SFPUC 2001 Alameda Watershed Management Plan

XII. SUMMARY OF COMMMENTS AND RESPONSESB. SUMMARY OF COMMENTS AND RESPONSESP. HAZARDOUS MATERIALS/HAZARDOUS WASTEComment P-1: “With regard to Management Actions haz1 to haz12, we have previouslyrecommended that the SFPUC either maintain its own hazards material spill response equipmentand staff with the specific ability to control spills into reservoirs in the local watershed areas orassist local agencies with the acquisitions of this equipment and training.” (CaliforniaDepartment of Health Services)Response: In response to this comment, which is not directed to the EIR or its analysis, theSFPUC will consider the suggested change prior to adoption of the Management Plan.Comment P-2: “Nurseries on leased SFPUC land in the watershed use a number of pesticidesand insecticides adjacent to the creek, as revealed by a SFPUC survey (Bookman-Edmonston1995D). Many of the pesticides currently used by nurseries in the Sunol Valley, such asdiazinon, malathion, durzban, and Rice Mollinate are known to be toxic to frogs. Pesticideresidues in water, sediment, and aquatic vegetation can harm amphibians in aquatic environmentsby delaying or altering larval development or by reducing breeding or feeding activity (Hall andHenry 1992, Berrill et al. 1993). Insecticides obviously have harmful effects on butterflies, whichare insects, even in minute concentrations. The impacts of pesticide and insecticide runoff onmacroinvertebrates in Alameda Creek which are the food base for fish and amphibians has notbeen studied or analyzed. Alameda Creek was declared an impaired water body in 1999 by theU. S. Environmental Protection Agency due to diazinon poisoning. The Management Planproposes to expand nursery use in the valley and expand the existing golf course, which willincrease diazinon and other pesticide runoff to the creek. Pesticide use should be discontinued,especially since downstream water is used for municipal water supply, and Integrated PestManagement methods of pest control should be employed.” (Alameda Creek Alliance)Response: As noted on DEIR page II-1, the EIR assesses the potential impacts of theManagement Plan, and not the impacts of existing facilities and operations, which constitute theenvironmental baseline for the EIR. Currently, nurseries in the Sunol Valley are required toprovide reports to the SFPUC regarding their use of pesticides and fertilizers. The ManagementPlan calls for development of hazardous chemical management procedures for SFPUC operationsand operations on leased SFPUC lands, including nurseries and the golf course. In addition, theManagement Plan would require a greater setback of nurseries from Alameda Creek or otherwater bodies, as a best management practice. (Please see DEIR pages III.D-30 and III.D-31 for adiscussion of nursery operations impacts on water quality.) Implementation of this practicewould depend on lease agreements. The following discussion summarizes the SFPUCmanagement of pesticide use.The SFPUC has been on the San Francisco County Agricultural Commissioners Office task forceand the San Francisco Department of the Environments Integrated Pest Management (IPM) taskforce since the City’s IPM ordinance was approved in October 1996. The SFPUC has compliedwith the requirements of the ordinance by submitting monthly reports of pesticide use, submittingannual reports of Department use, designating IPM coordinators, submitting a Department IPMNOP 96.223E: Alameda Watershed Management Plan C&R.111 ESA / 930385