The recent controversy over commercial uses on parkland at Point Reyes National Seashore (PRNS) has inspired this case study, which seeks to explore the integration of park residents into decision-making processes of the United States National Parks system. Specifically, this research evaluates the tensions between the various users at PRNS and explores the potential impact of a citizen’s advisory commission at PRNS in terms of increasing interactions between the National Park Service (NPS), park residents, and the public. To carry out these objectives, this case study compares recent interactions at Point Reyes with those that took place during previous decades when an active citizens advisory commission was in place. This case study finds that the advisory commission at Point Reyes played a vital role as an intermediary, which facilitated productive interactions between the key local community, residents, and NPS.

INTRODUCTION

In accordance with federal law requiring public participation, the United States National Park Service (NPS), as well as other land management agencies, has identified a need for greater inclusion of the public in their decision-making processes and has made steps to address this issue [1, 2]. Scholars and agencies alike recognize that public and community inclusion will produce more effective plans and planning documents that reflect the visions of the people for whom the parks were created. There has also been a recent spotlight on the importance of working landscapes in protected areas, celebrating the cultural and natural history that agricultural communities share with parks and other public lands [36]. However, there is a glaring lack of literature and discussion on the inclusion of residents, the long-term lease-holders who are argued the most connected to the space, in planning decisions for U.S. parks.

This case study addresses the question of how working landscapes are incorporated into parkland and whether the people working in the land should have a more substantive voice in park decisions. It aims to shift attention from the inclusion of the public at large in public land management decisions—still an important issue in and of itself—to one far less looked at, the inclusion of residents, the lease holders within NPS units who depend on parklands for their livelihoods, in the decision-making process. When management conflicts arise in the park, a typical member of the visiting public may not agree with a given decision, but a resident has to live with that decision. NPS decisions, such as management plans, can directly affect a resident’s way of life and ultimately impact their ability to sustain a business and maintain a home that has potentially been in their family for generations. Except as members of the public at large, they are not legally given authority or even special input in the decisions made.1 This imbalance, or lack, of power can lead to tensions between lease-holders and those who possess the power.

One potential avenue for increasing the voice of resident leaseholders, as well as neighboring communities, is through the use of a citizens advisory committee (CAC). CACs, as a form of public participation, are hypothesized to be a more collaborative mechanism of stakeholder and public engagement for U.S. national parks than standard modes of participation, such as hearings and written comment letters [8]. They are usually composed of a small group of citizens chosen by sponsors, often local elected representatives or other prominent members of the community or state, to represent the interests of the public and stakeholders. They are convened in an advisory role (providing only recommendations and not final decisions) and meet typically four to six times a year to discuss a particular set of issues, policies, or plans [9, 10]. During meetings, members of the public, commission members, and relevant governmental personnel and decision-makers can interact and discuss issues. This case study specifically examines how 30 years of a CAC working with the Point Reyes National Seashore (PRNS), while it did not generally challenge NPS decision-making, provided a critical forum for public discussion of day-to-day management issues. By making the issues faced by park residents more visible and widely understood, the CAC mediated the relationship between leases and their landlord, the federal government—and after the CAC was dissolved in 2002, this absence of a regular public forum may have contributed to escalating tensions between the NPS and its neighboring communities [11].

METHODS

To address the aforementioned questions, a qualitative case study was conducted and the study was triangulated using archival methods, analyzing, and coding CAC meeting minutes, as well as reviewing policy, reports, media, attending community meetings, and conducting interviews. The CAC at PRNS was set in place by the legislation creating the Golden Gate National Recreation Area (GGNRA) in 1972, and jointly served the two park units (PRNS and GGNRA) until it “sunsetted” in 2002 without Congressional reauthorization [12].2 The archival documents reviewed were found at PRNS Archives and the Park Archives and Records Center at the GGNRA. Three-time periods were selected since the Seashore’s creation to analyze resident involvement in planning and decision-making both with, and without, a citizen advisory committee. The three 5-year time periods reviewed were selected to reflect the beginning of the CAC (1975–1979), the latter part of the CAC (1995–1999) (both time-periods in which PRNS was developing planning documents), and the most recent years without a CAC when tensions have escalated over a number of land management decisions.

