As you may have seen or heard about yesterday, four dog groups (Save Our Recreation, San Francisco Dog Group, Marin County Dog Owners Dog Group and Coastside Dog Owners Group) sued the National Park Service/GGNRA for failing to provide documentation critical to understanding the Proposed Final Rule for Dog Management that had been requested for many months. These groups are working with Christopher Carr at Morrison and Foerster, a large San Francisco law firm.
The information being sought includes data on the number of visitors to the GGNRA, the number of visitors at specific sites, citations issued with respect to alleged dog walking violations, and information on efforts to restrict dog walking in the GGNRA dating back to 1999.This case alleges that the GGNRA has broken promises on several occasions to produce the requested documents.
The next procedural step in the litigation will require the GGNRA to respond to the allegations in the dog groups’ complaint.
These four dog groups and CFDG coordinate where possible and try to support each other’s efforts on the political, legal and social fronts. CFDG supports this effort to make important documentation available to the public so that meaningful comments on the Proposed Rule can be made.
And another reminder, we hope to see next week for the two Public Writing Comment workshops on April 11th, at Calvary Church and April 12th, SF SPCA.Each workshop starts at 6:30 and ends at 8:30pm.Ash Miller, CFDG’s attorney, will lead these workshop sessions.
March 23, 2016
We want to share with you about the latest information regarding the GGNRA and the Golden Gate National Parks Conservancy plan to “redesign” the East Beach parking lot at Crissy Field.
As part of NPS’ Centennial Challenge Grant, the Haas Foundation has matched $2.5 million with NPS ($2.5 million) for a supposedly “deferred maintenance” project for the promenade and East Beach parking lot at Crissy Field.
The work for the promenade would include fixing drainage issues and resurfacing a portion of the promenade with shale composite. They also want to significantly widen the promenade in the area adjacent to the East Beach parking lot and move back the parking lot by 30 feet southward.
And they want to significantly reconfigure/redesign the East Beach parking lot in which many areas used for currently parking for Professional Dog Walkers and the staging area for the Board Sailors were be eliminated. Also, they have not addressed any American Disabilities Act (ADA) concerns.
Here is the link to the project so you can read and review the maps;
Martha Walters, CFDG’s Chair, attending a “field trip event” this past Saturday with GGNRA and GGNPC staff to check out the plan and asked many questions. She came away convinced that the NPS/GGNRA needs to conduct a NEPA (environmental review) analysis at a minimum and to include the public’s comments and concerns before they move forward with this project. This project is on a very fast track, so Martha is working with the SF Boardsailors in figuring a way to slow down this process and have the GGNRA address serious land use issues before rushing forward with this project.
We will keep you posted about the latest updates about the “redesign” project when we know them.
March 13, 2016; Public Comment Writing Workshops
CFDG will be hosting two public comment workshops about how to best write comments regarding the GGNRA”s Proposed Rule in San Francisco in mid April. Ash Miller, CFDG’s attorney will lead the talking points discussion at both sessions.
Here is CFDG’s Flyer for these two workshops…CFDG_flyer. Please make a copy and share far and wide!
The first workshop will be held on:
Monday April 11th at Calvary Presbyterian Church (corner of Jackson and Fillmore Streets) from 6:30 to 8:30pm
and the second workshop will be held on:
Tuesday April 12th from 6:30 to 8:30pm at the San Francisco SPCA, 201 Alabama Street.
Here is a recap of the Proposed Rule and affected areas:
The National Park Service is taking public comment until May 25, 2016 on the Proposed Rule for where they will allow dogs to be walked in the Golden Gate National Recreation Area. We are providing a recap of the rule and resources for submitting comments. These resources will be updated periodically and we will be posting suggested comments for you to consider in the next two weeks.
