FINAL

ENVIRONMENTAL i m p a c t s t a t e m e n t

OAKLAND INNER HARBOR ALAMEDA COUNTY, CALIFORNIA

Prepared by

U.S. ARMY ENGINEER DISTRICT, CORPS OF ENGINEERS, SAN FRANCISCO

February 1973 6. Draft statement to CEQ: 18 January 1973______

Final statement to CEQ: f>7 flPfl fri/j______FINAL ENVIRONMENTAL IMPACT STATEMENT OAKLAND INNER HARBOR ALAMEDA COUNTY, CALIFORNIA

( ) DRAFT (X) FINAL ENVIRONMENTAL STATEMENT

Responsible Office; U.S. Army Engineer District, San Francisco, California

1. Name of Action; (X) Administration ( ) Legislative

2. Description of Action: Navigation improvement for Oakland Inner Harbor which consists of deepening the existing channel from 30 to 35 feet. Disposal of approximately 2,150,000 cubic yards of material with 1,250,000 to be placed at Alcatraz disposal site and 900,000 at sea beyond the 100-fathom isobath.

3. a. Environmental Impacts: Disturbance of bottom sediment during dredging; increased turbidity at dredging and disposal sites; economic and social benefit for Bay Area; temporary reduction in productivity of biotic community; deposition of sediments adjacent to disposal area and to project area; displacement of "Pollutants" entrained in ■ sediment during dredging and disposal.

b. Adverse Environmental Effects; Release of sediments and of absorbed chemicals into the water; removal of deeper substrate material which houses burrowing organisms; removal of the original interface between the water and the bottom. Transitory increase in turbidity during dredging and disposal with possible smothering of plankton and sessile benthic organisms; temporary oxygen sag during disposal and dredging.

4. Alternatives:

a. No-action; land disposal; ocean disposal of all material; and disposal of all material at Alcatraz.

5. Comments Received:

Soil Conservation Service, USDA U.S. Department of Commerce U.S. Department of Interior U.S. Department of Housing and Urban Development Environmental Protection Agency The Resources Agency, State of California City of Oakland FINAL ENVIRONMENTAL IMPACT STATEMENT OAKLAND INNER HARBOR ALAMEDA COUNTY, CALIFORNIA

TABLE OF CONTENTS

Paragraph Subject Page

1 PROJECT DESCRIPTION 1

a. Authority 1 b. Proposed Project 1 c. Benefit-to-Cost Ratio 2

2 ENVIRONMENTAL SETTING WITHOUT THE PROJECT 3

a. General 3 b. Tidal Data 3 c. Climate 4 d. Land Use and Development 4 e. Water Quality 4 f. Sediment Quality 5 g. Recreation 6 h. Biota of the Oakland Eatuary 6 i. Alcatraz Disposal Site 7 j. Ocean Disposal Site 7

3 ENVIRONMENTAL IMPACT OF THE PROJECT 8

a. Dredging Effects 3 b. Disposal Effects 9

4 ADVERSE ENVIRONMENTAL EFFECTS WHICH CANNOT BE AVOIDED SHOULD THE PROPOSAL BE IMPLEMENTED 12

a. Water Quality 12 b. Sediment-Water Interface Effects 13

5 ALTERNATIVES TO THE PROPOSED ACTION 13

a. No Action Alternative 13 b. Alternatives to the Proposed Action Concerning the Disposal of Dredged Materials 15 TABLE OF CONTENTS (Cont'd)

Paragraph - Subject Page

6 THE RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF MAN'S ENVIRONMENT AND THE MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY 15

7 ANY IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCE WHICH WOULD BE INVOLVED IN THE PROPOSED ACTION SHOULD IT BE IMPLEMENTED 16

8 COORDINATION WITH OTHER AGENCIES 16

a. Public Participation 17

TABLES

Number Title

1 REPORT OF TESTS FOR POLLUTANTS IN CORE SAMPLES

2 ENVIRONMENT PROTECTION AGENCY TENTATIVE CRITERIA FOR CHEMICAL ANALYSIS OF DREDGED MATERIAL

PLATES

Number Title

1 PROJECT AREA MAP 2 DISTRIBUTION OF MERCURY 3 DISTRIBUTION OF LEAD AND COPPER

BIBLIOGRAPHY f i n a l ENVIRONMENTAL IMPACT STATEMENT OAKLAND INNER HARBOR ALAMEDA COUNTY, CALIFORNIA

1. PROJECT DESCRIPTION

a * Authority. The information in this final report is furnished in accordance with Section 102 of the National Environmental Policy Act of 1969, Public Law 91-190. The Oakland Inner Harbor Project, Alameda County, California, was authorized by the River and Harbor Act of 1962 under Public Law 87-874. Criteria for Bay and ocean dis­ posal expressed in this environmental impact statement comply with California Regional Water Quality Control Board (RWQCB) Resolution Ho. 72-15 (Amendment of Policy with Respect to Regulation of Dredged Spoil Disposal in the San Francisco Bay Region) adopted 28 November 1972.

b. Proposed Project. Deepening of Oakland Inner Harbor has been divided into two phases (Plate 1). The first phase includes the reach from the Inner Harbor Entrance (Mile 0.4) to Fortman Basin (Mile 5.9), and the second a continuation to the Park Street Bridge (Mile 7.3). Phase I is recommended for immediate construc­ tion and is the subject of this statement. Phase II work will be considered at a later date. Oakland Harbor has received a number of deep-draft navigational improvements authorized by Congress since 1874. The proposed project calls for deepening of the exist­ ing channel from 30 to 35 feet. Many larger modern vessels which now serve the port are required to wait for high tide before enter­ ing the existing channel. Deepening of the Inner Harbor will alle­ viate this problem.

Phase I of the proposed deepening of Oakland Inner Harbor calls for deepening of the Inner Harbor from 30 to 35 feet with two feet of overdepth dredging. The proposed work will be a continua­ tion of Oakland Outer Harbor with an existing depth of 35 feet. The Inner Harbor consists of an improved estuary channel 600 to 800 feet wide and a turning basin at the eastern terminus.

The proposed improvement will extend from the Inner Harbor Entrance (Mile 0.4) along the main inner channel and tidal canal to Fortman Basin (Mile 5.9), and include the triangular area and turn­ ing basin in Brooklyn Basin. No dredging will be performed closer than 75 feet from the pierhead line on each side of the waterway and closer than 75 feet along a 1,300-foot spur into the north channel of Brooklyn Basin. Approximately 2,150,000 cubic yards of dredged material will be dredged by clamshell under contract. In order to observe recent water quality restrictions as set forth by RWQCB, dredge material samples were taken and tested (Table 1, and Plate 1). The test results were used to delineate areas in which sediments were found to be "Polluted with Heavy Metals" using the Environ­ mental Protection Agency tentative criteria for determining accepta­ bility of dredged material disposal to the Nation's waters. Sta­ tions 2D-13, 2D-14, 2D-15, and 2D-17 are in exceedance of these "Heavy Metal" criteria. In conformance with RWQCB policy in ref­ erence to the regulation of dredge material disposal in the San Francisco Bay Region, dredge material from areas delineated as "Polluted with Heavy Metal" will be placed on barges earmarked for ocean disposal. The material which conforms with the criteria will be barged to the Alcatraz Disposal Area. Material from two reaches of the proposed project will require ocean disposal; (1) material from an area which is bounded by a line midway between stations 2D-15 and 2D-16 and extends to the upstream limit of the project, (2) material from an area which extends from a line midway between sta­ tions 2D-16 and 2D-17 to a line midway between stations 2D-17 and 2D-26, (delineated on Plate 1).

The respective separation of material will result in 1,250,000 cubic yards being placed at the Alcatraz disposal site and 900,000 cubic yards which exceed heavy metals criteria being placed at sea beyond the 100-fathom isobath. The ocean disposal site is approximately 30 miles out from the Golden Gate, eight miles south of the Farallon Islands. The area to be dredged is State-owned submerged lands deeded to the city of Oakland and the Alcatraz disposal site is also State-owned submerged lands.

A review of the maintenance record for the existing 30-foot depth project for the 1956-1968 period indicates an average mainten­ ance dredging rate of 430,000 cubic yards annually. The estimated incremental annual shoaling at the 35-foot depth is 80,000 cubic yards. Upon completion of the 35-foot depth, local interests are required to maintain the slips and berths to project depth of 35 feet, resulting in a volume of 30,000 cubic yards annually. The additional Federal maintenance contribution is 50,000 cubic yards for channel maintenance to the 35-foot depth.

c. Benefit-to-Cost Ratio. The overall authorized project for deepening Oakland Inner Harbor is economically justified at an esti­ mated cost of $8,300,000 of which $7,200,000 would be borne by the Federal Government. Incremental analysis shows, however, the con­ struction should be performed in two phases. Immediate construction (Phase I) should be undertaken between the Inner Harbor Entrance (Mile 0.4) and Fortman Basin (Mile 5.9) at an estimated cost of $4,030,000 of which $3,474,000 would be Federal costs. Expected total average annual benefits from Phase I construction are $619,000 and total annual costs are $277,000 for a benefit cost ratio of 2.2 to 1.0. Phase II, construction from Fortman Basin to Park Street Bridge, should be deferred to a future date as no benefits have been estimated to accrue from this work.

2. ENVIRONMENTAL SETTING WITHOUT THE PROJECT

a. General. Since about 1850 development of San Francisco Bay shores has for the most part taken place on an individualistic basis with little thought as to overall effect on the environment. The California Legislature created the San Francisco Bay Conserva­ tion and Development Commission (BCDC) to regulate filling, dredg­ ing, and development of the bay. Oakland Harbor is a major shipping port for California and is recognized as such by the BCDC Bay Plan. The Bay Plan calls for an overall regional port development plan and substantial redevelopment of existing facilities to meet future needs.

