Categories: Sally Stephens

A flawed process rigged from the start

I used to think of the National Park Service as good guys. Not any more. Over the past decades, NPS staff in the Bay Area have run roughshod over local concerns, repeatedly lied to the community and presided over an incredibly biased, unfair public process.

Last week, Park Service announced a new rule outlining where you can walk with a dog in the Golden Gate National Recreation Area. No matter what you think about the issue, you should be appalled at the way NPS developed the rule.

Federal law requires government agencies to consider public comments before making any decision that is either significant or highly controversial. Yet Park Service staff repeatedly ignored this mandate. Whether it was closing areas at Fort Funston to all visitors — not just people with dogs — or unilaterally rescinding the policy that had allowed dogs off-leash for decades on under 1 percent of GGNRA land, NPS made the changes without the required public comment period. People had to resort to the courts to force NPS to follow the law.

In the Fort Funston closure case, for example, NPS staff publicly assured the community there would be no additional closures after two areas had been cordoned off to all visitors. At the same time, in private, they were plotting how best to quickly fence off a third area. A federal judge found that emails between GGNRA staff about this third closure “show an intent on the part of the National Park Service to railroad through the closure, to maintain secrecy, to unleash the fencing with lightening [sic] speed, and to establish a fait accompli.”

That’s not how a government agency should act.

Even when they do take public comment, however, the Park Service ignores anything that doesn’t fit their predetermined view. At every stage of the process that resulted in last week’s rule, public comment has been overwhelmingly opposed to further restrictions on dog walking. Yet, at every stage, NPS has continued to push their plan for large cuts in access, with few changes.

Keep in mind, the GGNRA was created by Congress to “concentrate on serving the outdoor recreational needs of the people of the metropolitan area.” It is not a remote, pristine wilderness, but rather a highly modified, urban area. Yet the Park Service wants to manage the GGNRA, envisioned and created as a recreational area, the same as a national park.

At first, the Park Service proposed cutting the less than 1 percent of the GGNRA where people can now walk with a dog by nearly 90 percent. It’s really people who enjoy walking with dogs who will be forced out of these areas, not only the dogs. This cut would be the largest reduction in people’s recreational access in GGNRA history. NPS offered no scientific or site-specific evidence to justify the new restrictions.

A second version of the plan had only minor, cosmetic changes. Now the draft rule is out, with virtually no change from the second version … or the first.

The Boards of Supervisors of all three counties with GGNRA land — San Francisco, Marin and San Mateo — have gone on record opposing the plan that doesn’t consider impacts on city parks if thousands of people with dogs are forced out of the GGNRA.

A year ago, I went with a group to Washington, D.C. to talk with Congress about our concerns with the Park Service. Every member of Congress or staffer with whom we talked — both Republicans and Democrats — had their own stories of major problems with NPS and the agency’s heavy handedness with local communities.

There’s a culture deeply entrenched within the Park Service that encourages its unelected bureaucrats to make management decisions with little respect for public input, and then impose those decisions on the park or recreation area, without regard for how they impact surrounding communities.

The GGNRA, created to bring more people to nature, is now forcing large numbers of people out. Dog groups have participated in this decades-long process in good faith, only to find the process was rigged from the start.

For more information on the draft rule, go to

Sally Stephens is an animal, park, and neighborhood activist who lives in the West of Twin Peaks area.

Sally Stephens

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