In order to make informed assessments of any genuine risks associated with off-leash use, we propose that the EIRs draw on the following sources of information:
Threats to/harassment of human users:

• Animal Control statistics on dog bites: when and where they happen, and with what degree of frequency, as well as the incidence of rabies among domestic animals in Santa Barbara County

• Work with the [Audubon Society, Surfrider Foundation, Santa Barbara Wildlife Care Network?] (whose mission is the protection of local wildlife) to identify which fauna are really, as opposed to potentially, present; which are at genuine, as opposed to putative, risk, and what constitutes threat and harassment
• Identify the actual, as opposed to potential or "possible", presence of "sensitive" or "endangered" species at each area under study (for example, the Western snowy plover and steelhead trout) as well as the actual impact of dogs on such species when they are present, and possible mitigation strategies
• Identify precisely the ways in which the presence of dogs disturbs fauna-particularly "nocturnally dependent species," a concern raised repeatedly in the initial study despite the fact that dogs are not present in these areas at at night

Damage to local ecosystems:

• Work with Heal the Ocean (with its expertise in pollution abatement) to identify the real, as opposed to potential, effects of canine feces/urine on habitat, especially estuarine and riparian areas-define which bodies of water are at risk, and the extent of the risk involved
• Identify the actual presence of dogs in sensitive terrain such as bluffs which is hard for them to navigate, and the extent that such presence actually contributes to erosion and sedimentation Threats of disease associated with dog waste:
• Consult local veterinarians about what diseases are carried in dog feces, as well as the frequency of transmissibility to humans
• Consult with Heal the Ocean and Project Clean Water to determine the geographical origins of contaminants in local watersheds
• Conduct studies similar to the DNA study of the Lower Rincon Creek Watershed Study (see attached Executive Summary), to determine the specific role of dog waste in watershed contamination

Some of the strategies for mitigating the effects of off-leash dog use also require study. We suggest that the following issues be addressed in the EIRs:
Problems associated with creating a fenced play area, at the DFP or elsewhere:

• consult with local dog trainers about possible problems associated with overcrowding of dogs

Ensuring that restrictions on use are mitigated by providing alternative facilities:

• study the impact of restricted access, by day or time, and the benefit of providing alternative locations for off-leash use during those times;
• study how the provision of multiple, geographically diverse locations (each with times set aside for dog averse users) might function to mitigate environmental impacts by easing overuse of any single location

Study additions to the proposed locations of Shoreline Beach/DFP beachfront:

• consider other entrances to Shoreline Beach (such as 1000 Steps), eliminating off-leash use at crowded access points such as Shoreline Park
• consider the benefits of an additional beach, such as Arroyo Burro westward, with its long history of off-leash dog use
• Study the option of replacing Hale Park with a park whose historic use and design, as well as location, is better suited to off-leash use:
• alternatives for study should include Stevens Park and Honda Valley Park

• the community-building effects of dog owners interacting in specified off-leash areas as a catalyst for social interaction (Annual Review of Public Health 1996)
• the mental health benefits of off-leash recreation for those who otherwise would feel excluded from use of open spaces, such as single women, the elderly, and the physically challenged (Psychological Reports 1996)
• how to work with volunteer organizations such as Dog PAC to educate the public about responsible dog ownership-with emphasis on clean-up, courtesy, and control

We also remind the Planning Commission that any EIRs should not include Elings Park as either a model, or a presumptive alternative location for off-leash recreation, for two reasons: first, Elings charges a fee for use, is a private park, and has a limited number of permits available--and therefore does not qualify as public open space; second, Elings' current plan is provisional and may be revoked by its Board of Directors at any time, thus eliminating it as an option.

We thank you for your consideration of the needs of responsible dog owners. We look forward to working with the Planning Commission in providing information to assist in the EIRs, and in creating a win-win situation for all members of the community.

Sincerely,