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Poison Pill

The 2,400 plus page GGRNA Draft Environmental Impact Statement (DEIS) purports to offer its proposed alternative (almost everywhere on leash or no dogs at all) and then several alternatives. However, buried deep within the document is the GGNRA's Compliance-based management Strategy-a poison pill, which itself demonstrates that the alternatives are illusory - nothing more than a default to the GGNRA's desired change:

"In order to ensure protection of resources from dog walking activities, the dog walking regulations defined in action alternatives B, C, D, and E would be regularly enforced by park law enforcement, and compliance monitored by park staff. A compliance-based management strategy would be implemented to address noncompliance and would apply to all action alternatives. Noncompliance would include dog walking within restricted areas, dog walking under voice and sight control in designated on-leash dog walking areas, and dog walking under voice and sight control outside of established ROLAs.

If noncompliance occurs, impacts to resources have the potential to increase and become short-term minor to major adverse. To prevent these impacts from increasing or occurring outside of the designated dog walking areas the NPS would regularly monitor all sites. When noncompliance is observed in an area, park staff would focus on enforcing the regulations, educating dog walkers, and establishing buffer zones, time and use restrictions, and SUP restrictions.
If compliance falls below 75 percent (measured as the Executive Summary xiv Golden Gate National Recreation Area percentage of total dogs / dog walkers observed during the previous 12 months not in compliance with the regulations) the area’s management would be changed to the next more restrictive level of dog management. In this case, ROLAs would be changed to on-leash dog walking areas and on-leash dog walking areas would be changed to no dog walking areas. This change would be permanent. Impacts from noncompliance could reach short-term minor to major adverse, but the compliance-based management strategy is designed to return impacts to a level that assumes compliance, as described in the overall impacts analysis, or provide beneficial impacts where dog walking is reduced or eliminated."

 

The SEIS presents a "new and improved" Management Strategy which they euphemistically call "Monitoring Based Management Strategy". This new scheme purportedly addresses the comments/concerns of the public regarding the DEIS.  The DEIS plan is in italics above.  The SEIS plan is essentially the same except that it modifies the portion of the Management Strategy in blue above, substituting the following:


"Secondary management response: If compliance rates are deemed unacceptable based on the previous 12 months’ monitoring data in one of the zones, in spite of the park’s primary management actions, the park will evaluate secondary management responses and institute short-term measures, including but not limited to short-term closures and/or establishment of buffer zones, and will evaluate whether to propose long-term closures. Note that primary management responses may continue to apply. A short-term closure is a closure contained in the GGNRA Compendium, typically one year or less in length. A long-term closure is typically longer than one year in length, and would likely require a special regulation. Examples of buffer zones or short-term closures being triggered include a change in resource conditions requiring resource protection, such as sensitive species moving into an area, creek channel migration, beach erosion, habitat expansion or habitat restoration (such as allowing vegetation within a ROLA to recuperate), or re-establishment of a baseline level of compliance."

 

First, the discussion of compliance rates has changed from 75% to "deemed unacceptable".  Respectfully, this is even worse!  We now have a measure of compliance that is totally subjective, with the GGNRA making all the decisions.  This is unacceptable. 

 

Under this SEIS, the GGNRA may decide to impose a short-term closure.  This would be handled by Compendium.  Let us point out, a portion of Ocean Beach was closed to off-leash recreation some years ago by Compendium.  We had public comment, and we commented in opposition.  We enclosed the same scientific information in our Compendium Comment as we did in our DEIS Comment regarding Ocean Beach.  Our comments were ignored, our analysis of the science was ignored, and the GGNRA imposed their restrictions in the Snowy Plover Protection Area by way of Compendium.  It was a complete ruse.  The GGNRA utilized the same "science" about the plover in the DEIS.  We once again challenged that "plover science" within  our Comment on the DEIS.  Perhaps since this SEIS process has received more attention, someone within the GGNRA/NPS/DOI chose to omit the "plover science" we challenged from the SEIS.  Clearly, we were correct about the science, but now the GGNRA intends to use this SEIS to double down and actually ban dogs and some human activities in that same Snowy Plover Protection Area, even as their omission of their "plover science" is tacit admission they have no scientific basis to do so.

 

Further, these short or long term closures could be triggered by any number of conditions totally under the purview of the GGNRA, all of which we 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, and surprise--dogs are now banned.

 

Worse, the language indicates a long term closure would likely require a special regulation.  We have waited since 1979 for a special regulation codifying the 1979 Pet Policy.  Despite prevailing in court, elected officials applying pressure, and public outcry over all these years the GGNRA has refused to make the 1979 Pet Policy a Section Seven Special Regulation as they should have had they been honest (check the history section of this comment).  Why did they refuse?  Because they recognized how difficult it would be for them to achieve their goal of removing off-leash recreation from the GGNRA if it was instituted as a Section Seven Special Regulation.  But now, at their whim, under this Management Strategy they can initiate a long term closure and codify it as a special regulation--never to be reversed by the public.  


The entire concept of "compliance based management strategy" is one that has never before been utilized in any other National Park or National Recreation Area by the NPS.   The Draft Plan/DEIS states (page 1725) that “the compliance-based management strategy is an important and effective tool to manage uncertainty when proposing new action” and “has been created” to assure successful implementation and long-term sustainability.  We argued this policy attempts to allow the implementation of future restrictions without public notice and comment.  This is unlawful and should never have been included in the DEIS.  We were correct -- so they changed the Management Strategy to include public notice and comment, but their intent has not changed.  Because history has shown the GGNRA has their own agenda and cares little about the science or public comment, this SEIS version of a Management Strategy is every bit as much of a poison pill as the original version in the DEIS. 

It is clear that regardless of whatever alternative is finally selected by the GGNRA, the end game for the GGNRA is the complete removal of off-leash recreation throughout the GGNRA as well as the banning of dogs entirely from most, if not all, of the GGNRA.  At this point we are once again reminded of the revealing statement made by now NPS Director Jon Jarvis:  "I would rather give up those [the GGNRA] properties than have dogs running loose on them."  

In summary, in recent interviews GGNRA representatives have stated that they are forced to ban dogs entirely in many of the former GGNRA off-leash areas provided by the 1979 Pet Policy because, "We do not have the resources to enforce voice control or on-leash compliance...".  However, it seems to be no problem for them whatsoever to fund staffing resources, expensive surveillance cameras, and muster up a Compendium or special regulation when it comes to dispensing their "poison pill".