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Efforts to Regulate Off-Leash Dogs at Golden Gate National Recreation Area Spark Debate


Off-leash "dog walking" on a park beach. NPS photo.

The only NPS area in the country that currently allows off-leash dog walking has found that efforts to impose new limits on canines is a lot harder than one might expect. After years of litigation and meetings, Golden Gate National Recreation Area has released a draft Environmental Impact Statement (DEIS) for a dog management plan for public comments, and it's sparked plenty of additional debate.

According to information from the park, "Golden Gate NRA was established in 1972. Despite a federal regulation (36 CFR 2.15) requiring dogs to be kept on a leash wherever they are permitted in a national park, Golden Gate has allowed off-leash dog walking in some park areas for many years. Golden Gate is at present the only NPS area where off-leash dog walking is permitted."

How did the park get into this situation? Current managers at the park, who have struggled mightily to find any middle ground in an ongoing—and often contentious—debate about limits on dogs in the park, inherited a history of relatively unrestricted dog use when the park was established. According to the DEIS:

The history of dog walking in some areas of GGNRA began prior to the establishment of the park, when dog walking, including off-leash dog walking, occurred informally at sites under varied jurisdictions in San Francisco and Marin counties. Some of the lands designated as part of the new national recreation area had been formerly owned and managed by other public entities, and practices prohibited in national park system units, such as allowing dogs off-leash, had been sanctioned or allowed on those lands.

In the first years after GGNRA was established in 1972, those practices continued largely uninterrupted, although park staff recognized and documented issues arising from the practice during the early years of the park’s existence.

An effort to deal with the question of dog use resulted in what has become known as "The 1979 Pet Policy," which provided "general guidance for dog walking and recommended locations for both on-leash dog walking and off-leash or 'voice-control' dog walking in lands owned and managed by GGNRA.

How did that work out? Not very well, according the DEIS.

Since the 1990s, the San Francisco Bay Area population and overall use of GGNRA park sites have increased, as have the number of private and commercial dog walkers. At the same time, the number of conflicts between park users with and without dogs began to rise, as did the fear of dogs and dog bites or attacks. The hours devoted by park staff to manage these conflicts, rescue dogs and owners, dispose of dog waste, educate the public on dog walking policies and regulations at each park site, and enforce regulations also increased.

In addition, since the establishment of the park, several species with habitat in GGNRA areas used by dog walkers have been listed as threatened, endangered, or special-status species requiring special protection.

Those concerns, according to the park, pointed to the need "for a comprehensive plan for dog management." Coming up with a plan that would satisfy everyone involved has proven to be a herculean task. The following summary of key events in the process was provided by the park:

In 1999, the park closed a 12-acre section of Fort Funston to all visitor use to restore habitat, reduce visitor safety problems, and protect geologic resources. Litigation followed, and the park was successfully sued to prevent this change in management. The court ruling required the park to undertake a full public review and comment process prior to initiating such changes.

In 2002, the park issued an advanced notice of proposed rulemaking, requesting public input on the park’s intent to develop a rule for dog management.

Between 2006 and 2008, the park enacted emergency restrictions and a special regulation for two specific areas to protect the western snowy plover, a federally listed threatened species.

In 2006 and 2007, the park participated in a negotiated rulemaking process for dog management, which brought the NPS and stakeholders representing a broad array of interest groups together to try and develop consensus on a rule for dog management in the park.

Consensus on this issue, at least in the Golden Gate area, appears to be a serious challenge.

After an 18-month effort "the negotiated rulemaking committee determined that consensus could not be achieved for a majority of areas opened for consideration by the committee."

That's a polite way to say all sides had reached an impasse, and it's obvious from local media reports that emotions run high on this issue. Soon thereafter, the park began to develop this draft environmental impact statement for dog management.

The DEIS evaluates the impacts of a range of alternatives, including a preferred alternative, for managing dog walking at 21 areas in Marin, San Francisco, and San Mateo Counties. This is a key step in establishing a new regulation for dog walking in the park.

Among the elements of the DEIS likely to lead to considerable comment are provisions for "on-leash and/or voice-control dog walking in certain, specific areas of the park where impacts to sensitive resources and visitor experience were minimal" and "no dogs in areas of the park where impacts were unacceptable and could not be mitigated."

It's those revisions to policies which have been largely unchanged since 1979 that are provoking the greatest discussion.

Some dog owners see any new restrictions as a "perversion" of the "vision" for recreational use of the park's open space. Based on the 1979 Pet Policy for the park, they also view any new limits as an example of "broken promises" made by past managers at Golden Gate.

Current NPS management, meanwhile, sees the need to be consistent with laws and policies that mandate protection of natural resources, including endangered species such as the snowy plover, in all NPS areas.

