San Diego Bay National Wildlife Refuge

San Diego Bay National Wildlife Refuge Complex

6010 Hidden Valley Road

Carlsbad, CA 92011

Telephone: 760/930 0168

Fax: 760/930 0256

California Relay Service

TTY 1 800/735 2929

Voice 1 800/735 2922

U.S. Fish & Wildlife Service

http://pacific.fws.gov

For Refuge information

1 800/344 WILD

August 2006

Photo: USFWS/J. Konecny
Comprehensive Conservation Plans provide long-term guidance for management decisions 

and set forth goals, objectives, and strategies needed to accomplish refuge purposes and 

identify the Service’s best estimate of future needs. These plans detail program planning 

levels that are sometimes substantially above current budget allocations and, as such, are 

primarily for Service strategic planning and program prioritization purposes. The plans do 

not constitute a commitment for staffing increases, operational and maintenance increases, 

or funding for future land acquisition. 
San Diego Bay 

National Wildlife Refuge 

Sweetwater Marsh and South San Diego Bay Units

Final Comprehensive Conservation Plan and 

Environmental Impact Statement 

Volume III – August 2006 

Appendix P: Responses to Comments 

U.S. Fish & Wildlife Service
Appendix P: Responses to Comments 

Commenter Page

1. U.S. Environmental Protection Agency P-1 

2. U. S. Department of Commerce, NOAA, National Marine Fisheries Service P-3 

3. U.S. Department of the Navy, Commander Navy Region Southwest P-5 

4. Congressman Bob Filner, 51st Congressional District P-21 

5. California Department of Fish and Game P-23 

6. San Diego County Regional Airport Authority P-24 

7. Port of San Diego, Environmental Services P-27 

8. City of San Diego, Metropolitan Wastewater Department P-28 

9. County of San Diego Supervisor Greg Cox, First District P-29 

10. County of San Diego, Chief Administrative Office, Robert Copper P-31 

11. Environmental Health Coalition P-48 

12. Friends of the San Diego Wildlife Refuges P-76 

13. San Diego Audubon Society P-77 

14. Buena Vista Audubon Society P-80 

15. Southwest Wetlands Interpretive Association (SWIA) P-84 

16. San Diego Archaeological Society, Inc. P-88 

17. Sierra Club, San Diego Chapter P-89 

18. South Bay Salt Works P-93 

19. Johnson & Hanson LLP P-115 

20. Nils Warnock P-117 

21. Robert Patton P-120 

22. Elizabeth Copper P-157 

23. Brian Foster P-169 

24. Monica Alfaro P-176 

25. Kirsten Winter P-183 

26. Guy McCaskie P-187 

27. Shauna Wolf P-189 

28. Michael Evans P-191 

29. Therese Clawson P-193 

30. Kenneth Weaver P-194 

31. Susan Yamagata P-195 

32. Jack Daynes P-196 

33. James Sands P-197 

34. David Seay P-199 

35. Ed Kravitz P-201 

36. Gerrold Adler P-223 

37. Theresa Jancek P-224 

38. B. Sachau P-225 

39. Verbal Comments Presented at a Public Meeting Held on August 31, 2005 P-226 

 a. Jim Peugh, San Diego Audubon P-226 

 b. Laura Hunter, Environmental Health Coalition P-226 

 c. Dan McKirnan, Environmental Health Coalition P-228 

 d. Warren Dodd, South Bay Salt Works P-229 

Literature Cited P-232 
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1.1 Comment Noted. 
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2.1 The need to consult with NOAA’s Nat

under the Magnuson-Stevens Fishery Management Act during the preparat

restoration plans for the restoration oadded to Section 1.4 of the Final CCPEssential Fish Habitat has been adde

2.2 The specific locations, configurations, 

nesting enhancements to be implemenalternative would be determined durinengineering and restoration planningenhancements would be selected baseoptimal habitat value for both fish and This evaluation will consider input proother programs in the USFWS includEcological Services, NOAA’s NationaCalifornia Department of Fish and Ga

2.3 As described in Response 2.2, specific

areas to be restored under the preferrdetermined during subsequent detailetime, restoration is intended to includincluding tidal channels, unvegetated pickleweed-dominated salt marsh, and Because one of the objectives of the rerestore habitat essential to the conserlight-footed clapper rails in San Diego placed on restoring cordgrass-dominaportions of the South San Diego Bay U
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3.1 A discussion of surrounding military l

operations occurring in the vicinity of the Final CCP/EIS as Section 3.6.1.5. resource management activities for thlocated adjacent to and north of Emoraffect authorized Naval training activadded to Section 4.7.1 of the Final CC

3.2 With the exception of the northwest c

management recommendations are inwould affect the Naval Radio ReceivinCoronado (NRRF). In addition, the Cit include any management recommenStewardship Project. The need for coto making any changes to Pond 11 has (Required Permits and Approvals) anCCP/EIS. Various figures have also bownership in Pond 11 and indicate the Navy during step-down planning for P

3.3 The potential effects of the proposed m

San Diego Bay NWR on the endangerlands are addressed in Section 4.7 of t

3.4 We do not agree that restoration of a 

tidally influenced habitat would reducStreet Fill for least terns or western sis based on current and historic nestinand the proposed management actionunder the preferred alternative. NestStreet Fill from 1998 to present indicaand western snowy plovers are not nefor tidal restoration. The majority of 

end of the D Street Fill, although somnortheastern portion of the Fill (refer CCP/EIS). 
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This preference for the western portiosubstrate conditions, proximity to humeffects of night lighting from adjacent to appropriate foraging areas. Under Alternative C, approximately 3would be preserved and enhanced to sand 13 acres at the south eastern end habitat. As stated in the draft CCP/Enesting activity at the D Street Fill, thhave any significant adverse effects on intended to improve nesting success fsupported by the plan objective for le(Objective 2.1) that is included in SectCCP/EIS. This objective envisions inspecies. Strategies proposed to achievenhancing the existing nesting substradditional fencing, removing shrubs aappropriate, and improving access to Further, an increase in intertidal areawould provide additional proximal for

3.5 The management actions included un

San Diego Bay Unit are intended to cimprove the ecological conditions for a allowing for the dynamics of the ecosynatural and environmentally healthy shabitat within the salt works is directconditions for nesting least terns and the ground nesting birds supported wbenefits from this action. Currently, lnest on marginal habitat near the salt more remote levees. We believe this icompetition with other ground nesting expanding the area available for nesti
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be reduced and the number of least teincrease. Predation of the least tern and snowy terns is a management issue that exteRefuge. The fact that species conflictsuitable nesting habitats that remain should not result in a call to avoid habrestoration. Our challenge is to provican be used by as broad a range of naas possible. The Service, through the 

continue to monitor the interactions oleast terns, and western snowy plovermeasures intended to support the conspecies. 

3.6 A meeting to address the Navy’s comm

2006. 
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3.7 We understand that the Navy SEALS 

channel north of Emory Cove and use lands and established training areas asubmerged lands are leased to the SerCommission as part of the South San management actions are proposed for lands north of and adjacent to Emory access to NRRF or their ability to trasubmerged lands are not under the prService, Refuge compatibility determleased areas are not needed. 

3.8 With respect to the NRRF, refer to R

step-down restoration planning for Pothe Navy to determine what if any chabe appropriate in this location. The pinclude a proposal to permit public ac

3.9 Alternative B for the Sweetwater Mar

the management activities occurring onesting terns and plovers. No converintertidal habitat is proposed. Changto recontouring the southern edge of torange on Figure 2-3, to improve plovforaging areas. This proposal is intensuccess for western snowy plovers at The effects of implementing AlternatiMarsh Unit are addressed in Respons
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3.10 Data describing the historic and curre

California least terns and western snoSection 3.4.6, however, for clarity, this into a new figure, Figure 3-13, and adCCP/EIS under the discussion of Calisnowy plovers. References to this figuSection 3.4.4.1 (Breeding Birds, NestiAlternative C, the D Street Fill would nesting birds as well as provide additiplovers and other shorebirds. ApproxStreet Fill would be preserved and ennesting and 13 acres would be designaAs stated in the draft CCP/EIS, based use of the D Street, this proposal wouadverse effects to ground nesting birdimprove nesting success for plovers a

3.11 The conversion of upland habitat to in

expected to result in significant adverthis site and effects to tern nesting nuneutral or positive. Although some upconverted to intertidal wetlands, this would provide additional proximal forchicks and adults and California least Further, the preferred alternative incnew nesting habitat within the salt woperceived loss of potential nesting hab

3.12 Refer to Responses 3.4 and 3.5 above. 3.13 In both Sections 2.2.1.2 and 2.1.2.2 of 

Action alternative is described as follono change to past and present manage
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3.14 The Summary provides an overview o

draft CCP/EIS. Past and present masummarized for both the Sweetwater Bay Units on pages S-17 and S-19 resmanagement of federally listed specie2.2.1.1, 2.2.2.1, 2.3.1.1, and 2.3.2.1 of th

3.15 As stated on the inside cover of both t

CCP/EIS Volume I, “These plans are current budget allocations and, as sucstrategic planning and program priordo not constitute a commitment for stand maintenance increases, or funding The CCP is intended to provide a visiomanaged in the future, whether or noAppendix D (CCP Implementation), wbetter define existing allocations and proposed actions and provides estimaimplement each action. Potential fundone or more of the proposed actions is 
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3.16 The Summary document for the Fina

preferred alternatives for each Refug

3.17 Refer to Response 3.15 above. 3.18 Figures 1 and 1-2 are intended to info

location of the Refuge, not to describe therefore, it is not necessary to add insurrounding military lands to these fiStation North Island has been correctaddition, those military lands that supnesting are now depicted on revised FAmphibious Base Coronado has been of the Final CCP/EIS. A new figure, Section 3.6.1.5 of the Final CCP/EIS tthose military lands occurring in prox

3.19 Refer to Response 3.18 above. All gra

that include a reference to the NRRF that the Silver Strand State Beach is is acknowledged in new Section 3.6.1.5 

3.20 Section 1.4 of the Final CCP/EIS has 3.21 Details related to known and suspecte

Sweetwater Marsh Unit are described Objective 3.1) and Section 3.3.8 of the 

3.22 The implementation of conservation a

declines, naturally small ranges or pohabitats, or other factors are not rese
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Not only is the conservation of avian dprimary goal of the Service, but the 19Wildlife Conservation Act mandates tsubspecies, and populations of all migwithout additional conservation actioncandidates for listing under the EndaThe report, Birds of Conservation Cocarry out this mandate. The overall g

bird species, such as the gull-billed teconcern so as to stimulate coordinated 

actions among Federal, State, and pri

The statement in the fourth bullet on number of issues raised during the CCpurpose of presenting these issues, wh

public, affected agencies, and the plantypes of issues that were considered dmanagement alternatives. A more cois presented in Section 1.10.2, Issue 4 

is stated that the gull-billed tern is noThis section also addresses the concerthe chicks of California least terns and 

3.23 This citation has been added to Sectio3.24 Figures 3-8 and 3-9 have been update3.25 The proximity of Navy land to the Re

3 of Page 1.1. Refer also to Response 

3.26 Refer to Response 3.8 above. 
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3.27 Refer to Response 3.8 above. 3.28 Figure 1-6 has been revised. Refer al3.29 The text regarding fixed wing and rot

corrected. The statement on page 3-2state that the military is the primary that fixed wing and rotary wing aircrasignificant noise in the vicinity of the Rbased on personal communication witlocated on the Sweetwater Marsh Uni

3.30 A discussion of INRMPs has been inc3.31 The California Least Tern Recovery P

the official recovery plan for this specregarding the least tern has been collto revise the plan in the future. Howethe 1980 plan is the appropriate referrecovery of this species. The goal to sprotection efforts for the least tern is objectives and rationale presented in the purposes for which the Refuge wathe specific strategies for expanding aforaging habitat for the least tern withas described in the draft CCP/EIS, arprovided in the 1980 recovery plan. Pfor the Sweetwater Marsh Unit and O

Diego Bay Unit have been revised in taccurately describe the intended outcproposed within the CCP. 

3.32 The text has been revised accordingly3.33 Figure 3-13, which is now Figure 3-15

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3.34 Pair data is derived by balancing seve

depending on the site and number and For small populations or communitiescount each individual bird. For larger an approximate estimate is made of thTotal nests versus active nest numbercompared throughout the season. Th

may be derived from the maximum todate in the season. However, this may nest initiation dates may vary due to rnests, late arrival by so-called second terns), or other factors such as abandleading to immigration into the site bevaries considerably species to speciesare highly synchronous and have limiton the other hand are much less synchleading to a wide variety of age classelater in the season. 

3.35 The text has been revised accordingly3.36 The text has been revised accordingly
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3.37 Nesting attempts and number of nest

terms for the same number. To avoid revised to use the term number of neshave multiple nests within a given breplovers have been banded, it is not pocount of the number of breeding pairs et al. (2001) describes the calculations populations based on the number of n

3.38 The text has been revised to indicate t

preying on least tern and snowy plovevarious nesting sites in and around Samanaged by the Navy. The summariedescribe the results of endangered spNavy lands around San Diego Bay ackhave been observed preying on least tHowever, the full extent of gull-billed species cannot be quantified because deggs and chicks lost to gull-billed ternsummary reports. 

3.39 Mention of the Silver Strand Training 

included in Section 3.6.1.5 of the Final Responses 3.1 and 3.30 above. 

3.40 The text has been revised accordingly3.41 The results of on-going monitoring of 

of gull-billed tern predation on listed Service, primarily the Migratory Birdbest to manage this species to protect well as those of the California least te
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The Migratory Birds Program has debilled terns on this Refuge or elsewhewill not be authorized. As a result, cothe authority of the Refuge Manager. control of this species would not be cothe “no control” option discussed in thdoes not address issues related to the 

3.42 Improving seabird nesting at the salt 

the intent of having negligible adverse plover and California least tern. Plovmicrohabitats and with the exception pressures on newly hatched plover chconflicts with seabirds except in the cnesting. The nesting habitat at the saattractive to plovers for nesting as are located nearby. In the last few seasons, the tendency to only be observed after the gull-billesite for the season. This is occurring all three species. The Service acknowbilled tern nesting numbers may influwestern snowy plover and the CaliforSan Diego Bay and the Tijuana Estuarefer to Section 3.12. 

3.43 Comment noted. 3.44 Mention of the NBC INRMP, NBSD 

Training Complex project have been aFinal CCP/EIS. 
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3.45 The discussion of impacts to listed spe

been expanded in Section 4.9.2.2 of th

3.46 Mention of the Navy and Port’s involv

INRMP has been added to Section 5.2

3.47 Approval of the Predator Managemen

as part of the approval of the Final CCfollowing the issuance of the Record ofinal version of the plan has been datemanagement activities on NRRF has 

3.48 Comment noted. 
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4.1 Comment noted. 4.2 Although portions of the salt works in 

provide habitat to support a variety of restoration of the salt works would prrange of species, including avian, fish, plant species. 
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4.3 We concur. The CCP provides the vis

achieving that vision, considering the programmatic level. The CCP procesplanning” during which time additionadraft CCP/EIS, would be conducted awould be prepared. This subsequent would be conducted in an open procesdevelop the CCP. Once a final restorarestoration would be implemented in 

post-restoration monitoring and adaprevised Appendix D in the Final CCP/

4.4 The contribution of the salt works to t

are acknowledge in the draft CCP/EIdeveloping the preferred alternative. 

4.5 Comment noted. 4.6 A briefing was held prior to issuance o
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5.1 Comment noted. 5.2 The goals and objectives proposed for 

address the need to manage the Refugand habitat resources found on the Reecosystem. Consistent with the purpoestablished, a number of the objectiveactions included within the preferred Sweetwater Marsh and South San Dieconserving the Refuge’s listed specietern, light-footed clapper rail, Californsnowy plover, and salt marsh bird’s beaddress the need to provide high qualseabirds, shorebirds, and waterfowl spand to improve habitat quality for natand other wildlife. The Service appreciates the Departmplanning effort and looks forward to ydetailed restoration planning for this 
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6.1 Comments noted. 6.2 The benefits to birds that are provide

addressed in detail in Sections 3.4.1.3 CCP/EIS. References to these sectio3.4.2.1 (Solar Salt Evaporation Pondsensure a complete understanding of thponds to avian species. Detailed analysis of the potential effebeneficial, to fish, benthic invertebratspecies that could result from convertponds to intertidal habitat is provided draft CCP/EIS. 
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6.3 The description of the preferred alter

the Final CCP/EIS in both Chapter 2 Implementation) to include a more deRefuge would be managed under this restoration could be phased to incorpomanagement into the final project desregarding the types of studies and/or completed in association with subsequplanning have been added to Appendi

6.4 As stated in the draft CCP/EIS, the s

nesting and foraging habitat for a varhabitat quality for fish, benthic invertintertidal vegetation is poor to nonexiAlternative D is to maximize opportunwithin the Refuge, while maintaining salt pond system that support nesting birds. The value of any future mitigatavailable to the Airport Authority andDiego would be determined by the apaccordance with the terms of the Coop

6.5 As stated previously in your letter, th

state provide habitat value for a varieconversion of these ponds to intertidaareas would continue to provide habitproviding habitat value for fish and beDevelopment of the lands adjacent to to the same regulations (the Federal aAct, California Coastal Act, MSCP, C

Harbors Act, and others as applicable
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6.6 Comment noted. Although buffers m

existing conditions and regulations, as buffer would be required simply by viNational Wildlife Refuge adjacent to t

6.7 Refer to Response 6.5. 
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7.1 The San Diego National Wildlife Refu

inform the Port of all management acon Port developments and land uses o
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8.1 The requested change has been made

draft CCP/EIS acknowledges the neepublic utilities in the vicinity of the ReWildlife Refuge Complex will coordinmight affect City utility operations, mthe Metropolitan Wastewater Departdepartments. 
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9.1 The San Diego National Wildlife Refu

opportunity to coordinate with SANDWorking Group on our public use propbay. The pedestrian pathway proposethe Refuge is expected to benefit both traveling along the Bayshore Bikeway
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9.2 The San Diego National Wildlife Refu

with representatives from both the Ciidentify an alignment for the Otay Vaprotect Refuge resources and also meusers. 

