluctuations in cervid populations due to forage competition and natural mortality as a result of severe winter weather.
Because of these factors, the NPS must take a hard look at these options - especially in light of the social and political controversy that surrounds lethal management. Fertility control can be successfully and humanely deployed to reduce and maintain tule elk populations within the Seashore, the NPS must seriously consider such an alternative as part of its GMP Amendment and EIS.
B. Consider allowing Californias native carnivores to modulate elk herds
The newest science indicates that prey populations generally far exceed the biomass of their predators and the number of prey set predator numbers. Yet, the role of native carnivores is to hold prey numbers at levels so that they do not irrupt and then subsequently die from starvation, weather or other stochastic events. The scientific consensus for the last several decades has generally concluded that carnivores modulate prey populations and make them more vigorous, including removing the sick and weak animals who would die of other natural causes anyway.
The other benefit of apex carnivores such as pumas (or wolves) is that they can significantly influence biological diversity and ecosystem function. Biologists have found that ecologically-functioning populations of apex carnivores are instrumental in restoring biological diversity in the Northern Rocky Mountains, including increasing the number of song birds, pronghorn, lynx, and other species, while simultaneously improving the ecology of vital riparian systems.
The emerging literature on trophic cascades from apex carnivores is enormous. Pumas and wolves presence even affects soil nutrients, soil microbes, and plant quality because decomposing carcasses of prey enrich soils. Wolves and mountain lions lose significant amounts of their kills to scavengers. Wolves and mountain lions also act as a buffer to the effects of climate change by creating more carrion for scavengers and making it available year round, to the advantage of bald and golden eagles, bears, ravens, magpies and coyotes. These studies and stories are relevant and important to Point Reyes National Seashore managers even as all these species are not present here, because the most important message is that wolves and mountain lions are necessary to keep animal and plant communities healthy, vital, complex and functional.
Pumas and other native carnivores, as myriad studies show, are important ecosystem actors and help to modulate ungulate herds, by removing the sick and weak animals and preventing them from going past their carrying capacity. Native carnivores not only make their systems more biologically diverse, they are more ecologically functional-all the way to soils. Apex carnivores mitigate climate change by leaving carcasses for other animals to scavenge. Managing the elk herd using native carnivores makes sense for several reasons and the NPS must include this alternative in its GMP Amendment and EIS.
3. NPS is required to consider the best available science in determining management of tule elk in the GMP Amendment and EIS
A. Native carnivores mitigate climate change and their conservation on NPS lands is paramount
Earths temperature has warmed by 0.6 °C over the past century and may increase between one and six degrees in the next century. rate of climate change in this century is unusually rapid, which may prevent species from adapting. Climate change may be localized or widespread and it can affect food chains, nutrient flows, and the circulation of both the atmosphere and ocean currents. Scientists have predicted that climate change will result in increased temperatures, stochastic weather events, and changes in precipitation.
In U.S. national parks, Burns et al. (2003) predict that species will go extinct, including a 19 percent loss of carnivores (especially fishers, martens, and ringtails), 44 percent of rodent species, and 22 percent of bat species. As warming occurs, Burns et al. (2003) predict that a fundamental change in community structure as species associations shift due to influxes of new species As a result of these changes, a shift in the trophic dynamics will change too.
Predator-prey interactions will be altered, mammal communities will shuffle, breeding dates and producers flowering and budding will alter feeding patterns, and the abundance of species in different trophic levels will change. The need for improved corridors and connectivity is important to prevent extinctions. Species range shifts can be harmful. Invasive plants could threaten biodiversity and system integrity.
Because global warming will change ecosystems and species abilities to survive, the NPS must begin mitigation planning that includes creating wildlife-friendly habitats with connecting corridors for native carnivores such as pumas as part of its GMP Amendment and EIS.
B. If cattle operations continue on Point Reyes, the NPS must consider that native carnivores kill few cattle
While some believe that native carnivores such as wolves, coyotes, bears, bobcats and pumas are the key killers of American cattle, data from the U.S. Department of Agricultures (USDAs) National Agricultural Statistics Service (NASS) show otherwise. Figure 1 and Table 1. Far more alarming is the massive numbers of native carnivores killed each year for perceived and/or real losses to agribusiness, and the subsequent losses of ecosystem services provided by carnivores including maintaining biological diversity.
Large-bodied carnivores are sparsely populated across vast areas, invest in few offspring, provide extended parental care to their young, have a tendency towards infanticide, and limit reproduction, and in light of these biological factors, they rely on social stability to maintain resiliency. Human persecution of bears, wolves and mountain lions through predator control is super-additive, meaning that kill rates exceed naturally-occurring mortalities. This is because predator control agents kill adult breeding animals, which disrupts animals social structure and leads to indirect effects such as increased infanticide by incoming subadults (particularly male bears and pumas), resulting in the decreased recruitment of young. For these reasons, the NPS must not allow predator control of native carnivores, furthermore, most losses to livestock come from non-predator causes.
Far more cattle and sheep (4.1 million), died from non-predator causes (such as weather, illness, birthing problems and poisoning), than from predator causes (467,100). Of the total 99.6 million cattle and sheep inventoried in the U.S., less than one percent (0.47 percent) died from predation. Figure 1 and Table 1.
" Nationwide, native carnivores and domestic dogs killed less than one percent of the U.S. cattle inventory and about four percent of the sheep inventory.
" All felids together, including pumas, bobcats and lynx, killed fewer cattle than domestic dogs, taking 0.02% of the U.S. cattle inventory.
" Wolves killed even fewer cattle than the felids, or 0.01% of the cattle inventory.
Table 1: Comparison of Non-Predator vs. Predator Mortality for
Cattle and Sheep
Cattle
(NASS 2011) Sheep
2010a,b) Grand Total
Cattle & Sheep Inventory 93,881,200 5,747,000 99,628,200
Non-Predator Mortality 3,773,000 387,300 4,160,300
Percent Non-Predator Mortality 4.01 % 6.73 % 4.18 %
Predator Mortality 219,900 247,200 467,100
Percent Predator Mortality 0.23 % 4.30 % 0.47 %
C. If cattle operations continue on Point Reyes, co-existence with native carnivores is obtainable
The need for humans to coexist with large carnivores such as pumas is increasingly necessary as humans exploit their last remaining habitats. To prevent their extinction or fragmenting their populations (resulting in inbreeding), we must be willing to share habitat and tolerate the minimal risk that native carnivores pose. Non-lethal controls are often cheaper, more socially-acceptable and result in longer-term prevention of livestock losses because the social order of native carnivores is not disrupted leading to social strife and exploitation of easy prey. The exploitation of coyotes, results in more coyotes. The American public already embraces wild native carnivores, according to two comparative and seminal studies.
According to a 2017 public attitudes study, lethal predator controls such as shooting animals from aircraft (aerial gunning), neck snares, gassing of pups in dens, leg-hold traps and poisons are highly unpopular with the American public. The NPS should not permit lethal control measures on its special public lands. As part of its new GMP Amendment and EIS, the NPS must consider avoiding the use of lethal predator controls.
D. If livestock grazing is to continue on Point Reyes National Seashore, non-lethal, predator-control options must be employed
The newest studies indicate that non-lethal predator control measures are far more efficacious and cost effective than lethal ones and are far more humane. In a seven-year study of open-range sheep in Idaho, in an area where a variety of non-lethal deterrents were used (including human herders or range riders), sheep losses were the lowest in the state, whereas in a nearby control area (where, in this instance, wolves were routinely killed), sheep losses were 3.5 times higher, demonstrating that non-lethal deterrents were far more effective than lethal ones and even in an open range grazing area, contrary to common misperceptions. In central Mexico, wild cats (pumas and jaguars) were deterred using low-cost methods (e.g., dangling clothing and employing inexpensive audio and light equipment); the use of these methods significantly reduced predation in paddocks for cattle and goats compared to no non-lethal methods on nearby paddocks used as experimental controls.
" The NPS could assist cattle operators by developing risk maps- that is, mapping carnivores habitat and the locations where most livestock losses occur to concentrate prevention measures where they are most needed.
" Protect the principal prey herds (e.g., elk and deer) by preventing poaching and limiting legal overkill of wild herds.
" Keep livestock, especially maternity pastures, away from areas where wild cats have access to ambush cover.
" Keep livestock, especially the most vulnerable-young animals, mothers during birthing seasons and hobby-farm animals-behind barriers such as electric fencing and/or in barns or pens or kennels with a top. The type of enclosure needs to be specific for the predator to prevent climbing, digging or jumping.
" Move calves from pastures with chronic predation problems and replace them with older, less vulnerable animals.
" Concentrate calving season (i.e., via artificial insemination) to synchronize births with wild ungulate birth periods.
" In large landscapes, use human herders and/or guard animals (i.e., especially a variety of dogs).
" Guard dogs work better when sheep and lambs are contained in a fenced enclosure rather than on open range lands where they can wander unrestrained.
" Range riders, people who are employed to monitor cattle and sheep, monitor wild carnivores or facilitate livestock herding (keeping cattle bunched together); their goal is to reduce livestock losses by native carnivores. Range riders can more rapidly detect sick or injured cattle, who would otherwise be vulnerable to predators or to rapidly detect and remove dead cattle, reducing habituation and potential future losses.
" Use a variety of auditory and visual deterrents such as fladry (strips of plastic tied to a nylon rope and suspended above ground with stakes); turbo fladry (electrified using solar equipment); suspended clothing; LED flashing lights (sold as Foxlights); radio alarm boxes set off to make alarm sounds/noises when radio-collared wolves come in proximity of livestock; low-cost sound/visual equipment deters wild cats; spotlights and air horns.
4. NPS data show that wildlife watching on Point Reyes enormously benefits its gateway economies
Peoples spending habits are a good indicator of their values, and monetary spending shows that people both love Point Reyes and its wildlife. According to the NPS: In 2016, 2.4 Million park visitors spent an estimated $107.1 Million in local gateway regions while visiting Point Reyes National Seashore. These expenditures supported a total of 1.4 Thousand jobs, $57.3 Million in labor income, $84.8 Million in value added, and $135.3 Million in economic output in local gateway economies surrounding Point Reyes National Seashore.
The U.S. Fish and Wildlife Services (FWSs) 2017 wildlife-recreation report indicates that wildlife watchers nationwide have increased 20% from 2011 and number 86 million and spent $75.9 billion, while all hunters declined by 16%, with the biggest decline in big game numbers, from 11.6 million in 2011 to 9.2 million in 2016. Altogether, hunters spent $25.6 billion in 2016, about one-third that wildlife watchers spent.
NPS and FWS data together show that gateway communities to national parks benefit greatly from wildlife-watching tourism. A new study indicates that Americans highly value wildlife and animals, and are concerned about their welfare and conservation. Because of these factors, the NPS must consider implementing the most humane way to treat wildlife who are fortunate enough to live on NPS lands. If culling programs are permitted on elk and wild native carnivores, some may decide to spend their time and money elsewhere - curbing revenues in gateway communities and hurting local economies. Remaining elk may become wary, diminishing the wildlife-watching experience.
5. Conclusion
We are thankful for the opportunity to comment on the the initial stage of the Point Reyes National Seashores GMP Amendment and EIS, and ask that NPS fully consider humane management of the Parks wildlife-both elk and native carnivores-by using immunocontraception and non-lethal predator controls.
Sincerely,
Crystal Moreland
California State Director
The Humane Society of the United States
[e-mail]
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___________________________
# 2757
Name: N/A, N/A
Correspondence: These magestuc creatures should live freely!
___________________________
# 2758
Name: Warren, Linda
Correspondence: Dear Superintendent,
I'm writing because I'm concerned about the free-roaming elk at Pt. 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 of Point Reyes. History has shown us that if we alter ecosystems, there are many times unintended consequences. We must keep this balance.
Commercial lease holders on our public lands ARE NOT scientists & therefore 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,
Linda Warren
___________________________
# 2759
Name: Warren, Lynsey
Correspondence: Dear Superintendent,
I'm writing because I'm concerned about the free-roaming elk at Pt. 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 of Point Reyes. History has shown us that if we alter ecosystems, there are many times unintended consequences. We must keep this balance.
Commercial lease holders on our public lands ARE NOT scientists & therefore 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,
Lynsey Warren
___________________________
# 2760
Name: Warren, Leslie F
Correspondence: Dear Superintendent,
The free-roaming elk at Pt. Reyes National Seashore can be considered an endangered species which play an important ecological role in the landscape of that area. Fencing, removal, killing or sterilization could lead to unintended consequences, e.g., killing the wolves in Yellowstone Park. The natural balance must be maintained. Conversion of the land to crops or grazing could adversely affect this balance by creating conflicts with predators, not to mention degradation of water quality.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
Dr. Leslie F. Warren
___________________________
# 2761
Name: Schmid, Hans P
Correspondence: I frequently run the trails of Pt. Reyes National Seashore. I am always delighted to observe thule elk but, unfortunately, the sight of cows is often more frequent. I have tip-toed through cow manure and seen the damage cattle can cause especially during the wet season. I love the outdoors and must admit that I consider myself an environmentalist.
We are thankful to the ranchers for keeping the area development-free until the National Seashore was created. The whole idea of a National Park is to preserve land in its natural state for current and future generations to enjoy. Cattle Ranches are not natural to Pt. Reyes National Seashore. The ranchers sold their land to the Park Service for good money. Why would the Park Service pay Millions of Dollars just to maintain the status quo? The ranchers got paid but now want to operate their ranches for many more years, probably enjoying very cheap leases. They want their cake and eat it too. They occupy a substantial portion of the seashore. We should not have to fence in elk in a National Park.
There is strong pressure to offer the ranchers longterm leases. In my humble opinion I believe that all ranches within the Park should gradually be phased out.
Yes, these ranches have an economic impact on Marin County. However, there must be land / ranches outside the park in West Marin where owners are ready to retire or sell their lands. New homes for the Pt Reyes ranches could probably be found. An organization like MALT should be able to assist.
I urge you to work on a plan to phase out all ranching from Pt. Reyes National Seashore and return all its land to the natural state it was before the first settler and cattle ranchers arrived.
Respectfully submitted,
Hans Schmid
___________________________
# 2762
Name: Wheeler, Brett
Correspondence: I grew up in the area near the Seashore and began visiting the Searshore in the early 1970s. The original goal of the Park has been greatly fulfilled, to "save and preserve for purposes of public recreation, beneft, and inspiration, a portion of the diminishing seashore of the United States that remains undeveloped. However, that has been only selectively implemented, to the ecological detriment of the land of the nothern part of the Park under the General Management Plan, with a show of preference for the European Settlers over the aboriginal culture. It is time to turn the rest of the park over to nature the northern peninsula as has been the rest of the park. Only this even-handed way of stewarding the Park will live up to the need to preserve the area in its "natural setting, and protect it from development and uses which would
destroy the scenic beauty and natural character of the area."
It is clear that the management of Southern and Central segments of the park during the past decades has enabled much of those southern and central areas to evolve toward the period before indigenous peoples or European settlers arrived. All of the ecosystems along the ridge area have been allowed to develop without regard to the cultural or economic activities of pre-European peoples. Oak groves give way to fir forest. It now makes sense to allow the entire park to share in that evolution and not privilege certain cultural groups or economic practices such as those that are represented by farming in the northern part of the park. Therefore, the integrity of the park would be best served by the "No Ranching and Limited Management of Tule Elk" alternative under consideration.
Others have fully documented the extraordinary ecological impact of farming on the land. This includes the extensive destruction of native species and their ecosystems. It is also evident that the indigenous flora and fauna have the capacity to reestablish an ecological balance. This balance requires the complete or near-complete removal of the current economy of ranching, in particular the herds of stock and dairy cattle that make the return of the prior ecosystem impracticable.
As a citizen, a lover of the park, and a local resident of many years, I honor the ranchers and the cultural history that is so integral to West Marin. My family was part of the culture. However, this land is precious resource that cannot be replicated elsewhere. The goal of the Park to provide recreational land in its "natural" form can only be served with the gradual removal of the farming economy and its infrastructure. It is also the only way to treat equally the different peoples who have lived on this land and not prioritize those who arrived more recently.
___________________________
# 2763
Name: washburn, constance
Correspondence: National Parks Service - Point Reyes National Seashore General Management Plan
I recommend the alternative of continued ranching and management of the Drakes Beach Tule Elk Herd because it allows ranching to continue with long term leases and the elk to thrive if properly managed and provides a far reaching educational opportunity.
The Point Reyes National Seashore has an amazing opportunity to be an example for the world and educate the public about the positive possibilities at the intersection of wildlands and agricultural lands. Humans do need to eat and therefore grow/raise food and unfortunately in many places we are doing that in ways that negatively impact the environment. This does not have to be the case. The Park and the Ranchers have an opportunity to work together using the most up to date techniques to demonstrate how to raise domestic animals in collaboration with and in support of natural systems.
Grazing agriculture can be a beneficial force on the landscape when used correctly because it controls invasive species and can build healthy soils that sequester carbon with proper management and application of compost. The Park should support the ranchers in all ways possible to manage their lands and herds in ways that promote soil and water health and sequester carbon. For more information on grazing and composting benefits see http://ucanr.edu/sites/uccemarin/files/31000.pdf#page=7 & http://www.marincarbonproject.org/science/land-management-carbon-sequestration.
The Elk herds and the lands they graze likewise need to be managed so that they are not competing with the beef and dairy cows. There needs to be a fence to keep the Elk off the dairy and beef pastures. The Elk grazing lands like the beef pastures should be composted to sequester more carbon and provide better forage for the elk. This will make them less likely to invade the ranches. The "wilderness" areas could also benefit from controlled burns to manage invasives and keep healthy pastures open for the Elk.
The millions of visitors to the park would benefit from learning about the best rangeland management practices demonstrated in the Park and learn about the ways that food can be raised in harmony with nature. There should be interpretive tours and signage about the ranch management techniques that sequester carbon and build soil, encourage native species, and produce food. This is what we a species need to learn to do everywhere on the planet. Let us start here in Point Reyes National Seashore.
___________________________
# 2764
Name: Du Preez, Sieglinda
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,
___________________________
# 2765
Name: Alexander, Vicki C
Correspondence: I am writing in support of the free-roaming tule elk herds at Point Reyes National Seashore. I am a Bay Area resident, a conservationist, and a long-distance hiker. I love seeing the Tule Elk herds at Point Reyes, and I understand that the current herds are a success story for recovering a native species. I object to any fencing, removal, sterilization or killing of elk in the park.
Any cattle-ranching operators on our public lands are leaseholders, and I hope that they aren't setting policy. I also hope that commercial operations that have the opportunity to lease in our parks are required to have management practices that accommodate elk and other native wildlife, and that their operations don't harm habitat for endangered species.
I also urge you to reject any conversion of national park lands to row crops, and I also would like you to reject the expansion of commercial livestock farming to iinclude sheep, goats, turkeys, chickens or pigs. Such expansions would create conflicts with predators and would degrade wildlife habitat and water quality. Row crops and commercial farming aren't my vision for our national parks.
The Park Service's amendment to the General Management Plan should prioritize protecting the natural values of Point Reyes National Seashore.
Sincerely,
Vicki C Alexander
___________________________
# 2766
Name: N/A, N/A
Correspondence: Please protect the tule elk at point reyes national seashore. We do not need more cattle, we need more indigenous species
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# 2767
Name: Caldwell, Brenda P
Correspondence: Please protect the tule elk at Point Reyes. Protection of native species plays a part in protecting our planet from environmental degradation leading to global warming. Native species consume native plants which can then thrive and absorb carbon dioxide. Upsetting the balances of native species Is contributing to global warming. Please discontinue this disastrous plan of managing the time elk,and allow them to roam free.
___________________________
# 2768
Name: Klammer, Linda G
Correspondence: I am a retired U.S. Navy Nurse who owns and rides horses for recreation and physical therapy. After more than 20 years in the military, I now have the time and resources to enjoy trail riding and horse camping. I have camped with my horse at Point Reyes National Seashore, at Stewart's Horse Camp, many times over the past ten years and have found the varied terrain both extraordinarily beautiful and well maintained. The amenities at Stewart Horse Camp are rustic (as they should be) and more than adequate for horsemen. In addition, Amanda has always provided personable, informative, knowledgable, and safety-inspired service to us campers.
Because affordable horse camping facilities for both individuals and groups are already so few, and because Point Reyes is really such a unique and inviting place for horsemen, I most strongly urge you to retain Stewart Horse Ranch as an equestrian campground. Thank you.
___________________________
# 2769
Name: Nguyen, Don
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,
Don Nguyen
___________________________
# 2770
Name: Legacy, Daniel
Correspondence: Keep the ranches and tradition alive in Marin.
If you want elk management bring back the black bear
to the area.
First it was the oysters and now the ranches, I knew this
would happen.
___________________________
# 2771
Name: Dinkelspiel , Patricia F
Correspondence: We need our indigenous ranches to remain at their original locations to add diversity and local artesian lifestyle to our seashore.
___________________________
# 2772
Name: K, James
Correspondence: I have traveled to Point Reyes from Ohio multiple times and have then gone on to other parks in California and to Napa. If Point Reyes land is converted to more farm land and elk, coyotes and bobcats are removed or frightened off there will no longer be any reason for me to visit the area. I have hired guides for this park and others and staid at locally owned and operated lodges plus rented cars and purchased gas and food. All of this provides jobs for California small businesses, which will be put at risk by the land use change. If Point Reyes National Seashore becomes an artichoke farm or some other increased agricultural use then there will be a significant negative impact on tourism which will affect many small businesses.
___________________________
# 2773
Name: Sooby, Jane
Correspondence: Cynthia MacLeod, Acting Superintendent
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes Station, CA 94956
Nov. 15, 2017
Re: Point Reyes GMP Amendment
Dear Superintendent MacLeod,
Thank you for accepting public comment on the conceptual range of management alternatives for the Point Reyes National Seashore General Management Plan Amendment.
CCOF is a nonprofit organization governed by the people who grow and make our food. We are supported by an organic family of farmers, ranchers, processors, retailers, consumers, and policymakers. Together, we work to advance organic agriculture for a healthy world.
National Park Service (NPS) should consider all alternatives that will allow organic dairy and beef producers to continue their excellent stewardship of land and animals in the park. These certified organic operations are continuing the 150-year local tradition of managing these sensitive grasslands as working lands that produce high quality meat and dairy products. As certified organic producers, they are regulated under federal law and required to manage pastures and other outdoor access areas in a manner that does not put soil or water quality at risk.
CCOF is especially concerned about economic impacts to long-established organic livestock producers in the area. Elk that have traveled beyond their designated refuge areas pose a challenge to our certified organic livestock producers. Under federal organic standards, organic livestock producers must graze their animals on pasture for the entire grazing season and ensure that their diets contain at least 30 percent dry matter from certified organic pasture. The tule elk consume forage that organic ranchers need to meet the pasture standard. Feed or hay purchased to supplement pasture must be certified organic, which is much more expensive than conventional feeds and often difficult to source. Therefore, elk could threaten a rancher's ability to supply cows with adequate forage, which in turn would increase the cost of locally grown dairy and meat products.
It is increasingly difficult for organic livestock operations in California to find accessible and affordable land to continue or expand production. The unique partnership between NPS and ranchers provides the rare opportunity to support local, organic dairy and beef production. It is imperative that NPS find a means to balance protection of the tule elk with the environmental and economic benefits organic livestock bring to the local community.
For these reasons, NPS should modify the alternative
"Continued Ranching and Removal of the Drakes Beach Tule Elk Herd" to read
“Continued Dairy Farming and Ranching Combined With Removal of the Drakes Beach Herd and the Portion of the Limantour-Estero Road Herd Found on Rangelands.”
Conflicts between wildlife and agriculture on public lands are difficult to address, whether or not there are natural predators to control the size of wildlife populations. The National Park Service has an obligation to carefully balance the historical commitment to ranching and dairy production on the National Seashore with the need to responsibly manage the introduced elk populations.
Thank you for consideration of our comments. Please do not hesitate to contact me for further information.
Sincerely,
Jane Sooby
Senior Policy Specialist
cc: Cathy Calfo, CCOF Executive Director and CEO
Kelly Damewood, CCOF Director of Policy and Government Affairs
___________________________
# 2774
Name: Gallagher, Jean
Correspondence: I have been hiking Pt Reyes for decades, almost from the beginning, and find the ranches an integral part of the Pt Reyes experience. Without the desire to preserve the land for agriculture, it is unlikely that Pt. Reyes National Seashore would even exist today. With respect and appreciation for that legacy, I am 100% in favor of granting the 20 year leases and making it financially feasible for the ranch owners to continue investing in innovative, sustainable and environmentally friendly practices.
___________________________
# 2775
Name: N/A, Adri
Correspondence:
Dear Superintendent,
I live in Elk Grove, CA- ELK Grove. And there are no Elk. They are extinct in our region. They were here first, give them some respect. They should be treated as preciously as our Nation's Bison.
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,
Adri Walker
___________________________
# 2776
Name: Harston, Sharon
Correspondence: Please keep the livestock in Pt Reyes Park. Taking them away will result in increased fire fuels and in 20 years will probably be overtaken by brush. The ranchers are excellent caretakers and a much better brush management system than having to hire brush control done. Dr. Larsen spoke at a recent Sonoma County Board of Supervisors meeting about while there was some fire in grazed areas how much cooler the fires burned in the grazed areas.
___________________________
# 2777
Name: Guggenhime , Marjorie A
Correspondence: I strongly favor keeping the commitment made to the ranchers when they made their land available to all of us.
Surely we can coexist with the cows. There's plenty of space for all of us.
___________________________
# 2778
Name: Forer, Danny
Correspondence: I feel that ranching in not compatible with wilderness. This special place, Pt. Reyes, is for all people of the Bay Area and beyond. It is time to end the contracts with the ranchers, and restore the land.
___________________________
# 2779
Name: Hoge, Emily
Correspondence: I believe that the Park Service should extend leases to all the ranches in the pastoral zone. I think the original intension of the formation of the park was to preserve its agricultural heritage. I enjoy the wide open pastoral views and the picturesque ranches. I have seen countless visitors photographing the historic buildings. It doesn't take long for the brush to start to fill in when cows are removed. The Glenbrook trail is a good example. I don't think that the park can recreate "pristine wilderness" in the pastoral zone. The efforts to control invasive species in the park have largely failed and I believe that without cattle grazing there would be an acceleration in the spread of invasive plants. Like it or not the landscape has already been irrevocably altered. The budget of the park will not stretch far enough to maintain the historic buildings and manage the land. I think that Park Service should not be influenced by environmental groups who's motives and agendas should be questioned. I believe that most park visitors want to keep the ranches, I know I do.
___________________________
# 2780
Name: Richards, Wynn
Correspondence: I am strongly opposed to Tule Elk extermination! No sterilization, no "management," but let them live!
Sincerely,
Wynn Richards
___________________________
# 2781
Name: Young, Scott R
Correspondence: Point Reyes National Seashore should be for ALL the citizens and Wildlife to enjoy Not an elite group of ranchers paying practically nothing to barb-wire and control large swaths of public owned land. The destruction the for-profit ranches cause will last for decades, maybe centuries. Return the land back to the citizens and wildlife, so the land and nature can start the long healing process. From, Scott Young
___________________________
# 2782
Name: Spital, Wade
Correspondence: The Tule Elk are part of the beautiful and majestic heritage of the Point Reyes National Seashore. Given this and the fact that they inhabited these lands long before us, I feel it's a moral imperative that we preserve the viability of their habitat. I therefore urge you to adopt the second proposal entitled: "No Ranching and Limited Management of Tule Elk". Thank you for considering my position.
___________________________
# 2783
Name: Finn, Anya
Correspondence: Let the elks live.
___________________________
# 2784
Name: Tomko, Bradley A
Correspondence: Dear National Park Service,
I vehemently urge you to adopt the GMP Amendment for "No Ranching and Limited Management of the Tule Elk".
The Tule Elk of the Point Reyes Seashore and GGNRA should be fully protected from the Ranching/Dairy industry on the basis of their natural and historical significance and the preservation of the beauty and purity of these lands. To allow the Elk to be exterminated to further an inhumane and environmentally irresponsible agenda would be a disgrace to the department you serve. Furthermore, any decision less than driving out these rancher/dairy profiteers would be in defiance to a well established national trend of compassion towards animals and a more plant based diet for humans which is most prevalent in the SF bay area.
Please resist the pressure to capitulate to an overdeveloped, ethically reprehensible and environmentally exploitative industry and show the courage to support the popular will to preserve our cherished fauna and natural beauty.
Sincerely,
Bradley Tomko
___________________________
# 2785
Name: N/A, N/A
Correspondence: I vote for the No Ranching and Limited Management of Tule Elk. Let's improve the visitor experience and attract local hikers and tourists. Tule Elks are majestic sightings, while dairy and cattle ranches degrade the nature experience.
___________________________
# 2786
Name: della valle, lisa M
Correspondence: I would like to support the the Park Service's proposal to allow existing ranch families to continue beef and dairy operations with 20-year lease/permits and tule elk in the Drakes Beach area would be managed at a level compatible with authorized ranching. Let the cows have their area, the herd it's Area and the continuation of sustainable agriculture in the Seashore and GGNRA.
Thank you
___________________________
# 2787
Name: Dundas, Ruth
Correspondence: Re: PRNS GMP update
Ranching at PRNS should have as its goal to be exemplary and highly sustainable.
Thus I support only the NPS Initial Proposal because I believe it is the only concept that is consistent with Secretary Salazar's Order, existing NPS policies for public access and cultural and natural resource protection and also with PRNS enabling legislation and contemporaneous records of Congressional intent that families who were owners or lessors of land sold to create PRNS should be allowed to continue "ranching and dairying."
Sincerely,
Ruth Dundas
___________________________
# 2788
Name: Ford, David S
Correspondence: I strongly oppose any elk management that would limit elk population growth. They are a rare California treasure and should be allowed further expansion on public lands. To the extent that ranching is compatable with elk population growth it should be continued and alternative income for ranches (e. g. Bed and breakfast or other tourist services)should be encouraged. Of the plans offered, continuing current management (no action) would be best.
___________________________
# 2789
Name: N/A, N/A
Correspondence: Save the elk!
We don't need more dairy or beef farmers. America eats too much meat... it is bad for our health and bad for the animals.
___________________________
# 2790
Name: Parkinson, Leroy T
Correspondence: The National Park Service was created to protect and preserve America's natural treasures and wildlife for present and future generation. Please continue to do so and protect the land and elk living on it from encroachment of private interests. Thank you, Leroy T. Parkinson
___________________________
# 2791
Name: Palmer, Guy V
Correspondence: Just want to say that as a long time resident of Marin county (family moved here in 65) I'm very supportive of exenting the leases for the ranchers. I think grazing and erosion issues would be better dealt with when long term leases are in place. And the long term ranching families ( I had the pleasure to meet an individual whose family is one of those long term families -gallagher) should be allowed to stay as long as they desire.
___________________________
# 2792
Name: Newacheck, Paul
Correspondence: I would prefer to see Point Reyes National Seashore as a true nature preserve without the intrusion of commercial enterprises like the dairy farms/ranches.
___________________________
# 2793
Name: scott, Janel
Correspondence: I am expressing my concern and anger over the park slaughtering all the elk to give room for the ranchers to have the land. First of all, it is federal land and they have no rights to it. I implore you to end this plan. Those elk have first rights to the land which is their habitat. Why should the greedy ranchers take over land that they are not entitled to? I am so angry that you even consider this an option. Let them spend their own money and figure out how to take care of their animals. The elk have rights to that land and your idea, like most people in this area, is to kill everyone off who is in their way. I,for one, will not stand for this. Killing elk IS NO ANSWER!!! You have a responsibility to protect them without cowering to these bully ranchers.
Do the right thing..this is NOT it!! Thank you.
___________________________
# 2794
Name: Sullivan, Mary F
Correspondence: I visited Pt. Reyes this weekend for a hike. We had several options to consider. There is ample room for both ranchers and hikers. We've enjoyed seeing the cattle grazing as we drive through Pt. Reyes. Leave the ranchers alone.
___________________________
# 2795
Name: N/A, N/A
Correspondence: I support the park service's latest alternative allowing existing ranch families to continue beef and dairy operations with 20-year leases or permits.
___________________________
# 2796
Name: Higgins, Cheryl D
Correspondence:
Thank you for the opportunity to comment. I am a local resident and am strongly in favor of continued ranching in the Park - - both dairy and beef. I would like the Park to assist in making the ranches economically viable and in developing best practices that protect the environment.
My considerations are to protect the environment, the historic nature of the Park, the cultural character of the town, employment on the ranches, and small family farms.
At the same time, I urge the Park to carefully study any new proposals from the ranches for expanded use that might cause increased automobile traffic for tours, picnics or purchases. I am afraid that such entrepreneurial efforts would create a situation like the one we had recently on Highway 1 in Marshall, where long lines of cars carried visitors to the oyster farms for picnics. This created a hazardous situation, as visitors tried to drive, and even park and walk, along narrow roads. Let's not create this situation on Sir Francis Drake, Pierce Point Road and Highway 1.
Thank you.
Cheryl Higgins
Full Time Inverness Park Resident since 1998
___________________________
# 2797
Name: Edwarda, Kristi L
Correspondence: I stand with the ranchers. I would like to see the Point Reyes National Seashore reflect the history of this area and be a showcase of how humans can appropriately interact with the natural world for the sustainability of all. It is too bad that the Park Service missed this opportunity with the oyster farm - an example of the possibly the best form of sustainable protein production with the least carbon footprint. I believe that human beings are part of the natural world, not apart from it. We cannot separate ourselves and keep the 'wilderness' in a 'box' untouched by human hands. I lived in West Marin for over 43 years and visited the park frequently. I never felt that the ranching community hampered my enjoyment of the park, but contributed to my appreciation of it.
___________________________
# 2798
Name: N/A, Peter
Correspondence: I have lived in Marin County on and off for over fifty years. It's time to remove cattle from the National Park. They were supposed to be out by now.
The former Interior Secretary Ken Salazar was biased in favor of cattle, being a rancher himself.
Cattle are not compatible with a natural area, and it is a handout to a few people.
I would like a lease in the park, to establish a motorcycle recreation area. I know this will likely never happen, given the location and the density of environmentalists here, but it is what I would like to see. Off road motorcyclists were run out of the hills in the 1970's, and state promises to establish OHV parks were all lies.
Maybe if the Interior Secretary was a motorcyclist?
I see this whole process as crooked, with wealthy, well-connected ranchers having undue influence.
___________________________
# 2799
Name: Hall, Bronwyn H
Correspondence: I prefer this alternative: Continued Ranching and Management of the Drakes Beach Tule Elk Herd. I like the historic mix of wild places and ranching, and 20 year leases provide more incentive to manage the landscape well. I was very sorry to see the oyster farm go and I don't think Point Reyes should be a complete wilderness, given its proximity to civilization.
___________________________
# 2800
Name: N/A, N/A
Correspondence: As a native of Marin County, California, I strongly and absolutely support continued ranching in the Point Reyes National Seashore. Please extend these leases for at least twenty years. I would support longer extensions if you would make them available.
___________________________
# 2801
Name: Ryken, Ed T
Correspondence: Ranching has been a part of the Point Reyes area for long before the National Park began in the region. I was on the committee to expand the park when Peter Behr put forth the petition. Ranching was always a part of the discussions so as to maintain the rich character and history of the Seashore. Cattle ranching and Dairy ranching should continue in the park.
Tule Elk were brought back to capture the same rich feeling of what used to abound in the region. Keeping the Elk also offers a rare opportunity for young families to observe what the area may of looked like in the past. When we loose site of our past we destroy our future. The real issue is maintaining a workable balance.
___________________________
# 2802
Name: Garb, Linda
Correspondence: I support giving 20 year agricultural lease permits to the current ranchers and their families.
___________________________
# 2803
Name: Baack, Lawrence J
Correspondence: The current list of alternatives is incomplete. Surely, one of them should be that the elk should be removed from the ranching areas. Specifically, the elk should be confined to the wilderness area south of Limantour, in addition to their initial range on Tomales Point. They should not be co-mingled in the pastoral zone with ranching operations and animals, for reasons that are well known. Also the elk were reintroduced to the area in recent years and should not be included in the 150 year environmental baseline. The negative impact of the elk in the permitted ranching areas should be analyzed in the EIS.
Fundamental to the analysis of possible alternatives are two points: The Point Reyes National Seashore was created by the purchase of private properties, overwhelmingly ranches, and was envisioned from the outset as a mixed use park. Its history in this regard is quite unique. Second, ranching on the Point is historic in nature and is an important part of the cultural and ecological history of the peninsula. With this in mind, the preservation of agriculture on the Point is essential to maintaining the cultural heritage and agricultural contributions of the region. Thus a goal of this assessment should be how to sustain viable ranching out on the Point and to ensure sound mechanisms are in place to make the operations of the ranches examples of environmental and agricultural best practices. The ranches play a very important role in maintaining an agricultural community in the North Bay through the production of local food products, employment opportunities for members of the community and a visual and experiencial presence for understanding the importance of agriculture in the modern world - and doing so in a location adjacent to a major global metropolitan area. This is an extraordinary opportunity for learning.
In that sense, the ranches will be sustainable if they are allowed to diversify in sensible ways - ways that add to the community. These could include the offering of tours to the public , including schools, the processing and selling of their own food products as is done by local farmers in Europe, and much more flexibility in grazing management (best practices) and the diversity of animals raised. For all of this to work it is essential for the ranches to have 20 year rolling leases so that they can plan and make the improvements and investments necessary to pursue best practices in the management of the agricultural/environmental equation. Further, the ranches should be able to add worker housing. Housing is very expensive in the area, as we all know. If we want to maintain diversity in the county, to reduce the strain on families of long commutes and to enhance economic opportunities for our community, then additional housing is essential.
I have been coming to Point Reyes since I was a little boy. I am now 74. It is a very special place - beautiful and magnificent for its diversity and inherent character. I am a long time member of the Sierra Club, MALT, the Tomales Bay Association, the Green Belt Alliance and the Point Reyes National Park Association. In the 1990's, I was asked to chair the Bay Area Defense Conversion Task Force which had to deal with the reality of 12 closing military bases in the Bay Area. That presented daunting environmental and economic issues for our local communities. We are still working on those. In that context, Point Reyes presents a really unique and marvelous opportunity. I believe a healthy environment and successful, sustainable agriculture are compatible at Point Reyes. The can be achieved at the same time and should be. Point Reyes, can be , and should continue to be a model of that kind of synthesis and partnership
___________________________
# 2804
Name: N/A, Heather
Correspondence: Cease ranching operations. Leave the elk to roam free on the land. Stop exterminating wild animals to satisfy industry greed. Our wild places and wild animals are important parts of our country.
___________________________
# 2805
Name: W, Shiki
Correspondence: PLEASE don't kill these beautiful elk! They are protected in this reserve! Do not commit crimes against nature inside a national park! If you do this you will move us backwards in time.
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# 2806
Name: Brauer, Laurence
Correspondence: Dear Ms. Gunn,
I am a longtime visitor to Point Reyes National Seashore and 42 year resident of Marin County and 32 year resident of San Geronimo Valley. During those 42 years, I have hiked virtually every trail in the Seashore (many multiple times), regularly camped at the backcountry campgrounds, picnicked at Bear Valley countless times, and spent numerous days at all the beaches. As a resident of West Marin, Point Reyes National Seashore has been my wife and I's bit of paradise almost in our backyard. Therefore, we are extremely concerned about any proposed changes to the Seashore.
I support the "Continued Ranching and Management of the Drakes Beach Tule Elk Herd (NPS Initial Proposal)". When I first heard of this proposal before the lawsuit, I thought it was the best way to preserve the Seashore for future generations while continuing the vital partnership between local ranches and the National Park Service.
The other alternatives would upset the delicate balance that has been established between the Park and the ranches. The “No Ranching and Limited Management of Tule Elk” alternative is an overly extreme reaction to problems caused by the interaction of ranches and elk. The current and historical ecology of the Point Reyes Peninsula would be devastated. An unmanaged elk herd would possibly cause unforeseen consequences both to the surrounding communities and the elk. The “No Dairy Ranching and Management of Drakes Beach Tule Elk Herd” alternative is problematic on several fronts. Eliminating ranching and managing the elk herd would still devastate the current and historical ecology of the Point Reyes Peninsula. Ranching has long served a vital function in maintaining the delicate balance between humans and nature on the peninsula.
I find the “Reduced Ranching and Management of the Drakes Beach Tule Elk Herd” alternative to be acceptable, but not preferable to the NPS Initial Proposal. The “Reduced Ranching” alterative is unclear about what ranches would be closed. The alternative states, “Most of the areas identified for closure do not have developed complexes or permitted residential uses.” I am uncomfortable with the language of “Most of the areas” instead of “All of the areas.” What specific areas are slated for closure? I agree with the “agricultural lease/permits with 20-year terms.” The ranchers deserve to have the long-term surety of their continued existence within the park.
The “Continued Ranching and Removal of the Drakes Beach Tule Elk Herd” is the other extreme of the “No Ranching” alternative. Eliminating the elk when management is possible is cruel and unnecessary. The “No Action” alternative would simply continue the current problems of elk-human interaction that caused this need for amending the General Management Plan and will probably lead to another lawsuit.
Please continue to manage Point Reyes National Seashore as outlined in the Initial Proposal. It is obvious to any long-time visitor and user of the Seashore that a special equilibrium exists between humans and wildlife in this unique area. Indeed, the Seashore has long exemplified how to maintain a balance between people and the preservation of magnificent natural beauty.
Thank you for your consideration.
Sincerely,
Laurence Brauer
___________________________
# 2807
Name: Rodney, Ray
Correspondence: I do not yet have a preferred alternative, but believe it is critical to address the following questions.
The General Management Plan Amendment must protect, restore, and preserve park resources using ranch leases that ensure multi-generational, environmentally sustainable ranching is complementary to the natural resources and visitor experiences within the park.
1. Protection of Natural Resources:
Based on NPS management policies, what criteria and processes will the Seashore utilize to ensure the preservation of natural resources and the prevention of habitat degradation in the pastoral zone?
2. Diversification
Diversification is an inherently confusing term that needs to be defined so that the public understands that it could bring a dramatic shift of commercial land use within the Seashore. Without a definition or context it is difficult to comment on what this term means. I understand ranching operations are limited to dairy and cattle ranching as intended by the enabling legislation. That should not allow commercial conversion of pastoral land to uses other than dairy or cattle ranching.
3. Tule Elk
The Seashore is the only national park with a native population of tule elk. The Elk have been prevalent in the Bay Area and Marin for thousands of years, long before their extirpation in the 19th century. The Elk are park of the Seashore's natural resources, just like the seals and whales, and are an important part of the ecosystem. Considerations to manage Elk populations should be made based on the context of park policies that manage other natural resources. The Concepts all reference some type of "management" strategies for the Elk herds. I do not support culling the herds.
4. Climate Change
Climate change will impact park resources in the near future in many ways: to mention a few, sea-level rise, average temperature changes, changes in average rainfall totals, and distribution of native species. These impacts will alter the Seashore. For example, areas that border beaches and estuaries will experience increased flooding and migration of boundaries into the pastoral zone. This includes marine wilderness areas like Drakes Estero and Abbotts Lagoon that will eventually migrate into the pastoral zone. How will the Seashore manage these changes?
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# 2808
Name: Reichert, Elaine
Correspondence: Given that the Point Reyes National Seashore was created through an alliance with the local ranchers, this important aspect of land use should be protected in perpetuity. These good farmers cooperated with the formation of the Seashore with the express promise that ranching would continue to be part of the mix. These folks are very good stewards of the land and have worked to improve and implement practices that protect streams, land and natural resources along with sustainable dairy, beef and other food production methods. They need long term leases to assure their continued survival.
The elk herds were originally brought to the Seashore for hunting. The herds need regular culling to remain viable. The Park Service has done a terrible job of this, especially the egregious suffering deaths of 250 elk due to lack of water during the recent drought. Unconscionable. Elk meat is a delicious, sustainable, natural food which should be made available to local markets through humane slaughter of excess animals on an annual basis. Could be a good source of revenue too.
It's sad to see a few vegan extremists causing trouble for the majority who support our vital local agriculture. There are no factory farms in Marin nor in the Seashore. Give our farmers 20 year leases at a minimum so they can continue to provide us with great, local food, carbon sequestration, and bucolic vistas.
Thanks.
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# 2809
Name: BAUERNFEIND, MICHAEL
Correspondence: Park Service Personnel:
My wife and I began hiking into Point Reyes in the late 1960's. It was truly magical at that time, even with the farms going north from Bolinas. As a young attorney I worked on a number of environmental projects. I filed an amicus brief in Sierra Club v. Morten case before the Supreme Court. I have seldom strayed away from my commitment to the planet we all enjoy. I visit Point Reyes at least twice monthly for an extended hike. Not once have I considered the historic farms out of place or inconsistent with the "wildness" of Point Reyes. These cattle farms provide us with some of the most majestic views available on the entire West Coast. It shows me that family run farms can coexist with fauna and flora diversity.
I urge you to grant 20 year use permits to the farmers who deserve some security in their farming ventures. I want Point Reyes to exist as it has for the past 150 years with wildness and family farming. Coexistence is beneficial to everyone, park users and ranchers alike!
Most sincerely,
MICHAEL BAUERNFEIND
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# 2810
Name: Lewis, Matthew E
Correspondence: Ranching in the Pt. Reyes National Seashore is not just an agricultural business that solely benefits the few remaining pioneer families left in West Marin, but is a business that is vital to the health and well being of the National Park, the GGNRA, and to communities of West Marin.
First of all, these are multi-generational ranches whose families have managed these ranch lands for all of their lives. From the day they are born until they day they die, these ranchers work hard everyday tending their stock, mending their fences, and doing the never ending chores that are required to make a few bucks selling their beef and dairy products. They know how to manage these lands better than anyone else, and have managed to remain doing what they do best, in spite of having to put up with the ever increasing regulations, decreasing grazing lands, and the ever present legal battles (brought on by folks who don't even live here)that constantly threaten their homes and livelihood. These families are the heart, sole and character of the communities of West Marin. They live and breath West Marin. They are the essence of West Marin. We don't call, Pt. Reyes, "Cow Town,"for nothing!
Secondly: Grazing cattle on the hills, keeps the land open and accessible. Cattle are an integral part of the "Scenic environment" that the environmentalist are so afraid of losing. For example: when driving north on California, Hwy 1, between Bolinas and Olema,in the Olema Valley, you will see to the right of the highway, open, green pastures, intermixed with redwood, bay and oak trees that are thriving along with the cattle of the Giacomini Ranch! It is absolutely beautiful! To the Left of the Highway, where the cattle has been removed from the land at Five Brooks, there is nothing but tick bush, mesquite, and layers upon layers of dead brush that is choking out the trees and becoming more and more inaccessible to enjoy. It is dead and Ugly. The tourist industry depends on the accessibility and Beauty of our park lands, and the ranches and cattle vital for those reasons.
The most important reason for keeping the Ranches and the cattle grazing in our park lands, is fire protection. As a matter of opinion, the National Park and GGNRA should seriously consider expanding grazing throughout the parks in order to reduce the enormous amount of fuel that has been building up all over our hills ever since the the PT National Park and the GGNRA took away most of the grazing lands and ranches from Sausalito to Pt Reyes.
Since the 1960s, the National Park and GGNRA and California State Park has been kicking out the ranchers and removing the Cattle from the hills in and around the towns of Tam Junction, Mill Valley, Muir Beach, Stinson Beach, Bolinas, Olema, Pt Reyes, Inverness, Inverness Park, Fairfax and the towns of the San Geronimo Valley, etc., and have let everything grow! For almost sixty years the old ranch lands have been growing and dieing and being aloud to "Go back to Nature", and so much so, that most of the hills are not accessible because of the overgrowth and undergrowth is so thick. The fire danger in West Marin is so much greater than the counties north of West Marin before the recent devastating fires, it is ridiculous. Controlled burning is expensive, dangerous, and useless. Cattle feasible way to reduce the fire danger, make the parks more accessible & Environmentally Scenic,and help to keep the tourist industry and the agricultural industry thriving in West Marin.
It is only a matter of time before West Marin Goes up in Flames. The greatest fire danger to the West Marin Communities comes from the parks and the ever increasing fuel for fire they are creating.
Keep the Ranches. Give them their 20 year leases. And,for all of our sake,put the Cattle back on the hills.
Matt Lewis,
Bolinas, Ca.
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# 2811
Name: Pogorzelski, Stacey
Correspondence: Hello,
I am a Marin County resident who often hikes, birds and visits beaches at pt reyes national seashore. I support the ranchers AND support the NPS to upgrade the environmental quality of the ranches. As the landowner, NPS should improve the land (e.g. vegetating riparian areas, restoring native grasslands) and then require as part of the lease that ranchers use the land to protect/keep these environmental values. obviously, the NPS will need to spend money to do this, and not assume the ranchers can do it all and have ways to monitor the lands. Environmental review makes a lot of sense 50 years into the ranch/park arrangement, especially in light of climate change affecting sea level and animal migration (to name a few examples). Thank you.
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# 2812
Name: Claassen, Deborah
Correspondence: As a long time Marin County resident, homeowner and taxpayer, I am writing to express my outrage at your departments plans to exterminate the iconic Tule Elk. You have already killed off most of the predators and now you have a problem with the prey. It is time to let nature take care of itself and stop encroaching on their lands.
When our family moved to California over 18 years ago, we could have purchased a home anywhere in the bay area. We chose Marin for its natural beauty and commitment to keeping its wild spaces pristine and accessible. We enjoy the ability to roam our county and encounter the wild residents who find safety here. We consider it a privilege to share our environment with them and a blessing to see them in their natural habitat.
I have watched in horror as our county leadership has slowly but surely eroded the protections for the animals who have been pushed out due to development and the ever encroaching human influence. The ranching community has been taking over far too much of our public land and it is time for them to support themselves and keep their herds managed. We tax payers are weary of subsidizing their dying business.
Please stand up for those of us who pay our taxes and appreciate our wild spaces and those we share it with. Please spare the Tule Elk and "manage" the real invasive species...the ranchers.
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# 2813
Name: N/A, Lindsay
Correspondence: I would like ranching leases to expire and the lives of the elk to be saved.
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# 2814
Name: Ringer, Lindsay N
Correspondence: The alternative "Reduced ranching and management of the drake's bay tule elk herd" seems appropriate. It protects historic ranch lands and provides additional area for wildlife habitat, research, and conservation within the Point Reyes National Seashore.
This negotiation should also provide alternatives to the ranchers whose land is being converted to open space with other potential farmland through cooperation with the county and the local RCD and Agricultural Commisioner's office. NPS should provide reasonable similar cost alternatives to the leasees and landowners.
In addition, the restoration methods for tule elk grazing lands should go through a review process to help with prioritization of best management practices in partnership with the NPS SFAN Inventory and Monitoring Program.
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# 2815
Name: Feral, Priscilla
Correspondence: On behalf of thousands of Friends of Animals's members and supporters in California, we favor the second proposal which allows ranching leases to expire, and the lives and integrity of Tule Elk to survive in a climate where far too much emphasis has been given to the meat industry's demands. Tule Elk deserve the protection this proposal offers. In addition, the environment can't be improved by catering to an industry that pushes wildlife off the land for the benefit of private ranchers. This is especially true during an age where many people are seeing the benefit to their health, animals and the environment by not consuming animal products.
Priscilla Feral
President
Friends of Animals
www.friendsofanimals.org
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# 2816
Name: breitman, patti
Correspondence: Thank you for extending the comment period until Wednesday. Here is my comment:
There is no good reason to renew the lease for ranchers at Pt. Reyes.
People who cite tradition as a reason forget that not all traditions are worth carrying on. Child labor was a long standing tradition. Women as property was an enduring tradition. Even slavery was a tradition before it was understood to be abhorrent. Now, separating new born cows from their mothers, isolating the infants, and taking the milk for human consumption is a cruel tradition that should end. Witnessing the white shelters in which those baby cows are held breaks my heart every time I visit Pt. Reyes. There is no justification for renewing the lease for dairy or beef farmers in our national seashore, just as there is no need to drink the milk of cows or to eat their flesh for human health.
Please do not renew the leases for ranchers at Pt. Reyes.
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# 2817
Name: Meadows-Lucas, Kelcey
Correspondence: Hello,
I would like ranching leases to expire and the lives of the elk to be saved. Ranching is a huge contributor of the acidification of our oceans and of global warming. We need to stop subsidizing these industries that are destroying our environment and our wildlife. My vote is for plan 2 which would ease all but two ranching operations (with life leases) and save the elk.
Additionally, I don't understand why you have all the dairy farms on the National Seashore. It is so sad and depressing to see all the veal hutches where the babies are taken away from their mothers. Driving the bus and seeing the babies on one side and the bellowing mothers with mastitis on the other side of the road was incredibly distressing and traumatizing for my child. If you want to increase tourism, why would you destroy the view and the land with the cruelty and environmental destruction of dairy farms? One of the top causes of water consumption is alfalfa and dairy- in a state suffering from drought and devastating wildfires, it is absolutely tone deaf to be subsidizing industries that are using our precious natural resource of water.
Please read the scientists letter to humanity: https://academic.oup.com/bioscience/advance-article/doi/10.1093/biosci/bix125/4605229
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# 2818
Name: Hyde, Kathryn
Correspondence: I have a few additions to my earlier comments.
Please consider the following as the committee moves forward on the plans for Pt. Reyes:
1) Protest, restore and preserve the park's extensive resources
2) Ranches should be sensitive to the park lands and meet strict environmental standards to meet the needs of the parkland. of the park. Require the ranchers to meet standards for organic and/or sustainable land management practices. Provide required training, i.e. coordinate with successful ranches in Marin that follow sustainable practices for water conservation, wildlife preservation, erosion control, native plant restoration, etc.
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# 2819
Name: Crenna, Lloyd R
Correspondence: I am opposed to any plan which eliminates, or makes it unreasonably difficult, for family farms and moderate sized farm related business's like cheese, milk sheep, goat and beef ranching, to continues to operate in the GGNRA. These self sustaining farms and families have lived and worked on this land for over 150 years. Family farms are a strong component of the American way of life and encourage the best in the American spirit. These farms are not raising large herds of animals that destroy the land. Unbridled conservation can go too far and in its wake destroy a significant part of what is a valuable American way of life . Lloyd Crenna
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# 2820
Name: Bjornson , SherI
Correspondence: I beg you to protect our tule elk and not exterminate a single one to protect ranching. Tule elk are natives and national treasures that need to be treated as such. We don't destroy natural, generational resources to enrich businesses, and at that businesses that harm the environment. Please protect the tule elk.
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# 2821
Name: Schinner, Miyoko
Correspondence: The only environmentally sound choice that the Park Services can take would be to let the ranching leases expire and allow the elk to live (2nd alternative). As a recent and very comprehensive study led by Oxford University shows (http://www.fcrn.org.uk/sites/default/files/project-files/fcrn_gnc_report.pdf), cattle do more far more damage than good, even under the auspices of "rotational grazing." That they have been here since the 1800's is a fact often cited, but in fact, that is not a very long time from a historical perspective. Already, we have seen a decline in indigenous species here, and we can only guess at the longer-term impacts of cattle populations on our sensitive lands, although most studies conducted by impartial scientists (such as the study cited above, not ones funded by animal agriculture) attribute ranching to land degradation, soil depletion, contamination, and greenhouse gases.
It is not just in Marin, but all over the country - -the National Park and USDA's Wildlife Services have been culpable for over a 60% reduction of wildlife in the US in order to create more grazing opportunities for cattle. How can we pretend to be environmentalists when we value economic interests at the cost of nature and the environment? How can we pretend to care for wildlife when we exterminate them in order to preserve the "rights" of ranchers? Cows are not an indigenous species, and yet we allow them to proliferate (they would not on their own - - they are bred by ranchers).
I urge the Park Services to side with wildlife and the environment, and let these ranching leases expire, and save the elk.
Miyoko Schinner
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# 2822
Name: Raeside, Cecelia C
Correspondence: SAVE THE ELK!!!!!! There is no reason to "cull the herd"! These are as much of the environment as the whales and birds! We have no right to eliminate animals for any reason, let alone so they can "ranch" more profitable animals!
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# 2823
Name: Skellenger, Ronald W
Correspondence: As a Marin County resident for over 60 years I am writing to support the continuation of sustainable ranching on lands in the Golden Gate National Seashore. I deeply appreciate the many benefits the ranches provide: local organic milk, cheese and other foods as well as habitat preservation and protection. There would be no GGNS if the ranchers hadn't supported the idea in the 1960s. The 150-year legacy of west Marin ranching is moving well in the direction of protection of agriculture (with great help from MALT) as well as mitigation projects for stream protection and more. I am strongly in favor of 20-year leases to stabilize expectations. Hopefully you have already heard how much support the ranches have - - from MALT, from the Marin Conservation League, Save our Seashore (Inverness), and Environmental Action Committee of West Marin, along with many of us who are regular customers at Marin farmers' markets, enthusiastically buying local, organic foods.
I've camped at Sky Camp, Glen Camp, Coast Camp and Wildcat; I've hiked the trails many times; AND I support the presence of the ranches. - - Ronald Skellenger, San Anselmo
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# 2824
Name: Kirchner, Jose
Correspondence: The seminal Tule Elk herd was introduced to Point Reyes National Seashore lands as a desperation conservation measure. The elk have thrived and xceed the carrying capacity of the park, given the large land area given to cattle ranching. To preserve this area so close to the San Francisco and Sacramento areas, some view needs to be given to eventual and probably incremental winding down of some cattle and dairy ranching activities to deal with expanding numbers of park visitors. This needs to be done cautiously and with reference to supporting ranchers who use best practices in their management plan.
At the same time, the Tule Elk herd must be controlled to prevent land disruption and damage. Initially this might require limited culling, and in the long run other methods might also be considered, including birth control methods.
___________________________
# 2825
Name: McDaniel, Skot
Correspondence: 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?
___________________________
# 2826
Name: N/A, N/A
Correspondence: Please keep the Pt. Reyes National Seashore lands the SAME as it has been. Keep the Tule Elk.
The only thing I would change is make sure the farm workers have proper housing.
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# 2827
Name: Richmond, Lonna
Correspondence: Hello, I am concerned mostly about the tule elk. The Seashore is the only national park with a native population of tule elk. The Elk have been prevalent in the Bay Area and Marin for thousands of years, long before their extirpation in the 19th century. The Elk are part of the Seashore's natural resources, just like the seals and whales, and are an important part of the ecosystem. Considerations to manage Elk populations should be made based on the context of park policies that manage other natural resources. The Concepts all reference some type of "management" strategies for the Elk herds. I do not support culling the herds.
I believe that these animals deserve to continue living there and rather that the cattle ranching go away.
___________________________
# 2828
Name: Fontana, Claire
Correspondence: I grew up in West Marin and would like to submit a comment in support of Continued Ranching and Removal of the
Drakes Beach Tule Elk Herd.
The Tule Elk have no predators on the point and isolating them there seems unnecessary when there are so many wonderful wild, publicly owned lands in California that can support a herd. It's better for them and it's better for the point, and the NPS could be relieved of the duty of managing the herd.
The ranchers made a deal with the government when the land was sold, and that should be upheld. Sustainable practices can be implemented to keep the impact at a minimum. It would be even more amazing to see the ranches subsidized for sustainable agricultural practices, diversification, and experimentation.
Local food sourcing is a key component to reducing the environmental impact of food production, and Marin and the Bay Area is lucky to have such nearby resources when many in the country have products shipped from hundreds or thousands of miles away.
Let's stay true to Marin's agricultural roots, hold up the government's end of the bargain, and keep Marin supplied with wonderful, local, sustainably farmed food.
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# 2829
Name: N/A, N/A
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. 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.
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# 2830
Name: N/A, N/A
Correspondence: Keep West Marin 'Bovine and Bucolic'. A 20 year lease is a short time. A 50 year lease would be better.
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# 2831
Name: Rausin, Renee
Correspondence: Dear Acting Superintendent MacLeod,
I want to give my feedback about the proposed plans.
1. Protection of Natural Resources
The GMPA should protect, restore, and preserve park resources using ranch leases that ensure the multi-generational, environmentally sustainable ranching is complementary to the natural resources and visitor experiences within the park. It doesn't appear you are guaranteeing this.
2. Diversification
How exactly are you going expand the land use? What does diversification mean? Isn't the land exclusively to be used for cattle ranching? Please provide specific plans, We want to carefully analyze them to be sure diversity will be protected for real. I am unclear on this term, what it means, and what impacts this will have on park resources in the pastoral zone. The PRNS is a jewel in California. Who will benefit from the natural resources of the park, the public or big business? This is my land and your land, not your land alone.
3. Tule Elk
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 cringe calling them resources. You have said nothing about the Tule elk, do you plan to "remove" them? I can say this will not happen. Should they die out so businesses can take over the land? What other animals should die out? Don't disturb them, they have a right to be there.
4. Climate Change
We have data on climate change and the rising sea waters. What plans are place to manage this?
Thank you for the opportunity to submit my comments. I look forward to addressing them in person I don't want any expansion of the mission that will diminish the natural resources even if in the future.
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# 2832
Name: N/A, N/A
Correspondence: Let sustainable ranching and farming continue in the Point Reyes National Seashore. If it weren't for the ranchers and farmers we wouldn't have the National Park. It allows our children and grandchildren to experience ranching and farming and nature right in our backyard. Why take it away because some outside environmental group that doesn't live in the area wants to restore it to its natural habitat. If that's the case, ban all automobiles, hikers, bicyclist, roads, buildings and people.
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# 2833
Name: Aragon, R
Correspondence: I am writing to support the existing ranch families in Marin County to continue operations with 20 year leases or permits. Even better if we could do that for longer. It is time that we become reasonable in balancing these ranch operations with the environmental warriors who can see nothing but their own agenda.
Being able to have locally sourced food (and organic) that feeds the community is in the best interest of the greater population. And from a long time group of ranchers that have taken many steps to reduce their environmental footprint. Best practices have been adopted to reduce and eliminate pollution and damage to the environment. Being local provides a perfect situation for the continued review of ranch practices. And these practices have proven positive, with ranches across the country following suit.
Marin has an immense amount of open space and parkland. Let's be thoughtful and reasonable in this decision and allow 20 year leases to our ranch families.
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# 2834
Name: Butler, Mark
Correspondence: While too many generalities are inherent in all the alternatives mentioned to endorse any one of them I have a couple of areas of concern.
1.) Mixed use or diversification is an alternative I do not under any circumstances support. Dairy and cattle ranching while not a healthy activity has been 'accommodated' both environmentally and culturally and should be allowed to continue with scientifically informed management, at least for the term of the existing ranch family habitation. The habitat should never be converted for any other commercial use. The only alternative to ranch use should be managed habitat restoration.
2.) A clear plan should exist to protect all forms of native species within the pastoral zone. Policies and processes to protect the natural resources should be made public.
3.)Elk must continue to have a presence in the pastoral zone, and management should eliminate or at least minimize strategies that rely on culling the herd.
Thank you for your consideration.
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# 2835
Name: Cartier, Emmett
Correspondence: The following comments would apply to the Point Reyes National Seashore and North District Golden Gate National Recreation Area General Management Plan Amendment and Environmental Impact Statement and to the newsletter.
notion of carrying capacity should not be applied to recreational visitors, but are expected to be applied to management of pastures and populations for cattle and elk. Thus the focus of the planning so far seems inappropriately misplaced. The cattle are already monitored for their range management capacity by periodic measurement of residual dry matter, a standard practice. The recreational visitors are more flexible in use of various seashore lands and are not confined to particular pastures. Recreation is not strictly dependent on range conditions, numbers of animals, or even other site factors. Recreation is more variable by factors including external economic conditions in the region, weather or climate, transportation facilities, and internal park regulations. The various types of recreational visitors would naturally hope not to be treated as cattle or commodities in the park management. Consider allowing the full recreational uses of grazing pastures with or without cattle or tule elk present. These components of visitors and livestock are intermingled frequently elsewhere in the West without undue impacts on any components or the natural resources. Public use of the cattle pastures should be allowed under any lease conditions or special use agreements.
Because the cattle reportedly number about 6,000 and elk number only about 300, then the questions should be focused on why attempt to manage the elk further. The facts regarding occasional repairs of fencing or attempts at moving elk away from pastures seem inconsequential in perspective of the native wildlife on the non-native species. Point Reyes area has struggled with the management of less-native species including axis and fallow deer in recent decades. The introduction of tule elk should not be considered a substantial problem at the present or projected population levels within the planning time frame.
Control of tule elk populations should be made within the framework of California Department of Fish and Wildlife management as is done successfully for other elk herds in California by limited seasonal special hunts. No reasonable conflicts may be presumed to occur between recreational hunters and other non-hunting visitors or the livestock. Park regulations and planning alternatives should be changed to reflect this management option.
Thank you for your consideration.
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# 2836
Name: N/A, N/A
Correspondence: Marin County and its open spaces are a treasure that should never be disturbed. We should do everything in our power to preserve it in its natural state.
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# 2837
Name: Mallory, Ron & Amanda
Correspondence: Ranching at PRNS should have as its goal to be exemplary and highly sustainable.
Therefore I support only the NPS Initial Proposal because I believe it is the only concept that is consistent with Secretary Salazar's Order, existing NPS policies for public access and cultural and natural resource protection and also with PRNS enabling legislation and contemporaneous records of Congressional intent that families who were owners or lessors of land sold to create PRNS should be allowed to continue "ranching and dairying."
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# 2838
Name: Richards, Cathy A
Correspondence: Ranches and Elk 11/20/17
To Whom It May Concern:
Historic ranches in the park should stay on the seashore.
(5) Allow the continuation of farming and ranching in the Seashore and remove one herd of Tule elk threatening farming and ranching operations on the Point Reyes Peninsula.
One of the great attractions of our unique area in the Point Reyes National Seashore is the wonderful organic cheese, milk and pasture raised butter (dairy) and grass fed beef. No one wants to get their dairy or beef from feedlot cattle as on I-5 in Southern CA outside of LA. Having working ranches allows this area to have an important purpose in supplying a very important commodity of organic food production rather than turning it solely into a tourist destination as our only industry. Ranching families who have been here for 4-5 generations could be potentially driven out in spite of the fact that they have already contributed so much to our local community.
Over-utilization of our resources in this area by tourism alone as our sole industry will tax our valuable resources of water, sewage and garbage disposal even more. This is a problem that has already been identified by the Point Reyes Village Association. We do love our tourists, but as with all places that have "been discovered" we have to continue to put safe guards in place to insure our area's survival and the ranches are key to our community’s health and survival by allowing business diversification.
