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Last Day to Comment on GGNRA Beach Closures

Offleash SF Dog President Sally Stephens sent us this reminder for dog owners to comment on the GGNRA proposed closures of Crissy Field and Ocean Beach (to protect the Western Snowy Plover). If you have not commented on this very important issue, we urge you to do so now. Here's Sally's letter:

Today, Monday, Jan 21 is the final day to submit public comment on the GGNRA's proposed closure of parts of Ocean Beach and Crissy Field to off-leash dog walking because of the presence of Western Snowy Plover birds. It's important that people set aside their cynicism and comment even if it's just to say "I oppose the closure. There is no scientific evidence that off-leash dogs are deterimental to the plover population at Ocean Beach or Crissy field."

It's too late to mail a comment in, but you can comment online at:

http://tinyurl.com/299re6

For more detailed talking points, you can go to: http://sfdog.org/news/news.htm

Basic points:
1) GGNRA's own data indicates no negative impact on plover populations when off-leash dog walking has been allowed (1996 Hatch Report). Indeed, the numbers actually increase when off-leash dogs are present, perhaps because dogs scare away other plover predators such as ravens.

The GGNRA's own data (2006 Hatch Report) show no negative impact on plover abundance after the court rulings reinstated the 1979 Pet Policy allowing dogs off-leash on Ocean Beach. Plover numbers have fluctuated over the years, but there is no correlation between when the numbers of plovers are low and when dogs are allowed off-leash. Note that similar fluctuations in plover numbers were seen at Half Moon Bay State Park, a beach where all dogs are prohibited (whether on-leash or off-leash).

2) Recent research that actually studied the assumption that dogs "bother" plovers and other birds found that this assumption has no basis in fact.

One study ("Recreation Disturbance Does Not Change Feeding Behavior of the Western Snowy Plover", Megan Warren, UC Berkeley Environmental Sciences 196, Senior Research Seminar, May 7, 2007) found no significant relationship between feeding behavior of plovers and direct disturbance by people recreating on the beach. The study does "not support the hypothesis that western snowy plovers in more heavily disturbed areas devote less time to actively foraging and more time to being alert."

Another study of dogs and birds in urban parks in Edmonton, Alberta ("Effects of dog leash laws and habitat type on avian and small mammal communities in urban parks", Andrew Forrest and Colleen Cassady St. Clair, Urban Ecosyst (2006), vol 9, p. 51-66) found that whether a site was on- or off-leash had "no measurable effect on the diversity or abundance of birds and small mammals." This lack of effect was seen even when they considered only those species that appeared to be breeding, or only those species that nested on the ground or in low shrubs.

3) People without dogs cause "disturbances" equal to those of dogs (1996 Hatch Report), and yet there is no proposal to restrict the access of people without dogs and other recreational users from the plover areas. If the GGNRA is serious about "protecting" the plovers, it would put up temporary fences to keep all park visitors out of the areas in question.

4) The GGNRA should focus enforcement on the few off-leash dogs who actually do chase plovers (in the 1996 Hatch Report, only 19 out of 5,692 dogs, less than one-third of one percent, were observed to deliberately chase plovers; on another 15 occasions at least 100 plovers were "inadvertently disturbed" by dogs -- compared to 80 plovers inadvertently disturbed by people without dogs over the same amount of time). Park Rangers will have to be present on the beach to ticket people with off-leash dogs in the proposed rule, so there is no additional burden on the GGNRA to focus enforcement on those who break existing rules about bothering wildlife.

If you haven't already, please take a few minutes to comment on this proposed closure.

Sally Stephens
Chair, SFDOG

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