You are hereNew!! Suggested Comments on GGNRA SEIS

New!! Suggested Comments on GGNRA SEIS

By sally - Posted on 09 January 2014

Here are some suggestions for comments you can make about the GGNRA's plan to severely restrict where you can walk with your dog.

Deadline to Submit Comments: February 18, 2014, 11 pm PST

The Golden Gate National Recreation is currently taking public comment on a proposed Dog Management Plan that will cut by about 90% where you can walk with your dog off-leash compared to where you can walk now. An earlier version of the plan, contained in a Draft Environmental Impact Statement or DEIS, was released in 2011. Public comment was overwhelmingly (at least 3:1) opposed to the plan. The GGNRA announced that, in response to the comments, they would rework the plan and release a Supplemental EIS. We expected significant change, but when the SEIS was released in September 2013, it contained only minor changes.

Please take the time to send in a comment on the SEIS’ plan to severely cut where you can walk with your dog in the GGNRA.

Here are some suggestions for what you can say in your comment.

Always Include:
1) Who you are. Where you live. What parts of the GGNRA you visit and how often. What you do while you’re in the GGNRA. What benefits you derive from walking with your dog off-leash in the GGNRA. What will be the impact on your life if GGNRA restrictions take effect and whether nearby city parks are an adequate replacement. List any clubs or organizations to which you belong, especially any groups like the local Sierra Club that support GGNRA restrictions. Be sure to say that you disagree with the positions of the executive boards of these groups, and point out that these local boards do not speak for their members and they do not speak for you.

2) If you submitted a comment in 2011 for the DEIS, look at the SEIS Executive Summary or information on specific parks you mentioned to see if your comments were included or if any substantive changes to the preferred alternative were made based on what you said:

Essential Points to Make:
1) Oppose the Preferred Alternative because it is too restrictive. There is no justification in the SEIS for major changes. Support formalization of the 1979 Pet Policy PLUS off-leash access in San Mateo County and on new lands that the GGNRA acquires in the future.

2) Oppose fences to surround or delineate any off-leash area in the GGNRA. The SEIS Preferred Alternative proposes to install fences at the eastern and western ends of Middle Beach at Crissy Field, around the proposed off-leash area at Fort Mason, and around the proposed off-leash areas at Fort Funston. Fences will make off-leash areas feel like pens and visitors using them will feel unwelcome. Fences secure enough to keep small dogs in will hinder movement of wildlife. If fences are not secure enough to keep small dogs in, why have them?

3) Oppose the Monitoring-Based Management Strategy that replaced the DEIS’ Compliance-Based Management Strategy. The MBMS is still based largely on compliance with leash restrictions. Although the SEIS says the MBMS will consider impacts on resources from non-compliance, it still is primarily focused on mere compliance with leash laws and the GGNRA can consider changing off-leash status for non-compliance even if no impacts on resources or other visitors are reported.

Optional Points to Make (Choose as many or as few as you want):
1) SEIS did not adequately consider comments to the DEIS from dog walkers and appears to have dismissed nearly all of them. There is no information in the SEIS about why these comments (e.g., negative impacts on community and human health from off-leash restrictions) were dismissed and not considered in the development of the preferred alternative. The SEIS lists many, many comments from people opposed to dog walking and very few from people who support dog walking. The SEIS copies, without change, entire sentences and text from the DEIS about studies of dog impacts, especially on wildlife and birds, even though DEIS comment showed that this text was inaccurate, misleading, and misrepresented what the studies actually said. Yet the SEIS copied it word for word. Comments supporting dog walking were not used to argue that there should be more off-leash restrictions, while comments opposing dog walking were used to argue for more restrictions.

2) SEIS still lists impacts that “might”, “can,” or “could” happen, while providing no site-specific evidence that any of those impacts are occurring now or have ever occurred in the GGNRA. This point was raised in DEIS comments, and should have been addressed but was not. For example, the SEIS admits the GGNRA has not conducted site-specific studies at GGNRA sites to document impacts from dogs on vegetation and soils (p. 373). Yet they also claim these impacts are currently occurring in the GGNRA and therefore dog walking must be curtailed to stop them (e.g., p. 97). Without site-specific studies, there is no proof impacts are occurring.

3) SEIS says that, during the last six years, NPS staff did extensive literature searches to look for reports of impacts from dogs in other parks. In that same time, they could easily have conducted the site-specific studies that might have shown whether or not impacts are occurring in the GGNRA. Yet they chose not do them.

4) SEIS admits there are few scientific, peer-reviewed studies that show impacts from dogs (e.g., on vegetation and soils, p. 375), so they cite anecdotal observations of impacts made by NPS staff. However these anecdotal claims have no context – how frequent were they, how serious, etc. – and cannot be used to set policy. An SEIS is supposed to be based on science, not anecdote. The SEIS also says it relies on the “best professional judgment of NPS staff” to determine impacts from dogs and their importance when there are no scientific studies of impacts in other parks available (e.g., p. 396). NPS staff have demonstrated a long-standing, strong bias against dog walking, and the SEIS should not depend largely on their biased judgment and anecdotes for “proof” that impacts from dogs are currently occurring.

5) SEIS says there has to be a no-dog area at all sites where off-leash dog walking is allowed. For example, the SEIS says Muir Beach is too small to have both an off-leash and a no-dog area, so therefore there cannot be an off-leash area at Muir Beach (p. 113). There’s no similar idea that sites that are no-dog also have to include off-leash areas. This shows the inherent unfairness of the SEIS.

