Proposed Comment (for copy, modify and paste)
I object to the new 2016 Dog Management Policy (DMP) because it is in violation of Federal Law. GGNRA management can provide no "vital monitoring" report or data to substantiate visitor use patterns or conflicts, no documentation of degradation of the Recreation Area resources, and no documentation to support their claim that these alleged problems are caused by dogs and their guardians. In light of these failings, the decision to move forward with a new Dog Management Policy is arbitrary and an abuse of discretion.
Additionally, after using appropriate methods to establish resource degradation, Federal agencies are required to conduct site specific, peer-reviewed studies to ensure the proposed policy changes will be effective as a means to remediate damage to the resources. In the current SEIS the GGNRA acknowledges that they have no peer reviewed, site-specific studies to support their claims that dogs adversely affect water quality, vegetation, soils, or wildlife in the GGNRA.
How is it equitable for the GGNRA to abolish recreational access as a remedy to a problem they cannot document and when they have demonstrably violated the principles of sound land use planning and management (by their own agency definition) as well as numerous Federal laws designed to ensure the reliability of scientific evidence utilized to make management decisions?
The GGNRA further proves the point that they have knowingly failed to document resource degradation, and refused to provide site specific, peer-reviewed studies to support these proposed management changes by using this new DMP to exempt themselves from EVER having to follow these DOI/NPS rules regarding science-based resource management. The Poison Pill (Monitoring-Based Management Program) has again been included in this latest version of the DMP, and it is by far the most dangerous iteration yet. In this version of the Poison Pill, the GGNRA allows itself the flexibility to implement secondary management actions (which can include short, long or permanent closures of dog walking areas) to prevent unacceptable impacts or conditions before they occur. It's all up to the Superintendent-no documentation required! This is a bald-faced attempt to circumvent well established Federal Law to allow GGNRA management to lock dogs and their guardians out of the GGNRA altogether.
This 2016 DMP should be withdrawn and the original 1979 Pet Policy should be reinstated throughout the GGNRA. For properties added since 1979, sound land use planning and management should be implemented, whereby baseline studies are done and annual vital monitoring can be utilized to see if historical use patterns can be retained without damage to the resources.