General Management Plan Amendment and Environmental Impact Statement
What is a General Management Plan Amendment?
A General Management Plan Amendment is a document that partially amends an existing General Management Plan (GMP). National Park Service (NPS) policies allow for amending an existing GMP, rather than undertaking a new GMP, to address particular locations or issues. A GMP Amendment is prepared as part of a public planning process.
What is the planning area for the GMP Amendment?
The planning area for the GMP Amendment covers more than 28,000 acres, including all lands currently under agricultural lease/permit within Point Reyes National Seashore (Point Reyes) and the north district of Golden Gate National Recreation Area (Golden Gate).
Why aren't you doing a complete General Management Plan for the whole park?
The NPS is required by a court-approved settlement agreement (4,799 KB PDF) and subsequent extension to complete this plan and issue a record of decision by September 13, 2021. Consistent with the settlement agreement, the GMP Amendment will focus on the park's highest planning priority, the areas of Point Reyes and Golden Gate where ranching is currently permitted.
How will the GMP Amendment relate to the existing 1980 General Management Plan?
The GMP Amendment will replace the 1980 Point Reyes National Seashore and Golden Gate National Recreation Area GMP for lands within this GMP Amendment planning area.
Is the NPS required to consider and evaluate specific alternatives in the GMP Amendment?
Yes, under the settlement agreement, the NPS is required to consider and evaluate a no ranching alternative, a no dairy ranching alternative, and a reduced ranching alternative. The GMP Amendment also identifies and analyzes three additional alternatives.
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What is the selected action for implementation?
The selected action allows existing ranch families to continue beef & dairy operations with up to 20-year lease/permits which will include required infrastructure upgrades and operational changes for the protection of natural and cultural resources. Within an expanded Scenic Landscape zone, tule elk in the Drakes Beach area will be managed at a higher population threshold of 140 individuals consistent with desired conditions for the planning area. The Limantour herd will be allowed to expand in terms of population and geographic distribution, but female groups will be discouraged from occupying ranching areas. The NPS will implement a zoning framework to protect park resources by directing ranching activities to appropriate areas while allowing for some operational flexibility and limited diversification. The selected action also identifies opportunities to improve the visitor experience and a framework for managing visitor capacity in the planning area.
Is the selected action different from the preferred alternative in the final environmental impact statement (FEIS)?
Yes, the selected action includes modifications to the preferred alternative identified in the FEIS. These modifications are further responsive to public concerns raised during the planning process, include conditions agreed to at the public hearing with the California Coastal Commission, and incorporate feedback from regulatory agencies. The selected action includes more robust requirements for ranch operations, further restrictions to diversification, and improvements to the management of free-ranging elk. Modifications to the selected action are within the spectrum of alternatives considered in the FEIS.
How were stakeholder and public comments integrated into the selected action?
The selected action includes modifications to the preferred alternative identified in the FEIS that are responsive to public concerns raised during the planning process, including conditions agreed to at the public hearing with the California Coastal Commission and feedback received from regulatory agencies. These modifications include more robust requirements for ranch operations, further restrictions to diversification, and improvements to the management of free-ranging elk. Modifications to the selected action are within the spectrum of alternatives considered in the FEIS.
What types of diversification could be permitted in the selected action?
Beef and dairy ranching would continue as the primary agricultural operation on each ranch. Diversification activities could be authorized on the 18 residential ranch complexes, in subzones where no sensitive resources are known to occur. Diversification activities authorized under the selected action are limited to:
- a maximum of 50 sheep or 66 goats with an equivalent reduction of cattle animal units (note: this is equivalent to a maximum of 10 animal units)
- farm stays limited to 2 guest rooms per ranch pending water availability
- ranch tours
All diversification activities will follow applicable mitigation measures and begin only after approval from the NPS.
Will the proposed diversification in the selected action threaten wildlife?
Any diversification of livestock specifically prohibits ranchers from harming or harassing wildlife, including predators. Ranchers could use guardian animals for livestock protection with established mitigation measures.
