During the first comment period back in 2011, the GGNRA received 10,000 comments but only accepted about 4,700. There is an art to writing a comment. Make sure yours gets registered.

The NPS does censor comments in that they decide if your comment raises issues that they deem "substantive". If you submit a comment that says "I love walking my dog and it's what the GGNRA is for. You can't take it away...", that comment will not be recorded. They don't count each one like a "vote". They only count substantive issues raised in the comments. For this comment period, the draft rule specifically states that your comment must be about the merits of the proposed rule, and not the previous iterations that have already closed for comment.These comments are particularly important--this is the last round. And, even more importantly, these comments lay the basis for a legal challenge.


Tips for making a comment that counts:

1. Include who you are and where you live.

2. List the GGNRA trails and beaches you visit and how often.

3. Discuss how the proposed rule will restrict your personal dog walking
recreation access and how this will impact your life.

4. Review the Essential General and Marin Points listed below. Include one or two from each of the lists in your letter. Remember to choose the points that are most important to you. You don't need to include all of them, just a few.


ESSENTIAL GENERAL POINTS

  • Designation matters.  Golden Gate National Recreation Area (GGNRA) was designated an urban recreation area.  As such, the National Park Service has a duty to protect the recreational mandate of GGNRA.  It is not appropriate for the Park Service to manage GGNRA as a remote, back country wilderness area.  

  • Public input not adequately considered or responded to. During the NEPA (National Environmental Policy Act) process, the Park Service has failed to adequately consider and respond to public input and concerns provided by thousands of Bay Area residents, the San Francisco, Marin, and San Mateo County boards of supervisors, and members of Congress.
     
  • Not based on science.  During the NEPA process, the Park Service did not provide a single peer-reviewed, site-specific study (as required by law) to support such drastic restrictions in dog walking recreation in the GGNRA.
     
  • Failure to document actual site-specific impacts. During the NEPA process, the Park Service failed to document actual impacts of dog walking recreation on resources at each site. If the National Park Service cannot document actual impacts, then they cannot restrict access.
     
  • Circumventing the NEPA process by providing a "blank check" to GGNRA's Superintendent. The proposed rule includes a monitoring-based management provision that MUST BE REMOVED from the GGNRA rule for dog management.  Under this provision, if people do not comply with the new rule, GGNRA’s Superintendent would have the discretion to completely ban recreational dog walking from any area without going through the required public comment period.  There is no criteria for what level of non-compliance would trigger a change or how it is recorded.  Furthermore, the rule gives GGNRA's Superintendent the power make closures in anticipation of impacts by dogs BEFORE they even occur.    
     
  • Failure to study impacts on city, county, and state parks. As part of the NEPA process, the Park Service failed to study their proposed rule's impacts on city, county, and state parks.  Right now dog walking (both on-leash and off-leash) is only allowed on 1% of GGNRA lands.  Cutting this access by 90% would place a significant strain on neighboring city, county, and state parks.  The Park Service has not studied this dispersion issue. 

Marin county points

  • The proposed rule eliminates every single off-leash hiking trail in Marin County.
     
  • All trails and fire roads accessible from the Muir Beach parking lot will be lost entirely to dog walking, both on and off-leash.
     
  • The proposed rule renames fire roads as "trails" despite a long-standing tradition of off-leash dog walking on roads where vehicles are allowed.
     
  • The proposed rule bans dogs on Muir Beach during seasonal closures when the stream reaches the ocean, which could be up to four months of the year. No rationale has been given behind this substantial loss of access.
  • The GGNRA has been unwilling to consider integrative solutions. Such as temporal and spatial buffers that separate incompatible uses from natural resources. They need to seriously consider time of use or Voice and Sight Tag programs similar to ones that have been successfully implemented in other states.

  • The proposed rule eliminates community loop trails that ease trail congestion. For example, the loss of Oakwood Meadow trail forces people using the area to concentrate out and back only on Oakwood Valley, thereby increasing crowding on Oakwood Valley.

  • The proposed rule destroys community connector trails making it impossible to hike from Sausalito to Rodeo or Mill Valley to Muir Beach. The community of Muir Beach is completely stranded.
     
  • Requires anyone, not just professional dog walkers, walking more than three dogs to get a permit. They must only walk weekdays 8am-5pm and only the few designated leashed trails in Marin

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.


Examples of bad comments THAT WON'T GET REGISTERED

“I love my dog and I need a place to hike.”
..............

“Don’t take the trails and beaches away!  I’m a taxpayer!  Shame on the park service.”
..............

“Dog's Lives Matter.”
..............

“We need urban parks!  Not everyone can get out to wilderness. It’s social, it’s healthy, and it’s empowering.”


SUBMIT YOUR COMMENT ONLINE

Comments are due by May 25, 2016 and can be submitted online via the Regulations.gov site


OR MAILED IN A LETTER TO

Superintendent, GGNRA
Proposed Rule for Dog Management
Building 201, Fort Mason
San Francisco, CA 94123

*Be sure to include the RIN-1024-AE16 number on your letter and envelope.


**YOU CAN SEND IN MORE THAN ONE PUBLIC COMMENT**

So if you think of something you want to add later, just submit another comment that includes the addition.


For Maximum impact, send a copy of your comment to federal 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. 

National:

Congressman Jared Huffman
630 Longworth House Office Building
Washington, DC 20515
email

Honorable Sally Jewel
Secretary of the Interior
Department of the Interior
1049 "C" Street, NW
Washington, DC  20240
email

Senator Dianne Feinstein
331 Hart Senate Office Building
Washington, DC 20510
email

Senator Barbara Boxer
112 Hart Senate Office Building
Washington, DC 20510
email

Congresswoman Nancy Pelosi
235 Cannon House Office Building
Washington, DC 20515
email

Congresswoman Jackie Speier (She has been a big supporter so be sure to thank her for her hard work.)
211 Cannon House Office Building
Washington, DC 20515
email


National Park Service
Jon Jarvis, Director
1849 C Street NW
Washington, DC 20240

National Park Service
Christine Lehnertz, General Superintendent
Golden Gate National Parks
Building 201, Fort Mason
San Francisco,CA 94123-0022


State:

Senator Leland Yee
State Capitol, Room 4074
Sacramento, CA 95814

Senator Mark Leno
State Capitol, Room 5100
Sacramento, CA 95814

Assemblymember Fiona Ma
State Capitol
P.O. Box 942849
Sacramento, CA 94249

Assemblymember Tom Ammiano
State Capitol
P.O. Box 942849
Sacramento, CA 94249