Animal Behavior and the GGNRA DEIS


Frank Dean

General Superintendent

GGNRA, Building 201

Fort Mason

San Francisco, CA 94123-0022


Comments: Draft Dog Management Plan/Draft Environmental Impact Statement


Dear Superintendent Dean,

The GGNRA DEIS for a Dog Management Plan does not consider the impact that restrictions of off-leash access and resulting overcrowding in city parks will have on dog health and behavior. The DEIS contains no information on the benefits of off-leash play for dogs in terms of their physical and mental health and behavior. Dog behaviorists nearly universally view off-leash play as critical for well-exercised and well-socialized dogs. The severe restrictions on off-leash access proposed in the Preferred Alternative will likely decrease the amount of aerobic exercise many dogs receive, as it becomes more problematic for their owners to provide them with the level of exercise they currently get at Fort Funston, Ocean Beach and other locations in the GGNRA. The restrictions will also seriously interfere with the socialization of dogs both to other dogs and to people in general, as they lose access to places that allow them to interact freely and without crowding. The net result of this loss of off-leash space is likely to increase problem behaviors observed in many of those dogs who lose access to off-leash areas.

If the severe restrictions proposed in the Preferred Alternative go through, many people who currently walk their dogs off-leash in the GGNRA will instead move to the much smaller city parks. The nearly tenfold increase in dogs observed in Stern Grove mid-morning on Tsunami Friday (March 11, 2011, when the GGNRA closed Fort Funston and Ocean Beach because of the threat of a tsunami from the earthquake in Japan, as reported in the March 2011 issue of the West Portal Monthly) is indicative of the increases in visitor usage in city parks likely to occur if the severe restrictions in the Preferred Alternative go into effect. Off-leash areas in city parks are significantly smaller in area than those currently available in the GGNRA. Putting thousands more people and dogs into much smaller areas will inevitably lead to problems caused by overcrowding. This will result in more behavior problems in dogs forced to endure the overcrowding day in and day out.

Problem dog behaviors are one of the primary reasons given when owners surrender dogs to shelters. It is likely that the restrictions on off-leash access and overcrowding that come from the GGNRA’s Preferred Alternative will therefore result in an increase in surrenders to city shelters. Because dog rescue groups are already overwhelmed with the existing demand for placements out of shelters, it is likely that they will have difficulty finding homes for the additional shelter dogs that result from the GGNRA’s plan. Thus, there will likely be an increase in dogs in the city shelter at any one time. This increase will have an economic (supplies and staff resources) impact on city shelters, and an emotional impact on shelter staff as potentially adoptable dogs are euthanized at city shelters because there are too many dogs in the shelter or because they fall through the cracks of the rescue system.

On March 10, 2011, the San Francisco Commission of Animal Control and Welfare, of which I am the Chair, held a hearing on the GGNRA DEIS and its potential impacts on dog behavior and city shelters. We heard testimony from invited speakers that included dog behaviorists and trainers, as well as leaders of established dog rescue groups and shelter directors (the SF/SPCA and SF Animal Care and Control). The testimony supported what I have said in this letter. The Commission advises the Board of Supervisors on animal issues. At the March 10 meeting, the Commission voted 5-2 to recommend that the San Francisco Board of Supervisors oppose the DEIS Preferred Alternative because it did not consider impacts on dog behavior and possible increases in surrenders to city shelters.

I have attached a transcript of the GGNRA discussion for that meeting, including the public comment that followed the invited speakers. This is provided not as an attempt to submit public comments about the DEIS on behalf of these individuals, but rather to educate GGNRA staff and comment reviewers on this issue by providing the expert testimony of dog behaviorists, trainers, heads of dog rescue groups, shelter directors, and dog owners about the benefits of off-leash play for dogs and the impacts that the loss of off-leash space in the GGNRA will likely have on dog health and behavior and on city shelters. I have also attached letters sent to the Commission of Animal Control and Welfare Commission, as well as to the Land Use Committee of the Board of Supervisors by nationally recognized local dog behaviorists about these issues. Again, these letters are not intended to be considered as a submission of the individual’s public comment on the DEIS, but rather are intended to educate GGNRA staff and the comment reviewers about the benefits to dogs of off-leash play and potential impacts on dogs if off-leash access is severely restricted in the GGNRA, as provided by nationally recognized expert dog behaviorists.

The impacts on both dogs’ health and behavior, and on city shelters and rescue groups were not considered in the DEIS, and the document is therefore incomplete. As a result, any analysis of alternatives that did not include these impacts cannot be accepted. The GGNRA must go back and include analysis of these impacts before any dog management plan can go forward.



Sally Stephens



Click here to read March 10, 2011 Animal Control and Welfare Commission transcript


Click here to read statement of Internationally Known Dog Behaviorist Ian Dunbar


Click here to read statement of Dog Behaviorist Veronica Boutelle, from DogTec


Click here to read statement of Dog Behaviorist Trish King, from Marin Human Society


Click here to read statement of Dog Behaviorist Jean Donaldson, from Feb 8, 2007 Animal Control and Welfare Commission meeting