9.3 The Service looks forward to working 

accommodate such opportunities for w
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10.1 We appreciate the County’s interest i

the resources in the south bay both wadjacent natural areas provide importroosting habitat for a diverse array of 
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10.2 This information is presented in Secti

pages 3-62 and 3-63 of the draft CCP/

10.3 Page 3-64 of the draft CCP/EIS addre

by nesting double-crested cormorants western snowy plover population withthroughout the document (e.g., SectioSection 3.4.6.1 under Federally-Listed avocets and stilts, the text on page 3-6“In fact, the only recent nesting of theavocet and black-necked stilt] in San Dsalt works (Patton 2004).” The use of nesting by Caspian terns, Royal ternsdiscussed on pages 3-62 and 3-63 of thdiscussion has been expanded in the Falso contain a discussion of the signifithe elegant tern. Please note that the updated to include additional informaelegant tern nesting colony over the pForester’s tern nesting on the salt pon62 of the draft CCP/EIS and statemensignificance of this nesting site for the on page 3-63. Finally, the significance within the Refuge is described througCCP/EIS, including the discussion of establishment, within the Refuge goal3.4.6.1 (Federally-Listed Species). Adhistoric and current use of the pond leis provided on page 3-62 of the draft C
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10.4 The natural breeding habitats for the 

nest on the levees of the salt works inbeaches, and barrier islands. Althougin coastal San Diego County in the paareas has either been lost to urban an

now experiences significant levels of dseveral of these seabirds expanding ndecades and the historic breeding grospecies have had to adapt to landformtheir preferred native habitats. Based the scientific literature and our own pbelieve that the qualities which attraclevees include limited human disturbalevees, the availability of extensive arvegetated open ground, and unrestriclevees into the surrounding area. We provide safety from terrestrial predatseabirds because of the availability of these birds would not be present here by intertidal habitat instead of open wislands and unfortunately do not provpredators. Predation is a serious manworks requiring the identification of fpredator control program during the the San Diego Bird Atlas “the intrusioconstant problem for all the water bir

Although current brine invertebrate pfor some avian species that nest at the snowy plover, Belding savannah sparrAmerican avocet), these organisms do foraging item for the seabirds that ne
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With respect to adjacency to open watinformation available to support or renesting at the salt works is solely depopen water along the levees. Many of at the salt works have been observed surrounded by open water (refer to SCCP/EIS). 

10.5 The salt works replaced the native ha

area, and although it provides nestingopportunities for a variety of avian spthis artificial habitat provides better hof the species present in this area than natural intertidal environment. The Service also disagrees with the st“destroy this successful functioning enone that will undoubtedly displace the birds.” Implementation of Alternativopportunities for habitat restoration, some cases enhancing, those aspects othat support nesting seabirds and othpreparing the CCP, the Service analyavailable regarding the diversity and observed in the salt ponds. The draft some changes in species composition aresult of restoration. Based on furtheprofessional judgment, we do not belibe of a sufficient scale to result in signavian species, including the site’s groupopulations. To understand how restospecies composition and abundance, pmonitoring would be implemented in restoration. 
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10.6 Activities proposed within coastal wet

included within a designated conservaregulated by a variety of local, state, aeffort to conserve these resources. Thareas within the bay that are not inclunecessarily more vulnerable to disturbthe CCP does propose to manage habshorebird species. As presented in ththe Refuge is proposed to be managed shorebirds. There are a number of stenhance, and restore habitat to supporestoring tidal mudflat habitat in the floodplain, reducing disturbance withiforaging and roosting areas, and contibrine invertebrates. 
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10.7 Comment noted. 10.8 The Shorebird Conservation Plan and 

Plan that occur within the Refuge are (page 3-34) of the draft CCP/EIS. Birare discussed in Section 3.4.7.1 of the of Conservation Concern supported ware listed in Table 3-14. The importanSouth San Diego Bay Unit for shoreb2.3.5.2 under Objectives 1.3, 1.4, 3.2, 3The goals and objectives for the SweeDiego Bay Units are consistent with tSouthern Pacific Shorebird Conserva

For tidal wetlands - 1) restore tidal in San Francisco Bay and on the souenhance tidal action in existing wetlsedimentation from alteration of wehuman disturbance to shorebirds in For managed wetlands – 1) improve wetlands by expanding wetland manbenefit shorebirds, 2) restore additimigrating, wintering, and breeding manage a sufficient amount of salt pwater habitat to support shorebird p

10.9 The designation of this site as a Weste

Reserve Network Site is addressed in CCP/EIS and the use of the ponds by detail in Section 3.4.4.1 (Migratory Bi

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10.11 The salt ponds in San Diego Bay prov

resting habitat for an abundant and dwe do not agree that they represent dHistoric maps of San Diego Bay prepaGeodetic Survey in 1859 (refer to Figuindicate that the southern shoreline oby a broad band of intertidal mudflatswas an extensive salt marsh system lachannels and several freshwater drain

and possibly a few natural salt ponds salt marsh system, but based on the dother historic maps, it is unlikely that extensive in this area. The salt ponds quality of habitat that once occurred hMasero (2003) defines these types of s“anthropogenic habitats,” which “can complementary feeding habitat for wathat salt ponds are important feeding shorebirds, but the importance of this Masero (2003) notes that foraging oppsuitable for all of the species supportehabitats. To provide high quality foraspecies, the Service is proposing to reto the historic habitats of intertidal mwhile retaining other ponds as managspecies that favor the brine invertebrsystem. 

10.12 This statement from the Shorebird Pl

plover use in San Francisco Bay (see where about 10% of the U.S. Pacific cplover breeds (Hickey et al. 2003). Un3-76 of the draft CCP/EIS, despite reon the levees in South San Diego Baygenerally low and fledgling success is 
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Since 1999, an average of 1.8 snowy pl

observed at the salt works, with a totain 2004 and a high of four nests observcomm.). The proposals in Alternatives C and Dadditional nesting habitat within the senhanced access from nesting areas to are intended to improve habitat qualitboth alternatives, the following habitaPlan have been addressed: 1) manage especially at San Francisco Bay, Monspecifically for nesting, feeding, and rsome to be managed specifically for nrecommended in the Snowy Plover Drpublic closures of Snowy Plover nestinseason; 3) continue to manage non-naavian predators to limit predation of tSnowy Plover; and 4) use fencing and Plover nests from egg predators when implemented under Alternative D to eopportunities for western snowy plove2.3.2 and 2.3.5.2 of the draft CPP/EISsubstrate on the salt pond levees, recolevees to improve access to foraging alevees, and controlling water levels in during the nesting season to provide nnesting. 

10.13 Section 4.4.2.3.1 of the draft CCP/EIS 

to colonial nesting seabirds of breachiexception of the gull-billed tern, the sprey primarily on fish found within thThey also forage to a lesser extent for within Ponds 10 and 11. None of thesinvertebrates for any significant porti
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Introducing tidal flows into the ponds foraging opportunities for these birds habitat. Section 4.4.2.3.1 of the Final include a discussion of the potential efAmerican avocet and black-necked stisalt ponds. 

10.14 Currently, mammalian predators can 

areas via the existing levee system, as either by swimming across the narrow the channel during low tide. Avian prare controlled when deemed approprihowever improve access for mammaliduring low tide, and would provide adpotential predators such as northern haccessibility to the levees by predator4.4.2.4.1 of the draft CCP/EIS. Actionimplement predator management, insperimeter of the salt pond complex, dmanner that reduces accessibility from implementing a monitoring and adaptrecord and address any increases in prestored areas, have all been incorporalternative in an effort to minimize thground nesting birds within the South 

10.15 The eastern edge of the Refuge, which 

right-of-way by approximately 820 feethan the distant freeway; therefore, th

is not expected to have any effect on b

10.16 As described in Sections 2.3.2.3, 2.3.2.

CCP/EIS, sediment analysis would be detailed restoration planning to ensursediments present or to be added to thwould support future restoration per 
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and others who have successfully restsouthern California coastal areas. 

10.17 Enhancing and expanding nesting hab

expected to improve nesting conditionnest along the levees. The provision oelsewhere along the southern Californbeneficial to several species of terns. salt ponds for western snowy plover nconservation action included in the SoConservation Plan (Hickey et al. 2003

10.18 As discussed in Section 2.3.2.4 (page 2

additional modeling and analysis of thmanagement areas would be conductedown planning. In addition, a water mprepared to establish the operating, mactivities and associated costs requirewater systems. Prior to implementing proposal, funding adequate to maintaiproject would be identified. Water mahabitat needs of fish and wildlife has bcommon management practice on varNational Wildlife Refuge System. 
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10.19 As stated in the goals for this Refuge 

2.3.5.2 of the draft CCP/EIS, the purpD is to protect, manage, enhance, and benefit native fish, wildlife, and plants San Diego Bay Unit, to support the relisted species that occur here, and to pand breeding habitat for migratory anRefuge was established to conserve li

actions included within the CCP must purpose. It is our intent to enhance aspecies, while also providing habitat tabundant array of avian species within plans would include monitoring and adcomponents to ensure that all of the o

are being achieved (refer to Appendix 

10.20 This CCP/EIS is intended to present 

various management alternatives cona result of this analysis, a number of ugaps were identified that will require consideration before final restoration Following approval of the CCP, work uncertainties and develop more compof the data to be obtained includes updiversity, and use patterns within the characterization and groundwater and the salt ponds and Otay River floodpltidal flow within the salt ponds followiinformation will enable the planning tstrategies and develop the applied stumonitoring and adaptive management Implementation) has been revised to iregarding the steps to be completed in engineering and restoration plan as p
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We do not agree that the proposal to rto tidal influence would result in signiassessment of the impacts expected to the salt ponds to intertidal habitat is pand 4.4.2.4.1 of the draft CCP/EIS. Bpresented in the CCP, we believe the Refuge will be achieved and as such wmission of the National Wildlife Refugwhich the Refuge was established. 

10.21 The goals, objectives, and strategies f

the endangered California least tern aplover are presented in Section 2.3.5.2 not agree that the restoration proposaresult in the displacement of least tersite. Rather, the actions included undexpected to improve nesting success fimproved nesting habitat and better aalso to Response 10.20 above. (The coa Section A; therefore, we are unable in this portion of the letter.) 

10.22 The development of these alternatives 

related to biological resources that is were coordinated with the Migratory 

Programs of the Service to ensure conSpecies Act and the Migratory Bird Trelevant regulations and policies relatAlthough some of the strategies to be Alternative D focus on protection and which is consistent with the purpose oalso proposes to retain those aspects ovarious migratory birds and nesting s
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The potential outcomes of implementiponds are presented in the draft CCPadditional baseline data is obtained anconducted in association with detailed planning, the potential outcomes will bensure that the objectives established endangered species, migratory birds, (all of which are presented in Section are achieved, monitoring and adaptive integral part of this restoration propo

10.23 As stated in Response 10.21 above, we 

implementation of Alternative D woulspecies. In fact, the strategies proposgoals and objectives are intended to imspecies consistent with the recommenspecies’ approved recovery plan. With respect to elegant terns, it is the maintain the isolated nature of the salimprove potential nesting sites for thinesting birds within this area. The prfisheries habitat in proximity to these continued presence of open ground winesting, provide for predator manageunrestricted visual access from the levAs identified in the draft CCP/EIS in insufficient information available to stpond restoration might affect the elegnesting seabirds that breed on the salcharacteristics of the salt works that wbirds to the salt pond levees (isolationsubstrate, and unrestricted visibility) some cases enhanced. Further, obserelsewhere in coastal California indicatincluding elegant terns and California 
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nesting in areas that are not surroundof Alternative D is to ensure the contishorebirds at the salt works prior to, The effects of restoration on these ancontinue to be considered during the dimplementation of a phased restoratioUnder the Multiple Species ConservaDiego currently has no take authorizawestern snowy plover, or elegant ternthat support these species are not locaSubarea Plan boundary. Therefore, aoutside the County’s control and woulCounty’s Implementing Agreement oit is not the intent of this CCP to causdescribed above. Prior to the implementation of any reundergo internal Section 7 review to ejeopardize the recovery of any listed s

10.24 The public involvement component of 

Diego Bay NWR included numerous pto provide comments through public wCCP webpage, and an extended publidocument. A summary of the public oSection 5.2.1 of the draft CCP/EIS. Ipublic involvement component of the beyond the completion of the Final CCplanning for the development of detaifor the various public use proposals in
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10.25 The issues raised regarding the adequ

CCP/EIS are addressed in Responses 

10.26 The Service has used the best informa

studies, scientific literature, consultanconduct this program-level impact anamanagement alternatives. To ensure presented, some revisions to Sections the incorporation of additional maps athe Final CCP/EIS. A number of uncidentified in the draft CCP/EIS that wrestoration planning process moves foImplementation) has been revised to dsteps that will be completed prior to bwithin the Refuge. 

10.27 We agree and have clearly stated this 

and 2.3.2.4 of the draft CCP/EIS. Grabased on preliminary restoration planpotential impacts at the program leveand other issues typically analyzed in 

10.28 Alternative D includes a brine inverte

intended to meet the foraging needs ohistorically stopped at the salt ponds Response 10.26, the draft CCP/EIS huncertainties, which include the respogrebes to changes in the current salt pcontinue to be considered during the s

10.29 The CCP does not make the assumpti

footed clapper rail will be provided at Please refer to the goals and objectivepresented in Section 2.3.5.2 of the dra

10.30 Refer to Response 10.18 above. 
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10.31 The public uses proposed under the p

described in detail on pages 2-99 throuCCP/EIS and in Appendix K (CompaWith respect to neighboring agency cinvolved in ongoing discussions with bDiego park staff to determine the mosthe Otay Valley Regional Trail. We aCity of Imperial Beach on proposals tecotourism planning. Public uses on thave been discussed with the Chula VCity of National City and issues relatediscussed before the Coronado City C

10.32 Mosquito production in fresh and salt 

Section 4.7.5.2 of the draft CCP/EIS. salt water mosquitoes could be createDiego Bay Unit, low and mid-marsh hdominated salt marsh, is inundated daprovides little habitat suitable for salt (Maffei in Goals Project 2000). 

10.33 Although the implementation of the N

maintain the existing diversity and abcurrently found within the salt ponds, improvement in habitat quality for the the Refuge. Alternative B would provplovers in the form of expanded nestinbenefits for light-footed clapper rails realized. The Service continues to supsouth bay, including restoration of botRiver floodplain. Appendix D of the Final CCP/EIS hadescribe how restoration that would b
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Preferred Alternative. Step-down placollection of additional baseline data astudies related to hydrology, sedimencontaminants, and other topics, followengineering and restoration plans thapost-restoration monitoring and adaprestoration design. 
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11.1 The need to maintain and where appr

within the Refuge that support specieaddressed in several of the goals and draft CCP/EIS (refer to Sections 2.2.5CCP/EIS). Although adaptive managAppendix D of the draft CCP/EIS, thexpanded in the Final CCP/EIS. 

11.2 Information about the current habitat 

summarized in Section 3.4.1.3 of the F

11.3 Comment noted. 
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11.4 The potential for premature closure o

operation is addressed in Sections 2.3Phasing) of the draft CCP/EIS. 

11.5 The goals and objectives addressed in 

Sweetwater Marsh and South San Diemultiple species approach to refuge mproposed to benefit bird, fish, and othhabitats (refer to Sections 2.2.5.2 and Because this Refuge was established emphasis is placed on actions that suplisted species that occur within the Reevaluated a range of restoration scenaincluding a phased approach to restor

11.6 Comment noted. Appendix D (CCP I

revised to include a more detailed discof the preferred alternative should pr

11.7 Coordination between the San Diego 

Francisco Bay NWR is occurring to eregarding salt pond restoration is excResearch and modeling efforts underwPonds in San Francisco Bay will provrestoration proposals in San Diego Barecommendations developed for the Sincorporated into detailed planning efNWR. However, just as there are simprojects, there are also significant diffof the two restoration areas, and both differences must be considered when to restoration for either area. 