Our ranching families are very involved in the community and are continually giving back to the community. They provide local jobs, and help our economy be local. Their children and the children of their workers go to our schools, attend our community events, and fund raisers. They are also involved in various community service organizations. The ranchers live here full time and have a vested interest in keeping this area the very special community minded place that it is!
This area has always had human habitation from before recorded history. The Miwok Native Americans harvested food from the local flora and fauna because it was an area of rich natural resources way before the ranches came into being in the late 1800’s. It is a part of the human condition that as we live so must we find a way to produce food for ourselves in a sustainable way, which is what the organic dairy and grass fed cattle ranching industry is all about. These ranches are producing food that is actually good for us, not poisoning us! The ranching community has been involved in working with environmental groups and the park service in making their ranching operations compliant with these environmental concerns, as well.
In order to have a sustainable business the ranchers need to be able to have 20-year leases. Few if any banks will take a risk in funding capital improvements for 5 years or less at favorable terms. Just as people need a healthy sustainable food source, so too do the ranches need to have a sustainable business plan. The ranchers are currently limited as to what they can do with their leases in a very tough competitive market. They should be allowed to diversify just as an investor does. Putting all ones eggs in the proverbial one basket is a disastrous consequence for any investor if one market segment fails to perform s/he has others that perform well so s/he can overcome his/her losses. This is just a wise business practice that should not be denied to the ranchers.
Respectfully Submitted,
Cathy Richards
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# 2839
Name: N/A, N/A
Correspondence: I would like to add my voice to supporting the "Continued Ranching and Management of the Drakes Beach Tule Elk Herd", the initial NPS proposal. When I first heard this was up for discussion, I was concerned about the dissipating history of Marin County and felt it was my obligation as a lifelong citizen and utilizer of the parks to put my opinion in.
As I am sure you are aware, since the 1820's agriculture has been a staple of the economy of Marin county. As the greater Bay area is developing with companies such as Pandora and Google, it is our duty as citizens to support in whatever way we can to support the trade of these original citizens who live off the land. Having had the great pleasure of meeting some of these great farmers, their passion for the land is unmistakable and watching the way they know every inch and history by heart is incomprehensible. These individuals are the 'griots’ of the county and we need to let their stories live on through their ranches and not disallow them from continuing their trade. Without the rances, Marin would lose its best historians.
In addition, I would like to address the coexistence of uses of the Point Reyes National Seashore. Having run each trail multiple times growing up, I value the coexistence between those who simply use the land like myself, and those who utilize it like the farmers. They give to the community in a way that no other can and just as I have a right to run the trails, I strongly believe that the farmers deserve a right to continue ranching.
Also, I would like to address the point of fire damage. Having been directly impacted by the fires of Sonoma and Marin County, I am quizzical of the Parks ability to maintain fire safe open space without the assistance of the Farmers and the Tule Elk. Having run by pervious ranches that are now overgrown and recognizing the lack of funding which the the Parks service receives, I am not sure how a fire could be prevented without these means of creating fire blocks.
Now, you may notice that I do not support no regulation for the ranchers. I do see that the land management and environmental impact caused by ranching is harmful, but there must be a way to preserve Marin's past while also helping its future. With the assistance of the Ranchers, I am sure that a plan can be made where both the ranchers and the environment can be protected.
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# 2840
Name: Zelasko, Sandy
Correspondence: November 20, 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?
Thank you for the opportunity to submit my comments.
Best regards,
Sandy Zelasko
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# 2841
Name: N/A, N/A
Correspondence: Please continuing to permit ranching while managing the Tule elk herds. The initial NPS proposal was I believe the best way to give visitors, for generations, the full experience of Point Reyes national Seashore.
Having encountered, while hiking, both herds of free running tule elk, their current population will continue to expand. Just as the land can not carry unlimited cattle, it too can not carry unlimited tule elk.
The parks service's role is one of resource management, not benign neglect. This land has been farmed since the times of the Miwok. Human interaction with the land is part of the Point Reyes experience. The ranchers of today are valuable steward of the land (as are the NPS). To let the grazing areas return to choking coyotoe bush (as areas east of Muddy Hollow has become) is not being a steward.
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# 2842
Name: Herwill, Alice
Correspondence: People in Marin have always said that the National Park Service is in bed with the ranchers and I believe that's truer now than ever before! I do not support the existence of farming or dairy or cattle ranching within the Pt. Reyes National Seashore nor the north district of Golden Gate National Recreation area. I am concerned about the environment and particularly the effect of dairy ranching and cattle ranching, in particular with regards to the effects of methane in the atmosphere and it's contribution to climate change, and on the effect of the demands of cattle ranching with it's degradation of the land and it's obliteration of native species within our park system. To qoute Paul Hawkin, "If cattle were their own nation, they would be the world's 3rd largest emitter of greenhouse gases".The best approach to the reality of climate change is to eat a plant based diet. More and more people are choosing this lifestyle which is why dairy and beef consumption is declining. There is no reason for the public to subsidize these cattle and dairy ranchers in their choice of lifestyle no matter how long they have subsisted off of these lands at the public expense; and we certaily don't need any expansion of these privileged farming families activites to include AirB&B's to make up for their lost revenue from a nationwide decline in the demand for their animal products! No wonder you are afraid to do an EIR on these "proposals". Well we must all change with the times. The public wants more open space and recreational activities, including the opportunity to view wildlife, especially native wildlife, in lieu of having our open lands developed or continued as subsidized ranching and dairy operations. These latter activities have no place with our national parks. It is unbelievable that the National Park System allowed half of the native Tule Elk population to die of drought in 2015. To suggest that their numbers should be managed at a level compatible with authorized ranching is a travesity! 20 year leases are ridiculous. These dairy and cattle leases should be phased out immediately. I do not go to Pt. Reyes National Seashore to watch cows chew their cud and I don't know anybody else who does either. To even consider elemination of the Tule Elk from the Park System is UNBELIEVABLE. You need to be sued more often until you get the picture. The public wants to be able to see wildlife in their native habitats, hence the popularity of visitors going specifically to view the herds of Tule Elk. If you persist in this totally biased, extreme favoritism towards subsidizing ranchers at Pt. Reyes I will be one of the 1st to add my contribution to another lawsuit to compel you to take into account the potential environmental results of the "proposals" that you have put forth! These lands belong to the public and not to the dairy and cattle ranchers! Some stewards of our public lands and resources you people are. Your so-called management has been a depressing joke! Oh, and please do make my comments public!!!
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# 2843
Name: Schinner, Cammy
Correspondence: I vote for Option #2. It's time we (attn: the WASP/Caucasian male) end exercising dominion over everything in nature. It's time for compassion to the wildlife kingdom, not siding with outdated forms of animal husbandry. It's time for more secure food options for a growing population that is riddled with diet-related disease, famine, and poverty. I am an unabashed millennial, and on behalf of my generation, please do not mess this one up for us. We are paying money for plant protein (check market research! it's true!), and we don't like to see animals being killed pointlessly. Your approval ratings will seriously be in the dumps. Our little decision in West Marin will have a profound impact, and is representative of the powers-at-be on a federal and global level, which is why we must forge ahead by doing the right thing. Don't regret this. Think outside of yourself, think about the animals, the native plants of West Marin, the natural balance and order of our special region....
Don't be responsible for another mass genocide!
Thanks.
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# 2844
Name: Carolan, Kathleen
Correspondence:
Ranching at PRNS should have as its goal to be exemplary and highly sustainable.
Thus I support only the NPS Initial Proposal because I believe it is the only concept that is consistent with Secretary Salazar's Order, existing NPS policies for public access and cultural and natural resource protection and also with PRNS enabling legislation and contemporaneous records of Congressional intent that families who were owners or lessors of land sold to create PRNS should be allowed to continue "ranching and dairying."
I would like to see ranches (families) that were bought out by the park be able to pass their leases to direct descendants only. When the direct descendent decides not to Ranch,the ranch then reverts back to a natural state, without ranching. Ranchers should be able to live out their lives on the ranch but not to give it to a non descendent. The ranches must be organic and sustainable. It is up to the park to uphold the current and future rules.
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# 2845
Name: Nute, Ed
Correspondence: November 21, 2017
Ms Cynthia MacLeod, Acting Superintendent
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes, CA 94956
Re: General Management Plan Amendment Comments
Dear Acting Superintendent MacLeod;
We appreciate the opportunity to comment on the alternatives presented in the General Management Plan Amendment Newsletter. We attended the open house at Point Reyes Station in October and studied the posters of the various alternatives under consideration. If ranches are to remain on national park land they should be required to be good stewards of the land and environment and also be allowed to be economically viable so they are not run down. We have the following comments on the General Plan Amendment:
The Pastoral zone must be managed to protect the natural resources of the park. We urge the park to continue ranch leases on a 20 year renewable basis so that the ranchers have a long term assurance that they will not be evicted and thereby will also have the incentive to invest in protecting the land and upgrading their facilities. Erosion is a problem on some ranches and needs to be managed with limits on animal concentrations.
The leases should allow more uses of the land than just cattle ranching. As we understand it in the past, pigs were raised on the ranches to consume the whey byproduct from butter making. A limited number of pigs, chickens or other animals could be allowed as long as they consume the byproducts from the ranch itself rather than feed imported from elsewhere. Ranchers should be able to grow vegetable gardens for their own food production. Allowing for this type of diversification would make the ranches operate more like ranches elsewhere.
We think it is very important the tule elk continue to be allowed in the pastoral zone. The fallow and axis deer were allowed to roam and graze the pastoral zone since the park's creation. They were exotic species and are now gone. The tule elk is a native species and, although they are larger animals, they may graze an equivalent amount as the exotic deer. If the elk become over populated they will need to be controlled with birth control. An elk fence should be constructed if absolutely necessary. During droughts, forage should be brought in by the park to compensate for the grazing of the elk.
Ranchers should be allowed to have no more than one B&B at their ranch. This would diversify the income and allow the public to have intimate contact with the ranching community. In addition, it would give the ranchers an incentive to keep their places looking good. Interpretive signs should be installed to inform the public about the ranches in the park.
Thank you for this opportunity to submit comments.
Marcia and Ed Nute
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# 2846
Name: Gunn, Mary -Barbara
Correspondence: To protect and manage the natural resources of the area, please continue to maintain the fire roads that allow access- hikers prefer the dirt roads over paved. Mountain bikers utilize the dirt roads rather than making new trails through the underbrush, and causing erosion. Both groups, by their utilization of the area, provide extra eyes on current conditions, as the rangers and maintenance staff aren't able to cover all areas on a regular basis.
To provide more human resources, if there was a volunteer program, like the Peace Corps, whereby citizens (retired or not otherwise requiring a source of income for living expenses) could commit to yearly 'contracts' to act as caretakers in the park, providing assistance, and utilizing/maintaining current structures not being utilized by the NPS, this would increase the protection of the park at no cost (aside from the administration of the program, which would be very minimal).
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# 2847
Name: Matthews, Laurie
Correspondence: I support the continuation of dairy ranching on all or most of the historic ranches within Point Reyes National Seashore and continued management of the Tule elk herd to match the level of ranching that continues. To be specific, my first choice of the alternatives is the NPS Initial Proposal of Continued Ranching and Management of the Drakes Beach Tule Elk Herd and my second choice is Reduced Ranching and Management of the Drakes Beach Tule Elk Herd.
I do not support the elimination of ranching nor the continuation of 5-year leases which do not allow for the most optimal management of the ranching practices.
Thank you!
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# 2848
Name: ziman, steve D
Correspondence: Rather than go into a long song and dance, I will be succinct. I believe it is in the best interest of the NPS, Marin County, and California to continue to allow the ranches to remain within the Pt. Reyes National Seashore. Yes, there are issues that must be dealt with such as cow/elk interactions, but these ranches are historic, provide produce grown locally, and do not detract from the overall experience.
As someone who has hiked in Point Reyes for almost 50 years (and volunteers in one of the local state parks-I am an environmentalist), I have been on almost all of the trails in the seashore. There is more than enough room for us and the ranches to co-exist. Most trails are not crowded, aside from Bear Valley, and the ranches are in open area, which is not the most exciting place to hike. But again to repeat, they are historic and part of the entire experience.
And remember, there are plenty of folks in DC who would use any action to remove the ranches as another excuse to go after the NPS. After the removal of Drakes Oyster Company (totally disagreed with this), think a bit politically as well.
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# 2849
Name: Bouchard, Diane
Correspondence: Dear Committee,
I would like to make a request that the National Park Service consider visitors who have mobility issues, that do NOT fall into the requirements for the ADA. There is an un-served part of the community who would love to take in the beauty and wonder of the Point Reyes Seashore, yet cannot walk too far or need to be able to take rests.
This would not require anything fancy. A simple wooden or metal bench, a well placed redwood log, a large smooth stone or concrete curb. This type of seating would not interfere with the natural beauty of the seashore - yet provide a brief respite for visitors with such ailments as: bad hips, arthritic knees, recent foot, ankle or leg injuries. Also visitors with respiratory or cardiac issues would also appreciate a place to catch one's breath.
Having benches at the visitor's center and parking areas is insufficient. Additional seating needs to be available along the trails and vistas for full enjoyment of the region.
Thank you,
Diane Bouchard
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# 2850
Name: Anderson, Karen G
Correspondence: I am in favor of Continued Ranching, including 20 year leases for the Ranchers, and management of the Drake's Beach Elk Herd. Both dairy and beef cattle are a part of the Pt. Reyes culture and heritage and they help to lower our fire danger and they are a part of the visitor's experience. Children can see where our food comes from and gives them the opportunity to connect with our agricultural heritage. I think that the Ranchers should also be allowed to provide farm worker housing which will attract ranch workers, enrich our schools with diversity, and bring more economic opportunity to the area. Another idea to keep the ranches viable and thriving is to allow them to sell products at their ranches or in the local communities. This will help to keep the ranches economically so they will keep up best land practices for the environment. I also favor keeping the Elk herds as long as their health can be maintained. This may include thinning the herds if their numbers increase to where their health is jeopardized.
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# 2851
Name: Zorn, Lisa M
Correspondence: To whom it may concern:
Please support the alternative of "No Ranching and Limited Management of Tule Elk."
I find it disgraceful and abhorrent that our public lands are used to support violent industries like beef and dairy production. These industries are completely unnecessary (and detrimental to human health) and they are inherently violent and exploitative to feeling, thinking beings. We should not be supporting these industries with our public lands or subsidizing them with our tax dollars.
The Tule Elk are sentient beings and share these lands with us. I believe we should let them live peacefully and enjoy their majestic presence without harming them. They have as much right to the land as we do.
Thank you,
-Lisa Zorn
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# 2852
Name: britt, joyce e
The National Seashore was never meant to continue ranching indefinitely. The promise made to the public which funded the purchase of ranchers' land, was to recover that land for woodlands after the primary resident ranchers left or died out. The commercial exploitation now envisged in perpetuity is contrary to the promise made. Wildlife is not compatible with fencing, row crops, slaughter facilities, depletion of ground water, pollution of streams, and cows which eat Tule Elk food and spread disease to them. With 1.5 billion cows on the planet, over 5 million in California, and over 40,000 in Marin county, we must choose to save the elk and the other wildlife in this national park. The injustice in subsidizing 3 or more generations of so-called family ranching at the expense of taxpayers and wildlife is too high a price to pay for the political influence on this issue.
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# 2853
Name: Peterson, Bridget
Correspondence: We are born and raised Marin residents - work for local hospital and fire department and are very involved in our community. We have been following this issue for years and are in total support of continued ranching at the seashore. It it very important part of our agricultural roots, our local, sustainable food supply, and the ranching families who made the Point Reyes National Seashore a possibility. Bridget Peterson
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# 2854
Name: Roth, Jeremy
Correspondence: I am a part-time resident of Dillon Beach and when visiting I enjoy spending time kayaking Tomales Bay and hiking in Point Reyes. I enjoy watching the Elk and admiring the native flora. Point Reyes has a rich history of both agricultural and recreational land use. These distinct activities appear to coexist under the current regulatory structure and any changes to the structure that would negatively impact the delicate and beautiful ecosystems of Point Reyes should be avoided. If the traditional ranches cannot maintain economic viability under the current regime then the only viable option would be to allow them to close and let the land revert back to its natural state. The local economy depends far more on tourism than on ranching so that would seem to be the most important industry o protect if they are unable to coexist.
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# 2855
Name: Edmondson, Nancy
Correspondence: I support having all the ranches currently within the affected area STAY. I support allowing all of them to have long term leases, which can be "passed down" to heirs. I support having all of the ranches remain as agriculture, both with livestock and plant-based agriculture. I support allowing the ranchers to maintain their creeks and other environmental obligations in such a way that they are not "forced out" by default or pretext over impossible to meet environmental standards, such as requiring that all of their land be supporting only native species or other similar demands which are the same thing as eliminating ranching. I support allowing the ranching families to live on their ranches, using standard septic systems, adequate outbuildings, and any appropriately scaled technology to capture/reuse methane, treat water, harness wind, solar, and other renewable energy, and otherwise become "state of the art." I support allowing ranch hand housing and/or ranch hand family housing, to allow for efficient running of the ranches, limit auto traffic, and help support the economies of local towns. I support incorporating the presence of ranching as 'living history" for the education and enjoyment of all US citizens and visitors, so they can learn more about and have pride in our nation. The ranchers are motivated and able to be sure that criminal activity does not occur on their land, whereas the Park Service is underfunded and understaffed, thus is not even able to maintain what it has already. The ranchers were PROMISED when the park was formed, that they would stay. We, as a nation, need to keep our promises.
I reject the idea of having all of the affected area become "natural" or otherwise be managed by the Park Service, as Congress is refusing to fund this department sufficiently to cover its current obligations, as evidenced, in part, by the scandalous backlog of maintenance nation-wide. I can only imagine the marijuana grow problem which would occur if the ranchers weren't on the job.
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# 2856
Name: Rotella, Mary Anne
Correspondence: There are too many generalities in all the alternatives for me to endorse any one of them. Here are some of my concerns.
1.) Mixed use or diversification is NOT an alternative under any circumstances. Dairy and cattle ranching while not an activity i feel is in keeping with the founding principal of our seashore has been 'accommodated both environmentally and culturally and should be allowed to continue with scientifically informed management for the term of the existing ranch family habitation.
The habitat should never be converted for any other commercial use.
The only alternative to ranch use should be managed habitat restoration.
2.) A clear plan should exist to protect all forms of native species within the pastoral zone. Policies and processes to protect the natural resources should be made public.
3.)Elk must continue to have a presence in the pastoral zone, and management should eliminate or at least minimize strategies that rely on culling the herd.
Thank you for your consideration.
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# 2857
Name: Dreskin, William
Correspondence: I support phasing out all beef and dairy ranching on the seashore and returning the land to the public and to wildlife. Currently the public is fenced out of many areas. In many areas ranchers have not been cooperative about making gates in fences allowing people to walk across the land that is supposed to be ours. In some cases they have threatened people looking for rare plants or birds with guns. I support removing these fences and opening up the ranch areas.
Rather than managing tule elk to be compatible with ranching, I support returning the land to tule elk grazing as it was before European settlers. Visitors enjoy viewing the tule elk. On weekends cars exceed the capacity of the Tomales Point parking lot. Most of the people are there to see tule elk. There is nowhere besides Point Reyes people can see them locally. There are many places to see cows. You will never see cars lined up along the road for cow viewing. Many inland areas are perfectly good for grazing. An area with as many rare plants and animals as Point Reyes National Seashore should not be wasted on cattle.
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# 2858
Name: Noyes, Heather N
Correspondence: Cynthia MacLeod, Acting Superintendent
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes, CA 94956
Super. MacLeod, I have provided professional services for NEPA processes in the past and find the alternatives cited in the Amendment Newsletter lacking necessary information for the public to make an informed decision regarding preferred alternatives for the Pt. Reyes amendment. Specifically, I ask for the following information:
1. Evaluation Criteria for the alternatives: what am I supposed to use to measure each alternative against? This is an important component in any planning process and I'm unsure of how NPS and impacted stakeholders will move forward to ascertain whether programs and implementation strategies are being met.
2. Stormwater Management: Local drainage systems are impacted by increased run-off due to climate change, drought, fire. Increased vehicle traffic in the park will require a thoughtful approach to water quality. I would like more information pertaining to how Pt. Reyes will address water quality in those areas of the park most impacted by vehicular traffic and increased run-off.
To date, my preferred alternative is:
Continued Ranching and Removal of the Drakes Beach Tule Elk Herd.
I travel annually to visit Pt Reyes, and cherish the landscapes in the park that are a direct result of human cultivation and development. These landscapes are an important component to our cultural history, and 20-year leases are important to ensure that families are allowed to continue managing the land for ranching purposes. The Tule Elk Herd, while native, threatens the livelihood of both the ranchers and the integrity of the landscape.
Heather Noyes
4383 Tennyson St #1A
Denver CO 80212
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# 2859
Name: Gregg, Juno G
Correspondence: I prefer Continued Ranching and Removal of the Drakes Beach Tule Elk Herd alternative because when I visit Pt Reyes ever summer, I love to see the ranches and the people who take care of the land and the animals. They have lived there a long time and should be allowed to stay and ranch. I love the buildings, the trees that are the windbreaks and the way the roads wind through the grassy hills. The ranchers should have 20 year leases, but it if was up to me, I would let them stay forever. Let the ranchers stay. Because I live in Colorado, I know that elk are hard to manage - they want to roam and easily walk over even the tallest barb wire fences. I don't think the elk should be allowed to live near the working ranches.
Juno Gregg, 8th Grader, Skinner Middle School
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# 2860
Name: Edmondson, Alan
Correspondence: I think the ranches should also be allowed to have some land grow crops, rather than just be dairies and cattle ranches. There will be an accelerating trend over the next 25 years to eat less meat, due to the increasing need to feed more people without trying to farm the last marginal lands of the planet. People will get more protein from plants and less from meat. The demand for local beef may drop, and I would not want to see the ranches go bankrupt were this to happen and they were not permitted to change.
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# 2861
Name: Gregg, Lillian T
Correspondence: I want the ranchers to have 20 year leases and not have to worry about the damage that the elk might do to their fences and the hay that they store to feed the animals on their ranch. I love Pt. Reyes and the ranches are an important component of the park. The owners need an agreement that will allow them to make decisions that might take a long time to act on. These families should be granted a long term lease so that they know that all the effort they put into their ranch matters and that they won't get kicked out in the next year or two. This is only reasonable, especially for the families who have lived on Pt Reyes for a long time and who love the land.
My preferred alternative is Continued Ranching and Removal of the Drakes Beach Tule Elk Herd.
Lilli T. Gregg, 10th Grade North High School
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# 2862
Name: Kehoe, Tim J
Correspondence: Tim and Janice Kehoe
November 10,2017
Cicely Muldoon
Superintendent
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes Station, CA 94956
Dear Superintendent Muldoon:
Thank you for giving us the opportunity to give public input regarding your upcoming General Management Plan.
We would like to share a little history of our ranch. The Kehoe Family has operated a dairy on the Point Reyes Peninsula for ninety-five years. We established our dairy and continue current operations solely on the J Ranch. We have leased from the Pt. Reyes National Seashore since its inception in 1970. My Father had taken the longest lease offered at that time, which was 30 years. We have enjoyed a good business and personal relationship with the Park and its administration over the years.
We are working on four generations of our family making a living and raising a family on this beautiful property. At the present time we our operating as an Organic Holstein dairy that was certified organic in 2006. The milk we produce is certified organic and is distributed to a local dairy processing facility in Petaluma. This facility which prides itself on being a small, family oriented business that produces a high quality local product is why we chose to be associated with this company.
Our concerns to stay a viable productive organic dairy in the years to come are outlined below:
" Longer leases
" Diversification
" Stay economically competitive with other dairies outside the Point Reyes National Seashore
" Silage growth and harvesting practices
" Weed management
" Succession of family generations
" Access to alternative practices
" Dealing with elk in a timely manner
" Formal role of government agencies in the General Management Plan
" Rangeland improvement
" Priority Additional access to growing supplemental forage
" to additional land within the Point Reyes National Seashore
Longer Leases
The 20-year leases are a positive start to greater stability for the type of business that we are in. A suggestion we would like to make would be to have rolling 20-year leases. This, for example, would show a bank that we are committed to our operation and would make it easier to obtain loans or long-term investment loans if we so needed them. This will also allow us to stay economically competitive with other dairies within California.
Diversification
For my grandfather and grandmother, being able to diversify was one of the key reasons J Ranch was able to survive and be passed on to the next generation. In the 1970, s silage was introduced to save on feed cost and in the 2006 the dairy was converted to organic. These are some of the examples that we have implemented to be competitive with other dairys outside of PRNS. Having the opportunity to be able to return to diversification practices such as farmstead dairy products, growing grain crops, such as barley, wheat, or rye for specialty products, and being able to change to Beef production if dairying is not continued.
Silage
or forage production has been an applied practice within the park and should remain as such. Historically, hay was produced in the early 1900s and silage were started in the mid 1970s. When ranches are able to produce their own silage or forage, it reduces the amount of feed that is imported and lessens the carbon foot print of all the ranches. I also believe that there is more bird habitat when the silage fields are growing because of the forage density. We also believe that giving each of the ranches up to 25% of their leased acreage for silage or forage production would be very beneficial for all of the ranch operations within the park. It would make more available bird habitat during the growing season as long as mechanical harvesting would be done as late as possible with out hurting the quality of the feed.
Weed Management
Organic dairies have taken the place of conventional dairies in the Point Reyes National Seashore, and pasture and forage production are a key part of these family farms surviving for the next generation. Mowing or windrowing grasses, weeds, and brush have been proven to be a successful process that we have in controlling the spreading of evasive weeds. The bull thistle, poison hemlock, coyote brush and other problem weeds are an ongoing nuisance to our ranch specifically. The quality of our pasture is a key factor in producing high quality milk and reducing the reliance on imported feeds.
Succession of Family
Succession of family should be addressed in the GMP. Here are some of the suggestions that we see as a common-sense approach. The first choice would be to have the next generation of immediate family members taking over when the previous generation retires. If the next generation does not want to step in and take over the business, then other relatives that would be interested should have an opportunity to get involved. This is how my grandfather came to the J Ranch some 95 years ago. The second choice would be offering the ranch to neighboring ranchers which was a practice that took place in the 1900s.
Access to Alternative Practices
One of the issues that the J Ranch, as with many ranches all over the state of California, has had the last five years is a water shortage. The extreme drought has been a major problem for ranches within the Point Reyes National Seashore over the years. Water development will be a needed to deal with this issue going forward. We have to expand on the water sources that we currently have in place. Enlarging our dam, digging more wells, or using the creek as a backup for a major water supply should be used as a plan during the drought years. We have been allowed to pump water from a creek at the Kehoe Beach Trail Head for 3 out of the last 10 years. This has rescued us as a water source for our animals in the last major drought.
Dealing with Elk in a Timely Manner
The Elk situation is of major concern. Containing the Elk by fencing them out of the pastoral zone could be an option, it is already working on Tomales Point, as long as the fence is maintained. One of the primary requirements of being organic is access to pasture. The National Organic Program rules require a dairy to provide a minimum of 30% dry matter intake for a minimum of 120 days during the pasture season. Recent conditions from the previous droughts have made this difficult enough as it is. The accumulation of the elk competing for this pasture adds additional pressure to comply with the National Organic Program standards. The National Park Service constructed a fence to contain the original elk herd on the Pierce Point Peninsula in the 1970s, which borders us here at the J Ranch. Over the years wear and tear has occurred to what we refer to as the Elk Fence and elk have crossed over into the pastoral zone. Containment of the Elk between our properties could be simply rectified by repairing and maintaining this fence. The additional elk herds that are located on the Historic C, D, E, and Home Ranches need to be relocated or removed by other means. This is an acute problem and should be addressed in the General Management Plan.
Formal Role of Government Agencies in the General Management Plan
Point Reyes National Seashore should be in a working relationship with agencies such as National Resource Conservation Service (NRCS), Resource Conservation District (RCD), University of California Cooperative Extension, and other farm service agencies that have extensive experience with animal agriculture operations. Another alternative to assist the NPS would be to partner with Marin Agriculture Land Trust on management of the Pastoral lands. They are a nonprofit and oversee 50000 acres of farm land with agriculture easements in Marin County. This would be at a cost but they have the expertise in place already.
Rangeland Improvement
Pasture improvements such as seeding with perennial grasses and legumes has given us more pounds per acre of feed and has lessened the use of imported hay and grain. Also, the use of disking and replanting with grass seed has been effective to remove thistle and poison hemlock. Another tool beneficial to farming would be to use an aerator to lessen compaction on pastures and have more of an impact on pasture response when we do have years of normal rainfall. We also use No-Till seeding practices so we do not disturb highly erodible land. All of these practices would and have improved the RDM {Residual Dry Matter} when implemented.
Priority to Additional Land within the Park
Currently, there are idle lands that are adjacent to the ranches in the pastoral zone that could be utilized by existing lease holders. Most of the land adjacent to the J Ranch has been overrun with coyote brush and velvet grass. If the land could be used, the cycle of evasive weeds could be curtailed and brought back into productive pasture for the lease holder.
As an organic dairy we have many rules and regulations to comply with that must be followed in order to keep our certification. These requirements reflect the ideas we presume the National Park Service would agree to be good, sound practices of taking care of our land within the Point Reyes National Seashore. The GMP will hopefully address all of the issues that will arise and take a common-sense approach to the plan that the National Park Service will develop for the future of the historic ranches in the Point Reyes National Seashore.
The preferred alternative that I believe the historic ranchers and the PRNS can agree works in all of our best interests is the continuation of ranching in the PRNS with management of the Limantour/Drakes Beach Tule Elk Heard.
Sincerely,
Tim and Janice Kehoe
Kehoe Dairy INC/Historic J Ranch
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# 2863
Name: Wimpfheimer, David
Correspondence:
Dear Superintendent,
Thank you for the opportunity to comment on the General Management Plam Amendment.
As a background, I have lived in West Marin since 1980. In the last thirty years, I have worked as a naturalist for many organizations and have taught hundreds of natural history classes in Point Reyes National Seashore. As an ornithologist, I have conducted numerous studies on wetland species and other birds in West Marin. I am also on the board of two organizations, Point Reyes National Seashore Association and the Environmental Organization of West Marin. In short, I have a detailed knowledge of wildlife in the Seashore and the diverse natural history at Point Reyes.
The enabling legislation that created Point Reyes National Seashore in 1962 seemed to indicate that ranching would continue in the national seashore indefinitely as long as those original families/leaseholders continue their operations in the area. Unfortunately, the enabling legislation did not specify what is an acceptable amount of livestock in the national seashore. Nor did it make clear that the natural resources in the park should be protected fully and have precedence over domestic animals and agricultural operations.
Since 1962, there has been a compromise in the national seashore; there is some ranching, but there is also mostly protection of the natural resources. In brief, I am in favor of continuing that compromise, but I would like to see more protections of wetlands and other natural resources.
I accept that ranching can continue at the national seashore, but I would like to know what impacts the beef and dairy cows have on various habitats and wildlife in the park. I strongly feel there should be scientific studies to document these exact impacts. If there are documented negative impacts than clearly the number of cows should be reduced to an acceptable number.
Specifically, I am concerned about three management issues; the number of elk, diversification and the length of the ranching leases.
Elk
I understand that grazing elk can compete with cows for available forage in the national seashore. Has the park explored all possible solutions to this conflict? The construction of fences, while costly, might be one solution to allowing the number of elk to expand in the pastoral zone.
When the family occupying the "D" Ranch left the national seashore their lease expired. This would have been a logical time to create a reserve just for elk and not cows in that area. That did not happen. That is an example to me of the park choosing ranching over protection of the natural resources.
Diversification
Diversification is an inherently confusing term that needs to be defined so that the public understands that it could bring a dramatic shift of commercial land use within the Seashore.
I have read that “Diversification activities identified through the scoping process and ongoing discussions include the addition of new types of livestock, row crops, stabling horses, paid ranch tours and farm stays, small-scale processing of dairy products and sales of local agricultural products...”
In my opinion, it is extremely difficult to quantify not just the physical impacts those activities will bring to the pastoral zone, but the aesthetic ones as well.
I am greatly concerned about the level of these potential impacts therefore I feel that authorized ranching operations should be limited to dairy and cattle ranching, as intended by the enabling legislation.
I feel that limiting the commercial uses of the area is necessary to preserve the natural and cultural resources of the Seashore.
Ranching Lease Periods
In most of the alternatives or concepts presented at the two meetings in Point Reyes Station and Sausalito the NPS used 20-year leases for the various ranches. I am not opposed to that length of lease. However, I feel there must be exact conditions outlined that ranchers must fulfill otherwise that lease period may be reduced or ended. There should be strict guidelines as to the acceptable number of livestock and how the natural resources can best be protected. Ranchers should be held accountable for adhering to these best management practices.
Thank you for entering my views into your record.
Sincerely,
David Wimpfheimer
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# 2864
Name: Deutsch, Barry
Correspondence:
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?
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?
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?
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# 2865
Name: Jonik, Philip
Correspondence: I would like to see implementation of the NPS initial proposal, Continurd beef and dairy ranching, 20 year lease agreements, and compatible management of the Drakes Beach Elk herd. I think the 20 year optio gives ranchers the best planning time frame to keep their long range business plans succ3ssful. I am a 31 year full time resident of Inverness. I had worked in the local public schools for 21 years.
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# 2866
Name: N/A, N/A
Correspondence:
Scoping Letter
Lou and Wyatt Zanardi
Zanardi Ranch
750 Platform Bridge Road, Tocaloma, Ca
name is Lou Zanardi and my son Wyatt Zanardi and I currently hold the lease on the 404 acre Zanardi Ranch. In 1932 my father Louis Zanardi Sr. and his family moved here and carried on the dairy operation which was formally owned by the Mazza family from 1869 to 1937. In 1937 my family purchased the property from the Mazzas and continued to run a dairy operation until 1972. From 1972 through today it has operated as a beef ranch. For over 145 years this property has been run and managed by two families.
In the Park Service historical archives you can find the following statement:
The Zanardi Ranch is significant as an intact and well-preserved example of an early Marin County dairy ranch. Practically all of the original complex
remains, with few alterations and additions, and in reasonably good condition. The owners, from only two families, contributed to the important Marin County dairy industry for more than a century.
above statement is why after graduating from college and working in industry for the past 37 years that I decided to sign a 10 year lease agreement with the PRNS in 2011. I signed it because of the love and passion that my family has for the historical significance of this ranch and our community.
family came to the West Marin County area in 1923 when my grandparents began ranching in West Marin County on a leased dairy near Tomales. In 1932 they relocated to our Tocaloma Ranch and eventually purchased the property five years later in 1937. My father (Lou Sr.) was 15 years old at the time of the relocation and was attending Tomales High School. After the move, it became necessary for my father to drop out of high school and begin working at the Tocaloma dairy ranch full time in order to support his family. From 1932 to 1972 my father managed a small heard of dairy cows which supported his parents and four siblings.
1957 my father (who was 40 years of age then) married my mother Anna Marie Zanardi, who already had four children of her own. I was born the following year. Having five children, my father continued to operate the dairy until 1972. At which point, similar to the other dairy farms along Paper Mill Creek and Olema Creek, our family dairying business became too difficult to financially sustain and my father was forced to sell his dairy herd. Without the dairy operation my brothers and sister all began careers outside of agriculture. As the youngest of five I was just starting high school. My father switched to raising replacement heifers for sale and eventually also went to work as a dairy supply salesman for a business based in Petaluma.
1984 my father (now 67 years of age) sold the ranch to the National Park Service (NPS) as part of the GGRNA expansion. He, however, retained a 25-year lease/reservation use permit, which included residential and agricultural use. Three years later, at age 70, my father died of cancer. My brother, Pat Martin, then moved back to the ranch and has resided in the main house for the last 33 years. Pat is currently disabled and lives in the original farm house with his wife Lynette. My son, Wyatt Zanardi, and his wife Kayla have lived in a smaller home on the ranch for the last four years. Both Wyatt and Kayla have bachelors degrees and are working professionals outside of the ranch in addition to their current ranch duties. Shortly after college I married my wife Carol in 1980. We then moved into the small house on the ranch and commuted to our jobs until 1983 - which was just before the sale of the ranch to the GGNRA. In 1983, just before the sale, my wife and I moved from the ranch.
2011, my son Wyatt and I signed a ten-year lease with the NPS. Currently we are maintaining a small beef operation with a total of 45 animal units on 440 leased acres. Given the ten-year duration of the lease signing, I was able to work with the NPS to develop a ten-year ranch plan, aimed at stewarding the land on which our ranch resides and providing ecological benefits to the surrounding natural resources. Our efforts included creating a water distribution and management plan, a grazing improvement plan and a water shed quality improvement plan. I also outlined and prioritized capital improvement suggestions which are required to maintain the structural integrity of the historical buildings on the ranch. I have tried in every way to maintain good stewardship, a clean environment and improve the land for wildlife as well as future generations, my own familys and the public at large.
2013, I further initiated discussions with the Park Service and the National Resource Conservation Service (NRCS) to implement the plans mentioned above. All of us were in agreement and ultimately I was granted funding for a major Environmental Quality Incentive Program (EQIP). Over the next three years I personally installed and/or oversaw the implementation of two water spring developments, 7500 gallons of water storage capacity, over two and a half miles of water piping, an off grid solar pumping system, seven water troughs and over 2100 feet of wildlife friendly fencing. Near the conclusion of the project I also was able to obtain additional support from the Marin Resource Conservation District (MRCD) to provide additional fencing areas for livestock keep-out areas for a seasonal stream. These improvements were all recognized as aiding agriculture land use through better grazing practices and water distribution, wetlands improvement, Tomales Bay watershed quality improvement and erosion prevention. Additional benefits have resulted in areas where wildlife can benefit in the spring wetlands area and gain better accessibility to water. Attached as Exhibit 1 is a Conservation Plan Map identifying the multiple project locations. We are also committed to helping control invasive species such as distaff thistle and pampas grass.
I now have four years left on my ten-year lease. If it were not for the ten year lease I could/would not have invested the time, energy or money to make these improvements. Nor could I have asked for NRCS and MRCD to contribute since I could not guarantee that I would be able to maintain the improvements. I currently have additional improvements that I would like to make with the support of the NPS and other agencies if possible. For example, the barns are beginning to experience foundational and structural issues that need to be addressed with the aid and guidance of NPS professionals because these are listed as historical buildings. I believe that without my historical knowledge, investments and drive to be a good steward of the property that no improvements would have or will take place on this very historical and pristine property. I would like to make improvements to the original ranch buildings which date back to the 1860s and include two historic barns, the original dairy and the original ranch house.
conclusion, the economics of this ranch make it very challenging to sustain one let alone multiple families. Without a long-term lease (20 years ) it will be extremely difficult to commit to continued and necessary improvements on the property. I believe the community and the Park Service would also lose a significant bit of history if this ranch is left to be managed and improved by resources who may not possess the same care, urgency and passion for the land and buildings as my family currently does.
Sincerely,
Lou Zanardi
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# 2867
Name: Hanson, Victoria
Correspondence: Please clarify what criteria will be used to evaluate continuing impacts of domesticated animals on the natural resource environment and human beneficial uses of the Tomales Bay Watershed. This unique, internationally significant body of water and its tributary system already is impaired by sedimentation and e.coli contamination. Evaluating any alternative must include enforceable standards that ensure any change in use pattern represents no additional burden on watershed function or negative impact on habitat for native and migratory species. Thank you for considering this concern.
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# 2868
Name: N/A, N/A
I would like the GMP to include allowing supplemental activities to ranching for the existing ranchers within the PRNS or GGNRA.
example, there is a significant need for short-term and low cost stay accommodations and facilities for hikers, bikers and other visitors to the area. Allowing the ranchers to use their existing facilities to provide short-term stays for visiting outdoor enthusiast would provide a much needed low cost service. The accommodations could be as simple as one to three day room rentals, covered outdoor eating areas and a place to park your bicycle or place your hiking boots.
Accommodations like this could be an excellent way for the public to stay, explore and enjoy this beautiful area for a few days at minimal cost. It could also help some of the smaller ranchers who have limited earning potential sustain and improve their properties at minimal cost to the park service and tax paying public.
you for considering this recommendation in the GMP.
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# 2869
Name: Dumbra, Ashley
Correspondence: Nps.gov states "The Coast Miwok people lived in the same village, such as this (Kule Loklo), for hundreds of years. As we contemplate their existence here, we may learn from them an approach to life and land, which could be sustained for hundreds or thousands of years. As the first caretakers of Point Reyes, the Coast Miwok people continue to teach us much."
I would like to see the amendment process reflect continued teaching from Miwok people. Ranchers, environmentalists, and the Park Service appear to be well represented in the amendment plan process, but the presence of Miwok people in the determination of the alternatives appears to be absent. Because Miwok people are the original stewards and keepers of the Seashore Lands, Miwok people should have a seat at the table in this process. How will the amendment planning process include Miwok people? Will the Miwok peoples' sophisticated traditional ecological knowledge for how to live in dynamic equilibrium with the grasslands and coastal prairies be given voice in the plans for the amendment? How could Miwok involvement in the amendment planning process help reestablish Miwok interaction with the animals or plants in order to support the local ecosystem balance? We can look to the partnership between the Amah Mutsun Land Trust and the Midpeninsula Open Space District, Pinnacles National Park, and California Department of Parks and Recreation, to guide the ways in which we foster Miwok peoples’ role in the management of Seashore lands. In collaboration with the above partners, the Amah Mutsun Tribal Band has regained access to tending plant-life and practicing traditional customs.
When large predators were a functional part of the landscape and Miwok people managed the Seashore lands through a variety of practices, including extensive burning, other forms of indigenous vegetation management, and hunting, the tule elk population was kept in balance with the surrounding ecosystem. I would like the amendment plan to consider management practices that mimic Miwok practices. For example, can local residents apply for permits to hunt elk, as the Park Service deems necessary, in order to keep the population healthy? Because large predators and prescriptive burning are no longer available for managing the tule elk population, we need to consider practices that allow the tule elk population to remain healthy.
Since Miwok people have been removed from their ancestral lands, ranchers have been the caretakers of this land. While beef and dairy cows have impacted and limited the native species that can live in the Seashore, grazing in the Seashore lands has been an important tool in keeping the grassland ecosystem functioning properly. These benefits, including limiting populations of non-native plants, slowing or stopping the encroachment of woody shrubs into grasslands, and maintaining habitat for grassland birds, mammals, and amphibians, has been documented by Barry and Risman, amongst others. I am concerned the removal of grazing would negatively impact the remaining native species, because maintaining the coastal prairies and grasslands requires grazing from ungulates. If tule elk were the only ungulates grazing the Seashore lands, other stewardship practices would still be necessary, including burning and enabling large predators to control the population, so the number of tule elk matches the carrying capacity of the land. I would like the planning process to evaluate the range of ways in which ungulates, both elk and cows, can be managed to support native species. Please consult studies conducted by researchers like Barry and Rissman, along with the monitoring work underway in the Rangeland Monitoring Network Program, conducted by Point Blue Conservation Science and the NRCS.
A variety of organizations, including the California Native Grasslands Association, Marin Conservation League, Marin Agricultural Land Trust, Point Blue Conservation Science, and TomKat Ranch Educational Foundation work to determine best management practices for ranching to co-exist with natural ecosystems. Human beings are part of the ecosystem, a vital part. We need to assume our responsibility as caretakers of the Point Reyes National Seashore. Ranchers can play a role in this caretaking. With financial assistance and incentives, ranchers can implement best practices, as guided by current science of effective grazing practices. Ranchers can utilize rotational grazing, fence riparian corridors, run appropriate numbers of cows the land can accommodate, delay hay cutting to accommodate birds and other species, and so on. I would like the amendment plan to evaluate these and other best management practices, because these best management practices have proven effective in fostering biodiversity and healthy ecosystems.
Monitoring ranching’s impact on the biodiversity and health of the Seashore ecosystems will necessitate creating plans that adapt to specific ranches. Species of special concern on some parts of ranches might require different management techniques, including restricted access. I would like the Amendment Plan to consider adapting the plans for the specific sites, because a 'one size fits all’ approach will not adequately support the species in different habitats and locales of the various ranches.
Some of the alternatives in consideration include removing ranchers from the Seashore, which would exacerbate the strain on our local community. Because many students who attend the local schools come from ranching families, fewer ranching families would translate to fewer students attending the local schools. In turn, funding available to Shoreline Unified School District would be reduced. Families struggle to make ends meet in the community because of the high cost of housing. Some families rely on housing on the ranchlands to mitigate the difficulty of finding affordable housing locally. I would like the analysis to include an evaluation of diminished ranching on the local schools. How would reduced ranching impact the Shoreline Unified School District population and its funding?
Seashore feeds us in a variety of ways. We can continue to sustain this relationship, providing local food and stimulation to the local economy. I am concerned that reducing ranching in the Seashore would negatively impact our food shed, because the ranches in the Seashore make up almost twenty percent of Marin County’s agricultural acreage and production. I would like the analysis to examine the resulting impact to our food shed and economy, should ranching be reduced in the Seashore. Will reduced ranching in the Seashore negatively impact surrounding dairies and ranches not in the Seashore?
would also like the amendment plan to evaluate the benefits to active land stewardship, because there is a variety of current research about the benefits to people actively engaged with their natural environments. How can people partner with ranchers and park service personnel to use, protect, and steward the land? How can this cooperation and stewardship connect residents and visitors to the landscape? In turn, how can reestablishing the ecological associations between people and nature create health benefits for people?
Thank you for engaging in this process. My hope is that with sophisticated scientific research and traditional ecological knowledge, and collaboration with environmentalists, ranchers, Miwok people, and local residents, the Park Service can craft an amendment plan that provides the necessary tools to continue to restore the Seashore lands for elk, cows, native species, ranchers, outdoors enthusiasts, and indigenous people. As noted by Melissa Nelson, a Marin woman advocating for indigenous peoples’ health, “human beings can play a richly positive role in the web of life as a keystone species that creates conditions conducive to life for all beings.”
References:
Anderson, M.K., and M. Barbour. 2003. Simulated indigenous management: A new model for ecological restoration in national parks. Ecological Restoration 21 (4): 269-277.
Barry, S., T.K. Schohr, and K. Sweet. 2007. “Grazing research supports an alliance for working landscapes.” Rangelands 29(3): 31-34.
Barry, S., S. Larson, L. Bush, and L. Ford. 2015. “The benefits of livestock grazing California’s annual grasslands. ANR Publication No. 8517. University of California Agriculture and Natural Resources Catalog.
Nelson, Melissa and Ross, Jacquelyn. 2008. Original Instructions: Indigenous Teachings for a Sustainable Future.
Rissman, A.R., R. Reiner, and A.M. Merenlender. 2007. “Monitoring natural resources on rangeland conservation easements.” Rangelands 29(3): 21-26.
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# 2870
Name: Walla-Murphy, Meghan
Correspondence: Hello,
Thank you for taking comments. I am a wildlife ecologist working in the field of habitat connectivity and conservation. I teach for PRNSA and spend much time wandering the park's landscapes.
My largest concern is the poor management of the grazed grasslands. The grasslands are over grazed, causing run off and lack of water penetration into our water table. The soil is poorly tended, denuded, and devoid of biodiversity. I am astounded that these land management practices are permitted while Drakes Oyster Farm was de-commissioned.
I am huge proponent of mixed use landscapes, and I believe that humans are and can continue to be a benefit to the landscape, building biodiversity and regenerating decimated habitats. This is NOT what is happening at the ranches near Chimney Rock nor those on the way to Pierce Point. Frankly it is an embarrassment to the Park to allow this poor land management, especially with the Drakes Oyster Farm debacle in your recent history.
I strongly recommend the park bringing on holistic rangeland managers who embrace healthy grazing practices to advise the ranchers. Practices in which domestic grazers emulate the beneficial services of native ungulates. Sweet Grass Grazing is one resource as well as the Allen Savory Institute of Holistic Rangeland Management. I don't believe that the ranches need to be removed from the Park, only better managed.
Sonoma and Marin Counties are a haven of good land stewardship, and the Park could be yet another demonstration of these practices. Thank you for your time and energy in receiving community input.
Meghan Walla-Murphy
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# 2871
Name: Faulkner, Patsy L
Correspondence: I support the plan of 20 year leases for both the beef and dairy ranches in PRNS with management of Elk populations. I am a 31 year full time resident of Inverness, retired teacher of Shoreline USD and live in close proximity of many of the ranches.
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# 2872
Name: Pincetich, Christopher
Correspondence: Thank you for the opportunity to provide public comment on the proposed alternatives for the General Management Plan Amendment (GMPA). Most all alternatives provide the information that "NPS would 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)."
I feel very strongly that PORE staff must use this early planning stages of the environmental process to identify and analyze impacts for enhanced trail connections for narrow and wide multi-use trails with improved signage and new interpretive waysides throughout the GMPA management area. I am a local resident, professional environmental planner, biologist, education and interpretive contractor instructor at the Point Reyes National Seashore Association's Field Institute, avid hiker, father, and cyclist.
I propose PORE staff identify existing ranching roads and narrow trails and new trail connection opportunities to provide upwards of 100 miles of new multi-use trails that can be maintained in cooperation with ranchers and are not subject to the restrictions of the Wilderness Act. Many local organizations would gladly assist in this planning process and I encourage you to reach out to myself, the staff at Access 4 Bikes, and the Marin Bicycle Coalition. I feel strongly the following trail proposals should be included in the environmental analysis of the GMPA management area now to improve visitor experiences and improve the partnership with ranchers towards supporting visitor experiences aligned with recreational expectations of park visitors:
1) New off-road cycling trails (multi-use trails) be constructed or opened on existing facilities within the McIsaac Ranch to provide connectivity to the Bolinas Ridge trail and trails within State Parks on Mount Barnabe.
2) New off-road cycling trails (multi-use trails) be constructed or opened on existing facilities within N, M, H, and G ranches to connect the existing multi-use Estero Trail complex to extend north, across Sir Francis Drake Blvd. into and link access to the existing multi-use Abbotts Lagoon trail.
3) New off-road cycling trails (multi-use trails) be constructed or opened on existing facilities within M, L, K, and J ranches to provide a safer alternative to Pierce Ranch Roach for cycling access north from Sir Frances Drake Blvd. to reach the existing Duck Cove Road and Marshall Beach Road multi-use trails/dirt roads.
4) New off-road cycling trails (multi-use trails) be constructed or opened on existing facilities within M, N, O, A, B, C, D, E and F ranches to provide a safer alternative to Sir Frances Drake Blvd. for cycling access west to the Lighthouse. Visitor experiences at the Lighthouse would benefit from increased, safe access for cyclists to reduce congestion on existing roads and parking facilities.
5) New off-road cycling trails (multi-use trails) be constructed or opened on existing facilities within A, B, C, and D ranches to provide a safer alternative to Sir Frances Drake Blvd. for cycling access west from Drakes Beach parking lot to the existing multi-use trail at Chimney Rock. Visitor experiences at the Chimney Rock trailhead would benefit from increased, safe access for cyclists to reduce congestion on existing roads and parking facilities.
I will continue to advocate for these, and other, multi-use trail proposals throughout the GMPA process and recruit additional advocates for these goals. I strongly believe PORE staff must improve the partnership with ranchers towards supporting visitor experiences aligned with recreational expectations of park visitors, and the current system of trails fails to utilize the potential for ranching lands to support trails safe for cyclists, hikers, and other trails users. Hundreds of miles of trails exist in within San Francisco Bay Area public lands and parks have spring-loaded metal gates and other inexpensive structural features that allow cattle and trail users to share lands safely and responsibly. Expanding the public trails network into existing ranches through the GMPA process will provide increased opportunities for great partnership between ranchers and park staff where the ranchers can provide significant benefits to park visitor experiences with negligible impacts to their operations.
Finally, I would like to support that the GMPA work towards “Reduced Ranching and Management of the Drakes Beach Tule Elk Herd” because current ranching operations exist outside of the areas and terms originally outlined in the founding documents and agreements of the Park, and increasing the herd size and range of Tule Elk will greatly improve visitor experiences. I believe strongly that ranchers must follow the original planning documents, and that now, decades later, their current footprint has expanded beyond that allowed. Reducing ranching is not an attack on existing operations and operators, but rather enforcement of the founding agreements these families made with NPS. Their leases should be extended to 20 years, their operations reduced to those originally allowed, and any impacts Tule Elk have on their operations should be mitigated with financial compensation back to ranch owners to allow them to purchase additional organic, weed-free cattle feed.
I look forward to continuing to work with PORE staff to support these GMPA process and sincerely hope my comments here are understood and acted upon.
Thank you,
Chris Pincetich, Ph.D.
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# 2873
Name: Holmes, Ellen
Correspondence: November 22, 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.
My position is entirely consistent with that of the Environmental Action Committee of West Marin (EAC), which states:
"The GMPA must 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."
Specifically, our concerns are as follows:
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.
Best regards,
Ellen Holmes
___________________________
# 2874
Name: Ravizza, Barbara
Correspondence: marinwatch
355 Bryant, #105
San Francisco, CA 94107
November 21, 2017
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 process for amending the 1980 General Management Plan for the lands in Marin managed by the Point Reyes National Seashore. For reasons discussed below, we urge that in at least one alternative (a) the scope of the proposed amendment be expanded to include all of the lands within the Olema Valley and Point Reyes Historic Districts, whether or not currently in ranching, (b) elk be fenced out of the pastoral zone on the Point Reyes peninsula and (c) consideration be given to the climate benefits of encouraging the ranchers to implement best management practices that increase carbon sequestration in the soil. In all other respects we concur in the comments offered by the Marin County Board of Supervisors and the Marin Conservation League.
Specific Comments:
Expansion of Scope of Proposed Amendment:
Lands have been added to the Golden Gate National Recreation area managed by the PRNS since the 1980 GMP was released. Some of these lands were being ranched when they were acquired by the NPS but are not currently ranched. They will continue to be managed without the guidance of a general management plan unless the scope of the current process is expanded to include all lands in the Olema Valley and Point Reyes Historic Districts and more recently acquired agricultural lands in the GGNRA that are managed by PRNS. A detailed plan for managing lands not currently in ranching could be deferred until the GMP Amendment for the ranches within the scope of the settlement agreement is completed.
Ranching and dairying on the greatest acreage possible as authorized in legislation creating the PRNS and GGNRA will assure the continued and increased contribution of agricultural production in the parks to the local community and economy and meet the larger goal of preserving these cultural and historic resources. It will also reduce the management demands upon NPS staff, which are already in excess of capacity as evidenced by such examples as the sad and deteriorated condition of the once beautiful and historic Randall House, the Wilkins Ranch, which was to become more accessible to the public as an environmental education center, and the nonnative invasive species visible along Highway One south of Olema.
Perhaps the most compelling reason for expanding the scope of the GMP Amendment is the need to have the lands on the east side of Highway One grazed and managed in an environmentally sound way to reduce the fire fuel load and consequent threat to the urban areas in East Marin and the San Geronimo Valley. The recent wildfires that destroyed so much of the inhabited areas in Sonoma and Napa Counties are a fierce cautionary tale.
For planning purposes, both the 1980 GMP and the unreleased draft 1980 GMP Update include what is called a Natural Zone. Implicit in this description is an assumption that managing land for agricultural purposes harms the land:
"These areas are outside of wilderness, but would be manage to minimize adverse impacts caused by human activity to the greatest extent possible. In most cases, areas in the Natural Zone would not be as undisturbed as areas within the Wilderness Zone. Grazing activities could take place within the Natural Zone when used as a treatment tool for resource management. [Emphasis added.]"
the implicit assumption that land is best left unmanaged, the definition acknowledges that grazing can be a treatment tool for resource management. Realistically, does the PRNS have the staff and other resources necessary to sporadically use grazing as a resource management treatment tool? Would the PRNS competitively bid the opportunity to temporarily bring cattle in to graze on the ranches in the southern part of the Olema Valley? Would this require preparing an Environmental Assessment first? If cattle are brought in too late, and the vegetation has become woody, cattle wont eat it. The fire fuel load that has developed will continue to increase if these lands remain unmanaged. These unmanaged lands are also a haven for invasive plant species. To see how invasive species spread on unmanaged land, take a hike through the formerly ranched Limantour Wilderness area where it is sometimes difficult at a distance to distinguish between a herd of elk and pampas grass.
Speakers at the November 2013 California-Pacific Society of Range Management meeting at the PRNS identified the benefits of managed grazing as including "ecosystem services, food production, preservation of view sheds and heritage values, fire fuel load reduction, wildlife habitat and the potential for carbon sequestration. See the report in the Marin Conservation League Jan/Feb 2014 Newsletter, beginning on page 6: www.marinconservationleague.org/images/stories/Newsletters/nl14a_janfeb2014_forweb.pdf
In addition, Sheila Barry, a Natural Resource and Livestock Advisor for the U.C. Cooperative Extension, who has been conducting applied research on grassland and oak woodland management for over 20 years, observed in a May 2015 Bay Nature article reasons why Public Lands Need Cattle to Meet Conservation Goals:
". . . . the stewardship provided by ranchers on public lands is a significant benefit that is often overlooked. Ranchers pick up trash, watch for wildfires, talk to and help visitors, repair fences, roads and trails, and report problems at a time when budgets for park rangers and maintenance are reduced."
As Ms. Barry also said in her Bay Nature article:
"Concerns with grazing on public lands have focused on overgrazing and impacts to riparian woodlands. These are legitimate concerns, but have been effectively addressed with modern range management practices, such as maintaining proper stocking rates, creating riparian pastures, limiting grazing in sensitive areas and adding off-stream water sources."
The assumption that managing land for agriculture necessarily has adverse impacts is both wrong and out-of-date. It is not supported by the science of good soil and land management. There is a world of literature on the environmental benefits of managing rangeland. For example, see the conservation benefits of invasive plant management in chapter 7 of this NRCS article: www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb1045802.pdf.
In a rebuttal article, Cattle Grazing Is Incompatible with Conservation, by Karen Klitz, of the Western Watersheds Project, and Jeff Miller, an advocate with the Center For Biological Diversity, a plaintiff in the case that led to the current environmental review process, the authors observed:
"Public agencies simply do not have the staff or funding to properly monitor grazing operations, let alone reduce cattle damage or intensively rotate and manage cattle for beneficial impacts. The best-intentioned grazing management plans are often not carried out due to lack of monitoring, personnel, or funding, and can be abandoned or altered when committed and experienced project managers leave an agency. Meanwhile, our public lands suffer from soil erosion, impaired water quality, invasive weeds and damaged streams."
These remarks about public agencies not having the staff to properly monitor grazing operations are very relevant when the NPS is facing a 13% cut in a budget that is already insufficient to adequately manage the rangelands that are not in active agriculture. Engaging the stewardship services of ranchers under lease terms that allow for implementation of NRCS best management practices, including grazing, would be a cost effective way to reduce the fuel load that has developed in the Olema Valley and the consequent fire danger and spread of invasive species. Development and implementation of carbon farm plans would increase the sequestration of carbon and water in the soil resulting in both healthier soil and a reduction in GHGs in the atmosphere.
The solution to the limitations on NPSs resources to oversee the operation of agricultural leases may lie with the Cuyahoga Valley National Park model, where the Park contracts with a nonprofit corporation to manage compliance with agricultural leases. It is an efficient and cost effective way to ensure compliance and would relieve the PRNS staff from the day-to-day responsibility for ensuring use of best management practices. It would also ensure that the ranchlands would be managed consistent with the high standards common to West Marin ranches. There are existing bodies capable of providing this service, e.g., the Marin Resource Conservation District and the Marin Agricultural Land Trust or another non-profit could be formed exclusively for this specific purpose if that were deemed more appropriate.
In addition to all of the other benefits, restoring the Olema Valley rangelands to agriculture would provide more opportunities for existing ranches to expand their capacity to support additional family members and create opportunities for new folks to become agriculturists in what otherwise becomes a closed society.
Restoring agriculture to these lands would also bring the NPS into compliance with the State of Californias Coastal Management Plan. The Federal Coastal Zone Management Act requires that Federal activities in a coastal zone be carried out in a manner which is consistent to the maximum extent practicable with the enforceable polies of approved State management programs. See 16 U.S.C. Section 1456(c)(1)(A). The California Coast Act provides that to the extent possible under Federal law, Federal agencies comply with the provision in the Coast Act. California Public Resources Code Section 300003. The same code provides in Section 30242 that:
"All . . . lands suitable for agricultural use shall not be converted to nonagricultural uses unless . . . continued or renewed agricultural use is not feasible . . . .
Benefit of Fencing Elk Out of Historic Ranch Districts:
For all of the reasons the Marin County Board of Supervisors identified in their comments, [g]razing livestock and free-range elk are not compatible. Lands in the historic ranching districts should be given protection corresponding to their intended use and purpose as should lands in the area designated wilderness.
In addition, one of the benefits of fencing the elk out of the pastoral zone is having more elk in the Limantour Wilderness to help keep the fire fuel load down. Instead of competing with the cattle for forage, the elk, which are both foragers and browsers, will necessarily feed more on the plentiful vegetation in the Wilderness. The PRNS may need to take additional steps to reduce the fire danger posed by the dense vegetation and dead and dying trees in the Limantour Wilderness, but having additional elk at work on the vegetation would be a good starting point for addressing the problem that has only gotten worse since the disastrous 1995 Inverness Fire.
Mitigation of Ongoing Climate Effects:
The research in preparing the draft 1980 GMP Update could be very useful in preparing a GMP Amendment, but one area in the draft that is clearly out-of-date is the proposed response to the threat of climate change. The unreleased draft focuses solely on the reduction of the carbon footprint of the Seashore. Thanks to research supported through the Marin Carbon Project since 2007, it is clear that instituting carbon farming based on NRCS-recognized best management practices benefits soil health, improves wildlife habitat, and could offset all of the GHGs generated in the course of managing the PRNS plus a portion of the GHGs generated by visitors to the PRNS. For history of the Marin Carbon Project, see www.marincarbonproject.org/about.
Currently the PRNS authorizes ranchers to implement what the PRNS refers to as best management practices for the limited purpose of protecting sensitive resources including water quality and rare and endangered species. See the General Management Plan Amendment Frequently Asked Questions. Developing and implementing carbon farm plans using all of the NRSC best management practices suitable to specific sites on specific ranches would yield many more benefits. For example, as identified above the benefits of managed grazing include "ecosystem services, food production, preservation of view sheds and heritage values, fire fuel load reduction, wildlife habitat and the potential for carbon sequestration. Instituting NRCS best management practices through carbon farm plans can also increase water retention in the soil thereby increasing the growing season and reducing the need to draw water from other sources. These effects are documented in studies by UC Berkeley College of Natural Resources Prof. Whendee Silver, among others. Selected publications by Dr. Silver are listed on: https://ourenvironment.berkeley.edu/people/whendee-silver.
The Marin Resource Conservation District develops carbon farm plans specific to a ranch and to specific sites on a ranch. The plans take into account multiple factors, e.g., slope, soil type, water and watercourses. For two examples of carbon farm plans, including one for a ranch in Marin, go to www.carboncycle.org/carbon-farming/. The lands managed by the PRNS could become a model for the nation if the proposed GMP Amendment fully supports the long-term leases necessary for the ranchers to invest both capital and their sweat equity in implementing carbon-farming practices.
Thank you for considering these comments.
Respectfully submitted,
MARINWATCH
s/s
_________________________________
Barbara Ravizza
President
___________________________
# 2875
Name: Ratcliffe, Jackson
Correspondence: Dear Parks,
I love Marin. I love to explore on foot as well as by bike.
However, the bike options in Pt Reyes are very fragmented and provide little or no connectivity. Now I do understand that the wilderness area causes most of the issues, but the ranch areas are exempt from the bike ban.
Please, please, please figure out a way to give bikes some more options to explore our spectacular park by bike.
Thankyou
___________________________
# 2876
Name: Affonso, Barbara
Correspondence: Please don't jeopardize and sacrifice the herds. I want to support the tule elk..I don't feel they should be "managed" in order to be compatible with ranching...I would like to see more herds, less ranching, and I also want to be given access to areas of the seashore currently closed to hikers.
I do not want the ranching leases extended...I want to see less of that and more public spaces opened, which include tule elk herds...the kind of beauty that is appropriate to the magnificent Pt. Reyes seashore ...also, the ranches make the air pretty nasty out that way on many days.
___________________________
# 2877
Name: giammona, michael
Correspondence:
Giammona Family Ranch
Cynthia MacLeod, acting superintendent
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes, CA 94956
Dear Superintendent:
Thank you for the opportunity to comment on General Management Plan (GMP) concerning continued ranching in the Point Reyes National Seashore and Golden Gate) Recreational Area. (GGNRA)
We have a small Lease in the Olema valley located within the boundaries of the GGNRA, that we have been our family cattle operation on since 1995.
Over the last twenty-two years we have concentrated on habitat protection of a small stream that runs on the edge of our border by voluntarily fencing it from cattle at our own expense and using the small pasture next to the creek in dry months at very limited times.
We are currently working with the Marin resource Conservation district, (RCD)as well as National Park service (NPS) habitat protection, Pasture management, as well as water quality on our lease.
The issuing of long term leases (20 years) it would insure that we could participate in projects that would help protect the natural resources and sensitive habitat on our ranch.
It would also allow us to make capital improvements on degrading barns as well as replace existing fencing with a more wildlife friendly design, as well as allowing coordinated rotational grazing to help protect natural resources. We are excited about the possibilities to work with NPS on a long-term goal, were we can develop a ranch management plan that can help us implement the best management practices available while becoming environmental stewards of the land. We have a "unique" situation, where we don't have access to the residence on the ranch, moving forward we would like consideration from NPS for a family member to be able to live on the ranch. This would help us out greatly in management of the ranch as well being able to respond more promptly to emergency situations with the cattle that may arise.
The proposed "Reduced Ranching Alternative" if applied would eliminate our lease and put us out of business, the financial implication would be extremely difficult if not impossible to recover from. We urge the NPS to implement the “Continued Ranching Alternative”
think that allowing some types of limited diversification opportunities even under a trial basis could greatly enhance the sustainability of ranching operations, which in turn would increase flexibility of the lease operator to manage the land in a way to help in protecting environmental sensitive areas. In our situation one of our sons has a pasture egg business outside of the NPS borders, he would like to be able to use one of the barns periodically to raise day old chicks in.
Thank you for the opportunity to comment and look forward in working with the NPS in the future.
