Once again the GGNRA plans to close parts of Ocean Beach and Crissy Field to offleash dog walking to "protect" the western snowy plover. The areas proposed for closure are:
Ocean Beach -- from Stairwell 21 (just south of the Beach Chalet) south to Sloat Blvd
Crissy Field -- Wildlife Protection area at the west end (Warming Hut end) of the beach.
The closures are described as "seasonal" because they are only in effect when the plovers are actually present. But the birds are present from July through May, leaving at most two months (and more realisticially about one month) when the offleash restrictions are not in place.
Public comment on the proposed closure is due before Jan 22, 2008. There are two ways to comment:
1) online -- Go to: http://www.regulations.gov
Use
the center text box "Comment or Submission" and enter "GGNRA Plover"
and click on "Go" to get to the next page. From there, click on "Send a
Comment or Submission" to get to the actual comment page. It's not
particularly user-friendly.
2) Mail or hand deliver your comment to:
Superintendent
GGNRA
Fort Mason, Building 201
San Francisco, CA 94123
Attn: Snowy Plover Protection Rule
When the Federal Government moves to ban a single class of people from public land because of who they are, not anything they have done, they better have solid scientific evidence that the move is absolutely necessary. That is not the case here. Claims of "disturbances" of plovers by offleash dogs are anecdotal. Reports are based on observations with no attempt to address or correct bias in the people making the observations. The reports are based on commonly repeated assumptions that have never been put to the test. The GGNRA is moving to ban people with offleash dogs from two large areas on Ocean Beach and Crissy Field solely because of who they are -- people with offleash dogs -- not because their dogs have done anything. Other user groups that cause similar (and possibly greater) "disturbances" to the plovers are not banned. Without undisputed, solid evidence that proves offleash dogs cause signficant "harm" to plovers, the GGNRA should not adopt a discriminatory ban against this single class of people -- those with offleash dogs.
Please take the time to send in your comment on the proposed closure. Comments must be received before Jan 22.
More info on the closure can be found at the Ocean Beach Dog website: http://oceanbeachdog.home
Some talking points to consider:
1) There is no scientific consensus that offleash dogs have a significant impact on bird and wildlife populations.
A
recent study by Forrest and Cassady St. Clair (2006) (see below for
citation information) studied diversity and abundance of birds and
small mammals at 56 sites in urban parks in Edmonton, Alberta. To their
surprise, they found that whether a site was on- or off-leash had "no
measurable effect on the diversity or abundance of birds and small
mammals. Indeed, they said, "wildlife, particularly birds, in suburban
and urban areas exist there because they are fairly tolerant of
moderate levels of human activity."
2) The GGNRA's own studies
indicate that dogs have no significant negative impact on the
population of snowy plovers at Ocean Beach,
The Nov 15, 1996 report
of snowy plovers by GGNRA staffer Daphne Hatch found that there was an
increase of more than 100% in the number of snowy plovers in the years
after the 1979 Pet Policy went into effect (allowing offleash dogs on
Ocean Beach and elsewhere). There was no negative relationship between
the number of dogs and the numbers of plovers on the beach at the same
time. Indeed, the 1996 Hatch Report says: "Factors other than the
number of people or dogs, possibly beach slop and width, appear to
exert greater influence over Snowy Plover numbers on Ocean Beach."
3)
The GGNRA's own data indicate that there was no negative impact on
plover abundance after the court rulings reinstated the 1979 Pet Policy
allowing dogs offleash on Ocean Beach. Indeed, the numbers actually
increased.
A follow-up 2006 Hatch Report considers effects on the
numbers of plovers after two Federal Court rulings reinstated the 1979
Pet Policy, allowing offleash dogs back on Ocean Beach. According to
the study, the maximum number of plovers ever recorded was in 1994, at
a time when there were no restrictions on offleash dogs on Ocean Beach.
Numbers of plovers have varied since then, (from a low of 14 in 2000 to
35 in 2005), but there is no correlation between when numbers of
plovers were low and when dogs were allowed offleash. Over the same
time period, similar changes in plover populations have been seen at
Half Moon Bay State Park. At that beach, there was once a maximum of 60
plovers, but there are currently only 25-30 present. This decrease
cannot be blamed on dogs since dogs are not allowed on the beach at the
state park at all, even onleash. Clearly any decreases in plover
populations in recent years are unrelated to whether offleash dogs are
present or not. Indeed, data from the 2006 Hatch Report posted by the
GGNRA on its website actually show an increase in plover numbers in
2005, the year after the first Court Ruling. The annual mean of snowy
plover numbers (total number of plovers observed during all surveys in
a year, divided by the number of surveys done that year) show an
increase in plover populations after the Court rulings (from 26.55 in
2004 to 31.30 in 2005). The annual snowy plover median listed (the
number of plovers counted in a single survey, with half the surveys
counting more plovers than the median number and half the surveys
reported less) is 28 for 2004 and 33 for 2005.
4) People without dogs pose an equal "risk" to plovers, yet there is no attempt to restrict their access to the plover areas.
