The GGNRA’s Proposed Dog Management Plan
After the failure of Negotiated Rulemaking, the National Park Service continued its efforts to develop a dog management plan intended to severely restrict where you could walk with a dog. The plan was developed under the National Environmental Policy Act that assumed that the Park Service would conduct an impartial analysis of various alternatives and, based on that analysis, designate a Preferred Alternative for a Dog Management Plan. Unfortunately, the analysis was poorly done, with extensive bias against dog walking throughout the process.
Draft Environmental Impact Statement
In January 2011, the Service released a Draft Environmental Impact Statement that analyzed several alternative dog management plans and presented a Preferred Dog Management Plan.
The GGNRA’s Preferred Dog Management Plan would ban dogs from three-quarters of Ocean Beach, and significantly cut off-leash dog access at Fort Funston and Crissy Field. Marin County sites would be severely restricted, and there would be no off-leash available anywhere on the GGNRA’s San Mateo County land.
In addition, the Draft plan included a poison pill – a compliance-based management strategy – that would have given the GGNRA Superintendent the ability to remove all off-leash access if there was a claim that not enough people were abiding by the new rules, with no recourse to challenge the change in status.
The Draft Environmental Impact Statement cited problems that “might” or “could” happen, while presenting no site-specific evidence that any environmental or safety problems were actually occurring anywhere in the GGNRA. It did not adequately analyze negative impacts on San Francisco City parks (and parks in other neighboring communities) if large numbers of people who currently walk in the GGNRA were forced out and into City parks by the new restrictions. The Environmental Impact Statement was fatally flawed.
Supplemental Environmental Impact Statement
In September 2013, the National Park Service released a Supplemental Environmental Impact Statement for a Dog Management Plan in the GGNRA in a tacit acknowledgement that there were significant flaws with the original Draft Environmental Impact Statement. However, this Supplemental Statement did not correct all of the problems SFDOG identified in the Draft Statement. The Park Service still exhibited significant bias against dog walking in this newer analysis, and still had no site-specific evidence of impacts from dogs on the environment or visitor safety anywhere in the GGNRA.
Proposed Final Rule for a Dog Management Plan
In January 2016, the National Park Service released a proposed Final Rule for a Dog Management Plan for the GGNRA. The final rule did not address any of the concerns identified in the SFDOG comments to the Supplemental and Draft Environmental Impact Statements. Indeed, it put even more restrictions on dog walking.
In December 2016, the Park Service announced that it would announce the signing of a Record of Decision for a Dog Rule in the GGNRA in January 2017. This action would have been the final step in the creation and implementation of a Dog Management Plan for the GGNRA. But on January 10, 2017, a few days before the rule was to go into effect, the Park Service announced that they were suspending final approval of the proposed dog rule while the agency investigated staff use of private emails to conduct agency business and to collude with groups who supported the proposed dog rule, along with other irregularities.
These irregularities came to light as the result of a lawsuit filed by SFDOG, Coastside Dog of San Mateo County, Marin County DOG, and Save Our Recreation. The lawsuit would eventually lead to the withdrawal of the proposed Dog Management Plan in October 2017.