Point Reyes National Something-or-Other

“What’s in a name?  That which we call a rose, by any other name would smell as sweet.”

What should we call the diverse, wild, inspiring but scarred peninsula sliding very slowly past us, jurisdictionally in West Marin County, California, but geologically across the San Andreas Fault, on the Pacific Plate, going steadily its own way, namely Northwest?  Should we call it Point Reyes National Park or Point Reyes National Seashore?

Technically, the latter is correct.  And it really shouldn’t matter.  But it seems to matter a lot to some people, and understanding why tells a story.

First, in case you don’t know, Point Reyes National Seashore (PRNS) is an area of about 71,000 acres whose beauty, richness, and diversity are difficult to overstate.  The only National Seashore on the West Coast, surrounded by the Greater Farallones National Marine Sanctuary, it contains a genuinely unique roster of habitats: ancient conifer and mixed forests, coastal prairie, wind-swept chapparal, verdant canyons, riparian corridors, sandy and rocky beaches, fresh and saltwater estuaries, marshes, mudflats, intertidal zones, dunes, and lagoons.  Flora includes 750 species, including ~20% of all California natives.  Unsurprisingly, these habitats support veritable arks of wildlife: mountain lions, coyotes, bobcats, badgers, mountain beaver, two species of weasel, river and sea otters, fox, deer, elk and others. The Park is along the Pacific Flyway and almost half of all North American Bird species, nearly 500 in all, are recorded there.  There are seven species of bat.  On the coastline and offshore are seals, including elephant seals, sea lions, eight types of dolphin and two kinds of porpoise, 18 species of whale, seven species of shark including the greatest concentration of great whites anywhere.  The preceding list of lists is incomplete.  There are over 50 species registered as threatened, rare, or endangered at the state or federal level.

I visit the park often and rarely does one leave without witnessing something wonderful and wild. Ever see a badger stare down two coyotes over a recently caught gopher? Or a Belted Kingfisher splash down in a lagoon to avoid a pursuing Peregrine Falcon? Or a Great Horned Owl scatter a covey of California Quail like confetti into the beach lupine? Or a family of river otters swim out of one creek, frolic up-beach in the surf, and then waddle up the dunes again and into the next creek, as if on a schedule? Or an American Bittern drowning a vole and shaking it to make sure? Or a bobcat and a coyote sitting a few feet from each other with no apparent tension? I have.

And all this is without an entrance fee, just an hour or so from San Francisco and Oakland, even accessible via public transportation, making such experiences reachable to many who don’t or can’t travel to places like Yosemite or Yellowstone.

Second, for your information, the Seashore is currently and seemingly continually enmeshed in controversy. The briefest of timelines is given to provide context to what follows:

Ranching has existed on the peninsula since the mid-1800s. Previously, the land was occupied by the Coast Miwok people for thousands of years. The Park was formed on paper in 1962. Over the subsequent few years, the government purchased land from the ranchers to assemble the Park, extending them Reservations of Use and Occupancy (ROU) — effectively the right to stay on and work the land for a specified duration. In 1978, the Park’s charter was amended to allow the National Park Service (NPS) to extend leases for continued ranch use, regardless of the status of the original ROUs. Depending on whom you listen to, ranching was meant to be part of the Park in perpetuity, or the ROUs were transitional, sweetening the purchase agreements but known to be temporary.

Again, depending on whom you listen to, the ranches in Point Reyes are either laudable stewards of the land, or lamentable sources of greenhouse gases, water contamination, invasive species, erosion, and habitat loss (or, of course, somewhere in between, but views are polarized.)

Also in 1978, a small herd of tule elk, a California endemic species once very near extinction, was brought to Point Reyes to establish a preserve inside the Park on Tomales Point, behind an eight-foot fence stretching from the Pacific to Tomales Bay. Two free-ranging herds have since been established outside of the fenced reserve, in the southern part of the Park. PRNS is the only National Park with tule elk. Currently there are approximately 600-700 elk in total in PRNS and about 5,500 cows. During the drought of 2013-2015, several hundred elk died behind the fence in the preserve, whereas the free ranging herds grew over this time.

