You are hereSuggested Comments on GGNRA DEIS Dog Plan

Suggested Comments on GGNRA DEIS Dog Plan

By champsee - Posted on 07 February 2011

Some suggestions for your public comment on the DEIS. You should definitely say how much you enjoy walking with your dog off-leash in the GGNRA. But you need to include some substantive reasons why the GGNRA’s Preferred Alternative is not good and why they need to develop a new Alternative that will be more balanced, supportive of recreation, and reflects San Francisco’s values of co-existence, shared use, collaboration, and education to solve problems.


Feel free to pick and choose from these suggestions to fit what you want to say. You can use personal stories to illustrate these points, but you do not have to. Include at least one substantive point in your comment (see that section below).




1)    You can send in more than one comment so don’t worry if you forget to say something. Just send in a second, third, fourth, etc. comment.

2)    If you are a member of a protected class, be sure to mention that in the first sentence of your comment. Protected class includes, seniors, disabled, ethnic minorities, parents, gays. Parents get your children to write separate comments and note their ages on the comment.

3)    Be sure to say that you are a local resident (if you are), and how long you have been recreating with your dog(s) off-leash in areas controlled by the GGNRA, which areas you frequent, and how often you go to the GGNRA each week or month.




1)    The Compliance-Based Management Strategy must go.This poison pill that will allow the GGNRA to change the status of off-leash areas to on-leash or no dogs without additional public comment if there is not 100% compliance with the new restrictions will not work. The change would be permanent. A management plan should not come with a built-in nuclear option, which is what this is. It allows a relatively few bad players to undermine and destroy a traditional recreational use of the area. No number of responsible dog owners will stop what will become the inexorable removal of all off-leash access in the GGNRA if this strategy remains part of the plan. Tens or hundreds of thousands of hours of incident-free dog walking will not matter. There should be (and are) penalties for bad actors and these should be enforced. But the vast majority of people who do not act badly should not be penalized for the bad actions of a few. This strategy is unfair because off-leash status can be changed in only one direction (toward more restriction). It circumvents the legal requirement that management changes that are either significant or controversial must have a public process before they can be made. Critical information about how compliance will be determined – by volunteers biased against dogs? by surveillance cameras? – is not included in the DEIS.

2)    The Preferred Alternative is not acceptable.It is overly restrictive, and its restrictions are not justified by the totality of available data. It is based on separation and exclusion, a management philosophy that goes against the values of the Bay Area in which it is fully immersed. It violates the mandate for the” maintenance of needed recreational open space” contained in the legislation that created the GGNRA. The DEIS is full of negative things that “might” or “could” happen if dogs are allowed off-leash at various sites. But there is very little evidence presented that these hypothetical impacts actually happen. Given the intense scrutiny of dogs by the GGNRA over the past decade and more, the fact that there is not more persuasive real data about significant impacts of off-leash dogs means that there is no real justification for the proposed restrictions contained in the Preferred Alternative. The contraction of areas available for off-leash recreation will significantly compromise the park experience for people with dogs, and could lead to an increase in conflict as more and more people are forced into smaller and smaller areas. The impacts of people moving from the GGNRA into city parks is not adequately addressed in the DEIS. Any alternative must address these impacts on city parks and ways to mitigate them.

