EAC Submits Public Comment in Support of Tomales Point Elk Fence Removal

Public Comment Period and Elk in California

Last month, the National Park Service solicited public comment for the development of a management plan for the Tomales Point area of Point Reyes National Seashore. The new plan, named the Tomales Point Area Plan, will guide how the National Park Service will manage the population of tule elk  located in Tomales Point.

The tule elk is the only elk species whose entire historic and current range exists solely in California. Their range occupied the coast and valley regions from Lake Shasta to the Topatopa Mountains in Ventura County. However, hunting and habitat loss reduced the species to near extinction. The disappearance of tule elk across California caused so much alarm that as early as 1873 elk hunting was completely banned by the State Legislature. The last remaining population of tule elk was found on a private ranch in Bakersfield which numbered no more than 50 individual members. In fact, DNA evidence suggests that elk numbers could have been as low as two to four closely related individuals. Efforts to reintroduce tule elk to its former range began in 1914. However, most early state-wide reintroduction efforts were largely unsuccessful. In 1978, an effort began to return them to one of their known ranges at Tomales Point in the Point Reyes National Seashore. Today, the Tomales Point tule elk is one of the largest herds in California. With roughly 5,700 tule elk across California today, the reintroduction of tule elk to its former habitat is considered one of the success stories of conservation efforts.

Elk Fencing

The elk population in Tomales Point have been confined behind an elk fence since their 1978 reintroduction. When the elk population surpassed 130 individuals in 1990, concerns began to emerge that the land behind the elk fence in Tomales Point was not capable of sustaining such a large confined population. Concerns became real when drought conditions collapsed the  population from 585 elk to 422 elk from 2007-2009, 540 elk to 286 elk from 2012-2014, and 445 elk to 221 elk from 2019-2021. Each time, the population was unable to recover to its former size before another collapse occurred. Interestingly, there exists an unconfined herd population that began in 1998 after some elk in Tomales Point were moved to Limantour Beach and Drakes Beach. As opposed to the confined population in Tomales Point, the unconfined population in Limantour Beach and Drakes beach did not experience any population decline during the same drought periods. This has been largely attributed to the ability of the unconfined herds to travel to more resource-available areas rather than continuously grazing in the same area. In recognition of this, the National Park Service has provided supplemental water and minerals to the Tomales Point herd since 2021.

NEPA Alternatives Presented & EAC’s Position

Now, the National Park Service is faced with a decision about how to manage the herd in the future. Consistent with the National Environmental Protection Act (NEPA), the National Park Service solicited the public to comment on three different proposed plans.

The first proposal (Alternative A) would maintain the status quo. The tule elk at Tomales Point would remain a confined herd behind the elk fence with water and minerals continuing to be supplied to sustain the herd.

The second proposal (Alternative B) would remove the elk fence and the 2021 water system. This would provide for an unconfined herd in Tomales Point. Currently, the National Park Service is supportive of this proposal.

The third proposal (Alternative C) would maintain the elk fence and institute “active management” of the confined elk population. “Active management” would require culling the elk population if the number of elk reaches a certain threshold. The water system installed in 2021 would be removed.

We responded to the National Park Service by submitting a letter in support of Alternative B. Alternative B most closely adheres to several fundamental principles for management of National Park resources, including existing federal statute and National Park Service management policy.

Alternative B is consistent with the Point Reyes National Seashore Establishment Act that governs the Seashore and the Wilderness Act that governs the Phillip Burton Wilderness Area, which includes nearly all of Tomales Point. Alternative B is also consistent with the National Park Service management policies related to science-based management requirements and interagency cooperation guidance.

Learn More

EAC Comments re. Tomales Point Area Plan

California Department of Fish & Wildlife Tule Elk Webpage

National Park Service Tomales Point Area Plan Public Scoping Newsletter

Reports Cited in EAC Comment Letter

Dale R. McCullough et al., Final Report of the Scientific Advisory Panel on Control of Tule Elk on Point Reyes National Seashore (1993)

National Park Service, Point Reyes National Seashore Tule Elk Management Plan and Environmental Assessment (1998)

National Park Service, Management Policies (2006)

California Department of Fish and Wildlife, Elk Conservation and Management Plan (2018)