Position Statement: Proposed GGNRA Dog Management Plan

The Golden Gate National Recreation Area (GGNRA)’s Draft Dog Management Plan, which was released in January 2011, is overly-restrictive and represents a major departure from the current, balanced use of the park. We encourage all dog-lovers to get involved by attending one of the GGNRA’s public meetings or sending a letter to the GGNRA with their concerns.

Summary

Currently, off-lead areas are restricted to less than 1% of park land. The plan would drastically reduce the space available to off-lead dog recreation and prohibit any sort of dog walking, including on-lead, on new lands unless an unlikely exception is made by the park service.

We believe that responsible dog ownership is entirely compatible with environmental stewardship. Thousands of guardians and their dogs use the park each day. Most are responsible and keep dogs under control. The community, including dog walking groups and the SF SPCA, has come together to create numerous resources and initiatives to encourage responsible dog guardianship. By encouraging responsible guardianship – and enforcing the law against the small minority that are irresponsible – we can protect the GGNRA’s environment without the need to overcrowd dogs into an ever-smaller portion of the park.

For thirty years, the current Pet Policy has served the park, its users and the environment well. The GGNRA remains one of the best-preserved and much-beloved collections of open spaces in a major urban area. We readily accept that this plan should evolve over time to adapt to a changing population, but the GGNRA’s proposal represents a major departure from the current successful model and is overly-restrictive to dog guardians.

We believe we should be seeking ways to make the San Francisco Bay Area friendlier to dog and cat guardians. The GGNRA’s proposal is a step backwards for animal welfare in the Bay Area.

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What You Can Do

The GGNRA is accepting comments for 90 days on its draft management plan. Here’s what you can do to protect open space for dogs and their guardians:

  • Write a letter to urge GGNRA to amend the plan to provide more off-lead recreation areas for dogs, open new lands to dog walking, engage with community organizations to promote responsible dog guardianship and take a more balanced approach to enforcement.

Mail comments to:
Frank Dean
General Superintendent
Golden Gate National Recreation Area
Building 201, Fort Mason
San Francisco, CA 94123-0022
Or, email comments here: http://parkplanning.nps.gov/projectHome.cfm?projectId=11759

  • Attend one of the public meetings to comment.
  • Get involved with Eco-Dog to encourage responsible dog guardianship. Find out more at www.eco-dog.org.

Hurry! The comment period has been extended to May 29, 2011.

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Background and History

Early 1970s – The Golden Gate National Recreation Area (GGNRA), including land in San Francisco, Marin, and San Mateo Counties, was created as an urban recreational park in 1972. GGNRA was formed "to expand to the maximum extent possible the outdoor recreational opportunities available in this region" and it was supposed to be part of "new national urban recreational areas that will concentrate on serving the outdoor recreational needs of the people of the metropolitan region." Land continues to be added to the GGNRA.
Late 1970s – Local citizens expressed concern when federal regulations prevented traditional activities in areas now managed by the GGNRA, and dog owners lobbied to relax federal off-leash rules. In response, the GGNRA Citizens’ Advisory Committee held extensive hearings, which resulted in the 1979 Pet Policy. The Pet Policy outlined off-leash rules and defined specific off-leash areas in San Francisco and Marin Counties.
1983 – Congress mandated that all national parks must abide by the same regulations, but created the option of special rules for exceptions within individual parks. Special rules were created in the GGNRA to allow bicycles on trails and hang gliding at Fort Funston. Although the GGNRA superintendent requested a special rule for off-leash activity, there is no record of a reply. The GGNRA continued to abide by the Pet Policy until 2001.
1990s – The GGNRA began selectively closing coastal areas. In some cases the closures applied only to off-leash activity, and in other cases areas were fenced off and no activity was permitted. These closures included the coastal bluffs at Fort Funston, Ocean Beach from Stairwell 21 to Sloat, West Beach at Crissy Field, and Land’s End, among others.
2000 – The GGNRA closed another 12 acres of coastal bluffs at Fort Funston. The dog-owner community reacted and filed a lawsuit to prevent the closure. A federal judge ruled that the U.S. Park Service is required to issue a public notice and allow comment before making a highly controversial change. The Park Service issued a notice, collected comments, and ultimately closed a larger area than initially proposed – and closed it permanently rather than seasonally.
2001 – The GGNRA began enforcing the leash law from the 1979 Pet Policy in all areas of the park. In response to a significant public outcry, the GGNRA began the long process of creating a special rule (see "1983" section above).
2004/2005 – Three individuals from the Crissy Field Dog Group challenged the leash citations they received at Crissy Field and appeared before the same judge who had ruled that the 12-acre closure in 2000 was illegal. The Court again ruled that the GGNRA cannot make a highly controversial change without public notice and comment, and dismissed the citations. The GGNRA ceased enforcing the leash law in areas covered by the 1979 Pet Policy (see "Late 1970s" section above).
2006 to 2010 – In 2006, the GGNRA established a Negotiated Rulemaking for Dog Management committee. After a two-year period of intense negotiations, stakeholders failed to reach a consensus. However, the GGNRA Dog Caucus did submit a Proposed Dog Management Plan at the last rulemaking committee meeting regarding various off-leash/ on-leash and no-dog options.
2011 – The GGNRA released its Draft Dog Management Plan which drastically limits off-leash areas in the park and in some cases prohibits access for dogs altogether, even on-leash.

