You are hereSuggested Comments on NAP EIR -- Due Monday, October 31, 2011

Suggested Comments on NAP EIR -- Due Monday, October 31, 2011

By sally - Posted on 23 October 2011





The Planning Dept has released an Environmental Impact Review for the Rec and Park Dept’s (RPD) Natural Areas Program (NAP). Originally intended to preserve the few remnants of San Francisco’s historical habitat, the program has morphed into an empire that controls over one-quarter of all the City’s parkland. NAP plans call for the immediate closure of the off-leash area (Dog Play Areas, DPA) at Lake Merced, and for a reduction in the size of the off-leash areas in McLaren Park and Bernal Hill. The closures are necessary, NAP claims, because dogs impact native plants in natural areas. The closure and restrictions will result in a loss of 15% of the total off-leash space in all SF city parks. NAP refuses to call for any new off-leash areas to replace the ones lost.


It doesn’t end there. Nearly 80% of the total off-leash space in SF city parks is located either within or adjacent to natural areas. Should NAP claim impacts from dogs on those areas as well, those areas could be closed in the future. These closures, both the immediate ones and the possible future ones, come on the heels of the Golden Gate National Recreation Area’s (GGNRA) recent proposals to close 90% of the off-leash areas under its control, including severe reductions at Fort Funston, Ocean Beach, and Crissy Field. People who walk with their dogs must let the Planning Dept know they want off-leash access preserved in city parks.


You can see the NAP EIR at:

Scroll down to the sixth Project listed (Significant Natural Resource Areas Management Plan).


The Planning Dept. is accepting public comment on the NAP EIR until the end of business (5 pm) on Monday, October 31, 2011. Please write and let them know what you think of the NAP plans. Send comments to:


Bill Wycko, Environmental Review Officer

SF Planning Dept.

1650 Mission St., Suite 400

San Francisco, CA 94103


or email your comments to:



 Be Sure to Always Include in Your Comment:


1)    List any DPAs or other areas in San Francisco (and GGNRA) parkland where you walk with your dog. How long you’ve walked there. List any groups that you belong to, including any environmental groups you have supported.

2)    Include any personal observations you have made of natural areas in SF city parks. Especially let the Planning Dept know problems you have observed with ways the NAP plan has been implemented. For example, let them know if you have noticed poor maintenance of natural areas, or native plants that were planted then died and were not replaced, or trees that you didn’t want cut down that were, or fences that were put up, or places where access by people have been restricted.



Some Other Specific Comments (choose a few from among this list to comment on, or say something about them all):


1)    The NAP EIR provides no evidence to prove claims that dogs have an impact on plants and wildlife in natural areas. An EIR should be based on scientific evidence, and there is little presented here. Because the NAP EIR’s analysis of impacts from dogs is not based on any evidence, the analysis is inadequate. Without any demonstrated evidence of impacts from dogs, there is no justification for excluding people with off-leash dogs from natural areas. There is, therefore, no justification for the closure of the DPA at Lake Merced, nor for the reductions in the DPAs at McLaren Park and Bernal Hill.

2)    The NAP EIR does not take into account scientific studies that show off-leash dogs have little impact on plants and wildlife, including nesting birds when declaring that dogs have negative impacts. These studies were provided to the Planning Department by SFDOG in its comments on the Initial Study for the NAP EIR. Ignoring them shows that the NAP EIR is inadequate and inaccurate when it comes to dogs and “impacts.”

3)    The NAP EIR repeatedly says: Dogs MAY be impacting protected plant species or wildlife (pp. 297, 298, 305, 306, 472, 473, 502, 517), yet offers no evidence these impacts are actually occurring or ever have occurred. Unsubstantiated claims cannot be made in an EIR. After each of these examples, the EIR then goes on to say: Dogs MAY continue to impact plants or wildlife. If there’s no proof of an impact, then that impact cannot “continue.” EIRs must be based on observed impacts, not things that “may” happen. The analysis in the EIR based on this speculation is incorrect and inadequate.

4)    In several places, the NAP EIR says: Observations indicate dogs are impacting erosion, or plant damage, or damage to natural communities (pp. 471, 500, 505, 516, 519), yet offers no information on these “observations.” Who made them? Were they done in a scientifically rigorous way? Were they made by people biased against dogs? We have seen with the GGNRA’s attempts to get rid of dogs and with Point Reyes attempts to get rid of an oyster farm that reports by “observers” biased against dogs or oyster farmers do not stand up to independent scientific scrutiny. Is this the case here as well? We do not know, since the NAP EIR provides no information about them. Again, EIRs should be based on solid, scientific data, and definitely not on anecdotal “observations.” If not, their analyses cannot be trusted and are inadequate.

