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| Attention Nick Steytler DJEC September 12, 2006
With Appendix on Needs and Behaviour of Dogs by Taryn Blyth From FRIENDS OF THE DOG WALKERS Friends of the Dog Walkers (FDW) is a group of dog owners who prepared on behalf of the local dog-owning community the initial draft of TMNP's Environmental Management Program for Walking with dogs in the Cape Peninsula National Park (as TMNP was then called). This EMP was issued by the Park in May 2002 and expressed therein to be a "binding 'contractual document' between park management and dog walkers to facilitate responsible dog-walking in the Park." It is still in force though due for updating in the near future. FDW are neither contentious in our aims nor confrontational in style. Our mission is merely to maintain the status quo and retain traditional rights of access to the Park for visitors who enter for legitimate purposes and wish to be accompanied by their dogs as provided for in the existing EMP. We have gone to considerable lengths over the last four years to educate the public as to their obligations in regard to dogs, to publicise the EMP and to encourage park authorities to enforce the EMP's code of conduct. Some members of FDW committee are Park volunteers and hackers. We all support the principles of biodiversity and have the welfare of the Park very much at heart. At this date over five hundred local residents of the wider Cape Town community who take their dogs into TMNP have registered with us as supporters of our aims and more are doing so every day. Among these signatories are environmentalists, botanists and animal behaviorists. FDW also represents the Kennel Union of SA in regard to issues between its members and the TMNP. Regarding the entire CDF revision draft, we must mention our impression that we found it wearisomely difficult to follow in that it was peppered with acronyms without the usual explanatory section. Our comment concerns itself primarily with the suggested use zones as indicated in the map in the draft document. Firstly, it is impossible to know exactly where the proposed zones would begin and end on account of the lack of any topographical features. For instance, does the so-called Quiet Zone include the contour path or not? Is there a small area of Quiet zone near the Sivermine south gate? This vagueness renders meaningful comment difficult. Secondly, with regard to the public participation process, this has been further flawed by poor communication as to the purport of some of the proposals. The draft CDF is introduced as having only two significant changes from the existing Conservation Framework, namely the introduction of the Marine Coastal Park and of the new Remote Wilderness Zone. There is no mention of the highly contentious proposal to limit dogs to Quiet and Low Intensity Leisure zones that together constitute only a small section of this great Park, and consist largely of the lower slopes. The import of this can only be appreciated by examining the user zones map in relation to the chart in which recreational activities are ticked as appropriate and/or permissible. Not surprisingly this proposal remained un-noticed even by the media until it was publicised among dog owners by FDW. Our experience was that not one of the local residents we approached knew anything about it until the issue was eventually taken up by the media. Thirdly, the 2002 EMP for Walking with Dogs is based on the spirit of consultation between the Park and the dog-owning community. Such radical changes as are here proposed merited consultation prior to, and not after, the task of drafting this revision document was put in the hands of environmental consultants. Thus we take the view that the consultation process is essentially flawed for lack of clarity and failure to meaningfully communicate with the various communities who use the Park for their recreation. In regard to the substance of the notion of confining various recreational activities into demarcated zones, FDW are aware of the legislative framework regarding user zones. But the apparent intention behind these changes is deeply disturbing. Should the intention behind the introduction of Remote Wilderness zones be to acquire power to control public access in terms of s22 of the National Environmental Management: Protected Areas Act 57 of 2003 as amended, then the public is entitled to a genuinely explicit and properly publicised communication and consultation process. To return to the issue of dogs and user zones, we quote from p4 of the present EMP for dogs, a document issued by Park Management itself: ... Dog walking or walking with dogs? FDW prefer the latter expression for the reason that, while dog racing and hunting [for instance] could accurately be characterised as special activities or sports in the same sense as riding, paragliding or climbing, the walking community represented by FDW do not set out with the sole purpose of exercising their dogs. Certainly not anyway in the higher sections of the mountain where the remote and wilderness zones are situated. The dog owners take their dogs with them for a number of cogent reasons that have been very well expressed in the many comments mailed directly to yourself and copied to FDW. Our own investigations show that the walkers who take their dogs with them go in for such diverse reasons as hacking, exercise, botanising or just enjoying nature. It is thus inappropriate to characterise "dog-walking" as an activity separate from walking and there is no need or advantage in having different zones set aside for dogs. Naturally, FDW accept that dogs have an environmental impact as do all creatures in common with