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Water Quality

Dairy truck spreading excess liquified cow manure onto grasslands at Point Reyes National Seashore. Winter storms will wash this manure into adjacent streams, beaches, and the ocean, causing harmful fecal coliform levels.

Direct effects of grazing on riparian areas include increased sediment deposition in streams, water quality impacts such as elevated levels of fecal coliform bacteria, headcutting and localized changes in hydrology, breakdown of stream banks, disturbance and destruction of streambeds, destruction of riparian vegetation, and impairment of the ability of riparian vegetation to recover. Indirect effects include changes to nutrient

cycling and thermal effects, and increase risks for spread and establishment of invasive

species and algal blooms.























Water quality is an issue in the annual grasslands. Sediment, nutrients, pathogens and heat are potential water pollutants that may be associated with grazing in annual grassland watersheds.

In 2004, California’s State Water Resources Control Board adopted policies for regulating non-point source pollution. These policies affect landowners and agricultural producers, including range livestock operations. This new policy replaced a voluntary, education-supported program with regulatory programs, such as implementation of total maximum daily load (TMDL) requirements for non-point source discharges from

agricultural lands, including grazing land. The NPS should analyze non-point source pollution on all ranches, and impacts to surrounding park lands and waters.

The waters of Point Reyes National Seashore rank in the top 10 percent of U.S. locations most contaminated by livestock feces indicated by E. coli bacteria, according to a report released by Center for Biological Diversity.25 Point Reyes National Seashore has been one of the 10 most feces-contaminated locations monitored in California since 2012. The state’s highest reported E. coli level was on a Point Reyes cattle ranch.

The high fecal coliform measures came from wetlands and creeks draining ranches in the popular public Kehoe Beach area of Point Reyes National Seashore. Eight locations in the Olema Valley that receive runoff from cattle ranches in GGNRA also high fecal bacteria levels.









Pawley and Lay (2013) indicated severe pollution occurred at dairy locations, including North Kehoe Creek, at the J Ranch and K Ranch property line, the L Ranch Impact Yard, the A and B Ranches, and the McClure’s dairy

swale. How many times has National Park Service issued health warnings for park water bodies, or closed beaches or lagoons to public access?

The Park Service’s 2013 Coastal Watershed Assessment for Point Reyes National Seashore (Pawley and Lay 2013) documented numerous examples of cattle ranching polluting water resources in the park and identified bacterial and nutrient pollution from dairies and ranches as a principal threat to water quality. The Park Service allows dairy ranches to spread liquid cattle manure on grasslands throughout the park. The park report determined that dairies pollute the Drakes Estero, Limantour, Kehoe and Abbots Lagoon areas with high concentrations of fecal coliform. Other studies show that cattle ranches are one of the major contributors of fecal coliform and E. coli to Tomales Bay. 

Contamination of water by bacteria is one of the leading causes of impairment in U.S. surface waters. While many bacteria occur naturally in the environment and are an important component of many ecosystem processes, some are of concern because they may cause diseases. These bacteria (E.coli 0157:H7, Salmonella, etc.), as well as viruses (enteroviruses, adenoviruses, etc.) and some protozoans (Cryptosporidium, Giardia, etc.), are referred to as pathogens. Most are found in the gastrointestinal tract of humans and

other warm-blooded animals and are shed in the feces.

The presence of E. coli can be used as an indicator of the presence of fecal contamination.

Significant sources of fecal material to lakes and streams includes wastewater discharge, stormwater runoff, and manure runoff. The fecal material in these sources can come from farm animals. Many of the bacteria within feces can survive in environments outside of the animal, thereby elevating bacteria concentrations as they enter a stream.

EPA estimates that one dairy cow can produce about 120 pounds of wet manure in a day, with 80 percent being water. These values indicate that even a small quantity of fecal material escaping into surface water from livestock can cause a substantial impact. Regardless of whether the polluting animals are sick or healthy, they can transmit pathogens in their manure.













Fecal material also contains nutrients and organic matter. Nutrient addition to surface waters, particularly phosphorus and nitrogen, can increase algal growth, decrease water clarity, and increase ammonia concentrations which can be toxic to fish. The increased organic matter also serves as a food source for bacteria and other microorganisms, resulting in lower oxygen levels in the water, and often no oxygen in

deeper bottom waters.

During a heavy storm, the precipitation can wash off the land and flow to lower areas, or soak into the soil and either be taken up by rooted vegetation or continue flowing deeper (infiltrating) into the ground, eventually reaching groundwater. Eroded, degraded annual grasslands grazed by cattle may provide less ability to trap pathogens.

Manure recently applied to land prior to a heavy rainfall or to wet ground, can also be washed into nearby streams. Additionally, livestock with access to streams are not only a direct source of manure to the stream but can also erode and damage stream banks as they enter the water, which also results in increased inputs of nutrients and sediment.

When manure escapes from the application site can contaminate surface water and groundwater. Runoff from the farmstead, pastures and fields where manure has been applied can transport sediment, organic solids, nutrients and pathogens to surface waters. Vegetative buffers are not able to effective at capturing most fecal coliform bacteria.

Only removing cattle (both beef and dairy) will remove this health problem from national park watersheds. Climate change may lead to increased winter storm events of larger severity, which could cause more manure runoff into streams along the Pacific Coast.