The rule is the culmination of over a decade of debate about dogs in the GGNRA. It will reduce where you can walk with your dog now by 90%. Keep in mind that dogs have only ever been allowed on 1% of GGNRA land. This rule will cut that 1% by nearly 90%. And the Park Service has introduced entirely new restrictions and onerous permits that were never disclosed in previous drafts of the plan.
Check out CFDG’s video about the Proposed rule:
NPS gives no legitimate reasons for these drastic reductions and entirely banning people with dogs from many places. There is no scientific or legal basis that dogs are causing negative impacts on the environment, wildlife, or park safety. The NPS did not incorporate input from the thousands of Bay Area residents who had submitted public comments opposing the restrictions in earlier environmental review plan versions. They did not address any of concerns raised by the Boards of Supervisors of all three counties with GGNRA land – San Francisco, Marin, and San Mateo counties – who have all gone on record opposing earlier versions of the plan.
This rule will have an enormous impact on our city parks if thousands of people and their dogs are forced out of the GGNRA and into much smaller areas. The final rule is expected to be finalized by December 2016 and implementation would begin in early 2017.
Recap of the Proposed Rule
Baker Beach: All off-leash dog walking recreation will be eliminated. Dogs allowed on leash at southern half of beach and on Coastal Trail. Dogs banned from northern half of beach.
Crissy Field: Off-leash dog walking recreation will be cut by 60%. Dogs allowed off-leash at Central Beach and middle of airfield. On leash the rest of airfield and on Promenade. Dogs banned from East Beach (near parking lot) and from Western Beach.
Fort Funston: Dog walking recreation area will be cut by 60%. Dogs allowed off-leash at beach from Sand Ladder north to North Access Trail, and at Chip Trail (upper level). Dogs banned from the beach at the North Access Trail north to stairwell 21 at Ocean Beach. All other trails on leash or no dogs.
Fort Mason: Off-leash dog walking recreation will be eliminated from Great Meadow. Dogs allowed off-leash at corner of Laguna Street and Bay Street, and on leash at Great Meadow and some other places. Dogs banned from half of overall area.
Fort Point: Dog walking recreation will be allowed on leash.
Fort Miley: All off-leash dog walking recreation will be eliminated. Dogs allowed on leash at most trails.
Lands End: All off-leash dog walking recreation will be eliminated. Dogs allowed on leash at most trails.
Ocean Beach: Dog walking recreation area will be cut by 80%. Dogs allowed off-leash from stairwell 21 north to the Cliff House. Dogs banned from stairwell 21 south to Fort Funston.
There will be one beach area for off-leash dog walking recreation and almost all on leash trails will be eliminated. Park Service has just changed the names of fire roads to trails in order to eliminate off-leash dog walking at these locations.
Homestead Valley: Off-leash dog walking recreation will be banned from all fire roads and trails. Dogs allowed on leash at some trails.
Fort Baker: On leash dog walking recreation will be allowed at parade route and some trails.
Marin Headlands: Off-leash dog walking recreation will be banned from all fire roads and trails. Dogs on leash will be banned from all but several trails. No loop options. (Maps do not show detail of trails.)
Muir Beach: Off-leash dog walking recreation will be banned from beach and trails. Dogs allowed on leash at beach, but not where and when the ocean and Redwood Creek are connected by water. Dogs on leash banned from all surrounding trails. (Maps do not show detail of trails.)
Oakwood Alta: Off-leash dog walking recreation will be banned from all fire roads and trails. Dogs allowed on leash at some trails.
Rodeo Beach: Off-leash dog walking recreation will be allowed at beach, and at northern end when lagoon surface water and ocean are not connected. Dogs allowed on leash at some trails. Dogs off-leash banned from southern beach and all trails.
There will be no off-leash dog walking recreation access anywhere in San Mateo County and people will not be allowed to walk more than three dogs at one time.
Milagra Ridge: Dog walking recreation area will be cut by 50%. No loop options.
Mori Point: Dog walking recreation area will be cut by 50%.
