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Off-Leash Dogs and the Protection of Wildlife in the GGNRA

by Keith McAllister



The ANPR document is a long argument against off-leash recreation in the GGNRA.  Many of the specific arguments used are based on the National Park Service’s mandate to protect and preserve the wildlife in its charge.  Off-leash advocates concur with the desire to protect wildlife.  The wildlife within the GGNRA can be protected while off-leash recreation occurs in a small portion of the GGNRA.  This is exactly the meaning of ANPR Option B:  Identify specific locations/ways to address off leash use within the park.  I will go through a number of the concerns raised in the ANPR document to show that they do not preclude simultaneous wildlife protection and off-leash recreation.  I will also show instances where current GGNRA policy is designed to eliminate off-leash dogs rather than to protect wildlife.


Rocky Mountain Wildlife

In the ANPR document the GGNRA presents a list of claimed harmful effects of off-leash dogs under the heading “Impacts to Natural Resources.”   The first five claims are attributed to Effects of Recreation on Rocky Mountain Wildlife (herein Rocky Mountain Wildlife), which allows the GNRA to pretend they are based on science.  In fact these claims are not supported by science.  I will discuss them individually.


GGNRA/ANPR:  “Scientific studies attribute disturbance, harassment, displacement, injury and direct mortality of wildlife to domestic dogs that accompany recreationists.”


This comes from Rocky Mountain Wildlife, Chapter 8, “Domestic Dogs”, p 8.2.   GGNRA inserts the words “scientific studies,” a claim which Sime, the author of  “Domestic Dogs,” does not explicitly make.  On p 8.3 Sime uses similar language but attributes the harmful effects to “uncontrolled domestic pets.”


The scientific studies cited in “Domestic Dogs” do not report wildlife killed or injured by domestic dogs accompanied by recreationists.  The studies report that deer were chased, injured, and killed by a) specially bred and trained hunting dogs, usually under the direction of a wildlife researcher, and by b) unaccompanied dogs.  The latter include feral dogs, stray dogs, dogs running free without companion in rural areas, and coyotes.  The presence of a recreationist with a dog is not documented in these studies. 


Only deer were killed.  No other wildlife discussed in “Domestic Dogs” were injured or killed by dogs.  These studies are irrelevant to the lands under discussion in ANPR.  The “Conclusions” paragraph to “Domestic Dogs” begins, “Published data specific to wildlife disturbances attributable to companion dogs (emphasis added) are lacking,” a conclusion which the GGNRA should accept.


GGNRA/ANPR:  “This study indicates that domestic dogs retain their instincts to hunt or chase.”


Rocky Mountain Wildlife, “Domestic Dogs,” does say this, on p 8.2 and p 8.3, but does not present any scientific study to support the statement.  


GGNRA/ANPR:  “…mere presence of a dog can frighten wildlife away.”


“Domestic Dogs” says on p 8.2, “… disrupt many wildlife species.” and on p 8.3, “…may be an agent of disturbance or stress to wildlife.”  The phrase “frighten away” is not used.  On page 4.10 Rocky Mountain Wildlife says, “For some species of small mammals, just the presence of humans (emphasis added) may have adverse impacts.”


The deer that were chased from their home range by hunting hounds were not frightened away by the “mere presence of a dog.”


Studies cited in “Domestic Dogs” show that dogs could flush birds.  The studies also show that the mere presence of a person can frighten birds away.  The birds return.  The studies do not show that the birds are “frightened away” in the sense that they abandon their home range. 


Studies not cited in “Domestic Dogs,” show that the presence of humans disturbs songbirds more than the presence of off-leash dogs.  Miller, Knight, and Miller (“Wildlife responses to pedestrians and dogs,” Wildlife Society Bulletin 2001) disturbed vesper sparrows and western meadowlarks, both on and away from trails, with a dog alone, with a person alone, and with a person with a dog on leash.  The smallest area of influence and the shortest flush distance and distance removed resulted from the dog-alone treatment.  They disturbed American robins with person alone and dog-on-leash, and found that the area of influence, flush distance, and distance moved did not generally differ between the two treatments. 