3)    The GGNRA should develop a new alternative, the A+ Alternative, that will better balance the recreational needs of the Bay Area with protection of natural resources.The DEIS calls the “No Change” Alternative “A”. This is the 1979 Pet Policy with some restrictions, particularly restrictions on off-leash at Ocean Beach, Fort Funston, and Crissy Field because of the snowy plover and native plant restorations. More than one-third of Bay Area residents have dogs and we now know the importance of off-leash recreation for dog’s physical and mental health, as well as the importance of the significant social communities that develop where people recreate with their dogs off-leash. This large segment of Bay Area residents should not be restricted to significantly less than 1% of GGNRA land (that is how much GGNRA land is available for off-leash recreation in Alternative A) to have a satisfactory park experience, especially since there is little scientific evidence supporting restrictions on off-leash. There has to be more space available for off-leash recreation, not less, given the huge demand for it in the Bay Area. The A+ Alternative would include everywhere that is currently off-leash, plus sufficient off-leash opportunities in San Mateo County to meet the demand, and more trails off-leash throughout the GGNRA. In addition, new land added to the GGNRA would include off-leash areas, especially in those areas where it has traditionally taken place. There would be no compliance-based management strategy in the A+ Alternative. Any dog management philosophy in the GGNRA, like that for any other recreation use, should be based on Bay Area values of co-existence, shared space, collaboration among park user groups, and education where problems arise. Enforcement of already existing regulations should target irresponsible dog owners who create the few problems documented by the GGNRA, while allowing responsible dog owners to continue their traditional off-leash recreation without harassment.

4)    There are not enough trails available for off-leash recreation in the Preferred Alternative. We need more.Not everyone who goes to the GGNRA plays fetch with his or her dog. Many people enjoy hiking on trails with their dogs as their companions. There are not enough trails with off-leash access in the Preferred Alternative.

5)    There must be off-leash access in San Mateo County and on new lands as they come into the GGNRA.The Preferred Alternative has no off-leash on any GGNRA land in San Mateo County, even though much of the land allowed off-leash access before it became part of the GGNRA. Off-leash recreation is a traditional use of those lands, and it must be respected and maintained. That is in keeping with the GGNRA’s mandate for the “maintenance of needed recreational open space” contained in the legislation that created the GGNRA. The refusal to consider off-leash recreation for any new land that might come into the GGNRA in the future is an additional violation of the GGNRA’s recreational open space mandate. There needs to be a mechanism for additional off-leash recreational open space when new land comes into the GGNRA.




1)    The “Poison Pill” of a “Compliance-Based Management Strategy” is unfairsince it can only reduce off-leash access and not increase access in the future, and is an attempt to circumvent the legal requirement of a public process when management changes that are significant or highly controversial are made. It will not work and must be removed.

2)    The Preferred Alternative severely restricts recreational access for people with dogs, a fundamental violation of the reason the GGNRA was created.In the legislation that created it, the reason for the creation of the GGNRA is listed as “the maintenance of needed recreational open space.” Off-leash dog walking is among the recreational activities listed as traditionally occurring in the land that was to become the GGNRA. There is no off-leash access in San Mateo County in the Preferred Alternative and that must be changed.

3)    The Preferred Alternative is overly restrictive.The science and data do not support the level of restrictions on people with dogs included in the Preferred Alternative. When dogs are walked in a responsible way (as most are), there is no conflict with the environment or with other park users. Target people not walking their dogs responsibly, but leave the vast majority of us alone.

4)    The Preferred Alternative unfairly mandates that any new land that comes into the GGNRA cannot have dogs either on- or off-leash.This restriction is unneeded, and denies the traditional recreational activity of off-leash dog walking that has existed on many of these lands for decades. It goes against the recreational mandate that was the reason the GGNRA was created. If new land is added to the GGNRA, off-leash access must be allowed on it.

5)    The Preferred Alternative is not “balanced.”The 1979 Pet Policy allowed dogs off-leash on less than 1% of GGNRA land. Given recent additions of large tracts in San Mateo County to the GGNRA, this number is now significantly less than 1%. Off-leash dog walking started from a position of great imbalance. One-third of San Francisco households have dogs, yet they can currently recreate with their dogs on less than 1% of GGNRA land. The Preferred Alternative allows off-leash on even less, including no off-leash anywhere on GGNRA land in San Mateo County. How is that balanced? By denying the possibility of off-leash on any new lands that come into the GGNRA in the future, the Preferred Alternative will ensure there is no balance between recreation and protection of natural resources in the future. We need more off-leash recreational open space, not less.