machines. But their environmental impact has already been graded in Section 2 of the EMP and provision has been made in this program for minimising it. What is inconsistent is that there is no EMP in existence for human visitors whose environmental impact has, we are told, been graded as zero, which is clearly a fiction of convenience. Environmental impact of dogs. The map of user zones in the draft CDF is inappropriate for demarcating areas for dogs in any case. The effect would be to crowd dogs into confined areas that would be put under additional stress instead of dispersing the walkers with dogs over the mountain. Some of these Quiet zones and Low Intensity Leisure zones include fragile riverine areas or constitute plantation areas where, as the pines are phased out, there will be new growth that needs protection and will not provide essential shade for dogs. Those parts of the park where the fynbos and forests are well established would be less affected by people with their dogs. Cape Point Reserve and Orange Kloof, where it is already well accepted that dogs are not permitted, make natural areas for remote zones without trying to effect controversial and unpopular changes. The existing EMP for dogs is already designed to address environmental issues that are best dealt with at local levels. TMNP needs to take heed of the principle contained in s2(2) of the National Environmental Management Act 107 of 1998 which applies to the actions of all organs of state: "Environmental management must place people and their needs at the forefront of its concern and serve their physical, psychological, developmental, cultural and social interests equitably". In other words TMNP needs to adopt a more holistic approach to park use and not overfocus on a narrow ecological approach to such a degree that the traditional users are made unwelcome in the Park, making a mockery of the slogan "a park for all for ever." Where is the proof that small animals are endangered, if they are at all, by dogs brought in by their owners, as opposed to poachers, fires and other hazards? The borders between the city and the park are porous. Penguins foul up suburban gardens, kingfishers fly into adjacent gardens and steal expensive pond fish, porcupines come in to steal garden bulbs and baboons terrorise home owners. The people of the city tolerate most of this because they love what they consider to be their mountain and the Park authorities need to be equally philosophical when very occasionally a park creature is injured by a dog. Inevitably, things happen, however much we may try to prevent them and, mindful of its acceptance that this is a city park, TMNP needs to be realistic. What is not realistic is the importation into the open park areas of indigenous buck. They should be kept safely in the sealed off areas of the Cape Point reserve and the Game Camp where they will not be a hazard to themselves and to motorists or be used as an excuse to ban dogs. There is no evidence that local people go on the mountain for game spotting, the vast majority who walk would prefer to take their dogs with them. Moreover, the presence of buck leads to an increase in ticks that are a dangerous health hazard for people and for dogs. Devils Peak Game Park. This is another area where game can be safely kept and seen by the public. But please do not extend it above the road. This is a very highly used recreational area. Opposition to creation of specific dog-walking areas. TMNP has made no attempt to survey the habits of walkers with dogs as a preliminary to preparing this CDF revision, in particular to find out the proportions of dog owners who enter various sections of the Park or how long they walk. The last survey conducted by the Park authorities was in 1999 and it indicated that, conservatively, there were 78 000 individual dog walkers. (see the 2002 EMP for dogs). It is highly unlikely that this number has decreased. FDW, with limited infrastructure and no funds, have collected data on dog owners at entry points. Our observation is that of those visitors who come in to walk at the very least 70% come in with dogs. Most of them walk for two hours or more and there are a great number of women who walk on their own, relying on their dogs for protection. The dog owners are universally opposed to being confined to dog walking areas of any kind or size. So many objections have been sent to the Park's facilitator, DJEC, for the comments process that FDW refrains from dwelling in detail on the reasons given. But it would be an insensitive person not be moved by the accounts of the pleasure and joy combined with love for nature expressed in comments copied to FDW by dog owners together with their distress at the possibility of such a meaningful part of their lives being torn away from them. They have made it clear that for the reasons summarised below they would no longer enter park areas where dogs were excluded. It is not surprising that many park users are expressing their emotions with anger and resentment. Objections from dog owners follow a regular pattern and these considerations are shared and adopted by FDW: SECURITY. This is the prime reason why no one should be prevented from taking at least two dogs into an open access area. TMNP has openly admitted that it cannot guarantee the safety of walkers in any part of the Park. No amount of visitor safety officers in the park can substitute for being guarded by your own dog. Advising people not to walk alone in a public national park is an admission of defeat and people who must, or choose to, walk alone have every right to do so. The presence of dogs is also a general deterrent to people who enter for illegal purposes of all