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SFPUC 2001 Alameda Watershed Management Plan

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SFPUC 2001 Alameda Watershed Management Plan

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XII. SUMMARY OF COMMMENTS AND RESPONSESB. SUMMARY OF COMMENTS AND RESPONSESComment I-45: “The EIR states that <strong>Alameda</strong> Creek is not accessible to CCC steelhead. Asnoted above, this is incorrect, and there are also downstream impacts of the quarrying operationsthat have not been analyzed. As noted above, mining of the current leases and the proposedexpansion will alter surface flows and ground water in a manner likely to be harmful to CCCsteelhead. The stream will dry out sooner in the spring and begin flowing later in the fall,impairing migration, rearing, and possibly breeding of steelhead. These impacts are not limitedto the footprint of the mines, as they have the potential to impact hydrology both upstream anddownstream of the quarries. CCC steelhead/rainbow trout are currently known to migrate, spawn,and rear in nearby Pirate Creek, and are currently known to migrate and possibly rear in NilesCanyon downstream. <strong>SFPUC</strong> has not surveyed the creek for current spawning, rearing ormigration of CCC steelhead/rainbow trout in the area of the quarries, nor analyzed the potentialimpacts of quarrying on CCC steelhead habitat. CCC steelhead/rainbow trout potentially couldmigrate, spawn, and rear in the portions of <strong>Alameda</strong> Creek adjacent to the quarries in the nearfuture. Discharge from the quarries contributes sediment to the creek (sometimes in excess oflegal limits, as noted below), posing the risk of smothering or silting any trout redds downstream.None of these potential impacts has been analyzed.” (<strong>Alameda</strong> Creek Alliance)Comment I-46: “However, what stood out most for me, has been omitted in the inadequateanalysis of the impact on special-status species. So, I’d like to go into a few of those.First, is steelhead trout, and the EIR dismisses any discussions of steelhead trout by asserting thatthe current run stops at the BART. Those refer to the lower creek. This is not the case.Basically, the four reasons why steelhead trout impact this should be analyzed in this EIR. Thefirst is that we know for a fact that juvenile steelhead trouts which is part of the list of the Central<strong>Alameda</strong> Creek is documented to already be present in upper <strong>Alameda</strong> Creek and as well, is weput them there in 1998. Still, we’re asking they should be managed as part of the CCC steelheadpopulation for below BART by the fifth grade Pleasanton class.Under permit from the California Department of Fish and Game and the National MarineFisheries Service and as of 1998, there were over 250 juvenile central California coast steelheadswithin <strong>SFPUC</strong> watershed.The second issue is that the best, currently available science indicates that native rainbow trout in<strong>Alameda</strong> Creek ought to be considered and managed as part of the central California coaststeelhead population.And I’m basing this on genetics analysis by Dr. Jennifer Neilsen on the west coast. She analyzedclips from the returning steelheads and she, during the last few years, compared those to othergenetic types on the west coast and compared them to fin clips from the returning adult steelheadin the upper watersheds below major dams.NOP 96.223E: <strong>Alameda</strong> <strong>Watershed</strong> <strong>Management</strong> <strong>Plan</strong> C&R.78 ESA / 930385

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