I Thought He Came With You is Robert Ellison’s blog about software, marketing, politics, photography, time lapse and the occasional well deserved rant. Follow along with a monthly email, RSS or on Facebook. About 7,250,102,787 people have not visited yet so it might be your first time here. Suggested reading: Got It, or roll the dice.

GGNRA Victory

The San Francisco Chronicle reports that the National Park Service's effort to ban dogs from much of the GGNRA is dead:

"The National Park Service pulled the plug Thursday on a 14-year-long process for restricting dog access in the 80,000-acre Golden Gate National Recreation Area, 10 months after revelations emerged that agency officials had improperly corresponded about the process from their personal email accounts."

I've been fighting this for over six years. Some highlights from 2011, 2013 and 2016.

GGNRA Dog Management Round 3

GGNRA Dog Management Round 3

Today is the last day to comment on the latest version of the dog management plan for the Golden Gate National Recreation Area. I've just squeaked in under the wire. My main concern is that the National Park Service is sneaking in provisions that will allow them to further restrict access over time. The specific pros and cons of the rules for each site are less important than preserving the GGNRA as a recreation resource for everyone over time. I'm not a militant dog person - I think that there should be dog free beaches for people who prefer to not have dogs around for instance. Much of what is in the plan is reasonable. I just don't trust the NPS to stop here.

If you agree check saveoffleash.com to see what you can do to help push back on this.

Here's my full response to the NPS:

Dear National Park Service

I am writing to provide my feedback on the latest version of the proposed rule changes for dog walking in the Golden Gate National Recreation area (RIN: 1024-AE16). I also commented extensively on the first and second round and so will limit myself here to a few key points.

My primary concern with the new rules is the provision for the superintendent to further limit or remove access based on the following language:

"If primary management actions do not sufficiently address the problem, the superintendent would implement secondary management actions. Examples of secondary management actions may include, but are not limited to increased buffer zones, and additional use restrictions (e.g. limiting the number of dogs off-leash at any one time with one dog walker, requiring tags or permits for accessing Voice and Sight Control Areas, or short or long-term, dog walking area closures)."

I feel that the tone of the proposed rule changes suggests that the National Park Service would just prefer to have the same set of regulations system wide and shut down off leash access to the GGNRA. Regardless of how reasonable or unreasonable the new rules are initially it feels like excuses will be found to whittle down access over time. Enforcement should be limited to individuals who violate the rules and not to shutting down access for everyone. I cannot support the rule changes while it contains this provision.

My family lives in San Francisco and we regularly visit Fort Funston, Crissy Field, Rodeo Beach and Hill 88 (Marin Headlands) with our well behaved dog. We occasionally visit Ocean Beach, Sweeney Ridge and other GGNRA locations.

Given our use of the GGNRA I feel that the plan has improved considerably compared with the previous two versions. My chief remaining concern is the Sand Ladder trail at Fort Funston. Unless you are contemplating improvements to the trail I do not feel that this is safe for on leash walking and it should be maintained as an off leash trail for the safety of dogs and walkers alike.

In the Marin Headlands we often walk the loop up the Coastal Trail to Hill 88 returning to Rodeo Beach via Wolf Ridge and the Miwok Trail. The proposed leashed access to a portion of the Coastal Trail and Old Bunker Road is much shorter. I would love to still be able to hike the Hill 88 route with our dog (preferably off leash, but on leash would be better than nothing).

Sincerely

Robert Ellison

(Tracking number 1k0-8pu0-jdnh)

(Previously, Previously)

Response to updated GGNRA Draft Dog Management Plan

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.

--

(previously, previously)

Sweeney Ridge

Sweeney Ridge, starting from Skyline College and walking up to the Portola Expedition Monument and back again.

(Google Earth KML)

Hike starts at: 37.62864, -122.463666.

GGNRA Dog Management Plan Update

GGNRA Dog Managemnet Plan Update

I love it when making some noise works. The NPS is pushing its dog management plan back a year to incorporate the feedback from the current draft. A couple of encouraging considerations mentioned in the most recent newsletter are:

Evaluating additional access for dog walking, both on leash and under voice control.

Revising the compliance based management strategy by including natural and cultural resource monitoring, removing automatic triggers and restrictions, and incorporating additional education and enforcement.

So at the very least this looks like they’re walking back the “poison pill” provision that would allow the NPS to change the rules without further consultation. Won’t know how good or bad the changes are until the new DEIS is published later this year but at least the NPS is listening.

Response to GGNRA Draft Dog Management Plan

On Friday the National Park Service published their GGNRA Draft Dog Management Plan which is now open for public comment until April 14, 2011. The Golden Gate National Recreation Area encompasses over eighty thousand acres of Marin, San Francisco and San Mateo counties. In San Francisco GGNRA managed lands include Baker Beach, Crissy Field, Fort Funston and Ocean Beach. If you care one way or the other about dog access to the GGNRA please take the time to review the plan and send in your feedback. I’ve reproduced my comments in full below.

