SFPUC 2001 Alameda Watershed Management Plan

XII. SUMMARY OF COMMMENTS AND RESPONSESB. SUMMARY OF COMMENTS AND RESPONSESanalyzed in the EIR. The Grazing Element description presented in the EIR is for informationalpurposes only.Notwithstanding the CEQA status of the Grazing Element as a continuing activity, historicenvironmental impacts related to grazing have been reduced since the adoption of the GrazingElement. The stated goal of the Grazing Element is to ensure the proper management and controlof grazing to protect, maintain, and enhance source water quality and to reduce adverseenvironmental effects, such as those referred to by commentors. In addition, the SFPUC was alsointerested in grazing as an effective and fiscally responsible method to control fire hazard and tomaintain the overall health of the land. Prior to the adoption and implementation of the GrazingElement, it could be fairly stated that some adverse environmental impacts from past grazingactivities were evident, as noted by commentors. These impacts were generally linked to theintensity of grazing permitted at that time and included degradation of water quality, erosion,sedimentation, spread of invasive plants, loss of riparian vegetation, damage to streambanks andstream hydrology, and effects on special status wildlife and plant species. In addition, potentialwater contamination by the pathogen Cryptosporidium parvum was a concern, as noted by manymembers of the public. Cryptosporidium has been found to cause illness in humans and is ofgreatest concern to immuno-compromised individuals.The adoption of the Grazing Element was the culmination of an extensive public participationprocess and represents a negotiated compromise among various stakeholders, including theSFPUC, environmentalists, the Alameda County Resource Conservation District, the AlamedaCounty Water District, the California Cattlemen’s Association, the University of California, SanFrancisco (representing the concerns of immuno-compromised individuals), and the USDANatural Resource Conservation Service. In addition, the Grazing Element was developed basedon a Hazard Analysis Critical Control Points (HACCP) approach, as well as on other technicalreports that include recommendations for scientifically-based grazing best management practices.A grazing lease strategy was key to the implementation of the Grazing Element. This strategyconsisted of lessee selection criteria, which interested parties were required to meet prior to bidsubmittal. The selection criteria and terms included stocking rate requirements, annual operatingplans, water quality protection, timing of calving, staffing, fee structure, and other lease terms.By November 1999, 14 new leases had been executed under the terms and conditions required bythe Grazing Element.The most important shift in grazing practices since the adoption and implementation of theGrazing Element has been the reduction of cattle permitted on watershed lands (as defined byAnimal Unit Months or AUMs). The Grazing Element contains policies that require cattlereductions of at least 40% compared to pre-1991 stocking levels. With the exception of the EastBay Regional Park District, all tenants have complied with the stocking levels set in the GrazingElement. Lease negotiations with the East Bay Regional Park District are underway anddiscussions include compliance with the provisions of the Grazing Element. The pre-1991stocking level on lands leased to these tenants was approximately 33,486 AUMs. In fiscal year1997-1998, this level was reduced to approximately 21,006 AUMs through the implementation ofNOP 96.223E: Alameda Watershed Management Plan C&R.96 ESA / 930385