Update: May 30, 2013
Proposed Public Use Limit on Commercial Dog Walking in Area B of the Presidio and Revised Disposal Conditions
The Presidio Trust requested public comment on a proposed public use limit on persons who are walking four or more dogs at one time in Area B of the Presidio of San Francisco for payment (Commercial Dog Walkers).
The limit would require Commercial Dog Walkers in Area B to possess a valid Commercial Dog Walking permit obtained from the City and County of San Francisco (City). Commercial Dog Walkers would be required to comply with the terms and conditions of the City permit as well as those rules and regulations otherwise applicable to Area B. The Trust also proposed that throughout Area B, all dog walkers should remove pet excrement and deposit it in refuse containers. The initial 65-day comment period for the proposed use limit published November 21, 2012 (77 FR 69785–69788
) was extended by 30 days at the request of the public (78 FR 6273–6274
By the close of the public comment period on February 25, 2013, the Trust had received 256 individual comments on the proposed use limit, including 9 oral comments provided at the public meeting of the Trust Board of Directors on November 29, 2012.
All comments were carefully considered. View the full record of comments >>
Public Reaction to Proposed Use Limit
The comments received either express support for (49 percent) or opposition to (51 percent) the public use limit. Support for the requirement to properly remove pet waste was unanimous. Commenters in support of the public use limit maintain that commercial dog walkers have been using the Presidio for years, that commercial dog walkers provide an invaluable service to the residents of the City, and that adopting the rule is reasonable and appropriate. “Professional dog walkers provide needed exercise and socialization for responsible, safe, and humane dog care. Well cared for and loved dogs improve the health, safety, and well being of the people that live in the City” (Comment 34). “These requirements will standardize dog walking practices and provide better and safer services for dog owners and dogs living in the Presidio and adjacent City neighborhoods” (Comment 70). Many of the supporters feel that the Presidio should be viewed as a different kind of national park, as it serves a broad community of users and residents and accommodates numerous commercial interests. “We live in a densely populated area, not a true wilderness” (Comment 27). Several of those that otherwise express support believe that the maximum limit of eight dogs is too many for Commercial Dog Walkers to reasonably keep under their control.
Commenters who oppose the proposed use limit are largely “dissatisfied with the status quo” of the presence of Commercial Dog Walkers in the Presidio and wish to see the activity prohibited by enforcement of existing laws (Comment 2). They argue that commercial dog walking should be viewed as an “exploitation of park lands strictly for private financial gain, a use that is not compatible with the preservation of park values, park resources, and the park visitor experience” (Golden Gate Audubon Society Conservation Yahoo Group). Others who oppose the use limits appreciate the Trust’s efforts to accommodate commercial dog walking, but are concerned that more analysis is needed to determine spillover effects in Area A (Comments 6 and 7). Still others are against the proposed use limit because they believe the Trust is targeting Commercial Dog Walkers unfairly. “I see far more problems with individual dog owners who do not know how to handle their one, or two badly behaved dogs” (Comment 199) and “individual dog owners more often believe that their dog is well behaved, under voice control, and doesn't poop, when, in fact, none of this is true” (Comment 164). Finally, there are those that do not support any changes in dog regulations. They think the proposed limit is “foolish” and a “useless and unnecessary burden on lawful commercial and entrepreneurial commerce” (Comment 233) and believe “it’s ridiculous that time and energy is wasted on matters such as this… after hearing from the public over and over again about their love of dogs and the freedom of walking them in the Presidio...” (Comment 191). “Stop blaming dogs for all management issues!” (Comment 166).
National Park Service Letter
In its letter to the Trust, the National Park Service (NPS) states its support for the Trust’s action to manage commercial dog walking, without which “a potential redistribution [of Commercial Dog Walkers] could impact the Presidio Trust’s mandate to preserve and protect the park’s resources” (Comment 1). The NPS disagrees, however, with the number of dogs allowed under the City permit, and argues that a limit of six dogs is less likely to impact visitor experience and safety than eight. In response to the City’s program and Trust’s proposal to regulate Commercial Dog Walkers, the NPS is considering developing an interim commercial dog walking permit program for its San Francisco sites that would limit the number of dogs allowed to six, which is consistent with the proposed limits specified in the alternatives that permit commercial dog walking in the NPS’ upcoming Dog Management Plan/Supplemental Environmental Impact Statement for Area A and other NPS-managed lands within the Golden Gate National Recreation Area (GGNRA). Given the Trust’s and NPS’ shared management responsibilities within the Presidio, the NPS has asked the Trust to consider adopting the NPS’ interim commercial dog walking permit system, should it be implemented, rather than that being implemented by the City.
The Trust is encouraged that the NPS is considering moving forward at this time to create and implement an interim enforceable permit program to regulate commercial dog walking for GGNRA’s San Francisco sites. Rather than accepting the terms and conditions of the City’s permit as initially proposed in our public use limit, we see value in a bilateral and consistent Trust/NPS approach to Commercial Dog Walker management as a way to both avoid public confusion and protect park resources within the GGNRA. Therefore, after examining all public comments and considering the new information provided by the NPS, the Trust will postpone any decisions regarding the regulation of commercial dog walking until the earlier of November 1, 2013 or the date that an NPS interim commercial dog walking permit system may be enacted. Before taking any action, the Trust will provide the public with an additional opportunity to comment.
The Trust finds no compelling reason to delay the revised pet waste disposal regulation and will implement it as soon as possible. The Trust will provide additional refuse containers in places convenient to dog walkers to support enforcement of the regulation.
We thank you for your interest and participation in our effort to regulate commercial dog walking within Area B of the Presidio.
For Further Information Contact
Joshua Steinberger, Director of External Affairs, (415) 561-5300