11629 Westridge Place, Lakeside, CA 619-966-5147 wildlifeinnovationsinc.com
MEMORANDUM
Date: 16 October 2024
To: Derek Schweigart, Parks and Recreation Director, City of Foster City From: Dan Biteman, Senior Wildlife Biologist, Wildlife Innovations Subject: Foster City Canada Goose Adaptive Management Plan Project, Draft Initial Study/Mitigated Negative Declaration – Response to Comments In accordance with 14, § 15074, titled “Consideration and Adoption of a Negative Declaration (ND) or Mitigated Negative Declaration (MND),” prior to approving a project, the lead agency shall consider the proposed ND or MND together with any comments received during the public review process.
The decision-making body shall adopt the proposed ND or MND only if it finds on the basis of the whole record before it (including the initial study and any comments received), that there is no substantial evidence that the project will have a significant effect on the environment and that the ND or mitigated MND reflects the lead agency's independent judgment and analysis.
Although there is no legal requirement to formally respond to comments on a proposed MND as there is for an Environmental Impact Report (EIR), this memorandum provides a response to the written comments received for the Foster City Canada Goose Adaptive Management Plan Project, Initial Study/Mitigated Negative Declaration (IS/MND) , to provide City of Foster City decision -makers adequate information to assist with their review of the proposed project.
The Draft IS/MND was available for public review and comment from 03 July 2024 through 02 August 2024 and was submitted to the State Clearinghouse on 05 September 2024 . This memorandum includes all comments and responses received following completion of both public and agency review periods.
The MMRP will be adopted by the City of Foster City if the IS/MND is adopted.
Notice of Intent to Adopt Posted by Foster City
COMMENTS AND RESPONSES
This section includes a copy of all comment letters received regarding the IS/MND and associated responses to each substantive comment. Only one letter was received, and that letter only identified one primary comment, and suggestion, with additional information provided in support of the suggestion, with citations from literature.
The following comment letter regarding the IS/MND was submitted to the City:
LETTER A1
California Department of Fish and Wildlife
30 September 2024
Response:
The comment provided by California Department of Fish and Wildlife (CDFW) identified that irrigated grass is an attractant for Canada Geese and cautioned that hazing alone may not be effective to deter Canada Geese from using areas where irrigated grass exists. CDFW recommended that the Adaptive Canada Goose Management Plan Project be habitat modification centric, removing irrigated grass where possible, allowing irrigated grass to grow long where not possible to be removed, or replacing that grass with less palatable grasses, and adding taller, native, water-wise shrubs where possible to replace irrigated grasses.
The review, response, and information provided within the response from CDFW are appreciated.
Habitat Modification is identified as one of the primary methods that will be employed as a part of the Adaptive Canada Goose Management Plan and within the IS/MND . The Plan identifies in more detail specific habitat modifications that will be tes ted for efficacy within the identified city parks, and carefully evaluated. Removal of all irrigated grass from within all city parks where Canada Geese exist may not be possible. Although the applicability of that will be evaluated further within each park, as well as within specific areas of each park during the implementation phase of this Project. Where irrigated grass cannot be removed, the possibility of allowing grass to grow long to be less desirable to geese or replacing th e grass with less palatable grasses will be evaluated . Where grass must remain, and where less palatable grasses cannot be planted without negatively affecting public uses of those parks or park areas, taller, preferably native, and water-wise shrubs may be planted instead of irrigated grass. The Plan identifies all these options, and describes the expected pros and cons of each, for deterring grazing, loafing, and nesting by Canada Geese. The Plan also identifies specific habitat modifications to be tested and potentially implemented within each of the parks within the Project area.
Following review and consideration of the comments provided by CDFW, minor changes were made to a few sentences within the project description and are incorporated into the Final MND, which includes the Mitigation Monitoring and Reporting Program (MMRP). One sentence was modified within the Project Description of the IS/MND to clarify that habitat modification will be prioritized during implementation of the Plan , and additional clarification s were made to clarify the same priorities within the Plan documen t itself. This comment does not relate to the adequacy of the information provided in the Draft IS/MND, and no further response is required.
Letter A1: California Department of Fish and Wildlife