11.8 Comments noted. 
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11.9 The various actions or projects propo

alternative for each Refuge Unit are pAppendix D (CCP Implementation). Tthe Final CCP/EIS to prioritize all of for each Refuge Unit within one overa

11.10 Enhancements that support the recov

identified as high priorities for implemAppendix D (CCP Implementation) in 

11.11 The preparation and implementation 

Otay River floodplain are dependent uNo funding has been identified to date initiation of such efforts. As described in the project descriptioCCP/EIS), substrate analysis of the pmaterial excavated from the Otay Rivcompleted prior to detailed restoratioextent and type of contamination, if ansuitability for salt marsh restoration. suitability include, but are not limited and availability of nutrients. Incorporproject description represents a commshould this alternative be selected as 

Sections 4.2.2.3.4 and 4.2.2.4.4 and Apaddress the potential effects to air qurestoration proposals for the South Saon page 4-36, the projected duration oexport estimates, estimated truck tripthe types and numbers of construction implement the various phases of restogenerating the exhaust and fugitive dresult from project implementation. I
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grading quantities associated with imrestoration plan are significantly greaconduct the current analysis, additionconducted in association with step-dow

11.12 At this time, the Service is not conside

the approved acquisition boundary for discussion of the existing opportunity cooperative agreement with the Port the draft CCP/EIS. Unlike the tidal fSweetwater Marsh Unit, the J Street approved acquisition boundary for the can only be incorporated into the Refu(the Unified Port of San Diego) is willthe property to the Service. As stated CCP/EIS (Features Common to All ADiego Bay Unit), the Service is propoCity of Chula Vista, and the State Lanmanagement authority for the remainlocated within the Refuge’s approved 

11.13 The Service agrees that restoration of 

Diego Bay is an important component the bay ecosystem. Eelgrass restoratnot included as a proposed action in thconstraints and the need for additionapartners in the bay. The Service’s CCinclude a process for plan review that approved CCP, including the incorporproposed project is deemed appropriaAccording to the Policy, review of the annually to decide if the plan requires the plan and associated management this review or other monitoring and evneed changes to achieve planning unit 
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11.14 Page 2-103 of the draft CCP/EIS stat

would continue to be permitted within adhere to the existing five mile per hoon to say that this issue could be revisthe future related to wildlife disturbanactivities on the Refuge. The San Dieemployees a law enforcement officer wenforcement of applicable rules and reIn addition, we have initiated discussidiscuss the need for increased enforcethe south bay. Acquisition of a Refugpriority list of Refuge Operating NeedAppendix D of the Final CCP/EIS). 

11.15 The CCP/EIS, which is only the first 

developing a restoration plan for the sthe long-term vision for the Refuge anvarious actions to be taken to achieve raised here regarding phasing, adaptirestoration design will be explored in subsequent project-level restoration pImplementation) of the Final CCP/EIclearly describe the next steps in the pinclude the collection of baseline data additional studies related to hydrologcontaminants, and other topics that arCCP/EIS. Once this information has restoration plan for the salt ponds wilbeen revised in the Final CCP/EIS to discussion of restoration phasing unde
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11.16 Information about the current use of t

nesting seabirds is collected annually funded by the Service. Preliminary mto the Service weekly during the nestiannual summary report. We are not aother current information regarding bdata obtained during this annually moidentifying any short or long term chaand/or fledgling success, provides infoseabirds respond to substrate enhancand provides clues regarding the presfactors that could be adversely affectibirds. Pages 3-61 through 3-63 of the variety of colonial seabird species that To make this information more access(Table 3-13) has been added to the Finnumbers for 2005, which were not avaCCP/EIS was completed, have been aBased on the data, we do not agree thhas changed significantly since 1999. to state that the number of nests per svaries, sometimes significantly, from ysuch fluctuations are not easy to identoutside the influence of Refuge managchanges in prey availability, etc.). 

11.17 As stated on page 2-91 of the draft CC

managed water areas proposed under salinity levels no greater than 39 ppt othe ambient salinity levels in the bay. expected to have no deleterious effect south bay; however, additional water 
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conducted in association with the complans and our request for a discharge Water Quality Control Board. Additiimplement a managed water system whigh to benefit from tidal action would subsequent step-down restoration plaexamine options that minimize costs awhile also providing the appropriate clevels in some ponds and support the invertebrates in other ponds. 

11.18 All of these recommendations are incl

preferred alternative and will be implSpecific phasing for implementing theupon a variety of factors that we may Appendix D of the Final CCP/EIS hagreater detail a phased approach to re

11.19 Refer to Responses 11.10 and 11.18 ab

11.20 Refer to Responses 11.11 and 11.15 ab
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11.21 Comment noted. Please refer to Resp

coordination with efforts underway at Complex. Details regarding restoratiBay are available at www.southbayres

11.22 We concur with the need for monitori

well as other migratory birds, prior torestoration efforts in the south bay. Sa strategy for achieving Objectives 2.1draft CCP/EIS. The Refuge Complex current avian monitoring program coninclude a year-long avifauna survey of adjacent mudflats. 

11.23 As a program-level document, this CC

vision and goals for the Refuge. The opresented in the CCP describe the opgoals can be achieved. The strategiesactions under the preferred alternativdefined during subsequent project levdescribed in revised Appendix D of ththe step-down planning phase of CCP details of restoration design, monitoriwill be developed. Just as is the case subsequent step-down planning would opportunities for public review and coWe concur with your comments regarand intend to incorporate an adaptive our final restoration design. Jacobson 

management as “a cyclic, learning-ori
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management of complex environmentcharacteristic of high levels of uncertaand the potential ecological, social, anmanagement options.” To successfulmanagement, it is essential to have cletargets, sound conceptualization of thfor learning from restoration and manmonitoring and evaluation of the monprocess for refining and improving cuactions. It is this approach we propos

11.24 Much information regarding the life h

shrimp and brine flies, such as reprodhabitat preferences, and potential limavailable in the scientific literature. Ustarting point, additional data would bbrine management ponds would meet maintaining a stable source of brine inbirds (Objective 3.2 for the South San for additional studies and monitoring Appendix D. Different approaches to water system are addressed in Respo

11.25 The specific issues related to phasing 

maintaining various sizes of a possible construction mobilization, and funding addressed to the project level within tone pond at a time should be evaluatemanagement does not appear to be feto the east of the Otay River due to thof the pond system. However, a phasof the salt ponds (while still maintainifeasible by grouping certain ponds int
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The concern related to flexibility in fuaddressed through the adaptive manadiscussed in revised Appendix D (CCP CCP/EIS. The specific details of any Refuge would be developed during a swhich would include public involvemerequired environmental compliance d

11.26 As stated in Response 11.13, the CCP 

plan review that could result in modifithe inclusion of new projects if deememodifications, if needed, could also be adaptive management process rather revise the CCP. The need to further emanagement options under the preferto the Final CCP/EIS under Section 2

11.27 We believe that the implementation o

or 3, as presented in the draft CCP/Ethe actions necessary to protect habitshould the salt works be closed premato be implemented would be dependenavailability of funding and the extent is available to alter the pond elevationoccur, there would still be an opportunthe step-down planning process and ahave to be acquired. 

11.28 Water management to support the ha

has been and continues to be a commonumerous refuges throughout the Natherefore, staff training or expertise fSystem is available if required to addrmanagement needs on this Refuge. 
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11.29 Comment noted. 

11.30 The description of the managed water 

the Final CCP/EIS to include considemanaging the water and for providing invertebrates within the restoration p

11.31 Appendix D has been revised in the F

detailed discussion of restoration phaincludes various opportunities for pubpublic workshops to review monitorininitial restoration. Research opportunincorporated into this phasing plan to from the various restoration actions tRefuge Complex is also committed to dialogue with researchers and Refuge implementing salt pond restoration in 

11.32 With respect to public review and inp

involvement will continue to be an impimplementation process, with opportustep-down planning. Refer to the phaAppendix D for additional details on hwould be incorporated into the proceswould be conducted in accordance witof Interior’s NEPA guidelines. 

11.33 We appreciate these suggestions. Th

materials is addressed in the draft CCbeen revised to address directional sig
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11.34 Because of the nature of the commerc

involves the use of heavy equipment atime security around the salt plant, it security or safety perspective to constaround Pond 28 under any circumstansystem. There would however be otheto enjoy the wildlife and views within organized tours around the salt works future opportunities for wildlife obsereducation, and interpretation along th

11.35 We agree. The potential use of remote 

approaches for interpreting the resouRefuge are described on page 2-102 o

11.36 It is important to interpret all aspects 

The market hunting that occurred in timportant part of the history of San Dtraditional and legitimate form of wild

National Wildlife Refuge’s when deteRefuge purposes. The revenues geneProgram and the excise tax on huntinprovided a steady stream of revenue tRefuge System over the past 60 yearscontributions have provided to wildlife With respect to how implementation othe Refuge would be prioritized, it is limplemented based on the availability sources. 

11.37 The discussion of water quality within 

the Final CCP/EIS. 

11.38 The Final CCP/EIS has been revised 

San Diego County Department of Hea
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11.39 The need for public outreach regardin

monofilament accumulation in the Souaddressed in Objective 1.7 of the draft greater detail under Alternative B for Unit. This proposed action should havSection 2.3.1.2 (Features Common to was inadvertently omitted from this shas been revised accordingly. In addidetails of the Monofilament Recovery (MRRP) being implemented in FloridWildlife Conservation Commission anprovides an excellent model for develoSouth San Diego Bay. The details of tincluded in the Final CCP/EIS. 

11.40 Comment noted. 
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12.1 Comment noted. 
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13.1 Comment noted. 13.2 Please refer to Responses 11.5, 11.15, 
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13.3 Comment noted. 13.4 These target numbers have been revi13.5 As described under Objective 1.5 for t

the draft CCP/EIS, participation in wplanning for those watersheds that inRefuge Unit is a strategy to be implem

13.6 Comment noted. 13.7 The Environmental Consequences sec

addresses the potential benefits to learestoring the Otay River floodplain. Hspecifically addressed under ObjectivBay Unit; therefore, Section 2.3.5.2 of revised to include a discussion of this 

13.8 Appendix D has been revised to bette

be phased within the salt pond comple11.23 and 11.26 above. 

13.9 These actions are included in the pref

on page 2-93 of the draft CCP/EIS. 

13.10 As stated on page 2-99 of the draft CC

platforms are included as a componen2.5 has been added to the Final CCP/Emaintain appropriate pelican roosting Refuge Unit. No substantive conflicts seabird nesting have been documentesituation is not expected to change fol
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13.11 Refer to Responses 11.17 and 11.30 ab

13.12 Comment noted. 

13.13 We concur and believe that the goals 

draft CCP/EIS address this desire to the need to restore a portion of the hilost in San Diego Bay. 
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14.1 Although we agree that a number of t

important habitat for an abundant and species, we do not agree that this systfunctioning ecosystem. The salt worknot contribute to the bay’s fish populabenthic invertebrates or plants that ainfluenced portions of the bay. 

14.2 The draft CCP/EIS describes the sign

to the array of birds that utilize the simigration, or as a wintering area. As draft CCP/EIS, the southern portion the salt ponds, the mudflats, and the sbay, is designated as a Western HemiNetwork Site. This portion of San Diproviding habitat for globally significabilled terns and continentally significaand western snowy plovers, all of whic

as well as continentally significant numoccur in greater numbers outside the Implementation of the preferred alterrestoration of the salt ponds and Otay expansion of and improvements to neand sensitive seabird species) is intenfor habitat restoration, while also maienhancing, those aspects of the existinsupport nesting seabirds and other manalyzed and considered all of the datdiversity and abundance of avian specsalt ponds. The environmental conseqCCP/EIS acknowledges that some chand abundance could occur as a result based on the analysis of the existing d

restoration projects, and our best probelieve that these changes would be o
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significant adverse effects to any aviaconverting the salt ponds to tidal actioabundance and diversity of fish, inverwhich would benefit the entire bay eco

14.3 Based on the data available, it is likely 

favored by colonial seabirds because odisturbance that occurs in this area anunvegetated level nesting areas that pthe surrounding area. We do not agrearea is free of predators; in fact, predpredators is a continuous problem thaintensive refuge management. Although additional studies are needemigratory birds are utilizing the site, 1993/1994 avian survey of the salt ponprovide some insight. A number of splevees for rafting or roosting during hwinds, while other species, such as earspend much or all of their time in the abundant brine invertebrates present that feed on the mudflats during low tsupplementing their diet by feeding ohigh tide. The assertion that birds favsalt marsh habitat cannot be supportecoastal salt marsh habitat that remainprovides essential foraging, roosting, habitat for the many birds that migra
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14.4 Maintaining the status quo would reta

ecosystem support of the existing divespecies currently found within the salimprovements in habitat quality for thcurrently supported on the Refuge woof salt ponds in accordance with Alterstrategies for maintaining and in somof the system that support specific avisupport a diverse and abundant array expanding habitat for a variety of othbay ecosystem. Under current conditprovide little or no habitat value for bRestoration of the salt works would suhabitat value of these areas. The no aopportunity to restore tidal influence the bay, returning some 650 acres of thabitat. Of this, a minimum of 120 acrmudflats, a habitat that has been sevelevels in the Bay and elsewhere in southis habitat has resulted in the decline shorebirds along the Pacific Flyway (H

benefit of restoration would be the abthe managed ponds at elevations apprforaging. Under current conditions, wmaintained to facilitate salt productioTo ensure that the goals and objectivedetailed restoration planning that wouthe CCP is proposed to incorporate mmanagement as essential components 
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Appendix D (CCP final Implementatiin greater detail the next steps in rest

14.5 Comment noted. 
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15.1 Section 3.6.1.3 of the Final CCP/EIS h

relationship between the Refuge and planning efforts, such as the Otay ValWatershed Management Plan, and thcompleted or are currently underway 

15.2 We agree and the Final CCP/EIS has 

hour and access restrictions for this in
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15.3 We agree. These are some of the topi

within future public outreach, environinterpretation programs. 

15.4 The City of San Diego is the lead agen

therefore responsible for the design arecreational facility proposed in the arstaff has been coordinating with RefuEcological Services Program in an effrecreational center in a manner that whabitat goals of the Refuge. 

15.5 The Service is coordinating with the C

issues and hopes that such a partnersfunding opportunities that will allow bindividual public use goals and objecti

15.6 The alignment of the Bayshore Bikew

determined by the City of San Diego aBikeway Working Group. The Servicand other appropriate measures be indesign to minimize disturbance to sen

15.7 Various objectives described within th

these concerns including Objectives 1Response 11.39 above. 

15.8 Refer to Response 11.23 above. 15.9 Refer to the first section of Response 
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15.10 Restoration of the disturbed areas of 

expansion of the tidal prism is describstrategy proposed in the preferred alt

the Sweetwater Marsh Unit. 

15.11 This project is located outside the app

the Refuge and is therefore not addreEcological Services Program of the Seregarding this project. 

15.12 The property sold to the Charles Com

acquisition boundary for the Refuge. would require prior approval from the and various resource agencies. The Sprocess of relocating its facilities from located to the west of the railroad righapproved permits from the California Service and review from the U.S. ArmRegional Water Quality Control Boar

15.13 The preliminary restoration plans inc

to restore a minimum of 120 acres of iwithin the salt ponds, with additional within the Otay River floodplain. In awould be expected to colonize the 230 would be regulated to provide foraginmigratory shorebirds and waterfowl. be further refined during subsequent 

15.14 Refer to Response 11.28 above. 

15.15 Comment noted. 
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15.16 The southern end of Pond 20A is owne

Diego and is located outside the acquiDiego Bay NWR; therefore, the Servithe Port to use this property for a spedecide to restore the pond to coastal wdoes describe how restoration of the Oimplemented to facilitate restoration wPond 20A. 

15.17 Comment noted. 

15.18 The Service has a policy in place to ad

Refuges. Adherence to this policy and the Compatibility Determination for twould limit or avoid adverse effects to mosquito control operations on the Sain Tijuana Estuary, are conducted by Department of Environmental Health Refuge Special Use Permit #11681 04permit spell out the protocols all persconducting vector control activities, animplemented under the supervision of 

15.19 Comment noted. 
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16.1 The Final CCP/EIS has been revised 
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17.1 Comment noted. 17.2 Refer to Response 11.12. 
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17.3 Comment noted. 17.4 You are correct; the purpose of the ac

critical link between the coastal marinBay and the native habitats of the Otapurchasing the Egger-Ghio property Coastal Conservancy, which transferrorder to complete the acquisition and property to the National Wildlife Refuto the City of San Diego. 

