Federal wildlife officials are poised to finalize Stanford University's deeply flawed Habitat Conservation Plan, a move that would compromise the health of San Francisquito Creek and San Francisco Bay, while posing new flooding and Searsville Dam safety concerns. Adoption of this 50-year plan, and associated federal permits to allow Stanford to incidentally harm and kill endangered species like steelhead trout, would be a major setback for ongoing watershed planning efforts to implement comprehensive habitat restoration and improve regional flood protection.
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- National Marine Fisheries Service
- U.S. Fish and Wildlife Service
- EIS Public Comment email- NMFS
- EIS Public Comment email- USFWS
- Stanford University President
I write to object to the incomplete and inadequate Stanford University Habitat Conservation Plan (HCP) and associated Environmental Impact Statement (EIS). I request that the National Marine Fisheries Service and U.S. Fish and Wildlife Service carry out the following actions:
-Withdrawal, and if Stanford wishes to proceed, revise, and reissue the EIS for the Stanford University HCP for adequate public review. A revised plan must accurately describe the unpermitted modification of the Searsville Dam diversion as an active and integral Felt Reservoir diversion source and mitigate its impacts. Alternatively, if Searsville Dam is to remain an uncovered activity, then all related activities (including channel excavation of Searsville Reservoir sediments and its connected, off-stream Felt Reservoir) must also be removed. The EIS must also assess identified Searsville Dam safety hazards and flood risks associated with the proposed Searsville Reservoir channel excavation and Corte Madera Creek re-routing along with the expected elevation in sediment transport over the dam.
-Cease in issuing any Incidental Take Permits to Stanford University related to this current EIS.
-Immediately reinitiate formal consultation on the 2008 Stanford University Biological Opinion for the Steelhead Habitat Enhancement Project. This outdated Biological Opinion, supported in this EIS, fails to accurately describe and consider the full extent of Stanford's water system (including all diversion operations to the off-stream Felt Reservoir), omits new information about negative effects to listed species and designated Critical Habitat in upper San Francisquito and Corte Madera Creeks (below Searsville Dam and booster pump constructed to improve diversions to Felt Reservoir), fails to consider unpermitted construction and modification to the Felt Reservoir diversion connected to Searsville, and fails to consider impacts from the project on other federally listed species, besides steelhead, and designated Critical Habitat below all stream diversions that currently feed Felt Reservoir or receive water from Felt Reservoir.
-Finally, I request that the agencies uphold the regulations of the Endangered Species Act and take enforcement action against Stanford University for unauthorized take of steelhead, red-legged frog, and other listed species harmed by their unpermitted Searsville Dam.
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