Rancho Corral de Tierra: Historical dog walking recreation area will be cut by 50%. Dogs allowed on leash at four trails.
Sweeney Ridge: Dog walking recreation area will be cut by 65%. Dogs banned from Pacifica access.
New Restrictions on 3 or more dogs in San Francisco and Marin
There will be additional restrictions for anyone walking with more than three dogs in San Francisco and Marin, and they apply to everyone – not just professional dog walkers. People with more than three dogs will need to purchase a permit, they will only be able to walk with more than three dogs and a maximum of six during weekdays from 8 a.m. to 5 p.m. They will not be allowed with more than three dogs at Lands End, Fort Miley and Sutro Heights. They will also be restricted from more areas than are already being cut at places like Crissy Field and Baker Beach. The maps that accompany the rule are unclear where these additional restrictions will take effect. The tables in the rule list where dog walkers with more than three dogs will be restricted regardless of whether they are designated for dog walking. (We have asked the National Park Service to amend the maps to show these areas and differences.)
A monitoring-based management program is part of the Proposed Rule. It means that if people do not comply with the new rule, the GGNRA Superintendent may arbitrarily change the status of any area without going through the required public comment period. For example, the few remaining off-leash areas could be changed to on leash or no dogs, and on leash could be changed to no dogs. There is no criteria for what level of non-compliance would trigger a change or how it is recorded.
The Proposed Rule directs law enforcement rangers to engage people walking a dog by stopping and asking them for proof of rabies vaccination, proof of dog license, and prove the dog has immediate “recall.” Voice and Sight control has been redefined to mean a dog that is within direct eyesight of the dog walker and that the dog walker is able to both immediately recall directly to his or her side, without regard to circumstances or distractions, and attach a leash to the dog’s collar. The dog walker must demonstrate this ability when requested to do so by an authorized person. GGNRA will spend $2.6 million annually to hire rangers to enforce the new rule.
GGNRA dog rule: https://s3.amazonaws.com/public-ins…
Marin Human Society: http://www.marinhumanesociety.org
San Francisco SPCA: http://www.sfscpa.org
February 2016 Update
The GGNRA released the Proposed Rule for Dog Management today and it’s looking pretty grim for off leash spaces in the proposed rule. Here is the link to the rule…www.regulations.gov. You can read and comment on the Proposed Rule there.
As far as Crissy Field goes, only the central beach and part of the grassy airfield will be open for off leash. So, that means east and west beaches will be closed, the promenade, parking lots and another part of the grassy airfield.
And the GGNRA has agreed to extend the public comment period to 90 days, instead of 60 days.
We will post more information as we know it.
CFDG will host a “How to write an effective public comment” session in San Francisco, probably in late March. Ash Miller, CFDG’s attorney will lead this important session.
The GGNRA recently sent out a notice regarding the release of their Proposed Rule for Dog Management. Below is their press release:
Dear Friends of the GGNRA:
Later this month, you will receive a message from Superintendent Chris Lehnertz announcing the release of the Proposed Rule for Dog Management in the Golden Gate National Recreation Area. The Proposed Rule is an important step forward in the dog management planning process that ensures the protection of park resources and provides recreational opportunities for a wide variety of park users.
What is the Proposed Rule?
The Proposed Rule is a draft regulation based on the Preferred Alternative in the Draft Dog Management Plan/Supplemental Environmental Impact Statement (SEIS) that would govern where and how people would be able to enjoy the park with their dogs – on and off leash – as well as parameters for responsible dog walking and where to experience a dog-free visit to the park.
Public Meetings & Review
The Proposed Rule will be released for a 60-day public comment period. During the public comment period, we will schedule a series of public informational meetings to discuss the Proposed Rule, answer questions, and provide direction on how to comment. Details on these meetings will be posted on the Park’s website.
For questions, please contact GGNRA Director of Communications, Howard Levitt, at 415-561-4730 email@example.com.