CASE EXAMINATION

A Brief History of PRNS

PRNS is a mere 40 miles north of San Francisco and a popular destination for visitors near and far. While many visit Point Reyes to get away from the hustle and bustle of the nearby city life and commune with the natural landscapes, some folks get to call the Seashore home. PRNS is a working landscape, which contains dairies and ranches that have been in place for generations [7]. While active working landscapes are unusual in the United States national park system, PRNS is not unique: there are at least 35 NPS units, approximately 9% of the system, that allow for grazing by leaseholders within their boundaries [13]. While not all of those units have leaseholders living within their boundaries, there are other units which are home to residents (leaseholders and private ownership) and productive landscapes, such as Cuyahoga Valley National Park, Ebey’s Landing National Historic Reserve, and John Day Fossil Beds National Monument [5]. The inclusion of working landscapes and long-term residents in protected areas is furthermore much more common outside the United States [14]. The NPS does not have an overarching cohesive policy on grazing and agriculture leaseholders, simply a general view as they should be limited, which has resulted in variation in the policy and management of lease holders in each park unit [13].

Long before Point Reyes became a National Seashore, it was a significant seasonal resource to the Coast Miwok, native Americans indigenous to this region of California. After hunting, gathering, and fishing on the Point Reyes peninsula for centuries, the Coast Miwok found their lives disrupted when nearby Spanish missions and Russian settlers contributed to displacement, physical violence, and disease among their communities [15]. Soon after, Mexican rancheros took ownership of much of what is now Marin County and their free-range cattle grazed on the peninsula, destined for the hide-and-tallow industry. When California became part of the United States in 1850, ownership of the Point Reyes peninsula was contested in court, and by 1856 it wound up in the hands of the lawyers, who divided the landscape into 32 tenant-run dairies and cattle ranches to keep up with the demand from the rapidly growing urban centers of the San Francisco Bay, as can be seen in the map depicted in Figure 1 above [13, 16]. In the early twentieth century, agricultural use of the peninsula diversified to include pea and artichoke farming, and World War II even brought mining and military installations to what would later be relabeled as pristine wilderness.

FIGURE 1.

Map of historical ranches at PRNS. Livingston, Dewey. 1990. Historical Alphabet Designations of Point Reyes National Seashore. U.S. National Park Service. Retrieved October, 2019, from: https://www.nps.gov/pore/learn/historyculture/upload/map_ranches.pdf

FIGURE 1.

Map of historical ranches at PRNS. Livingston, Dewey. 1990. Historical Alphabet Designations of Point Reyes National Seashore. U.S. National Park Service. Retrieved October, 2019, from: https://www.nps.gov/pore/learn/historyculture/upload/map_ranches.pdf

After studying the area in the 1930s as a potential location for a public recreational area, in 1962 the NPS was authorized to purchase private land to establish the PRNS as a 53,000-acre recreational area, surrounding a 21,000-acre pastoral zone intended to remain in private ownership [17]. However, rapidly rising land values, and particularly the associated rising property taxes, made this “hole in the doughnut” model of maintaining private ownership within the Seashore unsustainable; in addition, the initial appropriation of US$14 million from Congress proved to be inadequate to purchase even just the public use zone. A citizen campaign for additional funds, christened “Save Our Seashore,” convinced Congress to amend the original legislation in 1970 to authorize the purchase of not only the public use zone but also the entire pastoral zone as well, to be leased back to the cattle ranchers who wished to remain [7, 18]. While allowing for the continued operation of the ranches and dairies, with the tenant families and many of their employees living as well as working on the ranches, this created a new role for NPS officials at PRNS—having to interact with ranchers no longer just as neighbors, but as landlords.

Despite authorizing the acquisition of the pastoral zone, Congress’ explicit intention in 1970 was that ranching activity remains part of the Seashore. This intention was made clear by Senator Alan Bible, then-Chairman of the Senate Subcommittee on Parks and Recreation, who stated that, despite their amendment to the 1962 Act, “the federal government in effect made a promise to the ranchers in the pastoral zone that as long as they wanted to stay there, to make that use of it, they could do it. We must keep our word to these people.” In case his meaning was not clear, Bible continued, “it is the firm intent of the committee [on Interior and Insular Affairs] that the amendment shall in no way operate to impair the integrity of the dairyman who wants to continue dairy farming.”3 While some ranches closed voluntarily, other ranching families decided to stay. Each retained a reservation of use and occupancy (RUO), allowing them to remain on the property for a set number of years, as if they still owned it privately. The reservations were “paid for” by reducing the government’s purchase price by 1% per year of the reservation. Most of the ranches received identical 20-year reservations, although one opted for a longer term of 30 years, and Johnson’s Oyster Company, an oyster operation in Drakes Estero dating back to the 1930s, took a 40-year reservation.4 In 1978, Congress passed additional legislation creating a leasing mechanism for the working ranches to continue operating past the original terms of their reservations of use [19]. Point Reyes’ first General Management Plan, written in 1980 in conjunction with the nearby GGNRA, specifically supported continued ranching uses in the pastoral zone.5