6)    The Preferred Alternative is based on a philosophy of separation and exclusion. It denies that different park users can co-exist.Rather than share space between different park users, the Preferred Alternative carves up park space into separate areas for different park users. This basic philosophy is the exact opposite of the way we approach problems in San Francisco. It flies in the face of the unique social qualities of San Francisco. The GGNRA needs to develop a new Alternative that will better reflect San Francisco values such as co-existence, shared space, collaboration, and education to address problems should they occur.

7)    The Preferred Alternative discourages cooperation between different park usersand will increase conflict between park users, as more and more people are crammed into smaller and smaller spaces. Park user groups can work together to resolve problems when they come up. For example, Fort Funston Dog Walkers, SFDOG and the hang glider group Feathered Flyers of Fort Funston collaborated on a series of signs to warn dog owners to keep their dogs out of the hang glider take-off area.

8)    The Preferred Alternative condemns every dog owners for the actions of a very few irresponsible owners.According to the GGNRA’s own statistics, 94% of dogs do not chase birds (and most of those who did chased seagulls). Yet, all people with dogs will be excluded from a majority of Ocean Beach to “protect” birds. . Focus enforcement on people who do not keep their dog from chasing birds rather than on excluding all people with dogs.

9)    Dog owners are being held to a standard of behavior that is impossibly high, and significantly higher than any other park users.For example, studies by GGNRA staff routinely show people without dogs “disturb” plovers, but there is no attempt to restrict people without dogs from the beaches where plovers roost (not nest).




The restrictions on access for people with dogs contained in the Preferred Alternative are not warranted. They cannot be used to justify a fundamental violation of the recreational mandate that formed the reason the GGNRA was created.


1)    Severe restrictions are not needed to protect other park visitors from dogs. 
Problems with dogs represent a tiny fraction of the total incidents and citations issued by the GGNRA over the past decade. Of those incidents and citations issued to people with dogs, the majority were leash law violations, or being in a closed area, and did not reflect any safety issues between dogs and other park visitors. Target enforcement on the small number of people whose dogs misbehave, not on excluding the entire class of people with dogs from most of the GGNRA. Jean Donaldson, nationally recognized expert on dog behavior testified before the SF Animal Control and Welfare Commission on 2/8/07: “[S]elf-selection operates strongly, i.e., people who take the time to get into their car or walk to a designated off-leash area to exercise their dogs tend not to be the type who are derelict in other areas of dog guardianship, such as training, socialization, or appropriate containment.” [Click here for more information on dog safety in the GGNRA] [MANISH – connect to the Dog Safety in the GGNRA page]

2)    The DEIS does not adequately address dispersion issues.  
The DEIS does not adequately address the environmental and social impact of forcing large numbers of people and dogs into much smaller areas. Reducing the amount of area available for off-leash will significantly degrade the park experience for people with dogs. It will increase conflicts. Even more importantly, the DEIS does not address the environmental and social impact on small, neighborhood parks in cities like San Francisco next to the GGNRA. Because the GGNRA is located immediately adjacent to one of the most densely populated areas in the United States (San Francisco), it provides much needed recreational open space for Bay Area residents. If that open space is lost to recreational access, people and their dogs will move to the much smaller city parks and they will not be able to absorb the hundreds or thousands of people with dogs each day that will be kicked out of the GGNRA. As further proof that the GGNRA did not consider impacts on city parks in San Francisco, the Preferred Alternative suggests the nearest legal off-leash area in San Francisco to Fort Funston is Lake Merced. That off-leash area has been closed to off-leash for years and has been turned into a native plant restoration area and habitat for the endangered red-legged frog among other animals. Yet this is where the DEIS suggests people with dogs go.