5)    The NAP EIR does not differentiate between impacts caused by people with dogs and impacts caused by people without dogs. Do people in the natural areas with dogs cause significantly more impacts than people in the natural areas without dogs? Clearly a 200-pound person will have a much more significant impact on plants than a 20-pound dog. Because this was not evaluated in the EIR, the analyses presented in the NAP EIR are inadequate. If there is little difference in impacts, then the EIR cannot justify banning dogs from the natural areas.

6)    The NAP EIR considers only the NAP plans to close 15% of the legal off-leash space in SF city parks when considering impacts on the remaining DPAs and on recreation. However, the NAP plan also calls for expanding the most sensitive areas within natural areas, and this potentially could result in the closure of significantly more DPAs (up to 80% of the total off-leash space currently available in city parks, off-leash space that is located either within or adjacent to a natural area). These added closures (up to 80%) will significantly increase the impacts on recreation, on people with dogs, and on the remaining DPAs. These increased impacts were not considered in the EIR when it evaluated the Project Alternative, and without them, the analysis of the Project Alternative is incomplete and inadequate.

7)    The NAP EIR acknowledges that the NAP plans to close 15% of the DPAs in city parks immediately, when added to the GGNRA’s plans to cut off-leash access by 90%, will have a significant and unavoidable cumulative impact on remaining off-leash areas in city parks and on recreation. However, the EIR says that because they don’t know the final GGNRA plan, they cannot analyze what that cumulative impact will be. We do know what the GGNRA originally proposed (cutting off-leash access on its lands by 90%) and the cumulative impact of that plan, when combined with the NAP closures can and should be analyzed. We saw on Tsunami Friday what the impacts could be. The GGNRA closed both Fort Funston and Ocean Beach to all visitors on the morning of Friday, March 11, 2011 because of concerns that a tsunami triggered by a major earthquake in Japan would strike the coast. The busiest weekend days normally find about 60 dogs at the Pine Lake DPA at any one time. Weekday mornings normally have far fewer, closer to 20. On Tsunami Friday, a Rec and Park Dept staffer counted over 200 dogs at the Pine Lake DPA at 10 am, almost 10 times more dogs than on a normal weekday and more than 3 times the maximum numbers of dogs seen on weekends. This example can be used to quantify the cumulative impacts of the GGNRA and NAP closures of off-leash space. The analysis presented in the EIR, which does not contain this, is inadequate.

8)    The number of DPAs in city parks listed in the NAP EIR is wrong. Page 155 says there are 19 DPAs, when the actual number is 29. To get such a basic fact wrong is shocking and calls into question other information about dogs, such as their alleged “impacts’ on plants and wildlife.

9)    The NAP EIR incorrectly summarizes RPD’s so-called moratorium on creating new DPAs until a systemwide survey of DPAs is conducted. The NAP EIR says that this moratorium was a directive from the Rec and Park Commission that was announced at the October 10, 2006 meeting of the RPD Dog Advisory Committee (DAC). This is not true. The idea of a systemwide survey of where dogs and DPAs are in San Francisco came not from the Commission, but from RPD staff. It was not discussed at the October 2006 DAC meeting. It was not fully discussed in the DAC until 2007 when RPD made the decision to “sunset” the DAC and conduct the citywide survey. While the survey was being conducted, the DAC was told, there would be a hold on new DPAs. The DAC was told the survey would take maybe a year or a year and a half at the most. The idea of the citywide survey was not presented to the Rec and Park Commission until mid-2007. This was no “direction from the Commission.” This hold was never meant to be permanent. Yet the NAP EIR implies it will last for decades (the length of time covered by the NAP EIR) and therefore the EIR does not have to consider new DPAs. In the four years since the DAC was sunset, however, RPD has done nothing on the citywide survey. And now this inaction by RPD is being used to prevent the EIR from considering whether or not creating new DPAs to replace ones closed by NAP could decrease the impacts of the closures. The NAP plan will last for decades, and for the NAP EIR not to consider a major mitigation like opening new DPAs to replace closed ones because of a temporary halt on new designations is absurd. Any analysis of alternatives that does not include this possible mitigation is incorrect and inadequate.

