175 Buckingham Way, #104
San Francisco, California 94132
January 15, 1999
Joan Ryan
Lake Merced Program Manager
Public Utilities Commission
1212 Market Street, 2nd & 3rd Floors
San Francisco, CA 94102
Dear Joan:
Friends of Lake Merced (FoLM) appreciates this opportunity to comment on the “Lake Merced 1998 Baseline Natural Resources Inventory, Draft Report.” Let me begin by complimenting you on an important addition to the reference material supporting the restoration of Lake Merced. This report represents a very good starting point.
We do, however, have a few questions, and would like as well to make one or two observations:
1) The action item in the Lake Merced Comprehensive Management Plan, Revised Draft (Action WRS-1.3) states that the purpose of this “survey and assessment” is “to assess the impact of changing lake level on the natural resources and to recommend a range of appropriate lake levels consistent with the beneficial uses.” We do not see any reference to this objective in the present report, nor do we find the background material, e.g., a description of flora and habitat by height above current lake level, that would support the stated goal. How should we use this report to achieve the desired assessment, and to develop an objective criteria for establishing a lake level goal?
2) The listing of sensitive plant species and special status animal species is very helpful. However, we do not see specific reference to habitat and/or environmental conditions needed to support those species, nor any assessment as to how varying lake levels may impact those habitats and conditions. How do we develop a program that provides specifically for the protection and encouragement of those species?
3) Similarly, with regard to fish species, there is a general belief that the condition of the lake has deteriorated with respect to edibility of fish caught in Lake Merced. We do not see any reference to the health of various species, just their existence. We do not see any reference to the water quality monitoring program recently implemented at the lake. And again there is no assessment as to how varying lake levels may affect fish health. How do we develop a program to assure the health of fish species, one that supports recreational fishing at the lake?
4) The existence of invasive plant species is noted in this report, but only briefly, and in very limited detail. A plate is provided that maps some instances of tamarisk and acacia. However, other invasive species that have become extensive at Lake Merced, including Cape Ivy, Iceplant and Wild Radish, have not been mapped at all. In fact, the report states that “since comprehensive species-level surveys were not part of this inventory, Cape IVY (sic) is not mapped separately on the plates.” It seems to us to be very important that the progress of these species is mapped, and that the potential damage to habitat, especially of special status plant and animal species, be noted.
5) The report refers to “unvegetated shoreline habitat . . . available in isolated locations, such as the fishing/picnic area between North and South Lakes, and adjacent to the viaduct between South and Impound Lakes.” We would like to point out that the areas described are not shoreline at all, vegetated or unvegetated, but are exposed lake bottom resulting from a reduction of lake level. A report intended to support the establishment of an optimal lake level goal should be very clear as to this distinction.
Throughout this report it is clear that the level of detail is limited by availability of resources needed to collect important data. We believe that community organizations, including but certainly not limited to FoLM, could help provide the eyes, and some of the legs, needed to complete this inventory. This report would have been much stronger had community involvement been actively solicited. For example, two years ago FoLM developed a detailed inventory, by site, of the then existing distribution of Cape Ivy. Had we been asked, we would be very happy to share that with you, and to update it as well.
Similarly, Lisa Wayne, Director of the Natural Areas Program of the Recreation and Parks Department, recently circulated a proposal for application of $197,000 in recently allocated grant funds. Included in the proposal is an allocation of $35,050 for “Surveys and mapping . . . of organisms, including many vertebrates, invertebrates and plants.” If Lisa was aware of the PUC inventory she made no specific mention of it in her proposal. Certainly she does not include it as a reference document upon which progress in preparing a restoration and management plan for the Lake can be based.
So long as we continue to have separate activities, and separate organizations each going its own way, we will not be able to harness the resources needed to develop a fully effective restoration plan. Friends of Lake Merced is ready and more than willing to contribute to a unified effort, one that involves all interested City and State agencies, working together with the community, to achieve this most desirable goal.
Sincerely,
John Plummer