17.5 Refer to Response 15.4. 
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17.6 Comment noted. 17.7 Refer to Responses 15.12 and 15.16 ab17.8 Comment noted. 17.9 Refer to Response 11.39 above. 17.10 Refer to Response 15.2 above. 
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18.1 We appreciate your recommendations

among other factors the mission of thSystem and the purposes for which thAlternative D was selected as the predescribed in Appendix D (CCP Implerevised in the Final CCP/EIS, restoraalternative would include monitoring important components of the final res

18.2 We agree that the salt ponds in their 

important resources for a variety of m

18.3 Comment noted. 18.4 Although habitat restoration to rever

wetland habitat loss in San Diego Bay in the development of the San Diego Bprincipals” in the development of the 1.2 of the draft CCP/EIS, are to prepamission of the National Wildlife Refugthe Refuge purposes, is consistent witmanagement, and maintains the bioloenvironmental health of the NWRS. The Service recognizes the existing vavariety of migratory and resident birdinformation regarding current habitat 3.4.4.1 of the draft CCP/EIS. It is the alternative to improve habitat values organisms, including many of the migspecies that currently utilize the forag
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habitats provided within the salt worksustain the resources of the Refuge anthat is not dependant upon the continuoperation, as the continuation of the cseveral factors that are out of the conour best professional judgment and taexperience, knowledge of the resourceecosystem, applicable laws, and best awas selected as the preferred alternatalternative would provide the managevision for the Refuge, a vision that womonitoring and adaptive managementDeveloping a long-term vision for the CCP is just the first step in achieving designed to make major “programmaThe details required to implement therefined once the major policy and direduring subsequent project level planndescribed in the draft CCP/EIS and fof the Final CCP/EIS would be implepermits would be acquired, and final eplanning would be completed. Public be an important component of this “st
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18.5 We do not agree that all of the scienti

associated with project-level analysis need to be completed in order to selecprogrammatic stage of planning. The analysis of all issues at a programmatdetails regarding a specific proposal aanalysis is provided. 

18.6 The 1993/1994 avifauna study provide

available regarding bird abundance anend of San Diego Bay. The findings odetail in Section 3.4.4.1 of the draft CCis information regarding species richnbird guilds within the salt ponds, bird individual ponds, and specific numberspecies of interest, such as phalaropes addition, the impact analysis included 4.4.2.4.1 of the draft CCP/EIS providetypes and number of species observed the effects that restoration could have recognition of the need to obtain additsubsequent project-level planning, the program will be expanded to include a avifauna in south San Diego Bay simil1993/1994. 

18.7 The focus of the preferred alternative 

support the recovery of several federa

array of fish, wildlife, and plants that 

The focus is not on “one species and oobjectives included in Section 2.3.5.2 othe direction for how the Refuge shourepresent the focus of this CCP. The preferred alternative are intended to reproduction of the Refuge’s listed sp
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least tern, light-footed clapper rail, anexpand and enhance nesting habitat fmaintain significant numbers of shoreand invertebrates, and minimize distuand other migratory birds. The strateCCP/EIS for the light-footed clapper supported by the Refuge are consisterecommended in the Service’s recoverthe strategies proposed to support othwith various bird conservation plans. 

18.8 The potential effects to listed species 

D are presented in Section 4.5.2.4 of tto Response 10.21. 

18.9 Monitoring in accordance with the im

MSCP is conducted annually on the Rthe draft CCP/EIS). Specifically, annactivity at the salt works and D Streefederally-listed California least tern aother seabirds, such as the elegant terAnnual surveys are also conducted for Nuttall’s lotus. As stated in Response for this Refuge would have no effect oresponsibilities. 

The analysis of the consequences to Mthe California least tern, western snowthat is provided in the draft CCP/EIS than eight years of California least terground nesting seabird monitoring daknown nesting sites, and our best proproposal to conduct additional baselin
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restoration monitoring is an importanrestoration planning and does not repsurvey work to the future. Further, tunder current conditions is not likely to the question of how individual specrestoration of the salt ponds. Howevenesting sites in southern California coseabirds do not restrict their nesting lsurrounded by water, nor do they alwimmediately adjacent to water. We alboth at this site and at other sites thadiversity and abundance varies from y“abandon” a site either temporarily or various factors that are unrelated to eThis is the type of data that would be preparation of detailed restoration pla

18.10 Successful and marginally successful 

habitat in Southern California have prthose factors, such as tidal inundation

sediment grain size and organic contecontaminants, and availability of nutrinfluence restoration success. The daprovided from previous projects woullevel restoration plans for the Refugethe program-level, the draft CCP/EIS final restoration planning, substrate athe material to be excavated from the completed to determine the suitability marsh restoration. This analysis wougrain size and salinity levels. An inveconducted to characterize the extent aany, within the areas to be excavated.provided on pages 2-89 and 2-90 of the susceptibility of the underlying soils tto its suitability for cordgrass restora
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18.11 The need for routine monitoring and o

internal and external levees following Sections 2.3.2.3 and 2.3.2.4 of the drafwould always be the potential for leveunder current conditions at the salt wdesign would take into consideration ttrigger such a failure and incorporateminimize such an occurrence. An exapage 2-80 of the draft CCP/EIS, wherproposed along the southeastern edge the internal and external levee system overtopping during a major flood evenof a levee within the brine managemetemporary impacts to resources withihowever, based on the hydrodynamic modeling conducted by Philip Williampotential effects of pond breaching on to Sections 4.2.2.3.3 and 4.2.2.4.3 of ththat any significant adverse impacts tresult from such a levee failure. 

18.12 Chapter 4 of the draft CCP/EIS inclu

environmental consequences. This anto the physical environment, biologicaand the social and economic environmdefined in Chapter 2 of the draft CCPcomparison of the alternatives by issu

18.13 Cordgrass habitat within the South S

limited due to the extent of habitat mothis area over the last 100 years. Currails occupy the habitat within the Otathe salt works. Based on experience eadditional suitable rail habitat were to 
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number of clapper rails would increascordgrass-dominated salt marsh habitin the recovery of this species is discuClapper Rail Recovery Plan (USFWS 

of the recovery plan is to increase the by preserving, restoring, and/or creatsuitably managed wetland habitat conmarsh vegetation, and the recovery plamount of suitable habitat in the vicinan effort to increase rail numbers in t

18.14 Page 2-68 of the draft CCP/EIS state

characteristics, grain size, and other fmaterial excavated from the Otay Rivwetland habitat] could be exported froareas of the site proposed for upland rthe levee that would be relocated to thin Pond 20A; and/or used to restore ansalt ponds . . .” Tables 4-3 and 4-4 in testimated truck trips that would occuall potential earthmoving scenarios thimplementation of Alternatives C and Sections 4.7.2.2.3 and 4.7.2.2.4 include trips per day for implementing each apotential air quality impacts as they rexcavation, worker commute trips, anSections 4.2.2.3.4 and 4.2.2.4.4 and ApCCP/EIS. The potential effects of nowell as recommended mitigation measSections 4.2.2.3.5 and 4.2.2.4.5 of the d

18.15 The geotechnical engineering investig

River floodplain by GEOCON in 1986 

and geotechnical constraints on the prrecommendations for mitigating the erecommendations were intended to be 
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development on the site, as well as an enhancement project proposed for a rrecommendations were reviewed for arestoration project and addressed in t

the conclusions in the report, it would conditions related to geotechnical issuproposed restoration project through construction. The specific mitigation construction techniques for the propoRiver floodplain would be determined additional site analysis that would be restoration planning. As stated in the “A qualified geologist would review thissues prior to project implementation
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18.16 Dewatering and soil drying prior to co

construction practices in floodplains, wwithin the Otay River floodplain. Placcompacting of fill material would be uqualified soils engineer. No modeling these tasks; however, soil testing woucomplete final restoration plans. Thewould be addressed during step-down consequences of implementing these taddressed in the draft CCP/EIS. 

18.17 Liquefaction is a process that occurs d

shaking associated with an earthquak

The hazards caused by liquefaction arstructural damage to buildings and inundeveloped land. Ground subsidence restoration areas; however, in this casinvestigations that have been conductidentified a significant concern related the erosion hazard of the soils present described as slight (USDA 1973). The significant storm event are described Appendix I of the draft CCP/EIS. Admodeling would be conducted during restoration plans. 

18.18 Impacts to the surrounding neighborh

addressed in Sections 4.7.2.2.3 and 4.7Imported soil could come from the adj(which would generate trips internal tadverse effects to the surrounding netransported onto the site via Main Str

route currently used to transport salt 

18.19 We disagree with the statement that s

information is not provided within the 
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program-level analysis of potential im3.3.3.2 of the draft CCP/EIS, several investigations have been conducted wUnit over the years and these investiginformation regarding surface and subas provide recommendations relative aspects of future site development. A be conducted during project-level rest
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18.20 The potential for water quality impact

restoration within the Otay River floo28 of the draft CCP/EIS. Measures, sactivity during the rainy season and imManagement Practices (BMPs), that wor minimize impacts to below a level o

discussed. The specific BMPs to be imdetermined during detailed restoratiowith the Regional Water Quality Cont401 Water Quality Certification proceClean Water Act). Page 4-28 of the drthe potential presence of contaminatesite and states that if contamination is removal of the contaminants would be association with site excavation. 

The proposed restoration is intended patterns in a manner that would not instagnation; no significant alteration of patterns is proposed. Page 4-28 of the measures necessary to ensure proper circulation would be incorporated into long residence time in the south bay i3.3.6.2 (San Diego Bay) of the draft CThe implication that cooling water disPower Plant has a significant effect on bay is incorrect. The results of modelenvironmental factors that influence eSouth Bay revealed that the natural texceeds the relatively minor influence Plant has on circulation in the south b2000). Therefore, should the power pleffects to tidal circulation within the b
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18.21 We agree. The need to conduct additi

type and extent of contaminants presefloodplain prior to restoration is cleardraft CCP/EIS. Appendix D (CCP Imexpanded to delineate the types of stuwould be obtained prior to completing the Otay River floodplain and other p

18.22 Restoration of the salt ponds is propo

federally listed species, including the tern and light-footed clapper rail and plover. Additionally, Alternative D prsome cases enhance, those aspects of that support nesting seabirds and othService agrees that the salt ponds provariety of avian species, however, undfor benthic invertebrates, vegetation, limited to non-existent in this closed squality for all organisms supported wService proposes to restore the salt powould take into consideration the resumonitoring and adaptive management the project design. As stated in the draft CCP/EIS, dischinto the bay would not exceed 5 ppt abThe proposed discharge would not reseffects to water quality within the bay
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18.23 The adverse effects of restoration on t

that utilize the salt ponds, as well as tpredation, are presented in Sections 4draft CCP/EIS. In addition, a predat(Appendix M) accompanies the CCP aadverse effects of predation on listed Competition for foraging, nesting, and roosting areas by shorebirds and seabthe number of avian predators increasrestoration. Further, the preferred aenhance and expand suitable nesting birds and improve foraging opportuni

18.24 The CCP does assume that intertidal 

and cordgrass-dominated salt marsh, species and wildlife in general than do Although monitoring shows that some good foraging habitat for certain specprovide adequate habitat for fish, bay vegetation, each of which represents athe various species of shorebirds, watthat migratory through or reside in thare portions of the salt pond complex habitat value for birds or other wildlifwetlands has been identified as a recolisted species supported by the Refugtern, light-footed clapper rail, and westep-down planning, the mix of vegetawithin the restored ponds would be anthe intent of ensuring that the objectilisted species, migratory birds, coloniin general will be achieved. 
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18.25 Refer to Response 10.22. The statem

designated as a Globally Important Baccurate; the designation applies to thUnit and includes the shallow subtidahabitats in the bay, as well as the salt 

18.26 The brine management ponds are pro

specific suite of avian species that rely currently available at the salt works twater management plan, as described draft CCP/EIS, would be prepared in completion of detailed restoration plamaintenance, and monitoring activitieto maintain the water management syAlternative D. Refer to Response 11.history requirements of brine invertea discussion of the potential for levee 

18.27 Sections 4.3.2.3.1 and 4.3.2.4.1 of the d

discussion of the potential impacts to occur as a result of restoring tidal inflService has been involved in various cthe past few decades and has significaWe believe that the program-level anaof restoration is adequate to enable us project development; preparation of d
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18.28 The issue of levee maintenance is add

draft CCP/EIS (Section 4.2.2.3.2) also tidal action could affect the internal pstudied in greater detail during step-dWe do not anticipate the need for maifollowing breaching due to the limited movement and accumulation in San Dcontributions to the bay are limited dudrainages that enter the bay, the fact are controlled by dams, and the genervelocities experienced downstream frGraham 1977). Additionally, because series of ponds located just to the east of the sediment generated to the west reservoirs never enters the bay. 

18.29 The Port acquired the land and equip

1999 with the understanding that salt eventually be phased out. Sections 3.6revised in the Final CCP/EIS to descrcontributions of annual sales tax and lthat rent could also be paid to the Serproduction continue beyond 2009. 

18.30 Based on our review of the North Am

(NAFTA), we disagree that NAFTA iobligations on the FWS. As required discloses the economic consequences 

salt production in the south bay. 
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18.31 As described on page 4-123 of the dra

allocates payments to the counties unSharing Act to partially compensate fThe fact that there is a commercial opgenerates revenue for local and state allocated through the Refuge Revenusituation that will provide added benebut does not result in the need for mitrevenue cease to be available. 

18.32 No habitat for least terns and snowy p

of implementing Alternative D. In facAlternative D are intended to increasforaging habitat for these species. Re

18.33 Cost is not one of the factors consider

management alternatives for a CCP. considered are described in Response selected as the proposed action, the pimplement the various strategies woufunding sources are described in Appe

18.34 Refer to Response 18.33. 

18.35 Water quality impacts have been eval

the Service has coordinated with the RBoard, NOAA Fisheries, and CalifornGame regarding our preliminary modbreaching. The impact analysis for thSection 4.2.2.3.3 and 4.2.2.4.3 of the dranalysis would be implemented in assstep-down restoration plans and the pdischarge permits from the Regional 
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18.36 In Section 4.2 (Effects to the Physical 

CCP/EIS, there are detailed descriptproposed to implement restoration wiand the salt ponds could affect topogrand soils, agricultural resources, hydrquality, and noise. Sections 4.3 and 4.grading would affect habitat and vegeand fisheries, respectively. Section 4.to listed species. Section 4.6 describegrading on cultural resources and Seceffects to the social and economic envtraffic circulation (truck traffic), publiodors. Refer also to Response 18.14 a

18.37 The information known about potenti

Otay River floodplain is presented in draft CCP/EIS and the need to conducharacterize the type and extent of coand to remove or otherwise remediate or groundwater prior to or in associatis stated on page 4-28 of the draft CC

18.38 The purpose of the brine feasibility as

would be feasible to maintain a brine odraft CCP/EIS. The assessment consto provide suitable habitat for brine inbrine back to salinity levels no higher levels prior to discharge into the bay. is feasible to achieve these conditions. conducted during detailed restoration most feasible method, in terms of cost to achieve the objectives of the managaction. At the program level, the anainto the bay would not exceed 5 ppt abon our current analysis, no significant 
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environment, or to bay water quality, conditions. Additional analysis would with subsequent step-down restoratio

18.39 The use of recent studies is appropria

studies provide a regional perspective relevant to the existing water quality of the Refuge that includes the open wpreviously, the information provided ipotential impacts of the various manaprogram-level. Additional analysis woappropriate by the Service, the RegioBoard, and others during detailed res

18.40 Air quality issues are discussed in Sec

CCP/EIS and the current national anstandards are provided in Appendix Gincluding those for lead, that must be are stated on page 3-21. Sections 4.2.2the air quality calculations were conduwere made, and the results of the calcnot analyzed as leaded gasoline is no llead emissions from gasoline-powered eliminated. Diesel fuel does not conta

diesel-powered construction vehicles iair quality impacts are addressed in th

18.41 Comment noted. 

18.42 The Service recognizes the contributi

operation to Refuge resources and agmanagement direction, implementatiowill achieve the Refuge purposes, goa

18.43 Comment noted. A phased approach 

revised Appendix D of the Final CCP/
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18.44 The suggestions for restoration phasi

restoration should be implemented in and adaptive management, as address

18.45 Several meetings were held to discuss 

aspects of the project. 
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18.46 Submission of the attachment is ackno

18.47 Refer to Response 18.44 above. 
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18.48 Responses to these verbal comments 

39.12 – 39.21. 
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19.1 The potential effects to ground nestin

habitat as a result of implementing AlSections 4.4.2.3.1 and 4.4.2.4.1 of the dthe draft CCP/EIS, Alternative D is inesting and shorebird foraging habitathat implementation of Alternative D effects on seabird or shorebird habita

19.2 The benefits to birds that are provide

addressed in Sections 3.4.1.3 and 3.4.4Section 4.4 of the draft CCP/EIS provpotential effects, both adverse and beinvertebrates, habitat quality, and bir

result from converting some or all of thabitat. The need for additional studirestoration plans is acknowledged in tdescribed in detailed in revised Appen

19.3 A phased approach to restoration of t

Section 2.3.2.4 and Appendix D of the described in revised Appendix D of thIdeally, restoration of the Otay River complex would occur as one comprehereduce costs and allow grading to be bbecause the timing of restoration is deof funding, such a comprehensive appFortunately, restoration of one of thethe restoration of the other. Monitorican be incorporated into each of the pdesign. 
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Finally, the lessons learned during thfloodplain would not be fully transferafor the salt pond complex. Thereforeassuming that restoration of the Otay logical first phase of restoration withi