How can the NPS ensure protection of sensitive resources with continued ranching in the selected action?
To ensure the protection of natural and cultural resources, lease/permits will include required infrastructure upgrades and operational changes. Additionally, the NPS will implement a zoning framework on each ranch based on analysis of topography and sensitive resources. Ranching activities will differ by subzone, with more intensive activities in zones without sensitive resources. Examples of sensitive resources are threatened or endangered species, riparian corridors, wetlands, or archeological sites. The area of each subzone will differ by ranch and will be field-checked, updated, and modified as appropriate.
- Resource Protection Subzone: approximately 2000 acres excluded from ranching due to sensitive resources
- Range Subzone: approximately 16,400 acres or 64% of lands where grazing is compatible with resource protection objectives but more intensive activities are not
- Pasture Subzone: approximately 8900 acres or 35% of lands where no sensitive resources are known to occur and more intensive ranching activities can take place
- Ranch Core Subzone (designated on the 18 residential ranch complexes): approximately 220 acres or less than 1% of lands including the developed complex of buildings and up to 2.5 acres of adjacent disturbed lands
What happens to forage production in the selected action?
Forage production for livestock feeding currently takes place on approximately 1000 acres in the planning area. In the selected action and with the closure of the dairy operation at I Ranch, authorized forage production will be limited to one dairy with existing silage, a total of approximately 163 acres. Forage production on beef ranches will no longer be authorized. Should the one authorized dairy ranch discontinue forage production, the total acreage of forage production in the planning area will be further reduced.
Does the selected action expand ranching in lands managed by the NPS?
No, the plan does not expand active acres of ranching in the park or cattle numbers. The selected action authorizes lease/permits with terms up to 20 years with required infrastructure upgrades and operational changes for the existing beef and dairy ranch operations on approximately 25,500 acres.
Is the NPS protecting Coast Miwok archeological sites? What is the status of the nomination of the proposed Coast Miwok historic archeological district to the National Register of Historic Places?
Yes, the NPS is protecting Coast Miwok archaeological sites and manages the proposed historic archeological district and its contributing sites as a historic property, in coordination with the Federated Indians of Graton Rancheria (FIGR). The NPS is seeking funding to update the draft nomination with newly available information for resubmittal to the State Historic Preservation Officer and the Tribal Historic Preservation Officer of FIGR for formal listing on the National Register of Historic Places.
Can park visitors access the ranching areas of the park for public use?
Yes, the ranching areas of the park are open to public access with the exception of the developed ranch complexes and residences. The developed ranch complex, feeding areas, equipment and feed storage areas, outbuildings, and access roads through the ranch complex are closed to public access for safety due to the presence of livestock, heavy machinery, etc., and to ensure that permitted ranch operations are conducted without impediment.
How was the selected action identified? Does the public get to vote for and choose the selected action?
The NPS identified the selected action as the alternative that has the best combination of strategies to protect both natural and cultural resources, achieves desired conditions for the planning area, and furthers park purposes as expressed in the enabling legislation and legislative history for Point Reyes and Golden Gate. All public comments are read, considered, and used to inform the planning process and final decision, but commenting on an alternative is not a form of voting or choosing a selected action.
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How many tule elk are there at Point Reyes National Seashore?
There are nearly 600 tule elk in three distinct herds at Point Reyes. Two of these herds are located in the planning area. The NPS conducts a tule elk census at the end of each calendar year. In 2020, there were 293 elk in the Tomales Point herd (not addressed in this plan), 155 elk in Limantour herd, and 139 in the Drakes Beach herd. The selected action maintains both free-ranging herds in the planning area.
How would the NPS manage tule elk in the selected action?
With expansion of the Scenic Landscape zone, tule elk in the Drakes Beach area would be managed at a higher population threshold from what was indicated in the FEIS of 140 individuals consistent with desired conditions. Management of tule elk in the park will be done in consultation with the California Department of Fish and Wildlife (CDFW) and Federated Indians of Graton Rancheria (FIGR) to include tribal views and traditional ecological knowledge. Lethal methods, or if practicable, translocation outside of the park will be used to maintain Drakes Beach herd at this population threshold.
