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Courtesy George Russel (Marin Independent Journal)

Comments on the 2013 GGNRA SEIS must be submitted via the GGNRA SEIS site between the period of September 6, 2013 and February 18, 2014 (extended due to the federal closure).  Click here to go directly to the GGNRA SEIS document page which contains a link to their electronic comment form where you can enter your comments. We have supplied you with several proposed comments (see below) which you can copy, modify and paste for your comment. Additionally, please click here to download and view the OBDOG comprehensive comment on the GGNRA Dog Management SEIS. Finally, please be sure to check out The Posion Pill section of this site which explains why any off-leash alternative in this SEIS is merely a temporary condition. But most importantly, please comment.

Proposed Comment #1  (short form comment)

The GGNRA, by its own rules, must conduct site-specific, peer-reviewed studies as the foundation for any policy changes intended to protect the resources of the GGNRA. The GGNRA acknowledges the required studies do not exist. This renders the proposed policy changes arbitrary and capricious, and as such they are unlawful and cannot be implemented. The ORIGINAL 1979 Pet Policy should be reinstated per the 2005 Federal Court decision because all closures since then have not been based upon site specific, peer-reviewed studies as the law requires. For lands added after the drafting of the original 1979 Pet Policy, DOI policy requires historical usage be maintained. Any changes would have to be justified by the requisite site-specific, peer-reviewed studies followed by a formal rulemaking process.

Proposed Comment #2

I am opposed to the entire GGNRA Dog Management Policy because I disagree with its premise that dogs in the GGNRA are compromising visitor safety and damaging the resources of the Recreation Area.  By their own admission, the GGNRA had no data or studies to support these claims and they are relying upon these claims to initiate a process whereby access for people with dogs will be severely limited or completely banned.   Even now, with this SEIS, the GGNRA admits they have no site-specific peer reviewed studies (required by Federal law) to substantiate their claims that dogs are a problem for wildlife, water quality or vegetation in the GGNRA.  Instead, they rely upon anecdotal evidence and baseless assumptions to claim dogs have the potential to damage this Recreation Area.

Additionally, in the SEIS the GGNRA asserts they have the right to redefine the term "recreation" as utilized in its enabling legislation and in the promises made to the voters of San Francisco back in 1972 by the GGNRA/NPS/DOI and the GGNRA's first Superintendent, the Honorable William J. Whalen, in order to secure various properties then owned by the City and County of San Francisco. These promises, most importantly, stated that this National Recreation Area would retain historical recreational access (including off-leash recreation) should the citizens vote to include SF park properties in the GGNRA. These promises, along with the conventional definition of  the term "recreation", do not comport with GGNRA's current philosophy exemplified by Daphne Hatch, Chief of Natural Resources Management and Science for the GGNRA, who in 2007 was quoted as saying "Ocean Beach without the people is an incredible habitat. But people think of it as a sandbox or their backyard."  The GGNRA does not have the legal authority to rewrite history or its enabling legislation to their own design.

Once again, buried deep within the SEIS is the GGNRA's poison pill.  Only the name has changed; it is now the Monitoring-based Management Strategy. The GGNRA gets to decide whether we are in compliance, and the measures of compliance are subjective.  Under this SEIS the GGNRA may decide to impose short-term or long-term closures of areas.  These short or long term closures could be triggered by any number of conditions totally under the purview of the GGNRA, all of which dog guardians have no ability to influence by our actions.  The GGNRA could decide they want to make Fort Funston in its entirety a native plant restoration/habitat; and they can do so, based upon this language.  More erosion at Ocean Beach or the beach below Fort Funston could be their reason to ban dogs entirely from these beaches. This is unacceptable.

The GGNRA still has the authority, the ability and the moral responsibility to codify the original 1979 Pet Policy as a Section Seven Special Regulation.  All properties added subsequent to the 1979 Pet Policy and in the future should have historical off-leash recreational usage allowed. This would accurately reflect the enabling legislation for this National Recreation Area which GGNRA management has held in disregard for quite some time.

