History of Dog Walking in the GGNRA
Here is a brief summary of the history of dog walking in the Golden Gate National Recreation Area (GGNRA) and CFDG’s involvement with the GGNRA’s Dog Management legal and technical issues since 2000.
GGNRA Enabling Legislation
In 1972, the United States Congress established the GGNRA, which encompasses most of the coastal land (and some interior areas) in Marin and San Francisco Counties. A group of local activists banded together to address the recreational needs of an urban population in the open spaces of the San Francisco Bay Area by designating the GGNRA as the first urban recreation area as part of the National Park Service system. The U.S. House and Senate reports for this bill clearly identified dog walking as an important visitor use as part of the GGNRA. In the 1990s, GGNRA acquired additional lands in San Mateo county. The total acreage of GGNRA is approximately 80,000 acres.
GGNRA Enabling legislation: link
GGNRA 1979 Pet Policy
When the original founders created the GGNRA in 1972, they intended off-leash dog walking to be one of its primary purposes. A reasonable and thoughtful dog management policy was agreed upon in 1979, known as the 1979 Pet Policy. It defined specific and limited areas for off-leash recreation and established certain reasonable standards of dog behavior and obedience of dog walking in the GGNRA.
1979 Pet Policy: link
GGNRA Pet Policy Rescinded, CFDG Established
In 2001, the GGNRA Advisory Board (a Citizens Advisory Board for the GGNRA that ended in 2002) rescinded the 1979 Pet Policy unilaterally, without gathering any public input in their decision. There was a massive public outcry and a lot of media attention drawn by this decision.
The Crissy Field Dog Group (CFDG) was organized in 2001 by a group of interested people with a variety of seasoned professionals in San Francisco to address the National Environmental Policy Act (NEPA) proposed restrictive actions as it relates to dog related recreational activities and participate in the GGNRA’s Negotiated Rulemaking process. CFDG was legally established as a 501(c)(3) non-profit organization in 2004 with the purpose to “educate the local community about responsible dog ownership through advocacy and educational activities intended to benefit the local community.”
In 2006, after conducting a nation-wide search, CFDG hired an environmental attorney who specialized in NEPA federal land use law (and who was an author in writing this law in 1969) from K &L Gates, in Seattle, Washington.
CFDG has always looked at the “bigger picture” of dog recreation and management by considering the impacts to all of the areas open to recreation on GGNRA lands in Marin, San Francisco and San Mateo counties.
To this end, CDFG created 12 videos explaining what and how to submit public comments for the several versions of the Dog Management Plan with interviews with Congresswoman Jackie Speier, former Board of Supervisor Scott Weiner, SF SPCA President Jennifer Scarlett, and others providing their perspectives. In addition, we created videos of all of the off leash dog recreation areas under the 1979 Pet Policy.
CFDG YouTube Channel: https://www.youtube.com/channel/UC472ArZKo4jU-Sdyj5KehfQ
Negotiated Rulemaking
In 2006, CFDG participated as one of 26 stakeholders from various organizations (SF SPCA, Marin Humane, Marin Unleashed, Fort Funston Dogwalkers, Center for Biological Diversity, Audubon Society, Sierra Club, etc.) in the GGNRA’s Negotiated Rulemaking process. After several years of discussions, it was clear that this process was intentionally designed by the GGNRA to fail despite the well intentions from some of the stakeholders who offered viable solutions to reasonable dog recreation and management guidelines. One of these solutions included “A Plan for Visitors with Dogs” in 2007, which was authored by CFDG and Fort Funston Dogwalkers. Unfortunately, the GGNRA was not receptive to this joint proposal or, more generally, for a collaborative approach to developing a win-win outcome.
GGNRA Proposed Name Change
In June 2008, at the behest of the Golden Gate National Parks Conservancy (a non-profit arm of the GGNRA), Speaker Pelosi sponsored a bill that would have changed the name of the GGNRA to the Golden Gate National Parks, to move the focus away from recreation.
