SFPUC 2001 Alameda Watershed Management Plan

XII. SUMMARY OF COMMMENTS AND RESPONSESB. SUMMARY OF COMMENTS AND RESPONSESpermanent pools where they may be more susceptible to predation (Hayes and Jennings 1988).The SFPUC should presume the species is present within the watershed, and conductcomprehensive protocol surveys for the species. The potential impacts of SFPUC managementactions on the foothill yellow-legged frog and its habitat in the watershed, including impacts fromdam operation, water diversions, cattle grazing, gravel mining, and pesticide use need to beanalyzed, and the significant impacts avoided or mitigated. This has not been done.” (AlamedaCreek Alliance)Comment I-10: “Callippe silverspot butterfly (Speyeria callippe callippe). The EIR assumes amoderate potential for the Callippe silverspot to occur in the watershed. Populations of theCallippe silverspot found within the Livermore Valley, which are presumed to be intermediatebetween two subspecies of silverspot are mentioned. However, a recently discovered butterflypopulation in Happy Valley in southern Pleasanton, adjacent to SFPUC watershed lands, wasidentified by entomologist Dick Arnold to be Callippe silverspot (David Wright, FWSentomologist, pers. comm., 1999). The U. S. Army Corps of Engineers (Public Notice #23275S,November 8, 1999) and FWS (David Wright, FWS entomologist, pers. comm., 1999) are treatingthis population as Speyeria callippe callippe for regulatory and management purposes. TheSFPUC should presume the species has a high potential to be present within the watershed, andconduct comprehensive protocol surveys for the species. As mentioned in the EIR, excessivelivestock grazing is a threat to the species, because of the risks of trampling, cattle eating foodand host plants, and creating disturbed soil conditions that favor the spread of invasive weedyplants at the expense of native species necessary for the survival of the butterfly (62 FederalRegister 64306). Also, the adult and early larval stages of the Callippe silverspot are prone tomortality from dust because their respiratory apparatus (spiracles) are easily clogged, and FWSbelieves that dust from nearby quarrying operations may adversely affect the species (62 FederalRegister 64306, at 64310). According to FWS, the use of insecticides would threaten the callippesilverspot if use occurred in proximity to occupied habitat. Silverspot butterfly larvae areextremely sensitive to pesticides, and even the accumulation of runoff in the soil after sprayinghas proven lethal to larvae of butterflies of the same genus (Speyeria) (62 Federal Register 64306,at 64314). The potential impacts of SFPUC management actions on the Callippe silverspot andits habitat in the watershed, including impacts from gravel mining and pesticide use need to beanalyzed, and the significant impacts avoided or mitigated. This has not been done. The analysisof the potential impacts from cattle grazing is completely inadequate. (Alameda Creek Alliance)Comment I-11: “Berkeley kangaroo rat (Dipodomys heermanni berkeleyensis). The EIR makesno mention of the Berkeley kangaroo rat. The Berkeley kangaroo rat is a Federal Species ofConcern which was decimated by ground squirrel poisoning campaigns in the 1940’s and 1950’s.It was presumed extinct by some biologists, with the last reported sightings of the speciesoccurring in the 1980’s near Mt. Diablo and San Pablo Reservoir. However, biologist GaryBeeman, a local expert on the species, believes it may still be extant, and that the areas aroundCalaveras Reservoir may have the best remaining population (Gary Beeman, pers. comm., 1999).Beeman believes the species has not been detected during other rodent trapping because impropersurvey methods are used, including not using the preferred foods of the species in traps (Beeman,pers. comm., 1999). If shown to still exist, the species would certainly be a candidate for federalNOP 96.223E: Alameda Watershed Management Plan C&R.56 ESA / 930385