Oakland Harbor is located on the eastern side of San Francisco Bay about 8.7 miles from the Golden Gate. The harbor occupies the waterfront of the city of Oakland and about half of the waterfront of the City of Alameda. The Oakland Harbor location with reference to the San Francisco Bay system is shown in the vicinity map on Plate 1. Oakland Inner Harbor, formerly known as San Antonio Estuary, is the seven-mile deep-water channel with a depth of 30 feet that provides 13.2 miles of waterfront between the cities of Oakland and Alameda. At Mile 6 in the estuary, the Inner Harbor branches around Government Island with a north and south channel. The main 30-foot-deep water­ way is on the south side of the island and is referred to as the south channel. The north-branching channel, known as Brooklyn Basin North Channel, is 25 feet deep. The water area in the vicinity of the island is known as Brooklyn Basin.

b. Tidal Data. The datum for the depths shown on the United States Coast and Geodetic Survey charts of the harbor and used in this report is mean lower low water, abbreviated MLLW. Tidal ranges at the Outer Harbor, Grove Street, and at Park Street Bridge are shown in the following tabulation. The lowest estimated tide is 2.5 feet below mean lower low water.

Location Mean Range Diurnal Range Maximum (ft.) (ft.) (ft.)

Outer Harbor 4.3 6.0 11.0

Grove Street 4.6 6.3 11.0

Park Street Bridge 4.6 6.3 11.0 c. Climate. The prevailing winds of the region are from a westerly direction. Records show winds of gale force, or greater, have occurred only rarely in the Bay Area. Heavy fogs occur on the average of 21 days per year. These fogs impair visibility for navi­ gation at Oakland an average of less than 100 hours per year. Freez— ing temperatures rarely occur and no snow or icing conditions are encountered. Rainfall averages about 20 inches annually, generally occurring from October to Hay. The Inner Harbor is protected from direct exposure to winds and storms.

d* Land Use and Development. Oakland is one of five commercial deep-draft harbors which make San Francisco Bay one of the most impor­ tant shipping centers of the Facific Coast. This harbor serves not only the Bay.Area but also northern California and a considerable part of the United States. About one-half of the total tonnage is foreign and the remaining half is coastal and Hawaiian. The Inner Harbor con­ tains facilities for off-loading steel imports and loading scrap metal exports. Modern container storage and loading facilities as well as canned food shipment handling facilities are situated there.

ihe major industrial area contiguous to Oakland Harbor extends from Berkeley on the north to Fremont and Newark on the south, and to Pleasanton and Livermore on the southeast. The two principal cities adjoining the harbor are Oakland and Alameda. Both of these cities are industrial and military bases and Oakland is an established world- trade shipping port. Much of the land use in Alameda County is devoted to the shipping industry and includes manufacturing plants, warehousing and distribution facilities, the Oakland Army Base, the Naval Supply Center, the Alameda Administration Center, and the Alameda Naval Air Station. Industrial activities located in the harbor area include major food-processing, transportation-equipment manufacturing and metal-fabricating plants, primary metal plants, shipbuilding and repair yards, chemical plants, glass and paper products manufacturing plants. There are also grain mills and storage elevators, public utility power and fuel ghs stations, oil and gasoline depots, truck freight-line terminals, and moving products manufacture and distribution centers situated there.

The extensive arable lands tributary to Oakland and Alameda by rail and highway embrace the greater part of the Central Valley of California. The immediate Bay Area community is well advanced in agricultural development with products such as fruits, nuts, dairy foods, vegetables, livestock, and poultry predominating.

e. Water Quality. Water quality of the Oakland Inner Harbor is considerably below that of Central San Francisco Bay. Many factors contribute to this disparity in water quality. Foor circulation plus addition of waste materials generated within the area are major factors. Sewage effluent discharges from ships within the harbor and releases from storm sewers during periods of high runoff have also contributed to the problem. Median coliform counts have been recorded as high as 620 organisms per milliliter of water during winter months in some areas of the Oakland Estuary*, and dissolved oxygen is periodically as low as 5.2 milligrams per liter of water.

Seasonal and diurnal temperature fluctuations are more extreme within the Oakland Inner Harbor Area than in the main body of Central San Francisco Bay. In the more stagnant areas of the Inner Harbor, an oil residue is often visible on the water surface.

The turbidity of San Francisco Bay is lowest in the central portion (which includes the Oakland Estuary), and varies between 7 and 17 mg/1. Turbidity is highest during March-April-May, and lowest during July.

f . Sediment Quality.

According to 12 borings made in Oakland Inner Harbor along .the existing channel alignment (Plate 1), the upper 6 feet of sub­ soil consists of silty-clay with lenticular deposits of fine sand. The silty-clay, or bay mud was predominant in all samples from 0 to 2 feet in depth with the exception of Station 24 in which the sample contained 83% fine sand.

Twelve core borings were made in Oakland Inner Harbor along the existing channel alignment (Plate 1) on 13 through 18 January and 12 February 1971 and were delivered immediately to the Corps of Engineer South Pacific Division Laboratory in Sausalito, California. To classify the samples according to pollutant content, test results for Volatile Solids, Chemical Oxygen Demand (COD), Total Kjeldahl Nitrogen, Mercury, Lead, and Zinc are included in Table 1. The tests were preformed as follows:

1. Volatile Solids - Organic, loss on ignition, Standard Methods, 12th Ed.

2. Chemical Oxygen Demand - FWPCA Methods for Chemical Analysis of Water and Wastes 1969 (saline water).

3. Organic Nitrogen (Kjeldahl), Standard Methods for Examination of Water and Wastewater, 12th Ed. 1965.

4. Mercury - Hatch and Ott Method, using Coleman 50 Mercury Analyzer.

* East Bay Municipal District, 1970. Coliform organisms are an indi­ cator of human waste in water. The bacteriological quality standards of the San Francisco Bay Regional Water Quality Control Roard specify that 80 percent of the water samples taken at a particular station must have coliform bacterial counts less than 10 organisms/ml. before the water is considered safe for water contact sports. 5. Lead - FWPCA 1969, Atomic Absorption, Nitric Acid Soluble.

6. Zinc - FWPCA 1969, Atomic Absorption Methods, Hydro­ chloric Acid Soluble.

In addition tests were preformed for which no criteria have been developed.

Test results indicated that four of the twelve stations were "Polluted with Heavy metals" according to EPA criteria. Four stations were high in mercury, and four exceeded the criteria for lead. These results provided a basis for the delineation of areas "Polluted with Heavy Metals".

g. Recreation. The Oakland Inner Harbor is well fitted to needs of recreational boating. Approximately 1,330 berths are pro­ vided. This represents 58 percent of all recreational boating moorages in Alameda County. These are located at Jack London Square, Brooklyn Basin and scattered along the central to eastern perimeter of Alameda. The Port of Oakland Shoreline Development Plan of November 1968, calls for two additional marinas on the Brooklyn Basin perimeter. Development of marinas along other stretches of the Inner Harbor is precluded by use and/or zoning for industrial and shipping activities. Three areas are set aside for fishing. No historical or archeological sites noted on the "National Register of Historic Places" will be affected by the project.

h. Biota of the Oakland Estuary. In general, Oakland Inner Har­ bor is heavily committed to commercial activities. Dredging and harbor related activities have created physical stresses upon marine flora and fauna for almost 100 years. The biota at present lacks both abundance and diversity.

Phytoplankton (free-floating microscopic plants, algae) forms the principal plantlife in the estuary. The shallow muddy floors of the Inner Harbor support growths of some larger algal forms: Chiefly Bryopsis corticulans, Ulva sp., and Gracilaria sjoestedtli.

The Oakland Harbor Area is not rich in bottom fauna. Some locations in the harbor were dredged as early as 1874. Annual main­ tenance dredging of the 30-foot channel causes the bottom community to be in a constant state of flux. Many marine invertebrates have a free-floating larval stage which, after a period, reach a stage at which they migrate to the bottom. By this method, bottom organisms reestablish in areas that have been dredged. However, the overall productivity of a community is reduced because of the time require­ ment for recovery and limited number of organisms with the ability to adapt to such an environment. Historically, annual maintenance dredging and the heavy pollution associated with commercial ship­ ping have resulted in a relatively unproductive biotic regime in the harbor. Some Coelenterates, Annelids, a few Bryozoans, and Arthropods still inhabit the estuary. The most predominant inver­ tebrates are gaper and little-neck clams and ghost shrimp.

At least 25 species of fish, mostly non-game species, may on occassion be found in the harbor (Alpin, 1966). These include three species of shark, and two species each of rays and smelt. The game- fish striped bass and American shad are occassionally taken. The most predominant species are shiner perch and pile perch. Fish popu­ lations are relatively low, due mainly to poor water quality and lack of foraging material.

The Oakland Estuary is not an important wildlife area. In some of the algal growth near the southern reach of the estuary, one may find a limited number of shorebirds, diving ducks, grebes, gulls and cormorants at low tide. However, the lack of marshy habitat in the project area combined with a density of urban and industrial develop­ ment limits wildlife populations.

i. Alcatraz Disposal Site. Because of tidal flushing, the Central Bay has the highest water quality within the bay system. The benthic community is healthy and displays a high diversity. The disposal site just south of Alcatraz Island is not, however, typical of the aquatic environment found in the Central Bay. The area is subject to heavy scouring activity due to high tidal vel­ ocities. The area ranges from 122 to 164 feet in depth and the bottom sediment is composed predominantly of sand. Heavily scoured sandy areas seldom support significant benthic populations. The physical features of the area, however, make extensive chemical or biological sampling difficult.

j . Ocean Disposal Site. The ocean bottom at 600 feet (100 fathoms) ranges from mud to fine, hard-packed sand. The great depth of this disposal area aids in dispersion. The tidal currents at the ocean site are not as strong as those found in the Alcatraz disposal site. However, the great depth of this disposal area aids in the dilution and dispersion of dredged material which is released on the surface.

