GMPA Comment Period Results and Habitat Restoration Allowable Uses

Background

For 47-years, EAC has addressed the important environmental issues that face our community and public lands. We have worked on community development and public access to parks and coastal areas, supported pathways for ecologically sustainable agriculture, promoted affordable housing development, protected wildlife, supported strong coastal protections, provided environmental education, and protected Tomales Bay and West Marin’s watersheds. 

We are currently engaged in the public process around the Point Reyes National Seashore (Seashore) and their amendment of the General Management Plan (GMPA) that will provide guidance on future ranching operations. 

In October 2017, we activated our membership and community members to submit comments on the Seashore's 37-day public comment period on six conceptual alternatives. 

We have some updates on the results of the comment period, next steps, and a review of the November 6, 2017 Seashore letter to the Marin Resource Conservation District concerning Carbon Farm Planning.


Comment Period Results and next steps

The Seashore received over 3,000 comments on the proposed concepts. (Read EAC's comments). The Seashore is currently reviewing the comments and revising their proposed concepts based on public feedback.

The Seashore expects to release copies of the comments in the next few months and the official Notice of Intent should be filed 12-15 months from the October 2017 comment period so in the Fall of 2018 or Winter of 2019. The public can stay up to date on the timeline and process by checking the Seashore's GMPA update page and signing up for email alerts. 


Habitat Restoration and Interim Allowable Uses

Recent discussions in the West Marin community have implied that the Seashore may be preventing habitat restoration practices due to the language of the 2017 lawsuit settlement agreement . EAC wanted to take this opportunity to share our findings with our membership concerning this topic. 

Paragraph five of the Settlement Agreement outlines that the Seashore may issue interim leases to existing lease holders or their family members that do not exceed the interim period (until July 14, 2021). Those interim permits authorize the ranches to continue under the current terms and conditions and do not allow for new uses.

During this interim period, some ranchers are interested in implementing Carbon Farm Plans or grants through the Marin Resource Conservation District (RCD). The Seashore submitted a letter to the Marin RCD on November 6, 2017 outlining the types of Carbon Farm Plan techniques that may or may not be allowable under the language of the settlement.

Allowable: Techniques that have been implemented under past permits should be allowed. This includes items like: riparian restoration, riparian forest buffers, critical area planting, and wetland restoration.

Potentially Allowable: Some of the techniques that may be allowed include forage biomass planting, conservation cover, no till, improved nutrient management practices (improvements/refinement of locations for current manure spreading practices would be considered), prescribed grazing (if practice does not exceed current authorized annual and maximum stocking rates).

Not Allowable: Some of the techniques that are considered potentially new activities that cannot be implemented at this time include silvopasture establishment, windbreaks, hedgerow planting, compost application to rangelands, range planting, and anaerobic digesters without additional study and information. 

Overall, EAC understands the Seashore’s interpretation of the Settlement Agreement to allow for a wide variety of conservation and restoration projects on the ranches during this interim period.

We hope the ranching community will take advantage of the opportunities made available to them through varying techniques of allowable Carbon Farm Planning that will restore habitat and improve water quality while sequestering carbon and improve natural resource conditions on the ranches. Additional techniques may be available following this interim period.


Throughout this process, members can rely on EAC to stay engaged and provide updates and information on the process and additional opportunities for public engagement.

General Management Plan Amendment (GMPA) Comment Period Open

The Issue:

The National Park Service (NPS) has started their General Management Plan Amendment (GMPA) process for the Point Reyes National Seashore (Seashore). In October, NPS released the GMPA Newsletter that provided the public with information on how they propose to integrate changes to ranching in the pastoral zone of the Seashore. 

The proposed Concepts range in land-use intensity and natural resources management including: no ranching, limited ranching, continued ranching with removal of the tule elk, and no changes. The Conceptual Alternatives provide limited information about best management practices, creation of resource protection buffers, management of tule elk, diversification, operational flexibility, visitor carrying capacities, and improved visitor experiences. Some of these terms need to be expanded and explained in further detail. In addition, the Concepts propose various modifications to the type and amount of ranching acreage occurring on NPS lands. Ultimately, this leaves room for more questions than answers. 

EAC's Guiding Principles:

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. 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. This may be achieved through a comprehensive public planning process that balances the unique qualities of the park resources within the pastoral zone.

EAC's Concerns:

EAC understands that the Concepts presented by NPS to the public marks the commencement of a process to engage public feedback and ideas. Therefore, the public should not be constrained or feel pressure to support a specific Concept. 

EAC advises our members to use this comment period to seek clarification, question the choices in the Concepts, present information that is missing, and offer your thoughts on how things could be done. Below are a few of EAC's concerns and suggested questions for each topic. 

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. EAC understands ranching operations are limited to dairy and cattle ranching as intended by the enabling legislation. Therefore, EAC does not support the 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. EAC does 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?


Take Action:

Research: 

GMPA Newsletter
NPS GMPA webpage
EAC's GMPA webpage

Submit Comments:

Sample Letter (word file)
Sample Letter (pdf)
Send to the Seashore

Important Notes:

  • Remember, the Concepts are not limited by what NPS has suggested.
  • You do not need to support a specific alternative at this time. Some important items and definitions are missing. In fact, you can propose a new alternative they may not have considered.
  • This is the time to ask NPS questions, including their criteria for determining what is included and why.
  • Finally, if you don't like something explain why you do not like it.