Comment on FR Doc # E7-22654

Do not release my contact infromation to requesters. Preliminary comments: 1. On p. 65279, the GGNRA claims that the GGNRA permitted dogs to roam off leash in the park historically. This is not accurate. The park never went through formal or informal rulemaking to permit off-leash dogs, they just brazenly ignored the rule on a local level through "compendium" amendments that are not subject to public scrutiny. It was wink-and-nod policy, which is not consistent with basic principles of good and honest government. 2. On p. 65278, GGNRA claims that increased enforcement of the restrictions would be a good idea. We agree, but the rule contains no specific measures to enforce and prosecute leash law violations from the line officers and their duties to getting NPS and US Attorney lawyers to prosecute violations. As evident by Josiah Clark's recent situation, Park Police have been directed not to enforce wildlife protection laws and this rule doesn't change that institutional problem. A rulemaking must do something along those lines to be effective by including an enforcement plan. 4. on p. 65280, the limits of this rule are made clear. These ?protections? give away more than ? of the last remaining protected beach habitat at Ocean Beach and a third of it at Crissy Field to off-leash dogs all year. This is absurd in a National Park which contains a directive to preserve imperiled species such as the plover. Where will they go instead: private lands to the north or south of the park? 5. on p. 65280, the rule explains it is also temporary until the reg-neg rulemaking process is over. This is arbitrary and capricious, because these areas were never on the table in the reg-neg process for off-leash dogs at any time of the year. There is simply no reason for the GGNRA to make this rule a temporary rule. Furthermore, reg-neg was an abject failure and reached no consensus on protecting wildlife or park visitors from harm. It is also unrealistic for NPS to think GGNRA will get closure from reg neg in 2009. This rule should be permanent. 6. on p. 65280, the rule is inadequate and will lead to additional confusion because it is only a seasonal closure and will not apply year round. Plovers are present in the GGNRA almost year round, perhaps 1 or 2 months of the year they are absent. By creating limited exceptions the GGNRA creates problems for compliance and enforcement: it creates confusion for both anti-leash groups and park police and therefore leads to enforcement problems.