GGNRA is Changing Commercial Dog Walking Permit to CUA

 

(Note: see Feb. 28 update below)

The Golden Gate National Recreation Area is changing its commercial dog walking Special Use Permit, in use since 2014, to a Commercial Use Authorization (CUA) business permit beginning on March 1, 2025. This means that people who walk 4 or more dogs up to a limit of 6 dogs for a living will need to apply for a CUA with the National Park Service to walk on GGNRA land in San Francisco and Marin. (Note that the initial CUA erroneously stated 3-6 dogs, which was corrected by the GGNRA on Feb. 18.)

There are some significant differences between the old permit and the new CUA. Apparently, the GGNRA mailed a notice in December to dog walkers who had previous permits. However, many dog walkers have said they did not receive any notice and were unaware of the forthcoming changes.

The fee for the CUA application is $350 and a separate fee for an individual commercial dog walker badge will increase to $200 (and increase annually). CUA holders will also be required to report annual income from dog walking in the GGNRA.

The GGNRA says that five items are required to apply for the new CUA which are similar or the same as previously needed with the special use permit:

  1. Certificate of Insurance: Required in the amounts of $1,000,000 per occurrence, $2,000,000 aggregate; and listing “The United States of America, National Park Service, Golden Gate National Recreation Area as Additional Insured.”

  2. Business License: Required from the county(ies) in which dog walking services will take place.

  3. Proof of Training: Proof of training is required and must be specific to the county in which you will be conducting dog walking services. If you will be doing so in both San Francisco and Marin Counties, you will need to meet the requirements for both.

  4. Color Photo: Please clearly identify the names of dog walkers in each photo. This information will be used for badge or placard fabrication.

  5. Payment: Payment must be made online when submitting your application. Your CUA and badges will not be issued until all payment is complete.

CUA CONCERNS

SFDOG has concerns about some additional terms and conditions of the CUA, which the GGNRA said is being changed as part of a standardized system that NPS uses for all entities that conduct business in national parks such as tour operators and transportation companies.

SFODG has asked the GGNRA to clarify and explain under what circumstances the below CUA terms, which seem onerous and unnecessarily burdensome for sole proprietors, would be applicable and enforced:

  • Rates:  “The holder shall provide commercial services under this authorization to visitors at reasonable rates satisfactory to the area Superintendent.”

    SFDOG would like to know when and why the Superintendent would be allowed to review rates charged to clients? (See Feb. 28 update)

  • Reporting:  “The holder must submit annually the CUA Annual Report (NPS Form 10-660) by January 31 for the prior CUA season and also must submit upon request the CUA Monthly Report (NPS Form 10-660A).”

    SFDOG would like to know when and why monthly reporting would be requested? (See Feb. 28 update)

  • Accounting:  “The holder is to maintain an accounting system under which its accounts can be readily identified within its system of accounts classification. The holder grants the United States of America access to its books and records at any time for the purpose of determining compliance with the terms and conditions of this authorization.”

    SFDOG has aked the GGNRA if certain software or systems must be used, such as QuickBooks, and under what circumstances it could be accessed by NPS?

  • Other Required Insurance:  “Commercial Auto Liability Insurance is required if a CUA holder transports passengers or uses owned/leased/rented vehicles in the performance of the service in the park.”

    SFDOG has asked the GGNRA for clarification and under what conditions additional insurance is necessary? Commercial dog walkers already have their own auto liability insurance and “passengers” is a legal term that applies to people, not dogs. (If it applied to dogs they would be very popular for HOV carpool lanes.)

We will post any response from the GGNRA to our questions when we get them.

Feb. 28 update note:

The GGNRA is preparing a response to the concerns and questions raised by SFDOG about the CUA that should be publicly available at the end of March. (We will provide a link when it’s available.)

In the meantime, we have spoken with the GGNRA twice this week and want to share changes they have already made to the CUA and the context they provided about rates that a commercial dog walker charges clients, which is covered in the CUA.

Changes

The new CUA originally said it applied to anyone walking 3 or more dogs up to a limit of 6 for pay. This was a change from the 4-6 dog requirement in the previous dog walking permit in use since 2014. The GGNRA told us this change was an error. Over the past week the GGNRA changed the CUA permit requirement back to the previous 4-6 dogs.

In addition, the GGNRA noted that the “Required Reporting” section of the CUA shows that only Annual Income reporting is required for the commercial dog walker CUA (NPS form 10-660).

Although a separate point in the terms and conditions states that the CUA holder “must submit upon request the CUA Monthly Report (NPS Form 10-660A),” the GGNRA has told SFDOG that it only collects the year-end tally and does not request or use monthly data.

Rates

The GGNRA also provided context about the term in the CUA that states “the holder shall provide commercial services under this authorization to visitors at reasonable rates satisfactory to the area Superintendent.” The GGNRA told SFDOG that it has no interest in or intention to review the rates dog walkers charge their clients. 

Essentially, the GGNRA said to us that NPS requires this clause as a recourse to protect the public in the event there is an out-of-control CUA company charging exorbitant rates for people to use their services. This would apply to companies that have inflated their rates because the activity they do is in high demand or if the company has a monopoly, like, for example, a tour boat operator (our example, not theirs).

Since commercial dog walking is not exclusive to the GGNRA nor does anyone have a monopoly on it, we believe there would be no reason or justification for the GGNRA or NPS to use this clause to review dog walker rates.

Other Required Insurance

This other required insurance only applies to interstate travel and is not applicable to commercial dog walkers.

 
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