Unable
to prove any impact on plover population numbers, the 1996 Hatch Report
argued that dogs "disturb" plovers. However in the entire 1.5-year
study, only 19 out of 5,692 dogs -- less than one-third of one percent
-- were observed deliberately chasing plovers, and none was reported to
actually catch or harm a bird. The report adds that on another 15
occasions, at least 100 additional plovers were "inadvertently
disturbed" by dogs, comparing this to the 48 plovers inadvertently
disturbed by people without dogs, implying dogs inadvertently disturb
plovers at least twice as often as people alone. But a closer reading
of the report shows that the disturbances from people were noted in
about half the recording time (24 hours of observations) as that
devoted to studying dogs (40 hours). Had the two groups been observed
for equal amounts of time, the number of disturbances would have been
nearly the same. Yet there are no proposed restrictions on people
without dogs who walk or run through the plover protection areas.
Note that in the 2006 Hatch Report, an incident is classified as a "disturbance" when, in response to an offleash dog, a plover lifted up its head and looked around. This overreaching and misuse of the term "disturbance" illustrates the bias inherent to the Hatch observational studies.
5) The Federal Government cannot make policy decisions
(such as this proposed closure) that are based on assumptions that have
no hard data to back them up.
The assumption that any disturbance of
plovers or other shorebirds causes significant problems for the birds
is repeatedly stated as fact. However, even the 1996 Hatch Report says
that "Little research has been conducted on the energetic effects of
disturbances, and on whether individuals can compensate for this lost
energy intake and increased energy expenditure." One recent study,
conducted as part of a Senior Research Seminar at UC Berkeley did test
the commonly repeated assumption that recreational disturbances changed
the feeding behavior of snowy plovers. Megan Warren (2007) found no
significant relationship between feeding behavior and direct
disturbance by people recreating on the beach. "The Crissy Field study
did not provide any relevant results, however, the data from the two
Point Reyes study sites do 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." What other
often-repeated assumptions about the effects of disturbances on plovers
and other shorebirds will be similarly disproved when studies are done
that put them to the test? Do we really want to restrict an entire
class of people based on unproven assumptions?
6) The studies of offleash dogs in the GGNRA do not consider "real" threats to plovers from natural predators like ravens.
Offleash
dogs may be more likely to chase ravens, a natural predator of plovers,
because the ravens are so large. Thus the presence of offleash dogs may
keep ravens away from plover areas. This is one possible explanation
for why the numbers of plovers increase when offleash dogs are present.
7) If the GGNRA was sincere about protecting plovers, they would put up "temporary" fences to keep ALL park visitors out of the plover protection areas, not just people with offleash dogs. To restrict only one class of park users and not others who have similar "effects" is discriminatory.
8) The GGNRA has not taken any other action to protect plovers, despite clear opportunities to do so.
During
the recent Cosco Busan oil spill, the GGNRA quickly erected floating
booms to keep oil from entering the Crissy Field lagoon at the eastern
end of Crissy Field, yet made no attempt to similarly protect the
plover area at the western end of the beach. The oil posed a
significant risk to the plovers, yet the GGNRA did nothing to protect
them from it. Indeed, oiled plovers have been reported in the GGNRA.
The GGNRA has allowed sporting events like the 2006 Turkey Trot to
proceed, with the result that at least 1000 people (more likely 1500)
walked or ran through the plover protection area on Ocean Beach. Park
rangers routinely drive four-wheel drive cars and trucks through the
Ocean Beach plover protection area while pursuing people with offleash
dogs. During Fleet Week, the plover protection area at Crissy Field is
filled with people watching the air show, with no restrictions or
protections in place. Dead sea mammals are left on beaches, encouraging
natural predators of plovers like ravens to come to the beach.
9)
The GGNRA should focus enforcement on offleash dogs who actually do
chase plovers. Banning an entire class of people (those with offleash
dogs) from the area because of the actions of a very few is
discriminatory and does not offer the plovers any significant increase
in safety.
In order to ticket people with offleash dogs in the
plover protection areas, Park Rangers will have to be present at the
sites. They could, therefore, easily cite people whose dogs chase
plovers (the few) and leave those people whose dogs ignore the plovers
(the vast majority) alone.
10) Even if the restriction is justified, the area closed at Ocean Beach is much too large.
The
plovers are located down by Noriega St, and yet the area closed begins
near Lincoln, nearly six city blocks farther north. A similarly large
buffer zone is claimed at the southern end of the plover area. The
buffer zones are too large and should be shortened.
Please, send in your comments, before Jan 22. Thank you.
Permission to post this email to other lists for groups that support offleash recreation in the GGNRA is hereby given. Permission to copy or post this email (or any portion of it) to lists or groups that oppose offleash recreation in the GGNRA is not given.
Scientific Citations:
1)
"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
2) "Recreation
Disturbance Does Not Change Feeding Behavior of the Wester Snowy
Plover", Megan Warren, UC Berkeley Environmental Sciences 196, Senior
Research Seminar, May 7, 2007