The NPS was sued in February of 2016, and in the settlement was compelled to produce an Environmental Impact Statement (EIS) and update its management plan for ranching inside the Seashore. The draft plan and EIS were released in August 2019, public comment collected, and a final EIS published in September 2020. The EIS includes six management options, including Alternative B which extends 20-year leases to the ranches and expands and diversifies their permitted commercial activities, and Alternative F which phases out all ranches and dairies over five years. Alternative B is identified as the “preferred” alternative by NPS and is favored by the ranching community, whereas Alternative F is supported by various citizen and environmental groups. The final decision is imminent and might beget more lawsuits.

The reader is now more or less caught up on what’s going on and what’s at stake. Now here is the latest twist:

On February 9, 2021, the Seashore distributed an email entitled “Corrections to Media Coverage on the General Management Plan Amendment,” in which they explained “the National Park Service would like to make sure you have the most factual information available.” The email enumerated eight corrections, all aimed at Peter Byrne’s article, Apocalypse Cow: The Future of Life at Point Reyes National Park published in the Pacific Sun on December 9, 2020.

Byrne’s article is very much worth reading and is highly critical of the NPS’ preferred plan, which will expand and entrench commercial livestock operations in the Seashore, despite the documented environmental damage done by the ranches and dairies (think methane, E. coli, soil erosion, invasive species, habitat degradation, etc.) The plan is wildly unpopular with the public, because, among other things, it provides for the immediate killing of dozens of native tule elk and schedules their ongoing culling, on behalf of the ranchers in the park, who see the elk as competition for pasture.

Byrne and the Park independently confirm that the Park communicated a version of its putative corrections to Pacific Sun before publication, and that its editors replied indicating the story was factually correct and offered to meet with the Park and provide a detailed response. The Park did not reply to the offer, nor did its public allegation of errors acknowledge that the offer had been made.

As for the nature of the corrections, I brought significant bias as a reader, but they seemed to me obtuse, as when the Park refutes Byrne’s claim that the ranchers agreed to leave after 25 years by citing the 1978 legislation allowing continued leases, which is not contradictory; or obscurantist, as when the Park claims Byrne’s oft-cited figure for how much the Park paid the ranchers when purchasing their land ($382 million, adjusted) is wrong, without supplying the correct figure; or defensive, such as where the Park points out that the elk in 2013-15 die-off did not succumb from thirst, but rather from drought-induced malnutrition, and adding the biologically implausible statement, “if there was no water available to the elk at this time, all of the elk would have perished.” (I’m not a biologist, but this is wrong: lack of water will take the most vulnerable to dehydration first, not 500+ animals simultaneously, and it is known that there are sub-herds north of the fence, with territorial behavior, such that water might have been available to only a subset of the animals based on distribution.)

If it seems unusual to you for a government agency to first decline to meet with a journalist and subsequently blast an email pleading its case, you’re right. Laura Cunningham, California Director of the Western Watersheds Project (WWP), said, “I have never seen a federal agency spend so much time and effort critiquing a single reporter and specific article in such detail and then publicly.”

So what’s going on here? To return to Shakespeare, “Methinks the lady doth protest too much.”

Let’s take one more of the eight corrections from the Park’s email, ostensibly the most innocent and factual:

The name of the park is “Point Reyes National Seashore,” not “Point Reyes National Park.”

Harping on that last word would be merely pedantic, except for the fact that the Point Reyes ranchers have long implied that Seashores fall under different laws and policy than Parks, presumably in an attempt to inoculate themselves against charges regarding their legal and ecological status. For example, a July 22, 2020, op-ed in the Marin Independent Journal from Point Reyes rancher Kevin Lunny claims, “PRNS is not a national park. Where parks are created for quieter, contemplative uses, national seashores are for public activities, recreation and historic cultural uses.” Additionally, a 2014 scoping letter from the Point Reyes Seashore Ranchers Association (PRSRA) to the Park says, “… PRNS is a “National Seashore,” not a “National Park.” PRSRA asks that all [Environmental Assessment] documents, publications and communications be corrected…this error, if not corrected, could cause the public and consultants to apply the wrong standards to this environmental review.”

