Things to Include in Your GGNRA Public Comment
Deadline to Submit Comments: May 30, 2011
(mailed comments must be postmarked by May 28, due to holiday)
Always Include:
 Who you are. Where you live. What parts of the GGNRA you visit and how often. What you do while you’re in
the GGNRA. What benefits you derive from walking with your dog off-leash in the GGNRA. Impact on your life
if GGNRA restrictions take effect. List any clubs or organizations to which you belong.
Essential Points to Make:

Compliance-based Management Strategy cannot be part of any plan. It changes status of areas (off-leash becomes
on-leash; on-leash becomes no dog) automatically and permanently if GGNRA claims not enough compliance
with new restrictions. No evidence of impacts from non-compliance are necessary, only the fact that there is noncompliance. This will potentially end off-leash access without giving people a chance to comment on the change.
This punishes responsible dog owners for the bad actions of a few irresponsible ones. It must be opposed and
removed.

Oppose Preferred Alternative because it is too restrictive. There is no justification in the DEIS for major changes.
Support formalization of 1979 Pet Policy PLUS off-leash access in San Mateo County and on new lands that the
GGNRA acquires in the future.
Optional Points to Make:

Recreation – The GGNRA has a recreation mandate and the DEIS treats recreation as an adverse impact, rather
than a value to be preserved. DEIS should add section evaluating benefits of recreation. Give your personal story
of why recreation with dogs should be maintained.

Urban Environment – The GGNRA is in a dense urban area, yet the DEIS is written as if the Bay Area and its
residents don’t exist just outside its boundaries. This is an urban area, not a pristine wilderness. The DEIS ignores
impact on residents or area resources, especially city parks if restrictions take effect. Note that the SF Board of
Supervisors passed a resolution opposing the Preferred Alternative because of the lack of study of impacts on city
parks.

Human Environment – The DEIS does not consider impacts on the health (physical, mental and socialization) of
people if dog walking is severely restricted. The DEIS also does not consider impacts on social communities of
people with dogs at GGNRA sites of severe restrictions take effect. Give your personal story of benefits you
derive from dog walking, and impacts on you if it goes away.

Undocumented Assumptions – The DEIS is full of assumptions about impacts – things that “might” or “could”
happen – but there is no evidence of actual observed impacts. Cannot base management plan on hypotheticals.
The GGNRA has had years to observe and document actual observed impacts. The fact the GGNRA did not
include them in the DEIS indicates they don’t exist. Give your personal story of how you don’t see dogs causing
major problems, like dogs attacking people or bothering bank swallows’ burrows on sheer cliff face at Fort
Funston.

Safety – DEIS claims a major safety problem with dogs in the GGNRA. But their own data indicates dogs
accounted for only 2% of serious safety incidents involved dogs. The vast majority of serious incidents involved
people only. Even if you include non-serious incidents, dogs accounted for a mere 7% of incidents in the
GGNRA. Dogs are not a major safety problem. Give your personal experiences about safety, including if you
don’t feel safe on a deserted trail without a dog at your side.

Diversity – Dog walkers constitute the most diverse group of people who use the GGNRA – seniors, kids, people
with disabilities, gay and straight, all ethnic groups, all religions, all social and economic classes – all interacting
in positive ways, bound by their common love of dogs. There is no mention of this diversity in the DEIS.
Minorities are mentioned only in the context of being afraid of dogs. The DEIS incorrectly quotes from a focus
group of people who had largely never been to the GGNRA as proof that minorities don’t come to the GGNRA
because of the dogs. DEIS did not consider negative impacts on minorities and disabled who lose access to dog
walking. Give your personal experiences with diversity of dog walkers in the GGNRA.

Bad science – The DEIS uses misleading literature citations to claim dogs have negative impacts on wildlife and
the environment. When examined closely, many of these studies do not say what the DEIS says they do. Other
references cite non-existent studies. Claims of impacts on snowy plovers and bank swallows are not supported by
available data. The DEIS must start over and study actual impacts documented to occur at each site in the
GGNRA, and must consider whether there are simpler mitigations that can address any impacts that are actually
found.

Management Tools – The DEIS does not consider simple management tools that could be added to the 1979 Pet
Policy that could alleviate concerns without needing to ban people with dogs. For example, if concern is dogs
going over cliffs at Fort Funston, a low-lying fence near the cliff and better signage could keep people and dogs
away from the cliff. Education programs to socialize dogs to horses could help reduce negative interactions
between horses and dogs on trails.

Visitor Experience – The DEIS describes the visitor experience as focused on people who don’t want to be around
dogs. Give your personal experience with people who come to the GGNRA to interact with dogs.

Relative Impacts of Dogs Compared to Other Causes – The DEIS considers dogs as if they are the only thing in
the GGNRA. There is no context. For example, there is no discussion of impacts of natural predators on snowy
plover birds and how that compares to those from dogs, or how do disturbances from people compare to
disturbances from dogs. Without this context, the DEIS cannot say restricting dogs will have a significant positive
impact on species.

Negative impacts on dog behavior – The DEIS did not consider negative impacts on dog behavior caused by
severe restrictions on off-leash in the GGNRA and by resulting overcrowding in city parks. Dog behaviorists,
including Ian Dunbar, Trish King, Jean Donaldson, and Veronica Boutelle, have said the loss of off-leash exercise
will cause an increase in problem dog behaviors, including bites. This resulting increase in problem behaviors will
lead to an increase in surrenders at city shelters, which cannot handle the increase. This is another impact on
surrounding communities that was not considered in the DEIS. The SF Animal Control and Welfare Commission
held a hearing on this and passed a resolution calling on the Board of Supervisors to oppose the Preferred
Alternative because of that.

Lack of Site Specific Information – The DEIS fails to document actual impacts on resources at each site. DEIS
assumes that if an impact “could” occur, it does occur at each site, even though there is little evidence of actual
impacts documented at each site. If the DEIS cannot document actual impacts, then they cannot restrict access.

Non-compliance does not equal negative impacts – The DEIS assumes that non-compliance with leash restrictions
means there are negative impacts on environment by dogs. Yet there is no evidence that impacts actually happen.
DEIS has to re-evaluate that assumption and must base any conclusion on actual documented impacts.

San Mateo County and new lands should have off-leash too – The DEIS mandates that there will be no dogs,
either on- or off-leash on any lands that get added to the GGNRA in the future. Even if dog walking has taken
place on those lands for decades. Give your personal experiences on GGNRA lands in San Mateo County.
NOTE: When you talk about your dog being off-leash in the GGNRA, be sure to add the words “under voice control”, to
indicate you are a responsible dog owner/guardian.
MAKE COPIES of your comment and send them to federal, state and local officials. Include a handwritten note on the
copy to any official, e.g., “This is really important to me. Please help.” The personal touch helps your letter be noticed.