KPIX, CBS’ Channel 5 produced an excellent segment about how the GGNRA’s Dog Mgt Plan could have a very negative impact on SF City’s parks and other open space areas within GGNRA lands for dogs and their owners. SF Supervisor Scott Wiener is interviewed in this piece. Here is the link: https://www.youtube.com/watch?v=1vGvvfe7DyM (Aired on November 3, 2015)
San Francisco Supervisor Scott Wiener wrote an Op/Ed piece in the SF Chronicle’s Open Forum today. Scott has been a BIG champion, leader and supporter to lessen the GGNRA’s proposed restrictions for dog walking. Here is the link for the article:
Please let Scott know how much you appreciate his support; you can email him at firstname.lastname@example.org!
October 2015 Update
October 23, 2015: CFDG sent a letter to NPS Director Jon Jarvis today regarding the release of the GGNRA’s Dog Management Proposed Rule. According to the GGNRA, the Proposed Rule will be released within the next week or so. Here is a copy of the letter we sent:
Also, Martha Walters, CFDG Chair and other stakeholders met with GGNRA Superintendent Chris Lehnertz and other GGNRA last week to provide suggestions about the upcoming Public Workshops/Public meetings the GGNRA will hold for the Proposed Rule for Dog Management. CFDG provided some pragmatic suggestions and hopefully the GGNRA will incorporate them. CFDG also requested that the public comment period be extended beyond the 60 days as required. This is the tenth time we have requested this extension without any movement from the GGNRA.
As of this moment, the GGNRA anticipates that they will release the Proposed Rule in early November.
September 2015 Update
As always, CFDG wants to thank all of our members who have supported us and continue to do so as we try to retain responsible off leash and preserve recreation at Crissy Field and other areas within GGNRA lands.
It’s our annual fundraising time where we ask our members and everyone to donate to this important cause. Please donate here on-line on our home page or send a check made to CFDG and send to PO Box 475372 SF, CA 94147. We have had another very busy year, working with other stakeholders, the GGNRA and Congressional staff in moving this land use process forward. Below is small list of this past years accomplishments:
Worked with our K and L Gates (Lawyers and Lobbyists) to create a “Limitations Amendment” aimed at stopping changes to dog management in the GGNRA which was sponsored by Congresswoman Jackie Speier (Unfortunately that amendment was stopped on the House floor and will not be revived);
Clearly articulated our legal and factual position to the NPS Director Jon Jarvis regarding Dog Management issues and the conduct of the National Park Service;
Met with and again articulated our legal and factual positions with Chris Lehnertz, GGNRA’s New Superintendent in an attempt to open a dialogue but also to establish our record should it be necessary for litigation:
Continued to work closely with stakeholders including San Francisco Supervisor Scott Wiener, SF SPCA, and the Marin Humane Society about the Dog Management Plan as well as other dog groups;
Created and publicized a video about the future of dog walking in the GGNRA to promote public awareness and to generate support for efforts to preserve off leash dog recreation in the GGNRA: here is the link: https://youtu.be/3BgRrS2GaXg
Continued to support the cooperative effort between the San Francisco SPCA’s “Open Space Dog Training Class” and the GGNRA to educate, raise public awareness and to promote good canine citizenship at Crissy Field.
At this time, the GGNRA’s Proposed rule is scheduled to be released in late October/early November timeframe. Unfortunately, we have not seen any encouraging signs that the GGNRA is listening to our local politicians, and citizens who have commented throughout this process or to any of the other dog groups. Nor have we seen any indication that the GGNRA is intending to comply with their own regulations or laws governing land use changes for their public lands. The proof will be in the Proposed Rule when it is released for public comment this fall.
CFDG is aware that many people who love to walk their dogs and recreate in the GGNRA still do not know about the severe restrictions that the GGNRA has proposed without demonstrating scientific or legal merit to support these changes at places like Crissy Field, Baker Beach, etc., places where we love to walk our doggies. It is very important for you to let other people know about this issue and get involved and support CFDG!