A marked midsummer upwelling and a downwelling in the winter when winds are from the southwest exists at the ocean disposal site. The California current and counter-current are the dominant influence on the area. Temperatures of surface waters seldom vary more than 9#C. during the year and salinity approximates 32.5 parts per thou­ sand. Salinity increases with depth in the disposal area and when combined with upwelling, a marked seasonal variation in salinity occurs. 3. ENVIRONMENTAL IMPACT OF THE PROJECT

a. Dredging Effects. There will be a disturbance of bottom sediments. Turbidity will be kept to a minimum during dredging and will be tested with an Imhoff Cone. Dissolved oxygen measurements will be undertaken by the Winkler Method and by continuous monitoring equipment during dredging. Dredging will be coordinated with the U.S. Fish and Wildlife Service and State Department of Fish and Game, the Regional Water Quality Control Board, and the Environmental Protection Agency.

Future maintenance dredging over the long-term will necessitate periodic disruption of benthic organisms in dredged channels and in the disposal sites. This will be the subject of a separate environmental impact statement when such dredging is envisaged (upon completion of the deepening project).

The principal short-term ecological effects of the proposed dredging are as follows:

(1) Removal of the original interface between the water and the bottom. With the exception of burrow worms and molluscs, life along the muddy bottom is limited to occasional crabs, starfish, and benthic scavengers. The absence of a stable bottom hinders attachment of the more divergent forms of marine life. Occasional oil spills in the estuary further reduce fauna and wildlife diversity. The water- mud interface will be affected by dredging. This effect should be localized and of short duration, since dredging will open a new face of the same sediment type.

(2) Removal of deeper substrate material, which may have housed burrowing organisms. Dredging will remove burrowing organisms native to the area. A period of months will be required for these localized populations to reestablish. Organisms dependent on these forms for food will also be temporarily displaced.

(3) Release of sediments and of adsorbed chemicals into the water. Chemical compounds are frequently accumulated in sedi­ ments, where they remain trapped in interstital water or physically associated with the sediment particles. These may include heavy metals, pesticides, nutrient salts and many other materials. The effects of stirring, partial release and redistribution may vary from growth stimulation by nutrient to toxicity from poisons. Thus, re­ leased metal cations and organic materials may result in the increase of algal populations which in turn may decrease the dissolved oxygen levels of portions of the estuary. The effect could be a decrease in fish populations there. Sediment analyses indicate an exceedance of RWQCB standards for some elements tested (Table 1 and 2). Nonrelated dredging could over the short-term reduce dissolved oxygen levels in the dredging area, remove benthic organisms over the area to be dredged, and increase turbidity which is detrimental to fish production.

Dredging activities need not affect the City of Oakland’s Lake Merritt Recreation and Wildlife Area because the lake is equipped with gates and pumps to exclude tidewater from the Oakland Estuary.*

Specifications for the maintenance dredging work require that the contractor not pollute the waters of the harbor with fuels, oils, or other materials and that he comply with all Federal, State, and local regulations concerning pollution. The contractor will also be responsible for controlling excess turbidity and disposal of any materials, wastes, effluent, trash, garbage, oil, grease, etc. in order to minimize wildlife loss by controlling levels of toxic wastes. Specifications indicate that the dredge operator will monitor turbidity levels with an Imhoff Cone and dissolved oxygen levels by the Winkler Method and by continuous monitoring. No adverse effects on rare or endangered species are expected to result from the proposed dredging.

Dredging will take place on State tide and submerged lands granted by the legislature to Oakland and Alameda, while disposal will be on ungranted tide and submerged lands at Alcatraz and at sea. Dredg­ ing has been coordinated with the State Department of Fish and Game and the U.S. Bureau of Sport Fisheries and Wildife to minimize the effect on fish in the bay or at sea, and wildlife on land.

b. Disposal Effects.

(1) General. The environmental effects of dredged material disposal within marine and estuarine waters have been the subject of intensive research in recent years. Some of the major considerations have been:

(a) There is some impact ot suspended sediments on photo­ synthetic organisms. The suspended particles absorb and reflect light, therefore, the depth light penetrates the water is inversely proportional to sediment concentration. The light available to photosynthesizers is likewise reduced. When light falls to an intensity below 200 to 500 foot candles (saturation intensity for most algae) reproduction is reduced. (Sorokin and Krauss, 1958). The temporary turbidity accompanying disposal of dredged material will affect algae. Also, some loss to plankton may also occur through flocculation. Some scientific evidence indicates that silt can adsorb plankton and carry it to the bottom. At present the threat of over-production of algae is a greater problem than inadequate growth conditions.

* Burress, Rex E., Parks and Recreation Dept., City of Oakland, Personal Communication, Jan 1973. (b) There is evidence that fish populations, for at least some period of time, will be reduced in disposal areas. Whenever possible, fish avoid turbid waters. They are not equip­ ped with long, feathery mastigobranchs, or gill cleaners, like the crab, so they must depend on other means to remove suspended matter from their gills. To avoid clogging their gill system, fish rely on a free flow of water through their gill chambers, the production of mucous, and an intermittent violent release of water or coughing. Long periods of high turbidity can cause gill damage (thickening of the cells of the respiratory epithelium and fusion of adjacent lamellae). Some fish are basically sight feed­ ers and murky water impairs their quest for food. Many experiments dealing with the effects of turbidity on fish have been plagued with specimen mortality due to diseases. It was eventually pos­ tulated and well substantiated that, in fact, increased turbidity did lower the fish's resistance to microorganisms. Silt particles have an adsorptive capacity for heavy metal ions and some chemical substances such as chlorinated hydrocarbon pesticides. When silt particles containing these substances come in contact with the gills of fish, there occurs a chemical transference, due to the absorptive powers of the basic gill structure and the highly sol­ uble character of the chlorinated hydrocarbons. Conclusions reached in preliminary studies have indicated that fish have ac­ cumulated pesticides in direct proportion to the degree of turbid­ ity existing in their habitat.

It is doubtful, however, that fish mortality actually occurs in disposal areas. Turbidity in disposal areas is only a momentary phenomenon. To kill fish within several minutes, (Jones, 1964) tur­ bidity levels would probably have to reach 175,000 to 200,000 ppm (Highest turbidities recorded within disposal plume - 2,000 ppm, Fish and Wildlife Service, Report Nov 1970). In areas slow to recover after spoiling, however, fish may be secondarily eliminated by the environmental stress placed upon other components of the ecosystem.

(c) Disposal of dredged material causes a momentary oxygen sag. The silt particles and organic acids contained in dredged material absorb available oxygen when released.

(d) Disposal may add nutrients to the disposal site which have bio-stimulatory properties.

(e) Disposal may release toxic substances and heavy metals into the marine environment. Chronic exposure to low levels of these metals eventually becomes lethal to fish and other organisms. Ingestion of food chain organisms which have been contaminated by heavy metals compounds the the accumulation problem. Tbe lmPact of disposal on local estuarine or marine communities is dependent on several factors. The quantity and quality of dredged material, as well as the season of operationjmust be considered. The nature and location of the disposal site, its resident biological pop­ ulation, and its depth and current characteristics are also critical.

Criteria concerning estuarine and marine disposal. Using tentative EPA guidelines, the RWQCB h-s applied the following interim ~ *I|ia't0^be U?e? fcr deterninin8 method of disposal of maintenance dredging5 5 material4 in San Francisco Bay:

If the material does not exceed the guidelines for organic matter or heavy metals (lead and mercury), one of the five local sites within the bay area would be specified.

If the material exceeds the guidelines in organic matter but conform to heavy metal guidelines, the Alcatraz disposal site or the 100-fathom isobath at sea must be used.

If the material exceeds the guidelines for the heavy metals (lead and mercury), it must be deposited in a land disposal site when available. If no suitable sites are available, alternate project dis­ posal sites are considered for disposal on a case-by-case basis by the Board. 3

Sediment analyses show that Oakland Inner Harbor sediments aJe^uighr.fn or8anlc matter and he^vy metals (Tables 1 and 2). Four of the thirteen samples station were high in lead, and also exceeded the mercury criteria. The analysis indicates that some of the Inner Harbor sediment would be classified as "polluted in organic matter" and some as "polluted in heavy metals (lead and mercury)." Ocean disposal of the latter and Alcatraz disposal of the former was stipulated by the RWQCB. For those cases where heavy metals are in excess (900,000 cu./yd.) ocean disposal is required. iLeT^ mentS limiteci to unpolluted or polluted organics conforming to RWQCB criteria (1,250,000 cu.yd.) will be placed at Alcatraz.

Additional results from tests for lead, copper, and mercury were obtained by the U. S. Geological Survey for the entire Bay Area. The results are depicted two maps showing test results and location of samples (Plates 2 and 3).

(3) Disposal at Alcatraz.

Corps of Engineers' Bay Model sedimentation and shoaling tests indicate that 48% of the 1,250,000 cu.yd. of material proposed for de­ position at the Alcatraz disposal area will move from the bay system to the ocean via tidal circulation. Approximately 28% of the material will be re-circulated and deposited in the bay between the Oakland Bay Bridge and a line running east from San Francisco International Airport. Ap­ proximately 21% of the material will be deposited between the Oakland Bay Bridge and the San Pablo Strait. The remaining 3% of the material w*11 be dispersed to the South Bay and north of the San Pablo Strait in the North Bay. As previously outlined the release of sediments and of adsorbed chemicals into the water could have adverse effects through­ out the water column. Suspended sediments can clog and damage the gills of fish, reduce photosynthetic production, and reduce the buoy­ ancy of eggs of marine fauna. As they settle, the sediments can create soft bottom layers. Such sediments, however, frequently occur naturally in estuaries such as San Francisco Bay and coastal waters, and many successful species of these areas can tolerate considerable quantities of fine material. For example, as silt is deposited, some burrowing polychaete worms flourish where other organisms are smoth­ ered. Typically, during June to July, when bottom sediments are naturally deepest in the Bay, the larval forms of these organisms increase twenty-fold. The deposition of dredged material at Alcatraz during summer months will tend to favor these tolerant organisms. However, because of the wide dispersion of material released in the disposal area and the fact that sediments are naturally deepest in the Bay during June and July it is doubtful that there will be a significant changes in the biota of the Central Bay associated with the disposal process.

The newly designated Golden Gate National Recreation Area encompasses Alcatraz Island and the area off shore of the island for a distance of approximately .25 miles. The boundaries of the Alcatraz disposal area overlap a portion of the offshore limits of the recrea­ tion area. Dredged material disposal will not interfere significantly with the recreational usage of this off-shore area.

