Measurements Alt a Alt B Alt C Alt D Alt E Preferred Trails
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GOGA Dog Management SEIS acreage/mileage summary October 2012 Milagra Ridge Measurements Alt A Alt B Alt C Alt D Alt E Preferred Trails - On leash miles 2.73 1.48 1.48 1.65 1.48 Trails - Off leash/ROLA miles Beach - On leash miles Beach - Off leash/ROLA miles Other Acreage - on leash Other Acreage - off leash/ROLA Sweeney Ridge Measurements Alt A Alt B Alt C Alt D Alt E Preferred Trails - On leash miles 6.84 4.13 2.43 Trails - Off leash/ROLA miles Beach - On leash miles Beach - Off leash/ROLA miles Other Acreage - on leash Other Acreage - off leash/ROLA Cattle Hill Measurements Alt A* Alt B Alt C Alt D Alt E Preferred Trails - On leash miles 1.12 1.12 1.12 Trails - Off leash/ROLA miles Beach - On leash miles Beach - Off leash/ROLA miles Other Acreage - on leash Other Acreage - off leash/ROLA *not yet GGNRA GGNRA004235 GOGA Dog Management SEIS acreage/mileage summary October 2012 Pedro Point Measurements Alt A* Alt B Alt C Alt D Alt E Preferred Trails - On leash miles 0.31 0.31 2.40 0.31 Trails - Off leash/ROLA miles Beach - On leash miles Beach - Off leash/ROLA miles Other Acreage - on leash Other Acreage - off leash/ROLA *not yet GGNRA Rancho Corral de Tierra Measurements Alt A Alt B Alt C Alt D Alt E Preferred Trails - On leash miles 16.2* 6.48 6.48 1.10 6.48 6.48 Alt A mileage for info only Trails - Off leash/ROLA miles Note: alts B, C, D, E updated Beach - On leash miles trail milage to reflect alt maps Beach - Off leash/ROLA miles Other Acreage - on leash 3858.00 Other Acreage - off leash/ROLA 1.39 1.39 GGNRA004236 Golden Gate National Recreation Area Commercial Dog Walking Interim Permit Requirement Proposal August 2013 INTRODUCTION The National Park Service, Golden Gate National Recreation Area (GGNRA) is considering requiring permits for persons walking four or more dogs at one time for consideration (commercial dog walker) on lands under the administrative jurisdiction of GGNRA in City and County of San Francisco and Marin County where dog walking is allowed for the interim period prior to the promulgation of a final rule for dog walking in GGNRA, anticipated in 2015. Permits under this interim program would allow a maximum of six dogs per dog walker, and require a business license and proof of liability insurance and approved dog-handling training through existing training courses, such as those offered by Marin Humane or SF SPCA. Permit holders must abide by all National Park Service (NPS) regulations, including 36 CFR 2.15(a), which requires that dogs be restrained by a leash no longer than 6 feet in sites that are not open to voice control dog walking per the 1979 Pet Policy. In a related action, the Presidio Trust (Trust), a federal agency governing the interior Presidio lands that area within the GGNRA boundary, is also proposing an interim public use limit on persons who are walking four or more dogs at one time for consideration (commercial dog walkers) in Area B of the Presidio of San Francisco (Presidio). The limit will require any commercial dog walker with four or more dogs at one time in Area B to possess a valid commercial dog walking permit obtained from GGNRA. Commercial dog walkers will be required to comply with the terms and conditions of the GGNRA permit as well as those rules and regulations otherwise applicable to Area B of the Presidio. This document outlines and describes the reasons why action is needed. Purpose of the Proposed Action This proposed interim permit requirement is a direct response to commercial dog walking permit programs recently enacted by the San Francisco Board of Supervisors and the Town of Tiburon 1 GGNRA004237 in Marin County which went into effect in July 2013, and which limit the number of dogs per commercial dog walker to 8 or 6 dogs, respectively. The proposed permit requirement would be adopted as an interim measure and would be replaced by a new regulation governing dog walking in GGNRA that would be published in Title 36 of the Code of Federal Regulations. The new regulation would be developed after GGNRA completes the dog management planning project which addresses both recreational and commercial dog walking. The plan and its accompanying environmental impact statement (EIS) are well underway; a draft Plan/EIS was released for public comment in 2011 and a supplemental draft Plan/EIS is expected to be released for additional public comment in Fall 2013. Once the plan is finalized, the NPS will initiate a rulemaking process and seek public comment on the proposed codification of the dog management plan’s regulatory elements in the Code of Federal Regulations. A