Mike, Connie, Ryan and Morgan Giammona
___________________________
# 2878
Name: Magliocco, Mario J
Correspondence: Introduction: I am a lifelong resident of Marin County and have spent a good part of my life enjoying the Point Reyes National Seashore. I am lucky to be able to enjoy the park via numerous activities including hiking, biking, camping, picnicking, animal watching, boating, kayaking, fishing in the bays and ocean, diving, and foraging for mushrooms. I am especially lucky that the General Management Plan allows these amazing recreational opportunities for the public. Through my many years spent exploring the park I have intimate knowledge of the land and the impacts that the current ranching has on the environmental resources and the recreational opportunities in the park.
How can Point Reyes protect and manage the diverse and important natural and cultural resources in the planning area? Are there opportunities that could enhance future stewardship in the planning area?
PRNS should no longer give special consideration to non-life estate ranchers, and decide if ranching should remain based on an open and fair process. If ranching is to remain for historical, or cultural preservation purposes, it should be open to all operators without regard to paternity or family relation and it should include opportunities for public education. Additionally I would
Point Reyes National Seashore can better protect and manage the park if it stops giving special consideration to the decedents of the original ranch operators who sold their land to form the park. Securing the livelihood of ranch families in the Seashore should be of no concern of NPS. It is unfair and plainly against American values for the government to give special economic opportunities to individuals based solely on their paternity, especially when weighed against the interests of the public and the environment These families were handsomely paid for their properties and the original contract should be honored, with no further special consideration given to descendants (non life-estates).
The NPS could further protect and manage the cultural resources of the park by only allowing ranching and agricultural use that is historical in nature and included a public education component. The current ranching operations are nothing like the historical operations that existed before and at the time of the parks creation. If the PRNS wishes to continue ranching for cultural and historical reasons, those ranching operations should be historic, unique, and worth preserving in a way that makes them accessible to the public. The PRNS should not be simply preserving the historic commercial ranching "use" of the land, it should be preserving the cultural aspects of that historic "use" including the technology, language, materials, animals, crops, and techniques, and sharing that with the public. Currently the ranches at PRNS are similar to ranches throughout the region, with little to no opportunities for the education or recreation of the general public, and little reason to preserve them.
Removing special consideration for ranch families past the original owners and their wives (life-estates) and refocusing ranching in the park on preserving and protecting historical ranching culture would open up many exciting opportunities for protecting and enhancing natural and cultural resources in the park. Uses for the ranch lands could now include historical and educational ranching and agriculture, natural resource restoration and preservation, and more recreational opportunities for park visitors.
What types of visitor experiences, activities, and facilities should be available in the planning area?
Based on my personal experiences and interests, I would like to have more off-highway bicycling opportunities, more hand launched watercraft access, and more opportunities to learn and experience the historic culture of the area.
Biking and the use of human powered personal watercraft are two potentially environmentally friendly recreational activities that are becoming more popular amongst the general public and visitors to the area. The General Management Plan allows for bike use on a few fire roads and trails throughout the park, but due to their disconnected nature the experience suffers. More off-highway interconnections to allow bicycle riders to travel between the trails and fire roads where bicycles are allowed especially in areas that allow camping. More off highway bicycle routes would be safer for riders, automobile users, and would relieve congestion caused by bikes sharing narrow roads with cars. When considering the future use of the plan area bicycle route interconnection should be considered. Hand launched watercraft access could also be improved for bays and esteros bordered by and within the area.
If the ranch leases are extended, the PRNS should require the ranchers to provide educational experiences and activities related to current and historic agricultural activities and culture of the area. Additionally more experiences and facilities should be dedicated to the prehistoric culture of the area as well as pre-California history.
The PRNS should also expand camping, and recreational opportunities in the park. Instead of leasing the ranches areas for agricultural uses, concessionaires could provide a host of services and amenities such as camping, rustic lodging, and recreational experiences such as ropes courses or horseback riding.
What types of specific strategies can/should be considered for managing agricultural lease/permits?
The General Management Plan must clearly state the purpose and benefits to the public of continuing to allow private commercial activities on public park land. If commercial agricultural use of park land is to continue, the NPS must make a clear statement of the purpose of this use, how it benefits the public and base all further decisions on this. Currently there is no clearly stated purpose or intent given for extending the current ranch leases outside of the original contractual requirements. If it is for historic cultural reasons, then ranching activities should be historical in nature and include activities and experiences for park visitors. If it is for local economic reasons than the ranch leases should not be limited to family descendants of the original ranchers. If it is in order to secure the livelihood of a specific families in the seashore, then the PRNS should plainly state this and explain how it is in the best interests of the environment and the public for the federal government discriminate based on paternity.
Current ranching at the PRNS is a completely commercial activity and alternative uses, commercial or not, should be considered in a manner that serves the best interests of the people of the United States without regard to paternity. If commercial use of PRNS land is to continue, it should be open to proposals for use from private and public entities in an open and fair process that adheres to the guiding principles of the Park Service.
What types of specific strategies can/should be considered for managing tule elk?
elk should be declared native to the Pt. Reyes peninsula, and should be protected as such. Fences should be removed where they limit the elk from finding forage or water. From 2012 to 2014 more than 250 elk, fenced into the Tomales point area of PRNS died (about half of the heard), due to being unable to locate water sources due to the fences. Only if it is proven that the elk are harming agriculture or property outside of park land should any corrective measures be taken to manage the elk. Ideally this would involve fencing placed to stop the elk from going on to private property. All elk fences not on the boundary of the park should be removed.
___________________________
# 2879
Name: Bozinovich, Lu
Correspondence: MY RESPONSE:
I select option two as the most beneficial: "No Ranching and Limited Management of Tule Elk"
I am in favor of having the Point Reyes area be preserved as a national park, and the farming and ranching be phased out TOTALLY or the leases be shortened to the proposed five (5) years.
The trend in much of our society is away from animal agriculture and towards a plant-centric or plant-based diet.
Though smaller boutique farms could be allowed, even this type of farming of animals is still problematic and not humane.
1. Ranched agriculture and farmed animals are separated from each other, mothers from children and children from fathers, which is inhumane and unnatural.
2. There are still excess antibiotics used in animal agriculture and may be needed, noting the spread of a new disease mentioned on your site as one. And that overuse of antibiotics causes MRSA and other resistant strains to gain hold.
3. Externalities of this animal agriculture seem to be already evident in some of the reports from your area, in that mussels in the Pacific and nearby waters are infected and inedible. A particular disease is spreading between the farmed herds and the elk, and someday through various vectors to humans. And the tule elk are being killed off, a rare species endemic to California, worth having around.
e.g. "California Department of Public Health (CDPH) announces an annual quarantine of sport-harvested mussels gathered along the California coast. The quarantine is in effect from May 1 until October 31 and applies to all species of mussels that are recreationally harvested along the California coast, including all bays and estuaries. The quarantine is in place to protect the public against poisoning that can lead to serious illness, including coma and death."
4. Not all these family farms are following the rules. I was there some years ago, never saw an elk, but one of the cute boutique family dairy farms was egregiously mismanaging its herd. They were all filthy with dirt encrusted on their udders and all of them that I could see had mastitis (evident from the reddened areas of their teats). I drove by and then returned to be witness and photograph it, but by then all the cows were herded back inside and could not get any photos.
5. Animals are still taken to slaughter, and subjected to cruel inhumane practices, which should stop, and their lives are shortened unnaturally.
6. Our humanity is becoming more and more violent, at the same time, there is a trend afoot of people becoming vegan / vegetarian or more plant-based in their diets. And some doing so also for the reasons of ethics, the environment and world hunger. Whilst this does not guarantee a more peaceful society, there are a lot of arguments that reducing or eliminating animal agriculture (ranching and farming) leads to a more peaceful, enlightened society.
7. I wish you had provided a link to the lawsuit, for me (and anyone) to give you a better-informed response. It has been difficult and impossible for me to find a neutral source, so this comment is almost totally based on what you (NPS) provided to us.
So, I select option two as the most beneficial, based on my views and what I know. As you list it, this is:
"No Ranching and Limited Management of Tule Elk"
And your description is:
"This alternative is required by the Settlement Agreement. Under this alternative, ranching in all
areas of Point Reyes and the north district of Golden Gate would cease.
"With the exception of the two locations with life-estates, ranching operations would be phased out over a 5-year period. No agricultural activities would be permitted after the life-estates expire."
MY RESPONSE ENDS
___________________________
# 2880
Name: Velebit, Milan
Correspondence: Reviewing the alternatives provided in your NPS planning document subject to the court settlement I believe that for the general public benefit and the Tule Elk the No Ranching and Limited Management of Tule Elk is highly preferable as it increases public use if these lands with outdoor activities as nicely stated in your document. This includes public appreciation of the Tule Elk.
I would find the alternative Continue Current Management (No Action) much less desirable but certainly preferable to the other alternatives that would increase usage of these precious lands for a few for commercial purposes instead of the many for public benefit. The quantity of agricultural output is minimal and hence a loss of this production would have no economic impact outside of the few that would benefit directly.
I have personally enjoyed the area and the only change I find desirable is for an increase in public benefit as should arise from my choice.
___________________________
# 2881
Name: Evans, David D
Correspondence: November 22, 2017
Superintendent Cynthia MacLeod
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes Station, California 94956
Dear Superintendent:
We appreciate the opportunity to comment on the Point Reyes National Seashore (PRNS) and North District of Golden Gate National Recreation Area (GGRNA) (collectively the "Seashore") General Management Plan (GMP) Amendment process and the subsequent National Environmental Policy Act (NEPA) review. We understand this to be the first of several scoping and issue identification steps as part of the GMP and NEPA processes.
The GMP Amendment is the foundation for providing the cultural resource, natural resource, andeconomic benefits envisioned by Congress when it established and preserved these magnificent areas
and provided for continued ranching and dairying in the Pastoral Zone. We are honored and grateful to be part of this longstanding history and we take great pride in continuing to ensure that ranching and dairying contribute to the agricultural heritage of Marin County and promote the environmental and scenic quality of the working landscapes of the Seashore. Accordingly, we offer the following comments for consideration during this public comment period and we will participate fully in subsequent stages and opportunities to discuss the development of the GMP for the Point Reyes National Seashore and Golden Gate National Recreation Area.
I. Purpose and Need
A fundamental first step in the NEPA process is defining the purpose and need for the underlying federal action. The purpose and need forms the basis for identifying the reasonable range of alternatives to be evaluated and provides the criteria by which to systematically compare the identified alternatives. Through the GMP amendment process, the NPS is establishing a strategic framework which will guide the long-term management of the 28,000 acre Pastoral Zone. We believe that it is critical that this statement must recognize the critical need for fostering and maintaining sustainable dairy and beef ranching in the Seashore to protect the historic resources of the area, maintain the environmental conditions, and continue to contribute to the local economy. Ranching has a long and important history on the Point Reyes peninsula and adjacent National Park Service lands. These working ranches are a vibrant part of the culture of the Point Reyes National Seashore and represent an important contribution to the superlative natural and scenic resources of these NPS lands. Protection of these diverse and unique resources is an important responsibility shared by the NPS and Seashore ranchers within the Pastoral Zone. A comprehensive management plan is needed to:
• Articulate a clear vision for ranching on existing ranch lands in the Pastoral Zone administered by Point Reyes National Seashore.
• Allow for issuance of leases with terms of at least 20 years to provide for maintenance and improvement of ranching infrastructure, the working landscape, and the associated environment.
• Address concerns related to tule elk impacts on the environment and working ranches.
• Provide clear guidance and streamline processes for Seashore and regulatory review of proposed ranching activities, including best management practices that promote protection of Seashore resources.
II. Alternatives
heart of the analysis required under NEPA is the identification and evaluation of alternatives. NEPA regulations require an agency to “rigorously explore and objectively evaluate all reasonable alternatives” (40 CFR §1502.14(a)), to devote substantial treatment to each alternative (40 C.F.R. §1502.14(b)), to identify the federal agency's preferred alternative (40 C.F.R. §1502.14(e)) and to describe the environmental impacts of the proposed action and potentially feasible alternatives in a comprehensive form to sharply define the issues and provide a clear basis for choice among options by decision-makers and the public. We recognize that pursuant to the terms of the July 2017 Settlement Agreement, NPS must include the three alternatives identified therein. As is recognized in the GMP Amendment newsletter, the NPS is not limited to these alternatives and it is imperative that NPS consider a full range of alternatives. The NPS GMP notice includes three additional alternatives which we agree should be
part of its review.
In addition to the three alternatives proposed by the NPS, we urge consideration of the following modifications or expansions of the existing list of alternatives referenced by NPS:
• Evaluate an alternative similar to the second “Continued Ranching Alternative” proposed by NPS, which allows for defined additional opportunities in farming and diversified agricultural production to complement existing ranching and dairy activities. We believe that such limited additional uses would provide multiple economic and educational benefits to the community, would increase the economic viability of Seashore ranches, and would strengthen the overall agricultural economy of our region. We are not proposing in this alternative expanding beyond the current 28,000acre Pastoral Zone. In addition, in this alternative, we would ask that NPS consider a somewhat longer lease term (25-30years) for ranches and dairies to facilitate investments in our agricultural infrastructure that will make us more productive, efficient, and protective of the environment. The added term can help us amortize such measures in a sustainable, long term fashion.
• Consider forage improvement practices which could result in modest additions to existing herds and dairy farms consistent with water quality improvements and carbon sequestration practices. Allowance of forage improvement practices could be a consideration for addition to the NPS’ best management practices that would allow ranching on the Seashore to evolve to be a national model for renewable and beneficial ranching for resource management.
• We suggest that the “Reduced Ranching” should be amended to reduce ranching only where there is an arguably justifiable reason. No such reason is apparent In the initial description of the alternative. For instance, the AT&T Lease is currently managed in concert with D. Rogers Ranch Lease (as referenced in the D. Rogers Ranch Lease) in such a way as to allow seasonal grazing of each, controlled rest periods and stocking rates, and improvement of habitat for listed endangered species (Red Legged Frogs, Sonoma Alopecurus, Beach Layia, and Myrtle’s Silverspot Butterfly). Specifically, we ask that AT&T Lease remain in active ranching, and not removed from active ranching, as proposed in the “Reduced Ranching” alternative.
III. Issues
A. Economic analysis
Reducing or eliminating ranching and dairies from Point Reyes would have profound adverse economic consequences for the local and regional economy. These family ranches are essential to many local and regional businesses and represent an important cultural and economic way of life that extends beyond the Seashore. The ranches are a critical part of that cultural mosaic of estuaries, lagoons, ridges, hillsides, forests, and beautiful grasslands that make up the overall environment which in turn attract thousands of visitors every year. Without the stewardship of the ranching community, much of this landscape would not be there today. We ask that through the GMP and EIS process, the NPS, as a member of our local community, assess the positive and important economic benefits not only to the ranching and dairy families, but to our broader community and region as a whole. Local employment, changes to demographics, and local community well-being should be considered, as the ripple effect of ranching in the Seashore is vast. For example, our local school system is heavily dependent upon the enrollment of students and tax base from ranching families and the ranch employees’ families. These economic considerations should be a critical part of identifying the agency’s preferred alternative.
B. Diversification & Increased Seashore Visitor Experience
The GMP/EIS process should evaluate a variety of additional agricultural and agricultural-related activities that could help to strengthen the area’s economy, build on its tourism base, and bring high quality educational programs to the area, the latter two points of which increase the public’s access to and interaction with the Seashore’s ranch lands and cultural heritage. These complementary uses add to the sustainability of the ranches and ranching families while enhancing visitor experiences. Diversification can include selected planted or naturally occurring crops, additional livestock production, farm stands and retail sales, processing and value-added production, farm stays, farm educational tours, and expanded work with the school systems and 4-H organizations. The NPS visitor experience enhancements that would come from a comprehensive NPS educational/tourism program celebrating the cultural history of the area and its contribution to ranching, agriculture, and the resulting ecosystem services and environmental stewardship would be beneficial to NPS.
Consideration of on farm grown and stored livestock feed of silage and hay should be included in this examination. This long-standing farming practice combines the benefits of critical seasonal forage production with effective weed management, balanced herd nutrition and distribution management. It also reduces the need for imported supplemental feed and incentivizes effective on-site resource use and ranch resiliency.
We ask that non-commercial animal units continue to be allowed on a limited but expanded basis of 10 animal units per lease, to allow for production dedicated to feed family, employees, or other non-commercial uses like educational or charitable events. These non-commercial animal units can also serve as tools for prescribed impact use, such as evasive plant suppression, habitat restoration, and other resource management uses.
C. Succession
We encourage the GMP and EIS to review the all-important issue of succession to current and future leases. One overall goal of NPS should be to ensure that current families continue their stewardship of existing ranch and dairy lands, and provide a continuity of ownership going forward. But in the event that families choose not to continue ranching and dairying, and to continue this rich heritage and the environmental stewardship that accompanies it, we ask that existing families of current lessees be first considered and prioritized as successional lease holders. This continuation of ranching and agriculture at the Seashore should be a component of the GMP. Within this framework, we know the past cumulative experience and judgment of existing ranching families will provide important guidance to NPS.
D. Environmental Stewardship and Best Management Practices
We support implementation of best management practices (BMP) for ranching, dairy, and other agriculture activities. The GMP and accompanying EIS should evaluate these BMPs to insure their applicability, practicality, and success in protecting the environment and insuring economic viability, all of which are consistent with federal, state, and local requirements. As we have done frequently in the past, we are prepared to step forward to assist with important environmental projects ranging from preserving threatened species to improving water quality. We continue to be willing participants in considering, where feasible and necessary, other environmental measures that may add to the success of BMPs in protecting the natural values of the Seashore. With respect to methane and climate change, we believe the GMP/EIS should address how local ranches and dairies can play an important role in mitigating such impacts, potentially through carbon offsets and other payments for environmental services. Marin County and the State of California are leaders in this area and we welcome the opportunity to work with them as part of this effort. We also believe that a variety of public and private partners may provide important technical and financial resources to assist in this effort. NPS and the ranching community at the Seashore can develop state of-art approaches and serve as a model for programs elsewhere.
E. Operational Flexibility
infrastructure maintenance and repair at the Seashore has often been delayed for extended periods of time in part because guidelines are unclear or nonexistent. The GMP should contain more specific guidelines to allow for critical work to be efficiently authorized by NPS in the future. In the coming months while the GMP progresses, we would welcome a working group to develop appropriate guidelines to assist the agency in more efficient and timely decision-making to allow effective management of weeds, fire fuels, protect water quality, livestock watering and distribution, and other field and ranch level concerns. We ask that preliminary processes and procedures be completed that satisfy regulatory requirements far in advance of potential projects, such as but not limited to archeology, sensitive habitat, cultural resources, natural resources, that will allow approved projects to proceed without delay. Each alternative should include a process for future decision making.
F. Tule Elk
We support managed populations of tule elk throughout the Seashore. We urge the NPS to adopt a GMP amendment that defines a broad range of management methods to prevent tule elk from over impacting any of the pastoral areas within the Seashore. We also ask that the NPS implement a tule elk maximum population threshold, much like Animal Units on ranches, that will trigger established efforts in population control, as defined by the GMP. The goal of the maximum population threshold would be to determine the number of tule elk that would create a thriving herd which remains compatible with competing resource uses, such that tule elk, other wild life, and agricultural activities are all provided for. We further ask that the tule elk be managed as a sustainable natural resource, and that partnership be established with the local USDA inspected slaughterhouse (Marin Sun Farms Inc, Petaluma CA) to implement humane culling best management practices that will allow culled tule elk to be processed and distributed for human consumption. Marin Sun Farms, Inc. is already approved by the United States Department of Agriculture (USDA) to process Exotic species and a precedent for humane USDA harvesting of elk has already been established in locations such as Maui, HI.
G. Leases
To ensure consistency and facilitate clear understanding of forthcoming requirements and operational
issues, it would be helpful for the GMP to contain a draft lease template. We urge NPS to meet with individual ranchers to discuss past leasehold provisions and how new approaches can be adopted to reflect important on-the-ground considerations. We ask that incentives be added to leases that provide value-based reward in the form of a rent credit for exceptional environmental stewardship, infrastructure maintenance, visitor experience, ranch appearance and upkeep, and other incentives based on Seashore values.
We thank you for the opportunity to provide these initial comments and we look forward to working
with NPS on all subsequent stages of the GMP and EIS.
Sincerely,
David Evans & Claire Herminjard
___________________________
# 2882
Name: Herminjard, Claire L
Correspondence: November 22, 2017
Superintendent Cynthia MacLeod
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes Station, California 94956
Dear Superintendent:
We appreciate the opportunity to comment on the Point Reyes National Seashore (PRNS) and North District of Golden Gate National Recreation Area (GGRNA) (collectively the "Seashore") General Management Plan (GMP) Amendment process and the subsequent National Environmental Policy Act (NEPA) review. We understand this to be the first of several scoping and issue identification steps as part of the GMP and NEPA processes.
The GMP Amendment is the foundation for providing the cultural resource, natural resource, andeconomic benefits envisioned by Congress when it established and preserved these magnificent areas
and provided for continued ranching and dairying in the Pastoral Zone. We are honored and grateful to be part of this longstanding history and we take great pride in continuing to ensure that ranching and dairying contribute to the agricultural heritage of Marin County and promote the environmental and scenic quality of the working landscapes of the Seashore. Accordingly, we offer the following comments for consideration during this public comment period and we will participate fully in subsequent stages and opportunities to discuss the development of the GMP for the Point Reyes National Seashore and Golden Gate National Recreation Area.
I. Purpose and Need
A fundamental first step in the NEPA process is defining the purpose and need for the underlying federal action. The purpose and need forms the basis for identifying the reasonable range of alternatives to be evaluated and provides the criteria by which to systematically compare the identified alternatives. Through the GMP amendment process, the NPS is establishing a strategic framework which will guide the long-term management of the 28,000 acre Pastoral Zone. We believe that it is critical that this statement must recognize the critical need for fostering and maintaining sustainable dairy and beef ranching in the Seashore to protect the historic resources of the area, maintain the environmental conditions, and continue to contribute to the local economy. Ranching has a long and important history on the Point Reyes peninsula and adjacent National Park Service lands. These working ranches are a vibrant part of the culture of the Point Reyes National Seashore and represent an important contribution to the superlative natural and scenic resources of these NPS lands. Protection of these diverse and unique resources is an important responsibility shared by the NPS and Seashore ranchers within the Pastoral Zone. A comprehensive management plan is needed to:
• Articulate a clear vision for ranching on existing ranch lands in the Pastoral Zone administered by Point Reyes National Seashore.
• Allow for issuance of leases with terms of at least 20 years to provide for maintenance and improvement of ranching infrastructure, the working landscape, and the associated environment.
• Address concerns related to tule elk impacts on the environment and working ranches.
• Provide clear guidance and streamline processes for Seashore and regulatory review of proposed ranching activities, including best management practices that promote protection of Seashore resources.
II. Alternatives
heart of the analysis required under NEPA is the identification and evaluation of alternatives. NEPA regulations require an agency to “rigorously explore and objectively evaluate all reasonable alternatives” (40 CFR §1502.14(a)), to devote substantial treatment to each alternative (40 C.F.R. §1502.14(b)), to identify the federal agency's preferred alternative (40 C.F.R. §1502.14(e)) and to describe the environmental impacts of the proposed action and potentially feasible alternatives in a comprehensive form to sharply define the issues and provide a clear basis for choice among options by decision-makers and the public. We recognize that pursuant to the terms of the July 2017 Settlement Agreement, NPS must include the three alternatives identified therein. As is recognized in the GMP Amendment newsletter, the NPS is not limited to these alternatives and it is imperative that NPS consider a full range of alternatives. The NPS GMP notice includes three additional alternatives which we agree should be
part of its review.
In addition to the three alternatives proposed by the NPS, we urge consideration of the following modifications or expansions of the existing list of alternatives referenced by NPS:
• Evaluate an alternative similar to the second “Continued Ranching Alternative” proposed by NPS, which allows for defined additional opportunities in farming and diversified agricultural production to complement existing ranching and dairy activities. We believe that such limited additional uses would provide multiple economic and educational benefits to the community, would increase the economic viability of Seashore ranches, and would strengthen the overall agricultural economy of our region. We are not proposing in this alternative expanding beyond the current 28,000acre Pastoral Zone. In addition, in this alternative, we would ask that NPS consider a somewhat longer lease term (25-30years) for ranches and dairies to facilitate investments in our agricultural infrastructure that will make us more productive, efficient, and protective of the environment. The added term can help us amortize such measures in a sustainable, long term fashion.
• Consider forage improvement practices which could result in modest additions to existing herds and dairy farms consistent with water quality improvements and carbon sequestration practices. Allowance of forage improvement practices could be a consideration for addition to the NPS’ best management practices that would allow ranching on the Seashore to evolve to be a national model for renewable and beneficial ranching for resource management.
• We suggest that the “Reduced Ranching” should be amended to reduce ranching only where there is an arguably justifiable reason. No such reason is apparent In the initial description of the alternative. For instance, the AT&T Lease is currently managed in concert with D. Rogers Ranch Lease (as referenced in the D. Rogers Ranch Lease) in such a way as to allow seasonal grazing of each, controlled rest periods and stocking rates, and improvement of habitat for listed endangered species (Red Legged Frogs, Sonoma Alopecurus, Beach Layia, and Myrtle’s Silverspot Butterfly). Specifically, we ask that AT&T Lease remain in active ranching, and not removed from active ranching, as proposed in the “Reduced Ranching” alternative.
III. Issues
A. Economic analysis
Reducing or eliminating ranching and dairies from Point Reyes would have profound adverse economic consequences for the local and regional economy. These family ranches are essential to many local and regional businesses and represent an important cultural and economic way of life that extends beyond the Seashore. The ranches are a critical part of that cultural mosaic of estuaries, lagoons, ridges, hillsides, forests, and beautiful grasslands that make up the overall environment which in turn attract thousands of visitors every year. Without the stewardship of the ranching community, much of this landscape would not be there today. We ask that through the GMP and EIS process, the NPS, as a member of our local community, assess the positive and important economic benefits not only to the ranching and dairy families, but to our broader community and region as a whole. Local employment, changes to demographics, and local community well-being should be considered, as the ripple effect of ranching in the Seashore is vast. For example, our local school system is heavily dependent upon the enrollment of students and tax base from ranching families and the ranch employees’ families. These economic considerations should be a critical part of identifying the agency’s preferred alternative.
B. Diversification & Increased Seashore Visitor Experience
The GMP/EIS process should evaluate a variety of additional agricultural and agricultural-related activities that could help to strengthen the area’s economy, build on its tourism base, and bring high quality educational programs to the area, the latter two points of which increase the public’s access to and interaction with the Seashore’s ranch lands and cultural heritage. These complementary uses add to the sustainability of the ranches and ranching families while enhancing visitor experiences. Diversification can include selected planted or naturally occurring crops, additional livestock production, farm stands and retail sales, processing and value-added production, farm stays, farm educational tours, and expanded work with the school systems and 4-H organizations. The NPS visitor experience enhancements that would come from a comprehensive NPS educational/tourism program celebrating the cultural history of the area and its contribution to ranching, agriculture, and the resulting ecosystem services and environmental stewardship would be beneficial to NPS.
Consideration of on farm grown and stored livestock feed of silage and hay should be included in this examination. This long-standing farming practice combines the benefits of critical seasonal forage production with effective weed management, balanced herd nutrition and distribution management. It also reduces the need for imported supplemental feed and incentivizes effective on-site resource use and ranch resiliency.
We ask that non-commercial animal units continue to be allowed on a limited but expanded basis of 10 animal units per lease, to allow for production dedicated to feed family, employees, or other non-commercial uses like educational or charitable events. These non-commercial animal units can also serve as tools for prescribed impact use, such as evasive plant suppression, habitat restoration, and other resource management uses.
C. Succession
We encourage the GMP and EIS to review the all-important issue of succession to current and future leases. One overall goal of NPS should be to ensure that current families continue their stewardship of existing ranch and dairy lands, and provide a continuity of ownership going forward. But in the event that families choose not to continue ranching and dairying, and to continue this rich heritage and the environmental stewardship that accompanies it, we ask that existing families of current lessees be first considered and prioritized as successional lease holders. This continuation of ranching and agriculture at the Seashore should be a component of the GMP. Within this framework, we know the past cumulative experience and judgment of existing ranching families will provide important guidance to NPS.
D. Environmental Stewardship and Best Management Practices
We support implementation of best management practices (BMP) for ranching, dairy, and other agriculture activities. The GMP and accompanying EIS should evaluate these BMPs to insure their applicability, practicality, and success in protecting the environment and insuring economic viability, all of which are consistent with federal, state, and local requirements. As we have done frequently in the past, we are prepared to step forward to assist with important environmental projects ranging from preserving threatened species to improving water quality. We continue to be willing participants in considering, where feasible and necessary, other environmental measures that may add to the success of BMPs in protecting the natural values of the Seashore. With respect to methane and climate change, we believe the GMP/EIS should address how local ranches and dairies can play an important role in mitigating such impacts, potentially through carbon offsets and other payments for environmental services. Marin County and the State of California are leaders in this area and we welcome the opportunity to work with them as part of this effort. We also believe that a variety of public and private partners may provide important technical and financial resources to assist in this effort. NPS and the ranching community at the Seashore can develop state of-art approaches and serve as a model for programs elsewhere.
E. Operational Flexibility
infrastructure maintenance and repair at the Seashore has often been delayed for extended periods of time in part because guidelines are unclear or nonexistent. The GMP should contain more specific guidelines to allow for critical work to be efficiently authorized by NPS in the future. In the coming months while the GMP progresses, we would welcome a working group to develop appropriate guidelines to assist the agency in more efficient and timely decision-making to allow effective management of weeds, fire fuels, protect water quality, livestock watering and distribution, and other field and ranch level concerns. We ask that preliminary processes and procedures be completed that satisfy regulatory requirements far in advance of potential projects, such as but not limited to archeology, sensitive habitat, cultural resources, natural resources, that will allow approved projects to proceed without delay. Each alternative should include a process for future decision making.
F. Tule Elk
We support managed populations of tule elk throughout the Seashore. We urge the NPS to adopt a GMP amendment that defines a broad range of management methods to prevent tule elk from over impacting any of the pastoral areas within the Seashore. We also ask that the NPS implement a tule elk maximum population threshold, much like Animal Units on ranches, that will trigger established efforts in population control, as defined by the GMP. The goal of the maximum population threshold would be to determine the number of tule elk that would create a thriving herd which remains compatible with competing resource uses, such that tule elk, other wild life, and agricultural activities are all provided for. We further ask that the tule elk be managed as a sustainable natural resource, and that partnership be established with the local USDA inspected slaughterhouse (Marin Sun Farms Inc, Petaluma CA) to implement humane culling best management practices that will allow culled tule elk to be processed and distributed for human consumption. Marin Sun Farms, Inc. is already approved by the United States Department of Agriculture (USDA) to process Exotic species and a precedent for humane USDA harvesting of elk has already been established in locations such as Maui, HI.
G. Leases
To ensure consistency and facilitate clear understanding of forthcoming requirements and operational
issues, it would be helpful for the GMP to contain a draft lease template. We urge NPS to meet with individual ranchers to discuss past leasehold provisions and how new approaches can be adopted to reflect important on-the-ground considerations. We ask that incentives be added to leases that provide value-based reward in the form of a rent credit for exceptional environmental stewardship, infrastructure maintenance, visitor experience, ranch appearance and upkeep, and other incentives based on Seashore values.
We thank you for the opportunity to provide these initial comments and we look forward to working
with NPS on all subsequent stages of the GMP and EIS.
Sincerely,
David Evans & Claire Herminjard
___________________________
# 2883
Name: LeMieux, Dotty E
Correspondence: I support continued ranching in the seashore. Please do extend twenty year leases. Ranchers need assurances of continuity. I also support erosion control practices, and believe these can be done working cooperatively with the ranchers. They provide a needed service, good food, and historical use in the parklands.
___________________________
# 2884
Name: Isadore, Megan
Correspondence:
November 21, 2017
Cynthia MacLeod, Acting Superintendent
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes, CA 94956
RE: Comments on General Management Plan Amendment Concepts
Dear Acting Superintendent MacLeod,
Thank you for the opportunity to submit comments on the General Management Plan Amendment (GMPA) Concepts.
River Otter Ecology Project, based in Marin County, CA, engages the public in supporting conservation and restoration by linking river otter recovery to the health of our watersheds through education, research, and community science. River otters, although not a protected species, are sentinel apex predators that use every part watersheds, from headwaters to ocean. Their presence and success are important indicators of ecosystem function and environmental health.
For nearly six years, we have conducted intensive research on river otter populations within Point Reyes National Seashore (PRNS). Consistent with NPS Management Policy 4.2, our "studies support the NPS mission by providing the Service, the scientific community, and the public with an understanding of park resources, processes, values, and uses that will be cumulative and constantly refined."
Our research entails field study in the PRNS at least once a week at up to 10 different sites, and we've had abundant opportunity to observe and document changes and conditions that affect the natural resources and visitor experience in the Seashore.
Some of our observations connected to ranching uses in the Point Reyes National Seashore include the following:
Cattle are regularly outside their pastures and the pastoral zone at Abbott’s Lagoon. There is no time that we don’t find cattle sign (prints and droppings) around the outer Lagoon at Abbott’s, close to the foot bridge. What strategies will the GMPA propose to ensure that cattle do not encroach on and impair park resources in wilderness areas?
The most egregious example was in 2016 when approximately 10 young cows made their way to Abbotts outer lagoon, and proceeded to spend the next 4-6 weeks around the inner and outer lagoons, trampling plants, causing erosion and impeding access for wildlife to their foraging areas. We informed PRNS staff, who informed the rancher, but nothing was done for many weeks. Will the GMPA outline penalties or other sanctions for ranchers whose cattle habitually roam and graze outside the ranch lease areas?
Many fences in the pastoral zone are not wildlife friendly. Many are battered, broken, or missing the upper and lower “wildlife friendly” wires lacking the barbs that allow wildlife to pass without harm.
We are concerned about water quality in the stock ponds, which may be detrimental to wildlife habitat due to erosion, run-off, siltification, and nitrogen overload.
We often see barbed wire or other harmful wire left in fields for long periods of time. These are hazards to wildlife, as well as detrimental to visitor experience.
We occasionally take volunteers or other visitors to see river otters in the PRNS. We get many questions about why the “whole park” seems to be ranching. We’re aware that it is not the whole park, of course, but there is that perception. Our walks tend to be conservation outings, explaining the importance of watershed conservation not only for humans, but also for wildlife. There’s an obvious disconnect between conservation and ranching values and practices in the PRNS, and it is noticed.
We have questions about the Management Alternatives, and request that the following issues are clarified:
Tule Elk: We will not support any alternative that includes “culling” of the herds. The PRNS has a responsibility to preserve the elk, a precious resource within the PRNS ecosystem. One example of a conservation walk question we received about tule elk and ranching: “Why don’t we see elk here? I came to see elk and all I see are cattle.” Management strategies for the elk should benefit the elk, not the ranchers.
Climate Change and Sea Level Rise: Wildlife will bear the brunt of sea level rise. As climate change effects make their inexorable way into PRNS watersheds, they’ll inevitably change pastoral zone areas. River otters depend upon intact watersheds with freshwater and wetland habitat, to thrive. How will the Park deal with conflicts due to climate change among ranchers, wildlife and natural landscapes?
What do you mean by “diversification?” Does it involve intensification of use of the land and water? How can it be consistent with your mandate to ensure non-impairment of park resources, especially habitat value?
In conclusion, river otters’ charm and relative ease of viewing provide a truly inspiring resource to support conservation in the PRNS. The fact that they’re making an unassisted recovery in the PRNS is a conservation success story. As long as they thrive, the public has an enormous interest in protecting our public lands. Let us please concentrate on the needs of our charismatic megafauna like otters, elk, bobcats, coyote, puma and raptors to support appropriate use of the seashore, rather than old-fashioned and, frankly, unsustainable ranching practices, going forward.
Sincerely,
Megan Isadore,
Co-Founder and Executive Director
The River Otter Ecology Project
___________________________
# 2885
Name: Yancy, Vennie A
Correspondence: To the National Park Service Superintendent, et. al.:
I am writing to express my strong belief that the farmers of cattle using California Parklands should NOT be given extensions of their leases.
Several Points:
Water quality, erosion, native plants and species must be prioritized over ranching operation. The effects of cattle on soil, watersheds, as well as air quality, are well documented. To allow cattle to graze on OUR parklands is a violation of the Park Service's stewardship mandate of the land. I could provide links to show the detriment of cattle, but I am sure these facts have been presented to you. Please review them. This information, in my opinion, is all we need to end the use of Parklands for cattle grazing. You need to conduct adequate environmental studies if you are truly still considering allowing beef and dairy farmers to actively use our lands.
The Miwok Indians lived on the land long before the Spaniards and ranchers. Their history goes much further back than a few dairy farmers. These farmers would never have had the open land if not for the Miwok working of the land. Now the land is being misused.
The use of the word agriculture is misleading. It has been misused in legal circles to include living creatures, the cattle. Any right claimed under the use of agriculture is erroneous and should not be honored.
In this time of great concern for our planet, surely we must protect the lands that are for the Public, not for a few environmentally destructive industries. In addition, the sight of veal huts, while driving in West Marin is painful. The reality is more painful. The calves, taken from their mother at birth and raised in small huts to severely limit their movement until their slaughter, is inhumane and should not be allowed. In dairy cattle, a constant birthing of calves is required to keep the cow in full milk production.
Across the country, cattle are allowed to graze on the American people’s public land. It’s a practice that has been abused. Now that more is understood about cattle’s detriment to the environment, you must educate yourselves, as the stewards of our land.
Please do not offer 20 year leases to west Marin beef and dairy farmers.
Sincerely, Vennie Yancy
___________________________
# 2886
Name: Rice, Jack L
Correspondence:
California Farm Bureau Federation
2300 River Plaza Drive
Sacramento, CA 95833
November 22, 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 California Farm Bureau Federation (Farm Bureau) appreciates the opportunity to comment on the General Management Plan Amendment (GMP) for the Point Reyes National Seashore (PRNS).
The ranches and dairies operating on PRNS are an integral part of the environmental, economic, and cultural fabric of the seashore and of the surrounding communities. Farm Bureau encourages the Park Service to consider, and ultimately adopt, the amendments to the GMP that preserve the PRNS' unique agricultural and natural heritage for future generations of agriculturalists and visitors.
Farm Bureau is a non-governmental, non-profit, voluntary membership California corporation whose purpose is to protect and promote agricultural interests throughout the state of California and to find solutions to the problems of the farm, the farm home, and the rural community. Farm Bureau is California’s largest farm organization, comprised of 53 county Farm Bureaus currently representing approximately 48,000 agricultural, associate, and collegiate members in 56 counties. Farm Bureau strives to protect and improve the ability of farmers and ranchers engaged in production agriculture to provide a reliable supply of food and fiber through responsible stewardship of California’s resources.
Consideration of Modified Alternative
Farm Bureau requests the National Park Service to consider a modified version of the "Continued Ranching with Removal of the Drakes Beach Tule Elk Herd" alternative. Specifics of this alternative are more fully described in letters from the Point Reyes Seashore Ranchers Association and the California Cattlemen’s Association, both of which are incorporated herein by this reference. In this letter, we highlight a few of the key elements of the alternative, including agricultural lease/permits with 20-year terms, removal of elk from the pastoral zone, and increased operational flexibility for ranches and dairies.
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 the 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 the 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 the PRNS. These ranches are not just creating economic value, they are producing high quality food appreciated by consumers locally, regionally, and nationally.
To maintain this unique piece of California, it is important the National Park Service manage PRNS in a way that enhances the viability of the ranches and dairies that operate in the pastoral zone.
Lease/Permits with 20-Year Terms
Providing leases/permits with 20-year terms is essential to maintaining the long-term viability of ranches and dairies in the PRNS. Farmers and ranchers have been raising cattle in Point Reyes for more than 150 years. It was their willingness to sell to the Federal government in the first place that allowed the creation of the PRNS. As part of the transaction, ranchers were assured they would be allowed to continue raising livestock on their family ranches within the PRNS. This assurance was based in part upon Congressional recognition that the agrarian nature of the area was an essential element of what made PRNS unique.
20-year terms for leases/permits helps preserve this aspect of the PRNS by allowing for greater investment in improvements on these ranches and dairies. Shorter terms prevent the ability of agricultural managers to obtain financing or justify investment for improvements.
Elk Management
management of the PRNS elk herds is necessary for the ecological and agricultural health of PRNS. 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. The 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, the 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.
 
Agricultural Flexibility
Farm Bureau encourages the National Park Service to consider expanding the operational flexibility of ranches and dairies within the PRNS. Some of the expanded flexibility should include alternative forms of weed control (e.g. goats), variable stocking rates, and increased opportunities for crop production. This flexibility will not only improve the viability of the family farms, but also afford ecological and cultural benefits to PRNS and surrounding communities.
Alternatives That Do Not Include Continued Agriculture Should Be Rejected
Farm Bureau supports consideration of all the alternatives required in the settlement agreement. However, when considering those alternatives, it is important to recognize that those alternatives which reduce or eliminate livestock on the PRNS would be inconsistent with the original vision of the seashore and would fundamentally harm the environmental, agricultural, and cultural character of the areas. We strongly encourage full consideration of the detrimental impacts of removing agriculture from the PRNS.
Conclusion
Ranches and dairies on the 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. Providing 20-year lease/permits, improving elk management, and increasing operational flexibility are key elements to ensure that the unique aspects of the PRNS that make is so enjoyable for so many are preserved for future generations.
Sincerely,
Jack Rice
Associate Counsel
Noelle Cremers
Director, Natural Resources and Commodities
___________________________
# 2887
Name: N/A, N/A
Correspondence:
I urge the NPS to prioritize the park, its wildlife, and recreational access over ranching consistent with the mission and spirit of our national parks.
While I recognize and applaud the vital contribution made by ranchers when the park was created, there were no agreements to maintain ranching beyond the lifetimes of the ranchers who willingly sold their lands (or in some cases leases) to the Federal government for the purpose of establishing the National Seashore. National Parks have typically offered Reservation of Use leases to property owners enabling them to remain on park lands for a set period (up to 40 years) and/or the remainder of the lifetime from the original land owner. I don't believe any circumstances exist which, over fifty years since the park's creation, would justify extending leases beyond the lifetimes of those who originally sold their land.
Therefore I would argue for the General Plan to establish a timeline for a phase out of ranching. I fear that political pressure from politicians who are responding to local interests will have undue influence on a decision which should focus on the broader implications on national park policy.
The current options which include killing, or severely limiting, native wildlife in favor of for-profit activities runs counter to the spirit and founding legislation of our national parks and would set a terrible precedent for other national parks that are facing similar pressures from local interests. The ranchers aggressive lobbying (which includes numerous signs along our roads urging local residents to choose their for profit interests {cows} over native wildlife {elk}, the construction of expensive fences to protect their stock is an outrage and a warning for how they will manage future disputes.
The public has a right to know how much ranching subsidies cost each year and why, after over fifty years, taxpayers should continue to fund them (as well as proving below-market leases) as they clearly impair the flora and fauna of the park due to numerous factors including erosion, introduction of nonnative species, pollution, and fencing. And ranching not only impairs lands within the park, but water bodies both inside and outside the park's jurisdiction such as Tomales Bay where the RWQCB has identified numerous pollutants related to ranching-including those lining the shore of Tomales Bay and within the park including designated Wilderness areas in Drake's and Umantour Estero.
I also urge the rejection of the option under consideration that would enable ranches to diversify their for-profit activities in order for them to remain viable. This proposal further amplifies the degree to which supporters of continued ranching are willing to trample on long- -established principles eschewing for-profit enterprises in our national parks and should be rejected.
Finally, if an extension of ranching leases is to be extended I urge that a set time frame be established up to but not to exceed twenty years after which time it is mandated that no further ranching in the park will be permitted.
At a time when thousands of our neighbors have been burned out of their homes and funding for their needs is limited, I think it is unconscionable for our local politicians and Congressional representatives to argue for continued funding for a subsidy that has run its course. Taxpayer dollars do not grow on trees, and our National Parks will not thrive on for-profit schemes.
___________________________
# 2888
Name: Arndt, Laura
Correspondence: To whom it may concern,
I support taking any and all actions to support and problem solve issues in order to maintain Dairy and Beef operations in PRNS.
If we can't solve problems in this community of creative minds and resources, then we are in trouble. We must find ways to maintain our ranching operations, to provide food, jobs, and services to the locals and the county. We value our historic heritage and the Park has a duty to uphold their mission.
PRNS is under increased pressure on our resources by a constant increases in tourism. This has a bigger impact on the environment here. There is no need to refer to open space out here as "Wilderness" - There is no wilderness - it's a park. It's open space to be shared and maintained in the best possible way, no other reason. Human activity should also be considered as the impact to the environment and managed.
The Ranches are already micro-managed and doing their part in the agreement they have with the Park. They need to be valued and supported.
___________________________
# 2889
Name: Boyes, Molly
Correspondence:
I feel strongly that cattle and ranching families should NOT be removed completely from the park planning areas.
I have seen the negative effects on native plant communities where cattle have been removed.
Elk do not graze on many of the introduced species that cattle control by grazing. Examples are forage radish, agricultural mustard, and velvet grass.
We cannot return to pre-European times and the land should be managed with grazing to maintain native plant communities.
The old Hall Ranch has been overrun by weeds since the removal of cattle there. Also the area between the main road and Kehoe Beach is all weeds now.
Tomales Pt. has a small fraction of the native plant communities that flourished there with cattle.
I would support the option of allowing ranchers to convert to beef ranching instead of daily farming.
Also improving farming practices should be ongoing.
Cultural burning may be very beneficial to native ecosystems.
___________________________
# 2890
Name: Zlatunich, Eugene C
Correspondence: I would like to make a few comments on the National Park Service's (NPR) General Management Plan Amendment (GMP Amendment) for Point Reyes National Seashore.
In your letter to interested parties, you point out that: "These lands host diverse natural and cultural resources, million of visitors, layers of human history, and ongoing active agricultural." All of your points are very true and, in combination, are the very reason the park has so many satisfied visitors every year.
Although you make the point that the Park lands include "layers of human history and ongoing active agriculture," you are, in certain alternatives, considering the elimination of active dairy and beef cattle ranches which, in essence, terminates the continuance of the "layers of human history." These dairy ranches were established and developed by "diverse" individuals of many cultures (Irish, Italian, Portuguese, etc.) who undertook nothing less than the entrepreneurial spirit of years of hard work in clearing the land and establishing their ranches. These working ranches not only provided economic profits to Marin and the local communities but continue to this day to provide such resources. In addition, these working ranchers not only provide substantial employment for the local communities and economic value to the businesses but also provide the farm workers with essential housing which helps to reduce the housing crisis in the communities surrounding the Park.
I believe it would be unconscionable and irresponsible to terminate and eliminate the dairy and cattle ranches which would, in essences, bring substantial economic suffering to, not only the local communities, but to the farm workers and their families, not to mention the loss of their housing. I believe NPS should provide all ranch families with 20 year leases with a provision that provides that these leases may be extended until a ranch family declines to extend such lease.
The other area of concern is with the Tule Elk situation. After the Tule Elk herd was reestablished in Point Reyes in 1978, nearly half the herd had died between December 2012 and December 2014 from drought and related starvation and thirst. The two free roaming Elk herds (Drakes Beach and the one near Limantour) trample the ranchers fences, feed on drought-limited forage and drink precious water meant for the milk cows. When NPS traps and contain animals and not have them get feed and water, it's unconscionable if not criminal. I believe that the NPS has mismanaged the Tule Elks over these many years and that the NPS may be incapable of providing proper management of the Tule Elks if another natural disaster should occur.
I recommend that the NPS should, at least, eliminate the free ranging Tule El herds from Drakes Beach and the one near Limantour that extends onto the ranch lands in the Estero Road area. This would reduce costs and expenses of the ranches and would also reduce cost and expense of NPS which would certainly please the current Administration.
If NPS continues their stewardship of the Tule Elk herd located on the fenced wilderness reserve on Tomales Point, I would certainly hope NPS would provide such caregiving to ensure the safety and wellbeing of the herd.
I further believe that the personal experience that visitors now enjoy will continue without any additional activities provided by NPS. The visitors now enjoy the inspiration of the natural beauty and character of the area along with the inspiration of the continuance of human history by visual observation of the working ranches.
___________________________
# 2891
Name: Graham , Ruth K
Correspondence: I am writing to express my support for the family ranches that currently operate within the Point Reyes National Seashore. I support the alternative of Continued Ranching and Management of the Drakes Beach Tule Elk Herd, the NPS' Initial Proposal. The family ranches that operate at Point Reyes manage their land well. They are also an important supplier to the Northern California market for natural and organic products. What they do is compatible with the preservation of Point Reyes as a natural area.
I hope you will do the right thing and allow these ranches to continue their leases. Please don't be sucked in by the loud voices of a minority who don't see the value these ranchers provide.
Thank you.
___________________________
# 2892
Name: Gregg, Charles W
Correspondence: I always like to see a plan and it doesn't appear that the newsletter includes a graphic depiction of the alternatives...I would also note that I am not clear on how the responsibilities for implementing this will be shared by NPS and individual ranches...its easy to imagine the costs of "implement(ing) actions to manage the elk from the Limantour-Estero road herd" falling exclusively on the ranches and that is unfair...
Still, as a many time visitor over a long period of time, I would offer my support for the "Reduced Ranching and Management of the Drakes Beach Tule Elk Herd" alternative with NPS doing the work and bearing the costs of establishing the 750 acres of buffers.
___________________________
# 2893
Name: Zlatunich, JoAnn
Correspondence:
I would like to make a few comments on the National Park Service's (NPR) General Management Plan Amendment (GMP Amendment) for Point Reyes National Seashore.
In your letter to interested parties, you point out that: "These lands host diverse natural and cultural re­sources, million of visitors, layers of human history, and ongoing active agricultural." All of your points are true and, in combination, are the very reason the park has so many satisfied visitors every year.
Although you make the point that the Park lands include "layers of human history and ongoing active agriculture," you are, in certain alternatives, considering the elimination of active dairy and beef cattle ranches which, in essence, terminates the continuance of the "layers of human history." These dairy ranches were established and developed by "diverse" individuals of many cultures (Irish, Italian, Portuguese, etc.) who undertook nothing less than the entrepreneurial spirit of years of hard work in clearing the land and establishing their ranches. These working ranches not only provided economic profits to Marin and the local communities but continue to this day to provide such resources. In addition, these working ranchers not only provide substantial employment for the local communities and economic value to the businesses but also provide the farm workers with essential housing which helps to reduce the housing crisis in the communities surrounding the Park.
I believe it would be unconscionable and irresponsible to terminate and eliminate the dairy and cattle ranches which would, in essences, bring substantial economic suffering to, not only the local communities, but to the farm workers and their families, not to mention the loss of their housing. We believe NPS should provide all ranches with 20 year leases with a provision that provides that these leases may be ex­tended until the lessor declines to extend such lease.
The other area of concern is with the Tule Elk situation. After the Tule Elk herd was reestablished in Point Reyes in 1978, nearly half the herd had died between December 2012 and December 2014 from drought and related starvation and thirst. The two free roaming Elk herds (Drakes Beach and the one near Liman- tour) trample the ranchers fences, feed on drought-limited forage and drink precious water meant for the milk cows. When NPS traps and contain animals and not have them get feed and water is unconscionable if not criminal. I believe that the NPS has mismanaged the Tule Elks over these many years and that the NPS may be incapable of providing proper management of the Tule Elks if another natural disaster should occur.
I recommend that the NPS should, at least, eliminate the free ranging Tule Elk herds from Drakes Beach and the one near Limantour that extends onto the ranch lands in the Estero Road area. This would reduce costs and expenses of the ranches and would also reduce cost and expense of NPS which would certainly please the current Administration.
If NPS continues their stewardship of the Tule Elk herd located on the fenced wilderness reserve on Tomales Point, we would certainly hope NPS would provide such caregiving to ensure the safety and well being of the herd.
I further believe that the personal experience that visitors now enjoy will continue without any additional activities provided NPS. The visitors now enjoy the inspiration of the natural beauty and character of the area along with the inspiration of the continuance of human history by visually observation of the working ranches.
___________________________
# 2894
Name: Zentall, Lena
Correspondence: November 22, 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.
Im a long-time Bay Area resident, Point Reyes land owner, and an enthusiastic visitor and supporter of Point Reyes National Seashore as well as a volunteer with PRNSA, the Point Reyes NPS, and the Environmental Action Committee of Marin (EAC). I spend time in the Seashore several times a month. Much as I would like to see the Seashore as an unfettered area for Tule Elk to roam, Point Reyes has been shaped by a culture of ranching and aquaculture for hundreds of years commercially, and for thousands of years in the land management practices of the Coast Miwok. To a great extent, the park is here because ranching persisted in West Marin and preserved these open spaces from residential development. I would like to see ranching continue to persist and thrive in an environmentally responsible way. Overall, I support the parks initial plan recommendation which does a good job of balancing ranching, environmental, and recreational interests. I strongly support EACs comments and questions below, and I respectfully submit these additional comments and questions.
Succession planning
Point Reyes is a small community with deep family roots and strong community values centered around appreciation for this unique place. To sustain a long-term thriving dairy and cattle ranching tradition in Point Reyes, the park should consider alternatives in addition to family-based leases. When a family decides to stop ranching or when a familys ranch is not meeting environmental standards, the ranch should be leased to someone skilled and eager to ranch in Point Reyes in an environmentally responsible way. As a local example, when the Point Reyes bookstore owners decided to get out of the book business they searched for a worthy successor who shared their values and would keep their vision going.
Lease terms based on stewardship
Why 20 year leases for all ranches? I support more favorable terms (e.g., even longer leases, subsidized capital improvements) for ranches that meet high standards of environmental stewardship. Conversely, ranches that do not meet the standards should face consequences culminating in the cancelation of their lease. Who sets the standards? How are they refreshed? How are they monitored? Would it make sense for the park to partner with another organization(s) to set the standards and monitor for compliance? For example, University of California Agriculture and Natural Resources division?
Diversification
Point Reyes has been a working landscape of dairy ranching for 150 years. Throughout this time, Point Reyes has prided itself on its high-quality dairy products. What is the purpose of diversification? Who is asking for it? What crops and/or livestock would be allowed? Who decides whats allowed? How will it fit into the Point Reyes eco-system? Will it need to be protected? For example, if chicken farming is an option, would the park need to create a coyote management plan? What unintended consequences might new crops, livestock, or other uses introduce in the park? Is non-agricultural use part of the diversification? I dont oppose diversification, but I would like to see the parks plan and rationale for diversification.
Partnerships with ranchers and researchers
NPS should partner with ranchers to do education/interpretation on ranch life and practices for park visitors, schools, etc.
How do we make Point Reyes ranching a model for 21st century agricultural practices in a national park? Could opportunities be cultivated for ranches to participate in research on environmentally sustainable ranching practices with research institutions? Testing new technologies such as methane conversion, innovative fencing, water conservation, erosion control, etc.? Could the costs of the new technologies be paid for with research grants?
Interpretation of ranch life past and present
Restore at least one historic ranch house to educate visitors about the history of ranching in Point Reyes and life at the height of Point Reyes dairy ranching (1857-1956). The house could be used for tours and events. It would be ideal to have present day ranch life interpretation at a working ranch but that may not be practical. In that case, contrasts between now and then could be included in the historic house. The time to act is now before the remaining historic ranch houses rot into oblivion.
Coast Miwok and significant archaeological sites
Id like to see the park do more education about the traditions, practices, and historic sites of the Coast Miwok.
Trail enhancements
I would like to see more loop trails in the park and more trails in the agricultural area similar to the Bullpoint Trail which traverses grazing area.
I strongly endorse the following EAC 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 Seashores 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.
___________________________
# 2895
Name: Lewis, Stephen C
Correspondence: To whom it may concern:
We understand that the National Park Service is in the planning process for a General
Management Plan Amendment (GMP Amendment) for Point Reyes National Seashore
("PRNS"). The GMP Amendment is intended to guide how the more than 27,000 acres currently
leased for ranching at PRNS will be managed once the current five-year leases, recently adopted
as an interim measure, expire in 2022. The Nicasio Land Owners Association (NLOA) and the
Nicasio Land Preserve (NLP) welcome this opportunity to comment on the GMP Amendment
process.
Summary of the NLOA/NLP Position
The NLOA and NLP have analyzed the six alternative approaches set forth in the Park
Service publication summarizing the GMP Amendment process. We support the Park Service's
Alternative 5, which retains the existing 27,000 acres of ranches on the Point Reyes peninsula,
while managing the tule elk in a manner consistent with the existing ranching. We acknowledge
that issues related to balancing the interests of ranchers and tule elk, and whether the PRNS lands
should be allowed to return to the native condition they were in before the 1800's, are complex
and controversial, and they stir strong emotions and opinions.
For the reasons detailed below, the NLOA and NLP believe that a decision to severely
restrict PRNS ranching ultimately would negatively and significantly impact agriculture in West
Marin, including Nicasio. The PRNS ranches are an integral part of a Marin/Sonoma agricultural community that is nationally renowned for quality, sustainability, and product innovation.
Reducing PRNS ranching will threaten the viability of other farms and ranches, as well as those
marketing, distribution and supply enterprises that provide critical support to existing farming
and ranching activities. Furthermore, PRNS was created with the direct support of the ranching
families that occupied the land, based in part on their understanding that they would be permitted
to continue their ranching activities consistent with their stewardship obligations. The NLOA
and NLP respect that contribution and support an approach that will preserve both that
partnership and at least one of the tule elk herds that presently grazes on the peninsula.
The NLOA/NLP Analysis and Position
The NLOA and NLP support continued cattle and dairy ranching, along with existing
small-scale farming, on the Point Reyes peninsula, consistent with both reasonable
environmental regulation and management of the tule elk herds in a manner that does not
interfere with responsible and economically viable ranching operations. As explained in more
detail below, we believe the success and sustainability of agriculture-based enterprises in Nicasio
and elsewhere in Marin are dependent in significant part on the success of beef and dairy cattle
ranching at PRNS. Such ranching has been ongoing in the PRNS area since the mid-1800's, and
it is a key part of Marin's agricultural history and economy. However, we are not advocating for
the expansion of existing farming/ranching activities (to permit, e.g., large vineyards, feedlots,
etc.) at PRNS.
At the present time, the PRNS ranches contribute significantly to the overall strength,
vibrancy, and economic success of Marin agriculture. If the Park Service were to decide to phase
out ranching within PRNS boundaries, or to only grant a few of the existing families five-year
leases (which would not permit any long-term planning on the ranchers' part), we believe that in
time the overall scale of ranching and agriculture in West Marin and Sonoma Counties would
diminish. This is because the benefits and economies derived from the existing scale of
Marin/Sonoma ranching and agriculture (e.g., marketing, distribution, diversity and quality of
products, food processing, excellent national reputation, etc.) would likely be materially reduced
were the 27,000 acres of PRNS ranch lands withdrawn from agricultural use. This diminution
would not be seen overnight, but within the next several years we would expect ranching and
agriculture operations, and the infrastructure that currently supports them, to recede.
Nicasio is not isolated from existing development pressures in eastern Marin County. To
the extent the overall scale of agriculture decreases in Marin/Sonoma, existing agricultural
enterprises in Nicasio and adjoining West Marin communities are likely to also become
economically challenged, in turn leading to increasing pressure to develop property presently
devoted to agriculture. In short, supporting existing agricultural uses of PRNS land, in an environmentally sensitive manner that also makes economic sense for ranchers, is in the best
interests not only of PRNS but also of Nicasio, Marin County, and many other constituencies.
Another very important factor in our consideration of the GMP Amendment process is
the historic role played in the formation of PRNS by the ranching families that occupied (and
continue to occupy) agricultural lands in what is now PRNS. PRNS could not have been created
without the cooperation of the ranchers, whose historic operations helped preserve the rural,
unspoiled character of this unique peninsula. Obviously other groups advocated for the formation
of PRNS (dedicated activists, environmentalists, astute politicians, and agricultural visionaries)
and helped prevent Point Reyes from becoming another Malibu. That said, we believe that the
present-day manager, the Park Service, has a moral obligation to the ranchers and to ranching to
ensure that agriculture continues as an integral component of PRNS and that ranches should be
included in the Park's future in perpetuity.
Even today, it is the cattle grazing on the Peninsula that has kept the coyote brush in
check and the vistas open, and reduced fire hazard. Ending ranching in PRNS - returning it to its
so-called "natural state" — would in a matter of a few years lead to fields, previously devoted to
cattle grazing, becoming overgrown. Over time, this process will reduce and ultimately eliminate
the dramatic open feeling that currently helps make PRNS such a memorable area.
We understand and agree that preserving tule elk at PRNS is an important
concern. Although we believe that ensuring the future of beef and dairy ranches and attendant
small-scale farming at PRNS is a key priority, responsible and humane management of the tule
elk herds by the Park Service would permit elk to graze while economically viable ranching
continues.
The NLOA/NLP Recommendation
After considering the various alternatives, including the proliferation of tule elk and their
effect on Point Reyes ranching, the NLOA and NLP recommend as follows:
1. On balance, we favor Alternative 5 (Continued Ranching and Removal of the
Drakes Beach Tule Elk Herd) taking effect in 2022. This would allow the existing ranch
families to continue beef cattle and dairy ranching operations on about 27,000 acres under
agricultural leases/permits with 20-year terms. The Drakes Beach tule elk herd would be
humanely removed using methods developed as part of the GMP Amendment planning process,
but the Limantour-Estero Road herd would remain where it is and be managed to mitigate any
negative effect they might have on ranching activities.
2. However, if the Park Service demonstrates during the upcoming five-year interim
lease period that it can effectively manage the existing tule elk herds (much more effectively
than it has done so to date), then we would be willing to support Alternative 4 (Continued
Ranching and Management of the Drakes Beach Tule Elk Herd (NPS Initial Proposal)). Under
Alternative 4, existing ranch families would be permitted to continue beef cattle and dairy
ranching (and presumably existing small-scale sustainable farming) on about 27,000 acres
currently under agricultural leases/permits with 20-year terms, but the Drakes Beach and
Limantour-Estero Road tule elk herds would be humanely managed so as to not negatively affect
the environment or the economics of successful cattle ranching in the planning area to which the
GMP Amendment applies.
Thank you for favorably considering our comments on this matter.
___________________________
# 2896
Name: Lucchesi, Gino and Kathy
Correspondence: Superintendent MacLeod,
There needs to be an additional alternative in this process.
The range of alternatives favors the elk over ranching. Three alternatives call to end or reduce ranching and five alternatives suggest elk remain on the ranches. Not one alternative removes the elk from the ranching areas and not one alternative make cultural resources conservation and historic ranching a priority.
When Point Reyes National Seashore was signed into legislation in 1962 the intent was to preserve this working landscape.
If elk were to remain on the ranches the elk would destroy this working landscape. They will multiple and therefore consume more grass each year and soon there will be no room left for cattle thus eliminating the ranches.
We ask for an additional alternative to include:
• Continued dairy and beef ranching with 20 year renewable leases
• Elk permanently moved back into the wilderness and managed there
• Improved signage educating public about the working landscape
• Implement best land management practices
For those who would like to see continued ranching at Point Reyes National Seashore, we thank you for giving this alternative consideration.
___________________________
# 2897
Name: Luebbermann, Mimi
Correspondence: I am writing to urge the Park to support the ranchers in the historic pastoral zone
with 20 year leases to ensure their continued stewardship of the land. I do so for
a number of reasons, the first being that the families of these ranches gave up
their private ownership with the agreement they would be able to continue
ranching. We owe it to them to not back out of this agreement. I also feel that
they are the best caretakers of land they and their families have known for over
100 years.
Equally important is the agricultural landscape those ranches protect. As a
farmer for a mere 22 years, I know that ranches and ranchers in full view of the
public serve another function, that of educators to a public that may even think
milk in cartons comes from machines in the back of the supermarket In a time
when children only see cows as cartoon figures on screens, and when obesity
because of poor diets is increasing at a monumental rate, ag education is more
and more critical nationally. These farms, most of which are certified organic,
are the picture perfect opportunity for an education campaign, across the nation,
to talk about the importance of healthy, fresh food. Here on my farm, we have
almost 50 field trips from local Bay Area schools. For many children, it is the first
time they have ever seen a real cow, goat, or sheep, and they learn about the
contribution these animals make to our diets.
I think that the Park has an opportunity to promote heathy agriculture to a
public becoming more and more ignorant of farming, its complexity, and
farmers' careful attention to the health of their land, besides its feeding our
nation. I would love to see a living history museum of agriculture with a
curriculum that included ranch visits and ranch stays. Besides generating
additional income for the ranchers and the Park, such an education program
could become a model for the nation.
I am in wholehearted support of the Pt. Reyes ranches, think the tule elk should
be culled and removed from the pastoral zone, and urge the 20 year leases to aid
in maintaining an economically viable ranching community.
___________________________
# 2898
Name: McIntosh, Beverly
Correspondence: Thank for this opportunity to comment on the Point Reyes National Seashore General Plan
Amendment.
The following comments are in support of Alternative 5, Continued Ranching and
Removal of the Drake's Beach Tule Elk Herd.
The adoption of the presentation on page 8 of The General (Management Plan Overview",
titled "Ranching Background" includes the November 29, 2012 Memorandum of
Understanding of the Secretary of Interior that directed the NPS pursue the issuance of
Lease/permits for up to 20 years.
The implementation of this directive resolves the issue of allowing continuing ranching
with leases long enough to enable our valuable agriculturalists to continue to make their
contributions to a continuation of these terribly important issues of resource conservation,
biodiversity and history.
In support of the removal of the Drake's Beach Elk Herd, their numbers when combined
with the estimated totals for both herds, 110 for the DBEH and 130 for the Limantour-
Estero Herd, come very close to the 1999 Interim Management Plan limit of 250 to 350
Elk. The expansion of the LEEH into neighboring ranch land was not anticipated by the
Seashore at that stage of planning. New totals for both herds are due very soon.
The removal of the DBEH would simply relocate those elk to larger, more suitable
habitat at one or more of the existing 25 reserves.
In conclusion, the introduction to Laura Alice Watt's excellent book, "The Paradox of
Preservation" includes a quote from Aldo Leopold, " conservation means harmony
between men and the land"
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# 2899
Name: Moran, Brigitte
Correspondence: Thank you for this opportunity to provide comment 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 Agricultural Institute of Marin (AIM) is in its 34th year as a leader in the San Francisco Bay Area Food System. We manage seven farmer's markets around the bay, including the long running Marin Civic Center Market in San Rafael on Thursdays and Sundays. Our organizational goals are:
• To support Regional Sustainable Producers by Providing them with Direct Access to Consumers; and
• To Educate the Public about the Nutritional and Economic Benefits of Buying Locally Grown Food Directly from Farmers.