(4) Ocean disposal at 100 fathoms.

Because of the presence of heavy metals beyond acceptable levels in some sediment samples (see Table 1 and Plate 1) approxi­ mately 900,000 cu.yd. of material will have to be deposited in the marine environment at the 100-fathom line approximately 30 miles seaward from the Golden Gate to comply with RWQCB criteria. The ocean has a limited capacity to assimilate pollutive substances, but it does provide many times the dilution capabilities of the bay. Ocean dis­ posal has an added advantage in that it removes virtually all the dredged material from the bay system and does not allow recirculation of these sediments.

4. ADVERSE ENVIRONMENTAL EFFECTS WHICH CANNOT BE AVOIDED SHOULD THE PROPOSAL BE IMPLEMENTED

a. Water Quality. The project will involve both dredging and disposal operations. The dredging process does not have a notice­ able long-range impact on water quality. As previously discussed dredge disposal does have a temporary effect on turbidity levels in a localized area. The upgrading and enforcement of water quality standards regard to vessel operation within the bay is improving. Vessel operators are required to refraim from polluting the harbor with fuels, oils, trash, and other materials, and to comply with Federal, State and local regulations concerning water pollution. This im­ provement can be expected to offset any increase in water pollution resulting from increased harbor usage.

b * Sediment-Water Interface Effects. Removal of the original interface between the water and the bottom which is frequently an area of high biological activity could have an effect on benthic fauna. However, Oakland Inner Harbor does not have a rich and diverse faunal population. The absence of a stable bottom hinders attachment of the more divergent and exotic forms of marine life.

Removal of deeper substrate material, which may house bur­ rowing organisms, will result in temporary loss of these organisms. Annual maintenance dredging specified for the Inner Harbor removes burrowing organisms native to the area. A period of months passes before these populations reestablish. Organisms dependent on such forms for food will be displaced to adjacent areas. This effect should be localized and of short duration since the dredging will open a new face of the same sediment type.

Release of sediments and of adsorbed chemicals into the water could have adverse effects throughout the water column. Sus­ pended sediments can clog and damage the gills of fish, reduce photosynthetics, production, and reduce the buoyancy of eggs of marine fauna. As they settle, the sediments c m create soft bottom layers which are uninhabitable for many benthic species. Such sed­ iments frequently occur naturally in estuaries such as San Francisco Bay and coastal waters, and many successful species of these areas can tolerate considerable quantities of fine material. The possi- damage are greatest when large quantities of sediments are released where they will move onto and cover rich plant commun­ ities or other areas of unusual value.

5. ALTERNATIVES TO THE PROPOSED ACTION

a * No-Action Alternative.* There are presently 24 deepwater ship berths on the Inner Harbor Channel plus 14 berths at the Oakland Naval Supply Center served by the outer portion of the channel. With­ out the project, some of these facilities will soon face obsolescence due to inaccessibility to the larger deeper draft vessels. At present, the major facilities affected are located within the Port of Oakland shore jurisdiction. The Ninth Avenue steel terminal, the Seatrain container facility and a scrap metal facility are the major facilities relying on the dredging of a deeper channel.

* Adapted From: Cheney, Michael, Associate Engineer, Planning. Dept., Port of Oakland, Calif., Personal Communication, Jan., 1973. Container ships, which were built on converted T-2 and C-3 hulls, are now in service in the Oakland Inner Harbor, but are due for replacement by newer-type container ships, such as the C-6's and the C-7's, with normal load drafts of 28 and 30 feet. Further, the container terminal is being enlarged from one berth to four berths. Bulk carriers with cargoes of scrap and steel shapes either originate or terminate their sailings at Oakland Inner harbor at drafts of 30 feet or greater. The bulk carriers now in service are similar to the newer ships expected in the future. The Inner Harbor serves primar­ ily foreign breakbulk carriers, which are in the European and South American trades. Most of the breakbulk vessels now call at an aver­ age draft of 26 feet. The reason for this situation is that Oakland is an intermediate port of call for those ships in the above-mentioned trades. These vessels first unload at either the Port of Los Angeles or Long Beach before continuing to Oakland and northwest ports. By 1975 the 12,000 dead weight ton (d.w.t.) combination ship is expected to be in service on the European and South American trade routes. These vessels, when minimally unloaded at a port in Southern California, will require 30 feet of draft upon arrival at Oakland. Added to the almost fully loaded 12,000 d.w.t., carrier port calls are the breakbulk ships that come directly to Oakland Inner Harbor at their maximum draft of 30 feet. These types of carriers are estimated to constitute one-third of the total port calls. Total cargoes - container, general and bulk - that would benefit from a deepened Inner Harbor to 35 feet will increase from 1.0 million tons in 1971 to 6.5 million tons in 2025. With the absence of the project, the container and new steel tonnage, shipping will probably be lost. Of the 2,850,000 revenue tons shipped in 1971 in the Port of Oakland jurisdiction portion of the harbor, 1,300,000 tons were sand and other bulk cargoes and 1,500,000 tons were containerized cargo and steel. The payroll impact per ton has been estimated at $78.00 a ton for general cargo with $30.00 a ton as an average.

During the last quarter of 1972, the Inner Harbor of the Port of Oakland received 99 vessel calls. Of these, 40% has a draft of 30 feet or more and 100 percent drew 27 feet or more. With the recommended three feet draft leeway allowance, it can be seen that all the above vessels require a channel in excess of 30 feet and are thus affected by the project. Of container vessels built in 1972, worldwide, 84% have drafts greater than 27 feet. At present, vessels with drafts in excess of 27 feet must carry on restricted operations within Oakland Inner Harbor.

New super-container vessels (the SL-7, 940 foot length, 33 foot draft) are operated by -Sea Land Inc. in the Oakland Outer Harbor but not in the Inner Harbor. Shipping firms,in the Inner Harbor have no present plans for use of vessels in excess of 32 foot draft after completion of the project. Vessels which presently operate out of the Inner Harbor with draft capacities in excess of 32 feet consist of two scrap metal vessels, one each of 33 and 35 feet which presently carry partial loads or are operated only at high tide. The socio-economic impact of no-action in the Inner Harbor is also expressed in terms of employment. The number of persons in the shipping industry directly affected by the availability of a deeper channel is approximately 700 with a median suggested Income of $10,000. If the approximate 1,400 jobs in trucking, rail trans­ fer, and services (partially dependent on ocean shipping) are added, it can be seen that the total number of jobs affected is 2,100.

b. Alternatives to the Proposed Action Concerning the Disposal of Dredged Materials.

(1) Land disposal. Land disposal sites were not selected because suitable sites are unavailable in the vicinity of the proj­ ect. In May 1972, the Port of Oakland presented a study of land disposal of dredged materials from Oakland Harbor to the San Francisco Bay Regional Water Quality Control Board summarizing the feasibility of land disposal sites. After extensive investigation, the report concluded that currently there are no feasible land sites which are available to accept all or part of dredged materials from Oakland's harbors.

(2) Ocean disposal of all material. Ocean disposal of all dredged material would allow a greater dilution of dredged material. However, disposal of all material at the 100-fathom isobath increases project costs significantly without providing a measurable environ­ mental benefit.

(3) Disposal of all material at Alcatraz. According to the RWQCB Resolution No. 72-4, the Alcatraz disposal site isnot acceptable for the disposal of materials polluted in heavy metals. Approximately 900,000 cubic yards of the proposed dredging work consists of material classified as "polluted in heavy metals." Disposal of all dredged material at Alcatraz would significantly reduce project costs but would not be in compliance with existing criteria.

6. THE RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF MAN’S ENVIRON­ MENT AND THE MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY

Oakland Inner Harbor is primarily a commercial shipping center. Channel dredging will tend to promote greater use of the Inner Harbor for commercial shipping and warehousing purposes.

Recent innovations in cargo-handling methods and equipment and larger ships are prompting changes in berthing facilities worldwide. The availability of a deeper channel will allow use of the Inner Harbor by vessels of deeper draft. Larger areas of the Inner Harbor docks will be modified and finger piers and pilings will give way to marginal wharves. The Alcatraz and marine disposal sites were selected because they characteristically provide for optimal dilution of dredged material. Such dilution and dispersion greatly reduce the threat of smothering of benthic organisms as a result of disposal.

To determine any long-term effects of dredging and material disposal on the marine and estuarine environment and to develop dredging and disposal procedures to mitigate possible adverse effects on and/or enhance the marine resources of the affected areas, a comprehensive dredge disposal study for San Francisco Bay and Estuary was initiated in December 1970.

The objective of the Dredge Disposal Study is to provide answers for the many questions relating to the environmental impact of dredge material disposal and to provide information to mitigate the identi­ fied adverse affects. The completed study will identify the environ­ mental impacts and will permit the evaluation of dredging technology to mitigate identified adverse effects associated with continued dredging operations within San Francisco Bay.

7. ANY IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES WHICH WOULD BE INVOLVED IN THE PROPOSED ACTION SHOULD IT BE IMPLEMENTED

No irreversible or irretrievable commitment of resources is foreseen. Dredging would result in removal of 2,150,000 cubic yards of material and associated benthic organisms. Such removal would result in a change in species diversity and numbers. However, present populations are small and lack diversity. Thus, no irreparable im­ pact on resources is foreseen.

The marine community at the ocean disposal site will be changed slightly as a result of disposal with its attendent smothering and effects on water quality. Fifty percent of the material disposed of at Alcatraz will remain in the bay system. Since the material de­ posited will be non-toxic in heavy metals, no irreparable damage to organisms in the bay is expected. The benthos affected will restore in time.

Increased shipping will result from the project. Appropriate enforcement of anti-pollution regulations involving ship wastes will combat possible water quality degradation.