10)   The NAP EIR assumes that, because the DPAs at McLaren Park and Bernal Hill are not being closed completely, the 15% closures will not cause a significant number of people to drive to other parks to walk their dogs. People will just walk in different parts of the parks that are still off-leash, the EIR assumes. However, the NAP EIR does not take into account the topography of the remaining land in the two DPAs. If what is left is mostly steep hills, people will not be able to walk there with their dogs. Thus, even though the acres of off-leash space may remain relatively high in these two parks, the amount of space that is practically available for off-leash access may be much less. This will increase the impacts on recreation and also will make it more likely that people will be forced to drive to other parks to walk their dogs off-leash. This must be included in the analysis of any and all alternatives. Since it is not, the analysis in the NAP EIR is inadequate.

11)   The NAP EIR does not adequately consider the impacts of the use of herbicides, especially Garlon, on dogs who walk either within or adjacent to natural areas (this applies whether the dog is on- or off-leash). In a paper on the effects of Garlon, the Marin Municipal Water District ( notes that Garlon can cause kidney problems in dogs because of their limited physiological ability to excrete weak acids such as those in Garlon in their urine (they are somewhat unique among mammals in this). The NAP’s reliance on herbicides to speed the removal of non-native plants in natural areas will have a negative impact on the health of dogs walked where it has been applied. This is especially true in Glen Canyon, where Garlon was applied over 30 separate times last year. This impact was not considered in the Hazards and Hazardous Materials section of the NAP EIR and a discussion of the health impacts on dogs of repeated exposure to Garlon should be included.

12)   The NAP EIR says that the impact of people driving to other parks to walk their dogs because of the closures of 15% of off-leash space at Lake Merced, Bernal Hill, and McLaren Park will be less than significant because there will remain sufficient off-leash space in those parks (except for Lake Merced). However, the EIR does not consider the impact of people driving to other parks if 80% of the legal off-leash space in city parks is eventually closed because NAP claims impacts from dogs. This must be included in the analysis of the Project Alternative, and will likely show a much more significant impact than what the EIR now shows.

13)   The NAP EIR refers to dogs as “nuisances”. The EIR does not consider any positive aspects of dog walking, including the physical and mental health benefits to people who walk with their dogs. This lack is especially noticeable in sections dealing with impacts on recreation of the various alternatives considered. The reason so many people walk their dogs off-leash in Bernal Hill and McLaren Park is that those areas are large enough that people can hike long distances with their dogs off-leash. The majority of DPAs in city parks are too small for similar hikes. You can play fetch with a dog in these smaller DPAs, but not take a long walk. You cannot have the same recreational experience in a small DPA that you can have in a larger one; DPAs are not interchangeable. This difference in DPAs creates a significant impact on the recreational experience for dog walkers if the DPAs in Bernal Hill or McLaren Park are closed. In addition, there would be a significant negative impact on the physical and mental health of dog walkers if 80% of off-leash space were closed because NAP claims impacts from dogs. This is not considered in the NAP EIR, which is inadequate without it. These negative impacts on the physical and mental health of dog walkers of the 80% closure will be amplified considerably when combined with closures of off-leash in the GGNRA. This must be considered in the cumulative impacts sections.

14)   The NAP EIR does not adequately analyze mitigations should any impacts from dogs be proven other than closing the DPA. Fences are mentioned briefly, while DPA closures are featured prominently in the EIR. Other mitigations – education, signage, more extensive fencing, etc. – are not discussed. NAP seems to go straight from a single impact to closing the DPA.

15)   The NAP EIR states that impacts to land use planning can be considered significant if they have a “substantial impact on the existing character of the vicinity.” (p. 176) In all of its analysis of impacts on the existing character of the vicinity, the NAP EIR never considers the impact on the social community of people who walk with their dogs in the DPAs and portions of DPAs that NAP wants to close. This community, in many cases, defines the “existing character” of the park. Dog walkers are perhaps the most diverse group of park users. If you watch dog walkers in SF city parks, you will see kids and seniors, people with disabilities, gay and straight, every ethnic and religious group, and every socioeconomic class walking, talking and laughing together, all united by their common love of dogs. There are few places in San Francisco where you will see so many different types of people interacting without rancor. People who walk in the same park at the same time every day know their fellow dog walkers. These friendships extend outside the park into the neighborhoods, helping create the sense of belonging to a community that is so important in today’s impersonal urban society. Closures and reductions in DPAs (especially if 80% of the total off-leash space in city parks are closed) will have a significant negative impact on these social communities. DPA closures will destroy these communities. Because the NAP EIR did not consider these impacts on community of those who live near and walk in parks, it is inadequate.

