[Used with permission from SFDOG.org]
Some suggestions for your public comment on the DEIS. You should definitely say how much you enjoy walking with your dog off-leash in the GGNRA. But you need to include some substantive reasons why the GGNRA’s Preferred Alternative is not good and why they need to develop a new Alternative that will be more balanced, supportive of recreation, and reflects San Francisco’s values of co-existence, shared use, collaboration, and education to solve problems.
Feel free to pick and choose from these suggestions to fit what you want to say. You can use personal stories to illustrate these points, but you do not have to. Include at least one substantive point in your comment (see that section below).
PERSONAL COMMENTS – ALWAYS INCLUDE THIS INFORMATION
1) You can send in more than one comment so don’t worry if you forget to say something. Just send in a second, third, fourth, etc. comment.
2) If you are a member of a protected class, be sure to mention that in the first sentence of your comment. Protected class includes, seniors, disabled, ethnic minorities, parents, gays. Parents get your children to write separate comments and note their ages on the comment.
3) Be sure to say that you are a local resident (if you are), and how long you have been recreating with your dog(s) off-leash in areas controlled by the GGNRA, which areas you frequent, and how often you go to the GGNRA each week or month.
1) The Compliance-Based Management Strategy must go.This poison pill that will allow the GGNRA to change the status of off-leash areas to on-leash or no dogs without additional public comment if there is not 100% compliance with the new restrictions will not work. The change would be permanent. A management plan should not come with a built-in nuclear option, which is what this is. It allows a relatively few bad players to undermine and destroy a traditional recreational use of the area. No number of responsible dog owners will stop what will become the inexorable removal of all off-leash access in the GGNRA if this strategy remains part of the plan. Tens or hundreds of thousands of hours of incident-free dog walking will not matter. There should be (and are) penalties for bad actors and these should be enforced. But the vast majority of people who do not act badly should not be penalized for the bad actions of a few. This strategy is unfair because off-leash status can be changed in only one direction (toward more restriction). It circumvents the legal requirement that management changes that are either significant or controversial must have a public process before they can be made. Critical information about how compliance will be determined – by volunteers biased against dogs? by surveillance cameras? – is not included in the DEIS.
2) The Preferred Alternative is not acceptable.It is overly restrictive, and its restrictions are not justified by the totality of available data. It is based on separation and exclusion, a management philosophy that goes against the values of the Bay Area in which it is fully immersed. It violates the mandate for the” maintenance of needed recreational open space” contained in the legislation that created the GGNRA. The DEIS is full of negative things that “might” or “could” happen if dogs are allowed off-leash at various sites. But there is very little evidence presented that these hypothetical impacts actually happen. Given the intense scrutiny of dogs by the GGNRA over the past decade and more, the fact that there is not more persuasive real data about significant impacts of off-leash dogs means that there is no real justification for the proposed restrictions contained in the Preferred Alternative. The contraction of areas available for off-leash recreation will significantly compromise the park experience for people with dogs, and could lead to an increase in conflict as more and more people are forced into smaller and smaller areas. The impacts of people moving from the GGNRA into city parks is not adequately addressed in the DEIS. Any alternative must address these impacts on city parks and ways to mitigate them.
3) The GGNRA should develop a new alternative, the A+ Alternative, that will better balance the recreational needs of the Bay Area with protection of natural resources.The DEIS calls the “No Change” Alternative “A”. This is the 1979 Pet Policy with some restrictions, particularly restrictions on off-leash at Ocean Beach, Fort Funston, and Crissy Field because of the snowy plover and native plant restorations. More than one-third of Bay Area residents have dogs and we now know the importance of off-leash recreation for dog’s physical and mental health, as well as the importance of the significant social communities that develop where people recreate with their dogs off-leash. This large segment of Bay Area residents should not be restricted to significantly less than 1% of GGNRA land (that is how much GGNRA land is available for off-leash recreation in Alternative A) to have a satisfactory park experience, especially since there is little scientific evidence supporting restrictions on off-leash. There has to be more space available for off-leash recreation, not less, given the huge demand for it in the Bay Area. The A+ Alternative would include everywhere that is currently off-leash, plus sufficient off-leash opportunities in San Mateo County to meet the demand, and more trails off-leash throughout the GGNRA. In addition, new land added to the GGNRA would include off-leash areas, especially in those areas where it has traditionally taken place. There would be no compliance-based management strategy in the A+ Alternative. Any dog management philosophy in the GGNRA, like that for any other recreation use, should be based on Bay Area values of co-existence, shared space, collaboration among park user groups, and education where problems arise. Enforcement of already existing regulations should target irresponsible dog owners who create the few problems documented by the GGNRA, while allowing responsible dog owners to continue their traditional off-leash recreation without harassment.
4) There are not enough trails available for off-leash recreation in the Preferred Alternative. We need more.Not everyone who goes to the GGNRA plays fetch with his or her dog. Many people enjoy hiking on trails with their dogs as their companions. There are not enough trails with off-leash access in the Preferred Alternative.
5) There must be off-leash access in San Mateo County and on new lands as they come into the GGNRA.The Preferred Alternative has no off-leash on any GGNRA land in San Mateo County, even though much of the land allowed off-leash access before it became part of the GGNRA. Off-leash recreation is a traditional use of those lands, and it must be respected and maintained. That is in keeping with the GGNRA’s mandate for the “maintenance of needed recreational open space” contained in the legislation that created the GGNRA. The refusal to consider off-leash recreation for any new land that might come into the GGNRA in the future is an additional violation of the GGNRA’s recreational open space mandate. There needs to be a mechanism for additional off-leash recreational open space when new land comes into the GGNRA.
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