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<br />PERMIT NO. 6-94 <br />(Issued on July 24, 1996, As <br />Amended Through March 4, 2010) <br />AMENDMENT NO. SIX <br />(Exclusive of Amendment No. Four) <br />City of Redwood City and <br />Keech Properties, LLC <br />Page 19 <br /> <br />While supporting evidence is sparse and somewhat speculative, there is evidence to <br />support USFWS's concerns. On some levee trails us'ed for recreation in the South <br />Bay, the ability to manage predators has proven to be extremely difficult because of <br />the hazards of placing traps in areas frequented by people and their pets, vandalism <br />to tarpaulins, and the negative perception of predator management by some people. <br />To conduct predator management in these areas, additional measures have been <br />taken to reduce contact between the public and the trapping program, such as <br />setting traps after dark, checking traps before sunrise, and careful placement of traps <br />to avoid heavily traveled paths. The USFWS states that these extra measures have <br />greatly reduced effective trapping time and area, and required more personnel to <br />maintain trapping efforts. <br /> <br />The Commission staff, the Commission's Design Review Board, and others pointed <br />out that both the Clapper Rail and the Salt Marsh Harvest Mouse have persisted at <br />the site despite over 20 years of public use of the levees. While development of the <br />tip of the Redwood Shores peninsula can reasonably be expected to increase public <br />use of the levee, increase the presence of predators, and increase the conflicts <br />between predator control efforts and public use, the Commission believes that some <br />combination of the public access design and management alternatives described <br />above could lessen the severity of those impacts sufficiently that even with increased <br />public use, impacts on the rail and the harvest mouse would be less than currently , <br />exists. The Commission staff also pointed out that the fences, gates, and mitigation <br />channel designed to exclude predators <br />and the public will not be completely effective, a point that the USFWS <br />acknowledges. However, the USFWS believes that these exclusion measures will be <br />effective in keeping many potential predators from rail and harvest mouse habitat. <br />In addition, by closing 2.2 miles of public access on the perimeter levee, as well as by , <br />mandating large open space buffer areas between urban development and <br />endangered species habitat, the USFWS believes that the activities of predator <br />control will be shielded from public view, increasing their effectiveness and <br />minimizing the controversy that predator control programs often engender. <br /> <br />However, the public use of the levee has not appeared to significantly alter the <br />habitat's viability for the Clapper Rail or Salt Marsh Harvest Mouse. In addition, the <br />installation of the moat and fences will not effectively exclude the red fox and other <br />feral predators from the levee, which is a reason given to fence the area from human <br />use. Thus, a major reason for closing access on the levee is so the public will not be <br />able to observe or interfere with predator control activities. <br /> <br />Therefore, because the Commission is not thoroughly convinced that relocating the <br />public access is justifiable-absent the ability of the USFWS to block the overall <br />project, because rights to the levee were expressly obtained by the State of California <br />to provide public access, and because no alternative inland public access could <br />match the experience afforded by access on the perimeter levees, the Commission <br />finds that eventually access should be returned to the perimeter levee as soon as the <br />apparent conflict between public access on the perimeter levee and sensitive wildlife <br />species is eliminated or reduced to an acceptable level. Therefore, this authorization <br />