Both the Drakes Beach and Limantour herds of tule elk will be actively managed to stay within their core areas, however a core area could expand if a neighboring ranch ceases to operate or with expansion of the Scenic Landscape zone. The NPS will use a graduated management response, including standard and aggressive hazing techniques and the potential for lethal removal of individual elk. If these techniques are unsuccessful, NPS will not eliminate new herds. Areas of high elk concentration on ranchlands by the Limantour herd will be monitored and managed in response to localized resource impacts. However, no population-level management will be taken that will threaten the future existence or viability of the Limantour herd. The Tomales Point herd is outside the planning area and is not addressed in this plan.
How did the NPS arrive at a population threshold of 140 adult elk for the Drakes Beach herd in the selected action?
The population threshold of 140 adult elk is based on consultation with CDFW, estimated forage consumption by elk, forage productivity on ranches, time that elk spend on ranches, and NPS capacity to manage elk. The selected action will manage the Drakes Beach elk herd at a stable and viable population level compatible with desired conditions. The NPS estimates the removal of 12 to 20 elk annually in a typical year, in consultation with CDFW and FIGR.
Could the NPS translocate elk from the Drakes Beach herd beyond the population threshold outside of the park instead of using lethal removal?
Currently, the State of California does not allow the translocation of elk outside of the park because of concerns of spreading Johne's disease. CDFW's comment letter on the draft EIS reads in part, "Translocation of elk out of PRNS [Point Reyes] is not a viable option for population management due to the potential for translocation of diseases, short and long-term costs, risk to staff or contractors, and risk to animals."
Could the NPS use contraception to manage the tule elk at Drakes Beach instead of lethal removal?
No, there is not a currently approved product for fertility control in elk by the US Environmental Protection Agency (USEPA), the regulatory agency that approves the registration of such products. If the USEPA approves a contraceptive product for tule elk in the future, NPS would consider the feasibility of using it to control the size of the Drakes Beach herd. Factors that would be considered would likely include the risk of adverse behavioral effects, the length of the product's effectiveness, and the feasibility of administering it in the field.
Is the management of tule elk in the selected action consistent with the management of the tule elk in the state of California by CDFW?
Yes, elk management in the selected action is consistent with how tule elk are managed by CDFW and consistent with the Elk Conservation and Management Plan (2018) for the State of California. CDFW allocated 332 elk tags in 2019 for lethal removal through recreational hunting.
Are elk managed by lethal removal in other units of the NPS?
Yes, elk are managed by lethal removal at other NPS units including Rocky Mountain National Park, Wind Cave National Park, and Theodore Roosevelt National Park.
How many tule elk are in the state of California? Are tule elk threatened or endangered?
Tule elk are native and endemic to the state of California. Currently, there are approximately 5,700 tule elk in California outside of the park. Tule elk are not listed by the State of California or the Federal Government as a threatened or endangered species.
What will happen to the elk that are lethally removed?
The NPS will evaluate options to donate meat to the extent possible. Options could include donation of meat to local charitable organizations, the California condor program, FIGR and other tribal groups, or for the purposes of disease testing. Meat donation will occur in collaboration with the appropriate state and federal agencies, including the NPS Office of Public Health, the California Department of Food and Agriculture, US Department of Agriculture (USDA), FIGR, and CDFW.
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Beef and Dairy Ranching
Why are there beef and dairy ranches within Point Reyes National Seashore and Golden Gate National Recreation Area?
The enabling legislation for both Point Reyes and Golden Gate gives the Secretary of the Interior the discretionary authority to lease federally-owned land for beef and dairy ranching if the land was in agricultural use prior to its acquisition by the United States. The legislation also authorizes the Secretary to add any conditions to the leases that the NPS deems necessary to accomplish park purposes. This authority has been used consistently by every Secretary of the Interior since its enactment. In 2012, Secretary of the Interior Ken Salazar asked the NPS to pursue issuing 20-year lease/permits for beef and dairy ranching, ultimately leading to this planning process.
