Take Action to Stop the 2019 Superintendent’s Compendium!
On the Friday before Labor Day weekend, the GGNRA released a Superintendent’s Compendium that attempts to implement parts of the withdrawn Dog Management Plan—but without a public input process. If the National Park Service gets its way, on September 30, 2019 we will lose valuable dog walking trails and access at Rancho, Mori Point, and Milagra Ridge (see the maps below). These aren't the only worrying changes for dog walking recreation. NPS is misusing the Superintendent’s Compendium to erode dog walking recreation throughout the GGNRA, including Fort Funston. Below is a full list of our concerns.
PLEASE TAKE ACTION
Submit an official comment before Sept. 30th, objecting to the compendium to firstname.lastname@example.org and cc the GGNRA Superintendent (Laura_Joss@nps.gov), Western Park Service Regional Director (email@example.com), GGNRA Community Liaison Amy Brees (firstname.lastname@example.org), and your local, state, and federal representatives.
These are the most important points to make:
1) The GGNRA cannot change parts of the 1979 Pet Policy, cannot implement parts of the withdrawn Dog Management Plan, and cannot make major changes to recreational access including the status of our dog walking trails via a Superintendent's Compendium. It is a misuse of the Compendium process.
2) All changes to the status of dog walking access must be removed from the 2019 Compendium, including removing Exhibits 37-39 (maps) which make major changes to dog walking access at Rancho, Mori Point, and Milagra Ridge—changes that NPS has not acknowledged in the Compendium’s narrative or changes table. Dog walking in the GGNRA must be managed by the 1979 Pet Policy and NPS Dog Policy.
3) The GGNRA must keep the terms and definitions of dog walking the same in the 2019 Compendium as they are in the 2017 Compendium, or, better yet, the 1979 Pet Policy.
4) GGNRA Commercial Dog Walking Permit process must be extended to San Mateo County.
5) The public comment period for the 2019 Compendium should be extended to 90 days.
6) Please also make specific comments about the GGNRA sites you visit. Details about how this compendium impacts those sites are below.
PROPOSED CHANGES TO DOG WALKING ACCESS IN SAN MATEO COUNTY
*Note: NPS has not acknowledged any of these major changes in their Compendium narrative or changes table. They have not provided any explanation for this loss of dog walking access.
What is a Superintendent’s Compendium?
A Compendium is designed to allow a site Superintendent to make relatively minor changes in management policies in response to changing conditions, e.g., closing a part of a trail that has eroded away, or addressing how to deal with new technology, like electric scooters. Compendiums are not supposed to be used to make larger changes or ones that require a public process. The GGNRA is misusing the Compendium process to make some significant and controversial changes to dog walking in the GGNRA.
Details about the 2019 GGNRA Superintendent’s Compendium
The 1979 Pet Policy is the historical cornerstone of where dogs may walk in the GGNRA yet neither the 2017 nor the 2019 Compendium adequately explains where dog walking is permitted under the 1979 Pet Policy. Indeed, the 2019 Compendium doesn’t even mention the 1979 Pet Policy.
There are multiple locations in the 2019 Compendium that will create a change in dog walking status that have not been subject to public review and input:
Rancho Corral de Tierra (San Mateo County): Significant loss of dog walking acreage and trails not included on GGNRA's trail map.
Milagra Ridge (San Mateo County): Dog walking banned on the Milagra Creek Overlook Trail, part of the Milagra Ridge Trail, and part of Milagra Ridge Road. According to Exhibit 37, people with dogs will no longer be able to access Milagra Ridge from the park site’s southern entrance.
Mori Point (San Mateo County): Dog walking banned on the Mori Bluffs oceanfront trail and the Timigtac trail.
Fort Funston in San Francisco will lose a portion of a public parking lot and space designated for off-leash dog walking to “administrative and operational” uses by GGNRA staff, San Francisco Unified School District, and a park partner, the Golden Gate National Park Conservancy.
Additionally, the GGNRA has identified new “signed sensitive restoration areas” at Fort Funston without providing specific information if there are any specific threatened or endangered species that need protection. Again, this closes down more off leash dog walking space there without public review and input.
These unilateral moves to close access at Fort Funston could set a precedent that other areas in the GGNRA can be closed with the addition of a sign that reads “sensitive restoration habitat” or because of an “administrative requirement” without a robust public comment process.
They want to require dogs to be on-leash in all of the stairwells at Ocean Beach.
The GGNRA identified more Voice Control areas at Crissy Field in their overall summary but it’s unclear to us where this increase has occurred.
