Saturday, January 15, 2011
GGNRA Draft Environmental Impact Statement: The Poison Pill
The 2,400 page GGRNA Draft Environmental Impact Statement purports to offer its proposed alternative (almost everywhere on leash or no dogs at all) and then several alternatives. However, buried deep within the document is the GGNRA's poison pill, which itself demonstrates that the alternatives are illusory - nothing more than a default to the GGNRA's desired change:
"In order to ensure protection of resources from dog walking activities, the dog walking regulations defined in action alternatives B, C, D, and E would be regularly enforced by park law enforcement, and compliance monitored by park staff. A compliance-based management strategy would be implemented to address noncompliance and would apply to all action alternatives. Noncompliance would include dog walking within restricted areas, dog walking under voice and sight control in designated on-leash dog
walking areas, and dog walking under voice and sight control outside of established ROLAs.
If noncompliance occurs, impacts to resources have the potential to increase and become short-term minor to major adverse. To prevent these impacts from increasing or occurring outside of the designated dog walking areas the NPS would regularly monitor all sites. When noncompliance is observed in an area, park staff would focus on enforcing the regulations, educating dog walkers, and establishing buffer zones,
time and use restrictions, and SUP restrictions. If compliance falls below 75 percent (measured as the Executive Summary xiv Golden Gate National Recreation Area
percentage of total dogs / dog walkers observed during the previous 12 months not in compliance with the regulations) the area’s management would be changed to the next more restrictive level of dog management. In this case, ROLAs would be changed to on-leash dog walking areas and on-leash dog walking areas would be changed to no dog walking areas.
This change would be permanent. Impacts from noncompliance could reach short-term minor to major adverse, but the compliance-based management strategy is designed to return impacts to a level that assumes compliance, as described in the overall
impacts analysis, or provide beneficial impacts where dog walking is reduced or eliminated."
A ruse by any other name is still a ruse!!