.: August 2015 Update
First and foremost, CFDG wants to thank all of our members who have supported us and continue to do so as we try to retain responsible off leash and preserve recreation at Crissy Field and other areas within GGNRA lands.
CFDG has been working closely with US Rep. Jackie Speier’s office about the Dog Management Plan/Rule issue. On July 8th, Rep. Speier offered an amendment “that would slow the NPS’ regulatory overreach and ensure that the people in the Bay Area continue to have recreational access to these urban parks”. Unfortunately US Rep. Speier’s amendment did not pass but CFDG and her office will continue to work on other avenues together.
CFDG greatly appreciates US Rep. Speier’s leadership on this issue and certainly hope that US Rep. Pelsoi and US Rep. Huffman will join her in this effort since their districts encompass GGNRA lands too.
We understand that the GGNRA plans to release their Draft Dog Management Rule in October 2015. To date, CFDG has requested a 180 day public comment review period to the GGNRA two times. Currently, the GGNRA has not responded to our request.
CFDG created a new video regarding this update and the importance of letting everyone you know about this draft rule and to get involved!
And CFDG wants to extend our gratitude to the San Francisco SPCA’s Co-President Dr. Jennifer Scarlett and San Francisco Supervisor Scott Wiener for taking the time from their busy schedules and providing excellent presentations for our video!
February 2015…and the not so good news. On February 9th, the GGNRA released an announcement that their General Management Plan (GMP) was signed on January 30, 2015 by Christine Lenhertz, the National Park Service’s (NPS) Western Regional Director.
And yes, all of us were blindsided by the GGNRA and NPS by this action. CFDG still has serious concerns about the GMP on it own merits and the nexus between the GMP and the Dog Management Plan (DMP).
CFDG is working closely with our attorney and other stakeholder groups about the path forward about how to best address this irresponsible action by the GGNRA/NPS. We will keep you posted as to our next steps.
We are also concerned that the GGNRA/NPS does not take our public comments seriously and how these land use changes by the GGNRA will affect our communities in the decades to come. CFDG is also concerned that our comments on the DMP will again fall on deaf ears to the GGNRA which is scheduled to be released this Fall, 2015.
.: January 2015
CFDG submitted our GMP comments to the GGNRA in May 2014 and the GGNRA, as of this writing, is not taking our comments seriously as well as comments from other members of the public. Ash Miller, CFDG’s attorney, wrote most of these comments for CFDG.
You can sign to an online petition at https://change.org/p/president-barack-obama-access-to-the golden-gate-national-recreation-area-is-in-jeopardy to let public officials know that the GMP should NOT be signed as currently written!
The DMP is currently under review and revision by the GGNRA and it is anticipated that the EIS will be finalized in Fall, 2015. We will keep you updated about the status of document if anything changes.
Again, CFDG sent in our comments to the GGNRA regarding the SEIS and we have significant issues with this document. We worked closely with Ash Miller, CFDG’s attorney in crafting this comment letter.
.: 2014 Milestones
In Feburary 2014, Martha Walters, CFDG’s Chair and Ash Miller CFDG’s Attorney, met with representatves from House Minority Leader Pelosi, Congresswoman Jackie Speier’s and Congressman Jared Huffman’s offices in Washington DC. Although a very brief trip, Martha and Ash advocated the many concerns that they had with the GGNRA’s Dog Managment Plan and General Management Plan.
In June 2014, the Board of Supervisors from Marin, SF, and San Mateo counties submitted a letter articulating their opposition regarding the GGNRA’s preferred alternatives and the significant reduction of open space for dog walking and recreation access.
CFDG collaborated with the San Francisco SPCA to create an Open Space Dog etiquette class at Crissy Field.
CFDG collaborated with the SF Boardsailors and the GGNRA in installing a dog rinse station at East Beach, Crissy Field. Many thanks go to CFDG members Nancy Solari and Bill Moffett in supporting the construction of the dog shower!!