19.4 The Service has reviewed the analysis 

the draft CCP/EIS in light of the varithe public review and comment periodcorrections have been made in the Finspecific concerns and/or to clarify inteThe intent of the statement in the comconsideration of other locations for pomarsh habitat is unclear. The CCP re

restoration in various locations througthat are not proposed for coastal wetleither native upland habitat, or in the D Street Fill, represent an area imporThere are no other areas within the Rsalt marsh restoration. The purpose omanagement plan for the Refuge. We restoration proposals for properties lo

boundary. 
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20.1 We believe that there is adequate info

disclose and evaluate, at the programenvironmental consequences of convesalt ponds to a combination of coastal saline ponds to provide habitat for showaterfowl, as described in the CCP. Tprovide a combination of subtidal, intehabitat to optimize support for a diverother wildlife resources, with specific habitat to be determined during the nplanning. We agree that additional badata would benefit the detailed restorSan Diego Bay Unit. Assuming the pas the proposed action, we plan to fullongoing salt pond restoration studies Conservation Science and others for Selsewhere in developing specific projethe salt ponds in San Diego Bay. 
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20.2 Restoration of the Otay River floodpla

minimum of 60 acres of disturbed uplawetland habitat, providing significant habitat for shorebirds. In addition, rewould provide a minimum of 125 acres and approximately 275 acres of ponds accommodate shorebird foraging durirelatively small size of the San Diego (approximately 1,000 acres), the proxiareas immediately to the north of the habitat that would be provided adjaceareas, and the existing depths of the sdo not believe that the predicted declithe San Francisco Bay salt pond compeither the pre- or post-restoration confact, we believe that shorebirds would changes in habitat type within this Re

20.3 Information regarding current use of 

by phalaropes is provided in Section 3and the environmental consequences species are addressed in Sections 4.4.2

20.4 The significant benefit to snowy plove

Alternatives C and D should have addfor plover chicks. Under both of these the existing levees would be made to iexisting and new foraging areas (interponds). The Summary of Potential Ef“Expanded nesting and improved chic

provide significant benefits.” Currentsuccess is poor at the salt works and unesting by adult pairs is very limited. salt ponds used by snowy plovers in Sdifferent from the salt ponds in San D
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dry salt pan and unvegetated sand flaDiego Bay salt ponds. Additionally, thspace limiting to snowy plovers due to 

of other seabirds and shorebirds that intent of the proposals in Alternatives additional nesting habitat within the senhanced access from nesting areas to 

the actions included in the preferred aplover fledgling success would result ispecies. Section 4.5.2.4 of the Final Cprovide a more detailed discussion of would be managed in relation to snow

20.5 Monitoring of the physical and biologi

following restoration is addressed for Section 2.3.2.4 of the draft CCP/EIS. and post-restoration monitoring is pre(CCP Implementation) of the Final C

20.6 Refer to Responses 11.7 and 20.1. 
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21.1 The CCP, once approved, will provide 

should be managed over the next fiftevision for achieving the Refuge purpoCCP/EIS, the EIS is intended to addrprogram level. However, where adeqabout a proposed action, such as predis intended to provide project level revproposals included in the preferred alMarsh and South San Diego Bay Unitdown” planning to more fully develop step-down planning process includes prequires completion of appropriate endocuments. As stated in the draft, “thfor each restoration proposal reflects available for the specific restoration oon page 2-87 of the draft CCP/EIS th

for step-down planning prior to impleproposals including within the preferrclarify the purpose and intent of the CSection 1.3, and Appendix D (CCP Imrevised in the Final CCP/EIS. In addexpanded to describe how restoration a phased approach that incorporates mmanagement. Revised Appendix D althat would be implemented prior to apfor the Refuge. These steps include ttechnical studies and the gathering of 
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21.2 To achieve the CCP objectives related 

proposals in Alternative C or Alternatwork closely with the operator of the continued production of salt within thD of the Final CCP/EIS has been revrestoration phasing plan that could be Alternative D. With respect to the need for additionaimplementing the proposal to manage ponds, the draft CCP/EIS (Alternativstates that additional modeling and andevelopment of a water management address water management in the absanalysis would be coordinated with thagencies. Once the design is completewater management plan is available, tthe necessary permits and approvals w

21.3 During our evaluation of alternatives, 

benefits that the salt ponds currently bird species, as well as the benefits thprovide not only to birds, but also to fother wildlife, and plants. We believe includes a variety of components to mof the bird species currently supporteassociated levees, while also providing organisms that rely on the natural habfull accounting of the consequences to converting the salt ponds to intertidal presented in Section 4.3, 4.4, and 4.5 o

21.4 The need to conduct additional baselin

prior to completion of a detailed restoAppendix D (CCP Implementation) of history requirements of brine shrimp 
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documented in the literature. Any adrequired will be compiled during the drestoration plans. 

21.5 All available information regarding bi

habitats within the Refuge is included and 4.4.2.4.1 of the draft CCP/EIS. Aacquired as a result of subsequent stuworks in accordance with revised App

21.6 Refer to Response 21.1 above. 21.7 The Service believes that all of the alt

CCP/EIS are consistent with the goalpurposes for which each Refuge Unit the draft CCP/EIS, some alternatives 

benefits for listed species (the primarIt is the intent of the Service to implewill improve habitat conditions for listproviding habitat to support the other species found on the Refuge. 

21.8 Comments noted. 
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21.9 Refer to Responses 6.2, 10.20, and 21.21.10 Comments noted. 

21.11 Comment noted. 
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21.12 Although the Port currently funds en

and predator management on the D S

draft CCP/EIS is not incorrect; monitmanagement are primary managemenSweetwater Marsh Unit. Additional dparticipation in predator managemen(Predator Management Plan) of the d

21.13 This paragraph has been revised in th

discussion of limited guided tours arouses noted in the comment do not occuboundary and are not uses managed binformation about existing public uses Section 2.3.2.1 (Public Use Program) 

21.14 All aspects of the draft CCP/EIS, incl

objectives, are considered draft propoapproved. The public comment period the public to address any and all propThe Refuge Vision was prepared to adBay NWR, which includes the SweetwDiego Bay Units. The reference to exsalt marsh applies to both Refuge Unthe amount of cordgrass to be restorecordgrass would be provided. There arestoration within the Otay River flooponds. In accordance with the Refuge federally listed endangered and threavision includes restoring habitat to sufooted clapper rail. The Refuge purpoconditions for the light-footed clapper to the public on numerous occasions, iEnvironmental Assessment prepared 

South San Diego Bay Unit (USFWS 1
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21.15 You are correct; the statement should 

remaining area of intertidal mudflat hstatement is not essential to the discuFinal CCP/EIS. 

21.16 The habitat value of the salt ponds do

area now occupied by the ponds historsubtidal, intertidal mudflat, and salt mponds to an array of bird species is addocument. 

21.17 The benefits to birds that are provide

addressed in detail in Sections 3.4.1.3 CCP/EIS, as well as noted in the paraparagraph 3 on page 1-33. We do not provide higher value habitat for migrahabitats of intertidal mudflat and coas

21.18 This addition has been made to the tex
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21.19 The Service does not have the authori

the United States Congress has that aComplex can however propose specifiRefuge Operating Needs System (ROManagement System (MMS). Appenthe Final CCP/EIS describes and prioproposed in the CCP for the preferred noted that once the National City Marmanagement activities on the D Streethe Port for the life of the marina. 

21.20 Comment noted. 21.21 As a program-level EIS, the level of a

information available. Page 2-21 of thdetails of how and when these proposwould be further defined in a future sManagement Plan). According to Serdown" the direction provided in a CCP specific guidance for the implementatstrategies. Preparation of HMPs is apublic and other interested parties. 

21.22 Based on the nest site data for the yea

initial data for 2006), the majority of tconcentrated near the center of the D plovers have not nested on this site sinobserved. The habitat enhancement pin Alternatives B and C are intended of this portion of the Fill for these two on the data, the existing conditions in enhancement are not providing favoraterns or snowy plovers (refer to Figur
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Enhancement activities would involve access to the adjacent tidal areas, enh

where appropriate, and installation of disturbance and mammalian predatio

proposed to support the plan objectivleast terns and reestablishing snowy p

21.23 Under Alternative C, the Refuge’s 55

include 33 acres of upland managed foand western snowy plovers and 13 acrhabitat. An additional eight acres of u

provide access to the nesting site and species. Portions of this eight-acre arnesting by various ground nesting birwould support about 45 acres of potenleast 33 acres provided on the Refuge provided on the adjacent Port propertseason, less than ten acres of Refuge being used by least terns for nesting anested at this site since 2000. The amthese species at the D Street Fill unde

is not considered a limiting factor; hownesting habitat, the distance from and foraging areas, current predation leveand other human-related disturbancelimiting the use of this area by terns apreferred alternative is to improve thnesting in an effort to increase the nuproductivity. Tidal restoration would adjacent nesting area by providing approximity to nesting and establishing for snowy plover chicks and adults froA minimum of 33 acres of new nesting within the salt pond complex, which wany loss of 13 acres of potential nestin
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21.24 Refer to Response 21.23 above. 

21.25 Comment noted. 
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21.26 The Sweetwater Marsh Unit objective 

revised to address productivity rather numbers of nesting pairs. The revised year average of at least one fledged chD Street Fill. The objective for westerrevised to state that the proposed enh

fledged chick per male snowy plover awith at least 20 nests established annuimplementing the proposed enhancemaddressed in Response 21.19 above. 

21.27 The proposal to increase foraging hab

in the No Action Alternative because conditions of the biological opinion issexchange the Naval Training Center lsalt works site. (This exchange resultRefuge.) This action must be implemalternative is selected. Specifically, thhabitat enhancement, including expanand enhancement of nesting substrate minimize incidental take of the Califorenhancement began several years agoincreased foraging habitat still to be iterms and conditions of the biological Section 1.6.3 of the Final CCP/EIS. Apreparation of a step-down restoratiobe conducted prior to implementing aportion of Pond 28 or 29 to shallow suAs stated in Response 21.1, the draft document intended to analyze propos

except in those cases where sufficient provide project-specific analysis. All will be evaluated in accordance with Naccordance with the Service’s CCP Po
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21.28 The discussion of the various scenario

salt works was included under the No would be misleading to imply that the over the fate of the salt works. Even were to be adopted as the proposed prthat the salt works would cease to ope2.3.2.1 of the draft CCP/EIS. We do himplementing any actions that would within the salt ponds, further analysis necessary. We also agree that a dischif any such actions resulted in the disc

21.29 The discussion of public access on pag

access onto the Refuge. The discussioon page 2-52 of the draft CCP/EIS unPhotography. That discussion has beaccess from the Biological Study Area

21.30 Pages 2-57 through 2-62 of the draft C

discussion of how the nesting sites wothis section describes the magnitude orequired to create nesting areas rang8.0 acres in size, as well as the anticiprecommended slope gradients, and suAn analysis of the environmental cons

nesting areas is provided in Sections 44.6.2.3, 4.7.1.2.2, 4.7.2.2.2, 4.7.3.2.2, 4.7the draft CCP/EIS. 
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21.31 The text has been revised to state tha

in a manner that would support snowy Alternatives B and C, while under Altnumber of ponds or portions of ponds nesting habitat for plovers. Because Athat salt production would continue, Pfeasible location for controlling water season. The intent of this proposal unlower the water level in Pond 20 durinexposed areas for plover nesting, whilwhich still contain shallow areas of brto support brine invertebrates, providplovers during the nesting season. Thwould have no relevance since nesting provided within the same pond. Amerstilts, which already nest in this pond appear to be adversely affected by preproximity of the access road, utility poAdditionally, much of the pond is locainfrastructure, therefore, these facilitthe quality of potential nesting habitaThe benefits of managing water levels other avian species would be evaluateduring annual monitoring. If this strathen we could simply cease to manage 

21.32 Implementation of patrols within the 

enforcement personnel; however, this implemented if funds are provided to boat and other ancillary equipment. R

Implementation) identifies the need fopatrol of Refuge waters to reduce wildsignage, fencing, and a monofilament addressed in Appendix D. 
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21.33 Analysis of the restoration options for 

into consideration the results of prelim(described in Section 4.2.2.3.3 of the dPhilip Williams and Associates for eactopographic data for the site that was the preliminary engineering work conestimate cut and fill volumes for each results of previous geotechnical surveRefer also to Response 21.1. 

21.34 We appreciate these suggests and rec

be involved in the next step of restorarestoration plans for this area would b
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21.35 Restoration of the primary ponds wou

habitat values in the salt works; howeintroduction of tidal influence into thehabitat and associated tidal channels wadverse effect as it relates to habitat qabundance or diversity. Refer also to and 19.1. Information regarding the anticipated potential need for bridges and/or levelevee monitoring and maintenance reqpages 2-79 through 2-80 of the draft Cthis preliminary information is providassessment at the program-level; thesbe evaluated and likely refined during restoration planning. No dredging of 

proposed and pond breaching is not asignificant adverse effects as a result tidal channels through the existing muhowever be further analyzed during schanges to the existing mudflats that than offset by the restoration of similaThis alternative includes provisions to habitat within the salt pond complex btherefore, any reduction in nesting habreaching or levee protection would bprovide these new nesting areas. 

21.36 Comment noted. Refer also to Respo

21.37 The need to temporarily or permanen

path that extends down Saturn Boulevduring detailed restoration planning f
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The right-of-way to be used to extend Main Street to 13th Street is not locate

therefore, the construction of this proCCP/EIS. The City of San Diego, whproject, is currently preparing an Envaddress this project. 

21.38 Refer to Responses 14.4, 18.7, and 21.

21.39 The water management component of 

the program level in this document. Adraft CCP/EIS, the proposed brine mmodeled to assess the feasibility of malevels in the ponds and the feasibility salinity levels to facilitate discharge in results indicated that such a system cobjectives. This discussion goes on to and analysis would be conducted as paSimilarly, on page 2-93, the discussion levels in other ponds includes the propmanagement plan in association with engineering and restoration plans. Thwould address among other factors thof the system and initial and long-term 

21.40 As indicated in Section 5.2.1.7 of the d

coordinating with the Regional Water issue of levee breaching. All of the datopic has been shared with Regional BCalifornia Department of Fish and Gapropose to continue to work with thesin restoration planning, when additionand data collected to address the poteon bay resources. Refer also to Resp
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21.41 Implementation of Alternative D wou

least 60 acres of wetland habitat withiThis component of the restoration plaloss of existing wetland habitat within providing new nesting areas. Restoridoes not result in the loss of wetlandsfor wetland loss is required for this ac

21.42 The discussion of the three scenarios 

CCP/EIS, and a discussion of how salphased under Scenario 2 has been addCCP/EIS. 

21.43 We agree and the issue of potential di

a result of opening an interpretive traas follows in Section 4.4.2.4 of the drafdisturbance impacts are minimal, use periodically during fall and spring migare found to be higher than anticipateregulated in a manner that would redacceptable level. Various approaches during fall and spring migration, closionly permitting trail use on weekendsbe determined based on the level of di
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21.44 The rationale statements provided for 

Chapter 2 relate to the overall intent presented in bold italics following th

than the measured objective describestatement. These rationale statementabout historic and existing conditionsplan recommendation, recommendatioand Refuge goals and purposes. We dstatements favor one alternative over would meet to some degree the intent 

21.45 Comment noted. Refer to Responses 

21.46 This objective for least terns on the S

been revised to address productivity r

revised objective is to maintain a 15 yfledged chick per nest within the salt 

21.47 Reproductive success of least terns is 

availability of suitable undisturbed newaters with adequate supplies of apprThe least tern will typically travel fartwhen feeding itself, but when feeding tern must capture very small fish and shallows (Massey 1988, Cimberg and 

reintroduction of tidal influence into pprovide additional habitat for fish, parproximity to the salt pond levees. AltPonds 10 and 11 when bay water is intthe salt making process, the fish densthose that would occur under tidal conthat the provision of new foraging areproximity to existing and future least salt pond complex is necessary in ordetern reproductive success at this site. 
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21.48 This objective for snowy plovers has b

productivity and numbers of nests. Wobjective involving 20 snowy plover nethe various strategies included within improving nesting and foraging habitacomplex) is to encourage new snowy peventually result in increased productNWR. 

21.49 With the exception of some avifauna, 

that feed on brine invertebrates while shorebirds that forage on brine invertonly do so along the edges of the pondthe ponds that are shallow enough to present, the water levels in the ponds commercial salt production, not avian portions of the 600 or so acres of pondfavorable for brine invertebrate produforaging by many of the species of mi

south bay. Under the preferred alterto a portion of the pond system would opportunities for many shorebirds wittides. A minimum of 120 acres of salt intertidal mudflat, with additional tidachannels that would be present in areadditional 275 acres of foraging habitamanaged ponds and the water levels wcontrolled to facilitate avian foraging. increase shorebird foraging opportunavailable within the salt ponds. Durinrestoration plans for this area, the Seexperts who can assist in designing a that would maximize such foraging opongoing studies, such as one in the Mohow salt ponds can be managed to supfor migratory birds, could help us ach
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21.50 Refer to Response 21.49. 