Does the federal government own the land where beef and dairying ranching occur in Point Reyes and Golden Gate?
Yes, the federal government owns the land where ranching and dairying operations occur. The enabling legislation for both parks allowed the NPS to acquire ranchlands from willing sellers. As lands were purchased, ranchers could continue beef or dairy operations under either a Reservation of Use and Occupancy (RUO) or an agricultural special use permit at 5-year intervals. Under an RUO, ranchers could retain a 25-year or life estate right to continue ranching in exchange for a portion of the purchase amount. (Two reserved life estates remain in effect.) When ROUs expired, ranchers could continue beef and dairy operations with agricultural special use permits at 5-year intervals. In 2009, the NPS was delegated the authority to offer 5- or 10-year lease/permits for beef and dairy ranching.
Is it true that ranchers were paid for their lands and were supposed to leave after 25 years?
No. Under the enabling legislation for both parks, ranchers could continue beef and dairy operations under leases/special use permits immediately after sale of the land or after the expiration of a 25-year or life estate RUO.
Has Congress recently addressed ranching in Point Reyes National Seashore?
In early 2019, Congress addressed ranching in a Joint Explanatory Statement regarding House Joint Resolution 31 (the Consolidated Appropriations Act, 2019). The Congressional statement noted that "multi-generational ranching and dairying is important both ecologically and economically" and is "fully consistent with Congress's intent for the management of Point Reyes National Seashore."
Do the ranches in Point Reyes and Golden Gate have historical significance?
Yes, the Point Reyes Peninsula & Olema Valley Dairy Ranches Historic Districts are listed on the National Register of Historic Places. The 22,237-acre Point Reyes Peninsula Dairy Ranches Historic District consists of seventeen tenant-operated dairy ranches established by the Shafter and Howard families beginning in 1857. The 14,127-acre Olema Valley Dairy Ranches Historic District includes nineteen properties operated by tenants or families beginning in 1856. Together, these districts reflect more than a century of change and modernization in the industry including the evolution from original wood frame milking barns to concrete Grade A sanitary barns of the 1940s. All but three of the ranches within the planning area are contributing resources to these historic districts.
Can ranchers participate in greenhouse gas mitigation or carbon sequestration practices often referred to as carbon farming in the preferred alternative?
Yes. Appendix F identifies USDA Natural Resources Conservation Science practice standards that have greenhouse gas mitigation and/or carbon sequestration benefits on farms and ranches, including Tree/Shrub Establishment, Conservation Cover, Riparian Forest Buffer, Riparian Herbaceous Cover, Critical Area Planting, Windbreak/Shelterbelt Establishment, Nutrient Management, Solid/Liquid Waste Separation Facility, Residue and Tillage Management, Grassed Waterway, and Filter Strip.
What type of agricultural lease/permits do the park ranchers have now?
Under the terms of the settlement agreement, the NPS issued lease/permits to ranchers who are party to the agreement for terms not to exceed five years from the date the agreement was approved on July 14, 2017. These lease/permits expire on July 14, 2022. Ranchers who did not sign the settlement agreement operate on 1-year authorizations. In addition, there are two remaining 10-year authorizations and two remaining life estates.
What happens in the event that an existing rancher decides to discontinue ranching?
The NPS will follow the succesion policy that supports multi-generational ranching compatible with the park’s natural and cultural resource objectives. The succession policy also recognizes the government-to-government relationship with the FIGR and the importance of considering traditional ecological knowledge in strategies to achieve park management objectives. In the event an existing dairy rancher and their immediate family members decide to discontinue dairy operations, no new dairy operations will be considered.
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What actions will the NPS take to address the water quality concerns in the ranching areas of the park?