It's an emotional issue, especially in a densely populated urban area where room for dogs to run free for exercise and play is a scarce commodity. Although the discussion is carefully couched in terms such as "off-leash dog walking," with dog owners required to keep their unleashed pets under voice control, visitors who aren't fans of dogs say it's a bit more complicated. One website for a pro-dog group shows three unleashed dogs splashing through the edge of the surf; the caption reads, "Recreation as it should be at Ocean Beach."

As an example of the complex issues involved, the DEIS even contemplates how, or if, to regulate commercial dog walking services that use the park, and how many dogs each such walker-for-hire can bring to the park at one time. There's more involved here than grandma taking Fido for a short stroll on the beach.

Opponents of any new regulations are well-organized, with a variety of dog owners groups such as SFDOG, Fort Funston DOG, Ocean Beach DOG, Eco-Dog and Crissy Field Dog Group gearing up for the latest round of public meetings and comments.

The complete DEIS is about 2,400 pages long and pundits claim a printed copy weighs in at over 14 pounds. In the interest of saving paper and ink, we've declined to verify those figures, and if you're interested in viewing the material before making any comments to the park, you can view or download the document at this link. Mercifully, that website allows you to select individual parts of the plan, such as the Executive Summary and Preferred Alternative, rather than downloading the entire file at once.

While some will say the DEIS in an example of a public input and regulatory process gone amuck, the length of the document is also an example of what can happen when litigation, court decrees and highly emotional issues become part of an attempt to manage public lands.

“This is truly a defining moment for Golden Gate National Recreation Area,” said Superintendent Frank Dean. “After more than 30 years of conflicting uses and general confusion, today we are releasing the draft of a unified plan for dog management in the park. We believe the proposed plan offers clear, consistent, and enforceable management, and most important of all, it balances conservation and recreation."

“We know the passion surrounding dog use at the park,” said Dean. “We look forward to the thoughtful review and comment by the entire spectrum of park users to assure that our approach to dog management is ultimately wise and appropriate for this national park area.”

During the review period, the NPS is "seeking substantive public input such as issues or impacts the NPS may have failed to consider, or inconsistencies in the plan. Following consideration of those comments, a proposed rule for dog management will be published for public comment."

If you'd like to make comments on the DEIS, you can mail them to: Frank Dean, General Superintendent, Golden Gate National Recreation Area, Building 201, Fort Mason, San Francisco, CA 94123-0022, or submit your comments on-line at this link. The comment period closes on April 14, 2011.

A series of public open-house meetings will also be held in the vicinity of the park in early March, and comments can be made during those events.

There will be no change in dog walking management in the park until a final environmental impact statement is completed and a formal rule on dog management is issued. According to the park, "this is anticipated to occur in late 2012."

There's a lot to be said for resolving this issue once and for all, but at least one pro-dog group has already threatened further litigation if the recommendations in the DEIS are implemented. The group feels restrictions on dogs at Golden Gate would not only violate their rights, but also create over-crowding and public safety issues at other nearby areas that do allow off-leash pets.

Should Golden Gate continue to be an exception to pet policies in effect in other NPS areas. What do you think?

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I would great if all dog owners are were responsible, they are not. In CHNS where there has always been a leash law. I have personally witnessed many worse case dog off leash interactions here: from dogs running through colonial bird nesting colonials that have unfledged chicks, fawn deers being killed and sunbathers being peed on (very common). I love dogs. I wish there were a good way to allow them to be off leash as many dog and dog owners manage and control their canines in a responsible manner.

Apparently, Golden Gate is at present the only NPS land where off-leash dog walking is permitted where voice control is the method of pet control.If my recent experience on GGNRA trails in Tennessee Valley was an example of how well that’s working in other parts of it are protected from domestic pet impact, it’s time for Congress to put an end to the debate. Stop off leash access in a “protected zone”,limit leash length and the number of pets allowed where dogs are permitted with a single person, and enforce regulations where dogs are permitted.This approach will hopefully start a process that will reduce damage done in GGNRA by people who apparently could care less about the law and/or impact dogs have on the Golden Gate National Recreation Area. The Superintendent’s Compendium of January 2012 unwisely allows off leash control on certain trails, but dog owners I encountered don’t seem to care and feel empowered to do as they please on Federal land.Regulations in the GGNRA appear to be simply a“Paper Tiger” where many dog walkers do not feel apply to them.

