am writing to request that you strengthen the leash law regulation proposed for
Ocean Beach and Crissy Field in order to adequately protect the western snowy
plover, people, our pets, the Golden Gate's other wildlife, and the park itself.
The proposed rule contains too many loopholes to be effective and enforceable.
First, the rule is ambiguously worded. It states it will only be in place from "July 1
until monitoring by the park determines that [the plover] is no longer present."
Although plovers tend to leave the park for a few weeks during the summer,
leaving this loophole open will make it difficult for the public to comply with the rule
and also make it difficult for park personnel to enforce. Moreover, by permitting off-
leash dogs in the plover's habitat during any portion of the year, the park will
reduce compliance with the rule when the plover is present, as many people will
not realize that the closure is seasonal. The rule must be expanded to apply year-
round.
The proposed rule is also inadequate because it does not include the entire
portion of Crissy Field and Ocean Beach. It draws imaginary boundaries that do
not comport with typical visitor's understanding of the Golden Gate, and therefore
the typical visitor will not know if he or she is entering an area where plovers are
safe from off-leash dogs. This again will invite violations of the rule, as people
claim ignorance or confusion over the exact boundary. The rule should apply to all
of Ocean Beach and Crissy Field.
Off-leash dogs should not be permitted in the Golden Gate absent safeguards
such as enclosures that will keep people, our pets, wildlife, and the park safe to
all visitors, including the plover. As this species recovers from the oil spill, please
ensure that additional disturbance is minimized by strengthening the leash law at
the Golden Gate, not by creating loopholes, as the current proposal seems to do.
Comment on FR Doc # E7-22654
This is comment on Proposed Rule
Special Regulations; Areas of the National Park System
View Comment
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