Under the selected alternative, the NPS will identify and require implementation of actions to modernize manure management systems on dairies consistent with USEPA, state, and Regional Water Quality Control Board requirements. The NPS will monitor and evaluate water quality in the planning area and use monitoring data to target areas for improvement. Requirements will be incorporated into individual ranch operating agreements (ROAs) with required timing to ensure resource protection outcomes are realized. ROAs will regularly document and evaluate implementation of water quality improvement practices, monitoring, manure and nutrient management, and grazing management. Water quality regulations include total maximum daily loads and associated grazing waivers in the Tomales Bay water shed, as well as waste discharge requirements or waivers of discharge requirements for confined animal facilities. All beef ranches in the planning area will be regulated under a framework consistent with the requirements for the Tomales Bay watershed. ROAs will identify approved operations, practices and resource protection investments at the ranch scale and be used to monitor and enforce rancher compliance with permit requirements. ROAs will identify and monitor relevant metrics, such as authorized activities and grazing regime by area, establishment and maintenance of buffer areas, cattle stocking rates, and timing and location of grazing. The NPS will continue to seek funding and partnerships to implement water quality improvement projects on grazing lands.
What are fecal indicator bacteria and where do they come from?
Fecal indicator bacteria are species such as E. coli that live in the gut of warm-blooded animals and are introduced to the environment through fecal matter. Although most fecal bacteria are not harmful to humans, water quality testing often uses fecal indicator bacteria as a sign that harmful bacteria, known as pathogens, may be present. Inputs of fecal indicator bacteria can come from a variety of sources including livestock, humans, pets, and wildlife. Fecal indicator bacteria are found in the natural environment, but high concentrations in surface waters often indicate inputs or runoff from developed or agricultural areas.
What is National Park Service (NPS) doing to address water quality in the ranching areas of Point Reyes and Golden Gate?
To date, the NPS has overseen implementation of more than 170 management activities intended to improve resource conditions, including water quality, on lands under agricultural lease/permit managed by Point Reyes. These projects were completed in cooperation with ranch operators and other partners including the Marin Resource Conservation District, USDA Natural Resources Conservation Service, and San Francisco Bay Regional Water Quality Control Board. These management activities include fencing to exclude livestock from waterways or limit time spent in certain locations; controlled stream crossings to direct livestock across waterways at established locations; water supply for off-stream livestock drinking water; ranch infrastructure improvements such as road rehabilitation, roofs and gutters; waterway stabilization projects to reduce erosion; and riparian and upland vegetation planting (See Figure 4 of Appendix A in the FEIS's Appendices [49.4 MB PDF]). Identification and prioritization of additional management activities to improve water quality conditions is ongoing. Additionally, herbaceous plant material on ranches is monitored by the NPS each fall before the onset of winter rains, with a goal of maintaining an average of 1200 pounds per acre on the ground, to protect from soil erosion and stimulate the next season's vegetative growth. (See the Bartolome, et al., report published in 2015, and specifically Updated Figure A.2 the latest monitoring results.)
What water quality monitoring activities are ongoing in the ranching areas of the park?
The San Francisco Bay Area Network Inventory and Monitoring Program conducts monthly monitoring in the Olema Creek watershed. Water quality monitoring is also conducted monthly in Lagunitas Creek tributaries and Pine Gulch Creek, but alternates watersheds every two years, so after eight years, each water body will have four years of monitoring. Measured water quality parameters include water temperature, pH, conductivity, dissolved oxygen, turbidity, nitrate, total Kjeldahl nitrogen, and fecal indicator bacteria (E. coli and fecal coliform).
In addition, National Park Service staff collect samples at the same Olema Creek watershed monitoring stations mentioned above for five consecutive weeks in winter and five consecutive weeks in summer. These samples are analyzed for fecal coliform concentration to inform the San Francisco Bay Regional Water Quality Control Board's Tomales Bay Pathogen Total Maximum Daily Load (TMDL) program.
The Tomales Bay Watershed Council regularly monitors eleven tributary sites and four sites on Tomales Bay to document the long-term water quality trends in tributaries and Tomales Bay, including sites within Point Reyes National Seashore. The Tomales Bay Watershed Council also participates in monitoring to inform the TMDL program discussed above.