Marin locations Muir Beach, Rodeo Beach, and Oakwood Valley will have closures (some seasonal) in central parts of popular off-leash walking areas that cannot be fenced-off or easily avoided
With these changes, the GGNRA is making changes to the 1979 Pet Policy without adequate public review and input.
In the 2019 Compendium, the GGNRA explicitly bans commercial dog walking at the San Mateo County GGNRA sites without adequate public process. Commercial dog walkers are able to get permits to walk in SF and Marin, but not in San Mateo County.
In the 2019 Compendium, the GGNRA has presented new definitions that will affect dog-walking management now and into the future.
These definitions are new and were neither in the 1979 Pet Policy nor in the 2017 GGNRA Compendium. The public has not had an opportunity to adequately review and provide input with these new definitions. We are concerned that the GGNRA has changed the definitions of Voice Control, Managed Dogs, and Unmanaged Dogs in order to restrict dog walking in the GGNRA in ways that are inconsistent with the 1979 Pet Policy. These changes also mirror those made in the Dog Management Plan that the Park Service withdrew in 2017. The GGNRA is trying to use the Compendium to implement portions of its withdrawn Dog Management Plan.
DEFINITION OF MANAGED DOGS:
MANAGED DOGS in the 1979 Pet Policy: Those dogs under control of their owner at all times. This control may be by voice or by leash. The criterion is that the dog may not harass any person or animal.
MANAGED DOGS in the 2019 Compendium: means a dog that is under the control of its owner or handler at all times through the use of a leash not in excess of six feet in length, or by Voice Control in those designated areas open to off leash dog walking, such that the dog does not annoy, harass, harm, or threaten any person, animal, or harm park resources.
Changing the definition of “Managed” dogs adds unnecessary details.
DEFINITION OF UNMANAGED DOGS:
UNMANAGED DOGS in the 1979 Pet Policy: “Unmanaged dogs and cats [are]: 1) Feral dogs and cats. Those dogs and cats having escaped domestication and become wild. 2) Those dogs not supervised by their owners.
UNMANAGED DOGS in the 2019 Compendium: means that a dog that annoys, harasses, harms or threatens a person in a manner that a reasonable person would find annoying, harassing, harmful, or threatening, or that annoys, harasses, harms, or threatens another animal or harms park resources. This includes threatening behavior by dogs towards people or other animals such as snarling, snapping, chasing, charging directed and sustained barking at, or uninvited taking or attempting to take food from another visitor or pet.
Changing the definition of an “unmanaged” dog to criteria determined by a “reasonable person” is a subjective. For example, when two dogs roughhouse, they show their teeth and make all kinds of noises that sound aggressive. A “reasonable” person with experience with dogs knows they’re playing. But a non-dog person, who might otherwise be quite “reasonable,” might think they were fighting and report aggressive behavior. Park Rangers do not have adequate training to understand dog behavior.
DEFINITION OF VOICE CONTROL:
VOICE CONTROL in the 1979 Pet Policy: This is a flexible system. The success of such a system is dependent upon the willingness of visitors and local residents to cooperate with GGNRA personnel, and the willingness of GGNRA personnel to manage dogs, people and wildlife situation; to enforce regulations and to cite violators.
VOICE CONTROL in the 2019 Compendium: means a dog that is within earshot and eyesight of its owner or handler and that responds immediately to commands to return to leash when called or signaled. The owner or handler must demonstrate this ability when requested to do so by an authorized person. A dog not meeting these requirements will be considered running at large under 36 CFR, Section 2.15(d).
It is not clear what “responds immediately” means – One call? Within 10 seconds? Within 20 seconds? But perhaps most disturbing is that this definition designates a dog that does not have immediate recall—whatever that means – as “running at large.” The regulation cited in this new definition, 26 CFR, Section 2.15(d), is clearly intended to refer to dogs that are running wild, with no owner nearby, for example, a dog who has gotten away from home. This section states that “Pets running-at-large may be impounded, and the owner may be charged reasonable fees…” That makes sense if a dog has gotten away from home and is running wild. But it makes no sense if an owner is standing 20 feet away from the dog. Yet this new definition could empower Park Rangers to impound dogs and charge owners fees if the Ranger subjectively doesn’t think the dog came back fast enough.
The three sets of documents within the 2019 Compendium have inaccuracies and are not consistent: Dog walking trails that are being eliminated in San Mateo County are only acknowledged in the fine print on the Exhibit maps. The changes are not disclosed in the Compendium narrative or its comparison table; the maps with the Compendium are different than the maps used in the GGNRA’s Dog Management Plan.