Whereas you can be sure that the Ranchers Association was not worried about the operative standard being too low, there simply is no such distinction; “Seashores” and “Parks” are both “National Park Units” and are subject to the same laws, for example the Organic Act of 1916, which requires the National Park Service to “manage park resources and values in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.” In addition, the PRNS Enabling act, specific to this Park/Seashore/Park Unit requires the land to be administered “supportive of the maximum protection, restoration, and preservation of the natural environment within the area…”

So a bystander may wonder why the Park is taking pains to underline the basis for such a self-interested obfuscation, rather than correct the actually-substantive inaccuracy in the first place — which, as far as the author is aware, they have not done, publicly or otherwise. Why are they being faithful to a six-year-old request from the Ranchers’ Association to correct “Park,” which is common usage, confusing no one, and technically equivalent? In other words, why is the Park telling Byrne he is wrong instead of the ranchers?

And a cynic may supply the answer: because the distinction is rhetorically useful to certain interests and the NPS works for the ranchers. If that sounds overly cynical, towards paranoid, read on.

The controversy did not start with Apocalypse Cow, of course.

The West Marin community is still agitated by the “Oyster War,” culminating in 2013, when the Drakes Bay Oyster Company, run by Mr. Lunny, shut down after the Park Service declined to offer a lease at the expiration of a 40-year ROU, the balance of which Lunny had purchased from the former operator, Johnson Oyster Company. The Park Service stated that issuing a lease for the business to continue would have been illegal in designated potential wilderness. Site clean-up cost over $4 million, paid for by the National Park Service and the National Park Foundation.

There is also the mentioned recent lawsuit and resulting EIS, which cost nearly $1.5 million to generate, and the General Management Plan, including the preferred Alternative B, which as mentioned is decidedly opposed by the public. As part of the scoping process for the Plan, the Park Service was legally obliged under NEPA to accept public comments. More than 7,600 comments were received. They are available online from the NPS (link). The author was personally involved in an analysis of the comments done by the Renewal Resource Institute (link). The analysis shows that over 91% (6,969) of the 7,627 respondents opposed Alternative B on various grounds. Of all public comments which endorsed any specific plan explicitly (1,859), over 94% (1,751) endorsed the plan that removes ranching altogether (Alternative F). Further indication of the public’s will regarding the way forward in the Park is found in the public comments submitted to the California Coastal Commission, which has yet to render a “determination of compliance” on the plan. (The Coastal Commission cannot block the plan, but a finding of non-compliance would be awkward for the Park and would encourage opposition.) The staff report indicates that the overwhelmingly majority of comments were opposed to the plan, especially regarding the culling of tule elk.

Lastly, many advocate groups such as forelk (link), Save Point Reyes National Seashore (link), In Defense of Animals (link), et al, have joined the lawsuit’s plaintiffs (Resource Renewal Institute (RRI), Western Watersheds Project (WWP), and the Center for Biological Diversity (CBD)), are trying to raise awareness of the contents of the plan, and are making some headway despite the massive news shadows cast by covid-19, the election, capital riots, and the like, and despite the impressively disciplined “there’s-nothing-to-see-here” stance from status quo politicians and organizations sympathetic to the ranch families. It’s not surprising, for example, that if well-respected and normally green U.S. Representative Jared Huffman routinely portrays PRNS as a popular model of balance and sustainability (“a unique mosaic which most people love pretty much the way it is”) despite the lopsided and unequivocal counterevidence, that those trying to block the unfortunate plan have a long row to hoe. CBD, for example, strongly opposes Representative Huffman on this issue, but works with him on too many other public-lands protection and conservation matters to withhold their endorsement from him. Besides, he faces no serious challenge for his seat, as of now.

So, Apocalypse Cow can be read as an exposé, trying against long odds to keep the dice uncast, and the Park’s “corrections” email can be read as a counter-tactic, seeking to mute those voices and discredit those concerns.