8. COORDINATION WITH OTHER AGENCIES

This final environmental impact statement reflects the results of informal coordination with numerous government and private agen­ cies and is considered responsive to the criteria outlined in para­ graph 102 (c), Public Law 91-190. Data secured and/or developed through formal coordination measures incudlng public participation and specific review by Governmental and private entities are iden­ tified and summarized below. Copies of all comments received con­ cerning the proposal are attached. a. Public Participation. The environmental aspects of the proposed plan were thoroughly discussed and news releases were issued reporting public meetings and the availability of the draft environmental statement.

b. The following is a list of Governmental and private organ­ izations from which comments were solicited on the initial draft statement:

Maritime Administration, USDC Public Health Service, Region IX, DHEW National Park Servcie, Western Regional Office, USDI Bureau of Outdoor Recreation, Pacific Southwest Region Office, USDI Bureau of Sport Fisheries and Wildlife, Region 1, USDI National Marine Fisheries Service, USDC Department of Housing and Urban Development, HUD Environmental Protection Agency, Region IX U.S. Coast Guard, Western Area, USDT Twelfth Naval District, Department of the Navy The Resources Agency, State of California San Francisco Bay Conservation and Development Commission Association of Bay Area Governments City of Alameda County of Alameda City of Oakland Port of Oakland California Heritage Preservation Commission Board of Pilot Commissioners, San Francisco Bay Region Sierra Club National Audubon Society Save the Bay Association COAAST Ecology Center

Comments received are summarized below and copies of the replies are attached to this Environmental Impact Statement.

(1) Department of Commerce, Assistant Secretary of Commerce.

Comment: The need for the project would be better eval­ uated if the following questions were answered: (a) What percentage of shipping traffic will be affected by the project? (b) Will larger vessels be attracted which will have to wait for high tide to enter the port? (c) What is the draft of newly constructed container ves­ sels? Response. The Port of Oakland supplied the answers which were Incorporated In the statement, (a) Vessels negotiating a 30-foot channel require a draft of 27 feet or less. All vessels using the Port of Oakland's jurisdiction portion of the Inner Harbor during the last quarter of 1972 drew in excess of 27 feet, (b) Vessels requiring a draft greater than 35 feet are being operated by Sea Land Inc., but only in the Oakland Outer Harbor; no Inner Harbor firms have immediate plans for such vessels, (c) Of the container vessels built in 1972, worldwide, 84Z have drafts greater than 27 feet, which, allowing for the recommended 3 feet clearance, is greater than the capacity of the present Inner Harbor.

Comment; "Environmental setting without the Project.” The statement makes the comment that "This harbor serves not only the Bay Area, but alro Northern California and a considerable part of the Western U.S." It is suggested that the Statement is too restrictive and that the Statement read "This harbor serves not only the Bay Area, but also Northern California and a considerable part of the United States.

Response; This comment was considered valid and the ap­ propriate changes were made in this Statement.

Comment; "Water and Sediment Quality" — This paragraph alludes to the poor quality of the water in the area of proposed dredg­ ing. The coliform count is the only parameter quantified. It would be more meaniful if other water quality criteria were also measured.

Response; Quantitative data was added pertaining to dis­ solved oxygen which is periodically as low as 5.2 mg/1. (Often critical to fish and invertebrates). Quantitative data on turbidity was also added.

Comment; "Ocean Disposal" — The first paragraph refers to the ocean bottom habitat at the 100 fathom disposal site and to the rich invertebrate fauna of unknown diversity. The reasons for choos­ ing a disposal site which happens to support a rich benthic fauna should be given.

The third paragraph in the section on Ocean Disposal states that zoo- plankton concentrations reach seasonal highs of 300 parts per billion. Some explanation should be provided concerning the method (and the rationale for selecting the method) of determining zooplankton concen­ trations in terms of parts per billion rather than in terms of the num­ ber of organisms that are present in a certain volume of water.

Response; The 100 fathom disposal site is required by RWCQB Resolution 72-15. At the present time there is little specific informa­ tion available concerning the marine environment at the 100-fathom dis­ posal area. The information included in the Draft Statement concerning the physical and biological characteristics of the area was misleading. The information was adapted from a discussion of the California Current in Roads Fairbridge, Encyclope*''’ a of Oceanography. The subject informa­ tion has been omitted from this Statement because it implied that speci­ fic data was available on the disposal area. Comment; "Environmental Impact of the Proposed Action." Dredging Effects — The second paragraph in the section on "Removal of the original interface between the water and the bottom which is fre­ quently an area of high biological activity" is speculative, and we suspect the conclusions cannot be substantiated. The polluted mate­ rials removed from the dredged area are to be reintroduced at the dis­ posal sites. There will be dispersion in important rearing areas of polluted material that is now confined to the bottom sediments in an area of little value to fisheries resources. The net change in water quality conditions will probably not be an improvement, as implied in the statement. Finally, the meaning of the statement that "the produc­ tion of oxygen reducing algae in the estuary will be reduced thus providing better conditions for the game fish" should be clarified.

Response; Before preparing this Final Statement, a review of available data concerning biological activity in the benthic interface and oxygen production relative to the suspension of dredged material was undertaken. It was concluded that the subject statements made in the Draft Environmental Impact Statement were misleading if not inaccurate. The subject statements have been omitted from this text and additional information has been included concerning these issues.

Comment; "Any adverse effects which cannot be avoided." The statement is made that "Dredging of the channel should improve the flushing characteristics..." Allusion to the benefits that can accrue from dredging does not appear to be appropriate in a discussion of adverse impacts of the project.

Response; This comment has been considered and concurred with. The subject statement has therefore been eliminated from the impact statement.

Comment; "Alternatives to the Proposed Action." Deep­ ening of only a portion of the channel should be discussed as an alter­ native. Presumably, all vessels entering the Oakland Inner Harbor do not require deeper berths. Also, a discussion of alternative 100 fathom disposal sites should be provided in light of the high benthic productivity of the proposed ocean dumping site.

Response; The deepening of Oakland Inner Harbor involves essentially the improvement of a 6.9-mile reach of water way from its presently maintained 30-foot depth to the .35-foot depth as authorized by the River and Harbor Act of 1962 (Public Law 87-874). Because of a low benefit-cost ratio, the upper 1.4 miles of the project has been indefinitely postponed (Phase II). Phase I, (the western 5.5 miles), on the other hand, has a high benefit cost ratio (2.2 to 1.0). The proposed project is now considered as a single unit because present port activity is well distributed throughout the inner harbor, and because deletion of any incremental part would result in a corresponding incremental decrease in benefits.

The proportion of large ships utilizing the area of the Inner Harbor Indicates a need for dredging throughout Phase I as discussed under "ALTERNATIVES TO THE PROPOSED ACTION."

The reference in the Draft EIS to the "High Benthic Productivity of the Proposed Ocean Disposal Area" was in error. We know of no benthic study which has been conducted in or near the 100 fathom disposal area. The subject mate­ rial has been omitted from this Statement.

Comment: This section discusses coordination - of the draft statement, but not of the project. There is no indication whether the requirements of the Fish and Wildlife Coordination Act have been satisfied.

Response; The project authorizing document, House Document No. 353, contains letters from the U.S. Fish and Wildlife Service and the California Department of Fish and Game which state that they each believe that fish and wildlife resources will not be significantly affected.

(2) Environmental Protection Agency.

Comment: Some attempt should be made to,esti­ mate the long-term impact of depositing polluted dredge spoils in the open ocean. The assessment of long-term ef­ fects should take into account the aggregate volume of dredge spoil generated within the Bay each year. While there is a lack of primary research on the environmental impacts of polluted dredge spoils, the Corps of Engineers' studies in the New York Bight (The Effects of Waste Disposal In The New York Bight Final Report) indicate that toxic spoils have sig­ nificant, adverse impacts on fish and crustaceans. The Corps of Engineers might, therefore, wish to consider study­ ing the biological effects of the toxic spoils on pelagic and benthic organisms at the open ocean spoil site. Response; An investigation has been initiated by the San Francisco District Corps of Engineers on Dredge Disposal Study for San Francisco Bay and Estuary. The purpose of the Dredge Dis­ posal Study is to determine the effects of dredging and material disposal on the marine and estuarine environment and to develop dredging and disposal procedures to mitigate possible adverse ef­ fects on and/or enhance the marine resources of the affected areas. The study was begun in FY 1972 and is scheduled for completion by the end of FY 1974. Admittedly, the use of the 100 fathom disposal area is only an interim procedure specified by the RWQCB pending the outcome of ongoing studies.

Comment: If the disposal sites for these projects change as a result of the new regulations now being prepared by the California Regional Water Quality Control Board, San Francisco Bay Region, new impact statements should be prepared.

Response; In the event of a significant change in the scope of work or environmental conditions, an environmental impact statement will be reevaluated and a new or supplementary statement will be considered.

(3) U.S. Dept, of the Interior, Pacific Southwest Region.

Comment; We note that Lake Merritt and the entrance channel thereto, in the City of Oakland, is excluded from consider­ ation in the statement. We consider these waters to be an extension of the Oakland estuary; they are of substantial importance to both recreation and wildlife. Water quality degradation resulting from the proposed dredging activities could well extend into Lake Merritt. Scheduling of dredging should consider the seasonal pattern of rec­ reation and wildlife uses of the lake, as well as the considerable seasonal variations in water quality already existing at the lake and the potential for compounding those problems. All such activi­ ties should be coordinated with the appropriate State and Federal resource agencies.

Response; Oakland Inner Harbor dredging activities need not affect the Lake Merritt recreation and wildlife area because the lake is equipped with gates and pumps to exclude tidewater from the Oakland estuary. The city of Oakland has contracted its own dredging operations in Lake Merritt during the last quarter of 1972 to remove silt deposited from city street runoff and other freshwater inflow. A portion of this response has been incorporated into the Statement. Comment: The statement does not fully consider the secondary effects of spoil disposal within San Francisco Bay. Spoil disposal in the Bay contributes to annual sedimentation rates and augments dredging requirements at other locations. For example, the disposal of spoil at Alcatraz will cause suspended material to be moved seaward through the Golden Gate to settle in the channel across San Francisco Bar. This is an undesirable environmental action and should be discussed in the statement.

Response: Information on redistribution of sediments within the Bay following disposal activities was obtained from Corps Bay Model research data and is incorporated in the statement.