21.51 The information that is available rega

types present within the ponds is provCCP/EIS and the need to sample and within ponds is provided on page 3-24sediments would be conducted prior trestoration plans. Appendix D (CCP revised to more clearly present the tywould be completed during subsequen

21.52 The graphic has been revised in the F

21.53 The text in the Final CCP/EIS has be

describe the properties that are subjeproperties, which are illustrated in Fi(Hydrodynamic Modeling Analysis), ithe south of the Refuge, the parking lPark, and areas in the vicinity of Palm 

such flood event, which affected homeof Palm Avenue and 19th Street, occur

San Diego 1988). With respect to leveconducted by Rick Engineering (1987Associates, Ltd. (2003) both indicate t

subject to overtopping during a 20-yesuch events have occurred in recent ti
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21.54 The intent here was to state that the s

mudflat habitat included within the bo

eliminated upon the creation of the porevised to clarify the intent. 

21.55 The paragraph has been revised in th

the Refuge, which includes both natursystem of salt ponds, protects habitatbirds of the Pacific Flyway. The statebeen designated as a Western HemispNetwork (WHSRN) site and a Globalentirely accurate. It is more appropr

south end of San Diego Bay is designahabitats included in this WHSRN sitewebpage (http://www.manomet.org/Wconsist of the open waters of the bay, 

marsh, salt ponds, dikes, sub-tidal habriver/riparian habitats. The Globally designation also applies to the entire SThe site is recognized for providing hanumbers of nesting gull-billed terns anumbers of Caspian Terns and westerdo nest on the salt pond levees, as welnumbers of surf scoters, which occur isalt ponds than within them (Stadtlan

References to these designations have the Final CCP/EIS. 

21.56 We do not agree that restoring the sa

Alternative D is contrary to the South

Conservation Plan (Hickey et al. 2003

conservation actions presented in the presented in Section 3.4.1.3 of the dra
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• Increase the extent and habitat 

• Increase the amount and quality 

salt marshes by: 

o incorporating shorebird h

marsh restorations and crexposed mudflat during loforaging and breeding, an

o increasing tidal circulation 

to enhance invertebrate pforaging areas; and 

• Maintain sufficient amount of hi

support breeding shorebirds, inPlover, as well as migrating and 

The priority conservation action for saamount of salt ponds at San Diego Bafeeding, and roosting shorebirds, incluspecifically for nesting snowy ploversPlover Draft Recovery Plan. Alternatactions (providing a minimum of 125 asalt marsh habitat areas that include sand managing 275 acres of salt ponds Within these managed ponds, about 4support brine invertebrates and one omaintained to support snowy plover n

21.57 Brandt’s cormorant has been added to 

Diego Bay in Appendix C in the Final (2004), this species, although common seen in the southern end of the bay. Oduring winter months range from zer
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21.58 As stated in Response 21.56, Alternat

range of habitats to support a variety listed species that each has its own haShorebird Plan states that about two-wetlands that existed along the Califocentury have been degraded or destroactivities. It is generally accepted thaadverse effect on the abundance and dregion (Hickey et al. 2003). These cha

negatively affected other waterbird pproposals included in the preferred aladdress the habitat needs of the south 

and in particular, the habitat needs of the Refuge. To do this, it is necessarshorebirds, like the western snowy plspecies, such as the light-footed clapptern. This direction is consistent with Refuge was established. See also Res

21.59 Refer to Response 6.2. 21.60 We agree. A survey of the diversity a

in the salt ponds and adjacent mudflacompleted in association with the prepplans. Additionally, a study of bird usconducted to assist us in designing the 

the restoration plan. The proposal to studies is addressed in revised Appen

21.61 This discussion has been revised in th

the presence of these species on the D 

is already presented in Table 3-12, Taand 3.4.6.1 of the draft CCP/EIS. 
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21.62 The section that follows this paragrap

the importance of the salt ponds to miresponse to this comment, additional t

paragraph in the Final CCP/EIS. 

21.63 This statement is based on observatio

past five years, as well as observationcomprehensive surveys conducted in and Konecny 1994). Refer also to Re
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21.64 The sentence has been changed in the 

importance of the wetlands in South S

21.65 The significance of the seabird nesting 

is reflected in the proposed Refuge goGoal 3 and Objective 3.1 (page 1-25 of respect to the dates of colonization, Seof the draft CCP/EIS includes the datrecorded for each species described. provided, and where this location is onlocations in the United Stated for a paThe discussion of unvegetated upland significance of the levees as nesting hshorebirds. A summary of the importseabird nesting habitat has been addeContext) in the Final CCP/EIS. 

21.66 Refer to Response 10.3. 

21.67 Information regarding the diversity a

within South San Diego Bay is provid3.4.7.1 of the draft CCP/EIS. As indicPacific Flyway Project did not separafrom those on the salt ponds. 

21.68 Shorebird use of the salt ponds and le

addressed in Section 3.4.4.1 of the dra

21.69 The large numbers of phalaropes that 

addressed on page 3-57 of the draft C
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21.70 According to Unitt (2004), red knots a

mudflats of San Diego and Mission Banear the Sweetwater River mouth espRed knots were also observed in relatsouth of Emory Cove and in Ponds 10 Pond 28 (a crystallizing pond) during the salt works. They were also observthroughout much of the salt works anthe north. Terp (1998), while studying 

the habitat use patterns of red knots aobserved that during low tide red knohigher on the mudflats to the north of within the salt ponds. Knots were obshigh tide, using the secondary ponds dat densities of almost 200 birds/hectarfour birds/hectare) in the early fall for 

of knots in Cadiz Bay by Masero (2002

indicate that only a small percentage shrimp at high tide. Based on the curin San Diego Bay and information knohabits, restoration of the salt ponds as is not expected to adversely affect the population. 

21.71 A discussion of the brine invertebrate

is provided on pages 3-50 and 3-51 of tdocument also acknowledges the need determine what other foraging opportponds. The need for such a survey ha(CCP Implementation) in the Final C
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21.72 The draft CCP/EIS does address the 

birds. Refer also to Responses 6.2 an

21.73 Refer to Responses 11.24 and 21.49. 

21.74 The salt works replaced the native ha

area, and although it provides nestingopportunities for a variety of avian spthis artificial habitat provides better hof the species present in this area than natural intertidal environment. Sectiohas been revised to clarify the discusssalt ponds, and salt marsh habitat for comes from the discussions included iShorebird Conservation Plan (Hickey 

Shorebird Plan states that tidal flat is habitat within the coastal embaymentstates that shorebirds use salt marsh flats, but the larger non-vegetated chaforaging habitat by the same species tnote, the Plan states that some shorebleast sandpiper, and long-billed dowitand nocturnal roost sites “possibly to predators” (Hickey et al. 2003). With 

states that the ponds and levees provifor a wide variety of non marsh-depenprovide important foraging areas for of wetland dependent avian species. 

21.75 The draft CCP/EIS addresses the nee

conducted in association with the prepand restoration plans. A list of the stuVolume 1 has been compiled and addeImplementation) in the Final CCP/EI
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21.76 The bird survey data collected in 1999

the data collected during the 1993/199collected using the same protocols as Service will be initiating a new year-lothat will enable us to compare the rescurrent conditions in the ponds and on information will provide baseline data restoration planning for the salt pond

21.77 As noted in the comment, the populat

has declined in the county since the 19

speculates that this decline is most likspecies’ winter distribution rather thanumbers of the species. Over the past individuals of common goldeneye have San Diego Bay. Although an uncommworldwide population of common gold(Eadie et al. 1995) and despite its inclManagement Concern developed by tProgram, the common goldeneye is cuabove long-term averages or managemDuring the 1993 – 1994 avian study of was observed both within the ponds athe north of the ponds. Because the dconsists largely of mollusks and crustattributed to insects (Eadie et al. 1995is solely depended upon the limited reto satisfy its foraging requirements. Rintertidal habitat is therefore not expesignificant adverse effects to common 

21.78 The Final CCP/EIS has been revised 

information about the potential effectPond 28 or 29 to provide additional for

21.79 Refer to Response 10.11. 
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21.80 Refer to Response 21.87 above. 

21.81 A graphic indicating known locations 

Street Fill over the past few years haCCP/EIS. In addition, Section 4.5.1.3 been revised to indicate that plover anoccurred in the distant past on the porproposed for restoration, but have not No maps indicating the presence of nehave been located, nor were any maps documentation prepared for the originthat ultimately resulted in including a within the National Wildlife Refuge S

21.82 To restore more than 13 acres to inter

Fill would require a revision to the CCand evaluation under NEPA. The porlocated within the Refuge boundary c23 acres are permanently committed tpreviously approved mitigation agreebeen committed to fish habitat. Of thare proposed under Alternative C for be restored to intertidal habitat and 1upland habitat (with at least 10 of thonesting habitat). The other eight acreof the proposed wetland area would parea and preserve areas of the fill thaspecies. The 13 acres of intertidal habcomplement the adjacent nesting habfrom the nesting area to the tidal areaproviding fish habitat to support least 

21.83 Refer to Response 21.78. 
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21.84 The draft CCP/EIS acknowledges tha

may be lost from the site as a result ounder Alternative C, Salt Works OptiHowever, to maintain foraging opporthabitat suitable for the production of in the preliminary restoration plan unThe draft CCP/EIS does not state tha

increase as a result of restoration; rat4-82 reads, “foraging . . . opportunitiefrequent these ponds, would be expec

21.85 Section 4.4.2.3.1 and 4.4.2.4.1 of the dr

discussion of how restoration could afcurrently supported at the salt workshave been incorporated into the prelimaddress potential adverse effects to threstoration include: maintaining somsupport shorebirds and waterfowl, morestoration on seabird nesting, and enplans include phasing and an adaptive restoration. With respect to mitigatioto intertidal habitat does not require cconversion would not result in any losto wetlands as a result of providing nethe salt ponds would be offset by the pof 60 acres of intertidal habitat in the Additionally, a minimum of 50 acres othat currently provide limited if any fwould be converted to managed ponds
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21.86 We agree and the text does not disput

the salt works were established on levwater. We also acknowledge that on-gcolonies before, during, and after the essential to understanding the actual colonial nesting seabirds that have hisunderstanding of the conditions at othCalifornia is also important in predictdata available in the literature about tsome insight into what factors may be existing nesting colonizes. Refer also 10.23. With respect to those species that curthe text on page 4-84 of the draft CCPspecies that have been observed nestiThe statement that the species that nnot expanded into other areas in the 6nesting at the salt works is not accuraits breeding range in California in 198nesting at Bolsa Chica, and again in 1Chica birds relocated to the Los Ange(1999) indicates that the first adult eleprobably from the crowded San Diego was also attempted in 1998 at Zuniga Bay. Caspian terns colonized the salt workexpansion covering the entire Pacific at San Francisco Bay and Bolsa Chica salt works is the only breeding locatioalthough this species also attempted b1998. Similar to the elegant tern, the its breeding range from San Diego to Harbor. 
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The Forster’s tern first appeared at tsubsequently expanded its breeding rWildlife Reserve and to the new nestiin 1990. Following the construction of skimmer also began nesting at BatiquIt is a goal of the CCP to retain the diwithin the South San Diego Bay Unit. are proposed to improve nesting oppothe area available for nesting and consubstrate on the existing levees. Incluthe draft CCP/EIS are a number of acimplemented in an effort to ensure thfor seabird nesting. 
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21.87 Refer to Response 10.14. The statem

not controlled within the Refuge when species is incorrect. As stated in Sectdraft CCP/EIS, if an individual harriethreat to listed species, it can be live-tlethally removed following consultatio

21.88 As described in Section 4.4.2.3.1, ther

colonial seabirds nesting in areas surrrather than open water. These areas 

2003), Upper Newport Bay (Seto et al 

Buck, pers. comm.), and Isla Montagu(Burness et al. 1999). Additionally, wskimmers expanded their breeding rathen to Los Angeles Harbor, the sites to nest were not surrounded by waterflat, generally unvegetated areas with 

area, physical characteristics that appthe seabirds that nest at the salt worket al. 1999, Buckley and Buckley 2002observations, the proposed conversion habitat may not be as significant as asdoes however acknowledge the potentarea by one or more species and inclumeasures that could be implemented 

21.89 We do not agree that conversion of th

habitat would result in a reduction in the diversity of shorebird species that bay. Under present conditions, forag(the primary exception being phalaropin many ponds to the shoreline. In oth10A, 20 and 22, additional foraging opwhen water levels are lower due to fluevaporation process (Stadtlander and 
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comm.). Following restoration, larger available for shorebird foraging. Specforaging would be provided in those pintertidal mudflat habitat (at least 125 water levels would be managed to acc

waterfowl (approximately 230 acres), (approximately 45 acres), and within tassociated mudflat areas to be includecordgrass restoration. All acreages pdraft CCP/EIS are based on preliminActual acreages would be determined subsequent detailed engineering and A discussion of mitigation is provided 

21.90 Sections 4.4.2.3.1 and 4.4.2.4.1 of the d

discussion of the potential effects to pknot, refer to Response 21.70. 

21.91 As stated in Section 4.2.2.3.2 of the dr

effects of settlement prone soils and wexternal and internal pond levees wouprior to the completion of detailed engThe outer levees already include a sigprotection that has been added over tsolar salt operation. It is possible thalevee breaches, particularly breaches required, however, this armoring can deters the potential for rodent and primpacts to shorebird foraging areas. explored during subsequent restorati

21.92 Although not illustrated in the 1859 d

(Figure 3-3 of the draft CCP/EIS), it 
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that existed within the adjacent salt mthe mudflats to the shallow subtidal hlikely form in association with levee bthe existing mudflats is proposed to crchannels that form would form naturatidal action. Although the creation of not expected to result in any significaexisting mudflat habitat, additional hyin association with detailed restoratiomore detailed assessment of where ancould be created. With respect to habitat value, the Seravailable from this site and other restprofessional judgment believe that thAlternative D, which would incorporamanagement into the final restoration value within the South San Diego Bay benthic invertebrates, and a variety otime, the actions included under this athose aspects of the existing salt pond seabirds and other migratory birds. 
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21.93 Refer to Responses 11.17, 18.35, and 2

21.94 As stated in draft CCP/EIS, a compre

species observed within the San Diego completed, therefore, Appendix C onlhave been recorded to date on the sitespecies are expected to occur here and additional baseline studies are compleSweetwater Marsh Unit has been corrgolden plover and delete the America

21.95 Appendix D (CCP Implementation) h

CCP/EIS to more clearly define the simplementing a restoration design tha

adaptive management. 

21.96 Refer to Response 21.31 above. 

21.97 Comment noted. 

21.98 The draft CCP/EIS provides a progra

management alternatives considered step in the planning process is to condgather additional data necessary to prand restoration plans. With this inforrefine the restoration design and deveapplied studies that would enable the management approach into project imbeen revised to include detailed informbe completed in developing detailed eplans for the Refuge. 
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21.99 As discussed in Section 4.2.2.3.3 (Wat

CCP/EIS, no adverse effects of breacanticipated due to the relatively low sThis assumption is supported by the mbreaching of Ponds 12, 13, 14, and 15. salinity levels in the sediments prior trestoration plans is also acknowledgecoordinate with the Regional Water Qacknowledged in Section 1.4 of the draResponses 10.18 and 11.24 for informainvertebrates. 

21.100 Intent of this comment is unclear. 21.101 Page 4-45 of the draft CCP/EIS state

several simplifying assumptions for thfeasibility assessment. To implement component, these assumptions would association with the development of fi
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21.102 The need for sediment analysis and so

addressed in several places within the 4-40 where the need for subsequent acrust is addressed in detail. Refer als

21.103 Refer to Response 18.38 above. 21.104 Comment noted. 21.105 Comment noted. 21.106 This information has been revised acc21.107 The text has been revised to read: Pr

Manager is required for all actions invpredator. This approval for lethal remblanket discretionary removal of certaconfines of the breeding colony site (sor feral cats where live trapping has bbegun) or on a case-by-case basis (sucraptors). 

21.108 The Predator Management Plan prov

lethal removal of corvids that are a thnot however agree that blanket approremoval of kestrels. 

21.109 Comment noted. 
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22.1 Sections 3.4.1.3, 3.4.2.2 (Salt Evaporat

draft CCP/EIS include detailed informthe habitats, including the salt ponds, abundant and diverse array of avian ssome of this information has been incoto make the information easier to locaimportance of the habitats within the shorebirds and colonial nesting seabir2.3.5.2 under Objectives 1.3, 1.4, 3.1, 3As described in greater detail in RespAlternative D is to restore historic coasouth bay, while also maintaining and aspects of the existing salt pond systeseabirds and other migratory birds. 

22.2 The relevant components of the habit

San Diego Bay Unit are acknowledgeobjectives, and strategies (Section 2.3well as in the Effected Environment S(refer to Response 22.1 above). It is tthe various strategies that the relevanwould be maintained, enhanced, and rquality for an array of organisms, inclspecies that utilize the site. 