Prohibiting livestock from accessing streams and other surface waters is another effective way to reduce water pollution and also maintain stream habitat. Fencing off areas that have direct stream access keep livestock from trampling stream banks, increasing erosion, and destroying vegetation along the stream bank. It also prevents livestock from defecating directly into the water. We saw no fences along Kehoe Creek

or several other creeks, and manure spreading happens within meters of creeks. The National Park Service should detail how manure management is done so that human health is taken into account, and pathogens minimized or eliminated.

These practices may be difficult to achieve at Point Reyes and Golden Gate National Recreation Area due to the rainy and foggy conditions on this coastal grassland. The Environmental Impact Statement (EIS) should detail how Best Management Practices are achieved. 

Water quality testing in all water bodies in the park units should occur quarterly because pollution levels will vary based on certain variables, such as the location of cattle on a ranch in terms of which pastures they are in and not in, and the effect of seasonal variations in water levels or flows which would cause pollution levels to vary. The park service should conduct a cumulative watershed effects analysis for the watersheds in the project area, including a water balance of the water removed from the watershed to water the livestock as well as to dilute the manure to allow manure spreading in the park, and should present this data in the draft EIS. The EIS should also discuss the measures that will be taken to eliminate or reduce any impacts. What

watershed-level surveys have been conducted?

We have seen ranches in Point Reyes National Seashore, including areas impacting Kehoe Creek, allow manure spreading by various trucking means across pastures. These appear to show sludge-slurry trucks spraying fields, trucks piping manure slurry from holding ponds, trucks releasing manure onto a field, and a liquified manure sprinkler system on a pasture. How are these methods compatible with a national park

unit? What are the human health hazards of such methods? The park service needs to describe each method for disposing of manure on each ranch, as well as the impacts to wildlife, biological resources, sensitive species, native plant communities, visitor experience, water quality, and human health. How much manure is spread on pastures, grasslands, or rare plant communities? When are these manure spreading operations undertaken—spreading manure in the fall before and during rain storms can have serious runoff problems into streams and the ocean.



















































In the Midwest, dairies are using methods that lessen the pollution of water bodies from runoff by injecting manure into the ground. Are any ranches required to do this by the park in order to reduce the risk to human health? The park examine show how watersheds are impaired by being severely polluted. This should trigger enforcement actions. Severe pollution should trigger actions implementing the wording in the 1916 National Park Service Organic Act about keeping Parks in an unimpaired state.

As E. coli concentrations increase in surface waters, it is likely that some type of fecal contamination has occurred. When the concentrations exceed water quality standards, people are at a greater risk of coming into contact with pathogens. The most common illness associated with exposure (swimming, ingestion) to fecal-contaminated water is gastroenteritis, which can result in nausea, vomiting, abdominal cramps, fever,

headache, and diarrhea. Swimming in impacted waters can also lead to eye, ear, nose, skin, and throat infections and respiratory illnesses. In rarer cases, contaminated waters can lead to more serious conditions such as hepatitis, salmonellosis, or dysentery. Agricultural waste products are posing a health hazard for beachgoers at some parts of the National Seashore.

Livestock grazing can lead to soil compaction, massive soil erosion, and sediment flows into streams, which will harm fish and aquatic invertebrates in freshwater streams, brackish lagoons, and nearshore ocean habitats. The environmental review should consider grazing impacts to all soils in the Pastoral Zone from trailing, high-impact areas next to feed troughs and water facilities, ranch core areas, and heavily grazed grasslands where soils are being lost from trampling and erosion. Trampling from beef and dairy

livestock also causes increase runoff during rain storms, as well as decreased vegetative cover to hold soils in place.

The alternative that restores deep-rooted coastal prairie and native wet meadow plant communities should be analyzed in detail as to how these management options could vastly increase soil stability, soil formation, and groundwater retention. Increased live vegetation and dry residual plant matter has been shown to increase soil moisture and rainwater retention.

Erosion is also a significant problem in the watershed. Sedimentation from Lagunitas Creek into Tomales Bay resulted from nineteenth century logging and cattle grazing of riparian plants which otherwise slow erosion. Livestock grazing continues to erode slopes, downcut stream headwaters, and remove deep-rooted vegetation such as native bunchgrasses.

Severe erosion and headcut in ravine on heavily grazed beef ranch at Point Reyes National Seashore.

Dairy cows in water at Point Reyes National Seashore ranch. Photo courtesy Shame of Point Reyes.

Too many cattle at Point Reyes National Seashore. Photo courtesy Shame of Point Reyes.

Manure trucks pumping liquified dairy cattle manure from a holding pond near the barns, right next to Kehoe Creek in Point Reyes National Seashore. 

Manure truck being loaded with liquified cow manure from the Kehoe Creek holding pond, Point Reyes National Seashore.

Manure truck spreading liquified cattle manure onto pastures and fields that were once coastal prairies full of tule elk. Point Reyes National Seashore ranching zone.

Point Reyes National Seashore dairy cow erosion of banks, depositing sediments and excess manure into water bodies. Photo courtesy Shame of Point Reyes.

Industrial modern dairy ranch at Point Reyes National Seashore: not historic. Photo courtesy Shame of Point Reyes.

Lagoons on the Seashore, such as Abbott's Lagoon, are adjacent to these industrial dairy facilities, and fecal coliform manure pollution has caused human health warnings and beach closures.


Pawley, A. and M. Lay. 2013. Coastal watershed assessment for Golden Gate National

Recreation Area and Point Reyes National Seashore. Natural Resource Report

NPS/PWR/NRR-2013/641. National Park Service, Fort Collins, Colorado.