Disturbed bottom sediments which are destined to move seaward from the Bay System do not contribute measurably to the volume of material deposited on the Bar or Bar channel. The Bar and channel are comprised of littoral material, principally sand.

Comment: It is anticipated that there will be some improvement in the quality of water in Oakland Harbor as a result of removing sediments with a high concentration of heavy metals. However, it should be noted that in-water disposal will transfer these pollutants to different sites, possibly with adverse effects. Consideration should also be given to the possibility of water quality degradation which would result from increased harbor use.

Response: Additional information addressing possible water quality degradation as a result of in-water disposal and increased harbor usage has been included in this Statement. (Sections 3b. and 4a.)

Comment: The final statement should include a dis­ cussion of the geologic conditions of the project area as well as a lithologic analysis of the spoil material.

Response: Additional information concerning the sedi­ ments of the Inner Harbor area have been included in Sections 2d. and 2g. of this Statement.

Comment: We note that land disposal is listed as a possible means of spoil disposal. If, after further investigation, land disposal is selected, it will be necessary to conduct archeo­ logical, historical, recreational, and biological studies to determine the impact on these resources. Qualified personnel from research institutions or resource agencies should be employed to conduct these studies and their findings included in the final environmental state­ ment . Response: Land disposal sites were not selected due to lack of suitable sites in the vicinity of the project. In May 1972, the Port of Oakland presented a study of land disposal of dredged materials from Oakland Harbor to the San Francisco Bay Regional Water Quality Control Board summarizing the feasibility of land disposal sites. After extensive investigation, the report concluded that currently there are no feasible land sites are avail­ able to accept dredged materials from Oakland ship channels and harbors.

(4) U.S. Department of Agriculture; Soil Conservation Service.

Comment: With your plan for ocean disposal of all dredged materials, this project should have no impact on soil con­ servation programs or projects.

(5) U.S. Department of Housing and Urban Development, HUD.

Comment: We feel that some of the secondary socio­ economic and land use transportation effects were not adequately discussed. For instance, a more definite statement on the expected warehousing land uses expected by the dredging activities would be useful. Also, if increased shipping can be expected to result from the project, a discussion of the socio-economic effects would be in order.

Response: Additional information concerning socio­ economic and land use considerations has been included in Section 5a. of this Statement.

Comment: The environmental effects on the biota of the Oakland Estuary need to be amplified by a more definite state­ ment on the Phytoplankton relationship to the eco-system especially the "food chain".

Response: Additional information concerning phyto­ plankton's relationship to the eco-system has been included in Section 3b.(1)(a).

(6) The Resources Agency of California.

Comment: The Resources Agency has serious reservations regarding the long-term effect of placement within San Francisco Bay of large volumes of dredge spoil. We believe this Impact Statement is somewhat deficient in discussion redistribution of dredge spoil. We have recently reviewed several Environmental Impact State­ ments for maintenance and development dredging in San Francisco Bay where 5,000 to 200,000 cubic yards of spoil were to be placed at the Alcatraz Island disposal site. This proposal calls for additional spoil placement of more than one million yards of very fine-grained material, much of it polluted to some degree.

Because of the very strong tidal currents, most of the sediment is carried away from the disposal site. The report says about 50 percent of the spoil material leaves the bay system. The remaining 600,000 cubic yards (from this project) would be redistributed throughout the bay system, carried about by the currents until finding some quiet water to settle in, perhaps the Oakland Harbor. We question that this is the most efficient procedure. Alternative dredge spoil placement procedures have been considered. Other pro­ cedures appear to be required.

Response: Information on redistribution of sediments within the Bay was obtained from Corps' Bay Model research data and has been incorporated in Section 3b. in this Statement. A small pro­ portion of the material deposited at Alcatraz will find its way into Bay shipping channels. The majority of shoaling which occurs in Bay channels, however, is resultant of natural runoff, tributary flows which carry an annual sediment load of more than 4,000,000 cu.yds, and the constant natural processes of deposition and resuspension which accompany wind, waves, and tidal fluctuations.

(7) City of Oakland.

Comment: The effect of no action would materially a^f®ct the economic and employment base of this community and a requirement for either total land disposal or total ocean disposal of dredged material is not considered with the overall considera­ tions of economic benefits and environmental effects of the actions required to maintain a viable shipping center.

Response: Similar information has been included in this Final Statement.

Comment: Unreasonable disposal criteria for the dredged material would similarly have a strangling effect on Oakland and other East Bay cities. Therefore, it is our conclusion that the benefits of the project require its construction despite the minimal permanent or semipermanent environmental effects.

Response; Concur. BIBLIOGRAPHY

Aplin, J.A., "Biological Survey of San Francisco Bay," State of California, the Resource Agency, Department of Fish and Game, Marine Resources Operations, MRO Reference No. 66-, Menlo Park, October 1, 1966.

Davis, H. C., "Effects of Turbidity Producing Materials in Sea Water on Eggs and Larvae of the Clam" Mercenaria mercenaria, Biol. Bull.. 118(1): 48-54, 1960.

Einstein, H. A., & R.B. Krone, "Estuarial Sediments Transport Pat­ terns." J. Hydr. Div., HYZ, Proc. ASCE, pp. 51-59, March 1961.

Hedgpeth, Joel W., "Introduction to Seashore Life of the San Francisco Bay Region and the Coast of Northern California," University of California Press, 1967, 136 pp.

Krone, R. B., "Predicted Sucpended Sediment Inflows the San Francisco Bay System," Central Pacific River Basins Compre­ hensive Water Pollution Control Project, Federal Water Pollution Control Administration Southwest Region, Davis, September 1966.

Lossanoff, V. L., "Effects of Turbidity on Some Larval and Adult Bivalves," Proceedings of the Gulf and Caribbean Fisheries In­ stitute. 14th Annual Session, Miami, April 1962.

Schultz, E. A., "San Francisco Bay Dredge Spoil Disposal." Prepared for Presentation to the Committee on Tidal Hydraulics, 53d meeting, San Francisco, May 1965.

Smith, B. J. "Sedimentation in the San Francisco Bay System, California." Prepared for the Federal Interagency Sedimentation Conference, ICWR, Jackson, Miss. U.S. Army Engineer District, San Francisco, California, 1963.

Sorokin, C., and R.W. Krauss, "The Effects of Light Intensity of the Growth Rates of Green Algae," Plant Phys., 33: 109-113, 1958.

Storrs, P.N., R.E. Selleck, & E.A. Pearson, "A Comprehensive Study of San Francisco Bay," Third Annual Report, Sanitary Engineer­ ing Research Laboratory, College of Engineering, School of Public Health, U.S. Berkeley, SERL Report No. 64-3,

Fourth Annual Report, SERL Report No. 65-3, 1965.

Final Report, SERL Report No. 67-4, 1969.

Final Report, SERL Report No. 67-2, 1969. TABLE 1

REPORT OF TESTS FOR POLLUTANTS IN CORE SAMPLES OAKLAND INNER HARBOR

Sample Hole 2D-13 2D-14 2D-15 2D-16 2D-17 2D-19 2D-20 2D-21 2D-22 2D-23 2D-2 4 2D-25 2D-26 Totals Excavation in C.Y. 202,392 344,202 204,892 232,532 143,272 34,409 122,354 258,931 192,581 159,467 49,209 93,593 158,637 2,196,471 % of Total Exc. 9.214 15.671 9.328 10.587 6.523 1.567 5.570 11.789 8.768 7.260 2.240 4.261 7.222 100.000 C.O.D. Avg. % Dry Wt. 4.088 3.203 2.326 3.187 2.180 4.190 4.930 2.010 2.930 3.270 2.680 4.100 2.262 % of Total C.Y. 0.03767 0.05019 0.02170 0.00374 0.01422 0.02334 0.05812 0.01762 0.02127 0.00732 0.01142 0.02961 Total Avg. % Dry Wt. /-N 0.0703 0.0603 0.0269 0.0302 0.0254 H C 0.0165 0.0271 0.0348 Kjeldahl % of CL «H Total C.Y. B 60 0.00648 0.00945 0.00251 0.00320 0.00166 to X) 0.00135 0.00239 0.00279 0.00171 0.00060 0.00070 0.00196 w a)t-i 1 Q Pb Avg. 10-4% Dry Wt. 67.0* 53.0* 58.0* 48.0 59.0* 18.0 16.0 42.0 43.0 35.0 50.0 50.0 01 U-i 45.0 10-4% of Total C.Y. 6.2 8.3 5.4 5.1 3.8 •H O 1 . 0 1.9 3.7 3.1 0.8 2.1 3.6 . n CO 4J Hg Avg. 10-4% Dry Wt. O "H 1.36* 1.08* 1.60* 0.91 1.29* •H B 0.51 0.58 0.35 0.71 0.33 0.48 0.84 iH >H 0.89 10-4% of Total C.Y. 0.125 0.169 0.149 0.096 0.084 CL l-J 0.028 0.068 0.031 0.052 o. 0.007 0.020 0.061 Zn Avg. 10-4% Dry Wt * § 146.0 77.0 113.0 82.0 117.0 ■U fH 109.0 82.0 137.0 100.0 121.0 139.0 134.0 106.0 10-4% of Total C.Y. O

Remarks: Samples taken by San Francisco District Corps of Engineers 13-18 January and 12 February 1971.

* Sample classified as "Polluted With Heavy Metals" in accordance with Environmental Protection Agency tentative criteria and RWQCB Resolution No. 72-15. TABLE 2

ENVIRONMENT PROTECTION AGENCY TENTATIVE CRITERIA FOR CHEMICAL ANALYSIS OF DREDGED MATERIAL

Sediment in Fresh and Marine Waters Cone. % (dry wt. basis)

Volatile Solids 6.0

Chemical Oxygen Demand (COD) 5.0

Total Kjeldahl Nitrogen 0.10

Oil - Grease 0.15

Mercury lxlO-4

Lead 50xl0-4

Zinc standards currently under review by Environmental Protection Agency.

