SFPUC 2001 Alameda Watershed Management Plan

XII. SUMMARY OF COMMMENTS AND RESPONSESB. SUMMARY OF COMMENTS AND RESPONSESComment A-9: “We believe that the deficiencies in the management plan and DraftEnvironmental Impact Report are very serious. 2 We believe that these deficiencies would best beaddressed in a new draft document that would go through another review period for publiccomment.” (California Sportfishing Protection Alliance and the Northern CaliforniaCouncil/Federation of Fly Fisheries)Response: Some of the above comments request project details and/or the analysis of projectimpacts that are not known at this time and are not appropriately found in this type of EIR. As isstated on DEIR page I-10, this is a programmatic EIR that analyzes, at a general level, thepotential environmental impacts of a broad range of policies and management actions proposedby the draft Alameda Watershed Management Plan. The nature of the programmatic approach isfurther described on DEIR pages I-10 and II-22. The Management Plan was prepared by theSFPUC as a land resource management guide, and does not address ongoing operation of theSFPUC water service facilities. The scope of this EIR was determined by the MajorEnvironmental Analysis section of the San Francisco Planning Department, and was described inthe Initial Studies published in October, 1996 and August, 1998 (see DEIR page II-23). The EIRscope was also reviewed in a public meeting held on November 6, 1996 (see DEIR page II-24).The scope of the Management Plan and alternatives were chosen to meet the primary goal ofimproving water quality and water supply. The scope of the EIR is broad because insufficientdetails are currently available to enable full discovery or disclosure of significant impacts forsome of the projects or actions called for in the Management Plan. Throughout the EIR it isstated that implementation of certain management actions will require further environmentalreview at the time more specific project details are proposed (see DEIR Table II-1 for a list ofthose actions that are likely to require such study). It is appropriate to prepare a programmaticEIR given the nature of this planning level document. Similarly, it is appropriate for SFPUC toprovide the goals and objectives that must be met by the Management Plan and any alternativesanalyzed.Some commentors suggest that the EIR should address the impacts of SFPUC’s past or ongoingwatershed operation and maintenance practices. To the extent that the actions of the ManagementPlan modify existing facilities and/or operation and management practices, the scope of this EIRincludes these modifications and addresses their potential impacts. For example, with respect toimpacts on natural resources habitats, DEIR pages III.E-24 through III.E-30 specifically addressthe programmatic impacts of proposed changes to Watershed operations and maintenanceactivities, and construction activities that would occur under the Management Plan. Additionalanalysis of operations, maintenance, and construction activities can be found on DEIRpages III.D-24, III.F-8, III.H-10, III.I-9, III.L-3, III.M-3, and III.M-9. In most instances,Management Plan actions are designed to improve operation and management practices and/oravoid environmental impacts. Consistent with CEQA requirements, the EIR does not analyze oraddress the effect of past or ongoing operations and maintenance activities at existing facilities.2 The comment letter previously discussed impacts on fisheries related to ongoing Watershed operations and ongoinggrazing activities. See Comments I-34, I-35, and K-4.NOP 96.223E: Alameda Watershed Management Plan C&R.8 ESA / 930385