The organic dairies within Point Reyes National Seashore are required to conduct surface water sampling during or directly following three major storm events per year to comply with regulation of Confined Animal Facilities by the San Francisco Bay Regional Water Quality Control Board. Sampling typically occurs where watercourses leave lands used for dairy operations, and includes measurements of water temperature, pH, specific conductance, and total ammonia nitrogen.
Are there long-term trends in water quality in the Olema Creek watershed, where many of the Golden Gate ranches are located?
The University of California Cooperative Extension, in partnership with Point Reyes National Seashore, published an analysis of fecal indicator bacteria data collected in the Olema Creek watershed in the peer-reviewed journal Sustainability. This study found that the mean concentrations of fecal coliform declined by over 95% from 1999–2017. This reduction was concurrent with 40 best management practices implemented on ranches intended to improve water quality during the same time period.
Lewis, D.J.; Voeller, D.; Saitone, T.L.; Tate, K.W. Management Scale Assessment of Practices to Mitigate Cattle Microbial Water Quality Impairments of Coastal Waters. Sustainability. 2019, 11, 5516. Available at https://doi.org/10.3390/su11195516 (accessed 13 September 2021).
Are there other long-term trends for other watersheds within the park?
An analysis by NPS staff of water quality data collected in several coastal watersheds, including Kehoe Creek, Abbotts Lagoon, and Home Ranch Creek, indicates fecal indicator bacteria concentrations declined by 54-99% from 1999–2013 at 13 water quality stations downstream of 30 management activities implemented on grazed lands during the monitoring period (Voeller et al. 2021). There was no trend in turbidity (a measure of water clarity), but it was generally low, with approximately 92% of turbidity results collected between 2010–2013 in these coastal watersheds below a turbidity threshold representing unlikely harm to aquatic life (Voeller et al. 2021). This new trend analysis provides updated information for some of the parameters in the coastal watersheds described in Pawley and Lay 2013, which only looked at data from 1999–2005.
No long term analysis has been conducted by the San Francisco Bay Area Network Inventory and Monitoring Program to date, however they have produced a number of annual and biennial reports that provide snapshots of conditions.
The Tomales Bay Watershed Council also produced a summary report of monitoring conducted in the Tomales Bay watershed between 2007–2012, which includes stations in the park.
Carson, Rob 2013. Tomales Bay Wetlands Restoration and Monitoring Program 2007–2012 Final Water Quality Technical Report and Program Summary. Tomales Bay Watershed Council Foundation prepared for California State Water Resources Control Board SRF Project No. C-06-6926-110. Available at https://citeseerx.ist.psu.edu/viewdoc/download?doi=10.1.1.590.5117&rep=rep1&type=pdf (accessed 13 September 2021).
Voeller, D.J., Ketcham, B. and Becker, B.H., 2021. Improved Microbial Water Quality Associated with Best Management Practices on Coastal Dairies and Livestock Grazing Operations. Rangeland Ecology & Management, 76, pp.139–149. Available at https://doi.org/10.1016/j.rama.2021.02.011 (accessed 13 September 2021).
Why do some people refer to Point Reyes as one of the "crappiest places in California"?
A website called The Revelator reviewed publicly available water quality data collected and analyzed for E. coli from October 2012 to October 2017, and retained the single highest result from each individual monitoring station. From this, several isolated single sample results from the Kehoe Creek watershed appeared in their "10 most contaminated locations" map for the State of California. These single samples were collected at stations positioned by NPS in order to identify and address water quality concerns below high use portions of dairies such as corrals and feeding areas. A full analysis of water quality data collected at these stations from 1999–2013 conducted by NPS indicates fecal indicator bacteria concentrations have been reduced over time, concurrent with the implementation of best management practices on ranches in the watershed (Voeller, et al. 2021. See Appendix L in the FEIS's Appendices [49.4 MB PDF]).)
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