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