General Management Plan Amendment: Draft Environmental Impact Statement Frequently Asked Questions

What is a General Management Plan Amendment (GMP Amendment or GMPA)?

A General Management Plan Amendment is a document that partially amends an existing General Management Plan (GMP). The 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 and the north district of Golden Gate National Recreation Area.

Why aren’t you doing a complete General Management Plan (GMP) for the whole park?

The National Park Service is required by a court-approved settlement agreement (4,799 KB PDF) to complete this plan and issue a record of decision by July 14, 2021. Consistent with the settlement agreement, the General Management Plan Amendment will focus on the park’s highest planning priority, the areas of Point Reyes National Seashore and Golden Gate National Recreation Area where ranching is currently permitted.

How will the GMP Amendment relate to the park's existing 1980 General Management Plan?

The General Management Plan Amendment will replace the 1980 Point Reyes National Seashore GMP (4,015 KB PDF) for lands within the General Management Plan Amendment planning area.

Is the NPS required to consider and evaluate specific alternatives in the GMP Amendment?

Yes. Under the multiparty settlement agreement, the National Park Service is required to consider and evaluate a no ranching alternative, no dairy ranching alternative, and a reduced ranching alternative. The draft General Management Plan Amendment also identifies and analyzes additional alternatives.

What is a preferred alternative?

A preferred alternative is the alternative the National Park Service (NPS) determines will best accomplish the purpose and need of the proposed action that meets the NPS mission and responsibility, with consideration to economic, environmental, and technical factors.

How will my comments on the plan be used?

We will review every comment submitted and prepare responses to substantive comments. Some responses may be reflected as edits to the text of the final Environmental Impact Statement (EIS) if needed to clarify existing information or add new information. The final EIS will contain summaries of the substantive comments and responses to those comments in an appendix. Numerous comments that repeat the same basic message will be responded to collectively.

Substantive comments are defined as those that do one or more of the following:

• Question, with reasonable basis, the accuracy of information in the draft EIS.
• Question, with reasonable basis, the adequacy of the analysis.
• Present reasonable alternatives other than those presented in the draft EIS.
• Cause changes or revisions to the restoration actions proposed in the alternatives.

Is commenting like voting on an alternative?

No, commenting is not a form of “voting” on an alternative. Comments in favor of or against a particular alternative, or comments that only agree or disagree with National Park Service (NPS) policy are not considered substantive. Although all comments will be read and considered in the development of the final Environmental Impact Statement, only substantive comments require a response from the NPS. The number of comments received on an alternative is not a determination of its merit for consideration in the planning process.

Will the NPS issue lease/permits to the park ranchers during the GMP Amendment planning process?

Under the terms of the settlement agreement (4,799 KB PDF), the Natioinal Park Service has 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 by the court on July 14, 2017. These interim leases, which expire July 14, 2022, provide greater certainty to ranchers than the 1-year authorizations the NPS issued during the Ranch Comprehensive Management Plan process. The planning process will be complete well before these leases expire.

How will impacts to ranch operations from tule elk be mitigated while the GMPA is being developed?

The park recognizes this is an ongoing concern to ranch operations. The park will continue to work with park ranchers and the Point Reyes Seashore Ranchers Association throughout the planning process to address the management of tule elk in a manner consistent with the settlement agreement.

Does the Point Reyes range program partner with other agricultural organizations?

Yes, the NPS works closely with local agricultural organizations, state agencies, natural resource conservation experts, and stakeholder groups such as UC Cooperative Extension, Marin Resource Conservation District, Natural Resources Conservation Service, and Marin Agricultural Land Trust to share information and discuss issues related to ranching.

What park management is currently happening on ranches?

In order to adhere to various regulatory requirements and park service mandates, the Point Reyes range program:

• Monitors various attributes including vegetation, water quality, and ranch infrastructure.
• Implements management practices to protect sensitive resources including water quality and rare and endangered species.
• Conducts residual dry matter monitoring each fall to get a sense of how much grazing occurred during the year.
• Conducts invasive species management.
• Conducts permitting for individual management actions and improvements by ranch operators not covered under lease/permit, such as fence construction and installation of water troughs.

Do the ranches in Point Reyes and Golden Gate have historical significance?

Yes, the Point Reyes Peninsula & Olema Valley Dairy Ranches Historic Districts are formally 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.

Will this public comment period satisfy the public involvement requirements of the NHPA?