My family lives in San Francisco and owns a dog. Many of the places we regularly go for walks are in the GGNRA. I fully accept that dogs can cause trouble and even danger and that there should be areas in the park that are free of dogs. Dog owners are a large user group though and I’m concerned that the NPS is going too far. If you walk your dog in the GGNRA here’s why you should be concerned:

The plan significantly curtails off-leash dog walking. For example, Fort Funston could go from this (red shaded area is off-leash, click for larger version):

Fort Funstong - Current Dog Access

To this (yellow shaded area is off-leash):

Fort Funston - NPS Proposed Dog Access

Worse than any of the proposed immediate changes is that the new off-leash is different from the old off-leash. The plan creates ‘Regulated Off-Leash Areas’ or ROLAs. A key part of the ROLA definition (PDF) is:

“ROLA areas are subject to adaptive management as identified in each alternative. Subject to monitoring, an area can be changed from ROLA to on-leash or no dogs if compliance is not achieved.”

In other words, despite the two thousand plus page dog management plan we’re being asked to accept that the NPS can revoke access in the future without further consultation. The ‘adaptive management’ described in the plan would use NPS maintained statistics to downgrade off-leash to on-leash to no dogs at all and explicitly rules out ever moving any area in the opposite direction.

Here are the comments I’ve submitted to the NPS (comment ID: 457979-38106/85):

General Comments

My family owns a dog and lives in San Francisco. We visit the GGNRA at least once a week. The Draft Dog Management Plan would reduce our enjoyment and use of the park considerably.

In the plan the enabling legislation for the GGNRA is quoted: “In order to preserve for public use and enjoyment certain areas of Marin and San Francisco counties, California, possessing outstanding natural, historic, scenic and recreational values and in order to provide for the maintenance of needed recreational open space necessary to urban environment and planning, the Golden Gate National Recreation Area is hereby established”. The plan also discusses the long history of off-leash dog access before and after the creation of the park.

Because open space is so limited in San Francisco, and because the GGNRA controls the entire coastline I strongly support continued access to provide reasonable exercise and recreation for dogs and their owners.

I’m very concerned about the tone of the plan and some of the specific provisions.

The objectives listed in the executive summary all relate to controlling, reducing and restricting dog access. Given the park’s charter to provide ‘public use and enjoyment’ and ‘needed recreation open space’ an important objective should be to preserve sufficient space for off-leash dog access.

The plan exhaustively lists real and theoretical issues related to dog access however there is no comparable section discussing issues with prohibiting or restricting dog access. These include wasting limited park resources on restricting responsible dog owners rather than cautioning the irresponsible, forcing dog owners to travel further to take their dogs for a reasonable walk and increasing the likelihood of aggression by concentrating dogs in increasingly small designated areas.     

The plan also continually discusses dog access in the context of park-wide regulations preventing any off-leash dog walking. San Francisco donated properties to the GGNRA on the proviso that traditional recreation would be maintained. The tone suggests that leash-free access was a mistake, and that the park service is begrudgingly fulfilling the park’s mission only when forced to do so. I’d have much more confidence in the process if the plan started from the position of accepting a variety of recreational activities, including off-leash dog walking, and then attempted to balance the varied needs of visitors, culture and wildlife from there.

Given this I find the adaptive management provision of the regulated off-leash areas (ROLAs) to be unacceptable. This provides the NPS with a mechanism to further erode dog access to on-leash only and even to prohibit dogs entirely without further consultation. The plan further states that under no circumstances will the reverse be true – once dogs are banned the park will never consider opening up access again. This is a far greater threat to preserving the park for future generations than any amount of dog access.

Rather than penalizing the vast majority of responsible dog owners the Dog Management Plan should focus on enforcing existing rules and regulations.

Below I discuss the proposed plan for the sites we visit regularly:

Fort Funston

The preferred alternative is far too restrictive. When the closed section of trail to the north of Fort Funston is open again there should be off-leash access for the full length of the beach and alongside trails so that a loop can be made down the sand ladder and then returning via the central or northern access trails. Of all the GGNRA sites Funston would seem to be the best candidate for Alternative A – maintaining current access – especially if the preferred alternative is selected for restricting most of Ocean Beach. We visit Fort Funston weekly, rain or shine, and given how heavily the area is used I’m surprised at how rare it is to encounter any problems.

Crissy Field

The preferred alternative is a good balance. When the east beach is busy there can be far too many dogs and people competing for space. For this reason we usually visit Crissy field when the weather is too severe to walk on an ocean facing beach and so it tends to be just dog walkers anyway.

Ocean Beach

The preferred alternative is reasonable, provided that Fort Funston is not overly restricted (see above).

Marin Headlands / Rodeo Beach

The preferred alternative massively reduces the trail available for hikers with a dog. We often complete the loop up the coastal trail to Hill 88 and then down Wolf Ridge / Miwok to return to Rodeo Beach. The trails are rarely crowded and a well behaved dog has no more impact than a person. The Hill 88 loop should be kept open to off-leash dogs. The preferred alternative for Rodeo Beach is acceptable.

--

Update January 17, 2011: KQED has a Forum segment on the dog management plan at 9am PST today. Join the discussion or access the audio archive here.

Update February 2, 2011: Sign up for this Facebook page: Save Off-Leash Dog Walking Areas in the SF Bay Area.