In a five mile walk through tree shaded trails you see dog feces left on the ground and in bags on the path daily. Dog tracks off trail and in the creek. It is hard to have peaceful enjoyment when you have to watch almost every step taken to avoid dog excrement or avoid a pet running loose with no one near it to exercise “voice control” no matter what the rules are for a given trail.I suppose leaving dog feces in bags offers some containment, but it is an eyesore and still poses risk of disease to wildlife.Visitors to these fragile trails must think we are nuts to allow this assault on them and nature.I’m sure someone is paid to come along behind those acting badly to clean up the mess, but at what cost and how is that working for GGNRA wildlife?

If you offer information regarding animal control regulations on trails, pet owners don’t want to hear it becoming verbally abusive and aggressive, and NPS Ranger advice is to say nothing to the violators. From what I saw they do the same. GGNRA leadership must not allow Tennessee Valley to remain to be a dog park driving others off the trails.Responsible dog owners and non-dog walkers should join in the effort to keep bad actors off the trails.Otherwise Congress must intercede to protect the Recreation Area from long term impact of domestic animals in National Parks lands. Tennessee Valley is at risk from pets and it is time to act.I was advised when in GGNRA, and encounter a situation where law enforcement intervention is needed, you can contact our 24/7 dispatch office at 415-561-5505 (for non-emergencies), or (415-561-5656) for emergencies only. Good luck with that.Regardless, if they get enough complaints, the Superintendent might reconsider the unique access pet owners appear to have on Federal Park lands in the Golden Gate Region.

Pipi is very noticeable on the main path - my child has to constantly avoid not to touch it or get too close to it - and tons of cacca is hidden under the sand...'com on people, this is not a matter whether or not you love dogs, this is a healthy, hygiene issue, not to mention kids and people in danger for unleashed dogs - by the way, wasn't there already a law for un-leashed dogs? Uhm, I've been here for ten years and never, ever saw a police officer nor a park ranger at Chrissy Field, you know, just to enforce the law...uhm!

 The regulations are complex and vary by time of year. As it is, there are areas where off-leash dogs are allowed part of the year.

I have seen a park ranger at Chrissy Field. I was there to see a talk on the history of aviation there. At the end, our ranger was about to excuse himself to go and give a warning (or perhaps a ticket) to people with dogs. He was under the impression that dogs weren't allowed at all that time of year. I had previously killed a little time reading the signs before the talk, and pointed out to him that the signs said that on-leash dogs were allowed year-round. The dog wasn't doing anything but sitting, so I recall he just gave them a warning that the dog should be on a leash.

From a dog-lover point of view, I understand the frustration dog owners feel. However, I am from Europe and I am rather used to see dog dudu/cacca all over the place...I thought San Francisco would have been different. San Francisco is one of the most beautiful city in the US - until you land at SFO and head to Chrissy Field - I admit that it is rather disgusting to walk not only on the main path, not to mention that I don't even try to go on the sand to enjoy what Europeans always thought of California. Pipi is very noticeable on the main path - my child has to constantly avoid not to touch it or get too close to it - and tons of cacca is hidden under the sand...'com on people, this is not a matter whether or not you love dogs, this is a healthy, hygiene issue, not to mention kids and people in danger for unleashed dogs - by the way, wasn't there already a law for un-leashed dogs? Uhm, I've been here for ten years and never, ever saw a police officer nor a park ranger at Chrissy Field, you know, just to enforce the law...uhm! Now, I am assuming all dog owners may think of me as an anti-dog at Chrissy Field, wrong. I am European and very used to the dirty streets. The point here is that I would love for me and my family enjoying walks with bare feet on the sand, digging the sand with my child's shovel and bucket, being captured by the beauty of Chrissy Field, the Golden Gate Bridge, people, just relaxing...Unfortunately the extremism and individualism of some American dog-owners believes that the rights of behaving the way they want is justified by the so called "American freedom" or "we are in a free country". The Chrissy Field dogs issue goes beyond  dogs, dudu, pipi, being attacked by a dog, it is just a matter of being civil, balanced in all we do. Thinking black and white just doesn't work, the solution is a bit of wisdom in how we deal with other people. We criticize people in other country, ready to think that "we are the best in the world", yet, we are blind when it comes to deal with minor issues like how to handle dogs in a more reasonable and balanced way...Welcome dogs and welcome dog-owners...I welcome you when you clean after your dog and not pretend he/she was just playing and any cacca did not come out of him/her - watch your dog and chat less with people, perhaps you'll see when and where your dog has hidden his/her cacca. I welcome you when you are aware that your dog, although a loving dog that will never, and then ever do any harm, not even a fly, remains an animal with hidden animal instinct and might do harm other people/children, other dogs...

