COMMENT from Friends of the Dog Walkers on the Draft Tokai/Cecilia Management Framework of 2006 19 Amhurst Avenue Newlands 7700 Ph 021 6717451 November 21, 2006 FDW represents The Kennel Union of SA in regard to issues relating to dogs in Table Mountain National Park. At this date we also represent 585 individual dog owners or families. These people have signed that they support our mission, which is: To ensure that dogs and their handlers continue to have free access to all areas within the Table Mountain National Park. Dogs under voice control will not be required to be leashed but must conform to the code of conduct agreed between TMNP and FDW. Certain areas designated by the Environmental Management Program for Walking with Dogs of 2002 which was agreed between TMNP and FDW [such as certain picnic sites, Good Hope Nature Reserve, etc] are accepted as being out of bounds for dogs. Consequently, the proposals in this draft that relate to dogs are unacceptable to the dog owning community that uses Tokai and Cecilia for recreation. We note that the underlying philosophy and strategy of Park management is based on the notion and concern that their responsibility is to avoid conflict by separating park users into groups and dividing the areas into compartments with designated routes for different activities. There may be a case for a dedicated track for horses and for downhill biking but some of the distinctions made, such as that between hiking and walking, are quite artificial and could give rise to suspicions in the public mind of a hidden agenda to impose unwanted restrictions in the future. The basic principle, as implied in the existing Environmental Management Program for Walking with Dogs is that walkers, whether described as hikers or not, must be free to walk anywhere on the mountain with their dogs except for the listed areas. The reasons for this, particularly for the safety of their owners, were amply demonstrated by the hundreds of comments sent on the recent draft CDF document. Out of about 400 comments related to dogs only about 10 complained about dogs in the Park. TMNP management will be accused of flagrant disregard of public opinion if they fail to accept this. Any departure should be negotiated with FDW as representatives of the dog owners and there needs to be cogent and proven reasons for banning local citizens from walking where they wish. Our experience is that conflict between park users is minimal and that park management's responsibility should be to educate and give opportunity to park users to learn how to mix and show respect for each other in the spirit of the new South Africa. The strategy of dividing and compartmentalising people into separate but equal facilities, as was tried and failed in the history of our country, simply resulted in the public having less instead of more in that they were denied access in a meaningful way to the enjoyment of their own heritage. We see that the ultimate objective for lower Tokai (see map for 2025 in fig 2) is a small pocket of shade to be assigned for walkers with dogs while the upper slopes are to be utilised for mountain biking, horse riding and hiking, presumably without dogs. Lower Tokai Forest, east of Orpen Rd, has always been used by horses, family bikers and people walking with dogs. They have co-existed with few incidents. It does not make any sense to restrict horses to a narrow strip on the south side of the forestry block. The whole area should be open to all these activities as it always has been. Even the riders of horses and bikes could well want to be accompanied by their dogs, and as the majority of walkers have dogs the effect would be to ban many walkers from the upper slopes. FDW were assured at the time that they negotiated the EMP that the upper Tokai Forest would be opened to walking with dogs. The proposals for the future of Cecilia are equally objectionable. Fig 7 (Cecilia Recreational Use Areas) which apparently relates to the present time, indicates service roads which may be used for dogs, walkers and horses as opposed to paths and other roads from which apparently dogs would be excluded. As the intention is to phase out service roads no longer needed for park management as harvesting of sections of pines gets underway, even most of these routes will be eventually taken out. These roads will be downgraded to paths or minor tracks that, according to plan will be reserved for the dogless walkers and hikers. A glance at these maps by the hundreds of local people who walk in the company of their dogs can only bring home the obvious wish of the present park management to discriminate against them for no reason other than that the Park does not have the will to properly implement and manage the existing EMP which has the support of the dog owning population as well as many other citizens. When this EMP was first issued the plan was that dog owners, when they purchased a (then Green Card, now Wild or Cape Town) Card would be obliged to read and sign agreement with the EMP and its Code of Conduct. To our knowledge (and we are continually repeating this) this never happened. Practically all the walkers who have been apprised of the code have received it from