Marin County Farm Bureau has submitted the following comments on the agriculture and biological resources sections of the Local Coastal Plan update.  The October 2nd hearing is the the only  hearing planned by our Supervisors on these issues.  We still have many outstanding concerns that our letters address.  

To see the staff report please click on the following link…..

Staff Report

Links to MCFB’s comments and recommendations…….

Letters to the Board of Supervisors

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LCP Issues

The Marin County Farm Bureau submitted its comments and concerns on the Local Coastal Program Amendments (LCPA) Planning Commission-Recommended Draft documents.

 The following documents contain Farm Bureau’s discussions and recommendations:

  Land Use Plan Amendments (LUPA) Issues – Attachment #1

  Development Code Tables 5-1, Recommendations – Attachment #2

  Development Code Definitions, Recommendations – Attachment #3

The basis for our concerns relate generally to three categories:

1)      Economic Viability of Marin’s agriculture:  The LCP must find a balance between natural resource protection and agricultural sustainability by including policies and ordinances that will protect and honor the importance of Marin County agriculture for future generations, and which will reasonably limit regulatory burdens that threaten their economic viability.

2)      Protect Property Rights:  LCP policies must respect private property rights, allow landowners to protect against illegal confiscation of their rights, prevent trespass and destruction of private property, require judicially mandated nexus and proportionality tests, and support the U.S. Constitution’s Fifth Amendment:  “…nor shall private property be taken for public use, without just compensation.”

3)      Fair, Accurate, Accountable and Transparent Government:  The LCP must serve as a trustworthy guidepost that accurately and fairly reflects the laws of our land.  LCP policies and ordinances must represent accountable and transparent governance by containing objective, concise, and clear language to eliminate ambiguity and preferential biases, so that all stakeholders are treated with fairness and respect.

 These three documents can be found at 3/25/2012 at the County Local Coastal Program update website.

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Marin County Farm Bureau Honors George Grossi and Hal Brown

Friday night, February 24th at the Margaret Todd Center in Novato, Marin County Farm Bureau held its annual dinner where Farm Bureau members along with public officials get a chance to get together and enjoy a fabulous dinner and drinks and honor those that have played an intricate role in agriculture.


This year, George Grossi was honored with the Lifetime Achievement Award.  Although he is only in his 60’s and has many more years of agriculture achievements, it was fantastic to have the entire family there to see him receive his award for his accomplishments thus far.

Marin County Supervisor Steve Kinsey, congratulates George for his accomplishments.

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MCFB Comments on LCP Natural Systems

Marin County Farm Bureau submitted these comments on the “Natural Systems” section of the Local Coastal Plan on  November 25, 2011:

November 25, 2011

 Marin County Planning Commission

c/o Kristin Drumm via email:


Re:      Local Coastal Program Update: Natural Systems


Dear Planning Commissioners:

 The Board of Directors of the Marin County Farm Bureau appreciates this opportunity to comment on the Natural Systems section of the Local Coastal Program (LCP).   We believe strongly that the LCP needs to balance environmental protection and agricultural viability. Farmers and ranchers have protected the land with all of its various species and habitat, preserved open space and provided food for Bay Area residents and beyond. Because agriculture is such an important part of Marin’s economy, we feel that it needs strong protection in the updated LCP. 

Policy, C-AG-1 discusses the importance of preserving important soil and water resources for agriculture, which we appreciate.  Unfortunately this policy seems to conflict with policies in the Natural Resources section of the LCP.  The fundamental problem is the fact that the most productive soils, capable of sustaining our richest grasslands and row crops are the bottom lands adjacent to creeks and laced with wetlands and ESHAs of every description. County government and the Coastal Commission cannot have it both ways.  We cannot allow the elimination of our most productive land in favor of creating arbitrary buffer zones. Even if a simple grandfather status is granted to these valuable lands it then becomes a matter of use it or lose it. If an active farmer dies or a property changes hands and the farm goes fallow, must this land go out of production forever only because a new owner applied for permits and triggered the imposition of ESHA buffers?


C-BIO-14 Wetlands

            3. Prohibit grazing or other agricultural uses in wetlands except in those reclaimed areas used for such activities within five years before the date that a Coastal Permit application is accepted for filing.

This program only allows agriculture production in areas that were used for agriculture in the past five years.  We are concerned that there may be ranches that have sat fallow for longer than that but are very productive soils just waiting for the right rancher to use that land.  We need to look at the long history and evolution of agriculture in Marin in order to protect it for the future; a five year history is not nearly long enough.