GGNRA/ANPR:  “…urine and fecal deposits…equally alarming to native species…”


This statement is not made in Rocky Mountain Wildlife, “Domestic Dogs”.  GGNRA cites no other source for the claim.


GGNRA/ANPR:  “…vegetation may also be destroyed.”


“Domestic Dogs,” p 8.9, refers to “Sensitive alpine environments…” where “…physical disturbance by dogs…could damage vegetation and soils…”


This is presented as speculation, with no study cited.  Note that there are no alpine environments under discussion in ANPR. 


Further, Rocky Mountain Wildlife devotes a whole chapter to “Vegetation, Soils, and Water.”  The chapter discusses trampling and other harmful effects of human recreation on vegetation and soils, but does not mention dogs.


Rocky Mountain Wildlife, particularly Chapter 8, “Domestic Dogs,” makes many incriminating statements against off-leash dogs accompanying recreationists, but the statements are speculative, without evidence to support the indictments.  They present no studies focused on the effects of off-leash recreation on wildlife.  On the other hand, a study like “Wildlife responses to pedestrians and dogs,” (cited above) was designed to evaluate the effects of off-leash recreation on wildlife, and shows the dogs are less disturbing to songbirds than are humans.  Results like this aren’t mentioned in “Domestic Dogs” or the ANPR document.


Off-leash recreation in the GGNRA will not involve 1) hunting deer with trained hunting dogs, or 2) free-roaming, unaccompanied dogs.  The bloody stories cited in Rocky Mountain Wildlife, “Domestic Dogs,” do not argue against off-leash recreation in the GGNRA. 


Another study not included in “Domestic Dogs” (“Interactions among dogs, people, and the environment in Boulder, Colorado: A case study,” Anthrozoos 1997) directly observed the interactions of off-leash dogs with people and wildlife in four open space areas near Boulder and two locations in Boulder.  Bekoff and Meaney found:  “Behavioral data showed that off-leash dogs generally did not travel far off trail, that when they did it was for short periods of time, and that they were rarely observed to chase other dogs, disturb people, chase wildlife, destroy vegetation, or enter bodies of water.”


Bank Swallows

In the ANPR document the GGNRA continues its false claim that banning off-leash dogs is necessary for the protection of the Bank Swallow colony at Fort Funston.


GGNRA/ANPR:  “The goals and objectives of the closure were to: (1) Provide protection to the new nesting locations of the state-listed (threatened) bank swallow colony at Fort Funston;”


In fact, off-leash dogs have no negative impact on the Bank Swallow colony at Fort Funston.  There is no evidence of negative impact; there is no reason to expect a negative impact; and actual observation in the field has shown there is no negative impact.


During two years of public discussion, neither GGNRA nor Golden Gate Audubon has presented a single piece of credible scientific evidence that off-leash dogs have any negative impact on the Bank Swallows at Fort Funston.  The ANPR document does not cite any such evidence.


There is no reason to expect, a priori, a negative impact on the Bank Swallows from off-leash dogs.  Bank Swallows are remarkably tolerant of human activity close to their nesting colonies, and care little about the surrounding vegetation.  I will cite two swallow experts:


Bank Swallow, by Barrett Garrison, says, “Bank Swallows appear relatively insensitive to moderate levels of human-induced disturbance.”  Garrison lists documented land uses around Bank Swallow colonies:  hydroelectric power generation, irrigation, recreational boating, commercial agriculture, vehicular and pedestrian traffic, and livestock grazing.  Garrison then says, “These land uses appear relatively benign as long as the integrity of the nesting bank remains,” and, “Adjacent land uses that retain nesting bank integrity, allow bank erosion to occur, and provide insect food resources are unlikely to have substantive adverse impacts to Bank Swallows.”  Regarding surrounding vegetation, Garrison says, “There appears to be no selection for specific vegetation communities …” and lists the vegetation amidst which California colonies are found:  riparian forests, deciduous orchards, irrigated row crops, dryland grain crops, coastal grassland, coastal scrub, coniferous forests, irrigated pasture, and desert scrub.  Garrison also lists many predators on Bank Swallows, but does not mention dogs.