Because of the connection of our goals with the farming and ranching on PRNS/GGNRA and contributions it makes to the Marin and Regional community, AIM expresses its fullest support for the continuation of these local farm family operations on the National Park service. Our vision of the regional community and food system does not see the border around PRNS/GGNRA as a boundary, demarking different land use and ownership. We see it as a connection with a national agency partner, in this case the National Park Service, making it possible to achieve a strong local community and food system that serves as an example for others to replicate around the country and beyond.
We are proud to host many of the PRNS/GGNRA farmers and ranchers as participating vendors at our farmer's markets. Their local farm products represent everything AIM is striving for - quality local food made available through strong personal farmer and customer relationships.
At this step of the GMP Amendment process, we ask that our specific goals be used as criteria for alternative analysis.The National Park Service's (NPS) goals and objectives in this process to facilitate the viability of PRNS/GGNRA producers through 20-year leases and to enhance the visitor's experience are in direct alignment with our goals.
Developing and analyzing alternatives to achieve these will position NPS as a leader and partner in the complex provisioning of multiple benefits through working ranches and farms.
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# 2900
Name: McClure, Michelle
Correspondence: November 22, 2017
Superintendent Cynthia MacLeod
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes Station, California 94956
Dear Superintendent:
We appreciate the opportunity to comment on the Point Reyes National Seashore General Management Plan Amendment process, and the subsequent National Environmental Policy Act review.
As the 5th generation in our family to be involved in dairying in the National Seashore, we are grateful to be part of this longstanding history and take great pride in continuing to ensure that ranching and dairying contribute to the agricultural heritage of Marin County. We are very proud of our family's efforts to promote the environmental and scenic quality of the working landscapes of the Seashore.
We have seen our family's dairy make significant improvements over the years, out of care for the animals, the environment, and our consumers.
When we were little kids, we can all remember going with our dad to check on the cows in the back pasture at night, and then check on the cows that were getting ready to calve (have babies). Back then, everything was done outside - we didn’t have barns to protect the animals from the rain, or to protect the ground and waterways from runoff. This really concerned my dad, and he and my grandpa made the decision to build two barns; one Maternity Barn for the expecting cows, and another set of barns for the Milk Cows. These were huge projects (both in terms of financial and time investment), but my family saw them as necessary to protect the environment, and our animals.
change we made was converting our entire herd to Organic. The decision was made in part as a response to consumer preferences, but also was a logical transition in continuing to improve the sustainability of the dairy as part of the landscape of the National Park. A major component of organic dairying is grazing and access to pasture, and this is really our only advantage over the dairy farms in the Valley (with sometimes well over one thousand cow herds). We are very thankful the Park, the Community, and our Consumers appreciate the 'Happy Cow’ lifestyle our animals are provided, and we hope to continue this tradition.
We are all in our twenties, and would all like the opportunity to continue our family’s legacy of ranching in the Park. We are so thankful that we had the privilege to grow up on the dairy. The lessons learned - hard work, environmental stewardship, compassion for animals, business and financial management, the importance of family and neighborly support –shaped us into the people we are today. We hope we can give these opportunities to the next generation as well.
Thank you again for the opportunity to provide our thoughts and comments.
Sincerely,
Jeannette, Michelle, and Alyssa McClure
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# 2901
Name: Watts, Jamison
Correspondence: November 14, 2017
Point Reyes GMP Amendment
Superintendent
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes Station, CA 94956
RE: First Phase Comments on the Point Reyes National Seashore General Management Plan Amendment
Superintendent MacLeod:
Marin Agricultural Land Trust (MALT) was founded in 1980 to protect Marin's agricultural land for agricultural use. Over the past 37 years, MALT has invested over $70 million to permanently preserve the agricultural utility and natural resources on 81 Marin farms and ranches totaling 49,700 acres. We also work regionally with agricultural landowners and public and private partners to support and enhance agriculture viability and sustainability. One-third of Marin County is in productive agricultural use, including the approximately 28,000 acres in PRNS and GGNRA. These family farms and ranches and the agricultural landscape they occupy are fundamental parts of the extraordinary and unique history, culture, environment, economy and character for which West Marin, Marin County and PRNS are known regionally and nationally.
Because the continuation of sustainable agriculture in PRNS and GGNRA’s north district directly affects our mission, MALT unequivocally supports the continuation of sustainable farming and ranching in these areas. Together, they represent nearly a fifth of Marin’s agricultural acreage and production. If these agricultural operations disappear, we face losing the critical mass necessary to sustain suppliers, processors and other services crucial to the future of agriculture countywide. These ranches also represent a significant portion of the county’s managed coastal grasslands, which through cattle grazing provide habitat for endangered species, sequester carbon, store water, support pollinators, reduce wildfire danger and control invasive plants.
We believe the conceptual alternatives required by the settlement agreement, including No Ranching and Limited Management of Tule Elk, No Dairy Ranching and Management of Drakes Beach Tule Elk Herd, and Reduced Ranching and Management of the Drakes Beach Tule Herd, as well as the No Action alternative would result in major adverse impacts to the region’s socioeconomic and cultural resources. We ask that, beyond the minimum required by the GMP Amendment Settlement, alternative analyses make consideration of the following:
Protecting and managing the diverse and important natural and cultural resources in the planning area
• The affected farm families have upheld for nearly 40 years (1978 Public Law 95-625) their promises to manage natural and cultural resources in a manner consistent with agricultural lease/special use permits issued and audited by NPS. They have met detailed and specific range management program activities, terms and conditions. This includes compliance with San Francisco Regional Water Quality Control Board’s water quality regulations for grazing livestock and dairy operation.
• Marin County completed its Climate Action Plan Update in 2015, and the agricultural community has demonstrated that it can be an important part of the solution to climate change through carbon farming and carbon offsets. NPS should work directly and proactively with the Marin Resource Conservation District (MRCD) and Natural Resources Conservation Service (NRCS) to develop and implement carbon farm and/or conservation plans as appropriate.
• MALT works to secure the future of farming and ranching in Marin County through the conservation easements we purchase to protect the land from nonagricultural development. Once the easement is acquired, we take on the deep and permanent responsibility of supporting the landowner as they steward the land and its soil, water, plants and wildlife. Stewardship is a set of practices that maintain or improve the agricultural and natural values of the land. Some of the ways MALT supports stewardship include providing technical and financial assistance for restoration and rangeland improvement projects, offering information and resources on rangeland management, invasive weed control, and watershed health, and working with MRCD and NRCS to develop and implement carbon farm plans. In like kind, the NPS should play a more active role in supporting the management outcomes they wish to see in the planning area.
Specific strategies for managing agricultural leases and permits
• Assurance of tenancy through 20-year leases is critical to the ranchers’ ability to secure financing, make necessary improvements, and implement beneficial stewardship practices. The MRCD and NRCS require 10-20 year maintenance and monitoring agreements to qualify for their programs. A 20-year rolling lease in 5, 10, or 20-year increments would enable lessees to qualify for these programs on a consistent basis and better qualify them for bank loans.
• The absence of clear guidance for agricultural operations negatively affects the decision-making ability of the rancher and NPS field-level staff. The needs to reroof barns, manage invasive plants, and repair fences are a few examples of operational decisions that often are delayed. These delays have had financial and ecological impacts. Alternatives in the GMP Amendment will be stronger and have increased success in realizing the mutual benefits of working farms and ranches if they include guidelines to facilitate ranchers and NPS making real-time operational decisions.
• Succession is essential to ongoing land management and stewardship in the planning area. Marin has benefited greatly from the successful transition through as many as five family generations. Additionally, hand-offs of agricultural property and operations to non-family members have gone successfully with agricultural production and environmental stewardship persisting. Successful succession from current to future agriculturalists is critical to the continuation of Marin’s valued working landscapes. Therefore, any alternatives should have a plan for succession to new members of existing farm families and alternative agricultural candidates if that option is not presented.
• Diversification is a proven tool for the economic viability of both individual ranches and the broader community and it is a recognized and supported tenet in the Marin Countywide Plan. Diversification has enabled Marin’s small and medium sized farms to be economically viable, build additional resiliency, and to avert the risks of business failure. This is especially important because these ranches do not benefit from economies of scale that larger operations enjoy. In effect, diversification has strengthened Marin’s local family farms, local economy, and local food system. For these reasons, diversification on the PRNS and GGNRA ranches and dairies should be fully considered in any analyzed alternative so that it can be facilitated going forward. This includes farm processing, farm stays, farm tours, selected crop production, forage production, and farm sales.
Specific strategies for management of Tule elk
• As evidenced by the ongoing experiences of PRNS ranches, grazing livestock and free-range elk are not compatible. Because the main herd has 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 (Johne’s).
Wilderness designated lands and Pastoral/Ranch leased lands should be given equal protection corresponding to their intended use and purpose. Intended for nature preservation, Wilderness Areas are managed by resource specialists. Conversely, Pastoral Areas are intended to be managed for agricultural use by the "rancher". There should be little allowance for commingling resource use and management styles between them. When livestock are found in Wilderness, they are removed. Likewise, when Elk are found in Pastoral Zones, management methods should be used to control their population and remove their impacts.
As our society works to produce food for a growing world population in a sustainable manner, Point Reyes National Seashore should be viewed as an example - a place where all the ranchers work closely with the National Park Service to cooperatively manage the land in an economically viable and environmentally sustainable way. Furthermore, any alternative that might lead to a reduction in overall food production in the planning area should consider the social, environmental and economic costs of replacing that production elsewhere in the Sonoma-Marin region.
Thank you for the opportunity to comment on this phase of the GMP Amendment.
Sincerely,
Jamison Watts
Executive Director, Marin Agricultural Land Trust
Ralph Grossi
Chairman of the Board, Marin Agricultural Land Trust
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# 2902
Name: Salzman/Peterson, Barbara/Phil
Correspondence: Thank you for the opportunity to comment on the range of conceptual management alternatives for the Point Reyes national Seashore. We offer several overall comments and recommendations as well as comments and quastions related to specific alternatives identified in the public notice and at the meetings.
We strongly recommend that the plan address the following:
Natural Resource Protection - While natural resources are mentioned in a few of the alternatives, none of the alternatives mention what resources will be included. Understandably, the alternatives focus on Tule elk and ranching, but there is no indication that the many native and migratory bird species that depend on the Pt. Reyes Peninsula would be given adequate consideration nor is it clear how native plants would be addressed.
The Range Management Program description states that the range program works with ranchers to implement BMPs to protect sensitive resources including water quality, and rare and endangered species. While this is required, the many other nesting and migratory birds also need to be protected. Habitat needs of native and migratory species should be identified along with areas of the park that are especially important for wildlife.
Natural Resource Alternative - Provide an alternative that maximizes benefits to natural resources of the Seashore. One feature that is lacking in the current conditions and alternatives is one whi:h would allow the elk and other wildlife to move between the peninsula and the wilderness area. Connection corridors between habitats is a recognized essential component of habitat systems for many species. We strongly recommend that an alternative be developed that ensures the elk and other wildlife have a corridor through which to move between larger habitat areas of the seashore. This alternative should also focus on restoration and enhancement of Seashore habitats.
Impacts of Alternatives - Some components of the various alternatives could have unintended consequences. With the heavy focus on visitor uses and identifying additional visitor experience, significantly increased use could be anticipated. It is essential that impacts on wildlife and habitats resulting from anticipated increase in use, be identified and analyzed. Impacts on traffic could also occur. Habitat needs for native and migratory species and the areas of the park that are especially important for wildlife, should be identified.
Our comments on specific alternatives and issues they should cover, are below. Some of our comments and questions apply to multiple alternative as they have the same components.
No Ranching and Limited Management of Tule Elk
How large are the two ranches with life estates?
Bullet two states that many of the areas would be converted to visitor serving recreation. This is not in keeping with the natural resource focus of the Seashore. We recommend that most of the lands that are vacated, be restored to wildlife habitat. One of the primary reasons visitors come to this Seashore is to view wildlife.
What would eliminating acres of dairy and beef ranching mean to the viability of dairy ranching in Marin, if anything? It is often heard that with each dairy ranch that goes out of business, the viability of ranching as a whole is threatened. Is this still the case with the focus on organic dairy, and the already occurring change of many ranches to beef operations?
No Dairy Ranching and Management of Drake HerdWith no population management of the elk, what is the risk that they eventually go out of the park?
What is the relevance and importance of that and how would it be construed? Describe how the grassland habitats change or differ with dairy and beef cattle ranching? Describe how the elk would be managed. What are the methods that would be considered? The Seashore resources that would be preserved, must be clearly defined.
The buffers that would be established to protect sensitive resources should be described, i.e. width, characteristics and sensitive resources they are designed to protect. With all of the increased visitor use, how would the buffer restrictions be enforced?
One of the "broad management strategies to protect park resources" should be habitat enhancement and expansion.
Reduced Ranching and Management of the Drake's Beach Herd
Discuss why elk may be moving: for water, forage, other, or all?
How would the decision be made as to what ranches would be closed? What criteria would be used and who would be making the decision?
Describe the approaches for streamlining, and the best management practices that would be streamlined. How would the BMP's be enforced?
Continued Ranching and Management of the Drakes Beach Herd {NPS Initial Proposal)
In considering opportunities for diversification, the impacts of the new agricultural practices/crops must also be identified and evaluated? Growing crops or grazing other animals might have adverse effects on soil, water quality, vegetation, and other habitat components.
How would the "level compatible with authorized ranching operations" be determined? Ranchers are complaining about impacts of the elk. How many ranchers are affected and where are they located?
Continued Ranching and Removal of Drakes Beach Elk Herd
What methods would be used to remove the elk? What is the risk to the elk?What actions would be used to manage the elk from the Limintour-Estero Road herd?
Continue Current Management
The Residual Dry Matter is currently monitored by the Range Management Program to assess the amount of plant life left after the grazing season. How is this used to control the number of cattle allowed per acre? How does the range management program value the presence of non-native plants in assessing the plant material left at the end of the grassing season? For example, is non-native thistle which thrive in overgrazed soil, considered as a benefit even though they are invasives? Are the numbers of grazing animals reduced or allowed to be maintained or expanded if populations of thistle and other problematic non-natives are found? How are invasive plants considered when evaluating
RDM?
What methods are used to control or prevent the expansion of invasive plants? Are these measures required? If so how is that requirement enforced?
Thank you for considering our comments.
 
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# 2903
Name: Lafranchi, Bruce E
Correspondence: Point Reyes GMP Amendment Superintendent
Point Reyes National Seashore 1 Bear Valley Road
Point Reyes Station, CA 94956
Dear Sir,
I believe dairying and ranching in PNRS should be retained as originally intended in the creation of the Park. Further, the tule elk should be managed to preserve and enhance these agricultural uses. The following six points are germane.
1) Human activity has been part of Pt Reyes environment for thousands of years. For example, Miwok Indians have lived on Pt. Reyes for over 3000 years.
2) Protecting continued dairying and ranching was integral to parks' establishment. The idea was to protect the area from urbanization not eliminate its agricultural use nor turn it into a wilderness
3) Dairies and cattle ranching educate the urban bay area population about family farming in a unique way.
4) Loss of dairy and cattle ranching will harm the environment, eventually turning open fields into impassible coyote brush and poison oak.
5) Loss of Dairying will adversely impact dairy industry in Marin and Sonoma county leading to hire prices and less supply of organic milk and meat products,
6) The tule elk population in California is double the population agreed by California and the Federal government. The tule elk in PRNS are expendable.
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# 2904
Name: Schlesinger, Susie
Correspondence: Thank you for the opportunity to comment on the (general Management Plan Amendment I would like to see a few additions to the proposal.
The first would he a humane management of the elk herd, which has exceeded its carrying capacity by culling and testing those that are carriers of Johne's disease. The elk should be contained and the herd not located within the ranching operations.
The ranchers should not he tasked with all of the damages done to their rangelands and feed costs that these herds incur. The MTS should take into consideration the destruction and the costly economic factor that the elk incur to these vulnerable ranching operations. Secondly ranching has been part of this landscape since the 1800's and is a significant cultural and historic part of the park. The MTS and the ranchers need a set of guidelines and standards that could streamline and implement current Best Management Practices ie Carbon sequestering, diversification and sustainable farming practices such that PRNS could he a working model for visitors of what and can be done to protect the environment and its resources. These ranches represent one fifth of Marin County's agricultural and production and represent a significant portion of the county's managed coastal grasslands. Presently I am told that the ranchers are NOT allowed to put these practices in use. As we are facing climate change these guidelines and reasonable standards worked out between the Park and the ranchers could he implemented to keep the ranching operations more viable and the natural resources protected
There is also an educational and cultural factor that has been overlooked, as urban people no longer have a connection to how and where their food is produced at the turn of the century 97% of the population lived rurally whereas today only 3% live rurally. As the population increases the know (edge of these 4th and 5th generational farms will disappear and the only knowledge will be the factory farm' model farm tours are ways to connect your food and the environment in which it was raised The emphasis of frown in Marin" will further the concept of eating locally produced food My own experience of people meeting my livestock has shown me how magical and time less that can be.
The ranchers need the Conger Ceases as it takes time to meet the standards and guidelines to transition to better practices. The economics needed to do these crucial things require a long view to plan and implement. Ranching is an intensive practice and each season brings with it it's own challenges.
Pt Reyes National Seashore is an unique treasure of the National Parks. To not acknowledge the historic precedent of the ranching families who have made the landscape what it is today is to rewrite California coastal history. Thank you.
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# 2905
Name: Schnapf, Esq. , David
Correspondence: These comments are submitted in response to the notice you published soliciting input on "a conceptual range of management alternatives" that you will examine in conjunction with the General Management Plan Amendment ("GMP Amendment") for the Point Reyes National Seashore and north district of Golden Gate National Recreation Area (collectively "PRNS"). I note that, contrary to legal requirements, the GMP for PRNS has not been updated since 1980, and that the present review is being undertaken only because of a lawsuit over this legal failure.
My wife and I have lived in the Bay Area since 1980, and in Marin County since 1992. I am an avid outdoor enthusiast, and am a frequent visitor to PRNS. PRNS is a unique place providing a wealth of nature experiences that are not available elsewhere. Highlights of my visits always include viewing the wonderful array of wildlife that can be seen in and around the park - elk, whales, elephant seals, harbor seals, sea lions, all sorts of birds, and even, on one occasion, a badger, to name just a few. The tule elk herds are a particularly rare and majestic sight.
Since my first visit to PRNS in 1980,1 have been appalled to see the extensive and destructive intrusion of ranching in the park, and the extensive ranch fencing that keeps much if not most of the public park off limits to visitors. This is wholly contradictory to the core purpose of any National Park which are set aside as nature and wildlife preserves.
In my opinion, there is no valid justification to maintain any ranching in PRNS. Yet, over the years, the NPS has shown a clear bias in favor of continued ranching. This bias is quite evident at the very outset of the process for the GMP Amendment - five of the six alternatives that the NPS proposes to examine would allow continued ranching. None of the continued ranching alternatives suggests any public interest or benefit in allowing continued ranching.
None of the continued ranching alternatives makes any mention of public access to ranch lands or to the ranches themselves. Moreover, no justification is provided for evaluating continued ranching alternatives other than those required by the settlement agreement (the "new alternatives"). These new alternatives reflect continued bias in favor of ranching.
Accordingly, I believe that the range of alternatives that would allow ranching should be restricted to only those required by the Settlement Agreement. There is enough flexibility in the settlement agreement that additional ranching alternatives are not required and will only make the review process more difficult, expensive and time consuming. Moreover, any and all alternatives allowing ranching should be based on the requirement that ranch leases be set at full market rates. There is no justification for subsidizing private businesses in a national park.
Further, any and all alternatives allowing ranching should require the ranches to maintain roads and other park facilities in and around their land. Presently, the road to the lighthouse is in constant need of repair due to the heavy truck and commercial traffic generated by the ranches.
There is no reason the public should pick up the tab for road maintenance for damage caused by ranching. In addition, all of the ranching alternatives should require full public access to ranch lands, and require all ranchers to establish demonstration projects for visitors.
PRNS is one of the most popular park destinations in the Bay Area, attracting visitors from around the world. These visitors do not come to PRNS to see cows, they come to see nature. I believe that the process for the GMP Amendment should examine additional alternatives that would enhance visitor accessibility and highlight the unique experiences that PRNS has to offer. For example, the establishment of additional campgrounds, hostels and the like would enable more visitors to enjoy the park. Perhaps some of the old farmhouses can be converted to inns or B&Bs. Businesses related to, for example, kayaking, fishing, boating, cycling, would be encouraged under this alternative. Thus, I ask that the GMP Amendment process include consideration of at least one alternative that promotes more intensive recreational and overnight access to PRNS.
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# 2906
Name: Scolari , Nancy
Correspondence: Thank you for the opportunity to provide comments on the National Park Service General Management Plan Amendment planning process. The Marin Resource Conservation District (Marin RCD) is supportive of agricultural activities and conservation actions that take place within the Point Reyes National Seashore and the north district of the Golden Gate National Recreation Area (NPS) and is pleased to provide suggestions for your consideration in the development of alternatives.
The Marin RCD was created in 1959, following a vote of the district, with a specific mission in mind: "to conserve and enhance our natural resources. It is our belief that the health of the county's natural landscape is dependent upon a robust agricultural economy and the active preservation of our agricultural heritage. In addition, it is our firm conviction that the agricultural productivity of the county is dependent upon the diligent application of practices which conserve and enhance our natural resources."
Over the last 50 years, we have supported NPS and the ranches in fostering a conservation-based land stewardship ethic. The Marin RCD has partnered with NPS and our sister agency, the USDA Natural Resources Conservation Service (NRCS), in supporting this ethic. NRCS is authorized to distribute USDA Farm Bill funding within our district based on these formal partnerships and collectively we have successfully partnered with many agencies and organizations over the years to match these funds by turning our local plans into meaningful conservation actions. It is our responsibility to establish a solid set of community values that will direct our future endeavors. It is for these reasons the Marin RCD believes the General Management Plan Amendment to be critical in developing a sustainable future for agriculture.
The Marin RCD is responding to three specific questions suggested in the NPS letter to Interested Parties: "How can Point Reyes protect and manage the diverse and important natural and cultural resources in the planning area", "Are there opportunities that could enhance future stewardship in the planning area", and "What types of specific strategies can/should be considered for managing agricultural leases/permits" The Marin RCD recommends NPS protect the important natural and cultural resources within the pastoral zone by incentivizing and streamlining the delivery of stewardship projects and by establishing a programmatic structure that supports environmental stewardship. We offer the following suggestions:
1. Hire technical support staff for the ranching community. NPS currently employs 1 full time permanent (career seasonal) and 1 full time temporary (term) position dedicated to ranching in the pastoral zone across 28,000 acres. The implementation of stewardship practices requires careful design, permitting and construction planned by NPS personnel. Increasing agricultural technical staff from 1 to 3 fulltime permanent positions will provide a support system that will broaden NPS' agricultural knowledge, provide technical assistance to the ranchers, enable ranchers to complete conservation projects expeditiously and result in the increased implementation of stewardship practices.
2. Facilitate practice implementation by establishing pre-authorized federal approvals for common stewardship practices. Each proposed stewardship practice is required to be authorized through the NPS Planning, Environment and Public Comment (PEPC) process on a case by case basis which can cause anywhere from 3-24 week delays in implementation. A list of NPS pre-authorized stewardship practices will enable NPS staff to streamline the approval process in a way that supports the ranchers forward in project implementation. The Marin RCD has developed such a program for compliance with the California Environmental Quality Act
(http://www.marinrcd.org/wp/wp-content/uploads/2014/01/Final-PCP IS MNP 20101110.pdf). Furthermore, a pre-authorized list of practices will provide clear natural resource protection guidance and enable ranchers to work with NRCS and Marin RCD in developing ranch water quality and carbon farm plans that strategically guide long-term management thereby resulting in meaningful and measureable improvements.
3. Provide cost-share funding for environmental projects in the pastoral zone. The ranches are motivated to improve natural resources. In the last several years, NPS has secured federal Clean Water Act funding to assist the ranches with water quality improvements. This type of assistance to the ranchers should continue to be supported and expanded to include practices that support soil health, climate resiliency and greenhouse gas (GHG) reduction. Soil health plays a direct role in agriculture's ability to adapt to variable climatic shifts in addition to soil's ability to fight climate change. This is a concept supported by the State of California's Healthy Soils Initiative and the NRCS Environmental Quality Incentives Program. A 1% increase in organic matter results in as much as 25,000 gallons of available soil water per acre (Kansas State Extension Agronomy e- Updates, Number 357, July 6, 2012); an important benefit during periods of drought. Additionally, NRCS has identified several practices (http://comet-planner.nrel.colostate.edu/COMET- Planner Report Final.pdf) such as no-till farming, rangeland seeding, nutrient management, mulching and rotational grazing that offer this benefit to our pastoral soils. They are designed to increase infiltration, reduce evaporation, moderate soil temperature changes, increase rooting depth, increase nutrient uptake, and improve the water-holding capacity for most soils. Finally, these practices, when managed well, offer exceptional GHG reduction benefits. The application of organic amendments to soils has the ability to increase soil carbon by 50 metric tons C per ha in the top meter of soil (Ryals et a I, 2015. Ecological Applications, 25(2): 531-545). Many of these conservation practices support our farmers and ranchers in enhancing sensitive ecosystems (windrows, buffer strips, grassed waterways, hedgerows, riparian forest buffers, silvopastures). They are designed to increase infiltration rates and decrease runoff, thereby reducing sediment and nutrient loading to streams.(https://www.nrcs.usda.gov/wps/portal/nrcs/detailfull/soils/health/mgnt/?cid=stelprdbl257753).
4. Provide 20 year leases automatically renewed in 5 year increments. PRNS ranchers have demonstrated a strong interest in the implementation of stewardship practices that have been slowed by short-term leases conflicting with long-term maintenance requirements. The Marin RCD and NRCS require 10-20 year maintenance and monitoring agreements to qualify for our programs. Additionally, when a rancher nears the end of a long-term lease, they are left in the same noncommittal predicament. A 20 year renewable rolling lease in 5 year increments would enable lessees to qualify for stewardship programs on a consistent basis, regardless of lease year and fosters a stewardship ethic that spans multiple generations. It is this type of cultural knowledge of the land that is passed through the generations and melded together with NPS ideals to inform adaptive management. Furthermore, the assurance of tenancy supports continuous land management requirements (i.e. erosion control and weed management) transcending NPS budget cuts associated with changes in administration.
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. The ability for the ranches to diversify and adapt to market trends is critical to the strength overall agricultural community. NPS ranches constitute 19% ($18.3M) of total agricultural production in Marin County. Their survival is essential in sustaining a local food source for Marin County residents. Consequently, the health of our natural environment is essential to agriculture's sustainable future. 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.
The Marin RCD strongly supports these ranchers and NPS in being national models of sustainable land stewardship and we offer our assistance in any way that is beneficial to both parties. Please do not hesitate to contact us for additional information or clarification
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# 2907
Name: Spaletta , Ernie, Nichola & Ernest Jr
Correspondence: Thank you for giving us the opportunity to comment on the PRNS and GGNRA General
Management Plan Amendment environmental review and EIS for the November public scoping period.
In 1859, C Ranch lands were settled by noted inventor; engineer Capt. Oliver Allen for a future site for a dairy farm. This dairy site is now an organic small scale dairy farm consisting of natural grass pastures to feed dairy cattle. Our family, fourth and fifth generations take great pride in the area that we have lived and worked on since 1946. We implement sustainable, organic Best Management Practices. We take care of the lands, waters, wildlife and historic structures. We are environmentally certified and also are adding more carbon farming to our family dairy practices. Our goal has been and continues to be a producing farm that supplies quality organic milk for consumer local and far while taking care of the natural and cultural resources in our area.
Our family has looked over all the alternatives listed in your General Management Plan Amendment. In your Additional Preliminary Conceptual Alternatives under Consideration : "Continued Ranching and Removal of the Drakes Beach Tule Elk Herd" would be the best fit and equally fair for all ranching at Point Reyes National Seashore and Golden Gate Recreational Area, if you "add" in Removal of Tule Elk off the Limantour-Estero Road ranchlands as well to this alternative. We would like to see if it is possible to add an extension on the 20 - year leases/permits for ranchers wishing to pass the legacy on to their family members. This will help rancher maintain a long standing commitment to preservation of the historical ranch and its natural resources on the lands.
If we chose "No Ranching" or even "Reduced Ranching", agriculture would be an economic loss for West Marin along with its history. Many jobs, companies as well as the consumers that have been affiliated with these historical ranchers would be affected. The public will have to seek agricultural products that will not be local and the community will be forever changed. In addition, "Reduced Ranching" is a selection of some ranchers to stay while others must shut down is not a choice for us. We believe in equality and fairness for all ranchers involved in this General Management Process. We are a small community and we support one another and have so for years and years."Removal of Drakes Beach Tule Elk along with Removal of All Tule Elk Permanently off All Ranches" is the only management practice that will keep ranching alive on the Pastoral Zone. Ranchers for many years were promised that elk were not to conflict with ranchers infrastructure. The Tule elk were not a part of any lease or agreements. 'The 1998 Point Reyes National Seashore Tule Elk Management Plan and Environmental Assessment' provided protection for ranchers when the public chose Alternative 'A'. Past Superintendents placed elk back in their 18,000 acres of Limantour/Phillip Burton Wilderness that was set aside for them in this plan if they were bothering ranchers.
Today, there are over 150 Tule elk that are out of their designated wilderness area. Our family has wrote numerous letters, made phone calls, attended meetings, sent emails to the Point Reyes National Seashore for well over 10 years to ask for elk to be placed back into the Wilderness area with no luck. (Enclosed is our first letter sent to Cicely A. Muldoon when she started at Point Reyes as the new Superintendent.) The elk damage in our area is costing us more money to buy more and more feed for our dairy cattle, because there is little grass left for the cattle due to the 110 elk grazing on our rotated pastures. Over the years, we have cut our dairy cattle herd numbers in half to remain in compliance to meet grazing standards for forage amounts left on ground each year. We have tried every angle to keep viable, but we are getting close to the end if these elk are not relocated. These elk should be managed as a Natural Free-Range herd in a wilderness area where they are not hazed through fences and do not have to forage on ranches' hay and drink out of livestock watering areas. The hazing of elk in the morning hours through cattle pastures is a waste of time, elk health and tax payer dollars. These elk are full from feeding all night and come right back into the areas that park staff haze the elk from to eat again through the next night. These elk need to be managed in a wilderness area, the area that was meant for them to thrive and be wild. The elk need to have sufficient natural forage and running water to keep them healthy, meanwhile helping with fire prevention.
Many years have passed since elk encroached on ranches and the elk population is escalating so much that elk damage on ranches is accruing more and more. It is to the point of placing both the elk and the rancher at risk with disease transmission and certification loss for pasture grazing requirements for Organic Pasture Rule and PRNS Grazing Standards. Ranchers would like to continue pasture improvement with weed control and planting of native grasses as in years past. There are fences down, cattle missing, dairy cattle not milked, cattle bred by a neighbor's bull to young, farm equipment damaged, cattle gored, pasture grass forage competition, hay loss, disease contamination, dry stock ponds due to breaking pipes, all by elk. These are just a few of the many conflicts as why elk and cattle need separation. There is a place for both cattle and elk at Point Reyes National Seashore. The cattle are to be on the Pastoral Zone that was set aside for them when ranchers sold their land to make the Point Reyes National Seashore in 1962. The elk are to remain in the Wilderness at Limantour according to the 1998 Elk Management Plan that the National Park Service states that they are still following.
Ranches in the Seashore have all used some form of "Diversification." It may be new or a historic method of remaining viable in hard times. That is why in all leases/permits we are able to have 10 other livestock to add or delete in a business or climate change. These diversification actions are a way that ranchers can keep up with the local food system and add to the scenic beauty of agriculture production that visitors can see and learn by.
Secretary of Interior, Ryan Zinke, issued and order (S03355) directing agencies within the Dept. Of The Interior to complete EIS processes within one year and to limit the final EIS document to 150 pages. We ask that the Point Reyes National Seashore file the NOI this fall as they had planned to do. The Point Reyes National Seashore would like to wait three years before they file the NOI so that the NPS will comply with the new secretarial order. Ranchers can not wait that long for the elk to be managed properly. The elk need solitude, forage, and running water from the wilderness, not hay and grass from the rancher's cattle pasture.
Our family continues to communicate with the Point Reyes National Seashore regarding ranching in the Seashore and we hope that we can work together on what is best for all historical cultural and natural resources into the future.
- - -
Ernie, Nichola and Ernest Spaletta Jr. ask that you please remove the elk heard off of "C" and "D" ranches that we are leasing from the Dept of Interior N.P.S. in the Point Reyes National Seashore.
We feel that the herd is growing in numbers and our dairy farm can not continue to operate in a profitable manner. Spaletta Dairy has had numerous concerns about the elk grazing and running freely across our operations for over the last three years.
Building a fence near our leased ranches would place the elk on our neighbor's leased lands. This would not be fair to our neighbors. A fence would also have to be placed on sandy beaches. Erosion would take place do to sand movement Elk may escape.
We feel that the elk need to be removed off the dairy and beef ranches along Sir Francis Drake Blvd in the Point Reyes National Seashore.
Spaletta Dairy "C" ranch has 590 graze able acres. This is a pasture ranch, no crops are grown to support feed for cattle. We rely on good pasture management to support our feed program and to be profitable. The "D" ranch has 131 acres and is also strictly pastureland. These two rented ranches cannot support elk grazing along with our dairy cattle. We rotate fields and let them rest for a period of time. We rise liquid and dry manure spreaders to enhance proper nutrient growth in grasses. We brush cut and seed with natural grasses to improve pasture quality. These elk have found our grasses to be the tastiest and will not leave our ranches. They eat all our forage and damage our fences. The elk also have broken our irrigation system and destroyed our electric fencing and boxes. The elk run with our cattle herds and make it hard for us to contain our dairy cattle in their proper pastures, because they create holes in fencing on a daily basis. We also have had problems with the bull elk at breeding season goring our cattle. We have lost two heifers and one is still ill in the field from being hit by an elk.
Otter great concerns are the many diseases that elk may produce and transfer, Johne's, Chronic Wasting Disease, Scabies, Brucellosis, and Bovine Tuberculosis. We vaccinate our dairy cattle and or do not have these diseases present in our herd. We have a licensed veterinarian on a regular basis oversee and vaccinate our dairy cattle. These elk graze off our pastureland and drink from our water sources on a daily basis. They could easily wipe out the Spaletta Dairy milk operation with the diseases that they might introduce into our livestock. They are not vaccinated or all checked for being a Johne's carrier.
We hope that we all can come to an agreement on how to manage the growing elk population on Sir Francis Drake Blvd. in the Point Reyes National Seashore.
- - -
Re: ELK DAMAGE TO "C" and "D" RANCHES LEASED BY SPALETTA'S
2- Electrical Panel Boxes @ $ 219.00 each $ 438.00
8- Rolls of Barbed Wire 10,632ft @ $ 67.99 each $ 543.92
1- Box Fencing Staples 501b @ $ 89.00 each $ 89.00
4- Bags of Fencing Clips 1 OOct @ $ 5.99 each $23.96
2- Rolls of Barbed Less Wire 2658ft @ $ 70.00 each $ 140.00
8- Rolls of Electrical Fence Wire 10496ft @ $ 39.95 each $ 319.60
25- Aluminum Irrigation Pipes 4"x 30ft @ $ 110.00 each $ 2750.00
75- Fiberglass Electrical Sticks @ $ 2.50 each $ 187.50
3- Electrical Fencing Clips 25ct @ $ 6.50 each $ 19.50
1- Sprinkler PTO System Repaired $ 232.29
350- Wood Fence Post 8' Long @ $ 14.95 each $ 5232.50
TOTAL $9976.27
Tax @9.000% $ 897.86
TOTAL $10874.13
Above Items purchased at M. Maselli & Sons Inc, SC Bams Buildings & Fence, Rain for Rent and General Dairy-Dairy Animal Equipment
Labor for Fence Building for last three years, lhour a week @ $ 30.00 a Hr. $4680.00
Forage Lost by Elk each year off of "C" & "D" Ranches leased by us.
4-Loads of Medium Grade Alfalfa Hay- Test 54 TDN @ 150.00 a Ton Delv.(Average 56,000 LB. a truck load) @ $ 4,200.00 each $ 16800.00
This bill does not include water consumed by elk from ranch **C" & "D" water resources. Spaletta Dairy buys Park Water @ 3.37 a CF. We have to purchase water from the park while the elk drink the water that we save for our cattle. This is costly to us.
We are fixing fence now on an almost day to day basis. These costs are rising each day as the elk stay and eat on our leased ranches. We can not contain our cattle in their proper fields due to elk damaging our fences. Total Cost Of Elk Damage $ 32,354.13
Please work with us on a solution to this costly damage that the elk are doing to our dairy operation.
___________________________
# 2908
Name: Stone, Michele
Correspondence: My comment is regarding the Point Reyes National Seashore Planning for ranches in residence on the Park land.
I am a resident of West Morin County, bordering PRNS. My sister and her husband (the Spalettas) own an organic dairy ranch in the Park Seashore area.
I'm concerned about them losing their lease for continued ranching, as well as all the other ranches in the Park that are in danger of losing their leases.
These ranches provide high quality, mostly organic products for local residents and beyond.
Providing 20 year, renewable leases by the Park, would keep ranching families together for continued work (most of these family ranches go back generations!) in providing organic milk, beef, and other quality products.
My other concern for my sister's family ranch and all the Point Reyes National Seashore ranches is the problem of the Tule Elk that were introduced into the Limanton Wilderness area, by the Park Service, and was to be maintained by the Park Service. There.
What's happening is, the elk have multiplied and large herbs (100 or more) have spread into the grazing land of the ranches, eating a lot of the dairy and beef cattle's food.
In turn, the ranches are forced to buy expensive (organic) hay to make up for the huge loss of grazing lands.
A solution that the ranchers agree on is to move the elk herds back to the Limanton Wilderness area where there is plenty of forage for them; fence off their area from the ranches grazing land thus maintaining both elk and the food providers.
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# 2909
Name: Wilson, Sallyanne
Correspondence: I am writing in support of continuing sustainable agriculture in the Seashore and GGNRA. The ranches located there are vital to maintaining the future of agriculture in Marin County. Without these multi-generational ranches that have served the Bay Area for more than a century, there would not be sufficient production to support continued critical services.
As a Marin resident since 1970 I have strongly supported efforts to enhance our incredible coast and enable the West Marin community to protect the coastal environment and ensure economic security for our county's agricultural region. I've watched with great joy the development of environmental sustainability techniques on our area farms that are being copied around the world, as well as efforts within our national seashore to provide enhanced educational opportunities for park visitors to learn about the natural environment.
I have a great sense of pride in knowing that accomplishments made in both Marin agriculture and parks are copied elsewhere in the U.S. and the world at large. Most of all, I'm proud of Marin citizens and government officials for supporting decisions that have made Marin an outstanding example about what diverse communities can accomplish over many years despite disparate points of view at every step.
All of Marin's successes are attributable to people — often with different backgrounds, points of view and strong opinions — who have come together through the decades to reach consensus on what's needed for the common good.
I have been privileged to be a volunteer in many organizations associated with Marin County's environment and agriculture. I served as a Marin County planning commissioner and was the Marin Community Foundation's program officer for the environment for many years.
I strongly support the continuation of ranching in the Seashore which is critical to our county maintaining a strong agricultural economy and a healthy community with locally produced foods.
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# 2910
Name: Mendoza, Jarrod
Correspondence: Hello my Name is Jarrod Mendoza. I am currently one of the ranchers in the Point Reyes National Seashore. I lease 1200 acres on the Historic B Ranch. I am writing to propose an alternative to be reviewed that would expand upon the 5th alternative or the continued ranching alternative. The park service needs to study relocating all of the elk in the pastoral areas. The elk herds have been causing damage to fences. Compete with cattle for forage. There is also the issue of disease transmission which Tule Elk can carry from one herd of cattle to another. The Park Service also needs to understand that the ranches in the park are part of the economic and social structure of the West Marin area. Many of the ranches have children that go to local schools and shutting down the ranches would have major negative effects on those schools. The ranches also provide at least 20% of agricultural production in Marin County. Offering the ranchers 20 year leases would give the ranchers the security that they need to make capital investments that would benefit both the businesses that the ranchers are trying to operate and the environment in which they are located. Eliminating or reducing the ranches/dairies in the park would only lead to higher unemployment in the West Marin are. Point Reyes National Seashore is the only park in the United Sates that has working dairies operating within it. This would be a great opportunity to show the public how and where this food product is made.
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# 2911
Name: N/A, N/A
Correspondence: Growing up in West Marin, my world view was deeply influenced by the environmentalists, people working for food justice, ranchers, fishermen, contractors, farm workers, backpackers and bikers that surrounded me. West Marin, as a thriving community of both working class and wealthy people, does not merely exist adjacent to, or alongside the Point Reyes National Seashore, but within it. As we all know, the vision and cooperation of many of the same ranching families that are still working within the PRNS today, was integral in the formation of the national seashore. In my opinion, these two elements distinguish PRNS from other parks, where the NPS's commandment to "preserve and protect" may be carried out without questioning what exactly deserves to be preserved, and what ought to be protected, from whom.
The ranchers' long standing connection to the land on the point, and to the park make the institution itself a more obvious local actor within the political economy and cultural landscape, and in the same way, makes both the locals that work with the land, and the park administration more accountable to each other, and the wider community. While the inclusion of working ranches- -and the working people they hold- -into the list of things worth protecting by the National Park Service may be a challenge to the classical (and in my opinion old-fashioned) conception of environmentalism and the NPS's mission, I think this challenge should be taken on with enthusiasm and hope. And, while the issues that have arisen from this combination of interests may have caused some negative controversy (elk and oysters being the notable ones) in the community, I think West Marin's public conflicts have been intense as a microcosm of the same kind of tensions that exist within the wider United States, between the interests of people who work on the land, and people who visit the land.
As it stands, the National Park System, designed by enlightenment era environmentalists, has been largely modeled to serve the interests of these visitors, excluding the protection of both the native people that in many cases lived within protected lands, and the people that worked within them. Because Point Reyes is, and has always been different than that, I think this moment presents an opportunity for the NPS, ranchers, community members and park visitors to work out a more contemporary and progressive way of interacting with each other. I hope that the PRNS keeps this relationship in mind when deciding how to update its ranch plan. I hope that ranching continues on the point, with long term leases to meet the needs of the ranchers and ensure the stability of their businesses. I hope that free-ranging elk on the point are managed in a way that makes them compatible with the ranches, acknowledging that the entire landscape is managed by humans, and has been for over two millennia in some way or other. The wildness, or "naturalness" of these elk herds has very little place in the discussion of their role within such a park.
It is my deep hope that these challenges spur a new kind of national park, that takes into its mission the care of wild spaces within their diverse cultural frameworks, that give them meaning.
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# 2912
Name: Speh, Suzanne M
Correspondence: I support "Continued Ranching and Removal of the Drakes Beach Tule Elk Herd"
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# 2913
Name: Speh, John C
Correspondence: I support "Continued Ranching and Removal of the Drakes Beach Tule Elk Herd"
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# 2914
Name: N/A, N/A
Correspondence:
November 22, 2017
Point Reyes GMP Amendment
Superintendent
Point Reyes National Seashore
1 Bear Valley Road, CA 94956
To Whom It May Concern:
We request that the NPS consider an additional alternative to the ones that have thus far been presented as part of the GMP Amendment process. This new alternative could be titled "Preserving Historic Beef and Dairy Ranching" (PHBDR). This alternative would allow beef and dairy ranching in PRNS/North GGNRA to continue into the future. PHBDR would focus on the existing beef and dairy operations based of the following considerations and parameters.
PHBDR would have dual goals of preserving the current agricultural uses in the park and assuring that natural resources and visitor experiences are being adequately protected. Park staff, with support from agency partners (examples such as RWQCB and USFW), could evaluate impacts from current beef and dairy operations with the directive to allow continued agricultural use when impacts to both natural resources and recreational uses can be reduced or mitigated. Policy could also be focused on helping ranchers improve their current operations, both visual and environmental impacts. Cultural resources (e.g., archeological sites) and highly sensitive habitats could be preserved to a higher degree. This could result in a reduction of acreage in agricultural production and/or changes in the current permitted uses (e.g., silage production). Under this alternative, tule elk would continue in the pastoral and wilderness zones and be managed appropriately.
Commercial diversification would not be permitted under this alternative. “Diversification” is an undefined euphemism for what might often be an increased intensity of agricultural use. PRNS has limited resources for management and enforcement and while staff does a commendable effort to oversee existing operations, it seems naïve and unrealistic to image that multiple additional agricultural uses could be effectively managed. Non-commercial diversification such as growing a vegetable garden or raising chickens or a few farm animals for personal consumption could be allowed on the ranches. If “operational flexibility” is defined as the common practice of switching from dairy to beef production and shifts such as dairy to heifer production, then operational flexibility could be offered in the PHBDR alternative. If diversification is considered in any of the alternatives, it should be on a net balance of all resources- --not just a simple AUM evaluation. Net agricultural considerations need to also include water usage, ground and surface water impacts, impacts to wildlife and access issues.
As currently proposed, the “reduced ranching” alternative would allow continued ranching in the historic Point Reyes and Olema Valley pastoral zones and therefore apparently end ranching in all park lands north and east of Olema. This would immediately create winners and losers amongst agricultural leaseholders. The alternative would be further skewed in favor of the few by the proposed allowance of “diversification.” Drawn along somewhat anachronistic cultural guidelines this proposal summarily fails to consider natural resources and recreational values of that are paramount in the park's founding purpose.
Finally, agricultural lease housing needs to be explored under each of the alternatives. Many of the larger leases with multiple structures have significant housing units that are currently used for both agricultural worker housing and as a significant source of, hopefully, affordable rental housing. The economics of these units need to be realistically considered in the planning process.
The PHBDR alternative could help PRNS/GGNRA keep the ranches operational while reducing negative impacts on the natural systems and recreational experiences of park visitors.
Sincerely,
Tom Baty
President, Public Lands Conservancy
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# 2915
Name: N/A, N/A
Correspondence:
November 11, 2017
Point Reyes GMP Amendment
Superintendent
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes Station, CA 94956
To Whom It May Concern:
appreciate the opportunity to comment on the Point Reyes GMP Amendment (PGMPA) pre-scoping alternatives. The National Seashore (PRNS)and North District of Golden Gate National Recreation Area (GGNRA) are truly two of America's treasures and we appreciate the National Park Service (NPS) management of these nationally significant areas.
The Public Lands Conservancy is dedicated to preserving, protecting, and appropriately managing public lands. This is accomplished by raising awareness in the American public about the value of public owned lands and facilitating actions to protect them.
Our comments follow.
The timeline for this pre-scoping is unreasonably short. In the future, please provide adequate time for scoping. This will allow a more thorough review by the public.
It is not clear what document is being amended by this process. The Frequently Asked Question and Answers (Q&As) state the PRNS GMP 1980 is being amended. However, that document does not contain any information regarding the North District of GGNRA and no environmental analysis is attached. Please clarify which document(s) are being amended to ensure what baseline is being used.
This document seems to be only looking at those lands already under agricultural lease/permits without regard for other land uses within the park boundary. Overlaps in the formerly recognized pastoral zoning, current agricultural leasing and the conditional inclusion of some natural and wilderness areas in this document are both awkward and confusing. Please clarify exactly what lands are in the planning area.
The presentation of preliminary draft alternatives in this scoping document do not provide enough detail to fully comment on their merits or distinctions. For future scoping activities, the level of detail must be sufficient to ascertain their potential positive, negative and cumulative impacts. For example, terms used such as "diversification," “ranch core,” and “succession” for ranching operations must be defined to understand their implications and impacts. In addition, the preliminary alternatives do not provide any specifics on additional visitor opportunities or other natural and cultural resource activities. Because the park’s legislation is specific in its guidance about the protection natural and cultural resources, and visitor use, specific strategic policies and actions regarding mandated protection of park resources should be included in future alternatives, (e.g., management of historic structures, invasive species control, rare species protection, and riparian fencing, additional visitor use activities.)
The maps are unclear and have several discrepancies. For example, the map on page 11 shows the “free-range elk core use area” as not being included in the planning area. It’s unclear how elk core use areas could not be included and yet evaluated as part of the amendment. Please provide more accurate and readable maps in the next scoping document.
The current ranching operations do not follow the current 1980 PRNS GMP. For example, some areas are zoned natural and environmental protection reserves, but are in ranching today. We recommend that implementation of the 1980 GMP Proposed Action be considered as a future alternative.
We are concerned about how cumulative impacts will be addressed in the EIS. Areas of impacts that need more evaluation include, but are not limited to ground water and riparian impacts, water supply, water quality impacts and waste disposal considerations.
The PRNS does not have a wilderness plan as required by policy and law. However, much of the PGMPA planning area is adjacent to wilderness and will have direct, indirect, and cumulative impacts of wilderness values. We believe additional data and baselines studies need to be completed to ensure the Philip Burton Wilderness is managed to maintain its wilderness character, as required by law. At present, lack of a wilderness plan and baseline information makes characterization of impacts impossible.
The viability of agriculture in Marin and Sonoma County is often cited as an important issue. Please ensure updated baseline information on the economic aspects of visitor use and ranching is collected and used in the EIS impact analysis. In addition, economic impacts of overall park use by visitors and secondary effect should be discussed and quantified in the EIS.
Tule elk management is a critical issue. We strongly believe the continuation of a managed tule elk herd is important ecologically (restores natural process).and provides for enjoyment for park visitors. The PGMPA should fully address this issues by providing specific guidance to park staff, additional baseline information in affected environment, and analysis of impacts of agricultural operations.
This document cites monitoring activities related to agricultural operations and tule elk management currently undertaken by the park staff. Please post the data and results from these monitoring activities with the other park planning documentation.
The park’s “Initial Proposal” seems to imply an increase in agricultural use from current levels - if not in actual acreage, at least in intensity. While this proposal suggests a minimal decrease in acres under agricultural use, it does not have any correspondent reduction in herd sizes nor does it acknowledge that “diversification” could lead to a net increase of impacts on resources. This alternative needs to be more clearly identified as “Expanded Agricultural Use.”
We suggest that you change the titling of the “Reduced Ranching and Management of Drakes Beach Tule Elk Herd” alternative to “Preserving Historic Beef and Dairy Ranching” alternative. This more accurately reflects the proposed action and focuses on the historic Point Reyes and Olema Valley ranches. We further suggest that “diversification” and “operational flexibility” be excluded from this new alternative.
We appreciate the opportunity to comment. Thank you for your public service in maintaining and preserving our precious parks.
Sincerely,
Tom Baty
President, Public Lands Conservancy
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# 2916
Name: Cutrano, Chance
Correspondence: GMP Amendment c/o Superintendent
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes Station, CA 94956
Re: Scoping Comments on GMP Amendment for Point Reyes National Seashore and GGNRA Lease Areas
Since 1985, Resource Renewal Institute (RRI) has worked to strengthen society's ability to secure the future health of the planet by fostering innovative solutions to increasingly complex environmental problems. RRI combines education, advocacy, organizational development, and sustainability analysis to leverage the global adoption of long-term environmental management strategies to benefit natural resources, wildlife, and society.
RRI was founded in 1985 by former California Secretary of Resources and founder of the Trust for Public land, Huey Johnson. Before the seashore was a unit of the National Park Service (NPS), Huey met with the Secretary of Interior Rogers Morton to discuss the future of the land. Starting in the 1960s, Huey spent fifteen years trying to figure out how to acquire 2,300 acres of private land and valuable shoreline that housed telephone poles and turn it into open space. Huey eventually acquired this land through a deal between RCA and Trust for Public Land. It was subsequently sold to the Department of the Interior (DOI). Huey was often asked to out to the seashore to acquire properties the National Park Service had trouble securing. One example of his dealings was the acquisition of property that belonged to Bob Power.
As a stakeholder invested in the future of Point Reyes National Seashore (PRNS) and the north district of Golden Gate National Recreation Area (GGNRA), RRI makes the following recommendations to the NPS so it may adequately refine the initial proposal and conceptual range of alternatives for the Point Reyes National Seashore General Management Plan (GMP) Amendment:
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, 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 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).
As it relates to the GMPs full and proper use of scientific and scholarly information, RRI requests the NPS conduct studies on current conditions within the planning area to establish a robust environmental baseline. This baseline will help the NPS, stakeholders, and the general public determine the direction of future trends within the planning area. These trends may include, but are not limited to, climate change impacts, water supply, water contamination, protection and restoration of wildlife communities, protection and restoration of plant communities, landscape productivity as it relates to agriculture, visitation and use, costs related to preservation and restoration of cultural resources, funding and staffing for the NPS at PRNS.
Recommended Topics of Study
To adequately prepare for the GMP/EIS process and provide sufficient information for meaningful public comment, RRI recommends further study be done and information to the public be provided regarding the following topics:
Elk Management
Evaluate 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.
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.
Evaluate 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.
Endangered Species
Identify, map, and evaluate 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 and evaluate 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.
Evaluate 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.
Evaluate which ranching and dairying activities and uses within the planning area are compatible with or conflict with protection and recovery of federally listed species.
Evaluate any adverse or potentially significant impacts (under NEPA) from ranching activities on designated critical habitat for any federally listed species.
Evaluate 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
Evaluate any potentially significant impacts (under NEPA) from ranching activities on Central California Coast coho salmon, California Coastal Chinook salmon, or salmon habitat.
Evaluate 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 within the planning area, 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 UFWS 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
Evaluate and discuss any adverse or potentially significant impacts (under NEPA) from ranching activities on the California red-legged frog, or frog habitat.
Evaluate and 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
Evaluate and 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
Evaluate and 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.
Evaluate and 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
Evaluate and 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.
Evaluate and discuss the scientific evidence that excessive livestock grazing adversely affects Sonoma alopecurus.
Discuss the trends of Sonoma alopecurus populations subject to livestock grazing.
Evaluate and discuss the scientific evidence that livestock grazing negatively affects the Tiburon paintbrush. Discuss the trends of Tiburon paintbrush populations subject to livestock grazing.
Evaluate and discuss the scientific evidence that livestock grazing may negatively affect the Sonoma spineflower. Discuss the trends of Sonoma spineflower populations subject to livestock grazing.
Evaluate and 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
Evaluate and discuss the current condition of freshwater resources within the ranching areas, and any impairment due to grazing and ranching activities.
Evaluate and discuss impairment to water quality in creeks within PRNS and GGNRA from livestock grazing and dairies.
Evaluate and 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.
Evaluate and discuss impairment to water quality in Tomales Bay due to livestock grazing and dairies at PRNS and GGNRA.
Waters within the planning area of Point Reyes National Seashore rank in the top 10 percent of U.S. locations most contaminated by feces indicated by E. coli bacteria, according to a new report published on the investigative journalism website The Revelator. Evaluate and discuss current fecal coliform, ammonia and bacteria inputs to creeks and freshwater habitats from livestock grazing and dairies, and the impacts on aquatic wildlife and ecosystems.
Evaluate and discuss current nutrient inputs to creeks and freshwater habitats from livestock grazing and dairies, and the impacts on aquatic wildlife and ecosystems.
Evaluate and discuss current sediment inputs to creeks and freshwater habitats from livestock grazing and dairies, and the impacts on aquatic wildlife and ecosystems.
Evaluate and discuss how dairies and livestock grazing leases control or fail to control livestock waste discharge and runoff.
Evaluate and 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
Evaluate and discuss livestock grazing impacts to native vegetation at PRNS and GGNRA.
Evaluate and discuss 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 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 the NPS analysis of PRNS grazing (RDM or Residual Dry Matter monitoring), which found overgrazing at several ranches.
Discuss how RDM levels are established for lease areas and whether they are adequately protective of native ecosystems and wildlife.
Evaluate and 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, erosion, and sediment loading into adjacent bodies of water via runoff.
Evaluate and discuss documentation of overstocking of cattle and other violations of lease conditions, and NPS failure to enforce lease stocking allowances.
Evaluate and 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.
Evaluate and discuss the effectiveness of achieving conservation goals using either US Department of Agriculture or US Department of Interior grazing BMPs? Discuss the rationale for implementation of either at PRNS.
Assess the effectiveness of current 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.
Evaluate and discuss how much feed is imported as a percentage of total feed for cattle at PRNS.
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 and migratory birds.
Discuss elevated populations of ravens due to ranching and dairy operations and impacts on native and migratory birds, particularly snowy plovers.
Disease Transmission
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. What risk, if any, does the spreading of infected manure pose to humans recreating throughout the seashore?
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. Evaluate and 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 within PRNS and the GGNRA.
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
Evaluate and discuss the science showing that ranch roads contribute to erosion, sedimentation of streams, and pollution.
Evaluate and discuss the extent to which PRNS and GGNRA ranch roads fragment habitat or affect wildlife movement.
Evaluate and 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.
Evaluate and discuss how public recreation and visitation is affected due to roads impacted by 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?
Evaluate whether concentrated animal feeding operations such as dairies have serious impacts on air pollution and human health from ammonia and other gases within 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.
Evaluate and discuss dumping of trash, including barbed wire, and improper disposal of livestock carcasses in the lease areas. Evaluate and 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?
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.
Explore opportunities to protect and enhance pre-ranching cultural resources within the planning area.
Evaluate how current historic buildings may be used to promote pre-ranching cultural resources for public education, use and enjoyment.
Comments on 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 how prescriptive grazing of nonnative plant communities conflicts with preservation and restoration of 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 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 (NPS Initial Proposal)
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 (No Action)
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
Evaluate the climate change impact of each of the proposed alternatives.
Discuss the ways and degree to which each of the proposed alternatives conflict with or support maximum protection, restoration, and preservation of the natural environment at PRNS and GGNRA.
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.
Provide a detailed explanation of diversification and optimization of agricultural activities.
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.
Frequent grazing lease reviews 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.
RRI looks forward to our continued participation in this planning process.
Thank you,
Chance Cutrano
Director, Special Projects and Strategic Initiatives
Resource Renewal Institute
187 E. Blithedale Ave
Mill Valley, CA 94941
[e-mail]
___________________________
# 2917
Name: Campe, Pamela and Jim
Correspondence: We are replying to the L7617 - GMP Amendment
We HIGHLY support existing ranch families to continue beef and dairy operations with 20 year lease/permits.
Of the six alternatives that the Park Service is proposing there isn't one completely viable option for the ranchers.
Two significant issues are:
1) All the land in the pastoral zone needs to be kept in agriculture.
2) The elk need to be controlled or contained or limited in number. At the moment it appears that nothing is controlling
them.
We sincerely hope that your process will include meetings with the ranchers to forge a plan that suits their needs as well as yours. It is in everyone's best interest to work together to find that solution.
We trust that you will find it!
Sincerely,
Pamela and Jim Campe
___________________________
# 2918
Name: N/A, N/A
Correspondence: You should be protecting and preserving our parks, not letting harmful animal agriculture pollute and degradation our natural landscapes. Please do not renew leases.
___________________________
# 2919
Name: Allison, Mickey
Correspondence: POINT REYES NATIONAL SEASHORE GENERAL MANAGEMENT PLAN AMENDMENT
CONCEPTUAL RANGE OF PRELIMINARY DRAFT ALTERNATIVES
Cynthia MacLeod, Acting Superintendent
Point Reyes National Seashore
1 Bear Valley Road
Point Reyes Station, CA 94956
Dear Ms. MacLeod:
Thank you for the opportunity to provide input into the alternatives for the
Point Reyes Seashore GMP Update
I am torn between the No Ranching and Limited Management of Tule Elk and the No Dairy Ranching and Management of Drakes Beach Tule Elk Herd alternatives as you will see below.
A timely FYI:
National media outlets might pick up on 2 recently online publications that might create a firestorm for the National Park Service. Six ranches/farms in Point Reyes N.S. and nine ranches/farms between Point Reyes and Bolinas appear in a map with the heading The top 10 percent most contaminated locations in America: Six of them also show up in a map titled The 10 most contaminated locations in each state: In addition there is a press release that mentions locations in Point Reyes N.S.
Ive attached the links below to give you a heads up.
" Wasted Water: The Crappiest Places in America - Literally, Americas waters are contaminated by poop and bacteria. Use our maps to find the worst waste locations near you. by Dipika Kadaba, November 20, 2017. http://therevelator.org/wasted-water-crappiest-places/
" Center for Biological Diversity Press Release, November 21, 2017 - Cattle Waste Puts California's Point Reyes on 'Crappiest Places in America' List https://www.biologicaldiversity.org/news/press_releases/2017/point-reyes-11-21-2017.php
To be honest, the above information I received today hardened my attitude about Ranching in the seashore. I believe it is incumbent for the NPS to hold ranchers to a high standard and meet at minimum The NPS Management Policies (2006), 180 pages, which summarizes the Underlying Principles as including:
Prevent impairment of park resources and values; and
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.
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..."
Note: The underlined portions above appear to require that resources be improved.
In addition, regarding various uses allowed in parks, Sec. 8.6.7 states 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..."
Practices that must be addressed by all ranches, but especially if Dairy Ranches are to be allowed.
Converting Current practices of Manure Storage is expensive, but the alternative is method manure piles and spreading is unacceptable. See: Wasted Water: The Crappiest Places in America - Literally
" Compost dairy waste instead of spreading dry or slurry manure. See Manure vs. Compost: Dairy Waste Transformed into High Quality Compost http://blog.midwestbiosystems.com/blog/bid/248273/Manure-vs-Compost-Dairy-Waste-Transformed-into-High-Quality-Compost
" Convert manure to bio-methane similar to Strauss Dairy. http://strausfamilycreamery.com/values-in-action/methane-digester and https://www.adisystemsinc.com/en/case-studies/adi-systems-solves-strauss-dairys-wastewater-dilemma
Also see: Biogas from Manure: An anaerobic digester will partially convert manure to energy in the form of biogas which contains methane. http://blog.midwestbiosystems.com/blog/bid/248273/Manure-vs-Compost-Dairy-Waste-Transformed-into-High-Quality-Compost and https://extension.psu.edu/biogas-from-manure
The control of Johnes disease or Mycobacterium avium ss. paratuberculosis (MAP) is important not only to beef and dairy cattle ranchers, but also to environmentalists. See: Johnes Information Center, University of Wisconsin, School of Veterinarian Medicine, Epidemiology. https://johnes.org/general/epidemiology.html and
" The infection begins in very young animals but signs of illness do not appear until they are adults.
" Infected adults pass the infection to neonates via feces and milk contaminated with the organism.
" When MAP is transmitted through the feces, it can survive at low numbers for up to a year in soil and water, but it cannot multiply there.
" MAP is swallowed in manure-contaminated milk, water or feed; sometimes manure is swallowed directly.
" MAP is also shed directly into the milk and colostrum of infected dams in later stages of infection, providing another route of exposure for susceptible young animals.
" Another transmission route is in utero: a fetus may become acquire the infection from its infected dam even before it hits the ground.
" Dirty maternity pens or fecal contamination of feed and water supplies will promote spread of the infection.
" Animals that are infected early in their lives show no evidence of Johnes disease. The time from initial infection to onset of clinical signs (diarrhea and weight loss) is generally two to five years. https://www.ag.ndsu.edu/publications/livestock/johnes-disease-in-beef-and-dairy-herds
" MAP infection prevalence is much higher in closely housed domestic agriculture ruminant herds than in wildlife. The risks of transmission are thus much greater from cattle, sheep or goats than from deer or other free-ranging ruminants.
Independent scientific experts should determine the carrying capacity individual ranches, based on current condition of grazing lands and the prospect of climate change. The number of cattle (dairy or beef) per ranch should be based on the goal of not only avoiding future impairments, but allowing land to recover, restoring, and then sustaining the resource values of the pastoral zone.
" Ranching History at Point Reyes on the PRNS website, states the dairy farms at Point Reyes throughout the late 19th century. Herds of Devons, Jerseys, Guernseys, and later on Holsteins, numbering from 100 to 250 cows per ranch, catapulted the Point Reyes enterprise as perhaps the largest operation in the early years of the state. See: https://www.nps.gov/pore/learn/historyculture/people_ranching.htm
" Current authorizations allow approximately 6,000 cattle on a year round basis. See: Point Reyes National Seashore General Management Plan Amendment Newsletter, page 8.
" A Cattle Census (dairy and beef) should be taken for each ranch to determine how the number of cattle is greater than allowed in the current lease, how herd size has changed from the historical herd size.
" An independent scientific assessment to determine the maximum carrying capacity in both wet and dry seasons for each ranch. It should be based on current condition of the pastures and not be based on any current or past precedents.
" An ongoing count of beef and dairy cattle during GMP Amendment process should include spot check/no warning counts of dairy and beef cattle to determine normal fluctuations (seasonal, sale/purchase, birth/death) and possible violations of current lease agreement.
" The Center of Biological Diversity has a 2-page pdf that states in part:
Cattle grazing versus elk impacts
" Average weight of a Holstein dairy cow: 1,400 pounds
" Range of weights for adult cow elk and adult bull elk at Point Reyes: 300-500 pounds
" Pounds of dry-weight forage an average adult Holstein dairy cow eats daily: 50
" Estimated pounds of dry-weight forage an average tule elk eats daily: 9
" Studies showing environmental impacts or overgrazing by elk at Point Reyes: 0
" Number of imperiled wildlife species at Point Reyes for which livestock grazing was a factor in their listing as endangered or threatened: 14
" Gallons of water cattle drink each day in the Seashore and GGNRA lands: 156,000
Diversification of additional ungulate species makes no sense unless Johnes Disease is eradicated. Diversification should be limited to areas in and around ranch buildings.
" Small vegetable plots, near residences, to grow food for the both the rancher and hired worker families.
" A non commercial number of smaller live stock species (sheep, goats, chickens, turkeys) that can be kept in predator proofed paddocks and/or vacant buildings to supplement residents diets.
" Reuse of vacant buildings for tourist lodging (bed-and-breakfast or full-service lodging) if inspection shows that vacant ranch buildings have no toxic elements that they are structurally sound or can be made so and larger buildings could house displays of antique equipment, photos of ranch activities showing changes over time.
" Bruce Keegan suggests this in his book THE CALIFORNIA COASTAL PRAIRIE OF POINT REYES NATIONAL SEASHORE FROM PREHISTORY TO RANCHING - - AND BEYOND, 2012, 28 pages.