Despite Point Reyes’ extensive history as a working landscape, in 1976 Congress designated 25,370 acres, mostly in the southern half of the peninsula, like the Phillip Burton Wilderness Area at PRNS [20]. Today, PRNS is a 71,028-acre protected area, see map in Figure 2 above, containing both designated wilderness and 11 working ranches, with a mix of dairy and beef production. While these historic ranching uses have managed to remain economically viable, they are not without restrictions, in terms of what they can do on the property and in terms of the leases; everything from the size of their herds to the color they can paint their houses requires approval from the NPS. Additionally, the certainty of their lease renewal is controlled unilaterally by the federal government. As noted by Deur and Mark [13], PRNS remains an experiment of sorts in balancing public and private uses to appease multiple stakeholders.

FIGURE 2.

Current map of PRNS. U.S. National Park Service, restoration/cleanup by Matt Holly. 2016. Retrieved October, 2019, from: http://npmaps.com/wp-content/uploads/point-reyes-map.jpg.

FIGURE 2.

Current map of PRNS. U.S. National Park Service, restoration/cleanup by Matt Holly. 2016. Retrieved October, 2019, from: http://npmaps.com/wp-content/uploads/point-reyes-map.jpg.

A CAC at PRNS

Although CACs are not common within the NPS, they have been used as a form of active community involvement since 1961, with the establishment of the Cape Cod National Seashore Advisory Commission, intended to help guide the establishment and management of the newly authorized Seashore—an innovation widely hailed as a key element of Cape Cod’s success [21]. To create a formalized process for establishing, operating, overseeing, and terminating the advisory bodies, Congress passed the Federal Advisory Committee Act in 1972. Over time, CACs have become pervasive throughout federal agencies, although the NPS currently only administers approximately 30 commissions in a system of over 400 park units. While CACs have been criticized for being time and energy intensive, and cumbersome to agency personnel, they have been found to facilitate greater stakeholder involvement in decisions [22, 23].

As mentioned above, the CAC at Point Reyes was established following the creation of the GGNRA in 1972, and for 30 years it acted as a vital mechanism for relaying resident and public opinion during the creation of PRNS General Management Plan and other important decisions for the two park units. The commission was dominated by appointees from San Francisco with fairly prominent social standing and/or jobs within the city—such as former athletes, mayors, lawyers, planners, and educators—and its meetings’ location alternated between San Francisco and West Marin, yet these regularly scheduled meetings provided a dependable forum for increased interaction with the public and organizations across the area. Members of the NPS were always present at the meetings, ranging from park planners to superintendents, and sometimes upwards of five park personnel.

While the commissioners’ role was solely advisory to the NPS, commissioners made joint recommendations and took votes on plans and issues for both parks, which appeared in almost all cases to be the adopted resolution of the park. Additionally, when drafting plans, such as the General Management Plan, opportunities for public comment were often held during the commission meetings. When deciding on larger issues at the parks, the commission frequently formed subcommittees look further into an issue—sometimes soliciting input from members of the public with specific expertise or knowledge in that area, particularly during the 1970s—before making recommendations.

PRNS leaseholders generally did not speak at the CAC meetings themselves—they tended to prefer to work one-on-one with NPS officials on the specific issues about their leases—yet the meetings provided an avenue for other locals in the community to advocate in favor of leaseholders’ interests. Attendees often took the opportunity to articulate the importance of working landscapes to their sense of place and community, to ask questions of NPS officials to clarify their intentions and decision-making processes, and to get their responses on the public record. The CAC meetings were not only beneficial for those in attendance but also provided an update on the inner workings of NPS planning and management to the entire area—or at least those that read the local paper, the Point Reyes Light. Its regular coverage of the meetings allowed those who could not attend the meetings to follow the issues and potentially encouraged future participation.