3)    The DEIS continues a trend of GGNRA claims about impacts by dogs on birds that are not supported by the data. It is based on bad science.
There is no scientific consensus that severe restrictions on off-leash dogs are needed to protect natural resources and wildlife. Some of the most compelling research in the last few years has been by researchers such as Forrest and Cassidy St. Clair (2006) and Warren (2007) who admit that they expected to find that off-leash dogs had a major impact on the diversity, abundance, and feeding behaviors of birds and small mammals. However, when they did the actual research, they found no such impacts. This indicates that assumptions about impacts from off-leash dogs must be tested and proven to be true before they can be used to justify restrictions. Unfortunately, most of the assumptions cited by the GGNRA have not been adequately tested or proven. In addition, the GGNRA has repeatedly cited research that they claim shows major impacts from off-leash dogs. However, when the raw data from these studies is analyzed, it is clear the claimed conclusions are not supported by the data. This is highly reminiscent of the problems documented at the Point Reyes National Seashore, where claims by staff biologists about negative impacts from an oyster farm located within the park were proven to be baseless when the raw data was independently analyzed.[Click here for more information on the non-impact of dogs on birds and wildlife] [MANISH – Connect to the Do Dogs Bother Birds and Wildlife page]
a)Severe restrictions are not needed to protect the snowy plover.  
The GGNRA’s own data show that off-leash dogs have no impact on the numbers of snowy plovers, a threatened species that roosts only (does not nest or raise chicks) on relatively small parts of Ocean Beach and Crissy Field. Indeed, larger numbers of snowy plovers frequently coincided with times when dogs were allowed off-leash in the area. The 1999 Hatch Report observed 5,692 dogs at Ocean Beach and found that only 6% chased birds (mostly seagulls). Indeed, of these 5,692 dogs, a mere 19 were observed to chase plovers. That is one-third of 1% of the dogs observed. Target those dog owners for enforcement, but leave the other 99.66% of dogs that did not chase plovers alone. Some studies define “disturbance” of a bird so broadly as to include the fact that if a bird merely looked up when it heard a sound, even if it took no further action, it was a disturbance. The GGNRA’s own studies show that joggers and walkers, not to mention parents with toddlers, equestrians, surfers, and other park users “disturb” plovers, yet there is no attempt to restrict their access in the plover areas.

There are much less restrictive measures the GGNRA could take to protect snowy plovers, including the use of temporary “exclosure” fencing when the plovers are present. This would keep everyone, people as well as dogs, out of the area. Enforcement that targets people who intentionally disturb plovers would also help.

During a 2/17/07 Negotiated Rulemaking meeting, Barbara Goodyear, Field Solicitor for the NPS, said that deliberate behavior (e.g., training your dog to chase birds) should be the target of a management policy, but that incidental behavior (e.g., walking by a bird and causing it to flush) should not. Yet the Preferred Alternative cites incidental behavior as a justification for increased restrictions on off-leash dogs.

b) Severe restrictions are not needed to protect the bank swallow.
The DEIS claims “continuing” impacts from dogs and/or humans that include digging at or collapsing the burrows of bank swallows, flushing the birds from nests, and causing active sloughing and landslides that may block or crush the burrows. However, there is no documentation that any of these impacts actually occur. Bank swallows burrow near the top (but not at the top) of sheer cliff faces at Fort Funston. There is no way dogs can access these burrows, so there can be no impact on them from the dogs. A GGNRA bank swallow report claimed that these impacts “could occur” even without proof that they actually do. This “could occur” has been changed in the DEIS to “continuing impacts”.

4)    The DEIS is full of impacts of dogs on wildlife and other park visitors that “could” occur, but there is little evidence that these impacts actually do occur.After over ten years of intensive scrutiny of off-leash dogs in the GGNRA, it should be obvious if those impacts really do occur. The lack of data indicates they do not. For example, the DEIS mentions that disease “could” be transmitted to people from unpicked-up dog feces. However there has not been a single case of dog-feces-caused human illness reported by the San Francisco Department of Health for over 50 years. A management policy should not be based on hypothetical impacts. It should be based on actual, observed impacts. Hypotheticals that are not actually seen in the GGNRA cannot be used to justify restrictions on off-leash recreation in the GGNRA.