" His book is posted on the Center for Biological Diversitys website. www.biologicaldiversity.org/...elk/.../KeeganPt ReyesBook.pdf
Section 1.3 of the Management Policies covers Criteria for Inclusion for new parks and states:
" "An area is considered suitable for addition to the national park system if it represents a natural or cultural resource type that is not already adequately represented in the national park system..." (p. 9)
" The park's founding act states that "In order to save and preserve, for purposes of public recreation, benefit, and inspiration, a portion of the diminishing seashore of the United States that remains undeveloped, the Secretary of the Interior (hereinafter referred to as the "Secretary") is authorized to take appropriate action in the public interest toward the establishment of the national seashore..." (16 USC 459(c))
This statement seems to say that the act is to protect the seashore, meaning as a natural resource and recreation area. Cattle grazing is represented in the NPS system. It is not possible to say otherwise. The history of ranches in the seashore is important, but cattle grazing or dairy farms are not required to illustrate this history.
The Seashore's act states "... the owner of improved property or of agricultural property ... may, as a condition of such acquisition, retain for himself and his or her heirs and assigns a right of use and occupancy for a definite term of not more than twenty-five years, or, in lieu thereof, for a term ending at the death of the owner or the death of his or her spouse whichever is later..." (Sec. 459 (c)(5), as amended in 1978)
" There are no statements as to longer leases, as often stated by some current lease holders.
" Once an original leaseholder and the heirs to that family choose to discontinue ranching, the lease should be terminated.
" No terminated lease should be reassigned to another rancher. The leased land should be restored native grassland.
My observations on Ranching in the Pastoral Zone of Point Reyes N.S.
I have visited Point Reyes National Seashore frequently in all seasons since 2005, and the following are some observations and concerns about current practices on many of the historic ranches in the pastoral zone:
" During the rainy season and early spring the pastures are green, but cattle create large muddy gathering places and tracks as they move along fence lines. In the summer and fall, many fields have been over grazed to almost bare earth with hay now the only source of food. Trucking in hay costs money. The more outside feed purchased, the lower the profit and the more damage to existing roads.
" Ranchers in the pastoral zone tend to pile manure without regard to nearby lagoons or stream beds that drain into nearby bays. Spreading dry or manure slurry to fertilize overgrazed or fields/pastures mown for silage to almost bare earth can contaminate nearby water sources because it hasnt undergone natural decomposition to destroy the E. coli present in the manure. When the rain starts the run-off affects water sources downstream and contaminating the bays and beaches of Tomales Bay. See: Wasted Water: The Crappiest Places in America - Literally
" A huge building, uphill from the older farm buildings, with a growing pile of manure placed on a slope that drains into Abbotts Lagoon. In mid November 2017 the startling green vegetation surrounding the upper portion of the lagoon signals that too many nutrients, and likely E. coli, had leached into the lagoon. The manure storage area was now bare earth. One could assume, judging by appearance, that the manure pile had been spread over nearby fields adding to the problem mentioned above. See: Wasted Water: The Crappiest Places in America - Literally
" The same farm has a huge covered silage pile, and nearby fields in the region of Ranches H, I, L, M had been mown to bare or almost bare earth for silage. Ranch L or M had a truck parked uphill that sprays manure slurry in the area marked as the worst polluter in California (red dot surrounded by blue). See: Wasted Water: The Crappiest Places in America - Literally
Final comments;
I am not anti-farm or anti-ranching, and I learned through a variety of experiences that taking care of the land was critical to making a profit, over grazing could create an economic disaster the following year and culling a herd when necessary is a norm if your pastures and finances are to survive long term.
" My family owned a small cattle ranch near Grass Valley, raising beef cattle on both dry and a few irrigated pastures.
" Our immediate neighbors had larger farms and herds and let me ride with them moving cattle, not only from pasture to pasture, but also to and from grazing U.S. Forest Service lands during the late spring, summer and early fall. About 15-20 head of our yearlings, ID branded, went with theirs.
" My uncle also raised cattle on his ranch near Grass Valley. My cousin, now a blacksmith, still owns the ranch but decided it was too much work for too little profit. He trains horses and keeps a string of mules for pack trips into the Sierras.
" Two of my husbands uncles who lived in Pennsylvania raised beef cattle for market as well as corn for feed and sweet corn for human consumption. They rarely had dry summers, but when drought occurred they reduced their herd size accordingly to save their pastures from overgrazing.
" We owned 17 acres in Maryland, with enough pasture for 3-4 horses and 4 Angus cows with calves. The latter changed to a 4-H breeding sheep project with a summer flock of 35 in rainy years and less than 20 in dry years, relying on rain and spring fed water troughs and rotating 2 species between 3 pastures to avoid over grazing. Id already learned from earlier experiences and conversations commercial farmers that culling during dry/drought years was a norm.
" Most farmers/ranchers dating back to the 1950s, made sure their livestock got water from troughs and fenced off springs and streams. Manure in fields was broken up by chains link fence dragged behind a tractor. Piled manure was turned with a front end loader to create compost for vegetable gardens or corn/hay fields.
" With a Bachelors degree in Biology and a Masters in Zoology, I taught Junior and Senior High Biology, A.P. Biology and Biology 101 in a Community College. I loved both teaching and research. I volunteer at Bayside/MLK in Marin City assisting their math/science teacher. I strive to keep up on the latest science research and enjoy keeping up with new technology and discovery new ways to doing things that are better for the environment and productivity.
Thank you for your consideration of my comments.
Mickey Allison
November 22, 2017
___________________________
# 2920
Name: Creque, Jeffrey A
Correspondence:
Jeffrey A. Creque, Ph.D.
Land Stewardship Consultation
November 20, 2017
Cynthia MacLeod, Acting Superintendent
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;
We appreciate the opportunity to provide comment 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. There has always been, and remains, an enormous opportunity at PRNS/GGNRA to achieve a uniquely powerful synergy between NPS resource management goals and
objectives and agricultural practice. The GMP Amendment presents an opportunity for
NPS, working with the remaining PRNS/GGNRA ranchers and the Point Reyes Seashore
Ranchers Association (PRSRA), whose families have managed the land for generations,
to provide a national example of collaborative strategies safeguarding -and enhancing natural resources, including the working landscape within the Seashore. This process must engage both agriculture and PRNS in a creative, adaptive ecological and agroecological approach to resource management both within and beyond the Pastoral Zone.
Community and Agricultural Economy
The three settlement-required alternatives represent an existential threat to Marin
agriculture and significant increased risk to agriculture regionally. The PRNS dairies represent 20% of dairies in Marin County and 20% of the milk provided to local processors. Losing these dairies, as would occur under the No Dairy Ranching alternative, would eliminate an irreplaceable source of milk for the Marin-Sonoma milkshed, and would compromise the cultural ecology and economy of both counties. Agriculture on the PRNS/GGNRA lands represents roughly 20% of both the area and total agricultural production in Marin County, with a 2016 gross value of $18.3M. Multiplier effects, through processing and value-added production, result in an estimated annual value of over $73M. These significant community benefits should be recognized in the purpose and need statement for the GMP Amendment. The loss of this component of the countys agriculture, and as many as 1,019 on farm and farm-related jobs, following on the heels of the gratuitous NPS elimination of 55% of Californias shellfish aquaculture capacity in Drakes Estero, would be severely detrimental to the community and the region and would further undermine NPSs already damaged credibility as a community partner. For these and other reasons discussed below, we fully support the continuation of ranching, dairy production and agriculture generally on PRNS/GGNRA lands, consistent with the proposed PRNS alternative: Continued Ranching and Removal of the Drakes Beach Tule Elk Herd.
Sustainable Agriculture and Climate Change
Realizing the enormous potential for carbon sequestration in PRNS Pastoral Zone soils and vegetation could move PRNS/GGNRA beyond carbon neutral to carbon
beneficial through implementation of practices verified on Marin rangelands by the
Marin Carbon Project (Ryals and Silver 2013, DeLonge et al 2013)
(www.marincarbonproject.org) and promoted by organizations such as the Carbon Cycle
Institute (www.carboncycle.org). PRSRA members should be encouraged to act
collectively to implement carbon beneficial practices, including on-farm energy
renewable generation, and to aggregate the carbon benefits realized for economic return under CEQA or the California Cap and Trade framework. In addition, PRNS- generated organic wastes, including fire fuels and landscape debris, should be composted and the resulting material utilized in soil and landscape restoration projects within the Seashore.
The PRNS/GGNRA ranchers are dedicated to environmental stewardship through working landscape management, including a growing interest focused on agricultural solutions for climate change. The Marin RCD has been working since 2013 to develop
and implement whole-farm conservation plans quantifying the potential of the farm
landscape to sequester additional quantities of atmospheric GHG. The Carbon Cycle
Institute has worked closely with the Counties of Sonoma and Marin, the Marin RCD and the Marin Carbon Project to develop agricultural elements for County Climate Action Plans (CAP) in response to California Assembly Bill 32. The Marin CAP explicitly recognizes the potential, through implementation of on-farm conservation practices, for agriculture to be a net sink of carbon and to provide offsets that make significant contributions to achieving Marin CAP GHG emission reduction objectives. To this end, the Marin County Board of Supervisors recently passed the Drawdown: Marin goal. The GMP Amendment should include an analysis of GHG reduction strategies (particularly carbon sequestering conservation practices) that can be implemented at the farm/ranch scale at PRNS/GGNRA while also helping meet NPS objectives for reducing GHG emissions.
Leases
Lease length is directly related to the strength and viability of farming and ranching operations. Longer leases promote long-term viability of ranching operations, enabling investments in and maintenance of infrastructure, natural resources, and farm employee welfare. Twenty year leases -promised by Interior Secretary Salazar in 2014 but not delivered - would be a good first step, but NPS should further augment 20-year leases with five year incremental extensions, so that every five years, assuming ranching family compliance with lease terms, leases are extended for another 20 years. This will provide ranchers the long-term equity and stability needed to support infrastructure upkeep, resource enhancement, a skilled and well-paid farm workforce, access to federal cost share programs and other natural resource enhancement and financing opportunities. Further, leases could be structured as Stewardship Contracts, similar to US Forest Service and US Bureau of Land Management models, allowing reduced lease rates for enhanced stewardship activities on the part of ranches, individually or collectively, by
establishing resource enhancement goals above and beyond regular lease agreements.
Importantly, operational resilience cannot be realized if agricultural activities are limited to only beef and dairy operations. In order to encourage a sustainable combination of agricultural land uses, a diversity of food and fiber crops should be permitted. Lessees should be supported in the continued adoption of ecologically sustainable farming approaches, including organic and carbon-beneficial practices, with incentives such a Stewardship Contracts. Expansion of options for agricultural operations, including on farm value-added opportunities, is key to maintaining operational flexibility and should be encouraged as consistent with overall Seashore management goals.
Tule Elk
Significant conflict exists between free-ranging Tule elk and the ranches at PRNS. This conflict will continue to increase without meaningful intervention. Ranchers and the public have repeatedly raised concerns related to Tule elk and their impact on current ranch operations over the past several years, resulting largely from the failure of PRNS to follow its own 1998 Tule Elk Management Plan. This, among numerous other egregious missteps on the part of NPS and PRNS administrations over the past several decades, has created both a serious threat to the survival of ranching in the Pastoral Zone and a serious credibility gap between the PRNS planning and implementation processes. If indeed PRNS plans to manage Tule elk within the Pastoral Zone independently of the remainder of the PRNS landscape, and if survival of the ranches within the Pastoral Zone is a genuine management objective, as suggested by the Secretarys action precipitating the current planning process, then exclusion of elk from the Pastoral Zone is the only possible management objective.
The PRNS 1998 Tule Elk Management Plan/EA envisions a PRNS free-ranging herd of
250-350 elk, and does not include expansion of the elk herd into the Pastoral Zone.
Failure by NPS to manage this introduced herd in accordance with the 1998 PRNS elk
management plan does not change the legitimate environmental baseline of the proposed EA, which must not include the presence of elk in the Pastoral Zone. Elk have killed heifers in the Pastoral Zone, consumed forage to the point of compromising the ability of certified organic producers to meet their pasturage requirements and for other producers to meet residual dry matter requirements, forced ranchers to purchase expensive feed, consumed limited water, broken fences repeatedly and continue to increase in numbers on the Pastoral Zone. PRNS elk were known to carry Johnes disease, transmissible to cattle, at the time of release from their Pierce Point enclosure. This release took place despite the explicit
recommendation that elk not be released where contact with livestock could occur
(Cook et al 1997).
Given elk populations in PRNS are not limited by any significant predator pressure, already exceed PRNS estimated carrying capacity for elk, and now reside within the Pastoral Zone in numbers high enough to have a serious detrimental economic and ecological impact on the ranches there, reduction and control of the PRNS Tule elk population is an immediate necessity. As a first step, all elk should be removed from the Pastoral Zone. Remaining elk within the wilderness areas should be managed to maintain populations within carrying capacity of those lands, in order to reduce inevitable migration pressure onto the Pastoral Zone. Control via off-site transfers, contraception, and limited but consistent hunting pressure should all be deployed as appropriate. Because PRNS has neither the land base nor the predator population to support a freeranging, unmanaged herd of Tule elk, with or without the PRNS ranches, population control and other NPS management interventions are needed to avoid elk damage to PRNS natural resources and extreme elk population fluctuations, including mass die-off events under low resource conditions, as occurred during the recent drought. It makes sense, therefore, to initiate elk population management sooner rather than later, and to eliminate the Drakes Bay elk herd entirely to both avoid further damage to agriculture in the Pastoral Zone and provide some buffering capacity for periodic -and predictable- short-term increases in numbers that may drive future elk incursions into the Pastoral Zone.
Visitor Access and Experience
We support the concept of increasing the hiking trail network in the planning area as long as visitor safety and management needs of the affected ranches are respected. Trail locations should be determined in close collaboration with ranch operators to insure a workable trail system for both land managers and visitors. Trailheads and points along the route should include discrete signage with relevant cultural, historical, and natural interpretive information. PRNS visitor experience would thus be expanded through explicit access to portions of the Pastoral Zone, and the opportunity to learn about PRNS agriculture, its history, and the names and faces of the ranching families that continue stewardship of the PRNS ranches.
Cultural and Historic Resources
The PRNS/GGNRA ranches have contributed to maintaining the ecological richness of
the landscape and continue as an important element in maintaining the iconic landscape mosaic of west Marin County. PRNS/GGNRA are unique among national park units in the potential for integration of an actively managed pastoral landscape with large areas of that landscape that have been allowed -whether wisely or not- to follow a course of unmanaged ecological succession following cessation of historical agricultural use. Cuyahoga National Park is a somewhat comparable NPS unit, albeit at a smaller scale. PRNS should focus on the implementation of sustainable agricultural practices as a means to enhance the cultural ecology of the Pastoral Zone and PRNS/GGNRA generally. Such an approach would seek to maximize protection of both natural and cultural resources and support continuation of a working landscape that is both ecologically and economically sustainable, reflecting its continuing evolution over the 400 years since European disruption of the indigenous cultural ecology of the region. This would both support continued ranching and farming on historically agricultural areas, and provide a context for renewed leasing of ranches that have gone out of production but which still have the infrastructure to support an active agricultural operation (including D Ranch and Wilkins Ranch). This process should include an evaluation of the potential for use of agricultural practices, including livestock grazing, to achieve PRNS/GGNRA management objectives both within and beyond the boundaries of the Pastoral Zone. BMPs must look beyond resource protection to enhancing cultural and ecological resilience, particularly in light of accelerating anthropogenic climate destabilization.
Rangeland and agricultural management plans should be co-developed among the
lessees, NRCS, RCD and NPS staff in an adaptive management approach to link
agriculture and pastoralism to ecological stewardship, restoration and climate change resilience and mitigation. This approach builds on a growing movement of conservation scholars and practitioners, including those within NPS, to provide leadership in exploring integrated approaches to landscape stewardship at a time of unprecedented global change. See: "Speaking for the Future: A Dialogue on Conservation," Jan. 2003, http://www.nps.gov/mabi/csi/new/speaking.htm and The Future of Working Cultural Landscapes: Parks, Partners, and Local Products, 2008,
http://www.nps.gov/csi/pdf/Working Cultural Landscapes Report Full.pdf
This approach also provides synergistic support for the efforts underway in Marin County aiming to enhance and strengthen its sustainable agricultural community, including the efforts of Marins Agricultural Commissioner, the Marin Agricultural Land Trust, the Marin Resource Conservation District, UC Cooperative Extension and the Marin Carbon Project. By taking this approach, rather than one that conceptualizes natural and cultural resources as existing in inherent conflict, PRNS has the opportunity to become a model for parks management around the nation.
Conclusion
The PRNS management framework would benefit from an understanding of the
potentially potent role of agriculture and the natural resources -including human
resources- it embodies to facilitate and inform the broad resource management objectives of the NPS and PRNS/GGNRA. Ranching and farming, including the use of livestock, offer potential tools to enhance wildlife habitat outside the Pastoral Zone, while helping to advance both broader and more specific vegetation management objectives -such as fire fuel reductions and T&E species habitat enhancement- both within and outside the Pastoral Zone. The potential interpretive and educational opportunities such an integrated process represents are innumerable. For such an effort to succeed, however, requires PRNS to add upper-level staff with advanced
training and experience in both Agricultural Ecology and Cultural Ecology, with capacity and authority to guide and implement a fully integrated approach to natural resource planning and adaptive management at PRNS/GGNRA. This effort must be engaged in full collaboration with agriculturalists and the regions natural
resource and agricultural agencies, including NRCS, MRCD, UCCE, Marins
Agricultural Commissioner, and MALT.
We stand at a time of unprecedented challenge to our planet and to ourselves as an
exceptionally powerful biotic factor (Tansley 1935). PRNS/GGNRA represents a
tremendous opportunity to address the pressing needs of the ecosystems for which we all bear collective stewardship responsibility. At a minimum, the GMP amendment for the Ranches and Pastoral Zone of PRNS/GGNRA must address:
1) the role of sustainable agriculture in the cultural ecology of PRNS and the region;
2) the role of local, sustainable agriculture in regional and national food security and climate change;
3) the potential beneficial role of PRNS and its ranches and ranching community in
climate change mitigation;
4) the management of the PRNS elk herd and its designated range both inside and
outside the Pastoral Zone;
5) the nexus and potential nexus between agricultural practices and NPS resource
management objectives at PRNS, including the possibility of expanded livestock
grazing within the Seashore under a targeted grazing management scenario to meet PRNS vegetation management objectives (including fuel management and elk habitat improvement outside the Pastoral Zone), possibly under a Stewardship Contract agreement framework per USFS/USBLM models.
Over half a century ago, Marins agricultural community joined with local and national environmental groups and the NPS to realize the shared goal of protecting this unique landscape from significant residential development. The success of this shared effort is manifest in todays working landscape with its strong community, economic, and ecological benefits. Because of this historic alliance, the opportunity for a vibrant local cultural ecology, including provision of climate change solutions, sustainable food production and functional landscapes, among other ecosystem services, remains. The GMP Amendment process is an opportunity to again embrace the original purpose and intent of PRNS/GGNRA; the preservation of this unique working landscape, including its multi-generational ranching families and the regional cultural ecology of which they are a defining component.
Sincerely,
Jeffrey Creque, Ph.D.
Director of Rangeland and Agroecosystem Management
Carbon Cycle Institute
CA State Board of Forestry Certified Rangeland Manager
LITERATURE CITED
Tansley, A. G. 1935. The Use and Abuse of Vegetational Concepts and Terms. Ecology,
16(3): 284-307.
Ryals, R. and Silver, W. 2013. Effects of organic matter amendments on net primary
productivity and greenhouse gas emissions in annual grasslands. Ecological Applications 23(1): 46-59.
DeLonge, M.S.; Ryals, R. and Silver, W.L. 2013. A Lifecycle Model to Evaluate Carbon Sequestration Potential and Greenhouse Gas Dynamics of Managed Grasslands.
Ecosystems 16: 962-979.
Cook, W.E., Cornish, T.E., Shideler, S., Lasley, B., and Collins, M.T. 1997.
Radiometric culture of Mycobacterium avium paratuberculosis from the feces of tule elk. J of Wildlife Diseases, 33(3): 635-637.
___________________________
# 2921
Name: Ahlers, Rebecca
Correspondence: Dear Ms Superintendent Muldoon and members of the Point Reyes National Seashore,
Thank you for the opportunity to comment during this first phase of the GMP amendment process. Growing up in the seashore, I feel I have a unique insight to the rich history and culture of Point Reyes. I have been witness to the changing environment for the past 30 years in the seashore. I would like to help preserve and improve the rural landscape as well as promote traditional and historical farming and ranching operations which have lured so many visitors to the seashore.
I urge the National Park Service to continue ranching and farming on 28,000 acres in the seashore by issuing 20 - 30 year leases/permits with the ability to renew with similar terms. 20 – 30 year leases are important not only for capital investments but to encourage multi-generational farming. Capital investments are necessary for any operation to be sustainable. Capital investments include the purchase of new environmentally friendly equipment, employee housing, and barns to store equipment and house animals from the harsh elements. California is stringent on greenhouse emissions and requires farmers and ranchers to replace outdated equipment and machinery to meet new standards. The average age of the farmer or rancher is over 50 years old. It is important to ensure stability in order for the next generation to continue to improve practices and support a growing demand for a local food source. Capital investments also help improve the aesthetics of the farm.
The lease and permits issued by the National Park Service need to be flexible in order to achieve agricultural diversification. Farmers and ranchers do not control the price of commodities they sell. The price is driven by the current market. Diversification allows farmers and ranchers to stay viable in an ever changing economy. Diversification also allows for options to improve the biodiversity and health of the land. Education about agricultural diversification is a great opportunity for the NPS to educate the public about how a local food source can adapt to the changing environment and encourage the preservation of natural resources.
I encourage the National Park Service to help streamline approval of Best Management Practices in the seashore. Most decisions which impact animals, a living being, need a quick and educated decision. The farmers and ranchers have the knowledge and assistance from dedicated veterinarians and local agencies with the experience to help streamline much needed solutions. The farmers and ranchers in the seashore currently follow strict guidelines set forth by Local and Federal agencies. The farmers and ranchers are not only happy to follow the guidelines, they encourage them.
I urge the National Park Service to help promote traditional and sustainable food production. Small scale farming is disappearing fast. The definition of local food has changed from 30 miles, to 100 miles, and now to the State of California. With an ever growing population, it is important to maintain our local food source and encourage sustainable farming practices while educating consumers and travelers. The historic farming operations provide a perfect opportunity to educate travelers on the history of food production in West Marin. Agritourism is a growing market and should be capitalized by the national government with the help of the farming community. My family is more than happy to help in this process. I have personally gone through extensive training on educating the public on agriculture along with experience on giving educational farm tours.
I recommend the removal of the Tule Elk on the areas designated for farming and ranching. Tule Elk encroaching on the pastoral zone directly impact not only the farming and agricultural operations, but also the natural resources and rural landscape in the seashore. The Tule Elk compete for forage, harm cattle, and cause over-grazing resulting in erosion and growth of obnoxious weeds. Farmers and ranchers are unable to rest their pastures and have to supplement additional hay in their daily feed rations. I have personally witnessed elk feeding on hay meant for cattle and the disturbances they cause to a farming operation. The reason the Drakes Beach herd prefers my family farm over the other areas is due to our pasture management practices and that we feed hay on the field when grasses are low. Sometimes it seems we are more elk farmers than dairy farmers. A simple and most feasible solution would be to fence the tule elk away from the pastoral zones designated for agricultural uses. One option to help raise funds for an elk fence and management solution would be to sell hunting tags. Tags could be issued to a select few with strict rules including an experienced guide.
I acknowledge that buffer areas are important and necessary to protect natural resources and endangered species. I know from my experience that fallow land can be quickly overgrown and can encroach on neighboring properties and as well as take over fencing. Growing populations of animal, insect, and reptile species in buffer zones can also out grow their designated area and may try to overtake nearby areas. These zones should be managed so that they do not overgrow or overtake their designated area. Overgrown grasses, brush, and trees can also create a fire hazard. From experience, it takes 20 – 30 minutes for a fire department to arrive for a fire in the seashore. A wildland fire can cause devastation similar to what we recently saw in Sonoma County.
Farmers and ranchers were the first environmentalists. The health of the land and its natural resources are important to the sustainability of living off the land. Agricultural and land stewardship education and research is key to preserving a local food source and preserving our natural resources.
The National Park Service has a wonderful opportunity to promote traditional and sustainable food production while preserving the ecology and biodiversity in the Point Reyes National Seashore. Please consider the families, the community and the animals which call the Seashore home.
Thank you,
Rebecca Spaletta - Ahlers
___________________________
# 2922
Name: Frankal, Daniel
Correspondence: I am against the leasing of the public land to ranch cattle and other such land animals. Such things should be done on private property and not on public land due environmental effects. I ask the board to consider a no-ranching option. Thank you.
___________________________
# 2923
Name: Farr, Gina
Correspondence: Please prioritize the environmental health of our beautiful Park.
We need our Park to protect, restore, and preserve park resources - - including native plants, ecosystems... and our heritage elk.
Do not fence them in, please. Fewer ranches, more wonderful park FOR ALL.
Thank you for taking my comment.
___________________________
# 2924
Name: Smith, Douglas
Correspondence: I want more opportunity to restore the park, nature and protect the rare elk- - Not to support big at and ranchers!
___________________________
# 2925
Name: N/A, N/A
Correspondence: Stop giving ranchers so much power to kill innocent lifes.
___________________________
# 2926
Name: Livingston, Douglas S
Correspondence: I support the alternative titled, "Continued Ranching and Removal of the Drakes Beach Tule Elk Herd," and would, to a lesser degree, accept “Continued Ranching and Management of the Drakes Beach Tule Elk Herd (NPS Initial Proposal).” After continual study of the Point Reyes ranches during the past 33 years, and intimate knowledge of both the NPS and ranching communities, I conclude that it is important for the people and environment of the San Francisco Bay Area and California to continue the traditional use of these lands for food production, with appropriate oversight and environmental protections, and without the competition of tule elk, which could potentially range farther south in the National Seashore as a tradeoff for the pastoral lands they now inhabit. Controlled grazing has been shown to protect certain native plant species and control invasive plants (aided by human intervention), as well as scenic grassland views; the high quality of the milk and meat products provides the area communities with locally grown foods; and the deep culture of the Point Reyes area is largely based on ranching families who have been here for up to six generations and would suffer with the removal of these families and their employees; subtle changes like this have been happening around the country for years and it is only after it is too late that people realize the loss to community. I do not support any of the other alternatives. The one entitled “Reduced Ranching and Management of the Drakes Beach Tule Elk Herd” is especially worrisome as it would fragment the ranching areas, making some ranches isolated and vulnerable to closing in the future; it also would allow formerly ranched lands to go ungrazed (not replaced with tule elk), which has been shown to negatively impact native plants, hiking access and scenic views; this alternative would also negatively impact the livelihoods of the longtime local ranching families.
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# 2927
Name: Andersen, N/A
Correspondence: Superintendent,
Regarding the amendment,
I vote for the 20 year lease for the ranches, with diversity.
Tule Elk need to be managed at a level compatible with ongoing ranching and the elk.
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# 2928
Name: Baty, Tom
Correspondence: We appreciate the opportunity to comment on the Point Reyes GMP Amendment (PGMPA) pre­scoping alternatives. The National Seashore (PRNS) and North District of Golden Gate National Recreation Area (GGNRA) are truly two of America's treasures and we appreciate the National Park Service (NPS) management of these nationally significant areas.
The Public Lands Conservancy is dedicated to preserving, protecting, and appropriately managing public lands. This is accomplished by raising awareness in the American public about the value of public owned lands and facilitating actions to protect them.
Our comments follow.
1. The timeline for this pre-scoping is unreasonably short. In the future, please provide adequate time for scoping. This will allow a more thorough review by the public.
2. It is not clear what document is being amended by this process. The Frequently Asked Question and Answers (Q&As) state the PRNS GMP 1980 is being amended. However, that document does not contain any information regarding the North District of GGNRA and no environmental analysis is attached. Please clarify which document(s) are being amended to ensure what baseline is being used.
3. This document seems to be only looking at those lands already under agricultural lease/permits without regard for other land uses within the park boundary. Overlaps in the formerly recognized pastoral zoning, current agricultural leasing and the conditional inclusion of some natural and wilderness areas in this document are both awkward and confusing. Please clarify exactly what lands are in the planning area.
4. The presentation of preliminary draft alternatives in this scoping document do not provide enough detail to fully comment on their merits or distinctions. For future scoping activities, the level of detail must be sufficient to ascertain their potential positive, negative and cumulative impacts. For example, terms used such as "diversification," "ranch core," and "succession" for ranching operations must be defined to understand their implications and impacts. In addition, the preliminary alternatives do not provide any specifics on additional visitor opportunities or other natural and cultural resource activities. Because the park's legislation is specific in its guidance about the protection natural and cultural resources, and visitor use, specific strategic policies and actions regarding mandated protection of park resources should be included in future alternatives, (e.g., management of historic structures, invasive species control, rare species protection, and riparian fencing, additional visitor use activities.)
5. The maps are unclear and have several discrepancies. For example, the map on page 11 shows the "free-range elk core use area" as not being included in the planning area. It's unclear how elk core use areas could not be included and yet evaluated as part of the amendment. Please provide more accurate and readable maps in the next scoping document.
6. The current ranching operations do not follow the current 1980 PRNS GMP. For example, some areas are zoned natural and environmental protection reserves, but are in ranching today. We recommend that implementation of the 1980 GMP Proposed Action be considered as a future alternative.
7. We are concerned about how cumulative impacts will be addressed in the EIS. Areas of impacts that need more evaluation include, but are not limited to ground water and riparian impacts, water supply, water quality impacts and waste disposal considerations.
8. The PRNS does not have a wilderness plan as required by policy and law. However, much of the PGMPA planning area is adjacent to wilderness and will have direct, indirect, and cumulative impacts of wilderness values. We believe additional data and baselines studies need to be completed to ensure the Philip Burton Wilderness is managed to maintain its wilderness character, as required by law. At present, lack of a wilderness plan and baseline information makes characterization of impacts impossible.
9. The viability of agriculture in Marin and Sonoma County is often cited as an important issue. Please ensure updated baseline information on the economic aspects of visitor use and ranching is collected and used in the EIS impact analysis. In addition, economic impacts of overall park use by visitors and secondary effect should be discussed and quantified in the EIS.
10. Tule elk management is a critical issue. We strongly believe the continuation of a managed tule elk herd is important ecologically (restores natural process).and provides for enjoyment for park visitors. The PGMPA should fully address this issues by providing specific guidance to park staff, additional baseline information in affected environment, and analysis of impacts of agricultural operations.
11. This document cites monitoring activities related to agricultural operations and tule elk management currently undertaken by the park staff. Please post the data and results from these monitoring activities with the other park planning documentation.
12. The park's "Initial Proposal" seems to imply an increase in agricultural use from current levels - if not in actual acreage, at least in intensity. While this proposal suggests a minimal decrease in acres under agricultural use, it does not have any correspondent reduction in herd sizes nor does it acknowledge that "diversification" could lead to a net increase of impacts on resources. This alternative needs to be more clearly identified as "Expanded Agricultural Use."
13. We suggest that you change the titling of the "Reduced Ranching and Management of Drakes Beach Tule Elk Herd" alternative to "Preserving Historic Beef and Dairy Ranching" alternative. This more accurately reflects the proposed action and focuses on the historic Point Reyes and Olema Valley ranches. We further suggest that "diversification" and "operational flexibility" be excluded from this new alternative.
We appreciate the opportunity to comment. Thank you for your public service in maintaining and preserving our precious parks.
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# 2929
Name: Beesley, Louise
Correspondence: To Whom It May Concern:
Point Reyes NS and environs is a favorite vacation destination for me and for my family. The presence of the ranches is such an integral part of the ambiance, and keeps the area from being just another pretty but sterile park . It is also important to keep the local economy diversified, and allow the area to continue contributing to the regional food supply
In conclusion, l cast my vote for continuing the current plan, and allowing the management of the ranches and the elk herd to remain as they are today.
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# 2930
Name: Cooley , Mary Ann
Correspondence: As a recent visitor to the Point Reyes National Seashore, I wanted to tell you my views on the park. It seems the NPS favors Elk over ranching. Is there a way to manage the Elk? Perhaps Culled hunting or Birth control? As with any wild animal there is not an easy way to keep them in place.
The ranches have maintained the grazing and kept things looking the way they should. I saw where the elk are "supposed" to be and it is all, total brush. The general public would be much more comfortable walking in an open field than one with brush.
A working farm is a good thing for the terrain, from fencing to weed control and the list could go on and on.
The Elk would be OK if they are in their place, but I am not sure that is doable. I think the ranching is a win-win.
I hope you will consider all of this. It is a beautiful park and the farmers/ranchers have helped keep it that way.
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# 2931
Name: Dent, Sidney
Correspondence: I am disappointed to learn that the National Park service is planning on extending leases for ranches on public land.
Point Reyes National Seashore is a major tourist attraction. In 2016 Marin county's national parks generated tourist income of $565 million, according to the Sweeney article in North Bay business article. Stacy Carlson, Marin Agricultural commissioner reports 2016 figures for animal agriculture in Marin of $79,459,000 . Down $14,555,000 from 2015. He cites the reason was a fall in the price of cattle, even though Marin cattle production had increased.
This may indicate that the demand for beef and meat products is declining. So why are we forfeiting our parklands for ranching?I suggest we focus on using the parks to encourage tourism and return the area to its natural state and allow the native animals to thrive.
Marin Board of Supervisors voted in March 2017 to allow animal slaughter in Marin County. This is means that animals are slaughtered on park land with little or no oversight. Is this activity likely to attract tourists? Now there is talk of killing the Tule elk, native to the area and at one time facing extinction.
Herds of elk in the parkland would be a tourist attraction. The small number allowed (and controlled by the park service presently) are rarely visible.
Animal agriculture is a major factor in climate change that people are hesitant to address. The National Park service has the opportunity to protect the land by not renewing leases for ranching.
Please take a stand and make Marin a leader in promoting the terrain for native animals and encouraging its lucrative tourist industry.
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# 2932
Name: Dowie, Mark
Correspondence: "Keep your nature out of my nature " -Aaron Lucich
First of all, what is a park? Zion is one, so is Yellowstone, Central, Yosemite, Gramercy, the Maasai Mara and Golden Gate Park. Then there's Fenway, Candlestick and Cominsky Parks. They're ball parks. Parks exist everywhere — in cities, towns, suburbs and wide open spaces. Most are public but some private (Gramercy and Zuccotti). They're on every continent and serve many purposes from entertainment to human refuge, sport, wildlife and native plant protection, eco-system integrity, as well as cultural, historical and natural preservation. There are even temporary parks created for county fairs, revivals and weekend events. And there are tiny urban parklets formed in San Francisco by people who fill a parking meter with coins, lay down some sod in the parking space, set up chairs and relax until the meter runs out. Their variety is limitless, but all parks have one thing in common. They are human creations and are without exception designed and managed primarily for human use.
In their very creation parks create controversy. Some usurp private property, others displace native people. Still others turn pasture grazed by livestock into pasture for wild ungulates. Lands eyed by developers become public playgrounds, and treasured hunting grounds are turned into reserves for the hunted. So while they are ostensibly created for people, parks also piss people off. That seems to be almost unavoidable. In fact the fate of most every park is controversy.
As I traveled the planet researching my last book I was surprised to find that one of the most heated controversies surrounding rural parks around the world is agriculture and whether or not it should be allowed in any form inside a park boundary. The very sight of grazing cattle, plowed fields, silos, bams, vineyards and fishing boats inside a national park is horrifying to some nature enthusiasts, particularly those who believe that cultivated land can be stripped of agriculture, crisscrossed with asphalt roads leading to parking lots and tailored trailheads, and declared "wilderness." Ironically, many of the people who oppose agriculture in parks near their communities also treasure fresh, locally produced foods.
Most rural American national parks that are not historical monuments were created on open, uncultivated land. Some displaced true wilderness. And most of them have remained free of agriculture, although roads, trails, lodges and over 600 commercial concessions have stripped most of them of any semblance of the wild places they once were. A few began their existence on land that had been grazed and cultivated for centuries, most notably Grand Teton, Great Smokey Mountains, Shenandoah, Apostle Islands and Cuyahoga Valley National Parks, as well as National Lakeshores in Michigan and Illinois and the Point Reyes National Seashore, which are not legally parks, but are managed as such by the U.S. National Park Service. In some of those places agriculture has been continued in some form since the park's founding. In others the cultural dynamic that created the landscape was replaced with idealized natural settings in keeping with the ideological and pastoral themes of the Park Service and its supporters. "Rewilding" is the word most frequently used to describe this process. In Cuyahoga farming was stopped altogether, the Park rewilded for a while, then farms were reestablished. But Cuyahoga is an exception which I will return to in a moment.
The creation of Shenandoah National Park provides a better example of a fairly prevalent American attitude toward the notion of farming in parks. While there were still hundreds of productive farms and plantations in Shenandoah Valley, many of which had been cultivating the land for centuries, advocates for a national park were describing the entire area as "primeval wilderness." In 1930 the State of Virginia issued a blanket condemnation of the entire area. Eminent domain was challenged by the farmers but failed, and 465 families were evicted from their land. Homes and barns were razed or burned to prevent anyone from moving back in. The National Park Service called for "a quick return to nature while cleaning up the landscape and preparing to receive visitors in large numbers." In the time it takes to seed, grow and harvest a crop, 300 square miles of diverse and prosperous farmland was taken out of production.
But not all American Parks are created equal. They are in fact remarkably different from one another, run as they are, autonomously by Park Superintendents, who display a wide diversity of attitude toward agriculture and mariculture. Some won't even consider it, while others are more open to the idea, like John Debo, former manager of Ohio's 33,000 acre Cuyahoga Valley National Park, who willingly bowed to local pressure from the pro-ag Cuyahoga Valley Countryside Conservancy and reopened deteriorating but picturesque old farms that once existed in the Park.
The Conservancy was established in 1999 as a cooperating partner with the Park, and for four years after Debo gave a green light to agriculture, focused on rehabilitating and revitalizing the old farms. To preserve the area's rural landscape, the "Countryside Initiative" invited farmers to live and farm inside the park, but only using sustainable methods appropriate for a nature reserve. Eleven rehabilitated farms were operational by 2009, and two more leases are being offered this year. Citizens of Cleveland and Akron can and do travel the short distance to the Park to buy fresh produce, eggs, cheese, meat and wines made from restored vineyards. There are also two smaller National Lakeshores on the Great Lakes, Sleeping Bear and Indiana Dunes, that have allowed farms to remain in operation, partly for educational purposes and partly cultural. Delaware Gap National Recreation Area has 3,000 acres in strictly controlled agricultural production. And subsistence farming of bananas, breadfruit, taro and coconut is allowed on a federally managed preserve inside the National Park of American Samoa.
The Adirondack National Park is experimenting with a fascinating compromise they call "wild farming" which involves planting native pollinator corridors, building ponds, bird and bat houses, restoring riparian and wetland habitats while adopting non-lethal predator controls on local ranches, and developing cropping systems uniquely adapted to each ecosystem in the bioregion. Those practices are combined with sustainable farming. The protection of biodiversity is the ultimate goal of wild farming, as it is in most national parks. The Adirondack project covers many acres of natural land and farmland, including a once private farm now owned and operated by the Eddy Foundation.
The farm is inside a wildlife corridor called the Split Rock Wildway which connects the Park to the Lake. Most of the area is covered by forest maintained in or returning to a natural state. The rest is composed of cultivated fields of organic fruits, vegetables, grains and mushrooms. The fields are criss-crossed with hedgerows of native fruit-bearing trees and shrubs. By all indications the experiment is a huge success and could encourage other superintendents to consider similar projects elsewhere in the system, were it not for considerable public opposition to the whole idea of farming in parks.
In 1949, when Britain decided to follow America's example and create a chain of national parks there was virtually no uncultivated land left anywhere in the kingdom. Following the Shenandoah model by kicking thousands of farmers off land that had been grazed and cultivated for centuries to create parks for weary urbanites and tourists would have caused such a national uproar that the idea was dismissed without debate. The result: Parliament passes the National Parks and Access to the Countryside Act creating fifteen rural parks in England and Wales, In fact, in my travels I haven't found a single country with national parks that doesn't allow agriculture and mariculture in some of them. And cities throughout the world are converting ornamental plots in their public parks to fruit and vegetable production.
So what is a park really for? That remains a hard question to answer because so many of them are created around the world for so many purposes. While few if any were created to advance agriculture, many were formed to protect it. And the idea of combining food cultivation with human recreation, practiced on every continent but Antarctica, seems quite reasonable. Whatever becomes of the relationship between farming and recreation, trying them both at once, in the same place, seems like a worthwhile experiment in sustainable agriculture from which much can be learned about both farms and parks.
 
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# 2933
Name: Evans, Evans, Rossotti, Rossotti, Delores, Dan, Julie, Tony
Correspondence: Subject: First Phase Comments for the Point Reyes National Seashore General Management
Plan Amendment
Dear Superintendent MacLeod,
Thank you for 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 process and the subsequent National Environmental Policy Act (NEPA) review. The first of our Ranches, H Ranch, sits on a sharp turn in Pierce Point Road overlooking Abbott's Lagoon and the Pacific Ocean within the Point Reyes National Seashore. We are a multi- generational family who produce high quality grass-fed, pasture raised beef on the coastal pastures of the Historic H & K Ranches.
Dolores' grandparents, Domenico and Teresa Grossi first arrived in West Marin in the late 1800's, purchasing H Ranch in 1939. Alfred and Florence Grossi, Dolores' parents, operated a 400 cow dairy on the ranch until 1976, when we transitioned the ranch from milk to beef. Our rotational grazing and other conservation practices contribute to the scenic working landscape of the Point Reyes National Seashore.
As generational Point Reyes Ranchers, we are grateful for having the opportunity to continue and enhance our family's business. We have the same connection to maintaining the health and productivity of the landscape, as our parents, grandparents and great-grandparents-who cared for it before. In 2008 we developed and introduced the Rossotti Ranch brand, producing some of the finest local meat available in the San Francisco Bay Area.
We are committed to continuing our family's tradition of producing healthy food for our local community, while implementing sustainable, viable and environmentally friendly ranching practices that protects the land, water, and history of the Seashore.
Specific Comments
We offer the following specific comments for consideration and recommendations for issue identification, refinement and analysis of the alternatives during the GMP Amendment planning process and environmental review under NEPA. We will participate fully in subsequent stages and opportunities to discuss the future of the GMP for the Pt. Reyes National Seashore and Golden Gate National Recreation Area.
Alternatives:
While the Settlement Agreement identified three alternatives that were to be evaluated in the Environmental Impact Statement (EIS), it is also clear that the National Park Service (NPS) is authorized to consider a full range of alternatives that we believe must include additional options for Point Reyes. The NPS GMP notice includes three additional alternatives which we agree should be part of its review. Added to this list we urge consideration of several modifications or expansions of the existing list of alternatives referenced by NPS:
We request an expanded alternative building off the second "Continued Ranching alternative" proposed by NPS whereby NPS would allow for limited additional opportunities in farming and diversified agricultural production to complement existing ranching. 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 in the Seashore to the local community and economy, and meet the larger goal of preserving this cultural, historic and scenic resource in the Seashore. We believe that such limited additional activities would provide multiple economic and educational benefits to the community and would strengthen the overall agricultural economy of our region. We are not proposing in this alternative expanding beyond the current 28,000 acres.
In addition, we would ask that NPS consider a lease term beyond 20 years (25-30 years) for ranches and dairy operations. 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 soils, water and air quality, and assurances of farm employees' welfare. Longer leases would contribute even greater confidence and stability to the entire community of ranchers, employees and park visitors.
Issues:
Diversification on the Seashore ranches and dairies should be fully considered in all analyzed alternatives so that it can be facilitated going forward. Diversification is a proven tool for the economic viability of both individual ranches and the broader community. Diversification has enabled Marin's small and medium sized farms to be economically viable, build additional resiliency, and to avert the risks of business failure. This is especially important because these ranches do not benefit from economies of scale that larger operations enjoy. In effect, diversification has strengthened Marin's local family farms, local economy, and local food system. Diversification can include selected planted or naturally occurring crops, additional livestock production, farm stands and retail sales, processing and value-added production, farm stays, farm educational tours, and expanded work with the school systems and 4-H organizations.
We ask that consideration and analysis of on farm grown and stored livestock feed of silage and hay be included in this examination. This long standing farm practice combines the benefits of critical seasonal forage production combined with effective weed management. It also reduces the need for imported supplemental feed and incentivizes effective on site resource use and ranch resiliency.
We request that the GMP and EIS review and include a plan for succession to new members of existing ranch families and alternative agricultural candidates if that option is not presented.
Succession is critical for the perpetuity of agriculture's management and stewardship contributions. The Seashore has benefited from successful transition from one generation to the next through as many as five family generations. Additionally, families who choose not to continue ranching operations, we ask for NPS to think through the issue of succession with the families of current leases, and then, if necessary, look to other parties interested in continuing ranching and agriculture at the Seashore.
Alternatives in the GMP Amendment will be stronger and have increased success in realizing the mutual benefits of working farms and ranches if they include guidelines to facilitate ranchers and NPS making real-time operational decisions. The need for regular infrastructure maintenance, repair, and replacement along with management of invasive plants are a few examples of operational decisions that often are delayed. This is the operational flexibility that the field level partnership between the ranches and staff require to be successful.
We also urge NPS to include an alternative or modify existing alternatives that would remove the free-range elk herds (Drakes Beach and Limantour-Estero) from the pastoral areas. That said, we support relocation of the herd in other areas either within or outside PRNS but outside the pastoral areas.
We support enhancing visitor experience through educational opportunities. We recommend that NPS explore the opportunity for visitors to learn about PRNS agriculture, its history, and the names and faces of the ranching families who are dedicated to achieving the synergy of a working landscape and environmental resource stewardship. The cultural, historic and scenic resources that have been preserved in the Seashore is the combination of the historic pastoral landscape and the multi-generational families that are managing them The ranching families are the most direct link to the legacy of the historic period of ranching and farming on the Point Reyes Peninsula which dates back to the mid 1800s. The working landscapes we manage exemplify and manifest the national movement to strengthen local food systems and community supported agriculture. Visitor experience would be enhanced by providing relevant cultural, historical, and natural interpretive information, (i.e. brochures, audio tours, signage) along the boundaries of the ranch operations.
Seashore staff have previously been collaborators and partners amongst a broad group of agricultural support organizations in Marin County. We recommend that considered alternatives provide for the inclusion and enhancement of these partnerships and its ability to implement integrated farm production and environmental stewardship solutions. These partnerships have included Marin County departments such as the Agricultural Department, Community Development Agency, and Cooperative Extension. Federal agencies such as the United States Department of Agriculture Natural Resources Conservation Service and the National Organic Program are integral to this partnership. So too are community based organizations like the Agricultural Institute of Marin, Marin Agricultural Land Trust, and Marin Resource Conservation District. This partnership has provided the combined complementing missions and expertise in land use policy, agricultural and natural resource management, marketing and outreach, and education to accomplish precedent setting land conservation, environmental stewardship projects, and value-added farm production.
The GMP Amendment is an opportunity to celebrate a more than 50 year partnership, which has resulted in a working landscape with strong community ties, economy, and ecosystems. We thank you for the opportunity to provide these initial comments and we look forward to working with NPS on all subsequent stages of the GMP and EIS.
 
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# 2934
Name: Gale, Mike, Sally
Correspondence: REGARDING;
Point Reyes National Seashore General Management Plan Amendment for the 18,000 acre pastoral zone on the Point Reyes Peninsula and the 10,000 acre pastoral zone in the GGNRA. This land is currently being used for dairy and beef ranching, as well as the protection of natural resources.
INTRODUCTION
For five generations, our family has ranched the agricultural land outside the Park in Marin County. As such, we are personally involved in the preservation of the ranching community. Along with this commitment to local agriculture, we love the natural world and as such have worked for decades to enhance and preserve the environment on ranchland.
AKNOWLEDGEMENT
The National Park Service is landlord to 20% of Marin County ranches. Along with a responsibility to protect natural resources within the pastoral zone, the Park Service has a crucial effect upon the 24 families whose stewardship predates the establishment of the Park, and who wish to continue this stewardship. This relationship is acknowledged in the enabling legislation for the Seashore. These writers appreciate the opportunity to comment on the PRNS GMP Amendment, which will guide this relationship into the future.
COMMENTS;
RECOMMENDATION TO EXTEND LEASES TO 20 YEARS, WITH ROLLING RENEWALS EVERY 5 YEARS
For ranchers to remain in the SEASHORE and the GGNRA, they must be able to run viable businesses within guidelines that protect the environment In order to borrow money, invest in infrastructure, receive cost shore conservation project monies, comply with Natural Resource Conservation Service (NRCS) requirements and Marin Resource Conservation District (MRCD) requirements, they must show a commitment to their land beyond what is now allowed in 5 year leases. Extending their leases with a reasonable renewal every 5 years or so would help them remain viable and enable them to improve the environment on their leases.
RECOMMENDATION TO CONTINUE A COLLABORATIVE PARTNERSHIP WITH LOCAL, STATE AND FEDERAL AGENCIES
The County of Marin and local agencies, such as the MRCD, U.C. Davis Agricultural Extension Office and the NRCS have long partnered with the National Park Service to improve and enhance natural resources in the pastoral zone. Given the strong interest on the part of Seashore and GGNRA ranchers, we urge you to consider expanding this relationship. With the federal budget cuts of around 13%, this assistance is practical as well as wise.
RECOMMENDATION TO ESTABLISH AN EFFECTIVE WORKING RELATIONSHIP WITH RANCHING FAMILIES
The relationship between NPS and the ranchers has improved greatly over the past several years. That said, we would recommend the adoption of a formal structure by which communication between parties would improve. This might take the form of a Council of ranchers through which issues can be discussed and solutions to current problems can be found. Involving the ranchers more in decisions which affect them, being able to benefit from their expertise and experience, having one message go out to all of them, and having a transparent process, would improve this delicate relationship, in our view.
RECOMMENDATION TO MANAGE ELK
Maintaining a biologically sound number of elk in the Seashore while minimizing forage use and property damage in the pastoral zone requires an active management plan. Such plans do exist (See the Strategic Management Plan for Elk, January 2016, Minnesota Department of Natural Resources, among others).
As ranchers of cattle in a limited area, we believe we have some understanding of the management of grazing animals. Careful attention must be paid to forage, animal damage to infrastructure and natural resources, reproduction rates, animal health, nutrition and the like. Introducing elk into the Seashore includes a responsibility to care for them. The elk are not able to leave the Seashore in order to compensate for increased numbers and decreased forage, as they would under truly wild conditions. Changes in climate necessitate a commensurate management response.
That said, culling, castrating, removing to better locations, medicating, and insuring adequate nutrition and water would all be part of a good management plan, in our view. This might include the improvement of their habitat through more active management of the land outside the pastoral zone.
Without a plan, these animals will increase beyond the ability of the Seashore to provide for them, as well as impact the ranching part of the pastoral zone negatively.
VISITOR EXPERIENCE RECOMMENDATIONS
There are many ways to improve visitor experience in the pastoral zone. Besides limiting the number of visitors at any one time in any one location to minimize environmental damage caused by these visitors, we would propose two activities; the opening up of farmhouses to farm stays and the giving of ranch tours by ranchers.
A positive way to support the cultural attributes of the Park would be to increase the opportunity for contact between the living embodiments of this cultural heritage, the ranchers, and Park visitors. Allowing the ranchers to provide lodging and visitor experiences in a controlled and protective manner (See Agricultural Farm Stay; ucanr.edu/sites/CESonomaAgOmbuds/Agricultural_Farm_Stay) would enhance visitor experience and provide education regarding environmentally beneficial food production. Farm Tours are another way for ranchers to share their cultural heritage with visitors. Along with overnight farm stays, tours have the benefit of providing work for the next generation of ranchers.
RECOMMEND STATE OF THE ARTS FARMS AND RANCHES AS AN EDUCATIONAL
OPPORTUNITY
As there are millions of visitors to the Seashore and the GGNRA each year, an opportunity exists for the demonstration of complimentary food production and environmental stewardship, as well as beneficial greenhouse gas reduction strategies. Resources put into these ranches in the way of state of the art food production, carbon sequestration, riparian restoration, methane digesters, solar energy and electric ranch vehicle and machinery use...the list goes on and on, offers a wonderful opportunity to educate the public on a green way forward.
THANK YOU!
We appreciate this opportunity to be part of the planning process for the GMP Amendment We look forward to a positive outcome.
 
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# 2935
Name: Hagen, Bob
Correspondence: I enjoy the peaceful tranquility of Pt Reyes National Seashore. It is beautiful with the terrain and wildlife. However I am troubled with the cattle and all that is involved with raising them in a National Park. The fences, gates, excrement, and trampled ground are impediments that make hiking unpleasant in such a beautiful environment I do appreciate the Tule Elk being brought back to this area. They are a natural species that belong in Pt. Reyes. I would hope that the long term management of the Park would support the Tule Elk population and eventually eliminate the cattle.
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# 2936
Name: Larson, Stephanie
Correspondence: My name is Dr. Stephanie Larson, and I work for the University of California Cooperative Extension. I am currently the Director of the University of California Cooperative Extension for Sonoma County and have worked with dairy producers, livestock producers, and rangeland managers in Marin and Sonoma Counties over my career. I have Bachelor's and Master's degrees in Animal Science, University of Idaho and Wyoming, respectively, and a PhD. in Rangelands Ecology and Management, Oregon State University. I provide education and research-based information to livestock producers and rangeland managers. I have lead research projects that address payments for ecosystem services that are produced from rangeland management. I am familiar with native and invasive plant and animal species which are found on rangelands in Marin and Sonoma counties and the Point Reyes National Seashore (PRNS).
Agriculture has always been an integral part of the PRNS landscapes; Native American managed these lands for the production of food, fiber and other vital resources (Anderson 2005). Ranching began at Point Reyes when Mexican land grantees introduced the first cattle to the area in the mid-1800$. Dairying soon became a dominant agricultural land use in Point Reyes and Marin County, (Livingston 1994). i have worked with beef and dairy producers at PRNS for over 30 years to provide advice, and to conduct livestock and natural resource projects designed to support, good grazing practices, environmental stewardship, and economically sound ranch management. Some projects with the PRNS beef and dairy producers include short courses on practices to maintain water quality and how to prepare Ecological Site Descriptions (ESD).
Scoping Plan Alternatives:
I have reviewed all the alternative plans that have been present by Point Reyes National Seashore and support the development an alternative that provides for more flexible use of the existing ranches and dairies based on environmental improvements. The additional alternative should provide for operational flexibility, diversification opportunities and a modest expansion of herds over the life of the permits predicated upon the adoption and implementation of forage improvement practices that expand the carrying capacity of the rangeland and successful implementation of water quality improvement and carbon sequestration practices.
Sensitive Species:
Through the 1980s and 1990s and into the early 2000s, efforts to conserve threatened and endangered (special status) species on western rangelands often meant removing livestock ranching. Research findings, demonstration results, and failed conservation efforts in recent years involving endangered species has supported the continuation of livestock ranching and the reintroduction of grazing to some rangelands that were "protected" through grazing removal. At the landscape level, research has demonstrated that livestock ranching maintains extensive, open spaces by reducing land use conversion, fragmentation of habitat, and vegetation type conversion from invasion of brush.
Threats to native biodiversity, including special-status species, are likely to increase with removal or decrease of grazing. Research and experience have shown that grazing is strongly linked to maintaining habitat for some special-status species on PRNS lands, while they have been inconclusive for others. In all cases though, grazing has proven compatible with preservation of the special-status species found at PRNS (Table 1).
Table 1. Special status plants that occur in grazed areas at PRNS (Federally listed plant species per USNPS 2001, and California Native Plant Society plant species per Bob Soost, 2004).
Federally listed as threatened or endangered
Common Name Scientific Name
Sonoma alopecurus Alopecurus aequalis var. sonomensis
Sonoma spineflower Chorizanthe valida
Tiburon paintbrush Castilleja affinis ssp. neglecta
Marin dwarf flax Hesperolinon congestum
beach layia Layia carnosa
Tidestrom's lupine Lupinus
Tidestrom's lupine Lupinus tidestromii
California Native Plant Society rare
Point Reyes horkelia Horkelia marinensis
Point Reyes meadowfoam Limnanthes douglasii ssp. Sulphurea
Sonoma alopecurus (Alopecurus aequalis var. sonomensis) is found in eight naturally occurring populations in Sonoma and Marin Counties; the four sites in Marin County all occur at PRNS and are all grazed by cattle. One historic colony that was located near Botinas disappeared following exclusion of cattle from the site (US Fish & Wildlife Service, (USFWS) 2002). The largest occurrence of Sonoma alopecurus at PRNS is on the former AT&T Ranch, which has been grazed for many decades.
Sonoma spineflower is found solely in a grazed pasture at PRNS. A master's thesis completed in 1992 on the ecology of Sonoma spineflower concluded that grazing of competitive, non-native plants had a positive influence on Sonoma spineflower survival (Davis 1992a and 1992b; USFWS 1998).
Tiburon paintbrush and Marin dwarf flax occur on serpentine grasslands, with six occurrences of Marin dwarf flax on GGNRA grazing lands. PRNS staff concluded that "Marin dwarf flax may benefit from a moderate level of cattle grazing through the reduction of taller competing vegetation as the flax is subject to shading by competing grasses or may be suppressed by buildup of thatch from previous year's herbage if left ungrazed." (USNPS 2001). Beach layia and Tidestrom's lupine are found in dune habitats and do not appear to be dependent on grazing, though many of their occurrences are within grazed pastures (USNPS 2001). Point Reyes horkelia and Point Reyes meadowfoam are also found primarily within grazed areas (Bob Soost 2004).
The relationship of grazing to some threatened and endangered species was reviewed in our U.C. Extension Report co-authored with Marin County, The Changing Role of Agriculture at the Point Reyes National Seashore. The report addresses Myrtle's silverspot butterfly which inhabits coastal dunes, prairie, and scrub.
Habitat suitability depends on numerous factors, but two critical components are the presence of its larval host plant, the native dog violet (Viola adunca), and adult nectar plants including numerous native wildflowers, as well as common weeds such as bull thistle (Cirsium vulgare) and Italian thistle (Carduuspycnocephalus). Most of the Myrtle's silverspot butterflies documented at PRNS have been found in areas that are grazed either by cattle or by tule elk. Butterfly surveys done by PRNS staff in 2003 showed occurrences of Myrtle's silverspot on 13 ranches, all of which support livestock operations (Adams 2004). Recent research on Myrtle's silverspot (Adams 2004; USNPS 2007) documents that Myrtle's silverspot and cattle have co-existed for over a hundred years and that the density of the nectar sources was higher in grazed areas. Biologists studying the Myrtle's silverspot at PRNS recorded more butterflies in grazed dunes and grasslands than in ungrazed plant communities.
At time of listing the USFWS believed that cattle grazing significantly decreased the habitat quality of the Myrtle's silverspot butterfly. However, a five-year status review by USFWS found that the moderate cattle grazing regime currently used at the Pt. Reyes National Seashore did not significantly affect the distribution of Myrtle's silverspot butterfly at that site, https://ecos.fws.gov/docs/five year review/doc2394.pdf. Current threats to the Myrtle's silverspot butterfly include urban or industrial development of any property with suitable habitat for the butterfly, poaching, small population size, the effects of reduced host and nectar plant density due to invasive plants and forbs, road mortalities during the adult flight season, and the probable constriction of the range and distribution of this butterfly due to global climate change.
Grazing exclusions in Point Reyes National Seashore (PRNS) have resulted in extirpation of some populations of special status species from "protected sites." Rancher stewardship, "managed grazing" included development and maintenance of livestock water sources, pest management, debris clean-up, and forage improvement. Ponds developed for livestock water provide half of the available habitat for the endangered tiger salamander (Ambystoma californiense) in the San Francisco Bay Area. These results focus on California's annual rangeland, which is the habitat type where most of the special status species associated western rangelands are found.
In the 1996 final listing rule for the California red-legged frog the USFWS cited livestock grazing as a contributing factor in the decline of the subspecies. However, in its 2006 revised proposed rule, the USFWS acknowledged that:
"our understanding of the threats of livestock grazing and stock pond development described in the previous final listing of the subspecies has changed. Stock pond and small reservoir impoundments can provide suitable breeding habitat for the California red-legged frog. In many areas, the presence of California red legged frogs is due solely to these small ponded habitats. For example, at the Point Reyes National Seashore in Marin County, an area where there are more than 120 breeding sites with an estimated total adult population of several thousand California red-legged frogs, the majority of the breeding sites are within stock ponds constructed on lands that have been grazed by cattle for over 150 years (Fellers and Guscio 2004). In the East Bay Regional Park District (EBRPD) lands in Contra Costa and Alameda counties, 43 of the 179 ponds surveyed (25 percent), which were exposed to grazing and were characterized as with and without emergent vegetation, supported successful breeding frog populations and often exhibited high rates of annual breeding (Bobzien et al. 2000). Ponds can silt in after being fenced off from moderate levels of grazing. EBRPD is currently removing fences and restoring ponds as California red-legged frog habitat (Bobzien pers com. 2005). We now recognize that managed livestock grazing at low to moderate levels has a neutral or beneficial effect on California red-legged frog habitat (Bobzien pers com. 2005) by keeping a mix of open water habitat and emergent vegetation). Therefore, we believe grazing helps contribute to the conservation of the California red-legged frog and its habitat."
I am familiar with rangeland watershed issues, the protection of riparian areas, and the development of ponds and springs to distribute cattle and provide alternative water sources for wildlife. In Marin and Sonoma counties and on PRNS, ranchers have developed numerous springs and ponds to capture runoff to water their cattle. The springs and ponds help to more evenly distribute the forage consumption by cattle across a pasture.
The springs and ponds also provide drinking water for many wildlife species some of which, as discussed above, are rare species that coexist or are enhanced by grazing and the development and maintenance of ponds and springs. In riparian areas such as creeks, good range management may call for fencing to prevent heavy grazing of riparian vegetation but fencing may not always be the best solution. Conversely at Yellowstone National Park, the lack of management of elk caused damaged to riparian areas. In order to managed the elk grazing, the Park introduced wolves into the ecosystem, resulting in the recovery of vegetation in riparian areas; photographs taken at a variety of locations showed considerable recovery of aspen in areas where it had become overgrazed in the years when elk were abundant (Ripple and Beschta, 2012, Ripple and Beschta, 2007).
Although these riparian areas cover only a small area of the ecosystem (<2%), the park witnessed the first significant growth of aspen for over half a century. More recent data suggest that similar recoveries are being seen in cottonwoods and willows (Ripple and Beschta, 2012); this in turn has led to an increase in the abundance and diversity of riparian bird species (Hollenbeck and Ripple 2008).
Residual Dry Matter:
Residual dry matter (RDM) (Bartolome et al. 2006) is the herbaceous plant material -living or dead- left standing or on the ground at the end of the grazing season (typically considered the beginning of October, or the start of the new water year). RDM measurement is commonly used to assess the year's grazing use on annual rangeland, whether moderate, excessive or light. The recommended standards are based on the observation that the amount of RDM remaining in the fail interacts with site conditions and weather to influence rangeland vegetation species composition and forage production in the coming year.
RDM is based upon a percentage of total annual above ground production. Thus, while total recommended RDM may decline from wetter to drier rangeland types, RDM, as a percentage of total production, should actually increase on drier annual rangelands. The long-term implications of reduced RDM should be considered when adjusting RDM targets downward, as reducing RDM as a percentage of total annual production will tend to drive a downward spiral of soil degradation, reduced water-holding capacity and reduced rangeland productivity overtime.
RDM standards are guidelines and it is recommended that local guides be developed for the very reason that production varies on the same mapping unit and ecological site due to differences in weather and growing season length at a given location. Because production is so closely linked to prevailing weather other locations in the same ecological site can vary greatly in production. Thus production estimates from individual ranchers at PRNS should be used whenever possible. Monitoring of RDM can help determine these values are correct over time. Too much RDM left is also a concern; too much RDM could improve the site for annuals, such as medusahead, that flourishes under high RDM levels.
While leaving appropriate amounts of RDM (Residual dry matter) can appear to represent lost grazing opportunity in any given year, consistently low levels of RDM over time can be expected to result in gradual loss of soil organic matter and soil carbon, soil water holding capacity and rangeland productivity. Insufficient soil cover, whether live or dead material, can result in a downward spiral of declining rangeland condition. In this sense, RDM can be understood as an investment in the long-term productive capacity of the land, albeit at the "cost" of current season's total grazing capacity. Because of the limited amount of site-specific research information, however, RDM standards normally must be developed using local experience and general guidelines, particularly on perennial pastures.
Unmanaged grazing, as in a "free-ranging elk herd", has shown to result in over grazed and under grazed areas. Ungrazed areas over time can result in a buildup of dead grass on the other side of the fence where grazing is excluded, and a thick mass of dead grass forms that prevents native plants from germinating and growing. The mass of dead grass can be overcome by invasive species such as coyote brush and Himalayan blackberry. The buildup of dead grass results in a less than healthy system, which could lead to increased erosion, reduced nutrient and water cycling and increased fire hazards.
In the General Management Planning (GMP) Amendment process, PRNS staff are being asked to:
• Work collaboratively with each respective rancher to identify RDM monitoring locations that accurately represent the landscape and managed grazing lands. Existing RDM monitoring locations have proven to be useful for other management objectives and are not located where they reflect ongoing rangeland and grazing livestock management.
• Develop RDM monitoring clear methodologies with documentation that clearly communicates how to conduct measurements, compile and analyze the date, and report the results. This will avoid confusion, and even potentially misleading use of RDM monitoring and result reporting, that does not clearly explain if specific plant species or function groups are excluded from the RDM monitoring program and the implications of that exclusion.
In my experience and in working with, the ranchers at the PRNS, they are well informed about practices that can be beneficial and detrimental to wildlife, water quality, and rangeland health and they have strived to implement those practices that maintain and improve rangeland and watershed conditions, s They are well aware of RDM and manage their animal to meet the required levels. Conversely, with a "free roaming" elk herd, these levels will not be meet and will be detrimental to special status species in PRNS. They fully cooperate with myself at U.C. Cooperative Extension, Kristan Norman, at U.S.D.A. Natural Resource Conservation Service, along with National Park Service personnel.