The topics of grazing, ranchers, wildlife, and land management were staples at the CAC meetings that took place at Point Reyes. For example, the question of what exactly constituted “wilderness” was discussed in the mid-1970s meetings, when Representative John Burton, working to draft legislation to formally designate wilderness at the Seashore, sought input from both the Commissioners and the public. In addition, the CAC formed a subcommittee to better study the issues, which met on its own three times between July and August 1975 and invited several speakers both for an against the proposal to offer their perspectives.6 The commission made recommendations in favor of Burton’s legislative language with an emphasis on allowing some flexibility within the area designated, such as the continued “unrestrained” existence of prior non-conforming uses, and allowing fencing for a group of native Tule elk to be reintroduced into part of the wilderness area without affecting nearby ranches.

While there were occasional disagreements at the meetings concerning ranchers’ lease lengths or interactions with wildlife, the discussions that ensued usually led to general agreement that supporting the ranches remained a priority. It was also noted, when drafting the General Management Plan, that it was not a “master plan,” so that new issues and demands could be addressed by the CAC as they arose. While some commissioners and public members’ stance on the use of commercial activities within parkland and certain other issues, such as the free range of Tule elk, shifted between the 1970s and 1990s, the overall sentiment towards the ranching/grazing/agricultural usage was positive. The commission and public tended to be in favor of their continued existence, acknowledging the state-wide significance of the ranches at PRNS.

Rising Contention

The GGNRA’s establishing legislation only required that the CAC be in place for 30 years, and after that authorization expired in 2002, Congress did not renew it, effectively disbanding the Commission. Since that time, several key stakeholders at Point Reyes have come into conflict, each pressuring the NPS to fulfill their vision of the park. Contention has erupted around the issues of who has the rights to use parkland, who should be involved in the decision process, and what uses are deemed acceptable. The most notable of these, receiving national-level media attention, involved the removal of the Drakes Bay Oyster Company from the park, the last incarnation of mariculture operations that had been in place since the 1930s [24]. As mentioned above, oyster farming was a well-established use within Drakes Estero, an estuary at the very center of the Seashore, long before the designation of PRNS and adjacent wilderness lands. However, Drakes Estero was included in the 1976 wilderness bill as “potential” wilderness—a new category created to indicate lands that almost meet the criteria for federal wilderness, but fall slightly short of the mark. Having been considered a non-conforming prior use, the oyster company was not affected by the potential wilderness designation and continued its production under a 40-year RUO, which would expire in November 2012. As was the case for the remaining ranches at the Seashore, the 1978 legislation allowed the PRNS Superintended to shift the oyster operation over to a special use permit once the reservation expired.

As the expiration of agreement approached controversy was incited among people, particularly environmentalists, throughout the community, region, and state over the proper use of parkland [25]—yet without a CAC in place, no forum existed for those in the community to ask questions or debate the issues. Several environmental groups, led primarily by the National Parks and Conservation Association and the locally based Environmental Action Committee of West Marin, joined forces to lobby against the oyster farm, citing NPS claims of environmental harm as one of the main reasons for not allowing the oyster company opportunity to receive a permit, as well as wilderness law, arguing that areas designated as “potential” wilderness ought to be converted to “full” wilderness at the first opportunity.7 While an Environmental Impact Statement (EIS) was drafted, disagreements over the data collection and analysis surfaced, and a final EIS was never completed. The decision of whether to issue the new permit landed in the hands of the Secretary of the Department of the Interior Ken Salazar, who ultimately “decided that a commercial enterprise was incompatible with wilderness and with the concept of a national park” [26].

Perhaps surprisingly, increasing hostility has developed since the oyster farms’ closure over the protection and continuation of ranching at PRNS. In January 2016 a trio of environmental groups—the Resource Renewal Institute, the Center for Biological Diversity, and Western Watersheds Project—filed a lawsuit against the NPS, which demanded that the environmental impacts of grazing across this long-time dairy and beef ranching landscape be studied before renewing any existing grazing permits. Local and national newspapers were suddenly full of the groups’ accusations of “‘welfare ranchers’ who take advantage of subsidized grazing rates they pay on park grounds,” and assertions that ranching is incompatible with the area’s wildlife [27]. In July 2017 this suit was settled, requiring a new public planning process to be commenced, with court-mandated plan alternatives to be considered, including reduction or complete elimination of ranching from the Seashore [28]. Despite the settlement, the original litigants have continued to use the press in attempts to paint historic land uses as “industrial agriculture” that is inherently damaging to public lands [29]. In contrast, in 2018 Representative Jared Huffman proposed a bill, H.R. 6687, aimed at reaffirming the original Congressional intent to retain agriculture as an active part of the Seashore [30, 31], and the NPS formally placed this historic ranching district on the National Register of Historic Places [32]. These recent events reveal a deepening polarization of the community compared to the years when the CAC existed, pitting those who support the continuation of a working landscape against those who feel that commercial activity, at least in the form of ranching, does not have a place in national parks.