5)    The claim that environmental justice requires severe restrictions on off-leash dogs is not supported by the studies cited in the DEIS.
a) The DEIS cites a 2007 SF State study that claims all Latinos and Asians surveyed said that dogs were a problem. However, the study itself was not about the “ethnic minority visitor use experience at the GGNRA” as claimed by the DEIS, but was actually intended to address ways to improve “connecting people to the parks.” Off-leash dog walking connects all different kinds of people to the parks. In addition, the SF State study was not an extensive survey – it interviewed less than 100 non-randomly people who were largely unfamiliar with the GGNRA (only 1/3 had visited at least one GGNRA site in the past year).

b) A second study cited by the DEIS (Northern Arizona University phone study) was a scientifically rigorous study that used random sampling in identifying who was interviewed for the survey. This study concluded that there was no real difference in attitudes between the various ethnic groups about dogs in the parks.
c) Indeed the restrictions on off-leash access supported by the Preferred Alternative will have a serious negative impact on the thousands of ethnic minorities who walk their dogs off-leash in the GGNRA, a point not addressed in the DEIS. Off-leash dog walking is the most diverse recreation activity in the GGNRA, enjoyed by the widest variety of people – seniors, kids, the disabled, every ethnic group, every sexual orientation, and every social and economic class.

6)    The claim in the DEIS that they have to manage the GGNRA in a manner similar to the way they manage parks like Glacier National Park or Yellowstone National Park is misleading and cannot be used to justify the restrictions called for in the Preferred Alternative.
a) The GGNRA is a National Recreation Area, not a National Park. The mandate for the GGNRA’s creation was, according to the legislation that established the GGNRA in 1972, for the “maintenance of needed recreational open space”. Off-leash dog walking was acknowledged at the time as one of the traditional recreational uses taking place in the GGNRA when it was created. In 1979, the US Congress passed a law that all national park units, including national recreation areas, national seashores, and national monuments have to be managed uniformly. But, concerned that the unique purposes for each park would be overlooked in this change, they added the following language to the law: “The authorization of activities shall be construed and the protection, management, and administration of these areas … shall not be exercised in derogation of the values and purposes for which these various areas have been established”. So there is no mandate to match the GGNRA’s policies with National Park Service requirements that dogs not be allowed off-leash in a national park.

b) In 2002, a panel of senior National Park Service officials concluded, in part, “[T]hat off-leash dog walking in GGNRA may be appropriate in selected locations where resource impacts can be adequately mitigated and public safety incidents, and public use conflicts can be appropriately managed.” Adequate mitigations and management already exist – target people whose dogs bother birds and wildlife or who jump on people, but leave the vast majority of responsible dog owners free to recreate off-leash with their dogs on the less than 1% of GGNRA land on which they’ve always been allowed off-leash.

c) Dogs are allowed off-leash to hunt in national preserves, and other units administered by the National Park Service. Surely, if it’s okay for a dog to be off-leash while it helps chase, corner and kill a wild animal, it should be okay for a dog in the GGNRA to be off-leash to play with people and other dogs.

d) The GGNRA is located in the densely populated San Francisco Bay Area. It is in a major urban area. Much of the land was highly modified by the military when they controlled the land before the GGNRA was created. The GGNRA contains numerous missile silos, artillery batteries, and their assorted support structures. The military planted huge amounts of ice plant to stabilize the sand dunes at Fort Funston and elsewhere. Standards of management that treat much of the GGNRA, especially those parts in San Francisco, like pristine wilderness are misguided.

e) During 2/17/07 Negotiated Rulemaking meeting, Barbara Goodyear, the Field Solicitor for the NPS, made it clear that while all parks are managed to the same level (conservation of resources), there is flexibility in how that is done from park to park. She cited as an example, the fact that you don’t manage Yosemite Valley with the expectation that people will have a solitary wilderness experience. You manage it with the knowledge that people will bump into each other in that part of Yosemite. The GGNRA, an urban park located in and immediately adjacent to a large city, does not have to be managed in the same way as Yellowstone or Glacier National Parks.

