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SFPUC 2001 Alameda Watershed Management Plan

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XII. SUMMARY OF COMMMENTS AND RESPONSESB. SUMMARY OF COMMENTS AND RESPONSESIII.E-38), which could be mitigated to less than significant levels through new mitigationmeasures (see DEIR pages IV-3 and IV-4, Section E.2.0, mitigation measures 1, 2, and 3).There is no CEQA prohibition against the inclusion of, or other problems resulting from the useof, information and conclusions of a project-level EIR such as SMP-32 in a program EIR such asthe <strong>Management</strong> <strong>Plan</strong>. The SMP-32 EIR represents the best available information about thatproject’s environmental impacts and mitigations. The SMP-32 EIR was prepared by the localjurisdictional agency (<strong>Alameda</strong> County) and there is no basis for the City and County of SanFrancisco to substitute its judgement by overriding that EIR and <strong>Alameda</strong> County’s findings,particularly when upheld by trial and appellate court decisions. As noted in the <strong>Management</strong> <strong>Plan</strong>EIR (see DEIR pages I-9 and I-10), it was anticipated that many Sunol residents would disagreewith these findings.No finding of less than significant impact in the <strong>Management</strong> <strong>Plan</strong> EIR was based on futurediscretionary action by a permitting agency. These comments refer to the <strong>Management</strong> <strong>Plan</strong>’sproposal to mine existing pits wider and/or deeper. The EIR could not identify a significantimpact at the program level, and merely noted that similar projects (mining wider and/or deeperin the same areas) have been able to mitigate all identified potential impacts to less thansignificant levels, while disclosing the likely need for future environmental review of suchproposals. However, because of the uncertainty about the timing and extent of future proposalsfor expansion of mining south of I-680, and the lack of a comprehensive groundwater andhydrologic study for that area, potentially significant project level impacts cannot be ruled out.Therefore, a discussion of potential impacts to <strong>Alameda</strong> Creek and its resources, and a mitigationmeasure, has been added to EIR Section III.D, Hydrology and Water Quality. Please see theresponse to Comments H-7 through H-10 (Section II.H of this document) for this discussion.In response to Comments E-8 and E-11, the <strong>Management</strong> <strong>Plan</strong> EIR analyzed the alternativeadvanced by some Sunol citizens. The analysis of this alternative (Alternative S) is discussedalong with mining alternative B, which is similar to the mining alternative proposed by Sunolcitizens. Please see DEIR pages VII-18 through VII-30 for the discussion of Alternative S,Alternative B, and the other mining alternatives.NOP 96.223E: <strong>Alameda</strong> <strong>Watershed</strong> <strong>Management</strong> <strong>Plan</strong> C&R.23 ESA / 930385

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