If the GGNRA does not want to manage these properties as a Recreation Area, then they should transfer the Recreation Area to another entity better able to manage it, e.g. the Forest Service or Bureau of Land Management.  Alternatively, for sites heavily utilized by dogs and their guardians, such as Ocean Beach and Fort Funston, these properties should be reverted back to San Francisco.

Proposed Comment #3

 

I am opposed to the entire GGNRA Dog Management Policy for the following reasons:

In 1972, my husband and I both voted to transfer our beaches and other properties owned by the City and County of San Francisco to the NPS to become the GGNRA because of the promises made to the voters that this new recreational area would retain historical recreational access, including off-leash recreation.

When congress established the GGNRA in 1972, they included two "specific provisions" unique to the GGNRA:

 

First, the park was established "to provide for the maintenance of needed recreational open space necessary to urban environment and planning."

 

Second, the GGNRA statute imposes a unique limitation on NPS's discretionary power for "management of the recreation area" by providing that the "Secretary of Interior...shall utilize the resources in a manner which will provide for recreation and educational opportunities consistent with sound principles of land use planning and

management."

 

The GGNRA does not use sound principles of land use planning and management or even follow their own rules and regulations.

The premise that dogs in the GGRNA are compromising visitor safety and damaging the resources of the Recreation Area is absurd.  By their own admission, the GGNRA has no data or studies to support these claims. They ignore/omit all studies that contradict their desired outcome.

How can the GGNRA undertake a Dog Management Policy change as proposed in this SEIS without any evidence of monitoring or site specific studies (as required by federal law) as a means to identify the alleged impairment?!  Anecdotal comments and the “potential” to damage the area just don’t cut it.

Once again, buried deep within the SEIS is the GGNRA's poison pill.  Now called the Monitoring-based Management Strategy, the GGNRA gets to decide whether we are in compliance, and the measures of compliance are subjective.  Short or long term closures could be triggered by any number of conditions totally under the purview of the GGNRA, all of which dog guardians have no ability to influence by our actions.  The GGNRA could decide they want to make Fort Funston in its entirety a native plant restoration/habitat; and they can do so, based upon this language.  More erosion at Ocean Beach or the beach below Fort Funston could be their reason to ban dogs entirely from these beaches. This is unacceptable.

My preferred option is one the GGRNA deliberately omitted:  the original 1979 Pet Policy which was affirmed as legal and the current law of the land by Federal Judge William Alsup in 2005.

 

The only way the citizens of San Francisco can get the GGNRA to follow their own rules and regulations is by taking them to court, which has consistently ruled in favor of the citizens. 

 

Why must ordinary citizens use their own resources to battle the limitless legal resources of the NPS because of the GGNRA’s illegal actions and refusal to abide by the enabling legislation? 

 

I am old, tired, broke; and am on my 4th dog since this battle began nearly 2 decades ago.   Fourth dog will surely cross over the Rainbow Bridge before this entire BS is settled.  I’m tired of writing letters, attending meetings, and submitting comments, but I will continue until I’m dead or until the GGRNA honors their promise to the citizens of San Francisco. 

 

Enough already.  Either codify the original 1979 Pet Policy with a Section Seven Special Regulation, or … turn the lands over to another agency to manage as promised  … or the land reverts back to the City and County of San Francisco.   No more DEIS, SEIS, Rulemaking, or comment periods when we all know you totally ignore the thousands who have responded to you and continue to pursue your own agenda of keeping people and animals out of the GGNRA.

 

NO on SEIS

YES on 1979 Pet Policy

 

Most sincerely,

 

Jane Shepard

San Francisco, CA  94127

 

If you live in San Francisco, we recommend that you contact your Supervisor and let them know how unhappy you are with the GGNRA's management of their recreational properties within San Francisco City and County. Let them know you want them to seriously consider reversion because the GGNRA's preferred alternative for pet management is inadequate and will result in serious overcrowding and conflict at City managed parks.