This proposed name change sparked another huge public outcry and CDFG’s attorney wrote a comprehensive and detailed letter that outlined the legal seriousness of this proposed dramatic change. This letter was supported by a very vocal GGNRA Recreation Coalition, comprised of surfers, hikers, horse people and dog groups.
In addition, this Coalition met with Speaker Pelosi’s staff to convey our strong objections to this proposed “name change.”
Speaker Pelosi quietly withdrew this contentious bill before it went to Subcommittee.
GGNRA’s Environmental Review of Dog Management under NEPA
In 2009, the GGNRA began an environmental review (NEPA) and Dog Management Plan process that was very lengthy in time and legally and technically flawed.
In short, after years of three iterations of NEPA documents, some dog groups filed a Freedom of Information Act (FOIA) lawsuit against the GGNRA. Emails uncovered evidence of GGNRA staff bias, illegal use of private emails, and collusion between the GGNRA employees and opponents of dog walking. For further information, go to www.woofieleaks.com.
The National Park Service withdrew its proposed Dog Management Plan, leaving the 1979 Pet Policy as the baseline guidelines for where you can walk with a dog in the GGNRA and expected reasonable levels of dog control by owners.
Unfortunately, the GGNRA did not sign the Record of Decision (ROD) under NEPA to fully close out the GGNRA Dog Management Plan process. Because of this fact, dog walking and the definitions of voice control and unmanaged dogs in the 1979 Pet Policy administratively still remain open for the GGNRA to change on their own schedule.
GGNRA’s General Management Plan
In 2014, the GGNRA released their twenty year General Management Plan that replaced the word “recreation” with “diverse opportunities”. After numerous comments letters by dog groups and other park visitors, the GGNRA, again, ignored the legally substantive comments submitted by CFDG and others that the GGNRA were again trying to change the focus from the purpose clearly written in their 1972 enabling legislation that made recreation an equal value with other park resources, uses and goals.
GGNRA 2019 Compendium
In September 2019, the GGNRA released the Superintendent’s Compendium in which the GGNRA unilaterally attempted to quietly change elements of the 1979 Pet Policy imposing significant restrictions on dog walking without going through public notice and comment and rulemaking. The GGNRA attempted to implement part of the flawed, illegal and abandoned Dog Management Plan by way of amending this Compendium.
This Compendium tried to create a change in dog walking status at five locations in all of the GGNRA lands in Marin, San Francisco and San Mateo counties. In addition, this Compendium included new language that presented deeply troubling definitions of Managed dogs, Unmanaged dogs and Voice Control.
CFDG worked hard behind the scenes to address and mostly resolved all of the issues from this Compendium, short of the new definitions. GGNRA Superintendent Laura Joss refuses to make any changes to these inappropriate and consequential definitions.
CFDG also requested that the GGNRA provide the supporting NEPA Categorical Exclusion documentation for this Compendium but we never received any supporting documentation back from the GGNRA.
CFDG’s letter re: GGNRA DMP closure: link
GGNRA lawsuits
There have been four lawsuits to date, beginning in 1995 when the GGNRA tried to illegally close two habitat areas at Fort Funston. The second lawsuit occurred when three people walking their dogs were ticketed at Crissy Field which led to a 2005 Federal Court Appeals decision that the GGNRA 1979 Pet Policy was the baseline for dog walking in the GGNRA. The decision also stated that the GGNRA was required to go through a public review and comment process for managing dogs in the GGNRA.
Interestingly, it was the Department of Interior who filed this lawsuit against the three ticketed dog walkers at Crissy Field.
Additional lawsuits include two Freedom of Information Act (FOIA) lawsuits, one of which was responsible for stopping the Final Dog Management Plan due to internal and external GGNRA emails that revealed extreme bias against dog walking in the GGNRA, and the other lawsuit to address issues from the 2019 Compendium.
The GGNRA has lost all four lawsuits and lost an appeal in federal court.
See Federal Judge Alsop’s decisions for the Crissy Field lawsuit and Fort Funston Dog Walkers lawsuit.