This has been one of the best open discussions of an extremely volatile situation affecting many Parks and Recreation Areas. I am encouraged with the manner in which so many people have commented. Facts and opinions without the, too often, accompanying insults and adjectives. There might be hope yet for everyone to work things out and get along with each other, enjoy our parks together and with all God's creatures.
It occurs to me that Many of us have learned a lot with all that has and is happening. I think we are learning a lot about each other. I know my thoughts and attitude has changed in some ways. I still believe in "free and open access" but, being sure that due respect be given to all concerns. Not so much because it's law or policy, but because its what's right. On the same note, If those same laws and policies allow actions or activities which I feel are detrimental, I just won't do those things. If only we can figure out how to limit the influence of the most extreme and have our Government listen to the real people. The people that have only one goal, that being to experience the wonder and activities the resources provide in a respectful and responsible manner. One thing for sure, we need to stop the insane litigation. Does anyone really think that Attorneys or Judges know better how our Parks and Recreation Areas should be managed than the people, the users. I want to believe that the people, if approached properly, can and would act responsibly. There would be no incentive not to. And, we will support our Parks financially, not drain them of desperately needed funds.
Thanks All,
Ron (obxguys)


Yes, the Sierra Club Lobby or doctrine also wants the removal of Mules in the Grand Canyon (75% of them) except when their members want to catch raft trips going down the Colorado, really! Hard to believe but I know it to be true.
What a crock the Sierra Club has gotten to be. I know old time members that have walked away from it since they've become such a burden on the courts costing, like you said, millions of dollars, lost access and jobs while living high off government paid attorney fees and donations by well meaning contributors. With the mood of the country tired of the BS, things need to change.

I certainly understand some of the frustration. It's difficult to own a large dog in San Francisco. If I were to adopt another dog, I feel fortunate that I would find many open spaces available in the East Bay Regional Park District, including the best off-leash area in the Bay Area in Point Isabel.

However - that it's a RECREATION area can't be a justification for off-leash dogs. Kurt noted that GGNRA is the only NPS unit where off leash dogs walking is allowed. All other NPS units (including "National Recreation Areas") only allow dogs on-leash, except for areas that allow hunting dogs for expressed hunting purposes and of course trained service dogs.

Part of the problem is conflicts with various users. I've seen several websites of the various off-leash dog proponents. Most try to encourage responsible dog ownership, including leashing dogs that chase wildlife or that rapidly approach people. I know people who are panicked when large dogs or specific breeds approach them. Most of GGRNA's users are not walking dogs, so proper voice control is essential. One dog walker who can't control a dog can turn someone into a vocal enemy of off-leash dog walking.

I've described the Endangered Species Act as the "neutron bomb" of all land use laws. It's stopped all sorts of development in the Bay Area when a single San Francisco garter snake was found at a construction site. The federal government is spending (I kid you not) hundreds of millions of dollars to try and protect the Western snowy plover, so any area where the birds nest is going to come under scrutiny for protection. It wouldn't matter if it's a federal, state, county, or city park; there's a pretty powerful group of people whose concerns aren't about dogs but of the wildlife. I know dog owners in San Francisco have formed a pretty formidable lobby, but so has the Sierra Club and Audubon Society.

The proposal will deny thousands of people in the Bay Area the ability to use these parks for recreation. Golden Gate National RECREATION area, is supposed to be used for recreation. Of course the environment needs to be protected, but there needs to be a balance and proof that the current use is irreparable harm.

My family heads to Fort Funston at least once a week to enjoy the beach and trails with our dog. The parking lot at Fort Funston is jam packed on the weekends, where will these people go if they are turned away from using the park? The environmental impact will be huge and put an enormous burden on city parks and recreation when dog owners are forced to find alternate spaces within city confines to exercise their dogs.

These off leash areas at the GGNRA have provided us a place to exercise our pets . There just aren't enough spaces in the Bay Area that are open to people with dogs and taking away this vital and greatly appreciated recreation area is gong to contribute to new problems for municipalities up and down the Peninsula.

Without a valid environmental impact report indicating that the current usage is having a negative impact on the GGNRA, there's no reason this proposal should be accepted. Furthermore, the GGNRA should be required to study the potential impact to City and County parks when people are forced out of the GGNRA due to this proposal.

The proposal fails to consider how it will impact City parks and playground if people are forced off GGNRA land. It's just makes no sense to change the policy now, with more and more people living in the Bay Area who need to get outdoors and exercise, along with their dogs. And we have shown ourselves to be good stewards of the GGNRA lands - there is no threat to wildlife or significant problems with having dogs running free on the beach and trails where they currently are permitted to do so.

Walking dogs on leashes around City streets is fine, but they need to run free and socialize with other dogs, and more importantly their OWNERS need spaces where they can go and enjoy their leisure time and bring the family.
The Golden Gate National Recreation Area needs to be stopped from implementing it's plan to deny families like our access to the parks in San Francisco.

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