INTRODUCTION

Recent recognition that mercury in surfaca sediments in aquatic environamnts aay antar tha food chain through biologici activity Bakes it iaportant to evaluate the existing reservoir of aarcury contained in sediaents of aajor estuaries such as San Francisco Bay. Tha distribution of aarcury in aquatic sediaents is not well known (Klein and Goldberg, 1971> U.S. Geological Survey, 1970), neither are the processes or rates of procssses by which this toxic aaterial is raaoved froa the sediaent, nor how auch of such sediaent-associated aarcury aay eventually present a health hasard to man. A first stsp in evaluating this potential problea is to establish the amount of aarcury present. The accompanying aap presents the aost comprehensive data yet available for any aajor estuary. It is hoped that this information will help to stimulate a quantit tiva assesaaent of the potential hasard to man.

MERCURY DISTRIBUTION

The concentration of mercury in the estuarine sediaents can be considered froa several aspects. In Tabls 1, the aercu concentrations (in parts per million of dry weight of sediaent) are compared for all the sasples (199) collected within fou major segments of the estuary. In the table, the segments (bays) are listed in order of decreasing median aarcury concentr tion. If listed in order of decreasing average mercury concentration, Suisun Bay replacas San Pablo Bay as second highest.

Table 1.— Concentration of aarcury within four aajor segments of San Francisco Bay

Mercury concentration (d e b ) Bay Median Average Total Range Range of 70% of values Soutfci/ 0.25 0.37 1.60 - 0.04 0.54 - 0.13 San Pablo 0.19 0.28 1.20 - 0.04 0.42 - 0.06 Suisun 0.13 0.32 2.00 - 0.02 0.63 - 0.06 Central 0.13 0.18 0.75 - 0.04 0.26 - 0.08

1/ Calculations for the south bay exclude the high value of 6.43 ppm found in Islais Creek because it is abnormally high relative to the other values.

The concentration of sediaent-associated aarcury seams to reflect not only sources, but also three major hydraulic environamnts in the estuary. Hydraulic environments are primarily determined by interrelated physical properties, such as velocity of the water currents and the sedismnt grain sise. The highest aarcury concentrations are found in natural and ai ficial tributaries and along the bay marginal interasdiate concentrations occur in fine sedismnt (silt-clay) on the shoal areasi lowest concentrations occur in sediaent in the channels, where sand is abundant and currents are strongest.

Table 2.— Concentrations of aarcury in three aajor hydraulic environments in San Francisco Bay Msrcurv concentration (bom) Median Average Total Range Tributaries and margins 0.40 0.41 2.0 - 0.04 Shoals 0.21 0.24 1.1 - 0.02 Channsls 0.13 0.17 1.1 - 0.04

This general pattarn varies somewhat if bays ars considered separately. In Table 3 and Figure 1, the bays ars listed order of decreasing median concentration of aarcury in the tributaries and the bay margin. Heavily industrialised Suisun : ranks highest, south bay second and San Pablo Bay nearly 25t lower. Central bay is lower still, with a aedian concentrati of only about one quarter that of Suisun Bsy. In the shoal areas, the highest aedian concentrations occur in San Pablo, central and south bays. Mors measurements are necessary to characterise Suisun Bay shoals. In ths channels, the median o centration is highest in south bay, and only alightly lowar but approximately the saam in the other bays.

Table 3.— Concentrations of mercury (ppm) in three hydraulic environments within the four aajor segments of San Francisco Bay Tributaries and margins Shoals Channsls Suisun Range 2.0 - 0.04 0.15 - 0.02 1.10 - 0.04 Median 0.44 0.13 0.11 Average 0.60 0.10 0.13

South Range 6.43 - 0.13 0.95 - 0.08 1.00 - 0.04 Median 0.40 0.17 0.19 Average 0.51 0.25 0.23

San Pablo Range 1.2 - 0.06 1.10 - 0.11 0.42 - 0.04 Median 0.38 0.26 0.10 Average 0.49 0.32 0.13

Central Range 0.75 - 0:08 0.42 - 0.06 0.38 - 0.04 Median 0.10 0.21 0.10 Avarage 0.26 0.21 0.12

1/ These values were calculated from the range of 1.60 - 0.27 because 6.43 appears to be abnormally high.

DISTRIBUTION OF LEAD AND COPPER IN SURFACE SEDIMENTS IN SAN FRANCISCO BAY ESTUARY, CALIFORNIA by D. H. Peterson, D. S. McCulloch, T. J. Conomos, and R R. Carlson 1972

INTRODUCTION

«l « M i n g « n y toxic or potentially toxic chemical elements to the ocean environment at increasin, i l m n t ! t h f t ^ n ^ n J i r 1^ ^ °rdr t0 di*tingui>h clearly the elements that are potential problems laments that can be neglected, considerable information is needed about the temporal and spatial distribute elements in the water, sediment, .„d biota of our coastal .urine, estuarine, and river systems This r e ^ t e a T 1^ r*POrt,°n ”*rCUry

DISTRIBUTION OF LEAD AND COPPER

, . l**T *'“ lytical presented in figures 1-5 are fro* subsamples of the same surface grab samples the analysed previously for mercury (McCulloch and others, 1971), In addition, results are included from two nee with^results*from **" - S J T S (fie and concentrations (parts per million (ppm) of dry sample weight) are given for i f ^ l o i L d ^ o ? 0??*' !!9, 21: !19Ur* 3* th# P€rcenta9® frequency of the various concentrations of lead an l s p lottedfor the entire estuary (top graph), in the lower graphs it is separated into the frequency of the - concentrations from the tributaries and margins and from the channels and shoals. Both lead andcopper are m eh "hf1"*"? c°U *ct*d ttJ m tha tributaries and along the bay margins than in sediment from the shoals and cha W“ n°L?*t,Ct*d

«P« 1 1 W“ “ h?1* Y ndJ r \ a r 4*1 concantration °r 30 Pt» in sediment from the tributaries ai “ « 11 , that fr°? *h* channels and shoals. The bimodal distribution in the lead and copper concentrate gure 3 may be artificial due to the small ratio of modal concentration to analytical resolution (table 3 of h J E Y ! ? ? " ? C “ ?tent f°r V*rio,“ Betal concentrations is given in figure 4. In general, the cone f both Kintals increase with increasing concentrations of organic carbon. In addition, the median concentrat ti£"to Y Y di« « anf metals are more similar than the median concentrations of organic ca diff*r*nt •nvironments. This similarity in concentration of lead and copper is aim in figure 5. . Lead and copper are present in approximately equal abundance, particularly at or below50 ppm. To compare the composition of surface sediment with that of sediment uncontaminated by man's activities dance of lead and copper (and other trace elements, see table 3, in section on methods) was examined in one d r^tii fC°?d* Y 1* 1 *, S4mpl*S fr° " th* deep cor® are considered uncontaminated by man (prehistoric) becau to??it? °n *?* !88 Y " 5 feet P*r 1,000 years (Kvenvolden, 1962, Story and others, 1966 Results indicate a higher concentration of lead and copper in surface sediments than in prehistoric sediments

THE ASSISTANT SECRETARY OF COMMERCE Washington. D.C. 20230

December 29, 1972

Colonel J.L. Lammie District Engineer San Francisco District, • corps of Engineers 100 McAllister Street San Francisco, California 94102

Dear Colonel Lammie;

The draft environmental impact statement for Oakland Inner Harbor, Alameda County, California, which accom­ panied your letter of November 1, 1972, has been received by the Department of Commerce for review and comment.

The Department of Commerce has reviewed the draft environmental statement and has the following comments to offer for your consideration.

1« Project Description

Page 1 — The need for the project would be better eval­ uated if the following questions were answered.

a. What percentage of shipping traffic will be affected by the project?

k. Will larger vessels be attracted which will have to wait for high tide to enter the port?

c. What is the draft of newly constructed container vessels?

2. Environmental Setting Without the Project

Page 3, item d, Land Use and Development — The statement makes the comment that “This harbor serves not only the Bay Area, but also Northern California and a considerable part of the Western United States.,r It is felt that this statement is too restrictive. Foreign commerce flowing through the Port of Oakland is not only derived from the narrow geographic areas outlined, but from the whole of the United States, particularly in view of the "land bridge" application instituted between Seatrain Lines, Inc. and the Santa Fe Railroad. It is suggested that the statement read "This harbor serves not only the Bay Area, but also Northern California and a con­ siderable part of the United states.!'

Page 4, item e. Water and Sediment Quality — This para­ graph alludes to the poor quality of the water in the area of the proposed dredging. The coliform count is the only parameter quantified. It would be more meaningful if other water quality criteria were also measured.

Page 6, item i, Ocean Disposal — The first paragraph refers to the ocean bottom habitat at the 100 fathom dis­ posal site and to the rich invertebrate fauna of unknown diversity. The reasons for choosing a disposal site which happens to support a rich benthic fauna should be given.

The third paragraph in the section on Ocean Disposal states that zooplankton concentrations teach seasonal highs of 300 parts per billion. Some explanation should be provided concerning the method (and the rationale for selecting the method) of determining zooplankton concentrations in terms of parts per billion rather than in terms of the number of organisms that are present in a certain volume of water.

3. Environmental Impact of the Proposed Action

Page 8, item a. Dredging Effects — The second paragraph in the section on "Removal of the original interface between the water and the bottom which is frequently an area of high biological activity" is speculative, and we suspect the conclusions cannot be substantiated. The polluted materials removed from the dredged area are to be reintroduced at the disposal sites. There will be disper­ sion in important rearing areas of polluted material that is now confined to the bottom sediments in an area of little value to fisheries resources^ The net change in water quality conditions will probably not be an improvement, as implied in the statement. Finally, the meaning of the statement that "the production of oxygen - reducing algae in the estuary will be reduced thus providing better con­ ditions for game fish"1 should be clarified.

4. Any Adverse Effects Which Cannot Be Avoided

On page 12, the statement is made that "Dredging of the channel should improve the flushing characteristics... " Allusion to the benefits that can accrue from dredging does not appear to be appropriate in a discussion of adverse impacts of the project.

