SFPUC 2001 Alameda Watershed Management Plan

XII. SUMMARY OF COMMMENTS AND RESPONSESB. SUMMARY OF COMMENTS AND RESPONSESSuch activities constitute the baseline setting against which the impacts of changes proposedunder the Management Plan are addressed.Comment A-10: ‘One proposal for increased public assess is the creation of new trails. UnderManagement Action Number roa12, (page II-28) stating that “design, site, and construct newroads and trails following guidelines for wildland conditions,” the DEIR indicates that thisactivity will have no potential adverse physical effects and is not analyzed in this program levelEIR, and that this activity would not require project-specific environmental review. Trails alonehave the potential to fragment habitat and, coupled with public access, have significant impacts,including, but not limited to, dispersal of exotic species, both plant and animal, increasedpredation of local wildlife, increased incidence of fire, and increased habitat disturbance anddestruction, all resulting in reduced diversity and habitat. Individually these impacts aresignificant. Cumulatively these impacts have the potential to change large parts of the watershedecosystem. If these impacts are not addressed in this DEIR and they are not going to beaddressed in a project-specific DIER, where exactly are they going to be addressed under CEQA?The Department recommends that Impacts associated with these activities should be addressed ata programmatic level in the DEIR with recognition that a project-specific document shall addressproject-specific impacts.’ (California Department of Fish and Game)Response: This comment expresses a concern that the programmatic nature of the EIR precludesthe analysis of impacts that might occur as a result of new trail development. This commentpoints to the conclusion that management action roa12 will not require further environmentalreview and is not analyzed in the EIR itself (see DEIR page II-28). However, roa12 actually callsfor the use of construction guidelines appropriate for wildland conditions when siting trails orroads. Action roa12 does not call for the actual siting of trails or roads. Future specific proposalsfor new trails or roads in the Watershed would require review for CEQA compliance.At a program level, the potential impacts of trail construction are analyzed throughout the DEIR,with reference to Policies WA15.2 (consideration of new trails in zones of lesser vulnerabilityand risk, where consistent with the goals and policies of the Management Plan) and WA15.4(support of new trial connections that link to adjacent communities and to the trail facilities ofother agencies), both of which more specifically support the development of trails and trailfacilities. These analyses are referenced in the following tables within the DEIR: III.C-2, III.C-3,III.D-2, III.D-3, III.E-4, III.E-5, III.F-3, III.G-2, III.H-2, III.I-3, and III.M-1. Each of these tablesnotes the potential impacts on the resource analyzed and shows the proposed management actionsnecessary to reduce potential impacts to less than significant levels. It should also be noted thatthe San Francisco Planning Department would review SFPUC activities under the ManagementPlan and the impact assessments and required mitigation measures would be carefully consideredwhen new trails are proposed.4.0 FUTURE ANALYSISComment A-11: “Alameda County believes that there are activities contemplated in the Planthat will require the review and approval of County agencies. In addition to General PlanNOP 96.223E: Alameda Watershed Management Plan C&R.9 ESA / 930385