We encourage each and everyone of you to stay involved with this process…your voice and input can and does make a difference!
The GGNRA released their Supplemental EIS in 2014. This Final EIS will lead to new dog-walking management rules at places in Marin, San Francisco and San Mateo counties, including Crissy Field. These rules will determine for years to come where you and your dog can go within the GGNRA, what you can do and how you can do it.
The GGNRA’s preferred alternative for Crissy Field includes off leash only at Central Beach and a portion of the Grassy Airfield. On leash would be allowed on the promenade. No dogs would be allowed on East or West Beaches.
Clearly, this is an extremely restrictive proposal and your public comment and support continues to be needed.
Background of this issue
Off-leash dog walking in the GGNRA is still in jeopardy.
Off-leash dog walking with dogs under voice control is currently allowed at Crissy Field and other specified areas of the GGNRA under the 1979 Pet Policy pursuant to a Federal Court ruling in June of 2005.
Areas where you can have your dog under voice control at Crissy Field include the East and Central Beaches, the promenade and Crissy Air Field (the large grassy area). For the West Beach, dogs may be off-leash and under voice control from May 16 to June 30 of each year. From July 1 to May 15 there is a seasonal restriction for the Western Snowy Plover in the Wildlife Protection Area at the West Beach during which timeframe dogs must be on leash.
By way of background, the history of off-leash dog walking rights in the GGNRA dates back to the early 1970’s when the GGNRA was created as an urban recreational park. In the late 1970’s regulations applicable to federal lands, which prohibited certain traditional recreational park activities, were enforced. As a result, dog walking enthusiasts lobbied the park to relax off-leash rules in a few areas. In response, the GGNRA Citizen’s Advisory Committee held extensive hearings that led to the creation of the 1979 Pet Policy. The 1979 Pet Policy outlines off-leash rules and defines specific off-leash areas in San Francisco and Marin Counties, including portions of Crissy Field as indicated above.
In 1983, Congress mandated that all types of National Parks must abide by the same standard regulations but created the option of “special rules” for exceptions. The standard regulations regarding dogs in national parks basically restrict dogs to on-leash and in parking lots only.
The GGNRA continued to abide by the 1979 Pet Policy until 2001. In 2001, the Park Service began enforcing the leash law in all areas of the GGNRA based on the standard regulations applicable to national parks. This led to a lawsuit and eventually a ruling in June of 2005 by a Federal Magistrate, which upheld the 1979 Pet Policy.
The Park Service then began the process of creating a special rule relating to dog walking within the GGNRA. A Negotiated Rulemaking Committee was formed and met many times with the charter to work to develop consensus recommendations to the park about where it may be appropriate to allow dog walking within the GGNRA. Unfortunately, that process was not successful in reaching any consensus.
The GGNRA has released several versions of the EIS and CFDG and other dog groups as well as the general public have submitted their concerns about this very flawed document.
In June 2014, the Board of Supervisors from Marin, SF, and San Mateo counties submitted a letter articulating their serious opposition regarding the GGNRA’s preferred alternatives and the significant reduction of open space for dog walking and recreation access.
What can you do to help preserve and protect the ability to continue to walk dogs off-leash in the GGNRA?
Join Crissy Field Dog Group – support our mission and help us to keep you informed.
Support Crissy Field Dog Group with donations – financial support is especially needed for our legal fees that result from efforts to attain our mission.
Be a responsible dog walker and clean up after your dog; don’t allow your dog to harass any persons or wildlife; carry a waste pick-up bag and a leash for your dog and leash your dog if it is not under your voice control; respect and protect natural resources; don’t allow your dog into restricted areas; follow all posted signage; don’t allow dogs to make an unreasonable amount of noise; and fill in any holes dug at the beach for the safety of persons and other dogs.
Visit the CFDG website often to get updated information.