The recent controversies at Point Reyes also demonstrate the ramifications that polarizing views of the proper use of parkland can have on a community, pitting, as historian William Cronon calls it, the “urban recreationalists against rural people that earn their living from the land” [33], p. 83. These increasing tensions have left local community members, both the resident leaseholders and neighboring communities, arguing for a change to the Park Service’s engagement with the residents of the Seashore [34]. Yet the decision processes, and those in charge of decisions, at PRNS—as well as at other NPS units—are not always visible. The NPS is bound by Congressional law and administrative rules to receive public input on decisions, but whether that input affects decision-making is up to the federal officials themselves. Additionally, public input provided on planning processes is supposed to be weighted equally—regardless of whether the person lives near or far from the park, or whether it is a private individual or a non-profit organization making the comment—but the NPS is not required to directly respond to or follow any input provided. This case study ultimately demonstrates a recent example of local communities, those living in and near the park unit, having a lack of transparency and adequate participation in the often behind-the-scenes decision-making process of the NPS.

Soothing Tensions: A Potential Solution for Substantive Interaction

While differing views on how to manage PRNS existed in the 1970s–1990s, these views were often aired and discussed at CAC meetings, creating an outlet for considering alternative perspectives. These meetings also brought a level of transparency in NPS decision-making that has not been seen in recent years. Members of the NPS listened to, and worked with, the commissioners and members of the public to develop joint plans and decisions. There was also an underlying sentiment that ranches were a key component to the park. While there is not a definitive way of measuring whether having the regular CAC meetings as a public forum would change the outcomes of the recent disputes, its disappearance is at least coincident with an abrupt rise in contentiousness. Additionally, having a CAC in place may have at least reduced or mitigated some of the hostility within the local community; instead, the oyster debate in particular split West Marin so badly that years later, some neighbors are still simmering over it.

The NPS cannot legally give decision-making authority to the residents of a park unit, but it can provide a venue for open communication between the stakeholders and the NPS, while also allowing for greater input to be provided by the residents and local community. When the CAC was in place, it acted as a public forum for discussion of the Seashore’s management. While the CAC was strictly advisory, its recommendations were almost always adopted. The commission’s regular public meetings allowed for greater participation of members of the community in discussions of management decisions, and the presence of key NPS staff at the meetings facilitated further interactions between the residents, the local community, and the NPS. Based on interviews conducted with PRNS staff and residents, in recent years without the commission, there has been a shift from larger meetings to more one-on-one meetings with individual interest groups and residents [11]. While this style of interaction allows for voices to be heard by the NPS, it does not allow for cross-communication and discussion between the stakeholders in the area—the residents, local community members, and interest groups. Additionally, this lack of transparency and inconsistency in communications and decisions by the NPS can further divide members of these groups.

The former CAC at PRNS played an important role as an intermediary between the residents, local communities, and NPS. The CAC considered the local public’s comments when making recommendations that influenced park decisions. Although rising tensions in recent years cannot be attributed to the discontinuation of the CAC, the creation of CAC or similar entity that allows for increased public and resident input and acts as an intermediary between the public, resident community, and NPS could provide a means with which to give greater voice to residents of the seashore, as it did when it was previously in place. Additionally, a consistent public forum could assist in simmering tensions as it would allow from cross-communication and openness of discussion between various stakeholders and the NPS. The NPS has a policy on the need to be more inclusive of the communities they work within decision processes, however, this has not been implemented at PRNS. It appears that since the discontinuation of the CAC, the NPS and resident/community interactions have been based on only those that are legally required when making specific planning documents and decisions. There is a lack of general meetings and interactions for the sake of building relationships and trust, which the residents feel is needed for them to feel more a part of their community and foster cooperation and mutual support with the NPS. While a CAC is not a decision-making body, it could provide a forum for communication and at least a sense of legitimacy to the residents and local community members that their views are being considered.

