GGNRA “Negotiated Rule-Making” Update
Unfortunately, the outcome of discussions over the twelve Golden Gate National Recreation Area (GGNRA) park sites closed to off-leash dogs since 1979 is looking rather grim. The sites have been up for reconsideration since the GGNRA implemented its 1979 Pet Policy, the guiding principles of which are mostly biased against dogs. Currently off-leash recreation is allowed on less than one percent of GGNRA acreage. Beautiful Baker Beach, for example, may now be forever sans dogs, on leash or off.
The final meeting of the Negotiated Rulemaking Committee was held on the 27th of October at Fort Mason. The committee is made up of participants from nineteen groups representing the environment, the general public, and off-leash dog recreation. (It is interesting to note that the groups hand-picked by GGNRA included six that were actively anti-dog, in that they had previously submitted petitions to the Federal government to ban all off-leash activity
The GGNRA requires consensus among participants, but it became apparent early on in the process that the groups representing the environment would not go along with any alternative to the off-leash ban. In a last ditch effort, the GGNRA selected particular members to meet in small working groups ahead of time to work out their differences, but to no avail.
The final meeting was called to discuss the 1979 GGNRA pet policy, and specifically to reconsider the closing of twelve sites. Only four of them came up for discussion, however, and no consensus was reached. A partial consensus occurred regarding the Oakwood Valley trail in Marin, leaving the status of relatively larger and more popular areas like Fort Funston and Ocean Beach unresolved.
The committee was tasked with creating proposals that would provide workable alternatives to closure to be submitted to National Environmental Protection Agency (EPA) for analysis. In considering alternatives, if it was determined that the environment would be impacted, a plan to mitigate that impact should also be included in the proposal.
The other requirement was that if there is an off-leash area, there also needs to be an area where dogs are out of sight (even on leash), so that those who prefer a “dogless” park experience can have that.
The dog caucus is made up of representatives from local dog-focused groups, such as professional dog walkers, the SPCA, San Francisco Dog Owners Group, and the like. To their credit, they came up with reasonable and creative alternatives for each site.
NEPA will review the alternatives presented, including those that the Park Service came up with, and is expected to present a draft environmental analysis report next year. There will be a public comment period before the final management policy is finalized by the GGNRA in 2009.
The GGNRA floated the idea of extending the Negotiated Rulemaking Committee, but the participants representing the dog-loving community came away with a feeling that that’s not likely to happen.