William Shields (Professor of Biology at SUNY, elected fellow of American Ornithologist’s Union, leader of SUNY’s Conservation Biology concentration, in letter to GGNRA re: closures at Fort Funston, October 2000) reiterates the Bank Swallow’s tolerance of human and pet presence and their lack of appreciation for “native plants.”  “The poor arguments presented in their (GGNRA’s) plans make little sense to me.  The Bank swallow like other swallows is quite suited to live with humans and their pets.” and, “… I do not understand or condone what I believe are their misrepresentations about the needs and safety of the Bank Swallows breeding in the cliffs.  … the notion that the swallows would do better by having more species of insects or even more insects on the short flyway between their breeding burrows and their main foraging sites at the nearby lake is a major stretch and smacks of special pleading to me.”


There is good, observational evidence from Fort Funston that off-leash dogs are not a problem for the Bank Swallow colony.  I provide three such reports:


Betsy Cutler  (A Bank Swallow Colony on an Eroded Sea Cliff, 1961) spent 131 hours observing the 1960 breeding season of the Bank Swallow colony at Fort Funston.  She saw no successful predation, although one Kestrel was mobbed at the colony and another was chased away by a few swallows.  She notes the presence of dogs (as well as Ravens, Red-tailed Hawks, horseback riders, helicopters, and jet planes), but does not indicate they harmed the swallows.


Nola Chow (1994-95 Bank Swallow Annual Report, 1996) together with other observers, closely monitored the Fort Funston Bank Swallow colony during the 1994 breeding season, and less closely monitored the 1995 season.  In 1994 they logged more than 124 observer-hours on 24 days. 


Chow’s observers documented Kestrel predation in both 1994 and 1995.  They also noted the presence of Ravens, aircraft, people, hawks, dogs, nesting starlings, and a hangglider.  Chow writes, “Observers noted on two occasions swallow activity ceased when aircrafts (sic) flew near the colony, but responses to the other potential disturbances were not noticed or documented.”  That is to say:  They carefully observed the dogs and the Bank Swallows at Fort Funston and saw no negative impact of dogs on the swallows.


Chow notes a decline in the colony population from 1994 to 1995.  She attributes the decline to Kestrel predation, “limited site fidelity” of breeding Bank Swallows (i.e. they may have gone elsewhere to nest), and graffiti on the cliff face.  Dogs are not mentioned.  Chow identifies graffiti, Kestrels, hanggliders, and fireworks as problems that management should ameliorate.  Again, dogs are not mentioned.  It must be noted that many off-leash dogs where present at Fort Funston in 1994 and 1995; they simply had no negative impact on the Bank Swallows.


The colony decline from 1994 to 1995 documented by Chow occurred contemporaneously with GGNRA destruction of iceplant, replanting of the sand dunes, and closure of the area to the public, efforts that purported to be for the protection of the colony.  The colony declined further in 1996, when the 1992-95 round of replanting and closure was complete.  Fencing dogs (and people) away from the colony did not help the swallows.  In fact, the swallows moved away from the protected area into an unprotected area where iceplant still thrived.  GGNRA efforts are ineffective because they are based on unscientific dogma that a) Bank Swallows are harmed by proximity to dogs, and b) Bank Swallows prefer “native plants” to iceplant.


