SFPUC 2001 Alameda Watershed Management Plan

XII. SUMMARY OF COMMMENTS AND RESPONSESB. SUMMARY OF COMMENTS AND RESPONSESB. APPROPRIATE BASELINEComment B-1: “For establishing existing environmental conditions in the Watershed (i.e.comparison baseline) to support a CEQA analysis, we believe it is inappropriate for the EIR toestablish these conditions based upon a comparison with the pre-history of site conditions prior toarrival of European cultural influences. As described … in the EIR, the Watershed has beensubject to various environmental perturbations for more than 200 years. Indeed, the pristinewilderness conditions that existed cannot be feasibly restored and should not be used as thepresent day basis for comparison of land use changes. The EIR should instead evaluate changesin the environment based upon present site conditions, which include encroaching development,public recreation, dams, reservoirs, roads, livestock grazing, non-native vegetation, animal pestsand various other changes in the environmental baseline that now comprise the normalcircumstances in the Watershed.” (East Bay Regional Park District)Comment B-2: ‘The EIR contains a discussion on page III.E-1 about the condition of existingnatural resources in the Alameda Watershed. This discussion attributes much of the overalldecline in the abundance and general health of these resources to a 200 year history of grazingand the Watershed’s proximity to “highly urbanized” areas of the San Francisco Bay Area. Whilehistoric overgrazing and encroaching urbanization have contributed towards a decline in qualityof terrestrial habitats in the Watershed, fire suppression, invasive exotic vegetation and pestspecies, and other disturbances to natural processes have also greatly contributed to the decline.Another cause for decline in natural resources not thoroughly addressed in the EIR is the loss orpermanent alteration of terrestrial and aquatic habitats as a result of water diversion, damconstruction and water impoundment. Specifically, the three large reservoirs in the Watershedarea (i.e. San Antonio, Calaveras and Del Valle Reservoirs), have substantially altered oreliminated thousands of acres of native grasslands, oak woodland, chaparral/scrub and riparianareas, and have significantly altered or eliminated native populations of fish and amphibians.Construction and operation of these reservoirs and smaller diversions have also resulted insignificant changes in the hydrology, sedimentation rates, flood frequency and duration of creekflows in the Alameda Watershed. While some of these diversions have helped to create nonnativewarm water fisheries, they have in most instances come at the loss of the native fisheries(including steelhead) and amphibians (including California red-legged frog and foothill yellowleggedfrog). This section of the EIR appears to understate the impact of these changes inWatershed processes and places an inappropriate burden for these impacts on other land uses.’(East Bay Regional Park District)Comment B-3: “The operation of SFPUC dams and accompanying diversion and retention ofwater which would otherwise flow down Alameda Creek and its tributaries has not beenanalyzed. The SFPUC must analyze the operation of Calaveras Dam, San Antonio Dam, UpperAlameda Diversion Dam, Sunol Dam, and Niles Dam on steelhead/rainbow trout, Pacificlamprey, and other native fish species, Western yellow-billed cuckoo, California red-legged andfoothill yellow-legged frogs, and California tiger salamander. The SFPUC must mitigate for anysignificant impacts to these species due to dam operation.” (Alameda Creek Alliance)NOP 96.223E: Alameda Watershed Management Plan C&R.11 ESA / 930385