SFPUC 2001 Alameda Watershed Management Plan

XII. SUMMARY OF COMMMENTS AND RESPONSESB. SUMMARY OF COMMENTS AND RESPONSESneeds to include a specific mitigation monitoring plan as part of the EIR, which will ensure thatadequate mitigations for its management actions actually occur on the ground.’ (Alameda CreekAlliance)Comment D-6: “The one thing that really bothered me reading, there’s a number of managementactions of EIR and I forget, there’s a table and some of those management actions are proposedmitigations to reduce significant impacts to a threshold less significant and that’s the table that’sin Table 2-1.And then there’s a disturbing footnote at the bottom of the table which simply states inclusiondoes not ensure that funding, staff, or equipment will be made available to implement theseactions, nor does it obligate the SFPUC to implement actions it chooses not to, essential renderingthe mitigation actions meaningless.There’s no assurance in the EIR that anyone will be actually undertaking or funding the staff.Inclusion of this qualifier calls into question a commitment to tell SFPUC -- even address theseimpacts. So I don’t know why the qualifiers are included.Some of those actions in table 2.1 are specifically listed in the EIR as mitigations which willreduce impacts less than significant and if you can’t guarantee it, then you cannot rely upon thosemitigations.” (Jeff Miller – Pleasanton Public Meeting)Response: The way in which mitigation measures were introduced and the commitment toimplementing mitigation measures was a point of concern for many commentors. It is theintention of the SFPUC to avoid significant impacts from any actions or set of actions it mayundertake, however it is not possible at this time to determine which particular action or set ofactions the SFPUC might undertake and in what timeframe. Therefore, the DEIR took aconservative approach and identified the potential impacts for any action or project for whichimpacts could not be ruled out. Unfortunately, this approach confused commentors and somereaders presumed that the SFPUC was serving notice that it might choose to ignore mitigationmeasures or manage land in such a way as to cause significant impacts. This is not the case.The Management Plan actions are primarily a set of best management practices that may beimplemented by the SFPUC. Whether or not these practices are implemented is dependent onwhether the SFPUC receives funding and staffing for implementation of actions or sets of actions.As actions are specifically proposed (or receive funding), the San Francisco PlanningDepartment, Major Environmental Analysis section would review the project specifics pursuantto Sections 15168 and 15162 of the CEQA Guidelines. Section 15168 defines a Program EIR,lists the advantages to using a Program EIR, describes how a Program EIR can be used for lateractivities, and establishes public notice requirements for a Program EIR used for CEQAcompliance for later activities. Section 15162 contains basic tests for determining whether acertified Program EIR (or any certified EIR or adopted negative declaration) may be used forCEQA compliance for a project and, together with Sections 15163 and 15164, would be used toNOP 96.223E: Alameda Watershed Management Plan C&R.18 ESA / 930385