kinds. COMPANIONSHIP. The dog owners of many of the suburban communities bordering the Park are closely bonded to their dogs. They are part of their families and share in their leisure time. For many of the walkers who go alone their dogs are their only family. EXERCISE AND HEALTH of local population. People with dogs walk more and have a healthier life style. TRADITIONAL RIGHTS Most of the land in the Park has always been public land. TMNP has been appointed managing authority but much of the area is still municipal land. It has no right to derogate from the rights of citizens and ratepayers of Cape Town. This is a deeply held view of the traditional park users, many of whom have walked all over the areas which are sought to be classified as remote and wilderness for a great number of years. If dogs should ever be denied entry to the mountain chain TMNP will be regarded as an interloper by the people of the city in direct contradiction with its expressed aim of fostering constructive relations with the broader park community. See below. HEALTH AND BEHAVIOUR OF DOGS . On account of the burgeoning crime wave in suburbs more and more residents of the Cape are acquiring large dogs. On needs of dogs and potential for behavioural problems see Appendix supplied by animal behaviourist Taryn Blyth. FDW also submits the following considerations: Relationship between local communities and TMNP. The draft CDF asserts that "Constructive relations, based on trust and respect, between the broader park community is essential to the sustainability of the Park". (p10). FDW could not agree more, but must unfortunately emphasise that this objective needs to embrace the community comprised of the traditional users of the park. Extending a hand to the disadvantaged sector of the surrounding community is indeed a worthy objective and FDW would not quarrel with this. But who could deny that relations between Park Management and the occupants of the surrounding suburbs is on an ever extending downward trajectory? FDW have not taken up any positions on a number of highly contentious issues that have, and are currently, bedevilling dialogue between park and local users. Whatever may be the rights and wrongs of these issues the existence of growing resentment against Park Management cannot be denied, even to a growing backlash against the acceptance of biodiversity. While TMNP is increasingly being seen as dedicated to taking away long standing enjoyments in public land, the heavy handed action of effectively denying vast areas of the park to dog owners who will not wish to walk without their pets will provoke even more hostility. TMNP needs badly to cultivate the support and co-operation of dog owners who comprise a significantly large portion of the local park visitors. Pressure on city parks and beaches. The huge increase in violent crime in the suburbs is motivating many more people to acquire large dogs which, of course, need to be taken out for exercise. The ideal areas are the more remote parts of the TMNP where they can be well dispersed. Banning them will bring increased pressure on city parks and beaches. Car park guards at Park entrances. These guards are doing sterling work in protecting visitors'cars and, in effect, guarding the entrances in that undesirable people are less likely to enter the park. They get no wages from TMNP and are reliant on donations from park visitors. If dog owners are discouraged from coming in their funds will dry up to the extent that it will not be worth their while to come. Policy of separation of activities. The CDF refers to the objective of separating recreational activities. FDW do not agree with this. There are people who like to cycle or horse ride together with their dogs and we think it is excellent for people and animals to learn to get along together. We recommend that park management take a walk along the Constantia greenbelt where they will see dogs, horses, cyclists, toddlers, etc, enjoying themselves in harmony. The Wild and Cape Town Cards. The draft CDF document refers to the objective of increasing the sale of Wild and Cape Town cards. We wish to point out that by endorsing and publicising the principle that dog handlers would be required to buy these cards as a condition for taking dogs into the Park, FDW have made a considerable contribution to their sale. The gates at Silvermine, the area in which dogs would be most restricted, are the only Park entrances where TMNP has been able to enforce this condition. The Park stands to lose nearly all its prospective revenue from dog owners who are unlikely to buy into the idea if they are antagonised. The Coastal Marine Park. FDW have had enquiries from people who are confused by the map of the peninsula with proposed use zones for the coast. Should there be any moves to introduce blanket bans on dogs on popular walking beaches such as Noordhoek and Scarborough they will be strenuously opposed by FDW as well as the local public. Local problems such nesting periods of birds should be dealt with at the level of the EMP. Park rules. Two primary principles should be: only introduce regulations which are generally acceptable to reasonable people who have the interests of the park at heart and do not make rules which cannot be enforced as this leads to a general contempt for regulations. The proposed restrictions on dogs do not meet with either of these criteria. In summary:
TMNP would not merely be keeping out dogs should it implement these proposals. It would be keeping out people. This is clear from the plethora of comments sent to DJEC and FDW. Is that what Park Management wants? We hope not.
FRIENDS OF THE DOG WALKERS
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