16)   The NAP EIR does not adequately consider the impacts on the social fabric of San Francisco if one-quarter of its city parklands are closed to residents. Natural areas are not generally accessible to people, whether they have a dog or not. The NAP plan calls for the closure of many trails and reduction of recreational access. You cannot play catch with your child, have a picnic lunch, or play with a dog in a natural area. It can only be a plant museum. The EIR does not adequately consider the significant impact on families and the sense of shared community that access to parks fosters in our urban setting.

17)    The NAP EIR does not adequately analyze the impacts on recreation of NAP plans to plant sensitive plant species (those that are listed as either endangered or threatened) throughout its natural areas. These plants, by virtue of their special status, trigger automatic federal and state protections, the primary one of which is severe restrictions on access to people and dogs. The NAP goal to preserve existing remnants of historical habitat does not require the planting of threatened and endangered species. There are plenty of native species that are not threatened or endangered that can be planted in San Francisco’s urban parks. Ecologists have noted that planting a few sensitive species plants does little to preserve the species. It is not an ecological decision; it is a landscaping decision. So why does NAP feel it should plant so many sensitive species when it knows their mere presence will “require” NAP to restrict access to its lands? The NAP EIR should consider the major negative impact on recreation that planting threatened and endangered species causes in its analysis of the Project Alternative and other alternatives.

18)   The NAP EIR does not consider impacts on recreation and land use from the fact that NAP controls the entire park in over half of the parks (18 of 32) where there is a natural area. No other recreational use is possible in those parks. In an additional 10 parks, NAP controls over 50% of the land. Only four of the 32 parks with natural areas have less than 50% of their land controlled by the NAP. A majority of land under NAP control citywide (57%) will have significant restrictions to access by all people (not just people with dogs); that is the amount of land designated as MA-1 and MA-2. In 8 parks, all of the land in the natural area are designated as MA-1 and MA-2, with resulting significant restrictions on access to everyone. In some cases, this denial of access will be in the only park within easy walking distance in the neighborhood. The NAP EIR must consider this large-scale denial of access when analyzing the Project Alternative.

19)   The NAP EIR does not adequately consider the negative impacts on aesthetics and land use of poor maintenance in natural areas. In most parks, the NAP plan allocates fewer than 20 days/year for planting/maintenance of the natural areas. In 16 of the 32 natural areas, the total maintenance planned is 10 or fewer days each year. There are countless stories of volunteers who have spent long hours planting native plants in NAP areas, only to see absolutely no maintenance performed once the plants are there. Without maintenance, the plants die, creating unsightly vistas of dead and dying plants. The NAP EIR should have considered the impacts of scaling back the program to a few areas that can be well maintained, as opposed to the current plans to take over one-quarter of San Francisco’s city parkland. The NAP plan is more ambitious in the amount of work to be done annually than NAP has demonstrated it has the capacity to actually DO on a consistent basis.

20)   The NAP EIR does not consider the negative impact on aesthetics of NAP management decisions. For many people, brush piles used in natural areas look like accumulations of trash and are aesthetically unpleasing. For many people, shaded areas with tall, non-native trees are aesthetically pleasing, while areas without tall trees are less so. People like to see their parks green not brown half the year. Because these impacts were not considered, the NAP EIR is inadequate.

21)   The NAP plans call for cutting down over 18,000 healthy trees simply because they are not native. The NAP EIR does not adequately consider the long-term impacts on climate change and global warming of the conversion of land covered by trees with grasslands. Tree are much better at carbon sequestration than grasslands, and the long-term consequences of this difference are not adequately considered. For more on NAP impacts on trees, see:

22)   The NAP EIR does not adequately consider the fact that the climate in San Francisco has changed (and continues to change) from the time several hundred years ago that the NAP plan is trying to re-create. Native plants suited to the earlier climate may no longer be suited to today’s (and tomorrow’s) climate. The NAP EIR does not consider the lack of sustainability of trying to re-create what the habitat was at one snapshot in time when the climate has changed since that time. The environmental consequences (for example, more herbicides, etc.) of trying to force the old habitat into today’s climate should be analyzed more thoroughly.


Please be sure to send in a comment before the end of business (5 pm) on Monday, October 31, 2011. Help preserve off-leash access to our city parks!

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