22.3 Sections 4.4.2.3.1 and 4.4.2.4.1 of the d

discussions of the potential environmespecies that could result from restorinintertidal habitat. 
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22.4 The Service provided a 60-day comme

CCP/EIS and no requests for additionAll data available to the Service has band evaluating the range of alternativCCP/EIS; however, the Service welcoany additional data that to this point hconsideration. Refer to Response 22.existing conditions. Refer to Responsidentification of data gaps. 

22.5 Advanced notice of the availability of 

distributed to approximately 1,000 indagencies throughout the country. Thianother notice to the same distributiothe comment period. A Notice of Avathe Federal Register on July 22, 2005distributed to all who requested a coporganizations and individuals outside Point Reyes Bird Observatory, ManomSciences, National Audubon Society, Nand many others. In addition, the docon-line. The distribution list for this dAppendix B of the draft CCP/EIS. 

22.6 Refer to Responses 21.1, 22.1, and 22.22.7 Comment noted. 22.8 Refer to Response 21.23 above. 
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22.9 The Final CCP/EIS has been revised 

Memorandum of Understanding (MOLeasehold Overlay expires in 2010, a mStreet Fill could be restored to intertithree alternatives presented for the S2010, any portion of the D Street Fill accordance with the Mitigation Leaseunder Alternative A, continue to be mincludes managing 23 acres of Refuge least tern nesting in accordance with prequirements); under Alternative B, eareas, including additional fencing, exsubstrate enhancement over approximbe implemented; and under Alternativredesigned to provide 33 acres of enh

of restored intertidal wetlands. With these projects: based on the best profService, the enhancement of 33 acres adjacent chick foraging areas would pterns and particularly snowy plovers ton the man-made D Street Fill. The oimprove nesting success over current Through enhancement, annual mainteimplementation of an adaptive managobjective can be met. 

22.10 Both Objectives 1.1 and 1.2 in Section 

address the need to improve tidal circbuild up in the marsh. The implemendescribed for these objectives would rforaging areas for shorebirds, particu

Objective 1.2 addresses the full range mudflats and salt marsh habitat. In aproposed under Objective 1.2 are inteforaging area along the existing tidal invasion of the Australasian isopod Sp
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22.11 Refer to the first part of Response 11

22.12 We concur, which is why both Alterna

proposals to improve access for plover Street Fill to adjacent foraging areas. 

22.13 Comment noted. As stated in the dra

document has been prepared in a manproposed decision to include any of thdocument or to include a combination more of the alternatives. 

22.14 This information is inaccurate. The sa

criteria for western snowy plover critsection 3 of the Endangered Species Aalternatives, including the preferred athat would result in management for jverified by reviewing the various objeAdditionally, the preferred alternativseveral strategies or actions that are iproductivity of western snowy plovers 

22.15 Refer to Responses 11.5, 18.7, and 21.

22.16 In Sections 4.4.2.3.1 and 4.4.2.4.1 of th

of potential effects to various avian spon the best available data. Current usvarious guilds of birds are described arestoration on current use. This analyinformation available for this site, but investigations and observation made iin published scientific literature. As sdraft CCP/EIS is intended to present direction for the Refuge over the next the analysis has been conducted at the step-down plans will be prepared follo
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to address the specific details of the vsteps in the planning process are descrevised Appendix D of the Final CCP/of additional discussion of the effects avian diversity and abundance and to and 21.76 for information related to thconditions. 

22.17 Refer to Response 10.3. 
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22.18 The findings of the Pacific Flyway Pr

3.4.4.1 of the daft CCP/EIS. It should Robert Patton, the Pacific Flyway Prcounted on the mudflats from those on some revisions to this discussion have CCP/EIS. 

22.19 Refer to Response 10.3. 

22.20 Refer to Response 21.70. 

22.21 Refer to Response 21.77. 

22.22 Waterfowl use in the salt ponds is des

draft CCP/EIS and an analysis of the is provided in Sections 4.4.2.3.1 and 4.waterfowl observed in the salt ponds dstudy of the south bay: brant were obbay outside the confines of the salt wogadwall, mallard, northern pintail, cinbufflehead, ruddy duck, red-breasted were recorded both within the bay anredhead, ring-necked duck, and commin very low numbers (seven, six, and ooccurring within the initial primary posystem along the tidal flats; greater sthe confines of the salt ponds; and lesobserved both within and outside the concentrations of these species occurrsystem and within the initial intake poobserved during this survey were obsthe salt ponds, however, the highest cwere observed within the salt pond co
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22.23 A discussion of phalarope use in the s

59 of the draft CCP/EIS. 

22.24 The distribution of birds in both the in

ponds is presented in Section 3.4.4.1 oinformation is addressed in the text anand Figure 3-12. The data is based on avian survey of the salt ponds and adjsubtidal areas of the south bay. This comprehensive data available to date this portion of the Refuge. Although collected in subsequent years, this shonot provide sufficient data to allow for two data sets. A new year-long survefuture using protocols that will permit survey with that obtained during the 
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22.25 A discussion of the intertidal mudflat 

within the Refuge is provided in Secti

CCP/EIS. Table 2-12 of the draft CCminimum of 124 acres of tidal mudflatAlternative D. Based on historic mapelevations within the ponds, the area prestoration historically supported this characteristics of the habitat following comparable to those that exist immedboundaries of the salt works. These aduring subsequent detailed restoratiosediments will be characterized to detsalinity levels, and the possible presen

22.26 Section 3.4.2.2 (Solar Salt Evaporation 

indicates that a comprehensive study the salt ponds has not yet been compldescribe the results of investigations cwhich provide insight into the species column and sediments of several of thBased on this information and data puscientific journals regarding brine shrthere is adequate information availablincluded in any one of the alternatives CCP/EIS at the program level. The nanalysis of the brine invertebrate popponds prior to completion of a final rerevise Appendix D (CCP Implementa

22.27 The 1993/1994 avian survey, seven yea

monitoring at the salt works by the Seinvestigations conducted in the south throughout the world, and the results projects in Southern California have pnecessary to develop and analyze the presented in the draft CCP/EIS. To f
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understanding of avian use of the soutsurvey will be initiated prior to complAll of this data will be important in immanagement approach to restoration respect to nesting seabird numbers, tannual monitoring of the seabird nestsince 1999 and the results of that moninto consideration. 

22.28 Based on the data available and the b

Service biologists, the draft CCP/EIS would not be adversely affected by reaccordance with Alternatives C or D. planning and implementation that incadaptive management, the Service beand objectives described in Chapter 2 be achieved. 

22.29 Refer to Response 10.6. 

22.30 Refer to Response 10.8. 
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22.31 Refer to Response 10.9. 

22.32 Refer to Response 10.10. 

22.33 Refer to Response 10.11. 

22.34 Refer to Response 10.12. 

22.35 Refer to Response 10.22. 

22.36 Data regarding the historic conditions 

Sections 3.2, 3.4.1.2, and 3.4.1.2 of the Response 21.74. 

22.37 Objective 2.3 for the South San Diego 

standards for measuring success of corestoration in terms of plant coverageAdditional criteria for measuring restwould be developed in association with monitoring plans and should provide timplementing adaptive management. 
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22.38 This information is provided in Sectio

22.39 Discussion of the restoration planning 

Bay has been added to Section 4.9 of taddition, a new strategy has been addObjective 3.3 that addresses the impocommunication among those involved at San Diego Bay, San Francisco BayPacific Flyway. 

22.40 According to the data provided in the 

Natural Resources Management Plan approximately 34% of the intertidal mcurrently included with the Refuge boremaining area is included within the acquisition boundary, but is currently facilitate long term habitat protection manage the uses that occur within and Objective 1.1 for the South San Diego to incorporate all of this area into the With respect to the management of thexisting and future habitat within the and in particular Section 2.3.5.2 of the detail the objectives and strategies thunder the various alternatives. 

22.41 We acknowledge that the byproducts 

solar salt operation include benefits to of bird species, as well as tax and leasagencies. However, this commercial o
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Wildlife Refuge, and in accordance wiWildlife Refuge System (“wildlife firsRefuge was established (to protect anService must consider management omaximizes habitat value for listed speand plants supported within the Refugoperator of the salt works has always ensure the protection of wildlife durinis not possible for the operator to manthe ponds to maximize benefits for wisalt pond system provides no benefits plants that exist in the adjacent bay ealternative for the South San Diego Bhabitat conditions for listed species, wneeded to support the variety of speciRefuge boundaries. 

22.42 Additional data gathering and analysi

Appendix D, would occur prior to impproposals within the Refuge. Howeveyears of study are required before resregional, and national goals and objecrecovery, migratory bird habitat restobegin. 
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23.1 We disagree with the conclusion that 

would result in reduced biodiversity. restoration would restore biodiversity providing habitat that supports an abuof birds, as well as numerous species oplants. The salt ponds provide the morestoring historic native habitat in Sathat restoration can occur in a manner some cases enhances those aspects of that support nesting seabirds and oth

23.2 This CCP/EIS is a programmatic doc

aspects of management within the Reincludes two distinct Refuge Units, SwSan Diego Bay. The alternatives for eenvironmental consequences of implealternatives, have been included in sepreader in understanding how the varispecific unit. The next step in the plandevelopment of “step-down” or detailepoint in the planning process where mplanning for specific areas of the Refualso to Response 21.1 above. 

23.3 Refer to Responses 21.27 and 21.28. 
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23.4 Both Alternatives A and B for the Sou

viable alternatives in terms of implemfocus of each would be little or no chanpractices on the Refuge. Under eithewould continue to be managed for comand migratory birds would continue to they do now from this operation. Althmanipulation could occur to improve hthe primary purpose for water movemproduce salt rather than optimize conbenefits to nesting seabirds would resAlternative B, with the intent of proviopportunities to support the diversity on the Refuge, while also improving cplover and California least tern. 

23.5 The restoration options for the salt wo

Alternative C represent a compromisportion of the salt ponds to tidal influeremainder of the pond system in solar intended to be a stepping stone to the ponds. We agree that there is no guarunder Option 2 is commercially viablemanagement perspective, it may very If this alternative were to be selected Record of Decision, further analysis w

detailed restoration planning. Based the salt operator, we do believe that Oviable and economically feasible from perspective, but once again additional part of detailed restoration planning. Alternative B is identified in the propone or more of the proposed public us

proposals that are included in Alternaon page 2-1 of the draft CCP/EIS whe
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vision may look very similar to the preinclude a combination of components falternatives presented in the draft CC

23.6 Table 7 and Table 2-12 are correct in 

nesting habitat are proposed under Asalt pond habitat would be restored to been corrected in the Final CCP/EIS 

23.7 Refer to Responses 10.15, 10.18, 10.2823.8 Refer to Responses 11.17, and 18.38. 23.9 Substrate analysis and contaminants 

sediments would be completed as part planning that would occur once a CCP identified. The need for these studies detailed restoration plans is addressedraft CCP/EIS. In addition, page 2-9describes the water management planintensive monitoring program, that wthe final restoration planning under Aconsideration of the potential effects trelate to residence time and bacterial issues has been added to the water mathe Final CCP/EIS. 

23.10 A year-long avian study similar to tha

1993/1994 will be initiated in the near documenting abundance and diversity

analysis of bird use within the ponds aneed for the implementation of such sfinal restoration plans for the salt ponD (CCP Implementation) of the Final 
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23.11 The Migratory Bird Treaty Act of 191

Section 5.1.4 of the draft CCP/EIS. WService’s Division of Migratory Birds development of this CCP and will con

step-down planning (see also Respons

23.12 The effects of pond restoration on wat

other waterbirds, Belding’s savannah presented in Sections 4.4.2.3.1 and 4.4for a discussion of common goldeneye 22.22 for additional discussion related 

Sections 4.4.2.3.1 and 4.4.2.4.1 have beCCP/EIS to address in greater detail swallows and horned larks as a result 

23.13 Plover nesting located anywhere with

be subject to predation by all of the spcomment. Therefore, as described in attempts to improve nesting success bwithin the South San Diego Bay Unit management (predator control, use of implementation of these actions is addobjectives and strategies (see Chapter 

23.14 The effects of pond breaching on bay 

subtidal and intertidal habitats are de4.2.2.4.3, 4.3.2.3.1, 4.3.2.4.1, 4.4.2.3.2, 4The concern regarding dissolved salts flushing is addressed on page 4-35 of tstates: “To avoid the potential for sucsediment sampling within the salt ponthe completion of final restoration plaelevated salinity levels] are present at remediation, contaminated sediments appropriately remediated prior to pon
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23.15 Continued access to accommodate fut

discussed in the draft CCP/EIS. Pleadraft CCP/EIS which states: “Some obridged to maintain access around the monitoring, law enforcement, and spe

the potential for erosion, particularly wind-generated waves, and tidal curre

ponds, the levees would require routinmaintenance to ensure the long-term actual size of the breaches and the infaccess to the outer levees for managempredator control and listed species moduring final restoration planning. 
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23.16 We disagree with the statement that n

habitat value available today at the sawere true, there would be no need to cremains along coastal California to sustatement is contrary to the habitat g

Shorebird Conservation Plan (Hickey 

Conservation Plan Pacific Region (USagree that the levees provide importaroosting birds, which is why all of the South San Diego Bay Unit include the maintain the existing salt pond levee sCCP/EIS includes a description of the taken to maintain the habitat quality orestoration. 

23.17 Refer to Response 22.13. 

23.18 This graphic has been revised to disti

sites and current nesting sites in San 68 of the draft CCP/EIS correctly ideleast tern nesting occurs within the ba
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23.19 Comment noted. Refer to Responses 
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24.1 Comments noted. 
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24.2 Although the restoration and water m

Alternative D would eliminate some pinvertebrates currently present in the also result in increases in the availabilinvertebrates within both the managemore acres of intertidal mudflat habitthe system. Some of the questions rewithin the system that would be examrestoration planning include: 1) to whspecies observed within the salt workavailability of brine invertebrates; 2) ithe presence of brine invertebrates in and diversity of avian species that use proposed changes to the system resulone or more avian species, and if so, sproposal would be made to increase ththe system. This discussion has been Implementation) of the Final CCP/EI

24.3 Page 4-84 of the draft CCP/EIS inclu

characteristics that likely attract nestLimited human disturbance and the gsalt ponds are believed to play the bigseabirds to the salt pond levees. Refe

24.4 Refer to Response 24.2 above. 24.5 It is unclear what the commenter is re

species would no longer be able to formanagement area. Water levels withi

would be regulated to support shoreb

roosting. As stated in Response 24.2 food supply availability would be condrestoration planning. 
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24.6 The quality of the salt marsh habitat a

degraded over the years as a result of human-related disturbances within anintroduction of Sphaeroma quoyanum

form of the tidal channels, the significwithin the Sweetwater River watershfreshwater flow into the marsh, high lplants, and sediment accumulation wiwhere tidal circulation has been reducdisturbance. Several strategies are pcould improve habitat quality for clapObjective 1.1 which addresses the neethe marsh. This proposal is consistendescribed in the Light-footed Clapper 1985). 

24.7 Refer to Responses 24.2. 24.8 It is a goal of the CCP to retain the di

within the South San Diego Bay Unit. CCP/EIS for the South San Diego Bamanagement actions intended to imprincluding expanding the area availablimprove nesting substrate on the exisResponse 21.88. 

24.9 Refer to Response 21.77. 24.10 The habitat requirements of the light-

received significant attention in the lit1988, Zembal 1989), and sufficient datthere is a tremendous opportunity for for clapper rails at the south end of Sagood tidal flushing, separation from inproximity to productive tidal flats. As 
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CCP/EIS, monitoring and adaptive mimportant component of ensuring suc

24.11 A prey source would continue to be av

(including the brine ponds) during higThe brine ponds would provide a sourat a smaller scale, and the other +230 

support benthic invertebrates and othDepending upon the time of year, the would be managed to support shorebirafting. The amount of foraging area grebes would be reduced, but not lost

24.12 The conclusion that foraging in the m

to larger shorebirds is incorrect. As sCCP/EIS, “the water levels in the ponthroughout the year to support the fomigratory birds.” Currently, water lconditions for making salt, while undewould be optimized for wildlife. Foraavocets, and stilts would be altered; hdistribution of avocets and stilts in Sais likely that these species would foragas well as the ponds managed to prod
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24.13 This is acknowledged on page 3-64 of 

24.14 Further analysis of current bird use w

association with the preparation of de

24.15 The data obtained from the 1993/1994 

Konecny 1994) is not adequate to supphigh bird abundance figures for Pondrelated to prey density. For instance, although shorebird foraging was obseof the birds appeared to utilize this locthe mudflats were inundated. The higattributed to a few species, including pwhile Pond 30, which experienced watresulted in land exposure within the phigh species diversity. In reviewing tequally important to note that all of thsalt ponds that were included in the sthigh species diversity and high to modresults of the study do indicate that btidal areas provide habitat important which is why Alternative D includes pinfluence to some ponds, while retainiand salinity levels in others. Appendibaseline data, including data regardinobtained prior to completing detailed 

24.16 Comment noted. Refer to Responses 24.17 Refer to Responses 10.4, 10.13, 14.3, a

nesting has not been documented adjaDuring the 1998 nesting season, CaspForster’s terns were observed nesting 
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24.18 Comment noted. 