5. Alternatives to the Proposed Action

Deepening of only a portion of the channel should be discussed as an alternative. Presumably, all vessels entering the Oakland Inner Harbor do not require deeper berths. A^so, a discussion of alternative 100 fathom disposal sites should be provided in light of the high benthic productivity of the proposed ocean dumping site.

8. Coordination With Other Agencies

This section discusses coordination of the draft state­ ment, but not of the project. There is no indication whether the requirements of the Fish and Wildlife Coordin­ ation Act have been satisfied.

We hope these comments will be of assistance to you in the preparation of the final statement.

Sincerely,

Sidney Iu Galler Deputy Assistant Secretary for Environmental Affairs UNITED STATES ENVIRONMENTAL PROTECTION AGENCY R E G IO N IX lOO CALIFORNIA STREET SAN FRANCISCO. CALIFORNIA 94111

PEC 13 1972 Colonel J. L. Lammie District Engineer, Dept, of the Army San Francisco Dist., Corps of Engineers 100 McAllister Street San Francisco CA 94102

Dear Colonel Laramie:

This letter is in response to your letters of September 29, 1972 and November 1, 1972, requesting our review and comments on your draft Environmental Impact Statements for the proposed Maintenance Dredging in Oakland Inner and Outer Harbor, Alameda County, California.

We have reviewed both impact statements and feel that they adequately discuss the probable short-term effects of the projects. However, some attempt should be made to estimate the long-term impact of depositing polluted dredge spoils in the open ocean. The assessment of long-term effects should take into account the aggregate volume of dredge spoil generated within the Bay each year. While there is a lack of primary research on the environmental impacts of polluted dredge spoils, the Corps of Engineers’ studies in the New York Bight (The Effects Of Waste Disposal In The New York Bight Final Report) indicateHEhat toxic spoils-Have significant, adverse impacts on fish and crustaceans. The Corps of Engineers might, therefore, wish to consider studying the biological effects of the toxic spoils on pelagic and benthic organisms at the open ocean spoil site.

If the disposal sites for these projects change as a result of the new regulations now being prepared by the California Regional Water Quality Control Board, San Francisco Bay Region, new impact statements should be prepared. EPA appreciates the opportunity to review these statements and would like to receive a copy of the final impact statements.

Sincerely,

Paul De.>Falco, Jr. Regional Administrator cc: Council on Environmental Quality, Washington, DC Attn: Mrs. Hope Hale (10 copies) UNITED STATES DEPARTMENT OF THE INTERIOR OFFICE OF THE SECRETARY

PACIFIC SOUTHWEST REGION BOX 36096 • 450 GOLDEN GATE AVENUE SAN FRANCISCO. CALIFORNIA 94102 (415) 556-8200

January 11, 1973

Colonel J. L. Lammie District Engineer San Francisco District Corps of Engineers 100 McAllister Street San Francisco, California 94102

Dear Colonel Laramie:

The Department of the Interior has reviewed the draft environmental statement for deepening a portion of the existing channel in Oakland Inner Harbor, Alameda County, California.

We note that Lake Merritt and the entrance channel thereto, in the City of Oakland, is excluded from consideration in the statement. We consider these waters to be an extension of the Oakland estuary; they are of substantial importance to both recreation and wildlife. Water quality degredation resulting from the proposed dredging activities could well extend into Lake Merritt. Scheduling of dredging should consider the seasonal pattern of recreation and wildlife uses of the lake, as well as the considerable seasonal variations in water quality already existing at the lake and the potential for compounding those problems. All such activities should be coordinated with the appropriate State and Federal resource agencies.

The statement does not fully consider the secondary effects of spoil disposal within San Francisco Bay. Spoil disposal in the Bay contributes to annual sedimentation rates and augments dredging requirements at other locations. For example, the disposal of spoil at Alcatraz will cause suspended material to be moved seaward through the Golden Gate to settle in the channel across San Francisco Bar. This is an undesirable environmental action and should be discussed in the statement. It is anticipated that there will be some improvement in the quality of water in Oakland Harbor as a result of removing sediments with a high concentration of heavy metals. However, it should be noted that in-water disposal will transfer these pollutants to different sites, possibly with adverse effects. Consideration should also be given to the possibility of water quality degradation which would result from increased harbor use.

The final statement should include a discussion of the geologic conditions of the project area as well as a lithologic analysis of the spoil material.

We note that land disposal is listed as a possible means of spoil disposal. If, after further investigation, land disposal is selected, it will be necessary to conduct archeological, historical, recreational, and biological studies to determine the impact on these resources. Qualified personnel from research institutions or resource agencies should be employed to conduct these studies and their findings included in the final environmental statement.

Cordially,

Webster Otis Secretary's Field Representative

ccs Director, Office of Environmental Project Review, USDI, v/cy Bureau comments Regional Director, BSF&W, Portland Regional Director, BOR, San Francisco Regional Director, NPS, San Francisco Assistant Director, GS, Menlo Park Director, Geological Survey, USDI UNITED STATES DEPARTMENT OF AGRICULTURE SOIL CONSERVATION SERVICE 2020 Milvia Street, Berkeley, CA 94704

November 9, 1972

: Colonel J, L. Lammie District Engineer U. S. Army, Corps of Engineers 100 McAllister Street San Francisco, -CA 94102

Dear Colonel Lammie:

Ve acknowledge receipt of the draft environmental statement for

Dredging the Oakland Inner Harbor, Alameda County, California.

With your plan for ocean disposal of all dredged materials, this

project should have no Impact on Soil Conservation Service programs

or projects.

We appreciate being given the opportunity to review and comment.

Sincerely,

€. H. STONE State Conservationist DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT AREA OFFICE OWE.EMBARCAOERO CENTER. SUITE 1600 SAN fRANCISCO. CALIFORNIA 94111

REGION IX January 9 , 1973 REGIONAL OFFICE SAN FRANCISCO. CALIFORNIA

Colonel J. L Lammie District.Engineer Department of the Army 100 McAllister Street San Francisco, California 91*102

Dear Colonel Lammie:

Subject: Draft Environmental Impact Statement Oakland Inner Harbor Alameda County, California

We have reviewed this draft Environmental Impact Statement. We find it to be very well done. However, we feel that some of the secondary socio-economic and land use transportation effects were not adequately discussed. For instance, a more definite statement on the expected warehousing land uses expected by the dredging activities would be useful. Also, if increased shipping can be expected to result from the project, a discussion of the socio-economic effects would be in order.

The environmental effects on the biota of the Oakland Estuary need to be amplified by a more definite statement on the Phytoplankton relationship to the eco-system especially the "food chain".

Finally, we feel that these considerations will constitute a good final environmental inpact statement.

Sincerely,

William R. Bellezer Assistant Director for Planning and Relocation THE RESOURCES AGENCY OF CALIFORNIA SACRAMENTO, CALIFORNIA

Colonel J. L. Lammie District Engineer • San Francisco District Corps of Engineers 100 McAllister Street San Francisco, CA 94102 Dear Colonel Lammie:

You requested, by letter dated November 1, 1972, comments of the Resources Agency on your draft Environmental Impact Statement • for deepening a portion of .the existing chapnel in the Oakland Inner Harbor, Alameda County, California.' Comments were coordinated with the Departments of Conservation, Fish and Game,, Navigation and Ocean Development, Parks and Recreation, and Water Resources, the San Francisco Bay Conservation and Development Commission, the State Lands Division, and the State Water Resources Control Board. The Resources Agency has serious reservations regarding the long-term effects of placement within San Francisco Bay of large volumes of dredge spoil. We believe this Impact Statement is somewhat deficient in discussing redistribution of dredge spoil. We have recently reviewed several Environmental Impact Statements for maintenance and development dredging in San Francisco Bay where 5>°00 to 200,000 cubic yards of spoil were to be placed at the Alcatraz Island disposal site. This proposal calls for additional spoil placement of more than one million yards of very fine-grained material, much of it polluted to some degree. Because of the very strong tidal currents, most of the sediment is carried away from the disposal site. The report says about 50 percent of the spoil material leaves the bay system. The remaining 600,000 cubic yards (from this project) would be redistributed throughout the bay system, carried about by the currents, until finding some quiet water to settle in, perhaps the Oakland Harbor. We question that this is the most efficient procedure. Alternative dredge spoil placement procedures have been considered. Other procedures appear to be required.

For your information, a proposal for alternate procedures is in preparation by the Division of Mines and Geology, Department of Conservation, for presentation to the San Francisco Bay Conservation and Development Commission and the Corps of Engineers.

Thank you for the opportunity to review and comment.

Sincerely yours,

N. B. LIVERMORE, JR. Secretary for Resources CITY O f OAKLAND

CITY HALL • 14TH AND WASHINGTON STRFITS • O A K I A N D, C A L I F O R N I A 9461 2

Office of the Cily Manager November 27, 1972 Cecil S. Riley City Manager

J. L. Lammle, Colonel, CE District Engineer S. F. District Corps of Engineers Department of the Army 100 McAllister Street San Francisco, CA 94102

Dear Col. Lammie:

The City of Oakland has received your draft environmental impact statement regarding the proposed improvement of the Oakland Inner Harbor by deepening from 30 to 35 feet by dredging an approximate 2,150,000 cu. yds. of material.

The report has been reviewed as to the benefits and possible adverse effects related to the project as well as the projected economic impacts associated with the deepening. The effect of 1) no action would materially affect the economic and employment base of this community and 2) unreasonable disposal criteria for the dredged material would similarly have a strangling effect on Oakland and other East Bay cities. Therefore, it is our conclusion that the benefits of the project require its construction despite the minimal permanent or semi-permanent environmental effects.

Additionally, the City of Oakland supports the continued maintenance dredging required for the Oakland Inner and Outer Harbors with disposal of material accomplished in the most economic manner consistent with reasonable considerations of water quality effects. In cur view a requirement for either total land disposal or total ocean disposal of dredged material is not consistent with the overall considerations of economic benefits and environmental effects of the actions required to maintain a viable shipping center.

Therefore, the City of Oakland supports the use of the Alcatraz dumping site consistent with reasonable water quality standards for disposal of the Estuary deepening and harbor maintenance projects.

Sincerely,

CECIL S. RILEY City Manager