The author, Keith McAllister, spent 39 hours on 37 days from April 29 to August 7 observing the colony during the 2001 breeding season.  He observed both from the beach beneath the colony and from the paved trail directly east of the colony (observing the swallows as they commuted between their nesting area and their foraging area at Lake Merced).  Dogs were present on the beach each day, but there was never an indication that a dog was aware of the presence of the Bank Swallows, nor that the swallows reacted to a dog.  The Bank Swallows commuting across the iceplant flew directly over people and dogs, without apparent reaction or deviation from their flight path.  Just as on the beach, the dogs on the dunes showed no indication they were aware of the swallows.


The inescapable conclusion is that the Bank Swallow colony at Fort Funston can be completely protected in the presence of off-leash dogs.  The colony needs two important things:  1) People (and dogs) must be kept off the cliff edge directly above the colony while the birds are present, in order to prevent cliff collapse from destroying active nesting burrows, and 2) People must be prevented from climbing the cliffs beneath the active colony.  Both can be accomplished with informative signage and limited fencing during the nesting season.  It would also help if the Park Service would eliminate fireworks on the beach beneath the nesting colony, particularly around July 4 when the colony is occupied and active. 


The banning of dogs which cause no harm while allowing cliff climbing and fireworks to continue show that the GGNRA goal is simply to ban the dogs, not to protect the Bank Swallow.


Snowy Plovers

The GGNRA has argued that Ocean Beach must be closed to off-leash dogs to protect the Western Snowy Plover which roosts there seasonally.  The GGNRA raises this concern again in the ANPR document.  Potential harm to the Plovers from dogs can be eliminated with reasonable management, while off-leash dogs remain on the beach.


Daphne Hatch (Western Snowy Plovers, 1996) made a concerted effort to indict off-leash dogs for a decline in the Snowy Plover population on Ocean Beach.  She was unsuccessful.  Hatch documents a precipitous decline in the plover population between the 1994-95 and 1995-96 seasons.  In fact off-leash dogs were present on the beach throughout both seasons.  Although Hatch counts dogs, she does not show an increase in dogs to correlate with the decrease in Plovers.  She merely states, without evidence, that the dogs caused the plover population decline.  Hatch further tries to show a negative correlation between number of dogs and number of plovers in small segments of the beach.  The correlation was insignificant, and again the dogs are exonerated.  Off-leash dogs were banned from a large section of Ocean Beach in 1997, but the plover population remains low.  As in the case of the Bank Swallow, unscientific dogma in the GGNRA leads to unsuccessful management of the Snowy Plover.


Peter Baye (U.S. Fish and Wildlife Service Biologist) noted the presence of the Snowy Plover, which roosts, but does not nest on Ocean Beach, and made recommendations to the GGNRA for its protection.  The plovers are present seasonally and relocate from year to year. Baye recommended, “Exclosures, in concert with educational signage, have been very effective in areas of concentrated usage where beaches are large (e.g. Cape Cod National Seashore).  There are no unique impediments inherent at San Francisco’s Ocean Beach which would render these measures infeasible here.  They should be implemented at least on an experimental full-scale basis.”  (Memo to USFWS, 15 March 1995).  Rather than establishing these flexible, seasonally rotated exclosures to protect plovers against humans, pets, and wild predators, NPS chose the fixed and narrow measure of banishing off-leash recreation.   Baye’s recommendation of a temporary, seasonal fence to be removed when the plovers left the area and repositioned when they return could still be adopted.  This solution would allow off-leash dogs on Ocean Beach in many places and at many times, but keep dogs out of the roosting area.  Better yet, Baye’s solution would protect the plovers from the runners, children, kite-flyers, etc., who now barge through the roosting area under the GGNRA’s current plan.  Although the plovers are still declining, GGNRA action to protect them remains ineffective because it is based on the unscientific dogma that the problem is off-leash recreation.  Baye’s recommendation clearly shows that off-leash recreation on Ocean Beach is compatible with protection of the Snowy Plover.


Again, the banning of dogs while allowing all other traffic through the roosting area shows that the GGNRA is more interested in simply banning dogs than in protecting the Snowy Plover.



