Proceedings of the Third International Conference on Invasive ...

Chapter 4: Spartina Control and Management<strong>Proceedings</strong> <strong>of</strong> <strong>the</strong> <strong>Third</strong> <strong>International</strong> <strong>Conference</strong> on Invasive Spartinasite. Issuance <strong>of</strong> site-specific BOs depended on <strong>the</strong> development<strong>of</strong> site-specific Spartina control plans by <strong>the</strong> ISP andits partners.SITE-SPECIFIC SPARTINA CONTROL PLANSConcurrent with, and subsequent to <strong>the</strong> completion <strong>of</strong><strong>the</strong> FEIS/R and PBO, individual site-specific Spartina controlplans (SSPs) (California Coastal Conservancy 2004(b))for 2004 were drafted by <strong>the</strong> ISP and its partners for 16 sitesscattered throughout <strong>the</strong> estuary. These sites were chosenbased on a variety <strong>of</strong> characteristics, including existing partnerinvolvement, infestation age and composition, endangeredspecies issues, access issues, adjacent land uses ando<strong>the</strong>r criteria. The 16 sites chosen for Spartina control in2004 included 45 sub-areas (areas fur<strong>the</strong>r delineated for ease<strong>of</strong> treatment) encompassing an estimated 181 net ha (447 netac) <strong>of</strong> Spartina, within just over 6,070 ha (15,000 ac) <strong>of</strong> estuarymarshland. Each <strong>of</strong> <strong>the</strong> SSPs included: Scope <strong>of</strong> Work Work Program defining <strong>the</strong> schedule <strong>of</strong> work Budget Impact Identification Matrix Impact Mitigation Matrix Spill Prevention Protocols Drift Reduction Protocols Marsh Safety Recommendations Site Maps Site PhotographsAs part <strong>of</strong> <strong>the</strong> requirements <strong>of</strong> <strong>the</strong> California EnvironmentalQuality Act (CEQA), each SSP contained an ImpactIdentification Matrix and an Impact Mitigation Matrix. TheImpact Identification Matrix evaluated <strong>the</strong> suite <strong>of</strong> Spartinacontrol methods proposed for each site for potential impactsto environmental resources. Included in <strong>the</strong> matrix were impactsrelated to geomorphology and hydrology, water quality,biological resources, air quality, noise, human health andsafety, visual resources, and cumulative impacts.Once <strong>the</strong> impacts associated with Spartina control workwere identified for a given site, an Impact Mitigation Matrixwas prepared. Each site’s matrix explicitly referenced thosemitigation measures defined in <strong>the</strong> FEIS/R that were to beimplemented in <strong>the</strong> field. Impact Mitigation Matrices weredesigned to require verification signatures next to each mitigationmeasure. Both <strong>the</strong> implementing agency representativeand a representative <strong>of</strong> <strong>the</strong> ISP were required to verifythat all mitigation measures were implemented.PERMITTING AND GRANTSThe completion <strong>of</strong> <strong>the</strong> SSPs enabled FWS review <strong>of</strong> <strong>the</strong>documents for issuance <strong>of</strong> site-specific BOs which analyzed<strong>the</strong> effect <strong>of</strong> <strong>the</strong> proposed work on <strong>the</strong> suite <strong>of</strong> endangeredspecies within <strong>the</strong> scope <strong>of</strong> <strong>the</strong> project (USFWS 2004(b)).Individual site-specific Environmental Assessments (EAs)were also prepared at this time to determine <strong>the</strong> effect <strong>of</strong> <strong>the</strong>proposed work on <strong>the</strong> greater environment beyond endangeredspecies issues (USFWS 2004(c)). The results <strong>of</strong> <strong>the</strong>seanalyses provided <strong>the</strong> basis for a Finding <strong>of</strong> No SignificantImpact (FONSI), which declared that <strong>the</strong> proposed Spartinacontrol work would not produce “significant impact” on <strong>the</strong>estuary’s natural resources (USFWS 2004(d)). Additionally,a Record <strong>of</strong> Decision (ROD) was published in <strong>the</strong> FederalRegister announcing <strong>the</strong> completion <strong>of</strong> <strong>the</strong> FEIS/R (USFWS2004(e)).Soon after its inception, <strong>the</strong> ISP worked to identify partneragencies and groups that would be willing to join in <strong>the</strong>effort to control non-native Spartina in <strong>the</strong> estuary. Many <strong>of</strong><strong>the</strong> partners involved in developing SSPs for <strong>the</strong>ir jurisdictionslacked <strong>the</strong> funds to initiate control work on <strong>the</strong>ir own,so outside funding for control operations were necessary forwork to proceed. In some cases, funding was not <strong>the</strong> constrainingfactor for <strong>the</strong> partner, but instead, clearing permittinghurdles, logistics or knowledge <strong>of</strong> control methodologiespresented <strong>the</strong> greatest challenge. In each case, <strong>the</strong> ISPprovided <strong>the</strong> necessary assistance to implement <strong>the</strong> Spartinacontrol plan. Where funding was <strong>the</strong> limiting factor, grantsfrom <strong>the</strong> Conservancy were provided to enable work to proceed.The terms <strong>of</strong> <strong>the</strong>se grant agreements were negotiatedduring late 2003 and <strong>the</strong> first half <strong>of</strong> 2004. Ultimately <strong>the</strong>Conservancy and <strong>the</strong> CalFed Bay Delta Authority issued atotal <strong>of</strong> $350,000 in grants for Spartina control work in <strong>the</strong>estuary for <strong>the</strong> 2004 control season. Official ISP partners forthis season included U.S. Fish and Wildlife Service, EastBay Regional Parks District, Alameda County Flood ControlDistrict, California Department <strong>of</strong> Transportation, SantaClara Valley Water District, City <strong>of</strong> Palo Alto, Friends <strong>of</strong>Corte Madera Creek Watershed, Tiburon Audubon Society,Marin Conservation Corps, and California Department <strong>of</strong>Parks and Recreation. Inclusion <strong>of</strong> any organization oragency as an <strong>of</strong>ficial ISP partner required that partner’s governingbody <strong>of</strong>ficially adopt <strong>the</strong> ISP’s FEIS/R, develop anSSP in coordination with <strong>the</strong> ISP, and adhere to any mitigationsdefined in <strong>the</strong> Impact Mitigation Matrix developed for<strong>the</strong> site within <strong>the</strong>ir jurisdiction.For each type <strong>of</strong> control method proposed for each site,certain permits needed to be acquired before work couldbegin. In <strong>the</strong> case <strong>of</strong> herbicide applications, all treatmentswere required to comply with <strong>the</strong> Environmental ProtectionAgency’s National Pollutant Discharge Elimination System(NPDES), administered by <strong>the</strong> California Water QualityControl Board’s (CWQCB) San Francisco Bay regional <strong>of</strong>fice.However, at <strong>the</strong> outset <strong>of</strong> 2004, <strong>the</strong> CWQCB had yet todevelop an NPDES permit to cover <strong>the</strong> discharge <strong>of</strong> aquaticpesticides, a novel application <strong>of</strong> this portion <strong>of</strong> <strong>the</strong> CleanWater Act that had, until recently, been reserved for <strong>the</strong>regulation <strong>of</strong> effluent discharge. As a consequence,herbicide-based control operations throughout <strong>the</strong> state wereon hold until <strong>the</strong> CWQCB revised its permitting procedures- 218 -