My peeve is that it is impossible to understand how pets on the seashore beaches will be regulated under the plan.
Depending on where you look, you will find widely varying statements on regulations of pets under Alternative F, which is the Park Service preferred option.
The statements from section to section, chapter to chapter, and table to table are all over the board when it comes to where and when you can take your pet – probably your dog – to the seashore beaches.
Let’s start on the Table 8: The Summary of Alternative Elements. This table is included in the executive summary in the Roman numerals at the beginning of the DEIS and again in the main body of the DEIS. Go to Page 113 of the document. This table of Alternative Elements is the basic summary and comparison of what you can expect from various options.
Under the table on the subject of pets, the summary says:
Alternative F: Same as Alternative C except:
Pets would be prohibited in all designated Breeding Shorebird SMAs from March 15 to July 31 or two weeks after all shorebird breeding activities have ceased or all chick in the area have fledged, whichever comes later.
So then you look back on page 113 under Alternative C. That says:
Same as Alternative A except:
--Pets would be prohibited within all designed breeding shorebird Species Management Areas (SMAs) from March 15 to Oct. 15.
--Pets would be prohibited within all nonbreeding shorebird SMAs that are otherwise open to recreation use.
If you go to Alternative A, you find it’s pretty much the regulation that we’ve had here – no pets in resource areas, pets on leashes not longer than 6 feet, etc.
So where does this leave us?
Under the preferred alternative pets would be prohibited from SMAs from March 15 to July 31, which is pretty much the breeding season.
However, the table says that the regulations would be the same as alternative C, which says there is a March 15 to Oct. 15 closure in SMAs.
Furthermore, Alternative C also prohibits pets in all non-breeding SMAs that are otherwise open to ORVs – that would be areas that are open to ORVs after the breeding season from late summer until early spring, including areas at the capes and spits.
So what does Alternative F, the preferred alternative dictate about pets?
Are they prohibited from SMAs from March 15 to July 31 or March 15 to Oct. 15? And are they prohibited from SMAs that are open to ORVs during the non-breeding season.
The SMAs, by the way, are the Species Management Areas. They are by and large areas that are already closed to ORVs and pedestrians during the breeding season, so closures here would be tolerable. Closures in the non-breeding season would not be for many pet owners.
If you are confused now, just read more of the DEIS and more conflicting statements about pet regulations:
--On Page 136 under Impact Topics for American oystercatchers, the document states that benefits to these birds, not federally listed but a state species of concern, would include “…prohibition of pets in the seashore during the breeding season, including in front of the villages….”
--On Page 447, the DEIS states that pets would be prohibited from breeding shorebird SMAs from March 15 until Oct. 15 and in all non-breeding SMAs, even those that are open to ORVs.
--On Page 472 under impacts of Alternative F on oystercatchers, the DEIS states, “These additional restrictions, along with the limitation of pets to villages beaches during the breeding season would result in long-term beneficial impacts…..” The next paragraph again references prohibition of pets in the seashore during the breeding season, including the beaches in front of the village.
--On Page 477 under impacts on state-listed species is another reference to the prohibition of pets from the seashore during the breeding season, including in front of the villages.
There are many other conflicting citations on pet regulation, but I think you get the point.
The choices in the DEIS are:
• Pets prohibited in SMAs from March 15 until July 31 – or two weeks after the last chicks fledge?
• Pet prohibited in SMAs from March 15 until Oct. 15?
• Pet are or are not allowed in non-breeding SMAs that are open to recreation vehicles?
• --Pets are prohibited from the entire seashore during the breeding season, including in front of the villages?
• --Pets are prohibited from the entire seashore during breeding season, except in front of the villages.
There is a HUGE difference between no pets in the SMAs during the breeding season and no pets on any seashore beaches during the breeding season.
I guess you pick and choose what you do or do not support when you make your public comments on the DEIS.
Don’t expect any clarifications from the National Park Service.
Island Free Press queried Mike Murray on this question. Murray is on vacation this week, but his assistant and public affairs specialist Cyndy Holda said in an e-mail on April 8 that any inconsistencies will be addressed in the Final Environmental Impact Statement due out sometime much later this year – if it’s on time.
Meanwhile, this is the Park Service’s well-rehearsed response to any questions on the DEIS is:
NPS does not provide responses to individual questions about the document or the issue until the release of the final environmental impact statement (FEIS). At that time written responses to substantive comments will be provided as part of the FEIS.
It’s understandable that NPS can’t respond to every question about the DEIS, but this case when statements are so obviously conflicting in different sections, it would seem that the public deserves a clarification so that those who have tried to read the document can compose a coherent response.
Regulation of pets may seem like a minor issue in this rulemaking process, but to many this will be a big, big deal.
Also, please remembers that this rulemaking process is not about ORVs only. It dictate access to the seashore for the next 10 or 15 years – for drivers and for walkers.
And their pets.