President Trump, recall meanwhile, invited Kevin Lunny to the White House in October, 2019, for an executive order signing ceremony giving access to private corporation profit from public land, where in reference to the “Oyster War,” they commiserated on the lamentable past abuses of big government of struggling, small businessmen like himself. During the photo-op, President Trump told Mr. Lunny, “We’ll have somebody right here in the White House looking at it, Kevin, so this doesn’t happen to other people.”

The rest of Mr. Lunny’s referenced op-ed to the Marin Independent Journal last July is also worth reading, where he unabashedly pines for the days when he and his family could hunt and fish as they please in what is now a National Park, add “any species of farm animal we wanted,” and “use the sand dunes,” etc. Mr. Lunny makes explicit his desire to return to the Shafter-era model of land use, namely 1860-1960, but omits any reference to the antecedent genocide of the former Native American inhabitants of the area, the rampant clear-cutting of the coastal conifer forests and decimation of the coastal prairies, vestiges of which can be seen in the elk preserve and other unranched areas of PRNS, to make way for livestock, or the extirpation of elk and grizzly and general domination of wilderness by our glorified frontier endeavors.

Another document worth reading on the topic is the aforementioned 2014 letter written by the Point Reyes Seashore Ranchers Association, delivered to then-Superintendent Cecily Muldoon and copied California Senators Feinstein and Boxer, Representative Huffman, State Assembly Member Marc Levine, and then-Marin County Supervisor Steve Kinsey. The letter is indeed worth reading, but then again one might save the time if one has already read the Park’s “preferred” Alternative B, for which the letter served as an apparent blueprint. It’s a brazen letter to Santa Claus, specifying what should be used as the environmental baseline (current day operations), what Park Unit elsewhere should be used as a model (Cuyahoga Valley National Park in Ohio), how long lease renewals should be (20 years) what should become of the lease succession policy (less restrictive), what activities should be expanded or newly allowed (poultry, sheep and goats, including guard animals, row crops, retail shops and farm stands, tours, B&Bs, onsite butchering, food-processing, including from produce brought in from elsewhere, cheese-making, et al.) It also characterizes the native tule elk as an invasive nuisance and implies that “overpopulated elk” may transfer Johne’s disease to cattle, when it is well known that the domestic livestock are from where the elk contracted the disease originally. (The disease in the elk, by the way, makes their relocation implausible and strengthens the case for culling them over any more humane or ecologically sound way forward.)

Into this ever-fresh pile steps new PRNS Superintendent Craig Kenkel, who most recently was head of — wait for it — Cuyahoga Valley National Park in Ohio — another on the short list of National Park Units which incorporates for-profit, private use of public lands and which utilized federal sharpshooters to cull deer populations, which is the likely fate awaiting scores of tule elk in PRNS. Superintendent Kenkel gave a careful interview to the Point Reyes Light last December in which he said, “everyone has a right to be heard” and later added, “farming is in my DNA.” He was named last November by scandal-ridden extraction and agriculture lobbyist-cum-Trump Interior Secretary David Bernhardt and appears to be handpicked in the background by the ranchers (so much for everyone being heard.) Superintendent Kenkel started in January, so the February 9th “corrections” email came out on his watch. One wonders whether the “corrections” email went out without his knowledge, at his direction, or against his wishes, as well as which possibility reflects least poorly on him.

If you’re keeping score at home, the Ranchers’ Association, in 2014, before the court-ordered Environment Impact Statement, asked the Park what moniker to permit, what length of leases to offer, what commercial activities to allow, and who to put in charge, and the Park has obeyed on each point and in high fidelity, entirely heedless of overwhelming objections from the owners of the land (the public).

Those of us who want our National Park to be a healthy haven rather than a heavily impaired livestock operation take heart in the promise offered by the incoming Biden administration, which has pledged to make climate change a top priority, which nominated a Native American woman as Secretary of the Interior, and which will bring science back into environmental policy, spelling an end to alternative facts and the persistent upper hand for the entrenched and powerful. PRNS should by swept up and turned around as part of 30 x 30, the new administration’s plan to protect 30% of U.S. land and coastal seas by 2030.