24.19 The assumption here is that no seabir

following restoration. That assumptioobservations of past seabird nesting hsystem and at other locations where tintent of the nesting enhancement proexisting nesting areas and expand oppactivity. 

24.20 The seabirds nesting on the salt pond 

mammalian and avian predation. The expected to increase significantly undsituation, predator management to prcontinue to provide indirect benefits t

24.21 The Chula Vista Wildlife Reserve was 

provide nesting habitat, however, the to some nesting birds, such as Califorterns. Additionally, the creation of thresult of the need to dispose of excess provide nesting habitat for seabirds. other species were attracted to the sitthis area have been set aside for proteRefer also to Response 10.3. 

24.22 There is no evidence to indicate that c

be successful at this location or that clinto the area following restoration. Tponds would remain permanently opeimportant factor in maintaining high qaddition, clapper rails have been obseareas of cordgrass that exist within th
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to the north of Pond 11. Human distudegradation have significantly reducespecies, which continues to contribute light-footed clapper rail population. TAlternatives C and D to restore signifclapper rail habitat in the south bay afor which the Refuge was establishedproposed recovery actions included wplan for this species (USFWS 1985). 

24.23 This is an interesting observation; how

the scope of the CCP. We will forwarresponsible for conducting the annual understanding the results of such surv

that rails may be using brackish and fbecause their preferred habitat, cordgso limited. Further, reproductive sucareas may be adversely affected by prthese habitats is generally higher for proximity to development. 

24.24 Refer to Response 22.41. 

24.25 Comment noted. 
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25.1 Comment noted. 25.2 Refer to Response 10.3. 
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25.3 The important of the salt pond system 

foraging is addressed in Section 3.4.4.

25.4 Refer to Response 22.23. 25.5 Refer to Response 21.70. 25.6 Refer to Response 22.22. 25.7 Refer to Response 21.77. 25.8 Refer to Responses 10.13, 22.26, 24.1125.9 An assessment of the impacts expecte

of the salt ponds to intertidal habitat iand 4.4.2.4.1 of the draft CCP/EIS anincorporated into the project design tbrine invertebrates within the second6.2, 6.5, 10.5, 14.4, 18.24, 21.35, and 23

25.10 Refer to Responses 10.14 and 21.87. 

25.11 Refer to Responses 21.88 and 24.17. 

25.12 Refer to Response 21.89. 
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25.13 Refer to Response 21.92. 

25.14 Under the “no action” alternative, the 

abundance of avian species currently would be maintained; however, there habitat quality for the listed species sAlternative B would provide new benethe form of expanded nesting opportulight-footed clapper rail or fisheries in believe that an approach that continueabundant avian population, while also listed species and a diversity of other in this portion of the bay, is the best aRefuge purposes and mission of the NSystem. 

25.15 Comment noted. Refer to revised Ap

CCP/EIS. 
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26.1 Comment noted. 26.2 Sections 4.4.2.3.1 and 4.4.2.4.1 of the d

environmental consequences to the vautilize the salt ponds for foraging, loaf

26.3 Refer to Response 10.3. 26.4 Refer to Response 10.8. 26.5 Refer to Response 10.9. 26.6 Refer to Response 22.18. 26.7 Refer to Response 10.3. 
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26.8 Refer to Response 21.70. 26.9 Refer to Response 21.77. 26.10 This is correct, boating is not permitt

are no proposals within any of the altewithin the confines of the salt pond co

26.11 Refer to Response 21.69 

26.12 Refer to Responses 10.25 and 23.19. 
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27.1 Comment noted. 27.2 Refer to Responses 21.2, 21.58, 21.8527.3 Refer to Response 10.3. 27.4 Refer to Response 10.8. 
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27.5 Refer to Response 10.9. 27.6 Refer to Response 10.3. 27.7 Refer to Response 22.22. 27.8 Refer to Response 22.23. 27.9 An assessment of the impacts expected 

of the salt ponds to intertidal habitat is and 4.4.2.4.1 of the draft CCP/EIS and mincorporated into the project design to cinvertebrates within the secondary pondexisting pond levees for seabird nesting shorebirds, and to reduce the potential disturbance following the closure of the Response 21.85. 
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28.1 Refer to Responses 6.2, 18.4, and 21.528.2 There are very few successful light-fo

southern California due to continually disturbance in existing habitat area, uhydrology which adversely affect the marshes, and increased predation by predators. The importance of restorinmarsh habitat to clapper rail recovery footed Clapper Rail Recovery Plan (U

the draft CCP/EIS proposes to increaSan Diego Bay Unit to support the ligproposal is consistent with the Recovethe amount of suitable habitat for this Otay River mouth be increased. 

28.3 As described in Section 2.3.2.4 of the d

levees would be breached under Alterlevee structures would be maintained condition to ensure the long-term avanesting seabirds and roosting shorebiavifauna. Refer also to Responses 21.
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28.4 Refer to Responses 10.28, 11.24, 18.2628.5 The draft CCP/EIS does address the 

nesting habitat for the western snowy in the draft CCP/EIS). We also concushould be provided for nesting avocetthe specifics of the nesting habitat desstep-down restoration planning, we hathe Final CCP/EIS to include specific these nesting shorebirds under Altern

28.6 As described in Responses 10.12, 18.7

strategies presented for Alternative D recommendations and recovery actionPacific Shorebird Conservation Plan, Recovery Plan, the Western Snowy Pvarious other conservation and recoveexpertise of the federal and state resogroups, academics, and professional bpreparation of these recovery and birbelieve that implementation of these sspecies by providing additional foragiopportunities within San Diego Bay. 

28.7 We disagree with this conclusion, as t

designed to improve nesting and foragspecies and maintain and in some caseforaging conditions for the migratory 10.21 and 10.22. 
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29.1 Refer to Response 14.4. 29.2 Refer to Responses 18.4 and 21.58. 
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30.1 Comment noted. 30.2 Refer to Responses 6.2 and 18.4. 30.3 Refer to Response 25.15. 
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31.1 Comment noted. 
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32.1 One of the objectives of the CCP is to 

nesting within the South San Diego Bactions are proposed to improve nestiexpanding the area available for nestinesting substrate on the existing leve10.5 and 10.12. 
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33.1 We appreciate your input and encoura

involved in the next step of CCP implthe development of detailed restoratiorestoration areas identified in the proplanning process would include opporsimilar to those provided during the dthis time, restoration within many of tinclude a mix of habitat types, includinmudflats, and cordgrass and picklewe

Various factors would be considered imix of habitat types within an individufactors as the physical and hydrologicthe potential habitat value for fish and an area to disturbance. Appendix D orevised to more clearly describe this nplanning. 
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34.1 The text has been revised per your su34.2 Because of the potential for disturban

well as during the nesting season, the levees would be restricted to guide toucombination of trails proposed under trail around Pond 28 and a pedestrian edge of the Refuge) would provide goto observe the variety of birds supporpond complex. These opportunities foobservation would be supplemented bpond complex, as described in the dra

34.3 Due to the limited acreage of developa

boundary of the South San Diego Bay include a proposal to construct a visitocomplex. It is possible that some othethe future propose an interpretative cof the Refuge, which could provide opthat would enable some interpretation 102 of the draft CCP/EIS addresses tcameras and other innovative approacresources supported within the Refug
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34.4 Comment noted. 
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35.1 Comments noted. 35.2 The railroad right-of-way addressed h

boundary of the San Diego Bay NWR

does not propose to implement any muses within this area. The use of this determined by the underlying landowapproval authority over the developminitiated for this area. 
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35.3 We are not aware of any disputes ove

Refuge. Revisions to an approved Rethrough an amendment the Refuge’s than through the CCP process. 

35.4 Refer to Response 35.2 above. 35.5 Comments noted. 35.6 Any uses proposed on Refuge lands w

determine if the proposed use would bpurposes and mission of the National to Section 1.5.2.1 of the draft CCP/EI
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35.7 Refer to Response 35.2 above. 35.8 Comments noted. 
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36.1 Hunting is not included as a proposed 

management alternatives evaluated in reasons described in Section 2.3.3.3 of 
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37.1 Refer to Response 36.1 above. 37.2 The tidal channels within the San Die

for use by self-propelled boaters becaeffects to listed species and other wildactivity. Please refer to the CompatibInterpretive Water Trail that is proviCCP/EIS. Opportunities for organizethe Refuge in cooperation with variouSan Diego Audubon Society and the FRefuges. During these clean-ups, accsalt pond levees and the D Street Fill volunteers to remove trash, fishing linwater’s edge. 

37.3 Refer to Response 36.1 above. Oppor

from boats are available within the Rebay itself. The areas closed to boating 

that meander through sensitive salt mwithin the Sweetwater Marsh and Sou
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38.1 Refer to Response 36.1. 38.2 No trapping, new roads, mining, graz

prescribed burning are proposed on twould continue to be permitted to opeSan Diego Bay. 
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39.1 Refer to Response 4.3. 39.2 A variety of public use opportunities h

preferred alternative that would provopportunity to observe wildlife and paeducation and interpretation activities Public Use Program, of the draft CCPcontinue to be permitted within the opproviding on the water opportunities f

39.3 Comment noted. 
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39.4 Refer to Response 11.12. 39.5 The need for the Refuge to increase it

planning issues that could affect Refuunder Alternatives B and C for the SwChapter 2 of the draft CCP/EIS. ThiObjective 1.4 for the Sweetwater Mar

39.6 These types of uses, activities, and res

maps throughout the draft CCP/EIS. 

39.7 Comment noted. 
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39.8 Various public use proposals are inclu

alternative that would provide opportto become connected with the natural successful environmental education primplemented on the Refuge, including Habitat Heroes. Both of these progra

partnerships with local agencies, publprofit organizations. Additional fundiand corporations. 

39.9 Comment noted. 39.10 The discussion of current fishing activ

revised in the Final CCP/EIS to incluto Response 11.38. 
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39.11 Refer to Response 11.39. 

39.12 Refer to Response 18.2. 
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39.13 Refer to Response 18.3. 

39.14 Refer to Response 18.4. 

39.15 Refer to Response 18.5. 

39.16 Refer to Response 18.6. 

39.17 Refer to Responses 10.23 and 18.9. 

39.18 Refer to Responses 10.18, 11.17, 18.22

39.19 We believe the list of required permit

types of permits required would be fustep-down restoration planning that wof the CCP. 
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39.20 Refer to Responses 18.29 and 18.31. 

39.21 Refer to Response 18.44. 
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Literature Cited 

Buckley, P.A. and F. G. Buckley. 2002. Royal Tern (Sterna maxima). In The Birds of North America, No. 700 (A. Poole and FNorth America, Inc., Philadelphia, PA. Burness, G.P., K. Lefevre, and C. T. Collins. 1999. Elegant Terns (Sterna elegans). In The Birds of North America, No. 404 (A

Birds of North America, Inc., Philadelphia, PA. Cimberg, R. and C. Dock. 1988. Least tern foraging studies at fixed stations in Los Angeles Harbor, 1986-1987. Appendix A.1.and Ecological Evaluation of Existing Habitats in Los Angeles Harbor and Adjacent Waters. September 1988. MEC AnalyticaPort of Los Angeles. City of San Diego. 1988. Report to the Mayor and Council of the City of San Diego from City Attorney John Witt, dated Septem

Eadie, J.M., M.L. Mallory, H.G. Lumsden. 1995. Common Goldeneye. The Birds of North America, No. 170. Hickey, C., W.D. Shuford, G.W. Page, and S. Warnock. 2003. Version 1.1. The Southern Pacific Shorebird Conservation Plan: A 

California’s Central Valley and coastal shorebird populations. PRBO Conservation Science, Stinson Beach, CA. Jacobson, C. 2003. Introduction to Adaptive Management. PhD dissertation. (Online) URL: http://student.lincoln.ac.nz/am-links/am-intro.html Keane Biological Consulting. 1996. Foraging study of the California least tern in the Los Angeles Harbor, 1955 breeding seaso

Port of Los Angeles. January 1996. Maffei, Wesley A. 2000. Summer Salt Marsh Mosquito. p. 167 – 168. In Goals Project. Baylands Ecosystem Species and Comand environmental requirements of key plants, fish and wildlife. Prepared by the San Francisco Bay Area Wetlands Ecosystem 

editor. San Francisco Bay Regional Water Quality Control Board. Oakland, California. Masero, Jose A. 2002. Why don’t Knots Calidris canutus feed extensively on the crustacean Artemia? Bird Study 49:304-306. 

Masero, Jose A. 2003. Assessing alternative anthropogenic habitats for conserving waterbirds: salinas as buffer areas against 

loss for shorebirds. Biodiversity and Conservation 12:1157-1173. 
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Massey, Barbara W. 1988. California least tern foraging study, Los Angeles Harbor, 1986/1987. Appendix A.1.2 35 pp. In Biol

Evaluation of Existing Habitats in Los Angeles Harbor and Adjacent Waters. September 1988. MEC Analytical Systems. Pre

Angeles. Merkel & Associates, Inc. 2000. Environmental Controls on the Distribution of Eelgrass (Zostera marina L.) in South San DieRelative Roles of Light, Temperature, and Turbidity in Dictating the Development and Persistence of Seagrass in a Shallow B

Parnell, J.F., R. M. Erwin, and K.C. Molina. 1995. Gull-billed Tern (Sterna nilotica). In The Birds of North America, No. 140 (Birds of North America, Inc., Philadelphia, PA. Patton, Robert. 2004. The Status of Western Snowy Plovers, California Least Terns, and Breeding Waterbirds at South San DiRefuge in 2002. Philip Williams & Associates, Ltd. 2003. Lower Otay River Salt Marsh and Wetland Restoration: Hydrodynamic Modeling An

Powell, A.N., C. L. Fritz, B. L. Peterson, and J. M. Terp. 2002. Status of Breeding and Wintering Snowy Plovers in San Diego 

Journal of Field Ornithology 73(2):156-165. Rick Engineering. 1987. Hydraulic Report for the Otay River Between Interstate 5 and the San Diego Bay. Prepared for MKSan Diego County, Department of Health Services. 1990. San Diego Bay Health Risk Study, Executive Summary. Seto, N., J. Dillon, W. D. Shuford, and T. Zimmerman. 2003. A Review of Caspian Tern (Sterna caspia) Nesting Habitat: A FeaManagement Opportunities in the U.S. Fish and Wildlife Service Pacific Region. U.S. Department of the Interior, Fish and Wil

Smith, David D. and Katherine Graham. 1977. Selected Environmental Aspects of Dredging in San Diego Bay, California. Pro

Dredging Seminar (November 1976). Stadtlander, D. and J. Konecny. 1994. Avifauna of South San Diego Bay: The Western Salt Works 1993-1994. U.S. Fish and W

Ecosystems Program, Carlsbad, CA. Terp, Jill M. 1998. Habitat Use Patterns of Wintering Shorebirds: The Role of Salt Evaporation Ponds in South San Diego Ba

Faculty of San Diego State University. U.S. Department of Agriculture, Soil Conservation Service and Forest Service. 1973. Soil Survey, San Diego Area, California. 
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U.S. Department of the Navy, Southwest Division (USDoN, SWDIV). 2000. San Diego Bay Integrated Natural Resources Man

Unified Port District. September 2000. San Diego, CA. Prepared by Tierra Data Systems, Escondido, CA. U.S. Fish and Wildlife Service. 1985. Light-footed Clapper Rail Recovery Plan. (Revised, original plan approved July 1979). 

U.S. Fish and Wildlife Service. 1999. Environmental Assessment and Land Protection Plan, Proposed South San Diego Bay U

San Diego National Wildlife Refuge. U.S. Fish and Wildlife Service. 2002. Birds of Conservation Concern 2002. Division of Migratory Bird Management, ArlingtonU.S. Fish and Wildlife Service. 2004. A Blueprint for the Future of Migratory Birds, Migratory Bird Program Strategic Plan 2U.S. Fish and Wildlife Service. 2005. Regional Seabird Conservation Plan, Pacific Region. U.S. Fish and Wildlife Service, Mig

Programs, Pacific Region, Portland, Oregon. Unitt, Philip. 2004. San Diego County Bird Atlas. San Diego National History Museum. 

Zedler, J.B. 1984. Salt marsh restoration: a guidebook for southern California. California Sea Grant Report No. T-CSGCP-009

Program, Institute of Marine Resources, University of California; La Jolla, California. 

Zembal, R. 1998. Proposal and Permit Request for Light-footed Clapper Rail Translocations, Management, and Survey, 1999-2Zembal, R. and J. M. Fancher. 1988. Foraging behavior and foods of the Light-footed Clapper Rail. Condor 90: 959–962. 
San Diego Bay National Wildlife Refuge

San Diego Bay National Wildlife Refuge Complex

6010 Hidden Valley Road

Carlsbad, CA 92011

Telephone: 760/930 0168

Fax: 760/930 0256

California Relay Service

TTY 1 800/735 2929

Voice 1 800/735 2922

U.S. Fish & Wildlife Service

http://pacific.fws.gov

For Refuge information

1 800/344 WILD

August 2006

Photo: USFWS/J. Konecny