The PRNS should have an alternative with elk removed from the grazing areas; especially areas in the pastoral zone that contain special status species. At the Rocky Mountain National Park, elk and vegetation management is guided by a 20-year plan that addresses the impacts of overabundant elk on vegetation. This plan's goal is restore the natural range of variability in the elk population and affected plant communities. The plan relies on a variety of conservation tools including temporary fencing, vegetation restoration, redistribution and culling; and may use additional management tools in the future using adaptive management principles. In 1998, Point Reyes National Seashore adopted their Elk Management Plan; in that plan the Park states there will be careful monitoring of both elk and threatened and endangered species is important to ensure that the Seashore's management of elk is not harming T&E species. There has been no monitoring of the elk's impact to these species as they expand past their 1998 borders. In the Rocky Mountain National Park elk management plan, recognizing the importance of monitoring elk grazing as it can adversely affect special status species.
Therefore, the elk should be removed from the pastoral zone where these special status exists currently because:
• The elk can damage the ecosystem because they're not managed
• They have plenty of grazing at Limantour and Tomales Point
• Ranchers should be the grazing stewards in the pastoral zone
• It is better for the natural resources in the pastoral zone.
Livestock producer's implement best management practices including brush control, weed, control, invasive species removal and sequestering of atmosphere carbon in rangelands soils. The results of livestock grazing should be measured by resource goals; goals that include residual dry matter, plant diversity, plant density and species competition. Livestock producer know best the stock density and rate to meet resource goals; and grazing animal numbers should not be limited by arbitrarily pre-set maximum animal numbers.
PRNS pastoral zone lands provide a direct link between urban consumers and local food producers, a powerful conduit for educating the public about the importance of local food production and security. Sonoma and Marin Counties are perfect models for demonstrating how preserving family farms, contribute to social, economic and ecological sustainability at local, regional and even national levels. Ranching and farming have positive health impacts including increased food access and food security, food to local business and schools, improved health literacy and general well-being. Ranching in Sonoma and Marin Counties, including PRNS, albeit smaller scale, remains a local industry which provides job creation, training and business succession, and market expansion for many other ranchers and farmers.
Ranchers should be allowed and encouraged by the Point Reyes National Seashore to allow continued and diversified ranching activities to include small scale historic plant and animal production because it more properly represents the important historic period (1860-1960) that the Park is entrusted to protect. There will be an increase in sustainability because:
• It will add interest for the next generation of livestock producers
• Connects the producers to the local food system
• Expands the cow monoculture; making it more interesting, educational and historically accurate.
 
___________________________
# 2937
Name: Larson, Stephanie
Correspondence: My name is Dr. Stephanie Larson, and I work for the University of California Cooperative Extension. I am currently the Director of the University of California Cooperative Extension for Sonoma County and have worked with dairy producers, livestock producers, and rangeland managers in Marin and Sonoma Counties over my career. I have Bachelor's and Master's degrees in Animal Science, University of Idaho and Wyoming, respectively, and a PhD. in Rangelands Ecology and Management, Oregon State University. I provide education and research-based information to livestock producers and rangeland managers. I have lead research projects that address payments for ecosystem services that are produced from rangeland management. I am familiar with native and invasive plant and animal species which are found on rangelands in Marin and Sonoma counties and the Point Reyes National Seashore (PRNS).
Agriculture has always been an integral part of the PRNS landscapes; Native American managed these lands for the production of food, fiber and other vital resources (Anderson 2005). Ranching began at Point Reyes when Mexican land grantees introduced the first cattle to the area in the mid-1800$. Dairying soon became a dominant agricultural land use in Point Reyes and Marin County, (Livingston 1994). i have worked with beef and dairy producers at PRNS for over 30 years to provide advice, and to conduct livestock and natural resource projects designed to support, good grazing practices, environmental stewardship, and economically sound ranch management. Some projects with the PRNS beef and dairy producers include short courses on practices to maintain water quality and how to prepare Ecological Site Descriptions (ESD).
Scoping Plan Alternatives:
I have reviewed all the alternative plans that have been present by Point Reyes National Seashore and support the development an alternative that provides for more flexible use of the existing ranches and dairies based on environmental improvements. The additional alternative should provide for operational flexibility, diversification opportunities and a modest expansion of herds over the life of the permits predicated upon the adoption and implementation of forage improvement practices that expand the carrying capacity of the rangeland and successful implementation of water quality improvement and carbon sequestration practices.
Sensitive Species:
Through the 1980s and 1990s and into the early 2000s, efforts to conserve threatened and endangered (special status) species on western rangelands often meant removing livestock ranching. Research findings, demonstration results, and failed conservation efforts in recent years involving endangered species has supported the continuation of livestock ranching and the reintroduction of grazing to some rangelands that were "protected" through grazing removal. At the landscape level, research has demonstrated that livestock ranching maintains extensive, open spaces by reducing land use conversion, fragmentation of habitat, and vegetation type conversion from invasion of brush.
Threats to native biodiversity, including special-status species, are likely to increase with removal or decrease of grazing. Research and experience have shown that grazing is strongly linked to maintaining habitat for some special-status species on PRNS lands, while they have been inconclusive for others. In all cases though, grazing has proven compatible with preservation of the special-status species found at PRNS (Table 1).
Table 1. Special status plants that occur in grazed areas at PRNS (Federally listed plant species per USNPS 2001, and California Native Plant Society plant species per Bob Soost, 2004).
Federally listed as threatened or endangered
Common Name Scientific Name
Sonoma alopecurus Alopecurus aequalis var. sonomensis
Sonoma spineflower Chorizanthe valida
Tiburon paintbrush Castilleja affinis ssp. neglecta
Marin dwarf flax Hesperolinon congestum
beach layia Layia carnosa
Tidestrom's lupine Lupinus
Tidestrom's lupine Lupinus tidestromii
California Native Plant Society rare
Point Reyes horkelia Horkelia marinensis
Point Reyes meadowfoam Limnanthes douglasii ssp. Sulphurea
Sonoma alopecurus (Alopecurus aequalis var. sonomensis) is found in eight naturally occurring populations in Sonoma and Marin Counties; the four sites in Marin County all occur at PRNS and are all grazed by cattle. One historic colony that was located near Botinas disappeared following exclusion of cattle from the site (US Fish & Wildlife Service, (USFWS) 2002). The largest occurrence of Sonoma alopecurus at PRNS is on the former AT&T Ranch, which has been grazed for many decades.
Sonoma spineflower is found solely in a grazed pasture at PRNS. A master's thesis completed in 1992 on the ecology of Sonoma spineflower concluded that grazing of competitive, non-native plants had a positive influence on Sonoma spineflower survival (Davis 1992a and 1992b; USFWS 1998).
Tiburon paintbrush and Marin dwarf flax occur on serpentine grasslands, with six occurrences of Marin dwarf flax on GGNRA grazing lands. PRNS staff concluded that "Marin dwarf flax may benefit from a moderate level of cattle grazing through the reduction of taller competing vegetation as the flax is subject to shading by competing grasses or may be suppressed by buildup of thatch from previous year's herbage if left ungrazed." (USNPS 2001). Beach layia and Tidestrom's lupine are found in dune habitats and do not appear to be dependent on grazing, though many of their occurrences are within grazed pastures (USNPS 2001). Point Reyes horkelia and Point Reyes meadowfoam are also found primarily within grazed areas (Bob Soost 2004).
The relationship of grazing to some threatened and endangered species was reviewed in our U.C. Extension Report co-authored with Marin County, The Changing Role of Agriculture at the Point Reyes National Seashore. The report addresses Myrtle's silverspot butterfly which inhabits coastal dunes, prairie, and scrub.
Habitat suitability depends on numerous factors, but two critical components are the presence of its larval host plant, the native dog violet (Viola adunca), and adult nectar plants including numerous native wildflowers, as well as common weeds such as bull thistle (Cirsium vulgare) and Italian thistle (Carduuspycnocephalus). Most of the Myrtle's silverspot butterflies documented at PRNS have been found in areas that are grazed either by cattle or by tule elk. Butterfly surveys done by PRNS staff in 2003 showed occurrences of Myrtle's silverspot on 13 ranches, all of which support livestock operations (Adams 2004). Recent research on Myrtle's silverspot (Adams 2004; USNPS 2007) documents that Myrtle's silverspot and cattle have co-existed for over a hundred years and that the density of the nectar sources was higher in grazed areas. Biologists studying the Myrtle's silverspot at PRNS recorded more butterflies in grazed dunes and grasslands than in ungrazed plant communities.
At time of listing the USFWS believed that cattle grazing significantly decreased the habitat quality of the Myrtle's silverspot butterfly. However, a five-year status review by USFWS found that the moderate cattle grazing regime currently used at the Pt. Reyes National Seashore did not significantly affect the distribution of Myrtle's silverspot butterfly at that site, https://ecos.fws.gov/docs/five year review/doc2394.pdf. Current threats to the Myrtle's silverspot butterfly include urban or industrial development of any property with suitable habitat for the butterfly, poaching, small population size, the effects of reduced host and nectar plant density due to invasive plants and forbs, road mortalities during the adult flight season, and the probable constriction of the range and distribution of this butterfly due to global climate change.
Grazing exclusions in Point Reyes National Seashore (PRNS) have resulted in extirpation of some populations of special status species from "protected sites." Rancher stewardship, "managed grazing" included development and maintenance of livestock water sources, pest management, debris clean-up, and forage improvement. Ponds developed for livestock water provide half of the available habitat for the endangered tiger salamander (Ambystoma californiense) in the San Francisco Bay Area. These results focus on California's annual rangeland, which is the habitat type where most of the special status species associated western rangelands are found.
In the 1996 final listing rule for the California red-legged frog the USFWS cited livestock grazing as a contributing factor in the decline of the subspecies. However, in its 2006 revised proposed rule, the USFWS acknowledged that:
"our understanding of the threats of livestock grazing and stock pond development described in the previous final listing of the subspecies has changed. Stock pond and small reservoir impoundments can provide suitable breeding habitat for the California red-legged frog. In many areas, the presence of California red legged frogs is due solely to these small ponded habitats. For example, at the Point Reyes National Seashore in Marin County, an area where there are more than 120 breeding sites with an estimated total adult population of several thousand California red-legged frogs, the majority of the breeding sites are within stock ponds constructed on lands that have been grazed by cattle for over 150 years (Fellers and Guscio 2004). In the East Bay Regional Park District (EBRPD) lands in Contra Costa and Alameda counties, 43 of the 179 ponds surveyed (25 percent), which were exposed to grazing and were characterized as with and without emergent vegetation, supported successful breeding frog populations and often exhibited high rates of annual breeding (Bobzien et al. 2000). Ponds can silt in after being fenced off from moderate levels of grazing. EBRPD is currently removing fences and restoring ponds as California red-legged frog habitat (Bobzien pers com. 2005). We now recognize that managed livestock grazing at low to moderate levels has a neutral or beneficial effect on California red-legged frog habitat (Bobzien pers com. 2005) by keeping a mix of open water habitat and emergent vegetation). Therefore, we believe grazing helps contribute to the conservation of the California red-legged frog and its habitat."
I am familiar with rangeland watershed issues, the protection of riparian areas, and the development of ponds and springs to distribute cattle and provide alternative water sources for wildlife. In Marin and Sonoma counties and on PRNS, ranchers have developed numerous springs and ponds to capture runoff to water their cattle. The springs and ponds help to more evenly distribute the forage consumption by cattle across a pasture.
The springs and ponds also provide drinking water for many wildlife species some of which, as discussed above, are rare species that coexist or are enhanced by grazing and the development and maintenance of ponds and springs. In riparian areas such as creeks, good range management may call for fencing to prevent heavy grazing of riparian vegetation but fencing may not always be the best solution. Conversely at Yellowstone National Park, the lack of management of elk caused damaged to riparian areas. In order to managed the elk grazing, the Park introduced wolves into the ecosystem, resulting in the recovery of vegetation in riparian areas; photographs taken at a variety of locations showed considerable recovery of aspen in areas where it had become overgrazed in the years when elk were abundant (Ripple and Beschta, 2012, Ripple and Beschta, 2007).
Although these riparian areas cover only a small area of the ecosystem (<2%), the park witnessed the first significant growth of aspen for over half a century. More recent data suggest that similar recoveries are being seen in cottonwoods and willows (Ripple and Beschta, 2012); this in turn has led to an increase in the abundance and diversity of riparian bird species (Hollenbeck and Ripple 2008).
Residual Dry Matter:
Residual dry matter (RDM) (Bartolome et al. 2006) is the herbaceous plant material -living or dead- left standing or on the ground at the end of the grazing season (typically considered the beginning of October, or the start of the new water year). RDM measurement is commonly used to assess the year's grazing use on annual rangeland, whether moderate, excessive or light. The recommended standards are based on the observation that the amount of RDM remaining in the fail interacts with site conditions and weather to influence rangeland vegetation species composition and forage production in the coming year.
RDM is based upon a percentage of total annual above ground production. Thus, while total recommended RDM may decline from wetter to drier rangeland types, RDM, as a percentage of total production, should actually increase on drier annual rangelands. The long-term implications of reduced RDM should be considered when adjusting RDM targets downward, as reducing RDM as a percentage of total annual production will tend to drive a downward spiral of soil degradation, reduced water-holding capacity and reduced rangeland productivity overtime.
RDM standards are guidelines and it is recommended that local guides be developed for the very reason that production varies on the same mapping unit and ecological site due to differences in weather and growing season length at a given location. Because production is so closely linked to prevailing weather other locations in the same ecological site can vary greatly in production. Thus production estimates from individual ranchers at PRNS should be used whenever possible. Monitoring of RDM can help determine these values are correct over time. Too much RDM left is also a concern; too much RDM could improve the site for annuals, such as medusahead, that flourishes under high RDM levels.
While leaving appropriate amounts of RDM (Residual dry matter) can appear to represent lost grazing opportunity in any given year, consistently low levels of RDM over time can be expected to result in gradual loss of soil organic matter and soil carbon, soil water holding capacity and rangeland productivity. Insufficient soil cover, whether live or dead material, can result in a downward spiral of declining rangeland condition. In this sense, RDM can be understood as an investment in the long-term productive capacity of the land, albeit at the "cost" of current season's total grazing capacity. Because of the limited amount of site-specific research information, however, RDM standards normally must be developed using local experience and general guidelines, particularly on perennial pastures.
Unmanaged grazing, as in a "free-ranging elk herd", has shown to result in over grazed and under grazed areas. Ungrazed areas over time can result in a buildup of dead grass on the other side of the fence where grazing is excluded, and a thick mass of dead grass forms that prevents native plants from germinating and growing. The mass of dead grass can be overcome by invasive species such as coyote brush and Himalayan blackberry. The buildup of dead grass results in a less than healthy system, which could lead to increased erosion, reduced nutrient and water cycling and increased fire hazards.
In the General Management Planning (GMP) Amendment process, PRNS staff are being asked to:
• Work collaboratively with each respective rancher to identify RDM monitoring locations that accurately represent the landscape and managed grazing lands. Existing RDM monitoring locations have proven to be useful for other management objectives and are not located where they reflect ongoing rangeland and grazing livestock management.
• Develop RDM monitoring clear methodologies with documentation that clearly communicates how to conduct measurements, compile and analyze the date, and report the results. This will avoid confusion, and even potentially misleading use of RDM monitoring and result reporting, that does not clearly explain if specific plant species or function groups are excluded from the RDM monitoring program and the implications of that exclusion.
In my experience and in working with, the ranchers at the PRNS, they are well informed about practices that can be beneficial and detrimental to wildlife, water quality, and rangeland health and they have strived to implement those practices that maintain and improve rangeland and watershed conditions, s They are well aware of RDM and manage their animal to meet the required levels. Conversely, with a "free roaming" elk herd, these levels will not be meet and will be detrimental to special status species in PRNS. They fully cooperate with myself at U.C. Cooperative Extension, Kristan Norman, at U.S.D.A. Natural Resource Conservation Service, along with National Park Service personnel.
The PRNS should have an alternative with elk removed from the grazing areas; especially areas in the pastoral zone that contain special status species. At the Rocky Mountain National Park, elk and vegetation management is guided by a 20-year plan that addresses the impacts of overabundant elk on vegetation. This plan's goal is restore the natural range of variability in the elk population and affected plant communities. The plan relies on a variety of conservation tools including temporary fencing, vegetation restoration, redistribution and culling; and may use additional management tools in the future using adaptive management principles. In 1998, Point Reyes National Seashore adopted their Elk Management Plan; in that plan the Park states there will be careful monitoring of both elk and threatened and endangered species is important to ensure that the Seashore's management of elk is not harming T&E species. There has been no monitoring of the elk's impact to these species as they expand past their 1998 borders. In the Rocky Mountain National Park elk management plan, recognizing the importance of monitoring elk grazing as it can adversely affect special status species.
Therefore, the elk should be removed from the pastoral zone where these special status exists currently because:
• The elk can damage the ecosystem because they're not managed
• They have plenty of grazing at Limantour and Tomales Point
• Ranchers should be the grazing stewards in the pastoral zone
• It is better for the natural resources in the pastoral zone.
Livestock producer's implement best management practices including brush control, weed, control, invasive species removal and sequestering of atmosphere carbon in rangelands soils. The results of livestock grazing should be measured by resource goals; goals that include residual dry matter, plant diversity, plant density and species competition. Livestock producer know best the stock density and rate to meet resource goals; and grazing animal numbers should not be limited by arbitrarily pre-set maximum animal numbers.
PRNS pastoral zone lands provide a direct link between urban consumers and local food producers, a powerful conduit for educating the public about the importance of local food production and security. Sonoma and Marin Counties are perfect models for demonstrating how preserving family farms, contribute to social, economic and ecological sustainability at local, regional and even national levels. Ranching and farming have positive health impacts including increased food access and food security, food to local business and schools, improved health literacy and general well-being. Ranching in Sonoma and Marin Counties, including PRNS, albeit smaller scale, remains a local industry which provides job creation, training and business succession, and market expansion for many other ranchers and farmers.
Ranchers should be allowed and encouraged by the Point Reyes National Seashore to allow continued and diversified ranching activities to include small scale historic plant and animal production because it more properly represents the important historic period (1860-1960) that the Park is entrusted to protect. There will be an increase in sustainability because:
• It will add interest for the next generation of livestock producers
• Connects the producers to the local food system
• Expands the cow monoculture; making it more interesting, educational and historically accurate.
 
___________________________
# 2938
Name: Lunny, Kevin
Correspondence: The Point Reyes Seashore Ranchers Association (PRSRA), on behalf of all of its members, and the undersigned individuals appreciate the opportunity to comment on the Point Reyes National Seashore (PRNS) and North District of Golden Gate National Recreation Area (GGRNA), (collectively the "Seashore"), General Management Plan (GMP) Amendment process and the subsequent National Environmental Policy Act (NEPA) review. We understand this to be the first of several scoping and issue identification steps as part of the GMP and NEPA processes.
The GMP Amendment is the foundation for providing the cultural resource, natural resource, and economic benefits envisioned by Congress when it established and preserved these magnificent areas and provided for continued ranching and dairying in the Pastoral Zone. The Association and the undersigned individuals are honored and grateful to be part of this longstanding history and we take great pride in continuing to ensure that ranching and dairying contribute to the agricultural heritage of Marin County and promote the environmental and scenic quality of the working landscapes of the Seashore. Accordingly, we offer the following high-level comments for consideration during this public comment period and we will participate fully in subsequent stages and opportunities to discuss the future of the GMP for the Point Reyes National Seashore and Golden Gate National Recreation Area. *
* We note the expedited way this GMP/EIS process is proceeding with an unusually short notice given to interested parties to provide initial comments on the GMP alternatives and key issues. NPS initially set a very tight deadline of 20 days from its open houses (and only 30 days from the initial request for comments) for the public to digest a voluminous administrative history and complicated Settlement Agreement. Then a one-week extension was provided. While we support NPS moving forward with due deliberation, we reserve the right to provide further comments on the scoping alternatives, major issues, and provide key information as the GMP and EIS are developed.
I. Purpose and Need
believe it is prudent for NPS to include early on a section on Purpose and Need as a framework establishing the long-term management of the 28,000 acre Pastoral Zone. This comprehensive direction should include the overall goals for sustainable dairy and beef ranching in the Seashore with terms of at least 20 years.
Ranching has a long and important history on the Point Reyes peninsula and adjacent National Park Service lands. These working ranches are a vibrant part of the culture of the Point Reyes National Seashore and represent an important contribution to the superlative natural and scenic resources of these NPS lands. Protection of these diverse and unique resources is an important responsibility shared by the NPS and Seashore ranchers within the Pastoral Zone.
A comprehensive management plan is needed:
• To articulate a clear vision for ranching on existing ranch lands in the Pastoral Zone administered by Point Reyes National Seashore.
• To allow for issuance of leases with terms of at least 20 years to provide for maintenance and improvement of ranching infrastructure, the working landscape, and the associated environment.
• To address concerns related to tule elk impacts on the environment and working ranches.
• To provide clear guidance and streamline processes for Seashore and regulatory review of proposed ranching activities, including best management practices that promote protection of Seashore resources.
II. Alternatives
While the Settlement Agreement identified three alternatives that were to be evaluated in the Environmental Impact Statement (EIS), it is also clear that the National Park Service (NPS) is authorized to consider a full range of alternatives that we believe must include additional options for Point Reyes. The NPS GMP notice includes three additional alternatives which we agree should be part of its review. Added to this list we urge consideration of several modifications or expansions of the existing list of alternatives referenced by NPS:
We envision a somewhat expanded alternative building off the second "Continued Ranching Alternative" proposed by NPS whereby NPS would allow for limited additional opportunities in fanning and diversified agricultural production to complement existing ranching and dairy activities.
We believe that such limited additional uses would provide multiple economic and educational benefits to the community and would strengthen the overall agricultural economy of our region. We are not proposing in this alternative expanding beyond the current 28,000 acre Pastoral Zone. In addition, in this alternative, we would ask that NPS consider a somewhat longer lease term (25-30 years) for ranches and dairies to facilitate investments in our agricultural infrastructure that will make us more productive, efficient, and protective of the environment. The added term can help us amortize such measures in a sustainable, long term fashion.
An additional modification to this Continued Ranching Alternative would be consideration of forage improvement practices which could result in modest additions to existing herds and dairy farms consistent with water quality improvements and carbon sequestration practices.
We also ask NPS to include an alternative or modify existing alternatives that would remove the free- range elk herds (Drakes Beach and Limantour) from the Pastoral Zone. This would provide the best solution for eliminating ongoing, documented conflicts that occur to historic, ranching, and cultural resources. The 1998 Elk Management Plan provides for this and the nearly 20 years of mixed and frustrating results in implementing alternative practices to reduce conflicts in forage use and infrastructure upkeep demonstrate why this alternative has merit. The scoping notice description of alternatives is misleading in that it presumes today's extent of the elk herds is currently approved in the existing GMP. That said, we support continuation of the herd in other areas within PRNS but outside the pastoral areas.
Finally, we suggest that the "Reduced Ranching" alternative contains no justifiable rationale for its proposed reductions and should be amended to reduce ranching only where there is an arguably justifiable reason. No such reason is apparent in this initial description of the alternative.
m. Issues
A. Economic analysis
Reducing or eliminating ranching and dairies from Point Reyes would have profound adverse economic consequences for the local and regional economy. These family ranches are essential to many local and regional businesses and represent an important cultural and economic way of life that extends beyond the Seashore. The ranches are a critical part of that cultural mosaic of estuaries, lagoons, ridges, hillsides, forests, and beautiful grasslands that make up the overall environment which in turn attract thousands of visitors every year. Without the stewardship of the ranching community, much of this landscape would not be there today. The GMP and EIS must assess these positive and important economic benefits not only to the ranching and dairy families but to the broader region as a whole.
Local employment, changes to demographics, and local community well-being must be considered. Even our local school system is heavily dependent upon the enrollment of students from ranching families.
B. Diversification
The GMP/EIS process should evaluate a variety of additional agricultural and related activities that could help to strengthen the area's economy, build on its tourism base, and bring high quality educational programs to the area. These complementary uses add to the sustainability of the ranches and ranching families while enhancing visitor experiences.
Diversification can include selected planted or naturally occurring crops, additional livestock production, farm stands and retail sales, processing and value-added production, farm stays, farm educational tours, expanded work with the school systems and 4-H organizations. Think of the community benefits that would come from a comprehensive NPS educational/tourism program celebrating the cultural history of the area and its contribution to ranching and agriculture.
Consideration of on farm grown and stored livestock feed of silage and hay should be included in this examination. This long-standing farming practice combines the benefits of critical seasonal forage production with effective weed management, balanced herd nutrition and distribution management. It also reduces the need for imported supplemental feed and incentivizes effective on-site resource use and ranch resiliency.
C. Succession
We encourage the GMP and EIS to review the all-important issue of succession to current and future leases. One overall goal of NPS should be to ensure that current families continue their stewardship of existing ranch and dairy lands, and provide a continuity of ownership going forward. But in the event that families choose not to continue ranching and dairies, how best can NPS continue agricultural operations on the affected land? The key operative is to continue this rich heritage and the environmental stewardship that accompanies it. Thinking through the issue of succession with the families of current lessees, and then, if necessary (because those families can no longer continue anching), looking to other parties interested in continuing ranching and agriculture at the Seashore should be a component of the GMP.
Within this framework, we know the past experience and judgment of existing ranching families will provide important guidance to NPS.
D. Environmental Stewardship and Best Management Practices
The Association and the individual ranching families support implementation of best management practices (BMP) for ranching, dairy, and other agriculture activities. The GMP and accompanying EIS should evaluate these BMPs to insure their applicability, practicality, and success in protecting the environment and insuring economic viability... all of which is consistent with federal, state, and local requirements. As we have done frequently in the past, the ranching community is prepared to step forward to assist with important environmental projects ranging from preserving threatened species to improving water quality. We continue to be willing participants in considering, where feasible and necessary, other environmental measures that may add to the success of BMPs in protecting the natural values of the Seashore.
With respect to methane and climate change, we believe the GMP/EIS should address how local ranches and dairies may play an important role in mitigating such impacts, potentially through carbon offsets and other payments for environmental services. Marin County and the State of California are leaders in this area and we welcome the opportunity to work with them as part of this effort. We also believe that a variety of public and private partners may provide important technical and financial resources to assist in this effort. NPS and the ranching community at the Seashore can develop state- of-art approaches and serve as a model for programs elsewhere.
E. Operational Flexibility
Regular infrastructure maintenance and repair at the Seashore has often been delayed for extended periods of time in part because guidelines are unclear or nonexistent. The GMP should contain more specific guidelines so critical work can be efficiently authorized by NPS in the future. In the coming months while the GMP progresses, we would welcome a working group to develop appropriate guidelines to assist the agency in more efficient and timely decision-making and allow effective management of weeds, fire fuels, protect water quality, livestock watering and distribution, and other field and ranch level concerns.
F. Tule Elk
While we support manageable populations of tule elk at Tomales Point and the Limantour Wilderness, we strongly urge NPS to adopt a GMP amendment that provides all the necessary tools to prevent elk from occupying the pastoral areas within the Seashore and insure that overpopulation of tule elk will not occur. Conflicts caused by the elk with existing ranches and dairies are well documented as is the spread of disease and associated environmental impacts. NPS has correctly expressed its concern about the difficulty and expense of managing tule elk outside the Tomales Point and Limantour Wilderness areas and explained that "The 1998 Tule Elk Management Plan/EA did not contemplate the expansion of tule elk into the pastoral lands." The GMP amendment should provide for removal of tule elk outside of Tomales Point and Limantour areas by using all effective means including full cooperation with the California Department of Fish and Wildlife.
G. Leases
To ensure consistency and facilitate clear understanding of forthcoming requirements and operational issues, it would be helpful for the GMP and EIS to contain a draft lease template. We urge NPS to meet with PRSRA and individual ranchers to discuss past leasehold provisions and where new approaches can be adopted to reflect important on-the-ground considerations.
We thank you for the opportunity to provide these initial comments and we look forward to working with NPS on all subsequent stages of the GMP and EIS.
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# 2939
Name: Martinelli, Peter J
Correspondence: Dear Superintendent MacLeod;
As a direct neighbor of the Seashore and ardent advocate for the future of agriculture in Marin County, I very much appreciate the opportunity to offer comments in the General Management Plan update process. I have operated a 25 acre organic crop farm on my family's ranch along Pine Gulch Creek for over 20 years. I am a former board member of the Marin Agricultural Land Trust, current board member of the Marin Resource Conservation District and the Marin County Farm Bureau. I am also a board member of the Wild Farm Alliance, a national organization that seeks to balance the needs of agriculture and wildlife on working lands.
For over 15 years two neighboring farmers and I worked collaboratively with PRNS staff to design and implement the Pine Gulch Watershed Enhancement Project, a model of water management in California. This project has insured the future viability of our farms, while improving instream habitat for endangered coho salmon and steelhead trout. In this spirit of the Park Service and farmers working together for the benefit of wildlife and agriculture, I offer the following comments in support of continuing the tradition of ranching in the Pt. Reyes National Seashore.
I would like to first respond to the question the NPS posed in its letter to Interested Parties that asks, "What types of specific strategies can/should be considered for managing agricultural leases/permits":
Leases and Management:
The leasing policy for PRNS ranches should be applied equally among all lease holders and not continue as a piecemeal process, leaving some landowners dangling on a year to year basis, while others hold leases that run through a rancher's lifetime. Short term leases put Seashore ranchers at a tremendous disadvantage when applying for farm loans and farm credit. To remain viable, Seashore ranches must have the access to credit that their competitors enjoy.
Twenty - year leases with an automatic five year roll-over would greatly incentivize leaseholders to properly maintain ranch infrastructure and historic structures. Long term leases would also incline ranchers to invest in long term practices such as regularly applying compost and cover crops to improve soil quality and sequester carbon in the soil. Such practices prevent erosion and improve water quality over time, ultimately benefiting natural resources and wildlife.
In a broader sense I encourage the PRNS to adopt the pro-active approach to agriculture as demonstrated by the Cuyahoga National Park in Ohio where agricultural leaseholders have been fully embraced as part of the ethos and experience of that NPS unit. The leases are up to 60 years (From Darwin Kelsey - founder and E.D. of the Countryside Initiative). Rather than NPS staff having to navigate the intricacies of agricultural management, Cuyahoga Park established the Countryside Initiative Program to manage the farms. This successful program is interactive, allowing the public to experience the farms, purchase farm products and learn about the agrarian history within the park.
Currently it seems that the ranches in Pt. Reyes are more or less tolerated as a holdover from a bygone era, rather than embraced and celebrated as the farms in Cuyahoga are. Transitioning to such a management model would benefit both ranchers and PRNS. Strong support of ranching in PRNS will also further the vital role (20 percent of active farmland) that the Seashore ranches play in the agricultural economy of Marin County.
I strongly encourage PRNS to better understand and further embrace the management benefit of having ranchers operate in the Pastoral Zone. My family's ranch, Paradise Valley Ranch, is surrounded by defunct ranches, acquired by the Park Service in the 1970s and designated wilderness. These tracts - the former RCA (above Mesa Rd.), Palomarin, Texeira, and Rancho Las Baulines (ranching ended 1999), have evolved into out of control sources of invasive weeds. Star thistle, Scotch broom, eucalyptus and others, are freely propagating on these properties and polluting the Bolinas Lagoon watershed with seed. New patches are popping up annually on PRNS land, County of Marin lands, and private lands.
On our property we must constantly manage the annual influx of invasive seed stock from these abandoned/unmanaged PRNS ranches. This problem impacts the entire watershed from Dogtown to Bolinas Lagoon, the Southern reach of Inverness Ridge and the steppes of Bolinas Ridge. If ranching were retained on these tracts, we would not have this exploding weed problem. Based upon this past experience, I am confident that any reduction of ranching on the Pt. Reyes Peninsula and Bolinas Peninsula would have the same damaging effect of an invasive weed explosion. In a nutshell, I encourage PRNS to embrace ranchers as partners in managing the land and its resources.
A deepening embrace and broadening support of ranching in the PRNS would foster more collaboration with the agencies that implement improvements on ranchland that benefit wildlife and protect natural resources. I am speaking of the RCD - Marin Resource Conservation District (See their letter), and the USDA Equip program. As an RCD board member, I can attest to our work which involves controlling invasive weeds, correcting erosion issues, fencing livestock out of creeks/wetlands, and improving water access to evenly spread livestock around pasture land. In a time of NPS budget shortfalls, these agencies can provide services and funding for projects that benefit the PRNS ranchers and natural resources.
Beyond The Six Alternatives:
The ranches in the PRNS should not be viewed one dimensionally as historic artifacts stuck in 20th century agriculture. They need to be able to operate and thrive in the 21st century agricultural economy. While there is great fear around diversification on the part of environment advocates, in reality diversification is the leading edge of the sustainable agriculture movement. Properly managed, rotated animal and crop agriculture that mimic natural processes are much more symbiotic with surrounding eco systems than mono cultures. Creating a closed circuit of nutrient cycling on a ranch or farm, such as permitting chickens on cattle pastures or rotating row crops plots with pastures, is proven to be beneficial to soil health. While grazing is the historic and naturally suited activity for PRNS ranches, diversification options should always be available for ranch operators to implement in the right circumstances that account for access to water, slope, and sensitive habitat areas. While there is a fear of rampant row cropping, in reality appropriate row crop areas in PRNS are limited.
The PRNS should go beyond the suggested alternatives and consider re -establishing ranches around the village of Bolinas. The old idea that former ranch lands will naturally revert to wilderness is nonsense. Most of these former lands become enormous weed patches. A revival of restorative, organic ranching is far superior to letting old ranch land go unmanaged. Besides the invasive weed issue from 40 years of non-management, the proliferation of brush and fuels on these former grazing lands present an enormous fire threat to the Bolinas Peninsula and Dogtown. If the former RCA ranch (above Mesa Rd.), Texiera , and Rancho las Baulines were returned to grazing the weed and fire issues could be properly addressed, saving the Park Service management costs and providing the residents of Bolinas a measure of protection from wildfires.
The issue of tule elk roaming on to ranch land is a much larger, unaddressed issue that has been allowed to spill into this GMP - ranching process. Re introducing a high impact, large herbivore into a dis functional eco system, void of bears and wolves, etc. is asking for trouble. The over population of elk and unfortunate die-off two years ago are evidence enough of this overarching problem. It is unfair for the PRNS to allow the mismanagement of the elk herd become a driving influence in this GMP process. Tule elk in other areas of California are managed properly by California Fish and Wildlife. Besides removing the elk from the designated pastoral zone, PRNS should consider allowing Ca. Fish and Wildlife to assume management, or implement some of their successful management tools, such as special hunts that generate revenue. Grizzly bears and wolves are not a viable option in our region.
Superintendent McLeod, I very much appreciate the consideration of my comments. I look forward to continuing to participate in the GMP process.
 
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# 2940
Name: McDonald, McDonald, Huld, Fuschi, L. , Merrin, Marshal, Ross, Kathleen, GF
Correspondence: Superintendent MacLeod,
Concerning the alternative: "Reduced Ranching and Management of the Drakes Beach Tule Elk Herd"
It is our strong opinion that both the Drakes Beach elk herd and the Limantour elk herd must be put back into the wilderness where the 1998 Tule Elk Management plan intended for them to be.
The problems caused by elk with existing ranches is well documented - disease, damaged fences, consumption of grasses, etc.
Also this alternative should not cease ranching just for the sake of eliminating ranches because there are no building on them. We recommend fencing out the actual sensitive areas. The fenced out sensitive areas would be removed from the leases and considered reduced ranching.
We are 5 generation ranchers in Marin County. We are currently 3 generations ranching in PRNS. Our matriarch is 94 years old and is still active in all ranching decisions. We have leased the N Ranch for 50 years and have leased the Home Ranch for 14 years.
Our family has already been displaced by NPS. In 1980 we were kicked off Pierce Point Ranch for the elk preserve. That move split up our family business because there were no ranches big enough for our business available. Now, in 2017 the N Ranch is slated as one of the ranches to cease operations. So here we go again - a possibility of splitting up the family business again!
The Home Ranch and the N Ranch border each other and are managed as one business. Eliminating the N Ranch would severely disrupt our working ranch plan.
The N Ranch is one of the most productive ranches on the point. It is one of the only ranches in PRNS that does not require supplement hay to be fed. Taking this ranch out of production would cause the vegetation to flourish and become under grazed, not to mention the economic impacts it would be for Marin County.
Thank you for considering these comments.
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# 2941
Name: McDonald, Merv
Correspondence: Superintendent MacLeod,
It looks like the park service has forgotten about the problems it had with the exotic deer in the park in the past.
Dr. Ottinger turned about 12 Axis and Fallow deer loose in his ranch years before he sold it to the park. Those deer multiplied to several hundred and scattered over most of the ranches that are now parkland. The park tried to shoot some and give the meat away.
That did not last long, so they quit shooting them. The deer now were at the park headquarter and became a nuisance so they hired expert shooters and a helicopter and shot all the exotic deer they could find.
Now it looks like history is repeating itself. The elk are using the same area the deer had except the elk are more destructive. Some of the elk have tested positive for Johne's disease (a deadly intestine disease with no cure). No one seems to want to take the surplus elk from Tomales Point on account of this disease, so the park turned some Tomales point elk in to the wilderness. The elk are going in to the pastoral zone in the park and competing with cattle. Next they will be at Park Headquarters. They are much more destructive than the deer so the park will have to do the same with the elk as they did with the deer.
I was a tenant rancher on the Pierce Point Ranch in 1980 when the first elk were brought to the park. Ray Arnett (Fish and Game) would not give them to the park until a fence was built to keep the elk from the pastoral zone as he was sure cattle and elk don't work together.
Cattle have to be controlled by fences and managed. Elk will jump the fence or beak through it.
Our cattle are moved from pasture to pasture as the grass grows. As soon as new pasture growth comes, the elk break in and eat all the new growth. Come time to rotate cattle back to the new grass, it is all gone because the elk ate it all.
The only way to manage elk is to build an elk fence. Put the elk back in the wilderness and out of the pastoral zone like was done in the past and let the ranchers grow food for the public.
 
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# 2942
Name: Moore, Rhonda
Correspondence: Thank you for the opportunity to provide comments during the initial phase of the PRNS and - - - - General Management Plan.
I prefer the "Continued Ranching and the Removal of the Drake Beach Tule Elk Herd based on previous PRNS GMP and the 1998 PRNS Tule Elk Management Plan and Environmental Assessment that provides guidance for PRNS during this NEPA process. I recommend that PRNS include in their assessment of alternatives a comprehensive statement measuring community, agricultural, and economic benefits and impacts including multiplier effects throughout the Region, including tourism, cultural and historical resources should also be included highlighting the partnerships of the PRNS, SSNRA, generations of ranchers, as well as numerous organizations such as MCL, Sierra Club, EAC (to name a few) and the Point Reyes community who have collaborated since the inception of PRNS .
Additionally, these partnerships [such as PRNS, SSNRA, generations of ranchers, MCL, Sierra Club, EAC] should be evaluated to determine best practices to enhance visitor experience and education and certainly assessments of visitor capacity to preserve the integrity of the ecosystem within both PRNS and surrounding communities.
I also recommend PRNS thoroughly address the sustainable agriculture and regulatory compliance (IE Organic, etc.) currently in place on ranches within the scope of this NEPA process. It would benefit the public and clarify my misconceptions of pastoral zone management. For example, Bay Area Waters Quality Board organic certifications required for these operations, and certainly, please differentiate between small sustainable family farms and large industrial style agricultural operations.
 
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# 2943
Name: Nunes, Nunes, Hemelt, Carleen, Tim, Jacqueline
Correspondence: Thank you for this opportunity to provide comments for the Point Reyes National Seashore (PRNS) and North District of Golden Gate National Recreation Area (GGNRA), (collectively the "Seashore"), General Management Plan (GMP)
Amendment process and the subsequent National Environmental Policy Act (NEPA) review. We understand this to be the first of several scoping and issue identification steps as part of the GMP and NEPA process.
We support the letter submitted by the Point Reyes Seashore Ranchers Association (PRSRA) dated November 22, 2017 and we will participate fully in subsequent stages and opportunities to discuss the future of GMP and NEPA processes.
Our current leases cover the Historic A, D & E Ranches. It appears that a significant portion of the D could be subject to removal and portions of the E subject to resource protection buffers under the GMP Amendment "Reduced Ranching and Management of the Drakes Beach Tule Elk Herd" alternative. Based on the initial description of the alternative and the map provided, there appears to be no arguably justifiable basis for removing these acres on the land that we lease. We cannot identify the full impact that this acreage removal would have to our business operation and thereby ask that this alternative be amended. Ceasing agricultural use of these acres at the Historic D & E Ranches has the potential to put our present and future business operations at risk of failure.
We look forward to continued communication with NPS. We appreciate the opportunity to provide these initial comments and we look forward to working with PRNS and NPS on all subsequent stages of the GMP and EIS.
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# 2944
Name: Respini, Kathleen
Correspondence: This is to all of you who are not only first responders, but responders of every area and of every expertise, on the front lines, or behind the scenes, who responded in one way or another, during the wild fire crisis in Northern California during the month of October, 2017.
I am an ordinary citizen of the city of Napa. I was very fortunate in that my home happens to be in a neighborhood that was untouched by the fire. We also had cell phone service and electricity during the entire crisis. That's not to say we weren't very nervous as the situation remained fluid for so many days.
As I had errands to take care of during these days, I couldn't help but notice the multitude of police, sheriff, fire, news, and many other vehicles that originated from so many places...with city or county names I didn't even recognize. It was this that touched me to my core. I know you all will say you were just doing your jobs, but to me, you all are the heroes who came to our aide in our most desperate hours. I thought of the families you left behind, some under evacuation. And I thought of those of you whose homes were burned to the ground as you fought to save our communities. I thought of your selflessness as you worked long hours in unforgiving conditions. I saw the many white tents and the trucks all lined up at the Town and Country Fair Grounds in Napa. As I drove past, I willed my truck to be quiet so as not to disturb your sleep. It felt as though even the ground you slept on was sacred, bringing much needed rest.
I have never witnessed such sacrifice by so many for communities where they are not even known. This is humanity at its best, while in the worst of circumstances. This was nothing short of amazing.
I wish to convey my deepest appreciation to all of you, each and every one, although I doubt there are words adequate to this task.
Thank you from the bottom of my heart.
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# 2945
Name: Rucker, Catherine
Correspondence: I am providing public comments on L7617 - General Management Plan (GMP) Amendment, for the Point Reyes National Seashore. I have expertise in environmental law because I earned an LLM in Environmental Law from Golden Gate University School of Law in December 2016.
However, my comments are about applying basic legal skills for the interpretation of federal laws.
I. Alternatives 1 and 2 Must be Eliminated Because In 1962 and in 1978, Congress ExpresslyStated its Intent to Preserve Both Cattle Ranching and Dairy Farming Within the Point ReyesNational Seashore
In 1962, in Public Law No. 87-657, section 4, Congress stated:
No parcel of more than five hundred acres... shall be acquired without the consent of the owner so long as it remains in its natural state, or is used exclusively for ranching and dairying purposes including housing directly incident thereto. 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.
In acquiring access roads within the pastoral zone, the Secretary shall give due consideration to existing ranching and dairying uses and shall not unnecessarily interfere with or damage such use. 1 (emphasis added)
In this section, Congress stated its intent to preserve cattle ranching and diary farming, within the proposed boundaries of the Point Reyes National Seashore. And then Congress clarified its intent by defining the term "ranching and dairying purposes," specific to the Point Reyes and by directing the Secretary to protect the access roads - so that cattle ranching and dairy farming would continue. Thus, in section 4, Congress provided explicit instructions to the Secretary for cattle ranching and dairy farming to continue, within the boundaries of the then-proposed Point Reyes National Seashore.
In 1978, in Public Law No. 95-625, known as the "National Parks and Recreation Act of 1978," Congress defined the term "agricultural property," that was specific to the Point Reyes National Seashore. In section 318(c), Congress stated:
The term "agricultural property" as used in this Act means lands which were in regular use for, or were being converted to agricultural, ranching, or dairying purposes as of May 1,1978, together with residential and other structures related to the above uses of the property.2 3 (emphasis added)
Within section 318(c), Congress restated its intent for cattle ranching and dairy farming to continue at the Point Reyes National Seashore.4
One counterargument is that the Secretary "has discretion" to remove cattle ranching and dairy farming from the Point Reyes National Seashore.5 With the Organic Act of 1916, Congress granted the Director of the National Park Service, within the Department of Interior, with the authority to manage the "several national parks," and to "make and publish such rules and regulations as he may deem necessary."6 However, the Department of Interior must act according to the applicable Public Laws and according to the intent of Congress within such laws - because federal laws are superior to federal agency policies. And on the subject of the Secretary's discretion, in 2012, Secretary of the Interior Ken Salazar published a letter to announce his decision to remove the Drakes Bay Oyser Company from Drakes Estero. In the letter, Secretary Salazar explained that cattle ranching and dairy farming should continue at the Point Reyes National Seashore - because Congress wanted for those activities to continue. 7
Because Congress has expressly stated its intent for cattle ranching and for dairy farming to continue at Point Reyes, through Public Law 87-657 (1962) and Public Law 95-625 (1978), then Congress is the governmental entity that must decide whether to discontinue cattle ranching or dairy ranching, or both, at the Point Reyes National Seashore.8 As a result, the Secretary of the Department of Interior does not have the authority to decide to remove cattle ranching or dairy farming, or both, from the Point Reyes National Seashore, within a purely administrative General Management Plan (GMP) Amendment.
As a result, Alternative 1, for "No Ranching and Limited Management of Tule Elk," and Alternative 2, for "No Dairy Ranching and Management of Drakes Beach Tule Elk Herd," must be eliminated from the General Management Plan (GMP) Amendment process for Point Reyes National Seashore and the north district of Golden Gate National Recreation Area.9
II. Alternatives 1 and 2 Must be Eliminated Because The "Potential Wilderness" Process is Applied in Order to Convert Developed Areas Within a National Park to Undeveloped" Wilderness Areas" - and it Involves Congress.
If the Secretary of the Department of Interior decided to eliminate all cattle ranching and dairy farming, or just all dairy farming, at the Point Reyes National Seashore through a General Management Plan (GMP) Amendment, then presumably, the goal would be for all of the affected areas to be converted into undeveloped areas. And the proper method to carry out this task would be to apply the "Potential Wilderness" process, which involves Congress.10 The "Potential Wilderness" process was established with Public Law 94-544 (Oct. 18, 1976) and Public Law 94-567 (Oct. 20,1076).11 To clarify, a "Potential Wilderness Area" is an area that would qualify to be designated as a "Wilderness Area," except for a preexisting "prohibited use."12
The Potential Wilderness process begins when the Secretary of the Department of Interior identifies an area within a National Park that would qualify as a "Wilderness" area, except for a pre-existing "prohibited use."13 According to the Wilderness Act of 1964, "prohibited uses" include: commercial enterprise, permanent roads, temporary roads, use of motor vehicles, and structures.14 For example, cattle ranches or a dairy farms, with structures, would be "prohibited uses."15 The next step is for the Secretary to prepare a "Wilderness Proposal" and to hold a hearing and to gather comments from state and local government entities and from the public about whether the area should be designated as a "Potential Wilderness Area."16 Through the President, the Secretary submits a report to Congress, and then Congress holds a hearing, in order to decide whether the area should be designated as a "Potential Wilderness Area" or not.1'
If Congress designates an area as a "Potential Wilderness Area," and once the Secretary has removed the "prohibited use" from the area, then the "Potential Wilderness Area" automatically converts to a "Wilderness Area."18 And the final step is for the Secretary to publish a notice in the Federal Register.19 This "Potential Wilderness" designation process is also summarized in the Final Environmental Impact Statement for the Drakes Bay Oyster Company Special Use Permit, dated November 2012, on page 263.20
Within the Point Reyes National Seashore, several areas have been designated as "Potential Wilderness Areas," which have then been subsequently converted into "Wilderness Areas." For example, in the early 1970's, the Secretary identified the "Muddy Hollow," "Abbotts Lagoon," "Limantour Area," and "Drakes Estero" as "Potential Wilderness" areas.21 The Secretary created "Potential Wilderness" proposals for the areas, held a hearing, and gathered governmental and public comments, as required.22 Congress held Committee hearings, and then Congress decided to designate all four of the areas as "Potential Wilderness Areas."23
In 1999, because "prohibited uses" had been removed from the "Muddy Hollow," "Abbotts Lagoon," and "Limantour Area," those areas converted from "Potential Wilderness Areas" into "Wilderness Areas."24 Similarly, in November 2012, Secretary Salazar, of the Department of Interior, decided to remove the Drakes Bay Oyster Company from the "Drakes Estero Potential Wilderness Area" by not renewing the lease.25 And then Secretary Salazar published a notice in the Federal Register that the "Drakes Estero Potential Wilderness Area" had converted into a "Wilderness Area."26 (Although the oyster company filed a lawsuit in order to have its lease renewed, the Secretary ultimately prevailed.27)
As a result, the proper way to remove all of the cattle ranches and all of the dairy ranches, or to only remove the dairy ranches, from the Point Reyes National Seashore, would be for the Secretary of the Department of Interior to follow the Congressional Potential Wilderness Process.28 That is, the Secretary of the Department of Interior does not have the authority to remove the cattle ranches and dairy farms, or just the dairy farms, through a purely administrative process, such as creating a General Management Plan (GMP) Amendment. As a result, Alternative 1, for "No Ranching and Limited Management of Tule Elk," and Alternative 2, for "No Dairy Ranching and Management of Drakes Beach Tule Elk Herd," must be eliminated from the General Management Plan (GMP) Amendment process for Point Reyes National Seashore and the north district of Golden Gate National Recreation Area.29
III. Alternative 3, for "Reduced Ranching and Management of the Drakes Beach Tule Elk Herd," Must be Evaluated Further Before it can be Included in the GMP Amendment Process
The issue is: Was cattle ranching or dairy farming established in the areas identified for "closure of ranch operations" prior to May 1, 1978?30 If so, then Congress must decide whether to eliminate cattle ranching or dairy farming in the areas designated in the General Management Plan (GMP) Amendment proposal, alternative 3, and the Secretary of the Department of Interior lacks the authority to make the decision to remove cattle ranching and dairy farming from those areas.31 As a result, Alternative 3 may require further analysis before it can continue to be considered in the GMP Amendment process.
Conclusion
Because the Secretary of the Department of Interior does not have the authority to remove (nearly) all of the cattle ranches and (nearly) all of the dairy farm operations from the Point Reyes National Seashore, then alternative 1, for "No Ranching and Limited Management of Tule Elk," must be eliminated.32 In addition, because the Secretary does not have the authority to remove all of the dairy farm operations from Point Reyes, then alternative 2, for "No Dairy Ranching and Management of Drakes Beach Tule Elk Herd," must be eliminated.33 Further, if prior to May 1,1978, cattle ranching and/or dairy farming was established in the areas under consideration for the removal of such activities in alternative 3, then the Secretary does not have the authority to remove cattle ranching and/or dairy farming from those proposed areas.34
The main reason why substantial residential and commercial development did not occur at Point Reyes - is because so many cattle ranches and dairy farms were already established there, and because Congress has consistently encouraged the cattle ranchers and dairy farmers to remain there. In order to establish the Seashore, the Secretary of the Department of Interior was required to purchase enough land from the cattle ranchers and the dairy farmers so that the new Point Reyes National Seashore could be "efficiently" administered.35 As a result, many of the ranchers and farmers agreed to sell their land to the Secretary - because the ranchers and farmers trusted that the federal government would continue to lease-back the same land they were on. And now, if certain organizations want for the entire Point Reyes National Seashore to be converted into an undeveloped "Wilderness Area," or for more sections within the Point Reyes National Seashore to become "Wilderness Areas," then they, and the Secretary of the Department of Interior, and the President of the United States will have to convince Congress to make those decisions.36
- - -
1 The Point Reyes National Seashore Establishment Act, Pub. L. No. 87-657, § 4, 76 Stat. 538 (Sept. 13, 1962) codified at 16 U.S.C.A § 459c-459c-2.
2 The Point Reyes National Seashore Establishment Act, Pub. L. No. 87-657, § 4, 76 Stat. 538 (Sept. 13,1962). But See Resource Renewal Institute, et al. v. National Park Service, 3, Case 3:16-cv-00688 (N.D. Calif., filed 02/10/2016) (claiming: "Although ranching within the National Seashore is not mandated by any law...").
3 The National Parks & Recreation Act of 1978, Pub. L. No. 95-625, § 318(c), 92 Stat. 3467 (Nov. 10,1978); codified at 16 U.S.C.A § 459c-5(b).
4 Id.
5 Resource Renewal Institute, et al. v. National Park Service, 2, Case 3:16-cv-00688 (N.D. Calif., filed 02/10/2016).
6 National Park Service Organic Act, Pub. L. No. 64-235, 39 Stat. 535 (Aug. 25, 1916), codified at 16 U.S.C.A § 1-4) ("The property acquired by the Secretary under such sections shall be administered by the Secretary..."); The Point Reyes National Seashore Establishment Act, Pub. L. No. 87-657, § 7, 76 Stat. 538, codified at 16 U.S.C.A § 459c-6 (Sept. 13,1962) ("The property [within the boundaries of the proposed Point Reyes National Seashore] acquired by the Secretary under this Act shall be administered by the Secretary, subject to the provisions of the Act entitled "An Act to establish a National Park Service," and for other purposes, approved August 25,1916...").
7 Letter from Secretary Ken Salazar, Department of Interior, to Director, National Park Service, 6 (Nov. 29, 2012) (claiming: "Long-term preservation of ranching was a central concern of local interests and members of Congress as they considered legislation to establish the Point Reyes National Seashore in the late 1950s and early 1960s.").
8 The Point Reyes National Seashore Establishment Act, Pub. L. No. 87-657, § 4 (Sept. 13, 1962); National Parks & Recreation Act of 1978, Pub. L. No. 95-625 § 318(c) (Nov. 10,1978).
9 Letter to "Interested Parties" about the L7617 - GMP Amendment process and the six concept alternatives, from U.S. Department of Interior (Oct. 16, 2017).
10 The Wilderness Act of 1964, Pub. L. No. 88-577, §3(c), 76 Stat. 890 (Aug. 20,1964) codified at 16 U.S.C.A. § 1132(c).
11 An Act to Designate Certain Lands in the Point Reyes National Seashore, California, as Wilderness, Pub. L. No. 94- 544, 90 Stat. 2515 (Oct. 18,1976); An Act to Designate Certain Lands Within Units of the National Park System as Wilderness, Pub. L. No. 94-567, 90 Stat. 2692 (Oct. 20, 1076).
12 Id.; The Wilderness Act of 1964, §4(c) codified at 16 U.S.C.A. § 1133(c).
13 An Act to Designate Certain Lands in the Point Reyes National Seashore, California, as Wilderness, Pub. L. No. 94- 544, 90 Stat. 2515 (Oct. 18,1976); An Act to Designate Certain Lands Within Units of the National Park System as Wilderness, Pub. L. No. 94-567, 90 Stat. 2692 (Oct. 20, 1076).
14 The Wilderness Act of 1964, §4(c), codified at 16 U.S.C.A. §1133(c).
15 Id.
16 The Wilderness Act of 1964, §3(d), codified at 16 U.S.C.A. §1132(d). See e.g. Wilderness Recommendation, Point Reyes National Seashore, Aug. 1972; Final Environmental Statement, Proposed Wilderness, Point Reyes National Seashore (Apr. 23,1974).
17 The Wilderness Act of 1964, §3(d), codified at 16 U.S.C.A. §1132(d).
18 The Wilderness Act of 1964, §3(c) ("A recommendation of the President for designation as wilderness shall become effective only is so provided by an Act of Congress.") codified at 16 U.S.C.A. §1132(c); An Act to Designate Certain Lands Within Units of the National Park System as Wilderness, Pub. L. No. 94-567, 90 Stat. 2692, § 3 (Oct. 20,1076) ("All lands which represent potential wilderness additions, upon publication in the Federal Register of a notice by the Secretary of the Interior that all uses theron prohibited by the Wilderness act have ceased, shall hereby be designated wilderness.").
19 An Act to Designate Certain Lands Within Units of the National Park System as Wilderness, Pub. L. No. 94-567, 90 Stat. 2692, § 3 (Oct. 20, 1076).
20 Final Environmental Impact Statement, Drakes Bay Oyster Company Special Use Permit, 263 (Nov. 2012).
21 Final Environmental Statement, Proposed Wilderness, Point Reyes National Seashore (Apr. 23,1974).
22 Fed. Reg., Vol. 36, No. 134,13044 (July 13,1971), "Notice of Public Hearing Regarding Wilderness Proposal."
23 Final Environmental Statement, Proposed Wilderness, Point Reyes National Seashore, (Apr. 23,1974); House Report No. 94-1680 (Sept. 24,1976); Senate Report No. 94-1357 (Sept. 29, 1976); An Act to Designate Certain Lands in the Point Reyes National Seashore, California, as Wilderness, Pub. L. No. 94-544, 90 Stat. 2515 (Oct. 18, 1976).
24 Fed. Reg., Vol. 64, No. 222, 63057 (Nov. 18, 1999).
25 Letter from Secretary Ken Salazar, Department of Interior, to Director, National Park Service (Nov. 29, 2012).
26 Fed. Reg., Vol. 77, No. 233, 71826-27 (Dec. 4, 2012).
27 Drakes Bay Oyster Co. v. Salazar, 921 F.Supp.2d 972 (N.D. California, Feb. 4, 2013); Drakes Bay Oyster Co. v. Jewell, 729 F.3d 967 (Ninth Cir„ 2013).
28 An Act to Designate Certain Lands in the Point Reyes National Seashore, California, as Wilderness, Pub. L. No. 94- 544, 90 Stat. 2515 (Oct. 18, 1976); An Act to Designate Certain Lands Within Units of the National Park System as Wilderness, Pub. L. No. 94-567, 90 Stat. 2692 (Oct. 20, 1076).
29 Letter to "Interested Parties" about the L7617 - GMP Amendment process and the six concept alternatives, from U.S. Department of Interior (Oct. 16, 2017).
30 The National Parks & Recreation Act of 1978, Pub. L. No. 95-625, § 318(c), 92 Stat. 3467 (Nov. 10,1978); codified at 16 U.S.C.A § 459c-5(b).
31 Letter to "Interested Parties" about the L7617 - GMP Amendment process and the six concept alternatives, from U.S. Department of Interior (Oct. 16, 2017).
32 The Point Reyes National Seashore Establishment Act, Pub. L. No. 87-657, § 4, 76 Stat. 538 (Sept. 13,1962); The National Parks & Recreation Act of 1978, Pub. L. No. 95-625, § 318(c), 92 Stat. 3467 (Nov. 10, 1978); codified at 16 U.S.C.A § 459c-5(b); L7617 - GMP Amendment Handout (2017) (exceptions for two areas with "reserved life estates")
33 Id.
34 The National Parks & Recreation Act of 1978, Pub. L. No. 95-625, § 318(c), 92 Stat. 3467(Nov. 10, 1978); codified at 16 U.S.C.A § 459c-5(b).
35 The Point Reyes National Seashore Establishment Act, Pub. L. No. 87-657, § 4, 76 Stat. 538 (Sept. 13, 1962).
36 An Act to Designate Certain Lands in the Point Reyes National Seashore, California, as Wilderness, Pub. L. No. 94- 544, 90 Stat. 2515 (Oct. 18,1976); An Act to Designate Certain Lands Within Units of the National Park System as Wilderness, Pub. L. No. 94-567, 90 Stat. 2692 (Oct. 20,1076); See e.g., Resource Renewal Institute, et al. v.National Park Service, Case 3:16-cv-00688 (N.D. Calif., filed 02/10/2016).
 
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# 2946
Name: Spivak, Randi
Correspondence: Re: Point Reyes General Management Plan Amendment
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 fanning 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.
___________________________
# 2947
Name: Desai , Neal
Correspondence: Re: NPCA comments on pre-scoping/pre-NOI, conceptual alternatives for GMPA
The National Parks Conservation Association (NPCA) provides the following comments on the
pre-scoping/pre-NOI, conceptual alternatives phase of the Point Reyes National Seashore's
(PRNS) General Management Plan Amendment (GMPA). These comments will be further
refined through ongoing discussions with stakeholders, and we look forward to submitting more
detailed comments soon.
The National Park Service's (NPS) Ranch Comprehensive Management Plan (RCMP) process
generated comments across the spectrum. Some environmental groups called for the removal of
ranching whereas some Seashore ranchers and ranching-interest groups called for wholesale
changes to the Seashore leading to defacto privatization of a national park and damage to
resources. NPCA does not support either of these egregious propositions.
SETTLEMENT AGREEMENT
Though NPCA was not a party to the lawsuit brought against the NPS, which we did not support,
or the settlement agreement and its terms, we are pleased to see the matter resolved and in a form
of Settlement Agreement, which demonstrates to the public that all formal parties (Plaintiff
environmental groups, Defendant NPS, Defendant-Intervenors Seashore Ranchers, and
Defendant-Intervenors Marin County) formally agree with the terms and conditions, including
the process and timeframe established. This will hold accountable these parties that include 3
non-profits, 2 governmental agencies, and numerous Seashore Ranchers.
PURPOSE AND NEED
As this is a GMPA, the purpose and need should reflect park purposes and goals as stated in law
and policy. Though this GMPA was a result of the Settlement Agreement regarding the RCMP, a
GMP is broader in scope. The existing GMP is 37 years old. Perhaps there is no fundamental
purpose and need more important than for NPS to include and update the environmental conditions of topic areas such as natural resources, cultural resources, visitor use, economics,
climate change, visitor access, and recreation so that planning in the future can reflect the
fulfillment of the PRNS vision as established in law and policy.
Updating the environmental conditions will ensure that the analysis of environmental
consequences is sound and defensible. We presume that over the past 37 years, through research
and management, PRNS and its partners have likely gathered considerable amount of new
information and knowledge regarding resources and visitor use. However, it appears to be the
case, based on available information, that PRNS will have to conduct more research to ensure
that its data is updated and defensible. This will also help engage and build support from the
public.
The GMPA, though broad in scope, should certainly analyze and address important topics that
were discussed during the RCMP process, such as:
• pasture/range management
• best management practices
• succession
• diversification
• Tule elk protection and management
• Terms and length of leasing
• Transparency in management, compliance, and ranching operations
DEVELOPMENT OF ALTERNATIVES
At this stage, NPCA is unable to submit specific alternative(s) that we would like to see
considered by NPS. However, in the coming weeks and months, potentially in partnership with
other environmental groups and/or ranching interests, NPCA looks forward to submitting
specific alternative(s).
TULE ELK
NPCA understands various conflicts that exist between some elk and some ranches, and believes
that the GMPA should address this issue. The goal should be to minimize the impacts. We look
forward to hearing about the results of efforts (e.g. study, review of options, etc.) by NPS, CA
Dept. of Fish and Wildlife, and other experts before formulating a final position on what
management of tule elk should look like. That said, NPCA would agree that no management of
the elk is inappropriate. Similarly inappropriate would be concluding right now that there should
be no elk in the pastoral zone as a matter of policy.
ECONOMIC ANALYSIS
PRNS contributes significantly to local economies, as documented by the NPS in annual reports.
This economic generation stems from visitation to the parks. It is not a park purpose to support
ranching and dairying for the purposes of supporting economies or financial/product markets in
Marin County or other jurisdictions outside the park. We understand, and will research further,
that past and/or current decisions by Marin and Sonoma Counties, as well as the agriculture industry in general, have negatively impacted the ranching community. If the NPS reimagines
the purpose of the Seashore in order to address these regional, market-driven, and political issues
and decisions in jurisdictions outside of the Seashore, we believe that public support for ranching
and the NPS would severely be eroded.
Related, the NPS must independently verify any economic-related claims from Marin County
and other jurisdictions outside the park, given factually incorrect information provided to the
park, public, and elected officials over the years. For example, "The Changing Role of
Agriculture in Point Reyes National Seashore, June 2009" by UC Cooperative Extension -
Marin/Marin County was widely recognized as a hit piece intended to build animosity against the
NPS as part of efforts to privatize wilderness.
Given the history of various stakeholders to overreach on the "economic analysis" topic, and the
potential for this to occur moving forward, we find the aforementioned comments and concerns
justified.
DIVERSIFICATION
NPCA looks forward to further discussions with stakeholders, specifically environmental groups
and ranchers, to discuss the potential for diversification and associated conditions. This topic, if
not approached smartly by the NPS or stakeholders, has the potential to severely erode public
support for continued ranching in the Seashore. We look forward to submitting more detailed
comments on diversification. That said, it is clear to us that it would be highly inappropriate to
consider farming, row crops, or other non-ranching or dairying diversification activities in the
pastoral zone, with the exception potentially being the consideration of these types of activities
within a portion of the "ranch core" subject to various conditions.
CONCLUSION
We believe there is the potential to demonstrate that exemplary ranching and dairying can exist
at PRNS - anything less would fall short of what is needed to build public trust and confidence
in the NPS and continued ranching. We look forward to working with NPS and stakeholders in
advancing the GMPA and ideally building a large, broad coalition in support of the final plan.
Sincerely,
Neal Desai
Director of Field Operations, Pacific Region
National Parks Conservation Association
___________________________
# 2948
Name: Kept Private, Kept Private
Correspondence: I very strongly urge the National Park Service to adopt the option that would allow ranching to continue on Point Reyes with the ability of the ranchers to diversify as they deem necessary to keep their operations viable, and that the Park Service should control the Tule Elk herd that is currently encroaching on the Pastoral Zone. The Point Reyes Ranching Community have been careful stewards of the their land for many generations and with the support of the Park Service, will hopefully be allowed to continue into the foreseeable future.
The Point Reyes ranches are an essential part of a larger Marin County agricultural network, and if ranching on the Point is not allowed to continue. The supporting, County wide, food producing infrastructure will be in imminent threat of collapse. It is unconscionable to consider the inability to locally produce our own food supply from an environmental, economic, and practical standpoint, especially when our local ranchers raise their animals humanely, sustainably, and for the most part, organically.
I hope this letter will be accepted despite lacking the numerical identification of the option above. Despite a protracted search of the Website, I could not find the six options listed.
___________________________
# 2949
Name: Berto, Constance B
Correspondence: I have lived in Marin County since 1958, and I have enjoyed PRNS and visited it times beyond number. wish to support the original intent of the GMP for Point Reyes National Seashore, to wit:
Continue the present-day ranching/farming/dairy operations and support them by awarding 20- year leases and/or permits.