 It is also important to recognize that ESHA designations will not just affect the prime soils near creek bottoms.  There does not seem to be any real method for determining where an ESHA should be, therefore all agricultural land becomes susceptible to this arbitrary designation.  The potential to eliminate agriculture from the Coastal Zone becomes a real concern to the agricultural community.  The fear that a permit would trigger these designations on a ranch may prevent any rancher from ever building or adding on to their homes to allow for additional family members to participate in the agricultural business.  In addition, just changing the intensity of use on a ranch would trigger these designations because a change in use signifies development, (more on this below).

The Planning and Coastal Commissions could truly demonstrate their commitment to the future of Marin agriculture in the LCP by exempting existing agricultural lands from condemnation for the creation of ESHA buffers. The LCP language must not assert a primacy of ESHA designation over established agricultural land.

It is also important to recognize that ESHA designations will not just affect the prime soils.

C-BIO-19 Wetland Buffers

This policy calls for a minimum buffer of 100 feet.  Environmental enhancements on our farms and ranches must not become a matter of rigid policy that imposes arbitrary setbacks and ESHAs on farmland. We urge the Commission to avoid restrictive LCP policies and instead, appreciate the ongoing environmental improvements that are made on Marin ranches without such policies.

The Marin RCD (Resource Conservation District) has a long history of implementing environmental enhancements on our farms to protect environmentally sensitive areas. The RCD has a solid reputation amongst ranchers and environment groups. The implementation of ESHA buffers as determined by permitting authorities on ranch land can be hugely cost prohibitive. The fear of a permit application triggering such a time consuming and expensive process of ESHA establishment may well convince farmers and ranchers not to make important improvements in infrastructure to their operations. The cost of fencing miles of streams and ESHA could well break many small operators financially. The RCD brings years of experience in partnering with farmers on habitat improvements, providing engineering expertise and assisting with funding. By leaving the business of habitat enhancement to the RCD and other appropriate agencies such the USDA Equip Program, the Commission would truly be helping ranchers avoid another layer of regulatory burdens.  Rigid buffers are also referenced in C-BIO-24 Coastal Streams and Riparian Vegetation and we ask that these be removed as well.


Program C-BIO-5.a Determine Locations of Environmentally Sensitive Habitat Areas.

This program mentions “a level of review,” we would like clarification as to who would be doing that review, will this be county staff or will the county be hiring biological experts?

We wish to point out again an issue about the definition of agriculture and development in the Proposed Development Code Amendments. A change in Agricultural Usage Is NOT Development, It is Essential for our survival and is clearly recognized by our history of agriculture in Marin.  A view of Marin’s agricultural lands over the last 170 years would reveal constantly changing patterns of crops, animals and production of all kinds. In the decades since the Gold Rush, vineyards, grain fields, row crops, hog pens, and orchards, have often been interspersed with the great cattle pastures of Marin. There was no permit for changing agricultural usage in the 1940s when pasture land in Bolinas and out on Pt. Reyes were instantly converted to pea production for the war effort. The LCP must not freeze Marin agriculture in time.

The ability to shift production within an agricultural operation, adapting to changing market and climate conditions, is key to the survival of our farms. Once we open the door to policy makers, and thus, environment advocates, to review and regulate the business of farming, then only those who can afford the expense and lost time of such processes will be able to farm in Marin. Is it fair to tie the hands of our coastal producers, locking them into losing production systems while farmers and ranchers elsewhere can constantly change (USE) production regimes, experiment and adapt their production to shifting market trends?                                                                    


In a bad grass year, a few acres of vineyard could produce an exceptional harvest that helps offset the difference in lost income. In a drought, a row crop farmer should have the option to graze his or her land when there is not enough water to irrigate. The year- to-year survival of farming operations depends on the ability to shift agricultural regimes instantly. It must not become a cumbersome process at the mercy of policy makers and environment groups who have scant knowledge of farming. How the land is used is, and must remain, the business of the farmer. 

In all the excitement about sustainable agriculture one fundamental practice stands in the face of “change of use” rules. More and more research shows that diversity within a farming operation is essential to maintaining a healthy farm with a diverse nutrient pattern resulting from the rotation of animal and crop regimes. Several farms in Marin have adopted this style of management. Will an updated LCP require us to obtain a permit each time the rotation occurs?  





Dominic Grossi

President, Marin County Farm Bureau



Marin County Board of Supervisors

Stacy Carlsen, Marin Agriculture Commissioner

Jack Rice, California Farm Bureau Federation

Chris Scheuring, California Farm Bureau Federation

Paul Beard, Pacific Legal Foundation

David Lewis, UCCE

Bob Berner, MALT

Ruby Pap and Rick Hyman,

California Coastal Commission

45 Fremont Street, Suite 2000
San Francisco, CA 94105-2219

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Drakes Bay Oyster Company EIS Comments

Marin County Farm Bureau submitted the following letter on the  Environmental Impact Statement {EIS} for the  Drakes Bay Oyster Company Special Use Permit:

Re:      EIS on Drakes Bay Oyster Company Special Use Permit


Dear Superintendant Muldoon

The Marin County Farm Bureau appreciates this opportunity to comment on the Draft Environmental Impact Statement (DEIS) regarding the issuance of a special use permit for DBOC (Drakes Bay Oyster Company) in the Point Reyes National Seashore. Marin County Farm Bureau works for the solution of the problems of the farm, the farm home and the rural community, by use of the recognized advantages of organized action, to the end that those engaged in the various branches of agriculture may have opportunity for happiness and prosperity in their chosen work.  We represent, protect and advance the social, economic and educational interests of the farmers of Marin.