GGNRA claims of harm to wildlife by off-leash dogs have been shown to be over-blown and inaccurate.  Rational land use management can protect the wildlife in the GGNRA while allowing off-leash recreation to continue on 1% of GGNRA land.  The GGNRA should enlist the off-leash community as active partners in wildlife protection.  As a GGNRA brochure says, after listing the off-leash areas, “Remember, people, dogs, and wildlife can enjoy this park together if you follow these rules.”  This statement remains true, and should be formalized with ANPR Option B.



“Wildlife responses to pedestrians and dogs”

Miller SG; Knight RL; Miller CK

WILDLIFE SOCIETY BULLETIN 2001, Vol 29, Iss1, pp 124-132




As participation in outdoor recreational activities escalates, land managers struggle to develop management policies that ensure coexistence of wildlife and recreation.  However, this requires an understanding of how wildlife responds to various forms of recreational activities and the spatial context in which the activities occur.  Therefore, we measured responses of 2 species of grassland songbirds, one species of forest songbird, and mule deer (Odocoileus hemionus) exposed to a pedestrian, a pedestrian accompanied by a dog on leash, and a dog alone (only for grassland birds) on and away form recreational trails.  We assessed the “area of influence” for each treatment by determining the probability that an animal would flush or become alert (for mule deer only) given its perpendicular distance to a trail or a line of movement in areas without trails.  When animals were disturbed, we measured flush distance (the distance between the disturbance and the animal when flushed), distance moved, and, for mule deer, alert distance (the distance between the disturbance and the deer when it became alert).  For all species, area of influence, flush distance, distance moved, and alert distance (for mule deer) was greater when activities occurred off-trail versus on-trail.  Generally, among on-trail and off-trail treatments in grasslands for vesper sparrows (Pooecetes gramineus) and western meadowlarks ((Sturnella neglecta), the smallest area of influence and shortest flush distance and distance moved resulted from the dog-alone treatment, and these responses were greater for the pedestrian-alone and dog-on-leash treatments.  In forests, for American robins (Turdus migratorius), the area of influence, flush distance, and distance moved did not generally differ between pedestrian-alone and dog-on-leash treatments.  For the mule deer, presence of a dog resulted in a greater area of influence, alert and flush distance, and distance moved than when a pedestrian was alone.  Natural lands managers can implement spatial and behavioral restrictions in visitor management to reduce disturbance by recreational activities on wildlife.  Restrictions on types of activities allowed in some areas such as prohibiting dogs or restricting use to trails will aid in minimizing disturbance.  Additionally, managers can restrict the number and spatial arrangement of trails so that sensitive areas or habitats are avoided.
Interactions among dogs, people, and the environment in Boulder, Colorado:  A case study

Bekoff M; Meaney CA

ANTHROZOOS 1997, Vol 10, Iss 1, pp 23-31




From September 1995 to April 1996 we studied interactions among dogs, people, and the environment in Boulder, Colorado.  Data on behavioral disturbances by off-leash dogs who were accompanied by a person were collected with respect to dog-dog and dog-human interactions, dog-wildlife encounters, dogs trampling vegetation, and dogs entering and disturbing bodies of water.  A questionnaire also was administered.  Behavioral data showed that off-leash dogs generally did not travel far off trail, that when they did it was for short periods of time, and that they rarely were observed to chase other dogs, disturb people, chase wildlife, destroy vegetation, or enter bodies of water.  Results from analyses of the questionnaires (skewed toward non-dog owners) showed that dog owners and non-dog owners agreed that people were more disruptive to the environment than dogs and that unruly people were more problematic than unruly dogs.  We conclude that the well-being and interests of dogs should not summarily and dismissively be compromised when dogs and people attempt to share limited space that can be used by all parties for recreational purposes.  Indeed, a higher percentage of people reported that the quality of dogs’ experience of the outdoors would be compromised more than their own enjoyment if dogs could not walk off-leash in areas where this is currently permitted.  The methods used and the results from this case study can serve as a model for other locations in which dogs and people compete for limited spatial resources.