Friends of the Dog Walkers. It is therefore incumbent on park management to set about educating and informing the public instead of complaining that the existing program does not work. It is not acceptable for TMNP to pick out those parts of the EMP which suit them and ignore their own obligations. Neither is it acceptable for the Park to attempt to make unilateral changes. It is being reported to us that signboards declaring dogs must be on leads are appearing. This is a contravention of the EMP which Park management accepts as legally binding. Dogs are required to be under voice control, and only on leads in particular circumstances. These notices should be removed immediately if park management wishes the park users to comply with and respect the EMP. With regard to the harvesting of the pines and prospective planting, FDW have not engaged in the controversies surrounding this issue. Nevertheless, there is considerable concern regarding the needs of walkers in what is still the most popular green lung for the surrounding suburbs and those who come from greater distances to walk in shade. As the pines are harvested there will be increasing pressure on other shaded areas of the park, which is mostly delicate afromontane forest. The maps delineating the Broad Landscape Proposals for both Tokai and Cecilia propose that there will eventually be only segments of shade. Walkers, with dogs or not, but particularly with dogs in hot weather and bearing in mind the UV factor for humans, do not want to walk round and round in small sections. We strongly suggest the planting of suitable trees alongside paths to create shade corridors from one wooded area to another. There are not that many trees indigenous to the Cape and indigenous trees from up country might be inclined to spread. Non-invasive aliens, particularly if deciduous, would be enjoyed by Park users who could be involved in taking responsibility for a particular tree. These can be supplied with small sunken pipes and walkers could carry water to their adopted tree in the first year. On the lower slopes of Cecilia above Rhodes Drive there are many beautiful trees such as cork oaks and sweet chestnuts as well as young indigenous trees which have sprung up under the canopy of the pines. All these trees, particularly the very large stand of gum trees, provide the beautiful wooded appearance of Rhodes Drive and this area along the road should be classified and protected as heritage. Removal of them would be an act of desecration. This shaded area should rather be enlarged to provide a shaded recreation area near to the entrance. Nevertheless, as the pines are removed there will be increasing pressure on other parts of the park and the recreation areas of the city. Newspaper columns and letters together with many complaints sent directly to FDW indicate that there is growing disaffection for park management and a desire for a different managing authority. FDW have worked hard since 2002 to support the park and the present EMP and it is a matter of regret and disappointment for us that our energies are currently being dissipated in defending the rights of park users against the unpopular strategies of SanParks, instead of on education. We strongly suggest that TMNP makes a generous gesture and reopens the Tokai Arboretum to dogs as it used to be in the 1980s in compensation for the future loss of a considerable area of shady recreational space. The ground vegetation is not fragile, the small animals are nocturnal and baboons need to be discouraged from the urban fringes. The vulnerability assessment for the Arboretum ( Annexure A, p13) states "The Arboretum is not sensitive to human damage and will not be negatively impacted by high visitor numbers". As most of the walkers in Tokai want to exercise themselves and their dogs together it is currently under-used. Annexure E 1. Preliminary guidelines for recreational activities. This is another demonstration of inaccurate categorising. Re dogs - please change activity criteria: Why are steeper slopes and soft path surfaces not considered suitable for dogs? Man with a weight of 60 - 120 kg and a footprint of +- 30cm does a lot more damage that a dog with a weight of between 5-25kg and four paws each with a surface print of up to 5cm. For dogs the main danger area is hot surfaces in mid summer which can cause serious damage to paws. Mountain bikes cause more erosion than dogs or walkers but F2 map for Tokai indicates plenty of routes for bikes in contrast with dogs. With regards to steeper gradients as indicated on the chart, we are not talking about rock climbing here, but many dogs are better than humans on steep gradients. Please alter the x mark in the square for steeper gradient to a tick and in the square for soft sandy surfaces to two ticks. In conclusion, we are left with the impression, yet again, that there is an agenda to discriminate against the dog-owning community. Please rather strive to make friends with them. They should be the best supporters of TMNP. FRIENDS OF THE DOG WALKERS committee Geraldine Goncalves   Roy Joynt (for the Kennel Union of SA)   Neil van der Spuy   Phyllis Carter   Carol de Gendt   Chris Walker   Val Bennett   Taryn Blyth.