CONCLUSION

While this case study only provided insight into one park, it allows for conclusions to be drawn and recommendations to be made to better address the current controversies at Point Reyes as well as protected areas more broadly. This case has begun to bridge discussions around acceptable park uses with methods of inclusion in park decisions. A persistent issue of lack of authority and inclusion of the public in public land management decisions exists throughout the United States and other countries [14]. While actions have been taken to rectify this problem, one key user group appears to have been overlooked. Residents, tenants of the park focused on agriculture and other alternative uses, have been found at PRNS to not be given legal authority in decisions that affect their long-term leased land and livelihoods. While the residents are given the same rights as the general public in providing comments on planning documents, and taking part in meetings required for the planning process, their recommendations do not have to be taken into consideration when developing documents that will impact their future ability to sustain their livelihoods. This lack of inclusion in decision-making processes can lead to a lack of communication, trust, and sense of validation of their role in the park, as demonstrated by the case of PRNS. The lack of inclusion of the residents of PRNS in decision-making processes underscores issues of power, access, marginalization, and historical and cultural recognition.

While policy remains unchanged, there are methods for increasing the inclusion of residents into decision-making processes. This case study found that CACs can increase the types and number of interactions between the key decision-makers and the residents. A CAC can provide a forum for discussion and interaction as well as providing needed expertise to the decision process. They take on the position of an intermediary that is trusted by the local community, residents, and NPS and facilitate frequent productive interactions. While this study only provided insight into one park, it provides a foundation for future work in understanding the role of advisory committees, and other intermediary bodies, in national parks.

CASE STUDY QUESTIONS

  1. Are working landscapes and parkland compatible? Why or why not? What are some other examples of parks incorporating alternative uses within their boundaries?

  2. In what ways can a land management agency (e.g., the U.S. National Park Service) balance the interests of the broad public and diverging local interests?

  3. Should lease-holders have greater input than the general public in park decisions? Why or why not?

  4. How could one provide greater input from the lease-holders while still following NPS and federal policy?

  5. What are some potential drawbacks to utilizing an advisory commission? What are other participation options that could facilitate more substantive engagement?

  6. What considerations do you think are important when creating an advisory commission (e.g., who should serve on the committee)?

AUTHOR CONTRIBUTIONS

The content of this article was jointly contributed by the authors. The case emerges from the confluence of research conducted by both authors. Megan Foster researched advisory committees in U.S. National Parks as part of her thesis and dissertation. LW’s research focused on wilderness and working landscapes at Point Reyes National Seashore. Both authors participated sufficiently in the concept, design, analysis, writing, or revision of the manuscript.

FUNDING

Part of this research was funded by an Erna and Orville Thompson Award, University of California, Davis, 2014–2015, Megan Foster.

COMPETING INTERESTS

The authors have declared that no competing interests exist.

1.

Historically, lease-holders have often actively excluded from national park units, pushed to the margins, or at best, simply tolerated [7].

2.

There was some discussion through the 1970s of merging PRNS and GGNRA into a single management entity; this never occurred, but PRNS still has management authority over the northernmost portion of the GGNRA.

3.

U.S. Congress, Senate Congressional Record, March 17, 1970, page S3823, written statement by Senator Alan Bible, discussing the amendment to repeal Section 4 in the 1962 legislation that established the pastoral zone; emphasis is ours.

4.

Watt [7], at 128-131. The legislation creating the neighboring Golden Gate National Recreation Area in 1972 only allowed a maximum of twenty-five-year RUOs within its boundaries; some recent news articles have incorrectly claimed this limit also applied to PRNS lands. Non-land-owning tenants within both park units were sometimes allowed to remain via special use permits.

5.

National Park Service, General Management Plan, Environmental Analysis: Golden Gate National Recreation Area/Point Reyes National Seashore. Denver, CO: Denver Service Center, National Park Service, 1980. The GMP also stated, “The concept of these pastoral lands has the support of the public and many organizations and groups, and it is probable that this use will continue indefinitely,” at 11-12.

6.

“Summary of GGNRA CAC Wilderness Subcommittee Meetings,” September 7, 1975, printed on NPS letterhead; PRNS archives.

7.

This argument presumed the obstacle to declaring Drakes Estero “full” wilderness in 1976 was the presence of the oyster farm; in fact, it was an incomplete federal title, as the State of California had retained fishing and mineral rights to the Estero, and only the land in complete federal control can be designated as wilderness. See Watt [24].

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