Response to updated GGNRA Draft Dog Management Plan
The National Park Service just released a new version of their Draft Dog Management Plan for the Golden Gate National Recreation Area (GGNRA).
After the response to the previous version the NPS said that they'd consider allowing dog access in additional areas and more importantly that they would reevaluate the 'poison pill' provision that enabled changing the rules in the future without further consultation. Additional access was considered and rejected. 'Compliance-Based Management Strategy' has been rebranded as 'Monitoring-Based Management Strategy' and while they've technically dropped the poison pill the language is still pretty dire up to and including year plus closures:
"When the level of compliance is deemed unacceptable based on violations and/or impacts to resources, primary management actions such as focused enforcement of regulations, education, and establishment of buffer zones, time and use restrictions, and SUP restrictions would be implemented. If noncompliance continues, secondary management actions including short-term closures (typically one year or less) would be implemented through the compendium."
That 'typically one year or less' is just such a throw away line, like it's a minor punishment and not 7 dog years or more.
Here are my full comments on the new plan (comment ID 875407-55416/35):
Dear National Park Service,
I commented on the previous Draft Dog Management Plan/ Supplemental Environmental Impact Statement (comment ID: 457979-38106/85) and as requested will focus on the changes made between then and the current draft.
My chief concern with the previous draft was the provision that allowed the NPS to degrade off-leash ‘ROLA’ areas to on-leash or banning dogs entirely without further public consultation. The latest draft has removed this language, but the new ‘Monitoring-Based Management Strategy’ doesn’t strike me as a material improvement.
The compliance section of this strategy begins with focused enforcement of regulations and education. It should stop there. Instead it goes on to mention buffer zones, time and use restrictions, and SUP restrictions and then goes on to short-term closures that are typically one-year or less.
While the previous draft was worse, the prospect of losing access to the limited off-leash areas that will remain after the implementation of this plan for a year or possubly more isn’t a material improvement.
I live in San Francisco and frequently visit the GGNRA with my family, which includes a toddler and well behaved dog. I completely support a reasonable allocation of the available space between visitors who want to bring their dog and visitors who would prefer a dog-free experience.
Given the tone of the plan and the history of the NPS seeking to ban off-leash dog access altogether I cannot help but fear that any provision in the plan to curtail dog access will end up being used.
Please remove the language around further regulating, restricting, permitting and closing the ROLA areas. Focus on enforcement and use your limited resources to handle the minority of irresponsible dog owners rather than closing down access for everyone.
Sincerely,
Robert Ellison
P.S. The sand ladder at fort funston is an unstable and dangerous trail. Introducing leashes would increase the risk of injury to people and dogs alike.
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iD (The Machine Dynasty, #2) by Madeline Ashby
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Flaggermusmannen (Harry Hole, #1) by Jo Nesbø
4/5
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Doctor Who: Harvest of Time by Alastair Reynolds
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Top Dog: The Science of Winning and Losing by Po Bronson
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Inferno (Robert Langdon, #4) by Dan Brown
2/5
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