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Analysis

We believe that the recommendations in the GGNRA Draft Dog Management Plan are overly-restrictive and represent a major departure from the current, balanced use of the park.

Currently, off-lead activity is restricted to less than 1% of the park’s land. This proposal would drastically reduce the land available for off-lead recreation. The plan is difficult enough in San Francisco and Marin counties, where beloved areas like Fort Funston and Muir Beach will be restricted or off-limits to off-lead dogs. Worse, the plan leaves San Mateo with no GGNRA land that permits off-leash use.

In addition, the proposal that any new lands added to the GGNRA allow no dog walking of any sort (even on-lead) unless a specific exception is made is draconian and ignores the needs of future generations of dog guardians as the region’s population grows.

The GGNRA’s proposal in the event of "noncompliance" with its rules are heavy-handed and do not engage the community to find solutions. The proposal indicates that if noncompliance is observed, "…the area’s management would be changed to the next more restrictive level of dog management. In this case, ROLAs [regulated off-lead areas] would be changed to on-leash dog walking areas and on-leash dog walking areas would be changed to no dog walking areas. This change would be permanent." This approach unnecessarily punishes responsible dog guardians for poor behavior by a small minority. Further, the idea that no area could ever be changed to less-restrictive rules, such as when compliance is good and environmental protection needs are reduced, is one-sided and unfair.

Responsible dog guardianship is entirely compatible with environmental stewardship.

We recognize there are guardians whom we would like to be more responsible with their dogs. But they are few in number – incidents involving dogs in GGNRA are less than 4% of all incidents in the park. Penalizing all dog guardians for the behavior of a truly small minority is not the right approach.

We have worked hard as a community to educate and encourage responsible dog guardianship. Examples include:

  • Community volunteer efforts to stock dog poop bags and other amenities
  • Launch of the Eco-Dog website (www.eco-dog.org), a community-funded online resource encouraging and educating about responsible guardianship
  • Community educational collateral and workshops distributed and conducted by local dog walking and advocacy groups
  • Community policing and "peer pressure"
  • Low-cost and free dog training classes at the SF SPCA, Marin Humane Society and Peninsula Humane Society/SPCA.

We believe this collaborative, educational approach is best and encourage the GGNRA’s partnership in these endeavors as a viable alternative to simply closing areas to dogs or placing new restrictions.

The GGNRA’s goal has always been to bring the park into compliance with a federal rule (36 CFR 2.15) which bans off-leash dog walking in national parks. But the San Francisco Bay Area has a unique culture, history and community. Instead of trying to force the GGNRA to look like every other national park, the GGNRA board should respect the citizens’ commission of 1979 and the unique history of the land.

The proposal also ignores the needs of dog guardians with limited transportation options or with special needs, such as wheelchair access. As evidenced by the work of organizations like Pets Are Wonderful Support who support low-income disabled and senior pet owners and document the health benefits of the human animal bond, this proposed plan would limit access for an entire class of people who have few other options and depend on the current off-leash areas to keep their dogs exercised and healthy.

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Conclusion

We believe we should be seeking ways to make the San Francisco Bay Area friendlier to dog and cat guardians. The GGNRA’s proposal is a step backwards for animal welfare in the Bay Area. We look forward to working with the GGNRA Board to modify its proposal to be more balanced and friendlier to dog guardians.

Sources

  1. GNRA Draft Dog Management Plan/EIS, January 2011, Executive Summary page xiii-xiv.
  2. Source: GGNRA Data 2001-2006

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