Yes, this comment period will satisfy the public involvement requirements of the National Historic Preservation Act (NHPA). Section 106 of the NHPA requires the National Park Service (NPS) to identify and assess the effects its actions may have on historic and cultural resources. In this planning process, the NPS is coordinating compliance with Section 106 of the NHPA with the requirements of the National Environmental Policy Act. The NPS will consider comments on the historic preservation issues presented in the draft Environmental Impact Statement.

What is the timeline for this planning process?

• Notice of intent to prepare an EIS, 30-day public comment period and meetings: fall 2018
• NPS develops a draft EIS for the GMP Amendment: fall 2018–summer 2019
• Draft EIS released for 45-day public review & comment period, including public meetings: summer–fall 2019
• NPS develops final EIS for GMP Amendment: anticipated fall 2019–summer 2020
• Final EIS released to public, followed by a minimum 30-day waiting period: anticipated summer 2020
• GMP Amendment record of decision signed by NPS Regional Director: anticipated in 2020 with a minimum 30-day waiting period after release of the final EIS

How many tule elk are there at Point Reyes National Seashore?

There are 730+ tule elk in three different herds at Point Reyes National Seashore. The National Park Service (NPS) conducts a tule elk census at the end of each calendar year. In 2018, there were 432 elk in the Tomales Point herd (this fenced herd is not included in this plan), 174 elk in Limantour free-ranging herd, and 124 in the Drakes Beach free-ranging herd. The Draft Environmental Impact Statement for the General Management Plan Amendment's preferred alternative maintains these two free-ranging herds in the park (pp. 40–42).

How did the NPS arrive at a population threshold of 120 adult elk for the Drakes Beach herd?

The Draft Environmental Impact Statement for the General Management Plan Amendment's preferred alternative proposes management of the Drakes Beach herd at viable population threshold of 120 individuals, compatible with authorized ranching operations. This population threshold is based on consultation with the California Department of Fish & Wildlife, forage productivity on ranches, estimated forage consumption by elk, time elk spend on ranches, authorized ranching operations, and NPS capacity to manage elk, while also maintaining the viability and health of the herd (p. 40).

How does the NPS proposed management of the Drakes Beach herd compare to CDFW tule elk management?

How does the NPS proposed management of the Drakes Beach herd in the Draft Environmental Impact Statement for the General Management Plan Amendment's preferred alternative compare to tule elk management by the California Department of Fish & Wildlife (CDFW) throughout the state?

The Draft Environmental Impact Statement for the General Management Plan Amendment's preferred alternative proposes lethal removal of 10 to 15 elk per year in the Drakes Beach herd by NPS staff or trained volunteers. The elk management approach in the preferred alternative is consistent with how other tule elk herds are managed by the California Department of Fish & Wildlife (CDFW), and is in line with the Draft Elk Management Plan (2017) for the State of California. CDFW has allocated 332 elk tags in 2019 for lethal removal through recreational hunting throughout California.

How will the park ensure protection of sensitive resources with continued ranching?

The new zoning (Resource Protection, Range, Pasture & Ranch Core subzones) is designed to protect threatened, endangered, and other sensitive species, wildlife habitat, and water quality while authorizing continued beef and dairy ranching.

Will the proposed diversification threaten wildlife and replace beef & dairy ranching?

Any new diversification of livestock or row crops in the preferred alternative specifically prohibits management of predators and other wildlife by ranchers (p. 38). Diversification is limited to the Pasture subzone (livestock: no more than 10% or 10 animal units (AU), whichever is less, of overall authorized animal units; chickens: no more than 500 per ranch) or Ranch Core subzone (livestock and other diversification in developed areas of ranch core and non-irrigated row crops limited to 2.5 acres) (pp. 37–38).

Does the DEIS for the GMPA's preferred alternative expand ranching in lands managed by the NPS?

The preferred alternative grants 20-year leases to the existing 24 beef and dairy ranch operations on approximately 26,100 acres. The plan does not expand the active acres of ranching in the park. It does provide limited opportunities for diversification, and establishes a subzoning framework to protect park resources while maintaining ranching. The NPS estimates authorizations in the preferred alternative would be similar to existing lease/permits, with approximately 2,400 AU of beef cattle and 3,130 dairy animals (p. 25).

Has the Congress recently addressed ranching in Point Reyes National Seashore?

In early 2019, the 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."