Help Stop the GGNRA Dog Rule - Submit a Public Comment Today!
Right now, it is critical that people submit comments on the National Park Service's Proposed Rule for Dog Management at GGNRA. If we do not comment, the Park Service will say we agree with the plan. Also, submitted comments will be part of the legal record—critical should this issue go to court (which we think it will).
Comments are due by May 25, 2016 and can be submitted online via the Regulations.gov site -OR- mailed in a letter to:
Proposed Rule for Dog Management
Building 201, Fort Mason
San Francisco, CA 94123
*Be sure to include the RIN-1024-AE16 number on your letter and envelope.
You can send in more than one public comment. So if you think of something you want to add later, just submit another comment that includes the addition.
Send copies of your comments to your federal and county 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. Click here for addresses of San Mateo County and federal officials.
Comment Writing Tips & Talking Points
PERSONALIZE YOUR COMMENTS. In your comments, make sure to include:
- Who you are and where you live.
- What parts of the GGNRA you visit and how often, and what you do while you’re in the GGNRA.
- What benefits you derive from walking with your dog in the GGNRA.
- How the proposed rule will restrict your personal dog walking recreation access and how this will impact your life.
- How the proposed plan will increase congestion on the GGNRA trails and/or beaches that you frequent.
- How banning dogs from your community's trails and beaches will require you to get in your car and drive to other locations--increasing traffic and pollution.
- How the proposed dog walking restrictions will impact your city and county parks--impacts which the National Park Service failed to study as part of the NEPA process.
- Which GGNRA trails and beaches are critical to your community and should be kept open to on-leash and off-leash dog walking. Please be specific.
- Include some of the General and San Mateo County talking points below or craft your own.
GENERAL TALKING POINTS (include those most important to you)
Designation matters. Golden Gate National Recreation Area (GGNRA) was designated an urban recreation area. As such, the National Park Service has a duty to protect the recreational mandate of GGNRA. It is not appropriate for the Park Service to manage GGNRA as a remote, back country wilderness area.
Public input has not been adequately considered or responded to. During the NEPA (National Environmental Policy Act) process, the Park Service has failed to adequately consider and respond to public input and concerns provided by thousands of Bay Area residents, the San Francisco, Marin, and San Mateo County boards of supervisors, and members of Congress.
Failure to document actual site-specific impacts. The Park Service has not provided any evidence that dogs are causing significant impacts on wildlife, plants, or other visitors. Two environmental impact studies have only talked about things that “could”, “might”, or “may” occur, with no evidence the impacts are actually occurring – or have ever occurred – at sites in the GGNRA.
Circumventing the NEPA process by providing a "blank check" to GGNRA's Superintendent. The proposed rule includes a monitoring-based management provision that MUST BE REMOVED from the GGNRA rule for dog management. Under this provision, if people do not comply with the new rule, GGNRA’s Superintendent would have the discretion to completely ban recreational dog walking from any area without going through the required public comment period. There is no criteria for what level of non-compliance would trigger a change or how it is recorded. Furthermore, the rule gives GGNRA's Superintendent the power make closures in anticipation of impacts by dogs BEFORE they even occur.
Failure to study impacts on city, county, and state parks. The Park Service has failed to study their proposed rule's impacts on city, county, and state parks. Right now dog walking (both on-leash and off-leash) is only allowed on 1% of GGNRA lands. Cutting this access by 90% would place a significant strain on neighboring city, county, and state parks. The Park Service has not studied this displacement issue.
San Mateo County Talking Points
On-leash dog walking areas at all San Mateo County GGNRA sites would be reduced by 50-65%. The significant and arbitrary reduction of on-leash dog walking trails at Rancho Corral de Tierra, Sweeney Ridge, Mori Point, Milagra Ridge will have a dramatic negative impact on the surrounding communities. Impacts include increasing traffic, reducing opportunities for healthy recreation, restricting access for women, seniors, and others who may not feel safe hiking without their dog, burdening smaller adjacent parklands, etc. Neighboring communities have walked their dogs on these lands for decades and in many cases have been the stewards of these lands. Cutting off community access goes against the main reason why GGNRA was established.
San Mateo County is the only county that did not receive any off-leash areas under the proposed rule. Under this provision, people in San Mateo County would have to drive to another county to have an off-leash experience with their dog. The Park Service has failed to provide a reason for this access inequity. With 4,000 acres and its long history of off-leash dog walking, part of Rancho Corral de Tierra should be designated for off-leash dog walking. The baseline that the National Park Service used for dog walking when it took control of Rancho was incorrect because it ignored the fact that the site had been used for off-leash dog walking for decades. Having legally designated off-leash at Rancho will reduce unsanctioned off-leash dog walking and improve the visitor experience.
Under the proposed rule, people walking more than three dogs (this is for everyone, not just professional dog walkers), would no longer have access to San Mateo County GGNRA lands. San Mateo County is the only county that did not receive any trails for people walking up to six dogs. These additional dog walking restrictions were just sprung on the public in late February when the proposed rule was released. The Park Service has failed to provide a rationale for this provision, which will place a greater strain on county, city, and state parklands.
*Click here for the full list of proposed dog walking recreation restrictions throughout the entire GGNRA--Marin, San Francisco, and San Mateo counties.