SFPUC 2001 Alameda Watershed Management Plan

XII. SUMMARY OF COMMMENTS AND RESPONSESB. SUMMARY OF COMMENTS AND RESPONSESAs discussed on DEIR page III.P-3, the SFPUC intends to implement the Alameda FisheriesEnhancement project, which will result in greatly improved rearing habitat for steelhead. Thisproject was designed in part to address the issue of water releases from SFPUC reservoirs.Participation in this project may change current practices (i.e., the potential removal of Nilesand/or Sunol Dams). However, the impacts of those changes would be addressed at the timethese changes are proposed. The Alameda Fisheries project (the “rubber dam” project) will bethe subject of an EIR to be released later this year. Neither the Management Plan nor the EIRattempts to address barriers to fish migration that are owned and operated by others (e.g. theBART structure).The SFPUC has been participating as part of the Alameda Creek Steelhead RestorationWorkgroup. The SFPUC has committed resources to fund studies of water supply operationalscenarios designed to create better conditions for an anadromous steelhead run. The Workgroupscurrent estimate for removal of the lower Alameda Creek barriers is fall of 2003; the SFPUC’sNiles and Sunol dams could be removed or modified by that time, following appropriateenvironmental review. The SFPUC adopted Resolution No. 00-0076 on February 29, 2000 thatdirects staff to continue to participate in Workgroup discussions in a constructive fashionconsistent with the needs of its water customers and larger environmental concerns, expeditiouslydevelop appropriate recommendations related to options and costs addressing possible restorationof an anadromous steelhead run to the Alameda Creek watershed in a manner consistent with thecontinued reliable supply of water to the SFPUC service area, and undertake the necessary stepsrequired to define a project to remove or modify Niles and Sunol Dams and proceed with theproject as soon as possible following identification of funding and appropriate environmentalreview.Since publication of the DEIR, the National Marine Fisheries Service designated Critical Habitat:Critical Habitat for 19 Evolutionarily Significant Units of Salmon and Steelhead in Washington,Oregon, Idaho, and California (February 16, 2000). This designation includes establishingminimum riparian zone widths for maintaining specific riparian functions (e.g., sediment controland large woody debris recruitment) and overall watershed processes. The designation notes thatriparian zones in the range of 30 meters (98 feet) appear to be the minimum needed to maintainthe biological integrity of stream elements. The designation also notes that site-specificconditions may warrant substantially larger or smaller riparian management zones. This recentNational Marine Fisheries Service regulation may require federal agencies to consider habitatimpacts in the event that the SFPUC needs a 404 permit or other federal entitlement (Section 7consultation) within the boundaries of critical habitat. If there is no federal involvement, theSFPUC might be required to do a Section 10 consultation with the National Marine FisheriesService for future projects in the area. As has been described in the DEIR and in this document,riparian habitat in Sunol Valley proper is limited because of percolation of surface water into theshallow aquifer and rocky conditions.As required by CEQA, this EIR does not analyze impacts from past and ongoing permittedmining operations, which constitute the environmental baseline setting, but rather analyzespotential impacts of future mining entitlements called for under the Management PlanNOP 96.223E: Alameda Watershed Management Plan C&R.81 ESA / 930385