final rule is not anticipated until 2015. In the absence of this interim action, if the status quo is not changed, commercial dog walkers would continue walking unlimited number of dogs at GGNRA sites where dog walking is currently allowed. Need for the Proposed Action Given the extremely broad geographical reach (parks, open spaces, Port of San Francisco lands, and San Francisco Public Utility Commission properties) of the City and County of San Francisco's ordinance, coupled with the effect of the City of Tiburon’s ordinance, GGNRA reasonably anticipates that a number of commercial dog walkers, who would otherwise use areas that would cause them to fall under these ordinances, will instead walk their dogs in areas managed by GGNRA in San Francisco and Marin Counties that are already regularly used by dog walkers, including commercial dog walkers. The San Francisco ordinance on commercial dog walking went into effect July 1, 2013, although there is a 120 day grace period to allow completion of permit training requirements. As of August X, XX commercial dog walking permits had been issued by San Francisco’s Animal Care and Control. The City of Tiburon’s permit program went into effect July 19, 2013; as of XXX, 2 permits had been issued by the City of Tiburon. Research and interviews conducted as part of the GGNRA’s dog management planning project indicate that there are now at least 100 commercial dog walkers in the City and County of San Francisco, although there are also commercial dog walkers who do not have a business license and are not listed in the phone book. Many of these dog walkers are single individuals (who may or may not be licensed), as well as companies with several employees. There is at least one association for commercial dog walkers in San Francisco (Prodog). In a recent interview about San Francisco’s new commercial dog walking ordinance, a spokesperson for ProDog estimated that there might be as many as 300 commercial dog walkers in San Francisco. In San Francisco, the GGNRA sites most often used by commercial dog walkers are Fort Funston, Crissy Field and Fort Mason, but commercial dog walkers are also seen at Baker Beach and Ocean Beach. 2 GGNRA004238 Commercial dog walkers typically bring between four and ten dogs or more at a time to GGNRA sites and spend about one hour, twice a day, in the park. The San Francisco ordinance is anticipated to have a noticeable impact, particularly at Fort Funston and Crissy Field, the two sites regularly used by dog walkers. Crissy Field already receives very high visitor use (approximately 3.2 million in 2009), including from individual and commercial dog walkers. GGNRA staff estimates that there are generally ten to fifteen commercial dog walkers per day (fewer on weekends than weekdays), and typically at least three present, with at least four to eight dogs each, at any given time of the day. A 2011 Visitor Use Study found that 24% of visitors at Crissy Field were dog walkers. That same study found that at Fort Funston, where the average number of dogs walked on the site each day is 1,600, approximately 62% of daily visitors were dog walkers (66% on weekdays and 57% on weekends). On weekends, 3.1% of dogs at Fort Funston are walked in groups larger than 6, accounting for 10 dog walker visits. However, on weekdays, 34.7% of dogs were in groups larger than 6, accounting for approximately 127 dog walker visits. Of that group 19.4% of dogs were in groups larger than 8 (approximately 61 dog walker visits). The study notes: “At Fort Funston, many visitors were observed with large groups of dogs. While some of these visitors may be individuals who own multiple dogs, most are likely professional dog walkers.” Marin County Parks and Open Space began requiring permits for commercial dog walkers on Open Space lands in 2002; the permits allowed a maximum of 6 dogs per walker. Currently, certain GGNRA-managed sites in southern Marin are used by commercial dog walkers with more than six dogs per person; dog walkers with six or more dogs have been seen at both Rodeo Beach and the Alta Trail above Marin City. The Alta Trail, an easily accessible GGNRA site in close proximity to Tiburon, is regularly used by commercial dog walkers who have an average of ten dogs per dog walker. GGNRA staff have often experienced up to 50 off-leash dogs at one time on the Alta Trail. Because of the ease of access from Highway 101, availability of on-street parking at the trailhead and proximity to Tiburon, Alta Trail is likely to be an alternative for those commercial dog walkers who would otherwise use Tiburon open space areas, where there is now a permit requirement and limit of 6 dogs per walker.