GGNRA Enforcement Issues
Over the past 26 years, the GGNRA’s Park Rangers and U.S. Park Police have been known to be hostile to dog walkers and one specific case highlights this concern.
In 2012, a man was jogging in San Mateo county (on county land) with his two eleven pound terriers. One dog was on leash and the other was off leash. A NPS/GGNRA Ranger cited the man for having his dog off leash even though he was not on GGNRA lands. Words were exchanged between the two parties and the Ranger tased him even after he told the Ranger that he had a heart condition. The man fell to the ground and was taken to the hospital where he recovered.
After hearing about this incident, Congresswoman Jackie Speier immediately called for a community hearing with the GGNRA to understand what happened and what the consequences were to be for this Ranger. GGNRA Superintendent Frank Dean said that an independent internal NPS investigation would be held.
Several months later, Superintendent Dean informed Congresswoman Speier and the public that the Ranger was clear of any misconduct. The Ranger was subsequently reassigned to another NPS unit in Colorado.
Later, the injured man won a civil action lawsuit against NPS.
CFDG relationships with the San Francisco Bay Congressional Delegation
CDFG has established good working professional relationships with Speaker Pelosi’s, Congresswoman Speier’s and Congressman Huffman’s offices.
Congresswoman Speier has been the most vocal and supportive champion of this important cause. Beginning in 2015, she introduced three limitation amendments in Congress over several years to stop the funding of the GGNRA’s Dog Management Plan but each limitation amendment was stopped by Speaker Pelosi’s office.
Additionally, Congresswoman Speier made a major effort to work with the GGNRA and NPS and made some viable suggestions such as creating a Recreation Roundtable Committee and endorsing, as a useful model, the City of Boulder, Colorado’s Green Tag Program. All proposals were rejected by the GGNRA.
CFDG Outreach Efforts
Over the course of the past twenty years, we have worked with other dog groups (and their dedicated members) including Fort Funston Dog Walkers, Montara Dog Group, Marin Unleashed, Cal Dog, SF DOG, Coastside Dog, Save Our Recreation, and Marin County Dog as well as SF Boardsailors, SF SPCA, Marin Humane, and other GGNRA user groups.
In addition, CFDG partnered with Fort Funston Dog Walkers, Marin Unleashed, Montara Dog Group, Marin Humane and the SF SPCA in creating Eco-Dog for several years during the environmental review process. The SF SPCA held several workshops for the public with CFDG and our environmental consultants and attorney on how best to respond to the three versions of the GGNRA’s Environmental Impact Statements.
We coordinated our efforts with other dog advocate groups to have call-in days to our congressional delegations, local county Board of Supervisors, peaceful marches at Crissy Field, etc. Their incredible involvement and grassroots efforts have help us all stand up to the GGNRA’s divisive bias against dog walking on land designated for recreation by all citizen, including those with dogs.
Educational outreach and creation of the Crissy Field Dog Rinse Station
The SF SPCA in partnership with CFDG and the GGNRA have offered very successful Open Space Dog Etiquette classes at Crissy Field. Additionally, CFDG worked closely with the SF Boardsailors and the GGNRA in purchasing and building the Crissy Field Dog Rinse station which is adjacent to the bathrooms at East Beach.
Moreover, for the past twenty years, CFDG has purchased and provided doggie bags that our very dedicated volunteers have put in all of the dispensers at Crissy Field on a daily basis. Every day is a cleanup at Crissy Field.
CFDG is very committed in making sure that dog walking in the GGNRA remains in all three counties on GGNRA lands. It is now up to Speaker Pelosi to lead her constituents and other Bay Area residents in sponsoring and finalizing legislation to uphold the 1979 Pet Policy and add the areas in San Mateo for off leash access in perpetuity.
Disclaimer: This document is a concise summary of the main highlights as there have been many other issues and concerns that CFDG has been involved with over the past twenty years regarding dog walking on GGNRA lands.