Farm Bureau strongly supports the issuance of a renewable SUP, an alternative that was not even offered in the DEIS.  We believe strongly that agriculture is an important part of Marin’s economy, and that DBOC is a significant and important part of Marin’s economy and its success.  The DEIS mentions that removing the oyster farm would cause “major, long-term, adverse effects to the California shellfish market” but does not provide a complete analysis of these impacts, nor does it include these impacts in the overall analysis. The EIS must assess and address the economic impacts of eliminating the production of 50% of California’s oysters and the subsequent impact on the local, state and national economy. Further, the DEIS does not analyze the impacts of eliminating one of the largest employers in West Marin. The DEIS also fails to recognize other businesses that would shut down in the area.  The oyster shell byproduct from the Lunny cannery is a critical and sole resource for reestablishing oyster beds and Snowy Plover habitat  in San Francisco Bay. The loss of the Lunny resource would shut down these restoration operations as well.  In addition, The discussion of the socioeconomic impact of the alternatives is seriously flawed.  Different geographic parameters are used throughout that chapter seemingly at random, switching from Inverness proper, to greater West Marin, to Marin, to multi-county, to statewide, to nationwide.  This switching of parameters is used to argue that the job losses caused by shutting down the oyster farm would be minimal.  This is extremely misleading and shows a bias towards eliminating the oyster company.

Additionally, there is no socioeconomic discussion in the DEIS on how the closing of DBOC will affect the surrounding agricultural operations in PRNS and Marin County as a whole.  There is great concern throughout our community that once one business is eliminated from the Park a domino effect will follow.  Support for agriculture on PRNS lands is described in the Marin County Local Coastal Program Unit II (County of Marin 1980), illuminating its value to the local economy with this statement: “The economic activity associated with agriculture in the federal parks forms a significant part of Marin County’s total agricultural industry.”  The Parks ranchers’ economic contribution to Marin’s direct gross agricultural income is significant, at roughly 17 percent.  Marin has 165,064 agricultural acres and 17% is in the Parks.  This number represents the approximately 137,000 acres of privately owned agricultural land in Marin County plus the 28,064 acres of land in ranching at PRNS and GGNRA. The 137,000 acres includes all agriculturally zoned land, some of which is not in active production. Therefore, PRNS and GGNRA agricultural land actually accounts for more than 17% of land in production.  If this one business is eliminated and a domino effect occurs in the Park, it will certainly affect all of Marin.  The agricultural infrastructure for supplies and maintenance on all these farms will collapse if ranchers continue to disappear.  The businesses that do this work will have fewer farms to work on and supply goods to; as this happens those businesses will be forced out of business.  We are already seeing this as many dairy supply companies have already merged or gone out of business over the past several decades.

The DEIS also fails to address the socioeconomic impacts on the oyster farm’s approximately 50,000 visitors annually who enjoy the oysters and the interpretive services provided by Drakes Bay Oyster Company. Visitors to the oyster farm represent a wide range of incomes, races and ethnicities, some of whom might not otherwise have any connection to the National Park System. The National Park Service itself actively searches for ways to increase access to the National Park System for underserved communities. If DBOC’s Special Use Permit is denied, these underserved communities would be impacted. The DEIS must address the subsequent impacts to these visitors and how these impacts will be mitigated.

While the NEPA process mandates the consideration of a “no-action alternative,” there are no alternatives here that qualify as “no-action.”  Alternative A forces DBOC out of business next year, and the other alternatives shut down DBOC in ten years.  An alternative must be presented that allows for the oyster company to continue.  This alternative must then be completely analyzed in the DEIS to determine all impacts of keeping the oyster farm in production.  None of this has happened in the DEIS.  We believe this alternative was left out of the DEIS because of the false belief that Drakes Bay must convert to Wilderness.  You must remember that nowhere in the Wilderness Act of 1976 does it say this land must convert to Wilderness.  It is only “proposed” for wilderness which means it does not have to convert to Wilderness.  The authors of the Wilderness Act have even come out publicly and said the intent was never to force out DBOC and convert this area to Wilderness.

Respectfully submitted,

Dominic Grossi

President Marin County Farm Bureau

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