Long-standing policy and historical use set precedent for off-leash dog walking at Crissy Field, Fort Funston and other GGNRA Land

See: Legislative history for the 92nd Congress, Second Session, 1972, from the House Report, Section 1(c) of USC Section 16:

"As a national urban recreation area, this new component of the National Park System will be confronted with problems which do not frequently occur at other national park and recreation areas."(Page 4857)

"It is expected that the predominant use of the recreation opportunities offered by the Golden Gate National Urban Recreation Area will be the people residing in the nine county San Francisco Bay Region."(Page 4852)

"It is an ideal location for a national urban recreation area for many reasons, but foremost among them must be that the Golden Gate National Urban Recreation Area is located in the heart of one of the nation's major urban complexes."(Page 4851)

Our right to walk dogs off-leash arises from the Organic Act (16 USC 1c), the enabling statute for the GGNRA (16 USC460bb), and the promise made to the City in 1975 that "historical recreational activity" occurring on the beaches and contiguous parks would be continued, and from promises made to the community in 1995 while soliciting funds for the Crissy Field restoration projects.

The Organic Act of 1916 Section 16 USC 1c requires the National Park Service (NPS) to develop regulations consistent with specific provisions for each national park.GGNRA was established to provide "needed recreational open space necessary for urban environment and planning." 16 USC 460bb.To understand what Congress meant by "needed recreational open space necessary for urban environment" one must look to the legislative history of the enabling statute.

The use of these parks for off-leash recreation was specifically addressed during the House Hearings on the parks. One letter by a six year old child from San Francisco confirms that these beaches were intended to be used for recreation by children and dogs: "Dear Congressman Roy Taylor: I want a park so I can play in the park and my sister wants a park too and so my dog can play with another dog and my Mom wants a park so she could take my dog out to play. I hope you will make a park. Elizabeth Linke" House Report on Hearings, page 414.

The House Report also enumerates dog walking as a necessary urban recreational activity at Page 4852:

"On a nice day, it will satisfy the interest of those who choose to fly kites, sunbathe, walk their dogs, or just idly watch the action on the Bay." (Page 4852)

The City was promised in 1975 that "historical recreational" use like off-leash dog walking would be continued if the beaches were donated to the NPS.

The NPS through the auspices of the Citizens Advisory Commission developed a 1979 Pet Policy designating off leash areas because "ordinary guidelines outlined in the Code of Federal Regulations do not really apply in an urban area. People and their animals have been visiting the park for too long to apply an all-inclusive arbitrary policy."

In 1992, Stanley Albright, NPS Director of Western Region advised both Senators Cranston and Seymour that the 1979 Pet Policy was the official policy for the GGNRA.

In 1995 NPS promised San Franciscans that off-leash dog walking would be increased to 60 acres if they would donate money to development of the new restoration area at Crissy Field.

On March, 19, 1999, Superintendent Brian O'Neill advised Representative Nancy Pelosi in a letter that "GGNRA has adopted a pet policy that is more liberal than pet regulations at other national park sites throughout the country. In all other areas of the national park system, pets are required to be leashed at all times and are, for the most part, excluded from all but developed areas. GGNRA has, with the assistance of the park's Advisory Commission, established a pet policy that allows some opportunity for visitors to enjoy a few designated areas with their pets under less restrictive circumstances. Certain areas of the park have been designated as voice control areas where pets are permitted off-leash."

For over thirty years, NPS has admitted that off-leash recreation is a recreational activity "necessary for urban environment" as provided by the enabling statute. Under 16 USC 1c general provisions inconsistent with specific provisions of the enabling statute are not applicable. For this reason, the general regulation does not apply to this urban park, in the same way that it does not apply to those 45 parks where hunting is permitted.

Off-leash Dog Walking is not Illegal Use.  The 1979 Pet Policy is not illegal. 

Please – let your voice be heard

Write to the GGNRA, to Secretary of the Interior Gale Norton, to local and state and national elected representatives in support of Off-Leash Dogs.