6) SEIS never gives results of public comment on the DEIS (neither does the “Response to DEIS Comments by the GGNRA” document on the GGNRA website). They say they received over 4,700 comments, but never say how many opposed restrictions on dog walking and how many supported them. The SEIS says: “NPS received many public comments complaining that dog use precluded their enjoyment of areas.” (p. 100). But there’s no indication of how many negative comments were actually made. Are they from a small minority or are they widespread? An independent analysis of the DEIS comments showed that the vast majority (at least 3:1) supported dog walking. This is not reflected in the SEIS.

7) SEIS still does not adequately analyze impacts on nearby parks of the Preferred Alternative. This analysis was requested by public comment to the DEIS and by the San Francisco Board of Supervisors in 2011. The SEIS claims that, because some off-leash space will still available in the GGNRA, even though much smaller, most people will continue to walk their dogs there and not move to nearby city parks. It also claims that because people will still be able to walk their dogs on-leash at some sites, most will continue to walk in the GGNRA. No evidence is given to support either assumption. The SF Supervisors and dog walkers asked for a thorough analysis. What we got was cursory at best.

8) SEIS data still does not support claims that there are major safety problems from dogs that require off-leash restrictions. The total number of dog bites or attacks from 2008 to 2011 (four years) was 95 (p. 21). Even if this number is undercounted and should be tripled or quadrupled, it still represents a miniscule portion of the millions of dog visits each year to GGNRA sites. Even the total number of dog-related incidents (nearly all of which were for having dogs off-leash where they weren’t supposed to be) from 2001 to 2011 – 4,932 – represent a tiny fraction of the million dog visits each year (p. 252). The vast majority of incidents (at least 89%) in the GGNRA involve people without dogs, including murder, rape, robbery, drugs, and larceny. People are the safety problem in the GGNRA, not dogs.

9) SEIS still does not consider management tools that could mitigate alleged impacts from dogs in the No-Action Alternative. For example, dog training classes, dog-horse workshops, and poop cleanup days could all mitigate concerns about dog safety and pathogens in feces that are used to argue that the No-Action Alternative will not work and therefore the GGNRA must restrict off-leash access.

10) SEIS misrepresents the enabling legislation and the reason for the founding of the GGNRA. It says the GGNRA’s purpose is to offer a “national park experience to a large and diverse urban population” (p. 1). However, the enabling legislation says the purpose of the GGNRA is to “provide for the maintenance of needed recreational open space” (Enabling legislation, first paragraph). The SEIS notes, in a negative way, that “In many parts of the San Francisco Bay Area, residents have come to expect that GGNRA lands will be available for dog walking and other recreational activities.” (p. 19). Yet that is exactly what Congress intended when it created the GGNRA in 1972 – “The objective of [the creation of the GGNRA] is to … expand to the maximum extent possible the outdoor recreational opportunities available to the region.” (H.R. Rep. No. 1391, 92nd Congress, 2nd Session, 1972)

11) SEIS will not allow off-leash dog walking on any trail anywhere in the GGNRA. The only site-specific consensus agreement to come out of Negotiated Rulemaking was to allow off-leash dog walking on a trail in Oakwood Valley in Marin. This was included in the DEIS. However, it was removed from the SEIS (Oakwood Valley is now proposed to be on-leash only) because the GGNRA decided that there would be no off-leash dog walking on any trail. All the money and work that went into Negotiated Rulemaking was wasted.

12) SEIS still will not allow any off-leash dog walking on New Lands acquired by the GGNRA in the future, even if dog walking occurs has traditionally occurred there.

13) SEIS cites several surveys of visitor use and visitor satisfaction, including two done in 2011 in response to DEIS comments, that were so poorly done that their results are essentially meaningless. A 2008 visitor use survey at Ocean Beach and Crissy Field used people who intercepted people at these sites and asked about their park usage. However, the “interceptors” were observed by several people to actively avoid talking to people walking with dogs, hopelessly skewing their results. A 2011 visitor use survey at Fort Funston and Muir Beach, done specifically in response to DEIS comments, only counted people as walking dogs if they had a leash in their hand. People walking with a friend and the friend’s dog were not counted as a dog walker (because they did not have a dog of their own with them), even though they were only walking there to walk with the friend’s dog. A 2011 Visitor Satisfaction Survey was so confusing respondents didn’t know if they were being asked about their satisfaction with current conditions at GGNRA sites or with the severe restrictions proposed in the DEIS.

14) SEIS still describes the visitor experience as focused on people who don’t want to be around dogs. This criticism was made of the DEIS too and apparently ignored.

NOTE: When you talk about your dog being off-leash in the GGNRA, be sure to add the words “under voice control”, to indicate you are a responsible dog owner/guardian.

NOTE: You can submit more than one comment if you want or if you think of additional things you want to say. There is no maximum number of comments any individual can submit.

NOTE: It’s better to not just say: “I love my dog and I hate what you want to do.” Comments like that will be ignored. However, if you say that as part of more specific comments about the SEIS (like those above) or about conditions in the GGNRA as you observe them, your comments will be considered “substantive” and the GGNRA will have to record and respond to them. It is also better to not just quote other people: “I agree with SFDOG’s comment” since that will not be considered a substantive comment. However, if you repeat comments that were made by others, such as listed above, they will all be counted as a substantive comment.

Continue to periodically check and other dog websites, such as, as we will be updating our suggested comments as more information comes to us. If you see something new, you can always send in an additional comment to address it.

MAKE COPIES of your comment and send them to federal, state and local officials. Include a handwritten note on the copy to any official, e.g., “This is really important to me. Please help.” The personal touch helps your letter be noticed.

Comments can be made online at:

Or mailed or hand delivered to:
Superintendent, Golden Gate National Recreation Area
Fort Mason, Building 201
San Francisco, CA 94123
Attn: SEIS.

Deadline to Submit Comments: February 18, 2014, 11 pm PST

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