Furthermore, we continue to press our case. Western Watersheds Project, one of the 2016 lawsuit plaintiffs, along with In Defense of Animals, recently conducted independent tests of water quality downstream from some of the ranches in PRNS, at popular public-accessed streams and beaches, including Kehoe Lagoon, which drains into the Pacific. The Park has not done water quality tests since 2013, for reasons withheld, even though there were significant bacteria and other issues found at that time. The new results, published March 3, 2021, show 5X the safe human limit of coliform bacteria, 40X the safe limit for E. coli, and 300X the safe limit of enterococci. As of this writing, PRNS has acknowledged receipt of the study results but has not indicated any planned response, such as placing a sign to warn the public.

What should be done at a minimum, in the authors opinion, is a deferral of the deadline for a finalized plan, allowing public hearings at which previously ignored voices, such as those of the Coast Miwok, can be heard; at which the owners of the land (the public) can express their will to decision-makers without any chance of genuine or feigned misunderstanding; at which previously unquestioned assumptions, such as that the ranches in PRNS appropriately preserve history, can be tested; and at which already refuted claims, such as that the ranches in PRNS are good stewards of the land and ecologically important, can be retired as a matter of public record.

The hearings should not be dominated by parties that have shown themselves to be partisan, such as the National Park Service itself or the Marin County Board of Supervisors, or which have vested financial interests, such as the Point Reyes Seashore Ranchers Association and the Marin Agricultural Land Trust (MALT). Such criteria also disqualify Senator Feinstein and Representative Huffman, in whose district the park lies, both of whom, without any hint of irony or chagrin, boast that their positions on Point Reyes survived the publication of the EIS without significant modification, and both of whom accept significant campaign contributions from agricultural sources.

There is little time left. The General Management Plan must be finalized by July 14, 2021. It is not expected that the Park Service renders its final decision before hearing from the California Coastal Commission. The Coastal Commission has postponed its determination of compliance from its original target date of January 20, 2021 (yes, inauguration day) to April 22, 2021, (yes, Earth Day).

– – –

Park Service Pushes Back on ‘Apocalypse Cow’


Apocalypse Cow: The Future of Life at Point Reyes National Park

Meet the new superintendent of the Point Reyes seashore




Trump’s fix is in on Point Reyes





  1. Maggie Frazier Avatar
    Maggie Frazier

    Really good read! Much I’ve read before & all of which needs much publicity & public outcry. Hope the people who care about this wonderful Park/Seashore all speak up and loudly! AND that our new Secretary of DOI steps up and does what she does best!

  2. Ed Loosli Avatar
    Ed Loosli

    Ken Bouley – Bless you! and all those working to talk truth to power regarding returning Pt. Reyes Nat. Seashore to its more natural and wild condition. The mission of the National Park Service, which is supposed to be looking out for the lands, air and waters of PRNS – is preservation and protection, not exploitation and degradation of the park’s natural resources.

    It continues to amaze me how about 20 private businessmen (the so-called “ranchers”), who do NOT own one acre of this land, can literally push the National Park Service and the public around, and get away with it year after year – no matter what the law says.

    The Nat. Park Service and the livestock-owners claim to be preserving the history of livestock grazing carried out by previous European descendants of these California coastal lands. However, the real historic grazers of these publicly owned Pt. Reyes lands, going back THOUSANDS OF YEARS, are the native Tule Elk that are now in the gun-sights of the Nat. Park Service snipers. How pathetic and illegal it all is.

    1. Kenneth Bouley Avatar
      Kenneth Bouley

      Thanks, Ed. That these ranches preserve history is one of the persistent myths perpetuated by Jared Huffman and other. Besides the blunt insult to the Coast Miwok people, these are simply not historic operations. They are modern, intensive, profit driven, and damaging.

  3. lonna richmond Avatar
    lonna richmond

    well, ken, i don’t think you missed anything in this excellent and informative article.

  4. Ida Lupine Avatar
    Ida Lupine

    Yes! The thought of a cull of Tule elk, and a regular one at that, and denying them access to water, is very upsetting. And any proposed plans we’ve heard of too, expanding ranching activities, B&B’s, row crops, just not for a place such as this, where water may be at a premium. There are other places for that kind of thing already. Bad tenants!