7)    The level of enforcement required by the Preferred Alternative is excessive and unsustainable. Targeting people walking their dogs irresponsibly and leaving responsible dog walkers alone would be a much more efficient use of GGNRA resources.
The DEIS states that it will cost nearly $1million to enforce the Preferred Alternative, through the hiring of more Park Rangers or Park Police. In an era of shrinking federal budgets, this seems a poor use of scarce financial resources. Existing Park Rangers could easily enforce already existing rules such as picking up pet litter or no chasing of birds. These enforcement actions are all that are needed to ensure responsible dog walking and minimal impact on natural resources and other park visitors from off-leash dogs.

8)    The inclusion of a “poison pill” in the DEIS suggests the GGNRA will use it as an end run to ban off-leash dogs in the near future, bypassing the kind of public process such an action is normally required by law to follow.  
The DEIS includes a “compliance-based management strategy” that says that, if there is not enough compliance with the restrictions imposed by the Preferred Alternative, the GGNRA will change the management of the various areas to the next more restrictive level – an off-leash area will become on-leash only, an on-leash area will become no dogs at all. This change will be permanent, with no chance to go back to less restrictive levels at any time in the future. This section must be removed from any final Dog Management Plan.
a) This compliance-based management strategy is decidedly unfair, because it can only be changed in one direction – toward more restrictive levels of access for people with dogs.
b) There is no provision for public comment in the case of a change in status of an off-leash or on-leash area because of the compliance-based management strategy. The GGNRA has already lost two court cases (and one appeal) when it tried to make a significant and controversial policy change without going through a public process. The federal courts have routinely told the GGNRA that they have to hold public meetings and take public comments before making such changes. Clearly, a change in status of an off-leash area to leash-only would be both significant and very controversial, and therefore should require a period of public comment and public hearings before being implemented. The poison pill in the DEIS is an end run designed to allow the GGNRA to make such changes without having to go through a public process (they can claim the public process was the public comment on the DEIS itself, not on the changes it allows at a future time).
c) How will compliance be monitored? Who will do the monitoring? The GGNRA has repeatedly relied on poorly trained volunteers with a deep-seated bias against dogs to monitor the interactions between dogs and snowy plovers. Why would we expect these compliance monitors to be any less biased? Will their claims of non-compliance be valid? Will the GGNRA resort to the use of surveillance cameras to monitor compliance? While noting that there is no mention of surveillance cameras in the DEIS, GGNRA staff have refused to say they would never be used.
d) This allows a few bad actors to result in the removal off-leash access everywhere in the GGNRA, even if there are tens of thousands of hours of incident-free dog walking for every single incident. Including a “nuclear option” in a management plan is not good management policy. Regulations already exist to target those who do not control their dogs when they are off-leash. Target enforcement at those bad actors, not at the huge numbers of dog walkers who do not cause problems.

9)    Off-leash play decreases the likelihood of dog aggression in dogs.
In comments to the SF Animal Control and Welfare Commission on 2/8/07, Jean Donaldson, then head of the Dog Training Program at the SF/SPCA and a nationally recognized author on dog behavior said: “There is not only no evidence that allowing dogs off-leash for play opportunities increases the incidence of aggression, to a person, every reputable expert in the field of dog behavior in the United States is of the opinion that it is likely that off-leash access decreases the likelihood of aggression.” She also said: “Interestingly, it could very well be that the safest dogs are those that attend off-leash dog parks.” And she said: “There is no research demonstrating that dog parks or off-leash play contributes to any kind of aggression, including dog-dog aggression.”

10)A well-exercised dog is a well-behaved dog.
Dogs that are not adequately exercised can develop behavior problems such as barking, destroying property in the home, etc. Behavior problems are one of the primary reasons that people surrender dogs at shelters. San Francisco has a “No Kill” goal that no potentially adoptable animal in a city shelter (SF Animal Care and Control, SF/SPCA, Pets Unlimited). Representatives of the SF/SPCA have said that the Preferred Alternative will make it harder for the SF/SPCA to perform their mission to reduce surrenders to city shelters and make San Francisco a truly No Kill city.

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