Manage the tule elk herd! Don't let them reproduce uncontrollably and ruin pasture (grazing) management!
Keep the Stewart Horse Camp and allow the present concession holder to continue operating this valuable amenity.
Thank you for extending the comment period.
___________________________
# 2950
Name: Gallagher, Rich
I am in full support of the comments submitted for this EIS process by the Point Reyes Seashore Ranchers Association. My family purchased the Historic F Ranch on the Point Reyes Peninsula in 1919, and has managed it ever since. This ranch represents my main income. Although I don't live on the ranch, I am on the ranch every day to feed and check my cattle. My dream is that my children and grandchildren carry on this tradition long into the future. I strongly object to any alternative in the GMP Update that eliminates or reduces ranching at Point Reyes or the GGNRA. Any reduction in ranching would devastate my family or any of
the other family ranches. Please honor the will of Congress when it created the Point Reyes National Seashore. We were promised that we could stay.
___________________________
# 2951
Name: Huffman, Jared
Correspondence: Thank you for the extension for public comment for the Point Reyes National Seashore and Golden Gate National Recreation Area north district General Management Plan (GMP) Amendment, and for this opportunity to provide my comments. Updating the management guidance for more than 28,000 acres of National Park Service (NPS) lands including all lands currently leased for ranching is an important endeavor, and I am pleased to see you are planning a robust process with plenty of opportunities for public participation.
For over 150 years, agriculture has been a vital part of the fabric of West Marin. That includes the historic ranches and dairies in the Point Reyes National Seashore (Seashore), which contribute to the special history, character, and appeal of this magnificent national park unit. The NPS recognized this in designating the ranches on the Point and in the Olema Valley as Historic Districts. They are vernacular cultural landscapes that evolved through use by the people whose needs and activities shaped them. While ranching practices continue to evolve, the fundamental distinctive characteristics of these landscapes have existed for many generations and have become an integral part of the cultural and scenic resources the NPS is charged to conserve unimpaired as part of its mission.
These ranches and dairies also provide broader benefits: they help preserve agriculture outside the park boundaries by ensuring that our regional agricultural economy, consisting almost entirely of small-scale agricultural operations, remains large enough to support the facilities and services that are necessary for most of these ranches, dairies, and farms to stay viable.
The statutory history of the site reflects that Congress showed great vision by providing for ranching to continue within the Seashore to ensure that future generations would be able to experience the park's unique working landscapes. Most recently, in November of 2012, the Secretary of the Interior reinforced the commitment of the federal government to this vision by directing the NPS to pursue the issuance of agricultural lease I special use permits for renewable terms of up to 20 years. That vision, and the many benefits it represents for the park and our region, is worth protecting. I am writing to once again express my firm commitment to ensuring that these historic working ranches remain a permanent part of the Point Reyes National Seashore.
Reducing conflicts between the reintroduced Tule elk herds and the park's historic ranches and dairies is essential for NPS to maintain the historic, cultural, and scenic resources and values of the Seashore. The successful return of the majestic
elk to the Point Reyes National Seashore is good for park visitors ·and speaks to the health and abundance of the park's natural environment, but the growing number of elk taking up permanent residence on working ranches and dairies -­ mingling with cattle and potentially acquiring and spreading cattle-borne diseases, damaging fences and equipment, and competing with cows for carefully managed organic forage on ranch lands - - is a serious problem for ranchers now and will certainly lead to impairment of the historic values of the working ranches. Moreover, as unmanaged elk inevitably replace ranches, the scenic values of the Pastoral Zone will suffer unacceptable impacts leading to impairment.
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# 2952
Name: Lafranchi, Rick
Correspondence: I'm writing this letter in support of Continued Ranching and Managing the Elk Herd at Drakes Beach.
I've spent my entire life closely connected with West Marin agriculture. Over the years I've come to realize the amazing legacy connected with this region.
I've learned the pastures in the Point Reyes National Seashore are arguably the most productive sustainable pastures in the world.
I've learned the cattle ranches and dairies of the Point Reyes National Seashore are among the most successful sustainable operations of their kind in California.
I've learned the ranches of the Point Reyes National Seashore generate well over 100 million dollars of economic activity annually.
I've learned the families on the ranches of the Point Reyes National Seashore are an important part of the fabric of the local communities. From patronizing and supporting local schools, local churches and non-profits the ranchers of the Seashore along with their primarily latino employees are a critical component of the local culture.
37 years ago the Marin Agricultural Land Trust was founded to preserve West Marin agriculture. Since then MALT has protected from development nearly 50,000 acres on 85 ranches, with more to come. This has been a huge commitment to supporting and enabling West Marin ag to become a viable, vibrant, cutting edge ag economy utilizing the unique sustainable strengths of this region.
Anything reducing the activity on the ranches of the Point Reyes National Seashore would seriously threaten the viability of the rest of West Marin Agriculture. This in turn could cast the mission of MALT as irrelevant and potentially open up West Marin to development.
Every region provides a unique opportunity to realize the strengths inherent within. The Presidio offered by improving and leasing the buildings therein the ability to protect historic vistas, trails and waterfronts.
The Point Reyes National Seashore can be a win, win by generating revenues from the existing ranches to offset the costs of managing the Elk Herd and stewarding the lands of the Seashore.
A couple more requests I have for your consideration:
Please consider partnering with MALT to steward the ranches. MALT has a long history of monitoring and managing Marin ranches. MALT is very aggressive in demanding it's easement holders uphold the important elements of responsible stewardship.
I also ask for the Park service to consider making a huge commitment to Marin Agriculture by designating agriculture in the park the equal of MALT properties by being dedicated to agriculture in perpetuity. Along with this I ask for the existing leases to betransferable outside of the current tenants. This would forever establish West Marin as a thriving sustainable agricultural region.
The Point Reyes National Seashore Ranches could and should be the leading examples of cutting edge environmentally sound agriculture for our Nation.
As you can see the ranches in the park are far more important to the local culture, economy and environment than one may realize. They are critical to the future of an entire region.
___________________________
# 2953
Name: Levine, Marc
Correspondence: We are writing to comment on the Point Reyes National Seashore Management Plan Amendment. We support sustainable ranching in the park that strikes a balance: one that preserves the environmental habitat while supporting those whose livelihood and family legacy is built upon sustainable farming practices in the Seashore.
Point Reyes National Seashore's creation was due to an innovative agreement with local ranchers, and without their support over a half century ago, the public would not have this jewel to explore and enjoy. Not only are the ranches a vital part of the park's history, these family farmers and dairies remain an important part of Marin's modern-day agricultural economy. West Marin farming operations generate an estimated $25 million per year, which is a significant economic driver in the North Bay Area.
Our preferred alternative allows ranching to continue on the land, grant long-term leases which provide desperately needed stability for these family farmers. The short-term permitting process currently places unnecessary stresses on the twenty-four families who operate in West Marin. Twenty year leases will allow ranchers and farmers to focus on the operation of their family-run businesses, rather than the complicated permitting process they currently navigate. Not to mention the significant challenges families face when securing agriculture related loans.
Ranchers should have a reliable, streamlined permitting process with long-term leases which eases the burden on families, allows them to invest in their businesses and contribute to the local economy.
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# 2954
Name: Daley, Dave
Correspondence: The California Cattlemen's Association (CCA), Public Lands Council (PLC), and National Cattlemen's Beef Association (NCBA) appreciate the opportunity to provide initial feedback on the General Management Plan (GMP) amendment for the Point Reyes National Seashore (PRNS) and the north district of the Golden Gate National Recreation Area (GGNRA). CCA represents more than 1,700 cattle ranchers throughout the state of California, including many of the ranchers at PRNS and GGNRA. PLC is the only organization devoted solely to representing the 22,000 cattle and sheep producers who hold public lands grazing permits throughout the western United States. NCBA is the national trade association representing
United States cattle producers, with more than 25,000 individual members throughout the
nation.The GMP amendment is of importance to our organizations not just because of its immediate impact upon the ranchers at the PRNS and GGNRA, but also because any impact of the GMP upon ranchers at Point Reyes is likely to reverberate throughout Marin County, and may have direct, indirect, or precedential impacts upon ranchers elsewhere in California or on other federal lands throughout the United States.
Of primary importance to our organizations and their members is that the National Park Service (NPS) provide long-term leases for the ranching operations within the PRNS, and that NPS remove tule elk from the pastoral zone, ensuring via fencing or other means that the elk do not repeat their encroachment onto the historic ranching area. Additionally, our organizations ask that in developing a GMP amendment, NPS remain mindful of the beneficial and historic nature of the ranches at PRNS, which Congress sought to preserve when it established the PRNS. Given the importance of these ranches for land stewardship and the local economy, as well as the thin profit margins ranchers operate within, we ask that NPS seek to ensure operational flexibility for the ranchers within the GMP amendment.
Our organizations have carefully reviewed the initial alternatives advanced by the NPS in its GMP Amendment Newsletter. In the comments that follow, we outline the policy considerations that ultimately favor adoption under the GMP amendment of a modified version of the "Continued Ranching and Removal of the Drakes Beach Tule Elk Herd" alternative, an analysis of why the required Settlement Alternatives should ultimately be disfavored in the GMP amendment, and various considerations that NPS should fully explore in future scoping/EIS documents.
SPECIFIC COMMENTS REGARDING THE "CONTINUED RANCHING AND REMOVAL OF THE DRAKE'S BEACH ELK HERD" ALTERANTIVE
Our organizations' preferred alternative is a modified version of the "Continued Ranching and Removal of the Drake's Beach Tule Elk Herd" alternative. This alternative appropriately ensures the viability of ranches by providing 20-year leases, and ensures management of the tule elk herd at PRNS better than any of the other alternatives currently under consideration.
The GMP amendment should ensure 20-year (or longer) leases for ranchers
Our organizations are pleased that, under this alternative (as well as the NPS Initial Proposal), "existing ranch families would be authorized to continue beef cattle and dairy ranching operations under agricultural lease/permits with 20-year terms" and that those permits "would identify authorized measures for operational flexibility and diversification." Any PRNS GMP amendment ultimately finalized by NPS should absolutely prioritize long-term leases for ranchers at PRNS.
Cattle ranchers, including those at PRNS, strive to be good stewards of the land, water, and wildlife resources. However, short-term leases stymie efforts at good stewardship. With short-term leases, ranchers are unable to obtain external financing for ranch improvements that could benefit the land. Additionally, without any intermediate- or long-term certainty regarding the continuation of ranching permits, ranchers are hesitant to invest their own capital in ranch improvements, as there is no assurance that they will see returns on those investments. Long­ term leases will enable ranchers to obtain financing and see returns on their own investments, incentivizing good stewardship practices and benefitting both the rancher and the unique environment of the PRNS.
The solution to environmental concerns at PRNS is not to eliminate or reduce ranching, but to provide the Seashore's ranchers with operational security that will allow them to invest in improvements benefitting the ranch, the land, the water, and the Seashore's unique wildlife.
The GMP amendment should prioritize removal of tule elk from the pastoral zone
In 2014 comments addressing the now-abandoned PRNS Ranch Comprehensive Management Plan process, CCA addressed the need for removal of tule elk from the pastoral zone:
The destruction tule elk have caused on PRNS ranches is devastating and well­ documented. In particular, the elk regularly compete with cattle for forage, and have been known to damage fences and other ranch property during such incursions. The Limantour elk make daily incursions upon the Home Ranch and graze grasslands which are leased by NPS for cattle grazing. Likewise, the lessees of C Ranch have seen repeated loss of pasture as a result of elk living on what used to be the D Ranch. As tule elk require 10-15 pounds of forage a day, such incursions represent a significant strain on the resources required by these ranchers.
As elk eat grass intended for cattle forage, ranchers have no option but to purchase supplemental feed to sustain their cattle. This can be extremely costly for the rancher . . . .
California's cattle ranchers already operate on exceedingly thin margins-most
do it not because it turns any substantial profit, but because it is a way of life they cherish and which is rooted in long-standing family tradition . Elk foraging in the pastoral zone places an additional financial burden upon these producers, threatening their very livelihood and way of life. Additionally, by presenting them with an economic burden not faced by other ranchers throughout the state and nation, this foraging by tule elk puts the ranchers in the PRNS at a competitive disadvantage over other ranchers throughout California and the United States.
For those ranches certified organic, these incursions can also threaten their organic status. This is particularly troubling given the increased time, effort, and expense incurred by those ranchers who choose to serve their customers by certifying organic.
Finally, tule elk impact the grazing standards for permittees at PRNS. Through no fault of their own, and regardless of livestock management practices, ranchers may exceed the PRNS grazing standard of 1200lbs[/acre] of residual dry matter left on pastures prior to the rainy season when elk routinely graze the areas.
To ensure that historical ranching remains viable within the pastoral zone, as Congress intended, we urge NPS to take immediate action to remove elk from the pastoral zone and to ensure that elk do not return to the pastoral zone. This may involve bolstering fence lines separating the Phillip Burton Wilderness Area from
existing ranches within PRNS. 1
While the "Continued Ranching and Removal of the Drakes Beach Tule Elk Herd" alternative envisions removal of the Drake's Beach herd, such management is insufficient. It is
not enough that NPS could additionally "implement actions to manage tule elk from the Limantour-Estero Road herd on the ranchlands" under this alternative; the NPS must manage the Limantour elk to keep them from straying into the pastoral zone, whether by bolstering fence lines separating the Phillip Burton Wilderness Area from the ranches within the pastoral zone or via other means.
It is also essential that the NPS carefully analyze the Phillip Burton Wilderness Area's carrying capacity for tule elk (factoring in available forage and water) as a basis for establishing a reasonable population limit for the elk, and that NPS develop a detailed plan for managing the elk population to ensure that it does not exceed that population limit. Any population limit should be conservative in nature, accounting for a wide variety of environmental factors that could impact the elk population, including the likelihood of future drought conditions in the region. Such management would avoid future losses of tule elk such as that experienced from 2014-2015 due to California's historic drought.
ANALYSIS OF ALTERNATIVES REQUIRED BY THE SETTLEMENT AGREEMENT
While our organizations appreciate that the NPS is required by the Settlement Agreement resulting from the lawsuit Resource Renewal Institute v. National Park Service to consider the "No Ranching," "No Dairy Ranching," and "Reduced Ranching" alternatives within the GMP amendment process, there are numerous reasons that these three alternatives should ultimately be rejected. All three alternatives are inconsistent with both the Point Reyes National Seashore
Enabling Act and the Coastal Zone Management Act of 1972, and should thus be rejected as a matter of law. Additionally, all three alternatives would have devastating economic impacts throughout the region, and should be rejected as a matter of good policy.
The Settlement Agreement alternatives are contrary to laws governing the PRNS
Alternatives required by the Settlement Agreement are inconsistent with the Point Reyes National Seashore Enabling Act
The Point Reyes National Seashore Enabling Act states that the PRNS
shall be administered by the Secretary [of the Interior] 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 2
Continuance of dairy and beef cattle ranching at the PRNS is essential to historic preservation of the PRNS because ranching is part of the very fiber of the Point Reyes peninsula. Cattle were grazed at Point Reyes as early as 1820, when the longhorn cattle of a Spanish Franciscan
Mission at San Rafael roamed the peninsula. 3 When the missions were dismantled, ownership of
land was established by Mexican land grants, and the grantees of these ranchos continued to graze cattle on the peninsula (for instance, former Mexican Army corporal Rafael Garcia grazed 3,000 head of cattle at the peninsula). 4 After California's acquisition by the United States, many rancheros sold their lands to American entrepreneurs. By the 1930s, ownership had largely stabilized; many of those ranching families continue to ranch at Point Reyes today.
Beef cattle and dairy ranching are fundamental to the history of the Point Reyes peninsula, and it is precisely these historic uses that the Point Reyes National Seashore Enabling Act sought to preserve. Any alternative which eliminates or reduces historic ranching at the PRNS, then, would violate the spirit, if not the letter, of the law which paved the way for the creation of the PRNS.
Alternatives required by the Settlement Agreement are inconsistent with the Coastal Zone Management Act of 1972
Though federal lands such as the PRNS and GGNRA are excluded from the "coastal zone" under the Coastal Zone Management Act of 1972,5 the "federal consistency" provision of the Act nevertheless states that "Each Federal agency activity within or outside the coastal
zone that affects any land or water use or natural resource of the coastal zone shall be carried out in a manner which is consistent to the maximum extent practicable with the enforceable policies of approved State management programs. "6
As detailed in Unit II of the Marin Local Coastal Program approved by the California Coastal Commission in 1981,7
The [California] Coastal Act strongly supports the preservation of agricultural lands in productive agricultural use and strictly controls the conversion of agricultural lands to other uses. Agricultural land uses are given priority over many other[ ]use[s] in the coastal zone, including visitor-serving development . . . .
Because of the Coastal Act's strong support for preserving agricultural lands and the important role which agriculture in the parks plays in Marin's agricultural economy, the LCP recommends that agriculture in the GGNRA and PRNS be encouraged and carefully monitored to avoid adverse impacts on natural resources and public recreation. Where conflicts arise between agriculture and public park uses, they should be resolved so as to protect resources and public safety while still allowing the continuation of the agricultural operation. Regarding existing leases, the LCP recommends that they be reviewed five years prior to expiration for compatibility with park goals, and revised as necessary. To provide greater security to agricultural operations, long-term lease arrangements and automatic lease renewal provisions are recommended if all terms and conditions of a lease are met. Uniform procedures and standards should be established by the National Park Service to deal with all agricultural tenants.8
The GMP amendment conducted by NPS is a federal agency activity which effects land use and natural resources within California's coastal zone, and thus must be "consistent to the maximum extent practicable with the enforceable policies of approved State management programs." As demonstrated above, the "No Ranching" alternative, "No Dairy Ranching" alternative, and "Reduced Ranching" alternative would not be "consistent to the maximum extent practicable" with the policies outlined in the Marin Local Coastal Plan approved by the California Coastal Commission because it would not encourage agriculture at GGNRA and PRNS nor continue existing agricultural operations.
All three settlement alternatives fail to uphold federal consistency with state-approved coastal management plans in accordance with the Coastal Zone Management Act of 1972. The Draft EIS should fully examine the interrelationship between the Settlement Agreement alternatives and all local, state, and federal laws and regulations governing the portions of PRNS and GGNRA within the coastal zone.
The Settlement Agreement alternatives would be devastating to Marin County's economy,
with impacts reverberating throughout the State of California
According to the Marin County Board of Supervisors, the ranches at PRNS account for nearly 20% of agricultural production in Marin County, a direct production value of $20 million. A 2009 analysis by U.C. Cooperative Extension found that ranches at PRNS and GGNRA
directly provide 65 jobs, and provide livelihoods for another 25 ranch family members. The presence of these ranches supports local schools, churches, and businesses.
Should these ranches be "phased out" under the "No Ranching" alternative or be reduced in number under either the "No Dairy Ranching" or "Reduced Ranching" alternatives, Marin County would be deprived of the economic benefits of these ranches, resulting in a loss of 20% of the County's agricultural production and devastating the local businesses that rely on the presence of the ranches and ranchers.
Any consideration of the Settlement Agreement alternatives in the Draft EIS should fully consider the direct and indirect economic impacts that such alternatives would have upon the Seashore, Marin County, and California.
Specific comments regarding the "Reduced Ranching and Management of the Drakes Beach Tule Elk Herd" alternative
The "Reduced Ranching and Management of the Drakes Beach Tule Elk Herd" alternative detailed in the GMP Amendment Newsletter states that "The areas identified for closure of ranch operations [under this alternative] would minimize the overall impact on the Point Reyes Peninsula Dairy Ranches and Olema Valley Dairy Ranches Historic Districts, both of which are eligible for listing on the National Register of Historic Places." The "Ranching Background" section of the GMP Amendment Newsletter, however, suggests that these districts have been determined eligible for nomination to the National Register of Historic Places in part because of the "active beef cattle and dairy operations that occur" in those districts.
To reduce the dairy and beef cattle ranching activities that occur in these districts would be to deprive the districts of the very history that has rendered them historic in the first place.
Consequently, this alternative should be rejected.
Conclusion
CCA, PLC, and NCBA appreciate the opportunity to provide initial comments on the GMP amendment for the Point Reyes National Seashore, and thank NPS for their efforts. We look forward to continued communication with NPS as it develops its Draft EIS-and ultimately a final GMP amendment-for the Point Reyes National Seashore.
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# 2955
Name: Zegart, Margaret
Correspondence: PLEASE RESUME WORKING WITH THE WORKING BEEF CATTLE AND DAIRY RANCHES AND INCLUDE IN THE AMENDEDUPDATED MANAGEMENT PLAN
Consideration of these ranches as a cultural historic resource area of highest value to retain within the
Include (a) Map original ranching area by parcel ownership (b) map of current ownership, (3) produce and financial assets for Marin County (4) Add mapping of land characteristics. (5) Use one farm - preferably the ranching area now a grading a paving business to recreate a demonstration ranch. Create one former ranch site as the original I working model -of a demonstration historic ranch. and preservation of sisal open space, working methods for visitor experience (as in other National Parks) Include early cattle, livestock shelters, early equipment and earliest home shelters.; (6) combine archaeology, Miwok seasonal gathering areas; hunting styles and transition to current ranching and ideal sustainable ranching in education film at Visitor Center. cultural transition to s current ranch activity demonstration in the Visitor Center as an adjunct to the Morgan Horse focus.
Use this cultural designation to continue in perpetuity a natural flow of ranch produced dairy products and services to meet and augment community needs.
Include in he visitor center visual documentation and orientation to surrounding Marin Agricultural Land Trust ( MALT) farming and sustainable such as methane conversion energy;; fertilizer from manure, native plant uses Point Reyes National Sea Shore mapping 0 Consider these as a whole to be historic by Native American and early settlers,
Provide sequential twenty year leases..
as property owners, Golden Gate Recreational Area (GGNRA) hall provide funds for maintenance and upgrading facilities while restoring and keeping ranch landscape.
Resolve elk containment by natural barriers- (e.g.) ha ha of English Capability Brown's landscape, electric fencing within traditional drift wood early fencing mode and herd size monitoring using acceptable fertility mitigation methods or transfer of elk to other formerly native habitats in National forests, monuments or parks.
Maintain the road to the light house; try to continue special road surfacing where exists by importing oyster shells from Tomales Bay commercial oyster harvesting and include traffic reduction to adverse impact by van shuttles from the Visitor Center
DOOCUMEMNT THAT RANCHING AND NATURAL ENVIRONMENTAL FISH, FIN FUR ARE ACCEPTABLE COMPONENTS: IN FUND CONTSTRAINED INTERNATIONAL PARKS:
Cultural resources are nonrenewable that adversely may not be restored by narrative and visually, sustainable recovery methods are already begun by park staff.
The International Union of Conservation and Natural Resources (OCUN), in order to world-wide best protect and manage significant historical, cultural or especial ecosystems identifies and defines them under six categories. Categories IB and VI are relevant to the discussion today and the decision of an EPR for the Point Reyes National Seashore's cattle ranches that have been operated by the same families since the 1860s.
IB Wilderness Area: Large protected area of land or sea managed mainly for wilderness protection and without permanent or significant habitation.
VI Managed Resource protected Area: a protected area managed mainly for the sustainable use of natural resource systems. An area containing predominate unmodified natural systems, managed to ensure long-time protection and maintenance of biological diversity, while at the same time providing a sustainable flow of natural products and services to meet community needs.
IB would not include as wilderness area the significant historic family ranches or small scale dairy farms The NPS recognizes and cooperates through studies and support for this long time maintenance of land use and visual scapes of the ranches and adjacent wild life. When subdivisions on the Point Reyes Peninsula in the 1950s threatened these historic ranches and views, families formed an alliance with the Sierra Club and other environmental groups to establish the park in 1962 that would include their ranches, vistas and habitat.
VI includes the currently National Park Service (NPS) recently avowed plan to renew for another 20 years the culturally historic. small scale ranch leases on Point Reyes National Seashore. The ranchers rightly view their family operations as an integral part of early California's west coastal history and their viable preservation of land use and adjacent habitats. Is a vial component of integrated parks . The ascertained historic Drakes Landing and the culturally historic ranch component of the Golden Gate National Recreation Area Drakes Landing sold be verified and A grading and paving business, any semi-industrial, construction, future mining or consolidated large conglomerate agricultural or dairy businesses or housing developments are not viable under VI. Any impact for a change from ranch comprehensive management within the larger visitor recreational area mandate, whether pre­ existing or considered in the future, shall not be permitted. within these public recreational I park lands
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# 2956
Name: Whitt, Michael
Correspondence: I was a general practitioner of medicine in Pt. Reyes Station for 44 1/2 years, retiring in 2015, and have been a strong supporter of agriculture in PANS - and in Marin County -from the beginning, as well as a strong supporter of the park's environmental mission, early on as president of the board of the Inverness Association, a life member of Point Blue - formerly Point Reyes Bird Observatory, whose first home was on the old Heims Ranch in the seashore - and a long-term member of the Environmental Action Committee.
I am writing to recommend that the tradition of dairy and beef-cattle ranching be continued by PANS with 20-year leases to the ranchers - as directed by President Obama's Secretary of the Interior Ken Salazar in a Decision Memorandum to the park - to insure the viability of their operations and the stability of ranching countywide.
At a time when attacks on our government are at an all-time high and trust is at an all-time low, it is especially important for the government to honor its stated commitment to agriculture. An EIR to help the park meet its obligation to endangered species and the introduction of better practices to mitigate the impact of cattle on the parklands is appropriate and will further cooperation between ranchers and the park. It should be remembered that after the park was founded with its dual mission of preserving ranchlands and wildlands, it served as a template for cooperation between environmentalists and agriculturists nationwide.
This is a tradition that should also be preserved.
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# 2957
Name: Tretiakoff, Dimitri
Correspondence: Please continue to allow ranching. Just give the ranchers more guidelines for stewardship. Remember that if it weren't for them, PT. Reyes wouldn't exist, it would have become another LA.
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# 2958
Name: Straus, Vivien
Correspondence: Thank you for the ability to comment during this process.
I grew up on a dairy in Marshall in West Marin and now own and manage that same farm.
I am in support of keeping the ranches in the park and giving them extended rolling leases of 20
years.
I love the park. And I truly believe the ranches can co-exist. Here are a few of my thoughts:
1.The mandate of the park is to maintain the culture and history of the region/park.
Commercial dairying and cheesemaking in California began on the Point Reyes peninsula. For this reason, the farms should stay.
2.Longer leases allow farms to obtain loans and thereby better maintain good stewardship practices (which cost money) and make needed repairs.
3.The elk should be kept out of the pastoral zone and away from the ranches. The intent, as I understand, was that they were to live in the Limantour and Tomales Point areas and not in the pastoral zone.
4.I suggest the park work with an organization that has experience in managing Tule Elk herds to help figure this out.
5.Considering that agriculture is a different set of skills, the management of overseeing the ranchers and maintaining good stewardship practices, could be overseen by an agricultural organization (like MALT, or something along those lines) or by hiring staff with an agricultural background. Sustainable practices should be outlined and monitored and supported.
6.I believe the ranchers should be allowed to diversify as well as be able to have housing for their families and workers.
7.The park's inclusion of the ranches make this park unique. That's exciting, and a good thing.
8.I worry that since these ranches comprise approximately 20% of the farms in Marin County, if they were to be closed, it would be the death knell for the rest of agriculture in the region. It's crazy to live in a region where there is so much talk about supporting local food. Yet, losing these farms will kill that option. We, in the San Francisco Bay Area, are lucky in that we're unlike the rest of the country where food travels an average of 1,500 miles to get to the plate.
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# 2959
Name: Pharis, Ronald
Correspondence: I hope you will consider keeping the ranches inside the seashore as working ranches. It was with the help of these same ranches that made the seashore possible. I think we can all live and work together to make this possible.
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# 2960
Name: Patton, Morgan
Correspondence: The Environmental Action Committee of West Marin (EAC) greatly appreciates the opportunity to provide comments on the Point Reyes National Seashore (Seashore) General Management Plan Amendment (GMPA). Since 1971, EAC has worked to protect and sustain the unique land, waters, and biodiversity of West Marin.
EAC is appreciative of the planning process for the GMPA and the opportunity to provide public comments on six proposed conceptual alternatives (Concepts) recommended by the Seashore. The GMPA addresses all lands currently under agricultural lease/permits in the Seashore and the north district of Golden Gate National Recreation Area. The Seashore is a unique landscape and EAC remains committed to our guiding principles to ensure the protection and preservation of natural resources, restoration of degraded habitats and park resources, and maximum public access to parklands.
Based on EAC's review of the 2006 National Park Service (NPS) Management Policies, when there is a conflict between the protection of resources and the use of those resources, conservation will be predominant, and concerns will be resolved with scientific study and public involvement, in order to pass on all park resources, not merely unimpaired, but in better condition, for the enjoyment of future generations.
The GMPA must protect, restore, and preserve park resources using ranch leases that ensure multi-generational, environmentally sustainable ranching is complementary to the natural resources and visitor experiences within the park.
EAC understands the six Concepts presented in the GMPA Newsletter are a 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 Concepts and should use this comment period to seek clarification, question the conceptual choices, and present information that is missing.
Based on this understanding, EAC offers the below comments and questions regarding the GMPA Newsletter. These comments are organized under the following eight areas of concern: 1) establishing a baseline, 2) management strategies and regulations, 3) diversification of
operations, 4) protection of natural resources, 5) climate change, 6) habitat protections, 7) habitat restoration, and 8) public access.
Establishing a Baseline
The GMPA Newsletter does not provide any information on the baseline for new leases. What is the baseline against which new leases will be measured? The baseline for environmental impacts should be the conditions and practices authorized by the existing leases. However, if a leaseholder has violated their permits, the unauthorized practices should not represent a baseline.
EAC supports an additional baseline measurement to evaluate ranching operations based on the 1962 enabling legislation that allows for ranching and dairying purposes within the pastoral zone.1
Management Strategies and Regulations
The GMPA should provide for clearly defined regulations concerning ranching operational practices in order to ensure the protection, restoration, and preservation of park resources
(natural and cultural). The GMPA Newsletter does not include information on how ranching will be conducted, a critical subject that must be clearly defined and made available for public comment before any new leases are issued. EAC has included several topics under this heading of management strategies and regulations for the Seashore's review and response.
2. a. Issuing Long-Term Permits
Concepts 2-52 propose issuing new long-term permits (20-year) to ranching operations. Any long-term leases should ensure lease holders are engaged in dairy and cattle ranching practices that are compatible with the Seashore's mission to protect park resources (natural and cultural), and that the operations are based on conditions and practices that are complementary to the natural resources and visitor experiences within the park. Additionally, if new permits are issued, EAC requests that they be made public and posted for maximum public transparency, while allowing any information that is considered proprietary to be redacted.
2. b. Constructing Long-Term Management Goals
Will the Seashore identify and include short and long-term management goals and metrics into the new leases? Ifso, what science-based criteria will be applied to determine the success of each of these goals? How will the Seashore update the goals and metrics in response to changed conditions?
2. c. Developing Permit Transparency, Compliance, and Incentives
Management guidelines for ranching permits should be transparent, consistent, and uniformly applied. EAC supports public disclosure of management metrics, monitoring of lease compliance, and habitat restoration efforts. We also support clear and timely consequences for non-compliance with permit terms. The leases should contain trigger mechanisms for
non-lease compliance and include public transparency when leases are violated.
2. d. Defining Succession Planning
Succession planning is an important part of the GMPA process, yet references to succession planning for the proposed long-term leases are missing from the Concepts. A transparent succession planning process is necessary before long-term leases are issued so that the public and the lease holders can understand the obligations and conditions ranchers must satisfy in order for a lease to pass to another family member. What is the Seashore's current policy for succession planning when a family no longer wishes to operate under their lease? Will the Seashore have a new proposal for the GMPA regarding succession? Ifso, what will that include? EAC understands that leases/permits for multi-generational dairy and cattle ranching operations may be issued to the existing lease holders.
2. e. Establishing Best Management Practices
Best Management Practices (BMPs) promote protection of park resources and provide the Seashore and lease holders with measureable outcomes and expectations for operating practices. The proposed Concepts reference "establish programmatic approaches for streamlined implementation of best management practices." Please define how programmatic approaches will be developed and what streamlined implementation means. What are the primary objectives of the BMPs?
EAC supports BMPs that promote the protection and improvement of park resources, with clear and measurable goals and outcomes being written into all the operational permits.
Sensitive resources like wetlands, riparian corridors, and estuaries are of particular concern. Water quality and the overall health of these important habitat areas must be adequately safeguarded.
2.f. Identify Authorized Measures for Operational Flexibility
Concepts 2-5 propose lease/permits that would identify authorized measures for "operational flexibility and diversification." It is important to differentiate and define these two terms.
EAC requests that the Seashore separate these terms in subsequent planning documents and define what operational flexibility means. In addition, we request that the Seashore provide an explanation of the process by which the Seashore will use to determine how operational changes impacting land-use intensity will not impair resources, and how those operational changes will be measured and evaluated.
3. Diversification of Operations
Diversification is an inherently ambiguous term that needs to be defined so that the public understands that diversification could bring about a dramatic shift of commercial land use within the Seashore. Diversification is proposed in Concepts 2-5, implying that the Seashore is considering authorizing some level of diversification in the lease/permits. The November 2014 Ranch Comprehensive Management Plan Update public workshop newsletter described diversification as
"an important activity for some ranchers, but typically the first priority is to improve pasture management and then focus on potential diversification opportunities ...
Diversification activities identified through the scoping process and ongoing discussions include the addition of new types of livestock, row crops, stabling horses, paid ranch tours and farm stays, small-scale processing of dairy products and sales of local agricultural products ..."
EAC understands authorized ranching operations are limited to dairy and cattle ranching, as intended by the enabling legislation. Therefore, in order to preserve the Seashore's natural and cultural resources, EAC does not support the conversion of land to commercial uses other than diary or cattle ranching.
3.a. Production of Silage
The Seashore has recorded 490 bird species (54% of all North American birds) and is located along the Pacific Flyway, a major north-south flyway for migratory birds extending from Patagonia to Alaska3. The Seashore currently allows some lease/permit holders in the pastoral zone to produce silage to provide forage for cattle. Mowing the silage fields is known to exterminate nesting birds.How does the Seashore ensure that nesting birds are protected during the production of silage to ensure compliance with the Migratory Bird Treaty Act and other federal laws? How does the Seashore ensure that allowances, procedures, and timing for silage production are followed?
EAC does not support the expansion of silage production outside of those locations that have currently permitted allowances for this practice, and encourages the establishment of a long­ term program to monitor silage production and mowing, and to levy penalties where limits are exceeded. Additionally, the Seashore should require silage producers to implement best management practices to reduce the impacts on nesting birds and require advance bird surveys before fields are mowed to ensure compliance with federal nesting bird protection legislation. Finally, there are successful no-till practices for silage that can be implemented within the Seashore to protect and conserve habitat and soil quality.
3.b. Proposals for Visitor Experience Diversification
The November 2014 Ranch Comprehensive Management Plan Update public workshop included references to events (large and small) as potential opportunities for lease holders to generate income through commercial activities other than dairy or cattle ranching. In order to ensure visitor experiences are managed and regulated by the Seashore, all events should go through Seashore headquarters for special use permits. Individual lease-holders should not have the authority to permit special major events as they could cause detrimental impacts to park resources that the Seashore would not be able to manage.
3.c. Authorization of Diversification
What level of diversified agricultural production could be allowed under the enabling legislation of the Seashore? EAC's reading of that legislation is that it provided for ongoing dairies and cattle ranch operations. What criteria and/or authority will the Seashore utilize to sanction diversification activities? If the Seashore plans to base those criteria on the intensity of land use, what baseline and scientific criteria will be utilized? Under what legal authority could the Seashore justify allowing diversified commercial agriculture that honors the preservation of park resources (natural and cultural)?
4.Protection of Natural Resources
The GMPA must protect, restore, and preserve park resources using ranch leases that ensure multi-generational, environmentally sustainable ranching is complementary to the natural resources and visitor experiences within the park.
The 2006 NPS Management Policies direct NPS to manage natural resources "to preserve fundamental physical and biological processes, as well as individual species, features, and plant and animal communities" and recognize all components of a natural system by preserving these processes in their natural conditions and avoiding resource degradation.4 Based on the management policies, what criteria will the Seashore utilize to ensure the preservation of natural resources, processes, and prevent degradation of habitats?
4. a. Tule Elk
The Seashore is the only national park5 with a native population of tule elk. The elk have been prevalent in the Bay Area and Marin for thousands of years, long before their extirpation in the 19th century. Tule elk are part of the Seashore's natural resources, just like the seals and whales, and are an important part of the Seashore's ecosystems. Considerations to manage the elk populations should be in the context of park policies to manage other natural resources of the Seashore. Based on these criteria, EAC offers comments on the elk management strategies.
The Concepts all reference "management" of the different elk herds. Please define management, and the tactics it includes. EAC is supportive of utilizing a diverse combination of management strategies, however EAC does not support culling or removing the herds.
The Philip Burton Wilderness area should not be manipulated or changed as part of any management strategy to accommodate the elk. Absolutely no structures should be authorized in the wilderness area that would diminish or compromise management of this dedicated wilderness.
Long-term leases and overall agriculture management strategies may strive to reduce conflicts and find a way to balance and accommodate the presence of both cows and elk, but the elk must not be managed for the purpose of benefitting commercial lease holders.
5. Climate Change
Climate Change will impact the park resources in the near future in many ways: to mention a few, sea-level rise, average temperature changes, changes in average rainfall totals, and distribution of species, both native and invasive. These impacts will alter the Seashore. For example, areas that border beaches and estuaries will experience flooding and migration of boundaries. This includes wilderness areas like Drakes Estero and Abbotts Lagoon that may eventually migrate into the pastoral zone. How will the Seashore manage changes to these bordering coastal areas?
EAC requests that the natural resources and buffers are prioritized, and suggests reduced ranching areas be designed with sea-level rise in mind. This would provide a reasonable basis to plan for pasture use for dairy and cattle ranching, while ensuring the long-term protection of park resources that will be subject to change in the foreseeable future. The Seashore should use the best available science to determine potentially impacted areas and to plan for the protection of the threatened natural and cultural resources. How will the proposed long-term leases incorporate flexibility for the Seashore to adjust for climate change impacts?
5. a. Carbon Farming Planning
Carbon farming is a set of management techniques that help to reduce the greenhouse gas emissions from a ranch through multiple techniques to sequester carbon. Carbon farming planning practices are being demonstrated on private lands in Marin County and through conservation easements managed by Marin Agricultural Land Trust (MALT). According to MALT's Carbon Farming website, the techniques used to reduce the overall greenhouse gas emissions include rotational grazing, woodland and stream restoration, native vegetation planting, no-till agriculture, dry-manure management, planting of hedgerows and windbreaks, methane capture, and compost application on pasturelands 6•
Carbon farming planning techniques that restore habitat, improve water quality, and promote no-till farming practices are excellent ways to sequester carbon and improve the natural resource conditions on the ranches. These techniques should be prioritized and emphasized by the Seashore as one way the ranches may become more sustainable in their environmental practices.
Carbon farming planning techniques should not impair park resources and techniques that may inappropriately impact park resources should be considered only after long-term scientific studies have been conducted. For example, compost spreading could obstruct public access and cause harm to native plants on the coastal prairie by stimulating growth of non-native plants. In addition, if methane capture digesters are considered, what is the size of the infrastructure and what is the intensity of land use?
6. Habitat Protections
The proposed Concepts indicate ''NPS would identify broad management strategies to preserve park resources ..." What management strategies would be applied and what criteria will be utilized to measure natural resources and cultural resources?
6. a. Water Quality
The GMPA should ensure that water quality is not impaired by ranching and dairying activities. Water quality characteristics affect the ability of species to persevere. In order to ensure healthy and balanced habitats, the water quality of streams, creeks, wetlands, and estuaries should be subject to independent research to determine the acid-base status, nutrient conditions, and chemical stressors. As part of the conditions of the 2006 NPS Management Policies, protection and restoration measures should be taken into account to improve the water quality of natural riparian habitats and preserve natural system components.
6. b. Resource Buffers
Resources buffers are essential to protect sensitive habitats and ensure ecosystem health. How does the Seashore determine which park resources are included in a buffer area?
Will resource buffers be designed to adjust over time, due to changing environmental conditions? How will the Seashore manage buffer areas that change with the landscape over time and due to climate change?
6. c. Pasture Management
EAC understands that the Seashore has adjusted its measurements of Residual Dry Matter (ROM) as of 2016 based on the 2015 Residual Dry Matter Analysis Report 7, and has
implemented an adaptive management technique to better understand the overall health and grazing patterns of the pasture grazing lands. How will the Seashore ensure that this type of important and comprehensive program continues year after year with limited personnel resources? In order to protect the rangelands and coastal prairies, what ROM techniques will be applied to ensure accurate measurement of the rangelands and prevent overgrazing? What actions will the Seashore take in response to indications of overgrazing?
6. d. Fencing
EAC supports the installation and maintenance of wildlife-friendly fencing to exclude cattle from sensitive resources and prevent degradation of natural habitat. Additionally, how much electric fencing is currently in use in the Seashore? EAC would not support this becoming the dominant form of fencing. The GMPA must analyze the cumulative impacts of electric fencing on public access and movement of wildlife.
6. e. Pesticides and Chemicals
The GMPA should require a permit/lease condition requiring a process for disclosure of the chemical types, storage techniques, and uses for pesticides, antibiotics, insecticides, herbicides, etc. to prevent these toxins from being released into the environment through improper storage, in the event of a natural disaster, or other inadvertent applications.
6.f. Integrated Pest Management (IPMs)
IPMs should be documented and approved by the Seashore before implementation by permit holders. Pesticides that have the potential to impact other species should not be applied under any conditions, for instance, rodenticides that would harm other species.
What is the current usage level of herbicides to control weed management? Is the current level assumed to be the baseline? Will the GMPA include a weed and pasture management plan? How will the Seashore evaluate and control the negative impacts of mowing as a weed management technique, including erosion and wildlife dangers? What priority will the Seashore place on restoration of native grasses?
7.Habitat Restoration
The proposed Concepts are deficient in references to restoration of habitats that have been degraded or impaired by ranching activities. It is important that habitat restoration (and protection) is a top priority of the GMPA. Specifically, water quality, erosion, native plant and species impacts must be prioritized over other strategies to ensure that ranching operations are meeting the highest possible environmental compatibility standards. What criteria will the Seashore use to review habitats within lease/permit areas? What opportunities will be available to lease/permit holders to engage in restoration activities?
7. a. Mitigation
The Seashore must determine that activities authorized in the GMPA will not impair park resources. What ranching and dairying activities require mitigation? How will the requirements for mitigation be re-evaluated over time due to changed conditions? What are the consequences of non-compliance with lease terms? Will the Seashore require that outstanding management issues and mitigation be addressed prior to the issuance of a new lease?
7.b. Native Grass Restoration
Restoration of native grasses must be included in the GMPA process to ensure a healthy pastoral zone. One method to support the reintroduction of native grasses would be to require that any lease holders who bring hay, hay cubes, straw, grain, and/or other crop or mulch products into the Seashore be required to use certified "weed free" products based
on the standards of the North American Weed Management Association, regardless of how they are used (feed, livestock bedding, erosion control, etc.)8.
7.c. Endangered Species
The 2006 NPS Management policies specifies that natural resources will be managed to preserve fundamental physical and biological processes. In the cases of special status and endangered species, NPS is legally compelled to protect habitat. How will the Seashore ensure that endangered species habitats are protected for established or newly discovered species? How will the Seashore anticipate and plan for protecting these habitats over time given changing conditions?
8.Public Access
The Concepts propose review of visitor carrying capacities and enhanced visitor experiences. EAC supports maximum public access to parklands, recognizing the respect needed within the ranch core. How will the Seashore improve visitor experiences working with ranchers to ensure clear signage, access points through gates, and maintaining trails? EAC would like to see improved visitor interpretation in areas of the pastoral zone and the removal of locks that prevent public access to these parklands. How will the Seashore evaluate and respond to visitor use in highly impacted areas that is damaging and impairing park resources, e.g. at Bass Lake in the Seashore? How will the Seashore establish visitor carrying capacities to manage public use while concurrently protecting park resources? What enhanced visitor experiences will be prioritized as part of the GMP amendment process?
Conclusion
Thank you for this opportunity to present comments. EAC looks forward to actively participating in the GMPA process. EAC would like to see the GMPA protect, restore, and preserve park resources using ranch leases that ensure multi-generational, environmentally sustainable ranching that is complementary to the natural resources and visitor experiences within the park. Specifically, impacts to water quality, erosion, native plant and species must have the highest priority to ensure that park management achieves the greatest possible level of natural resource protection.
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# 2961
Name: Coda, James
Correspondence: Your request for comments on a conceptual range of alternatives for a General Management Plan Amendment is extremely disappointing. It reads like a re-shuffled version of your unlawful ranch management plan proposal and, like the ranch plan proposal, it ignores your statutory duty for management of the two parks. Furthermore, the fact that you have identified your ranch plan proposal at this early stage as your "initial proposal" for how these 28,000 acres of land should be managed shows a bias, or pre-judgment, in favor of ranching before the GMP planning process has even begun.
Under the court settlement (and applicable law), you are supposed to be conducting a public process under your GMP statute to objectively determine the best use of these 28,000 acres. In doing so, you must adhere to the laws applicable to the two parks which require that the lands be managed first and foremost to protect their natural resources. You ignore this.
According to your planning procedures, a GMP begins with a Foundation Statement.
The Foundation Statement - The planning process begins with the development of a foundation statement that is based on the park's enabling legislation . . . and that documents the park's purpose, significance, fundamental resources and values, and primary interpretive themes. It also includes any relevant laws . . . that apply to the national park system or the individual park unit. The foundation statement
is generally developed early, as part of the public and agency scoping and data collection for the [GMP] 1
Director's Orders 2.2. (Emphasis added.)
The "relevant laws" in this case are the PRNS statute, the GGNRA statute and the Organic Act. The parts of those laws that actually control what you can do (and not do) going forward are relatively short.2
The Point Reyes National Seashore legislation provides, in pertinent part, as follows:
§ 459c-6. Administration of property
Protection, restoration, and preservation of natural environment
Except as otherwise provided in sections 459c to 459c-7, . . . the property . . . 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 ... the maximum protection, restoration, and preservation of the natural environment within the area, subject to the provisions of sections 1, 2, 3, and 4 of this title ...and in accordance with other laws of general application relating to the national park system as defined by sections 1b and 1d of this title 3
U.S.C. § 459c-6. (Emphasis added.)
The GGNRA legislation provides, in pertinent part, as follows:
§460bb - Establishment
In the management of the recreation area, the Secretary . . . shall utilize the resources in a manner which will provide for recreation and educational opportunities consistent with sound principles of land use planning and management. In carrying out the provisions of this subchapter, the Secretary shall 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.
16 U.S.C. § 460bb. (Emphasis added.)
2 Needless to say, you would have to comply with these laws regardless of what a Foundation Statement might say.
3 From the quoted language it is clear that the Park Service is required by law to manage
the park in such a way as to not cause "impairment of its natural values." The law goes on to make clear that even traditional uses of national parks, namely "recreational, educational,
historic preservation, interpretation, and scientific research opportunities" are allowable [only] to the extent "consistent with ... the maximum protection, restoration, and preservation of the natural environment within the area ...." The highest priority is to not impair natural values.
Recreation, education, historic preservation, etc. are all subject to that highest priority.
The Organic Act provides, in pertinent part, as follows:
§ 100101 (a) In General-
The Secretary . . . shall promote and regulate the use of the National Park System by means and measures that conform to the fundamental purpose of the System units, which purpose is to conserve the scenery, natural and historic objects, and wild life in the System units and to provide for the enjoyment of the scenery, natural and historic objects, and wild life in such manner and by such means as will leave them unimpaired for the enjoyment of future generations."
54 U.S.C. § 100101(a). (Emphasis added.)
These three laws make clear that your overarching management obligation is to protect the natural resources of these park units. While I think it is implied in all three laws, Congress even specifically ordered the "maximum . . . restoration ... of the natural environment" in the seashore statute. Ranching, on the other hand, is discretionary. It can only be allowed to the extent it doesn't violate these statutes. Generally, ranching involves the subjugation of nature. As it is being practiced in the two parks, it can't be squared with your duty to protect and restore nature.
You should read these three laws again because their importance cannot be overstated. Their words control everything you might do that would have any effect on the lands and resources of each park.
While a Foundation Statement may contain more words, these three statutory provisions are the only words you are required to follow. Everything else you might do is discretionary (or unauthorized). Ranching is discretionary. That means it can only be allowed to the extent it doesn't run afoul of the three statutes quoted above. And let's be honest, ranching is extremely harmful to natural resources and that is prohibited by the three statutes. The Park Service has been violating these three statutes for as long as it has allowed ranching in the two parks.
Finally, instead of focusing on the question of whether these lands should continue in ranching or not, you are getting into details in the alternatives that are distracting and that should be decided later if ranching is the decision you make. Your planning procedures define a GMP as follows:
[A GMP] is a broad umbrella document that sets the long-term goals for the park based on the foundation statement. The [GMP] (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 park's 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.
Director's Orders 2.2. (Emphasis added.)
The question for this GMP is whether ranching should continue or whether the land should be allowed to return to a natural condition.
YOUR LISTED ALTERNATIVES
alternatives (except no ranching) read like they were written by the ranchers. Furthermore, all of them (except no ranching) ignore the fact that ranching is prohibited if it harms natural resources. Some small amount of ranching at one location to demonstrate how ranching was conducted historically might be allowable, but turning over 28,000 acres to private ranching serves no park purpose and does tremendous harm to the parks' natural resources which you are obligated by law to protect and restore. In short, ranching doesn't trump protection and restoration of natural resources (including elk) as required by the laws you have a duty to carry out. To date, you and your predecessors have ignored this.
comments on the alternatives are set forth below. With the exception of the first alternative, they should all be rejected as unlawful. You could try to develop one or more acceptable alternatives that begin with the requirement that management of the area will be done in strict accordance with the above statutes and with no harm to natural resources. However, it is virtually impossible to conduct profit-driven ranching without harming natural resources.
Alternative 1. No Ranching and Limited Management of Elk.
Under this alternative, you state that ranching would be phased out over a period of five years. However, ranching has already been extended five years for the planning period to decide if ranching should continue. I don't see why ranching should continue for five more years for a phase-out.
You state that the ranch lands would be converted from ranching to not-for-profit education, research, outdoor recreation and other opportunities. Even your alternative of "no ranching" is problematic. It is premature and unrealistic to envision that if ranching is removed the area should be converted to not-for-profit education, research, outdoor recreation activities and other opportunities. The most logical thing to consider is to let the 28,000 acres return to a natural condition, as in the elk reserve, with possible human assistance in removing non-native vegetation and planting native vegetation. This would be in keeping with your statutory management obligations, such as the duty to "preserve the recreation area . . . in its natural setting" and to provide "the maximum protection, restoration, and preservation of the natural environment within the [seashore] area."
You state that you would coordinate prescriptive grazing in priority areas to maintain native and rare plant communities. I assume this implies cattle grazing. Why are you so fixated on cattle? You work for the National Park Service, not the Bureau of land Management. Rather than bringing in cattle to "maintain native and rare plant communities," you should let nature take its course and use other means, such as human labor (removing non-native plants and planting native plants), to restore the area to the natural environment it was before cattle were introduced, the vegetation types were thereby altered, the elk were shot, and the natural environment was, for the most part, wiped out. You have statutory obligations to, among other things, "preserve the recreation area . . . in its natural setting" and to provide "the maximum protection, restoration, and preservation of the natural environment within the [seashore] area."
The free-range elk herd would continue to expand with limited to no population management. If ranching is discontinued you should state here that the 8-foot fence separating the elk reserve and the ranches would be removed. There would no longer be any reason to keep the captive elk locked up.
You state you would " identify broad management strategies to preserve park resources . . . ." The first broad management strategy to preserve park resources would be the end of ranching. But you need to do more. Ranching has destroyed these 28,000 acres. You have a duty to restore these lands and their natural resources. This includes, among other things, removing non-native vegetation and planting native vegetation.
Alternative 2. No Dairy Ranching and Management of the Drakes Beach Elk Herd.
Under this alternative, dairy ranching would be stopped and the dairies would be allowed to convert to beef cattle operations. You don't state any benefit, but damage from cattle would be reduced because milk cows damage the environment more than beef cattle. Also, Johne's disease would be greatly reduced because it is most prevalent in dairy herds.
A. You state that the beef cattle (and former dairy) ranches would be given 20-year leases. You can't state that beef ranching would continue (including on former dairy lands) and that 20-year leases would then be issued to all ranchers because you don't know now that that would comply with your obligations under the three laws above that you are required to follow. Ranching is harming the natural resources of the parks just as grazing is harming the natural resources of BLM and Forest Service lands. There is evidence of that harm all over the parks. You are required to administer the lands in such a way that protection of natural resources is your overarching goal.
You state that the leases "would identify authorized measures for operational flexibility and diversification and to establish [sic] programmatic approaches for streamlined implementation of best management practices." It is premature to propose that at this stage because you don't know if doing so would violate your statutory duty to protect natural resources, just as you don't know if ranching in the first place would violate your statutory duty. You don't explain what these words and phrases mean so the public can't comment on them. While I don't know what most of the words mean, because you haven't explained them, I assume diversification means what it meant in the ranch management plan. Allowing any livestock on these ranches smaller than cattle, such as pigs, sheep, goats, as well as free-roaming turkeys, chickens, geese, ducks etc. will create extreme predator conflicts that will result in killing of predators or harming them directly or indirectly, in violation of your statutory duty to protect natural resources, including wildlife. It will also require much more restrictive fencing that will reduce wildlife habitat and restrict wildlife movement. Allowing the planting of row crops will also cause problems to natural resources, including, but not limited to, reduced habitat for wildlife; the use of fencing that is
more impermeable to wildlife travel than the current barbed wire fencing which will further impede wildlife travel across thousands of acres of land; and the use of herbicides and pesticides, including dangerous chemicals injected into the ground where artichokes4 and certain other crops are grown and which may then enter the groundwater of the park.5 Any other diversification ideas are also contrary to the three statutes above.
You state that the " Drakes Beach tule elk population would be managed at a level compatible with authorized beef cattle ranching operations." You make a similar statement regarding the Limantour - Estero Road herd. You are basically saying that ranching trumps the "protection, restoration and preservation" of elk (and other natural resources). It doesn't. All Park Service employees should know that based on the Organic Act. Furthermore, you should know that even more so because of the language quoted above from your seashore statute. Apparently, you are not alone in not knowing that your primary duty is to protect nature. In his book "Preserving Nature in the National Parks," retired NPS employee Richard Sellars writes that the Park Service has never protected nature, in spite of its Organic Act. According to Sellars, at its core the Park Service has never been more than a tourist agency, in spite of its mandate to protect natural resources. It should also be kept in mind that tule elk are not abundant. Their numbers today are not much above the level that was protected under the Endangered Species Act a few decades ago. They are not that much better off, numbers-wise, than the California sea otter, which is still protected under the Endangered Species Act.
You state you would " identify broad management strategies to preserve park resources . . . ." The first broad management strategy to preserve park resources is to end ranching. But you need to do more. Ranching has destroyed the ranching lands. You have a duty to restore these lands and their natural resources. This includes, among other things, removing non-native vegetation and planting native vegetation.
Alternative 3. Reduced Ranching and Management of the Drakes Beach Tule Elk Herd.
Under this alternative, ranching would be reduced by 7,500 acres. Another alternative would be to combine your alternatives 2 and 3.
A. You state that the areas you would close have been selected to minimize the overall impact on the Point Reyes Peninsula dairy ranches and the Olema Valley dairy ranches historic districts. This means no consideration was given to what reductions would be best for carrying out your statutory duty to protect the natural resources of the 28,000 acres which is your first obligation. Your focus is on what is best for ranching, as was the case in the ranch management plan.
4 While the ranchers have mentioned artichokes as a possible row crop, it is likely that some will want to grow wine grapes and, to the extent it is now legal in California, marijuana. Each is far more profitable than artichokes. This comment applies to all your alternatives, except the no ranching one.
5 Speaking of groundwater, you should investigate and discuss how much groundwater would be needed to irrigate each type of row crop.
You state that most of the areas to be closed don't have developed ranch complexes or residential use and will thus have the least impact on ranching. Again, this shows a bias toward continuing ranching and disregard for your statutory duty of protecting natural resources above all else.
You state that the remaining 20,000 plus acres would be leased for 20-year terms. You can't state that ranching would continue and 20-year leases would be issued to all ranchers because you don't know now that that would comply with your obligations under the three laws above that you are required to follow. Ranching is harming the natural resources of the parks just as grazing is harming the natural resources of BLM and Forest Service lands. There is evidence of that harm all over the parks. You are required to administer the lands in such a way that protection of natural resources is your one overarching goal.
You state that the leases "would identify authorized measures for operational flexibility and diversification and to establish [sic] programmatic approaches for streamlined implementation of best management practices." It is premature to propose that at this stage because you don't know if doing so would violate your statutory duty to protect natural resources, just as you don't know if ranching in the first place would violate your statutory duty. You don't explain what these words and phrases mean so the public can't comment on them. While I don't know what most of the words mean, because you haven't explained them, I assume diversification means what it meant in the ranch management plan. Allowing any livestock on these ranches smaller than cattle, such as pigs, sheep, goats, as well as free-roaming turkeys, geese, chickens, ducks etc. will create extreme predator conflicts that will result in killing of predators or harming them directly or indirectly, in violation of your statutory duty to protect natural resources, including wildlife. It will also require much more restrictive fencing that will reduce wildlife habitat and restrict wildlife movement. Allowing the planting of row crops will also cause problems to natural resources, including, but not limited to, reduced habitat for wildlife; the use of fencing that is more impermeable to wildlife travel than the current barbed wire fencing which will further impede wildlife travel across thousands of acres of land; and the use of herbicides and pesticides, including dangerous chemicals injected into the ground where artichokes and certain other crops are grown, which may then enter the groundwater of the park. Any other diversification ideas are also contrary to the three statutes above.
You state that the " Drakes Beach tule elk population would be managed at a level compatible with authorized ranching operations." You make a similar statement as to the other wild herd, the Limantour/Estero Road herd. You're not paying attention to your statutory obligations. The obligation to protect and restore natural resources, including wildlife such as elk, trumps commercial ranching which can only be allowed by you if it doesn't harm natural resources. Ranching is harming natural resources. Elk are the statutorily protected animal, not cattle. How can you justify ranching, which is not required in the Seashore, with reducing elk numbers which you have a statutory duty to protect, restore and preserve? You can't.
You state you would "identify broad management strategies to preserve park resources . . . ."
The first broad management strategy to preserve park resources is to end ranching. But you need to do more. Ranching has destroyed the ranching lands. You have a duty to restore these lands and their natural resources. This includes, among other things, removing non-native vegetation and planting native vegetation.
Alternative 4. Continued Ranching and Management of Drakes Beach Elk Herd (NPS Initial Proposal).
Under this alternative, ranching would continue and the ranchers would be given all that they asked for with the Ranch Management Plan, except elk would be managed, not totally eliminated. This was your preferred alternative under the Ranch Management Plan.
A. You state that ranching would continue and the ranchers would be given 20-year leases. You can't state that ranching would continue and that 20-year leases would be issued to all ranchers because you don't know now that that would comply with your obligations under the three laws above that you are required to follow. Ranching is harming the natural resources of the parks just as grazing is harming the natural resources of BLM and Forest Service lands. There is evidence of that harm all over the parks. You are required to administer the lands in such a way that protection of natural resources is your overarching goal.
B. You state that the leases " would identify authorized measures for operational flexibility and diversification and to establish [sic] programmatic approaches for streamlined implementation of best management practices." It is premature to propose that at this stage because you don't know if doing so would violate your statutory duty to protect natural resources, just as you don't know if ranching in the first place would violate your statutory duty. You don't explain what these words and phrases mean so the public can't comment on them. While I don't know what most of the words mean, because you haven't explained them, I assume diversification means what it meant in the ranch management plan. Allowing any livestock on these ranches smaller than cattle, such as pigs, sheep, goats, as well as free-roaming turkeys, geese, chickens, ducks etc. will create extreme predator conflicts that will result in killing of predators or harming them directly or indirectly, in violation of your statutory duty to protect natural resources, including wildlife. It will also require much more restrictive fencing that will reduce wildlife habitat and restrict wildlife movement. Allowing the planting of row crops will also cause problems to natural resources, including, but not limited to, reduced habitat for wildlife; the use of fencing that is more impermeable to wildlife travel than the current barbed wire fencing which will further impede wildlife travel across thousands of acres of land; and the use of herbicides and pesticides, including dangerous chemicals injected into the ground where artichokes and certain other crops are grown, which may then enter the groundwater of the park. Any other diversification ideas are also contrary to the three statutes above.
Next you state that the " Drakes Beach tule elk population would be managed at a level compatible with authorized ranching operations." You go on to state that "[m]inimum and maximum population thresholds would be established . . . ." You add that you could also "implement actions to manage . . . the Limantour-Estero herd." You're not paying attention to
your statutory obligations. The obligation to protect and restore natural resources, including wildlife such as elk, trumps commercial ranching which can only be allowed if it doesn't harm natural resources. Elk are the statutorily protected animal, not cattle. How do you justify ranching, which is not required in the Seashore, with reducing elk numbers which you have a duty to protect, restore and preserve? You can't.
You state you would identify broad management strategies to preserve park resources . . . ." The first broad management strategy to preserve park resources is to end ranching. But you need to do more. Ranching has destroyed the ranching lands. You have a duty to restore these lands and their natural resources. This includes, among other things, removing non-native vegetation and planting native vegetation.
Alternative 5. Continued Ranching and Removal of the Drakes Beach Elk Herd (Ranchers Preferred Alternative).
Under this alternative, ranching would continue, but all the elk would be "removed" (likely by shooting because they have acquired Johne's disease from the cattle and therefore can't be moved outside the seashore).
A. You state that ranching would continue and the ranchers would be given 20-year leases. You can't state that ranching would continue and that 20-year leases would be issued to all ranchers because you don't know now that that would comply with your obligations under the three laws above that you are required to follow. Ranching is harming the natural resources of the parks just as grazing is harming the natural resources of BLM and Forest Service lands. There is evidence of that harm all over the parks. You are required to administer the lands in such a way that protection of natural resources is your overarching goal.
You state that the leases "would identify authorized measures for operational flexibility and diversification and to establish [sic] programmatic approaches for streamlined implementation of best management practices." You can't propose that at this stage because you don't know if doing so would violate your statutory duty to protect natural resources, just as you don't know if ranching in the first place would violate your statutory duty. You don't explain what these words and phrases mean so the public can't comment on them. While I don't know what most of the words mean, because you haven't explained them, I assume diversification means what it meant in the ranch management plan. Allowing any livestock on these ranches smaller than cattle, such as pigs, sheep, goats, as well as free-roaming turkeys, geese, chickens, ducks etc. will create extreme predator conflicts that will result in killing of predators or harming them directly or indirectly, in violation of your statutory duty to protect natural resources, including wildlife. It will also require much more restrictive fencing that will reduce wildlife habitat and restrict wildlife movement. Allowing the planting of row crops will also cause problems to natural resources, including, but not limited to, reduced habitat for wildlife; the use of fencing that is more impermeable to wildlife travel than the current barbed wire fencing which will further impede wildlife travel across thousands of acres of land; and the use of herbicides and pesticides, including dangerous chemicals injected into the ground where artichokes and certain other crops are grown, which may then enter the groundwater of the park. Any other diversification ideas are also contrary to the three statutes above.
You state that the " Drakes Beach tule elk population would be "removed" (presumably shot) using methods established through this planning process." You're not paying attention to your statutory obligations. The obligation to protect and restore natural resources, including wildlife such as elk, trumps commercial ranching which can only be allowed if it doesn't harm natural resources. Elk are the statutorily protected animal, not the cattle. You can't justify killing or otherwise removing all the Drakes Beach elk for the benefit of ranching when you have a statutory duty toward the former and no duty toward the latter.
You state you "would identify broad management strategies to preserve park resources . . . ." Let me get this straight. You're saying that after you shoot all the elk you would then identify broad management strategies to preserve park resources? I'm at a loss for words.
The first broad management strategy to preserve park resources is to end ranching. But you need to do more. Ranching has destroyed the ranching lands. You have a duty to restore these lands and their natural resources. That includes, among other things, removing non-native vegetation and planting native vegetation.
Alternative 6. Continue Current Management (No action alternative).
Under this alternative, you state that ranching would go on as it has in recent years under short term leases or permits of 5 to 10 years.
While continuing current ranching could be an alternative, it isn't the same as no action. If you take no action, ranching would end with the expiration of the current 5-year leases. No action is essentially the same as your first alternative. If you mean to say that ranching would continue as it has been conducted for many years, you can't really state that because you don't know now that that would comply with your obligations under the three laws above that you are required to follow. Ranching is harming the natural resources of the parks just as grazing is harming the natural resources of BLM and Forest Service lands. There is evidence of that harm all over the two parks. You are required to administer the lands in such a way that protection of natural resources is your overarching goal.
Alternative 7. [Additional Alternative.] Manage the lands with protection, restoration and preservation of natural resources as the overarching priority. Ranching only allowed to
the extent it causes no harm to natural resources.
All of your conceptual alternatives violate your statutory responsibilities, except the no ranching one. While I favor elimination of ranching because it doesn't belong in a national park and can't be conducted without harming natural resources, you could try to develop an alternative that would be closer to meeting your statutory obligations. It would have to start with the assumption that the three statutes above apply and that therefore protection of all natural resources limits what can be done ranching-wise.
NPS Questions on page 12 for consideration by the public as it prepares its comments:
"How can Point Reyes protect and manage the diverse and important natural and cultural resources in the planning area? Are there opportunities that could enhance future stewardship in the planning area"?
Your statutory duty is to protect, restore and preserve the natural resources of the area.
"What types of visitor experiences, activities, and facilities should be available in the planning area"?
Your statutory duty is to protect, restore and preserve the natural resources of the area. After ranching is ended, consideration can be given to more specific uses in implementation plans.
"What types of specific strategies can/should be considered for managing agricultural lease/permits"?
Your statutory duty is to protect, restore and preserve the natural resources of the area. You should end ranching. You can't manage these lands and their natural resources in the way you are required to do and still allow ranching.
"What types of specific strategies can/should be considered for managing tule elk"?
Your statutory duty is to protect, restore and preserve the natural resources of the area. You have very little discretion here. You have to manage the elk in a way that is best for the elk. You can't do anything that would favor ranching that would harm elk in any way.