    1. Maggie Frazier Avatar
      Maggie Frazier

      Making this a part of 30 x 30? Seems to me a good idea. Allowing the contamination of the water? How in the world can this continue to be allowed? That, on top of slaughtering (which is what culling is) native wildlife in order to make room for livestock? Hasnt this country done enough of that? I hope the lesson is at least beginning to sink in.

  5. Todd Steiner Avatar

    Thanks for your detailed mastery of the facts and your beautiful description of your wildlife encounters in this gem of one of our National PARK Service units! Public protests is needed now and this article is a cal to arms. #ElkNotCows

  6. Kate Ames Avatar
    Kate Ames

    Ken, Thank you for this informative and carefully laid-out history leading up to the current state and possible future of the PRNS. You brought up the “Shafter-era model” of land use and indeed that was not a time of wild-land stewardship awareness. We are now in a very different era and we know what impact humans have on our limited land and resources. We need to speak out to preserve this sacred and beautiful “Island in Time”
    Great article!

  7. Rich Avatar


    Excellent article! Have you shared it with news outlets in San Francisco, LA, Sacramento or other environmental reporting organizations like ENN? It is critical that Californians in particular are aware of the threat to the PRNS and the native wildlife that depend on it. Killing native elk to expand the footprint of a handful of farmers who have taken buyouts but refuse to leave is outrageous. The real owners of these public lands need to be inspired to speak out.

    1. Kenneth Bouley Avatar
      Kenneth Bouley

      Thank you, Rich. We are trying to spread the word as much as possible. I was not familiar with ENN but see them online. If you have any contacts or specific recommendations, please let me know and we’ll arrange on offline exchange.

  8. Frances P Wilkerson Avatar
    Frances P Wilkerson

    Interesting article
    Could you share with me where these March 2021 water quality data for Drakes Estero were published

  9. cynthia brown Avatar


  10. Alec Bennett Avatar
    Alec Bennett

    A good read and thanks for collecting a few of the relevant articles available at the time. But you brush over one of the most critical issues, which is whether the elk have access to water. You wrote: “[The Park Service is] defensive, such as where the Park points out that the elk in 2013-15 die-off did not succumb from thirst, but rather from drought-induced malnutrition, and adding the biologically implausible statement, “if there was no water available to the elk at this time, all of the elk would have perished.” (I’m not a biologist, but this is wrong: lack of water will take the most vulnerable to dehydration first, not 500+ animals simultaneously, and it is known that there are sub-herds north of the fence, with territorial behavior, such that water might have been available to only a subset of the animals based on distribution.)”

    Interestingly the Park Service released a press release 13 days after you published this (March 31, 2021) where they released the results of actual autopsies of deceased elk:


    They say “Although the NPS and CDFW believe the elk population declines are drought-related, there is no evidence that the population decline is due to dehydration and a lack of water. Park staff mapped water sources and monitored water conditions at Tomales Point on a regular basis from July to November, confirming adequate water supplies are available for the elk in the many creeks, seeps, and springs distributed throughout the reserve. Conversely, the nutritional quality of forage is exacerbated by ongoing drought conditions.”

    Death By Design, published June 2021 quotes amother study by the NPS: “The Park Service released necropsies of eight confined Tomales Point tule elk who died in confinement during the fall of 2020. In total, 152 elk expired inside the enclosure. It is reasonable to extrapolate the probable causes of the deaths of the necropsied elk to the larger population, as the Park Service does. All of the necropsied elk were severely emaciated. They had either died of starvation, or by plant poisoning brought about by starvation.”

    That’s a lot more scientific than your rebuttal of the absolutely key issue of whether the elk are dying of thirst.

    I live in the area too and would be glad to lead you to plenty of accessible fresh water on Tomales Point. And of course if I can find the water so can the elk.


Ken Bouley is a software developer at the data analytics company FICO, where he has worked for the last 24 years. He and his wife Kelli live in Inverness, immediately adjacent to the Point Reyes National Seashore, hiking there frequently and indulging Ken’s wildlife photography hobby. Bobcats are his favorite.

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Ken Bouley