SFPUC 2001 Alameda Watershed Management Plan

XII. SUMMARY OF COMMMENTS AND RESPONSESB. SUMMARY OF COMMENTS AND RESPONSESare proposed by project proponents to be included in the project and other measures proposed bythe lead, responsible or trustee agency or other persons...” Since the DEIR relies solely on theManagement Actions as mitigation, the Management Actions should reflect the measures whichshall be implemented by the SFPUC. As currently stated in the DEIR, there is no commitment bythe SFPUC to implement or provide funding for any of the proposed Management Actions. Anymanagement action that is not assured by funding, staff, or equipment or that the SFPUC choosesnot to implement should be removed from the DEIR to accurately reflect what actions the SFPUCshall commit to.In addition to stating a commitment to basic mitigation for impacts associated with the proposedactivities, the DEIR should also include basic monitoring requirements for mitigation. Nomonitoring requirements are included in the DEIR.’ (California Department of Fish and Game)Comment D-4: “Mitigation measures, specifically D 1.0(1), should ensure that managementplan actions intended to mitigate other management plan actions occur simultaneously. Iffunding or policy decisions eliminate or reduce a mitigation measure then the correspondingmanagement action should again be reviewed. Specific examples would include concurrentimplementation of Management Actions saf4, saf5, saf10 and sta4 with actions that increasepublic access to the watershed; concurrent implementation of fic4 and fic5, lea3 through lea8 andenv2 and env3 and concurrent implementation of was2 and lea3. If the mitigative managementactions can no longer be supported than the management action requiring mitigation should bereviewed for its impacts and, if necessary, revised or suspended.” (California Department ofHealth Services, Drinking Water Field Operations Branch)Comment D-5: ‘The SFPUC considers a management action to have a significant impact onbiological resources if it: has a substantial adverse effect on any endangered, threatened,candidate or sensitive species; has a substantial adverse effect on the habitat of these species; hasa substantial adverse effect on wetlands, riparian, or marsh areas; or substantially interferes withmovement or migratory or dispersal corridors of native fish or wildlife (page III.E-23). Asdocumented below, many SFPUC management actions which are not analyzed (but should beanalyzed) in the report have one or more of these effects, which are not mitigated for or reducedto a level of less than significance. Many of the management actions which are analyzed haveadditional significant impacts which meet the criteria above which were not considered.Many of the management actions which are analyzed by the report are presumed to be mitigatedby other management actions summarized in Table II-1. In other words, many of themanagement actions in Table II-1 are being promoted as reducing substantial adverse impacts toless than significant. However, all of these mitigations are qualified by the statement that“Inclusion does not ensure that funding, staff, or equipment will be made available to implementthese actions, nor does it obligate the SFPUC to implement actions it chooses not to,”essential[ly] rendering the mitigations meaningless. There is no assurance in the EIR thatproposed mitigation actions will be undertaken, leaving potentially significant impactsunmitigated. Inclusion of this qualifier calls into question the validity of the entire EIR, and thesincerity of the SFPUC in mitigating for the impacts of its management actions. The SFPUCNOP 96.223E: Alameda Watershed Management Plan C&R.17 ESA / 930385