The only NPS area in the country that currently allows off-leash dog walking has found that efforts to impose new limits on canines is a lot harder than one might expect. After years of litigation and meetings, Golden Gate National Recreation Area has released a draft Environmental Impact Statement (DEIS) for a dog management plan for public comments, and it's sparked plenty of additional debate.

According to information from the park, "Golden Gate NRA was established in 1972. Despite a federal regulation (36 CFR 2.15) requiring dogs to be kept on a leash wherever they are permitted in a national park, Golden Gate has allowed off-leash dog walking in some park areas for many years. Golden Gate is at present the only NPS area where off-leash dog walking is permitted."

How did the park get into this situation? Current managers at the park, who have struggled mightily to find any middle ground in an ongoing—and often contentious—debate about limits on dogs in the park, inherited a history of relatively unrestricted dog use when the park was established. According to the DEIS:

The history of dog walking in some areas of GGNRA began prior to the establishment of the park, when dog walking, including off-leash dog walking, occurred informally at sites under varied jurisdictions in San Francisco and Marin counties. Some of the lands designated as part of the new national recreation area had been formerly owned and managed by other public entities, and practices prohibited in national park system units, such as allowing dogs off-leash, had been sanctioned or allowed on those lands.

In the first years after GGNRA was established in 1972, those practices continued largely uninterrupted, although park staff recognized and documented issues arising from the practice during the early years of the park’s existence.

An effort to deal with the question of dog use resulted in what has become known as "The 1979 Pet Policy," which provided "general guidance for dog walking and recommended locations for both on-leash dog walking and off-leash or 'voice-control' dog walking in lands owned and managed by GGNRA.

How did that work out? Not very well, according the DEIS.

Since the 1990s, the San Francisco Bay Area population and overall use of GGNRA park sites have increased, as have the number of private and commercial dog walkers. At the same time, the number of conflicts between park users with and without dogs began to rise, as did the fear of dogs and dog bites or attacks. The hours devoted by park staff to manage these conflicts, rescue dogs and owners, dispose of dog waste, educate the public on dog walking policies and regulations at each park site, and enforce regulations also increased.

In addition, since the establishment of the park, several species with habitat in GGNRA areas used by dog walkers have been listed as threatened, endangered, or special-status species requiring special protection.

Those concerns, according to the park, pointed to the need "for a comprehensive plan for dog management." Coming up with a plan that would satisfy everyone involved has proven to be a herculean task. The following summary of key events in the process was provided by the park:

In 1999, the park closed a 12-acre section of Fort Funston to all visitor use to restore habitat, reduce visitor safety problems, and protect geologic resources. Litigation followed, and the park was successfully sued to prevent this change in management. The court ruling required the park to undertake a full public review and comment process prior to initiating such changes.

In 2002, the park issued an advanced notice of proposed rulemaking, requesting public input on the park’s intent to develop a rule for dog management.

Between 2006 and 2008, the park enacted emergency restrictions and a special regulation for two specific areas to protect the western snowy plover, a federally listed threatened species.

In 2006 and 2007, the park participated in a negotiated rulemaking process for dog management, which brought the NPS and stakeholders representing a broad array of interest groups together to try and develop consensus on a rule for dog management in the park.

Consensus on this issue, at least in the Golden Gate area, appears to be a serious challenge.

After an 18-month effort "the negotiated rulemaking committee determined that consensus could not be achieved for a majority of areas opened for consideration by the committee."

That's a polite way to say all sides had reached an impasse, and it's obvious from local media reports that emotions run high on this issue. Soon thereafter, the park began to develop this draft environmental impact statement for dog management.

The DEIS evaluates the impacts of a range of alternatives, including a preferred alternative, for managing dog walking at 21 areas in Marin, San Francisco, and San Mateo Counties. This is a key step in establishing a new regulation for dog walking in the park.

Among the elements of the DEIS likely to lead to considerable comment are provisions for "on-leash and/or voice-control dog walking in certain, specific areas of the park where impacts to sensitive resources and visitor experience were minimal" and "no dogs in areas of the park where impacts were unacceptable and could not be mitigated."

It's those revisions to policies which have been largely unchanged since 1979 that are provoking the greatest discussion.

Some dog owners see any new restrictions as a "perversion" of the "vision" for recreational use of the park's open space. Based on the 1979 Pet Policy for the park, they also view any new limits as an example of "broken promises" made by past managers at Golden Gate.

Current NPS management, meanwhile, sees the need to be consistent with laws and policies that mandate protection of natural resources, including endangered species such as the snowy plover, in all NPS areas.

It's an emotional issue, especially in a densely populated urban area where room for dogs to run free for exercise and play is a scarce commodity. Although the discussion is carefully couched in terms such as "off-leash dog walking," with dog owners required to keep their unleashed pets under voice control, visitors who aren't fans of dogs say it's a bit more complicated. One website for a pro-dog group shows three unleashed dogs splashing through the edge of the surf; the caption reads, "Recreation as it should be at Ocean Beach."

As an example of the complex issues involved, the DEIS even contemplates how, or if, to regulate commercial dog walking services that use the park, and how many dogs each such walker-for-hire can bring to the park at one time. There's more involved here than grandma taking Fido for a short stroll on the beach.

Opponents of any new regulations are well-organized, with a variety of dog owners groups such as SFDOG, Fort Funston DOG, Ocean Beach DOG, Eco-Dog and Crissy Field Dog Group gearing up for the latest round of public meetings and comments.

The complete DEIS is about 2,400 pages long and pundits claim a printed copy weighs in at over 14 pounds. In the interest of saving paper and ink, we've declined to verify those figures, and if you're interested in viewing the material before making any comments to the park, you can view or download the document at this link. Mercifully, that website allows you to select individual parts of the plan, such as the Executive Summary and Preferred Alternative, rather than downloading the entire file at once.

While some will say the DEIS in an example of a public input and regulatory process gone amuck, the length of the document is also an example of what can happen when litigation, court decrees and highly emotional issues become part of an attempt to manage public lands.

“This is truly a defining moment for Golden Gate National Recreation Area,” said Superintendent Frank Dean. “After more than 30 years of conflicting uses and general confusion, today we are releasing the draft of a unified plan for dog management in the park. We believe the proposed plan offers clear, consistent, and enforceable management, and most important of all, it balances conservation and recreation."

“We know the passion surrounding dog use at the park,” said Dean. “We look forward to the thoughtful review and comment by the entire spectrum of park users to assure that our approach to dog management is ultimately wise and appropriate for this national park area.”

During the review period, the NPS is "seeking substantive public input such as issues or impacts the NPS may have failed to consider, or inconsistencies in the plan. Following consideration of those comments, a proposed rule for dog management will be published for public comment."

If you'd like to make comments on the DEIS, you can mail them to: Frank Dean, General Superintendent, Golden Gate National Recreation Area, Building 201, Fort Mason, San Francisco, CA 94123-0022, or submit your comments on-line at this link. The comment period closes on April 14, 2011.

A series of public open-house meetings will also be held in the vicinity of the park in early March, and comments can be made during those events.

There will be no change in dog walking management in the park until a final environmental impact statement is completed and a formal rule on dog management is issued. According to the park, "this is anticipated to occur in late 2012."

There's a lot to be said for resolving this issue once and for all, but at least one pro-dog group has already threatened further litigation if the recommendations in the DEIS are implemented. The group feels restrictions on dogs at Golden Gate would not only violate their rights, but also create over-crowding and public safety issues at other nearby areas that do allow off-leash pets.

Should Golden Gate continue to be an exception to pet policies in effect in other NPS areas. What do you think?