SFPUC 2001 Alameda Watershed Management Plan

XII. SUMMARY OF COMMMENTS AND RESPONSESB. SUMMARY OF COMMENTS AND RESPONSESRecent surveys have also identified local anadromous steelhead attempting to access the AlamedaWatershed streams. Plans are underway to facilitate steelhead access to the upper Watershedareas via Alameda County Flood Control District. As noted in the EIR, steelhead migrationalbarriers also exist on Watershed lands.In addition to physical barriers, water diversion and riparian habitat impacts constitute two majorimpacts to this species. Alameda Creek within Sunol Regional Wilderness and the AlamedaWatershed above Little Yosemite have been identified as the best habitat for spawning andrearing of steelhead within the Alameda Creek Watershed. Expansion of gravel quarryingadjacent to Alameda Creek will further divert surface flows from the creek (and groundwater)into the quarry ponds. These diverted flows are necessary for successful native fish andamphibian reproduction and survival in the Watershed.” (East Bay Regional Park District)Comment I-34: “Our organizations are profoundly disappointed that neither the managementplan nor the DEIR have addressed the restoration of steelhead trout (Oncorhynchus mykiss) in theAlameda Creek watershed. The analysis correctly states (III.P-1) that the geographic scope forthe cumulative analysis includes the entire boundary of the physical watershed, but then fails torecognize downstream and upstream impacts of its management plan on the steelhead trout, aFederally recognized threatened species, and its supporting habitat. Impacts to evaluate includeadequate flows for all life stages of the steelhead trout and supporting habitat, proper timing offlows, barriers to migration, geomorphology and gravel recruitment, and effects of cattle grazing,mining, stables, and nursery operations on water quality parameters and instream habitat requiredby steelhead.The document inappropriately dismisses steelhead from its analysis by disavowing their presence(II.E-17 and IX.B-2). It fails to include, reference, or incorporate studies that would indicate theoccurrence of steelhead in the watershed. It fails to include, reference, or incorporate studies thatwould indicate the genetic similarity of trout locked above SFPUC impoundments with theanadromous steelhead that are known to enter lower Alameda Creek (Jennifer Neilsen, 1999).The document fails to acknowledge current efforts to convey migrating adult steelhead troutabove lower Alameda Creek barriers, or efforts that are underway to remove or ladder thosebarriers.Fish migration barriers within the watershed serve only the purpose of providing SFPUC anexcuse for not managing the restoration of steelhead trout and other species of concern. Themanagement plan and DEIR should include the proposal to remove Niles and Sunol dams. Theproposed new barrier to fish migration, an inflatable rubber bladder dam, should be reviewed as apotential barrier to steelhead migration.” (California Sportsfishing Protection Alliance and theNorthern California Council/Federation of Fly Fishers)Comment I-35: “Perhaps the most serious deficiency of the DEIR is its failure to recognizestream flow requirements under 5937 of the State Fish and Game Code. The code section statesthat adequate stream flows must be maintained downstream of dams and diversions to maintainfish in good condition. It is clear that this standard has not been met by the San Francisco WaterNOP 96.223E: Alameda Watershed Management Plan C&R.68 ESA / 930385