Additional Comments
Impacts of Ranching and Cattle Grazing
Cattle grazing causes significant impacts to the environment including, but not limited to, compression of soil due to the heavy weight of cattle; erosion of soil and faster runoff of rainwater due to that compression (and overgrazing), especially in hilly areas where cattle make deep trails; damage to plant life by overgrazing and trampling; conversion of native plants to non-native plants; damage to water quality; damage to air quality and concomitant increase in global warming; and harm to all forms of wildlife, including endangered and threatened species. As for wildlife, some of the ways ranching and cattle harm or kill wildlife are as follows: overgrazing; using fencing that is not "wildlife friendly;" disposing of manure by spraying it on pastures which can infect elk and deer with Johne's disease; pollution of streams and bays;7 and the mowing of silage in the spring which kills any ground-nesting or near-ground-nesting birds.
6 Johne's disease exists in some of the cattle herds in the seashore and, probably, the recreation area. It has been infecting the elk in the seashore since they were introduced. The Park Service should establish a rigorous five year program to eliminate Johne's disease,
Furthermore, most of the cattle in the seashore are dairy cows. Dairy farming has much greater impacts on the environment than beef cattle ranching, including, but not limited to, greater forage consumption, greater water consumption, greater manure production (and related greater collection and disposal problems), greater methane gas production, greater water pollution, greater trampling of vegetation and soils due to the fact that milk cows tend to not go any farther than necessary to graze given the need to return to the milk barn two to four times (round trips) per day, and greater erosion due to cattle making those two to four round trips per day to and from the milk barn, especially when they travel through hilly areas and create deeply rutted trails on slopes.
On most federal public lands grazing occurs for only a portion of the year and is limited to beef cattle. The rest of the year the cattle are on private ranch lands. In the seashore and the recreation area the grazing is year-round. Plus, the ranches themselves are on park lands and they can occupy many, many acres.
Attached hereto as Exhibit A, and incorporated herein by reference, is a declaration signed by me and filed in the Resource Renewal Resource v. National Park Service litigation which resulted in the settlement providing for the subject GMP Amendment. It sets forth some of the impacts I have seen from ranching in the seashore.
Need for Impact Studies
Given the many kinds of impacts ranching is having on the lands in these two parks, you will need to do scientific studies to assess those impacts in detail in order to make any decisions on whether and to what degree any ranching can be allowed.
Succession
While not mentioned in your 12-page request for comments, it is common knowledge that the ranchers want some kind of right of succession so that when a lessee dies his heirs have a right to succeed him as lessees and when those heirs die their heirs succeed them as lessees and so on in perpetuity. There is no right to succession currently and the Park Service should not attempt to create one. When a lessee dies, the land should be returned to a natural condition for national park purposes. Moreover, while the Park Service has the authority to lease land for ranching, where "appropriate" (no harm to natural resources), it doesn't have the authority to create any rights in land other than leases.
testing and culling. See https://johnes.org/general/control.html
7 While the pollution of Tomales Bay and Drakes Bay due to seashore and recreation area ranching is well known, there are other areas in the two parks that are heavily polluted from ranching that aren't well known. One example is Kehoe Creek.
Charging Fair Rental Amounts
The park has been leasing the ranches at well below fair market rental value. That is unlawful. Federal officials have an obligation to collect fair market value for all federal assets. The difference between fair rental value and actual lease amount constitutes an unauthorized gift by the federal official who signs each lease. You should be obtaining the same rent amount as comparable ranch lands rent for outside the parks. The rationales the seashore has been using for subsidizing ranching are unsupported.
Failure to Monitor Unlawful Grazing Numbers
It is widely believed that some ranchers have more cattle than allowed under their leases. The Park Service readily admits it doesn't do livestock counts. However, it could do livestock counts and, as trustee of these public lands, it should do such counts. As a private individual, I don't have the wherewithal to do such counts, but I have seen one instance where there were clearly more livestock than allowed. Attached hereto as Exhibit B, and incorporated herein by
reference, is an April 18, 2017, email I sent to Superintendent Cicely Muldoon enclosing a photo of 42 sheep on the M (Grossi) Ranch that I took on April 15, 2017. In the email I stated that the photo showed 42 sheep and that the M Ranch lease only authorized 5 sheep for personal use (in addition to the number of cattle it was authorized). In the email I asked Supt. Muldoon if the seashore would "require the immediate removal of the excess sheep and provide some penalty commensurate with the violation of the lease term and the overgrazing." I also stated that the overstocking "underscores the concern of many people that some ranchers are grazing more cattle then their leases/permits allow." Ms. Muldoon never responded. Also attached to Exhibit B is a photo taken on August 16, 2017, showing 25 sheep at the same location on the M Ranch. If the Park Service isn't enforcing sheep numbers, it's reasonable to assume it isn't enforcing cattle numbers either.
Livestock Fencing
fencing (most commonly barbed wire) can kill and injure wildlife. However, it can be constructed to be much less harmful to wildlife. Such fencing is commonly referred to as "wildlife friendly." On BLM grazing lands where deer or elk exist the specifications are: three wires, top wire 38 inches above ground, bottom wire to be smooth wire (non-barbed) and 16 inches above ground (for fawns and elk calves to get under) and at least 12 inches clearance between the top wire and the middle wire (to prevent "scissoring" or trapping hind legs between the top two wires). Unfortunately, to the best of my knowledge, none of the fencing in the parks is wildlife friendly. Attached hereto as Exhibit C, and incorporated herein by reference, is an article I wrote about fencing in the seashore and how none of the fencing that I examined is "wildlife friendly." As long as there is any ranching in the parks, all fencing should be "wildlife friendly."
Miscellaneous Issues
In addition to the matters above, there are a number of other problems that stem from the ranches. Some are listed below. Each needs to be studied and information disclosed during the GMP process.
Frequent road trips by heavy milk trucks, tanker trucks filled with manure, and 18-wheel hay trucks do tremendous damage to roads and cattle guards in the ranching areas. It is believed the ranchers pay nothing toward such damage. They should. Please investigate and provide information for public comment.
Most, if not all ranches, especially the dairy ranches, have several housing units over and above the main ranch house. Some appear to be very substandard and may not meet basic housing requirements, including sanitation requirements. Please investigate and provide information for public comment.
As stated above, most, if not all ranches, especially the dairy ranches, have several housing units over and above the main ranch house. There are reports that some ranchers sublease those housing units to people who have nothing to do with the ranch's business. Such subleases are unauthorized. There are also reports that some ranches make substantial profits from charging employees and non-employees for these housing units. This is especially true because the ranchers in the parks pay roughly half what ranchers outside the parks pay for comparable ranch leases. Please investigate and provide information for public comment.
Conclusion
You are supposed to be starting a public and objective process to decide the best use of these 28,000 acres of land. It's basically a question of whether ranching, with all of its negative impacts on natural resources, should be allowed to continue or whether the land should be allowed to heal and return to a natural state. In that process you are required to follow the three statutes quoted at the beginning of my comments that require you to manage these lands with protection of natural resources as your primary duty. Based on your invitation for comment, I can't help but conclude that you have already decided in favor of ranching and its negative impacts to natural resources.
References
Declaration of James Coda in support of plaintiffs' motion for preliminary injunctive relief. Case No. 4:16-cv-00688-SBA (KAW).
Point Reyes National Seashore; Fencing Harmful Wildlife. https://jmcoda.wordpress.com/2014/07/26/point-reyes-national-seashore-fencing-hamrful-to-wildlife/. 6/26/2014
___________________________
# 2962
Name: Hoffman, Walter
Correspondence: Have any of us walked a beach and witnessed creeks running green with cow manure or seen green foam in the shore break of the Great Beach of Point Reyes National Seashore? I have!
I have had it! No more cows or cow related equipment in our beautiful park. It's crazy we've gone this far (150 years) of this pollution and still continue to avert our eyes to this crime to nature in a national park. For Christ sakes, and get away with it.
I love our park. It deserves much better. Let the elk roam far and wide, Bolinas to Bodega, Fairfax to ocean reduce speed limit to 15 on high way one, slow down and smell the ceanothus.
___________________________
# 2963
Name: Hardin, Lois
Correspondence: I think the ranchers should remain in the Pt. Reyes National Seashore with 30 year leases.
Some of the ranchers were operating since 1860, long before the park was established in 1962. In fact, they sold their land so the park could exist.
20 years leases would allow ranchers to make long term decisions on improvements and established new environmental practice to keep up with the times.
Tule elk need to be controlled so they don't interfere with the ranchers.
It's a joy to drive to the lighthouse and see cattle grazing on the hillsides. It's part of West Marin history and needs to remain with help and support and go up leases.
___________________________
# 2964
Name: N/A, Lunny Ranch
Correspondence: Dear Superintendent MacLeod,
The Lunny Ranch is a member of the Point Reyes Seashore Ranchers Association
(PRSRA) and fully endorses the points made in the PRSRA scoping letter. This
letter is meant to focus more specifically on the Lunny Ranch (aka the Historic G
Ranch).
During the Shatter era, the same time frame the current historic working landscape
designation is meant to protect, the G Ranch, similar to other ranches on the Point
Reyes Peninsula, was quite diversified. A dairy, many large bams for cattle and
horses, a slaughterhouse to process cattle, sheep and hogs, a cheese processing
plant, pastures, hayfields, and worker housing all existed at the G Ranch. As
thousands of acres were under cultivation on the peninsula for artichokes, beans,
peas and other vegetables, it is quite likely that these crops were grown at the G
Ranch because most of the ranch is level with deep soil.
Post World War II, with the availability of inexpensive shipping, the landscape at
Point Reyes began to change. Ranchers realized that they did not need to depend
on the local food system to make a living. More money could be made by
concentrating all effort on the dairy, leaving traditional diversification behind. The
local diversified farms turned into a non-diversified dairy monoculture - shipping
feed in from distant locations and shipping milk to distant markets. This same
transition to large scale, single commodity agriculture was happening all over the
country. The Congress and the NPS created PRNS just after the conversion to a
cow-only, mostly dairy monoculture.
Before the time that the Lunny Ranch (G Ranch) was purchased by the federal
government in the 1970s to include in the Pastoral Zone of PRNS, the Lunny
family enjoyed hunting, fishing and water skiing (very occasionally) at Abbotts
Lagoon and the Lunny's cattle grazed from the edge of Drakes Estero to the edge
of Abbotts Lagoon. The Lunny family also had an annual 4th of July party on the
edge of the lagoon. The beef cows preferred calving in the clean sand in the sand
dunes. We milked about 250 cows at our dairy and we still had a few pigs around
from the time when every ranch had pigs. We could add any species of farm
animal we wanted - for commercial sale of meat, for our own consumption or for
management of invasive brush. We made decisions about stocking rates and
stocking densities that would utilize available forage, but never overgraze. We
took excellent care of our pastures and rangelands because our future depended on
it. When the Seashore was established, the Lunny Ranch had approximately 500
acres in crop production. We plowed, disked and planted oats, vetch, beans and
other forage crops and stored and fed the feed as silage. We had a makeshift
runway where fixed wing aircraft and helicopters would land, load with fertilizer,
and spread on the crop land. Much of the several thousand tons of silage produced
on the Lunny Ranch was sold to neighboring dairies. During this time, if a
building needed repair, we repaired it. If a waterline failed, we replaced it. If we
needed a water trough in a new location, we put it there.
Ranching at PRNS is very different today. We are no longer allowed to use the
sand dunes or Abbotts Lagoon, we are not allowed to make our own decisions
about stocking density or stocking rates, we are not allowed to cut brush, we are
now limited to only 180 acres for crop production, we are not allowed to choose
which livestock to raise on our pastures, we are not allowed to choose our crop
type, we are not allowed to sell excess forage to our neighbors, we are not allowed
to sell our products to the public from our farm location, we are not allowed to
repair our bams or other buildings, we are not allowed to replace water lines, we
are not allowed to install new fences and we are not allowed to implement other
NRCS approved BMPs. A few of these activities are currently possible following
a long, tedious and usually overly restrictive and sometimes duplicative
environmental review special permitting process. The Lunny family respects that
processes need to exist and processes need to be followed to protect the
environment of the Seashore. We ask that this EIS process evaluates the benefits
of having a plan that allows a programmatic approach to approvals for the
ranchers. Once implemented, such a seashore-wide approach could save PRNS
time, taxpayer dollars and ranchers' resources.
It is our understanding that NPS policy does not require that activities in a cultural
landscape present at the time of purchase be frozen in time, ignoring and/or
disallowing the rich historical activities and/or the need to allow modernization and
change from that moment in time. We have been very pleased with the fact that
the NPS has allowed significant changes, upgrades construction and development
to be undertaken over the years by the ranchers, which has allowed seashore
ranches to better compete in commodity markets. Since the 1960's when PRNS
was created, family farms generally strove to compete in a nationally price driven
commodity based agriculture, competing with large scale industrial agricultural
operations.
The reality for the small family farm has changed. Over the past decade or so, the
U.S. is losing approximately 50 family farms per week and big industrial
agriculture is getting bigger. Small family farms have realized that the secret to
survival is to begin to move away from large scale single commodity monoculture
and refocus on small scale diversified agriculture and local markets. The local
marketing allows small farmers to build local relationships, and to collaborate with
other ranchers on value added products processing and distribution. This "new"
model is actually a recreation of the traditional diversified farms found on the Point
Reyes peninsula during the Shafter era, not long before it became a unit of the
NPS.
The Lunny family appreciates the PRNS attempt to create a range of alternatives to
use in this EIS. Unfortunately, partially due to the settlement agreement
requirements, the range of alternatives is not balanced. We understand that there
should be a no action alternative. The problem is that the action alternatives
include a very extreme alternative that would end ranching altogether. To honestly
show a full range of alternatives, the NPS should include an alternative that
prioritizes cultural resource protection and ranching. None of the action
alternatives prioritize ranching. All action alternatives include elk on the pastoral
zone and none consider restoring ranching back into areas where grazing was
eliminated by PRNS and where grazing would be beneficial to the grasslands and
gateway communities if re-established. This includes areas in the Olema Valley
where fuel loads are increasing, and fuel ladders are forming up to the forested
ridge abutting private land. We appreciate that the PRNS initial proposal includes
ranching with 20 year permits, but are concerned that ranching may not remain
viable because of the elk conflicts built into this proposal. The Lunny family still
interprets the 1998 Elk Management Plan the same way that PRNS did in 2001 (see
attached copy of PRNS document "A Year in Review"), only 3 years after the plan
was completed.
Upon reading the PRSRA scoping letter, it is evident that all seashore ranchers are
encouraged and excited to see the PRNS focus on preserving the Shafter era
diversified agriculture as well. This gives new hope that our ranches and farms
will survive as viable businesses into the future. Without allowing the seashore
ranchers to recreate a small portion of the historic diversity and reasonable
operational flexibility, NPS would actually be contributing to the elimination of the
ranches and the loss of an important cultural resource.
The Lunny family has specific plans for the Lunny Ranch that, if necessary, this
EIS should evaluate so that PRNS can approve these changes in a long-term lease.
The Lunnys plan to return the ranch to a diversified farm consistent with the time
frame the National Historic Register means to preserve and protect, 1860 to 1960,
also described as the Shafter era. While doing so, recognizing that its location is
inside the highly visited working landscape of a national seashore, all
improvements will be ecologically responsible, compatible with public visitation,
public viewing, on-farm tours and educational opportunities. The Lunny Ranch
will become a current time, viable reflection of what originally protected Point
Reyes and what made Point Reyes worth protecting into the future.
1. Restore the dairy operation. The Lunnys operated a Grade A dairy for most
of its tenure on the G Ranch. The dairy was closed and the operation was
converted to a beef operation due to a downturn in milk prices in the late
1970s. Now, as the economic realities have changed dramatically, the
highest and best use of the G Ranch includes a dairy. With a dairy, it will
more closely resemble the Shafter era ranching on Point Reyes. Issues to
consider are:
a. This use existed on the G Ranch during the Shafter era;
b. The dairy would be grass-based, reducing the need for imported feed;
c. Pollution control - Almost the entire necessary pollution control
infrastructure is still in place. The manure sump near the dairy still
exists, the pipeline out to the manure lagoons still exists and the
manure lagoons still exist for the minimal amount of manured water
from milking bam and concrete corrals in need of containment;
d. A composting bam is proposed and could be constructed in the same footprint where a bam once was. This bam will house the small milk
herd during the wet season, all manure will be composted and GHG
emissions from a manure lagoon will be avoided and storm water
runoff water quality will be protected. This EIS should carefully
examine the environmental benefits of a composting bam, including the reduction of GHG production by avoiding manure solids from entering the manure lagoon;
e. All bedding for the composting bam would be grown on farm within
the currently permitted organic forage production fields;
f. Concrete cattle handling corrals still exit;
g. Milking bam still exists, but the interior will need to be remodeled;
h. Feeding areas and feed storage areas still exist; and,
i. PRNS has already allowed other previously closed dairies to resume
operations.
2. Begin milk processing to make butter. Issues to consider are:
a. This use existed on the G Ranch during the Shafter era;
b. The Point Reyes Peninsula was known for its high quality butter
produced on-farm;
c. The grass-fed milk produced on the Lunny Ranch will most closely
replicate the famous butter once produced on these ranches;
d. The Lunny family has extensive experience with on-farm processing
within the PRNS;
e. On-farm processing is not a new use at PRNS. On-farm processing
has been permitted within PRNS since PRNS was established.
f. The visiting public loved to see the processing of food produced
within the seashore and would certainly enjoy experiencing the
historic butter processing;
g. This would require new construction within the existing building
complex, or ranch core, to house a butter processing facility;
h. This would be an exciting historic use revived and could be shared
with the visiting public;
i. This EIS must treat this on-farm processing as a continued use within
PRNS with simply a 0.5 mile change in location with the same
permitted PRNS operators. The change in use that should be
contemplated within this EIS is
i. Different product being processed
ii. Less traffic is expected.
iii. There are no other changes to the human environment to be expected for this relocation.
3. Enhance row crop production. Issues to consider are:
a. This use existed on the G Ranch during the Shafter era;
b. This use currently exists on the G Ranch;
c. 24 acres of silage crop land will be converted to row crops, reducing
the silage crop area and increasing the row crop area from the current 6 acres to about 30 acres which represents less than 3% of the G Ranch;
d. Production will be located on land that is currently authorized for crop
(forage) production, no new areas will be converted to cropland;
e. Existing silage crop land closest to the ranch core with excellent soils
will be selected for conversion;
f. Production will focus on crop species that were historically grown
during the Shatter era, including artichokes, grains, beans and peas;
and,
g. Production will include dry-farming techniques.
4. Restore small scale hog production. Issues to consider are:
a. This use existed on the G Ranch during the Shatter era;
b. The number of sows on the ranch would be limited to 8 and would be
kept in the ranch core area;
c. The hogs will utilize the whey from the butter processing and the
waste vegetables from the row crop operations; and,
d. This use will avoid disposal of the above ranch resources.
5. Use goats or sheep to improve pasture and rangelands. Companion grazing
with multiple species and leader - follower grazing regimes with different
ruminant species have proven to be successful tools for rangeland
preservation. The Lunny Ranch requests that this rangeland management
tool be allowed at the Lunny Ranch. Issues to consider are:
a. Goats and sheep will eat weed species that cows will not eat;
b. Allows certified organic ranches to manage invasive plants without
the use of herbicides;
c. Provides other certified organic meat products to help augment the
ranch income;
d. Can be deployed carefully to target problem invasive species;
e. More closely replicates the diversity found on these ranches during
the historic period PRNS is entrusted to protect;
f. The Lunny Ranch proposes to limit goats or sheep to a substitution of
up to 10% of beef cattle or dairy cow animal units (AU). (There are
various animal-unit formulas, but they typically consider 5 sheep or 6
goats to be one AU, depending on the size of the breed.); and,
g. Other than fencing, no predator controls will be used.
6. Restore small scale chicken production. Issues to consider are:
a. This use existed on the G Ranch during the Shatter era;
b. The number of birds would be limited to 500;
c. Both eggs and meat will be produced;
d. Chickens will be pastured; e. Chickens will be used to enhance pasture fertility and health;
f. Chickens will be used to help control parasites and weeds within
certified organic pastures;
g. Both the meat and eggs will help augment ranch income; and,
h. Chickens will be closed in at night and other than fencing, no predator
controls will be used.
7. Build a new composting bam to house the milking cows during winter.
Issues to consider are:
a. Water quality improvements;
b. Rangeland protection;
c. Housing for animals during inclement weather;
d. Reduction of stress on animals;
e. Allows the Lunny Ranch dairy to compete with other dairies;
f. Will reduce GHG emissions;
g. Would facilitate carbon sequestration in G Ranch soils by appropriate
application of on-farm compost;
h. Would reduce the need to spread raw manure;
i. Would reduce manure solids in manure lagoon thereby reducing GHG
emissions;
j. Would be construction similar to what has been allowed on other
seashore ranches; and,
k. Would be located in the Ranch Core in the exact same location that a
bam previously existed.
8. Build a roof over the existing feed storage and feeding area. Issues to
consider are:
a. Protection of feed from rain damage;
b. Keeping birds, including ravens, away from the livestock feed;
c. Allows the Lunny family to purchase feed at the right time if a safe,
dry storage area is available; and,
d. Would not change the use of the area.
9. Begin direct on-farm sales of Lunny Ranch farm products as well as farm
products produced on other seashore ranches. Issues to consider are:
a. Provides opportunities for the visiting public to connect with the
working landscapes. The visiting public loves the opportunity to
experience and taste the bounty of the Seashore;
b. Provides an opportunity for the visiting public to meet the farmers and
ranchers personally;
c. Provides educational opportunities;
d. The Lunny family has extensive experience with on-farm sales within
PRNS; e. There is plenty of safe parking at the Lunny Ranch;
f. On-farm sales of farm products are not a new use at PRNS. On-farm
sales have been permitted within PRNS since the establishment of
PRNS;
g. Provides additional income to the Lunny family by capturing the retail
prices of our farm products instead of only commodity wholesale
prices;
h. Provides other Seashore ranchers additional income by selling their
farm products at the Lunny Ranch on-farm sales location;
i. Requires minor new construction within the ranch core; and,
j. This EIS must treat this on-farm sales use as a continued use within
PRNS with simply a V2 mile change in location with the same
permitted PRNS operators. The change in use that should be
contemplated within this EIS is
i. Different products are being processed
ii. Minimal construction required
iii. There are no other changes to the human
environment to be expected as a result of this relocation.
10. Continue to produce and harvest on-farm forage crops. Issues to consider
are:
a. This use existed on the G Ranch during the Shafter era;
b. This practice is vital to the Lunny Ranch;
c. The use is currently authorized on the Lunny Ranch;
d. The Lunny Ranch will work with PRNS staff to optimize harvest
timing;
e. The 180 acre maximum per year currently allowed for forage crops
would be reduced by the number of acres used for row crops, not to
exceed 24 acres; and,
f. This use is still occurring.
11. Replace 2 worker residences within the ranch building complex ranch core.
Issues to consider are:
a. This use existed on the G Ranch during the Shafter era;
b. 2 housing units were lost at the Lunny Ranch since the establishment
of PRNS;
c. The housing units could be placed where the original worker housing
was;
d. Most of the other ranches within PRNS and GGNRA have more farm
worker housing than the Lunny Ranch;
e. Housing will meet current health and safety codes;
f. The septic system will be upgraded;
g. Provides rare, affordable, necessary farm worker housing in West
Marin;
h. Due to extremely high home values, it is difficult or impossible for
farm workers for find a home to rent or buy within 40 miles of the
Lunny Ranch;
i. Allows the Lunny Ranch to compete for good employees; and,
j. Allows for the necessary staff for round the clock emergency work
often encountered on a working ranch.
12.Farm stays have become important to urban visitors as well as to ranchers
and farmers for many reasons. The Lunnys are very pleased that PRNS has
already allowed seashore ranchers to undertake this activity within PRNS.
The Lunnys requests the approval for this activity as well. As PRNS has
already authorized this use, it is unclear whether it needs to be evaluated in
the current EIS. This EIS should evaluate the benefits to the visiting public
if they are allowed to stay on and learn about a working historic farm at
PRNS.
13.Organized farm tours. The Lunny Ranch would like to work directly with
the interpretive staff at PRNS to develop a farm tour program at the Lunny
Ranch. This EIS should fully evaluate the lack of interpretive services
currently available to educate the public about the historic ranching. It
should also evaluate the public benefit that could result from a joint effort
with PRNS, the Lunny Ranch and other interested seashore ranchers if a
collaborative educational program were created.
14.Operational Flexibility. To operate a successful ranching or dairying
business, the rancher needs to be able to implement best management
practices and make operational decisions quickly. Weather conditions and
other factors may necessitate quick reaction by the ranchers to protect
natural resources and to protect their businesses.
a. Brush Removal - Invasive brush has been controlled by humans in
this region for millennia. For the past approximately 70 years, the
Lunnys have controlled brush on the G Ranch by grazing, burning,
dozing and mowing. The Lunnys request permission to continue this
vital activity - specifically, mowing.
b. Water and pasture Improvements - The Lunnys request
that the PRNS re-authorize the implementation of the NRCS approved
water and pasture planting project designed for the Lunny Ranch and approved by PRNS. (See attached NRCS Water Development
description.) Once implemented, all water on the Lunny Ranch will
be moved by solar pumping systems and gravity, new red-legged frog
habitat will be developed, wetland and riparian areas will be
protected, cattle water troughs will be moved away from sensitive
habitats and certified organic cattle will be provided cleaner water.
This EIS must evaluate the multiple environmental and ecological
benefits of this completed plan, including reduced energy use,
improved habitat, and reduced livestock impacts on sensitive resource
areas.
c. Composting, using feedstocks from both on and off farm
sources, and compost spreading. The Lunnys plan to continue to
spread compost (from outside sources as well as on farm source) on
silage producing areas, on vegetable producing areas, as well as on
rangelands and pastures used solely for grazing. This EIS should
evaluate the benefits of on-farm compost production and compost
spreading, including carbon sequestration, reduced reliance on other
fertilizers and the reduction in GHG emissions.
d. Carbon Farming - The Lunny Ranch applied for a grant
for Carbon Farm Plan with the Marin County Resource Conservation
District (MRCD). The Lunny Ranch was successful in obtaining the
grant. The Lunny Ranch looks forward to working with the MRCD
and its carbon farm plan partners to create a plan to sequester more
carbon in the soils of the Lunny Ranch. The practices included are all
practices known to benefit the natural resources and most have
already been allowed to be implemented on ranches within the
seashore by PRNS. This EIS must evaluate creating a clear path to
implementing the stewardship practices included in the carbon farm
plan without delay. This EIS should fully evaluate the carbon benefits
- the capture of atmospheric C02 and the increased soil carbon that
results from implementing these practices. The EIS process should
work with MRCD to determine the C02 equivalent that the Lunny
Ranch can sequester by implementing the plan. The EIS should also
evaluate how implementing carbon farm plans on Seashore ranches
could help the PRNS meet it's carbon emission reduction goals.
15. Greenhouse Construction - Although the Lunnys have temporarily fallowed
the 6 acre irrigated row crop garden, for the past decade, the Lunnys have
depended on outside sources for organic vegetable starts. Star Route Farms
in Bolinas has provided many of the plants grown in the current 6 acre
vegetable crop area on the Lunny Ranch. Many plants do not do well when
started by seed in the field. An on-farm greenhouse has become an
economic necessity. It will become even more important when this EIS
process approves the small vegetable production area on the G Ranch to
increase from 6 acres to 30 acres. The Lunnys request permission to build a
small greenhouse on the G Ranch. The EIS process should consider the fact
that this small increase in acreage (24 acres) represents only 2 to 3 percent of
the Lunny Ranch. This is properly viewed as small scale, historically
appropriate diversification with all its cultural and environmental benefits
over monoculture. Historic records demonstrate that thousands of acres were
planted with vegetables on the seashore ranches. Even if many ranchers
elected to plant 30 acres each (which they will not), it would total only a
fraction of what existed during the Shatter era. The EIS team should also
acknowledge the fact that the Lunnys intend to simply change crops on 24
acres of silage fields (crop land) to vegetable fields (crop land). This should
not be considered a change in use; it should be recognized as simply a
change of crop. The Lunnys are not asking to convert native, untouched
rangelands to crop land. The Lunnys recognize that there will be 24 acres
less to continue silage crop production. This EIS should evaluate the
addition of a greenhouse to start certified organic plants for the Lunny
Ranch within the core area of the Lunny Ranch.
16. Foundation Repair to Dairy Bam - the south end of the milking bam on the
G Ranch is settling and is causing other structural damage. The Lunnys
request permission to support the foundation and to make the necessary
structural repairs. All work will be performed by licensed contractors upon
PRNS approval. This work is necessary to keep the building standing. It is
also a necessary step in repairing the dairy bam and readying it to resume
milking operations.
17. Wall Replacement and New Roof on shop containing the ranch electrical
service. The Lunnys have made several requests to PRNS to get this
building repaired. PRNS has not given approval. The Lunnys have requested permission to make the necessary repairs to this building with the
Lunny Ranch paying for the repairs. All work will be performed by licensed
contractors. The Lunnys have consulted with 2 contractors who have agreed
that in the repairs are not made immediately, the building is likely to fall to
the ground making repairs impossible. This EIS should review the record,
confirm the repeated requests, confirm the offer by the Lunnys to pay for the
repairs, and to confirm that the building will collapse soon if not repaired.
The EIS team must also evaluate the financial damage to the Lunny Ranch if
this building collapses, including increased cost to replace instead of repair
existing, the loss of electrical service to the ranch core, the loss of electricity
to the homes, the loss of electricity to water pumps delivering water to
livestock, the cost and time to design and permit a new electrical main
service at another location on the ranch, the time it will take for the County
of Marin to permit and inspect the new service, the time PG&E to approve
the new service and to install the power to a new location the cost to have an
electrician install the new electrical main service in a new location and the
time and cost to have an electrician re-route the entire ranch electrical
distribution system to a new location.
18. Cyclic Maintenance vs. Capital Improvements - Currently, the PRNS SUP
describes and defines cyclic maintenance and makes clear that cyclic
maintenance is the responsibility of the lessee (the rancher) and capital
improvements are the responsibility of the Lessor (PRNS). The above
described construction projects (bam foundation, shop repairs) would fall
into the capital improvement definition. The Lunny family requests
permission to perform and pay for the improvements and that the cost of the
improvements are reimbursed over time by PRNS via permit fee reduction.
This EIS should consider where responsibilities lie for ranch improvements
maintenance, include it in the new 20-year renewable permits, and describe
how the parties will be required to comply.
19. Lease / Permit - This EIS should consider the benefits of issuing 20 year or
longer renewable permits. Given compliance with the terms, the permits
could be renewed after each 5-year review, for 20 years. Ranchers would
always have at least 15 years left on the lease. This EIS should evaluate the
benefits, including:
a. It would show a commitment by NPS and DOI that the
historic ranching is important and will remain at PRNS;
b. It would allow for long term ranch planning;
c. The Lunnys would be more likely to invest in
infrastructure repairs;
d. The Lunnys would be more likely to invest in long term
resource conservation practices including the carbon farming
practices;
e. The next generation of Lunnys would more likely be
interested in continuing the Lunny Ranch tradition because of more
security;
f. Banks are more likely to offer loans for ranch projects;
and,
g. Agencies that require long-term monitoring agreements
for resource conservation grants, including the Marin Resource
Conservation District and the Natural Resources Conservation
District, are more likely to award grants to the Lunny Ranch and other
seashore ranchers, benefitting the natural resources found within the
ranchlands at PRNS.
20.Lease / Permit valuation needs to be considered by the EIS because
the Lunny Ranch, after implementing this plan to improve visitor
experience, resource conservation and historic activities, will also increase
its gross farm income. Currently, the PRNS has no process for lease
valuation other than a farm appraisal and forage usage (AUM consumption).
The Lunny Ranch proposes that PRNS implement an agricultural lease
valuation similar to the Cayuhoga National Park. Here, we ask that the EIS
consider the effects of charging a minimum annual rent / permit fee equal to
the current fees charged to the ranchers. As separate calculation could be a
3% of gross farm income charge for rent. For example, if 3% of gross farm
income is less than the current rent, the rancher pays the minimum rent. If
3% of gross farm income is higher than the current (minimum), the rancher
pays the higher - 3% of the gross farm income. The EIS could consider the
public benefit of charging the ranchers with the most intensives land uses
more rent. The EIS could analyze how this method of charging rent / permit
fees could:
a. Charge more rent to those of us that would like to add
value to our farm products through diversification;
b. Keep the current rent stable for ranches with small gross
farm income;
c. Be more fair to all ranchers if all ranchers were paying
the same percentage rent over a minimum;
d. Be revisited and adjusted for changes in gross farm
income every 5 years;
e. Allow ranchers and the public to know what the rates are
and they are applied evenly;
f. Allow ranchers to plan, knowing how rent would be
affected by diversification and other management changes
g. Calculate gross farm income, how the information can
be obtained and how the information, tax returns or other, can remain
confidential;
h. Eliminate the need for expensive appraisals and
inappropriate charges based on useless AUM calculations; and,
i. Increased rent, or rent over the minimum rent, could be
made available to ranchers from PRNS for resource conservation
projects.
The Lunnys recognize that most of the above can be approved without a formal
NEPA analysis just as PRNS has done in the past. Nevertheless, because new,
comprehensive, long-term permits are being developed, the Lunnys want to be sure
that each of the items raised by PRSRA and the Lunnys during scoping, are
authorized and incorporated in the new Lunny Ranch - Historic G Ranch lease /
permit. The Lunnys appreciate this opportunity to further explain our ranch plan
and to further describe what is needed to fully execute an environmentally
conscious, viable, small scale historically and ecologically appropriate diversified
farm for the benefit of the Lunny family, the community, the visiting public and
the local food system.
This simple plan, once approved, would allow the Lunny family to restore an
exciting, diversified, profitable, visitor-friendly farm that more closely resembles
the Shaffer era ranching than anywhere else in the seashore, while protecting the
natural resources at the same time.
If PRNS allows the Lunny Ranch plan to come to fruition, the average visiting
public passing by the Lunny Ranch is not likely to notice any change. They would
have to look carefully to notice the composting bam and greenhouse in the core
area. Only a local resident or a regular visitor could pick out the minor changes.
Even the regular visitor is likely unaware that there were several large bams on the
G Ranch that are now gone, and that the new structures simply are replacing a
small portion that has been lost over time. They probably wouldn't notice the
increased soil carbon offsetting their GHG produced during their visit to the
seashore by automobile. The new seashore visitors wouldn't probably notice that
more members of the Lunny Family are now working on the farm and staying
connected to the community they were raised in. The new visitor may not realize
that this ranch is now more fully connected to local food system and its
diversification makes it much more likely that it will survive through changing
economic times and changes to the pasture productivity due to climate change.
This EIS must fully evaluate the enormous benefits that would result from this
complete plan.
A new or returning seashore visitor is more likely to notice the availability of on-
farm PRSRA rancher farm products, the availability of farm tours in collaboration
with PRNS staff, a chance to watch organic cows being milked, a chance to
experience the historic butter processing on farm and whey utilization with a few
hogs, some vegetables growing with farm-produced compost soil amendment - all
a small demonstration of the true historic use the historic G Ranch on the Point
Reyes Peninsula. This EIS should consider the fact that PRNS and the NPS have
allowed all or most of these uses at PRNS and at other units of the NPS. The EIS
should evaluate the restoration of these historic ranch practices with the
understanding that PRNS was created because of the ranchers. PRNS is a national
seashore and not a national park, where parks were created for quieter,
contemplative uses and seashores were created for more public activities,
recreation and historic uses. PRNS is responsible for the preservation of the
cultural resources and the ranching areas within the seashore that are now being
designated as national historic dairy districts - both PRNS and GGNRA.
Supporting the Lunny Ranch farm plan appears to meet all NPS objectives at
PRNS - natural resource conservation, cultural resource conservation, historic
resource preservation and visitor enjoyment.
Clearly, this Lunny Ranch Plan includes only high level descriptions of historic use
restoration. More detail may be necessary for PRNS to prepare the Lunny Ranch
20 year, renewable permit. The Lunny family pledges to work with the team preparing this EIS as well as the team preparing the new leases to answer any
questions regarding the Lunny Ranch farm plan.
Sincerely,
The Lunny Family
References:
Ethan L. Lane. Ranching at Point Reyes: Two Centuries of History and Challenges. May 2014
Lunny Ranch NRCS Project Summary, Water Development Section
Elk Fence Facts. November 20, 2014
NPS. Point Reyes National Seashore 2001 Year in Review - 2001 Annual Report. 2001.
NPS. Figure 1- Map of Point Reyes National Seashore; Figure 7- Map of Tomales Point Elk Range and Proposed Elk Range for relocated population. Point Reyes National Seashore Tule Elk Management Plan.
___________________________
# 2965
Name: Pozzi, Martin
Correspondence: Dear Superintendent MacLeod:
The Marin County Farm Bureau (MCFB) was established in 1920 and represents approximately 300 members in Marin County including most, if not all, of the ranchers within Point Reyes National Seashore (PRNS) and Golden Gate National Recreational Area (GGNRA).
MCFB appreciates the opportunity to comment on the planning process that affects nearly 20% of Marin County's agricultural production. According to the Marin County Crop Report, the Seashore ranchers produced more than $18 million in agricultural products in 2016. Many of these Seashore ranching families run their businesses with very small profit margins. This analysis must recognize that continued restrictions on these family farms could result in the loss of some or many of these historic ranching families. This EIS process must also evaluate the adverse economic impact to the entire county's agriculture if the Seashore ranchers were lost. Losing a significant portion of the existing agriculture in the county could result in the loss of other businesses that support agriculture. Without the critical mass, Marin and Sonoma counties could lose veterinarians, feed suppliers, equipment suppliers and others - to the detriment of all our members.
PRNS was created to protect the area from development, not from ranching. Most of the ranching families within the boundaries of PRNS were there when the seashore was formed. The area was still worth protecting because of the good stewardship of the ranchers and PRNS was created because of the ranchers' agreements. All agreed at the time of the creation of PRNS that ranching would continue. Since then, many of the ranches have been closed down by the NPS, including within the Pastoral Zone, without a public process. MCFB asks that this process evaluates and forms a new plan for PRNS whereby no more ranching is lost. A plan that would guarantee the future of the family farms within PRNS and GGNRA would greatly improve the trust and relationship between the NPS, PRNS and the gateway communities.
PRNS has shared with the public a range of alternatives to consider in this planning process. MCFB recognizes that three of the anti-ranching alternatives were required by the settlement agreement. NEPA requires a federal agency to evaluate a full range of alternatives. In this case, the range of alternatives is unbalanced and creates a bias against the ranches. Of the six alternatives, one is the required no-action alternative, three require the removal of all or some of the ranches and the two action alternatives that would allow ranching to continue both allow elk to remain to compete with ranching and neither consider longer than 20-year leases. In addition, neither considers any recovery of ranching on previously grazed lands within PRNS or GGNRA.
To balance the range of alternatives, an alternative should be added that would prioritize cultural resource conservation and ranching. This alternative could include longer leases (up to 60 years, similar to what NPS offers ranchers and farmers in Cuyahoga National Park), should require the relocation of elk off of the ranching areas and keeping them off, evaluation of ranches recently removed from grazing (perhaps within the last 20 years) and consider restoring grazing on these ranches to provide all the necessary ecosystem services provided by grazing, as well as fire fuel reduction.
MCFB recognizes and appreciates the fact that PRNS is proposing an alternative that does not directly
require the removal of any ranchers. Because of the potential adverse impacts to ranching in each action alternative, MCFB cannot fully endorse any of the proposed alternatives. MCFB looks forward to continuing to work with PRNS regarding the development of an alternative that will benefit the Seashore ranchers, as well as preserve natural resources, that can be used in the future EIS process. To fully consider the benefits of grazing on ranches recently removed from grazing and to fully evaluate the elk management plan for all elk at PRNS, the boundaries of this planning process must be expanded beyond the areas currently being leased for grazing.
This EIS process must fully explore the benefits to the ranching families, the visiting public and the natural resources that would result from providing operational flexibility for the ranchers. The plan that results from this process must include a clear path to implementing Best Management Practices (BMP) as designed by the Natural Resources Conservation Service and the Marin Resource Conservation District. The plan should allow the ranchers to mow brush at the appropriate time when that activity is necessary. The plan must have a process to allow ranchers to repair their barns and buildings. Delaying permission to take care of the ranches in a timely manner is resulting in rancher frustration, increased costs to make repairs because of delays, visitor concerns about failing infrastructure and natural resource degradation from failures to implement BMPs.
Seashore ranchers have managed the rangeland and pastureland at Point Reyes and the Olema Valley for generations. Ranchers know how to manage the resource to keep it healthy. Their futures depend on it. PRNS staff in charge with overseeing ranching activities usually has little experience and usually no experience with grazing at this particular area. Grazing limits were arbitrarily set for each ranch in 1995. Ever since, the PRNS uses these numbers to "control" ranchers' cow numbers. The current permits include these 1995 cow numbers as maximums, regardless of the weather, changes in grazing strategies, and fluctuations in forage production or pasture improvements made by the rancher.
Using strict maximum cow numbers as a management tool is wrong. This takes away the ranchers' incentive to implement better grazing practices and from implementing BMPs that would result in more soil carbon and more forage production. This EIS process must consider setting resource goals, including residual dry matter, for the pastures and rangeland and requiring the ranchers to meet the resource goals. The rancher can then implement management that will optimize forage production and resource conservation by adapting to year to year changes. The benefits could include better range and pasture management, increased carbon sequestration in the soils due to increased photosynthesis, increased viability of the ranch businesses, increased teamwork between PRNS and the ranchers, reduced spoiled, unused forage standing in the fields due to under grazing, reduced weed proliferation, as well as other benefits. This EIS should also fully evaluate how the maximum numbers were established in 1995. Was there rancher involvement in the calculations? Were the calculations based on actual carrying capacity of each ranch separately?
This process should evaluate the benefits of requiring Seashore ranchers and the PRNS to develop succession plans to be incorporated in each individual lease. The rancher should prepare the plan and it should be approved by the PRNS. This EIS should evaluate the benefits including the rancher's succession plan in the lease, including the assurance every ranch will remain in agricultural production, simplify the re-issuance of a lease by PRNS, increased security for the next generation rancher and reduce the likelihood of conflict that can result if no plan is in place.
Small scale diversification on farms and ranches is allowed and supported in the Marin County Wide Plan as well as across the country. Diversification has saved ranches in Marin and given family members new enthusiasm to carry on the farming and ranching tradition. Diversification, including small scale row crops, various livestock species including sheep, goats, hogs, chickens and turkeys to mix into a cattle operation can have many economic and environmental benefits. PRNS should consider the benefits of allowing small scale diversification on Seashore ranches, including the fact that these are not new uses but restoring historic uses, increased ranch viability, improved visitor experience, and reconnecting Seashore ranchers to the local food system.
Agriculture is always changing due to economic factors, climate factors, market factors and regulatory factors. The Seashore ranchers were once quite diversified and very locally connected. When the PRNS was formed, the ranches had only recently transitioned into a mostly dairy monoculture. Now, as is seen outside the Seashore, the Seashore ranchers need to evolve slightly, to actually resemble more closely the historic operations.
If this process and plan results in simply "allowing" ranches to continue with many of the current restrictions, it would be putting historic families out of business. The next generation would lose interest in a struggling business and move on. MCFB hopes that PRNS will choose a path that truly supports the continuation of secure, exciting, traditional, viable, beautiful and locally connected agriculture while protecting natural resources. This can be done, and it can be done well here, at PRNS and GGNRA. Everyone benefits.
MCFB exists for its members and the communities in which we live. The Point Reyes peninsula and the Olema Valley have always been agricultural areas and have always been able to coexist with the natural wonders of these areas. Cooperative conservation requires cooperation and mutual respect among the parties. This EIS process will inform decisions that may protect this cooperation into the future, or it may support a decision that spells the end for the Seashore ranchers quickly, or over time by a thousand cuts. MCFB pledges to cooperate with PRNS in any way so that the original agreements during the formation of PRNS are respected and upheld.
The Marin County Farm Bureau fully endorses, and includes in its scoping letter by reference, the scoping letters written by the Marin County Board of Supervisors, California Farm Bureau Federation, The California Cattlemen's Association - National Cattlemen's Beef Association - Public Lands Council, Western United Dairymen, The Marin Conservation League and the Point Reyes Seashore Ranchers Association, who together represent hundreds of thousands of local, regional and national agricultural and environmental interests.
Martin Pozzi
1st Vice President
Marin County Farm Bureau
___________________________
# 2966
Name: Watt, Laura
Correspondence: Thank you for the opportunity to provide comments to inform the first phase of the Point Reyes National Seashore and Golden Gate National Recreation Area (PRNS/GGNRA) General Management Plan (GMP) Amendment planning process.
My relevant expertise includes nearly twelve years as a professor of environmental history, policy, and planning at Sonoma State University, and twenty years of experience researching the history and management of PRNS, recently published by the University of California Press as a book titled The Paradox of Presentation: Wilderness and Working Landscapes at Point Reyes National Seashore. In addition, I have four years' experience working professionally as an
environmental consultant for EDAW Inc. (now AECOM), focusing primarily on writing land management plans and EISs for federal agencies; in particular, I was project manager and primary author for the BLM's 2004 King Range National Conservation Area Resource Management Plan and EIS, which won an award for "NEPA Excellence" from the National Association of Environmental Planners. Many of the issues addressed in the King Range NCA plan are quite similar to those found at Point Reyes.
I would like to register my strong support for the continuation of ranching-both beef and dairy production-on lands managed by PRNS. As I wrote in my recent book, "The U.S. national park system contains areas that primarily aim to preserve natural scenery as well as those that primarily preserve history and cultural heritage; Point Reyes offers the suggestive possibility of protecting all types of heritage resources together, as a landscape whole and including the resident users' input in management, rather than separately. The continued presence of the ranches at PRNS alludes to the strength of such a broader approach, one more based in community collaboration, with implications for how we humans might better understand nature's role in a human-built world."1 I believe this current planning process is an excellent opportunity to align the Seashore's management practices with this broader, community-based approach.
My view is echoed in the attached article by Rolf Diamant (Attachment 1), retired Superintendent of Frederick Law Olmsted National Historic Site and Marsh-Billings­ Rockefeller National Historic Park, recently published in the George Wright Forum.2 In his essay, Diamant urges PRNS planners to "take a fresh look at ways to establish a more proactive, cooperative, and mutually beneficial relationship between ranching families and the seashore" (p. 118). He emphasizes the cultural significance of the ranching landscape, and specifically suggests longer-term leases, based on the model of Cuyahoga Valley National Park. I wholeheartedly agree with his essay.
The only one of the alternatives proposed so far that I support is the sixth alternative, "Continued Ranching and Removal of the Drakes Beach Tule Elk Herd," except that I would amend it to remove elk from all currently-working landscapes in the Pastoral Zone, including Home Ranch and other ranches being affected by the Limantour herd. A separation fence may be necessary to prevent future spread of the elk onto pastoral lands. I provide more background and detail for this in point #8, below, in my specific comments and recommendations. I hope these suggestions will assist in your planning efforts as they move forward:
Overall Planning Context and Schedule at Point Reyes National Seashore
As a long-time land management planning instructor and professional, I find it unfortunate that this new planning effort is simply amending the 1980 GMP for Point Reyes, rather than conducting a complete GMP update, articulating an overall vision for all of the resource types and land uses managed by PRNS, rather than a piecemeal approach that singles out the ranchlands. Agricultural use and management does not exist in a vacuum at PRNS, and some issues in particular, like management of the tule elk, should be addressed by considering management of the entire Seashore, not just the pastoral zone. Considering the ranches in isolation from the rest of the Seashore risks missing the larger landscape picture. In
particular, formerly-ranched lands in southern end of the Olema Valley should be included in the scope of this planning effort.
In addition, I do not believe this GMP Amendment requires multiple years to complete. In contrast, writing the 20-year Resources Management Plan for the entire King Range National Conservation Area, which is a similar size and has many similar land use issues to Point Reyes, took two years, start to finish. A substantial amount of work has already been
completed by the NPS from the never-released Draft GMP Update from 2010, as well as the more recent Ranch Comprehensive Management Planning process that this process now replaces, which could be utilized to help accelerate the GMP Amendment process.Additional delay in the planning process only puts more financial strain on the ranchers who have been in a state of complete uncertainty about the future for five years already. I urge the NPS to proceed with this planning process as quickly as practically possible.
Congressional Commitment to Protecting Active, Continuing Agriculture at Point Reyes
I would like to remind you of the widespread interest in and commitment to protecting agriculture within the Seashore, even among environmentalists, stemming back to the first discussions of creating PRNS. When Point Reyes National Seashore was established in 1962 it was primarily intended to provide beach access and recreation opportunities for the nearby population of the metropolitan Bay Area, even though the landscape had been in use for dairy and beef ranching since the 1850s. Initially, ranches were to be kept in private ownership, within a designated "pastoral zone." But for a variety of reasons they had all been acquired by the NPS by the early 1970s. The explicit intent of Congress in authorizing the acquisitions was that ranching activity remain part of the seashore, as stated by Senator Alan Bible, "At the time the initial authorizing legislation for Point Reyes National Seashore was enacted the federal government in effect made a promise to the ranchers in the pastoral zone that as long as they wanted to stay there, to make that use of it, they could do it. We must [now] keep our word to these people."3
I believe that these historical intentions must be kept in mind as the Seashore moves forward with its GMP Amendment process, particularly to avoid a form of "mission creep" where commitments made early on in the park unit's history are downplayed or overlooked as time goes by.
Retain all existing ranches, strengthen the ranchers' ability to manage their lands, and recognize that the ranches, as eligible historic districts, are equal/y valuable and essential resources to PRNS as any natural resource or endangered species
Despite the long history of Congressional intention detailed above, the number of working ranches (i.e. not just the acreage of land used for grazing) within the boundaries has dwindled significantly since the Seashore was established-hence I do not support any proposed planning alternatives that reduce or remove either dairy or beef ranching from PRNS or GGNRA lands. Both the Point Reyes Ranches and the Olema Valley Ranches have already been found to be eligible for nomination to the National Register of Historic Places as Historic Districts; those nomination forms should be submitted and finalized, to formally recognize the ranches' importance to the overall history and sense of place at the Seashore.
The agricultural operations on PRNS and GGNRA lands represent a substantial portion of this economy, contributing 17 percent of Marin's overall agricultural production and 17 percent of its agricultural land base.4 The 2007 Marin Countywide Plan lists among its core goals the protection of the area's working agricultural landscapes, and greater community food security by increasing the availability and diversity of locally-produced foods.5 Grazing on these lands also provides important ecosystem services, such as managing non-native weedy species and reducing fire danger. And most of the ranching families have historic connections to the land that go back through generations, helping to anchor the overall community's sense of identity and place.
This new GMP Amendment effort also must give close attention to assisting the present-day ranches with remaining economically viable, so that there is no further erosion to these important cultural landscapes. One way to increase their long-term viability would be to offer 20-year rolling leases, with automatic renewals each year that ranches remain in compliance (the NPS could retain its 30-day cancellation clause for non-compliance). This
would give the ranching families, particularly the younger generations, greater security and encourage their willingness to invest in long-term maintenance of their leased properties and structures.
The GMP Amendment should also encourage re-use of ranches that have gone out of operation, like the Horick (D) Ranch, Rancho Baulines (Wilkins Ranch), and/or the Jewel Ranch, to bring them back into the overall continuing landscape of agriculture at the Seashore. In addition, establish Best Management Practices for ranching, including brush and weed control, fencing, water system improvements, and variable stocking density (based on climatic factors rather than a set stocking limit), and streamline the approval process for maximum flexibility for the ranchers. NPS policies should encourage and support thoughtful and timely stewardship of the land, and particularly support management practices that can assist with carbon sequestration in the soil.
NPS should fallow well-established international policy approach to living, continuing landscapes, as outlined by UNESCO.
A t the international level, world heritage management policy is increasingly articulated as the protection of both cultural and natural resources and values, emphasizing local uniqueness and community input into management. For example, UNESCO's 2009 World Heritage Cultural Landscape: A Handbook for Conservation and Management identifies six guiding principles in its management framework:
1. People associated with the cultural landscape are the primary stakeholders for stewardship.
2. Successful management is inclusive and transparent, and governance is shaped through dialog and agreement among key stakeholders.
3. The value of the cultural landscape is based on the interaction between people and their environment; and the focus of management is on this relationship.
4. The focus of management is on guiding change to retain the values of the cultural landscape.
5. Management of cultural landscapes is integrated into a larger landscape context.
6. Successful management contributes to a sustainable society.6
PRNS should explicitly follow these internationally accepted policies in crafting the GMP Amendment, and particularly recognize that the pastoral areas of the Seashore are "continuing landscapes," that they are not only important due to their historic influence on the land, but also due to their current-day uses and continuing influences.
5. The NPS must take PRSRA seriously as a collaborative management partner, not just an ordinary ''member of the public."
The international policy approach to managing continuing landscapes outlined above makes clear the importance of working with local communities as primary stakeholders and management partners. In the case of PRNS, this highlights the essential importance of recognizing the Point Reyes Seashore Ranchers Association (PRSRA) as an organization that collectively represents the ranchers and their interests. Seashore staff should work collaboratively with this group to develop and maintain management of these pastoral landscapes, at a level that goes beyond just a regular member of the visiting public.
6.Establish a leasing program and management arrangement similar to that already in place at Caryahoga Valley National Park.
PRNS could easily follow the model of Cuyahoga Valley National Park (CVNP), with its Countryside Initiative bringing agricultural use back to parts of that park after decades of absence. Starting in 1999, CVNP has worked with a non-profit cooperating partner, the Countryside Conservancy, to reestablish working agriculture via rehabilitating historic farms and farmland and offering long-term leases, up to sixty years in length, via a competitive proposal process as a way of resurrecting and maintaining the rural character of the valley.7
Point Reyes could establish a similar relationship with Marin Agricultural Land Trust, which has an established track record of working well with local ranchers to conserve their lands, or some other non-profit focused on cultural landscape protection and management. The non-profit could serve as an intermediary partner, negotiating lease terms (again, ideally with rolling terms), working with ranchers to maintain land management practices, and generally buffering their tenant/landlord relationships with the NPS. It would also be essential to provide a clearer, more permanent avenue for community collaboration, viewing the ranchers and other locals as stakeholders in Seashore management and planning, distinct and separate from the general visiting public (see Point #5 above). The NPS needs to recognize that residents have a different relationship to place than visitors, and particularly that working the land, especially over generations, creates a unique connection and knowledge that should be respected and incorporated into management practices.
7. Additional policies addressing agricultural diversification restoration of pastoral lands, and ranch succession are needed.
In addition to forming this kind of a management partnership, PRNS should revise a number of its policies to encourage and strengthen long-term agricultural viability. These recommendations are not new; they were clearly articulated in 2009 in a letter from Senator Feinstein to PRNS and the Seashore Ranchers Association, and then expanded in a report written by the UC Cooperative Extension office. Senator Feinstein wrote:
"What came through loud and clear at these meetings were three things: first, that Special Use Permits which allow you to operate at Point Reyes need to be issued for longer periods of time than five years. Second, that many of you would like the opportunity to diversify your operations in an effort to stabilize your income. And third, it was very apparent that the National Park Service needed to do a better job of communicating with ranchers and facilitating communications among interested groups in the West Marin area."8
The UC Cooperative Extension report added detail to these recommendations, suggesting not only longer permit terms, but also formalizing agricultural diversification through the permitting process, giving ranching families more flexibility to raise different products and respond to changing market demands. It also recommends restoring agricultural uses to some lands that had been taken out of production, as part of a wider embrace of the working landscape component of the Seashore. There is absolutely a need for a clearer process for dealing with ranch succession, in case of either retirement or death of permittees, so that continuation of ranching will not come into question, whether through family members or other members of the community taking over the operation. Improved communication and utilizing ranchers in resource management are also needed, to genuinely recognize the value and commitment of these working families to the Seashore as their
home and livelihood.9 It is also needed to overcome a lack of trust that may exist at this point, caused by permit cancellations like Horick and Tiscornia, by the Drakes Bay Oyster Company controversy, and by NPS unresponsiveness and inaction over the tule elk issue in recent years.
Current tule elk impacts on ranches cannot wait for this plan to be completed; they should be removed from the pastoral zone immediately
Herds of tule elk are currently having significantly negative impacts on many of the working ranches, and should be relocated out of the Seashore's pastoral zone entirely-including both the Drakes Beach herd, which is considered under one of PRNS's proposed alternatives for this Amendment, and the Limantour area herd, which are not addressed by any of the alternatives. In the 1998 Tule Elk Management Plan and Environmental Assessment, the Seashore clearly stated, "The Park Service has a responsibility to be a good neighbor to adjacent and nearby landowners. Anticipating the effects of tule elk management strategies on the property or perceptions of neighbors is an important consideration. Any depredations by elk on fences, crops, or other property would require mitigation actions to correct or avoid problems."10 The leased ranches managed by PRNS are your neighbors, and should receive the same attention and consideration as would be afforded to private landowners.
In 2015 I published an article, which I am also attaching to this comment letter (Attachment 2), that details the history of tule elk across California and specifically at PRNS.11 This research clearly shows that both NPS staff and wildlife scientists have been aware since the mid-late 1990s that elk relocated to the Limantour area and allowed to "free range" would inevitably be drawn toward managed pastures and negatively impact ranching operations.
This work also suggests that the distinction made between the "enclosed" elk herd on Tomales Point, separated from nearby ranches by a high fence, and the "free range" herds near Limantour and Drakes Beach, is a false one. The Tamales herd roams across 2,600 acres, enough space for them to have established three separate sub-herds, and their population numbers are being at least somewhat controlled naturally by the availability of vegetation. In contrast, the Limantour and Drakes Beach herds are eating managed pasture and drinking managed water, and must traverse across fences, sometimes damaging the fences and/or themselves. Returning both of these herds to the designated elk range near
Limantour and building a separation fence to prevent them from returning to the pastoral zone will both avoid future conflicts and result in a more independent herd of elk free­ ranging southward into the wilderness zone.
Furthermore, the environmental impacts of returning the elk to the designated wilderness area had already been studied in the 1998 Tule Elk Management Plan. The elk range identified in the Plan is restricted to the wilderness area around and south of Limantour, not extending into the Pastoral Zone. The question for NEPA is whether or not environmental impacts have been analyzed, not about whether property is public or private. Any possible impacts of relocating elk that have wandered out of the elk range back to where they belong have already been analyzed (in the context of "neighboring" private property), and the resulting document was a Finding of No Significant Impact. Hence there should be no need for additional planning or NEPA review for returning the elk to their originally intended range in the wilderness area near Limantour, as such actions have already been determined to cause no significant impacts. This action should be implemented immediately.
Utilize an Appropriate Environmental Baseline for any Impacts Assessment
Lastly, once this planning process shifts into evaluating potential environmental impacts of the planning alternatives, an appropriate environmental baseline must be utilized. Potential impacts from ranching operations cannot be compared to a hypothetical environment with no human uses, as such a landscape has not existed at Point Reyes for hundreds or thousands of years. The Coast Miwoks' legacy in this landscape remains an important precursor to European settlement, and archeological evidence suggests that the Coast Miwok used fire extensively to promote and maintain open grasslands at Point Reyes for several thousand years, creating the very conditions that made the Peninsula so attractive to Mexican settlers raising cattle for the hide-and-tallow industry, and later to Anglo dairiers 12 The long-term baseline in all of West Marin has always included human use and management of pastures, and the environmental impact assessment must be completed with this history in mind.
I hope that these comments will assist you and your staff with developing a strong and effective vision for the historic and continuing ranching landscapes within the Seashore and PRNS-managed areas of the GGNRA. I will of course remain engaged with the process, and am happy to offer assistance as a scholar and planning professional at any time.
References
1 Laura .Alice Watt, 2017, The Paradox of Pme111ation: Wilderness and Working Landscapes at Point Reyes National Seashore (Oakland: University of California Press), at 4.
2 Rolf Diamant, 2017, "Point Reyes: .A Landscape Indivisible?" George Wright Forum 34(2): 113-19.
3 U.S. Congress, Senate Congressional Record, March 17, 1970, page S3823, written statement by Senator Alan Bible, discussing the amendment to repeal Section 4 in the 1962 legislation that established the pastoral zone; emphasis is mine.
4 Ellie Rilla and Lisa Bush, 2009, The Changing Role of Agric11lture in Point Reyes National Seashore, published by the University of California Cooperative Extension.
5 Marin Countywide Plan, adopted November 6, 2007.
6 UNESCO, 2009, World Heritage C11/t11ra/ Landscapes: A Handbook for Conservation and Management, at 35-36.
7 http://www.cvcountryside.org/farm-farming-home.htm, accessed 3/8/2014. Also see http://countrysideconservancy.worldsecureystems.com-countryside-initiative-program for more information on the program.
8 Letter from Senator Dianne Feinstein to PRNS and PRSRA, dated January 6, 2009.
9 Ellie Rilla and Lisa Bush, 2009, The Changing Role ofAgn·c11/t11re in Point Reyes National Seashore, published by the University of California Cooperative Extension, at 15-19.
10 PRNS, Tule Elk Management Plan and Environmental Assessment, July 1998, at 13.
11 Laura A. Watt, 2015, "The Continuously Managed Wild: Tule Elk at Point Reyes National Seashore," ]011rna f of International Wildlife Law & Policy 18: 289-308.
12 Email from Kent Lightfoot to Michael Newland, dated Jan 21, 2105: "The environment we are seeing at Point Reyes today is probably characterized, in large part, by a highly transformed vegetation that is the product
of both the termination of Native burning and more recent fire suppression policies." For more detail, see R. Scott Anderson, Ana Ejarque Peter M. Brown, and Douglas J. Hallett, 2013, "Holocene and Historical
Vegetation Change and Fire History on the North-Central Coast of California, USA," The Holocene 23(12):
Rolf Diamant, 2017, "Point Reyes: A Landscape Indivisible?" George Wright
Forum 34(2): 113-19.
Laura A. Watt, 2015, "The Continuously Managed Wild: Tule Elk at Point Reyes National Seashore," Journal of International Wildlife Law & Poverty 18: 289-308
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# 2967
Name: Lema, Melissa
Correspondence: Dear Superintendent MacLeod,
Western United Dairymen (WUD), the largest Dairy Trade Association in California, appreciates the opportunity to provide input on the General Management Plan (GMP) amendment process for the Point Reyes National Seashore (PRNS) and North District of Golden Gate National Recreation Area (GGNRA). WUD represents 650 member-dairies throughout California, including ail six dairies located within the PRNS. Western United Dairymen is an organization which works to promote sound legislative and administrative policies and programs for the profitability of the dairy industry and the welfare of consumers by striving always to develop concepts for the general welfare and longevity of dairy producers, while maintaining the strong, positive public image of our dairy families.
WUD has followed the initiation of the GMP process and reviewed the alternatives proposed by the NPS. Our comments reflect careful consideration of those alternatives and their potential impact on the PRNS, the local community and the dairymen operating within the Park. Our comments will specifically address: Alternatives set forth by the Settlement Agreement and the NPS, issuance of long-term leases for ranchers and dairymen, and active management of the Drake's Beach and Limantour-Estero Road Tule Elk Herds.
1. Alternatives
Following the Settlement Agreement resulting from the lawsuit Resource Renewal Institute v. National Park Service the three alternatives that were identified proved disappointing. We appreciate the hard work the NPS has done to include three additional alternatives in their GMP notice, and offer the following comments for consideration of those alternatives.
First, the "No Ranching," "No Dairy Ranching," and "Reduced Ranching" alternatives proposed by the Settlement Agreement are not only contrary to the Point Reyes National Seashore Enabling Act, but detrimental to the local community. With nearly 20% of Marin County's agricultural production happening within the PRNS eliminating or reducing the farming activity has the potential to eliminate 65 jobs and the livelihoods of 25 ranching families. The resulting impact of this "phase out" would affect local schools, businesses, and tax revenues, not to mention the loss of one of the area's most historic and important cultural resources. Ranching and dairy farming are a fundamental aspect of life on the Point Reyes Peninsula; alternatives that eliminate or reduce these historic ranches promise to significantly alter the culture and sustainability of the Park and the community at large.
After careful consideration and discussion with our member-dairies Western United Dairymen supports the "Continued Ranching" alternative. We praise the effort of NPS to include the provision of 20-year leases and management of Elk in this alternative, and offer further comment on those provisions below.
2. Leases
WUD firmly believes that the adopted GMP amendment should ensure long-term leases for farmers and ranchers located within the PRNS. WUD appreciates that under our preferred alternative, the "Continued ranching" proposal, "existing ranch families would be authorized to continue beef cattle and dairy ranching operations under agricultural lease/permits with 20- year terms." Additionally, we support the idea that those permits will " identify authorized measures for operational flexibility and diversification."
Providing operational security and flexibility to the dairymen operating within the PRNS will ensure their continued stewardship of these important lands. With the promise of longer- term leases these pasture-based, organic dairies will be better positioned to secure outside funding and more likely to invest personal capital in opportunities that would aid in addressing existing environmental concerns and improve already present on-farm best management practices; benefitting water, soil, air and wildlife in the Park and the Point Reyes community.
In conjunction with the issuance of long-term leases WUD encourages NPS to explore the options surrounding succession of these valued ranch lands. Developing two paths for succession:
1) a plan for current ranching and dairy families to continue operations, and
2) the opportunity for interested parties to inherit management of those lands should existing families be unable to continue
These options would foster the overarching goal that this important tradition continue on the Seashore.
3. Elk Management
WUD asks, in accordance with the wishes of our dairy producers, for an expansion of the "Continued Ranching" alternative to include the removal of the Drake's Beach and Limantour- Estero Road Elk herds from the pastoral zone per the 1998 NPS Elk Management Plan. The ranching community is supportive of the continuation of the Elk Herd both within the Park's wilderness zone and outside of the PRNS, a management move which would allow the Elk population to thrive while reducing the ongoing damage to livestock, infrastructure and forage land.
Western United Dairymen thanks you for the opportunity to provide comments on this initial step in the GMP amendment process. We're very proud to represent the six dairies of the PRNS. On behalf of our dairies we look forward to working in partnership with the National Park Service in subsequent steps to completing the GMP amendment. Please don't hesitate to reach out if we can provide further support in the matter.
Sincerely,
Melissa Lema, North Coast Field Rep
Western United Dairymen

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